IAA, ANCA, the passenger cap and flight paths
The Irish Aviation Authority, (IAA) has released their submission in response to An Bord Pleanála’s September 2024 draft decision on Dublin Airport’s night flights planning application (the so-called Relevant Action). This comes in the same week that ANCA, the Aircraft Noise Competent Authority released a letter requiring daa once again to submit a noise study, this time for its so-called “no-build” application to increase the capacity of the airport from 32 to 36 million annual passengers.
Summary
Dublin Airport (daa) is struggling with major planning issues and it’s mainly due to incorrect flight paths from its North Runway.
The Key Issue: Flight Paths and Passenger Limits
Daa wants to increase its passenger limit from 32 to 36 or 40 million, but there’s a problem: flights from the North Runway are not following the approved routes.
Originally, aircraft were supposed to fly straight for 9 km over empty fields before turning. Instead, pilots are making sharp turns at the end of the runway and just 400 feet above the ground. This affects 30,000 people with unexpected noise, violating Irish and EU laws.
Did the IAA Force These Changes?
Daa claims the Irish Aviation Authority (IAA) told them to change the flight paths for “safety reasons.” However, the IAA has now stated that they never required these changes.
In fact, the IAA criticizes An Bord Pleanála (ABP) for accepting daa’s claims without proper investigation. The IAA’s response makes it clear: safety was never the reason for the changes.
What Happens Now?
Daa refuses to submit a required noise study to ANCA because it would reveal the flight path problem. Without this study, their planning applications to remove the cap are blocked.
The North Runway Technical Group (NRTG), made up of aviation experts, is pushing for solutions that respect planning rules and reduce noise for affected residents. They are also calling for experienced directors to be appointed to daa’s board to improve decision-making.
Conclusion
Dublin Airport’s growth is at risk because it has ignored planning conditions. The solution is obvious: fix the flight paths to follow the approved routes. So why won’t daa do it?
How the Passenger Cap is linked to Incorrect Flight Paths:
At the heart of all daa’s planning permission woes and the company’s ongoing failure to increase the passenger cap are the flight paths of aircraft departing the North Runway. ABP has previously confirmed that the airport’s Instrument Flight Procedures, designed by AirNav for daa, do not follow the approved Noise Preferential Route. That route, chosen by daa, requires aircraft fly 5 nautical miles (approx. 9 km) straight ahead before making any turns. Daa applied for this route, over empty fields and solar farms, and was granted permission for the North Runway in 2007 with a strict condition, not to deviate from the daa-proposed route.
Daa, and their sub-contractor AirNav, chose to ignore this condition and take a short-cut requiring pilots to make turns up to 90 degrees off the route, starting at the end of the North runway and only 400 feet above the ground. This choice directly results in 30,000 residents being affected by aircraft noise without public consultation, in breach of Irish and EU law and the international Arhus Convention. Daa did no noise study or public consultation on the present route before they made the change and no permission to change the Noise Preferential Route was ever granted by Fingal, ABP or anyone else.
NRTG spokesperson Gareth O’Brien explained:
“The roadblock on both daa’s 36M and 40M passenger cap applications is the requirement for daa to supply a noise study to ANCA. Daa refuses to do so because they know their flight paths do not align with the Noise Preferential Route that they got permission for, and a noise study will clearly show this. All roads lead to the flight paths, which can be fixed, so why do they not want to fix them?”
IAA Submission
Daa has repeatedly claimed that IAA required them to make the flight path changes for “safety reasons” and claimed that this meant that “flight paths are not subject to planning permission”.
This new submission from the IAA calls attention to multiple errors and assumptions by ABP, central to the bord’s draft RA decision. An Bord Pleanála’s inspector made clear in September last year that IAA’s lack of a submission had been pivotal to ABP accepting daa’s claim that it was forced into the present routing of flight paths for safety and operational reasons.
IAA now calls this out in stark terms. The Inspector in paragraph 12.3.14 of their report stated that: ‘The flight patterns from the NR have also been amended […] to consider the requirements of the Irish Aviation Authority and divert north, northwest, earlier from the [North Runway] than originally proposed.’
IAA’s response: “The IAA did not specify any such requirement.”
Unusually for a State body the IAA is quite direct in its response to the Inspector’s failure to ask them any questions and criticises ABP accepting daa’s “Safety Reasons” claims on face value:
“The IAA considers that it is incumbent on ABP, if it is uncertain in relation to a function carried out by the IAA or on any technical points in relation to that function, to engage with the IAA to obtain clarity. This is preferable to making assumptions regarding what is required for safe operations, drawing inferences from the absence of a submission from the IAA on a particular point …”
Once again, the daa’s safety claim is debunked. The Inspector writes, “The IAA requirement to change the flight routes from the NR is raised as one of the greatest concerns in the third-party submissions. The applicant has repeatedly stated that this is a safety issue. No submissions have been received from the IAA in relation to this requirement.”
IAA’s response: “Again, the IAA did not specify any such requirement.”
NRTG spokesperson Gareth O’Brien said,
“The IAA’s submission demonstrates how An Bord Pleanála and others have been misled by daa’s often repeated claim that IAA required the flight paths to turn for “safety reasons”. Perhaps daa should now explain the real reason they chose to ignore the Noise Preferential Route from their planning permission and use a short cut that dumps noise on 30,000 people?”
orth Runway Technical Group continues doing all it can to explore various technical options to solve the problem and show alternatives to the flight paths which continue to cause huge disruption to tens of thousands of people living in areas never authorized for flight paths. We are deeply concerned for the future of Dublin Airport as daa continues to fail to meet Ireland’s international transport needs while blaming others for its own shortcomings.
NRTG calls on Minister Darragh O’Brien to appoint qualified and experienced directors to the board of daa plc with responsibility for Infrastructure Development, Environmental Protection and Aviation. Each director should have personal responsibility for one area and must have the appropriate professional credentials, knowledge and expertise in that area to oversee and ensure the performance of this key state-owned company.
The North Runway Technical Group is a group of pilots, commercial and private, along with engineers and others with various technical qualifications. Members of the group depend on Dublin Airport for their livelihood. The group formed to examine the non-compliant flight paths used by daa for the north runway and propose solutions that would reduce the harm to the people affected and help secure the future development of the airport.