Tuesday 16 December, 2014
Referral Business Entry Point
EIA Policy Section (EPBC Act)
Approvals and Wildlife Division
Department of the Environment
GPO Box 787
Canberra ACT 2601
Dear Sir/Madam,
Reference Number 2014/7391 - Commonwealth Government
Proposed Western Sydney Airport
The above referral for Environmental assessment relates to the following the proposed airport at Badegrys Creek.
Development of the proposed airport would be staged in response to demand, with an initial stage including one runway and an ultimate airport layout potentially comprising two parallel runways on a broadly north-east/south-west orientation of up to 4,000 metres in length, with supporting airside and landside facilities capable of handling up to about 70 million passengers movements per year. To maximise the potential of the site and its commercial viability, the proposed airport would operate on a 24-hour basis.
I am disappointed that this referral dismisses the impacts of the proposed Badgerys Creek airport upon the Greater Blue Mountains World Heritage Area. I consider these impacts to be significant.
The text regarding nearby reserves has been inserted into the referral from the 1999 Environmental Impact Statement and does not adequately consider the World Heritage Area created in 2000. The referral not does provide the correct names for some of the most affected reserves, now known as state conservation areas, and does not consider formally protected wilderness within the World Heritage Area that would potentially lose its natural quiet.
Diverting aircraft over the Blue Mountains is only to avoid overflying the suburbs of Western Sydney. There can be no doubt that maximum use will be made of airspace to the west. This tactic is the equivalent of Kingsford Smith Airport making maximum use of the airspace to the south, which it does.
Unless steep ascent and descent flight paths are mandated, aircraft will not fly very high above the Blue Mountains terrain – a dissected sandstone plateau that reaches to over 1000 metres in height. The Bents Basin State Conservation Area on the Nepean River, only 8 kilometres from the proposed airport site, receives half a million visitors per year and could be badly affected by aircraft noise.
Incorrect statement regarding noise in the World Heritage Area
Remarks in the referral that ‘noise levels resulting from infrequent aircraft overflights of these areas of the World Heritage property are expected to be relatively low’ are likely to prejudice the future environmental assessment by not placing emphasis on this important matter. This prejudice is further illustrated by the incorrect remark that ‘While aircraft at the proposed airport would fly at a lower altitude than current operations, they are not expected to represent a new source of impact on the World Heritage values of the World Heritage property’ (section 1.3(a) of 2014/7391).
Of course the noise impact will be a new source of impact, just not a new type of impact. This argument is equivalent to saying that because one freeway passes through a city a second freeway will not present a new source of impact. This remark in the referral is factually incorrect. The flights into and out of the proposed Badgerys Creek Airport will be a new source of impact. The remark indicates an intended bias to ignore what will most likely be a very significant aircraft noise impact.
Aircraft noise impacts on the World Heritage Area - Factors to be considered
The environmental assessment must consider how to mitigate the significant aircraft noise impact on the natural quiet of the World Heritage Area. There is a considerable amount of science and regulation regarding the protection of the natural quiet of wilderness areas. These materials have been developed to protect wilderness areas in the United States of America. I believe that this material is highly relevant to the proper regulation and mitigation of aircraft noise impacts associated with the proposed airport.
I recommend that the assessment methodologies applied in the United States of America to the regulation of aircraft noise over wilderness be applied to this environmental assessment for the proposed airport.
I further request that all prudent and reasonable alternatives regarding the regulation of aircraft noise over the Greater Blue Mountains World Heritage Area be examined in relation to the proposed airport.
The environmental impact statement must consider and make an assessment of aircraft noise impacts in relation to proposed flight paths on the World Heritage property. The environmental impact statement must then consider ways mitigate this impact by variation of flight paths so as to protect the natural quiet in wilderness areas. Given there is no sea area to dump 55% of aircraft takeoffs and landings and in order to give noise relief to the surrounding residential suburbs the Greater Blue Mountains is the only flight path not over peoples homes and is likely to be the sole flight path once noise complaints in Western Sydney rise to the levels of noise complaints in the Eastern suburbs.
A situation where 100% of noise from aircraft taking off and landing at Badgersy Creek is an impact on wildlife in the protected area thta needs to be considered. The impact on park visitors cannot be dismissed. The Greater Blue Mountains World Heritage Area is a refuge from noise for many park visitors. Any World Heritage Area must be provided with adequate protection, including that of its peace and quiet. The perception of noise in national parks by visitors is related to the fact that parks tend to be quieter than urban settings and the potential for noise pollution by aircraft is thereby much greater.
The southern Blue Mountains, arguably Australia’s most popular wilderness area, has been completely overlooked by past environmental assessments for this proposed airport. The Commonwealth now has legislative and treaty obligations to protect the Greater Blue Mountains World Heritage Area.
Blue Mountains tourism is known to sensitive to adverse environmental impacts, as was demonstrated by the significant downturn in visitor numbers following the 2013 bushfires. The post-fire downturn halved tourism income despite the fact that most of the popular tourist areas were free of bushfire impacts.
Nature-based tourism will be impacted if the Blue Mountains are subject to 24 hours a day of aircraft noise. The impact of aircraft noise associated with the proposed Western Sydney Airport on nature-based tourism in the Blue Mountains should be assessed and action taken to mitigate this potentially significant impact. If action is not taken to mitigate potential noise and visual impacts, then the nature-based tourism upon which the Blue Mountains economy depends will decline.
Under the NSW Wilderness Act 1987, large sections of the Blue Mountains National Parks must provide for the experience of solitude and thereby natural quiet. Maintenance of natural quiet in the Blue Mountains National Parks and wilderness areas is incompatible with 24 hour overflights by aircraft arising from the proposed Badgerys Creek Airport.
There has been no expert consideration of the environmental effects of flight path design for the new airport upon wilderness areas, World Heritage and the Blue Mountains National Parks and Reserves. These factors need to be remedied by the environmental assessment.
Impacts of Aircraft on National Parks – the Experience in the United States
In the United States, Congress commissioned acoustic studies and user surveys so as to determine how to maintain natural quiet in wilderness areas. The US Aviation Authority made specific regulations in the Grand Canyon for flight-free zones to an altitude of 14,500 feet above the park. Impact mitigation for general aviation was achieved through specifying flight corridors.
The proposed Badgerys Creek Airport must provide similar flight-free zones to 14,500 feet and specific flight corridors to protect the Greater Blue Mountains World Heritage Area.
If this is the case then the impact on surrounding residents in the future should also be considered. Further, I believe that the sensitivity of the acoustic environment in National Parks should lead to the development of specific Australian guidelines for monitoring and minimising aircraft noise in wilderness areas. This would make the proposal totally incompatibile with the site which should be sold to fund an airport in a less sensitive area for National Parks and residents.
I request that the noise modelling undertaken for the proposed airport covers the World Heritage Area and that it takes account of its elevated terrain. The loss of natural quiet arising from aircraft noise would not be in keeping with appropriate management of the World Heritage Area.
In relation to the previous environmental assessment quoted in this referral and stated by Minister Warren Truss in his recent media release to be one of the most comprehensive environmental assessments in Australia, it provides the following critique from the SMEC Auditor and the NSW NPWS.
- Despite the detail in the EIS, the SMEC Auditor’s Report found:
The draft EIS [of 1998] does not assess the effects of noise upon users of affected national parks and state recreation [now conservation] areas. The numbers and types of users are not discussed and the computer modelling did not extend over the Blue Mountains. [The 1999 EIS did not remedy this flaw].
- At the time of the draft EIS in 1998, the NPWS reported to its Minister that:
‘The proposed Badgerys Creek Airport would result in potentially severe and unacceptable noise and visual impacts on NPWS reserves which provide recreational, educational and visitor opportunities. This includes Blue Mountains National Park, Burragorang State Recreation Area, Bents Basin State Recreation Area, Kanangra-Boyd Wilderness Area, Nattai Wilderness Area, the Grose Wilderness Assessment Area [now declared wilderness] and the proposed Blue Mountains World Heritage Area [now listed].
‘Such impacts have the potential to significantly detract from the recreational amenity of the above reserves, a key purpose of which is to provide an understanding and enjoyment of the natural and cultural values of relatively undisturbed natural areas.’
The NPWS considered that the intrusiveness, of for example, up to twenty five flights over the Blue Mountains National Park exceeding 70dBA in a single day is likely to significantly detract from a visitor’s experience of nature during a visit to the park, which is a major tourist attraction to national and international visitors, attracting over 3 million visitors a year.
I specifically request that aircraft noise is assessed and mitigated in relation to all NPWS reserves which will be affected by this proposal, and not just the World Heritage Area, so that their natural quiet is preserved.
Other Matters of Significance that should be considered
within the EPBC referral scoping process
Regional planning considerations
The North-West and South-West Growth Areas combine with existing urban sprawl and the Broader Western Sydney Employment Area to occupy a semi-circle around the proposed airport site. This sprawl occurs on the assumption that noise and air pollution will be ‘acceptable’, yet what is deemed to be ‘acceptable’ for western Sydney would be intolerable if imposed on more affluent suburbs to the east. The 24 hour a day airport operation will cause sleep interruption for many thousands of people and the air and associated road traffic will create unacceptable levels of smog.
Western Sydney’s higher air pollution levels are due to its geography. This fact should alone be fatal to the proposal. A second Sydney airport should be located outside the Sydney Basin to prevent unacceptable increases in mortality and morbidity due to recognised air pollution problems and alternate and less polluting transport solutions, such a very fast trains, considered.
Planning without consideration of air pollution constraints is a serious concern
The 1999 EIS acknowledged that the proposed airport will increase ozone pollution, noting that 15 years ago the area was ‘already experiencing occasional occurrences of high background levels.’ Unacceptable air pollution levels arise when air is trapped and recirculated in the Sydney Basin., The air pollution model for the proposed airport should more accurately predict this air mass behaviour.
High ozone levels correlate with hospital admissions for respiratory illnesses, asthma and increased mortality. The EIS needs to consider the associated increased road traffic movement the airport will generate and predict by how much and when acceptable ozone levels will be exceeded as a result of the proposed airport.
I consider that the proposal to continue urban expansion in association with the proposed airport at Badgerys Creek is unethical as it is known that air pollution in western Sydney is already unacceptable.
Transport planning considerations
The infrastructure planning for the airport is biased toward motor vehicle transport. The tens of millions of passengers motoring to the airport each year will exacerbate the serious health problems associated with photochemical smog.
The impact assessment should consider the transport infrastructure planned for the airport. These associated infrastructure considerations have significant environmental and financial impacts that must be considered by the environmental assessment. They will also have contingent impacts on matters of environmental significance, for example Cumberland Plains woodlands.
The proposed airport impact assessment must also consider the relocation of water and electricity infrastructure. For example, Sydney Water Corporation has previously indicated that the large water supply pipes from Warragamba Dam to Prospect would need to be relocated underground in key areas to protect water supply security.
Water pollution and local flooding
While South Creek may already be polluted, the pollution will be quadrupled by the construction of the proposed airport. This will mean that South Creek will effectively poison the Hawkesbury River causing downstream impacts, such as the possible loss of the oyster fishery.
Further, stormwater runoff is likely to increase local flooding beyond existing levels, and much of the North West Growth Sector is flood prone land. While the NSW Government’s intended development of flood prone land in the North West Growth Sector is foolish beyond measure, the proposed airport has the potential to increase local flooding in this area. The extent and nature of this increased flood potential should be examined in detail.
Just because these increased flood risks would be external to the site does not mean that these impacts should be ignored. Flooding associated with South Creek can contribute to major flooding downstream in the North-West Growth Area. Failure to adequately consider and mitigate these impacts may make the Commonwealth liable to third party class actions for damages when these new urban growth areas are subsequently flooded.
Sewage from the proposed airport must be regulated on-site so that there are no off-site impacts at the end of discharge pipes. Similarly any discharge of saline groundwater from the proposed airport site to South Creek should be prevented.
Thank you for the opportunity to raise these concerns regarding the proposed airport. I am sorry that I was restricted by time in fully covering all my concerns but hope that the issues raised will be properly considered in the subsequent environmental impact statement.
Yours sincerely,
Jackie Kelly
