An Bord Pleanála

Development: Construct, on airport lands, a runway 3110m in length and 75m in width. The permission sought, to include all associated road works including internal road network, substations, navigational equipment, equipment enclosures, security fencing, drainage, ducting, lighting, services diversions, landscaping and all associated site development works including the demolition of an existing derelict house and associated outbuildings; the relocation of the Forrest Tavern Monument; the removal of a halting site including the demolition of any structure whether temporary or permanent on that site which is currently leased from the applicant. The road works include the realignment of an 800m section of the Forrest Little Road; the rerouting of a 700m section of the Naul Road (R108) and a 200m section of Dunbro Lane and replacement of these latter roads with a new 2km long road (7.5m wide carriageway) running in an east-west direction connecting to the St.Margaret’s ByPass at a new junction. The proposed duration of this permission is 10 years.

The development is located on lands of approx. 261 hectares in the townlands of Millhead, Kingstown, Dunbro, Barberstown, Pickardstown, Forrest Great, Forrest Little, Cloghran, Collinstown, Corballis, Rock and Huntstown north and north west of the airport terminal building. An EIS accompanies the application.

VOLUME 2 – CONSULTANTS’ REPORTS

PL06F.217429 An Bord Pleanala Vol.2

Report on Transportation Aspects

Of

Planning Appeal for New Runway & Associated Works

at

Dublin Airport

Report

by

Jerry Barnes, MRTPI, MIPI, ASCS, MRICS

for

An Bord Pleanála

PL06F.217429 An Bord Pleanala Vol.2

An Bord Pleanála Ref: PL06F.217429

P.A. Reg Ref: F04A/1755

Description: New northern parallel runway at Dublin Airport, including associated roadworks, demolition of existing structures, relocation of halting site, realignment of the Forrest Little Road and a re-routing of the Naul Road (R108) and a section of Dunbro lane.

Address: Dublin Airport, Co. Dublin

Applicant: Dublin Airport Authority Plc

Planning Authority: Fingal County Council

PL06F.217429 Page 1 of 69

CONTENTS

Page

1 INTRODUCTION 31.1 Terms of Reference 31.2 Background Information 3

2 ENVIRONMENTAL IMPACT ASSESSMENT 32.1 Relevant Sections and Guidelines 32.2 Assessment 4

3 POLICY CONSIDERATIONS 113.1 Strategic Ground Transportation Policy 113.2 County and Local Transportation Policy 13

4 METRO ALIGNMENT 16

5 ROADS AND TRAFFIC IMPACTS 175.1 Network Capacity 175.2 Junction Design 195.3 Local Access 205.4 Western Access 215.5 Emergency Access 235.6 Construction Traffic 23

6 PHASING ISSUES 24

7 FIRST PARTY APPEAL AGAINST CONDITIONS 247.1 Condition No.4 – Construction Management 247.2 Condition No.9 – Visibility Screening 247.3 Condition No.25 – Access to Viewing Areas 257.4 Condition Nos.27,28,29 and 33 – Road Issues 257.5 Condition No.27 – Junction Design 257.6 Condition No.29 – Permanent Closure of Roads 267.7 Condition No.31 – Western Access 277.8 Condition No.32- Variable Message Signs 297.9 Condition No.33 – Road Safety Audits 29

8 CONCLUSIONS AND RECOMMENDATIONS 30

1 INTRODUCTION

1.1 Terms of Reference

1.1.1 The Board has requested the undersigned to provide advice in writing

concerning transportation issues relating to the proposed runway and

associated works at Dublin Airport, Co. Dublin (PL06F.217429). In addition,

I attended the oral hearing between the 25th September and 4th October 2006.

I visited the site and surrounding area on the 2nd August and 4th September

2006. This report addresses the following requirements of the brief:

a) Adequacy and robustness of the traffic related information in the EIS,

having regard to the likely significant impacts upon the environment.

b) Report on the traffic and transportation aspects of the application/appeal.

It should be noted that the views expressed relate solely to the issue of

transportation and where there is a conflict with other non-transportation

consideration, then resolution of these issues are matters for the Inspector

and the Board.

1.2 Background Information

1.2.1 Reference shall be made, as appropriate, to relevant policy documents and

the proceedings of the oral hearings. A separate background paper has been

prepared by the undersigned reviewing relevant reports and plans, as

required by the brief.

2 ENVIRONMENTAL IMPACT ASSESSMENT

2.1 Relevant Transportation Sections and Guidelines

2.1.1 Considerations relating to the transportation assessment are contained in

various sections of the EIS and in particular, Section 2 (Alternatives),

Section 3 (Master Plan), Section 4 (Project Description), Section 5

(Construction), Section 7 (Land Use), Section 13 (Road Traffic), Section 14

(Air Quality), Section 19 (Commitments), Appendix E, Addendum

Appendices 13.1, 13.2 and 13.3, Emergency Access Study and Western

Access Study.

2.1.2 In the evaluation of the transportation elements of the submitted EIS, due

regard has been paid to the following:

The nature and extent of the proposal for which development consent is

sought.

Article 94 of the Planning and Development Regulations 2001.

Guidelines on the information to be contained in Environmental Impact

Statements – EPA, 2002.

Advice notes on current practice in the preparation of Environmental

Impact Statements – EPA, 2003 (with particular regard to pages 67-69).

Submissions and observations received in relation to transportation

aspects of the EIS.

2.2 Assessment

Alternatives (Section 2)

2.2.1 The assessment of alternatives included:

increased use of other airports in Ireland;

improved use of existing infrastructure at Dublin Airport;

alternative location for northern parallel runway at Dublin Airport;

provision of a single runway elsewhere in the Greater Dublin Area; and

replacement of Dublin Airport on a new site.

2.2.2 The landside transportation requirements of these alternatives were

considered in an appropriate level of detail and rational landside

transportation reasons were put forward for not pursuing these particular

options.

Master Plan (Section 3)

2.2.3 Section 3 of the EIS provides extracts from the Master Plan, which the

Dublin Airport Authority has prepared for the Airport. It is considered that

this can only be taken as a contextual document, as it has no statutory basis,

does not form part of the subject application for development consent and

there are many elements referred to in it which are not specified in the public

notices. The assumptions relating to mode split of ground transportation, car

parking provision and the role of public transport provide background

information on the approach which the applicant proposes to adopt in the

long term, but owing to the restricted nature of the subject proposal, they

should not necessarily form the basis for the transportation assessment of the

runway proposal and associated works.

Project Description (Section 4)

2.2.4 The project is on lands totalling 261 ha, of which 132 ha is within the

existing airfield.

2.2.5 The specific elements of the proposal are as follows:

New parallel runway 10L/28R totalling 3,110m in length and 60m in

width with 7.5m wide shoulders on either side.

Associated taxiways, including parallel taxiway, which would be 25m in

width with 2.5m wide shoulders.

Associated earthworks.

Road works which would include:

- A realigned section of the Forrest Little Road

- Re-routing of the R108 around the new runway with the provision of

a new link road to the St.Margaret’s Bypass to the south of the new

runway. Realigned roads would consist of 7.3m wide carriageways.

Security fence and perimeter road.

Radio navigational aids and meteorological equipment

Aerodrome lighting.

Runway services.

2.2.6 The description of the road works directly associated with the runway works

could be more detailed, but the public notices do further elaborate on the

nature and extent of these road proposals. The provision of a roundabout at

the junction of the re-routed R108 and St. Margaret’s Bypass, in addition to a

new link road to connect with the R122 to the north, which is outlined in

Appendix 13.2 of the EIS Addendum, is not detailed in the description of the

project. This revised proposal was however the result of an additional

information request by the planning authority and would come within the

general description of road works.

2.2.7 The Portmarnock Community Association, Teresa Kavanagh and the An

Taisce appeals strongly contended that the application should consider the

traffic and transport impacts resulting from the full development of the

Airport, which would infer that the 2nd terminal is also in place. These third

party appeals further contend that the subject assessment is inadequate and

that the development would result in significant traffic congestion on the

surrounding road network and in particular on the M50 and M1. The first

party and the planning authority contend that traffic assessment represents

the ‘worst case scenario’.

2.2.8 Details of runway capacity are not provided in this section of the EIS,

although in Section 1 (Introduction) it is projected under the high growth

scenario that passenger numbers would grow to 43 million per annum by

2025, requiring 348,000 aircraft movements. The clarification of additional

information submitted to the planning authority indicates that, if the second

runway does not proceed, there would be an air traffic capacity constraint

from 2009 onwards based upon the 2003 forecast. It is estimated that this

capacity constraint would lie between 21 and 22 million passengers per

annum (mppa). It is important to note that in the context of the subject

application and associated EIS, there are other factors constraining passenger

growth that are relevant in the subject appeal, not least the need for

additional terminal facilities and landside transportation provision.

2.2.9 The documentation on the appeal files relating to Pier D (06F.107665 and

PL06F.200940) indicates that the terminal capacity of the whole airport,

when Pier D is completed, would be approximately 20mppa. Importantly, the

subject planning application does not relate to additional terminal facilities,

public transport provision, strategic road infrastructure, parking or other

elements required to accommodate additional passenger numbers. These

other associated elements will be the subject of separate statutory planning

procedures and in most cases environmental impact assessments. The direct,

indirect, secondary, cumulative, short, medium and long-term, permanent,

temporary, positive and negative effects of these future developments can

then be assessed. Furthermore, it is noted that the subject application is an

application for full permission for the elements detailed above in 4.1 and not

an outline application for other associated facilities. On the issue of project

splitting raised by the third parties, it is considered that the runway and the

2nd terminal are two distinct projects, each requiring their own EISs rather

than constituting a single split project.

2.2.10 On this central point of the nature and extent of the development, it is

therefore concluded that the transport and traffic impacts are principally

restricted to the impacts arising from the realignment of the immediate road

network and the potential impact upon the Metro line. I accept that the EIS is

confusing in this regard, as it attempts to consider the full impacts of the

Airport development with both the runway and second terminal in place. The

further information sought by the planning authority on the 10th February

2005, requiring a full traffic impact assessment with/without rail merely

served to reinforce this excessive assessment of the subject development.

However, the excessive assessment of these transport impacts of the

development does render not the EIS inadequate.

2.2.11 The first and second parties’ contention that the assessment undertaken

represents a ‘worst case scenario’ for development is not necessarily

accepted. This broader assessment constitutes an appraisal of the subject

development plus other development which is not the subject of this appeal.

The adequacy of this broader assessment is therefore not a matter to be

considered by the Board at this stage.

Construction (Section 5)

2.2.12 Many of the construction traffic impacts are considered under this Section. It

is indicated that there would be a total of 46,000 HGV traffic deliveries to

the site during the course of this project. Appropriate mitigating measures are

proposed in Section 5.4.

Land Use (Section 7)

2.2.13 This section provides a review of existing planning permissions and the

statutory planning context. While it would be useful from a transportation

perspective if a schedule of all permissions and main conditions pertaining to

the surface car parks was provided, it is not essential in assessing the likely

significant effects of the runway upon the environment.

2.2.14 The EIS has taken into account proposed development in the adjoining area,

particularly in the South Fingal development area.

2.2.15 Paragraph 7.4.2.21 to 7.4.2.25 of this section relates to traffic and

transportation and the likely effects upon adjoining land-uses and in

particular the localised and indirect impacts upon journey lengths for certain

houses and uses as a result of the re-routing of certain elements of the road

network. This provides a reasonable assessment of these impacts.

Section 13 (Road Traffic)

Traffic Modelling Methodology

2.2.16 The EIS documentation provides a detailed traffic modelling exercise,

assessing the impacts of the utilisation of the runway in the opening year of

2010 and the design year of 2025. Sensitivity tests were undertaken with

Metro in place, for a new western approach road and for a major incident on

the M1. The methodology adopted involved utilising the 2001 DTO Traffic

model from which a cordon matrix was extracted and the model was then

updated to create a 2004 base year. The full inter-modal DTO model was not

used and the assessment considers the full development of the Airport with

an underlying assumption that there are no terminal facilities or parking

constraints. Traffic projections are based upon future estimated passenger

numbers, cargo generated HGV traffic and number of employees. The role of

other public transport elements, including bus services or LUAS, or

provision for taxis, cycling and walking has not been made explicit. It is

therefore solely a road traffic impact assessment, assessing the impact on

junctions and links. The assessment of Metro’s role in serving the airport is

only in the context of how it will relieve congestion on the local road

network.

2.2.17 For the full development of the Airport, there are a number of deficiencies in

the modelling exercise, which include:

- inter modal model not used

- the calibrated and validated 2004 DTO model not used

- it appears as though public transport, other than Metro, was not fully

modelled

- there is uncertainty over whether planned road infrastructure was

properly incorporated into the modelling exercise

2.2.18 However, given the restricted nature of the proposal that is the subject of

current application, such inadequacies are irrelevant when considering the

likely significant transport effects of the proposal.

Likely Significant Effects

2.2.19 The direct effects of the proposal will relate to the realigned road network in

the vicinity of the proposed runway and the associated construction access

impacts. Appendix 13.1 of the EIS Addendum provides a junction capacity

analysis of 9 existing junctions in the vicinity of the Airport for the 2010

opening year. It is based upon the assumption that there are no terminal

facility or other constraints and in this regard the points raised under 2.2.10

should be noted. Appendix 13.2 of the EIS Addendum provides further

details and a junction assessment of the re-routed R108 and the realigned

Forrest Little Road. The analysis of the St. Margaret’s Bypass / new R108

junction resulted in a proposal for a new roundabout and link road continuing

to the north. While the EIS does not appear to directly assess the closure of

the R108 link, traffic volumes are light and as such it is not a significant

omission.

2.2.20 The EIS also proposed the upgrading of:

Swords Road/North Corballis Road roundabout

Swords Road/South Corballis Road signalised junction.

These however lie outside the site and the control of the applicant and the

applicant is reliant upon the relevant roads authority to undertake these

works. Indirect effects, such as longer journey distances for some business

occupiers and residents, are also considered.

Construction Impacts

2.2.21 Section 13.7 provides a detailed and robust assessment of the temporary

impacts of construction traffic, particularly in terms of local access

arrangements. Three alternative routes are identified for construction access:

Route A - M50/R108/R122

Route B – N2/R121/R122

Route C – N2/Minor Road/R122

While the source of materials required for construction, or the location of soil

deposition, are not provided it would be unreasonable to have this level of

detail as it is probably dependent upon construction contracts not yet entered

into on the part of the developer. The broad appraisal is considered

acceptable.

Air Quality (Section 14)

2.2.22 Traffic impacts are taken into account in the air quality assessment.

Assumptions in relation to dispersal of road transport generated pollutants

are made. These pollutants are NO2, hydrocarbons such as benzene, carbon

monoxide, suspended particulate matter, sulphur dioxide and airborne lead.

No explicit air quality modelling exercise of traffic impacts was undertaken,

but given the nature of what is proposed, this approach is considered to be

acceptable.

Commitments (Section 19)

2.2.23 This section provides a schedule of commitments or mitigating measures that

are proposed for the project. There are no specific mitigating measures for

road transport outlined in this section. There are however transport related

mitigating measures proposed elsewhere in the document, e.g. junction

improvements, measures for construction traffic, etc. These have been

reflected in the planning authority’s decision and are considered adequate to

mitigate the adverse impacts of the development.

Interaction of foregoing

2.2.24 Given the nature of my brief, the interaction of the various impacts is a

matter for the inspector and the Board.

Conclusions

2.2.25 It is considered that the EIS and Addendum, in so far as it relates to

transportation issues, can reasonably be regarded as complying with Article

94 of the Planning and Development Regulations and the provisions of the

1985 EIA Directive, as amended.

3 POLICY CONTEXT

3.1 Strategic Ground Transportation Policy

3.1.1 While having due regard to the restricted impacts of the subject development,

given the issues that were raised in the appeal submissions and at the oral

hearing, a commentary on strategic issues is appropriate.

3.1.2 The Regional Planning Guidelines for the Greater Dublin Area (RPG)

makes specific provision for an additional runway at Dublin Airport. While

the National Spatial Strategy (NSS) does not specifically mention the

provision of a second runway, it does acknowledge that the expansion of the

services at Dublin Airport is critical in underpinning Ireland’s future

international competitiveness. With the expansion of the Airport, the need to

upgrade the landside ground transport system is recognised by the NSS, the

current Government’s programme and the RPG for the Dublin Area.

Enhancement of ground access will ultimately be achieved through the

provision of the integrated public transport network proposed by the DTO in

the Platform for Change and the implementation of the national roads

programme outlined in the National Development Plan (NDP). The RPGs,

however, emphasise the need to place public transport at the centre of the

Airport development strategy (page 143) and to promote demand

management measures to reduce reliance on the private car

(Recommendation 8.1).

3.1.3 The An Taisce appeal contends that development of the Airport and this

current proposal is contrary to the provisions of the National Climate Change

Strategy, the Sustainable Development Strategy and the NSS, particularly

having regard to its over-reliance on private car and associated parking

provision. In addition, the Platform for Change Strategy advocates a mode

split of 63% in favour of public transport for the year 2016. The contention

that the Airport has developed in an unsustainable manner, with an over-

reliance on the private car is a debatable point. The DAA Mobility

Management Framework Plan, August 2006 illustrates that the current mode

split in favour of public transport for passengers accessing the Dublin Airport

is 24%. This compares with 39% for Stansted, 36% for Heathrow, 32% for

Gatwick, 20% for Edinburgh, 11% for Glasgow, Birmingham and Newcastle

and only 9% for Manchester. No comparable figures are given for

continental airports. A total 16% of employees access the Airport by public

transport, which is comparable to the aforementioned British cities, although

Frankfurt, Amsterdam and Paris CDG have 23%, 21% and 20% public

transport mode share respectively. The An Taisce contention, that as the

Airport will not achieve the DTO target for the city of 63% public transport

mode share the proposal is contrary to policy, does not necessarily hold true,

as the DTO’s mode split is a target/outcome rather than a policy. The

introduction of Metro in 2012 would, it is estimated in the DAA’s mobility

management plan, increase the public transport mode share to 30% initially

and 40% by 2020.

3.1.4 Transportation outcomes highlight by the third parties, such a whole journey

times, accessibility and mode split are useful in assessing the sustainability of

a development. Undoubtedly, the failure to implement much enhanced public

transport, and in particular Metro and improved city and regional bus

services, is likely to result in an unsustainable pattern of airport development.

This could be argued would be contrary to broader strategic policies aimed at

reducing reliance on the private car and ensuring a fast, safe and efficient

integrated transportation system. However, none of the strategic policy

documents cited indicate a phasing for the development of the Airport in

terms of when precisely runways, terminal capacity, road upgrading and

public transport should be provided. While there is a clear mutual

relationship between effective runway and terminal capacity, as one cannot

expand without the other, the association with external landside

transportation systems is less clear. While there is the potential for an over-

reliance on private car access with potential for traffic congestion in the

vicinity of the Airport, it is noted that the RPA has recently announced the

preferred route and timetable for Metro North. The sustainable development

of the Airport will ultimately require careful co-ordination of all the relevant

agencies, including the DAA, the Department of Transport, the RPA, the

NRA, Fingal County Council and the relevant transport planning authority

for the Greater Dublin Area. The appropriate ground transportation

requirements to serve the needs of the second terminal are not however

immediate matters for this appeal. The important consideration in this

application is to ensure that anything proposed does not prejudice the

effective provision of other critical ground transportation elements.

3.2 County and Local Transportation Policy

3.2.1 The Fingal County Development Plan, 2005-2011 (CDP) also makes specific

provision for an additional runway at Dublin Airport, reflecting the RPGs.

The CDP outlines a comprehensive roads programme and Objective T01

includes the following road objectives serving the Airport:

14. N1 Junction Improvements

16. Forest Road Improvement Scheme

31. New Distributor Road to Baldoyle Station

33. Harristown Distributor Road

34. N2 (Cherryhound) to Harristown Distributor Road

35. St. Margarets Road (Ballymun) Improvement Measures

36. Ballymun Interchange to Harristown Road

48. N2-N3 Church Road Tyrellstown-Rathoath Road (N2 link)

49. N2-N3 Link Ballycoolin Road to Cherryhound (N2)

50. N2-N3 Link Church Road Tyrellstown to Damastown

56. M50 Upgrade

57. M2 Motorway

The one scheme directly affected by the proposed development is No.16,

which is the Forest Road scheme and this intersects with the proposed Forest

Little Road realignment. Even this Forest Road objective on the applicable

Map No.SW3 appears to terminate to the north of the said intersection. There

are consequently no statutory development plan objective issues arising from

the proposed realignment of the Forest Little Road at this point.

3.2.2 Policy TP7 seeks to preserve public transport alignments and TP12 promotes

the development of Metro from the city centre to the Airport and Swords.

Objective T06 protects the preferred route identified by the RPA. The Metro

alignment through the Airport is illustrated on Map SF2. The issue of this

alignment will be considered in further detail below under section 4. Other

issues relating to parking policy and the provision of park and ride were

raised by the An Taisce appeal, but parking policy, demand and supply are

not matters to be addressed under this application.

3.2.3 The Dublin Airport Local Area Plan (LAP) was adopted as a statutory plan

in August 2006. It provides a comprehensive framework for the development

of the Airport and surrounding lands. A full summary of its relevant

transportation provisions is outlined in the summary of plans and documents

accompanying this report.

3.2.4 One of the issues raised by the undersigned and by the St.Margaret’s

Residents’ Association at the hearing related to the status of part of the road

network proposed in the LAP. This statutory local area plan has been

prepared pursuant to a commitment in the CDP to draft such a plan for the

lands that are zoned DA. Section 2.1 of the LAP states that the plan area

“..extends from the Northern Diversion Road and Forrest Little Road in the

north to the Airport Perimeter Road to the south. The site extends in an east

west direction from the M1 to the east as far as St.Margaret’s by-pass to the

west”. Map No.1 of the LAP outlines this area reflecting the DA zoning in

the CDP. It is proposed to provide a dual carriageway road around the

complex and objective EA6 is “To realign and improve and upgrade the

road network surrounding the Airport in the form of an Airport Box to dual

carriageway standard. The roads proposed for this upgrading are the R132,

Collinstown Lane, the R108, the Forrest Little Road, the North Parallel Road

and the St.Margaret’s Road.” Objective IA5 is to provide a corridor for the

construction of a distributor road through the DAA lands to connect with the

N2. Map No.2 illustrates the road network. Those parts of the road network

illustrated on Map No.2, which are not contained in the County Development

Plan are:

- Forest Little Road upgrade

- The north western corner of the box (forming part of the western

access)

- Proposed western by-pass to Swords

- The onward extension of the Harristown Distributor Road to the east

of the M1.

3.2.5 With the exception of the Forest Little Road upgrade, all of these roads

appear to fall outside the area of the DA zoning and the local plan area

described in Section 2.1 of the LAP. There is a CDP objective to provide a

link between the Cherryhound interchange on the N2 and a point to the west

of St.Margaret’s, with a connection from there to the R122 to the south. The

alignment illustrated on Map No.2 of the LAP appears to be materially

different from that outlined in the CDP as it lies approximately 300m to the

north of it.

3.2.6 The planning authority in its closing submission (BY) correctly highlights

that under s 18(1) of the 2000 Act, a planning authority may prepare a local

area plan for any particular area within its functional area. It therefore does

not have to be restricted to the area zoned as DA in the CDP. However, there

is uncertainty over what are the boundaries of the LAP, as parts of the

proposed road network lie outside the area described in Section 2.1 of the

plan and that outlined in red on Map No.1. In addition, s.19(2) of the 2000

Act states that any LAP should be consistent with the CDP.

3.2.7 The above considerations only affect the current proposal in so far as it is

reasonable for the planning authority to make reservations for this road

network pursuant to conditions. This matter will be further considered below

in the assessment of appeals against conditions.

4 METRO ALIGNMENT

4.1 The alignment of the Metro, as illustrated in the CDP, passes under part of

the apron and the end safety zone at the eastern end of the proposed runway.

However, the RPA’s most recent publication appears to align the preferred

route approximately 100m to the east of the CDP alignment. Irrespective of

this, both the CDP and RPA alignment indicate that Metro would pass under

the 240m long runway end safety area (RESA). Mr. O’Connor of the RPA

confirmed to the hearing that it was not yet established whether the tunnel

would be cut and cover or bored at this point. If a cut and cover tunnel was to

be provided after the construction and commissioning of the runway, it

would inevitably require the closure of the runway for a period. Given that

the Metro alignment through this part of the Airport has changed over the

last 12 months, it is possible that its precise alignment will change again.

Ideally, if this section of the tunnel were cut and cover, it should be

constructed as part of the subject proposal. If it is a bored tunnel then it may

not be such a significant issue. It is of concern that this issue was neither

addressed by the applicant in the application, or by the planning authority in

its assessment of the proposal, particularly as it is a specific CDP objective to

preserve the alignment (objective TO6).

4.2 This raises the question of how the alignment can now be preserved in the

light the recent RPA and Government decision to progress this project. In

any event, there are no plans from the RPA of an appropriate scale before the

Board illustrating the precise alignment and as yet there are no engineering

details available. It would however be appropriate for a condition requiring

the lands to be made available for this part of the Metro tunnel when required

and that the applicant should liaise closely with the RPA regarding its

requirements. The issue of making lands available, rather than ceding them,

is considered below in relation the Western Access route. The project

management and phasing of the runway and Metro will have to be flexible

having due regard to any grant of planning permission for the subject

development, its construction, the confirmation of any rail order for Metro

and its provision through the Airport complex.

5 ROADS AND TRAFFIC

5.1 Network Capacity

5.1.1 Mr. Kelly on behalf of the Portmarnock Community Association strongly

contended at the hearing that the development would result in serious traffic

congestion on the surrounding road network, notwithstanding the proposed

improvements detailed in Table 6.1 of the CDP. It was also argued that the

development was premature pending the upgrading the road network and

provision of Metro. However, this appellant suggests that in the event of a

grant of permission conditions should be attached ensuring that there is no

increase in passenger numbers until the transport network has been upgraded

and that passenger numbers in the long term should be restricted to 30 mppa.

Mr. Kelly referred to a Fingal County Council Transportation Department

Report (submission F-H) relating to the development of the Airport ,which

concluded that by 2016 significant congestion would occur on all key links in

the study area, and the M50 in particular. A further study entitle Metro

North – A link to the future which was prepared Fingal County Council, the

DAA and the RPA suggests that access from the M1 is already under stress.

However, much of the transport case presented by the third parties is

predicated on the assumption that the full transport impacts of both the

runway and the second terminal should be considered in full at this stage. As

already highlighted above, as the second terminal is required to realise the

potential of passenger throughput, the capacity of the national road network

in the vicinity of the Airport is not a matter that should be considered in the

context of this appeal. The impact that IKEA would have on the network was

also raised, but this is not a matter for consideration under the current appeal.

5.1.2 An assessment was undertaken by ILTP on behalf of the planning authority

as part of the assessment of the planning application. Closure of the R108

will change the travel flows on Forrest Little Road, the R108 and the R122.

The effects on these parts of the road network have not been assessed in the

EIS. In the AM peak there will be a rise of approximately 14% northbound

and 27% southbound trips, while the PM peak sees a 6% northbound and 7%

southbound increase in trips along the R122 and Forrest Little Road. It

indicates that the realigned road network resulting from the proposed

development (the realignment of the Forest Little Road and the re-routing of

the R108) would have adequate capacity to cater for additional traffic

generated during the construction period and for the reassigned traffic flows.

5.1.3 These conclusions are reasonable in the light of the current free-flow of

traffic along the Forest Little Road, St. Margaret’s Bypass and the R108,

although there may need to be refining of the junction design. This is

considered below in further detail. It is not considered that there is any

requirement to restrict the number of passengers passing through the Airport

pending the upgrading the transportation network or to restrict the absolute

numbers to 30mppa in the long term. These are matters that should be

addressed under the 2nd terminal application.

5.1.4 There is likely to be an increase in cargo related HGV traffic, although it will

remain as a small percentage of the overall road traffic accessing the Airport

in the peak periods and is unlikely to have any adverse impacts upon traffic

flows in the vicinity.

5.1.5 It is also noted that both the DTO and the NRA, who are statutory consultees,

had no objections to the proposed development.

5.2 Junction Design

5.2.1 The EIS and further information proposed new or altered junctions at the

following locations:

New roundabout at the junction of re-routed R108 and the St.Margaret’s

Bypass (R122).

New junction arrangement at the Forest Little Road and Forest Road,

involving the relocation of the junction 13m in a northerly direction.

Upgrading of the Swords Road R132 / North Corballis Road (main

Airport access) roundabout.

Upgrading Swords Road R132 / South Corballis Road signalised

junction.

5.2.2 An assessment by ILTP for the planning authority using Paramics Model of

the proposed roundabout at the junction of the realigned R108 and the R122

was undertaken. The ratio flow capacity (RFC) of the different arms of the

R108/R122 roundabout was between 0.5% and 66% in the AM peak, which

is within capacity of 90%. It is however possible that with additional traffic

growth the junction could fail within 4 – 7 years and therefore a revised

junction arrangement is recommended. Submission L by Mr. Christy

O’Sullivan of ILTP to the oral hearing on behalf of the planning authority

indicates that a signalised junction may be the most appropriate arrangement

at this point, but further detailed design is required.

5.2.3 The upgrading of the Forest Road / Forest Little Road junction will enhance

capacity, but again Mr. O’Sullivan’s evidence to hearing suggests that a

signal controlled junction may be more appropriate at this location.

5.2.4 The planning authority considers that the upgrading of the eastern access

points to the Airport at R132 / North Corballis Road (main Airport access)

roundabout and R132 / South Corballis Road signalised junction is not

necessary. This is reasonable given the restricted impacts of the subject

proposal. The omission of these upgrades by condition no.30 of the decision

is therefore considered to be appropriate.

5.2.5 A matter that requires clarification is the status of the proposed link road to

the north-west of the proposed junction on the St.Margaret’s Bypass, which

is proposed under the further information submitted to planning authority on

the 09/08/06 and illustrated on Figure No.2 of the Scott Wilson Highway

Works Report. The decision issued by the planning authority does not

indicated if this spur is acceptable or not. Mr. O’Sullivan confirmed to the

hearing that this was acceptable to the planning authority and the Board

could require it by way of expressed condition, if it was considered

necessary. In the interests of clarity a condition should be appended to any

grant specifying that this spur road should be provided.

5.2.6 The issue of junction and detailed road design is further addressed in the first

appeal against condition nos.27 and 28.

5.3 Local Access

5.3.1 The St. Margaret’s Concerned Residents’ Group appeal highlights that travel

distances will be significantly increased for those accessing residences,

businesses and the Boot Inn at Huntstown, owing to the re-routing of the

R108 around the proposed runway. This is undoubtedly a significant impact

for those living and working in this area, and there are no apparent mitigating

measures that could overcome this problem. Those residences on Dunbroe

Lane will not however be adversely impacted in the manner suggested, as

there will only be a minor realignment at its northern end.

5.3.2 Mr. Thomas Murphy of M/S Ground Support Services, which is a company

providing airport ground equipment located immediately to the north of the

Boot Inn, has appealed on grounds that the proposal would increase travel

distance from the main Airport complex to its premise by 5km. At the oral

hearing it was requested that Board append a condition to any grant of

permission allowing access by this company to the service road within the

Airport complex. It is suggested that there is an access point through the

boundary perimeter fence 500m to the south of the appellant’s premises. The

first party has rejected this proposal on security grounds and the fact that

there is no security access point at the location indicated. Furthermore, as this

service road follows the perimeter boundary of the Airport complex, access

to it will not reduce journey distances.

5.4 Western Access

5.4.1 The Western Access to the Airport would be provided principally via the

Cherryhound Interchange off the upgraded N2. The link between the N2 and

a new western bypass of St.Margaret’s constituting the western side of the

Airport road box, varies between CDP and the LAP. It is evident that a

Western Access to the Airport will be required to facilitate the further

significant development of the complex, as access via the M1 and the old

Swords Road (R132) will be constrained in such a scenario. Map No.2 of the

LAP shows a link from the Airport Box to a possible third terminal on the

western part of the campus between the runways. The nature of this link is

somewhat unclear, as it is in the form of an arrow and its alignment is most

likely to be determined by the layout of a third terminal facility in this

location.

5.4.2 The Western Access in the context of this appeal was taken as representing

the northern side of the Airport road box with the realignment of the Forest

Little Road. This would ultimately be designed and constructed to a dual

carriageway standard. The St. Margaret’s Concerned Residents’ Group

interpret that a dual carriageway is proposed under the existing application.

However, the provision of a dual carriageway and associated road works

would be the subject of a separate statutory procedure. Under the current

proposal only a single carriageway for the realigned section of the Forest

Little Road would be constructed. These realignment works on the Forest

Little Road are where it intersects with the Forest Road and it follows the

line of the northern section of the Airport box at this point, as illustrated on

Map No.2 of the LAP. All of these works are on lands falling under the

control of the applicant. Further information, submitted to the planning

authority on the 9th August 2005 provides details of a reservation made for

the dual carriageway within the area under the control of the DAA, as

outlined in red and blue on the application drawings. This reservation

broadly follows the alignment illustrated on Map No.2 of the LAP and also

allows for an independent connection into the Airport complex on a new

route parallel to the R132. The aforementioned further information indicates

that the subject proposal does not prejudice the provision of this dual

carriageway. Where physical re-alignment of the Forest Little Road does

occur under the subject application at the junction with the Forest Road, a

reservation of 35m is illustrated in the further information report adjacent to

realigned road. This would appear to represent a reservation for a dual

carriageway that is additional to the realigned section of the Forest Little

Road. While it may be somewhat wasteful to construct a realigned section,

merely for a completely new section of dual carriageway to make it

redundant, there is the possibility that a further carriageway could be added

to this new section, thereby reducing construction costs and impacts. The

design of the dual carriageway has yet to be undertaken by the roads

authority, but the critical consideration in the assessment of the current

proposal and its relationship with a new dual carriageway along the northern

perimeter of the Airport is that it does not prejudice its provision. It is

considered that the subject application does not prejudice its provision.

5.4.3 The further information submitted to the planning authority in relation to the

Western Access indicates that future alignment at the western end of the

reservation has yet to be determined. Given the issues raised in section 2

above relating to the status of road proposals in this area, a condition

specifying its precise alignment at the western end of the DAA lands is not

justified.

5.4.4 The Forest Little Golf Club appeal objects to the realignment of the Forest

Little Road, as it will result in the loss of its practice grounds. It contends

that these grounds would have to be accommodated elsewhere within its

lands, although this is not possible, as 4.78 ha of its holding has been rezoned

for residential use. The realignment, which is on lands controlled by the

applicant, is now wholly in accordance with the provisions of the LAP. It is

noted that the remainder of the course would remain operational and the

management of its overall landholding is a matter for the Golf Club to

consider.

5.4.5 The Western Access is further considered below in relation to the first party

appeal against condition no.31.

5.5 Emergency Access

5.5.1 A full report on emergency access provision was submitted under a further

information response to the planning authority on the 9th August 2005

Alternative access arrangements to the Airport in the event of an emergency

on the M1 or M50 are outlined. The main access points to the Airport are

from the east. In the event of a closure of the M50 between junctions 3 and 4,

traffic approaching the Airport from the west along the M50 can exit the

M50 at junction 4 and access the Airport via the R108 and R132. In the event

of a closure of the M50 between junctions 4 and 5 traffic accessing the

Airport from the west could use the N2, county road network and the R108.

A new western access would make this route much easier.

5.5.2 If the M1 is closed north of the Airport interchange, access can be secured

via the Donabate Interchange and the R132 and if it is closed to the south of

this interchange the Swords Road (R132) can be used. VMS signage can be

used to manage diverted traffic. The provisions for emergency access are

therefore considered to be reasonable.

5.6 Construction Traffic

5.6.1 Three alternative construction access routes are indicated in the EIS. The

planning authority deems route B to be unacceptable, presumably on the

basis of the standard of the R121/R122 and the number of residences along

it. It has been omitted by way of condition (no.24 a)) which is considered

appropriate. Mr. Christy O’Sullivan’s evidence to the hearing (submission L)

indicated that a further route could be considered, which would utilise the

R108 via Huntstown and the Boot Inn. With the exception of Route B, those

routes indicated in the EIS are accessed via the N2 and M50 and avoid any

concentrations of residences.

6 PHASING ISSUES

6.1 There are a number of issues arising from the phasing of development.

Firstly, the first party’s closing submission to the hearing considers that a 10

year permission is justified given the size of the project and the need to

integrate it with the phasing of other projects such as Metro and the Airport

box. While the air traffic forecasts indicate that the runway would be

required well before the expiry of a ten year permission in 2016, if in the

event that it is delayed, a longer permission would allow for closer co-

ordinate with ground transportation infrastructure.

6.2 Mr. Pat O’Callaghan in his submission (K) to the oral hearing indicated that

all of the existing road network would have to be maintained during the

construction of the realigned roads. Condition no.29 addresses this issued,

but a revised wording is required.

7 FIRST PARTY APPEAL AGAINST CONDITIONS

7.1 Condition no.4 – Construction Management

7.1.1 The appeal contends that this condition, relating to prevention of mud, dust,

etc., on the public highway is a duplication of condition no.24 and should be

deleted. Parts g) and h) of condition no.24 do duplicate condition no.4 and

the two conditions should therefore be combined.

7.2 Condition no.9 – Visibility Screening

7.2.1 The developer argues that there is overlap between condition no.9, requiring

details of the design of the perimeter fence and condition no.26 which

requires certain road safety consideration to be included within the design.

There does indeed appear to be unnecessary overlap between the two

conditions, as the planning authority still has to approve the details of the

fence and can determine the nature of the design at that stage. Both

conditions should be combined as one.

7.3 Condition no.25 – Access to Viewing Areas

7.3.1 This condition relates to all viewing areas. The applicant wishes it to be

clarified so that it relates to viewing areas affected by the proposed

development. The planning authority agrees with this amendment. The

condition should therefore be accordingly amended.

7.4 Condition nos.27,28,29, 33 - Road Issues

7.4.1 It is submitted in the appeal that there is a lack of co-ordination between

condition nos.27,28,29 and 33 and that some rationalisation is required. It is

also argued that the development of the Western Access, an alignment of

which is reserved under condition no.31, could also impact upon the design

of roads that are an integral part of the subject proposal. A measure of

flexibility is considered appropriate by the first party to ensure that there is

not a waste in resources in road design or construction. The planning

authority contends that each condition serves a different purpose. However, it

is considered that there is a degree of overlap and nos.27 and 28 should be

combined.

7.5 Condition no.27 – Junction Design

7.5.1 Part a) of this condition allows for the consideration of alternative junction

designs at the Forest Little Road/Forest Road. The appellants submit that two

junction types proposed in the application are the ones that should be

incorporated into the permission. The costs associated with any other designs

should be offset against development contributions. Mr. O’Sullivan in his

evidence indicated that if a ten year permission is issued traffic conditions

may be different at the end of that period, thereby requiring a different type

of design. The condition is considered reasonable, as it allows for flexibility

in the detailed design of the junctions taking account of prevailing traffic

levels, particularly in the event that the junctions are provided at the end of

the permission period.

7.5.2 Part b) relates to a possible revised junction design at the Castlemoate

Road/Forest Little Road intersection. Castlemoate Road runs parallel to the

Swords Road (R132) and provides access to the hanger area of the Airport

complex. The first party contends that this is not affected by the realignment

of the Forest Little Road. Mr. O’Sullivan in his evidence to the hearing

indicated that this junction may be affected by increased traffic flows or a

redesigned perimeter fence. Mr. O’Sullivan in his proof of evidence

(submission L) also requested the deletion of the final sentence and

replacement with “for compliance prior to works”. The subject junction is

over 500m from the realigned section of the Forest Little Road and the

evidence submitted does not support the contention that it could be adversely

affected. Any proposed perimeter fence at this junction should be

appropriately set back to avoid any infringements of sightlines. It is

recommended that this part of the condition be deleted.

7.5.3 Part c) relates to the new junction at the western end of the runway and is

similar in content to part a). The same considerations therefore apply.

7.5.4 Part d) states that “Prior to the commencement of runway construction, all

associated road works including new junctions and the R108 road

realignments shall be in place”. The first party is concerned that this would

have serious implications for its construction programme. The intention is to

carry out road works at the beginning of the contract and if the Board is

minded to append such a condition, it is suggested that ‘runway construction’

be clarified to mean a point in the programme where aircraft pavement

materials need to be delivered to the site. The planning authority has

accepted that this part of the condition can be deleted. Omission of this part

is considered acceptable and the issues of phasing and the provision of re-

routed roads in advance of the closure of existing roads are dealt with under

condition no.29.

7.6 Condition no.29 – Permanent Closure of Roads

7.6.1 This condition requires that all statutory road closures be in place and the

Naul Road (R108), Dunbro Lane and Barberstown Lane be closed before the

commencement of construction of the runway. The first party highlights that

this could be interpreted as meaning that the relevant roads would be closed

before replacement ones are in place. The planning authority accepts that this

is not the intention of the condition. Mr. O’Sullivan in his submission to the

hearing suggests the following wording:

“All necessary agreements to extinguish rights of way shall be in place

before commencement of runway construction. No stopping off of access

shall be allowed until the proposed alternative routes are in place.”

Extinguishing public rights of way is a reserved function under s.72 of the

Roads Act. It is considered necessary to insert an additional clause in this

condition specifying that the extinguishment of these rights of way should

not be enforced until after the alternative routes are in place.

7.7 Condition no.31 – Western Access

7.7.1 This condition requires that a 35m wide reservation be made where possible

for the Western Access along the northern edge of the DAA’s lands and that

this reservation should be extended to the western edge of the applicant’s

lands. The final alignment should be agreed with Fingal Council Transport

Department, the area of land between the road and the reservation should be

kept free of development and the land should be made available when

required for the construction of the road. The first party appeal highlights the

following:

a) Flexibility should be introduced for the case where the Western Access

is constructed before or at the same time as the runway.

b) There are no developed proposals for the road and this introduces

uncertainty over how this condition should be interpreted and applied.

The onward link to the N2 is undefined and it is unreasonable to agree

the details of the corridor due to this uncertainty.

c) The value of the land required should be off-set against any

contributions levied on the development.

Mr. Hamilton, acting for the first party, in his submission (R) to the hearing

suggested the following wording:

“The applicant shall consult and liaise with Fingal County Council

Transport Department to facilitate the planning, design and implementation

of the proposed western access road indicated in the Airport Local Area

Plan.”

7.7.2 Mr. O’Sullivan in his submission to the hearing suggests that the planning

authority has no problem with the construction of the Western Access in

conjunction with the proposed runway. The DAA should satisfy the planning

authority that the airport operations would not prejudice the provision of the

Western Access. He also emphasised that IA5 of the LAP sought to provide

for a corridor for the construction of a northern distributor road through DAA

lands to connect the N2 to the R132, although the alignments in the plan are

indicative.

7.7.3 In general I find this condition to be unsatisfactory. Firstly, the planning

authority is uncertain over the alignment of the Western Access. The

alignment should be derived from the provisions of the LAP and should not

necessarily be included in a planning permission. Furthermore, the Scott

Wilson Report submitted as further information to the planning authority

indicates a deviation from the alignment illustrated in Map no.2 of the LAP,

particularly at its eastern end. The principal purpose of placing road

objectives in development plans, or local area plans, is to provide certainty in

the development process. The precise role of the specific reservation in the

condition is unclear, as any development, which is not exempt development,

would require planning permission from the planning authority, who could

then determine whether any such proposal would impinge upon, or prejudice

the alignment of the Western Access. There seems to be little point in

reserving an alignment that the planning authority is unsure of.

7.7.4 The matter of whether the proposed runway would prejudice the provision of

the Western Access is a matter to be determined at this stage under the

subject application and should not be deferred until some later assessment

prepared pursuant to a condition. From the evidence submitted in relation to

the appeal, it is considered that the runway would not prejudice the provision

of the Western Access.

7.7.5 The planning authority submitted a further revision to the condition at the

hearing (submission AH) and confirmed that it is not the intention that the

lands required for the road should be ceded free of charge, but merely that

they would be made available when required. The offset of the value of the

lands against contributions is not possible, as the Western Access is not

included in the current s.48 contribution scheme. The hearing also heard that

the term “to make available” related to the making available of the land

without a requirement for use of compulsory purchase powers and did not

necessarily relate to making the lands available free of charge. This is

considered to be reasonable, although it cannot at the moment be tied to a

specific reservation, as the planning authority is unsure of the precise

alignment.

7.8 Condition no.32 – Variable Message Signs

7.8.1 The appeal contends that this condition, requiring an alternatives route study

and the provision of VMS equipment, is ultra vires as it requires works to

lands outside the applicant’s control. The planning authority qualified this

condition at the hearing (submission BY), whereby a contribution towards

the study and VMS system would be made pursuant to s.48 (2)(c) of the

Planning Act. It was estimated that this contribution would be between

€150,000 and €2000,000. It is reasonable that the applicant contribute to the

costs of the study and required signage. A unspecified contribution under

s.48(2)(c) should be appended to any grant of permission.

7.9 Condition no.33 – Road Safety Audits

7.9.1 The appellant’s arguments in relation to the requirement to stage audits is

accepted and should be reflected in the condition.

8 CONCLUSIONS AND RECOMMENDATIONS

8.1 It is considered that the proposed development:

does not contravene national, regional or local transportation policy;

would not be premature pending the upgrading of the surrounding road

network;

would not result in traffic congestion; or

result in an unsustainable development pattern.

I have considered all submission and matters arising. There area no

objections to the proposed development and if the Board is minded to grant

permission, it is recommended that the following conditions be attached:

1. Prior to the commencement of development, the developer shall submit

for the written agreement of the planning authority a comprehensive

environmental protection plan to minimise the impacts of the construction

processes. The plan shall provide for, inter alia:

i) provision for loading and unloading of materials;

ii) storage of plant, materials, operatives vehicles;

iii) provision of temporary offices and car parking;

iv) temporary site access;

v) identification of the main routes to be used by construction traffic

having regard to the location of residences in the area and the

standard of roads to be used. Option B as outlined in the EIS shall not

be used;

vi) a survey of the road and pavement conditions affected by the

construction route. A bond shall be agreed with the planning authority

prior to the commencement of development;

vii) measures to minimise dust and spillages or deposits of clay or other

materials along the route. Such measures should include wheel

washes and other cleaning mechanisms;

viii)a waste management plan to ensure the minimisation of waste, re-use

or recycling of materials;

ix) hours of construction activities and access to the site, minimising

construction access during the AM and PM peak periods.

Reason: In the interests of traffic safety and amenity.

2. Further details of the layout and access arrangements including

consideration of alternative locations, to all existing and proposed viewing

areas affected by the proposed runway shall be submitted for the written

agreement of the planning authority prior to the commencement of

development.

Reason: In the interests of traffic safety and amenity.

3. Details of the northern perimeter fencing shall be submitted to the

planning authority prior to the commencement of development.

Reason: In the interests of amenity.

4. Prior to the commencement of development the developer shall submit to

the planning authority for its agreement details of the following:

a) full design details, including specification, of the realigned and re-

routed roads;

b) details of Forest Little Road / Forest Road junction;

c) revised details of the new R108 / St.Margaret’s Bypass junction;

d) details of the proposed spur to the north-west of the R108 /

St.Margaret’s Bypass junction, illustrated in Fig No.2 of the Scott

Wilson Highways Report submitted to the planning authority on the 9 th

August 2005.

Prior to the submission of these details, the applicant shall consult with

Fingal County Council Transportation Department.

Reason: In the interests of traffic safety.

5. The proposed upgrade of Swords Road R132/North Corballis Road

roundabout and the Swords Road R132/South Corballis Road signalised

junction shall be omitted.

Reason: In the interests of the proper planning and development of the

area.

6. The applicant shall consult and liaise with the planning authority to

facilitate the planning, design and implementation of the proposed

Western Access indicated in the Dublin Airport Local Area Plan, June

2006. The lands within the ownership of the applicant shall be made

available to the planning authority when required to do so to facilitate the

delivery of this road objective.

Reason: In the interests of the proper planning and development of the

area.

7. The applicant shall consult and liaise with the Railway Procurement

Agency to facilitate the planning, design and implementation of the Metro

North through the lands within the ownership of the applicant. The

required lands shall be made available to the Railway Procurement

Agency when required to do so to facilitate this piece of public transport

infrastructure.

Reason: In the interests of the proper planning and development of the

area.

8. Full staged Road Safety Audits shall be carried out for all road

infrastructure works and for the viewing areas and submitted to the

planning authority for its agreement. The Road Safety Audits shall be

compliant with the NRA Road Safety Audit Guidelines (DMRB Volume 5

– Section 2) and shall be submitted for compliance at the appropriate

stages of development.

Reason: In the interests of traffic safety.

9. All necessary agreements to extinguish public rights of way shall be in

place before commencement of runway construction. The extinguishment

of these rights of way shall not be enforced and no stopping off of access

shall be allowed until the proposed alternative routes are in place.

Reason: In the interests of the proper planning and development of the

area.

10. The developer shall pay to the planning authority a financial contribution

as a special contribution under section 48(2)(c) of the Planning and

Development Act 2000 in respect of the preparation of a study of

alternative access routes and provision of Variable Message Signs. The

contribution shall be paid prior to the commencement of development or

in such phased payments as the planning authority may facilitate and shall

be updated at the time of payment in accordance with changes in the

Wholesale Price Index - Building and Construction (Capital Goods),

published by the Central Statistics Office. The amount of the contribution

shall be agreed between the planning authority and the developer, or, in

default of agreement, the matter shall be referred to the Board for

determination.

Reason: It is considered reasonable that the developer should contribute

towards the specific exceptional costs which are incurred by the planning

authority which are not covered by the Development Contribution Scheme

and which will benefit the proposed development.

Jerry Barnes

16th November 2006

Review of Relevant Plans, Guidelines and Policy Statements

for

New Runway & Associated Works Appeal

at

Dublin Airport

Report

by

Jerry Barnes, MRTPI, MIPI, ASCS, MRICS

for

An Bord Pleanála

1 INTRODUCTION

This report summarises relevant landside transportation aspects of plans, guidelines and policy statements that the Board is required to have regard to under s.143 of the 2000 Planning and Development Act in relation to the appeal for the proposed runway at Dublin Airport. It is provided in compliance with part 2 of the brief of August 2006.

2 NATIONAL POLICY

2.1 Sustainable Development - A Strategy for Ireland, 1997

In relation to transport, the strategy outlines an action plan to minimise the potential growth in transport demand through effective land use planning, intensification of the implementation of the DTI strategy, implementation of the roads programme and promotion of public transport.

2.2 National Climate Change Strategy, 2000

It is recognised that transport is the most difficult sector in which to achieve control in greenhouse gas emissions. There are a number of transport sectors under which action can be taken.

Fuel Emission

Measures relate to:

EU Agreement with car manufacturers.

VRT and annual motor taxes.

NCT.

Fuel economy labelling.

Promotion of public transport.

Modal Shift

The measure include:

Investment in public transport (LUAS, suburban rail, bus services).

Traffic management.

Road investment.

Rail freight.

Demand Management

Those measures affecting mode choice include:

Fuel taxation measures.

Integrated transport policy.

Integration of land use and transportation planning.

Vehicle restraint and road pricing.

Greenhouse gas emissions targets are established.

2.3 National Development Plan 2000-2006

The NDP makes provision for significant investment in transportation infrastructure serving the Airport by 2006, and these include:

Motorway Standard

M1 Dublin to Northern Ireland Border

N2 Dublin/Monaghan/Omagh/Derry/Letterkenny

M3 Dublin/Belturbet/Enniskillen/Derry

M50 completion

Dublin Port Tunnel

Public Transport

Increasing capacity of bus services and network

Separation of long distance commuter rail traffic including a new rail line through Swords and Dublin Airport.

2.4 National Spatial Strategy, 2002

This is a twenty year planning framework for the country with the aim of achieving a greater balance of social, economic and physical development for the State. It recognises the central role which Dublin Airport has to play. The Strategy further indicates that national and regional benefits of expanded services from Dublin Airport can be enhanced through improved connections with:

a) the integrated public transport network proposed by the Dublin Transportation Office in a Platform for Change;

b) the national road network; and

c) regional airports.

2.5 Agreed Programme for Government Between Fianna Fáil and the Progressive Democrats

The provisions of relevance to the subject application include:

Establishment of an integrated Department of Transport with responsibility for the national roads programme, aviation and public transport.

Establishment of a new Greater Dublin Land Use and Transport Authority.

Enhancement of the bus fleet.

Ensuring that access to public transport is one of the criteria taken into consideration in the planning process.

Develop Metro to the Airport by 2007.

Implement the National Roads Programme.

Ensure completion of Pier D and consider further terminal capacity at Dublin Airport.

2.6 Transport 21

This plan, which was launched by the Government in November 2005, seeks to provide a 10 year investment programme for the State’s transport requirements. A budget of €34 billion has been allocated for the period between 2006 to 2015. Those elements of relevance to the subject proposal include:

Completion of the Dublin Port Tunnel by 2006.

Completion of the M1 and M50 Phase 1 upgrade by 2007. M50 Phase 2 upgrade by 2019.

Construction of M3 by 2009.

Completion of Metro North by 2012. Predicted journey time from the city centre to the Airport is 17 minutes.

2.7 Policy Statement on Development Management and Access to National Roads, 2006

The NRA has prepared this statement. The Authority seeks to protect the operational efficiency and capacity of the national road network and seeks to ensure the safety of road users. The Authority will seek to limit accesses to/from motorways and dual carriageways to:

a) approved interchanges.b) On-line service areas and rest areas.c) Garda enforcement platforms.

Requirements for planning applications are outlined in relation to traffic impact assessments, safety audits and consultation.

3 REGIONAL POLICY 3.1 A Platform for Change, 2000-2016

This strategy, prepared by the DTO, provides a integrated approach to the provision of public transport, roads, transport demand measure and land use planning in the Greater Dublin and Mid East Regions. The strategy reviewed and updates the original DTI Strategy from 1994. It notes that the original projections of passengers through Dublin Airport in 2000 (13.8m) exceeded those projected in the original strategy (11m) and highlights that the Airport is a major destination for trips from all parts of the Greater Dublin Area. Those elements of the Strategy that are of relevance to the development of the Airport include:

A further 495 buses will be required to implement the full bus strategy.

The Airport would be served by a combination of radial QBC routes via the Swords Road, Ballymun and Finglas, in addition to an orbital QBC along the outer ring road aligned along the southern boundary of the Airport.

The provision of LUAS to Ballymun by 2006 and extension to Sillogue to the south of the Airport by 2010.

Construction of Metro from Ranelagh to Swords via the Airport by 2010. The line would be aligned via Finglas before looping around on the southern side of the Airport.

Provision of the Eastern By-Pass and completion and upgrading of the M50 ring road.

Completion of the Dublin Port Tunnel.

Provision of Park and Ride and the management of parking provision in order to encourage the use of public transport.

Construction of the Outer Ring Road from Lucan to the N2 by 2016.

3.2 Regional Planning Guidelines for the Greater Dublin Area, 2004

The Guidelines recognise that Dublin Airport is one of the premier access points to the country. Landside access is recognised as a significant issue with regards to the development of the Airport. It’s continue development, along with required associated infrastructure is essential. Access can be improved by:

Rail/metro link

Completion of the M50

Construction of QBCs

Given the increase in passenger numbers it is acknowledged that a new runway will be required by 2009, in addition to new terminal and apron facilities. Future development at the Airport should give pre-eminence to the provision of public transport.

3.3 Report of Public Transport Forum on Short Term Measures for Improved Public Transport Access to Dublin Airport

The Public Transport Forum was orginally established under the Programme for Prosperity and Fairness under the Department of Transport. This Forum prepared the above report in 2002 and proposed measures to address short term public transportation requirements up to the provision of Metro in 2007. The strategy estimates that:

passenger numbers will reach 21.3m by 2008, 28m by 2018 and 42m by 2030;

employment will grow to 16,700 by 2006 and 25,000 by 2016;

morning peak hour trips will increase from 6,300 in 2001 to 13,500 by 2016;

parking, if unrestrained, would grow from 24,238 spaces in 2001 to upwards of 40,000 spaces by 2016:

in 2001, 22% of air passengers and 16% of employees travelled by bus to the Airport and 55% of air passengers and 81% of employees travelled by car. 22% of air passengers travelled by taxi.

There is congestion in and around the Cloghran roundabout. There will be large increases in traffic volumes at all key junctions surrounding the Airport. In particular, traffic flows at the Airport Roundabout, and at the Turnapin and Finglas Interchanges will more than double. In less than 3 years after the completion of the M1 motorway,

traffic flows on the new Airport Interchange will have exceeded capacity. The report therefore focuses on measures to reduce congestion in the peak hour.

In summary, the recommendations of the forum are:

1. QBC network, as outlined in Appendix B, should be implemented in full by 2003.

2. New northwest and southwest flier services to Blanchardstown and Tallaght town centres should be provided.

3. The realignment of route 748 to connect Heuston Station and separate the 747 service from Connolly Station.

4. Passenger Interchanges should be provided at St. Stephen’s Green, O’Connell Street, Howth Junction, Heuston and Connolly and Tallaght and Blanchardstown town centres with bus-bus interchange and taxi-bus interchange.

5. Integrated rail-bus ticketing by rationalised 747 and 748 bus services.

6. Promotional and advertisement measures to achieve a higher occupancy rate of public transport.

7. Taxi sharing scheme to be introduced at Dublin Airport.

8. Complementary demand management measures to reduce private car use by air passengers and employees. These measures to include:

- pricing strategy for parking

- capped employee parking at 2002 levels

- reduce parking level per million from current level of 1,298 to 1,090 by 2007

9. Adopt appropriate implementation and monitoring measures.

3.4 Metro North Route Selection, RPA February 2006

The RPA published the route alignment options for the Metro from the City Centre to Swords via the Airport in February 2006 for public consultation. A map of the options is attached. The three principal routes were:

a) Eastern Route – This would be aligned from Stephen’s Green – O’Connell Street – Drumcondra – Griffith Avenue –Santry – Clonshaugh Road –Airport (eastern side) – Airside – Swords.

b) Central Route – This would be aligned from Stephens Green – O’Connell Street – Mater – Botanic Road - DCU – Ballymun – Airport (eastern side or central) – Airside – Swords.

c) Western Route – This would be aligned from Stephen’s Green – Tara Street – Broadstone – Cabra Road – Liffey Junction – Finglas – Airport (central alignment) – Airside – Swords.

3.5 Metro North Selection of Preferred Alignment

The RPA announced on the 19th October 2006 that a preferred alignment had been selected. The western route is the preferred alignment. The alignment from that detailed in the February statement has shifted by approximately 100m to the east. It is

anticipated that a rail order application would be submitted by summer 2007, an enforceable order would be in place by summer of 2008, with construction commencing in 2009 and completion by 2012.

Selected Route

4 LOCAL POLICY

4.1 Fingal County Development Plan, 2005-2011

Chapter VI outlines the provisions in relation to transportation. The principal relevant policies relating to the Airport are as follows:

Road Transport

95PolicyTP2: To implement a programme of road construction and improvement works closely integrated with existing and planned land uses as resources allow.

PolicyTP4: To balance the requirement for an appropriate level of off-street parking facilities against factors of accessibility to means of alternatives transport to the private car applying at particular development locations, in the overall interest of sustainable land use practice.

PolicyTP6: To develop linkages with other modes of transport in order to facilitate the provision of an integrated transport system.

The following objectives are also of relevance:ObjectiveTO1:To implement the road construction and improvement measures set out in Table 6.1 as resources allow. Those road schemes included around the Airport are:

14. N1 Junction Improvements16. Forest Road Improvement Scheme35. St. Margarets Road (Ballymun) Improvement Measures36. Ballymun Interchange to Harristown Road48. N2-N3 Church Road Tyrellstown-Ratoath Road (N2 link)

49. N2-N3 Link Ballycoolin Road to Cherryhound (N2)50. N2-N3 Link Church Road Tyrellstown to Damastown56. M50 Upgrade57. M2 Motorway

ObjectiveTO3:To implement a programme of traffic and parking management measures in towns and villages throughout the County as resources allow.

ObjectiveTO4: To secure the provision of an appropriate level of vehicle parking facilities in new developments in accordance with Policy TP4.

ObjectiveTO5: To encourage the provision of facilities for the secure parking of Heavy Goods Vehicles at suitable locations.

Public Transport

Policy provisions of relevance are:99TP7: To prioritise public transport by safeguarding future rail and bus routes, promoting the provision and improvement of QBCs and bus priority on existing and planned road infrastructure measures (see Table 6.3), requiring mobility management plans for new developments and implementing traffic and parking management measures.

PolicyTP8: To work with CIE and the DTO to support and provide for, in as far as is practicable, the delivery of an integrated transport strategy for Dublin as a whole, to benefit the residents of Fingal.

PolicyTP9: To support demand management measures to reduce car travel.

PolicyTP10:To promote land use patterns which reduce the need to travel and support public transport, including higher densities at public transport corridors and nodes.

PolicyTP11: To ensure that new developments are laid out so as to facilitate the provision of local bus services.

PolicyTP12: To promote and facilitate the development of a METRO rail link from the City to the Airport and on to Swords.

PolicyTP13: To investigate the practicability of Section 49 schemes to secure contributions from developers towards the upgrading of public transport infrastructure.

PolicyTP14: To promote the provision of public transport interchange facilities at appropriate points on the public transport network in co-operation with the DTO and the public transport providers.

The statutory objectives which are of relevance to the proposed development at the Airport are:

ObjectiveTO6: To facilitate and promote the development of a METRO line from the City Centre to Dublin Airport and on to Swords by protecting the preferred route identified by the Railway Procurement Agency, preparing and implementing proposals for the integration of this line with the development of adjoining lands in co-operation with the developers of such lands, and implementing a scheme under Section 49 of the Planning and Development Act 2000 to secure contributions from developers of lands in the vicinity towards the cost of developing the line.

ObjectiveTO7: To protect a route for a heavy rail link between Dublin Airport and the Dublin-Maynooth railway line.

ObjectiveTO9: To protect from development any lands required for the upgrading of existing railway lines or stations or the provision of new railway stations throughout the County.

ObjectiveTO10:To secure the development of new Quality Bus Corridors and the extension and improvement of existing Quality Bus Corridors. These include the Swords Road QBC and a new QBC along the R108.

ObjectiveTO11: To promote bus priority measures on existing and planned road infrastructure where appropriate.

ObjectiveTO13: To facilitate the provision of feeder bus services to rail stations.

ObjectiveTO14: To promote and facilitate the development of Public Transport Interchanges at Blanchardstown Centre, Porterstown, Swords, Howth Junction, Baldoyle and Balbriggan, and at other locations which may be identified during the lifetime of the Plan.

ObjectiveTO15: To facilitate the provision of Park and Ride facilities at suitable interchange points between private and public transport.

ObjectiveTO16: To require mobility management plans for new developments likely to give rise to substantial movements of employees or customers.

ObjectiveTO17: To implement a programme of demand management measures adopted as a result of the Demand Management Study currently being carried out on behalf of the DTO.

Dublin Airport

The Plan highlights that the Airport accommodated 16m passengers in 2003 and provided 14,500 direct jobs, which were supported by 40,000 indirect jobs. The Plan estimates that the Airport will cater for approximately 22m passengers by 2010 and 31m by 2020. A total of 22,500 employees are also projected for 2020. Currently, there are 18,400 car parking spaces operated by Aer Rianta.

Landside transportation policies that are of relevance are:

PolicyTP15: To safeguard the current and future operational, safety, technical and developmental requirements of Dublin Airport.

PolicyTP16: To protect and enhance surface access to and from the Airport.

PolicyTP17: To control the supply of car parking at the Airport so as to maximise as far as is practicable the use of public transport by workers and passengers and to secure the efficient use of land.

PolicyTP20: To realise the optimal use of lands around the airport.

ObjectiveTO18: To determine a Designated Airport Area for Dublin Airport, and to zone the lands included in that area for uses integral or ancillary to the functions of the airport as such.

ObjectiveTO19: To facilitate the early development of a second east-west runway at Dublin Airport.

ObjectiveTO21: To facilitate the on-going augmentation and improvement of terminal facilities at Dublin Airport.

ObjectiveTO23:To promote the development for economic activities and employment generation, strictly in association with the provision of the METRO, of lands to the south of the Airport identified in the South Fingal Planning Study as being suitable for such uses.

ObjectiveTO24: To restrict development which would impede surface access to Dublin Airport.

4.2 South Fingal Planning Study, 2004

This study was commissioned by Fingal County Council and prepared by Llewelyn Davis. A second terminal is proposed to the west of the cross wind runway between the existing east west runway and the proposed 10L/28R Runway. This is favoured over development on the eastern side owing to external impact, e.g. on traffic. The recent phases of development would enable the airport to handle 20 mppa, which is expected to be reached by 2007. At 22 mppa an internal Advanced People Movement system (APM) is viable. A “station box” for Metro as part of advanced works maybe possible.

Mode Share of Dublin Airport passengers 2000-2010 (assuming Metro/Luas 2008)

2000 2002 2004 2006 2008 2010Passenger Numbers (million per annum)

13.8 16.07 17.86 19.72 21.31 22.91

Private Car 7.7355%

8.8455%

9.6454%

10.2552%

10.4449%

10.3145%

Taxi 3.3124%

3.7023%

3.5720%

3.5518%

3.2015%

3.4415%

Bus/coach 2.3517%

3.0519%

3.9322%

4.9325%

2.5612%

2.7512%

Luas 1.07 0.69

5% 3%Metro 2.98

14%4.5820%

Other 0.453%

0.483%

0.714%

0.995%

1.075%

1.155%

Total 100% 100% 100% 100% 100% 100%

In relation to transportation aspects of the plan, the vision for the development of the area recognises the need:

a) to create a public transport spine linking Dublin Airport and the City Centre as a quick and reliable alternative to the private car: and

b) for the creation of a balanced transport system with a choice of modes – bus, light rail, car, taxi and possibly heavy rail, which will be allied to a coordinated land use strategy.

Transport Policy recommendations include:

Preservation of the preferred Metro route alignment, which is indicated in Figure 4.1 as passing under main terminal building, multi-storey car parks and cargo handling facilities in a north south direction.

Total long and short term parking supply will need to reach around 30,000 spaces by 2011.

In the short to medium term, the Council should carry out planned improvements on the M1 and M50.

Road proposals to include:

- A second western airport access from Cherryhound Interchange to Airport may be required by 2007 due to forecast congestion on the eastern side and inevitable location of further facilities on the western side of the complex.

- New east-west link road east of Turnapin Interchange from R132 via Belcamp to meet the R107 Malahide Road.

- N32 east of the Turnapin Interchange to be upgraded

- R122 Clonshaugh Road to be realigned and upgraded

- R108 north of Ballymun Interchange may be upgraded to dual carriageway branching east and west along southern boundary of the Airport.

Provision of heavy rail and LUAS maybe required, but should complement the proposed Metro alignment. There is general support for connection to the general rail network.

The future Airport Action Plan, developed in conjunction with Aer Rianta, should address routing, alignment and integration of public transport facilities within the airport complex.

Improvement of bus services should be continued.

The Council should continue to promote park and ride at suitable locations.

Cycling and walking should be facilitated within the complex.

Mobility management plans should submitted with applications when appropriate.

A multi-modal interchange should be provided to the south of the airport.

4.3 Dublin Airport Master Plan, Fingal County Council, 2006

This plan was adopted as a statutory local area plan on 20th June 2006. The plan projects that passenger numbers will grow from 18.5 mppa in 2005 to 28 mppa by 2014 and 42-44mppa by 2030. Forecasts indicate that cargo will grow from 150,000 tonnes in 2005 to 200,000 tonnes by 2015. The plan outlines existing road infrastructure serving the Airport, in addition to existing public transport services. At present approximately 23% of passengers and 16% of employees travel to the Airport by bus. There are currently 5,360 parking spaces for employees, 17,500 long term parking spaces and 3,800 short term parking spaces within the Airport complex. The plan states that there was a demand for 20,500 parking spaces in 2005.

The plan allows for a second terminal to the south of the existing terminal and associated terminal facilities to cater for 30mppa, with provision for future cargo handling facilities and further terminal development to the west of the north-south runway. A future ground transportation centre will be accommodated and protection the Metro alignment will be included where necessary.

External Road Objectives

The proposed road upgrades of the external road network are outlined as follows:

Airport Box: The upgrading of R132 Collinstown Lane, the R108, Northern Parallel Road, Forrest Little Road and St. Margaret's road to dual carriage way standard which will form the Airport Box.

Blanchardstown/ Baldoyle Airport Road: This road will also be dual carriageway standard. This will allow traffic that does not need to use the M1 or M50 to easily access areas to the east of Dublin.

Link to N2: This road will link traffic from the N2 to the airport box and also to the terminal and cargo facilities on the Western Campus and the associated parking areas. This will allow for access to the airport from the west.

Upgrade of the R108 South: Upgrade of the R108, from Collinstown Lane to the interchange with the M50 at Ballymun, to dual carriageway standard. This will cater for the growth in traffic that will be generated by expansion at the airport.

Improved/Additional access: Currently the majority of airport bound traffic accesses the airport via the airport roundabout, with minor levels of traffic using Corballis Road South. It is proposed to construct new and improved accesses off the proposed upgraded R132 Collinstown Lane and Forest Little Road to the Eastern Campus and to also make provision for direct access to terminal facilities on the Western Campus.

Upgrading of the M50: Phase 1 of the M50 upgrade is due to commence shortly and will see the construction of an extra lane both north and south bound on the

M50 together with the upgrade of interchanges. When completed, the M50 will be a three-lane carriageway in both directions. According to the infrastructure timetable in Transport 21, phase 1 is due to be completed by end of 2007, with the entire project completed by the end of 2010.

Western Bypass: To allow for future connection of the possible western bypass of Swords, to link with the Airport Box.

External Access Objectives

EA1: To maintain and protect accessibility to the airport as a priority and provide for alternative access points to the road network.

EA2: To implement a programme of road development on the external road network.

EA3: To ensure that the road infrastructure has the capacity to cater for the estimated growth in traffic.

EA4: To develop the external road network on a phased and planned basis.

EA5: To improve and provide alternative access points to the Airport from the external road network, in particular via Collinstown Lane and Forrest Little Road.

EA6: To realign and improve and upgrade the road network surrounding the Airportin the form of an Airport Box to dual carriageway standard. The roads proposed for this upgrading are the R132, Collinstown Lane, the R108, the Forrest Little Road, the North Parallel Road and the St Margaret's Road.

EA7: To reserve an alignment for the Blanchardstown/ Baldoyle Airport Road from Collinstown Lane to Clonshaugh Road. This road is to be developed to dual carriageway standard.

EA8 To provide for road access to the airport from the west, which will include a link from the recently upgraded N2 at Cherryhound Interchange, in the form of a dual carriageway.

EA9: To allow for future connection of a possible western by pass of Swords to link to the Airport Box.

EA10: To improve and upgrade the R108 south of Collinstown Lane to the BallymunInterchange to dual carriageway standard.

EA11: To develop a strategy to cater for unexpected incidents on road networks.

EA12: To develop electronic signage facilities such as Variable Message Signs (VMS) signage and Intelligent Traffic Systems (ITS).

EA13: To provide an emergency access plan in consultation with the relevant bodies.

EA14: To develop a detailed model (based on the full DTO Area Model).

Internal AccessA number of proposals are incorporated into the plan, which include:

Internal Roads: These to include- Possible improvements to the Airport access roundabout.- Provide a corridor for the construction of a northern distributor road

through Airport lands, to connect the N2 to the R132.- Provide for improved capacity on the R132 corridor from the southern

distributor and northern distributor roads, using Airport lands if necessary.- Provide for an independent connection to the west of Cloghran roundabout

from the northern distributor road to the internal airport road network.- Provide for additional access off the R132 between the Airport roundabout

and the South Corballis Road.

Kerbside and Pedestrian Facilities: Appropriate set down facilities to be provided to segregate different modes.

Ground Transportation Centre: To be provided to accommodate bus, coach, Metro interchange.

Vehicle Entry Routes to Arrivals and Departure Kerbs: Clear directions for vehicles entering the Airport to arrivals and departure roads.

Internal Road Access Objectives

IA1: To review the circulation of traffic around the airport campus.

IA2: To provide a high quality high capacity link between the Eastern and Western campuses.

IA3: To agree an alignment around the southern airport perimeter for a transport service linking the terminal buildings with long-term car parks.

IA4: Prioritise passenger experience.

IA5: To provide a corridor for the construction of a northern distributor road throughDAA lands to connect the N2 to the R132.

IA6: To provide for improved capacity on the R132 corridor from the northern and southern distributor roads.

Public TransportFundamental to a public transport strategy for the Designated Airport Area is that public transport receives priority access to all terminal areas and linkages should be made between all public transport modes in order to provide an integrated transport system. In addition the use of public transport by both passengers and staff within the Masterplan lands should be actively promoted.

Principal public transport proposal are:

Metro: Map 2, illustrates the Metro alignment included in the Fingal Development Plan.

Improved Bus Infrastructure: Adjoining road network upgrade will be required.

This will facilitate the provision of east-west bus connections as well as the current north-south connections. An upgrade of the Swords/Airport QBC and the extension of the Ballymun QBC to the Airport will be facilitated.

Rail Link: New bus links along the proposed Baldoyle to Blanchardstown Airport Road.

Orbital Metro: When the alignment is selected, the lands will be protected.

Intermodal Interchange: A Ground Transportation Centre is proposed, which would cater for Metro, bus, coach, short-term parking.

Link between Eastern and Western Campus: This is required.

Link between intermodal interchange and commercial area: Development of commercial zone is dependent upon high quality public transport.

Public Transport Objectives

PT1: Facilitate the provision of an integrated public transport network to serve Dublin Airport.

PT2: To provide for the development of a transport interchange including a Metro Station at the centre of the airport campus.

PT3: To ensure Metro Station is to best international standards for public transport interchanges.

PT4: To provide for connection/links from the western campus to the recently approved Metro North.

PT5: To identify and protect an alignment for the Orbital Metro (Metro West) and toensure connectivity between Metro West and the Airport.

PT6: To support the provision of bus and taxi facilities including bus lanes, shelters and interchange facilities.

PT7: To prioritise public transport and taxis on the external and internal road network.

PT8: To provide and upgrade alignments for new and existing QBCs, in particular in an east/west direction.

PT9: To prioritise bus links to the new DART station at Baldoyle along the proposedBlanchardstown to Baldoyle Airport Road.

PT10: Incentivise use of public transport use for both staff and passengers through the use of tax incentives, integrated ticketing and personalised travel plans in co-operation with the Government.

PT11: To provide real time information regarding public transport.

PT12: To increase the emphasis on the promotion of public transport usage among staff and passengers.

PT13: To provide for bus priority on approach roads to the Airport as required.

Car Parking

The main objective in relation to employee and car hire parking is to locate this provision away from the central terminal area. Improved public transport will serve to reduce demand for long term, short term and employee parking. Parking is price sensitive.

Long Term Parking: This shall be dispersed on the periphery of the Airport.

Short Term Parking: Multi storey facilities close to terminals, including Terminal 2, shall be facilitated.

Car Hire Parking: Main facilities will be away from terminals. A further 1000 spaces to be provided at 30mppa and 500 spaces adjacent to terminals.

Employee Parking: 16% of employees travel by public transport. Terminal 2 and Pier D will remove 3,800 spaces and 1,500 spaces will be retained to the west of the RI32. Parking on the western campus will be provided away from the terminal buildings.

Car Parking Objectives

CP1: To review the location of bus/coach parking in front of Terminal 1 in conjunction with an analysis of Metro Station, Terminal 2, and Kerb proposals.

CP2: To provide for the removal of staff car parking from the centre of the campus.

CP3: To provide for phasing of short-term and long-term passenger car parking having regard to the improvement of public transport access.

CP4: To provide for the change of location of car hire facilities concurrently with the development of Terminal 2.

CP5: To provide for high quality parking facilities on airport lands.

CP6: To identify specific parking zones within the Designated Airport Area.

CP7: To provide for (a) good access from the external road network and (b) frequent shuttle connections to the terminal buildings, for long-term car parks.

CP8: To provide for short-term car parks close to the terminal buildings.

CP9: To control the supply of car parking at the airport so as to maximise as far as is practicable, the use of public transport by passengers and to secure the efficient use of land.

CP10: To limit the growth of employee parking in order to improve public transport usage.

CP11: To secure the implementation of a parking management strategy.

Mobility Management ObjectivesThe principles of mobility management are outlined. The objectives are as follows:

MM1: To secure the implementation of a Mobility Management Plan for the DublinAirport Area to ensure a greater shift away from private vehicle usage.

MM2: To review and update the Mobility Management Plan every 5 years.

MM3: To identify and implement measures to maximise non-motorised and public transport use while, minimising the use of the private car.

MM4: To require that all organisations operating within the Airport Area are signed up to and committed to implement the Mobility Management plan.

4.4 Dublin Airport Terminal and Piers Development Study, Aer Rianta 2004

High and low public transport projections were made for the 30mppa. The ground landside transportation provisions are as follows:

Between 750 and 850m of kerbside parking is required for arrivals and departures.

It is assumes access is from the M50 via the upgraded R108 and R132. Relocation of cargo handling and staff parking will reduce traffic in the central area.

New entrance at Kealy’s pub on the R132.

Entrance off Forest Little Road only to serve aircraft maintenance.

Proposed ground transportation centre to provide interchange between Metro, bus, regional bus services, taxis and private cars.

Currently there are 25,000 parking spaces, 3,800 short term, 14,600 long term and 5,360 staff spaces. Targets are set for long, medium and short term parking provision.

Mode split targets for passengers is 45% in 2020 from the current 22%. For employees the public transport target is 40% by 2020, rising from the current 16.2%

Six metro alignments are considered.

REPORT BY RUPERT THORNELY-TAYLOR ON ISSUES RELATING TO NOISE

Pauline Fitzpatrick,An Bord Pleanála64 Marlborough StreetDublin 1 4 June 2007

Dear Pauline,

An Bord Pleanála Reference: PL 06F.217429Dublin Airport : Proposed Parallel Runway

I give below my final report on the matter of noise and the proposed parallel runway development at Dubin Airport. This includes the content of my draft letter sent by e-mail on 9 November 2006, updated to take account of material submitted in response to the Bord’s information request of 9 January 2007.

My report takes into account the evidence, questions and answers during the noise module of the oral hearing into the proposed new runway and associated works at Dublin Airport, which was held on 9-11 October 2006. I have also read and considered the background papers, including the Decision by Fingal County Council and the associated report, the Environmental Impact Statement (EIS), the Addendum to the EIS, further information supplied by the applicants and the material submitted by third party appellants. I have been further assisted by the Bord’s audio recordings of the noise module of the proceedings.

The noise module of the hearing was concerned not only with the principal matter of the planning application as a whole, but also a specific appeal by the applicants relating to Condition 11 in the Planning Permission granted by Fingal County Council relating to aircraft engine testing.

This report, which is confined solely to noise matters, first outlines the application that is, among the many options that have been considered during the process, currently sought by the applicants. Secondly it sets out the position with regard to the performance of requirements for the assessment of environmental effects. Thirdly, it summarises the cases raised by the other parties to the hearing, Fingal County Council and third parties. Fourthly it discusses the merits of the issues involved. Finally it makes recommendations, from a noise point of view, regarding the appropriate decision and gives recommended planning conditions.

1 The development currently sought by the applicants The EIS considered a range of operational scenarios. Between the submission of the EIS and the opening of the hearing one operational scenario known as Option 7b has been favoured by the applicants, and it was confirmed to the hearing by the applicants, through their Counsel Mr O’Donnell, that the applicants would be content to be restricted to use of the new runway in accordance with the assumptions of Option 7b. In summary, these assumptions are1:

1) The parallel runways (10R-28L and 10L-28R) would be used in preference to the cross runway 16-34.

1 EIS Addendum Section 16 P37 et seq.

2) When winds are westerly, Runway 28L will be preferred for arriving aircraft. Either Runway 28L or 28R will be used for departing aircraft as determined by ATC.

3) When winds are easterly, either Runway 10L or 10R as determined by ATC will be preferred for arriving aircraft. Runway 10R will be preferred for departing aircraft.

4) No operations at night, defined according to the noise contour period as 2300-0700, on runway 10L/28R with very limited exceptions.

The definition of night, for these purposes, was confirmed by Mr O’Donnell as 2300-0700, and not 2300-0600 as referred to in the EIS Addendum2. The exceptions were clarified by Mr Andrew Evans as follows. The statement3 “where safety, maintenance considerations, air traffic demand and environmental consideration require the proposed runway to be used at night” is to be interpreted such that in clarification of the term “air traffic demand” this was included to cover broader air traffic issues not necessarily covered by safety and environmental issues at Dublin. These demands might occur as a result of widespread air traffic disruption over a large area—perhaps as a result of adverse weather, technical problems with air traffic control systems or declared emergencies at other airports. It does not mean air traffic capacity or capability.

The applicants seek a permission which, in relation to engine testing, is subject to a variation of condition 11 “Prior to commencement of construction of the new runway, aircraft engine testing at the northern end of the airfield shall cease and be relocated away from the populated neighbouring areas to a location to be agreed in writing with the planning authority” to the effect that “construction” is replaced by “operation”.

The application is accompanied by a set of Noise Mitigation Proposals4 that are summarised as:

1) All schools within the 60 dB LAeq contour (covering all modes of operation) will be insulated in line with the commissioning of the new runway.

2) A house buy-out scheme, for current houses, or houses currently approved, would be introduced as and when houses fall within the 69 dB LAeq contour

3) The current residential sound insulation programme will be extended, for current houses, or houses currently approved, from the 66 dB LAeq contour to the 63 dB LAeq contour

4) Noise and Flight Track Monitoring would be continued. It was made clear in evidence that the monitoring results would be integrated into a programme of biennial updating of the noise contours.

2 Ibid. P403 Observations on Third Party Appeals, RPS Planning and Environment 12 June 20064 Dublin Airport Noise Mitigation Review, Mouchel Parkman, February 2006.

It was confirmed by Mr O’Donnell that the noise mitigation proposals would be put into effect following any grant of permission even if there was a delay in implementation.

2 Environmental Assessment The Planning and Development Regulations, SI No 600 of 2001, set out the required information to be included in an Environmental Statement. Schedule 6 requires a statement of the likely significant effects of the proposed development. The EIS makes sparse use of the word “significant”, and the applicants through their noise witness responded to questions concerning the significance of the effects identified. SI No 600, however, requires that statement of the likely significant effects to be contained in the EIS, and evidence to the oral hearing does not form part of the EIS. The Bord issued a request for information dated 9 January 2007, which included a request for an assessment of significance of increase in noise level, the response to which was available for third parties and others to consider and to make further representations. The applicants have made a comparison between the “no development” case in the years 2010 and 2025 with the case assuming construction of the new runway and use restricted to the assumptions of Option 7b.

In the “no development” case, there would be growth5 in the use of the cross runways, particularly runway 16/34 such that in 2010 6.8% of total airport movements would use runway 16 and 2.2% would use runway 34. 2.2% of movements would use runway 29 and 0.8% would use runway 11. In 2025 the forecast is that 5.9% of total airport movements would use runway 16 and 2.0% would use runway 34. 6.5% of movements would use runway 29 and 2.1% would use runway 11.

In the Option 7b case6, runway 11/29 would be extinguished, and there would be a much reduced need to use runway 16/34. For both 2010 and 2025 the forecast is that 1.5% of total airport movements would use runway 16 and 0.5% would use runway 34.

Because the EIS is not explicit in its identification of likely significant effects, clarification was sought from the applicants during the hearing on this matter. The witness for the applicants responsible for the noise data in the EIS, Mr Douglas Sharps, stated that because the new runway would not be used at night (with restricted exceptions) there would be no significant effect from the development at night.

For daytime, Mr Sharps stated that the threshold of significant effects should be assigned to the 63 dB LAeq 16h contour, and for comparison between the contour for the “no development” case and the Option 7b case, the plans labelled ABP-RFI No 4b (2 of 2) and ABP-RFI No 4e (2 of 2) included in the response to further information request7 should be used.

5 EIS Appendix G6 page G/206 EIS Addendum, page 40, Table 17 Response to Information Request by An Bord Pleanála Planning Report by RPS Planning & Environment August 2006

Although Mr Sharps’s assessment assumed that the new runway would not be used at night, it was apparent from the noise contours that in the 2025 “with development” case and the 2025 “without development case” there is a forecast increase in noise at night even though the proposed new runway would not be used at night. For this reason, information request No 5 of 9 January 2007 requested that the applicants “Quantify the potential for increase in night flights on the existing 10R/28L runway which could derive from the growth of air traffic at the airport arising from the proposed runway relative to that which would occur without the new runway” and information request No 6 stated “Paragraph 16.1.2.35 of the EIS states that a system of assessing the increase in noise level would be used to assess night-time noise impact. As there appears to be a noise change when comparing night-time use of the existing runway between “with development” and “no-development”, please detail which category in the accompanying table to which significance should be attached”. A substantive answer to this request was not given.

3 CASES OF PARTIES PRESENT AT THE ORAL HEARING Fingal County Council

Fingal County Council, as planning authority, granted planning permission, nullified by the present proceedings, to which were attached 39 conditions. At least 8 of these were related to noise or had noise implications. Condition 11 relating to engine testing was the subject of appeal by the applicants.

Evidence was given my Mr O’Kelly, expert witness for Fingal County Council to the effect that Option 7b was the Council’s favoured option and that some restriction on night time use was appropriate. Mr Flanagan for the council confirmed that it now considered that while the council’s decision was not explicit in that regard some form of restriction on night noise is appropriate and an eminently practical proposal.

Thiird parties

The evidence of third parties overlapped to a large extent, and is addressed below primarily by topic.

3.1 No baseline Several third parties considered that the Environmental Statement failed to include a report of the existing baseline noise conditions.

3.2 Contour accuracy Both in written appeals and in evidence it was suggested that the accuracy of the noise contours provided in the EIS using the Integrated Noise Model (INM) and in subsequent documents was unsatisfactory. In this regard, reference was made to the response given to one of the further information requests which compared predicted noise levels with measured noise levels. The applicants, however, withdrew part of the data given in this response as being wrong, leaving only the first set of data in the response. This removal included an apparent 25 dB difference between the predicted and measured levels for one aircraft type. Replacement data were provided in a response to Item 1 of the 9 January 2007 information request. However, the replacement data did not facilitate true comparison with the contours, since all aircraft departures listed were assumed to be an INM stage 2 departure, whereas in the

contours, the appropriate range of departure stages was included. The replacement data were unclear in that the departures table stated two numbers for each measured result, with a note that they were average Sound Exposure Levels but no explanation as to why an average should be stated as two numbers. The replacement table for the approach data explained that the two numbers represented a sample of the SELs for each aircraft type.

A reprint of an Institute of Acoustics paper by Flindell and Humpheson was included in the response to the 9 January Information Request, and referred to in the response in support of a contention that the correlation between INM predicted and measured noise levels is reasonable and as expected. However, the Flindell and Humpheson paper is confined to a desk study of the effect of choice of INM input data on INM output, and makes no reference to correlation between predicted and measured noise levels. Rather, it draws attention to the error associated with incorrect choice of departure stage.

Following the evidence at the oral hearing, in which the absence of dispersion in the contour assumptions and the settings used for their computation were considered, revised noise contours were requested as item 2 in the 9 January Information Request. One of the figures was omitted from the response document, namely ABP-RFI Q 2d. This would have been the Night-time 2025 Option 7b contour with second runway, corresponding to Figure 58, Part 4 of the EIS.

The change in tolerance and refinement settings is shown to avoid the sharp pointed end to the contours referred to in the oral hearing, and changes the detailed shape of the contours including a few more houses in North Dublin, but does not materially change the overall area within the contours. The inclusion of actual flight tracks with dispersion has resulted in material changes to the contours. For example, the 57dB contour for 2003 in the EIS passed through Broghan and the northern edge of Kilreesk, while in the revised contour it passes through Newpark, more than 1km further from the airport. The 57dB contour is shorter, however, to the west, and while in the EIS the contour reaches a point some 13km from the eastern end of the existing runway, it now extends slightly over 11km from start of roll. In the contours for Option 7b there is also an extension of the 57 dB contour in the Kilreesk area and a shortening to the west of the airport.

3.3 2002/49/EC and SI 140 Representations were made to the effect that the EIS and subsequent material provided, and the proposals in general, did not accord with the requirements of the EU Environmental Noise Directive (translated into Irish law by SI 140).

3.4 Health Impact Assessment It was suggested that the Health Impact Assessment made was inadequate.

3.5 Trackkeeping The AIP for Dublin requires that departing Category C and D aircraft fly within a defined corridor. Information supplied by the applicants showed that a number of aircraft fly outside the boundaries of the corridor. While complaints at violations of the corridor are investigated, they do not necessarily result in action against the operators of the aircraft responsible.

3.6 WHO Guidelines References to the World Health Organization were made by Mr Searson and Mr Walsh. Mr Searson referred to a document written by Berglund and Lindvall “Community Noise” published in 1995; Mr Walsh to “Guidelines for Community Noise”. The latter document has been published on behalf of the World Health Organization by the Institute of Environmental Epidemiology, Ministry of the Environment, Singapore in 2000. The publication states that it is not a formal publication of the World Health Organization, and that the authors alone are responsible for the view expressed in this document, but it is widely referred to as the “WHO Guidelines”. It has no formal status in Ireland.

The WHO Guidelines contain a table of guideline values for community noise in specific environments which was referred to several times by third parties, and it was pointed out that in many cases the guidelines values were exceeded by existing and predicted noise from Dublin Airport.

3.7 L Amax

The noise predictions provided by the applicants, where they were in terms of LAmax, used the “S” or slow time constant whereas the WHO guidelines were stated in terms of LAmax using the “F” or fast time constant. It was stated that LAmax,F levels for the same aircraft noise event may be 3-5 dB higher than LAmax,S levels. Mr Sharps indicated a difference of 3 dB.

It was said that the “A-weighted” noise scale is inappropriate for assessment of noise with strong low-frequency content, and that this applied to aircraft noise.

3.8 Noise and schools A noise contour map was prepared by UPROAR and handed to the hearing my Mr Matthew Harley to show the effect of the proposed new runway on schools. The map was produced by transposing the applicants’ noise contours for night time in terms of LAmax,S for the existing runway 10/28 northwards by 1.7km and eastwards by 500m. The impact on schools was identified by reference to the WHO Guidelines.

3.9 The RANCH study and other research into the effect of noise on teaching On the day before the noise module at the oral hearing, questions were asked on Professor Stansfeld about the effect of noise on children in schools, based on the results of the RANCH study. This study showed an effect on children’s reading age and it was estimated that a 5dB (A) increase in noise was associated with a 2-month impairment in reading age in the UK and a 1-month impairment in reading age in the Netherlands. There was an exposure-response relationship between aircraft noise and annoyance. All other links between aircraft noise and children in schools were comparatively weak. Professor Stansfeld expressed doubts about the effective mitigation of the effects of aircraft noise on schools by sound insulation, particularly those with temporary buildings as classrooms, although the RANCH study excluded schools with good sound insulation.

The RANCH study referred to by Professor Stansfeld shows that annoyance starts to increase from about 57 dB LAeq upwards. The effect on reading score is less clear.

3.10 Noise and sleep Several third parties gave evidence about the effect of noise on sleep, principally by reference to LAmax,F noise level and the WHO Guidelines, to the effect that substantial sleep disturbance was caused by the existing airport, and that this, and any future extension of sleep disturbance was unacceptable.

3.11 Noise Insulation It was said that a planning condition similar to that attached to the Bord’s decision with respect to Kerry Airport8 should be attached to any permission for the current application.

4 MERITS of the issues raised 4.1 Is the application in conformity with the requirements of relevant

regulations and guidance?In answering this question, the considerations are (1) Is the EIS valid, i.e. does it contain all the information required by SI 600 and is the information of adequate quality? (2) Are the requirements of 2002/49/EC fulfilled and (3) What weight should be placed on the “WHO Guidelines”.

SI 600

As noted above, the requirements of SI 600 include in schedule 6 a requirement for a description of the likely significant effects of the proposed development. The EIS itself did not, as far as noise is concerned, expressly identify significant effects. Furthermore the Environmental Impact documents relied upon by the applicants at the hearing included many reports submitted after the preparation of the EIS, both in response to request for further information made by the Bord, and in additional material provided by the applicants. The applicants attempted to define significant effects in oral evidence to the hearing by their noise witness, although this was on the basis that because the proposed new runway would not be used at night there would be no effect at night. The answer to Information request 5 of 9 January 2007 makes clear that there will be an increase in noise at night in the unconstrained case, i.e. with the new runway. Since this information makes Mr Sharps’s evidence on significance at night inapplicable, information request 6 sought a specific answer on significance for night-time use of the existing runway when comparing “with development” and “no development”. A substantive answer to this request was not given. It was stated that “It is respectfully submitted that to provide an absolute figure attributable to ’significance’ is not equally applicable in all circumstances, having particular reference to the background noise.” No data have been provided about background noise. Furthermore the noise contours for 2025 with the new runway have been omitted from the response document. There is therefore no clear information about the significance of noise at night available to the Bord, and to this extent the requirements of The Planning and Development Regulations, SI No 600 of 2001 have not been satisfied.

Information request 4 asked the applicants to “detail a criterion for which ‘significant effects’ on schools should be assigned (a) without noise insulation and (b) with noise insulation.” The response was that the criterion is in terms of noise level alone and therefore independent of the presence or otherwise of insulation. The applicants

8 PL 8/5/89070 Planning Register Reference Number 1581/91

propose to offer all schools falling within the 60 dBA contour insulation necessary to achieve the 45 dBA internal noise level which they adopt as the significance threshold for internal noise. The units are not stated, but I assume that the reference is to LAeq 16h (0700-2300). If this is a correct assumption, the case for the use of an averaging period much longer than the school day, or of a lesson or examination period, is not made by the applicants. The inference intended is that there will consequently be no significant effect on schools. This of course assumes that (1) an external noise level of not more than 60 dBA (0700-2300) will result in internal noise levels of not more than 45 dBA during the length of a lesson or examination; (2) that all offers will be accepted; (3) that the insulation will be successful, which in turn assumes that internal environmental conditions in hot weather will be controlled so as enable the insulated windows to remain closed; and (4) that the effect of outdoor noise on school premises is not significant. While the technical basis of this position is clear, the Bord does not have information which enables it to be satisfied on points (1), (2), (3) and (4).

2002/49/EC

2002/49/EC is a Directive that places obligations on the governments of EU member states. It is only through SI 140 that its provisions have direct legal force in Ireland. The Directive requires that the following actions shall be implemented progressively:

(a) the determination of exposure to environmental noise through noise mapping, by methods of assessment common to the Member States;

(b) ensuring that information on environmental noise and its effects is made available to the public;

(c) adoption of action plans by the Member States, based upon noise-mapping results, with a view to preventing and reducing environmental noise where necessary and particularly where exposure levels can induce harmful effects on human health and to preserving environmental noise quality where it is good.

These requirements are implemented by SI 140 as follows.

The noise contours produced by the applicants as part of the EIS accompanying this application, and in response to subsequent requests for information are not noise maps as required by Regulation 10 of SI 140. The noise maps will be produced by the competent authority, identified in Regulation 7 as the airport authority, by 30 June 2007. Likewise, the action plan required by Regulation 11 will be produced by 18 July 2008 subsequent to the production of noise maps.

The requirements of the Directive and SI 140 concerning the noise indices to be used in noise mapping, and the methods used for creating the noise maps, therefore do not apply to the production of noise contours in connection with this application.

The WHO Guidelines

The WHO guidelines have no formal status. The document itself though produced under the auspices of the WHO is not, as is made clear in the Preface, a formal publication of the WHO. Only when its guidance is repeated by governments in national laws, regulations and guidance does it have any kind of mandatory or formal status. That is not the case in Ireland.

4.2 The accuracy and adequacy of the noise contours submitted Several sets of noise contours were submitted by the applicants. These included the contours in the EIS, and the contours submitted in response to the requests for further information.

Since the contours and associated information obtained from the noise contour model are the basis on which the assessment of significant effects, as required by SI 600, is made, their adequacy and accuracy are of great importance. Four main matters were raised by third parties in this regard:

1) The appropriateness of the noise model2) The appropriateness of the noise indices produced using the model3) The accuracy of the contours in terms of the difference between the

predicted noise levels and measured noise levels4) The accuracy of the contours in terms of their representation of aircraft

approach and departure tracks.

The appropriateness of the noise model

The model used for generating the contours and associated information was the Integrated Noise Model, Version 6.1. This model is sold by the United States Federal Aviation Administration, and is widely used in the production of airport noise contours. It differs from the model used by the UK Civil Aviation Authority, ANCON, which is not made available to others by the CAA. The principal difference between the models is the database of aircraft noise levels and the method of computing SEL values from the database.

Whereas past methods of computing noise contours were at least nominally based on frequency weighting systems other than the A-weighted decibel, the use of A-weighting is now the basis of recommended methods such as ECAC.CEAC Doc. 299.

There are two potential causes of inaccuracy, inappropriate coding of the model and/or selection of options in the computation of contours and inaccuracies in the database. It is open to the user to accept default settings both as regards the database and the computation options and Mr Sharps confirmed that default settings were used. In particular, no allowance was made for dispersion of flight tracks either side of the nominal flight tracks entered in the model, and that the default settings for refinement and tolerance in the contour generation were used.

9 Report on Standard Method of Computing Noise Contours around Civil Airports, European Civil Aviation Conference, 2nd Edition, July 1997

The absence of dispersion causes the contours to be slightly narrower and longer than would be the case if dispersion were included. The refinement and tolerance settings used are the cause of the pointed ends and non-smooth shape of the contours.

In response to the Bord’s request for further information, the applicants provided information by way of calibration of the model in which comparisons were made between measured and modelled noise levels. At the oral hearing Mr Sharps advised that part of the information provided was wrong, and on behalf of the applicants withdrew pages 9 and 10 of the response document except for the first two paragraphs of page 9. This left only one table of comparisons between measured and modelled noise levels in terms of average SELs for each aircraft type with a warning that the measured data must be treated with extreme caution. In fact they were not averages since two figures were given for each aircraft. Mr Sharps explained that the reason for the caution was that Dublin Airport were still in the relatively early stages of familiarisation with the use of that system in relation to the production of contours via the INM link within that system and in the assessment of noise levels from the monitors. He had not studied the locations of the monitors.

Replacement information was provided in the response to Information Request 1 of 9 January 2007. As explained above, there remain two issues with the replacement data. One is the inconsistency of stating pairs of numbers for measured departure noise that are identified as average Sound Exposure Level. The other is the use of stage 2 departure profiles for the INM values even though a different departure stage may have been appropriate.

In the replacement data, the INM values for the East departures are in all but one case below the lower of the two measured values, by amounts ranging from 0.9 to 3.9 dB. For the West only two cases show underprediction. However, the replacement table does not serve well as a validation of the model given the use of uniform stage 2 departures. On the other hand it does not show the extreme divergence between measured and modelled noise levels that originally appeared in the ES.

For landings, the use of a standard approach for all cases is appropriate. There are two cases of under prediction under the heading East and three for West. The energy average of all the East INM approach noise levels matches the energy average of the East measured ranges. The energy average of all the West INM approach noise levels is 1 dB less than the energy average of the West measured ranges.

As emphasised by the Institute of Acoustics paper included in the response to the information request, a major potential cause of inaccuracy would be inappropriate coding of the model in terms of the take-off weights and stage lengths of the aircraft. However, since the test of significant effect is a comparison between forecast contours for future years, which must of necessity rely on forecasting of aircraft numbers and operating parameters, the inevitable errors involved in forecasting are such that refinement of assumptions about stage length and take-off weight would probably not improve the accuracy of contours based on forecast data.

The contours have two principal functions. One is to inform the decision-making process associating with determining the present application. The other is to determine entitlement to noise insulation or offers to buy properties in the future. For

decision making purposes, the contours now before the Bord are the only information available, and it is necessary to decide whether or not they are adequate to enable a proper decision to be made. For purpose of determining entitlement to noise insulation or buy-out, the applicants intend to use the results of operating the noise and track-keeping monitoring installation to update the contours every two years. The data from the monitoring equipment would take account of dispersion and render the future updated contours more accurate.

For the purpose of present decision-making, the critical matters are the test of significance as required by SI 600 and the necessary judgement about whether the proposals contained in the application will cause, after carrying out a balancing exercise, harm sufficient to warrant refusal of the application after taking into account the effect of planning conditions to limit or eliminate adverse significant effects of noise.

As noted above, the EIS does not explicitly quantify the significant effects likely to be caused by noise. The applicants, through their witness Mr Sharps, advised that the test of significance is, by day, the extent of the 63 dB LAeq contour. The applicants indicated, through their advocate Mr O’Donnell, that they would implement a planning permission that contained a condition limiting the use of the new runway in accordance with Option 7b, and that this would involve prohibiting the use of runway 10L or 28R for departures during the hours of 2300-0700. He further advised that his statements to the hearing about what the applicants will do are enforceable under Irish planning law.

On the basis of the evidence, it can be concluded that with a planning condition prohibiting the use of the runway which is the subject of the application, the runway which would be designated 10L/28R if brought into operation, between the hours of 2300 and 0700, would itself have no noise effect at night.

Evidence was given by several third parties concerning the effects of the use of the existing runways at night. Powers are not available to impose controls on the use of the existing runways and it is necessary to consider the consequences of permitting the current application with respect to the resulting effect on the use of the existing runway. As noted above, the noise contour for 2025 with the new runway was omitted from the response to the 9 January 2007 information request, as was a clear statement of the test of significance. However, the response to information request 5 did make clear that the number of night movements in the modelling period would increase from 45 to 65 in the constrained case and from 45 to 95 in the unconstrained case. In dB terms the change from 65 to 95 is 1.6 dB, assuming similar aircraft types and stage lengths. The EIS states at 16.1.2.35 and 16.1.2.36 that an increase in Noise Level of less than 3 dBA is imperceptible and that the above criteria “will be used to assess night-time noise impact”. Although these paragraphs were not relied on at the oral hearing nor in the response to information request 6, and they do not use the word significance, it can be inferred that there is no significant effect forecast at night.

There would be some exceptions to a night ban on runway 10L/28R, but the applicants made clear they did not now seek to include operational reasons as an exception, and it can be concluded that the number of occasions on which the exceptions would result in night time use of 10L/28R would be very small.

This leaves the matter of the effect of the use of the new runway in the day and evening, between 0700 and 2300. Option 7b, which, as already stated under consideration of night noise is an option which the applicants offered as a basis for planning conditions, involves preferential use of the southern runway 10L for easterly departures and westerly arrivals. As a consequence, the principal effect of the new runway would be to the west of the proposed new runway

The effect of operating the proposed runway needs to be regarded from two points of view. The first, offered by the applicants as the method of quantifying the significant effect due to noise, is to count the number of people and properties within the 63 dB LAeq contour. The second is to look at the change in noise exposure for particular locations, including St Margaret’s. The applicants did not state noise change as a measure of significance.

At the conclusion of the oral hearing I concluded that the people and property count figures before the hearing were unreliable and could not form the basis of a decision. Revised figures have been provided in the response to Information Request 3 of 9 January 2007. The revised data show an increase in the number of households within the 63 dB contour from 112 to 185 between 2007 and Option 7b 2025 high growth. The number of persons within the 63 dB contour increases from 336 to 439 between 2007 and Option 7b 2025 high growth. The table assumes that the size of the household decreases between 2007 and 2025 from 3 persons to 2.3 below the 69dB contour.

However, the EIS states10 that the 63 dB LAeq 16hr contour represents “moderate annoyance”, and that the onset of disturbance – “low annoyance” is represented by the 57 dB contour. The revised data show an increase in the number of households within the 57 dB contour from 1801 to 3225 between 2007 and Option 7b 2025 high growth. The number of persons within the 57 dB contour increases from 5403 to 7431 between 2007 and Option 7b 2025 high growth.

4.3 Effects on individual schools A noise contour plan was put in to the hearing by third parties with a view to showing the effect of the proposed new runway on schools in the area. The contour was prepared by taking the applicants’ contour for LAmax for the existing runway and transposing it 1.7km to the north and 500m to the east. However, if planning conditions were imposed that had the effect limiting operations to those of option 7b, this transposition would not occur, because aircraft movements over the area to the east of the proposed new runway would be severely restricted.

By inspection of figures ABP-RFIQ2a, ABP-RFIQ2b and ABP-RFIQ2e it is evident that the noise at St Margaret’s will decrease 66 dB LAeq for 2003 to approximately 63 dB LAeq for 2025 without the second runway and be 66 dB LAeqfor Option 7b (though the contour is in this case associated with the proposed new runway). Being over 60 LAeq St Margaret’s will qualify for noise insulation according to the applicants’ noise mitigation proposals.

10 EIS Dec 2004 Page 292

By inspection of figures ABP-RFI Q 2b and ABP-RFI Q 2e, the schools in Swords, Malahide and Portmarnock, and St Nicholas of Myre School will experience an increase in noise. The increase is greatest to the north, and in Portmarnock the 48 dB contour in ABP-RFI Q 2b is, in places, in a similar location to the 54 dB contour in ABP-RFI Q 2e. Although this is a 6 dB increase, it is not great enough to trigger noise insulation. The 60 dB contour in ABP-RFI Q 2e appears to include St Margaret’s School, to come close to St Nicholas of Myre and include no other schools. Despite this, the applicant’s noise mitigation scheme (reference 4) states that Portmarnock Community School, River Meade, St Nicholas of Myre and Malahide Road schools will receive insulation. It states that St Margaret’s has already been insulated under the existing scheme.

4.4 Ground Noise Engine testing

The case advanced by the applicants concerning the variation sought in condition 11 contained no noise evidence. It was to the effect that the airport would be severely restricted if they are required to move the engine testing before the new runway becomes operational. The remainder of the condition is acceptable to the applicants.

Since no noise reasons were given for seeking the change in condition 11, no discussion of the issue is possible in this report.

4.5 Taxying and APUs etc The matter of provision of ground power facilities to avoid the use of APUs was raised by Ms Lawton, but since no permission is sought in this application for extensions to apron or stand facilities, the opportunity to impose a planning condition of this kind does not arise.

With regard to taxying noise, Mr Kelly corrected the information given on page 22 of reference 7 and further corrections were provided in the response to the Information Request of 9 January 2007. Reference 7 states that where appropriate the noise insulation programme and property buy-out schemes operated by the DAA should be considered.

4.6 Construction Noise The EIS contains no predictions of construction noise, but predicts that “due to the nature of the activities undertaken on a large construction site, there is no potential for generation of significant levels of noise”. Mr Damian Kelly said that he would consider that a condition based on the proposed noise limits in his evidence, in turn based on the National Roads Authority Guidelines11 would be appropriate noise limits. The levels would not continue for a long enough period to warrant inclusion in a noise insulation scheme.

5 Conclusions The EIS does not contain an assessment of significant effects as required by SI 600 of 2001. Evidence about the thresholds of significance was given at the Oral Hearing, and information about significant effects on schools was included in the response to

11 Guidelines for the Treatment of Noise and Vibration in National Road Schemes (Revision 1, 25 October 2004)

the 9 January 2007 Information Request. It a matter of law whether evidence to the Oral Hearing satisfies a requirement for information to be included in an EIS, and whether responses to Information Requests constitute inclusion in an EIS. If not, it would of course be unlawful to permit the application.

The remainder of my conclusions are made in case the Bord’s legal advice is that the requirements of SI 600 of 2001 have been satisfied.

The comparison between predicted and measured noise index values showed a variation between the two sets of data. While the variation reported is not out of line with that found in transportation noise prediction methods in general, the contours should not be regarded as a precise statement of the predicted noise effects in absolute terms, but since the factors which cause a divergence between real and predicted noise are to a large extent common to both the no-development and Option 7b contours, I consider that they do provide a basis for comparative assessment of the two scenarios. This assumes that the applicants’ air traffic forecasts are a suitable basis for such a comparison.

The applicants’ evidence to the oral hearing, in terms of the significant effects of the scheme, was that there would be a large reduction in the number of houses and people affected by noise when comparing the 2025 noise impact with Option 7b and with no development. This conclusion was reversed by the response to the Request for Information of 9 January 2007, to a position that within the applicant’s “significance” contour the number of persons increases from 336 to 439, and the number of houses from 112 to 185, between 2007 and Option 7b 2025 high growth.

I conclude that the proposed development will result in an extension of the significant effects of noise as indicated by the population counts given. These increased population figures take account of the reduction in the use of runway 16/34. This conclusion is predicated on confinement of the use to Option 7b and a ban on the use of the proposed new runway between the hours of 2300 and 0700. This will be partially offset by the noise mitigation scheme as a result of the extension to the noise insulation programme, the buy-out scheme and the scheme for noise insulation of schools, but outside the limits of these schemes there will be an increase in noise exposure for the people affected.

The fact that there will be an increase in noise for several schools will potentially have an adverse effect on children in the schools. The applicants’ approach is that this is mitigated by the noise insulation scheme for schools, although there remain technical and practicability issues associated with the provision of satisfactory noise insulation for at least some designs of school building. There will be an increase in noise for schools outside the limits of the scheme.

The applicant has proposed mitigation in the cases it identified at the Oral Hearing or in responses to Information Requests as significant effects. Other parties have not challenged the applicant’s significance thresholds. However, the applicants themselves have identified the 57 dB contour as delineating the onset of annoyance. There would be a large increase in the number of people included within this contours as a result of the proposed development, not benefiting from sound insulation or buy-out. The Bord will wish to be satisfied that if the development is permitted, such an

increase in the population annoyed, and uncertainty associated with mitigating the effect on schools, is counterbalanced by other non-noise advantages.

In the absence of counterbalancing advantages, which are outside the scope of my report, I do not consider that the applicants’ mitigation proposals would offset the effects of noise from the development sufficiently to leave no residual significant effects. It follows that on strict grounds of noise alone, the application should in those circumstances be refused.

6 Conditions If permission is granted, I recommend inclusion of the following conditions.

The runway hereby permitted shall not be used except in accordance with Option 7b as defined in the Environmental Impact Statement Addendum, Section 16, and accordingly:

the runway (10L/28R) shall not be used for takeoff or landing between the hours of 2300 and 0700;

no departures on runway 10L shall take place at any time;

except in cases of safety, maintenance considerations, exceptional air traffic conditions, adverse weather, technical faults in air traffic control systems or declared emergencies at other airports.

A system of monitoring of aircraft noise and track-keeping shall be operated at all times and used for the preparation of annual airport noise contours in accordance with the recommendations of ECAC.CEAC Doc. 29 or as amended or replaced.

The runway hereby permitted shall not be brought into use until a scheme for enforcement of breaches of the requirements of the noise abatement procedures set out in EIDW AD 2.21 or as amended or replaced by the Irish Aviation Authority has been submitted and approved by the planning authority. The scheme shall be operated at all times after the runway is brought into use.

The runway hereby permitted shall not be constructed until a scheme for the voluntary noise insulation of schools has been submitted to and approved by the planning authority to include all schools predicted to fall within the contour of 60 dB LAeq 16h with 12 months of the planned opening of the runway to use. The scheme shall include an annual review of the schools eligible for insulation. Noise from aircraft ground activities such as taxying, engine running by a stationary aircraft or the use of auxiliary power units shall be included in the determination of the noise level.

The runway hereby permitted shall not be constructed until a scheme for the voluntary noise insulation of dwellings has been submitted to and approved by the planning authority to include all dwellings predicted to fall within the contour of 63 dB LAeq 16h with 12 months of the planned opening of the runway to use. The scheme shall include an annual review of the dwellings eligible for insulation. Noise from aircraft ground activities such as taxying, engine running by a stationary aircraft or the use of auxiliary power units shall be included in the determination of the noise level.

The runway hereby permitted shall not be brought into use until noise insulation approved under conditions [X] and [X] has been installed in all cases where a voluntary offer has been accepted within the time limit of the scheme.

The runway hereby permitted shall not be brought into use until an offer of voluntary purchase, on the valuation basis that the dwellings were subject to compulsory purchase, has been made to the owners of all dwellings predicted to fall within the contour of 69 dB LAeq 16h with 12 months of the planned opening of the runway to use. The scheme shall include an annual review of the dwellings eligible for an offer of purchase. Noise from aircraft ground activities such as taxying, engine running by a stationary aircraft, or the use of auxiliary power units shall be included in the determination of the noise level.

Construction of the runway hereby permitted shall not be commenced until a scheme for aircraft engine testing at the northern end of the airfield to cease and be relocated way from populated neighbouring areas to a location has be agreed in writing with the planning authority. The scheme shall be operated at all times after the runway is brought into use.

No construction work shall be carried out except when the noise levels do not exceed the maximum permissible noise levels at the façade of occupied dwellings set out in the National Roads Authority publication “Guidelines for the Treatment of Noise Vibration in National Road Scheme (Revision 1, 25 October 2004)” or as subsequently amended or replaced.

Yours sincerely,

Rupert Thornely-Taylor