Category Archives: Airport / Aerfort

Submission to draft Airport Local Area Plan and Development Plan Variation

I made this submission to the public consultation on the draft Dublin Airport Local Area Plan and on the associated draft Variation to the County Development Plan. It refers back to my previous submission on the draft Local Area Plan and deals in particular with issues of climate change, noise, cycling access and water quality.

Letter to Fingal County Council in relation to Dublin Airport Third Runway

The Austrian Federal Administrative Court recently rejected plans for a third runway at Vienna Airport because it would have a negative impact on greenhouse gas emissions and would be contrary to Austria’s international obligations to tackle climate change.

I wrote to Fingal County Council drawing their attention

a) to the conflict between building a third runway at Dublin Airport and Ireland’s climate change obligations, and the Council’s duties under the Climate Action and Low Carbon Development Act 2017; and

b) to the fact that Dublin Airport Authority are applying to extend a permission they are simultaneously trying to alter, which I and many local residents suffering and expected to suffer from nighttime noise from the airport consider to be acting in bad faith.

My letter and attachments 1  and 2.

aviation-climate-change

Amendments to County Development Plan

Fingal County Council is currently preparing the County Development Plan to run from 2017 to 2023. The Draft Plan was on public display between February and April 2016 and a report on the over 900 responses received was supplied to Councillors at the end of July.

As Councillors we had until yesterday, 6th September, to draft proposals to amend the Plan based on the public consultation.  Those  amendments which the Council agrees to will go on public display in November.

I submitted amendments to a wide range of topics in the plan. A copy of my proposed amendments is here. In order to make them easy to navigate I have grouped them into the following topics:

  • On Special Amenity Area Order and Dublin Bay Biosphere Reserve
  • On cycle pedestrian routes to be added to the map
  • On public transport reservation from Clongriffin/Portmarnock – Balgriffin – Belcamp – Clonshaugh to metro reservations south of Dublin Airport
  • In relation to the Moyne Road bypass proposal based on discussions at the previous stage of the Development Plan and in response to submissions by the developer of the adjoining residentially zoned land and Portmarnock Community Association
  • On the zoning of the industrial estates beside Howth Junction railway station based on issues I raised at the previous stage of the Plan and a submission from a local business.
  • On the process for sub-county level plans based on the experience of Fingal councillors and citizens as well as submissions from public authorities including the National Transport Authority
  • Based on Fáilte Ireland’s submission
  • In relation to the circular economy and sustainable resource use
  • In response to the submission by Keep Ireland Open, Fáilte Ireland and others concerned with access to the countryside
  • Based on concerns about Fingal’s approach to open space in high density development, an issue raised both by developers and residents
  • On the transition to a low carbon climate resilient economy, a legal obligation of the Plan under the Climate Action and Low Carbon Development Act and raised in a range of submissions
  • On adaptation to climate change
  • On Ecosystem Services Approach
  • Transport motions based on a range of submissions by local road users and public transport users and the NTA
  • Motion incorporating text from the Dublin City Development plan in relation to cycle parking as recommended by the submission from the National Transport Authority
  • In relation to cycling in response to a wide range of submissions seeking better and safer cycling insfrastructure.
  • Based on text in the National Cycling Policy Framework, to which some of the submissions refer.

Observation to Dublin Airport Authority on proposed removal of nighttime noise restrictions

Dublin Airport Authority carried out a consultation in relation to the Environmental Impact Assessment of a proposal to remove the conditions in a permission they received from An Bord Pleanála which would restrict night time flights in order to enable local residents to sleep soundly. Exactly how they would apply to make such a change has not been explained despite direct questions.

I made the following submission:

1. The public is entitled to know what sort of application DAA is apparently planning to make, especially if we are being consulted on it.
For many months now, residents and public representatives have been hearing that DAA will be applying to change the planning conditions. However, we have not, despite repeated requests been able to understand whether this is a planning application or some other form of application. My request under the Access to Information on the Environment Regulations directed at obtaining this information also failed to clarify it.
Some sort of legal stratagem is presumably being developed. The fact that the public is being asked to participate in a consultation process where relevant details of the overall decision-making process are apparently being withheld is worrying. This is particularly the case when it is the ability of local residents to live normal lives and get a proper night’s sleep that is at stake.
2. DAA should not assume that it will be legally possible to make an application of whatever unspecified form which would relate only to two conditions of its planning permission given the passage of time since the granting of that permission, the fact that it has not commenced work on the permission and the requirements of the Environmental Impact Assessment Directive.
3. Analysis of aviation demand must take account of the need to reduce greenhouse gas emissions drastically and rapidly in order to avoid dangerous anthropogenic interference in the climate system, as set out in the UN Framework Convention on Climate Change and the Paris Agreement. Predictions of aviation demand must incorporate anticipated and necessary measures to reduce emissions including measures to control demand and measures which would change the makeup of the fleet using the airport.
4. DAA has misled itself in concluding that it is not subject to the Climate Action and Low Carbon Development Act 2015.
5. Analysis of demand for night time take off and landing must set out the degree to which this is stimulated or discouraged by pricing as well as the degree to which it results from measures taken at airports elsewhere to protect their neighbours from night time noise.
6. Alternatives examined should include the use of other airports in Ireland as well as technical alternatives, alternative modes of transport, and alternatives to transport.