20060509-Fingal- Dublin Airport

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					Our Ref:       20061121-FCC-1248-AP

The Secretary
An Bord Pleanala
64 Marlborough St
Dublin 1                                                            21 November 2006


REF:           F06A/1248
RE:            Appeal against Decision Notification by Fingal County Council
               for construction of two phase Terminal, pier building and other works
               by Dublin Airport Authority plc

Dear Sir/Madam,

We wish to appeal this decision notification on the following grounds:

1.     Deficient SEA justifying Project

The proposal is part of a larger project to accommodate the expansion of Dublin Airport
which is being put forward without adequate Strategic Environmental Assessment. The
purported SEA attached to the 2006 Local Area Plan does not meet the requirements of
the Directive, in that it fails even to refer to “climate” or “climatic impacts”.


2.     Lack of Integrated Assessment with Concurrent Development

This terminal is part of a larger airport development linked to the new North Runway
proposal under consideration, the direct and indirect effects of which are not addressed in
this Environmental Impact Statement

Dublin Airport currently caters for 19 million passengers per annum. This proposal is part
of an overall project to double that capacity to 38 million by 2025 with a target 30 million
for 2015 to 2016..

We submit that the lodging of consent applications for individual elements of an airport
expansion envisaged to cater for 38 million passengers, by 2025 is premature unless
appropriate assessment is carried out and mitigation measures are put in place with
regard to this expansion, including phased timetabled and targeted link between
passenger number increase and mitigation measures with regard to greenhouse gas
emissions noise, transport generation and ecology.

Apart from applications by Dublin Airport Authority, there are other private sector
proposals for car parking and other developments which need to be addressed.

3.     Inadequate Consideration of Alternatives required by EIA Directive

The EIS fails entirely to address the requirement of alternatives including alternatives
which would reduce the unsustainable need for and demand for air travel, and therefore
the need for the scheme.
4.     Section 18.4.3 of EIS provides Inadequate Assessment of Greenhouse Gas
       Generation

The EIS fails to quantify greenhouse gases generated by the proposed development
which is intended to serve the overall major expansion of the airport of which this project
is part, and therefore generates significant additional Greenhouse gases, both by aviation
generated by use of the terminal, land transport access and the terminal itself.

Greenhouse gases from aviation travel were exempted from the provisions of Kyoto.
However, this does not exempt the requirement to consider the environmental impact of
increased Greenhouse gas generation of any aviation development. The aviation
industry is using the same untenable argument used by consultants for motorway and
dual carriageway projects in Ireland. This is the claim that the Greenhouse gas
generation by road projects designed to cater for significantly enhanced road vehicle
traffic levels, will be mitigated by future fuel efficiency and vehicle emission improvement.
This has in fact not occurred. There is no evidence whatsoever that total aviation
emissions will be reduced if aviation growth continues at current levels.

None of the available scientific evidence validates the claims made by the aviation
industry and indeed including the Tyndall Centre for Climate Change Research and the
European Federation for Transport and Environment. In the absence of specific data in
this area for Ireland, the general trends and conclusions identified in the recently
published Stern Report reinforces concerns about the global impact of aviation emissions.
The EIS is entirely deficient in not proposing mitigation measures for the additional CO₂
emissions from transport demand to serve the proposed additional capacity at Dublin
airport. The EIS does not provide any data on Greenhouse gas generation by
transportation access. Yet these figures should clearly be open to calculation since the
breakdown of staff and passenger access between public transport, private car, taxi and
freight/service vehicle should be obtainable, along with origin and destination data, which
should allow average trip distance to be calculated.

The EIS is entirely deficient in assessing and mitigating energy consumption of the actual
terminal building.

5.     Inadequate Mobility Strategy

In their initial submission on the parallel application for the Northern Runway now being
determined by An Bord Pleanala (PL 06F.217429), the Dublin Transportation Office
stated that, „the corresponding landside transport requirements associated with the
growth in air traffic should be considered in this stage as part of an overall development
strategy for the airport. In particular, a substantial improvement in the level of public
transport accessibility, especially from the Dublin Metropolitan Area is crucial, which
include the development of a number of public transport networks across bus, light rail
and heavy rail modes.’

The DT0 Platform for Change, 2000-2016 has no budgeted or timetabled implementation
strategy. In November, 2005 the Government announced „Transport 21‟ including a
metro to the airport to be in place by 2010. Consultation on route options for this metro
has recently taken place. We submit as a preliminary principle that any consideration of
airport expansion in the absence of a metro proposal implemented within the most
immediate achievable timetable is untenable and should be disregarded.

However, the assumption that the mere building of a metro is sufficient as a solution to
resolve access to an expanding Dublin Airport is also untenable. We submit that the



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metro is only one of a range of measures and must be part of an overall integrated
transportation strategy for the Greater Dublin Area and linked towards enhanced rail
access from the surrounding regions. Dublin Airport is the largest single origin and
destination point in the State and needs an effective, and not just token, Mobility Strategy
to maximise efficient movement for passengers and staff and minimise the use of private
cars and taxis for a combination of reasons, congestion mitigation, efficient use of land
and resources and mitigation of greenhouse gas and air pollution particles.

No proper Mobility Strategy is currently in place to Dublin Airport to achieve these
objectives. The continued policy of the Dublin Airport Authority and previously, Aer
Rianta, has been the progressive accommodation of private car demand through the
uncontrolled accommodation of surface and increasingly multi-level car parks.

The modal split or modal share information now provided in the August 2006 document
“Dublin Airport: Mobility Management Framework Plan” shows the ratio between private
transport which must include taxis, which take up the same amount of road space as
private cars, and public passenger transport.

Even with a metro, the Mobility Strategy proposed (Table 5.3) only seeks to achieve a
30% public transport access ratio by 2012 and 40% by 2020. This is at total variance with
the DTO Platform for Change target of reducing congestion to 1991 levels and making
public transport the predominant means of mobility in the Dublin transport area. This
further places the development as proposed in breach of the Regional Planning
Guidelines for the Greater Dublin Area 2004 which endorse the DTO objectives.

6.      Loss of Corballis House, Protected Structure

This proposal involves the demolition of the charming, late Georgian Corballis House
which forms a landmark in the otherwise architecturally uninspiring approach to the main
airport terminal. Section 57 (10) (b) Planning & Development Act 2000 provides that a
planning authority or on appeal An Bord Pleanala shall not permit the demolition of a
protected structure “save in exceptional circumstances”. Given that the terminal has not
been justified on the basis of the grounds of appeal as stated above, we submit that as a
corollary, that the circumstances warranting the demolition of this protected structure
have accordingly not been demonstrated.


Conclusions

The proposal is based on an irrevocably flawed SEA. The proposal has been put forward
without integrated assessment with other recent, current and future planning applications
to accommodate airport and aviation expansion. The Environmental Impact Statement
provided by the applicant is deficient with regard to Articles 3 and 5 of the Directive with
regard to alternatives the identification of, consideration of and mitigation of adverse
environmental impacts with regard to greenhouse gases, traffic generation and
associated increased aviation.

Yours sincerely


IAN LUMLEY
Heritage Officer

Encl:   Acknowledgement from Fingal County Council



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