Travel

The advertisement was seen in a national newspaper and heard on radio.

The newspaper advertisement listed Cork Airport and Dublin Airport at the top and featured an animated image of the sky which included text in the shape of clouds. The text stated,“128,000 jobs lift us all.”

Further text towards the bottom of the advertisement stated:

“Together, Cork and Dublin Airports contribute a massive €10.6 billion to the Irish economy and support over 128,000 jobs nationwide. From direct jobs at both airports to the indirect boosts to local businesses, tourism, trade, investment and productivity, we’re proud of our role in connecting Ireland to the world.”

Beneath this was the daa logo.

The radio advertisement stated:

“At Cork and Dublin Airports, we want to lift everyone in Ireland, not just our passengers. The€10 billion we contribute lifts our national economy, with 128,000 jobs boosted by us being here! Our support also lifts dozens of charities and hundreds of local community activities. And, by halving airport emissions by 2030, we think we can lift everyone’s future hopes even higher! Cork and Dublin Airports lift us all!”

Six complaints were received against the advertising including one from Lynn Boylan, MEP. Two issues were identified.

Issue 1:
One complainant considered the press advertisement to be misleading on the basis that it was claimed that the daa contributed 10.6 billion to the Irish economy, however they said that when it was taken into account that Irish people travelling abroad took 12.9 billion out of the economy, this should have been made clear within the advertisement in line with normal accounting practice of completeness and transparency.

Issue 2:
Five complainants considered the radio advertisement to be misleading by omission as they said that the claim, “halving airport emissions by 2030” gave the impression that all emissions related to the airport (including flight emissions, etc.) would be halved. They said that this was not the case and that the reference to “halving airport emissions” referred exclusively to emissions relating to the airport directly.

Issue 1:
The advertisers said that the information relating to the contribution of both Cork and Dublin Airports to the economy was taken from an independent study carried out by an independent economics firm called InterVISTAS. They explained that InterVISTAS was established in 1997 and specialised in mobility/transport and has completed more than 2,000 projects in over 75 countries.

The advertisers said that the study measured the total economic impact of Dublin Airport including activity directly related to the airport, the multiplier impacts that flowed from it, and the other sectors of the economy facilitated by the airport. They said that this was an internationally accepted methodology to assess economic impact and that the full report was available at: www.daa.ie/esg.

The advertisers said that Dublin Airport supported or facilitated 116,100 jobs in the Republic of Ireland. They said that of the 116,100 jobs Dublin Airport was responsible for, 19,900 were direct, with a further 11,700 indirect jobs in firms that supported or supplied the airport.

The advertisers explained that a further 13,300 jobs could be linked back to the airport through employees spending in the economy, while the airport helped sustain 71,200 more jobs through its facilitation of tourism, trade, investment and productivity. They said that when it came to jobs, 27% of the employment generated by the airport was in Fingal, with a further 21% in the rest of Dublin, 22% in the rest of Leinster and 31% across the rest of the country.

The advertisers said that Dublin Airport was a key conduit to the equivalent of 2.3% of the national economy and in terms of Dublin Airport’s economic contribution, 29% of total GVA was located in Fingal, with 24% of GVA located in the rest of Dublin, 20% in the Rest of Leinster, and 28% in the Rest of Ireland. They said that Dublin Airport was a critical piece of national infrastructure which had an economic impact felt throughout the country.

he advertisers said that likewise, analysis by InterVISTAS showed that Cork Airport played a critical role in supporting jobs in tourism and trade across the south of Ireland as a key economic enabler for industry and commerce. They explained that day-to-day operational activities at Cork Airport directly supported 2,330 jobs in companies across the airport campus including airlines, air traffic control, ground handlers, airport security, immigration, customs, and airport retailers in 2023 and that an additional 10,320 jobs stemmed from the indirect, induced, and catalytic impacts of the airport’s operations.

The advertisers said that airports in Ireland played a vital role in supporting the economic, social and cultural wellbeing of the nation and demand for air travel to and from Ireland remained very strong. They said the fact that people chose to travel overseas and spend money that benefitted other economies was reciprocated when tourists travelled to Ireland.

The advertisers said that furthermore, those Irish residents who travelled out of Dublin and Cork airports often spent money associated with their holiday in Ireland before they travelled, purchasing clothing, toiletries, gifts, travel insurance, bus fares and other purchases to enable their holiday or to take with them on their trip.

The advertisers said that the ad was focused on the contribution of their airports only and there was no suggestion that this was a net gain figure or calculation.

Issue 2:

The advertisers said that they understood the importance of recognising and addressing the issue of climate change and that they fulfilled their requirements to record and report on emissions in line with their obligations under the Public Sector Carbon Reduction Targets, as detailed in the National Climate Action Plan. They explained that this Plan referred specifically to Scope 1 and 2 emissions (those from Airport facilities, fleet vehicles, generated and purchased energy).

The advertisers explained that the ad series was designed to reflect the overall role and impact of Cork and Dublin Airports, and while the significant economic and community contribution to Ireland was the primary message, it was important to acknowledge the sustainable change that was driving them. They said that the use of the term “airport emissions” created a degree of specificity regarding the nature of the emissions being referred to which they felt was appropriate to the overall tone and content of the ad.

The advertisers said that the carbon reduction requirement of Public Sector targets mandated a 51% reduction of carbon by 2030 vs a baseline of 2016 – 2018 emissions (a “halving of airport emissions”). They said that this target applied to both Cork and Dublin Airport.

The advertisers clarified that by taking actions such as, moving their owned fleet to electric vehicles (100% of light fleet by 2025), swapping diesel for low emissions HVO where practical and building a solar farm that could provide over 10% of their energy from the sun, they were doing the work now to create sustainable airports and meet the 2030 public sector targets.

The advertisers explained that the term, “airport emissions”, was the correct and accepted term to use when referring to emissions over which the daa had direct control and which were assessed when the airport was submitting its reports on progress against sustainability objectives.

The advertisers explained that the daa ran airports and operations therein, including a range of activities from retail to emergency services, from property management to buses and airfield operations. They said their objective to halve airport emissions encompassed all these activities, and not a fraction of them. The advertisers said that this was fully in line with requirements for public sector organisations under the National Climate Action Plan and was clearly outlined on their public website and in their Group Decarbonisation Policy.

The advertisers said that they did not consider that the advertisement exploited the knowledge of consumers and said that full details of the daa’s sustainability plans and granular information about emissions statistics, as well as their Group Decarbonisation Policy, were provided for the public at: www.daa.ie/esg.

The advertisers concluded that the advert did not overstate the airport’s environmental efforts and made no reference to or inference regarding the aviation sector, flights, airlines, air travel or anything that created a sense that this was an ad about aviation or air travel in general, or that it had been written on behalf of or jointly with airlines.

Further Information:
The International Civil Aviation Organisation (ICAO), a United Nations Specialized Agency, outlined in its ‘Greenhouse Gas Management and Mitigation at Airports’1 document that they used the Greenhouse Gas (GHG) Protocol to categorize emissions relating to airports into three broad scopes based on whether they were direct or indirect emissions:

Scope 1: All direct GHG emissions. These would include emissions under the direct control of the airport operator.

Scope 2: Indirect GHG emissions from consumption of purchased electricity, heat or stream.

Scope 3: Other indirect emissions not under the control of the airport operator. For example, aircraft emissions or ground access vehicles.

In their section dedicated to creating a Net Zero roadmap, the ICAO stated that the first step was to develop a carbon or GHG emissions inventory. They said that this inventory must include all Scope 1 and Scope 2 emissions, and while Scope 3 emissions were typically not covered in airport Net Zero plans, it could be useful to include some or all Scope 3 emissions sources in the inventory to assist the airport in identifying potential opportunities and partners for wider reduction activities.

1 https://www.icao.int/environmental-protection/Documents/GHG%20Management%20and%20Mitigation%20at%20Airports.pdf

Complaints Upheld In Part

The Independent Complaints Council considered the detail of the complaints and the advertisers’ response.

Issue 1(Press advertisement) – Not Upheld:

The Complaints Council noted that the claims were “contribute a massive €10.6 billion to the Irish economy” (press advertisement). The claim was not referenced as a net gain figure or calculation. In light of this, they did not consider that the advertising was likely to mislead consumers and therefore did not consider that Issue 1 of the complaints breached the Code.”

Issue 2 (Radio advertisement) – Upheld:

The Council considered what consumers’ understanding of a reference to ‘airport emissions’ was likely to be, and they considered that, in the absence of a clarification, it was reasonable to assume that consumers would see emissions from airplanes as being part of airport emissions. In the circumstances, they considered that a reference to ‘airport emissions’, without any qualification as to what those emissions related to, could mislead consumers. In the circumstances the Council considered that the radio advertisement was in breach of Sections 4.1 and 4.4 of the Code.

Action Required:
The radio advertisement should not appear in its current form.

The Council advised the advertisers that any advertisement that refers to airport emissions must include a sufficiently clear qualification as to what the emissions relate to.