The Dublin Airport Passenger Cap Bill – irresponsible climate destruction, dictating to local communities, and free pass for aviation to undermine Climate Act

In light of 1) the dramatic escalation of the State-declared Climate
Emergency over the last 12 months, 2) worsening implications for children
and future generations in Ireland as everywhere, and related State child rights obligations, and 3) already record-levels of increasing aviation fossil
fuel pollution, we assert that this Dublin Airport Passenger Cap Bill should be withdrawn.

Notwithstanding this, we would assert that the public consultation for the
Bill has not been sufficiently accessible and any consultation in relation to
this legislation should be extended.

A grave concern we highlight in relation to the Bill is the unacceptable
failure to adequately consider environmental harms and climate impacts
of removing the passenger cap. We call for a comprehensive environmental assessment, incorporating human rights and social impacts, of Dublin Airport aviation pollution – in line with the recommended framework by the UN Special Rapporteur on the right to a clean, healthy and sustainable environment.

We express grave concerns regarding the nature and provisions of Head 5
(a) and the unacceptably subjective basis upon which Ministerial power to
revoke or amend a planning condition is proposed. We point to a lack of
adequate evidence base or consideration of available and pertinent data.
We highlight flawed assumptions regarding economic impacts of aviation
which would appear to be implicit to the Bill. We call for a comprehensive
evidence-based review of the assumptions underpinning this Bill, to
include economic implications of aviation pollution, related climate and
health impacts, and economic implications of current aviation policy.

We express particular concern over a lack of definition of what the ‘public
interest’ is in the context of this Bill, and highlight the apparent absence of
consideration of harmful implications of increasing aviation air and noise
pollution to the public interest, nor of climate harms from increasing
aviation emission to the public interest. We assert that given there is no
evidence of consideration of children’s best interests in relation to
removal of the passenger cap nor this Bill, that provisions related to the
‘public interest’ are unfounded.

We express particular dismay at the implications of Head 12 and attempts
to disapply Section 15 of the Climate Action and Low Carbon Development
Act 2015 (‘the Climate Act’), and assert this as entirely unacceptable,
disconnected from the grave reality of the State-declared Climate and
Biodiversity Emergency, and completely at odds with the State’s obligations under international human rights law and relevant climate
obligations.

Read more in our full submission – Submission of Children’s Rights Over Flights to the public consultation on Dublin Airport (Passenger Cap) Bill 2026​.