SAMPLE TEMPLATE

NOTE:This template summarises key points from SMTW's full technical submission on the Draft Regulatory Decision and the amended NoiseAbatement Objective for Dublin Airport (Ref: F23A/0781), which sets out each point above in full legal and technical detail. You do notneed to use this exact wording. A short letter in your own words, sent before the deadline, is what matters most. The more residents whowrite in, the stronger the record.

Template Letter: Objecting to Dublin Airport's Expansion to 40 Million Passengers a Year

Prepared by the St Margaret's The Ward Residents Group (SMTW)

How to use this template. Copy the text below into your own letter or email. Fill in the bracketed details with your own name,
address and the date, and add a sentence in your own words about how the noise affects you, since personal letters carry more
weight than identical copies. Check the current consultation address and deadline before you send it. Delete this box before
sending.
[Your Name]
[Your Address]
[Date]
The Aircraft Noise Competent Authority (ANCA)
Fingal County Council
[Consultation email or postal address, check the current notice]



Re: Submission objecting to the amended Noise Abatement Objective and Draft Regulatory Decision for Dublin
Airport (Ref: F23A/0781)
Dear ANCA,
I am writing to object to the proposed changes to the Noise Abatement Objective and the Draft Regulatory Decision that
would allow Dublin Airport to grow to 40 million passengers a year. [I live at/near [your area], within the area affected by
aircraft noise from Dublin Airport.] I ask ANCA to take the points below into account before making its decision.
This is not a minor update. It is being presented to the public as a routine tightening of noise targets, something that will
support improved health outcomes. In substance it allows a major expansion of the airport, and the new target is already met
by the airport's own forecasts before a single additional protective measure is put in place. An objective that is already
satisfied on the day it is adopted asks nothing further of the airport and protects nobody further. Worse, the practical effect of
this change falls hardest on the community that lives closest to the runway and already carries the greatest burden of noise.
The previous objective set binding L den and L night reduction targets for exactly this reason, to give real, enforceable protection
to the people most affected. Recalibrating those targets to a level already achieved removes that protection in all but name. It
is hard for our community not to feel that this change has been designed around us, the households nearest the North Runway
and most exposed to its noise, rather than for us. If the objective no longer requires anything further from the airport in the
areas where the harm is greatest, it has stopped functioning as a noise abatement measure and become a formality.
The airport's own noise modelling understates the real noise we experience. Independent monitoring carried out at homes
near the airport shows real noise levels running 2 to 5 decibels higher than the airport's model predicts, in places close to
double the sound energy the model actually reports. Every map used to decide who qualifies for insulation or buyout, and
every claim that the noise target is already met, rests on this same understated modelling. If the modelling is wrong,
everything built on top of it is wrong too, and it should not be relied on to decide who is protected and who is not.
The comparison year used to judge the airport's performance has also been changed in a way that flatters the result. The
objective used to be measured against 2019, before the North Runway opened. It is now measured against 2023, after the
runway had already driven a large increase in the noise our community experiences.
This baseline problem is made worse by an issue that has never been properly assessed anywhere in the planning process.
The actual flight paths flown by aircraft departing the North Runway to the west do not match the flight paths that were
assessed and approved in the original 2007 planning permission for the runway. daa's own documents submitted as part of the
current planning process admit that aircraft now turn much earlier, and on a materially different track, than the straight
departure route the 2007 permission was based on. No planning application, and no environmental assessment, has ever
examined what that change in flight path means for the noise experienced on the ground, by comparing the noise from the
flight paths that were actually planned and approved against the noise from the flight paths that are actually flown today.
ANCA cannot set a noise objective, or claim that a 2023 baseline fairly represents current operations, while this gap remains
unexamined. We understand that the Minister for Transport has also gone on the record to say that the flight paths now in use
are not correct and that an independent review of them should take place. If a Government Minister accepts that the flight paths need independent review, ANCA should require that review to happen, and its results to be known, before finalising a
decision that depends on those same flight paths being accurate.
The health harm to our community is not a theoretical risk. Sleep disturbance from aircraft noise is already happening in our homes, and it will only get worse as flight numbers increase. The proposed change to the Noise Abatement Objective will not
restrict growth at Dublin Airport and not one flight will be impacted. This will lead to flights leaving and arriving on all runways in all directions impacting on every community around the airport in the future if not impacted already.
The objective's own measurements rely on average noise levels over a night or a year, but that is not how we experience it.
We do not hear an average. We hear each individual aircraft as it passes over our homes, and it is that single loud event, not the average, that wakes a child, a shift worker or an elderly parent. During the day our lives are interrupted by noise from aircraft every few minutes. Our children are woken at night by aircraft noise, and the disruption does not end when they get up in the morning. It follows them into the school day, into their concentration and their mood, and into the homes of their
friends and family who live under the same flight paths. An objective built around averages misses the exact harm our community is describing to ANCA, day after day, night after night.

Finally, ANCA has not made any real attempt to look at alternative ways of operating the airport that could reduce noise at
the source. Insulation is a useful measure, but it is only one part of what is needed, and it does nothing for the noise we experience outside our own homes, in our gardens, on our streets, or on the school run. A genuine reduction in the noise itself, rather than simply muffling it once it reaches our windows, can only come from changes to how the airport is actually operated, such as adjusted flight paths, a cap on night-time movements, or alternating which runway is used. ANCA has not examined any of these measures as alternatives before setting its objective, and it should not finalise a decision that offers
only insulation while leaving the underlying noise, and the true cause of the harm, unaddressed.

On this basis, I ask ANCA to:
1. require independent verification of Dublin Airport's noise modelling before relying on it;

2. measure the noise objective against the pre-expansion (2019) noise levels, not the post-expansion (2023) levels, and restore binding L den and L night reduction targets rather than a target the airport already meets.

3. require an independent review of the North Runway's westerly departure flight paths against the routes assessed in the original 2007 planning permission, consistent with the Minister for Transport's own public position that such a review is needed, before finalising its decision.

4. properly weigh the health costs of the noise, including the sleep disturbance already experienced by this community, against the economic benefits of growth.

5. examine real alternative ways of operating the airport, such as flight path changes, night flight restrictions and runway alternation, recognising that insulation alone cannot deliver a real reduction in the noise outside our homes.

6. reinstate the L night and L den reduction targets as binding requirements, rather than recalibrating them to a level the airport already meets.

7. expand the Noise Abatement Objective to include awakenings based metrics, such as maximum event noise levels and the number of additional awakenings per night, informed by the most up to date independent expert evidence on the health effects of night time aircraft noise.

8. not approve the increase to 40 million passengers a year until these issues have been properly addressed.

I ask that ANCA take this submission into account before making its regulatory decision, and that I be kept informed of the
outcome.

Yours faithfully,
[Your Name]