• PBCAI

CASA-OAR needs to review the major issues and consider all options for flight paths

SUNSHINE COAST AIRPORT EXPANSION - ACP 043-19

The PBCAI is very concerned about the proposed flight paths resulting from the second runway being built at the Sunshine Coast Airport scheduled to become operational in 2020.

Following totally inadequate consultations, Airservices Australia (ASA) recently submitted the Airspace Change Proposal (ACP) to Civil Aviation Safety Authority (CASA) Office of Airspace Regulation (OAR) for the new runway at the Sunshine Coast Airport.

There are a number of very significant issues that need to be addressed and/or reviewed prior to CASA making any decisions regarding ASA’s proposed flight paths.

These include:

A. The lack of proper comprehensive assessments of the consequences of the proposed flight paths for the wildlife of the region and the safety of aircraft.

B. The lack of proper consultation with residents north of the airport who are newly affected by the proposed flight paths.

C. The green flight path (arrivals from the south crossing the coast between Marcus Beach and Castaway’s Beach) should not be the main approach and departure corridor.

D. Noise amelioration is anticipated when jet aircraft fly below 5000ft

E. Sunshine Coast Airport (SCA) & Sunshine Coast Council have announced the closure of the existing runway once the new runway is operational.

We ask that CASA-OAR review the major issues and consider the full range of options for a flight path that does in fact meet the requirements of all parties including those of local residents

Submissions close on 9 September 2019 and can be sent to oar@casa.gov.au



Our full submission follows:

31 August 2019

Airspace Operations

Office of Airspace Regulation

Airspace and Aerodrome Regulation Group

GPO Box 2005

CANBERRA ACT 2601

Via email to

Dear Sir or Madam

SUNSHINE COAST AIRPORT EXPANSION - ACP 043-19

I am writing on behalf of the members of the Peregian Beach Community Association Inc. The PBCAI represents the interests of the residents of Peregian Beach and Marcus Beach on the Northern Sunshine Coast.

The PBCAI is very concerned about the proposed flight paths resulting from the second runway being built at the Sunshine Coast Airport scheduled to become operational in 2020.

Following totally inadequate consultations, Airservices Australia (ASA) recently submitted the Airspace Change Proposal (ACP) to Civil Aviation Safety Authority (CASA) Office of Airspace Regulation (OAR) for the new runway at the Sunshine Coast Airport.

There are a number of very significant issues that need to be addressed and/or reviewed prior to CASA making any decisions regarding ASA’s proposed flight paths. These include:

A. The lack of proper comprehensive assessments of the consequences of the proposed flight paths for the wildlife of the region and the safety of aircraft.

Neither the EIS process (2014, 2016) nor the recent ASA TEIS process adequately considered the potential impact on and from the significant protected areas north of the current airport. Map 1, attached, shows these protected areas.’

These areas are home to a range of wildlife including birds classified as vulnerable or threatened such as the glossy black cockatoo, high flying birds such as ibis and kites.

Low-flying aircraft on the proposed flight paths pose a risk to the wildlife in these protected areas. Similarly, migratory birds, ibis and kites pose a risk to aircraft on flight paths where the aircraft is flying at low altitude.

B. The lack of proper consultation with residents north of the airport who are newly affected by the proposed flight paths.

Concern about the proposed flight paths and the lack of, and/or inadequate consultation from the time of the EIS, the Additional EIS and the recent ASA consultation is widespread in the community. ASA received over 3,000 submissions following their consultation earlier in 2019 and the Aircraft Noise Ombudsman is inquiring into the adequacy, not only of ASA’s consultation but the consultation process for the 2014 EIS and AEIS.

i. The EIS and AEIS claim to have consulted widely however careful scrutiny of these documents demonstrates the lack of consultation

ii. Sunshine Coast Council claims that fewer residents would be affected by noise – however there is insufficient data to support this.

I have attached PBCAI’s submission to ASA which provides more detail.

C. The green flight path (arrivals from the south crossing the coast between Marcus Beach and Castaway’s Beach) should not be the main approach and departure corridor.

The recent ASA consultation process indicated that although the green flight path was described in the EIS as a secondary flight path, it would in fact take to bulk of the traffic – around 77%.

We understand that in 2012 ASA in fact considered the green flight path should be used only in bad weather.

The 2014 EIS shows the yellow flight path which crosses the coast around 15 nautical miles north of Marcus Beach as the primary route for flights from the south. As outlined in the PBCAI submission to ASA the responses to submissions or questions in the AEIS process made it clear that the green flight path was not intended to be the primary arrival and departure route for flights to and from the south.

It is unclear why ASA is recommending the green flight path rather than the yellow route further north.

Residents reject the notion that the green flight path represents a significant saving in time for aircraft. The yellow path is approx. 15 nautical miles further north taking a matter of minutes. Residents also reject the idea that resident’s loss of amenity is more acceptable than such a minor inconvenience to aircraft.

D. Noise amelioration is anticipated when jet aircraft fly below 5000ft – which is being proposed for flights approaching the runway from the south on the green flight path. The impact of the new runway could be ameliorated by changing the primary flight path to a western route

E. Sunshine Coast Airport (SCA) & Sunshine Coast Council have announced the closure of the existing runway once the new runway is operational.

The purpose of the process to date has been to expand the SCA not to reduce it back to one runway. The issue in relation to flight paths is that the green path will become even busier with general aviation also using that route.

We ask that CASA-OAR review the major issues and consider the full range of options for a flight path that does in fact meet the requirements of all parties including those of local residents

Yours faithfully

Marian Kroon

Vice-President

PBCAI

Attachments

Map 1 – Protected areas

PBCAI – submission to ASA

PBCA SUBMISSION RE PROPOSED FLIGHT PATHS FROM SUNSHINE COAST AIRPORT’S NEW RUNWAY

On behalf of our members and the residents of Peregian Beach and Marcus Beach the Association strongly objects to the proposed new flight paths from the Sunshine Coast Airport (SCA). Our reasons are summarised below and then discussed in further detail:

1) There are significant flaws with the original EIS

a) There was inadequate consultation with the residents in the Noosa Shire, particularly those in the coastal communities who would be affected by the new flight paths;

b) There was inadequate consideration of the environmental issues for fauna, flora and rivers and lakes potentially affected by proposed flight paths in the Noosa Shire;

c) The noise analysis did not consider the residents of the coastal communities in Noosa Shire that would be newly affected by noise;

2) The proposed flight path over Marcus Beach and Castaways Beach (the green path), which ASA advises is expected to take more than 75% of the traffic landing at SCA, was described in the EIS and consultation material at the time as the secondary path – whereas it clearly is now proposed to be the primary path;

3) The secondary flight path prioritises the convenience for aircraft over the inconvenience of residents;

4) The ASA website states that wherever possible flights lower than 5000ft should not fly over residential areas – which the “green path” clearly does;

5) The recently updated analysis by SCRC of the noise impact of the various flight paths on residents provided to Noosa Council draws conclusions that are counter intuitive;

6) The predicted closure/shortening of the existing runway would substantially increase the traffic on the green flight path;

7) The new runway is being built to take significantly heavier aeroplanes than the B737 that is being used as the base for noise analyses and the impact of this is not known to residents.

8) There needs to be a balance between the purported economic benefits resulting from the new runway and the liveability and amenity of the region for residents.

Given these issues we suggest the following steps are required:

i) An EIS for the affected areas and potentially affected areas in the Noosa Shire;

ii) A noise analysis based on the proposed affected areas and potentially affected areas within the Noosa Shire;

iii) An analysis of potential alternate paths with significantly less impacts including the option at Attachment A that uses the existing corridors;

iv) A period of intensive consultation with the residents of Noosa Shire once these three analyses have been completed.

THE ISSUES IN DETAIL:

1.There are significant flaws with the original EIS:

a) There was inadequate consultation with the residents in the Noosa Shire, particularly those who would be affected by the new flight paths:

The consultation carried out with residents is described in detail in the EIS: Volume A7: Stakeholder Engagement and the Additional EIS. These documents make very clear that communities in the SCRC area and/or close to the airport were consulted. However, of the total of approx. 363 engagement “events” prior to the release of the EIS (described in A7a of the EIS), around 212 were with business or community groups or individuals. Of those, 12 involved individuals or groups located in Noosa Shire. These engagement events included phone calls and emails. In fact there was more consultation with individuals and business outside the region than there were with affected locals in the coastal areas of Noosa Shire or north of Coolum.

The AEIS mostly contains information about the advertising of the public notification period for the EIS. It is clear that community consultation about the EIS content, and in particular advice to residents of the affected coastal areas of Noosa shire was inadequate and not commensurate with the consultation and information delivered to households in the SCRC area. The AEIS indicates that over 32,000 households were targeted and provided with a flyer detailing information about the impact of the new runway. This target group were residents 10km south of the new runway and 20 km north-west of the runway – ie not the residents in the coastal communities of Marcus Beach, Castaways Beach or Lake Weyba.

The response to a submission making this point is illustrative, suggesting that the view was that the impact would be negligible and therefore there was no need to consult with this group:

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). [1]

The response indicating the very low number of flights also demonstrates that the flight path over MB and CB was not intended to be the primary path.

b) There was inadequate, if any, consideration of the environmental issues for fauna, flora and rivers and lakes potentially affected by proposed flight paths in the Noosa Shire;

The EIS is silent about the effects on the environment in the Noosa Shire. The terms of reference indicate the objective of the EIS is“ to present the likely effects of the project on the natural, social and economic environment.”[2] Section 5 of the EIS makes it clear that any area affected by any phase of the project (including flight paths) should be considered, it’s environmental values documented, impacts including cumulative impacts analysed and options to avoid or strategies to mitigate impacts identified.

Given the nature of Noosa and the Noosa biosphere status, it is reasonable to expect a thorough analysis of the potential impacts of the total project as outlined in Section 5 of the TER.

c) the noise analysis did not consider the residents in the coastal communities in Noosa Shire that would be newly affected by noise:

The EIS noise analysis considered the noise impacts on the “heavily populated residential areas north and south of the [existing runway] at the airport[3]. The Terms of Reference for the EIS include [highlights added]:

5.1. Noise and vibration

5.1.1. Description of environmental values

Describe the existing noise and vibration environment that may be affected by all components of the project (including fill material extraction and delivery, airport construction activities and runway operations) in the context of the environmental values defined by the Environmental Protection (Noise) Policy 2008. Refer to both the Noise Measurement Manual (Environmental Protection Agency 2000) and the

Guideline: Noise and vibration from blasting (Environmental Protection Agency 2006).

Identify sensitive noise receptors (such as residences, educational facilities,health/child/aged care centres, community facilities, environmentally sensitive areas including Mudjimba Island)) adjacent to and/or impacted by all components of the project and estimate typical background noise and vibration levels based on surveys at representative sites. Discuss the potential sensitivity of such receptors and nominate performance indicators and standards

The analysis of the change to the number of people/dwellings experiencing noise was limited and did not include the communities further north.

So, very misleadingly, the conclusion reached was that “as a result of the new runway the number of dwellings likely to experience [ noise at N70 levels] would be significantly reduced by approx. 5,285 dwellings by 2040.”[4] This conclusion then became generalised to indicate that the number of dwellings on the Sunshine Coast impacted by noise would be reduced with the new runway. For example, in response to an issue raised in a submission re the EIS the response to the submitter was:

The Social and Visual Impact assessment (Chapter D5 of the EIS) determined that in 2020, with the proposed change to the main runway alignment, 3,500 fewer dwellings on the Sunshine Coast would experience five or more 70 dB(A) noise events. In 2040 there would be a 73 per cent reduction (5,285 fewer dwellings) in the number of dwellings affected by frequent noise events (five or more 70 dB(A) noise events on a summer weekday day.[5]

These statements are repeated in the press release from SCRC available on their website.[6] They are misleading because they do not clarify that the figures do not include newly affected residential areas that in fact are part of the Sunshine Coast.

2. The proposed flight path over Marcus Beach and Castaways Beach (the green path) has become the primary rather than secondary path.

The EIS describes the proposed flight path over MB and CB as the secondary flight path for arrivals into Runway 13 when the prevailing wind is coming from the south as well as the primary pathway for flights departing when the prevailing wind is coming from the north.

However, during the recent consultation process the term secondary path has been abandoned and ASA and SCRC advised residents that around 75% of arrivals would use that flight path and around 25% of departures.

There are currently 16 jets arriving and departing daily. If 75% arrive using the” green” path, that’s 12 jet arrivals. The noise tool on SC Council website shows this.

Compare this with the feedback to a submitter to the EIS [highlights added]

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). [7]

This response, indicating the very low number of flights, demonstrates clearly that the flight path over MB and CB was not intended to be the primary path.

The EIS includes a table forecasting the number of aircraft movements[8]:

Based on the response to the submitter above, of the anticipated movements in 2020 the green flight path was only expected to carry 2 of the anticipated 24 movements, and by 2040 around 7 of the anticipated 49 commercial aircraft movements. The noise tool for MB, as at 25 April 2019, indicates that around 11-13 flights in 2020 can be expected.

Despite protestations to the contrary, the demonstrable lack of detailed and targeted consultation with the communities in MB, CB and Lake Weyba appears to be related to the description of the flight path (the green path) as a secondary path.

3. The secondary flight path prioritises the convenience for aircraft over the inconvenience of residents. The following extract from the EIS summary makes it clear that the purpose of the secondary flight path is to save time and flying distance[9]:

. Secondary Approach and Departure Corridor – this is a secondary corridor that has been established to provide an efficient second flight path for aircraft arriving from, and departing to southern destinations such as Sydney and Melbourne. This corridor provides a shorter flight path for arriving aircraft able to carry out some types of advanced GPS based instrument approach procedures which can accommodate turns, as well as providing a suitable flight path for aircraft making visual approaches. Aircraft arriving from the south to RWY 13 will use the secondary corridor to save the extra flying distance and time which would otherwise be required if they were to arrive via an outer joining route to the primary approach corridor in the north.

It would be a relatively minor inconvenience for aircraft on a 1000km or further journey to travel a further 15-20 km north on an alternate path that minimises the noise and other impacts on residents.

4. The ASA website states a fundamental principle in considering the development of flight paths is that a height of 5000ft is considered the minimum acceptable altitude to avoid significant noise impacts on residential populations by jet aircraft[10]. Wherever possible flights lower than 5000ft should not fly over residential areas. – which flights on the “green path” clearly would. Alternate flight paths should be found that better meet the principle.

5. The recently updated analysis by SCRC of the noise impact of the various flight paths on residents provided to Noosa Council draws conclusions that are counter intuitive. Further work needs to be done on assessing the impact on residents of sensible alternate routes that minimise the impacts on residents.

6. The predicted closure and/or reduction in length of the existing runway would substantially increase the traffic on the green flight path. The Sunshine Coast Daily has been reporting on the issue of the closure of the existing runway since early 2018. The recent articles[11] indicate it will be reduced to 800m meaning that it will have limited use and most general aviation and small jets will use the new runway.

The “Fact Sheet” for the Northern Community states “Passenger jet aircraft will be using the flight paths [over MB and CB], although light aircraft may also use the flight paths if they have the appropriate satellite navigation equipment.” Also

In relation to the green flight path the Summary of the EIS states[12]:.

Secondary Approach and Departure Corridor – this is a secondary corridor that has been established to provide an efficient second flight path for aircraft arriving from, and departing to southern destinations such as Sydney and Melbourne. This corridor provides a shorter flight path for arriving aircraft able to carry out some types of advanced GPS based instrument approach procedures which can accommodate turns, as well as providing a suitable flight path for aircraft making visual approaches.

So the overall number of aircraft flying overhead will be substantially higher than the 11-13 predicted by the noise tool.

7. The new runway is being built to take significantly heavier aeroplanes than the B737 that is being used as the base for noise analyses and the impact of this is not known to residents. Whilst we accept that newer aircraft are both less noisy and more environmentally friendly, the noise impact of substantially heavier aircraft taking off and landing in the midst of a region with a huge population increase predicted is unknown.

8. There needs to be a balance between the purported economic benefits resulting from the new runway and the liveability and amenity of the region for residents. That is we don’t support increased flights and flyovers that comes with such a high cost to local residents. Whilst we appreciate that the new runway will bring more visitors, amongst other benefits, tourism needs to be sustainable and consider the liveability of the SC region.

Conclusion:

Given that the noise impact of the green flight path is unacceptable to local residents we suggest the following steps are required:

a. An EIS for the affected areas and potentially affected areas in the Noosa Shire;

b. A noise analysis based on the proposed affected areas and potentially affected areas within the Noosa Shire;

c. An analysis of potential alternate paths with significantly less impacts including the option at Attachment A that uses the existing corridors;

d. A period of intensive consultation with the residents of Noosa Shire once these three analyses have been completed.

Marian Kroon

Vice-President

PBCA

ATTACHMENT A: An alternate flight path using existing corridors

There is no conflict with the Airway Control Steps into Brisbane.

CC LL refers to the Control Airspace 'C' Lower Limit for the corridor for Jets approaching Brisbane Airport from the North and North West.

[1] AEIS p25

[2] Terms of Reference, 3.6.2, p9

[3] Sunshine Coast Airport Ex[ansion Project: Chapter Summaries (EIS, ChptD3, p40)

[4] As above

[5] AEIS p25

[6] https://www.sunshinecoast.qld.gov.au/Council/News-Centre/Airspace-design-and-flight-paths-for-the-new-runway-at-Sunshine-Coast-Airport-200319 - downloaded 23/4/2019

[7] AEIS p25

[8] EIS

[9] EIS summary p38

[10] Environmental Principles and Procedures for Minimising the Impact of Aircraft Noise – on the ASA website.

[11] Sunshine Coast Daily, 20 November 2018, Design issues plague airport project

[12] EIS Summary, p38

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