The change IMPACTS resident and tourist VALUES ON THE SOUTH EAST COAST
The proposed departure (SID) route impacts previously quiet rural and coastal communities almost 100% of time during the summer months, with about 50% of arrivals (STARs) impacting the same communities for the remainder of the year.
A number of these communities - which have never before been overflown by commercial jets - are host to existing and planned tourism developments which make a substantial contribution to the local economy, still in recovery from bushfire destruction in 2013.
It is also unclear why Airservices has chosen to move the Southern SID in particular closer to newly overflown communities which are already impacted by arriving aircraft - especially since this option was not put forward or discussed in public consultation sessions in November 2018.
In her investigation report, the Aircraft Noise Ombudsman strongly criticised Airservices’s procedures for determining the impact of aircraft noise as employed in its initial Hobart flight path design.
For example, Airservices’s trigger for conducting an environmental impact study is more than 10 planes per day over 60 decibels. This does not consider low background noise, tourism values, whether an area is newly overflown, the amplifying effect of water, or any other contextual information.
Airservices’s noise modelling does not consider the amplifying effect of water surfaces on noise – a phenomenon well-known to those who live on or enjoy the water.
Although it agreed to implement her recommendations to introduce a more effective noise assessment process, it has decided to delay implementation until June 2019 - hence its design of the Hobart flight paths will use the same process criticised by the ANO.
Although community stakeholders made these concerns known to Airservices during a public consultation process in November 2018, Airservices has chosen to ignore them.
Airservices must immediately implement the recommendations of the Aircraft Noise Ombudsman and improve its environmental assessment process so the impact of the proposed paths can be properly determined.
Improvements should include genuine and transparent consultation with potentially affected tourism operators, communities and other stakeholders.
Initial Environmental Assessment said that a number of communities would be newly overflown
Initial Stakeholder Engagement Strategy and subsequent public communications said that no new communities would be overflown
Airservices’s Case study of the Hobart implementation “The community that has been effected by the introduction of the changes has lost faith in Airservices ability to deliver accurate, genuine information, along with a solution that will both be acceptable to residents regarding aircraft noise outcomes and operationally viable for aircraft and airspace management …. This was recently demonstrated in Hobart, where a planned airspace change was implemented without appropriate identification and analysis of the impact of that change on the community.”
Executive paper acknowledging that limiting the consultation options to a single design will be ‘unpopular’
Second Environmental Assessment, which finds that ‘safety advantages’ are offered by an additional arrival route to the West of Hobart Airport
Aircraft Noise Ombudsman documents
Investigation into complaints about the introduction of new flight paths in Hobart, April 2018 “In other words, Dunalley residents would have perhaps heard one aircraft (at about 43 to 48 decibels) in the week 1 to 7 February 2017 with the remainder not likely to be perceivable. This is in stark contrast to the 30 aircraft (at a noise level of up to 58 decibels) that could be experienced on a daily basis when runway 30 was in operation following the changes introduced on 14 September 2017”
Australian Standard 2021-2015 Acoustics—Aircraft noise intrusion— Building siting and construction Cited by Airservices as the basis of its thresholds for acceptable noise. It states “Some experience has shown that communities that are newly-exposed to aircraft noise (e.g. as a result of the construction of new runways, or the redesign of flight paths near an aerodrome) tend to be more sensitive to such noise than communities that are accustomed to it. Land use planning must by necessity use a long-term horizon, and the building siting acceptability recommendations in this Standard are based on the reactions of noise-accustomed communities. Regulatory authorities are cautioned that a transient heightened reaction could result from substantial new noise exposure.”
Significant impact guidelines 1.2 Environment Protection and Biodiversity Conservation Act 1999 Policy guidelines for Commonwealth agencies for compliance with the EPBC Act 1999 “An action is more likely to have a significant impact on the environment if it will impact upon sensitive or vulnerable areas, components or features of the environment” and “When deciding whether or not a proposed action is likely to have a signi cant impact on the environment, you should consider only the adverse impacts that the action is likely to have. Bene cial impacts cannot be offset against adverse impacts.”