Submission to A Review of the need for a curfew at Brisbane Airport
In August 2013 the Department of Infrastructure and Transport released a discussion paper, Future Brisbane Airport Operations: A Review of the need for a Curfew at Brisbane Airport, to assess the need for night-time noise strategies at Brisbane Airport. The discussion paper called for submissions by 31 October 2013. What follows is my submission to this review.
1. It is widely accepted across the international community that aircraft noise has significant environmental and possible health impacts on populations living in the vicinity of major airports, particularly those living directly beneath the approaches and departure paths of large aircraft. While acknowledging the significant economic contribution the Brisbane Airport makes to the Queensland and Australian economy, the need for economic growth must be balanced with the rights of residents living in close proximity to enjoy a certain level of amenity.
2. Two recent studies published in the British Medical Journal support previous research suggesting a direct link between aircraft noise and adverse health outcomes. A study of those living in 2218 post codes surrounding 89 airports in the United States found a ‘statistically significant association between exposure to aircraft noise and risk of hospitalisation for cardiovascular diseases among older people living near airports’. The second of these was conducted in 12 London boroughs and nine districts west of London exposed to aircraft noise related to Heathrow airport in the United Kingdom. Researchers in this case found that ‘high levels of aircraft noise were associated with increased risks of stroke, coronary heart disease, and cardiovascular disease’. While many such studies may be contested it is clear that certain health impacts are likely to flow to communities from sustained and excessive exposure to aircraft noise.
3. As a resident of Brisbane’s Southside for the last 23 years I am fully aware of the negative impact of aircraft noise on communities living under a flight path. For those living in the electorate of Griffith the problem of aircraft noise has been a constant cause for concern. 3500 of my local constituents have made contact with my Morningside office in relation to aircraft noise. There has been some effort made by Brisbane Airport Corporation, Airservices Australia and the Australian Government to address the impact felt by this community. However, the ever-growing number of complaints lodged with my local office suggests that there has been no real reduction in the incidence of excessive aircraft noise caused by residential over-flight. In fact, as the number of inbound and outbound services at the Brisbane Airport has increased, so too has the discomfort, concern and increasingly, anger within the community.
4. The New Parallel Runway (NPR) is scheduled for completion by 2020. This will virtually double the capacity of the Brisbane Airport which is expected to experience annual growth in air traffic volumes from 219,920 in the last financial year to 272,000 in 2020 and 393,000 by 2035 more than 1,076 aircraft movements per day. Without adequate management of further growth, aircraft noise will affect more people because of the new flight paths that will be generated by both runways, and there will be less respite from noise in a given 24 hour period because of the rapid increase in the total number of flights.
5. In February 1999, the Howard Government through its Transport Minister, John Anderson, approved the Brisbane Airport Corporation’s (BAC) Master Plan and NPR proposal, despite more than 4,000 written objections from Southside residents and a petition submitted to the Federal Parliament by myself with over 10,000 signatures. In July 1999, I helped initiate a Senate inquiry into the BAC Master Plan process. The Senate Inquiry found a number of faults in relation to the Master Plan, and recommended that amendments be made to Airports Act 1996 to improve the consultative relationship between airports and the local community.
6. Between 2000 and 2002 I undertook four separate Court actions on behalf of the local community in both the Administrative Appeals Tribunal and the Federal Court in an attempt to stop construction of the second runway at the Brisbane Airport. I represented myself and the community in all of these cases, before losing the fourth;
· Re Kevin Rudd and minister for Transport and Regional Services
· Minister for Transport and Regional Services v Rudd
· Re Kevin Rudd and Minister for Transport and Regional Services and Brisbane Airport Corporation Limited
· Brisbane Airport Corporation v Wright.
7. In March 2002 the Federal Court ruled against me with $34,000 in costs awarded against me. Since then I have repeatedly stated my acceptance of the court’s decision that the BAC has the legal right to build the parallel runway and that the runway would proceed. I have also constantly argued since then that aircraft noise will need to be managed more effectively once the NPR is built. I have reflected this position in submissions to both the BAC’s 2003 Draft Master Plan and to the Draft Guidelines for the Environmental Impact Statement: BAC Parallel Runway Proposal in 2005.
8. For this reason, I argue that a night-time curfew (11pm to 6am) has the potential to provide residents with some respite from the sustained increase in aircraft noise that will accompany the parallel runway. I therefore propose a two year trial curfew be established immediately upon the completion of the NPR to properly evaluate its effectiveness as a measure to provide respite to residents from aircraft noise overnight, and whether such a curfew over the suburbs has any significant operational effect on the airport, given that most services between 11pm and 6am should be able to operate over Moreton Bay.
9. Currently there is an average of eight night-time (11pm-6am) aircraft movements over Brisbane’s residential areas. However, this number can regularly exceed 15 movements and on some occasions exceed 20 services. In May 2013 there were only eight nights which recorded zero aircraft movements over the city. During the month of June 2013 there were only five nights where Brisbane residents were provided respite from night-time over-flight. The truth is, a single noisy movement in the middle in the night is sufficient to disturb sleep for the rest of the night.
10. The most useful strategy deployed to mitigate ambient noise levels is to favour over-the-bay (Reciprocal Mode) operations wherever possible. Data provided in the NPR Project Environmental Impact Statement (EIS) and Major Development Plan (MDP) puts the proportion of night-time operations currently directed over Moreton Bay at about 68 percent in Summer and close to 82 percent in Winter. Airsevices Australia have repeatedly stated that the Reciprocal Mode of operation is only possible when weather conditions are appropriate. When the runway is wet and wind speeds are upwind and above 5 knots this mode of operation is unavailable. Bureau of Meteorology statistics show that on average Brisbane has 120 days of rain annually, 76 of those days rainfall above 1mm was recorded. The majority of these days fall in the summer months from October to May. The mean number of rainy days is above 9 days per month. Further, although wind speeds are often calmer in the evening and night, wind measurements at the Brisbane Airport between 2003 and 2013 show that monthly average wind speeds exceed the 5 knots threshold.
11. Furthermore, the 2010 Senate report into the ‘Effectiveness of Airservices Australia’s Management of Aircraft Noise’ found even when preferred operating modes during night-time periods were formalised, there was little guarantee that the majority of flights could be operated over water or non-residential areas. It found that although well intentioned, targets were just that. And in the case of Sydney Airport these targets, contained within their Long Term Operating plan (LTOP) had not been met in the 13 years since their introduction. If residents affected by aircraft noise could not have confidence in the airports ability to deliver on these assurances, in the absence of other effective measures, any operating plan could be seen as merely a PR exercise.
12. Furthermore, the NPR will create new flight paths over the southside, most notably over Bulimba, Hawthorne, Balmoral, Norman Park, East Brisbane and parts of Coorparoo. The result of this will be to subject new communities to the impacts of aircraft noise. This, coupled with significant changes to the Brisbane City Plan which will increase the density in inner-suburban areas, will mean a significant increase in the number of those affected in the wider geographical area. This will also be evident in suburbs situated along growth corridors like Coorparoo and Camp Hill that already suffer significant levels of aircraft noise disturbance. Property values in these various suburbs are also likely to be affected by the NPR.
13. There have been a number of strategies employed to reduce the impacts of aircraft noise on residential populations. One measure committed to by the previous Federal Government in the recent Aviation White Paper was to phase out the use of aircraft that fail to meet Chapter 4 noise standards. However, there still remain some foreign owned, marginally compliant aircraft operating freight services which exceed acceptable noise emission standards. Further, although the most modern aircraft are generally quieter, the pressure to reduce the unit cost of air travel has seen the size of aircraft getting larger and there are an ever increasing number of aircraft movements each day.
14. It has been argued that the use of ‘Smart Tracking’ technology or Required Navigation Performance (RNP) has the potential to enable pilots to more accurately navigate preferred flight paths or undertake noise sharing. However the over-use of preferred flight paths, particularly during night-time operations, has the potential to merely concentrate noise emissions over certain areas.
15. Noise sharing is the strategy of spreading over-flight paths between different residential areas in order to more equitably distribute noise emissions and provide some respite from multiple noise events both day and night. Although this strategy has been used by other airports in Australia, by definition because there will be an ever increasing volume of aircraft over Brisbane and the problem of aircraft noise will spread to more suburbs and the overall quantum of noise will increase for each suburb. This has the potential to subject a greater proportion of the population to the health and wellbeing, environmental and property value impacts associated with aircraft noise.
16. Imposing a curfew on night-time operations may result in a modest economic cost but this must be tested objectively. Dramatic assertions by the airlines or the BAC that a curfew would undermine the financial viability and economic utility of the airport are designed for headline effect rather than careful analysis of the facts. Sydney Airport with a curfew is entirely viable. Furthermore, any financial and economic impact must be balanced against the social and economic costs associated with the negative impacts of continued exposure to aircraft noise. This is what a proper cost benefit analysis means. And this can only be calculated in the real life circumstances of a two year night-time curfew during which time operational circumstances cannot be manipulated to achieve a desired policy result. A two year trial therefore, is essential to test both sides of the argument.