An Bord Pleanála



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Climate Change

This module was discussed on 2nd May, 2007. I note there were reference to this issue also during the first module in terms of policy issues and particularly in relation to adequacy of the LAP and the SEA.


First party evidence

Mr.Bailey had MSc in Meteorology and Climatology He was lead consultant for Air Quality management plan for the Greater Dublin Area, carried out in the late 1990s. He had also prepared the impact assessment for report on the northern parallel runway. He read form a written submission (BC-02/05/2007)
The operation of T2 would not have any significant impact on local climate. The curved roof of the building would help reduce of degree of turbulence downwind of the building, and there would be no impact on the existing wind flow conditions beyond airport boundary. Due to the size, alignment and height no shadowing impact would be observed at ground level beyond the airport boundary.
The National estimates of Greenhouse Gas emissions published by the EPA for the year 2005 gave a total from domestic civil aviation of 0.116million tonnes of carbon dioxide, compared with 13.5milion tonnes from the transport sector. These were based on aviation fuel sales for domestic flights. Even by 2012 the aviation sector was projected to be less than 1%.
While approximately 2.3million tonnes of CO2 contribution was estimated in 2004 from the annual fuel demand for the aviation sector (including domestic and international flights from airports in Ireland), this was based on annual energy, and the amount of CO2 emissions during landing and take-off cycle (LTO) was only a small percentage of this amount (7% for B737-400 series aircrafts), as much of the emissions occurred outside Irish Airspace.
Atmospheric emissions were excluded from the 1997 Kyoto Protocol on Climate change. National Climate Change Strategy 2007-2012 did not include specific emission reduction target for the aviation sector, but indicated support for the proposals of the European Commission for inclusion of aviation sector in the emissions trading.
The European Commission proposed in 2006 amendment to the Directive 2003/87/EC establishing a scheme for greenhouse gas emissions allowance trading to include aviation activities. This would allow airline operators to purchase emission allowances. This would also require operators to monitor and report emissions form their fleet entering into effect form 2011.
He noted that this scheme specifically related to aircraft operators and not to airport operators such as DAA, and was designed to encourage higher fuel efficiency.
Based on the data supplied by the DAA there would be less then 2% increase in aircraft traffic by 2012 and around 7% in 2024 from the operations of T2 and pier E. This was minor and would have insignificant impact on total Greenhouse Gas emissions generated at Dublin Airport arising from landing and take-off patterns.
Total future annual CO2 emissions from airside and landside activities at Dublin Airport had been derived based on projected aircraft movements. During the LTO cycle these would be 150,000 tonnes for 2012 and 200,000 tonnes for 2024. These were calculated from engine fuel consumption obtained from IACO database. Projected annual CO2 emissions from the boiler plant at Dublin Airport were 24,000-26,000 tonnes per year. The annual fuel consumption estimates for airside and airport operated landside traffic indicated an annual CO2 emissions of approximately 2,400 tonnes from the airport campus, bringing the total emissions from landside and airside activities to 176,500 tonnes in 2012 and 228,500 tonnes in 2024.
The Greenhouse Gas emissions from road transport associated with the operation of T2 on the local road network were of minor significance in the national context. National emissions from the road transport sector were estimated to be 13.5 million tonnes or about 19% of total CO2 emissions from Ireland in 2005. Therefore any change arising from the projected additional cars travelling to and from T2 would be negligible.
The traffic study carried out by the EIS had estimated that compared to the scenario without T2 volumes would increase by less than 15% in 2012 and 21% in 2024.
Use of alternative transport modes and improvements to engine design would help offset the increase in exhaust emissions from vehicles travelling to and from Dublin Airport.
The energy generating plant had the benefit of a permit for the EPA in relation to CO2 emissions under the National Allocation Plan.
T2 has been designed to include a high energy efficiency CHP plant with annual CO2 emissions estimated at about 6,200 tonnes. In terms of annual emissions form the energy sector this was insignificant at 0.1%.
The requirements of condition number 32/33 imposed by the planning authority would be achieved by planned energy saving measures to existing boilers /heating systems coupled with the CHP boiler plant proposals submitted for the T2 energy centre.


Evidence by planning authority



Rachel Kenny read from page 15 of her written evidence. Referring to the section 18.3.7 of the EIS stating that an annual allowance of 22723 tonnes has been determined by the EPA for the period of 2008-2012, and given that the applicant has indicated an estimate of 17,300 tonnes for T1 for 2005, concluded the cumulative annual amount for T1 and T2 would be 24,000 tonnes for 2012 and 26,200 for 2024.
Following a review of the issue of Greenhouse Gas emissions in conjunction with the Council’s environmental and sustainable energy policies she was satisfied that a re-wording of condition numbers 32/33 would be appropriate. She stated that the Council would have no objection to amalgamation of the conditions nos. 32 and 33.

Evidence by third parties



Ms. Lawton referred to the letter from DAA to EPA requesting increase of emission allocation (BI-02/05/2007), and asked whether they were seeking an increase in CO2 emissions.
She stated (referring to document she circulated BB-02/05/2007) the figures with Standstead (comparable to Dublin Airport with two dominant airlines- Ryanair and easy jet forming 87%of the fleet) CO2 emissions in 2005 were 6.9 million tonnes. She was querying the figures given by Mr. Bailey. Mr. Bailey would answer later.
Ms. O’Brien said it has been proven to be in place. The Government had introduced bans such as smoking ban in other areas to change behaviour. She asked measures to be introduced by the Government to take the lead.
Mr. Harley said as in other areas the EIS, Mr. Bailey’s analysis based on two scenarios had grossly underestimated the impact on global forming from emissions. Referring to section 18.6, he said he did not accept it was difficult to quantify. He submitted written evidence but would not directly read form it (BE-02/05/2007)
He would try to quantify it using Stern Report. He reiterated that economic analysis was a fundamental precondition to sustainable development. Therefore he would examine climate change impact in economic terms.
He believed that the proposed expansion of Dublin Airport will cost at least €8.4 billion in climate change damage alone, and waste of €13million in total.
Dublin Airport expansion plan would bring the total number of passengers to 35mppa by 2020 and to a full capacity of 60mppa by 2035 (as stated by CEO of Dublin Airport).
Ryanair had provided figures to US Securities and Exchange Commission based on fuel consumption, mileage per passenger trip and number of passengers stating that every Ryanair passenger had produced 93 kg of CO2 in fiscal year of 2006 (A report by UK Government economist had provided 300kg of CO2 for UK passengers, therefore Ryanair was a conservative estimate by 1/3)
He referred to figures provided by Prof. Stern that cost of the damage done by Global warming and the contribution of CO2 emissions to that damage at US$ 85 per tonne of CO2 (Page 322 of Stern report).
The report had also stated that the warming effect from aviation industry was 2-4 times higher as emissions were released at higher altitude. Using a factor of 2.7 (given by George Monbiot), he calculated that every Ryanair passenger did about €17 global warming damage. In view of the fact that Ryanair had the youngest and cleanest fleet, the other airlines with older fleet would have higher levels. Applying to all Dublin Airport passengers at 21 million in 2006, and using Ryanair figures he calculated 1.95 million tonnes of CO2 and €357million in global warming damage.
When the airport reached its capacity at 60 million around 2035 as a result of the expansion programme, the extra 40 million passengers would do an extra €680 million worth global warming damage per year. Using present day values, he calculated the damage from now until 2050 to be €8.4 billion.
The 20,000 tonnes equivalent of CO2 allocated by the EPA for each of the years 2005, 2006, 2007 to Dublin Airport was only one hundredth of the 2 million tonnes of CO2 emitted by Dublin Airports 21 million passengers in 2006. (anomaly was because international aviation was not included in Kyoto Protocol)
He concluded that when the cost of 4.5 billion arising from waste due to misuse of land, and economic cost of road congestion (as previously presented) are added a conservative estimate of expansion of Dublin Airport was €13 billion.
He concluded as such the proposed development was an unsustainable development.

Mr. Lumley (for An Taisce) provided a number of submission (BF1, BF2, BF3, BF4, BF5, BF6, BF7 –02/05/2007) He said he wanted to outline particular issues in relation to Climate change in three areas- terminal, land based transport and aircraft emissions. The overriding consideration was that climate impact must be quantified before anything else and quantification could only be done by way of tonnages.
He referred to lack of data both in Ireland and elsewhere and different terminologies, where some referred to CO2 equivalent (an aggregate figure which adds to CO2 emissions other Greenhouse Gas emissions, than converts to CO2 emissions)
Another difficulty was finding aviation figures in relation to CO2 emissions. There was also confusion as regards to dates of many documents, as well
Returning, three areas of emissions, he said there was immediate difficulties with regards to terminal building (18.4. of the EIS). Mr. Bailey document earlier simply referred to one of them and needed clarification, as raised by ms Lawton, he asked if DAA was able to meet the emissions cap imposed by EPA. He suggested leaving this to a later stage to be agreed by FCC was not appropriate
Every application had to be looked at in terms of its cumulative impact on national or Global emissions. State sector was required to provide exemplary standards in energy usage. There was no such measures as elementary as use of appropriate light bulbs.
Secondly, there was a major deficiency in the EIS 18.14.18, which Mr. Bailey had sought to address in the hearing. There was a major element missing. Land transport for the airport (staff, car hire, commercial development, public, passengers being dropped off / picked up). It should be possible having regard to extensive data available including origin destination figures provided, it should be possible to come up with tonnage of CO2 equivalent for the current land based transport to Dublin Airport.
There was a very serious national situation. All of the Greenhouse Gases in Ireland had already risen 160% over Kyoto 1997 levels, as against 13% requirement.

There was very limited lea-way to reduce transport emissions. Therefore they needed to be at least contained at current levels. It was quite clear the mobility strategy proposed by the DAA was inadequate in mitigating transport related emissions.


Although there would be advanced use of public transport due to Metro, this was not quantified, and would be undermined by DAAs own transport strategy, 10,000 long term spaces in un identified locations, additional demand by staff of other aviation operations, hotel and other servicing developments that arises from expansion of an airport.
If the figures used 15% in 2012 and 21% in 2024 (calculations not produced) how much land based traffic was going to increase taking today as basis. Those figures could not be tenable.
Another strategy was introduction of a cap for further growth of car based passenger and staff access. This was not proposed or its impact was not quantified. This was the largest single origin or destination point, and proposed by emanation of the state. Unless it set a precedent for addressing the CO2 emissions, we would be going nowhere.
It would be harder to find another project with trans-boundary effect, that would arise from expansion of the Dublin Airport to 38mppa.
He referred to difficulties in finding independently verifiable quantitative data on emissions. The EPA figures were only related to flights that had origin and destination within Ireland. He referred to figures related to Ryanair, as reported in the press. There was similar difficulties in obtaining figures from other airports such as UK. He referred to attempts made in the case of Standstead and Gatwick.
Some attempt was made on Standstead. The distinctive feature of Dublin Airport was similar to Standsted with Ryanair and Easy jet accounting for 80% of traffic. The study had come up with 6 million tonnes of CO2 (not CO2 equivalent)
He suggested a methodology using origin and destination of the flights and using the amount to half way point, they could quantify the emissions.
He then looked at the quality of the data (peer reviewed). He referred to The Tyndall centre for research, the need to contain CO2 concentrations, strategy for contractions, disparity between rapidly rising emission levels and governments inability to recognise and respond to the growing crises.
Ireland had fastest growing emissions, and had highest per capita aviation miles in Europe. He looked at other sections of the document, such as the need to obtain aviation forecasts, to curb aviation growth until fuel efficiency counter balances the effects. If these could not be achieved, the only way the targets could be achieved by way of contraction. He referred to importance of water vapours impact on higher altitudes causing additional warming.
In S.7.5 the conclusions suggested very little improvement and only arising from technical improvements in the aviation industry
The design life of the aircrafts locked the aviation industry into a situation of kerosene dependency as fuel. As such the improvements would not be adequate.
The other document he referred to was commissioned by coalition of a number of organisations, entitled ‘Clearing the Air’ by CAN (Climate Action Network) Europe.
He then introduced an extract from a book by George Monbiot (biologist and Guardian Columnist) who had originally argued trading to improve poverty. The extracts he read argued a single air trip of a passenger on London Newyork trip generated CO2 equivalent generated by a car in a year. It also explained why impact of airplanes was not confined to Carbon they produced.
Aviation was the fastest growing source of Greenhouse Gases. Between 1994 and 2004 the number of people using airports in the UK had risen by 120%, and the energy consumed by planes had increased by 79%. Their CO2 emissions had almost doubled in that period from 20.1 to 39.5 million tonnes. There was no technofix. It concluded that while cuts could be achieved at homes, it was not possible in the aviation industry.
Mr. Lumley maintained we could not proceed with analysing impacts of aviation unless we had actual tonnage of emission, without a baseline figures from the aviation industry (industry’s own data)

The burden to carryout an Article 3 assessment under the EIA Directive lied first with local authority and now with An Board Pleánala. He submitted An Board Pleánala could not carry out an assessment under Article 3, as neither the baseline data nor the projection data required under Article 5, were available. CO2 emissions had to be calculated. As such the Board could not make a determination without further information. Alternatively the permission could be refused on the basis of inadequate information on EIS.

In response to question by the inspector Mr. Lumley said unfortunately there was no model in calculating Greenhouse Gas emissions. The Intergovernmental Panel had used 2.7 figure.


Questions and clarifications



Ms. Lawton asked if they were aware of the European views on the effects of Nitrogen Dioxide on the climate change and asked that the Board take into consideration.
Mr. Harley asked why in this global warming case DAA did not use the usual

argument, ‘do something’ and ‘do minimum’.


Mr. Bailey said it was not an exact science, but it would not make much of a difference in this case. We were dealing with a campus development. The scale was different. He agreed with Mr. Lumley that it was very difficult to get information.
Mr. Harley did not agree with the figures Mr. Bailey has produced. The information given by Ryanair to Securities and Exchange Commision would suggest different figures.
Mr. O’Donnell said if the point made was that it went too far, he agreed they had gone beyond the impact this development, what they were required to do.
He re-explained that in a do minimum situation, the airport could continue to expand, as a matter of law.
Mr. Harley did not see any analysis of impact of the proposed development on the climate change.
Mr. O’Donnell responded it was very difficult to see how a terminal could effect climate change.
Mr. Sweetman stated the EIA directive required looking into trans-boundary effect.

He asked how much fuel was used at Dublin Airport. Mr. Bailey’s best estimate was 60-70% of the amount used in the country. (1.5million tonnes of CO2)


Mr. Bailey did not know how much fuel was used in Dublin Airport. Mr. Sweetman insisted DAA must have the figures (770,000 tonnes of fuel was used nationally-EPA). He agreed with Mr. Sweetman that it would be in the region of 500,000 tonnes.
Mr. Sweetman disagreed with the statement that most of the emissions occurred well outside Ireland.
Mr. Harley referred to S.18.4 of the EIS and asked which was ‘this’ figure.
Ms. O’Brien asked if registration base of the airplanes would determine the costs.
Mr. O’Donnell for DAA referred to EPA licence for the energy centre, and asked Mr. Dix to explain the process. He said Ms. Lawton was right and DAA had applied for an increase in EPA allowance. Yes there would be an increase in CO2 emissions for the airport site when T2 came into operation. But a lot had to be brought into negotiation, as use of CHP would produce more CO2 on site but offsetting what would have been generated by the ESB outside. He repeated CHP was supported by the EU and promoted by the Irish Government. The condition did mitigate against introduction of CHP into the site.
In response to question regarding imposition of limits in condition number 32 and whether DAA was appealing against it, Rachel Kenny for the planning authority stated that reason was sustainable development and minimisation of CO2 emissions. They had decided to combine the two conditions (32 and 33), following examination of the figures permitted by EPA.
Mr. Dix explained compliance with the original condition would force them to buy from ESB, but at a higher level of CO2 emissions.
Mr. Sweetman said the condition was not legal.
Mr. Dix explained that they did look at wind power but there was issues with safety, and yeas they had applied for subsidy to install CHP. It was in the process. The revision suggested by planning authority was acceptable to DAA.
Mr. Harley concluded that the figure must be 2.5 million tonnes of CO2, Mr. Bailey agreed.
Ms. O’Brien suggested monitoring locations at both ends of each runway, within the compounds of outer markers.
Mr. O’Donnell stated they had no difficulty with continuous monitoring and making info available to planning authority and to the public if required.
Mr. Bailey stated the monitoring network in and around Dublin Airport was quite good having regard to security of location, supply of electricity
In response to question by Mr. Lumley if he could extract tonnage of CO2 emissions for land based transport to the airport, and when he could provide a baseline data, (as EIA Directive required to quantify), Mr. Bailey said the answer was no. One did not know the origin of the journey. Mr.Lumley asked why the information could not be provided given the origin and destination of vehicles in and around Dublin Airport were available in the transport model.
Referring to Mr. Bailey’s earlier statement that emissions from short term car parks was larger, Mr. Lumley stated the ratio of short and long term parking was important.
Mr. Lumley reiterated Climatic impacts was trans-boundary and had to be examined in that context.
At the request of Ms. Lawton planning authority provided a copy of Draft Dublin Regional Airside Quality Management Plan (BG-02/05/2007)
Although not during the same session there were references to climate change in the short presentation by Trevor Sergeant (Green Party) on another day.
He was concerned that the development if permitted could be seen as another impediment on the road for the country for being carbon neutral (He was not talking about aviation industry being under the radar in Kyoto agreement, which would be revisited soon). An uninformed decision could come back to haunt us. It would be more difficult to comply with our responsibilities at international level morally and cost wise, if proper assessment was not made.


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