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The Environmental Resource Management group first published a Public Safety Zones Report ( PSZ) in relation to Irish airports in June 2003. In this report they outlined the safety issues for people living under a flight path, placing restrictions on infrastructural and environmental planning and community development.
World health Organisation studies and studies such as "Munich Airport Noise Study". Hygges, Evans, Bullinger1998 show that noise from aircraft is detrimental to children's health and education .A Trans-European study whose results were published in the Lancet Medical Journal found that for every 5 decibel increase in noise level the reading age in children was delayed by up to 2 months. Some of the children were exposed to noise that was up to 20 decibels louder, which the research said could translate into an 8 month delay in a child's reading age. The study also found that increased exposure to aircraft noise was associated with stress and a reduced quality of life among the children. Offers
of sound insulation would result in the unsatisfactory situation of
a "bunkering in" of our children in a designated crash zone. No gathering
of more than 220 people would be permitted within the newly created
Crash Zone. The Sports and Leisure Centre, had it not been built, could
not now be built. "high density housing developments, the building of schools, nurseries and hospitals and facilities attracting large numbers of people will not be permitted". Existing developments may remain. Severe restrictions are also placed on shopping centres, golf courses, sports halls and swimming pools with in some cases uses being confined to " a maximum of 12 hours in one week with no more than 220 persons should be exposed to the crash area (i.e. half hectare)" In Holland no house building is allowed within the outer crash zone because of the risk to human life. The ERM PSZ report attempted to give the people of Portmarnock who would live under the proposed flight path equivalence of protection to that given to people living beside a toxic chemical plant. Who would choose to live at a toxic chemical plant? The proposed new runway is unacceptable from a safety perspective in that it poses a huge threat to our well-being and quality of life by creating an Outer Danger Zone, an actual prospective Crash Zone over our homes. A Public Safety Zone is a sanitised zone in which people should not live, work or congregate. A PSZ should not be created over a settled community.
The Council's stated objectives for Portmarnock are; " to develop the town as a centre for both the residential population and for tourists, to carry out an environmental improvement scheme for the area and to improve the physical character of the area so that it can act as a service, social, recreational and tourist centre". These objectives of F.C.C. are in conflict with the PSZ restrictions and could not be met in keeping with the proposed PSZ for the proposed new parallel runway 10-28 as no new hotels or new recreational facilities could develop because of the flight path and Outer Crash Zone. Day-trippers using Portmarnock's beach will also contravene the embargo on congregations of no more than 220 people in a restricted area. Will FCC monitor numbers and density on the beach? It should be noted that FCC have not formally adopted the PSZ report nor have they to date put it on public display as required. They have a duty of care and a duty of notification on such a major matter. Yet FCC went ahead and gave planning permission for the propose runway in the absence of adequate and full public information on Public Safety and potential risk. The PSZ report was only adopted by the Dept. of Transport on 19th Jan '05(it was first published June '03). FCC accepted D.A.A's application in Dec.'04 in the absence of a masterplan for Dublin Airport (this has only now gone on public display, up to mid May '06) and without informing the public of the ERM PSZ report. The fact of the prematurity of the new runway application was pointed out to FCC in Portmarnock people's submissions, Dec '04 / early Jan'05, re the planning application. As recently as last month (April '06) FCC pre-emptively included the proposed new runway in the Airport Masterplan even though permission had not been given for the new runway at that stage.
Policy
DAP12 calls on the council; Policy
DAP13 calls on the Council; Here we see an acknowledgement of the necessity for a Health Impact Assessment in relation to major, and indeed possibly minor also, development proposals at Dublin Airport where an EIA is required. No such assessment accompanied the EIS submitted by DAA. Nor have the Council called for one when calling for additional information even though Councillors in Sept.'05 voted that the Manager seek medical advice in relation to the proposed runway. This has not been done. Policy
TP21 Transportation calls for the Council; This has not been done or implementation attempted. FCC is currently rushing through IPPC (Integrated Pollution Prevention and Control) licences on an individual basis belatedly and almost as an afterthought to facilitate the runway application. EPA is not involved. Please see copy of correspondence of 27-4-'06 in which they state " Dublin Airport Authority does not hold either a Integrated Pollution Prevention and Control licence (IPPC licence) or a Waste licence from the EPA." EPA 27-4-'06 But Engine Testing, it would seem, requires an IPPC licence. In reply to Dail Question 241 put by Trevor Sargent T.D on 14th May 2003 Minister Martin Cullen stated that " under the First Schedule of the Environmental Protection Act 1992, an Integrated Pollution Control Licence is required for the testing of engines, turbines or reactors where the floor area exceeds 500 square metres" (Minister Martin Cullen). We understand that no such licence has been granted to date although engine testing occurs daily. Engines are run at full power and force to test their capacity to the maximum. This activity creates irritating continuous loud noise and causes sleep disturbance and stress to the community. Yet the community have no protection or redress on this matter. No agency
will take responsibility. Confusion reigns. Fingal County Council Meeting 16th Sept 2003. Is the Airport a law onto itself?
In keeping
with Fingal County Council's Policy TP21 (Part VI Transportation) County
Development Plan '05; The EPA should take overall responsibility for Dublin Airport. Attempting to grant individual IPPC licences, as FCC now appears to be trying to hastily do, is not the answer, the way to proceed or best practice. Due to the large number of dangerous chemically related activities involving intensification, concentration and overlapping of toxins and high risk operations at Dublin Airport, as things stand even without the proposed new runway, there is an urgent requirement for an overall Integrated Pollution Prevention and Control Licence .The EPA needs to "police" Dublin Airport not DAA itself. FCC cannot be seen to put itself in the position where it might appear to be colluding with DAA with regard to DAA's self monitoring. Fingal
County Council accepted DAA's application for the new runway in Dec'04
even though the width of the runway was changed at the last minute from
45m to 60m (75m including shoulders); this change of width has implications
for the PSZ and the EIS. Very importantly it also has implications for
the public consultation process that had been conducted on the basis
of a same width runway as the existing east-west runway 10-28. The EIS
submitted by DAA is seriously flawed in that no HIA was done. It also
did not adequately examine alternatives to the proposed parallel runway,
it pointed to only one solution.
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