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RPS reply
18 July 2007. Ref: F06A/1843 Dear Mr Devine On behalf of the Portmarnock Community Association I wish to reply to the remarks made on behalf of the DAA by RPS Planning and Environment in its "Observations on Third Party Appeals" dated 11 June 2007, and sent by you on 29th June.
The RPS response impugns the motives of the Portmarnock Community Association while failing to deal with the substance of the matters raised by us. We make no apology for defending our community against what we see as a serious attack by Dublin Airport on our health and welfare. Rather, we question the objectivity of our RPS critics who, to our knowledge, in their work on behalf of the DAA over a number of years have never made a criticism of a DAA proposal. Their record is clearly one of defending all DAA proposed developments regardless of deficiencies. Their pecuniary interest should disqualify them from casting aspersions on the motives of a community whose only interest is the welfare of its residents.
Typical of RPS analysis on behalf of the DAA is "proof by assertion". A good example is their claim that the T1X proposal does not need an EIS. They simply assert that, as the T1X proposal will have no significant environmental effects it does not require an EIS. This is circular reasoning. Before making any attempt to measure environmental impacts they assert that there will be none of significance. This makes nonsense of the relevant EU Directives that require cumulative effects to be assessed. Of course, with its usual objectivity, Fingal County Council agreed no EIS was required. A critical factor in this case is the additional number of passengers resulting from the T1X development. The applicant's case is that there will be no such effect(1). But that is simply an assertion and is untrue. The RPS letter of 6 July 2007 making the case for no EIS indicated there would be no check-in facilities in T1X and hence it "does not provide facilities for a significant increase in passenger throughput." However, this is contradicted by Declan Collier who indicated that T1X will have "extra check-in desks"(2). Even by RPS' own selective criterion, T1X will increase passenger throughput directly through its extra check-in desks. The Board should clarify this matter of check-in desks in T1X by way of a Request for Additional Information
Even without extra check-in desks, it is patently misleading to claim that the T1X proposal will have no effect on passenger numbers when it is evidently part of a terminal expansion programme designed explicitly to increase passenger throughput. As pointed out in our submission, T1X is one part of a two or three-part expansion of T1, which together, according to DAA's CEO Declan Collier, will add six million to the annual passenger capacity of T1. It is stated that the Area 14 component will handle 4 million departing passengers per annum(3). It follows that the other extension works will accommodate 2 mppa. This breakdown into mppa shares is spurious as there is no rational basis for such a split. It is as if a hotel builder applied for planning permission but wanted to exclude consideration of the restaurant on the grounds that as checked-in guests would only be eating there, it did not add to the number of guests. The hotel as a whole is designed for a certain number of guests; it is ridiculous to claim that parts of it have no effect on guest numbers. It should be clear that with no restaurant, there would be fewer guests. Similarly, the current inadequate facilities at T1 without T1X should lead to fewer passengers using those inadequate facilities. In any case, contrary to the RPS claim, T1X will have check-in facilities and will directly handle extra passengers and DAA's own figures say T1X will accommodate an additional 2 mppa on top of Area 14's extra 4 mppa.
This of course is just a continuation of the DAA's "Project Splitting" strategy that RPS and others have pursued on behalf of the DAA since the new parallel runway application. Indeed the T1X case amounts to a pure case of "project splitting" unlike the new runway and new terminal proposals that were described by our legal council as "a more subtle version" of pure project splitting where "there is a failure to identify correctly the entire project and as a result only a partial assessment is carried out."(4) This involved shifting most of the impact of the development in question onto another component of the development, albeit providing a (diluted) EIS for both components. In the T1X case they isolate the proposal from other components and argue for no EIS. In the parallel runway case, in applying for planning permission the DAA and FCC argued that "of itself" the runway would have no impact on road traffic because such impacts would arise only with a new terminal to handle the extra passengers(5). The story reversed when it came to seeking planning permission for the new terminal (T2). The DAA's analysis of the impacts of T2 on noise, air quality and road traffic, was based on what they claimed were the extra aircraft movements with their passengers, due only to T2 assuming the new runway is already in place!(6) They then concluded that there would be less than 3% extra aircraft movements when T2 is full in 2024 compared to what would happen if T2 were not built(7). Using the DAA's own figures, that would amount to only an extra one million passengers by 2024. At the same time the DAA says that T2 is designed for 15 million passengers. Ryanair says it is designed for many more and the CAR agrees that the design is oversized(8). By this not-so-subtle ruse, the passenger impacts that were to be due to T2 rather than the new runway, have now been given back to the runway, that of course is assumed to be built and beyond any scrutiny of its full environmental impact. We would hope that these project splitting devices will be seen by An Bord Pleanála for what they are: feeble attempts to avoid proper scrutiny.
When it suits, DAA's expansion plans are revealed and all kinds of benefits claimed for them. The DAA's stated objective is to expand Dublin Airport to handle 60 mppa(9). The only large component of this plan not currently in the planning process is a possible Terminal 3 to be built sometime around 2020 to handle some 15-20 million passengers per annum. It follows that the current plans (T1X, T2 and R2) intend to expand Dublin Airport to some 40-45 mppa on the Eastern Campus and 60 mppa overall(10). Yet nowhere in the planning process for these three components has this doubling of passenger throughput on the Eastern Campus, and overall trebling, been assessed because of blatant project splitting. No doubt we will be told it all depends on T3 until, when it comes to T3, we will be told T3 has to be built to justify the investment in the previously built new parallel runway, T2 and T1X! Can RPS indicate to An Bord Pleanála where the cumulative impacts of T1X, T2 and R2 have been fully assessed? It beggars
belief that two public bodies (the DAA and FCC - a public company and
a local authority) would attempt to avoid public scrutiny of their proposals
with the support of paid consultants. It is incumbent on An Bord Pleanála
to refuse to accept these attempts to avoid due process and to demand
that a full EIS assessing the combined impacts of facilities for 60
mppa be provided before any component of this expansion programme is
approved. RPS defends
the quality of DAA forecasts on the grounds that the methodology was
reviewed eight years ago by Warbug Dillon Reid. A more recent and independent
evaluation of these forecasts concluded that: "DAA's forecasts
may not be internally consistent(11)." As usual,
RPS is selective in its reporting. RPS claim cost benefit analysis is irrelevant to planning. This is an odd claim when sustainable development is a sine qua non of good planning. At an aviation conference in 2006, An Taoiseach Bertie Ahern insisted that projects had to pass a test of sustainability before they are built(12). There is only one officially sanctioned test of sustainability: the Department of Finance Guidelines that require a full cost benefit analysis for projects costing more than €30 million. It would seem to be hard to imagine An Bord Pleanála ignoring findings that confirmed on the basis of such an independent analysis that the proposal was a waste of at least €4.5 billion in economic, social and environmental terms, and thereby unsustainable. On the other hand, we have no difficulty imagining RPS arguing that such a waste constituted sustainable development. Irrespective of the issue of the relevance of CBA to the formal planning process, this proposal has to be subjected to a full CBA under Department of Finance and NDP guidelines. We would also refer to the agreed Programme for Government that now requires a "multi-criteria analysis of all transport projects to take into account environmental factors on a whole project basis(13)." As this has not yet been done, it is now required. If planning approval is given before such a study reports, building still requires Cabinet approval. A Cabinet decision can only be made in the light of the results of such a study. RPS claims that Cost Benefit Analysis is irrelevant to planning yet said in the runway case that: "..cost-benefit analysis is a rigorous approach to assist in decision making about proposed projects(14)." They also went to considerable lengths to attack our CBA of the runway proposal referring to our work as "flimsy analysis." Our analysis has been largely confirmed by consultants for the Aviation Regulator whose preliminary results found that, even with very conservative cost assumptions, the Dublin Airport's planned investment yielded a negative return. RPS, of course, made no attempt at such an analysis and is apparently unaware of the CAR's work. As part of the DAA's runway case, York Aviation did an "Employment and Economics" analysis for DAA. When we demonstrated in our submission "The Economics of the Proposed Runway" that this jobs analysis was hopelessly flawed and the claims made about the economic benefits of job creation were false, RPS made the following statement: at 8.2.1 of its Observations: "It is our opinion that these estimates are the least important part of the economic analysis and that the economic impact case for the proposed second runway is crucially a function of the potential wider economic benefits of the project." This is quite an astonishing statement. Neither RPS nor York made any attempt to quantify such presumed wider benefits, yet when the jobs analysis was undermined RPS tried to switch the economic argument to a claim about wider benefits that were not even listed let alone quantified. We are effectively asked to take on faith that the proposal is justified, not on the basis of the discredited analysis carried out, but crucially on the basis of unspecified and unquantified economic benefits. And then RPS have the effrontery to state that our detailed, quantified and transparent analysis was "flimsy"(15). Tourism was mentioned by another consultant(16) as one of these "wider economic benefits". It is patently obvious that national tourism benefits would not necessarily suffer from an alternative such as a second airport and might very well increase due to lower congestions and a better service in a modern airport. We have also pointed out that real job creation benefits could be realized if such an airport were built in a region of higher unemployment than Fingal. The Dublin Airport proposal will not generate such benefits but by overheating the labour market in Fingal will actually impose economic costs(17). The presumption would be in favour of positive jobs benefits in the second airport case. The same is probably true of other "wider benefits". I.e., an alternative such as a second airport for the GDA would be likely to have similar "wider benefits" that may well be greater in many cases. It is just another unsubstantiated and worthless assertion by RPS that these benefits will be greater for the DAA's option.
We are accused of selective reading of the NSS when it is patently obvious that its objective is to rebalance economic growth in favour of the regions, in spite of a reference to the importance of Dublin Airport in the NSS. We do not deny the importance of Dublin Airport for our national economic welfare but do question its unsustainable expansion regardless of its regional impacts. This view is shared by a current Government minister. In a presentation to the runway oral hearing on 29 September 2006, Trevor Sargent said that, as far as National Spatial Strategy was concerned, the runway proposal was jeopardising the national interest by exacerbating the persistent economic imbalances between the Greater Dublin Area and the West. It appears RPS does not agree with the minister. Matthew Harley Attachments:
(1)
See letter from Richard Hamilton of RPS dated 6 July 2007 entitled:
"RE: AIRPORT TERMINAL 1 EXTENSION - SCOPING OF NEED FOR ENVIRONMENTAL
IMPACT STATEMENT." It was submitted to FCC and registered by them
on 14-12-2006. (3) See: http://www.dublinairportauthority.com/images/Transforming_DAP_Brochure.pdf Is it not odd that Area 14 which did not require planning permission is assigned the bulk of the extra passengers while the impact of the other parts of the expansion which do require planning permission is downplayed. (4) See attached Legal Submissions to runway oral hearing: "It is not it is submitted an example of "pure" project splitting which generally refers to the break up of a development to ensure none of the individual projects are large enough to trigger the requirement for an EIS. It is submitted that the development before the Board is a more subtle version of same ie there is a failure to identify correctly the entire project and as a result only a partial assessment is carried out." (5) "The provision of a second runway will not of itself create an immediate increase in traffic around the airport. The increase in vehicular traffic in the vicinity of the airport will be governed by terminal capacity." See: "Brief of Evidence to New Runway Oral Hearing by Mr Pat O'Callaghan for FCC. (6) The effect of growing employee numbers on road traffic was diluted by assuming that, as the new runway was already in place, jobs created by it were also in place so that passengers through T2 would add few extra jobs, hence reduced traffic impacts. They also forgot to add the traffic impacts of all the indirect jobs they claim will be created in and around Dublin Airport by their expansion plans. This is another good example of DAA double standards: when it suits the message they claim lots of jobs but when those jobs have negative impacts that have to be assessed (e.g. on road traffic) they are diluted or even disappear. See UPROAR's closing submission of 4 May 2007 to the T2 oral hearing, attached. (7) This 3% figure is contained in the T2 EIS - NTS page 20 and on page 18.7 in main text. Different figures were presented at the oral hearing (without explanation) but of a similar feeble magnitude. (8)
See Manahan Planners response for Ryanair of 13 June 2007. (10) The DAA says T2 will handle 20 mppa comfortably and the improved T1 will handle 20 million leading to a total terminal capacity on the Eastern Campus of 35 million. Ryanair believes the Eastern Campus, as planned, will accommodate 50 mppa and the Aviation Regulator agrees that T2 as specified is oversized by 38% and will set passenger charges accordingly if and when T2 opens. See: Table 4 of CP5/2007 at www.aviationreg.ie. (11) See: page 5 of "Review of Dublin Airport Authority, Capital Expenditure Programme (CIP 04) For The Commission for Aviation Regulation, Report No. 4 - Review of DAA Terminal Sizing", Rogersonreddan, 16th May 2007, available on www.aviationreg.ie. (12) An Taoiseach Bertie Ahern made the following comment at the "Towards Sustainable Airport Development Conference" on 23 October 2006: "One issue that has come increasingly to influence our thinking in recent years is now critical to the decision-making processes as regards all forms of infrastructural investments in all sectors of the economy. It's the issue of sustainability. The sustainability test of major development projects aims to ensure that the impact on the wider economic and social environment is taken into account before projects go ahead at all." (13) Draft Programme, Final Document, 12th June 2007. (14)
See: 8.2.4. of Proposed Northern Parallel Runway, RPS Planning and Environment,
"Observations on Third Party Appeals", June 2006. (16) David Stanley, "Brief of Evidence" to parallel runway oral hearing, September 2006. (17) In their investment 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 "Airport growth in an overheated regional or local economy could exacerbate local labour supply shortages and cause problems for local firms, perhaps causing them to relocate. These factors including the potential match between skills available within the workforce and skills required by potential employers as a result of airport development will be considered in the studies. A specific appraisal indicator used in the appraisal of specific packages will be "labour market overheating" which would relate the jobs created at the airport, by skill group, to the size of the labour force in a reasonable catchment area by skill group and to current rates of unemployment among the labour force." |
