ANNEX F. Public Consultation: ERM s Response to Public Submissions

Transcription

1 ANNEX F Public Consultation: ERM s Response to Public Submissions

2 F1 INTRODUCTION In July 2003, public comments were invited on recommendations made for Public Safety Zones (PSZs) at Cork, Dublin and Shannon airports. These recommendations were made by ERM Environmental Resources Management Ireland Ltd in a report issued to the Department of Transport and Department of Environment, Heritage and Local Government on 23 rd June 2003 (1). This annex is a record of the (written) public submissions received and ERM s response to them. Availability of ERM s report was advertised in both national and local newspapers, and three public information days were subsequently held. Advertisements appeared in the Irish Independent, Irish Times and Irish Examiner on Monday 30th June 2003 and Monday 7th July, and in the Cork Echo and North Country Leader on the 1 st July 2003, and the Fingal Independent and Clare Champion on 4 th July The three public information days were each held in the Great Southern Hotel s at Cork Airport, Shannon Airport and Dublin Airport on Monday 7 th July, Wednesday 9 th July and Friday 11 th July, respectively. All days commenced at 10:30 and closed at 19:30. Members of the public were invited to ask questions, express their opinions, view information boards and maps, take away copies of the report and PSZ maps, and complete or take away a public comment sheet. Over 130 people attended the three days: 24 at Cork, 21 at Shannon and 86 at Dublin. (1) ERM. (June 2003). Public Safety Zones: Cork, Dublin and Shannon Airports. Ref: / Prepared by Davies and Quinn. F1

3 F2 LISTING OF PUBLIC COMMENTS This section lists the written public submissions received by ERM on its report of 23 rd June A total of 42 submissions were received and these are listed in Table F2.1. Table F2.1 Written Submissions Received by ERM on its Recommendations for Public Safety Zones at Cork, Dublin and Shannon Airports (23 rd June 2003) Ref Submission Dated Received by ERM From 1 10-Oct-02 & 25-May Jul-03 B. McCarthy, Cork 2 9-Jul-03 9-Jul-03 T. Hourigan, Limerick 3 14-Jul & 28-Jul-03 K. O Carroll, Dublin 4 15-Jul Jul-03 S. Liddy, Co Clare 5 15-Jul Jul-03 P. O Dea, Co Clare 6 16-Jul Jul-03 V. O Brien, Co. Clare 7 17-Jul-03 Cllr T. Brovney, Cork 8 17-Jul Jul-03 D. O Briain, Cork City Council 9 24-Jul-03 N. Gilligan, Co. Clare Jul Jul-03 S. Ward, Town Planning & Development Consultants Ltd, Co. Louth Jul-03 Colin Buchanan & Partners, Dublin Jul-03 C. Roche, DPM, Co. Dublin Jul Jul-03 D. O Dwyer, O Dwyer & Jones Design Partnership, Dublin Jul Jul-03 Ballycalla, Co. Clare Jul Jul-03 W. M. Soffe, County Manager, Fingal County Council, Co. Dublin Jul Jul-03 B. Quinn, Strategic Planning & Development Consultations Ltd, Co. Dublin Jul Jul-03 A. Levey, Aer Rianta, Dublin Airport Jul Jul-03 P. Pugh, Ashquest Land & Property Jul Jul-03 D. Curtin, SIAC Construction Ltd, Dublin Jul-03 P. Ryan, Dublin Jul-03 Portmarnock Community Assoc Jul-03 Anonymous Jul-03 Woodlands Residents Association Jul-03 Anonymous Jul Jul-03 J. & P. Heron, Novan Jul Jul-03 G. Hughes, Beech Vista Garden Centre, Co. Dublin Jul-03 M. Lennon, MD Kart City, Cloghran Jul Jul-03 B. Dalton, Dalton B & Associates Ltd, Dublin Jul Jul-03 D. Torpey, Dunloe Ewart Ltd, Dublin Jul Jul-03 C. Greene, Clare County Council Jul-03 Anonymous Jul-03 D. O Keeffe Jul-03 T. Hourigan Jul-03 Capt. W. Butler Jul-03 Councillor P. Coyle, Fingal Co. Council Jul-03 J. Devlin Jul-03 B. Dalton, Dalton B & Associates Ltd, Dublin Aug-03 Anonymous Aug Aug-03 A. Bowen, Co Cork Aug Aug-03 A. Mulcrone, Reid Associates, Co. Dublin Aug Aug-03 M. Hogan, Property Development Manager, Shannon Development Aug Aug-03 R. Kenny, Snr Planner, Meath Co. Council F2

4 F3 RESPONSE TO PUBLIC COMMENTS This section details ERM s response to the public comments received from those persons/organisations listed in SectionF2, Table F2.1. Only those comments pertinent to ERM s scope have been addressed. The scope was a technical investigation to recommend Public Safety Zones (PSZs); the purpose of which is to control future development near Cork, Dublin and Shannon airports so that the risk to people on the ground, from the possibility of an aircraft accident, is minimised. ERM s scope is related entirely to safety risks and no response is made outside of this scope. For example, no comment is made on issues relating to economic and social considerations, cost-benefit analysis, regulatory impact assessment, green belt issues, aircraft noise, other airports in Ireland, and aircraft emissions, etc. For brevity, and to elucidate relevant issues, where appropriate, comments/issues have been summarised by ERM. This is in the form of either direct quotes or paraphrasing of the comments/issues. In addition, where similar comments/issues have been raised by more than one person (and where appropriate), these have been grouped together to avoid unnecessary duplication. In some instances, a comment/issue may only be attributed to one respondent. All written submissions received by ERM, regardless of relevance to ERM s scope, have been copied to the Department of Transport. F3.1 T. HOURIGAN (LIMERICK) F3.1.1 The safety zones around Shannon are designed, taking into account the normal civilian aircraft using the airport. These zones do not incorporate the higher risk associated with military aircraft using the airport. [Some of these aircraft carry explosives/munitions] which would cause a substantially bigger explosion on impact. The calculated PSZs do not account for military aircraft. Without details of the number of movements and cargo of such aircraft, it is not known whether inclusion of military aircraft would change the size and extent of the recommended PSZs. F3.1.2 Due to the military use of Shannon airport it now has an increased risk of attack by terrorists. The purpose of the PSZs is not to protect against terrorist activity. Hence, acts of terrorism are not included in the assessment of PSZs. F3

5 F3.1.3 A crash onto the chemical plant to the north-east of Shannon s main runway could release chemicals that could impact the local population. The chemical plant is subjected to the EU Seveso II Directive. This requires the operator of the facility to appraise the possibility and consequences of an aircraft crash, and demonstrate to the satisfaction of the Health and Safety Authority (HSA) that appropriate protection measures and emergency plans are in place. In addition, the Directive requires consideration of land-use around such facilities. The HSA has set zones around this facility to guide the local authorities on appropriate land-use. These zones account for worstcase accidents and would apply in addition to the recommended PSZs. F3.2 K. O CARROLL (DUBLIN) AND G. HUGHES (DUBLIN ONLY) F the level of so-called perceived movements on which [Runway 11/29 at Dublin] is based [are] without foundation.. From Tables D2.2 & D2.4 of your Report, the perceived movements on the 29-End are times greater than the actual [movements] for year Such an increase is totally unwarranted, particularly in view of the fact that Runway 11/29 is virtually closed. Please refer to Section F3.2.2 below. F3.2.2 What are the actual movements for each runway at Dublin Airport? Can you supply risk contours for [these] movements? If the new 10/28 runway is built at Dublin Airport surely the traffic movements will [decrease] by up to 50% on the old 10/28 Aircraft movements for each runway at Dublin for the year 2000 are listed in Annex D, Table D2.2. The Steering Group decided that the PSZs should be based on the maximum number of aircraft movements for each runway. This decision was taken to eliminate the need for frequent updates, and the uncertainty this would cause as to the extent of the zones and associated permissible land-use. Hence, PSZs based on a specified year (e.g. year 2000) have not been calculated. F3.2.3 The alignment of the new runway [at Dublin Airport] differs from the South Fingal Fringe Study map and Project study map supplied by Aer Rianta There has been a change to the proposed runway, 10L/28R. This has required re-calculation of the runway s proposed PSZs. The PSZs have not significantly changed. The revised PSZs are illustrated in the Executive Summary and Section 4. F4

6 F3.3 S. LIDDY, P. O DEA, V. O BRIEN, N. GILLIGAN (ALL CO CLARE) AND S. WARD (TOWN PLANNING & DEVELOPMENT CONSULTANTS LTD, CO LOUTH), D. CURTIN ( SIAC CONSTRUCTION LTD, CO DUBLIN) F3.3.1 The assumed aircraft movements used to calculate the PSZs are excessive (for all three airports) when compared against the aircraft movements for the year 2000 and in particular when compared against the decrease in movements experienced at Shannon Airport from year 2000 to year 2002 (Sean Liddy). The work completed by ERM was overseen by a Steering Group consisting of the Department of Transport, the Department of the Environment, Heritage and Local Government, the county councils of Clare, Cork and Fingal, the City Council of Cork, Aer Rianta and the Irish Aviation Authority. The Steering Group decided that the PSZs should be based on the maximum number of aircraft movements for each runway. This decision was taken to eliminate the need for frequent updates (as a result of changes/fluctuations in aircraft movements), and the uncertainty this would cause as to the extent of the zones. F3.4 CLLR T. BROVNEY (CORK) F3.4.1 Aircraft fly over the City of Cork but no PSZs cover the central and northern areas of Cork City. The PSZ calculations relate crash location to the known location of each runway rather than individual flight paths. This is not to say that flight paths do not influence crash location, nor that aircraft might crash outside PSZs. However, aircraft are more likely to crash within PSZs than outside them. For these reasons. Specific flight paths (or portions thereof) may not be encompassed by a PSZ. F3.5 D. O BRIAIN (CORK CITY COUNCIL) AND D. CURTIN ( SIAC CONSTRUCTION LTD, CO DUBLIN) F the outer zone contains within its coverage:- Cork University Hospital there appear to be implications for the University [Hospital] in respect of any further expansion. Is this the case? (Dominic O Brian). Yes. In the outer PSZ, further development of institutional accommodation (e.g. hospitals) is not recommended. The recommendation for no further development of institutional accommodation in the outer PSZ is based on the risk of an aircraft crash causing death to people on the ground, and society s general aversion to harming vulnerable members of the public. This recommendation is for guidance only (solely based on the safety risk ). Precedents have been set, for example around chemical facilities, where it has F5

7 been decided to grant permission for development because it is judged that case specific economic, civil and political considerations outweigh those solely based on safety risks. Section 6 has been amended to clarify this point. F clarification would be helpful as to how the thresholds [criteria] in Table 6.1 can be practicably applied. Section 6 has been revised to provide further clarification. F3.6 N. GILLIGAN (CO CLARE), C. ROCHE ( DPM, CO DUBLIN), B. QUINN (STRATEGIC PLANNING & DEVELOPMENT CONSULTATIONS LTD, CO DUBLIN), D. CURTIN (SIAC CONSTRUCTION LTD, CO DUBLIN), G. HUGHES (DUBLIN) AND M. LENNON ( KART CITY, CLOGHRAN) F3.6.1 Will the red zones be retained and if so, what is their purpose? Yes, the red zones will remain. It is ERM s understanding that the size and shape of each red zone will be retained. However, the red zones will no longer be used to judge whether developments can be permitted with regards to safety of persons on the ground. The red zones will only be used to control developments (within the red zones) that may hinder the safe navigation of aircraft. F3.7 S. WARD (TOWN PLANNING & DEVELOPMENT CONSULTANTS LTD, CO LOUTH), COLIN BUCHANAN AND PARTNERS (DUBLIN) AND S. LIDDY (CO CLARE) F the calculation of risk at is excessive and unjustified.. it is unreasonable to base the risk on an individual being exposed 24 hours per day, 365 days per year (Stephen Ward). To afford the public equitable protection from major hazards in Ireland, it is recommended that the boundary of the outer PSZs are represented by an individual risk of 10-6 (i.e. an individual risk of 1 in one million per year). This risk level is identical to that selected by the Dutch government for outer PSZs at Schiphol Airport. The UK government s outer PSZs represent a risk of 10-5 (i.e. 1 in 100,000 per year). Based on safety risk alone, this is inconsistent with that used for zoning around major hazard installations (e.g. chemical facilities) in the UK. The UK government used cost-benefit analysis to justify setting the 10-5 PSZs. Where risk assessment is used to set land-use planning zones, it is established practice to calculate the risk assuming an individual is exposed 24 hours per day, 365 days per year. This is the practice in Ireland, the UK and the Netherlands. F6

8 F3.8 S. WARD (TOWN PLANNING & DEVELOPMENT CONSULTANTS LTD, CO LOUTH) F3.8.1 We would suggest that a figure of 300 persons be allowed per half hectare [for Working Premises, rather than the recommended maximum of 110]. [And] a significant increase in the allowable persons in the holiday accommodation category. ERM s determination of the recommended number of people accounts for the likelihood that an aircraft may crash, the likely presence of people, and society s differing aversion to accidents involving different members of society. ERM is not aware of any evidence to justify increasing the recommended maximum number of persons (and none is provided by the respondent). F3.8.2 The introduction of multi-story car parks as a permissible use in the proposed outer PSZ area. Section 6 has been revised to provide further clarification on permitted developments (including car parks). F [with regard to aircraft movements, ERM s report] confuses operating rate with capacity. This gives rise to some doubt as to what rates of movement have been used for [Dublin s proposed main runway] 10L-28R. Maximum aircraft movements are assumed for each runway. This maximum has been determined by Aer Rianta (as part of the Steering Group) together with the proportion of such movements by aircraft types. For each runway, this maximum may or may not correspond to the maximum number of movements that could be accommodated if the runway was exploited to its full potential (i.e. capacity). The number of movements assumed for Dublin s proposed runway 10L-28R is identical to that assumed for the existing main runway 10R-28L. The number of movements are summarised in Annex D, Table D2.4. F3.8.4 The operating capacity of [Dublin s] proposed runway 10L-28R is not known, but it will have a bearing on the capacity. The number of aircraft movements for each runway will vary in relation to the operating mode, which is dependent upon fluctuations in aircraft numbers, aircraft types, runway maintenance, and weather conditions, etc. Therefore, to accommodate all possibilities, the Steering Group decided that maximum runway movements should be assumed in setting the PSZs. This decision was taken to eliminate the need for frequent updates, and the uncertainty this would cause as to the land covered by the PSZs. F7

9 F3.8.5 Calculation of the PSZ at Luton gave a best-fit shape of triangles, which pinched slightly about mid-way along their length.. More detailed evidence of intermediate plots of the PSZs for Dublin [should] be provided in order to clarify the statement that PSZs [calculated by ERM] are of a shape similar to that of a triangle. On behalf of the UK government, National Air Traffic Services (NATS) investigated how best to represent PSZs from the calculated individual risk contours (1). In some instances a pinching of the contours was noted. However, for the vast majority of airports, the pinching was so minimal that it was decided to represent the PSZs as simple triangles (2). ERM has found that the pinching for Cork, Dublin and Shannon airports is similarly minimal. Therefore, a simple and easily defined triangle was judged appropriate. F3.8.6 [ERM has used the SRI method] to determine criteria for Permitted Development. [The] assignment of... unity in the Modification Factor for population (c) [Annex B, page B10] is questioned. The conventional value of c for the working population is 0.25 The principal use of the Scaled Risk Integral (SRI) is to assess major accidents such as the dispersion of a toxic cloud over a populated area. In such instances, a modification factor of 0.25 is used for working populations, and a factor of unity (i.e. 1) for the general public at home. A factor of 0.25 is used for working populations because persons at work are judged to be in an organised environment where they are likely to receive an early warning to take protective actions before any irreversible injury occurs. In addition, in the workplace there are likely to be organised and predetermined emergency plans and (possibly) equipment to help mitigate against adverse effects (e.g. orderly evacuation to a safe location such as a toxic refuge, and the provision of respiratory equipment, etc.). Furthermore, even in the absence of these measures, toxic gas or fire hazards tend to have a lag time between detection and injury, thereby allowing individuals to take some protective measures. By comparison, when considering a crashing aircraft, whether people are at work or at home, there is little chance of an early warning prior to impact. Furthermore, there are few if any protective actions that can be taken, and many injuries are likely to be instantaneous. Hence, for aircraft crashes a Modification Factor of 1 (i.e. unity) is judged appropriate. (1) National Air Traffic Services. (February 2001). Individual Risk Contours as a Method for Determining Public Safety Zones at UK Airports. R&D Report (2) Telephone conversation, 29-Aug-03: Cox, P. (UK Department of Transport, Aviation Division) and Davies, P.A. (ERM). Conformation of PSZ shapes in the UK. F8

10 F3.9 C. ROCHE ( DPM, CO DUBLIN) F we request that the phrase No further development [relating to the permitted development criteria given in Section 6 of ERM s report] be clarified The phrase No further development refers to developments where people can be expected to be present for all or part of the day (hence, excludes developments where persons are not normally expected to be present). Section 6 has been revised to provide further clarification on permitted developments. F3.10 D. O DWYER (O DWYER & JONES DESIGN PARTNERSHIP, DUBLIN) F the risk factors associated with Topography, or with Shielding, may not have been included in the assessment [and they are not included in the UK studies].. within the much larger 10-6 areas we would expect some significant topographical effects. For example, at Cork Airport the elevated site (with increased cloud cover), and the hilly surrounding terrain. We would expect that a 10-6 zone outline (and the risk at particular locations within that zone) could be significantly affected by topography. The model used by ERM and the model used in the UK do not account for topography. The land encompassed by the PSZs is either of a similar height (above sea level) or lower than the land at Cork Airport. Hence, it is judged that the topography at Cork does not have an influence on the calculation of the PSZs. F the proposals for Ireland appear to be based on ultimate runway capacities. We believe that by the time ultimate runway capacities are achieved, the crash risk per aircraft movement will be less than in the year 2015 [used in the UK] and much less than the current crash risk per movement. With regards to aircraft movements, a similar comment is addressed in Section F It can be argued that the chance of a crash per aircraft movement will reduce over time and will be less than the current rate in It can also be argued that aircraft sizes will increase and hence, the size of the crash area will increase. Similar arguments can be made for crash locations, etc. Essentially, ERM supports the model used to calculate PSZs, and recommends that changes to the variables used to calculate the zones (e.g. aircraft crash rates) should be periodically reviewed to judge their significance. F Is it necessary to propose PSZs for minor/cross-runways? To ensure equitable protection, regardless of runway type, PSZs are proposed where the risk is calculated to be greater than that considered to be broadly acceptable (refer to Annex B, Section B1.1). F9

11 F Has any provision been made for future runway extensions? No. In the event of any extensions to runway lengths the PSZs would be recalculated. ERM is unaware of plans for extensions that are sufficiently detailed to warrant PSZ modelling. F3.11 S. LIDDY (CO CLARE) F The terms red zones, red safety areas and public safety zones have been used interchangeably over the years. Hence, there is confusion over the terms used. Over the years, a number of terms have been used when referring to the red zones. The reason for this, most probably, relates to the (existing) dual purpose of the red zones (i.e. to aid safe navigation of aircraft, by providing an obstacle clearance surface, and to protect persons on the ground by controlling land-use (within the red zones)). The ERM recommendation is for public safety zones to have the sole purpose of protecting persons on the ground by controlling land-use. If the recommendation is adopted, the existing red zones will serve only to aid safe navigation of aircraft. The red zones will not be used to control land-use to protect persons on the ground. Hence, if adopted, going forward, there should be greater clarity. F The Ordnance Survey (OS) Map used for Shannon Airport is not the latest version. The latest version of each OS map (for all three airports) was requested from Ordnance Survey, Ireland. ERM has been assured by Ordnance Survey, Ireland, that the latest maps were issued to ERM. F A number of developments at Shannon are within the outer PSZ Retrospective use of the proposed PSZ land-use criteria is not recommended. The purpose of the PSZs is to control future land-use. Based purely on safety risks from aircraft, the developments quoted as being within the outer PSZs are likely to be appropriate uses of land (i.e. Shannon Aerospace, Aer Rianta Hangar, Aer Rianta Control Tower and adjoining buildings, industrial estate). F Is the general repair and status of Runway 13/31 (Shannon Airport) of a standard warranting public safety zones? The runways chosen for analysis, and their location, length and usage were determined by Aer Rianta as members of the Steering Group. All information was open to scrutiny to members of the Steering Group, and no comments were raised as to the selection of the runways. Although Runway 13/31 is not currently used, this does not preclude its use in the future. Hence, PSZs for this runway have been calculated. F10

12 F3.12 W. M. SOFFE (COUNTY MANAGER, FINGAL COUNTY COUNCIL, CO. DUBLIN) F Chapter 4 The Scientific basis for connecting the triangular PSZs extending from the ends of each runway by means of lines running parallel to the runway is unclear. The risk alongside each runway was calculated in the same manner as the risk extending beyond the end of each runway. It was found that the risk pattern (along the runways) closely approximated a series of parallel lines extending from the base of each PSZ (i.e. triangle). The report has been revised to clarify the setting of the PSZs alongside the runways. F Chapter 6 The criteria proposed require some clarification. It would be important to state that the categories indicated as Permitted Developments would be acceptable only where these developments otherwise comply with the zoning and specific objectives of the relevant development plan and with the proper planning and sustainable development of the area concerned. Section 6 has been revised to provide further clarification on the proposed criteria. F It may be necessary to clarify the provisions to Paragraph with regard to Airport Terminals apply also to associated transport interchanges and to airport parking facilities. Section 6 has been revised to address this comment. F The developments specified in Table 6.1 require clarification of the thresholds indicated: Section 6 has been revised to address this comment. F3.13 B. QUINN (STRATEGIC PLANNING & DEVELOPMENT CONSULTATIONS LTD, CO DUBLIN), D. CURTIN (SIAC CONSTRUCTION LTD, DUBLIN) AND C. GREENE (CLARE COUNTY COUNCIL) Comments made by B. Quinn primarily relate to clarification of the land-use criteria given in Section 6. Similarly, some of the comments raised by D. Curtin and C. Green refer to interpretation of the criteria (e.g. the Shannon Rail Link). Section 6 has been amended to provide greater clarification on the interpretation of the proposed criteria. F11

13 F3.14 A. LEVEY (GENERAL MANAGER SAFETY & AVIATION STANDARDS, AER RIANTA, DUBLIN AIRPORT) AND S. WARD (TOWN PLANNING & DEVELOPMENT CONSULTANTS LTD, CO LOUTH - SECTION F ONLY) F What accident statistics support this proposal [PSZs extending alongside the runways]? A report issued by the National Air Traffic Services (NATS) lists crashes alongside runways: 68 impacts associated with landings and 30 associated with take-offs (1). For a number of UK airports, risk alongside runways is illustrated by NATS in its 1997 report (2). F Why have the UK and Dutch governments not adopted PSZs alongside the runways? It is understood that the Dutch government did not include PSZs alongside runways because most, if not all land is within the boundary of Schiphol Airport. It is not known why the UK government did not extend the PSZs alongside runways. F By continuing the PSZs along the runway [the] potential to develop [land] will be severely and unnecessarily restricted [e.g. cargo and maintenance facilities]. Working premises with no more than 110 persons per half hectare are proposed as permitted developments within the outer PSZs. F airport terminals have been exempted from restriction within the outer zone.. Could it not be argued that those working or using other types of development in such location e.g. a hotel also receive a direct benefit which outweighs the risk? (Aer Rianta) It is judged that the practical operation of an airport requires close proximity of an airport terminal. This is not the case for a hotel, although there are no doubt benefits, although these are likely to be insignificant when compared to those associated with a terminal. However, there may be other cases where the benefits of a development are similar to a terminal. The criteria proposed are for guidance, and not all development possibilities can be covered. Where it is necessary to balance safety, socio-economic, political and other considerations, the criteria should be used as part of the decision process. F How will the criteria proposed for permitted developments apply to extensions, roads, car parks, etc., and how will the criteria be applied? The criteria proposed are for guidance, and not all development possibilities can be covered. However, these are important points and Section 6 has been revised to provide greater clarity. (1) National Air Traffic Services Ltd, London. (January 2000). A Methodology for Calculating Individual Risk Due to Aircraft Accidents Near Airports. Refer to the diagrams on pages 58 and 59, and Table D.1 on page 77. (2) UK Department of the Environment, Transport and the Regions (DETR). (1997). Third Party Risk Near Airports and Public Safety Zone Policy. R&D Report National Air Traffic Services, London. F12

14 F As the landing crash rates are approx 2.5 times those of departures (para 2.1), should the predominant landing direction have a PSZ of greater area? If so, the outputs are inconsistent across the three airports. Generally, the predominant landing directions have greater PSZs. However, this is not always the case, due to the nature of the probability density functions, the relative split between the number of landings and take-offs, and the assumed number of light aircraft movements. Cork 7/25 and Shannon 13/31 do not follow the general rule. F Why are the PSZs for 10L/28R and 10R/28L of different dimensions while having the same levels and types of movements (note 1, Table D2.4)? The runways have different lengths and therefore different crash probability distributions. Hence, the dimensions of the PSZs for these runways are different. F The dimensions of the PSZs for 16/34 and 11/29 at Dublin seem counter intuitive in that more movements of larger aircraft take place on the former. Should the PSZs for 16/34 not be considerably larger than for 11/29? No. The PSZs are calculated based on the maximum movements summarised in Annex D, Table D2.4: 30,000 and 25,000 annual movements on runways 16/34 and 11/29. The majority of movements are on runways 16 and 29. Therefore, the larger PSZs are calculated at ends 16 and 29. The outer PSZs extend 5645 m and 5215 m at ends 16 and 29, respectively. This is consistent with there being more movements on runway 16/34. F Do the crash rates determined in D2.3 need to be reviewed as the grand total of movements assumed (455K) is in fact the cumulative total for the four runways rather than including for 11/29 or 10L/28R? No. The information in Annex D, Table D2.3 is only used to determine the average destroyed area and crash rate (per million movements). As the proportion of maximum movements is judged to be the same as for the year 2000, the average destroyed area and crash rate (per million movements) is the same. Annex D has been revised to clarify this point. F In Table D.25, the length of proposed runway 10L/28R should be 3110 m and not 3052 m as shown. This change in the length of the proposed runway 10L/28R has required recalculation of the runway s proposed PSZs. The change in the PSZ dimensions is minimal. F13

15 F3.15 P. PUGH (ASHQUEST LAND & PROPERTY, DUBLIN) F The extent of the outer PSZ is excessive..higher densities should be permitted within the outer half of the outer PSZ. Determination of the recommended number/density of people accounts for the likelihood that an aircraft may crash, the likely presence of people, and society s differing aversion to accidents involving different members of society. ERM is not aware of any evidence to justify increasing the densities (and none is provided by the respondent) nor to substantiate the claim that the extent of the outer PSZ is excessive. F3.16 D. CURTIN (SIAC CONSTRUCTION LTD, DUBLIN) F Although it is stated that there will be no change in current land use at any of the locations as a result of the proposals there does not appear to have been any serious investigation of the possible future land use requirements that might be considered, but for these proposals. Potential future land-use issues were discussed with the county councils of Clare (1), Cork (2) and Fingal (3), and the City Council of Cork (2). F The ERM proposals for Ireland seem far more restrictive than those applied in the UK [where there is no] outer zone [of 10-6 ]. The implications of this are that more stringent safety restrictions will be applied to Cork than Heathrow. Without investigating local conditions, it could also be argued that less stringent safety restrictions are proposed in Ireland than those applied in the Netherlands. Similarly, it could be argued that Schiphol Airport has more stringent safety restrictions than Heathrow. Solely based on the risk to persons (on the ground) from crashing aircraft, it is judged that ERM s proposals provide an appropriate balance between protecting people and not unduly restricting land-use. F The proposal does not specifically indicate what will happen to any existing developments within the 1:10,000 PSZ. No 1:10,000 (i.e ) PSZs are proposed. Where such a risk level is calculated, it is illustrated in Sections 3, 4 and 5 for information only. Such a risk level (where calculated), is within the proposed inner PSZs, whose boundary is set at an annual individual risk of 10-5 (i.e. 1:100,000). (1) Meeting in Ennis, 4-Jul-02: Dollard, G., Connealy, L. and Williams, A. (all representing Clare County Council), Davies, P.A. (ERM) and O'Mealoid, M. (Department of Transport). Telephone conversation, 15-Apr-03: Connealy, L. (Clare County Council) and Davies, P.A. (ERM). (2) Meeting in Cork, 12-Jul-02: Barry, R., Kelleher, B., Mansergh, N., Palmer, R., and Stritch, T. (all representing Cork County Council), Teehan, L. (Cork City Council), Davies, P.A. (ERM) and O'Mealoid, M. (Department of Transport). Meeting in Cork, 9-Apr-03: Barry, R. and Hydnde, A. (both representing Cork County Council), Ward, J. (Cork City Council) and Davies, P.A. (ERM). (3) Meeting in Swords, 11-Jul-02: O'Faircheallaigh, S. (Fingal County Council), Davies, P.A. (ERM) and O'Mealoid, M. (Department of Transport). Meeting in Swords, 8-Apr-03: O'Faircheallaigh, S. (Fingal County Council) and Davies, P.A. (ERM). F14

16 No inhabited developments have been identified where the risk is calculated to be 10-4 or more. However, had such developments been identified, their removal would have been recommended. F Have there been any aircraft crashes in Ireland (of the type covered in the ERM Report) that have resulted in fatalities on the ground? ERM is not aware of any aircraft crashes killing people on the ground outside the boundary of airports in Ireland. However, the absence of such incidents does not indicate that the risk is not present, nor does it suggest that the risk is of such a level that protection measures are not needed. F3.17 P. RYAN (DUBLIN) F The Report states that [the PSZs] are calculated based on [maximum movements]. This contrasts with the Netherlands and UK approach. [Assumptions] for future aircraft movements were supplied by Aer Rianta without any independent checking as to the reasonableness of the Aer Rianta data. The unquestioning use of Aer Rianta data is a major flaw in the Report. The basis for the 100% capacity utilisation is not stated in the Report. I recommend that the Department of Transport publish the assumptions used by Aer Rianta and... model various scenarios on capacity utilisation and show the effects [on] the different options [for PSZs]. The Steering Group decided that the PSZs should be based on the maximum number of aircraft movements for each runway. This decision was taken to eliminate the need for frequent updates, and the uncertainty this would cause as to the land covered by the PSZs. Please refer to Section F3.8.3 for clarification of runway capacity. The Steering Group discussed the movement data, and no concerns were raised to question the integrity of Aer Rianta in supplying appropriate movement data. F3.18 PORTMARNOCK COMMUNITY ASSOCIATION AND WOODLANDS RESIDENTS ASSOCIATION F due to the recent introduction of a so called Environmental Corridor aircraft at present fly beyond the boundary lines of [the outer PSZ for Runway 10R/28L at Dublin Airport]. This study does not appear to have taken [this into] account Aircraft deviate from the extended runway centreline this has not been accounted for. (Portmarnock Community Association) The outer PSZs do not mark the extent of flight paths and are not related to the Environmental Corridor. The PSZs refer to the chance of an aircraft crash. Aircraft could crash beyond the PSZs, but they are more likely to crash within them. F15

17 It is acknowledged that an aircraft s flight path can deviate from the extended runway centreline. The risk model is based on numerous accidents for which the original flight paths are unknown (many of which, however, would have deviated from the extended runway centreline). What is known, is the crash location and the location of the runway from which the aircraft departed or was approaching. Hence, the risk model accounts for deviation by inclusion of such accidents in the crash location pdfs (probability distribution functions). F If Portmarnock did not exist it would not be allowed to be built as it now stands due to societal risk arising from its location [beneath outer PSZ of the proposed Runway 10L/28R at Dublin Airport]. (Portmarnock Community Association). Existing developments should not be permitted to remain in Danger Zones [PSZs]. Developments e.g. car parks, hotels should be removed from Inner Zones. (Woodlands Residents Association) The proposed PSZs are not be applied retrospectively, and they do not signal that the risks to existing developments (within the zones) are intolerable/unacceptable. If they were, ERM would recommend that developments should be removed and/or people should be relocated outside the proposed PSZs. ERM advises a precautionary approach to the setting of PSZs and associated land-use criteria, and this reflects the approach taken by the Health and Safety Authority in advising on new developments in the vicinity of industrial hazards. This approach will help ensure that the safety risk situation in the environs of the airports does not become intolerable/unacceptable. F3.19 D. TORPEY, (DUNLOE EWART LTD, DUBLIN), SUBMISSION PREPARED BY SCOTT WILSON KIRKPATRICK & CO LTD ON BEHALF OF TURCKTON DEVELOPMENTS LTD F [The UK] has not adopted Outer PSZs[at 10-6 ] and has done this on the very valid basis of a cost benefit analysis It is not clear whether such an analysis has been undertaken [for Ireland]. Until such time as such an analysis is undertaken we find it difficult to support your proposals. No cost benefit analysis has been undertaken for Cork, Dublin and Shannon airports. Such an analysis would provide further information to the decisionmaking process but would not in itself be sufficient to support the adoption, or otherwise, of outer PSZs (10-6 ). Furthermore, the conditions at say, Heathrow Airport, are very different to say, Dublin Airport. For example, the calculated 10-6 individual risk contours to the east of Heathrow extend over well established and densely populated areas (e.g. Hounslow), so any in-fill development would not add significantly to the existing risk condition. To the west of Heathrow, significant portions of the land encompassed by the 10-6 individual risk contours present little if no development opportunities (e.g. reservoirs, common land, Windsor s Home Park), hence the existing risk condition may not be adversely altered. By F16

18 contrast, as an example, the proposed outer PSZs (10-6 ) for Dublin s main runway primarily extend over sparsely populated areas with possibilities for development (notwithstanding green belt and red zone issues, etc.). F The magnitude of individual risk reduces [with] distance from [the extended runway centreline]. [ERM] has chosen to disregard this and [has] adopted the highest magnitude of risk and applied this value across the whole Zone [outer PSZ]. This is a significant simplification and results in the overestimation of risk by up to 66% or more, particularly in areas near to the outer boundary of the Outer PSZ. Individual risk does reduce with increasing distance from the runway centreline, and to determine permitted development ERM has employed the Scaled Risk Integral (SRI) method assuming a maximum risk within the outer zone (i.e. an annual individual risk of 10-5 ). The SRI method was developed by the UK Health and Safety Executive (HSE) and is used by the Irish Health and Safety Authority. In addition to individual risk, SRI takes into account the number and type of people exposed, the population density and the proportion of time the area is occupied. For an SRI score of 35,000 or more (judged as not unreasonable by Scott Wilson Kirkpatrick), HSE advise against development, and if this advice is ignored, request intervention by the Secretary of State. However, between a score of 2,400 and 35,000 HSE advise against development, but do not attempt to prevent it, if other factors warrant development (e.g. socio-economic factors). ERM has assumed the maximum risk within the outer zone (i.e. an annual individual risk of 10-5 ) and the maximum SRI score (i.e. 35,000). Assuming the minimum risk (i.e. an annual individual risk of 10-6 ) and the minimum SRI score (i.e. 2,400) would result in more stringent criteria (i.e. fewer persons permitted per half hectare). Various options on the SRI score and assumed individual risk could be postulated, but it could be argued that the basis for adopting other intermediate values is simply to determine a maximum number of permitted persons. The statement overestimation of risk by up to 66% appears to assume a simple exponential decrease in risk with distance from the extended runway centreline. However, the decrease is not a simple exponential distribution and is a combination of the probability distribution functions outlined in Annex A. F17

19 F3.20 A. MULCRONE (REID ASSOCIATES, CO DUBLIN) F The Outer Public Safety Zone [PSZ] is defined as representing a risk factor of one in 1 million or The ERM report states however that this level of risk is universally considered to be broadly acceptable... It would appear therefore on the basis of the ERM report that there is no basis in terms of unacceptable safety risk for designation of an Outer Safety Zone. Only the extent (i.e. the outer boundary) of the outer PSZ represents a risk of Risk increases with distance from the outer boundary towards the inner PSZ (at which point the risk is ten times greater, i.e ). F The rationale for recommending the designation of inner and outer PSZs has not fully addressed the economic or land use implications of such a strategy. Please refer to Section F F [ERM state] that the adoption of the PSZs would not require any changes to existing land use around airports and would require only minimal changes to development plans. These conclusions are not strictly correct in the context of the Fingal Development Plan. Please refer to Section F F3.21 K. O CARROLL AND G. HUGHES (BOTH DUBLIN), S. LIDDY, P. O DEA AND V. O BRIEN (ALL CO CLARE) F What would be the extent of the proposed PSZs for year 2000 and year 2002 aircraft movements? The Steering Group decided that the PSZs should be based on the maximum number of aircraft movements for each runway. This decision was taken to eliminate the need for frequent updates, and the uncertainty this would cause as to the extent of the zones. Based on this decision, PSZs based on aircraft movements for the years 2000 and 2002 were not required, and have not been calculated. F18