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Appeal by Portmarnock Community Association - UPROAR* against a decision by Fingal County Council dated 19 April, 2007 to grant permission to Dublin Airport Authority for the construction of an extension to the existing main terminal at Dublin Airport (Reg. Ref: F06A/1843)
*UPROAR: United Portmarnock Residents Opposing Another Runway is a sub-committee of the Portmarnock Community Association. Objection to Extension to Existing Main Terminal 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 to the proposed extension to the existing main terminal at Dublin Airport. We have no objection to the sustainable development of the airport, but are most concerned that the proposed extension, in conjunction with other developments such as a proposed new parallel runway and second terminal, will have a deleterious and long-lasting impact on the lives, amenity and welfare of all residents in the Portmarnock area. Fingal County Council's Citizen Charter states:
In granting planning permission for this development Fingal County Council has ignored its own charter as far of the Portmarnock Community is concerned. 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 a 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. In making this appeal we have also taken cognisance of our National Spatial Strategy, the Dublin Regional Planning Guidelines, the Statutory Development Plan for the area, i.e. Fingal County Development Plan 2005 - 2011, and other important guiding documents, such as the DTO policy regarding Dublin transport, the NRA's policy regarding the protection of the national primary route resource and the overarching policy of Sustainable Development.
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 main terminal extension and its related runway and second terminal 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.
We do not object in principle to the provision of proper passenger terminal facilities at Dublin Airport. However, we do object to the ad hoc nature of the proposed extension that is part of the reckless and unsustainable development of Dublin Airport as a whole. We have previously appealed the decisions by Fingal County Council to approve a new parallel runway and a second terminal at Dublin Airport(4). The proposed extension is part of the overall development of Dublin Airport as set out in its €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 €2 billion development programme includes the proposed terminal extension as well as Terminal 2, a new Pier E and the second parallel runway 10L/28R (5). The proposed later Terminal 3 on the Western Campus of Dublin Airport, as set out in the Dublin Airport Masterplan, is additional. Declan Collier, CEO of DAA, said €450 million would be spent by 2009 on T1 related projects (6). As well as the proposed extension this figure also included Pier D, Area 14 and some other works. We do not have an estimate for the construction cost of the proposal for which planning permission has been sought. There can be little doubt that it exceeds the €30 million cost to which rigorous Government appraisal guidelines apply, see below. In our opinion it is impossible for the Board to make a proper planning assessment of the cumulative effects of this proposed terminal extension in the absence of a complete description of Dublin Airport's planned expansion in time and space, and this terminal expansion's part in that whole. To proceed, the Board should insist that DAA provide a comprehensive description and impact assessment of its full expansion plan including this T1 extension proposal, its second terminal proposal, its proposed demolition of existing runway 11/29 (7), its second parallel runway proposal, and all related piers, aprons, stands, taxiways, car parks short and long-term, and all requirements for ancillary services including: water supply, waste water disposal and sewage. Further, all related road works within and without the Designated Airport Area, must be described and analysed.
The Department of Finance appraisal guidelines provide this state's principle test of sustainability and proportionality (8). There are also EU appraisal guidelines that apply (9). 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 (10). Minster Cowen restated this requirement on announcing the 2007 Estimates on 16 November 2006 (11). 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."
Apart from the Finance Guidelines there are also guidelines set down by the European Commission, originally for the evaluation of investments using Structural and Cohesion Funds(12). These guidelines now apply to all investments under the National Development Plan, regardless of the source of funds(13). The new National Development Plan 2007-2013 envisages spending €1.8 billion on infrastructure at Dublin, Cork and Shannon airports. This includes Dublin Airport's expansion plan and it is therefore subject to the Value for Money assessment set down in the NDP. Announcing the plan, Finance Minister Brian Cowen said all projects in the new NDP costing over €30 million must be subjected to a full cost benefit analysis(14). The NDP evaluation guidelines therefore apply to all elements of Dublin Airport's expansion. The Value for Money assessment of the new NDP requires that all projects over €30 million be subject to Cost Benefit Analysis. EU and Department of Finance guidelines and methodology apply. A Central Monitoring Committee, chaired by the Department of Finance, will monitor implementation of the NDP. A new Central Expenditure Evaluation Unit, based in the Department of Finance, will have oversight of all reviews. All evaluations must be published and submitted to the various oversight bodies. There is no evidence that any such assessment either under Department if Finance guidelines or new NDP assessment requirements, has been carried out for the current proposal, or other components of the Dublin Airport Development Programme such as the new parallel runway and second terminal proposals. As Value for Money is a necessary condition for sustainable development, the absence of such analysis should be fatal for any planning application. Cost Benefit Analysis of Dublin Airport Development Programme.
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(17). 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, the Ten Year Capital Programme at about €1.2 billion, is €800 million less than the current DAA estimate. A figure of €300 million for T3 is conservative. 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 take some of the expanding airport traffic off the congested road network. Some 20% of the Metro use will be airport related. That should imply a Metro related cost of €750 - €800 million should be added to the cost of Dublin Airport's planned expansion. It is notable that FCC's Condition 13 requires a financial contribution to the Metro on the grounds that the proposed development will benefit from that Metro. If the proposal will not add to passenger numbers through Dublin Airport it is difficult to see how the Metro can be of benefit to them. The Commission for Aviation Regulation engaged consultants to undertake a Cost Benefit Analysis of Dublin Airport's proposed Capital Programme as part of the regulator's review of airport charges. They confirmed the failure of the DAA to provide the required cost benefit analysis. Including only a capital investment of €950 million the consultants found that the investment would be a net loss of €51 million. With capital expenditure of €1.2 billion assumed, the net loss is €330 million. No estimates were included for land costs and social costs such as road congestion, noise, pollution, health impacts and climate change(18). It is clear that if these costs are assessed, a result similar to UPROAR's loss of €4.5 billion will be found. The CAR's results are preliminary.
No analysis of alternatives was carried out by the DAA. This is a clear breech of the requirements of EIS Directives and other guidelines and statutes that alternatives be evaluated(19). Many of the arguments put by DAA for its expansion plans 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 previous preliminary analysis carried out by UPROAR of a second airport for the Greater Dublin Area applies(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. The full Masterplan for Dublin Airport including a third terminal is estimated at some €2.5 billion. That would be about the cost of a new airport. However, if located on low-cost land such as the cutaway bog proposed by Bórd na Móna, a new airport would not incur the land costs associated with Dublin Airport's expansion that amount to some €3.4 billion and have so far been ignored(21).
The National Development Plan 2007 - 2013 raises concerns about regional balance. It notes that there is: "a continuing imbalance in regional development". It states that: "…a pro-active and focused approach to balanced regional development continues to be necessary. The growth of the Greater Dublin Area (GDA), …has been dramatic in terms of population and economic output. While the economic success of the GDA has made a major contribution to the success of Ireland as a whole, it has also brought challenges, particularly in the area of infrastructure." Continued
unrestrained expansion at Dublin Airport is contrary to the objective
of better regional balance and is most certainly not "pro-active"
in favour of the regions. 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 (22)". 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 ten kilometres 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'.
National Spatial Strategy. 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(23). 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(25). UPROAR believes that national aviation policy is instead being dictated by the Dublin Airport Authority. 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(26). It is foolhardy and premature to approve the expansion plans 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.
No assessment has been made of the impacts of the proposal on climate change. Dublin Airport's expansion plan will bring passenger numbers to 35 million per annum by 2020 and to a full capacity of 60 million by about 2035. This proposal is part of that expansion. Using figures based on Ryanair's fuel consumption per passenger and the findings of The Stern Review(27) we found that the additional cost of the damage done by Dublin Airport's expansion, in terms of global warming, comes to at least €8.4 billion. See Appendix 2, which contains a submission made to the oral hearing into the Terminal 2 proposal on this issue.
The Transportation Department of FCC requested additional information of additional capacity and traffic impacts:
There is no evidence of any reply from the developer in regard to those questions although they were contained and expressly requested in the Planner's Report of 14 December 2006 (page 11). In the (final) Planner's Report of 2 February (page 9) the need for this information seems to have been overruled on the grounds that "increased capacity would be very low/marginal because of the checkout area proposed is simply relocated from its adjoining position in the existing terminal. It is only slightly longer with perhaps an additional 3 check in points." This is a repetition of the type of argument that has been manifest in FCC's decisions on the new parallel runway and Terminal 2, of minimising impacts in the face of clear statements of planning intent that indicate the facilities are required precisely to increase capacity. The traffic concerns are similarly dismissed: " Impact on traffic/parking would not be significant."
As noted, there is no recorded response to the Transport Department's request for information on increased capacity due to the proposal. It is therefore totally unclear what passenger capacity will be added by the proposal. Using multipliers provided by DAA to the Terminal 2 oral hearing and in the DAA's CIP 2005 provided to the Commission for Aviation Regulation, the 7,400 m2 proposed would provide capacity for some 1.2 to 1.4 mppa. This contrasts with information given by DAA CEO, Declan Collier, at the Sustainable Airport Development Conference in October 2006 where he provided data indicating the T1 extension and related developments (Area 14 and Northern Extension) would add some 6 mppa to T1's effective capacity. See the chart in Appendix 1. It is not correct to argue that passenger throughput will not be increased because the proposed development is only an improvement in the facilities for existing passengers. The case for the development is that the present facilities do not provide an adequate level of service to existing passengers. If so, the present situation is an unsustainable one that cannot continue. If that is not so, why are the improvements being proposed? If approval were not given, passenger numbers would have to be contract to a more sustainable level. If this form of argument was accepted by planning authorities, many unsuitable proposals for expanded facilities would be allowed. Developers need only allow overcrowding to accumulate until numbers reach the design level of the proposed expanded facility, and then argue that the additional facilities are required only to accommodate existing numbers. That cannot be sustainable planning. The passenger throughput facilitated must be measured by the capacity of the proposed facility less the capacity of the existing facility at an adequate level of service. The existing throughput at its current substandard level of service cannot be the basis of comparison. The provision of these extra facilities therefore generates the additional passengers that would not have to be displaced if it is built: about 4 mppa and possibly 6 mppa on Mr Collier's evidence. The failure to provide an EIS on the grounds that the development would not materially increase passenger numbers and "would not be likely to have significant effects on the environment" is therefore in breach of the Planning and Development Regulations 2001(28). In its absence, it is impossible to assess the impacts of this development both as regards impacts in its own right and as regards cumulative impacts with the other proposed developments at Dublin Airport such as Terminal 2 and the new parallel runway. This terminal extension is designed to increase passenger capacity by something between 1.2 and 6 mppa and will have the traffic and other impacts associated with that expanded capacity. No assessment has been done by the DAA of impacts on road traffic, and other consequences of additional aircraft movements associated with these additional passengers, such as noise and air pollution. It would be important for the Board to make its own request for additional information on the increased passenger capacity and its impacts, before any decision is made.
In view of the declared water shortage in the Fingal Area, this development threatens the water supply to communities such as Portmarnock(29). On 1 May 2007 Fingal County Council introduced direct water conservation measures. Due to the increased demand on the water supply during the hot weather FCC stated that: "it will not be possible to ensure a constant supply of water to our residents." In the light of its own concerns about our critically balanced water supply, it is highly irresponsible of FCC to have granted planning permission for this development.
Given the requirement 5 of the Water Services Dept of FCC : SW (i) there is no mechanism to dispose of any contaminated surface water runoff from the development. This conflicts with 7 (c) and (e) requirements of the Eastern Regional Fisheries Board to prevent pollution of the receiving waters. In view of the increased surface runoff there appear to be no plans for attenuation in the operational phase. If the development is on a 'brownfield' site attenuation may already take place in conjunction with runoff from the existing terminal facilities. No evidence of either attenuation is provided in the current application. In view of the requirements of the Dublin Airport Local Area Plan SW 4 and 5 this lack of planning for attenuation is a serious deficiency and is unsustainable in planning for the storm water implications of Climate Change.
* This copy of the chart (on paper) was provided to UPROAR by DAA on 19 January 2007. The copy was not of the same chart shown by Mr Collier at the conference. However, according to the DAA, it contains the same information; the only difference being in the title and in the notes on the right hand side.
Appendix
2: Portmarnock Community Association - UPROAR
Dublin Airport's expansion plan will bring passenger numbers to 35 million per annum by 2020 and to a full capacity of 60 million by about 2035. Using figures based on Ryanair's fuel consumption per passenger and the findings of The Stern Review(30) we find that the additional cost of the damage done by this expansion, in terms of global warming, comes to a staggering €8.4 billion, at least. Ryanair claims, with justification, to have clean and modern aircraft. In US fiscal year 2006 (year ending 31 March 2006). Ryanair's 32 million passengers clocked up 30.3 billion kilometres in total, or 940 km per trip. As Ryanair spent €463 million on fuel in the same period at a price of €488 per tonne, it follows that Ryanair planes burned 947,000 tonnes of aviation fuel transporting 32 million passengers, or 29.4 kg of fuel per passenger(31/32). Every kilogram of aviation fuel burned, produces 3.15 kg of CO2. Therefore, every Ryanair passenger produced about 93 kg of CO2 in fiscal 2006. Costing the damage done by global warming and the contribution of CO2 emissions to that damage, Professor Nicholas Stern puts that cost, on average, at about US$85 (now €68(33) ) per tonne of CO2 (Stern Review, page 322). According to Stern, the warming effect (radiative forcing) of aviation is 2 to 4 times greater than the effect of the CO2 emissions alone "because of other gases released by aircraft and their effects at high altitude. For example, water vapour emitted at high altitude often triggers the formation of condensation trails, which tend to warm the earth's surface." (Stern Review: Box 15.6). We use a factor of 2.7, given by George Monbiot(34) that is in the lower half of this range and gives a total global warming damage per tonne of CO2 of about €184. At 93 kg per passenger, this means that every Ryanair passenger does about €17 worth of global warming damage. The other airlines using Dublin Airport have older fleets and less efficient aircraft, on average, so that their passengers, assuming at least the average journey length of 940 km, do at least the same amount of damage per passenger(35). Applied to all Dublin Airport passengers these emission rates and their environmental costs are therefore conservative. It can be deduced that all the 21 million passengers of 2006, emitted at least 1.95 million tonnes of CO2 at a cost of at least €357 million (17*21) in global warming damage terms. As the Ryanair fleet is new, it can be assumed to have a service life of 30-40 years and therefore these emission rates will persist with little improvement for that lifetime. As other airlines are well behind Ryanair, it can be assumed that these rates of emission and their cost are conservative estimates valid for the lifetime of a new fleet for all Dublin Airport passengers. As far as the environmental costs of Dublin Airport's expansion programme is concerned, it follows that when the airport reaches capacity at 60 million passengers, around 2035, its extra 40 million passengers per year will be doing an extra €680 million worth of global warming damage per year. The damage of the extra passengers in each year up to full capacity would be less that this. To add up the damage of all these years it is necessary to discount the figures for future years to allow for the fact that, in a more prosperous future, €1 will have a lower utility value than it does today. Using a set of discount factors provided by the Stern Review (Fig 2A.1) we find that the present value of the stream of climate change damage from now until 2050, due to the expansion plans of Dublin Airport, is at least €8.4 billion. It is worthy of note that the Environmental Protection Agency allocated just over 20,000 tonnes CO2 equivalent for each of the years 2005, 2006 and 2007 to Dublin Airport. This is only one hundredth of the 2 million tonnes of CO2 at least, emitted by Dublin Airport's 21 million passengers in 2006. The anomaly is due to the fact that international aviation is not included in Kyoto protocol. This minimum total climate change cost of €8.4 billion is additional to the €4.5 billion net economic cost UPROAR has estimated for the proposed expansion plan of Dublin Airport. See: www.norunway.com/t2a/appt2.htm. That waste is due to a misuse of very valuable land, the economic cost of road congestion and an estimate of the loss of welfare to communities surrounding Dublin Airport. It can therefore be concluded that the expansion plans of Dublin Airport will incur, at a conservative estimate, a net loss of €13 billion. Matthew
Harley Endnotes (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) See our appeals at: http://www.norunway.com/t2a/bp.htm and http://www.norunway.com/t2a/t2.htm (5) See: http://www.dublinairportauthority.com/Airport_Development/index.html (6) Declan Collier at the Towards Sustainable Airport Development conference, 23/24 October 2006. (7) On 2 May 2007, Portmarnock Community Association - UPROAR objected to An Bord Pleanála to he proposed n of existing runway 11/29. (8) "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 (9)
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: (10)
"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
(12) "Guide to cost-benefit analysis of investment projects", (Structural Fund-ERDF, Cohesion Fund and ISPA), Evaluation Unit, DG Regional Policy, European Commission, 2002. See: http://ec.europa.eu/regional_policy/sources/docgener/guides/cost/guide02_en.pdf (13) http://www.csfinfo.com/htm/evaluation_process/index.htm (14)
See Minister Cowen's speech of 23 January 2007 at: (15) 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. (16) 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: T2 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. (17) 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. (18) See: http://www.aviationreg.ie/Commission_Paper_2007.HTML (19) 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]. (20) See: Chapter 7 of "The Economics of the Proposed Runway" attached. Also available at: www.norunway.com/bp/bp.htm. (21)
See: http://www.finfacts.com/irelandbusinessnews/publish/article_10002693.shtml (22) "Proposing Solutions", Page 3, "Short Term Measures for Improved Public Transport Access to Dublin Airport." (23) See "Use of NSS by runway advocates" in Chapter 8, "National Development Policies" in "The Economics of the Proposed Runway." (24) See "National Aviation Policy and the proposed runway" in Chapter 8, "National Development Policies" in "The Economics of the Proposed Runway." (25) "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 (26) "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. (27)
Nicholas Stern, The Economics of Climate Change - The Stern Review,
Cambridge University Press, available online at (28) Letter from Richard Hamilton, RPS Consulting, dated 6 July 2006. (29)
See: http://www.fingalcoco.ie/YourLocalCouncil/Services/WaterServices/EmergencyInformationandUpdates/ (31) This information was provided by Ryanair in a statement to the US Securities and Exchange Commission on 27 September 2006. See: http://www.ryanair.com/site/about/invest/docs/2006/20Fstatement06.pdf (32) These figures imply 3.13 kg fuel per 100 passenger kilometres and are consistent with the 3.8 litres (3 kg) of fuel per 100 passenger kilometres given on the Ryanair website: http://www.ryanair.com/site/EN/environment.php?pos=ENVIRONMENT (33) The Stern figure is US$85 in 2000 prices. At that time the US dollar and Euro were at about parity. The cost per tonne should therefore be taken as €85 in 2000 prices, which would be equivalent to about €100 in 2007 terms. By using current exchange rates we are understating the cost in current Euro terms. (34) See: http://www.guardian.co.uk/Columnists/Column/0,,1719728,00.html (35) In 2005 Aer Lingus' average journey was 1560 km. Given this longer trip length and older fleet, Aer Lingus passengers are doing much more damage than Ryanair passengers |
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