I have made the following submission to the consultation in advance of the drafting of a Local Area Plan for Dublin Airport:
Climate Change and aviation growth
The analysis of climate change in the document is inadequate. The National Mitigation Plan should be included in the policy documents listed on page 8.
The paper discusses a few minor aspects but doesn’t address the central issue, increasing aviation emissions. The reference to the EU ETS is an inadequate summary description, misleading in that it doesn’t acknowledge that the ETS only applies to flights within the EU.
The predictions of aviation growth seem to be predicated on action not being taken (in Ireland or internationally) to give effect to the Paris Agreement.
The analysis of climate change should include the differential climate impacts of aviation emissions at different times of the day.
The discussion of surface access seems to be oriented solely at passengers. The paper itself refers to over 13,000 jobs at the Airport; their travel needs and patterns also need to be considered. The analysis needs to consider the ability of public transport to meet far more of the airport travel needs. Given the dispersed nature of airport employment which can be hard to serve by public transport, there should be a specific study for the LAP of the potential to use cycling to meet travel demands.
The airport and associated uses including car parking are polluting local rivers and streams. In keeping with the obligations in the Water Framework Directive, the LAP must address how this pollution will be prevented.
The airport is a major source of noise for local residents, with consequent health and social impacts. The LAP, based on solid scientific analysis, must address how noise emissions can be reduced. This includes in particular preventing night-time noise and sleep disturbance which have significant impacts on health.