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Submission response to Airservices Australia (ASA) dated 25th April 2019.

Review of environmental, social and governance issues and impacts arising from the proposed operation of the Sunshine Coast Airport runway 13/31 and the related fight path plans. This submission is in response to ASA’s community consultation process inviting community stakeholders to address their concerns prior to the proposed commencement of flight operations at the Sunshine Coast Airport.

  1. Lodgement date : 25th April 2019

  1. Lodgement by : XXXXXXXXXXXXXX ,residing at XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX being a property in the affected area of the proposed flight paths.

  1. Definition of the complaint issue: The failure of the community consultation process conducted by ASA in relation to the above issue.

The process is in breach of the guidelines set out by the Aircraft Noise Ombudsman in the Investigation into complaints regarding the introduction of new flight paths in Hobart, dated April 2018. ASA has not taken sufficient steps to address their non-compliance with the recommended guidelines documented in the report. The process conducted by ASA has not achieved an efficient and effective community consultation outcome. This once again reflects the failure of process by ASA as seen in both the Perth and Hobart “changed flight path” events.

  1. Supporting information regarding the complaint issue in 3 above :

Issue 4.1  : Lack of formal notification of the process for community consultation to all residents in the affected areas

Negative Impact :

Not all residents in the affected areas were notified in a formal document posted to each address as proof of delivery on time and in full. Surveys show that many residents were not aware of the key issues and the short period for gathering meaningful information by the 30Th April 2019. Letterbox drops are normally considered to be junk as opposed to a formal letter commonly used by Government owned enterprises.

Issue 4.2 : Poor quality of information provided to the public.

Negative Impact:

The Information meetings held with ASA staff on a one on one basis in a kiosk environment failed. This process failed because of the ratio of attendees to consultants was grossly out of proportion. Attendees felt that questions were not fully answered in a meaningful manner to assist them with their decision making process. This is supported by media coverage of the outrage after each meeting. In some cases the consultant turned their back on the attendee and walked away. This poor process for gaining quality information has totally failed.

Issue 4.3 : Lack of effectiveness of community consultation based on media and consultative public meetings.

Negative Impact :

The effectiveness of providing meaningful information and the documentation of alternatives for public consideration has been incomplete. This is supported by the following :

Lack of detail of potential noise impacts on individual affected areas.

    • Insufficient evidence that the changes to the flight path have been stress tested against environmental and social criteria.
    • Lack of evidence that the impact of the changes to flight paths have been stress tested against the EIS 2014
    • Lack of clarity of the impacts that may occur if thresholds are exceeded and consequences that may follow.
    • Non-disclosure of a  list of assumptions behind the flight path modelling and the basis for assumption considered.
    • Lack of clarity supporting that the changes to the EIS of 2014 are not significant and the basis for categorising them as minor issues.
    • Lack of information supported by timelines, transparency, relevance, converted into a simple user friendly format.

Issue 4.4 : Failure to address interim complaints lodged prior to the deadline for submissions – 30th April 2019

Negative Impact :

Many complaints have been lodged with ASA with the sole purpose of receiving a meaningful response prior to making a submission before the 30th April 2019. This information is necessary for stakeholders to develop a meaning submission for review.

Issue 4.5 : Failure to provide potential options and alternative solutions for the public to consider prior to the 30th April 2019.

  Negative Impact :

ASA has failed to articulate any alternative flight path plans for consideration by the affected areas. This does not support an effective consultation outcome as the community needs to understand the implications of all possible options supported by full transparent disclosure.

  1. Conclusion  : The current process for community consultation does not meet best practice standards. This failed process needs to be re-engineered to allow community stakeholders to fully understand all implications of the proposed flight path changes. In addition to this, the community needs to re-build their confidence levels that information  provided by ASA is presented in full supported by transparency, accuracy and true disclosure.

Based on the above, my submission is that :

  1. The consultation period be extended by 30 days.

  1. ASA provide a detailed community consultation plan that meets best practice requirements and incorporates my findings. This needs to be implemented as a matter of urgency.

  1. ASA responds to my submission with full transparent and factual disclosure supported by logical reason as to why a new EIS should not be conducted with immediate effect.