SUBMISSION SUPPLIED VIA A CONCERNED RESIDENT
Introduction
 
I wish to lodge a formal submission against the  proposed  flight paths associated with the new runway at Sunshine Coast Airport.
The EIS prepared by Sunshine Coast Council and the flight paths designed and put forward by Sunshine Coast Council and/or Air Services Australia including in response to the Coordinator Generals Terms of Reference document is flawed on many fronts, and I ask you to receive and note in full detail the items raised in this submission. This is an important point – because as you will read – past submissions in relation to the EIS through the 2014 consultation process have been ‘watered down’ and ‘reworded’ by the project proponent and authors of the AEIS document, which purports to respond to the submissions received. There can be no other explanation for this other than to blindly and with bias support its own assertions and agenda at the detriment of large sections of the community to the north of the airport project.
The opposition to the proposed flight paths is now spread right throughout the Sunshine Coast and Noosa Communities. Calls for a review of the EIS and consultation process have been backed by many local community groups with numbers in the thousands. The calls have been supported by unanimous resolution of Noosa Shire Council and backed by Federal Members Llew and Ted O’Brien as well as State Member MP Sandy Bolton.
The process is so flawed it must be called in for independent review. All I ask is for natural justice in relation to this matter.
Air Services Australia in the past have been the subject of a scathing report by the Airport Noise Ombudsman in relation to the Hobart Airport, and many of the flaws identified in that report apply directly to the processes undertaken for both the EIS and Flights Path design for the new Sunshine Coast Airport runway and the current consultation process being undertaken by Air Services Australia. In light of this report it is little wonder that affected communities have little confidence in Air Services Australia to undertake open, transparent and meaningful assessment of the proposed flight paths. However I hope this will not prove to the case in this instance. I would like to attach a copy of the report as part of the submission but the online form does not allow – but I would hope you have taken the time to read the report, its findings and it’s recommendations. I sincerely hope that as an office of the federal government you will apply those findings to the matter at hand.
Thought the consultation process Air Services Australia and the Sunshine Coast Council have continually pointed blame and responsibility to the other party to the extent that the majority of the concerned community are confused about who the actual responsibility for the project and its impacts rest with. The majority of residents in affected areas do not understand the current ‘consultation’ process, or understand or are able to identify who is responsible for the ultimate approval of the proposed flight paths put forward in the EIS.
Ultimately however Air Services Australia appear to be the government authority with the responsibility to approve any changes to flight paths, and as it is ASA who are currently conducting this ‘consultation’ and to whom submissions are required to be directed.
Air Services throughout this process have continually failed to meet the standards set out in its own principles and standards of service set out in its own document “Air Services Commitment to Aircraft Noise Management”.
A request for an extension to the current consultation periodwas submitted to ASA on 4 April 2019, which was rejected by ASA on 8 April 2019. Given the enormous amount of information you expect the community to digest in just 30 days – and this in the context of the inconsistent, contradictory and false and misleading information previously provided throughout the EIS documentation – this request for a 1 month extension could hardly be deemed unreasonable. Despite this, right up until less than two days before the deadline for submissions, requests for an extension of time for submissions continues to be rejected – regardless of the fact that it has been requested by Noosa Shire Council (by unanimous resolution), Federal MP’s Llew and Ted O’Brien, State MP Sandy Bolton, backed in a petition signed by more than 1300 concerned residents (tabled at Noosa Shire Council Ordinary Meeting 18 April 2019) and with the support of all our regional newspapers including the Sunshine Coast Daily, Noosa News.
What is absolutely clear is that Air Services Australia current consultation in relation to proposed flight paths has been grossly inadequate – and the representatives on the front line have been unable to demonstrate even basic understanding of the affected areas (this includes both directly and indirectly affected by the ‘project’), the contents of the EIS, or give any meaningful advice in relation to the approval process.
The inadequacy of ‘one on one’ consultation was raised with Sunshine Coast Council and the response from the Project Director, Sunshine Coast Expansion Project (Ross Ullman) was as follows:
“we have tried on several occasions to convince AA that the forum format is what is required together with additional drop-in sessions …… ASA have steadfastly refused to partake in what they have called “town hall “ meetings, much to our frustration.” 
 
And this position of Air Services Australia as you are well aware has been maintained throughout the consultation process. Most people I talk to do not even consider this is a consultation process, merely Air Services Australia advising an already determined outcome. There is a very apparent lack of concern by Air services Australia to conduct meaningful and equitable engagement with the community in relation to the implementation of the proposed flight path changes. And this flies in the face of Air Services own stated protocols:
  1. “Airservices adopts a wide range of communication and consultation tools and processes based on individual situations and operational needs. Our consultation may range from one-way communication through to more comprehensive, interactive discussions and participation by stakeholders in the project planning and design process.”
You would only have to consider for a moment the rising swell of community unrest and the shear weight of numbers of people now protesting against the entire process that something is clearly amiss. The process has failed the community and is a damning reflection on the standards of Air Services Australia. 
 
Rest assured that all of the issues raised in this submission as well as the combined submissions of the entire community have been copied through to the Aircraft Noise Ombudsman for consideration as well as State and Federal MP’s, The Coordinator Generals Office,QLD Department of Environment and Science (Wetlands Team and Cultural and Heritage) , Department of Environment and Energy and others.
 
An overarching principle for myself as well as many others is the preservation of the pristine and as yet untouched majesty of Lake Weyba – a declared wetland of National Importance and and rich ecology supporting many endangered and threatened flora and fauna species – as well as being of very high cultural significance to the Kabi Kabi First Nations People. Yet despite this no mention of the Lake is made in the EIS, and nor are the impacts of the proposed flight paths over the lake considered in the slightest. Just a simple visit to the place would make Air Services Australia understand the importance of its preservation for future generations in its current state.
 
Of equal concern is the ‘oversight’ and understatement of the social and environmental (noise) impacts of the proposed flight paths over quiet rural areas with very low background noise that have never been subject to overflights by aircraft in the past let alone RPT jet aircraft. Impacts north of Coolum Beach have been inadequately addressed in terms of increase in expected noise levels.
 
I think it is time Air Services Australia takes a long hard look at who it purports to be as opposed to who it really is as an organisation. In this instance it would appear you have the opportunity as a government organisation representing your community to set things right – and I encourage you to take the opportunity to do so.
 
 

1. Non compliance with the Coordinator Generals Terms of reference Document – Environmental and Cultural Issues

 
The following statements are taken directly form Sunshine Coast Councils Lake Weyba Foreshore Plan which is readily available on their website:
Lake Weyba is popular destination for locals and visitors who enjoy the area for its natural attributes, its pristine and tranquil setting.
It is enjoyed on a multitude of levels from passive nature based recreation to access for water based recreation.
Values:
The following values, identified during community engagement, are to guide decision making for the Landscape Plan. They focus on the qualities of the Lake Weyba Foreshore:
1. A place of tranquility
2. A place of observation and education
3. A place that provides a deepened connection with nature
4. An ecologically restored, resilient and connected landscape 5. A place of passive recreation
6. A place of water based recreation

THE LAKE
Lake Weyba is a shallow tidal lake surrounded by a variety of vege- tation communities that includes mangroves, salt-pans and open for- est. The shorelines are dominated by melaleuca wetlands. The lake adjoins sections of the Noosa National Park along its eastern and part of its southern shores, as well as pockets of national park on the western catchment area of the lake. Land fronting the western sec- tion contains rural holdings as well as a rural residential development which includes a park with some retained vegetation. Also located on the northern shoreline is Noosa Springs which is an extensive urban residential development and golf course. With the variety of natural values Lake Weyba is recognised as a nationally important wetland.
Access to the foreshore is along Lake Weyba Drive with informal ve- hicle access points at the end of Charlotte Drive / Lake Weyba Drive, and at the northern end of Lake Weyba Drive.
The shallowness of the lake and creeks limits the ability of medium sized craft to venture onto its waters. The lake is therefore used mostly by shallow-draft boats such as catamarans, kayaks, canoes, kite surfers, paddle boards and small boats. Lake Weyba forms part of the Noosa River Marine Zone. The foreshore has limited facilities with no formal boat accesses to the lake. An existing natural trail me- anders along the foreshore and is used by riders and walkers.

CULTURAL HERITAGE ASSESSMENT
The traditional owners of the land are the Kabi Kabi first nations people (Kabi Kabi). The Kabi Kabi were engaged to undertake a site survey and assessment of the impact footprint. Specifically, the scope of the project was to:
• Determine the presence of any cultural heritage objects, significant Aboriginal areas and/or significant Aboriginal values within the study area; and
• Identify management and mitigation options in consultation with the Kabi Kabi People.
Kabi Kabi People consider Lake Weyba to have both traditional and historic significance and it continues to have high cultural values
for them. There are registered sites around Lake Weyba including
a bora ring, burials, scarred trees, a fish trap, artefact scatters and numerous shell middens. These sites reflect the cultural significance of Lake Weyba. Lake Weyba would have been a rich resource area, furnishing an abundant supply of fish, crabs, rays, oysters and other shell fish and birds for Aboriginal people.
When protecting cultural heritage values, a number of management options are available. These include:
1. Avoidance 2. Mitigation 3. Monitoring
The Kabi Kabi accept that some development around the lake is required, but their preference is for it to be limited and sympathetic to the landscape. The Kabi Kabi position is that any development be “as much as necessary and as little as possible”.
Ultimately, the most important factor for the successful management of the cultural heritage process remains ongoing consultation. Coun- cil will continue to consult with the Kabi Kabi People on the man- agement of cultural heritage. This will be especially important in the development of park infrastructure.

THE ABOVE STATEMENT ARE THOSE OF SUNSHINE COAST COUNCIL ITSELF, NOT JUST A VOCAL LOCAL COMMUNITY ALTHOUGH I AGREE AND SUPPORT THEM IN FULL.

I submit that the Coordinator Generals Terms of reference clearly requires consideration of such places in the EIS. No consideration has been given to the stated environmental or cultural significance of this place in the EIS – a document produced by the same council that prepared the above statements in relation to the lake and its inherent values. 

An independent EIS is required to be completed for Lake Weyba (DIWA) as well as impacts on Noosa River Wetlands, Noosa National Park and Noosa Biosphere – Lake Weyba is located within all of the aforementioned.

I implore you to consider the ramifications of the inconsistencies Councils position in the EIS AND THE ABOVE PUBLIC DOCUMENT. 


How can SCRC acknowledge the environmental and cultural values in the Lake Weyba Foreshore Plan yet entirely ignore the direct and indirect impacts of the airport project in the EIS as required clearly by section 5.2.1 of the Coordinator Generals Terms of Reference – which states: (commentary in brackets)
 
“Description of environmental values – Identify, on a map of suitable scale, environmentally sensitive areas which may be directly or indirectly impacted by the projectThis should include areas classified as having national, state, regional or local biodiversity significance, or flagged as important for their integrated biodiversity values. (Note  -no such map is provided in the EIS which identifies Lake Weyba and surrounds) Refer to both Queensland and Commonwealth legislation and policies on threatened species and ecological communities.
 
Areas regarded as sensitive with respect to flora and fauna have one or more of the following features and should be identified and mapped:
  •   important habitats of species listed under the NC Act and/or the EPBC Act as presumed extinct, endangered, vulnerable or rare (refer Australian Government report on Lake Weyba DIWA )
  •   regional ecosystems listed as ‘endangered’ or ‘of concern’ under state legislation, and/or ecosystems listed as presumed extinct, endangered or vulnerable under the EPBC Act – (Note Australian Government report on Lake Weyba DIWA)
  •   good representative examples of remnant regional ecosystems or regional ecosystems that are described as having ‘medium’ or ‘low’ representation in the protected area estate as defined in the Regional Ecosystem Description Database (REDD) available at www.derm.qld.gov.au
  •   sites listed under international treaties such as Ramsar wetlands, World Heritage areas, JAMBA, CAMBA and ROKAMBA
  •   sites containing near-threatened or bio-regionally significant species or essential, viable habitat for near-threatened or bio-regionally significant species (Note Australian Government report on Lake Weyba DIWA)
  •   sites in, or adjacent to, areas containing important resting, feeding or breeding sites for migratory species of conservation concern listed under the Convention of Migratory Species of Wild Animals, and/or bilateral agreements between Australia and other countries
  •   sites adjacent to nesting beaches, feeding, resting or calving areas of species of special interest (e.g. marine turtles, dugongs and cetaceans)
  •   sites containing common species that represent a distributional limit and are of scientific value or that contain feeding, breeding, resting areas for populations of echidna, koala, platypus and other species of special cultural significance
  •   sites of high biodiversity that are of a suitable size or with connectivity to corridors/protected areas to ensure survival in the longer term; such land may contain:
    • –  natural vegetation in good condition or other habitat in good condition (e.g. wetlands)
    • –  degraded vegetation or other habitats that still support high levels of biodiversity or act as an important corridor for maintaining high levels of biodiversity in the area
  •   a site containing other special ecological values (e.g. high habitat diversity and areas of high endemism)
  •   ecosystems that provide important ecological functions such as:
    • –  wetlands of national, state and regional significance
    • –  coral reefs
    • –  riparian vegetation
    • –  important buffer to a protected area or important habitat corridor between areas 
      • declared fish habitat areas and sites containing protected marine plants under the Fisheries Act
      •   sites of palaeontologic significance such as fossil sites
      •   sites of geomorphological significance, such as lava tubes or karst
      •   areas of environmental significance as defined by the Queensland Coastal Plan (Department of Environment and Resource Management 2011c)
      •   protected areas that have been proclaimed under the NC Act and Marine Parks Act 2004 (Qld) or are under consideration for proclamation
      •   areas of major interest, or critical habitat declared under the NC Act or high nature conservation value areas or areas vulnerable to land degradation under the VM Act.Areas of special sensitivity include the marine environment and wetlands, wildlife breeding or roosting areas, any significant habitat or relevant bird flight paths for migratory species, bat roosting and breeding caves including existing structures such as adits and shafts, and habitat of threatened plants, animals and communities. Potential impacts and mitigation measures
        1. Discuss the impact of the project on species, communities and habitats of local, regional or national significance in sensitive environmental areas as identified above. Include human impacts and the control of any domestic animals introduced to the area. “
      The above is just one of may sections of the Terms of reference document which clearly would require assessment of impacts of the project on Lake Weyba. The Lake meets so many of the above criteria – yet it has been consistently, and it would seem deliberately, overlooked. 
       
      The EIS is contradictory, false and misleading and does not conform with the CG’s TOR document for either the consideration of environmental or cultural values. The ommission of reference to impacts of the project on Lake Weyba and surrounds is inconceivable oversight and must be corrected. The TOR also requires reference to the Coastal Management Plan which is a document also referenced in the Australian Government Report on the Lake as a Declared Wetland of National Importance (DIWA) integral to its protection and reservation.
 
The adverse impacts of noise on wildlife is well enough documented through simple literature review, but somewhat lacking in Australia. However I would point out the principles of the Environment Protection Biodiversity and Conservation Act at 3A (b) “if there are threats of serious or irreversible environmental damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation;”
 
In fact the whole objective and principles of the EPBC Act are intended to protect areas such as Lake Weyba from the impacts of projects such as this. The impacts of aircraft (both Australian and non Australian) is clearly covered by the EPBC Act at Section
 
The EIS has failed in its obligations to comply with the Coordinator Generals Terms of Reference and is incomplete in the information it provides to allow fair assessment of the project impacts. 
 
Concerns for The Lake and Its environs were made during the EIS consultation period in 2014 by “friends of Lake Weyba’ a group representing around 350 members. Their submission (made validly) was as follows:
 

“ENVIRONMENTAL IMPACT 

  • Lake Weyba is a shallow salt water tidal lake, an integral part of the Noosa River system.  Lake Weyba, Weyba Creek and the Noosa River system are vital components in maintaining the health and well being of the local and wider region.   


Water quality

  • By placing a flight path directly over ecologically sensitive Lake Weyba and the catchment creeks there is a risk of contamination of these waterways from aircraft emissions.
  •  Lake Weyba is very shallow and has minimal tidal influence, therefore any small change to the existing balance of water quality has the potential for significant and long lasting ramifications.
  • Changes in water quality of Lake Weyba would cause significant consequences downstream in the creeks and river.
Flora
  • The proposed flight would place pressure on this fragile ecosystem including threatened foreshore mangrove forests and sea grass beds.
  • Lake Weyba is a “Wetland of National Importance” and is part of the Maroochy-Noosa Wallum Corridor which contains endangered and of concern species of international, national, and locally significance.  
  • The National park areas abutting the foreshore currently support a diverse range of plant eco-systems including wallum heath, sedge swamp and old growth eucalypt forest, and aircraft emissions could severely compromise biodiversity.
Fauna/Marine Habitat
    • Lake Weyba provides habitat for endangered frogs and other species including the wallum sedge frog and the endangered ground parrot.
    • The area is populated by a vast array of waterbirds, many migratory.  It is recognised as a nesting ground for the threatened jabiru. 
    • It is a recognised fish breeding and nursery habitat for endangered species as well as commercially impoprtant species.
Dredging
  • The dredging required for the project will have adverse impacts on Moreton Bay as it is a highly destructive process and of particular concern is the impact on the seagrass beds.  The fill which is proposed to be pumped on shore is likely to cause inflow of significant amounts of salt water into the Maroochy River.

SOCIAL IMPACT
  • The proposed flight path is completely out of keeping with existing rural, semi-rural residential and low density coastal areas.  It would force noise and visual impacts onto what is currently a quiet and peaceful environment.
  • Lake Weyba is one of the few local locations where Sunshine Coast residents can readily access an area that is largely visually as it was before European occupation.  The lake is used by canoeists, bush walkers, fishermen, windsurfers and kite-boarders.  Users enjoy a natural panorama devoid of houses, traffic, lights or other signs of urban existence.  Aeroplanes passing overhead, regardless of altitude or decibel output will impact significantly on the peaceful enjoyment and amenity of this natural asset.
  • Residents of the Lake Weyba catchment area which includes Weyba Downs, Noosaville, Noosa Springs, Marcus Beach, Castaways Beach, and Peregian Beach purchased their properties, after completing due diligence enquiries, secure in the knowledge that there was no existing or proposed commercial aircraft flight paths affecting the amenity of their property.
  • The proposed flight path/s adversely impact residential and rural areas not previously within an aircraft corridor whilst benefiting residential and tourist areas currently within an aircraft corridor, whose owners are fully conversant with this fact prior to purchasing the property.


ECONOMIC VIABILITY

  • Is another international airport at the Sunshine Coast needed, when Brisbane airport is less than 100 kilometres away?  Others are questioning the economic viability of this business proposal especially when the Virgin Airlines CEO has already indicated that Virgin has no identified need to increase its services to the region.
  • The current economic performance of the Sunshine Coast Airport is less than reassuring with an identified short fall of $10.4 million in operating expenses against budget from 2006/7 to 2012/13.  Ratepayers are likely to have to fund any shortfall and a far more solid economic and financial analysis provided on this preferred option is required.
  • The Applicant Council has failed to publish the basis for its projections in terms of future passenger and aircraft movements and has relied solely on its own strategic planning documents without doing a business model or costs benefit analysis which takes into account competition from the other 3 international airports in South East Queensland.
  • The option to widen and/or extend the existing runway would be much lower cost and should be investigated fully. 

Our organisation does not believe that the EIS adequately addresses the effect aircraft will have on this ecologically sensitive waterway or the social impacts on residents and recreational users of Lake Weyba and it’s catchment area.  Further EIS does not adequately assess the economic viability of the project and there is a real possibility economic liability will be passed onto already pressured ratepayers.  Further the EIS does not adequately demonstrate the need for the Sunshine Coast Council’s preferred option ie the realignment and expansion of the runway, nor does it adequately assess the alternative option to simply widen and/or extend the existing runway.  The EIS is flawed as the Sunshine Coast Council has failed to properly cost the alternatives, assess the negative impacts of the proposals and consult the community regarding its proposals.

 

We call on Queensland’s Coordinator General and the Australian Government Department of Environment to reject this development proposal.”

 
NO MENTION OF THE MATTERS RAISED IN THIS SUBMISSION WERE INCLUDED IN THE AEIS DOCUMENT WHICH PROVIDES A SUMMARY OF SUBMISSIONS RECEIVED AND THE RESPONSES OF THE PROPONENT – AS SUBMITTED TO THE COORDINATOR GENERAL FOR ASSESSMENT OF THE EIS. WHY HAVE THE IMPACTS OF THE PROJECT ON  LAKE WEYBA  BEEN CONSISTENTLY IGNORED AND OVERLOOKED THROUGHOUT THE ENTIRE PROCESS?
  1. Initial environmental assessment screening is used to determine whether a targeted environmental impact assessment is required. The process for this is set out in the National Operating Standard, with the stated purpose being to identify and assess potential impacts on the environment (including noise, emissions, wildlife, cultural heritage and impacts to humans) and to inform the accountable Airservices manager about levels of environmental risk associated with the proposal, as a basis for the manager’s decision making. 
  2. The Environmental Protection and Biodiversity Conservation Act 1999 (EPBC Act) is Commonwealth legislation to protect and manage important flora, fauna, ecological communities and heritage places defined in the EPBC Act as matters of national environmental significance. The proponent of a change must determine if any proposed action (called a ‘proposal’ or ‘project’) has the potential to have a significant impact on a matter of national environmental significance. If it might, the proponent must seek to have the action assessed under the EPBC Act by referring the project to the federal Department for the Environment. This referral is then released to the public, as well as to the relevant State, Territory and Commonwealth Ministers, for comment on whether the project is likely to have a significant impact on matters of national environmental significance. The Commonwealth Minister for the Environment will then decide whether the likely environmental impacts of the project are such that it should be assessed under the EPBC Act. Any relevant public comments are taken into consideration in making that decision. Once a project has been assessed by the Department, the Department makes a recommendation to the Minister about whether the project should be approved. In addition to considering potential impacts on matters of national environmental significance, the Minister also considers the social and economic impact of the project. 
    2. Flight Paths – Inconsistent, Conflicting and False and Misleading Information

The impacts of proposed flight paths over Lake Weyba, Castaways Beach and Marcus beach have been grossly underestimated and understated in the original EIS. The impacts on Peregian Beach (south of Lake Weyba as well as beachside) Weyba Down, Noosa Springs, Sunrise Beach, Sunshine Beach, Noosaville, Noosa Main Beach area have been understated. No consideration has been given to the noise impacts. The AEIS document states the following in relation to Noosa Area.(SUBMISSIONS RESPONSE ITEM 22)..”When passing over the Noosa area aircraft are likely to be above 10,000ft on departures and between 4,500 and 5,000ft on arrivals. Forecasts indicate in 2020 there may be one flight in the vicinity during the day (7am – 6pm) and between 0 and 1 during the evening (6pm – 10pm) and in 2040, 4 – 5 day flights and 1 – 2 evening flights. Departures and arrivals would generate noise of less than 60dB(A).” ALL OF THE SUBURBS LISTED ABOVE ARE PART OF THE NOOSA AREA.
IN RELATION TO FLIGHTS OVER Lake Weyba (submissions response item 174) ….Flights and noise in the vicinity of Weyba Downs: Weyba Downs is not typically overflown. However, it is likely that aircraft will be seen and potentially heard as noise events of less than 60dBA. With the new runway in 2020, aircraft departing Sunshine Coast Airport would be at between 8,000 and 8,500ft and arriving aircraft would be at between 3,000 and 3,500ft. In 2020 it is predicted that there would be between 2 and 3 flights on an annual average day (7am to 6pm). In 2020 evening flights (6pm – 10pm) are predicted to number between 0 and 1. No night flights (10pm – 7am) would occur. In 2040 it is predicted that there would be around 3 flights on an annual average day (7am to 6pm). In 2040 evening flights (6pm – 10pm) are predicted to number between 1 and 2. Night flights in 2040 are predicted to be between 0 – 1 (between 6am and 7am).

Totally false and misleading according to current consultation information provided by Air Services which now indicated that the flights over Lake Weyba, Castaways Beach, Marcus Beach and the Noosa Area are primary flight paths. This is in total contradiction to the EIS Summary of Findings document which clearly labels these flight paths as “secondary”. 

If the flight path over Lake Weyba, Castaways and Marcus proceed and these movements are proved to be incorrect, or noise levels exceed this stated, litigation could reasonably be expected. A class action could rightfully be initiated against Air Services Australia, The Coordinator General/DSDIP, Sunshine Coast Council and the consultants involved in the preparation of the EIS.

3. Noise assessment
This section relates specifically to proposed flights paths over the northern section of the Sunshine Coast and Noosa Areas, Specifically Lake Weyba, Hinterland Areas, Weyba Down, Castaways and Marcus Beach and all other areas impacted by the introduction of flights which have experienced no previous overhead flights and which have very low ambient background noise levels which are typically less the 45-50 db.
  1. In accordance with Airservices’ own Assessment Criteria, an increase of more than 5 decibels is a determining factor for potential environmental impact. Unfortunately, the Environmental Assessment report does not document consideration against this criterion. 
I  now draw your attention to Section 4.38 of the Aircraft Noise Ombudsmans report on the impacts of Hobart Airport – the comments are directly relative to the proposed flight path changes.

 

  1. 4.38  The N60/N65/N70 criterion should help to flag potential concerns, but using the cut-off noise level of 60 decibels has proven to be inadequate, given the significant community reaction to the changes in Hobart. The need for an increase of a certain fixed number of flights in a day (as averaged over a year) is also a questionable basis for determining potential significance in some situations. In the case of areas that previously had few or no over flights, particularly in semi-rural settings with low background noise levels, new noise impacts, even if below 60 decibels, may still be potentially significant as an indicator of social impact and which may need consideration under the EPBC Act. The context in which the noise occurs will affect its degree of significance. 
  1. According to the Standards Australia Handbook HB 149:2016 Acoustics- Guidance on producing information on aircraft noise:A change of 3 dB(A) is generally regarded as just discernible by humans, 5 dB(A) is regarded as clearly discernible, and 10 dB(A) is generally regarded as leading to the subjective impression of a doubling or halving of loudness. 
  1. the Environmental Assessment report made no mention of increased noise levels of potentially greater than 10 decibels (generally perceived as a doubling of the loudness) and a significant increase in the number of flights directly flying over noise sensitive areas with very low ambient background noise levels.
    And I draw your attention to the following Section from the Aircraft Noise Ombudsmans report on Hobart flights changes:
  1. 4.45  In Airservices’ Assessment Criteria a ‘High level of existing flight’ is defined in footnotes as being an average of greater than 35 flights per day at 60 decibels or more and a ‘Low level of existing flight’ is defined as being fewer than 35 flights per day at 60 decibels or more. This means that a quiet rural area which currently experiences an average of only two or three flights per day could be affected by change that imposes an additional 30 flights per day and not exceed the criteria as defined (a total of 33). In contrast, a rural area which already has an average of 36 flights per day and is affected by an increase of >25% – that is, just 10 extra flights per day – would be considered to have exceeded the criteria.
  2. 4.46  The inconsistency that arises from applying total values compared to percentages for the different areas leads to an inconsistent and unhelpful assessment. An area affected by few or no flights will certainly be affected more by a change to up to 33 flights per day than an area already experiencing a relatively high level of overflight. 
    Also of Relevance are the specific recommendations of the ANO’s report for Hobart:

Recommendations 1-4: Airservices should incorporate consideration of potential noise impacts from the commencement of flight path design and; Airservices should review its environmental assessment criteria to ensure they are appropriate as a quantitative measure for analysis against the EPBC Act requirements and for assessment of social impact. 

Airservices should ensure that its additional analysis of social impact to form part of the Environmental Assessment:

  1. (a)  includes a clearly defined purpose;
  2. (b)  includes explicit commentary on social impact taking into account particular community history, context and sensitivities; and
  3. (c)  incorporates a critically analytical assessment of the potential impact on the community of proposed change referring to both qualitative and quantitative values. 
  1. (a)  includes a clearly defined purpose;
  2. (b)  includes explicit commentary on social impact taking into account particular community history, context and sensitivities; and
  3. (c)  incorporates a critically analytical assessment of the potential impact on the community of proposed change referring to both qualitative and quantitative values. 

    In undertaking its Environmental Assessments and preparing reports on those assessments, Airservices should:

    1. (a)  ensure that all assessment criteria, for both EPBC Act purposes and for assessment of social impact, are clearly explained in its documentation in a way that makes clear their purpose, whether they are primary or secondary, the assessment methodology, and the consequences that follow if a threshold is exceeded;
    2. (b)  explicitly document any assumptions made and explain the basis for each assumption;
    3. (c)  explicitly document its consideration of change proposals against its stated criteria;
    4. (d)  undertake a more nuanced assessment of whether a change is ‘significant’ in social impact or under the EPBC Act requirements, taking into account both quantitative and qualitative values so that a non-binary and more informative approach is taken to assessment against criteria; and
    5. (e)  refer to or document all relevant information that forms the basis of its environmental assessment and conclusions in a single explanatory Environmental Assessment report. 

Airservices should review its environmental assessment criteria to ensure they are appropriate as a quantitative measure for analysis against the EPBC Act requirements and for assessment of social impact.

Airservices should ensure that its additional analysis of social impact to form part of the Environmental Assessment:

  1. (a)  includes a clearly defined purpose;
  2. (b)  includes explicit commentary on social impact taking into account particular community history, context and sensitivities; and
  3. (c)  incorporates a critically analytical assessment of the potential impact on the community of proposed change referring to both qualitative and quantitative values. 
integrate that consideration throughout the design process.

 

And again I draw you attention to the following: (Emphasis added)
  1. The Environmental Protection and Biodiversity Conservation Act 1999 (EPBC Act) is Commonwealth legislation to protect and manage important flora, fauna, ecological communities and heritage places defined in the EPBC Act as matters of national environmental significance. The proponent of a change must determine if any proposed action (called a ‘proposal’ or ‘project’) has the potential to have a significant impact on a matter of national environmental significance. If it might, the proponent must seek to have the action assessed under the EPBC Act by referring the project to the federal Department for the Environment. This referral is then released to the public, as well as to the relevant State, Territory and Commonwealth Ministers, for comment on whether the project is likely to have a significant impact on matters of national environmental significance. The Commonwealth Minister for the Environment will then decide whether the likely environmental impacts of the project are such that it should be assessed under the EPBC Act. Any relevant public comments are taken into consideration in making that decision. Once a project has been assessed by the Department, the Department makes a recommendation to the Minister about whether the project should be approved. In addition to considering potential impacts on matters of national environmental significance, the Minister also considers the social and economic impact of the project.
    1. In essence, Airservices’ / Sunshine Coast Council / Sunshine Coast Airport environmental assessment process has two functions – first, to ensure legislative compliance (identifying the potential for significant impacts within the meaning of the EPBC Act) and second, to make a business risk assessment (identifying potential business risks arising from potential environmental impacts). The environmental assessment is relied on by decision makers and informs the organisation’s Stakeholder Engagement Strategy. We consider there is also a need for the Environmental Assessment process to include the additional function of critically analysing the design from a noise (and environmental) perspective to ensure the best design is delivered. 
  1. On the face of the Environmental Assessment report only one of the assessment criteria is referred to – the average number of flights above 60dB(A). The ‘Assessment Criteria’ also include the average number of flights in the Day  and Night  as important considerations, with different thresholds identified for Day and Night. However, the  Environmental Assessment report does not comment on the impacts at different times. The Environmental Assessment does not document consideration of LAmax or LAeq variations. According to Airservices’ Assessment Criteria, an increase of greater than 5 decibels (during the Day period) would exceed the LAmax criteria. Consideration of this impact was not included in the Environmental Assessment.  
    1. Airservices’ current policy on community consultation is contained in its Communication and Consultation Protocol10 which is published on its website. We understand that the Protocol is currently under review. However, the current Protocol, dated July 2016, provides in its foreword:We are committed to providing information to stakeholders and the community on significant changes that may affect them, and to incorporating feedback into our planning, decision-making and implementation processes 
      AND I EXPECT THAT THIS IS APPLIED TO THE MATTER AT HAND. SIMPLY COMPLY WITH YOUR OWN POLICIES AND PROCEDURES.
    4. Alternate Flight Paths

 

It is clearly stated in the current consultation brief  document (Prepared by Air Services) in relation to this flight path “The introduction of SIDs and STARs will improve operations by reducing complexity of aircraft management and air traffic control systems, resulting in reduced fuel burn and lower emissions.”
These statements are false and misleading. 


Why on earth would planes coming from the south and going to the south fly north of the airport only to return in a southerly direction if there was any concern for reduced fuel burn? Would they not simply arrive and depart in a south-westerly direction for runway 31? This alternate flight path has been assessed by current commercial airline pilots as feasible, more safe, and affecting less people than the proposed flight paths. I will not explain the alternatives in detail here as I am sure they will be presented in full through other submissions
 
The project is the Sunshine Coast Council’s. Why should the impacts of the airport not be confined to within the boundaries of that Local Government Area where possible? Why do the flight paths need to impact on Noosa Shire and northern areas which have experienced no overflights in the past? The entire process has been designed to transfer Sunshine Coast Airport flight paths over Noosa Shire. Why?
 
Of further concern is the Sunshine Coast Airports stated intention to close the existing current North/south runway – effectively trashing a $150M asset of the Sunshine Coast. The proposal has met opposition from the local aviation industry. And I am sure you will have received more detailed submissions in relation to that matter. Simple common sense would indicate that if the remaining runway was left open for use a significant portion of domestic RPT aircraft could continue to use the existing runway and reduce impacts for areas which have not previously experienced any overhead flights at all.