|
|
|||||||||||||||||||||||||||||||||||||||||||||||||||||
|
*UPROAR: United Portmarnock Residents Opposing Another Runway is a sub-committee of the Portmarnock Community Association.
Objection to Terminal 2 at Dublin Airport Summary of grounds of appeal. In summary, our main grounds of appeal against the proposed development are:
Introduction The Portmarnock Community Association, UPROAR, C/O 150 Heather Walk, Portmarnock, Co. Dublin, objects in the strongest manner possible to the proposed new terminal and associated infrastructure at Dublin Airport. We have no objection to the reasonable development of the airport, but are most concerned with the proposed new terminal, which in conjunction with other developments such as a proposed new parallel runway, will have a deleterious and long-lasting impact on the lives, amenity and welfare of all residents in the Portmarnock area. There is an unwarranted presumption that large-scale public infrastructural undertakings are for "the common good" or "in the public interest" and that the objections of local communities are obstructing legitimate economic and social progress. Such a presumption is rather an hypothesis to be tested. When the state proposes to override the rights of citizens, decision-makers must satisfy themselves by means of proper, complete, and prior investigation as to the factors which should be taken into account in order to achieve an appropriate balance between the rights of individuals and the state's economic interests. The burden of proof is on the state. Mere reference to the economic well-being of the country is not sufficient to outweigh the rights of individuals.
A basic assumption of Bunreacht na hÉireann, Irish planning law, and Human Rights is that the state can only override individuals' rights in the interests of the common good. It follows that the state must show that it is acting in the interest of the common good. The issue is one of "proportionality": the means used must be proportionate to the ends sought(1). An Bord Pleanála itself is also predicated on the same principle of the common good(2). The decision as to what is in the common good in this type of major infrastructure case comes down to a "trade-off" between local communities' pain, on the one hand, and national gain on the other. If the former is greater than the latter, the common good is not served. We believe the DAA's proposals fail this proportionality test twice. The DAA has failed to prove that its expansion proposals are an economic and social gain and we have shown that, on the contrary, they are a huge economic and social loss. An Taoiseach Bertie Ahern made the following comment at the "Towards Sustainable Airport Development Conference" on 23 October 2006:
According to The National Spatial Strategy document(3), page 13: "Sustainable development is development that meets the needs of this generation without compromising the ability of future generations to meet their needs. The concept captures the important ideas that development has economic, social and environmental dimensions which together can contribute to a better quality of life, [and] will only be sustainable if a balance is achieved between these three dimensions, etc." It is our
contention that this terminal and associated developments has not been
subjected to the Taoiseach's sustainability test for airport development,
and that if it had been, it would not pass such a test. It follows that
the expansion programme is neither proportional nor sustainable, and
should proceed no further. Dublin Airport's Infrastructure Expansion package. We wish to point out that we do not object in principle to the provision of proper passenger terminal facilities at Dublin Airport. However, we do object to the scale, location and context of the proposed terminal as part of the reckless and unsustainable development of Dublin Airport as a whole. The proposed terminal is part of the overall development of Dublin Airport as set out in its €1.2 billion ten-year Airport Development Programme announced in September 2006 and as reflected in Fingal County Council's Dublin Airport Masterplan, passed in June 2006, and now enshrined in the Fingal County Development Plan as a Local Area Plan. That €1.2 billion development programme includes the proposed Terminal 2, a new Pier E, an extension to the existing Terminal 1 and the second parallel runway 10L/28R. The proposed later Terminal 3 on the Western Campus of Dublin Airport, as set out in the Dublin Airport Masterplan, is additional. During the Oral Hearing that began on 26th October 2006 into the proposed new runway at Dublin Airport, Fingal County Council attempted to divorce the runway from any impacts on strategic road traffic in claiming that "of itself" the runway would have no road traffic impacts. It was their contention that these impacts would only arise when the proposed Terminal 2 was built(4). The Dublin Airport Authority concurred with this position. The DAA
and FCC are now attempting to apply this "project-splitting"
tactic again, but in reverse. The DAA now claim, and having granted
permission it must again be assumed FCC agrees, that the terminal's
impacts can be divorced from those of the proposed new runway. Speaking
of the extra noise from extra aircraft movements on the proposed new
runway the EIS at 8B.6.1 states: "These issues are all independent
of the Terminal 2 building proposal." (See also "Noise Impacts"
below). It beggars belief that two public bodies (a public company and
a local authority) would collude again in a cynical attempt to avoid
public and transparent accountability for their actions and to deceive
the taxpayer by these à la carte "project-splitting"
tactics(5). The report of the Fingal County Council Planning Officer states that the planning application for the second northern parallel runway currently on appeal (F04A/1755) is part of the "Significant recent history" of the terminal application and is considered to be of relevance to that application(6). It should also be noted that it is the intention of the DAA that the new terminal be in place before the new parallel runway is constructed and that it is intended to cater for most of the increased airport passenger traffic resulting from that runway. The two construction proposals are therefore inseparable in terms of their impacts. We therefore
wish to associate all the documentation previously provided by the following
parallel runway appellants with this appeal and we do so with their
approval: Teresa Kavanagh, Board of Management of Portmarnock Community
School, Management of St. Helen's Senior National School, Matthew Harley,
Angela Lawton, Marie O'Brien and the Portmarnock Community Association
- UPROAR. We attach a copy of the appeal lodged by O'Neill Town Planning
on UPROAR's behalf on 9 May 2006. See also the attached "Legal
Submissions" prepared for the runway oral hearing for Matthew Harley.
Much of these legal submissions apply to the current terminal proposal,
either in its own right or as part of Dublin Airport's Expansion Programme.
The proposed development is described in the approval given by FCC on 25 October 2006 as follows:- "A 10 year planning permission for development at Dublin Airport, east of the existing terminal building adjoining Pier C. The development will consist of the construction of: 1) a passenger terminal (which will be built in two phases) of ca. 92,049 sq.m. in 4 no. interconnecting blocks ranging in height from two to four stories with an overall height of 35m, which partially bridges the access road to the existing passenger terminal building; 2) a three storey Pier Building with an overall height of 18m (ca. 24,052 sq.m.), complete with 19 no. air bridges and associated fixed links. 3) a two storey over basement energy centre containing water storage and plant for power supply, heating and cooling systems (ca. 5,049 sq.m. with total height of 11m and a chimney stack of 38m); 4) external service yard; 5) realignment of existing internal access road infrastructure and provision of new access roads, including pedestrian and cycle routes, all contained within the existing airport campus; 6) Rearrangement of the existing coach park adjacent to the north of the existing terminal building; 7) separate car, taxi and bus set-down areas; 8) associated services connections; site development; and landscaping works, including a feature access area; 9) refurbishment of the existing Pier C; 10) demolition of the following; Corballis House a two storey protected structure with an area of ca. 482 sq.m.; a single storey storage building (ca. 1295 sq.m.); 3 no. single and two storey car hire buildings ca 280 sq.m., 690 sq.m. and 1925 sq.m.); a single storey boiler house building (ca 373 sq.m.); single and two storey DAA Maintenance offices (ca 1,290 sq.m.); a mainly single storey Hanger Building (ca 2,165 sq.m.) and fixed links to Pier C (ca 380 sq.m.). All on an application site of ca. 32,646 ha. The following will be included within the passenger terminal and pier; check-in areas including 58 no. manned desks and 24 no. self-service facilities; passenger services and associated terminal support facilities; departure lounge; baggage processing hall; baggage reclaim area; ca. 5,813 sq.m. of retail (ca. 840 sq.m. landside, ca. 4,973 sq.m. airside); ca 2,730 sq.m. of catering facilities (ca. 643 sq.m. landside, ca. 2,087 sq.m. airside); 2 no. public houses totalling ca. 1,278 sq.m. (1 no. landside of ca. 491 sq.m., 1 no. airside of ca. 787 sq.m.); airline security, immigration and customs offices( ca. 4,625 sq.m. airside); links to a future multi storey car park and the existing passenger terminal; security check-in and arrival areas; associated plant, circulation and toilet space. An Environmental Impact Statement will be submitted to the Planning Authority with the application."
The Department of Finance appraisal guidelines provide this state's principle test of sustainability and proportionality(7). There are also EU appraisal guidelines that may apply(8). In October 2005 Minister Brian Cowen, in a "Value for Money" speech, announced that henceforth all projects costing over €30 million, would have to be subjected to the rigorous application of Cost Benefit Analysis (CBA) as spelled out clearly in both these sets of guidelines(9). Minster Cowen restated this requirement on announcing the 2007 Estimates on 16 November 2006(10). CBA is, according to Minister Cowen, a socio-economic analysis that includes the identification and carefully quantified analysis of all the relevant project costs and benefits, including indirect costs. There is no question but that these guidelines apply to all major projects submitted by the Dublin Airport Authority for planning approval. The guidelines say: "All Government Departments and public bodies (semi State bodies, local authorities and health agencies, etc.,) and all bodies in receipt of public funding for capital purposes must comply, as appropriate, with the relevant requirements of these guidelines. In the case of State Companies [e.g. the DAA] the Board of each company must satisfy itself annually that the Company is in full compliance with these guidelines." There is no evidence that these guidelines have been followed as far as a CBA is concerned for either of these two components (runway and terminal) of the Dublin Airport Development Programme. In a paper presented to the oral hearing into the runway at An Bord Pleanála, the DAA's Mark Foley admitted that the DAA did not do a Cost Benefit Analysis for the proposed runway, as required(11). He said: "DAA does not believe an 'unbounded' Cost Benefit Analysis is required, relevant or beneficial for either the north parallel runway or indeed the overall CAPEX programme..." Whatever the term "unbounded" means, there is no escaping Minister Cowen's requirement for "a full scale cost benefit appraisal" for all capital investment proposals by state bodies with an estimated cost over €30 million. This is a clear admission that no CBA was done for the proposed runway, and presumably not for the terminal either. Mr Foley's statement to the oral hearing that the DAA is not in receipt of direct funding by the taxpayer is irrelevant. The Finance Guidelines apply to semi-state bodies irrespective of the source of the project's funding, and in any case, this proposal will use substantial state assets, inter alia, the hundreds of acres of public land to be occupied and sterilised by this runway. The careful addition of the word "direct" cannot avoid the requirement(12). According to Mr Foley "The DAA has deployed the most rigorous and robust appraisal methodologies in relation to the parallel runway project." That is not correct, as the most rigorous methodology of CBA has not, by its own admission, been employed.
To test the proportionality and sustainability of the proposed Airport Development Programme, a preliminary CBA was undertaken by UPROAR (an update of the CBA done of the proposed parallel runway). The announced total DAA investment of €1.2 billion was taken to include the second runway and Terminal 2 and related developments. A third terminal is assumed to be built by 2019 when passenger numbers reach 35 million and is assumed to cost €300 million at that time, additional to the €1.2 billion(13). The airport is projected to reach a capacity of 55 million by 2040(14). When the costs of construction, including land asset costs, are added to pollution, noise, traffic congestion and other externality costs, and returns are deducted, there is a net loss of €4.5 billion. The Internal Rate of Return is negative infinity because there is not one year in the lifetime of the investment in which there is a positive cash flow. The Department of Finance requires a minimum return of 5%. The Aviation Regulator requires a return of 7.4%. This Airport Development Programme therefore fails the test of proportionality and sustainability and should be rejected, pending a full cost benefit analysis as required by the Department of Finance. Our analysis constitutes a preliminary appraisal and its results make a clear prima facie case for a full CBA(15). It may be approximate but it is probably robust and we expect a full independent analysis would confirm its findings. It should also be noted that costs have been conservatively estimated in that, for example, no charge has been included for the estimated €200 million required to build the Airport Box road network needed to relieve some of the traffic congestion resulting from the airport's expansion. Neither has any share of the cost of the proposed Metro serving Dublin Airport been added. This Metro is estimated to cost in the region of €3.5 - €4 billion and is also being justified on the grounds that it is needed to take some of the expanding airport traffic off the congested road network.
No analysis of alternatives was carried out by the DAA. Section 2.1 of the EIS states that "the option of developing airport facilities at another location instead of constructing the proposed terminal 2 at Dublin Airport, was not considered. This is because the proposed development is founded in the Aviation Action Plan proposed by the Department of Transport…which outlines government policy in relation to the provision of Terminal 2." This is a clear breech of the requirements of EIS Directives and other guidelines and statutes that alternatives be evaluated(16). If this "government policy" argument applies, one wonders why evaluation of any sort is required and, indeed, why planning permission has to be sought in the first place. Many of the arguments put for this development by reference to various national policies such as National Spatial Strategy, Regional Policies and Sustainable Development would apply, and probably more so, to alternative locations for airport capacity development elsewhere in or adjacent to the Greater Dublin Area. The claims made by reference to these policies on behalf of this proposed terminal cannot therefore be taken to apply uniquely to this proposal and as support for it.
It comes as no surprise the FCC Planner's Report is satisfied with the consideration of alternatives in the T2 EIS, both within and without Dublin Airport(17). In our opinion the location chosen for Terminal 2 is probably the worst of all possible locations within the 2,500 acres of Dublin Airport. It is to be located beside existing Terminal 1 at the congested Eastern Campus of the airport. It is in fact merely an extension of Terminal 1 and is so described in the T2 EIS(18). According to the T2 EIS its location was decided on capital cost grounds, an analysis that obviously ignored operational congestion considerations(19). It is hard to see how the proposed new parallel runway on the north side of the airport will be accessed from Terminal 1, or the new Terminal 2 jammed in beside Terminal 1 on the south side of the Eastern Campus with all of the ad hoc building mess between them and the new northern runway. The only route open to aircraft taxiing in both directions between T1, T2 and 10L/28R will be the narrow eastern taxiway of the existing 16/34 cross-runway. The airside congestion chaos within Dublin Airport will be matched only by the landside chaos on the airport's access roads and will reduce the overall operational efficiency of the airport. UPROAR's airport engineering consultants have previously pointed out the failure to take due account of airside ground delays incurred by aircraft trying to use the proposed new parallel runway. Experience from Hong Kong Airport is highly relevant. A second parallel runway at Hong Kong, with similar runway separation as proposed for Dublin, delivered only 25 of the expected extra 40 movements per hour on top of the 40 movements per hour from the first runway, due to unanticipated ground movement constraints. Only 63% of the expected gain in movements was achieved. The current proposals for Dublin Airport risk a similar outcome, even further compounded by the proposed location of Terminal 2 relative to 10L/28R and the continued existence of the cross runway 16/34. Even without a full investment appraisal, a runway and terminal that will only yield two-thirds of their design capacity at most, is evidently a very bad investment when fully exploitable facilities could be built elsewhere. UPROAR's cost benefit analysis of Dublin Airport's expansion programme took no account of this additional waste.
The previous preliminary analysis carried out by UPROAR of a second airport for the Greater Dublin Area stands(20). If well-sited, away from established communities, a second airport serving the Greater Dublin Area and adjacent regions would be economically viable (a 7.4% return on investment, as required by the Commission for Aviation Regulation) in spite of its higher construction costs, and could operate at the same €6-7 passenger charge as currently applies to Dublin Airport, but without the land-use subsidy received by Dublin Airport. Many of the additional spin-off benefits falsely claimed for Dublin Airport's expansion would actually be realised and it would, in addition, provide competition for the Dublin Airport monopoly, a monopoly that will be unassailable if its unsustainable and subsidised expansion is allowed. Such a second airport would also allow for the expansion beyond the 55-60 million capacity of Dublin Airport, if such expansion were needed(21). No such expansion will be possible at Dublin Airport and it will be too late or vastly more costly to develop such an alternative GDA airport if and when it is needed. This unsustainable expansion is a result of a hidden public subsidy. Dublin Airport is highly subsidised by the taxpayer because the aviation regulator does not require it to charge fair value for the use of the land in its asset base. The Commission for Aviation Regulation has confirmed that its valuation of land at Dublin Airport is less than €20 million for some or all of the 2,500 acres of publicly-owned airport land(22). Its charge for land therefore amounts to only €0.07 per passenger(23). This is equivalent to a subsidy of about €18.4 per passenger, assuming fair value of €2 million per acre. It is nearly three times the current maximum charge of €6.34 per passenger. It is impossible for the other state airports, Cork and Shannon, and any private interests considering building a new airport, to compete against this subsidy which is an anti-competitive state-aid from Irish and EU standpoints. The DAA is proud of its low passenger charge. At the "Towards Sustainable Airport Development Conference" in October 2006, DAA CEO Declan Collier said: "Dublin Airport is the lowest charged major airport in Europe. At €6 per passenger, we're less than 50% of the average European price." Rather than being thought laudable, this should be considered rather odd, given the generally high cost of doing business in Celtic Tiger Ireland and the price of land near Dublin. But there is no mystery; it is the result of a huge hidden taxpayer-funded subsidy. Privately owned, unsubsidised London City Airport charges between €25 and €30 per passenger for the convenience of landing and taking-off so near a major European city(24). A competitive unsubsidised charge at Dublin Airport would be similar. Removal of the subsidy would quickly lead to a demand for the provision of lower cost airport services for the GDA. Dublin Airport would probably become a higher-cost, lower-volume but efficient and sustainable Dublin City Airport, along the lines of London City Airport.
Apart from some references to utilities, no assessment was made in the T2 EIS of effects of the runway proposal on Material Assets (land and property) as required by EIS Directive 85/337/EEC. This should include an analysis of economic and social impacts of the proposed development. However, no assessment was made of the impact of the development on the value of land and property under the new flightpath associated with the new parallel runway and Terminal 2. No assessment was made of the cost of the buy-out of homes in St Margaret's in assessing the development or its costs. No assessment was made of the loss of value to thousands of homes near the airport as a result of the planned airport expansion and the cost implications of that.
The DAA justifies its "predict and provide" expansion plans on the basis of its own passenger forecasts. Those forecasts assume the land-use subsidy will continue. Its projected demand growth is a function of the public subsidy and is indicative of unsustainable subsidised growth, not a justification for competitive market demand driven investment at Dublin Airport. Even if such growth were a realistic prospect for future GDA demand, there is nothing in those forecasts that requires this demand to be serviced by expansion at Dublin Airport itself, rather than at alternative locations serving the GDA. Fingal County Council has also accepted this dubious "predict and provide" logic of the DAA without question. For example, the FCC Planner's Report even refers to the application during summer 2006 for a marquee on the roof of the short-stay car park as being "perhaps indicative of limitations on available space in the terminal building". It is perhaps rather more indicative of the unsustainable growth of a subsidy-driven monopoly, obsessed with market domination and a grandiose ambition that probably includes eventual airport privatisation. This expansion mania is supported without question by Fingal County Council, perhaps under some illusion that it is "good for Fingal". This is a serious failure in the FCC's duty of care for the welfare of its electorate. The DAA stands over the assumption in its capacity forecasts that assume aviation fuel prices would remain stable for the forecast period (to 2025). That is a reckless assumption. At the runway oral hearing, Dr Mary Coveney for the DAA, asserted, incorrectly, that air travel demand is not sensitive to fuel prices(25). Price elasticities of demand are high for leisure air travel (of the order of -1)(26) . Leisure travel accounts for more than business travel and is growing much faster. The assertion that air travel is not price sensitive is therefore not correct. Its price sensitivity has been masked in recent times by growing average disposable incomes and by airline deregulation that has pushed down the average ticket price through the squeezing of margins (mostly the labour cost element). As fuel pries now make up some 40% of the ticket price, demand for air travel will be increasingly sensitive to rising aviation fuel prices. The IMF are much more cautious about oil price levels and stability beyond 2010. Given such a warning on price levels and price instability, it is foolhardy to base long-term forecasts on an assumption of price stability. Further, as is well established, aviation fuel is the petroleum product with the least prospect for substitution, and it is therefore likely that pressure on aviation fuel prices will be more severe than that on oil generally(27). It should also be noted that the IMF does not even take account of the growing likelihood of eco-taxes on aviation fuel in its oil market forecasts(28). There is growing pressure for aviation's accelerating contribution to climate change to be internalised in the price of air-travel by way of ticket surcharges or direct taxation of aviation fuel. Cynically exploiting its reverse project-splitting argument that asserts that none of the deleterious impacts of extra aircraft movements on the proposed new runway should be attributed to Terminal 2, the DAA only admits to some miniscule impact Terminal 2 will have on the emission of greenhouse gases. See T2 EIS 18.3.7. The FCC Planner's Report goes along with this obfuscation. The simple fact is that the Dublin Airport Expansion Programme as a whole will generate significant amounts of greenhouse gases and that fact should be honestly stated, so that An Bord Pleanála can evaluate its implications. Aviation is now a relatively small source of the emissions causing global warming, but its share is growing the fastest. High altitude emissions, including contrails, are especially damaging(29). It is past time for serious attention to be given to the looming peak-oil crisis, global-warming and climate-change and the inevitable impact higher fuel prices and environmental taxes will have on aviation and the associated drive for unsustainable airport expansion.
Dr Mary Coveney in another paper presented on behalf of the DAA to the runway oral hearing and in her presentation to the hearing, listed many reasons that militate against a second airport for the GDA(30). Nowhere did she mention any of the obvious benefits, such as competition, lower congestion and pollution costs, low land prices and more favourable economics, operational cost savings and improved passenger services because of state-of-the-art design, etc. She also said: "Setting up a second airport means incurring a lot of sunk costs e.g. runway, taxiways, terminals etc." This reference to "sunk costs" implies that she assumes Dublin Airport with all its existing facilities would have to be closed with the subsequent loss of these "sunk" costs. That has not been suggested by UPROAR which assumed for its analysis that a second GDA airport would coexist with Dublin Airport. Albeit Dublin Airport might be required by economic and commercial necessity to slim down to a higher-cost Dublin City Airport operating in competition with a new second airport the same region. Dr Coveney cites international examples of where the building of second airports was followed by the closing of the old airport but she does not mention the counter examples where the old airport was not closed. E.g. Kuala Lumpur. If Dublin Airport had to close it could be assumed that all its traffic would have to pass through the new airport. Under such a scenario the second airport would be much more profitable than estimated in UPROAR's analysis. Further, if these old airports were closed, it was presumably decided for good commercial and economic reasons, in spite of sunk costs. Good economic and commercial practise requires sunk-costs be ignored in making economic and commercial decisions. The term is in fact correctly used to indicate that being "sunk" these costs are irrecoverable and irrelevant to good decision making. It is a common misconception to believe otherwise. It is pointless to continue incurring losses because of irrational concerns about sunk costs. Professor Lipsey's famous maxim applies: "'Bygones are bygones' and they should have no influence on deciding what is currently the most profitable thing to do(31)." Pubs and petrol stations are being demolished to build apartment blocks, because the sunk costs are irrecoverable and irrelevant to the best commercial decision. Astute owners do not bemoan the fact that they cannot recover the costs of their old buildings but look to the potential value of their site, regardless of such sunk costs. The only relevant cost in these cases is the cost of demolition and restoration of the site. Dr Coveney's evidence for the DAA against a second airport is self-contradictory and irrelevant. It does not attempt to refute by proper comparable analysis, UPROAR's finding that a second well-sited airport for the GDA would be a socially and economically attractive proposition. The issue should be treated as part of a full cost benefit analysis, where feasible alternatives must be considered in a rigorous analytical framework that avoids humbug.
The EIS at NTS7.11 claims a socio-economic assessment of the potential impact of the proposed airport development was done. This is not so. No original analysis was done for this terminal and the conclusions borrowed from the runway EIS are false. The T2 EIS repeats much of the questionable employment-gain arguments made for the runway in its EIS but does not even repeat the authors' caveats that were originally applied to these claims. In any case, estimates of employment impacts are not valid socio-economic indicators except in special circumstances that hardly apply to Dublin Airport for the foreseeable future. The DAA case begins by presenting estimates of jobs sustained by Dublin Airport as a whole. It should be obvious that attributing jobs to Dublin Airport is not an argument in favour of the proposed terminal itself for which no jobs implications are estimated. Any proposed expansion of an existing enterprise, foolish or otherwise, could be justified "by association" in this way. It is a common ploy of scheme promoters to blur the distinction between the jobs sustained by a given industry and the jobs that may or may not be created by a particular proposal to expand that industry. There is no necessary correlation, and damage can easily be done to existing employment by unwise investments. These jobs "boosters" misuse a methodology attributed to Wassily Leontiev(32). The abuse counts indirect and induced jobs, in addition to directly created jobs, in a manner that is statistically meaningless. All economic activity is interdependent and aggregating jobs together with related (indirect and induced) jobs leads to exaggerated estimates of the total number of jobs in an economy(33). Using this methodology, the 40,000-50,000(34) jobs supposedly attributable to Dublin Airport could just as easily be attributed to all the other industries, such as tourism, using Dublin Airport, rather than to Dublin Airport itself. It could be said, with equal justification, that tourism and the other users of Dublin Airport are the real source of all these jobs. In any case, job creation is only an economic benefit in its own right if it results in additional social and economic output. In the situation of low unemployment, congestion and the many other infrastructural impediments in the Fingal area, attempting to create extra jobs is a social and economic negative, not a benefit. The claim that any jobs created by expansion in such an environment flies in the face of the logic of Regional Development Policy and National Spatial Strategy. Such benefits do arise when jobs are created in a disadvantaged area, even if they are at the expense of jobs in a more prosperous area; but stimulating demand for labour in a prosperous region, creates economic and social costs, not benefits(35). It follows that more jobs are likely to be created and would be of real economic benefit, rather than a cost, if any needed expansion of airport capacity took place at another state airport such as Cork or Shannon or even at a new airport serving the GDA. The T2 EIS states, referring to the runway EIS: "The York Aviation assessment gives a good indication of which [sic] the potential impact of the proposed development on employment and income would be." However, in a paper presented to the oral hearing at An Bord Pleanála into the runway, York Aviation consultant Dr Nigel Mason insisted that York Aviation's work never claimed the direct and indirect jobs created by this runway would be additional (or net) to the national economy(36). He said: "..at no stage did we claim that all of the jobs and income would be additional to the national economy. On the contrary, it was explicitly stated in both the February 2002 and August 2004 [York Aviation] reports that the estimates of employment and income are 'gross', most importantly because they do not take account of the displacement of economic activity by the existence of Dublin Airport." In spite of Dr Mason's categorical qualifications, the DAA went on to claim these jobs as additional. The runway EIS itself said, referring to the York Aviation work: "The impact of the proposed new runway in 2025 would be around 30% more local, regional and national employment." Note "more" and "national". Indeed, the DAA's own website continues blatently to claim: "The overall impact of a new runway would be to facilitate additional aircraft and passenger traffic, thus adding another 30% to local, regional and national employment and to annual income(37)." Again, note the terms, "adding another" and "national". The DAA has misused and continues to misuse the analysis of its own consultants who have insisted that these claims are not justified. The DAA contradicted the authors of the study it commissioned in claiming all these jobs for the airport expansion programme as if they were additional and an economic benefit. As they are not additional, it is dangerous to claim them at all, because it must mean they are displaced from elsewhere, and as such indicate economic costs, not benefits, given the highly-developed and congested environment of Dublin Airport. In conclusion, no proper socio-economic analysis was done as claimed. The analysis done does not conform to the Finance Guidelines for such studies. The old "jobs analysis" that was done for the runway is repeated for the terminal and the same distorted conclusions drawn, contrary to the advice and objections of the original authors of the analysis. The conclusion that should be drawn by An Bord Pleanála from these claims is that the planned expansion at Dublin Airport is actually inimical to positive economic development and amounts to net socio-economic costs rather than benefits. It is therefore unsustainable, as shown by UPROAR's analysis.
The National
Development Plan 2000 - 2006 raises concerns about regional balance.
It states that the regional balance is the key to successful economic
development. The issue and the objective is to achieve regional balance
to "ease urban infrastructure" and try to "develop areas
lagging behind(38)" .
This would ensure the distribution of benefits of growth to other smaller
urban and rural areas. However the National Development Plan has identified
that there is one major weakness: distribution of benefits is not happening
and there is a greater disparity between regions as a result. The Dublin
Region and Dublin Airport are examples of this, whereby urban infrastructure
is intensified. The NDP states that such weaknesses must be addressed
and challenges must be overcome so that economic and social progress
can be maintained on a regional equilibrium. Continued unrestrained
expansion at Dublin Airport is contrary to these objectives. This is
underlined by the failure of the DAA to analyse with any degree of objectivity,
the potential for the development of any needed airport capacity at
an alternative site, not so close to the congested centre of Dublin
City. The Public Transport Partnership Forum The Public Transport Partnership Forum (PTPF) issued a report on the 'Short term Measures for Improved Public Transport Access to Dublin Airport' (2002), which carried out two passenger and employee surveys in 2001 to established statistics on public transport use. The report states that by 2007, 330,000 people will travel to and from the airport every week. The PTPF indicate that if no "active measures to encourage bus usage the bus modal share will fall and private car trips will grow to approx. 200,000(39)". This will result in an increase in almost 60,000 private car trips each week over 2001 figure of 142,000.
Sustainable Development is most important when it come to airports. Indeed sustainable development is most important when it comes to dealing with an airport that is located just over ten miles from a city centre, surrounded by a predominantly residential areas with most flight paths over a large area of residential land-use. Sustainability issues must be addressed and adhered to strictly for its smooth day-to-day operation. "Sustainable Development - A Strategy for Ireland" issued by the Department of the Environment in 1997 outlines the sustainability issues with regard to noise pollution and air pollution from aircraft. The section under the heading 'Air Transport' concludes that there should be greater attention paid to operational matters such as 'noise abatement procedures and selection of take-off and landing routes / orientations to minimise the impact of noise'.
Claims that this development is consistent with NSS are based on selective quotations from the NSS report about the importance of Dublin's role, but which fail to mention the immediately following qualifications that insist that the unbalance in favour of Dublin must be rebalanced by a positive discrimination in favour of the regions(40). We wonder what proposal would not be consistent with NSS using the interpretation of NSS applied by the DAA. Such sophistry cannot be taken as demonstrating that this development is consistent with NSS, which it patently is not. Among other things, how can a waste of €4.5 billion be consistent with NSS?
No further major development should take place at the Airport until such time as a national aviation plan is developed embracing Dublin Airport and all the other regional airports throughout the country, including the possibility of a second airport to serve the Greater Dublin Area. The Minster for Transport is responsible for our aviation policy, including the provision of adequate airport infrastructure(42). UPROAR believes that national aviation policy is instead being dictated by the Dublin Airport Authority. We recognise that the DAA's brief is to develop Dublin Airport. However the DAA's dominance of our national airport infrastructure capacity gives it a major influence on national social and economic welfare. Further development, with the construction of a new facilities as proposed, would put Dublin Airport in such an overwhelmingly dominant position that, a decision taken by DAA to apply for planning permission, would effectively determine national airport infrastructure policy for a generation, if construction were to follow an ultimately successful application. When UPROAR asked the Department of Transport what our national aviation policy was, we were referred to the aviation section in the Department of Transport's Statement of Strategy 2005 - 2007, published in July 2005. It is striking that what was presented as the "best steer" on Ireland's national aviation policy runs out in 2007, even before the terminal is built(43). The Chairman of the Fingal Development Board expressed the hope that such a policy might emerge from the "Towards Sustainable Airport Development" conference, held in October 2006. It is foolhardy and premature to approve the expansion plan for Dublin Airport in the absence of a coherent national aviation policy and approval should be withheld until such a comprehensive aviation policy or plan is in place following the appropriate policy review. An aviation policy review would start by asking some basic questions. As far as infrastructure is concerned a comprehensive review would be carried out of our existing airport facilities, public and private. Consideration would be given to the country's airport capacity needs into the future to meet likely demand, with likely future aviation fuel costs and climate change implications considered. There would be no preconceptions about where development should take place. Solid analysis would be used to determine the most economically and socially beneficial means to deliver needed infrastructure in ways that would integrate best with, and compliment other policies, such as public transport, sustainable development strategies and the National Spatial Strategy.
Dublin Airport at present is a totally unsustainable traffic generator, and the proposed development will add to the substantial increase in car usage to the airport. Both the DTI and the Government have clearly spelled out the need for rail connections to facilities such as the airport, and in the present instance the uncertainty of the development of the airport, allied to the long time horizon for rail links to the airport, clearly represents a unsustainable case for the present expansion of the airport, in the absence of a well documented land use and transport plan for the development of Dublin Airport, and indeed more importantly, the development of airports in the Dublin Region. The T2 EIS misleading presents the proposed Metro as leading to "reduced private car trips to/from the airport". While a Metro service would evidently reduce road-based transport relative to a situation with no Metro, this presentation covers up the unsustainable nature of the total road transport impact, even with the Metro in place. At the oral hearing into the proposed second parallel runway, it was admitted that at best, and assuming a Metro link to the Dublin Airport, non-road-based public transport would account for only 30% of airport passenger movements to and from the airport. The Metro will alter the current mode split only slightly as it is likely that many along the Metro corridor will shift from bus or taxi to Metro and the overall mode split will not alter significantly, i.e. most will still travel by road-based transport with severe consequences for the strategic road network, including the M1 and M50. As mentioned above, at the runway oral hearing Fingal County Council, supported by the DAA argued that all traffic implications of the runway, particularly those affecting the strategic road network should be deferred until the planning consideration of Terminal 2. We believe that the road traffic analysis presented in the Terminal 2 EIS, although a clear improvement on that undertaken for the runway proposal, does not deal adequately with the full local and strategic road-traffic implications of these proposed developments.
In this regard, we wish to refer to the appeal by the National Roads Authority dated 3 November 2006 against the planning permission granted by Fingal County Council for the construction of an IKEA store in the Ballymun area: F06A/0277. The concern of the NRA is to protect the €1 billion upgrade of the M50 from significant traffic delays and congestion that will result. The NRA states: "..the Authority is concerned to ensure that the benefits to be derived for the users of the M50 and the interface with the radial national road network are not jeopardised or prematurely undermined." And further: "Such as scenario would be unacceptable on this section of the motorway which forms part of the most critical artery for traffic distribution around Dublin and which serves as a vital link to Dublin Airport and Dublin Port, Ireland's largest airport and port respectively." The critical state of the upgraded road network serving Dublin Airport is not immune to developments at Dublin Airport itself. Why should Dublin Airport be exempt from a duty to ensure that access to its services is not threatened by its own development plans? Unwise developments at Dublin Airport are even more likely to impact negatively on its own access. It is our contention that the current runway and terminal proposals at Dublin Airport are unsustainable in terms of traffic impact and the Board should have the same regard to those threats to Dublin Airport access as to any other public or private sector development proposal threatening airport access. The proposed expansion at Dublin Airport is projected to handle an additional 20 million passengers by 2025. Eighty per cent of passengers passing through Dublin Airport currently use the car (taxi, private car or hired car). The extra staff needed to cope with these extra passengers would also add thousands more car movements a day. The proposed Metro to Swords would reduce the car pressure somewhat. As mentioned earlier, a mode shift to 70% is the best that can be expected from the Metro development. UPROAR estimates that at a minimum, even with the Metro to Swords in place, there will be an extra 35,000 car movements per day by 2025 due to planned airport expansion. That is at least three times the maximum daily car movements due to IKEA on the same full-capacity road network, that the NRA objects to. Car traffic generated will therefore cripple the upgraded M1-M50 network. It should also be borne in mind that the ultimate capacity of the airport, stated to be 55-60 million passengers per year, may be reached around 2030, if not sooner (based on the DAA's own annual growth figure of 6%.) That would double again the road traffic impacts and should put beyond doubt the unsustainable nature of the proposed airport expansion programme in its totality. The NRA appeal also states that: "It is understood that Fingal County Council are currently carrying out a study to determine the road network changes required in the South Fingal area up to 2024. That study is understood to be examining the traffic impacts of all the major development proposals in this area of Fingal - Ikea, Terminals 2 and 3, Airport Road Box, residential and commercial development proposals - and assesses in an integrated coherent manner their combined affects and which will then proceed to identify what can or cannot be facilitated and what infrastructure should be provided to cater for such proposals. In the absence of such an integrated examination and identification of transport solutions there is a significant risk that an ad hoc approach to determining developments, especially one as significant as Ikea, will lead to long-term problems." It is clear that the same reasoning should apply to the proposed terminal and associated developments whose impacts are to be assessed in this traffic study. It is premature to proceed with this terminal in the absence of this traffic impacts study. FCC's Planning Condition 6 that the M50 upgrade shall be substantially completed on the section comprising the M1/M50 Interchange and the Ballymun Interchange prior to commencement of operation of Terminal 2, presumes that this upgrade will be adequate to sustain the extra airport generated road traffic. This is evidently not the case in the absence of a full traffic impacts study.
The treatment of noise impacts is inadequate and misleading. The DAA has attempted a reversal of its project-splitting tactic from the runway oral hearing regarding the road traffic impacts of the proposed runway. They even stoop to the same "in itself" language previously applied to the new runway. The T2 EIS text says (see: EIS NTS7.2B):
This comes about: "due to the relatively limited growth attributable to the new terminal building in itself" (See EIS 8B.6.1.) This sleight-of-hand is achieved by forcing both the "do minimum" and "do something" scenarios to begin from 2012 when it is assumed that the new runway will be operational. By so doing the EIS is able to suggest that the new runway will be present when the alternative futures with and without T2 would apply. In fact the EIS makes clear elsewhere that T2 is planned to be operational by October 2009(44). The analysis should have started from that date. Had it done so, the above conclusion could not have been reached. The first sentence is simply false: there could be no increase in noise levels to the north without T2 because the new runway could not be built without T2. That is why T2 is planned to open before the new runway. The present terminal is already at or above its capacity of 20/21 million and it is stated (see EIS NTS3) that on completion of T2 in 2009, there will be an immediate switch of 10 million passengers from T1 to it; this is well before the completion of 10L/28R(45). On these EIS figures, it is clear that no passengers from the new runway could be accommodated in T1 (or T2) without the building of T2. Consequently all growth in passenger numbers on the new northern runway is dependent on T2 as therefore are all its noise consequences. To put it simply, it is clear that if all further expansion in terminal capacity was disallowed at Dublin Airport, the new parallel runway could not be built. Consequently its building and its subsequent noise and other impacts are dependent on this new terminal. It follows that all the noise-related objections raised by appellants regarding the proposed northern parallel runway apply also to Terminal 2. Indeed, this conclusion accords with the position adopted by the FCC and supported by the DAA at the runway oral hearing in its claim that all road traffic impacts of the proposed new runway were attributable to T2 and not to the construction of the runway "in itself". If that logic applied then, why not now? It is more logical than the reverse case now being made that, "in itself", T2 will have negligible noise impacts over and above that of the new runway. As pointed out above, it is a disgrace that public bodies would stoop to such contorted arguments to try to avoid proper scrutiny of their planning proposals when it suits them, and to try to reverse them when it does not suit. In our opinion, these separate planning proposals are part of an inseparable Dublin Airport Development Programme and, in the public interest, they should be honestly assessed as a package. It follows that all the criticisms of the noise impacts of the proposed parallel runway apply to T2. A key element of this criticism was that based on the RANCH study that showed a deleterious impact of aircraft noise on children's school learning, starting at low levels of noise(46). . Prof Stansfeld upheld these findings at the oral hearing into the proposed runway and confirmed that there was no evidence that school insulation solved the problem.
The treatment of the potential negative health impacts in DAA's Terminal 2 application is wholly inadequate, indeed it is derisory, based as it is on the DAA's "project-splitting" nonsense. A section titled "Impact on Human Beings" comprises the whole analysis of health impacts. It expresses some concerns for a temporary disruption to roads users during construction and otherwise deals with all health impacts by concluding that the overall impact will be positive: "The proposed Terminal 2 development is likely to have an overall positive socio-economic impact directly on airport users and on the local community and indirectly on the wider community, regionally an nationally. This is in part due reduced passenger "stresses"! See the Non-Technical Summary NTS7.11. The inadequacy of the treatment of human health impact issues in the application of the proposed runway was pointed out by Dr Anthony Staines of UCD. Clearly, as this terminal application does not even attempt to emulate that inadequate treatment, Dr Staines' criticism of the runway's impacts apply totally to this terminal's health impacts, which cannot be divorced from the impacts of the runway. His call for a full Health Impact Assessment of these airport expansion proposals stands. See: "Revised Dr Staines report for T2", attached.
As noted above, it is clear that the proposed terminal is planned to be operational before the proposed runway. It is also evident that the scale of the proposed terminal is influenced by the proposed runway. In granting permission the FCC's Planner's Report states: "Considering this [the absence of approval for the proposed runway], it is acknowledged that the operational/capacity restrictions on the existing runway may influence or limit the level of use of the new terminal." It is our submission that it was premature of FCC to grant planning approval for the terminal in the absence of a decision by An Bord Pleanála on the runway which will have such a crucial impact on the design and scale of the proposed terminal.
Under "Aviation
Considerations" the FCC Planner's Report says: "The proposal
has been referred for independent assessment to Mr David Stanley of
Stanley Associates, who is a private sector aviation consultant based
in England and is familiar with the aviation aspects and operations
of Dublin Airport." As Mr Stanley is a paid FCC consultant his
cannot be considered an "independent assessment". This is
also clear from his involvement with the runway proposal. Conclusion We believe the Dublin Airport Authority has failed to prove that its expansion proposals including Terminal 2 and associated developments constitute good planning in the interests of the common good and that we have demonstrated that, being a huge economic and social loss in its own right, it is disproportionate to the ends sought and an unsustainable development. Accordingly we ask An Bord Pleanála to uphold our appeal against the terminal and its associated developments and we request an oral hearing of the Board on the matter.
(1) Chief Justice C.J. Keane in the Supreme Court on 28th August 2000, regarding the Planning and Development Bill 1999, quoted an early Supreme Court Judge saying: "If the State elects to invade the property rights of the individual citizen, it can only do so to the extent that this is required by the exigencies of the common good. If the means used are disproportionate to the ends sought, the invasion will constitute an 'unjust attack' within the meaning of Article 40.3.2." Bunreacht na hÉireann 40.3.2: "The State shall, in particular, by its laws protect as best it may from unjust attack and, in the case of injustice done, vindicate the life, person, good name and property rights of every citizen." (2) The preamble to the Local Government (Planning and Development) Act, 1976 setting up An Bord Pleanála. "An act to make better provision, in the interests of the common good, in relation to the proper planning and development of cities, towns and other areas, whether urban or rural, and, for that purpose, to establish a body to be known as an bord pleanála…" (3) "The National Spatial Strategy 2000-2020, People, Places and Potential", Department of Environment and Local Government, undated but launched on 28 November 2002. (4) It is interesting to note that the FCC T2 Planner's Report says: "Whilst it is recognised that there are also significant externalities associated with increased aircraft movements arising from the increase in passenger capacity, these have been examined under the second runway application F04A/1755 and are being considered by An Bord Pleanala at present." This is a contradiction of the FCC's position on the runway that denied there were any road-traffic externalities due to the proposed runway itself. However, it is reassuring that at least one rational planner in FCC had trouble believing, like Alice, "in as many as six impossible things before breakfast". (5) See attached "Legal Submissions" prepared for Matthew Harley of UPROAR for the runway oral hearing for a criticism of this "project-splitting". (6) Report of the Planning Officer dated 25th October 2006 F06A/1248. (7) "Guidelines for the Appraisal and Management of Capital Expenditure Proposals in the Public Sector" - February 2005 See: http://www.finance.gov.ie/documents/publications/other/capappguide05.pdf (8)
EU guidelines: "Guide to cost-benefit analysis of investment projects",
(Structural Fund-ERDF, Cohesion Fund and ISPA), Evaluation Unit, DG
Regional Policy, European Commission, 2002. See: (9)
"Value for money is also not simply an item to be ticked in project
appraisal. Rather it is the outcome of a carefully considered appraisal
system and culture that takes into account, as objectively as possible,
the overall benefits and costs of a given project and seek to make sure
that budget estimates are met….Currently, Department of Finance
Guidelines require that projects with value in excess of €50 million
are subject to full scale cost benefit appraisal. I believe it is appropriate
to reduce the project value level to €30 million. This approach
will include identification and carefully quantified analysis of all
the relevant project costs and benefits, including indirect costs as
well as the identification of any risks of cost escalation. The principle
of cost-benefit analysis is that a project is only desirable if the
benefits exceed the corresponding costs." See: http://www.finance.gov.ie/viewdoc.asp?DocID=3561
(11) "Submission to Runway Planning Enquiry", by Mark Foley, Director - Capital Programmes, Dublin Airport Authority, September-October 2006. (12) The Guidelines do not qualify funding by the term "direct": "All Government Departments and public bodies (semi State bodies, local authorities and health agencies, etc.) and all bodies in receipt of public funding for capital purposes must comply, as appropriate, with the relevant requirements of these guidelines." Note also that all semi-state bodies such as the DAA are subject to the Guidelines, regardless of the source of funding, as indicated by the use of the conjunctive "and" before "all bodies". The EU guidelines are more explicit on proper accounting for existing state-owned assets, and the same principle obviously applies under the Finance Guidelines: "Capital assets, including land, buildings, machinery and natural resources should be valued at their opportunity cost and not at their historical or official accounting value. This has to be done whenever there are alternative options in the use of an asset, and even if it is already owned by the public sector." See: http://ec.europa.eu/regional_policy/sources/docgener/guides/cost/guide02_en.pdf, page 32. (13) This figure of €300 million for Terminal 3 was given by Mr Ulick McEvaddy at the "Towards Sustainable Airport Development" conference, October 2006. It is probably conservative. (14) This is the growth in passenger numbers predicted by the DAA, as far as can be ascertained. The two terminals are assumed to reach capacity by 2020/21, when the third terminal will be required, see: EIS 6.5.1. The results of the analysis are largely insensitive to these projections. However, at present rates of growth, it is likely that full capacity of T1 and T2 at about 35 million and full airport capacity of 55-60 million will be reached much earlier that expected by DAA. The DAA's own 6% per annum growth rate would see 60 million passengers by 2025. However, these rates of growth may not continue in the light of potential future aviation fuel costs, including scarcity prices and environmental taxes. (15) The 2005 Finance Guidelines require a preliminary appraisal: "The preliminary appraisal aims to establish whether a sufficiently good prima facie case exists for considering a project in depth." Evidently no such preliminary appraisal was done by the DAA either. (16) Council Directive 85/337/EEC Annex III. 2, which governs Environmental Impact Assessments, says "Where appropriate, an outline of the main alternatives studied by the developer and an indication of the main reasons for his choice, taking into account the environmental effects." The Department of Finance Guidelines for the Appraisal and Management of Capital Expenditure Proposals in the Public Sector state: "All realistic ways of achieving stated objectives should be identified and examined critically when considering project options for the first time. This should be done with a completely open mind, and should always include the option of 'doing nothing' or 'doing the minimum'" [bolded in the original]. (17) See FCC Planner's Report, "Adequacy of EIS", Item 1(d). (18) T2 EIS 2.2.3.1; "Option 1 - East: To expand the existing terminal to the south and east of the existing site to form as much as possible a large single terminal with a single set of landside and airside facilities with a capacity of 30 million passengers per annum (MPPA). Landside access would still be from the east, off the M1." (19) To quote the FCC Planner's report: "These options were critically evaluated against 3 criteria (2.2.3.1) and option 1 chosen on the basis that it ranked highest ' for its combination of robust functionality and has the highest potential to achieve the 5 year capacity milestone. It offers the best value in terms of early deliverables and represents the lowest overall capital cost to complete' (chptr 2 p 4 EIS)" (20) See: Chapter 7 of "The Economics of the Proposed Runway" attached. Also available at: www.norunway.com/bp/bp.htm. (21) Declan Collier, CEO of DAA gave a maximum capacity figure of 60 million passengers per annum to Pat Kenny on RTE Radio 1, on 21 September 2006. Ciaran Scanlon, DAA programme manager, gave a capacity figure of 55 million to Fingal Independent, 30 August, 2006. (22) "I understand that the figures used are based on those as published by Dublin Airport Authority in its annual report of 2005. Note 10 to the financial statement of that report states that the figures in respect of lands and airfields, for group and company, include airport land at a cost of €19.6 million." David Hodnett, Deputy Head of Legal Affairs, Commission for Aviation Regulation, 15/5/2006. (23) The regulator requires a 7.4% annual return on airport assets. Assuming 20 million passengers per year and a total land value of €20 million, the charge is 20*0.074/20 = 7.4 euro cents per passenger. (24) London City Airport was recently sold for £750 million (€1.1 billion). That is nearly twice the value (€614 million) the aviation regulator puts on Dublin Airport although it is twenty times the area and has ten times the passengers of LCA. As a consequence of this gross undervaluation the passenger charges at Dublin Airport are set at a hugely subsidised rate. (25) "DAA Passenger and Aircraft Movement Forecasts." "Proof of Evidence" paper delivered by Dr Mary Coveney of the DAA at the runway oral hearing Sept-Oct 2006. (26)
"Air Travel Demand Elasticities: Concepts, Issues and Measurement
- Final Report," Gillen et al., Department of Finance, Canada,
December 2002. See: http://www.budget.gc.ca/consultresp/Airtravel/airtravStdy_e.html (27)
See article 582 "Air Miles" at : http://www.peakoil.ie/downloads/newsletters/newsletter56_200508.pdf (29) See: http://www.economist.com/business/displaystory.cfm?story_id=7033931 (30) "Market issues associated with a second airport" "Proof of Evidence" paper delivered by Dr Mary Coveney of the DAA at the runway oral hearing Sept-Oct 2006. (31) Richard D Lipsey, "An Introduction to Positive Economics", 3rd edition, 1974, page 211. (32) "With the collapse of most centrally planned economies, use of I/O analysis is now largely confined to economic consultants hired to justify costly and underutilized building projects such as a convention center or football stadium because they will "create" jobs. In fact, such projects never create anything approaching the benefits projected through the misuse of these models, but there always seem to be local boosters, businessmen, and politicians willing to exaggerate the potential benefits." See: Professor Ronald Utt, "Highways and Jobs" at http://www.heritage.org/Research/Budget/bg1747.cfm (33) See: "The contribution of aviation to the economy: Assessment of arguments put forward." By Bart Boon and Ron Wit, CE Delft, July 2005, at http://www.norunway.com/BWstudy.pdf (34) The 40,000 jobs figure is contained in "Economic Impact of the proposed New East-West Runway at Dublin Airport", "Proof of Evidence" paper delivered by Nigel Charles Mason of York Aviation at the runway oral hearing Sept-Oct 2006. Declan Collier at the "Towards Sustainable Airport Development" conference in October 2006, gave a figure of 50,000 jobs, at least. (35) In their assessment procedures, specifically tailored to airport capacity, the British Transport Ministry pay particular attention to the dangers of overheating job markets, and impose an assessment penalty when it would be a consequence of bad investment proposals:
See: "Appraisal framework for airports in South East and East of England." U.K. Department of Transport, Page 15, at: http://www.dft.gov.uk/stellent/groups/dft_aviation/documents/pdf/dft_aviation_pdf_503309.pdf (36) See paper by Dr Mason of York Aviation, above. (37) http://www.dublinairport.com/about-us/airport-development/Parallel_Runway.html (38) Balanced Regional Development, Page 9, "National Development Plan 2000 - 2006." (39) "Proposing Solutions", Page 3, "Short Term Measures for Improved Public Transport Access to Dublin Airport." (40)See "Use of NSS by runway advocates" in Chapter 8, "National Development Policies" in "The Economics of the Proposed Runway." (41) See "National Aviation Policy and the proposed runway" in Chapter 8, "National Development Policies" in "The Economics of the Proposed Runway." (42) "The Department is responsible for ensuring that aviation practices and procedures comply with best international standards; promoting the development of a vibrant, competitive and progressively regulated aviation sector and the provision of adequate airport infrastructure and competitive airport services." See: http://www.transport.ie/aviation/index.asp?lang=ENG&loc=835 (43) "I understand that you have requested information on Ireland's national aviation policy. The best steer I could give you in that regard is to the aviation section in the Department of Transport's Statement of Strategy 2005 - 2007." Email from the Department of Transport, 4th May 2006. (44) There are various dates given in various DAA sources for the availability of the proposed parallel runway, none earlier than 2010. The T2 EIS assumes the new runway will be operational by 2012. (45) The proposed new terminal is designed to handle 15 million passengers and to allow total airport passenger throughput to reach 35 million by 2025. (46)
"Aircraft and road traffic noise and children's cognition and health:
a cross-national study." (47)"Dublin Airport Runway Appeal, Brief of Evidence", David Stanley, September 2006. |
|||||||||||||||||||||||||||||||||||||||||||||||||||||
