However, this process is likely to take at least two years to get a decision, leaving the airport in a limbo of sorts unless it gets some emergency relief from the restriction.

In the year to the end of October, there have been over 27m passengers passing through the airport with two months left in the year and the busy Christmas period to come.

Eoghan Corry, travel industry expert, said the cap will have to be lifted “within weeks” or Dublin Airport is going to be in trouble.

“They don’t have any time, it is a crazy situation. They almost hit the cap in 2019, had three years where nobody was worried about numbers and didn’t get that sorted,” he said.

In 2019, Dublin Airport recorded its best year on record welcoming 32.9m passengers, of which 2.2m were people using the airport for transfers to another location. For the overall figures, those transferring are counted twice — for arriving and departing — but for the purposes of the planning rules they are counted once so Dublin Airport did not breach the cap in that year.

Last week, the Daa chief executive Kenny Jacobs said that the total number of passengers starting and ending their journey at Dublin Airport should come to 32m or “slightly less” this year.

Fingal County Council, which oversees the airport for planning purposes, is keeping a very close eye on all of the airport’s passenger cap. A spokesman for the council said it is “responsible for the enforcement of planning conditions” including the passenger limit and it would “act accordingly if complaints were received”.

Discussions have already begun between the Daa and the airlines in order to reduce the passenger numbers coming into the airport during next year.

Mr Jacobs has said it is “actively managing down capacity” by removing growth incentives for airlines and making difficult choices on charter flights and non-scheduled flights.

Mr Corry said if the Daa really starts to run into trouble next year, it would simply have to go back to the airlines and say that flights would have to be cut by a certain amount adding that the airlines are already frustrated with the situation and Dublin Airport for letting it get to this position.

New data from Fáilte Ireland shows that the planned seat capacity for flights into Ireland this winter and into early next year are expected to be 11% higher than levels seen in 2019 and 2020.

According to the tourism body, over 90% of travellers into Ireland from the country’s biggest markets — US, France, and Germany — fly into Dublin Airport with 76% of travellers from Britain travelling into the airport.

Travel agency Click and Go’s chief executive and vice president of the Irish Travel Agents Association Paul Hackett said the level of advance bookings for 2024 is “stronger than what we would normally expect to see”.

“We only see the outbound numbers and the outbound numbers are pretty much close to, if not equal to, pre-pandemic,” he said. “It is a huge economic challenge if we are going to have a cap or limitation on an airport.”

Mr Hackett said there is a concern, which was also raised by Mr Jacobs, that airlines would move their better aircraft away from Dublin Airport if the cap continues to remain in place as they will “look for the return on capital employed that their shareholders are looking for”.

Passenger limits and frustrated airlines are not the only issues Dublin Airport has had to deal with this year as a number of other issues have cropped up forcing the Daa to respond.

In August, the Daa was hit with an enforcement order from Fingal County Council over the number of night-time flights scheduled by the airport. The High Court has stayed that order while it is adjudicated.

Following an excruciating couple of years where travel demand was dampened by the pandemic, Dublin Airport couldn’t have asked for a better 2023 in terms of passenger numbers rebounding.

However, while the success will have been welcomed, it has also created a number of headaches for management which is going to make next year difficult to navigate.

It is
a huge economic challenge if we are going to have a cap