Gerry Horkan (Fianna Fail)
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On behalf of the committee I am pleased to welcome from the Irish Aviation Authority, IAA, its new chief executive officer, Mr. Declan Fitzpatrick; Mr. Jim Gavin, chief operations officer; and Mr. Adrian Corcoran, director of economic regulation, consumer affairs and licensing.

Witnesses are reminded of the long-standing parliamentary practice that they should not criticise or make charges against any person or entity by name or in such a way as to make him, her or it identifiable or otherwise engage in speech that might be regarded as damaging to the good name of the person or entity. Therefore, if their statements are potentially defamatory in relation to an identifiable person or entity, they will be directed to discontinue their remarks. It is imperative that they comply with any such direction.

Members are reminded of the long-standing parliamentary practice to the effect that they should not comment on, criticise or make charges against a person outside the Houses or an official either by name or in such a way to make him or her identifiable. I remind members of the constitutional requirement that members must be physically present within the confines of the Leinster House complex in order to participate in public meetings. I will not permit a member to participate where they are not adhering to this constitutional requirement. Therefore, any member who attempts to participate from outside of the precincts will be asked to leave the meeting. In this regard, I ask any member partaking via MS Teams to confirm, prior to making their contribution to the meeting, that they are on the grounds of the Leinster House campus.

If attending in the committee room, members and witnesses are asked to exercise personal responsibility to protect themselves and others from the risk of contracting Covid-19. I now invite Mr. Fitzpatrick to make his opening statement on behalf of the IAA.

Mr. Declan Fitzpatrick:

I thank the committee for extending an invitation to the Irish Aviation Authority to this meeting to discuss the standard instrument departures in use at Dublin Airport. I am accompanied today by my colleagues Mr. Jim Gavin and Mr. Adrian Corcoran, who I may call on to assist in providing answers to queries as they arise. I will set out the background to standard instrument departures, SIDs, what they are, what safety regulations apply, who is responsible for supplying them, and the role of IAA as regulator when approving an SID. First, I should explain the overall role of the IAA as it has recently changed with the enactment of the Air Navigation Transport Act 2022.

The Irish Aviation Authority is a commercial semi-State company and is the single civil aviation regulator for Ireland. The IAA is the responsible authority in Ireland for the regulation of safety, security, economic and consumer interests in civil aviation. The company's responsibilities are set out in a framework of applicable global, European and national legislation and regulations. Since 1 May, the IAA no longer provides air traffic control services in Irish airspace and at the airports of Dublin, Cork and Shannon. These services are now provided by a separate commercial semi-State company, AirNav Ireland, which is responsible for the management of Irish sovereign airspace on behalf of the State as set out in the Air Navigation Transport Act 2022.

The regulatory functions of the IAA cover all aspects of civil aviation, including the certification and registering of aircraft; the continued airworthiness of aircraft; and the licensing of pilots, maintenance engineers, air traffic controllers, aviation security personnel and unmanned aircraft system, UAS, operators. It is also responsible for the certification and oversight of commercial airlines and aircraft operators; aerodromes; design and production organisations; continued airworthiness maintenance organisations; air navigation service providers; UAS-specific operations; training schools; and cargo consignors and shippers.

Since 1 May, the functions and personnel of the Commission of Aviation Regulation have merged with the IAA. These new functions include the setting of en-route charges for aircraft in Irish airspace; the setting of passenger charges at Dublin Airport; schedule co-ordination and slot allocation at Irish airports; the licensing of the travel trade in Ireland; commercial licensing of airlines and approval of ground-handling service providers; the oversight of air passenger rights regulations; and the provision of assistance to passengers with reduced mobility.

The IAA operates to the highest international safety standards developed over decades by the International Civil Aviation Organisation, ICAO, a UN specialist agency established by the Chicago Convention in 1944 to set global standards and recommended practices, SARPs, for aviation and uniform global procedures for air navigation services, PANS. The SARPs are contained in 19 annexes to the convention and run to approximately 13,000 individual requirements while the PANS are contained in six volumes approved by the ICAO’s air navigation commission.

In Europe, the ICAO SARPs are codified into law by the European Union, which has primacy in aviation transport, with some minor exceptions. The primary regulation in Europe, issued in 2018, is Regulation (EU) 2018/1139. The regulation covers all key areas of aviation, including airworthiness, aircrews, aerodromes, air operations and air navigation services. The aim of the revised regulation is to establish a high and uniform level of civil aviation safety while ensuring environmental protection. It includes a revised mandate for the European Union Aviation Safety Agency, EASA, and new rules designed to allow the European Union aviation sector to grow, make it more competitive and encourage innovation. It is further expanded by specific implementing regulations and delegated acts which lay out the specific obligations in each domain for the entities and for the IAA as the competent authority in Ireland. All these regulations are readily available through the EASA website.

As part of the ICAO and EU safety regulation frameworks, the IAA is subject to external independent auditing by both the ICAO and EASA. The ICAO operates the universal safety oversight audit programme while EASA operates a standardisation programme as per EU regulation (EU) 628/2013. Both programmes consist of a continuing monitoring assessment of the IAA as well as on-site audits of the IAA and entities the IAA regulates. For example, last year EASA conducted four such audits on specific areas and will conduct another two this year. The IAA consistently performs excellently in these audit programmes and ICAO ranks Ireland in the top ten states globally and second in Europe. Similarly, the EASA auditing continually places the IAA at the top end of EU states and well ahead of the EU average.

It is important that the IAA continues to perform well in these audits as it provides assurance to other states that Ireland’s aviation industry is effectively regulated and can continue to get the full access and benefits of the global aviation market. The IAA performs well because it is staffed by highly experienced aviation safety and security experts in all aviation disciplines including air transport pilots, airworthiness design and maintenance engineers, aviation security, ground handling, aeromedical and licensing experts, pilot training, aerodrome engineers, air traffic controllers, air navigation equipment engineers, unmanned aircraft systems and aviation safety management experts. The IAA always seeks to be a leader among aviation regulators and is highly respected by the ICAO, EASA and its regulatory peers in other states.

Regarding SIDs, each certified aerodrome must provide instrument flight procedures to assist aircraft to operate safely and efficiently at its aerodrome. These include standard instrument approach procedures and SIDs. Both depict the profile of an instrument departure or arrival route and consist of information such as direction to fly, minimum climb or descent gradients for the aircraft, minimum or maximum speeds to fly and relevant navigational points. These are all published and freely available in the aeronautical information publication, AIP, for Ireland, which is available on the AirNav Ireland website. In Ireland, the airports covered are Cork, Dublin, Shannon, Donegal, Ireland West, Kerry, Sligo, Waterford and Weston. Essentially these SIDs are roads in the sky which the air traffic controller can tell the pilot to follow, removing the need for the controller to continuously give detailed instructions.

The applicable implementing regulation for certified aerodrome operations is Regulation (EU) 139/2014. It requires that the aerodrome operator shall ensure, either directly or through arrangements with accountable entities, the provision of air navigation services appropriate to the level of traffic and the operating conditions at the aerodrome, and the design and maintenance of the flight procedures, in accordance with the applicable requirements. In Dublin, the Dublin Airport Authority, DAA, is the aerodrome operator and has put in place arrangements with AirNav Ireland for the provision of air navigation services at the airport, including the provision of the instrument flight procedures.

Regarding the design of flight procedures such as SIDs, the applicable safety standards to which these procedures must be designed are contained in the standards and recommended practices and procedure for air navigation services produced by the ICAO, as I referenced earlier. The design of flight procedures including SIDs is a safety-critical and complex process which must take account of multiple factors such as the airport layout, the topography, the capabilities of aircraft, and the communication, navigation and surveillance equipment available at the airport among other things.

Before an organisation can design flight procedures for an aerodrome it must first obtain an organisation approval from EASA. This ensures the organisation has the appropriate competencies, procedures and quality assurance processes to perform the work. The list of organisations currently approved to design flight procedures in the EU is available from EASA. The certified aerodrome operators in Ireland, either directly or through their arrangement with their air navigation service provider, source the flight procedures from these specialist companies.

Before an individual instrument flight procedure can be used, it must be submitted to the IAA as the applicable competent authority. The IAA reviews these submissions and determines if they meet all safety requirements set out by the ICAO and EASA. Where an instrument flight procedure submission does not meet the safety requirements, it is rejected by the IAA and cannot be published. Where a procedure is approved by the IAA, it is sent to the aeronautical information service provider, AirNav Ireland, for publication in the AIP. As part of the AIP process, there is a lead time between publication and its becoming active. This is to allow airlines and aircraft operators across the world adequate time to promulgate the new procedures and ensure flight crews are advised, aircraft flight management systems are updated, etc. This publication process is also defined by ICAO standards and recommended practices, and works to common applicability dates globally, referred to as the aeronautical information regulation and control, AIRAC, cycle.

All published instrument flight procedures for Irish airports are compliant with the safety requirements, and monitoring processes are in place to ensure their safety is maintained. For the avoidance of any doubt, the IAA approval process only verifies that the procedures designed for a specific aerodrome, as presented to the IAA, meet all safety requirements set out by the ICAO and EASA. It is not in our remit to assess if the aerodrome is compliant with other obligations the aerodrome may have to meet, such as planning conditions and noise abatement obligations.

The opening of the new runway 10L/28R at Dublin Airport in August 2022 required the development of new SIDs and standard instrument arrivals, STARs, for the airport. The new flight procedures allow for simultaneous segregated operations on both parallel runways compliant with the applicable safety standards. Currently there are over 30 different approach and departure charts approved and published in the AIP for Dublin Airport to cover the different operational scenarios possible on all three runways.

A key safety requirement when operating the parallel runways in the same direction, as introduced in Dublin Airport, is to ensure that aircraft do not collide. Specifically, the ICAO specifies that the flight procedures for segregated operations must be designed to ensure, when it is intended to use an instrument departure procedure and an instrument approach procedure in the same direction on parallel runways simultaneously, the nominal tracks of the departure procedure and of the missed-approach procedure shall diverge by at least 30° as soon as practicable. This is best depicted in ICAO document 9643, a diagram of which appears in our submission.

The SIDs and STARs submitted to the IAA aviation regulator for the introduction of the new parallel runway and the current approved versions which became effective in February provide for missed-approach tracks to 28L to continue straight ahead, while the departure tracks for 28R require the operator to turn in a northerly direction above a specified altitude after the designated end of the runway thus ensuring the minimum 30° divergence criterion is met.

There are several factors in the airspace surrounding Dublin Airport that add complexity to designing an instrument flight procedure. For example, the Irish Air Corps operates from Casement Aerodrome, which is protected by a large volume of restricted airspace. Flights with civil instrument flight procedures cannot enter the restricted airspaces without there being arrangements in place, thus constraining the footprint of the procedures.

To reiterate, the IAA's approval process for the SIDS and STARs presented to the IAA for the introduction of the new parallel runway, 10L/28R, verifies that the flight procedures meet all safety requirements set out by ICAO and EASA. However, we have no role, when certifying these flight procedures, to ensure the aerodrome is compliant with other obligations it may have to meet, such as planning or noise-abatement obligations.

I hope this fully explains to members' satisfaction the background to standard instrument departures, what they are, what safety regulations apply, who is responsible for supplying them, and the IAA's role as regulator when approving a standard instrument departure. I am sure members will have additional questions, so we will be happy to give further clarification.

Gerry Horkan (Fianna Fail)
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That was certainly a very comprehensive opening statement. Although I thought I knew a bit about aviation, I did not hear of SARPs, STARs or PANs before. There is a lot of jargon and technical information. We have present some particularly interested Deputies who live quite close to the airport. Deputy Farrell, who has joined us today, is very welcome.

I will go through the roster in the normal way, the first contributor being Deputy Martin Kenny.

Martin Kenny (Sligo-Leitrim, Sinn Fein)
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I thank Mr. Fitzgerald for the opening statement. The IAA is at great pains to point out it is not responsible for the SIDs. I understand that. Mr. Fitzpatrick is saying they are presented to the authority, which approves them on the basis of whether they meet the safety requirements, and only on that basis. In that respect, does the IAA consult in advance on their appropriateness? Does it have any input into the conversation on what will be presented to it?

Mr. Declan Fitzpatrick:

We do not have a consultation process but the service provider would have a consultation process in which the proposals would be gone through in great detail. We would have been involved in initial reviews in the modelling process. I reiterate, however, that we are coming at it purely from the safety perspective, ensuring that what is proposed covers all the safety aspects related to design and that the interactions associated with the various procedures are all safety compliant. That is as far as our role as the aviation safety regulator goes.

Martin Kenny (Sligo-Leitrim, Sinn Fein)
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It is particularly in respect of the north runway that we hear complaints about noise and issues of that nature. Are they referred to the IAA or does it have any role in carrying out inquiries or investigations in this regard?

Mr. Declan Fitzpatrick:

We have no role regarding noise. We occasionally get complaints about noise and refer them to the Aircraft Noise Competent Authority, ANCA, in Fingal, the competent authority for aircraft noise at Dublin Airport. Our role in respect of noise is purely limited to aircraft certification. Under ICAO's Annex 16, there is a role for the aviation regulator, having regard to the initial design approval and type certification of an aircraft, in issuing its noise characteristics. In Europe, that is actually done by EASA, which will type-certify the aircraft and issue its noise characteristics. At national level, we issue an individual noise certificate for each aircraft. It explains the expected noise given certain criteria. How the process works is detailed in ICAO's Annex 16. The type certification and initial design approval of a new aircraft are done by EASA. In the context of individual aircraft, we issue certificates based on the analysis done by EASA.

Martin Kenny (Sligo-Leitrim, Sinn Fein)
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The other issue I want to raise relates to an email I received from a pilot who finds that his qualifications are not recognised because of Brexit. He did much of his training as a helicopter pilot in Enniskillen and now finds there are issues with this. Is there work being done between the IAA and authorities in Britain in this regard to ensure people who have qualified will not have to resit all their exams and go through the whole process again?

Mr. Declan Fitzpatrick:

This is an ongoing issue as a consequence of the Brexit deal. To give the background, if you are flying for a UK operator or flying a G-registered aircraft, a UK-registered aircraft, you must hold a UK licence. If you are flying a European aircraft-----

Gerry Horkan (Fianna Fail)
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Is that based on a British regulation?

Mr. Declan Fitzpatrick:

It is a British regulatory requirement. Similarly, if you wish to fly an Irish-registered aircraft in Ireland, you must hold an EASA licence, or European licence. In our case, we issue licences to Irish staff. The licence is recognised across Europe.

A number of pilots have found they are unable to fly for UK operators even though they are operating in Ireland and have an Irish licence. It is a very peculiar situation and a consequence of Brexit.

Gerry Horkan (Fianna Fail)
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To clarify, it is based on a UK regulation. The UK could say that we recognise EASA but that it does not.

Mr. Declan Fitzpatrick:

It did for two years after the Brexit deal was done. Essentially, there is a political decision to be made as to what agreements can be made between countries. It is not at the safety level but at the national or European policy level.

Mr. Jim Gavin:

It sounds like the person who corresponded with the Deputy might have an EASA-issued licence, which, as the chief executive said, is issued by Ireland on behalf of EASA. There is a procedure whereby the pilot can apply to the UK's Civil Aviation Authority to get that licence validated, which would transfer the EASA licence to a UK licence. We do facilitate that arrangement.

Martin Kenny (Sligo-Leitrim, Sinn Fein)
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Is there any issue with the IAA recognising UK licences?

Mr. Jim Gavin:

Up to 31 December 2022, there was a European procedure whereby individuals who held UK-issued EASA licences could apply to another member state to get them transferred. In this case, it would relate to an Irish-issued EASA licence. The measure expired on 31 December 2022.

Martin Kenny (Sligo-Leitrim, Sinn Fein)
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It is bizarre that the licences of pilots who fly in and out of various jurisdictions are not recognised. It would not be the case with any other profession, such as the medical profession. It seems so bizarre that some solution has not been worked out before now given that the profession involves the crossing of borders. Mr. Fitzpatrick is saying that it is really a political decision.

Mr. Declan Fitzpatrick:

Yes.

Duncan Smith (Dublin Fingal, Labour)
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Who presents the SIDs to the IAA for its validation on safety grounds? Is it the DAA or airlines?

Mr. Declan Fitzpatrick:

The body that would submit the procedures to us would be the aerodrome operator. In the case of Dublin, it would be the DAA.

Duncan Smith (Dublin Fingal, Labour)
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The IAA is clear that it is not responsible for the issues related to noise, which is fair enough, but it will be aware of the history of the development of the north runway, as it is called, and the many years of consultation regarding an east–west-takeoff flight path for the purpose on insulation schemes. The thinking was that aeroplanes would depart the runway in a straight flight path and not bank or turn before having travelled 5 nautical miles or reached an altitude of 3,000 feet. Do those measurements relate to any of the IAA's safety thresholds? On the basis of the IAA's information, we are talking about 150 m, 650 m and 30° banking. Where do the 5 nautical miles and 3,000 feet come from?

Mr. Declan Fitzpatrick:

It depends on whether it is a single-operation runway or, as in the case we are dealing with here, there are simultaneous segregated operations. The specific requirement for the 30° turn comes from the fact we are dealing with two segregated runways operating simultaneously. If a single-runway operation were in place, the aircraft could continue straight on out. The regulation allows that in circumstances where only one runway is operating at a time.

Duncan Smith (Dublin Fingal, Labour)
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The SIDs that exist now for the new runway, which include the 30° banking, did not exist previously and there was no comparable SID for the previous runway.

Mr. Declan Fitzpatrick:

Correct.

Duncan Smith (Dublin Fingal, Labour)
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Surely it would have been known from the aerodrome operator what having a parallel runway would require. Was it not an industry standard that if running a parallel runway, there would be this safety requirement? Was that information not out there? It would have been known and seen in public consultations that there would be this banking issue.

Mr. Declan Fitzpatrick:

That would be a question for the operator.

Duncan Smith (Dublin Fingal, Labour)
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Was Mr. Fitzpatrick surprised at all in seeing the drawings? Did the IAA ever raise it, even informally, with the DAA that there were issues with the east-west projects and planning?

Mr. Declan Fitzpatrick:

To be frank, I was not following what the requirements were in terms of planning or noise. I was not personally attuned to the matter. We just concentrate on the safety requirements and what is submitted. The proposals were submitted to us early last year and we addressed them as they were submitted.

Duncan Smith (Dublin Fingal, Labour)
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An email has been released to the committee that was sent to the IAA on 7 September from someone in the DAA. That person states:

From my limited understanding, I believe collaborative engagement between the DAA and IAA ANSP over a number of years resulted in a set of assumptions being developed for noise modelling purpose. The IAA ANSP kindly provided technical information to assist DAA to assist our consultant to complete noise modelling aligned to these assumptions. It was made clear that this was indicative data only and no form of SIDs had been designed at this stage. The DAA used the output of this modelling in the relevant action application as well as modelling information provided to Fingal County Council for the Fingal county development plan and local area plan for land use planning noise zones. While I understand no instruction was given to IAA ANSP to design the SID aligned to this modelling, I am sure you can understand that it now causes a challenge that a significant number of aircraft are overflying areas not indicated in the relevant action application or communication material issued publicly.

The email was sent from the DAA to the IAA not long after the new runway opened.

Gerry Horkan (Fianna Fail)
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We have had advice from the Office of Parliamentary Legal Advisers about what we can and cannot say. I remind members to be careful in all their contributions.

Duncan Smith (Dublin Fingal, Labour)
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That email indicates there was at least an informal relationship between the DAA and the IAA on the modelling of the new runway for noise purposes. Is that an accurate reflection of the relationship between the two? Representatives of the DAA stated at meetings of this committee that they woke up on the day and when planes started to bank from 30° up to 75° north, they were not expecting it. That did not seem like something we could believe. Does Mr. Fitzpatrick have any thoughts on that?

Mr. Declan Fitzpatrick:

Deputy Smith specifically referenced the IAA ANSP.

Duncan Smith (Dublin Fingal, Labour)
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That is separate from the function carried out by the witnesses

Mr. Declan Fitzpatrick:

Up to 1 May, the IAA had two segregated sections, that is, the air navigation service provision, ANSP, and the aviation regulator. The IAA that is represented today at the committee is the aviation regulator. Even before 1 May, we performed a separate function to the ANSP, as referred to in the email, which is now AirNav Ireland. I cannot comment on the issue the Deputy raised as it was not part of the function we had prior to 1 May and certainly is not part of the function we have now.

Duncan Smith (Dublin Fingal, Labour)
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I thank Mr. Fitzpatrick.

Darren O'Rourke (Meath East, Sinn Fein)
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Will Mr. Fitzpatrick indicate whether there was any change in safety requirements in the period 2016 to 2019?

Mr. Declan Fitzpatrick:

There is a continuous evolvement of aviation regulation, specifically in regard to amendments to PANS-OPS, PANS-ATM and the European regulation. I would have to check exactly what changed. Specifically in regard to the 30° turn, that requirement has been there for quite a number of years.

Gerry Horkan (Fianna Fail)
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Is "quite a number of years" five or six, or 40 or 50?

Mr. Declan Fitzpatrick:

It is there at least since 2004.

Gerry Horkan (Fianna Fail)
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That is long before the development plan for the airport was being approved.

Mr. Declan Fitzpatrick:

For simultaneous operations, that requirement has been there for quite some time.

Darren O'Rourke (Meath East, Sinn Fein)
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Regarding the SIDs the north runway operated on the first day it opened, would they have been agreed with the IAA and assessed against safety standards?

Mr. Declan Fitzpatrick:

Yes, the aviation regulator would have approved those procedures in advance.

Darren O'Rourke (Meath East, Sinn Fein)
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Did they meet the safety standards?

Mr. Declan Fitzpatrick:

Yes, they absolutely met safety standards.

Darren O'Rourke (Meath East, Sinn Fein)
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Were the changed flight paths - the February SIDs - submitted to the IAA? I am wondering about the types of considerations the operator weighs up. Some of the query from the local community is around why one thing is being done but not another. People ask about option B, C, D and E. For example, is it the case that easterly departures are taking a different approach, with banking of 10°, not 30°? Could a similar standard apply on westerly departures?

Mr. Declan Fitzpatrick:

There are a multitude of permutations that could possibly be implemented. Depending on which option is chosen, there will be varying limitations on the operation of the two runways simultaneously. There can be completely independent operations, whereby what is going on one runway has absolutely no impact on what is happening on the other, or there can be dependent operations, such as at London's Heathrow Airport, where what is happening on one runway is dependent on what is happening on the other. It is all about designing a concept of operations and working out how the two runways will operate at the same time.

Darren O'Rourke (Meath East, Sinn Fein)
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The IAA does not adjudicate on that. Adjudication is on what is presented to the authority in terms of whether it meets the standard. If it meets the standard, the IAA says it meets the standard and that is it. Is that right?

Mr. Declan Fitzpatrick:

Yes.

Darren O'Rourke (Meath East, Sinn Fein)
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Is it correct that all of the other considerations in terms of how things operate and other factors are for the DAA to decide

Mr. Declan Fitzpatrick:

It is for the DAA to provide those flight procedures at the airport.

Darren O'Rourke (Meath East, Sinn Fein)
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Regarding the SIDs and the changed flight paths, is there a requirement for an environmental impact assessment or a noise abatement assessment to be done in conjunction with them?

Mr. Declan Fitzpatrick:

Under the ICAO regulation, we do not have that requirement. It might be a question for ANCA or Fingal County Council.

Darren O'Rourke (Meath East, Sinn Fein)
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Or An Bord Pleanála.

Mr. Declan Fitzpatrick:

It is not a requirement under our regulation.

Darren O'Rourke (Meath East, Sinn Fein)
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Somebody pointed me towards the IAA procedure to implement change to aerospace, which is the aeronautical service advisory memorandum No. 19. Is there a requirement in that regard?

Mr. Declan Fitzpatrick:

I would have to check the full detail. We might ask whether consideration has been given to it, but it is not a requirement in our regulation. I will come back to the Deputy on that.

Darren O'Rourke (Meath East, Sinn Fein)
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It would be helpful if the IAA representatives would agree to take a small number of written questions following the meeting.

Mr. Declan Fitzpatrick:

Certainly. That is no problem.

Gerry Horkan (Fianna Fail)
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The Deputy's suggestion is good. I thank Mr. Fitzpatrick for agreeing to it.

I have some questions for the witnesses. At the moment, the procedure is that the planes taking off on the new runway are banking to the right, while those taking off from the original runway are going straight on. I am sure other people have asked this before but I do so for my own benefit. Is there the possibility for planes on the new runway to go straight out and those on the southern runway to bank to the left instead?

Is there a reason this cannot be done? Is the area heavily populated? Does this aspect involve the Air Corps or Baldonnel? I do not know what the issue is.

Mr. Declan Fitzpatrick:

Again, our requirement is a divergence of 30°. How this divergence is made up, and whether it is straight ahead to the north, 30° in the south or 15° in both directions, is really not for us to say. I would assume in the analysis done that if there was a deviation of 30° off the southern runway it would certainly mean heading towards the military airspace. It might also mean going over more populated areas. I honestly do not know the criteria that led to this approach being selected. I am sure considerations such as these, however, certainly came into the analysis.

Gerry Horkan (Fianna Fail)
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This was an enormously expensive runway and the State made a great investment. I think the amount was €350 million, and this is without mentioning the need to build a new air traffic control tower for another €50 million to deal with the operation of the new runway, and so on.

Alan Farrell (Dublin Fingal, Fine Gael)
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The State did not spend a penny on the runway.

Gerry Horkan (Fianna Fail)
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I know, but the DAA did and it is ultimately owned by the State. This is an investment of the State and, yes, it is generated by-----

Alan Farrell (Dublin Fingal, Fine Gael)
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It is not Exchequer funding.

Gerry Horkan (Fianna Fail)
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It is certainly money that has been spent and, ultimately, an asset owned by the State. A second runway was certainly needed, but it is hard to believe there was no awareness in this regard when the planning application went in. I do not know what that planning application stated in terms of flight paths or whatever when it went in or why some houses were insulated rather than others. I presume Mr. Fitzpatrick does not have a view or understanding of this aspect. That development plan went in and the runway was approved in 2006 or 2007. It was a long time in the making, and the land was retained a long time before that as well. It just surprises me that this issue only seemed to appear on the first day of operations. All the witnesses have a great deal of aviation expertise. Is there a way of squaring the circle here? Is there a way forward that provides a solution which will stop these houses from experiencing the great deal of noise they never expected? Is there any way of resolving this situation?

Mr. Declan Fitzpatrick:

I think this is a question more for the operator than the regulator.

Gerry Horkan (Fianna Fail)
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I get that and I am not trying to put Mr. Fitzpatrick on the spot. I am saying he has much more aviation experience than I do and asking him if there are ways of addressing this issue at other airports. What have they done to ameliorate this situation we find ourselves in?

Mr. Declan Fitzpatrick:

We come back to the ICAO balanced approach to managing noise at airports. This centres on land management and various measures it is possible to take in respect of operations. Much work has been done in aviation at the ICAO level and in Europe on things like continuous descent approaches, continuous climb operations, etc., to try to mitigate noise. Options exist in these respects. Again, though, I think ANCA would be able to educate the committee more on what exactly is involved in the balanced approach.

Gerry Horkan (Fianna Fail)
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In the operation of the airport, the DAA operates the facility, AirNav directs the traffic in and out and the airlines use the different aircraft and follow instructions. Newer and more modern aircraft are generally quieter, and this is a positive factor in the long run. Can Mr. Fitzpatrick see any mitigating circumstances we are not aware of that could improve the situation as it stands now?

Mr. Declan Fitzpatrick:

The Leas-Chathaoirleach touched on one of the biggest improvements in this context and this is the operation of new, modern aircraft. As I understand it, more than 90% of the aircraft operating from Dublin Airport now are what are referred to as chapter 14 aeroplanes, which have lower noise emissions. This goes back to what I mentioned earlier concerning the certification of aircraft.

Gerry Horkan (Fianna Fail)
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At this stage, some aircraft are no longer allowed to use Dublin Airport. I refer to aircraft types like the old DC-8s and Boeing 707s, not that there are millions of those around. Those aircraft would no longer be able to use Dublin Airport.

Mr. Declan Fitzpatrick:

No, those aircraft would no longer be able to operate in airports in Europe.

Gerry Horkan (Fianna Fail)
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Okay.

Mr. Declan Fitzpatrick:

In some regions of the world, these aircraft types are still allowed to operate but not in Europe.

Gerry Horkan (Fianna Fail)
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Are these EU regulations or our own?

Mr. Declan Fitzpatrick:

I will have to check again exactly where they come from. Efficiency-wise and everything else, very few people want to operate these aircraft anyway because they are so inefficient now, regardless of the noise.

Gerry Horkan (Fianna Fail)
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I thank Mr. Fitzpatrick for that contribution. I call Deputy Alan Farrell.

Alan Farrell (Dublin Fingal, Fine Gael)
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I thank the Leas-Chathaoirleach and the members for allowing me to appear before the committee and for acceding to my request to request the attendance of representatives of the IAA and the DAA. By way of a brief statement, it is extraordinary that representatives of the DAA would refuse to come in to speak to this committee. It is a slight on this committee, which I think is indicative of the sort of attitude that organisation has towards the public. I feel strongly about this aspect, but I will leave this point here. I appreciate I am not privy to whatever advice the Leas-Chathaoirleach was given, but I suspect I may know what it was.

I sincerely thank the witnesses from the IAA for coming in and for the comprehensive statement provided. It contains a great deal of information for the public and it will clarify a great deal for many people. I wish to return to some remarks made by Deputy Duncan Smith. He quite rightly pointed out that the committee and the public have been provided with information by the DAA regarding its surprise concerning what occurred in August 2022.

I ask the next part of my question in the context of what has been said by the witnesses. For the purposes of description, the IAA is a planning authority. An applicant, the DAA, came to it and made an application. Rather than grant permission, the IAA verified that the permission was in line with the EASA guidance. For the purposes, therefore, of the context of the 70° to 75° divergence referred to in 2022 and as the representatives of the DAA told us about, privately and publicly, and the public via emails in response to direct queries, has something changed since the time before 28R became operational? I refer to how the process for approving or verifying an SID has taken place. I cannot ask the witnesses if they believe it is credible, but I think Mr. Fitzpatrick might understand what I am getting at. Would the DAA have known, or rather, should that organisation have known that aircraft would be departing and then banking by up to 75° when using 28R?

Mr. Declan Fitzpatrick:

The SIDs would have been submitted to the IAA early last year. I would have to check the exact dates for the Deputy. They would have been published in the aeronautical information publication, AIP, at least two months in advance of the operation of the aircraft. Everyone in the world involved in aviation, therefore, knew exactly what the SIDS were going to be on the first day of operation.

Alan Farrell (Dublin Fingal, Fine Gael)
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I thank Mr. Fitzpatrick very much. This makes it abundantly clear. Notwithstanding the presentation given to us, particularly the graph in the submitted document, which is very informative, is there an allowance under EASA guidance to allow dual operation of two runways? Is there a particular distance at which aircraft no longer have to depart at a particular angle? I refer to the 30° that Mr. Fitzpatrick outlined to us.

Mr. Declan Fitzpatrick:

No. What we are talking about here is simultaneous operations on segregated runways. There is a minimum distance the two runways must be apart. Regardless of this minimum distance, however, there is still a need for divergence out further.

Alan Farrell (Dublin Fingal, Fine Gael)
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Okay.

Mr. Declan Fitzpatrick:

If we think about this, if the aircraft were to converge further out, it is just a matter of being further away from the runways-----

Alan Farrell (Dublin Fingal, Fine Gael)
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That is understood.

Mr. Declan Fitzpatrick:

-----so it is always a requirement.

Alan Farrell (Dublin Fingal, Fine Gael)
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I thank Mr. Fitzpatrick for that clarification. It is important in the context of alternatives. If we are stuck with this 30° angle, which clearly we are, what I wish to touch upon are noise abatement departure procedures, NADPs, with specific reference to 28R. What role does the IAA have in this context, if any?

Mr. Declan Fitzpatrick:

Coming back to our regulation in this context, we have no specific role from a safety perspective in noise abatement.

Alan Farrell (Dublin Fingal, Fine Gael)
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I should perhaps clarify my question. I am referring to noise abatement procedures for aircraft using an SID. Is this aspect not built into the SID?

Mr. Declan Fitzpatrick:

It is built into the SID, but it is not a requirement of ours within the SID.

Alan Farrell (Dublin Fingal, Fine Gael)
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I see. Can Mr. Fitzpatrick outline in what circumstances it would be?

Mr. Declan Fitzpatrick:

I am sorry, but I am not following the Deputy's question.

Alan Farrell (Dublin Fingal, Fine Gael)
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Yes, that is fair enough, because I am not sure I fully understand what an NADP is. I know that in certain other jurisdictions NADPs, specifically NADP 1, are used and this allows, for want of a better description and I am not an expert, for the throttling of aircraft at a particular rate of climb or thrust, which results in less noise being generated. I understand this is a legal requirement in some European cities. It is not being applied in Dublin. My query specifically relates to this context. If Mr. Fitzpatrick can help me out with this, I would appreciate it.

Mr. Declan Fitzpatrick:

I should perhaps get a full and firm answer and then come back to the Deputy. Again, however, this comes back to the ICAO balanced approach. It would be one of its key pillars.

I would have to check whether it is a function of the Aircraft Noise Competent Authority, ANCA.

Mr. Declan Fitzpatrick:

I will check that.

Alan Farrell (Dublin Fingal, Fine Gael)
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I very much appreciate that. I appreciate that the IAA has been very forthcoming with me thus far. Mr. Fitzpatrick clarified that simultaneous operations minus the 30° is not possible and, under questioning from the Leas-Chathaoirleach, clarified the application of the 30°. Would it be possible, through the committee, to request any form of analysis that might be forthcoming in a trial scenario for a flight path to be developed on 28L that would not interfere with highly populated residential areas - I am thinking in particular of Ballymun, which would be off to the south west of the field - and would not interfere with military operations at Casement Aerodrome? Is there a way in which that could be done and, therefore, could we reduce the bank on 28R as a result of that minor change? It would have no bearing, because it is a matter for the DAA to apply for such a thing, but it would be helpful for public representatives and this committee to be able to show there are alternatives to what is being deployed by DAA. I understand completely that, as a regulatory body, the IAA does not have a function in making decisions for the DAA. I have understood that from the outset. However, it would be helpful if there was a point at which we could say we cannot go further than a certain degree on to 28L because of these circumstances. Does the IAA have a view? Would something like that would be possible, taking population into consideration?

Gerry Horkan (Fianna Fail)
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Are the SIDs prepared by the DAA or does it engage a specialist contractor to do this?

Mr. Declan Fitzpatrick:

Although the DAA is responsible, it used AirNav Ireland to have those developed for it and AirNav Ireland used the special services of an approved designer who-----

Gerry Horkan (Fianna Fail)
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Who does this all over the world.

Mr. Declan Fitzpatrick:

-----does this all over the world and is approved by EASA to do this. If we were to do this sort of analysis, we would have to contract someone like that to do it.

Gerry Horkan (Fianna Fail)
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It might not be for the IAA's budget to do it but it might be for the DAA's budget to do it.

Mr. Declan Fitzpatrick:

It is not in this year's budget anyway.

Alan Farrell (Dublin Fingal, Fine Gael)
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I understand and I appreciate Mr. Fitzpatrick entertaining the question. It is worth exploring alternatives. Deputy Duncan Smith outlined what all of us thought since 2007 when the permission for the runway was granted.

Gerry Horkan (Fianna Fail)
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I remember the meeting at which it happened. I was not even on Fingal-----

Alan Farrell (Dublin Fingal, Fine Gael)
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We were all under the impression it would be straight out and people's homes would be insulated using taxpayers' money - not the DAA's money - against the new aircraft movements. Now we find ourselves in the invidious position where aircraft are flying over homes that have never been in any scheme and cannot be included in this scheme because of-----

Gerry Horkan (Fianna Fail)
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And possibly houses that were insulated that did not need to be.

Alan Farrell (Dublin Fingal, Fine Gael)
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Indeed, and I want to make sure it is made clear. Homes that cannot be insulated unless it is done as part of a voluntary scheme because a review cannot take place of the noise corridor for another year under ANCA legislation, so there is a series of problems at play here. As a public representative for the community, as is Deputy Duncan Smith, it is incredibly frustrating that this circumstance has arisen and that it was handled by others so poorly.

Duncan Smith (Dublin Fingal, Labour)
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I was not clear in my first contribution, so I have an extra question. Regarding the distance of five nautical miles and height of 3,000 ft. that were used in the application, are these recognisable standard distances and heights for banking and divergence as per the regulations when the IAA is assessing it? Are they standards used in the industry?

Mr. Declan Fitzpatrick:

Possibly. After you take off, the key criteria before you do any banking - this is from memory so please do not quote me, although I can come back to the Deputy with specific details - is that the aircraft must be 65 m above the nearest obstacle on the route it banks. When an aircraft comes off the end of the runway and is climbing, before we would allow it under our safety regulations to start to bank, it should reach at least whatever the obstacle is in that area plus another 65 m because it should start banking. That is our criterion so whether that is 650 feet or if there was a hill ahead, it would be a much higher figure. That is our criterion.

Duncan Smith (Dublin Fingal, Labour)
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That is a very low height and is not a height we would have been used to when we were trawling through dockets. I really appreciate the IAA appearing before the committee today and I appreciate that its role is not directly related to the problems we are having locally but I really appreciate Mr. Fitzpatrick providing clarity insofar as he can.

Mr. Fitzpatrick mentioned that when the SIDs are presented to the IAA, it would go through a consultation process with the proposer of the SID. Is that a discretionary consultation process? Who is consulted? Is it the proposer plus the airlines? Is there a standard consultation process the presenter of the SID must go through or does it just have a consultation process of any kind?

Mr. Declan Fitzpatrick:

From the safety regulator's perspective, the process it would go through is a validation that the aircraft proposed to operate these can all operate them so it would have gone through simulations of the actual route, tested it with aircraft in simulators to see whether all the aircraft are able to meet the turns where it is proposing turns, the height climbs, etc. That is all part of the process it would go through. That would be tested. It would be flown physically to test the route. From our perspective, that is then going through a consultation process.

Duncan Smith (Dublin Fingal, Labour)
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A very technical consultation process.

Mr. Declan Fitzpatrick:

Absolutely.

Duncan Smith (Dublin Fingal, Labour)
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It is not like they are going to airline A, airline B and airline C, asking what they want to see in this SID. It has been put forward to us is that airlines wanted to be able to diverge early and quickly, particularly if they are going back to Europe, because they would have fuel saving and punctuality bonuses. That has been put forward to us as a reason for this, so I am trying to find out whether this came through a consultation process. From what Mr. Fitzpatrick is saying, the process seems to be technical as opposed to-----

Mr. Declan Fitzpatrick:

It is quite technical. From our perspective, it is a technical consultation with us.

Mr. Jim Gavin:

The airport operator DAA plc and the local IAA ANSP go through a consultation form that is called the Dublin Operators Planning Group, DAOPG, which consists of, in the main, the base airlines. They would have been consulted on the airspace requirements, the standards for departures, etc., so that consultation from an operator level would have taken place.

Duncan Smith (Dublin Fingal, Labour)
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And fed into this.

Mr. Jim Gavin:

That is correct.

Gerry Horkan (Fianna Fail)
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Basically that would involve Aer Lingus and Ryanair and maybe Stobart if it was around at the time.

Mr. Jim Gavin:

That is correct.

Darren O'Rourke (Meath East, Sinn Fein)
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Does the IAA have the actual timelines in terms of the presentation of the SIDs from the DAA regarding the operation of the north runway? Mr. Fitzpatrick said that it would have been on the ICAO or EASA publication a couple of months before. Was it last January?

Mr. Declan Fitzpatrick:

I do not have specific dates with me but we can supply the Deputy with them. The application would have come to us and we would have reviewed it. I am sure there were two or three iterations before we got to final approval.

Once it is approved by us it then goes into what I referred to earlier as the AIRAC cycle. It gets submitted to the aeronautical information publication. I would need to check the date of when that came in but, typically, it would be at least two months before the runway went into operation.

Darren O'Rourke (Meath East, Sinn Fein)
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In all of that, would those SIDs have taken into account the operation of the two runways as segregated runways?

Mr. Declan Fitzpatrick:

Yes, for the two 28 runways from the initial stage last year.

Darren O'Rourke (Meath East, Sinn Fein)
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Is Mr. Fitzpatrick saying he is satisfied that they were compliant with the safety requirements?

Mr. Declan Fitzpatrick:

Yes, they were.

Darren O'Rourke (Meath East, Sinn Fein)
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Is the IAA is responsible for overseeing the initial operation of those flight paths?

Mr. Declan Fitzpatrick:

Their operation is by Dublin Airport Authority but, specifically in terms of air traffic control, by AirNav Ireland, ANI. We regulate AirNav Ireland, so we have oversight of it in terms of safety. The actual operation on a day-to-day basis is by the airport and the air navigation service provider.

Darren O'Rourke (Meath East, Sinn Fein)
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Is the adherence to the flight paths monitored by AirNav Ireland?

Mr. Declan Fitzpatrick:

It is with AirNav Ireland in the first instance but where there are deviations outside of safety norms, we get occurrence reports. Either airlines or the air navigation service provider report occurrences to us and we get the information in that manner.

By way of background, Regulation (EU) No. 376/2014 requires all sorts of people in aviation to report to us very specific events. Last year, we received more than 10,000 mandatory occurrence reports. That is a very good reporting rate. Specifically on air traffic control-----

Gerry Horkan (Fianna Fail)
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Who makes those reports?

Mr. Declan Fitzpatrick:

The reports to us can be from individuals or organisations. Any certified organisation reports into us.

Gerry Horkan (Fianna Fail)
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What would they say? Could Mr. Fitzpatrick give us a flavour of what the reports say?

Mr. Declan Fitzpatrick:

It could be anything from a spilled cup of coffee to a failure of components. Probably the most common reported occurrence to us is what is referred to as system component failures, non-power plant. A component on the aircraft might have failed. Members should please not worry; this is normal operations.

Gerry Horkan (Fianna Fail)
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If a seatbelt clip is not working, does it have to be reported to the IAA?

Mr. Declan Fitzpatrick:

We ask them to filter that one out because they can deal with that internally. The whole purpose of the occurrence reporting regulation is to try to identify trends, new safety issues arising and new hazards across Europe. The details that we get from occurrence reports are fed into a European central repository, in order that we can do analysis at a European level.

Darren O'Rourke (Meath East, Sinn Fein)
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I wish to ask about the type of notifications the IAA might have got in the period following this runway coming into operation from communities. I cannot remember what the turn of phrase was but, ultimately, it was that the IAA was working towards a change of SIDs in February. Is the IAA getting notifications from the DAA or from anyone else about the operation of those flight paths?

Mr. Declan Fitzpatrick:

When an aircraft follows the flight path, there is a tolerance level. Each SID can be different but the tolerances will be defined. For example, we would see if there is an issue with any of the aircraft flying in today. There is no issue. They are able to fly them. The aircraft are well capable of flying those paths. There is no big issue in respect of following the SID.

Darren O'Rourke (Meath East, Sinn Fein)
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In the period between the opening of the north runway and the introduction of the new SIDs in February, was there much by way of occurrences?

Mr. Declan Fitzpatrick:

I will have to come back to the Deputy. I do not have the details here with me. I do not believe so.

Darren O'Rourke (Meath East, Sinn Fein)
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There was nothing outrageous or no major incident.

Mr. Declan Fitzpatrick:

I do not believe there was any adverse trend.

Darren O'Rourke (Meath East, Sinn Fein)
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Mr. Fitzpatrick is not aware that there was a major trend.

Mr. Declan Fitzpatrick:

No. I can come back to Deputy O'Rourke with specifics.

Darren O'Rourke (Meath East, Sinn Fein)
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I thank Mr. Fitzpatrick.

Alan Farrell (Dublin Fingal, Fine Gael)
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That was very informative. I was not aware that the IAA had oversight over deviation of aircraft, and I had not realised that this is something that is reported to it.

I omitted to ask a question, which may well be linked to NADP, but Mr. Fitzpatrick might clarify. Are continuous climb operations, CCOs, conditioned as part of an SID?

Mr. Declan Fitzpatrick:

No. We should remember that the idea of the SID is to try to ensure the separation of aircraft, to deconflict. In some cases a SID might say, climb to 3,000 ft and level off because, for example, the aim might be to keep the aircraft below another track above it. No, there is not a precondition for continuous climb operations.

Alan Farrell (Dublin Fingal, Fine Gael)
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I thank Mr. Fitzpatrick for humouring me on previous questions.

Gerry Horkan (Fianna Fail)
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We are all learning a lot here today.

Alan Farrell (Dublin Fingal, Fine Gael)
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I think so.

Mr. Declan Fitzpatrick:

It is lifelong learning.

Alan Farrell (Dublin Fingal, Fine Gael)
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If we are taking off on our flight path, when we get to 65 m above an obstacle, is the aircraft then permitted to go up in altitude?

Mr. Declan Fitzpatrick:

To bank.

Alan Farrell (Dublin Fingal, Fine Gael)
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Yes, to bank. Mr. Fitzpatrick should forgive me. I want to make absolutely clear who is responsible for the instruction to the aircraft to adopt a standard departure within the corridor that the IAA has given its assent to, by verifying that it was within the code?

Mr. Declan Fitzpatrick:

I will step back a little bit, and I might let the pilot come in then as well. The way the SIDs are used is that prior to even pushing back at the gate the pilot will be informed of which SID he is to follow on departure, which runway is active, which way he is going to go out-----

Gerry Horkan (Fianna Fail)
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Is that coming from the air traffic control?

Mr. Declan Fitzpatrick:

That is coming from the air traffic control. All these SIDs are programmed into the flight management computer so the pilot can select. For example, he might be told to take Liffey 1. This is the nomenclature that is used. He will select that on his flight management computer. That will give him all the waypoints on his display along that procedure. It is kind of like a Garmin or moving map in a car. It is the same kind of concept on where he has to go, what heights to climb etc., the whole way out to the end of the SID.

Gerry Horkan (Fianna Fail)
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Is it the case that the airline cannot say it wants to go this way or that way because it will save it fuel? Do the airlines not have that level of discretion?

Mr. Declan Fitzpatrick:

The SIDs are designed to make it easy to follow and to minimise the amount of communications that are necessary, but at all times a pilot has primacy. If a pilot experiences any difficulty on an aircraft, he can communicate with ATC and say he has a problem and he needs to keep going straight ahead. That is perfectly allowable.

Gerry Horkan (Fianna Fail)
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But, by and large, they follow the SID.

Mr. Declan Fitzpatrick:

Similarly, an air traffic controller might ask a pilot to vector in a particular direction off the SID, for some reason. That is perfectly acceptable.

Gerry Horkan (Fianna Fail)
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But, by and large, they would be using the SIDs, as described, and they do not have that much discretion, other than a bird strike or if something goes wrong. They follow what they have been told to do. We were talking about airlines being able to cut fat to save them fuel. They are not doing it for that reason.

Mr. Declan Fitzpatrick:

If they are assigned to a SID, they are expected to follow it.

Mr. Jim Gavin:

I will provide some more detail around the air traffic management, ATM, function. What primarily happens is that when the particular operator submits a flight plan, it is controlled by the network manager in Eurocontrol, which is part of the single European sky concept. That flight plan is then sent back to the local ANSP, in this case, ANI at Dublin Airport, which would issue that clearance to the flight crew, who as the chief executive said, will put that into their flight management system on the aircraft.

At a tactical level, the airport operator can change the SID, depending on a change in the departure runway or for whatever tactical reason there might be to assign a different SID to the aircraft, but primarily it is the ATM function that drives the SID that is issued to the flight crew.

Gerry Horkan (Fianna Fail)
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When there was a single or main runway, aeroplanes took off and landed in the same direction. There is no other way we could imagine them doing it. Is it the case with parallel runways in place that they both have to go the same way? Do they both go westerly or easterly or can we have one going one way and the other going the other way?

Mr. Declan Fitzpatrick:

It is preferential that they would go in the same direction.

Gerry Horkan (Fianna Fail)
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That is what I imagined.

Mr. Declan Fitzpatrick:

I think there are one or two cases globally-----

Gerry Horkan (Fianna Fail)
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Because there is a mountain at the end of the runway or something that makes them go the other way.

Mr. Declan Fitzpatrick:

There are one or two cases globally where they have tried to do that for different reasons. There could be limitations in an area such as mountains etc. but it is not preferred.

It introduces a lot of safety risk that has to be managed and there is no good reason to do that.

Gerry Horkan (Fianna Fail)
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It tends to be that the aircraft tend to come in over the sea when landing, and they go east-west and they take off that way as well. Is that historical? I can understand why they come in east-west because they are primarily flying in from Europe. That is the vast bulk, although there are US ones as well.

Mr. Declan Fitzpatrick:

There is a very practical reason for it, namely, the wind. The predominant wind in Dublin is westerly so that is why.

Gerry Horkan (Fianna Fail)
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You fly into the wind and it gives you the extra lift or whatever.

Mr. Declan Fitzpatrick:

Yes.

Gerry Horkan (Fianna Fail)
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So the option of turning the north runway around and flying the other way is not really an option.

Mr. Declan Fitzpatrick:

It is not when the winds are coming from the west.

Gerry Horkan (Fianna Fail)
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Which is 90% of the time or whatever.

Mr. Declan Fitzpatrick:

Exactly.

Gerry Horkan (Fianna Fail)
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As no one else wishes to contribute, I thank Deputy Alan Farrell for giving the committee this topic to consider and Mr. Fitzpatrick for facilitating the committee's request to come in. It has been very useful and particularly for the Deputies around the airport. I am sure many people have been watching and listening to us. They may have had questions of their own. This has been very useful and I thank everyone.