Dun Laoghaire Cruise Berth Facility – An Bord Pleanala Submission - August 2015 (Gen) Sailing Impact / Impact on other Harbour Uses & Users 1. The Heritage of Sailing in Dun Laoghaire Harbour There is a huge heritage of sailing in Dun Laoghaire. Since the harbour was completed in 1859, there has been a vibrant and important usage of its facilities by the sailing community. Early records show that there were three classes of sailing craft using the Dun Laoghaire locality even before the harbour was built. Dun Laoghaire is then described as “The Cradle of Yacht Racing”. Once the shelter afforded by the harbour was completed, sailing use accelerated and for the last 155 years, Dun Laoghaire has been the jewel in the crown for Dublin’s (and Ireland’s) marine leisure use. The addition of the public 840 berth marina in 2000, after years of delay, saw a further and rapid acceleration of sailing in the Harbour and in Dublin Bay. DBSC (Dublin Bay Sailing Club) is an institution of Dun Laoghaire since 1884. DBSC is the “glue” that binds the sailing community (junior & senior) together in Dun Laoghaire. The Water Wags sailing association has been actively and continuously sailing in Dun Laoghaire Harbour since 1887. They are the oldest dinghy class in the world and credited with being the “founding father” of modern Olympic one design racing. The Royal Alfred Yacht, founded in 1857, is credited with drawing up the first codified Rules of Yacht racing. This is a deep heritage. The harbour continues to be used by a wide variety of uses and users in 2015. 2. The Importance of Dun Laoghaire Harbour Dun Laoghaire Harbour is a natural safe protected area of open water. It is a large open recreational facility. It is equivalent to a large green “open space” in a housing development. It was built in 1887 as an “asylum harbour” for ships to take safe refuge from adverse gales, sea and tidal conditions while waiting to enter Dublin Port. Dun Laoghaire Harbour was never designed to be a commercial port for the berthing of massive 70m x 340m cruise vessels. The huge and intimidating scale of modern cruise ships, the height of Liberty Hall, will compromise if not seriously damage the attractiveness of Dun Laoghaire harbour as a sailing venue. It is an amphitheatre, viewable from all sides and has been described by ISAF, Sailing’s World governing body, as “the best sailing venue in the world” It is a thriving national and international centre of sailing training excellence. Being able to sail within the Harbour in adverse weather conditions is a major advantage both in sail training. Dun Laoghaire Harbour is the “gateway” for 1,000s of boat users and water sports enthusiasts to access the 40 square miles of Dublin Bay. 1 Dun Laoghaire Cruise Berth Facility – An Bord Pleanala Submission - August 2015 (Gen) 3. Role of Dun Laoghaire Harbour / Management of Dun Laoghaire Harbour There is a clear conflict between the role of the Dun Laoghaire Harbour (DLH) and the role of the Dun Laoghaire Harbour Company (the applicant). It is DLHC’s view that Dun Laoghaire Harbour is” first and foremost a Working Harbour”, which incorporates a marine leisure component which must function in a manner that does not detract from the primary function of the harbour. This is clearly at variance with the National Port’s Policy 2012 – see extract in appendix 1. The sailing and boating peoples view - in accordance with the NPP - is that it should always be “first and foremost a marine leisure harbour”. It is a Public Amenity. Commercial interests should not be permitted to take precedence over the long established marine leisure use. Of the 139 submissions received from the public during the consultation process, 135 were against this cruise berth proposal and only 4 were for it. With that level of objection, surely DLHC cannot rely on their “working Harbour” assertion and cannot ignore the “marine leisure” requirement and impact on sailing. Dun Laoghaire Harbour is to sailing & maritime activities in Dublin (& Ireland) as Croke Park is to the GAA or the Aviva is to Rugby. 4. Harbour Users Harbour users include are immense and multi faceted, it is not just sailors There is a sleeping giant of a multi-faceted marine industry that should be nurtured, properly developed and positively facilitated in Dun Laoghaire Harbour. 5. Access for the Public to the water Harbour users use Dun Laoghaire harbour for all sorts of maritime activities and for access to the water, to the harbour and to the open waters of Dublin Bay. 6. Sailing in EIS The impact on sailing and boating, together with the economic value of sailing for Dun Laoghaire, has not been fully and comprehensively addressed at all in the EIS. 7. Sailing Footfall, Infrastructure & The Value of Sailing to Dun Laoghaire Sailing footfall and the consequent economic benefit of sailing to Dun Laoghaire Harbour and to Dun Laoghaire Town is huge. The estimated footfall of persons sailing regularly in Dun Laoghaire is conservatively in the order of 300,000 to 350,000 people per annum. The sailboats and the sailing events are themselves an important part the spectacle that attracts millions of Dubliners and other visitors to Dun Laoghaire 2 Dun Laoghaire Cruise Berth Facility – An Bord Pleanala Submission - August 2015 (Gen) 8. Economic Benefit of Sailing The economic benefit of 350,000 sailors in Dun Laoghaire annually is estimated to be €10 million per annum. Sailing Impacts 1. Proposal is an inappropriate Use for Dun Laoghaire Harbour This proposal for a 435m pier in the middle of the harbour is not in the best long term interest of the harbour or its environs. Large cruise ships would be much better catered for in Dublin Port as they will not impact on other Port/Harbour uses or users. This represents a dominant preference of commercialisation of the Harbour over established uses and users 2. Proposal contravenes National Ports Policy (NPP) Dun Laoghaire Harbour should be developed for leisure and marine tourism and cultural amenity rather than for large scale shipping activities. Similarly, planning policy requires a Public Authority (DLHC) to justify proposals and the business case for the development of a similar facility in the same locality under Section 37(A)2 of the Planning & Development Act 2010. In this case, DLHC has failed to justify this proposal. 3. Proposal will cut Dun Laoghaire Harbour in two With this proposal for a 435m pier in the middle of the harbour, which itself is only 650m long, will cut the harbour into two. It will be permanent and irreversible. 4. Impact of Mariner’s Notices on restricting Sailing Activities in the Harbour This restricted area is defined in the Harbour Masters Notice to Mariners No 4 (2015) (attached in appendix 2) will result in an impossibly small and restricted Harbour Recreational Area for Small Craft in the Harbour. It is defined as “the North Bite, westwards of a line from the West Pier Lighthouse to the Marina Breakwater” for sailing and racing within the harbour. The assessment of this issue in the EIS is totally inadequate and is based on a misinterpretation of the current use profile and balance and coexistence of use within the Harbour notwithstanding the issue of the Mariners’ Notice 2015. Such balance between sailing and other uses of this Asylum Harbour has co-existed since the Harbour was first constructed. The Human Beings section and the socio economic assessment of the EIS is fundamentally flawed in relying on the Mariners Notice as the baseline conditions. 3 Dun Laoghaire Cruise Berth Facility – An Bord Pleanala Submission - August 2015 (Gen) The consequences for other harbour uses and users would turn the Harbour from an amenity architectural conservation area to a back end port area with restricted access. The sailors who sail in these restricted areas include disabled sailors, special needs sailors, junior sailors, trainee sailors of all ages, Wag class sailors etc. It will not be possible to have meaningful sailing or the different sailing events in the Harbour. The whole junior programme will have to be severely curtailed and could even be forced to move. Logically, with no junior sailing today, there will be no senior sailing in 5 years’ time. This will lead to the gradual demise of the yacht clubs, sailing schools and ultimately to the ruination of sailing in Dun Laoghaire Harbour, with the consequent loss of significant economic benefit from sailing to Dun Laoghaire Town of the value and order of €10m pa. It will not be safe to have junior sailing inside the harbour during the time these cruise ships arrive (6am – 9am) and depart (3pm and 7pm). The scale of the ships the equivalent of a 14 storey tower building (the size of Liberty Hall x the length of Croke Park) extending the length of a comparable street from Connaught Place to the Railway Station (which is exactly 400m) would dominate the space within the harbour and the use and amenity of that space. No sailing (junior sailing or senior sailing – in big or small boats) will be permitted at all in the harbour, on Health & Safety grounds, while these ships are idling, with their engines on, in the cruise berth for the duration of their 12 hour stay in the Harbour from 6am to 6pm. 5. Impact on Sailing Activities & Racing in the Harbour With the 435m pier structure in the Harbour, Sailing Courses / Racing tracks will not be able to be accommodated in the Harbour and there will be no in-harbour sailing or racing. The necessary racing course layouts and course lengths will not be possible. (You need a GAA pitch to play a GAA match). The extent of open water required for sailing is dependent on the wind direction which can change through 360 degrees of the compass from day to day. Sufficiently sized courses (the GAA pitch) are required, depending on the wind direction. The 2 types of courses – Triangle and Sausage – cannot be accommodated in the harbour. For each of these courses, all of the current open water space within the harbour is fully used up. In their public consultation document under the FQA, the DLHC dismissed these sailing facts has included the following by asserting “It will still be possible for racing to be held in the harbour, especially to the east of the Cruise Berth, albeit with smaller race courses”. Not possible. Attached in our submission are a series of diagrams to show the “normal” size of the Race course as laid within the harbour, for various wind directions. These diagrams show how the currently proposed Cruise Liner Berth will cut right across any racecourse. 4 Dun Laoghaire Cruise Berth Facility – An Bord Pleanala Submission - August 2015 (Gen) 6. Impact on Junior Sailing, Special Needs & Disabled Sailing The four waterfront sailing clubs and the Irish National Sailing School run extensive junior training courses in the 10 week junior summer sailing season – During the peak Cruise Season - attracting over 400, five to eighteen year old junior sailors in the Harbour every day, together with over 100 instructors, safety & rescue personnel. The entourage of parents and minders swell these numbers to well over 700 daily across the Dun Laoghaire waterfront.(35,000 pa). These courses are not just for children of members, but are offered to local schools and sailors from other clubs. It is not possible to move junior sailing to another safe location within Dublin Bay. Logically, with no junior sailing today, there will be no senior sailing in 5 years’ time. Loss of Junior sailing will lead to the gradual demise of the yacht clubs and ultimately to the longer term ruination of sailing in Dun Laoghaire Harbour and the historic clubs, with the consequent loss of significant economic benefit from sailing to Dun Laoghaire Town of the value and order of €10m p.a. “Dun Laoghaire is a spectacular world class sailing venue both on and off the water” said Göran Petersson, president of the International Sailing Federation (ISAF). Sail training for special needs and disabled sailors is catered for. The RSGYC hosted the sailing events for the Special Olympics in 2003. The DLCC, in association with Dun Laoghaire Marina, run an “Access to Sailing” programme providing boats and coaching for children with disabilities. With the 435m pier structure in the harbour, the harbour sailors will be forced to sail in restricted and congested areas within the harbour or go outside the harbour for less safe open water. Going outside the Harbour will expose young trainees to the full unpredictability of winds, waves, sea state, tides, visibility and fog in Dublin Bay. The Health &Safety risks to life for inexperienced sailors sailing in open waters outside the harbour are significant and can be extreme if the weather changes, or rain and fog obscures visibility. The Harbour provides a safe haven. Dun Laoghaire Harbour – the refuge Harbour was the base for the implementation of the National Emergency Disaster Plan on 7 July 2007, when over 150 junior sailors were unexpectedly caught out in a sudden squall in Scotsman’s Bay outside the Harbour and had to be rescued and towed into the shelter of the harbour. Easy access in and out of the Harbour is critical to ensuring the National Emergency Plan will work in the future. The Costa Concordia accident occurred within sight of shore. The risk scenarios are heightened at entering the harbour and docking and on leaving the harbour. The cruise time schedules are determined by the cruise line and this could have very serious consequences for other harbour uses primarily sailors but including all activities engaged in the harbour. The primary use of the Harbour will be for commercial shipping at the expense of long established and future development of sailing activities. This will result in the immediate severe curtailment and possible demise of junior sailing in Dun Laoghaire. 5 Dun Laoghaire Cruise Berth Facility – An Bord Pleanala Submission - August 2015 (Gen) Again, and in all these respects the proposed cruise berth facility runs directly contrary to Government’s National Ports Policy 2013 which states that Dun Laoghaire Harbour should be developed for leisure and marine tourism and cultural amenity rather than for large scale shipping activities. 7. Impact of Rules & Regulations & Colregs will destroy Harbour Sailing If the scale of the vessels do not do it, the Health & Safety regulations, the necessary harbour restrictions (- per notice to Mariners No 4 (2015), the required exclusion zones around the ship and seaways, the time delays forced on sailors to “keep Clear” regulations awaiting shipping movements or ultimately the International Maritime Regulations for the Prevention of Collisions at Sea (Colregs), will effectively destroy sailing in the harbour and in Dublin Bay. Shipping Lanes are the invisible roads in the sea and are regulated by the International Regulations for the Prevention of Collisions at Sea 1972 (COLRegs). The impact on sailing caused by the Colreg legal restrictions for up to 5 kilometres out into Dublin Bay (a safe distance), will be enormous for all sailing and for all local, National and International sailing events in Dublin Bay. 8. Impact of Wind Shadow will destroy DBSC Sailing in Dublin Bay and Harbour Sailing Sailing is always at the mercy of the wind. Yachts need wind to sail. Sailing in the harbour in any meaningful way will be entirely compromised and impossible caused by the wind shadow created by the pier structure and the sheer scale of these massive 70m high x 340m long ships while berthed in the Harbour. These ships are the height of Liberty Hall in Dublin. There will effectively be no wind on the leeward side of the ship (at the West Pier side) for the entire day the ship is berthed in Dun Laoghaire harbour and the wind pattern on the windward side of the ship (the East Pier side) will be greatly disturbed, as to render useless any hope of fair racing or sailing in a steady wind in the Harbour. The Cruise season (April to October) coincides with the peak sailing season (April to October). The EIS states that the development “ is not predicted to be a significant impact.” The EIS states that “Wind shadow will not prevent sail training or racing”. This is factually incorrect. The EIS and the application is premised on a false understanding of the nature of sailing within the harbour and the argument is advances that the area allocated to sailing within the harbour remains relatively the same in percentage terms when consideration of the Fairway for shipping is taken into account. These arguments ignore the basic premise of sailing and racing. The EIS is fundamentally flawed in both its analysis of harbour uses and activities, assessment and mitigation and is misleading in its conclusions. Junior sailing will not be safe around these ships while in harbour. The wind shadow effects are demonstrated by maps in our submission. 6 Dun Laoghaire Cruise Berth Facility – An Bord Pleanala Submission - August 2015 (Gen) Outside the harbour in Dublin Bay and for up to 5 kilometres from the Harbour, the wind shadow effect, the bow wave turbulence and the propeller track (or azipod jets) disturbance from these enormous 70m high x 340m long ships approaching and departing Dun Laoghaire Harbour will have a huge impact on the two DBSC (Dublin Bay Sailing Club) racing areas in Dublin Bay. The effects of the shipping channel on DBSC racing, inside and outside the harbour is illustrated in our submission. World and European events require uninterrupted and open sailing areas for multiple appropriate length racing courses. ISAF (the International Sailing Federation) has endorsed Dun Laoghaire and Dublin Bay as a world class venue for World and European championships. The consequence of the proposed development is that it would impose significant wind shadow effects from cruise ships, which would mean that the endorsement of Dun Laoghaire and Dublin Bay as a world class venue for international sailing events would be lost. 9. Economic impact of Displacement of other Harbour use & users Such international events as highlighted in the PMCA economic review have significant potential for revenue generation of the order of almost €10m from DLH hosting international sailing and sporting events during 2014-2022. Cruise ships which give little back to the local economy but require significant service infrastructure have the potential for significant displacement of other uses and on the economic activity of Dun Laoghaire. The PMCA report further highlights the potential for the proposed project, if realised, to displace existing leisure activities in-and-around DLH, such as yachting/sailing and other water sports. Already in 2015, the RSTGYC has secured the Laser Radial World Championship 2016 for Dun Laoghaire in 2016, The same DL International Sailing Events committee also estimates an economic impact of almost €10m from DLH hosting international sailing and sporting events during 2014-2022. The wider economic effects, stemming from the international coverage of the area, are estimated in the publication to average well over €10m per year between 2014 and the end of the decade, with the hosting of the Youth Olympics estimates to have an international media coverage impact of €25m in 2022. 10. Impact on ability of Dun Laoghaire to attract International Sailing Events to Dun Laoghaire Event planning will be compromised by Harbour restrictions imposed for cruise ships As with any sports, major International sailing events are planned months and even years, in advance. Sponsors are secured and Capital spending commitments are also made well in advance, to guarantee the event. Harbour restrictions imposed on event organisers and sailors during these events will not be possible. Either the International event will have to be cancelled or the cruise ship visit will have to be cancelled. The reality is that both cannot co-exist. 7 Dun Laoghaire Cruise Berth Facility – An Bord Pleanala Submission - August 2015 (Gen) ISAF regulations require that shipping movements, wind shadow effects, wave turbulence and propeller disturbance across the race course are not allowed to affect International sailing events. If they do, ISAF will not award the event to Dun Laoghaire. The sailing assets and the opportunity for a sustainable vision based on, amongst other things, international sailing events would be displaced by the proposed development. Large International Sailing Events provide the vision that would underpin a sustainable future for DLHC .The plan is for one major international sailing event in Dun Laoghaire at least every two years”. It’s planned approach over this period will open up other pinnacle events like the ISAF World Championship held every four years, valued at €25m to the host country or to bid for the Youth Olympic Games 2022 for Dublin”. The sailboats and the sailing events are themselves an important part the spectacle that attracts millions of Dubliners to Dun Laoghaire The ISAF Youth Event in 2010 as an example involved 600 participants, plus coaches & their entourage and continued for 2 weeks. It was followed by the ISAF Global Conference in Dun Laoghaire in November 2012 when an official commendation by the ISAF of Dun Laoghaire described it as “the best sailing development port in the world”. The economic value of this event was estimated at €25million to the economy. 11. Impact on Health & Safety The Health &Safety risks to life for inexperienced sailors sailing in open waters outside the harbour are significant and can be extreme if the weather changes, or rain and fog obscures visibility. The very thought of junior crew in a small craft with no steerage or no speed (because they have no wind) in the vicinity of massive cruise ships is frightening to contemplate. Wind shadow will prevent small craft without motors from sailing or manoeuvring out of the way of oncoming ships, entering and exiting the Harbour. Vessel safety requirements by Cruise Companies will restrict boat & sailing movements within the harbour and within the approach (and departure) channels in Dublin Bay. Health & Safety legislation will require adequate safety clearances and will necessitate timing restrictions in seaways reserved for these ships Ships with limited ability to manoeuver in confined spaces, need a minimum speeds to manoeuvre and higher speeds in stormy weather conditions with high winds, big waves and rough seas. Stopping without causing damage or disturbance to the seabed, to the marina breakwaters, to the Piers and to the harbour walls and roundheads is not easy? Accidents are waiting to happen. The cruise ships have no ability to avoid becalmed small craft. The HSS was much smaller, more manoeuvrable and unrestricted by draft (depth) with a Captain that understood sailing and winds. 8 Dun Laoghaire Cruise Berth Facility – An Bord Pleanala Submission - August 2015 (Gen) Dun Laoghaire will have no back up service instrastructure of pilots and tugs to guide cruise ships safely to berth and dock. 12. Impact on Natural Openness of the Asylum Harbour The proposed 435m pier structure in the harbour, will eliminate the original historic purpose function and the concept of the “asylum Harbour” as a safe refuge for vessels seeking shelter in bad weather or poor tide conditions and visibility. The Natural openness of the 251 acre Harbour will be lost forever by this permanent and irreversible structure. 13. Impact of Commercialisation of Dun Laoghaire Harbour With the 435m pier structure in the harbour, it opens up the potential for the DLHC management to change, to the detriment of other uses and users in the Harbour, the traditional dynamic of the large open marine leisure sailing harbour into a commercially oriented industrialised 24/7 year round commercial harbour with six shipping berths and eight navigational seaways (shipping Lanes) into these berths and to the Irish Lights and to the Coal Harbour. The economic impact of the DLHC’s approach, and a hardened Harbour Master approach as a result of this objection – see Mariner’s Notice No 4 (2015) - would likely be catastrophic for marine leisure uses and users, including sailing and the spectacle of sailing, in Dun Laoghaire Town and in the Harbour. The concept of Dun Laoghaire being a gateway for ferry passengers into Ireland is now over. All varieties of Stena Ferries have gone. Alternative low cost airlines (Ryanair) and improving wealth has killed the ferry passenger market. Dublin Port, with fast access to the port tunnel and the M50 (and all points across Ireland) for passenger vehicles and commercial traffic is again the preferred destination. Dublin Port wins each time. It has the infrastructure and does not have the same effect the on existing uses or the users of the Port. 14. Impact of Competition from Dublin Port A similar berthing facility, designed specifically with the same size target cruise-ship, is also included in Dublin Port. This will immediately undermine the viability of Dun Laoghaire proposal. The destination for Cruise ships is Dublin City. The EIS fails to fully and comprehensively deal with the impact of this competition on the viability of the Dun Laoghaire proposal. 15. Policies / Decision An Bord Pleanala must resolve the vexed question (“the monkey in the room”) of the role of Dun Laoghaire Harbour in the National Ports Policy and the necessary priority of marine leisure use & users over commercial or cruise shipping (or vica-verca) and the appropriate management structures necessary for the Harbour as a result of these decisions. 9 Dun Laoghaire Cruise Berth Facility – An Bord Pleanala Submission - August 2015 (Gen) The National Ports Policy document states that:- While the port’s location in the heart of Dun Laoghaire limits its potential as a transport hub, it provides significant opportunities. It has become increasingly clear over the past decade that the long-term future of Dun Laoghaire Harbour Company will be in terms of marine leisure, maritime tourism, cultural amenity and urban redevelopment. See attached NPP Policy extract in Appendix - 1 Making Dun Laoghaire Vibrant Again There are plenty of worldwide examples of successful developments of waterfronts and piers. We don’t need to reinvent the wheel to find a solution. Use the sea to lure people – Irish and Dublin people. The piers in Dun Laoghaire have been a fantastic attraction for nearly 200 years. There is no single solution. It must be a cocktail of a lot of smaller elements working together in an actively managed 7 day / 365 year round complex. It must be like an “open shopping centre” with a strong versatile manager. There is a sleeping giant of a multi-faceted marine industry that should be nurtured, properly developed and positively facilitated in Dun Laoghaire Harbour. The consequence of the proposed development is to undermine the sailing assets currently in Dun Laoghaire harbour. Create a National Sailing Event Centre, similar to the UK’s Weymouth and Portland National Sailing Academy or the Welsh Pwillheli sailing academy. Professionalise the exercise of attracting International sailing, boating, rowing, scuba, nature, bird watching etc events. Broaden horizons in the marine sphere. Develop a comprehensive “destination” marine leisure sailing & power boating Provide restaurants, themed bars, nightclubs, pavilions, exhibition areas, retail offerings, off continuous waterside boardwalks etc. Develop quality retail offerings around and associated with the marine industry – look at every marina in the world with lots of retail and restaurant spaces. Introduce ground floor showroom space for multiple managed commercial displays or exhibitions – “hot-desking concept” – used by multiple dealerships and exhibitions throughout the year for all sorts of events – like boats, cars, motorbicycles, etc etc – in good weather and in bad weather. Provide a roofed open venue for regular and impromptu concerts & events – like Millenium Park, Lake Shore Drive, Chicago 10 Dun Laoghaire Cruise Berth Facility – An Bord Pleanala Submission - August 2015 (Gen) Include a Diaspora Museum, the Jennie Johnston, a Children’s Museum, vibrant ideas that have been suggested for years for Dun Laoghaire. Provide car parking – plently of it – and charge if you have to, but not as rigidly policed as currently. Parking costs and clamping in DLRCC is a massive deterrent to visitors. Build affordable parking into the scheme. Develop the Coal Harbour area for fishing, fish markets, marine food, chandlery, boat-yards, international sail lofts and lots marine related uses. Create the space and target the end users. Reclaim shallow inner harbour areas for some larger hard-standings for boat parking and international sailing events. The plan has to face up to the fact that there will be peaks and troughs in DL depending on the weather. The objective is to attract more Irish & Dublin people to Dun Laoghaire – every week – not occasional tourists under time pressure from the cruise companies to rejoin their ships before their rigid departure time. Management of the Harbour Dublin people love and support Dun Laoghaire. Devise a water based and marine focused plan. Develop a sustainable programme. Build in a private financing model to attract private equity. Allow sensible investment returns for private equity. Don’t be overly ambitious. Expect some failures. Try again. Transport links are already in place. Prime the plan with public funds. Use the €18 million targeted for the cruise berth to develop the waterfront. Unfortunately, the existing harbour management clearly do not have the necessary skill set, the required breath of vision and or the active management culture required to make Dun Laoghaire successful. Remember, decisions taken today will determine the future of Dun Laoghaire for decades. What happens now will determine the future of Dun Laoghaire for decades. 11