North Runway Technical Group

How a passenger cap became a baseline

Story 8 of 13

In 2007 the planning board gave Dublin Airport permission for Terminal 2, with a condition. The two terminals together “shall not exceed 32 million passengers per annum unless otherwise authorised by a further grant of planning permission.”

Read the second half again. The condition comes with its own way out: ask for permission. And for something that size, a permission means an environmental assessment.

Remember “a further grant of planning permission”.

For the next eleven years daa didn’t ask. By 2018 it was at 31 million.

It also built a facility for transfer passengers, separate from the terminals. Its view is that people changing planes don’t count, because they never come through the terminal doors.

In 2023 it filed one giant infrastructure application, a bundle of projects running to 7,000 pages, with 40 million passengers among them. Fingal came back with a request for further information that ran to 407 pages.

In December 2024 it tried a smaller one: 36 million, nothing to build, so, it said, no assessment needed. Fingal declared it invalid. daa resubmitted. Fingal asked for more information. daa objected to being asked, never answered, and Fingal declared it withdrawn.

In 2026 the Oireachtas passed a law. The Dublin Airport (Passenger Capacity) Act lets the Minister amend or revoke the passenger cap by order. No further grant of planning permission required.

In August 2026 daa applied under it, for 40 million. Its view on the environment: no assessment needed (story 4 has that one). The law does let the Minister ask for an environmental report, so daa provided its preliminary findings, “without prejudice” to its view that it doesn’t need to.

So, an assessment! Let’s look at it.

An assessment compares two futures: one where you get what you asked for, and one where you don’t. daa’s “do nothing” future is 2029. In it, the North Runway opens an hour earlier and closes an hour later than now. The annual cap on night flights that ACP set in 2025 is gone. Both of those are in the “with” future too. So the longer night and the missing cap sit on both sides of the scales, and weigh nothing.

And the starting point, labelled “Existing Permitted Capacity”? It’s built from what was actually flown in 2023, “route structures” included. Those are the routes that turn over people. Nobody assessed the switch to them. In a document on the Minister’s desk, they’re now the permitted baseline.

So, here’s where we’ve landed. In 2007 the planning board said: you can go past 32 million passengers, but you have to get a further grant of planning permission, and that means looking at what it does to people. Nineteen years later the further grant of permission can be skipped, with a Minister’s order instead. The applicant says European law doesn’t require anyone to look. And the look it provides anyway starts from the unassessed routes, puts the longer night and the lost cap into both columns, and, on its preliminary findings, finds, unsurprisingly, that the difference is small.

The cap was there to make someone look. They are looking now, at a picture with all the changes already in it.

Sources
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