An Bord Pleanála



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Condition number 28

Mr. Flanagan referred to a discussion document the planning authority had prepared, and read the Condition number 28 as revised.




  1. Combined passenger throughput at T1 and T2 shall not exceed 35mppa

  2. At or before combined passenger throughput at T1 and T2 reaches 28mppa the applicant shall submit to the planning authority detailed proposals regarding the planning, design and delivery of T3, and associated structure in consultation with third parties if necessary

The council did not wish to proceed with this paragraph as it would be difficult to interpret (it would stray into non-planning considerations)

They would also propose an additional condition in relation to passenger experience T1
No later than 12 months after commencement of operation of T2, works to improve passenger experience and to re-balance passenger throughput within T1 shall commence and be completed within 36 months details of these works shall be submitted to the planning authority ....in the context of combined passenger throughput of T1 and T2 not exceeding 35mppa … (exhibit ..03/05/07)

He referred to the application letter from Tiros (31/08/2006) which had estimated annual passenger traffic to be 30mppa. It had also identified that T2 and pier would take the operating capacity to 35mppa when completed.


The EIS had indicated in a number of occasions (prg 2.2.1, ) that the capacity would be 35mppa

Under the planning acts the planning authority would had duty to secure the objectives of the development plan. They did not accept in any way that the LAP was prescriptive in relation to a cap of 30mppa.



Secondly their assessment of the adequacy of the EIS was based on the proposal put before the planning authority, where it was put that the combined passenger throughput would be up to 35mppa. To be consistent with policy documents, adjudication on the application put before them and adjudication on the EIS put before them were the main considerations.
Rachel Kenny, confirmed the comments by Mr. Flanagan. The application was assessed on the basis of 35mppa as put before them, and in the context of County Development Plan and LAP. They would have particular regard to terminal and piers objectives which required improvement and augmentation of facilities in T1 and T2 but also advancement of T3. They did not consider 35mppa to as a figure prejudicing advancement of T3 in due course.
Ms. O’Brien asked if the western campus would be the balance i.e 25mppa, with eastern campus at 35mppa. The planning authority responded that they did not know what would happen beyond certain levels. Economics, aviation taxation etc could easily effect the passenger figures. They did not know if it would get anywhere near 60mppa.
Mr. Foley was not saying 50mppa was their absolute upper limit changes in aircraft size would bring it higher. No body could predict future.
Sean O' Faircheallaigh stated that there were two principles behind the LAP one was flexibility the other was protection of what need to be protected so that the airport could reach its full potential.
Ms. O Brien said if the planning authority put as much effort to protect the people it would be a far better place to live.
Mr. Byrne restated that talking about campuses, and terminals was premature in the absence of examination of national aviation strategy for provision / location of airport infrastucture in the country as a whole.
Mr. Harley agreed with Mr. Foley that it was not possible to have certainty regarding capacity. The high growth scenario had indicated 53mppa which he thought was reasonable. He referred to an article where ESRI had stated ( in relation to transport) that there was no comprehensive analysis of alternatives, consideration of do nothing was not enough. Same thing applied here.
Mr. Manahan agreed with the trust of the plan to provide a balance both in terms of campuses and in terms of roads access, and two spread the traffic both air and surface between two runways, two campuses, different access. They were concerned that the proposed development would affect this balancing act and the western campus may never happen.
Simone Kenny for Ryanair supported the condition number 28, but drew attention to LAP which stated 30mppa as the capacity. She suggested revisions to condition number 28 so that passenger throughput of T2 does not exceed 10mppa and T2 when added to T1 does not exceed 30mppa. They agreed with omission of part c. This avoid destruction of Corballis House and improve the traffic situation.
Mr.Sweetman said the original condition no 28 was a proof of project splitting by condition. It was quite clear the planning authority was not happy with the proposed development, and was using a condition to encourage project splitting. The amended condition and suggestion by Ryanair were both illegal. They were both requiring submission before planning.
Ms. Sheila Morris referred to earlier reference to protect what needs to be protected, and the correspondence they had received from the planning authority and DAA. Presenting a map, showing how the roads indicated on the same would take out a number of their houses. The OS maps they received from DAA had blank sections (such as emergency access which went right through their homes. (Alternative routes, Scott Wilson report, emergency roads) these were not shown on the terminal application.
She referred to a number of letters they received (including that in April 2006), references to special policy area for St. Margaret’s area without any follow up, e-mail received following a meeting indicating that it was only a ‘conversation’, she stated that they were being treated as ‘nothing’ by DAA but also by Fingal County Council.
Mr. O’Donnell stated they had no problem with condition number 28 as revised by the planning authority. He agreed that sub paragraph (c) would not be appropriate.
They had made an application for 35mppa, and were bound by what they had submitted.
He was surprised by Ryanair suggestion in relation to limits. What was suggested was impossible to operate having regard to the fact that there were two major airlines operating. Balancing of two terminals was appropriate.
His concern was related to the language of (a) providing an absolute figure. he said development of western campus could be provided through other conditions. He suggested the condition should be more aspirational rather than prescriptive.
Mr. Sweetman stated that they opposed to further development of the airport as a whole. They opposed to another runway and to another terminal.
In response to question by Mr. Harley in relation to use of the DTO model, J. Ryan stated that they were certifying the use of the model and methodology.
Air Quality

(24/04/07,
This module was conducted in two separate days to facilitate absence of Mr. Flanagan, Counsel for Fingal County Council. In the first day the planning authority was represented only one person, solicitor (Mary …) who would take note of the proceedings to report back.
The first party brief of evidence (exhibit V-24/04/07) was presented by Michael Bailey, environmental consultant.
In response to question by Ms. O’Brien (referring to first page of document distributed entitled ‘Ambient airside quality Report, document control sheet, X-24/04/07) , Mr. O’Donnell stated that there was no additional or specific requirement on Dublin Airport as a distinct authority, and the same ‘law’ as everyone else applied.
Reading from a written evidence Mr. Bailey stated that he had prepared the impact assessment reports on air quality and climate change both for the runway and terminal cases.
The assessment undertaken of the likely impact on local air quality arising from atmospheric emissions was examined in two stages, namely construction and operation of T2.
The former included clearance of the ground, and haulage of materials. The impacts during operational phase were associated with road traffic and aircraft movements. A number of measures were planned to reduce dust and particulate PM10emissions.

There was an existing air quality monitoring programme independently carried out for the DAA at 11 locations, to survey Nitrogen Dioxide, Sulphur Dioxide, benzene, carbon monoxide, particulates PM10 since 2002.


The monitoring network included a number of locations in the locality of the airport such as Forest Little and St.Margaret’s as well as further a field at Kinsealy, Swords and Portmarnock.
The survey was extended to 13 locations in 2006, and was also extended to include ozone measurements and PM25 at certain locations near the airport.
The results for 2005 and 2006 showed that they did not exceed the levels set in NAQS (National Air Quality Standards) (statutory instrument 271 of 2002)
The construction of T2 and Pier E would result in emissions of dust, and PM10 from the construction area including new construction access roads, and concrete crashing and batching plant. In view of proximity of T1 and aircraft it was important to control dust emissions to ensure no risk to aircraft operations. The submission provided a number of control measures, such as hard paving of access roads to reduce dust emissions, wheel wash, covered trucks, and various dust suppression measures.
To predict the impact of emissions during operational phase a detailed air quality dispersion model was used, for the forecast years of 2012 and 2024 for ‘do nothing’ and ‘do something’ scenarios.
The emission data was derived from aircraft movements, ground traffic and boiler plant were compiled for the forecast years. The model predicted ground level concentrations of Nitrogen Dioxide, hydrocarbons, (benzene), carbon monoxide, particulates PM10. in the locality of the airport and adjacent to the motorway and local roads around the airport.
Emissions from aircraft were derived from LTO (Land and take-off cycle) using different aircraft and engine categories with estimates of times for LTO. The number type and category of aircraft using runways was supplied by DAA (a total of 28 aircraft categories ranging from large Airbus 340 and Boeing 767 to medium and small jets and turboprops).
Road traffic emissions for M50 and M1 were derived from traffic prediction models developed for the project (projected mean peak morning number of cars, commercial vehicles and speeds for 2012 and 2024 scenarios).
Emissions were also derived from ground support vehicles operating near the terminal and boiler plant complex and planned CHP for T2.
The results of the study demonstrated that there was no significant difference between the ground level concentrations for ‘do nothing’ and ‘do something’ scenarios for T2.
Going through each of the emissions, he concluded that predicted ground level concentrations within the airport boundary did not exceed NAQS.
The highest levels were predicted near the M1 and M50 and high along the main roads in the locality.
In conclusion the results of the modelling study demonstrated that the predicted increase in ambient concentrations in 2012 and 2024 due to T2 would not have significant impact within the adjoining communities or on the local environment.
For the operational phase, traffic management would be in place to reduce congestion on the approach roads to the terminal so as to reduce vehicle emissions within airport complex.
In response to third party assertions that a health impact assessment should have been undertaken, he stated that the health impacts in relation to air quality have been dealt with in the context of compliance with NAQS which provided limit values for each.
The methodology used in the EIS to assess the exposure risk to the local community around Dublin had examined the current ambient air quality based on monitoring results from the sampling network operated independently for DAA. To evaluate future air quality impacts a detailed dispersion modelling study was carried out based on road transport, aviation emissions and emissions form the airport complex, and the results were compared with current and future NASQ.
This type of evaluation procedure demonstrated the community health risk in terms of predicted or monitored airside pollutant concentration and these valued could be compared to the relevant airside quality limit value.
The results of the airside quality impact study for T2 indicated that the predicted impact emissions associated with the development did not have significant impact on the local air quality, and therefore a more intensive investigation of potential health impact from atmospheric emissions, by undertaking a Health Impact Assessment was not warranted for this development.

The planning authority had no comment to make but referred to condition number 35.



Questions and clarifications



Ms. Lawton stated that the data presented was out of date.
Mr. O’Donnell (DAA) stated that the date the report completed was 2006, but it included the year before. They were compiled annually, but he would try to get a report for the first half of the year.
Mr. Bailey had looked at a preliminary look at the monitoring results, they were below the impending Ozone Directive and similarly PM 25 were below ( he noted aircraft activity would not create the latter).
Ms. Lawton referred to a document in relation to airside quality around airports (W-24/04/07) and stated that it was very significant to the communities living around Dublin Airport. She noted references to high levels near the roads, stated that the proposed development was increasing the amount of traffic coming to Dublin Airport and increasing the number of car parks.
Most emissions occurred during take offs, effecting communities. There was no safe level for benzene. She referred to several individual readings and submitted they needed all the data, not selective. There was a sea breze along the cost between malahide and Portmarnock.
She asked for a list of all the aircraft types allowed to land and take of at Dublin Airport. While they were told Ryanair was renewing its fleet, charters were using old dirty aircraft. Mr. O’Donnell would try to find out. She said it was not enough not exceeding limit values on an annual basis.
Mr. Bailey repeated aircraft was not source of particulate emissions. Highest concentrations were near the M1 and M50. Near Portmarnock and Malahide it was due to burning of fossil fuels and cars, not related to Dublin Airport.
Mr. Bailey explained how the NAQS were set. The benzene levels of 5microgram referred to by Ms. Lawton was below the levels set.
Sea breeze did not stay static and unlike certain areas where it moved up and came down again, this did not happen in Dublin. Portmarnock was 7km from Dublin Airport, and the sea breeze was coming at an angle, and would not have any significant impact on any of the other communities around airport. It only impacted if there was a yo-yo effect (rise above, go to sea and then come back down on the coastal community, this did not happen in Dublin area)
The aircraft were well above a 500m above Portmarnock. (Poolbeg chimneys were 220m high). Mr. Byrne asked why he could smell kerosene, and films on the cars (dumping of fuel). Mr. Bailey said dumping of fuel could only happen far away from settled areas.
There were monitoring stations at Portmarnock, (toscar patha, GAA grounds). Ms. Lawton asked for a monitoring station at the coast, between Portmarnock and Malahide. She said benzene 558 was a quarterly result.
She asked for a list of gases coming out of the 30m high chimney stack at energy centre. Mr. Bailey said it was going to burn natural gas as in domestic uses. No there would not be heat pump.
In response to question by Ms. Lawton he said one needed very high levels of pollutants ‘Synergistic’ effects in air quality terms. This was not the case here. To have effects on lungs etc it had to be in very high levels.
Ms. Lawton said four local authorities were opposing to another runway at Heathrow, because of health effects on communities. Mr. Bailey said it was of a very different scale.
In response to statement by Ms. Lawton regarding high levels near other UK airports, he said he had looked at the results of monitoring carried out by independent consultants, and used NAQS. EPA used the same standards.
The monitoring locations were chosen to represent different local communities, end of the runway, rural, urban, locations and near Portmarnock. He said he did not carry out the monitoring, but was happy with what they did. Currently it was Bord Na Mona. He had done various ones including for air quality monitoring for Dublin, he had seen no reason for concern.
Mr. O’Donnell presented the uncertified 2006 figures compiled so far as asked by Ms. Lawton (Y-24/04/07).
In response to earlier question by Ms. O’Brien regarding last paragraph of first page of the document entitled ‘ Dublin Airport Ambient Airside Quality Report 2005’ Mr. O’Donnell agreed the wording was not the best, but they were trying to say that there was no requirement on DAA to carry out monitoring.
Ms. O’Brien asked who had the responsibility. Mr. O’Donnell referred to EPA Act, Air Pollution Act, and said local authority and EPA would be the authorities.
Mr. Sweetman said engine testing issue was not resolved, that issue was raised at the runway hearing.
Inspector reiterated that this hearing was concentrating on the air pollution issues arising from landside activities, as the other hearing would cover pollution arising from airside activity in more detail.
Mr. Bailey said the air dispersion model carried out for runway included the same road links, as such the cumulative effects were considered.
Ms. O’Brien asked if he had looked at the traffic as a result of T2. Mr. Bailey was given the traffic figures for the year 2024.
Mr. Harley said the figures were underestimating the current levels. The centre line projections were not adjusted to reflect the latest numbers (should be at least 5% higher).
Mr. Bailey said the information was supplied by DAA for the aircraft movements, he had used the high growth scenario.
Mr. Harley accepted that would be closer to reality. In terms of traffic he thought they would be higher than presented.
Mr. Bailey had taken vehicle speeds into account in the modelling exercise, and during am peak (two-way).
Mr. Byrne said as the monitoring station at GAA referred to earlier was not surrounded by houses, but located in a green belt, it was an indication of the quality of evidence by Mr. Bailey.
Mr. Bailey said other data showed no elevated level around Dublin Airport so it would be reasonable to conclude it was a local reason.


Evidence by third parties



Ms. O’Brien had MSc in Environmental Science and Degree in Biology, Diploma in geology and pollution control. With the help of a power point presentation (Z-24/04/07) she said she was going to read the material submitted with a sceptical eye.
She read from DAA website which stated that the monitoring programme was broadened and it provided and integrated picture of the spatial and temporal variations of ambient air quality around the facility, and that the results were assessed in conjunction with meteorological data from Met Eireann and statistics on aircraft movements, and that the environment department liased with EPA on the results of monitoring.
She said the monitoring system seemed to be carried out by engineers not biologists, who had a different way of looking them including cumulative effects. For example in the case of Sulphur dioxide the limits were ecological (such as grass) limits but not in terms of limits for humans.
In the case of Liverpool (which she was familiar with) measurements were taken every 15 minutes and provided on the website. Using an example she said she thought they needed to be presented in that format. While Dublin had measurement (numbers), but FCC did not provide their figures to the public even if they were taken.
While most of the time the Atlantic air carried the air towards England, there were times of no wind.
The ultimate capacity aimed by DAA was 60mppa. This would mean serious increase in traffic and workers and pollution. The workers needed to be protected too.
Pollution did arise just from the aircrafts, but a lot from the ground traffic. She did not think baseline figures were provided.
They lived down wind of airport. Annualising figures was not acceptable. Air pollution was trans-boundary as we all found out during Chernobyl. She showed a ‘Global Image’ by Heidelberg University to show how the pollution moved westward.

In response to question by the inspector, Mr. Bailey said the road traffic data was obtained from DTO model, which produced vehicle types and numbers and speed included the road links. The emissions data for cars, and vehicles were obtained from website for various vehicles.


He responded to other questions.
Sulphur dioxide was not a problem for Dublin Airport as it was produced by industrial processes or smoky fuel.
The ecological limit was for sensitive areas such as Black Forest or the Alps.
The ozone plumes did not occur where it was produced, moved with air stream. Distinguishing cause and effect was very important. Power stations in Pennines would be likely to cause the high levels of ozone in Liverpool.
In Ireland ozone levels were very low, only increased coming from easterly direction.
One could find variation if hourly results were provided, but the important thing was that they did not exceed the standards, not the variation.
Ms. O’Brien reiterated that Mr. Bailey was given ‘robust’ figures by DAA.
Mr. Bailey said deciding where the monitoring locations would be was important, not the numbers. He had visited the monitoring locations and from what he had seen, he was satisfied that he would have done something similar.
Location of equipment for continuous monitoring was important in terms of vandalism etc. continuous monitoring was carried out in five sites on a rotation basis (in one case). There may be justification in continuous monitoring, but moving around to get a snap shot to indicate levels was acceptable.
Ms. O’Brien said while they were monitoring continuously it was not true they were monitoring continuously at the same locations. There was discussion on what continuous monitoring meant. (it meant continuous monitoring for pollutants, if they were below limit at one point, monitoring continued at another). Who decides what to monitor was derived from NAQS. Then the concerns of the community would be taken into consideration including other compounds.
In response to Mr. Harley’s question if all numbers were actually based on high growth scenario, Mr. Bailey said the numbers (aircraft movements) were supplied by DAA.
Mary Coveney for DAA confirmed they were given centreline figures.
Mr. Harley repeated they were already out of date. In the forecast the centreline figure for 2008 it was 22.5mppa,
Ms. Coveney said the numbers were not understated. The trends since the runway inquiry indicated lower numbers. Airlines moved towards larger aircraft carrying same passengers on fewer aircrafts. Indeed the forecasts were already indicating lower figures. It was true that they were likely to be slightly ahead of the forecast.
Ms. Coveney said the issue was aircraft size. She repeated that aircraft size had increased from 120 to 189, as Ryanair and Aer Lingus started changing their fleet. Mr. Harley asked for aircraft movement figures.
The figures given to Mr. Bailey would not change, but may be slightly ahead presently.
The kind of analysis done by York Aviation was standard in that for every million passengers 1000 jobs were created. This method was used by many airports around Europe.
Mr. Harley said that was not the case here. That was not the methodology used here. If you had used this methodology there would have been higher number of jobs created.
Mr. Harley stated that employment figures effected traffic levels, and therefore were relevant to airside emissions.
Mr. Bailey stated even if there was 5-10% adjustments in growth figures for the aircraft movements, they would still be well below the NAQS levels.
In response to Ms. O’Brien’s question in relation to maximum hourly concentration, and averaging, Mr. Bailey said the values specified in the EIS were below the levels.
In response to question by Mr. Sweetman Mr. Bailey explained reasons for adjusting some of the monitoring stations was fire station and proximity to residential.
Directive for Ambient air Quality and cleaner air quality 2005/447: 447 was in proposal stage.
In the Castlemoate site the monitoring equipments seemed to be removed when the limits exceeded due to rock crushing. The purpose of air monitoring exercise was to look at ambient air quality, not to measures a short term impact arising from a single activity. The important issue was the impact on local community.

Mr. Sweetman said the equipment was being removed to exceed the times one is allowed. This would mean every breach of air quality was explainable, through other activities. Coachman’s Inn was outside the airport.


Mr. O’Donnell explained the results were provided following request by the third parties, but it was unfair to ask specific questions on that as Mr. Bailey did not carry out monitoring.
Mr. Sweetman said ‘SR Technic’ were subject to a pollution licence and there was continuous monitoring. (A1A2). This should have been included in the EIS as it was within the blue line.
In response to question by Mr. Sweetman in relation to impact on bats and otters, he said the limit values were set for black forest (acid rain). Mr. Sweetman said EIS said hourly values for sulphur dioxide was for the protection of human health. He repeated it was not a by-product of aviation activity.

The second session of the module was held on a different day (02/05/2007) and was attended by the full team of the planning authority. This session concentrated on questions and answers, firstly to planning authority.


Mr. Flanagan (for Fingal County Council ) stated that the planning authority’s position was that the planning authority was satisfied with the contents of the EIS and the assessment carried out and the mitigation measures identified by the applicant, particularly in relation to the construction phase.
Rachel Kenny (for FCC) stated air quality was considered in many ways. In terms of construction of T2 they were satisfied with the EIS, the mitigation measures proposed, as augmented by condition numbers 32/33, which they now proposed amalgamation thereof.
In respect of air quality in relation to aviation activities we had the benefit of details in relation to the second runway. In the EIS for the runway the impact in worse case scenario would be fully assessed. They were satisfied again in respect of air quality.
In response to question, Mr. Flanagan stated they did not consider any significant impacts arose in terms of air quality. They accepted the analysis by the applicant, and it did not form a major plank of their consideration. They considered there were more fundamental issues to be considered.
Ms. Lawton stated that looking through the DAA booklet (Jan 2006), referred to page 7, she said they dependent on accuracy of the figures, and asked whether it was referring to nit oxide or nitric acid. In page 36 they had given 31 days for the month of February, and asked if the report was fictitious. The Bord Na Mona report referred to exceedances on a number of pages. She said if there were exceedances now, they were worried there would be more after the expansion.
She asked FCC for air quality report, but had not received any. Had asked for the air quality management plan but have not yet been provided one.

Mr. Sweetman (for Teresa Kavanagh) referred to planning authority LAP and the SEA of the LAP, which said in 2005 ‘some of the monitoring positions were adjusted to better reflect th airport activities and the range of PMS extended to include, ..
These reports were shared by the planning authority. Levels were exceeded 13 times. Noting that monitoring positions were moved, repeated that the planning authority had not taken any action. The airport seemed to be free of any form of checking by the planning authority.
There was absolutely no assessment of the exceedences by the planning authority. They were not even included in the planner’s report. S.9 of the plan was completely forgotten. The planner’s report did not constitute an EIA. It did not even list ‘air’.
He asked where the monitoring was.
Mr. Lumley (for An Taisce) first wanted to address the adequacy of the information provided by the developer in relation to EIS as clarified by the evidence in relation to air quality, aviation emissions, transport emissions, and emissions by the terminal and other airport development, as these were areas of principle concern.
With regard to Aviation emissions he stated S. 9.3.2 of the EIS gave aviation emissions methodology, based on landing and take off cycle emissions. It referred to combined various aircraft emissions for the three runways. There was another significant emission –engine testing- these were not identified in this EIS. He noted this was also a concern in the parallel application.
There was also major deficiency in identifying the actual additional car parking requirements as a result of this application. There was absence of such information in relation the total car parking needs, whether it would be provided all together or on an incremental basis, whether it would be provided by DAA or by private operators, and the amount of car parking in the MSCP not yet applied for, all needed to be quantified for the 35mppa. These could then from the basis for calculation of emissions from these car parks, basis for air modelling.
In case of the central plant emissions there was an overlap between air quality and CO2 emissions. It would be more appropriate to concentrate on CO2emissions.
The evidence given by the planning authority showed there was wholesale failure by the planning authority to adequately assess the EIS and address the requirements of the SEA Directive. Had they done so they would have to provide baseline and ongoing monitoring data to allow for comparison and determine whether intervention was required.
Under Article 10 of the SEA Directive the authorities were required to monitor the implementation of the plan. This went beyond the principles of the EIA Directive. Evidence of that had to be provided prior to proceeding. If FCC had carried out a compliant SEA ( which was being disputed), baseline data and ongoing monitoring data had to be a primary requirement for assessment of the proposed development.

Mr. Bailey (for DAA) referred to the 13-14 consecutive days where there were exceedances, and said he examined the data in detailed and concluded that there were analytical errors . The station was near the rock crusher. (no wind in the direction required, Sunday levels as high as other days). Experience in pM10 monitoring required further analysis. While he did not refer to those during the hearing that was because he had after examination decided to discard the data.
The monitoring station at Castlemoate house was interfered with, and was relocated to a more secure location, (30m away in dog compound –more secure) which he considered gave a good representation of the air quality in that section of the campus, and in proximity to Caochmans inn.
Ms. O’Brien said Castlemoate house was at the end of the runway used by small aircraft, which had more wing movements. That could have been the reason. Mr. Bailey did not think so, they would not be taking off from Castlemoate house, thy would be using another runway.
In response to question he understood there would be a permanent continuous monitoring location at the edge of the 10/28 runway.
There were negotiations for further monitoring locations. The first would be within the airport boundary, with further rings outside the airport and towards Portmarnock, etc, on paths of the runways. He believed the expanded monitoring in 13 locations would be made available by DAA on a website.
While there would always be dissatisfaction with monitoring locations, it was important to note that DAA were attempting to represent the air quality at the airport and near a field in the vicinity of residential communities.
He had extensive knowledge and was satisfied that the chosen locations would give satisfactory information regarding air quality in effected communities such as Portmarnock, St. Margaret's and Swords.
In response to question by the inspector to extrapolate the validity issue to the rest of the data, referred to individual dates where he had checked the data together with wind speeds for the dates, he said that kind of levels would have brought in a lot of complaints. The complaints would need to be made to DAA or to Fingal County Council.
The assessment he carried out was based on the info available and he considered it adequate, to give an indication of the air quality and any exceedances. In response to Mr. Sweetman he said the data he used for the EIS was 2004-2005. Mr. Sweetman disagreed saying that was made available to the public at this hearing.

He had not carried out the monitoring.


Mr. Sweetman asked for the list of planes and wind charts to check. He asked for the purpose of monitoring on the site. PM10s were invisible. Nobody had given any information that the monitoring data was looked at by anybody, until the hearing.
The rest of the monitoring results were consistent with what one would expect from such a location. Monitoring was being carried out by Bord Na Mona, provided in reports presented to the board (DAA). He did not know if the results were submitted to the planning authority.

In response to question by the inspector to explain their air quality policies of the planning authority, and who reported on the air quality, Ms. Kenny stated that the comments of the EHO did not highlight any inadequacies in relation to air quality. The planner considered and accepted the description of the receiving environment to be adequate. They considered the air quality issue in the context of the T2 application, rather than runway.


Mr. O’Donnell (for DAA) stated that the monitoring results were sent to FCC and to EPA on an annual basis, at the end of the year. 2005 figures were sent in 2006.
Ms O’Brien stated there is no continuous monitoring at Dublin Airport , as in the case of other airports, day by day instantaneously.
Ms. Lawton had a copy of draft Dublin Regional Air Quality Management Plan (policy 14 strategy 2) referred to such data being made available to public and to media. The planning authority would get back on the issue, following checking its status.
In response to question by the inspector as to what happens when the data received shows exceedances, and if there were any enforcement arising from such exceedances Ms. Kenny said they would check with EHO.
Mr. Bailey said the report on the EIS and this hearing should address the receiving environment in the context of likely significant effects on the air quality as a result of the development. He would stand over his conclusions that there has not been any exceedances over the NAQS for Benzene, CO, NO2. While there would be an issue in relation to PM10, (he did not except there was) this would be a short term event.
DAA was in the process of setting up a monitoring station (advance stage of procurement) which would provide data on a continuous basis. If there were very high NO2 levels, there would be a necessity to check whether it was originating from the locality or was a wide spread issue. Air mass over Dublin had elevated levels arising from traffic.
Mr. O’Donnell would come back with some proposal to suggest measures for dealing with exceedances.
Mr. Sweetman suggested data was available to Bord Na Mona and to DAA but was not made public.
Ms. O’Brien said the DAA website stated ‘scope of the monitoring program was expanded in 2005 to cover 11 sampling locations, and analysed for concentration of various parameters likely to be associated with aviation activities, and that this provides an integrated picture of spatial and temperal variations of ambient air quality around the facility’. The impression was given that this was being done, and there was no problem. There was no information, no control.
Mr. Bailey referred to the annual report and going through individual figures stated that there was no evidence that there was a problem.
Ms. O’Brien stated that as the data was annualised or monitoring stations were removed or switched off, there was no evidence it was continuous. She suggested the data was invalid.
Mr. Bailey disagreed. The monitoring network was similar to Dublin city Council and other local authorities. He repeated following installation of the network continuous monitoring data would be made available.
Mr. O’Donnell clarified a person with environmental qualifications was employed by Dublin Airport and when the results come back they were analysed within the airport. Any difficulties identified were looked out. He gave examples in relation to fire tending activities. When the results of the Castlemoate house came back it was assumed that it was the rock crusher was the source of difficulties and the contractor on the site was asked to introduce dust suppression measures.
What was now being proposed was ‘continuous monitoring system’, and the Board might impose conditions to deal with the issue in the light of that development.
Ms. O’Brien asked for noise monitoring data as it would be used as a base for this development as well as for the runway.
Mr. O’Donnell stated that the traffic movement figures were not compiled in the manner requested by Ms. Lawton, who was concerned about free parking for the first fifteen minutes creating 4 movements who would drop and pick up passengers.
Mr. Sweetman insisted he wanted to see the data referred to by Mr. Bailey.
In response to question by Mr. Harley if he considered the two scenarios to be reasonable and sensible, Mr. Bailey said the information he used reflected on aircraft movements was based on projections supplied by DAA. In response to question in do nothing scenario where there would 38mppa with one terminal would he consider it to be reasonable and sensible, said he was satisfied with the difference between two years.
Mr. Harley repeated that the fundamental of the comparison was flawed. They were taking an impossible situation as being realistic.
Ms. O’Sullivan (ARUP) explained that do minimum scenario was developed in conjunction with Ms. Weston. It involved a situation where the peak hour spread to rest of the day. It was a realistic situation in the future where nothing happened. They were not saying it would be an adequate level of service.
Mr. O’Donnell explained that the scenarios were being developed for the purposes of this terminal proposal. The basis of the comparison of the effects were entirely consistent with what is required in EIS terms. It examined what is likely to occur if nothing is done.
Mr. Lumley referred to section 9.3.2.3 of the EIS in relation to miscellaneous operations and asked if he included engine testing activity. Mr. Bailey had not because it was a very short term activity. Mr. O’Donnell stated that engine testing was part of the runway application and was exhaustively examined in the runway hearing.
Mr. Sweetman stated we were told for the purposes of this case it was presumed there would be no runway. So they were asking engine testing in the context of no second runway.
Mr. Lumley asked if this would be a terminal with additional 15mppa, with aviation movements to accommodate extra 15mppa movements. Mr. Bailey was asked to calculate impact on the basis of aircraft movements, not passenger movements.
Mr. O’Donnell explained air emissions were determined by aircraft movements.
In response to question what brief was given in relation to no of car parking spaces required to accommodate the proposed development, Mr. Bailey responded only the MSCP. Yes it was 1500. No he did not factor mobility management plan. No he did not factor long term car parking movements in his calculations, as they had low turn over for generating air emissions, they did not generate impact in terms of air emissions. He did not take into account those outside the campus area.
The information he was supplied with included location of car parks, short term and long term in terms of capacity and turnover rate.
In response to question given that DAA was proposing additional 10,000 long term spaces as part of their mobility management plan, would he change his calculations, he said it would not, as car parking would take place in Harristown and Eastlands.
Mr. O’Donnell explained that all the traffic moving in and out of the airport was taken into account.
Mr. Lumley asked what other movements were taken into account, for staff, for hotel visitors etc.
The model took the projected traffic movements calculated by the traffic section. Mr. Lumley asked what the differences were between the car parks, short or long term, or their locations, or bus movements.

Mr. Sweetman asked Mr. Bailey to look at the cumulative effects of all the developments he stated would have insignificant impact.

Mr. Flanagan for the introduced John Healy (Environmental Officer for FCC).

In response to question by Mr. Flanagan to explain the air quality monitoring at the Dublin Airport, he said they carried out the monitoring on behalf of all three County Councils including around Dublin Airport for NO2 but not for CO. All the results complied with EU regulations.


They also received the monitoring data by DAA every couple of months, in a summary level. No he had no reason to take enforcement action.
The Air Pollution Act 1987 was the regulatory mechanism he worked under.

They might have a need for pollution licence for the engine testing. That was dealt with under the runway.


Mr. Sweetman stated there was no application to EPA for an IPC licence. There was only one which was from SR Techniques.
In response to question by Mr. Sweetman had he ever seen the results of 2005, Mr. Flanagan corrected that somebody else from the County Council would have seen the results.

Mr. O’Donnell introduced Victoria Carroll, (air and water manager for Dublin Airport.)


In response to questions by Mr. O’Donnell she said, the ambient air quality monitoring program had developed over time from a small program to present 13 locations around Dublin Airport and within the communities surrounding the airport, to test for parameters associated with transportation activities including aviation.
A broad range of locating monitors at the potential source and at the potential receptors was used, to correlate air traffic movements, road traffic movements and Met data to see if any elevated results were attributed to the aircraft activities. If elevated levels were identified they would examine the reasons, while continuing to monitor, so as not to neglect other community groups.
In general the air quality in Dublin region was good, due to prevailing winds from gulf stream and exposed nature of Dublin Airport.
The data they collected were compared with the air quality indices provided by the EPA. They would also compare them with Dublin city centre figures to provide a subcontext.
They conducted the air quality monitoring willingly in response to community concerns and made the results available willingly. They were available to members of public if asked.
In response to question by the inspector she stated the incidences where elevated results occurred were near the site of Castlemoate house- rock crusher. They took immediate action and mitigation measures they introduced such as dust suppression measures using water showed immediate effect. Another incident was due to parking of fire engines adjacent to a monitoring site. They were satisfied these did not represent ambient air quality, but due to specific activities in the vicinity.
In response to question by Mr. Sweetman she said, no, one could not normally see PM10 with naked eyes. But in the immediate vicinity of the rock crushing plant larger particles could be seen.

Ms Lawton asked Mr. Healy (FCC ) when he monitored PM10 in gate 12.

He had not. Within Dublin Airport they only measured NO2. The nearest PM10 monitor location was at Cloghran. NO2 monitoring was done at Malahide, Portmarnock, Balbriggan.

Ms. O’Brien asked the information to be available on the internet. Mr. Healy said the previous site had not worked very well, he would refresh the data as soon as he got a chance.
Ms. O’Brien asked how, where and when monitoring was decided.
Mr. Flanagan said they would normally recommend a condition only if they think there would be problem with this issues, such as a quarry. In this case they did not because there was no problem.
Mr. Flanagan provided a copy of the draft Regional Air Quality management plan 1999, adopted in Dec 1999 under 1996 Air Pollution Act. He said it was aimed at premises. Today most pollution arose from road transport, therefore local authority did not have legal authority to address those issues, take action
Mr. O’Donnell said the air quality monitoring locations and operations were controlled by independent consultants (previously by RPS and Bord Na Mona recently).
In response to question by Mr. Sweetman (referring to data on 10/03/05-11/03/05) that wind speed directions were the same, but the readings for PM10 s were different, and was that because the runway was used in one of the dates, Mr. Bailey said the runway in question was 11/29, he considered the aircraft activity on that small runway would not cause that type of change measured on a 24 hour basis.
In response to what caused it he thought (referring to earlier explanation that heavy rock crushing caused such elevated levels) Mr. Bailey said there was some contradiction. Mr. Sweetman said Mr. Bailey’s evidence in the morning was not based on facts but on hypothesis.
The hearing continued to move into the module of Climate change.



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