The North Runway Technical Group has asked Fingal County Council, acting as the Aircraft Noise Competent Authority for Dublin Airport, not to adopt the updated Noise Abatement Objective, the Draft Regulatory Decision or either Strategic Environmental Assessment Environmental Report as they stand. The submission runs to 146 pages with 99 pages of annexes and was filed on 29 August 2026 under planning reference F23A/0781. It is in two parts, and the first does not engage with the four documents at all.
Part A is the primary objection. Three questions are logically prior to everything the consultation puts out for comment, and each must be answered before any finding of compliance, or of no significant effect, can be made. The grounds are independent of one another and cumulative, so answering one leaves the others standing.
The first is that the deciding body is not the independent competent authority European law requires. The noise function is a division inside Fingal County Council, which the draft decision itself describes as discharging the Council’s own functions. Its costs are met by a levy on the airport operator, with a statutory duty to keep them low and no floor beneath them. One chief executive performs both that function and the planning function for the airport whose conditions it polices. The Oireachtas Joint Committee on Transport has found, in its own voice, that the structure breaches the functional independence the Regulation requires. The strict test of staffing, reporting, accountability and funding that disqualified the Irish Aviation Authority from this role in 2017 has never, on any public record, been applied to the body designated in its place.
The second is that there is no lawful baseline available to measure from. The routing flown since 2022 is an unassessed material change to the project that was assessed and permitted, so the 2023 noise climate it produced cannot serve as the yardstick, and no process this Authority conducts can regularise it.
The third is that treating the departure routes as though they were not a matter of the planning permission is a scope error, and the Authority cannot escape on either answer. If the routes are a matter of the permission, the deviation is unassessed and the assessed route must be restored. If they are not, they fall wholly within the noise remit, where the standalone duty over them has never been exercised.
Part B answers the four documents on their own terms. It is advanced strictly in the alternative and without prejudice to Part A: the group participates under protest, and nothing in Part B concedes that the decision-maker is entitled to proceed, or that this process is an effective remedy for the purposes of European Union law or the Aarhus Convention. Both parts require a reasoned response, and the duty to take the submission into account and to give reasons attaches to the whole of it.
Within Part B, one move carries into all four documents. Fingal has moved the noise baseline from 2019, the year its own statutory directions twice fixed, to 2023, the year of the highest population exposure ever reported at this airport and the first to contain the deviated post-2022 routes. Measured from 2023, the deterioration is never counted, and the route relief residents seek converts into headroom for growth. The same instrument demotes the one binding outcome, the duty that the population above 55 dB Lnight and 65 dB Lden shall be reduced, to an untargeted tracking indicator, so even the figure that would record the harm carries no duty to reduce it.
The scale of what is not being counted is set out in the annexes. Within 1.5 km each side of the track, the routes now flown newly overfly about 13,923 residents, against roughly 1,000 under a departure consistent with the route the Environmental Impact Statement assessed and the permission was granted on. At 3 km each side the figures are about 30,186 against 1,164. Neither count includes anyone already overflown by the legacy South Runway tracks. These are people brought under a departure track for the first time.
What the package offers them is insulation for homes at or above 60 dB Lden. Fingal’s own report recites the World Health Organization recommendation to reduce aircraft noise below 45 dB Lden, the level above which it is associated with adverse health effects, and Fingal’s own appendix counts 14,350 people in the 55 to 60 dB band immediately below the eligibility line. The objective sets no limit at all on the single loud overflight.
The powers to do otherwise exist and have never been used. Fingal has taken no enforcement action of any kind under the Aircraft Noise (Dublin Airport) Regulation Act 2019 between 2019 and April 2026. The authority France designates under the same European Regulation issued 637 sanctions in 2023 alone, totalling about 11.7 million euro. The enforcement framework is real, and its non-use here is not a limitation of the framework.
A lower-noise route costs the airport nothing it currently has. The throughput the present geometry serves is carried by the divergence between departures, and the redesign the group has put to the responsible bodies preserves that divergence by moving it onto the missed approach. No responsible body has assessed it.
The analysis behind the submission was carried out by the group because the bodies with the duty, the data and the resources did not. Acting as the noise authority, Fingal twice directed the airport operator to produce the route-attributable assessment and the comparison against the 2019 baseline. Asked in 2026 for its comparison of the routes flown against the routes assessed, the operator answered that it holds no such record. The group reconstructed the missing analysis from the operator’s own noise-monitor measurements, released under access-to-information law, and published it in full with the source data and mapping projects, so that any competent party can rerun it.
Submissions closed at 5pm on 3 September 2026. Fingal must take this submission into account and give reasons before it makes a regulatory decision.
The documents
These are the documents as filed with Fingal on 29 August 2026. Each page carries the digital object identifier of the deposit that fixes its text and date.
- Submission to the Aircraft Noise Consultation (PDF, 146 pages, 0.6 MB)
- Annexes A to D, F, G, I, J and K (PDF, 99 pages, 7.8 MB)
Two annexes are separately deposited technical studies, cited in the submission rather than reproduced: the geospatial impact study at doi.org/10.5281/zenodo.19567671 and the single-event LAmax model at doi.org/10.5281/zenodo.19567721. The submission itself is deposited at doi.org/10.5281/zenodo.22158002.