Friday December 18th, 2015

Department of Infrastructure and Regional Development

Western Sydney Airport Submission

Western Sydney Unit

GPO Box 594

Canberra ACT 2601

email WSAsubmission@infrastructure.gov.au

Dear Sir/Madam,

Submission as an objection to the proposed Western Sydney Airport

1. Introduction

An airport at Badgerys Creek will increase air pollution; spread intrusive levels of aircraft noise

pollution through the Greater Blue Mountains World Heritage Area and residential areas; and

increase the risks of cancer in the western Sydney community due to increased pollution. The

Colong Foundation for Wilderness opposes the proposed Western Sydney Airport for these reasons.

The draft Environmental Impact Statement (draft EIS) has come forward without adequate

information to determine the proposal. On page 19 of the draft EIS this is acknowledged –

‘Decisions about airspace management…would be made by Airservices Australia and the Civil

Aviation Safety Authority (CASA) closer to the start of airport operations. These decisions could

require further environmental assessment processes, community and stakeholder engagement, and

may be the subject of a future referral under the EPBC Act following detailed design.’

Given that there is no possibility of framing appropriate conditions without adequate information

about aircraft noise and air pollution arising from airspace management, the proposal should be

deferred until this information is provided. This is confirmed on page 24 of the draft EIS where

readers are advised that the Australian Noise Exposure Concept (ANEC) contours are likely to be

used to define the development of Australian Noise Exposure Forecast (ANEF) contours once flight

paths and operating modes are finalised and approved (my emphasis). The consideration of options

for preferred flight paths and modes must be the core element of the re-exhibited draft EIS.

In effect, the draft EIS is the first stage of a staged proposal seeking approval of an airport concept

plan that lacks detailed consideration of environmental impacts that must be avoided, prevented

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and mitigated by appropriate conditions at the time of decision for the initial stage one airport

proposal.

The proposed airport concept plan must be refused consent as it lacks the necessary detail for

approval. Options for flight paths, operating modes and orientation of runway(s) must be

considered in detail before stage one of the proposed Western Sydney Airport concept is

determined. The best means of proceeding is to re-exhibit a further draft EIS with consideration of

options, including a preferred option.

2. Alternatives to a second Sydney Airport must be examined in detail

In the emerging low carbon global economy, larger, more efficient planes, fast trains, as well as,

telecommunications will eliminate the need for a second Sydney airport. The Federal Government

must defer further consideration of this controversial Western Sydney Airport proposal to avoid

wasted expenditure on unnecessary infrastructure.

The Colong Foundation urges that the establishment of a Melbourne-Canberra-Sydney-Brisbane very

fast train network must be examined as an alternative to a second Sydney Airport, as such a VFT

network would generate far less greenhouse gases and be more energy efficient.

The assumption in the draft EIS that there will be continued rapid growth in aircraft movements in

the coming global low carbon economy is unlikely to prove correct. Air traffic growth will peak due

to major changes brought about by policies requiring a low carbon economy and adaption to climate

change. For example, in a few short years the National Broadband Network will provide

communications technology that will dramatically push down demand for face-to-face meetings

amongst senior management that currently generates a significant amount of domestic air travel

demand. Technology will further reduce the need for domestic and to a lesser extent international

air travel.

3. Air pollution impacts on western Sydney residents

Two of the damaging toxins and carcinogens contained in Sydney’s air, benzopyrene and associated

microscopic particles1, are copiously produced by large commercial aircraft. The draft EIS for the

proposed airport predicts modelled exceedences for PM10 and PM2.5 particles in the longer term

development, but does not consider benzopyrene generation associated with the generation of

these particles.

1 Shabad, LM and Smirnov, GA, 1976, IARC Sci Publ, (13) 53-60, Aviation and Environmental Benzopyrene

pollution. Abstract - Spectrofluorescent methods of analysis have shown that soot and exhaust products of aviation engines, both piston and turbine, contain benzo[a]pyrene (BP). A modern aircraft engine releases into the atmosphere from 2-10 mg BP per min. Extracts of aviation engine soot applied to the skin of mice induced malignant tumors in almost all treated animals. The ground within airports is polluted with BP, its level diminishing with distance from the runway. The concentration of carcinogenic hydrocarbons in aircraft exhausts is dependent on the working regime of the engine and on the character of fuel combustion.

3

Air quality modelling for the proposed airport estimates for NO2 and PM2.5 pollution will exceed air

quality standards when annual aircraft movements reach 63,302 per year. The draft EIS expects this

will occur in 20302.

The biggest culprit of Sydney’s worsening air pollution, car use3, will be encouraged by the proposed

second airport and associated development. The proposed Western Sydney Airport Stage One is

predicted to generate 41,800 vehicle movements/day by 2030 and provide parking for 11,500 cars.

The maximum vehicle usage for Stage One of the proposed airport could be three times that number

of vehicle journeys, as the number of air traffic movements are estimated to triple by 2050.

The net effect of large numbers of car and aircraft movements, increased smog, would accumulate

in western Sydney where the proposed airport site is located. The modelling reports insignificant

increases in air pollution in the draft EIS, but this conclusion is not supported by existing air quality

measurement data and what is known about air pollution trends with increased vehicle movements.

An independent air quality modelling report undertaken in 2014 concluded that controlling growth

in motor vehicle emissions represents a viable option for reducing peak ozone concentrations in the

Sydney basin4. Yet the proposed airport seeks to accelerate vehicle usage in this region.

It is illogical to direct growth in aircraft and motor vehicle activity to an airport in western Sydney

where ozone pollution levels are already above standard5.

Increasing aircraft and motor vehicle traffic is wilfully bad planning taken in the full knowledge of

growing ozone air pollution that was identified 40 years ago as an issue that would limit new

polluting developments in western Sydney. Further, peer reviewers identified that the draft EIS

assessment of air quality has underestimated the potential impact of the proposed Stage One

airport development by a considerable margin6. The capacity of stage One of the proposed airport is

185,000 aircraft movements per year. Air pollution modelling must be undertaken for this level of

vehicle usage, so as to consider an appropriate ‘worst case scenario’.

Further, air pollution modelling for the proposed airport assumes that 41,800 vehicles

movements/day will be generated by 2030. This is perhaps the amount of traffic generated in the

first five years of operation of the proposed airport, however, 125,400 vehicle movements/day is the

worst case scenario, the maximum predicted vehicle movements for Stage One. As ozone

exceedances occur now at St Marys, the draft EIS air quality modelling has erroneously predicted

that air and vehicle traffic movements associated with the proposed airport Stage One will have

virtually no effect on air pollution levels. This modelling outcome is plainly wrong.

2 Katestone Environmental Pty Ltd, 17 November, 2015, Western Sydney Airport: Peer Review of Air Quality

and Greenhouse Gas Assessment, prepared for Parsons Brinckerhoff, page iii and iv. 3 In Sydney the largest source of anthropogenic NOx emissions are on-road motor vehicles, which contribute

over 71% of total NOx emissions (page 36, Current Air Quality in NSW – a technical paper supporting the clean air forum, 2010, Department of Environment, Climate Change and Water, Sydney.). 4 Advisory Committee on Tunnel Air Quality, 2014 July, TPO2: Air Quality Trends in Sydney, Office of

Environment and Heritage. Sydney, page 11. 5 Ibid, Ozone concentrations in the Sydney region have exceeded either or both of the Air NEPM ozone

standards every year since 1994. … Exceedances of both the 1-hour and 4-hour ozone standard occur more frequently in western Sydney. 6 Katestone Environmental Pty Ltd, 17 November, 2015, Western Sydney Airport: Peer Review of Air Quality

and Greenhouse Gas Assessment, prepared for Parsons Brinckerhoff, page iv.

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The modelled air pollution estimates must be understatements as future ozone pollution levels after

the airport is built must dramatically increase. The proposed 125,400 motor vehicles/day from Stage

One of the proposed airport will have an impact on air quality. The modelling must be redone and

peer reviewed to ensure predictions are realistic.

Given that Western Sydney already has exceedances of the ozone pollution standard, the increases

for ozone pollution arising from the proposed airport will be unacceptable. Badgerys Creek is not an

appropriate location for an airport due to unacceptable air pollution and must be refused consent.

4. Noise impacts on residents and the Greater Blue Mountains World Heritage Area - discounted

A re-exhibited draft EIS must consider how to prevent significant aircraft noise impacts on the

natural quiet of the World Heritage Area. There is a considerable amount of science and regulation

methodology that the re-exhibited draft EIS must consider to effect the protection of the natural

quiet of declared wilderness within the World Heritage Area.

The Colong Foundation is disappointed that the draft EIS dismisses the impacts of the proposed

Western Sydney Airport upon the Greater Blue Mountains World Heritage Area as being not

significant, rather than undertaking an adequate assessment of the potential impacts. The

incomplete noise assessment in the draft EIS follows the apparent bias in EPBC referral

documentation that claimed aircraft noise from the proposed Western Sydney Airport would not be

‘a new source of impact on the World Heritage values’7.

The Colong Foundation considers there is strong evidence to indicate impacts on the World Heritage

Area will be highly significant.

The noise generated by the proposed Western Sydney Airport will also affect hundreds of thousands

of western Sydney residents who are currently little affected by aircraft noise. Western Sydney

residents in the suburbs of St Marys, Erskine Park, Mt Druitt, Walan, Emerton, Ropes Crossing and St

Clair will be significantly affected by aircraft noise if a second Sydney airport is built at Badgerys

Creek. The noise impacts on residents of Blue Mountains suburbs, such as 60dBA at Blaxland from

100 overflights per day by 2030, were discounted by the draft EIS. Further, the draft EIS noise

assessments only examine the first five years of operation, not the full capacity operation of Stage

One of the proposed airport.

Aircraft noise policies and regulations in Australia do not specify limits to apply to aircraft for

overflight noise occurring at sensitive receptor locations8. As a result, there is no enforceable

protection for sensitive receptors in our community – such as its schools and hospitals.

The proposed airport has been not designed to protect sensitive receptors in the above suburbs,

such as schools and hospitals, from unacceptable noise. Noise policy and regulation must be

developed and applied in a re-exhibited draft EIS to protect sensitive receptors from overflight noise.

7 Referral 2014/7391 section 1.3(a)

8 Marshall Day Acoustics, 20 Nov 2015, Western Sydney Airport draft EIS, overflight noise peer review, page

20.

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4.1 Probable effect of complaints about aircraft noise impacts on flight paths and operating modes

The draft EIS predicts that by 2030 there will be 63,302 air traffic movements per year, rising to a

maximum of 185,000 by 2050 when work for a second runway will be initiated. In response to

community aircraft noise objections, the western Sydney airport lessee will almost certainly divert

aircraft noise to the unsettled areas nearest to Badgerys Creek – national parks in the Blue

Mountains.

As detailed above, the proposed airport will initially result in tens of thousands of aircraft

movements a year growing to hundreds of thousands. The actual rate of air traffic growth is a

matter of conjecture and partly determined by the airport lessee, particularly if they also lease

Kingsford Smith Airport. It may be that the airport lessee will divert planes currently arriving in the

Sydney airport curfew and shoulder periods to the proposed Western Sydney Airport in order to

make the new airport more financially viable. The No Aircraft Noise group are calling for these

aircraft diversions in submissions to the draft EIS. This request is unfair to western Sydney residents

and condemned by NSW environment groups.

If these unethical aircraft diversions from Kingsford Smith Airport are allowed, air traffic movements

will grow more quickly than modelled in the draft EIS and associated noise and air pollution will

rapidly exceed the predicted levels. Rapid increases in pollution levels will be unacceptable to the

local community.

If air traffic grows quickly, resident objections will more aggressively seek maximum use of airspace

to the west, eroding the peace and solitude of the Blue Mountains wilderness. On take-off, aircraft

will crawl up into the sky over the Blue Mountains, spreading aircraft noise (55-70 dBA) over these

pristine areas.

4.2 Effect of aircraft noise on Blue Mountains tourism economy

Aircraft noise from the proposed airport is going to significantly detract from a visitor’s experience of

nature during any visit to the Greater Blue Mountains World Heritage Area (GBMWHA), which is a

major national and international attraction receiving over three million visitors a year9. The draft EIS

has failed to assess the economic impact of increased noise on the Blue Mountains tourist economy.

Blue Mountains tourism is known to be 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 adversely impacted, especially as the Blue Mountains are proposed to

be subjected to aircraft noise 24 hours a day. The impact, including economic impact, of aircraft

noise associated with the proposed Western Sydney Airport on nature-based tourism in the Blue

Mountains must be assessed in the re-exhibited draft EIS and action taken to mitigate this significant

impact. If action is not taken to mitigate potential noise and visual impacts, then nature-based

tourism upon which the Blue Mountains economy depends will decline.

9 NPWS, January 2009, Greater Blue Mountains World Heritage Area Strategic Plan, Sydney, DECC, page 14.

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4.3 Modelling of aircraft noise has underestimated impact on the World Heritage Area

Measurements of aircraft noise arising from existing airport operations report that at 5,000 feet

aircraft noise is generally higher than the modelled 55dB LAmax for the proposed airport. This

overflight noise level prediction for the Greater Blue Mountains World Heritage Area is an

underestimate10. For example, the Airbus A319, a medium sized aircraft, generates 69.7 dBA at

4,800 feet while climbing and the Airbus A321, another medium sized aircraft, generates 60.2 dBA at

6,000 feet while descending11.

Nats Limited, a company in the United Kingdom provides a range of Lmax data for aircraft. Lmax is a

measure of the loudest part of a flight passing overhead. Nats Limited has published Lmax for a

number of current aircraft at a range of heights. These measurements are all louder than the 55dB

LAmax estimate at 5,000 feet for all aircraft reported other than small regional jets with 50 seats.

Even turbo-prop jets are louder than 55dB LAmax when passing overhead. Twin engine, single aisle

jets at 5,000-6,000 feet generate 60-63 dB Lmax ascending and 57 to 59 dB Lmax descending.

‘Normal’ sized jets, such as twin aisle jets with two engines, generate 64-67 dB L max ascending at

5,000-6,000 feet. The assumed 55dB LAmax for modelled aircraft noise understates noise levels12.

While the draft EIS has questionably modelled aircraft noise levels, according to peer reviewers

Marshall Day Acoustics, the 55dB LAmax level is unlikely to be comparable to typical noise levels

associated with ambient noise sources in the GBMWHA. Marshall Day considers it is generally not

appropriate to assess aircraft noise intrusion by comparing sound pressure levels; the characteristics

of aircraft noise and natural sounds are very different, and are interpreted in very different ways13.

The claim in the draft EIS that the natural background noise within the World Heritage Area is

comparable with 55dB LAmax is also inconsistent with measures of indigenous sound levels in

United States wilderness14. In the US, ambient sound levels in wilderness areas varied considerably

over time and place from 27dBA to 47dBA15. A review of this United States 1992 noise data suggests

that the assumed background noise level for GBMWHA used in the draft EIS is too loud.

In fact, actual noise measurements in Blue Mountains National Park demonstrate that the assumed

background noise for the World Heritage Area is too loud. Daytime background noise levels (LA90,

15min) of the Blue Mountains National Park measured in remote areas but nearby walking tracks is 23

to 27dBA. At the same areas during gusty wind events, background noise levels increased to

45dBA16. These noise levels are not comparable to the stated 55dB LAmax both in loudness and

character.

10

Marshall Day, Op cit, page 18. 11

Nats Limited, 2015 http://www.nats.aero/environment/aircraft-noise/ 12

Inid, http://www.nats.aero/environment/aircraft-noise/representative-aircraft-lmax-data/ 13

Ibid, page 18. 14

US Dept. of Agriculture, Forest Service, July 1992, Report to Congress – Potential Impacts of Aircraft Overflights of National Forest System Wildernesses, Prepared pursuant to Section 5, Public Law 100-91, National Park Overflights Act of 1987, page 2-6. 15

Ibid, page 2-7. 16

Dr Urszula Mizia, July 1994, Proposal for Noise Control Criteria for Aircraft Flying over National Parks and other environmentally sensitive areas. A discussion paper prepared by Dr Urszula Mizia for the FNA Noise Criteria Working Group in relation to aircraft flying over the Blue Mountains National Park.

7

Peer reviewers Marshall Day believe that that ‘the potential for a large number of audible events

below 50 – 55 dB LAmax is therefore considered to represent a potentially significant and

widespread impact within the GBMWHA’17. As modelled aircraft noise levels were understated

when compared with measured noise levels emitted by aircraft leaving from existing airports18,

aircraft noise impacts from overflights from the proposed airport must have a significant impact on

the naturally quiet environment of the World Heritage Area.

4.4 Impacts on World Heritage and inadequate assessment, minimsation and mitigation

The proposed Western Sydney Airport at Badgerys Creek will result in severe and unacceptable noise

impacts on the Greater Blue Mountains World Heritage Area, Burragorang State Conservation Area,

Bents Basin State Conservation Area, the Kanangra-Boyd Wilderness, the Nattai Wilderness, the

southern half of the Wollemi wilderness and the Grose Wilderness.

A revised and re-exhibited draft EIS must use measured levels of natural quiet in Blue Mountains

national parks and adopt airport operation measures and airport design to protect it. Noise

modelling undertaken for the Greater Blue Mountains World Heritage Area did not consider how to

minimise noise impacts. The impacts on park visitors and wildlife were instead incorrectly dismissed

by the draft EIS as not significant.

The failure of the draft EIS to adequately consider the impact on visitors to the Greater Blue

Mountains World Heritage Area, despite impacts on World Heritage values being Controlled Actions

under the Environment Protection and Biodiversity Conservation Act, 1999, is unacceptable. The

World Heritage Area must be provided with adequate protection from aircraft noise, to secure its

peace and quiet.

Under the NSW Wilderness Act 1987, large sections of the Blue Mountains National Parks must be

managed by the NSW National Parks and Wildlife Service to provide for the experience of solitude

and natural quiet. Maintenance of natural quiet in the Blue Mountains National Parks and

wilderness areas is incompatible with frequent 24 hour a day overflights by commercial aircraft that

will arise from the proposed Western Sydney Airport. Peace and solitude will be lost over those

parts of the World Heritage Area subjected to frequent aircraft overflights.

The Federal Department of Infrastructure and Regional Development has a duty of care toward the

World Heritage property and the appropriate use and enjoyment of its declared wilderness areas.

The draft EIS has given no expert consideration of the noise levels of particular flight path designs for

the new airport on the World Heritage Area, its wilderness and other sensitive sites in the Blue

Mountains National Parks and Reserves, such as lookouts and campgrounds.

Given the status of the Blue Mountains as a World Heritage Area, and the potential for intrusive

impacts, further assessment of this sensitive receiver location is warranted. In particular, further

data must be obtained to demonstrate the relative merits of alternative aircraft arrival management

17

Marshall Day Acoustics, 20 Nov 2015, Western Sydney Airport draft EIS, overflight noise peer review, page 19. 18

Ibid, 18.

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procedures which avoid concentration of aircraft movements over the Greater Blue Mountains

World Heritage Area19.

The Department of Infrastructure and Regional Development, as the proponent of the airport, has

an obligation to consider practical measures which may be taken to prevent, control, abate or

mitigate noise pollution under the Civil Aviation Act, 1998 (see s. 9A (2) – performance of functions).

The Department must discharge this responsibility in regard to noise pollution for the proposed

airport before the determination of a re-exhibited draft EIS.

4.5 Need for noise criteria for World Heritage

The Federal Government has legislative and treaty obligations to protect the Greater Blue

Mountains World Heritage Area.

The Greater Blue Mountains World Heritage Area is a refuge from noise for park visitors and should

remain so. The World Heritage Area must be provided with adequate protection of its peace and

quiet by the Department of Infrastructure and Regional Development through the determination

process under the Environment Protection and Biodiversity Conservation Act for this proposed

airport.

The Department must develop noise criteria in relation to the World Heritage Area. The Department

has failed in this duty to mitigate noise as the draft EIS provides only aircraft overflight numbers, and

does not predict aircraft noise levels over the World Heritage Area arising from the proposed

airport. It also appears that the proponent’s consultants did not measure a range of background

noise levels in the World Heritage Area, but instead assumed aircraft noise level of below 50-55dB

LAmax is comparable to ambient background noise levels. This conclusion is wrong. The draft EIS

asserts that aircraft noise does not exceed background noise levels and it is further asserted that

aircraft noise arising from airport traffic would be not significant. These conclusions are also wrong.

In the United States of America the National Parks Service has taken steps to protect natural quiet by

ensuring no aircraft noise is audible in parts of the Grand Canyon National Park. This case provides

important information to assist with the environmental assessment for the proposed airport.

4.6 Impacts of Aircraft on National Parks —

the United States regulator experience in protecting natural quiet

Since the 1990s, the United States Congress commissioned acoustic studies and wilderness user

surveys to find ways to maintain natural quiet in wilderness areas20. A report to Congress dated July

1992 on the Potential Impacts of Aircraft Overflights of National Forest System Wilderness found

that park managers considered aircraft overflights were a problem damaging visitor enjoyment. The

perception of noise in national parks is related to the fact that parks tend to be quieter than urban

settings so the potential for noise pollution by aircraft is thereby much greater. The draft EIS for

Western Sydney Airport makes no such considerations.

In Grand Canyon National Park frequent tourist aircraft overflights were damaging natural quiet.

Regulatory action was taken to address the issue with the passage of the 1987 National Parks

19

Ibid, page 19 20

US Dept. of Agriculture, Forest Service, op. cit.

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Overflights Act (Public Law 100-91) requiring restoration of natural quiet and visitor experience in

Grand Canyon National Park. In February 2011, the National Parks Service released a Draft

Environmental Impact Statement for Special Flight Rules Area in the Vicinity of Grand Canyon

National Park with 120 days for public comment. These flight rules were to further protect natural

quiet of the park. These US rules provide a detailed and relevant regulatory model to control aircraft

overflights in the vicinity of the World Heritage Area and must be applied to the proposed Western

Sydney Airport.

The US Federal Aviation Authority made specific regulations in the Grand Canyon for “flight free”

zones to an altitude of 14,500 feet msl above the park21. Their purpose was to expand the

application of the Special Flight Rules Act in the vicinity of Grand Canyon National Park and increase

the area where no aircraft noise was heard. Aircraft noise mitigation measures were achieved

through specifying flight corridors and defining natural quiet between these corridors.

A re-exhibited draft EIS for the proposed Western Sydney Airport must identify flight free zones to

ensure aircraft noise is not heard in the Greater Blue Mountains World Heritage Area. Prudent and

feasible methods for achieving protection can be developed from the Grand Canyon National Park

case.

The shortcoming identified by the draft EIS peer reviewers regarding the absence of definitive

guidance on assessment techniques for aircraft overflight noise in sensitive wilderness areas22 are

addressed by the US National Parks Service23 draft EIS. The proposal to restore natural quiet in

Grand Canyon National Park is a relevant regulatory model that should be applied in a re-exhibited

draft EIS. There is no excuse for the proponent not to make use of this body of work.

The Colong Foundation recommends that the assessment methodologies applied in the United

States to the regulation of aircraft noise over wilderness must be applied to this environmental

assessment.

The Colong Foundation for Wilderness further requests that all prudent and reasonable alternatives

regarding the regulation of aircraft noise over the Greater Blue Mountains World Heritage Area must

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.

21

Special Federal Aviation Regulation No. 50-2—Special Flight Rules in the Vicinity of the Grand Canyon National Park, AZ 22

Marshall Day Acoustics, 20 Nov 2015, Western Sydney Airport draft EIS, overflight noise peer review, page 19. 23

National Park Service, U.S. Department of the Interior, 2011 Feb., Special Flight Rules Area in the Vicinity of Grand Canyon National Park Actions to Substantially Restore Natural Quiet Draft Environmental Impact Statement, DES 10-60

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5.1 Significant local biodiversity impacts have been poorly compensated

There are four major defects with the biodiversity offset package. The offset areas are not adequate

in size, some are not genuine ecosystems, some are double dipping by counting reserves and do not

consider or protect all threatened species on the Badgerys Creek airport site.

Key on-site biodiversity impacts of the proposed Western Sydney Airport are the loss of 90 ha of

Cumberland Plain Shale Woodlands and Shale Gravel Transition Forest critically endangered

ecological community; and the loss of 120 ha of habitat critical to the survival of the Grey‐headed

Flying‐fox, a vulnerable species24. The offsets proposed to replace these endangered ecological

community and habitat is extremely poor.

The proposed offsets are ‘notional’ and will inadequately compensate for the loss of Cumberland

Plains Woodland. About 300 hectares of Cumberland Plain Woodland are needed to meet

BioBanking and Federal EPBC policy offsets but only 180 hectares are available. In addition to the

significant shortfall in area, no specific offset sites have been identified and the actual sites

purchased may be different from the ones assessed. The proposed offsets are another ‘proof of

concept’ program in the draft EIS that has major defects.

While the Colong Foundation for Wilderness does not support the concept of biodiversity offsets,

the Department of Infrastructure and Regional Development must take the steps necessary to

ensure sufficient offset sites are identified before seeking approval of Stage One of the proposed

airport to ensure viability of these compensation measures. It has not done so.

There are also serious defects with the proposed offset sites. For example, the proposed Ropes

Creek and South Creek offset sites are not remnant woodland communities. These sites are areas of

pasture that have been planted with lines of trees. Such garden landscapes are not endangered

ecological plant communities. Such plantings are unsuitable to propose as offsets for the loss of high

quality remnant Cumberland Plains Woodland. Further, it is not acceptable to propose 340 hectares

of existing reserves as part of the identified offset areas. Protected areas must not be available for

biodiversity offsets. Protected land offsets would be a redundant compensation arrangement that

will not improve conservation outcomes. It is a dud deal and creates an expectation in land

managers that reserves can find additional funds for management by clearing endangered ecological

communities. The Colong Foundation opposes biodiversity offsets partly because they can

accelerate the loss of threatened ecosystems and wildlife while creating the opposite impression.

There are also no offsets proposed for the vine Marsdenia viridiflora subsp. viridiflora. There should

be.

5.2 Impacts of aircraft noise on wildlife

The impact of aircraft noise on wildlife has been little studied. Noise pollution can affect plant

pollination and disrupt seed dispersal by birds25. In the absence of full scientific knowledge, the

Grand Canyon National Park draft EIS examined areas where aircraft noise would be audible to

24

EMM Consulting, 19 Nov 2015, Western Sydney Airport EIS, Biodiversity Assessment Peer Review, page E.2. 25

Francis, C.D. et. al. 12 April 2012, Noise pollution alters ecological services: enhanced pollination and disrupted seed dispersal, in Proceedings of the Royal Society.

11

humans and examined the range of wildlife that could hear aircraft noise within those areas26.

Species of ‘special status’, such as the peregrine falcon and California condor, were considered

separately.

Using human impacts as a surrogate for wildlife impacts in the absence of full scientific knowledge

enables these impacts to be brought into consideration in the environmental assessment of aircraft

overflights. A re-exhibited draft EIS must adopt this approach so as to protect wildlife from aircraft

noise.

6. Summary list of recommendations

The proposed airport concept plan must be refused consent as it lacks the necessary detail

for approval and only examines the first five years of airport operations.

Badgerys Creek is not an appropriate location for an airport due to the generation of

unacceptable levels of air pollution and must be refused consent.

The Federal Government should examine a Melbourne-Canberra-Sydney-Brisbane very fast

train network as an alternative to a second Sydney Airport, as it would generate far fewer

greenhouse gases, be more energy efficient and more consistent with the development of a

low carbon economy.

The Federal Government must defer further consideration of this controversial proposal to

avoid wasted expenditure on unnecessary infrastructure.

Options for flight paths, operating modes and orientation of the runways must be

considered in detail before Stage One of the proposed Western Sydney Airport is

determined by re-exhibiting a revised draft EIS. The consideration of options must include a

preferred option.

Air pollution modelling must be redone for 185,000 aircraft movements/year and 125,000

vehicle movements/day, so as to consider an appropriate ‘worst case scenario’ for the

proposed Stage One airport.

The redone air pollution modelling must be peer reviewed to ensure the revised modelling

predictions are realistic.

The Federal Government must take the steps necessary to develop new Australian noise

policy and regulation to protect sensitive receptors from overflight noise and then apply

these to a revised draft EIS for the proposed airport.

The Department of Infrastructure and Regional Development, as the proponent of the

airport, must develop ways to prevent, control, abate or mitigate noise pollution under the

Civil Aviation Act, 1998 (see s. 9A (2) – performance of functions) before the proposed

airport is determined under the EPBC Act.

26

National Park Service, U.S. Department of the Interior, 2011 Feb., Special Flight Rules Area in the Vicinity of Grand Canyon National Park Actions to Substantially Restore Natural Quiet Draft Environmental Impact Statement, DES 10-60, page 390 to 444.

12

The Federal Government must take the steps necessary to develop noise criteria and a

scientifically-based regulatory methodology to protect the natural quiet of the Greater Blue

Mountains World Heritage Area before this proposed airport is determined under the EPBC

Act – the adopted scientifically-based methodology applied to draft EIS must be based upon

that applied in the United States to the regulation of aircraft noise over wilderness.

A re-exhibited draft EIS must use measured levels of natural quiet in Blue Mountains

national parks and adopt measures of airport operations and airport design to protect it.

All prudent and reasonable alternatives regarding the regulation of aircraft noise over the

Greater Blue Mountains World Heritage Area must be examined in relation to the proposed

airport in a revised draft EIS.

A revised and re-exhibited draft environmental impact statement must consider and make

an assessment of aircraft noise impacts in relation to proposed flight path options on the

World Heritage property.

Flight rules must be developed and applied to the proposed Western Sydney Airport to

control aircraft overflights in the vicinity of the World Heritage Area to preserve the

property’s natural quiet.

When examining measures to protect natural quiet, data must be obtained to demonstrate

the relative merits of alternative aircraft arrival management procedures which avoid

concentration of aircraft movements over the Greater Blue Mountains World Heritage Area.

A re-exhibited draft EIS for proposed Western Sydney Airport must have flight rules that

identify flight free zones to ensure aircraft noise is not heard in the Greater Blue Mountains

World Heritage Area.

The impact, including economic impact, of aircraft noise associated with the proposed

Western Sydney Airport on nature-based tourism in the Blue Mountains must be assessed in

a re-exhibited draft EIS and action taken to mitigate this significant impact.

The Department of Infrastructure and Regional Development must ensure sufficient

biodiversity offset sites are available before seeking approval of Stage One of the proposed

airport to ensure viability of these compensation measures.

Protected areas, such as reserves, and areas with planted trees must not be considered in

biodiversity offset processes.

Thank you for the opportunity to comment.

Yours sincerely,

Keith Muir

Director

The Colong Foundation for Wilderness Ltd