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We question the validity of the baseline noise map supplied with the EIS since no data is supplied to corroborate the contours. This data is recorded by D.A.A. We question the reliance on an I.C.A.O. metric without calibrating the model against actual observations. The figures for the present LAMax included are estimated from present aircraft movements. Noise mapping needs to be related to actual measurements on the ground which take land contours and new housing developments into consideration. Certified levels may differ from actual measurements. The cumulative effect of noise on the population is not addressed. The present
and projected population of the airport environs greatly Low frequency
sound is discounted by measurements. ( WHO Guidelines on The LAMax for the year cannot be compared with or imposed on the FCC noise contour maps since they are a completely different system of measurement. The present computed LAmax which in Portmarnock north is 80.1 dBA 2 km north of the glide path. This will increase to 94.6 dBA ( the present reading for south Portmarnock) if the new runway is built. The approach taken by the D.A.A. to present and prospective noise levels appears to be flawed. The baseline maps developed by D.A.A. is not supported by actual measurements of the operational aircraft noise merely the International Civil Aviation Organization (ICAO) certification data for the various airplanes at present using the runway. The computed noise contour maps supplied are based on 2003 F.C.C. maps also computer from ICAO certification data. They were developed without taking stakeholders views into consideration. They did not include all the environmental noise, ie car/ lorry sounds on roads only computed aircraft noise. The maps presuppose that all aircraft will follow the exactly define path. While this may be accurate on final approach, in practice many aircraft deviate from this path by as much as 1km either side of the 'outer marker' situated on the Baldoyle estuary. This broadens the noise impact on either side of the approach path. Any deviation north from the idealised track will lead to noise levels of 57dBA and above over Portmarnock. It has been the experience of residents that this occurs on a regular basis. The human ear hears actual operational noise rather than the noise certification standards of manufacturers. Heavier long-haul aircraft catered for by a longer runway will be emit more noise than smaller aircraft. The noise contour maps consider landings and take offs, not noise on the ground from taxiing and engine testing. Because of the elevation of the airport, noise generated within the airport confines is widely disseminated, increasing the noise impact to the surrounding area. The actual operational noise will be different for different weather conditions and will also depend on ground cover and contours. The vital importance of the noise contour maps is their use in planning of development since future housing should not be built where high noise levels interfere with normal living. Former planning policies limiting residential development in the proximity of the airport have been breached over the last number of years increasing the numbers of people affected by aircraft noise. The correct drawing up of the noise contour maps is of vital importance since mitigation measures are only applied at 60 dB Leq to schools. This would exclude mitigation in the 2 National schools in Portmarnock as well as the vulnerable institutions, eg St Rosalies Home, Prosper Fingal and St Annes Church. The present noise levels in the local schools exceeds the WHO guidelines of 35 dBA. Portmarnock Community Association has undertaken certified noise measurements. For a development of the scale of the proposed runway, it is inconceivable that no noise measurements have been undertaken and supplied by DAA. While previously specifically exempted from noise control, the operation of the airport will in the future have to comply with EU 2002/49/EC transmuted into Irish law by S.I. 140 of 2006 (Environmental Noise Regulations 2006) There is no protection for quiet areas provided for. Noise pollution is by definition unwanted sound and the effect of persistently high noise levels on health should not be underestimated. (EU Environmental Information and Legislation Database ) Monitoring is performed in the main by DAA with resulting lack of transparency. Projected air quality, if mimicking UK airport levels, will exceed EU limits. As with any projections there is significant uncertainty in predicting future air quality. The ambient air quality report 2004 supplies the maximum levels for relevant parameters rather than supplying the levels over time. The ongoing levels have a cumulative effect on the health of surrounding communities. Portmarnock is downwind of the airport in the path of the prevailing winds. The projected
increased passenger numbers will result in many more millions of car
movements, despite the inclusion of the proposed Metro line. Modern car engine modifications produce higher NOx emissions per unit of fuel. Heavier long-haul aircraft which will be able to take off on the longer runway being more fuel efficient will emit more NOx. NOx has a 310 times higher global warming potential than CO2 Public transport is not available to staff and passengers traveling before 7am and after 11 pm. It is likely that doubling aircraft movements will double the volume of pollutants being released. Car movements to and from the airport are likely to increase in parallel with a consequent increase in greenhouse gas emissions. Aviation fuel is delivered to the airport by tanker. An increase in the number of aircraft movements will require more fuel and as a consequence increased numbers of tankers. ( This will add to the danger to road users of transporting aviation fuel) Consideration needs to be given to the affects of increased aircraft movements on the emissions of greenhouse gasses affecting the fulfillment of the Kyoto Protocol commitments. The runoff from existing runways and parking flows into the Sluice and Mayne streams both of which are 'seriously polluted.' EPA. 'Water Quality in Ireland' The Sluice catchment consists mainly of small ditches down the sides of fields, leading into a lake at Kinsealy, which is already subject to contamination from discharges from the airport. The outflow from this lake is the Sluice River, which has already been deepened to eliminate flooding. The attenuation of runoff to green-field rates of existing car parks within the airport complex contributed to flooding in this catchment. It is likely that the calculated volumes of water involved will entirely overwhelm the Sluice system. The dry weather flow of the Sluice stream is 0.001m3s-1. It should also be noted that this stream flows into Baldoyle estuary a Nature Reserves It is a Special Areas of Conservation, a Special Protection Area, a National Heritage Area and a Ramsar Site and is protected under the Wildlife Act,1976 and the Habitats Directive (92/43/EEC) The reserve is rated as of international importance for Brent Geese. It is indicated that the portion of the runway within the Ward River catchment will be directed into the Sluice River Catchment. This will further exacerbate the problem of the volume of water involved by effectively increasing the catchment. It is likely that the temperature of water discharging from the expanse of runway especially in summer will cause oxygen depletion in the stream water. There will undoubtedly be a significant amount of petroleum oils, hydraulic fluids and other materials carried by rainwater being discharged from the facility. This is a recognised problem with motorways however the concentration will be higher from a runway due to the 'point source' of the discharge. Since the discharge will constitute a major part of the flow of the stream will have a detrimental effect on the nature of the river and to Baldoyle Bay. There is no evidence that the foul sewer and the sewage treatment plant will have the ability to cope with a pulse of contaminated runoff from de-icing. With the low temperatures involved it may be expected to poison the treatment plant leading to major problems for the treatment plant. As the odour problem in Ringsend Sewage Treatment Plant has shown, the biological systems involved have to be maintained in a delicate balance. The presence of glycol in the August sample quoted in the EIS could mean that leakage was occurring from a storage facility at the airport as any material from winter de-icing should have already been attenuated in soil. It can
be expected that there will be contamination in the groundwater, epecially
since infiltration of runoff is being encouraged. The Sluice River flows into Baldoyle Bay, a Nature reserve, in which Greenland White-fronted Geese, Shelduck, Pintail, Golden plover, Black-tailed Godwit and Bar-tailed Godwit , Amber listed species, winter. This is the river which will take the total runoff from the Northern Parallel runway. Any contaminated runoff will have a deleterious effect on this important site, especially on over-wintering birds. Flooding already occurs within this catchment downstream of the airport facility. It is likely that the Ward stream will be similarly polluted due to runoff from the airport. Expansion of the airport and increased passenger numbers will overwhelm the present sewage treatment capacity of Ringsend Sewage treatment Plant.
The increased volume of solid waste being produced by the airport as a consequence of increased capacity has not been addressed. There is no plan for recovery or recycling of appropriate material within the airport. The disposal of increased waste from the airport will necessitate an increase in the number of collection vehicles. |
