Re. Planning Application F23A/0781: An increase in the capacity of the airport from 32 to 40 million passengers per annum and associated Project Elements, Dublin Airport Co. Dublin, Applicant name DAA PLC

Dear Mr. McAleese,

I write to request that this Planning Application F23A/0781 is rejected as it will increase noise exposure from aircraft to residents of greater Dublin and cause a significant increase in greenhouse gas emissions. During a climate emergency, it is an act of folly to propose expanding airport passenger numbers by 25%.

I note that the Fingal County Development Plan supports growth of the airport, however it states that this must be ‘consistent with Sustainable development principles’ and ‘Appropriate noise and environmental measures designed to protect public health’. (Chapter 8.2, p. 316). The applicant fails to demonstrate that the proposal represents sustainable development or will protect public health.

Fingal County Council’s Dublin Airport Local Area Plan 2020 states “Climate change is one of the most pressing global public policy challenges facing governments today. This LAP recognises that objectives to facilitate increased passenger numbers at Dublin Airport must be considered in the context of the need to reduce carbon emissions and safeguard the environment in which the Airport is based.” (Chapter 5.0 p. 32). An increase in flights will manifestly increase emissions.  

Fingal County Council’s Climate Change Action Plan 2019-2024 states “The Council recognises the Climate Emergency as declared by the Dáil and commits itself in this plan to prioritising mitigation of, and adaptation to, climate change across its functions.” (p.9) An increase in flights will increase emissions significantly and fail to mitigate climate change.

The Irish Government’s Climate Action Plan ‘Changing Ireland for the Better’ 2023 states regarding the Commercial Semi State Sector that semi-state entities should achieve a “51% overall reduction in greenhouse gas emissions by 2030 and reach net-zero no later than 2050”. To be meaningful this figure must consider Scope 3 emissions that result from the infrastructure that is proposed by semi-state companies. Clearly airport expansion will fail to achieve a 51% reduction in emissions. 

At European Union level the adoption of the Refuel Aviation Regulation, a law to increase the uptake of Sustainable Aviation Fuels (SAFs) has passed into law. However, the requirement for the use of SAFs is only 5% use by 2030, 20% by 2035 and 32% by 2040. SAFs are not zero-carbon, and even if these targets are met, they would fail to achieve aviation emission reductions commensurate with Ireland’s obligations under the Paris Agreement. 

A decision of the Aircraft Noise Competent Authority (ANCA) Notice ANCA/0002/2024 of 17 January 2024 states that the planning application will need to be assessed for the need for a noise-related action. An additional eight million passengers per year would be an intolerable increase in noise exposure to Dublin residents, and that mitigation would not sufficiently tackle the noise pollution, and in particular night-time noise.  Regarding night-time noise, I note that the DAA appears not to be compliant with existing Planning Conditions for noise control from previous Planning Applications.

Local traffic conditions will worsen if the planning application is granted. This will lead to an increase in surface traffic congestion, and a commensurate increase in local air pollution for communities in North Dublin from such traffic. Such concerns have been insufficiently addressed in the supporting documentation for the Planning Application. It seems that the modals shift to sustainable transport set down in both national and local policy guidance will not be achieved. The proposals for walking and cycling infrastructure are poor, and it is unclear as to whether the proposed development will follow the requirements laid down in the European Union’s Alternative Fuels Infrastructure Regulation. The prioritisation of private car infrastructure appears excessive. 

I note that the greenhouse gas emissions Carbon Offsetting and Reduction Scheme for International Aviation, or CORSIA, aims to stabilise CO₂ emissions at 2020 levels by requiring airlines to offset the growth of their emissions after 2020. However, it is likely that insufficient offsets will be available to cope with the anticipated increase in demand from such growth.

Local air pollution is also a concern arising from the proposed increase in passenger numbers. The European Aviation Safety Authority has stated that: “While a major source of air pollution in the vicinity of airports originates from aircraft operations, air quality is also impacted by ground support equipment, surface access road transport and airport on-site energy generation. Aircraft engines produce similar emissions to other sources of fossil fuel combustion with the most significant being nitrogen oxides (NOX), particulate matter (PM), volatile organic compounds (VOCs), sulphur dioxide (SO2), carbon monoxide (CO) and unburnt hydrocarbons (HC).” It seems likely that local air quality in the residential communities adjacent to the airport will deteriorate to a significant degree if this expansion proposal is approved.

I therefore request that the Planning Application is rejected. 

I enclose the €20 fee for this Observation and ask that you acknowledge this observation in writing. Thank you for taking these comments into consideration.

Sincerely yours,

Ciarán CUFFE

MEP for Dublin