The DAA have submitted new noise contour maps to An Bord Pleanala as part of their case to allow more night flights.
The DAA have given new maps which bring in many new people and communities into the area they propose to expose to harmful night time flights.
Under planning rules only people who have previously made a submission in this case can comment on the new maps. Those people have until 5.30pm on Tuesday April 2nd to make a submission.
Cllr Ian Carey said:
“It is vitally important that if you made a previous submission that you follow up and comment on these new maps. The changes they are proposing will bring harm to households and communities that were never planned to be impacted. It is a national disgrace that such an abuse of planning laws should be allowed to happen. Changes like this need to go through the full planning process. Everyone needs to be given the full facts on why these changes need to be made and what alternatives could be considered.
“It is crystal clear from looking at how Gatwick is run that a ‘dependent’ approach to managing both runways would allow the DAA to both meet its planning obligation and achieve its aim to meet increased passenger numbers. In that context this change should not be allowed. At a time when ‘independent’ runway operation is necessary then they can apply for planning permission, but based on the plans for growth that will not be for many years.
“People’s lives and communities should not be trampled on by the DAA simply because it is convenient for them.”
Here is the sample text suggested:
An Bord Pleanála
64 Marlborough St.
Dublin 1
D01 V902
RE: Case Number ABP- 314485-22 Relevant Action Application Dublin Airport
Dear Sir/Madam
Further to your correspondence to us on the above case we wish to make the following observations/submissions:
- We are shocked to see that the noise contours have extended hugely into our community and that a very significant number of dwellings are now included within the noise eligibility contours. Firstly, we note that there was no notice of this fact in any of the planning notices for this application to date. Many of our neighbours who thought they were not affected by this application are now inside these contours but yet were never publicly notified until they attended a public meeting held by St Margarets /The Ward residents’ group who explained this to all of us. None of the newspaper or site notices informed the public. Secondly, the people who now know they are within the contours have not been given the opportunity to make a submission/observation as they do not qualify because they did not make a submission previously as they thought they were unaffected. An Bord Pleanála did not give a public notice of this significant additional information. The above is totally unacceptable and unjust to the communities affected.
- We note that the correspondence from Tom Phillips & Associates refers to the ANCA Regulatory Decision regarding eligibility to the noise insulation scheme and suggest that the change in contours is as a result of their assessing that the increased area is as a result of them considering this new area which contains dwellings to having “very significant” effects. We note that the DAA have never carried out significant test criteria within any of the EIAR they have submitted and therefore they have not met with the EIA directive. This is a fundamental flaw in the assessment as the EIA directive is clear, all significant impact on environment must be identified, quantified and mitigation proposed. That has not happened to date. For areas under the North Runway this involves comparing the scenario with no flights from the North Runway to a scenario where there will be night flights. This has not been done.
- Tom Phillips refers continuously to the regulatory decision by ANCA in his correspondence. However, what is not contained in his correspondence but is within the EIAR relating to these noise contours is that the proposal does NOT meet the Noise Abatement Objective of ANCA in future years. The proposed 2025 Scenario will fail the NAO when compared to 2019 when the total of the existing population, permitted developments and zoned developments are summed together. “2025 exceeds 2019 by 4,541 people (1533 v 6074).
- Why have the noise contours grown. St Margarets The Ward residents carried out noise monitoring on the north runway flight path and found the noise levels to be far beyond those PREDICTED by DAA. Their noise predictions are not accurate and unfounded and they are trying to obtain permission by manipulating numbers. Why can they not submit actual noise results along the flight path which has been in operation since August 2022. The community could.
- Reference is made to the noise zones on Fingal development plan. These noise zones must now be revised due to the proposed flight path over our area. Fingal County Council consider that there should be no residential development allowed in noise zone A as it is considered harmful to health or otherwise considered unacceptable due to the high levels of aircraft noise. However, the fight path now being operated by DAA is putting many existing residences in Noise Zone A and B which is just not acceptable from a health point of view.
- The noise insulation grant as proposed is not fit for purpose and is totally insufficient to protect for night noise. Measurements of noise in bedrooms of housing already insulated indicate that the noise levels exceed the recommendation in Fingal Development Plan are not sufficient to protect human health.
- In summary planning is an afterthought for DAA. Their actions show that they do not respect planning legislation or decisions of An Bord Pleanála. This application must be refused.
Yours Sincerely,
Sign: _____________________________________ Date: _________________________
Address: _____________________________________________________________
