Dun Laoghaire Cruise Berth Facility – An Bord Pleanala Submission – August 2015
Engineering Impacts
1. Dun Laoghaire Harbour is not big enough
Dun Laoghaire Harbour is just not big enough or long enough to safely accommodate these 340
meter cruise ships, the height of Liberty Hall. Any bigger ships will not fit.
The “Runway” from the Harbour mouth to the front of the berthing dock is not long enough. There is
just 270 meters (less than a full length of the ship) from the back of the ship to the harbour Pier wall
and Roundheads
The dredged channel and the Harbour Mouth is not wide enough, with any reasonable margin of
safety
2. Scale height and Visual Impact
The proposed pier will permanently and irreversibly split the harbour in two. The proposed pier is
435 metres long in a harbour that is just 650m long. It is enormous.
The proposal will effectively render the use of the whole harbour as a Navigable Seaway for
commercial shipping.
The length of the harbour is just 650 metres. There is just 270m from the stern of the ship in dock to
the harbour wall. It is not possible to fit 2 x 340m ships inside the length of the harbour.
The scale of the pier structures and the pylon dolphins, even without the ships, when fully dressed
with buffers and fenders will be monstrous within the harbour and unsightly, particularly at low tide,
and will have a significant impact on the visual amenity of Dun Laoghaire Harbour.
The berth is already obsolete in 2015 when the new generation of cruise ships - the Quantum Class
at 348m and the Oasis class at 362m are bigger than the Freedom Class at 340m.
Sailing of any form will not be possible in the safety of the harbour in or around these ships.
3. Commercialisation of the Harbour
The addition of this infrastructure will divide the harbour, render the whole harbour as a Navigable
Seaway (7 Berths & associated seaways) and will effectively reduce the use of the harbour to that
only of Commercial shipping.
4. Pollution – Noise & Air Pollution
Because there is not sufficient shore power for these ships, they will have to run their engines while
in Dun Laoghaire Harbour for the entire 12 hours duration of their stay. These engines are noisy and
emit massive pollution and black soot smuts into the atmosphere. This pollution will intoxicate the
entire waterfront population from Sandycove to Blackrock and beyond, depending on the wind
direction and strength.
As Ireland has not signed up to the Sulphates Directive of the EU, so these ships can burn cheaper
high carbon fuels in Ireland causing higher soot emissions
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Dun Laoghaire Cruise Berth Facility – An Bord Pleanala Submission – August 2015
The Board should satisfy itself that the noise and fume pollution emitted from these ships during
their 12 hour stay in Dun Laoghaire Harbour meets all the current and proposed national
environmental standards.
5. Health & Safety Risks / Disaster Planning
The EIS suggests that the management of disaster, grounding and collision risks, is by way of harbour
management in the form of further Notices to Mariners from the Harbour Master. It is our opinion
that this is entirely inadequate response and is deficient in its approach to the industry standard of
the hierarchy of Risk Control & Mitigation.
6. Planning Permission sought for Permanent & Temporary Facilities
The applicant has made an application for a permanent and irreversible pier in the middle of the
harbour but the application includes a significant number of temporary shore-side facilities,
including temporary bus parking, bollards, taxi and mini bus parking, seating areas, coffee shops,
information centre, bin store etc. The Carlisle pier and Accommodation are temporary bus
marshalling areas. Is this an application for a Permanent or Temporary facility?
The applicant is clearly “hedging his bets” for further large scale development.
We would ask the Board to determine whether the application as proposed is capable of being
certified as being permanent and completed development on a stand-alone basis.
7. Lack of necessary support shore side infrastructure to meet Industry Standards
The proposed pier is not long enough for the new next generation of Cruise Ships – Quantum &
Oasis classes.
The berth does not have the necessary support infrastructure for a floating town of 5,000 people.
There is not sufficient electric shore power, no foul sewerage connection, no mains water, no water
pressure for fire-fighting purposes and no refuelling capability.
There is no disaster planning infrastructure for fires, fuel spills or possible collisions.
There are no tugs to assist ship and no pilot in the Harbour.
8. Engineering Design is to minimum permitted standards
The whole design is predicated on a simulated model to determine if the shipping channel and
berthing pocket for an enormous Freedom Class Cruise ship - 65m high x 340m long x 40m wide
(beam) x 8.5m deep (draft below the waterline) cruise ship will work within the confines of the
restrictions of Dun Laoghaire Harbour and particularly at the harbour entrance.
EIS provides no details on the model, what assumptions have been included and what safety
tolerances and redundancy has been built into the model.
EIS advisors require further local metocean data, wave data, wind speed effects and data on local
currents needs to be assembled.
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Dun Laoghaire Cruise Berth Facility – An Bord Pleanala Submission – August 2015
The dredged channel is very narrow at just 120m at the Harbour mouth and up to 145m wide for
these 40m beam (wide) ships. The sides of the dredged channel are very steep at 1:5. We submit
that the dredged channel is again modelled to the minimum permitted standards. The safety
margins have no redundancy built in. Prudence, and good practice (and even rule of thumb) says
they should be built into the model.
We submit that the reason why these safety margins are not built in is that the tolerances do not
permit them to be included in the Dun Laoghaire Harbour situation. The model must work safely and
without doubt. We have been advised that the 120m wide channel is not navigable safely for ships
of this scale. This is particularly so at the Pier Roundheads at the Harbour Mouth. The design needs
to be proven beyond doubt.
9. Acceptable Safety Margins & Tug Facilities
The Permanent International Association of Navigation Congresses (PIANC) guidelines state that
vessels entering and leaving port should have a minimum of x 1.5 its length clearance between the
nearest obstacles – the harbour wall - to allow for safe manoeuvring. In DLH there is just 270m (just
50% of the PINAC guidelines. This is particularly important when there are no tug facilities are
available.
10. Maritime Navigation & Pilotage Issues
There are no detailed studies of the requirements, or otherwise, of the pilotage requirements for
the proposed +340m ships into and out of the harbour included in the documents or the EIS. There is
one sentence in Paragraph 6.3 of the Planning Application Report that states: “Simulated navigation
studies have been undertaken, and the channel width and turning circle are sufficient to permit the
selected cruise vessel class to navigate the approach, unassisted by tugs, in conditions up to the
tested wind limits.”
Advice from and consultation with marine pilots, with many years of experience in Dublin and other
ports, would suggest that this statement needs to be proven.
There is a one sided Harbour entry from the turning circle – the Ships will be required to line up on
the on the starboard side (right hand side / West Pier Side) of the dredged channel - in order to
make a direct straight line approach into the dock.
There are no tugs in Dun Laoghaire to assist with berthing
Windage - The passage of the45m beam (width) vessels into the harbour through a 120m wide
channel is of great concern considering the wind and tide conditions. The minimum speeds required
to manoeuvre to counteract these conditions needs to be considered more fully. There are no
studies showing sufficient margins of safety, or the required safety redundancy factors outside of
the simulated models, to guarantee no error in these delicate shipping manoeuvres.
Mooring - The mooring and securing of the ships in adverse wind conditions is not shown.
Shipping channels are dealt with in Sailing Impact.
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Dun Laoghaire Cruise Berth Facility – An Bord Pleanala Submission – August 2015
11. Safe Operating Speeds of Vessels
Vessel Operating Procedures require minimum operating speeds of 5 – 8 knots. These speeds are
not feasible in the context of entry and exit, of such vessels, from Dun Laoghaire Harbour.
How will vessels maintain 6 knot operational speed and also stop?
12. Scouring of Sea Bed and Dredged Channel
Scouring is the churn / disturbance of the natural silt sea bed and trench walls in the harbour caused
by the propellers (azipods and/or bow thrusters) of these enormous ships.
13. Energy Dissipation & Scouring of Seabed
Energy dissipation (Wave Train Energy) from the entry and exit of vessels from the harbour has not
been addressed fully in the EIS or the application.
This is a baseline study which must be completed, in advance but has not been included in the EIS.
This study must look at the current state of repair of the Harbour structures, the Pier Walls and
Marina Breakwaters and establishes a firm baseline and forward plan for the ongoing repair and
maintenance of the harbour.
This must also be understood in the context of the harbour being beside and adjacent to a Special
Conservation Area (SCA). It must also be assessed in the context of it being a Heritage Site of
considerable importance.
The impact of slow scouring and gradual erosion of the walled structures of the harbour (the Piers
and the Marina breakwaters), their foundations and the seabed structure within the harbour has not
been properly addressed in the EIS.
Neither has the impact of this of this seabed disturbance “churn” on the marine life, fauna and
angling been dealt with fully in the EIS.
14. Dredging Slopes – 1:5 in Dun Laoghaire and 1:16 for Dublin Port
The sides of the dredged channel are designed to be at a slope of 1:5 (ie - for every 1 meter of depth,
the slope is 5 metres wide). This is very steep for exposed underwater dredged slopes. This is more
akin to the sloped grassed embankments on a motorways (M1) built for the National Roads
Authority.
By comparison, Dublin Harbour’s dredged channel will have a slope of 1:16. For an equivalent 4.5m
deep dredged channel, this would mean the width of the slope required would be 72 metres either
side, making the maximum channel width 289m. This exceeds the width of the harbour mouth (at
230m) At this width, the harbour walls would be severely & continuously undermined.
We are advised that the design of the dredged channel is not technically achievable and the side
slopes will have to be reduced. This will have knock on impacts to surrounding structures,
particularly the Pier Walls and Roundheads at the harbour entrance.
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Dun Laoghaire Cruise Berth Facility – An Bord Pleanala Submission – August 2015
The Board must ensure that the dredging design by Waterman Moylan, who not a wholly recognised
marine engineering practice, has been properly and prudently designed for the safety of the harbour
and not just designed to “fit” the model into the restricted space that is Dun Laoghaire Harbour.
15. Concrete Scour protection in Dredged Channel
There is not sufficient concrete scour protection, just 5% of the entire length of the channel,
particularly when the slopes of the dredged channel is at 1:5. .
For comparison, Dublin Port is proposing 100% concrete scour protection over the entire 6 km
length of the channel.
There is not sufficient information provided in the EIS to be able to make a determination.
Again, we would ask the Board to ensure that the extent of concrete scouring is sufficient to prevent
any possible collapse of the 1:5 slopes. The consequences are a very significant additional financial
cost for these works and a predictable financial overrun for the Funding Body.
16. Dredging / Ongoing dredging & Maintenance regime
This is particularly relevant as no analysis was presented within the application or in the EIS, despite
indications of a need for Comprehensive Assessments, from ABP pre application meetings, and
particularly as Dun Laoghaire is beside a SAC and the dredged areas and dumping grounds not only
form a border with this SAC but the approach channel shares a tidal affects over the SAC and
adjacent (to be dredged) this approach channel and turning circle.
The ESI does not include an environmental risk assessment of both the dredging and the disposal
operations proposed.
17. Ecology
Damage to the seabed and marine ecology from the massive thrust required to move these 150,000
tonne ships when manoeuvring in the confines of the harbour. The HSS caused seabed damage. The
new ships have Azipod water jet thrusters (similar to jet engines) or large propellers, capable of
destroying the silt in the harbour.
18. Re-sedimentation of Dredged Areas
It is unclear from the application of the EIS if the continuous dredging will be required. Logically,
with such steep slopes of slopes of 1:5 in dredged channels, sediment will accumulate in the pit of
the channel that will require to be regularly dredged. Nowhere in the EIS has the applicant
confirmed that this ongoing maintenance and, more importantly, the ongoing cost of dredging and
maintenance of the channel has been included in the capital costs and the running costs of this
facility.
19. Dock Design & Buffer System
It is surprising that the detailed design does not include some form of “cow-gate” buffer system
(similar to a train buffer at the end of the line in a train station) at the shore side end of the berthing
pocket. All the previous mail boats and ferries required some form of a cow-gate.
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Dun Laoghaire Cruise Berth Facility – An Bord Pleanala Submission – August 2015
Given the proposed 100 year high tide level at +3.43m OD Malin, the new Pier top level at +4.49m
OD Malin ideally should be higher. This height is restricted / determined by the existing shore-side
levels at the HSS Terminal and bus marshalling area. This height of the New Pier also needs further
examination.
The new Pier, as a minimum should have some raked (angled) piles incorporated into the design to
resist the horizontal berthing forces while docked. The piling issues requires more examination.
20. Flooding risks & Wave Impact
There is no flood risk assessment in the EIS or compliance with DLRCC’s own “Planning System &
Flood Risk Guidelines. More detail is necessary on the effects of wave surge from these ships for the
EIS.
The impact from the ships wake surge at minimum operating speeds, bow waves & disturbance from
thrusters stopping on arrival and reversing on departure from the berthing pocket has not been
included in the flood assessment.
Additionally, the height of the proposed new Pier deck level is susceptible to flooding and should be
raised.
21. Harbour Exclusion Zone
DLHC was refused (in 2013/4) by its parent department, Department of Transport, for a 1km
‘exclusion zone’ at the harbour mouth. This current proposal seeks to, de facto, reinstate this..
22. Demolition of HSS Berth Infrastructure not included in Planning Application
The demolition of the HSS Berthing facility is not included in the planning application.
23. Marina Breakwater to be demolished
The marina breakwater walls and rock armour is to be temporarily removed. This is immediately in
the area of the deepest underwater dredging in the top shore-side end of the berthing pocket and
where the concrete scouring to the dredged slopes is most required. It is in the direct line of the bow
wave (wake) surge of the approaching cruise ship when berthing, which could also be the cause of
possible landside flooding. This area was the most abused part of the breakwater structure when the
HSS was using the harbour. Demolishing and repairing part of a contiguous structure will undermine
the integrity of the marina wall structure.
24. Does not meet Cruise Industry Standards
In minutes of meeting (MoM), 10/5/13, the applicant stated that it was industry standard that
harbour be simultaneously capable of facilitating two cruise ships [of 340m length].This is not
possible with this proposal. This proposal does not provide for the “new generation” of larger ships.
Shoreside infrastructure – ESB, water, firefighting are not provided for these mini towns of c 5,000.
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Dun Laoghaire Cruise Berth Facility – An Bord Pleanala Submission – August 2015
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