1. Preamble & Scope 1.1 While Nepean
Greens has many concerns with the document "Draft Environmental Impact: Second Sydney Airport Proposal (Badgerys Creek)", and strong objections to the foolishness of locating any international
airport in the Sydney airshed, this submission has been deliberately limited to those particular issues that are currently not being widely canvassed by others. 1.2 The omission of any particular issues
from this submission is not an indication of our concurrence with any given aspect of the Second Sydney Airport Proposal (Badgerys Creek), but rather not wishing to detract from others more succinct pointed
criticism with our tuppence on broadly agreed objections. 2. Fair Quality Considering… 2.1 Firstly we would like to commend PPK for the tolerably competent EIS work that they have executed. Its presentation for the most part is clear and easily
comprehended within a professionally presented package. As with any work of this magnitude there are inevitably some inconsistencies and oversights in the fine detail. The public review of the EIS is
intended to highlight and address these. 2.2 Nepean Greens strongly urge your detailed consideration of SMEC's "Draft Environmental Impact Statement Second Airport Proposal : AUDITOR'S REPORT"
as it highlights many of our concerns over the patchy quality and omissions in the Draft EIS. Concurring with the 'Auditor's Report' we accept that the shortcomings are in part the sponsor's, not the
author's fault because of "time and cost constraints imposed by the proponent (Department of Transport and Regional Development), the Draft EIS generally does not go into the degree of detail that could
reasonably be expected for such a proposal." [SMEC 'Auditor's Report' page i, para. S.4 ] 3. Greens' "No 'Second' Sydney
Airport" Policy Position 3.1 Because of the significant adverse impacts on the environment with NO identified feasible remedial
strategies:- Destruction of the National Parks natural solitude / tranquillity. Additional air pollution in the already precariously polluted Sydney airshed. 3.2 Nepean Greens are vehemently opposed
to 'Second Sydney Airport Proposal (Badgerys Creek)'. The Greens longstanding airport policy is quite explicit on these points:-
"2. Phase Out of Kingsford Smith Airport Kingsford Smith Airport (KSA) to be downgraded and eventually phased out, not increased. 3. No 'Second' Sydney Airport
The Greens oppose any new airport development within the Sydney Basin airshed.
(In accordance with the 1991 NSW Government Summit on Air Quality and the September 1995 statement of the Australian
Medical Association.) 4. Replacement Airport Outside Sydney An airport to replace KSA must be built outside the Sydney Basin airshed." [ For full statement of "THE GREENS NSW POLICY ON
SYDNEY'S MAJOR AIRPORTS" see Appendix A attached ]
3.3 Unfortunately we are not confident that the major political parties have either sufficient vision or moral courage to rise above the putrid smoke of stale orthodoxy that airports in the Sydney Basin
are economically desirable. The bulk of this response thus seeks to highlight strategies that we believe should be implemented to minimise the injustice and adverse environmental dividend, in the unfortunate
eventuality of an airport being constructed as proposed. 3.4 Nepean Greens recognise that any airport anywhere will by its very character have serious and highly undesirable impacts on those unfortunate
souls living under flightpaths. Where this EIS is most remiss is in its dismissive negligible concerns to the seriousness of those impacts, and scant examinations of full remedial strategies (and associated
costings) so that no population will suffer any negative welfare benefit in the event of the second airport being established.
4. Underlying Assumption 4.1 Given the political context of the commissioning of the Draft EIS, we do not find it surprising that while
methodologically the EIS may be apparently consistent, it unfortunately but not unexpectedly, does not critically question or analyse the cultural and ideological content and biases of its underlying
assumption of justice and social equity of the infliction of an airport on residents who to date have been free of such unacceptable environmental impositions! 4.2 In the recent publication 'Critical
Mass: Transport, Environment and Society in the Twenty-first Century' John Whitelegg notes
"Air transport, long-distance tourism and their impact on society, culture, environment and economy present serious difficulties for policy makers. The behavioural attributes and life-style
characteristics associated with long distance tourism are deeply embedded in contemporary thinking about freedoms, economic growth and a globalised economy" [p96] "the pursuit of the freedom to
travel by air over longer distances subsidised by public funds is purchased at a cost of serious loss of quality of life by millions of people living around the world's airports" [p90].
5. Ecologically Sustainable Development 5.1 The Nepean Greens sadly concurs
with the Auditor, noting the failure of the Draft EIS to address ESD issues as commissioned ".. the rationale for developing a second major airport was to be referenced to the principles of ecological
sustainable development (ESD)" [SMEC 'Auditor's Report' pp 30, para. 6.5.2 ] 5.2 Contrary to the Draft EIS's own outline of ESD guiding principles "the global dimension of environmental impacts
of actions and policies should be recognised and considered". The Draft EIS inextricably limits its examination of Badgerys Creek Airport, to the immediate (in global terms) facilities. No where in the
EIS is Greenhouse gas, ozone depletion and the social impacts of the COMPLETE aircraft journeys even mentioned let alone examined! 5.3 The Draft EIS then falsely reasons the assertion:- "These
principles {ESD} have been taken into account in the development of the following measures for ongoing environmental management. It therefore follows that adherence to these measures should contribute to
meeting the goals of ecologically sustainable development" [Draft EIS p 26-3]. Just because ESD principles have been part of some process it does not follow that the result of that process with all its
other competing concerns will contribute to the goal of ESD, particularly when current international air transport operations are seen as a highly dubious and problematic undertaking to reconcile with the
principles of ESD (Ecologically Sustainable Development)! 5.4 If a 'do-nothing' scenario is pursued the lack of additional capacity could be expected to constrain growth of air travel, in comparison to
whatever the particular projections are for Badgerys Creek. Thus:- What tonnage of air pollution and Greenhouse gas would not be generated? How much upper atmosphere ozone would not be destroyed? What
measures are proposed by the proponents for the proposed second airport to redress this international damage, consistent with ESD principles? 6. Unsubstantiated Demand for New Airport Capacity 6.1 'Development of a new airport and/or
expansion of existing airport capacity is needed to accommodate forecast growth in air passenger and aircraft movements" [p5 EIS Summary]. The perceived requirement to provide capacity to meet projected
demand is tending to be regarded among transport researchers as a self-fulfilling prophecy. Transport demand has been observed to grow to fill whatever capacity is available. In the road transport domain, it
was noted with surprise that loss of highway capacity after the recent San Fransisco earthquake was unexpectedly matched by a fall in demand, to the point that some of the affected communities elected not to
re-establish lost highway capacity! This has given rise to the radical concept that tearing down freeways may actually improve performance of road networks. Some in Europe are now questioning whether a
similar effect may not also apply to airports. 7. Need For Phasing Out KSA And Route Restrictions 7.1 The Draft EIS offers three whimsical air traffic scenarios, in the auditor's words "The three air traffic scenarios considered for the role of the second
airport were not developed from operational experience of other multi-airport systems overseas as called for in the EIS guidelines." [SMEC 'Auditor's Report' pp 37 ] 7.2 Contrary to the popular
political rhetoric about the need for a second airport at Badgerys Creek, none of the three air traffic scenarios' projections, even by the year 2016, would provide a substantial reduction in the activity of
Kingsford Smith Airport (KSA). At least one air traffic scenario that reflects the political demands for downsizing of KSA in favour of the second airport should also have been examined. 7.3 The social,
community and environmental disaster that KSA has become should be wound back post-haste irrespective of any other airport developments in the Sydney Basin. The Draft EIS fails to note, but is highlighted by
the Auditor's report that Badgerys Creek is not the only site deemed suitable by the latest site selection investigation. The '1985 Second Sydney Airport Site Selection Program' also identified "Wilton
as the 'best' mid-distance site (Kinhill Stearns, 1985)." [SMEC 'Auditor's Report' pp 2, para. 1.3.1 ] 7.4 The Draft EIS [p 6-4] perpetuates mischievous myths when it states:- "The Commonwealth
Government has a policy of reducing 'the noise and pollution generated by the airport as much as possible' and 'sharing the noise burden in a safe and equitable way' (Coalition of Liberal and National
Parties, 1996). In response to the policy three actions have been taken or initiated: increased use has been made of the east-west runway; legislation limiting movements to 80 per hour has been enacted by
Federal Parliament.." The fallacy of the public assurances that KSA is not being massively and dangerously expanded, is recorded in Australian Senate Hansard for 30th October 1997 when Senator Brown
(Tasmania) stated:
"The Australian Greens do not support the Sydney Airport Demand Management Bill 1997. The bill sets the maximum hourly movement rate of Kingsford Smith airport at 80 movements an hour. ......
It is a fallacy that a cap of 80 movements an hour will stop the growth of the airport. ........ However, the new Minister for Transport and Regional Development, Mr Mark Vaile, said in his speech to
the bill that `80 movements an hour equates to approximately half a million movements per year'. That is half a million flights through the airport per year. These are words designed to allay any fears
the air transport lobby might have that the cap will impede the growth of the airport. At present, the annual number of movements is about 270,000. By the minister's own admission, this so-called cap
will allow the number of movements to, in effect, double. The cap of 80 movements per hour is a clayton's cap. It is the cap you have when you are not having a cap at all. ............... One reason
the cap should be set at no more than 70 movements is that the noise sharing component of the long-term operating plan will not work at levels much above that. When it is handling high volumes of
traffic, the airport must employ the parallel runways and not use the east-west runway. David Warner, the chair of Sydney's Air Traffic Management Task Force--the body that designed the long-term
operating plan--has said that noise sharing modes will not be possible at movement rates of 73 or more an hour, or even at 64 an hour if certain taxiway improvements are not made."
8. Noise 8.1 The EIS does have a lot of detail about measurements and
prediction of noise. Vol. 1 cites "Australian Standard 2021" [p 12-43,44 ] as its guideline for determining which residences require 'Acoustical Treatment' and which activities are suitable for a
given noise exposure. Unfortunately it has negligible detail about the justice of inflicting noise on residents that to date have been free of such unwanted disturbances. There is no cost benefit / loss
analysis to quantify the population loss of amenity of peaceful outdoor and inside environments. Nor is there any costed remedial strategy for the provision of large enclosed soundproof public space (covered
stadiums, pools, gardens, parks etc.). 8.2 Approximately 53,000 residences (ABS 1996 Census of Population & Housing, Penrith Local Government Area, Total Occupied Private Dwellings: 52,560, not all of
Penrith LGA will be subjected to fly-overs but the discrepancy is easily less than the additional residences in neighbouring LGA subjected to fly-overs.) will be affected by 70 Dba aircraft over flights at
some time. The EIS Vol. 1 states "Allowing for larger areas of glazing expected in areas surrounding the Second Sydney Airport options, the estimate of acoustical treatment in these areas is $50,000 per
house" [p 12-43 ]. Obviously not all residences will need the same amount of insulation as required for a residence experiencing an ANEC of 35. Assuming insulation costs taper from the high-end $50,000
to a low of $2,000 for Sound Smart Windows, a mean price would then be approximately $25,000. Thus the full cost of a just remedial action on each and every home that may be subjected to 70 Dba is around
$1,325,000,000. Noticeably higher than the approximated maximum $20 million inferred in the EIS Vol.1 [p 12-43 ] ('12-19' or '6-12').
9. Transport 9.1 The EIS postulates a number of road infrastructure expansions that would be engendered by the airport's development.
Nepean Greens are passionately opposed to gratuitous expansion of road capacity. It is extremely disappointing that the projected impact of a rail connection to the airport are so insignificant and
"would result in between 66,000 and 77,000 road vehicle trips to the airport each day. The lower figure assumes that a rail line would be built, while the higher figure has been calculated to assess
transport impacts if no rail line is provided" [p46 EIS Summary]. The EIS provides no justification why there should be any passenger or visitor parking at the airport. 9.2 As
motor traffic to and from the airport represents a significant unneeded air pollution burden on the local environment it should be strenuously avoided. With the exception of some disabled passengers and a
small percentage of employees all journeys to and from the airport should be via the integral heavy rail link. Accordingly to promote such a strategy there should be no unpriced parking within three
kilometres of the airport terminals. All other parking should be taxed/priced parking so as to meet the planning objective, we would not consider it to be unrealistic in pricing the daily rate up to the
equivalent of the economy airfare to Brisbane or Melbourne. Monies raised in this fashion could then be hypothecated towards full subsidisation of the rail link. At first such policies could be seen to place
Badgerys Creek airport at a disadvantage to Kingsford Smith but with the completion of the Southern Railway such restriction should be introduced to KSA first! 9.3 The majority of the freight should also
leave Badgerys Creek Airport to other sub-distribution sites by rail. 10. Housing Values 10.1 The Sydney Morning Herald 26/7/97 quoted falls of 17% to 36% for housing affected by airports, but the research I am aware of ( "The Impact of Airport
Noise on Willingness to Pay for Residences." Eran I. Feitelson & Robert E. Hurd, 1996) put the figure as high as 2.4 ~ 4.1% for every additional dBA ( an extra 50dBA in my case). The peaceful nights
I currently enjoy, at around 20 dBA, I fear will become sleepless nightmares, erratically punctuated by 70 dBA jets. As many of the homes in the west (like mine), are of a light old fibro and tile
construction (unlike the double bricks of the inner-city), I am not confident that remedial soundproofing would be structurally possible, even if I could afford it! Like many other cases of the Coalition
Government's user pays methodology, it really seems to be about the poor paying to subsidise the Liberal party's rich supporters. When a full costing of all impacts are included, it becomes obvious that the
airport's location outside of the Sydney Basin or the off-shore proposal are the ONLY VIABLE, JUST, ECONOMIC ALTERNATIVES to Sydney's air traffic problems. 11. Air Pollution 11.1 While this submission has been deliberately limited to those particular
issues that are currently not being widely canvassed by others, air pollution is already a critical issue in Western Sydney. We consider that the Auditor's comment [SMEC 'Auditor's Report' pp 51] on the
Draft EIS air quality study should be strongly emphasised:-
"10.4.5 Western Sydney has well known air quality problems. The Sydney Basin, which includes the Badgerys Creek area, is a complex area for regional meteorological and air quality assessment.
The use of simplistic models and the failure to use the most detailed meteorological and air quality data available places some doubt over the accuracy of the conclusions in the Draft EIS. 10.4.6 The
Second Sydney Airport will generate pollutant emission both from direct activities and also from indirect activity such as airport-induced vehicle traffic and commercial/industrial development. It is
unclear whether the modelling of the Draft EIS included these inputs. "
12. Operational Issues 12.1 The Draft EIS doesn't detail some operational
issues of great concern to Western Sydney residents;-
How is AVGAS to be transported to the site? If transporting AVGAS by road? How many truck movements will this entail? Is a pipeline envisaged for the AVGAS? What will be the operational
impacts / risk caused by smoke plumes from bushfires particularly during night-time operations? Risks of bird strikes over the national park. Impacts on airport operations, and in turn the local
environment, from possible flooding?
13. Long-term Futures 13.1 Finally while obviously not a fault of the authors,
the Draft EIS pays only scant attention [Draft EIS p 9-34 '9.6.2 Conceptual Plans for Airport Options' ] to the long term operations beyond 2016, when our children let alone our grand children will be
subjected to the full impact of the developments. As early as 1946 it was realised that Kingsford Smith Airport would have to be replaced or augmented by a second airport in time. Fifty years later and we
still are faced with a poorly considered Second Airport proposal that already has a number of major problems. If Badgerys Creek Airport is ever built, then Conceptual Plans for Airport Options should be
emphatically ruled out to avoid repeating any miss-calculations that long-term expansion options exist! 14. Appendix A: THE GREENS NSW POLICY ON SYDNEY'S MAJOR AIRPORTS Adopted by the State Delegates Council 1.6.97
1. No Privatisation No privatisation of airports. Without Government ownership it will be impossible to enforce a solution. 2. Phase Out of Kingsford Smith Airport (a) Kingsford Smith
Airport (KSA) to be downgraded and eventually phased out, not increased. (b) The staged phase-out should begin immediately with a freeze on all new development proposals for KSA and infrastructure
developments such as motorways which would prolong the life of the airport. (c) In principle the "sharing of noise" through flightpath changes is necessary, but only as a short to medium term
expedient, until KSA is phased out. (d) The flightpath plan currently being prepared (the "Long-Term Operating Plan") must be subject to a comprehensive environmental impact assessment before it
is implemented. (e) The flightpath plan must be subjected to a monitoring and revision process that has genuine community input from all affected areas. 3. No 'Second' Sydney Airport
(a) No airport should be built at either the Badgery's Creek or Holsworthy sites. (b) The Greens oppose any new airport development within the Sydney Basin airshed.
(In accordance with the 1991 NSW
Government Summit on Air Quality and the September 1995 statement of the Australian Medical Association.) 4. Replacement Airport Outside Sydney
(a) An airport to replace KSA must be built outside the Sydney Basin airshed. (b) A site selection and assessment program must begin immediately to find a suitable location outside the Sydney Basin
airshed for a complete replacement airport (not a "second" airport). (c) Stringent environmental and social criteria must be laid down to assess the sites. This would include accessibility by
rail. (d) A new agency should be set up within the Federal Department of the Environment to conduct Environmental Impact Statements into each shortlisted site. Public inquiries should be part of each EIS
process; the community should be given information in an understandable form; and there should be a mechanism to allow appeals on the merits of each EIS. 5. Rein in the Growth of Air Travel (a)
Demand management should be used, including removal of tax deductibility for business air travel. (45% of domestic air travel is "for business" and is therefore tax deductible).
(b) The use of KSA as a hub for air routes must be discouraged.
(27% of all air passenger movements at KSA are accounted for by people who are in transit or transfer - i.e. they do not leave the airport
by surface transport). (c) Tax incentives to promote communication strategies such as teleconferencing should be implemented to promote alternatives to business air travel.
(d) Intercity rail links must be upgraded and integrated.
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