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Submission to Review of TEN-T

The Department of Transport has recently published its submission to the European Commission on proposed revisions of the TEN-T network see here.

The Department advocate for the inclusion of the Atlantic seaboard region of Ireland on the TEN-T Core Network, which the WDC welcomes. In his submission, Minister Ross provides the national policy context, in particular noting the overarching objectives of Project Ireland 2040.

We need to manage more balanced growth … because at the moment Dublin, and to a lesser extent the wider Eastern and Midland area, has witnessed an over concentration of population, homes and jobs. We cannot let this continue unchecked and so our aim is to see a roughly 50:50 distribution of growth between the Eastern and Midland region, and the Southern and Northern and Western regions, with 75% of the growth to be outside of Dublin and its suburbs[1].

One of the key objectives of the NPF is to move away from ‘business as usual’ and to redirect growth to other areas. In making the case for inclusion of the Atlantic seaboard region of Ireland in the Ten-T Core Network, Minister Ross also notes the adverse impacts of Brexit noting that,

Continued EU support for transport investment projects in Ireland will become even more important in the context of Brexitafter which our peripheral location on the western point of Europe will leave us even more isolated from other EU Member States. While Project Ireland 2040 aims to highlight the actions, including capital investmentrequired to strengthen the Northern and Western Regions and mitigate the adverse effects of the UKs exit from the EU which are expected to impact disproportionately on this area, its inclusion on the Ten-T Core Network would result in further Irish projects being eligible to apply for Connecting Europe Facility (CEF) funding, thereby contributing to the balanced development of our regions….

Policy and funding alignment

While the WDC welcomes the views expressed by the Department of Transport in relation to inclusion of the Atlantic seaboard region in the Ten-T Core network, in reality, for funding to follow from Europe, the Department of Transport needs to prioritise funding for Atlantic Economic Corridor Transport projects. So, for example the Capital Investment Plan allied to the NPF identifies transport projects for investment in the AEC region but many of these are not planned to occur until towards the end of the 10-year period, unlike other projects which are prioritised in the next few years.

The WDC have argued following publication of the NPF 2040, that if sectoral policies are not aligned to support the objectives of Ireland 2040 then Ireland 2040 is likely to fail. The National Aviation Policy (2015) predates the publication and consideration of Ireland 2040. The National Aviation Policy can be seen to unduly reinforce the dominance of the larger airports (Dublin in particular).  Now that the NPF is Government Policy, the National Aviation Policy should be reviewed and reassessed in light of the overarching objectives of the NPF and the need to ensure sectoral alignment. In the absence of such reviews it is difficult to see how development can move away from a ‘business as usual’ approach and how the NPF can achieve its targets. It is sectoral planning and policy that is the real driver of spatial and regional development.

 Aviation trends

As the WDC pointed out in its Submission on Future Airports Capacity Needs at Ireland’s State Airports see here, the West and North West region in particular has relatively poor accessibility by air, which is the preferred transport mode for international access.

The CSO Aviation statistics, Quarter 4 and year 2018, see here, highlight the trend of the increasing concentration of air passengers travelling through Dublin airport compared to other airports. For example, in 2014, Dublin accounted for 81.9% of all passengers (Total = 26.5 million), compared to 85.6% in 2018 (Total = 36.6 million). This represents an increase of 9.6 million passengers in 4 years, a 44.2% increase. So along with a significant increase in total air passenger numbers, there is an ever-increasing share travelling through Dublin airport.

This ever-increasing concentration is of concern to those supporting exporters. For example, the

IEA submission to the Draft National Planning Framework noted that of those IEA members surveyed who use airports to export, 81% use Dublin airport predominantly as their primary route to ship goods out of Ireland. 15% said that this was not the closest airport geographically. Members surveyed said that they would use a different Irish airport as their primary route to ship goods from Ireland if:

  • There were more frequent flights from another airport – 36%
  • Road networks between primary distribution centre and another airport were improved – 23%
  • Another airport was upgraded – 14%

The implementation of hub connectivity from the west of Ireland directly into Heathrow or another European hub airport (example Schiphol or Frankfurt) would significantly enhance business connectivity and attractiveness to locate in the west of Ireland[2].

The WDC considers that with Dublin Airport, operating at or near capacity, cost-efficient and accessible alternatives to Dublin are required. Shannon and Ireland West Airport Knock are important transport centres enabling the international success of businesses in Ireland’s West and North West.

The WDC believes that there needs to be consideration of how the other State airports, in particular Shannon (given the remit of the WDC) can be more effectively supported through policy changes to deliver on the regional growth targets of the NPF.

 Role of ‘Regional Airports’

Similarly, the WDC believe that the role of regional airports has to be reviewed in light of the NPF and its regional population and employment targets. The Department of Transport is currently conducting a consultation on the Preparation of new Regional Airports Programme 2020 to 2024.

The Regional Airports Programme provides for funding to regional airports to help them deliver on their goal as outlined in the National Aviation Policy. Recognising the relative difficulty which smaller airports have in both meeting operating costs and attracting and retaining air services, the Department provides support under different funding mechanisms. These funding schemes are governed by EU guidelines on State aid some of which apply to airports handling up to 3 million passengers per year.

As the consultation document highlights, all regional airports are not equal! While passenger numbers at all four regional airports are less than 1 million annually, three of four have less than 400,000. The exception is Ireland West Airport Knock which has had annual passenger numbers in excess of 700,000 for the last three years. This is because Ireland West Airport Knock essentially serves the same purpose for its region (the North West) as the State airports perform in the Mid-West, South-West and East respectively. National aviation policy needs to fully recognise the international transport function Ireland West Airport Knock provides, ensuring direct international air services to a region much of which is not in the catchment of the other international airports, Dublin, Cork and Shannon.

The WDC believes that the road improvements planned for the North West will help support greater traffic through Ireland West Airport, which in turn will allow Ireland West Airport Knock perform a key role in supporting the Government’s wider/broader policy objectives of delivering the population and employment targets for the Northern & Western Region under Project Ireland 2040. The road improvements must be prioritised.

Similarly, Shannon Airport with passenger numbers under 3 million (and therefore eligible for capital support without prior EU State approval) can help deliver the objectives of Project Ireland 2040, to enable the cities of Limerick and Galway on the Western seaboardto each grow by at least 50% to 2040 and to enhance their significant potential to also become cities of scale[3].

All sectoral policy areas, in this case – EU TEN-T, National Aviation Policy and the Regional Airports Programme – highlight the importance of an overarching policy framework, to which all other policies should be aligned in so far as possible. Without alignment, delivery on the overarching policy objective of Project Ireland 2040, is unlikely.


Deirdre Frost


[1] Project Ireland 2040, NPF, 2018, p.11


[3] p.22.