A “Balanced Approach”
According to An Bord Pleanala’s Inspector for the ongoing “Relevant Action” the ICAO Balanced Approach is relevant. She writes:
1.12.1 The “Balanced Approach” stems from international guidance for aircraft noise and consists of identifying the noise problem at the airport and the exploration of various measures to reduce noise. The end goal is to achieve the maximum environmental benefit, most cost-effective method, using objective and measurable criteria. The four elements of the Balanced Approach include:
1. Reduction of Noise at Source (Technology Standards)
2. Land-use Planning and Management
3. Noise Abatement Operational Procedures
4. Operating Restrictions.
It must be obvious that two of these are completely ignored by daa regarding operation of the north runway. There has been no “Balanced Approach” to operation of the north runway.
1. Land-use Planning and Management
The noise zones from the 2007 EIS were promulgated to Fingal and Meath County Councils and included in both county development plans for over 15 years. Planning permission was granted and denied based on those zones.
The aircraft noise today is not contained within the published zones. Homes were denied permission at locations that are not now overflown and homes were granted permission in locations that are now subject to extreme noise disturbance.
The Land-use Planning and Management effort between 2007 and now has been fundamentally undermined by daa and made the environmental impact worse than had there been no such effort at all.
2. Noise Abatement Operational Procedures
The airport’s general NAOP requirements conflict with the SID for the north runway 28R.
3.2.1 Departures from all runways except Runway 10R, must track the runway extended centreline after take-off until passing 750ft and then proceed in accordance with the relevant Instrument Flight Procedure published departure track and adhere to published altitude/level restrictions unless otherwise cleared by ATC.
The RWY28R SID conflicts with this, requiring the turn at 650ft (AMSL), 100ft lower. This is the altitude promulgated to the Flight Management Systems in the aircraft. Thus, every departure following the SID as required by NAOP 2 is in breach of NAOP 3.2.1.
For many of the aircraft using RWY 28R departures is not possible to simultaneously:
- Comply with the SID
- Comply with NADP2 (NAOP 3.2.4)
- Operate the aircraft within safe operational limits
NAOPs 3.2.3 and 3.2.4 when combined with the bank angle and speed limit required to confirm with the SID, routinely conflict with the safe operating speeds of the aircraft. The designer of the SID did not consider noise abatement or compliance with the NPR as requirements and did not understand the real-world performance capabilities of the aircraft.
NAOP 8 is nonsensical as it applies to the RWY28R SID. Strict track keeping on a SID that diverges perpendicular to the Noise Preferential Route achieves nothing but propaganda for the aerodrome operator who has redefined the meaning of NPR to suit.
Unlike at many airports, there is no penalty for failure to comply with the NAOPs at Dublin Airport. No action is taken even when SID deviations are reported via daa’s online system and confirmed by daa. Even when such events are confirmed by daa and notified to AirNav, follow up communication from the complainant to AirNav is ignored.
As far as “3. Operating Restrictions”, the purpose of the Relevant Action application presently before ABP is to remove the operating restrictions and give daa a noise quota so massive as to render night-time operations functionally unlimited.
As usual with daa, the Balanced Approach makes a good talking point with which to sound like “a good neighbour” until the facts are examined and it turns out daa’s only relationship with the Balanced Approach is to smash it to bits!
For reference from https://www.airnav.ie/getattachment/a091eb5d-50f6-45df-a381-5f8f11eb3928/EI_AD_2_EIDW_EN-(5).pdf?lang=en-IE
EIDW AD 2.21 NOISE ABATEMENT PROCEDURES
1. Aircraft operators shall ensure at all times that aircraft are operated in a manner calculated to cause the least disturbance practicable in areas surrounding the airport.
2. Standard Instrument Departures
Strict compliance with SID is mandatory.
3. Other Instrument Departures
3.1 Cat A, B Aircraft
3.1.1 Cat A, B Aircraft (Non Jet)
After take-off, pilots should ensure that they are at a minimum altitude of 750ft QNH before initiating any turn. No take-off turn shall be commenced before the departure end of the runway.
3.1.2 Cat A, B Aircraft (Jet)
Departures must track the runway extended centreline after take-off until passing 750QNH before commencing turn. No take-off turn shall be commenced before the departure end of the runway.
3.2 Cat C, D Aircraft
3.2.1 Departures from all runways except Runway 10R, must track the runway extended centreline after take-off until passing 750ft and then proceed in accordance with the relevant Instrument Flight Procedure published departure
track and adhere to published altitude/level restrictions unless otherwise cleared by ATC.
3.2.2 Departures from Runway 10R must track the runway extended centreline to 5NM before commencing turn to the north, or to 6NM before commencing turn to the south.
3.2.3 Take-off climb shall comply with the procedure detailed below, which is based on noise abatement departure climb guidance contained in PANS OPS Doc 8168 Vol 1 – Appendix to Chapter 3 – NADP2.
3.2.4 Take-off thrust, speed V² + 20 to 40 km/h (V² + 10 to 20kt).
3.2.4.1 At 240m (800ft) and while maintaining a positive rate of climb, body angle is reduced and flaps/slats are retracted on schedule as the aircraft is accelerated towards Vzf.
3.2.4.2 Power/thrust is reduced during the flap/slat retraction sequence at a point that ensures satisfactory acceleration performance.
3.2.4.3 (3000ft) Transition smoothly to en-route climb speed.
3.2.4.4 Cat C and D aircraft operating from Runway 28L directly to Weston or Baldonnel aerodromes are exempt from Sections 3.2.1, 3.2.2 and 3.2.3. These aircraft must not leave the environmental corridor below 1,500ft QNH.
3.2.4.4 Cat C and D aircraft operating from Runway 28L directly to Weston or Baldonnel aerodromes are exempt from
Sections 3.2.1, 3.2.2 and 3.2.3. These aircraft must not leave the environmental corridor below 1,500ft QNH.
4. Jet aircraft (Cat C/D) on visual approach to all runways must join final approach no closer than 6NM from touchdown. Aircraft must follow a descent path which will not result in being at any time lower than the approach path which would otherwise be followed using the ILS glide-path.
5. Runway 10L/R or 28L/R are the required Runways between 0600 and 2300HR Local Time when the crosswind component is 20KT or less. Runway 28L/R will be the preferential Runways when the tailwind component is 10KT or less and braking action is assessed as good. Aircraft will be required to use these Runways except when operational reasons dictate otherwise.
If the crosswind component on Runway 10L/R or Runway 28L/R is greater than 20KT Runway 16 or Runway 34 may become the active Runway. If the forecast crosswind component on Runway 10L/R or 28L/R is greater than 20KT Runway 16 or 34 may become the active Runway.
The use of Runway 16/34 will be kept to an absolute minimum subject to operational conditions.
6. Runways will be prioritised for noise abatement purposes between 2300 and 0600HR Local Time, subject to the same wind calculation method and values as used between 0600 and 2300HR Local time (see Section 5).
7. Reverse thrust should not be used during landing operations on any runway between 2300-0600HR Local Time, except where operational or safety reasons dictate otherwise.
8. Cat C and D aircraft using Runways 28L, 28R, 10L,16 and 34 shall operate within environmental corridors which are based on runway take-off flight path areas. The corridors have a width of 180 M at the departure end of the clearway,
diverging at 12.5% on each side to a maximum width of 1800 M, and extending in length to 5 NM from the point of origin. The corridors extend vertically from surface to 3000 ft AMSL.
Cat C and D aircraft using Runway 10R shall operate within an environmental corridor which is based on the runway take-off flight path area. The corridor has a width of 180 M at the departure end of the clearway, diverging at 12.5% on each side to a maximum width of 1800 M, and extending in length from the point of origin to 5 NM for the northern boundary of the corridor and 6 NM for the southern boundary of the corridor. There is no upper vertical limit to this corridor
The corridors apply for departures from each runway and also for approaches to the reciprocal runway, except for circling approaches