The Dublin Port Company has been urged to make better use of the 888 acres of land it controls rather than pursuing controversial plans to infill a further 52 acres of Dublin Bay.
Dublin Bay Watch, a voluntary group set up to protect what remains of the bay, claims the proposed eastward extension of the port would destroy an area of considerable value as a water amenity and wildlife habitat.
In a detailed submission, the group accuses the port company - chaired by the Taoiseach's associate, Mr Joe Burke - of paying no more than lip-service to the "excellent" plans by Dublin City Council to develop the amenities of the inner bay.
"On any given day, the Clontarf seafront, Bull Wall, Dollymount beach and the Royal Dublin golf course attract thousands of people to what, apart from Howth, is the only seafront amenity in the north-east of Dublin," according to Dublin Bay Watch.
If the port company was permitted to go ahead with the proposed infill, it would increase the industrialisation of the bay, with "warehouses, cranes, lights and the stacking of containers" destroying the natural amenity and vista of the inner bay, the group says.
After an "outcry" over earlier plans for the 52-acre infill, the group said the port company had promised local residents that the north shore of previous "ad-hoc" additions to the port estate would be landscaped, but less than half the area had actually been planted.
The company's latest plan follows the withdrawal of a 1999 application after the Minister for the Marine, Mr Fahey, made it clear that he would not consider it because the accompanying environmental impact statement was seriously flawed.
The plan has been reactivated, with a revised EIS, on the basis that additional land is needed to cater for expansion. Even the present throughput of the port, at 21 million tonnes, is well ahead of projected levels and way beyond what it can cope with.
But Dublin Bay Watch maintains that any major expansion of the port would run counter to national policy of spreading development to other areas, as well as exacerbating congestion caused by 8,000 heavy-goods vehicles making their way through the city.
In March of last year, it notes, Mr Fahey announced the establishment of a task force on transport logistics for the commercial sea ports with a mandate to explore opportunities for the diversion of trade to less-congested ports.
Though Dublin Port handles nearly half the throughput of 43 million tonnes nationally, a KPMG study found that 38 per cent of its ro-ro (roll-on, roll-off) traffic in imports and 54 per cent of ro-ro exports are destined for or originate in the Dublin area.
These figures showed that a considerable volume of trade could be diverted to other ports, according to Dublin Bay Watch.
Indeed, the port's chief executive, Mr Enda Connellan, had suggested that much of the bulk trade - in timber, for example - could be relocated.
The group also endorsed Mr Connellan's approval of the idea of relocating the port's petroleum tank farm to a site on the M50, with pipeline links to the port. The existing tank farm occupies an aggregate area of more than 100 acres.
"A great deal of the land in the port used solely for storage could then be freed up - roughly double the acreage of the proposed infill scheme," according to Dublin Bay Watch, which maintains that a further 40 acres of port land is derelict or under-used.
"Our contention is that with a slowdown in the economy, the construction of the Dublin Port Tunnel and a better use of its existing resources, the port company could further enhance its capacity from within," its submission says.
It also questions the redrawing by Dúchas, the Heritage Service, of a Special Protection Area for Birds excluding the proposed infill after meetings with the port company in 1999 - a matter now being investigated by the European Commission.
