Friends Of The Irish Enviroment challenge airport passenger cap

While the origins of the Dublin Airport passenger cap relate to road access, the environmental charity Friends of the Irish Environment have made a submission to Fingal County Council raising their obligation under Section 15 of the Climate Act 2015.

Section 15 of the Act requires the Council to ‘have regard to ‘the objective of mitigating greenhouse gas emissions and adapting to the effects of climate change in the State.’

According to a submission by FIE,  ‘Even though the original reason for the passenger cap was not directly related to emissions, the decision on the application will have a significant impact on Ireland’s greenhouse gas emissions and therefore the obligation of consistency under section 15 is triggered’.

FIE, which has three climate cases pending in the High Court, argues that the Dublin Airport Authority’s response to further information failed to identify the ‘major adverse’ impact of the proposed raising of the cap. FIE Director Tony Lowes explained that ‘Major adverse impacts are defined as ‘A project with major adverse effects is locking in emissions and does not make a meaningful contribution to Ireland’s trajectory towards net zero’. A measure (removal of the passenger cap) explicitly aimed at an uncontrolled/ unmoderated increase in the number of flights complies with the definition for this category.’

The anticipated passenger numbers using the airport in the predictions put forward by DAA are not consistent with the necessary emissions reductions to meet the targets of the Paris Agreement, even after taking into account aircraft efficiency improvement and sustainable aviation fuels in feasible quantities.  This point has not been recognised or responded to by DAA, according to the submission.

While the Environmental Assessment has been revised at the request of the Council, the revised Chapter 13 ‘Environmental Design & Management’ states ‘This section outlines measures that will be implemented to manage and reduce carbon’. However, non-CO2 effects are the majority of the climate impact of aviation. The Assessment ‘talks up the scientific uncertainty around the non-carbon emissions and decides not to quantify what is the majority of the climate impacts of the project’.

According to FIE: ‘Public debate on the passenger cap at Dublin airport has not in any way addressed the role that aviation is playing in driving up global warming, in spite of the most dramatic examples of the impact that are cascading around the globe as we speak.’