This was not a Stakeholder Engagement Panel. ASA were not asking various stakeholders including FPF, Noosa Council, State Members, SCC or SCA for their input nor was there any discussion about decisions yet to be made. This was a presentation of information where stakeholders had the opportunity to ask some questions about the information being presented. The meeting was time constrained which severely limited the opportunity for questions.
“Alternative flight paths submitted by community not considered as they were outside approved EIS – but ASA never disclosed this…”
PLEASE NOTE: the following information is based on handwritten notes without access to presentations made by Sunshine Coast Council (SCC) and ASA. FPF have been advised that both presentations will be provided. The meeting was recorded and minutes are to be supplied. Date TBA.
It is unfortunate that a late change to the agenda saw a substantial portion of the meeting taken over by a long presentation from SCC. Ross Ullman made an over long presentation that did not deal with the matter at hand i.e. ASA’s handling and consideration of feedback and their proposed responses. It was based around the EIS and AEIS and focused on what was done, and when, in terms of community consultation during that period. FPF asked SCC what their measure of success was in defining the outcome of the community consultation. Their disappointing reply was that SCC’s measure of success was they had met all regulatory requirements, rather than the obvious – that communities were well informed and engaged post consultation.
Prior to the EIS publication, SCC said they outsourced a letterbox drop to households from Yaroomba to Castaways Beach. A letterbox drop was not the ‘Gold Standard’ in notifying residents according to SCC. However, FPF is of the view that a letterbox drop to residents is indeed a ‘Gold Standard’ given the awareness that has been raised by FPF through letterbox drops in the past weeks which has seen hundreds of residents made newly aware, attend meetings and make around 4300 submissions through the feedback process.
This would not have occurred if it had not been for these letterbox drops, according to most residents who were unaware of the opportunity to attend ‘consultation sessions’ and make submissions until they received the FPF flyers.
The main unknown that was made public at the meeting was that at least three alternative flight path concepts were considered in 2009 and then dismissed as unsuitable. SCC were unable, or would not, confirm whether there was a formal concept evaluation document prepared for consideration prior to selection of the preferred EIS concept, or whether there was a documented evaluation of the strengths and weaknesses of alternatives in terms of impacts on the environment, as well as flight path safety. ASA have advised that a Concept Options Document would have been created. Why were residents not consulted on these flight path options? The three options were disclosed at the meeting:
- Showed a coastal path that leaves runway 31 crossing the coast line south of Peregian Beach, possibly over Coolum, at a height of 1,880ft.
- Showed a coastal path that leaves runway 31 crossing the coast line over Peregian Springs and Peregian Beach at a height of 2,400ft.
- Showed both a coastal flight path AND a western approach that came close to Valdora, south near Kiels Mountain and crossed over Mountain Creek.
SCC advised that two meetings were held with ASA & CASA to discuss the proposed EIS concept. ASA confirmed that these meetings did not include any detailed assessments by them of the alternate concept designs in order to determine whether the EIS concept was assessed to meet least environmental and community impact criteria. SCC couldn’t answer how far designs were assessed before they were dismissed, however – a request for this information was put on notice. Again, why were residents not consulted at this stage?
FPF asked SCC about the noise contours and how they were modelled on the 737-700 yet no contours were modelled on Code E aircraft which NATS Aero depict as being louder. It was confusing as SCC were stating that they would in fact be quieter. FPF also questioned whether the online noise tool had been updated with the newly proposed flight path track lines prior to ASA’s consultation regarding proposed changes. SCC eventually confirmed that they had not. Therefore, everyone in the community who used the tool during the consultation period to see if noise levels over their areas might change, were being misled. SCC stated that the tool was still correct because the flight path changes that were made fell within the ‘shaded areas of blue and yellow swathe’, so there was no difference in noise levels, in their opinion. This is clearly fallacious. It is very simple, if the flight paths have changed, so have the noise impacts. We have been advised by ASA that the new flight path coordinates had been sent to SCC prior to the consultation period, so this is inexcusable.
ASA presented the complexities of airspace management considerations and design including; safety, fly-ability, airspace management complexity, navigation, aircraft types, other airports and aerodromes, local airspace conditions, weather conditions, tactical sequencing, range of suitably qualified operators, aircraft capabilities, level of observation (communications/air traffic control), vertical separation, RNAV, RNP, landings, approach and departure procedures. Much of this information was presented on a scale that did not correlate with the specific characteristics and issues that apply to the Sunshine Coast region and was at a very high and relatively uninformative level. FPF has requested a follow-on meeting with ASA where more detailed examination of issues can occur.
ASA advised that they were constrained to examine fight path options within the corridors included in the EIS. The ‘blue and yellow swathe’ was shown in the EIS and also in some of the fact sheets presented at consultation sessions. ASA considered the concept design to be a good design. But most importantly, ASA have acknowledged that they did not undertake any thorough assessments to determine that the EIS concept was one that delivered the least environmental and community impact.
ASA targeted their consultation to the northern most communities, as the path changes there varied the most and they considered that the other communities were consulted about the flight paths during the EIS public comment period. Because residents outside of ASA’s ‘consulted areas’ had a lot to say, ASA expanded the consultation to include the feedback from other areas under the flight paths. It seems ASA had not even considered the fact that areas closer to the runway, where flight altitudes were lowest, might have had at least an equal right to be targeted for consultation.
FPF asked ASA if it was their responsibility to consult all newly affected areas underneath flight paths. ASA agreed. FPF then asked at what point did ASA engage with the newly affected areas outside of the ‘consulted areas’ as defined by their summary reports. ASA considered these areas were consulted during the EIS. FPF asked if ASA reviewed the EIS to ensure these newly affected areas were consulted properly. The answer was no, ASA did not review the EIS, instead accepting the QLD Coordinator General’s approval of the EIS as a signal that the areas had been consulted.
Some alternative flight paths that were submitted during the community consultation period in 2019 were displayed on screen and indicated a number of designs as were presented by pilots at public meetings and online through feedback process, most of which included a western approach. All flight paths outside of the EIS “swathe” were effectively dismissed for the purposes of ASA’s current flight path approvals process. ASA also commented that some would also have been dismissed for ‘operational reasons’ if they had been fully investigated.
Issues with other controlled airspace/air traffic routes were cited often as a reason for not considering a western or southerly approach. One design which depicted a flight path extending from the primary flight route high over the North Shore may be considered for future change despite falling outside the EIS corridor. It is also interesting to note that some of the suggested changes by ASA do fall outside the EIS “swathe”, so what is the actual criteria? FPF suggests that this is simply for administrative convenience and efficiency as there is a clear objective of avoiding any additional environmental and community impact assessment effort.
FPF has many unanswered questions about this rationale and we look forward to discussing this in more detail with ASA next week, including questions on notice previously supplied and many more which will be submitted.
In a diversion to proceedings, Ted O’Brien insisted that FPF disclose the nature of the attending executive’s personal submissions made to the feedback process. FPF challenged Mr O’Brien on the relevance of such information to proceedings citing that FPF were in attendance to hear information of relevance and importance to the communities we represent and that time would be better spent listening to what ASA had to say about the proposed final designs in order that we could take this information back to the community. FPF is unsure as to why this issue was of such importance to Mr O’Brien.
For the record, Mayor Tony Wellington made a statement supporting the community and FPF’s request for a Stakeholder Engagement Panel and sought to have a motion to this effect agreed. ASA advised they would consider the request. Thank you to Mayor Wellington for supporting the community.
It appears from ASA’s presentation that the community’s contributions, submissions and efforts to improve the flight path designs have not led to any material changes. This will only become clear when ASA release their report on how community issues have been considered. This is expected to occur on Monday. At this stage flight path designs are still only proposed and have not been made final. FPF had a useful discussion with ASA during the break and again after the close of the meeting and we anticipate productive discussions with them next week, without the involvement of third-party distractions. ASA are constraining themselves to the EIS concepts, however FPF is of the view that there is no mandated requirement to do so.
At the end of the meeting Ted O’Brien, Sunshine Coast Council, Noosa Council and Airservices made their closing statements. As stakeholders prepared to depart, FPF interjected asking if the community could also make a closing statement. FPF acknowledged that ASA have made opportunities for FPF to be informed prior to report releases in recent weeks.
FPF also asked ASA to ensure that they would not be driven by project deadlines prior to making their final decisions and to make their decisions based on the fact that the community were properly consulted and that process has been followed correctly, so that they won’t have to add Sunshine Coast Airport to their list of failed consultations.
ASA are working towards a lodgement date of 29 July. Their Airspace Change Proposal (ACP) will be submitted to CASA on this date. CASA then have 70 days to consider the ACP. The Office of Airspace Regulation will make a determination about whether to accept the ACP and give a final approval for the flight paths.
The ANO investigation is continuing, but this will not stop the process.
FPF will be briefing legal advisors again this week.
WHAT CAN YOU DO?
SUBMISSIONS TO ASA
Airservices is still not listening. Please continue to make submissions to ASA and most importantly – cc in the ANO – this is essential.
LETTERS TO THE EDITOR
The Australian: firstname.lastname@example.org
The Courier Mail: email@example.com
Sunshine Coast Daily: https://www.sunshinecoastdaily.com.au/contact/feedback/ (online)
Brisbane Times: firstname.lastname@example.org
Noosa News: email@example.com
SUBMISSIONS TO GOVERNMENT
Hon Scott Morrison (Prime Minister) firstname.lastname@example.org
Anthony Albanese (Opposition Leader) A.Albanese.MP@aph.gov.au
Hon Michael McCormack (Deputy PM) email@example.com
Hon Sussan Ley (Minister for Environment) Sussan.Ley.MP@aph.qld.gov.au
Hon Leeanne Enoch (State Minister Environment) firstname.lastname@example.org
Fiona Simpson (State MP Maroochydore) Maroochydore@parliament.qld.gov.au
Andrew Wallace (Federal MP for Fisher): email@example.com
Llew O’Brien (Federal MP Wide Bay): Llew.OBrien.MP@aph.gov.au
Dan Purdie (State MP for Ninderry) firstname.lastname@example.org
Sandy Bolton (State MP for Noosa) email@example.com
Please keep a copy of any correspondence you send to ASA, SCC, NSC, MP’s or other representatives – it will be useful in the future if we are able to access a wealth of communications to support further action.