INTRODUCTION
Federally-leased airports in Australia are required to produce a Master Plan (MP) every 5yrs. This is effectively a blueprint for the future coordinated development of an airport over a 20yr period, with an emphasis on the first 5yrs. It includes information relating to forecast growth, airport terminals and facilities, runways and incorporates an environmental strategy.
National Aviation Policy White Paper: This Paper was released by the Federal Government 16/12/09 and its objectives formed the basis for policy directions, and administration of regulation of aviation in Australia, which included; Reinforce the importance of minimising aviation’s negative impacts on the environment and communities. The goals included; A response approach is required to managing the environmental impacts of aviation.
Airports Amendment Bill (Dec.2010): The purpose of this Bill was to amend the Airports Act, giving effect to the Government’s policies contained in the Aviation Policy White Paper, particularly in relation to the planning and regulatory framework and requirements for Airport MPs and MDPs. The key changes to the Legislation included; Require that the MP explain in detail proposals for the first five years of development outlined in the twenty-year Airport MP, including among other things impacts on flight paths, noise and activity.
Gold Coast Airport MP 2011:“This 2011 MP specifically focuses on the development requirements over the next five years” (pg.16).
AIRPORTS ACT
Part 5, Division 3, Section 71-Airport Master Plans; specifies matters that must be set out in each MP for an airport.
(2)(c) – the airport-lessee company’s intentions for land use and related development of the airportsite, where the uses and developments embrace airside, landside, surface access and land planning zoning aspects;
The ILS development footprint and widening of the runway strip is not identified in the Gold Coast Airport (GCA) MP – 7.0 Aviation Development, 5yr & 20yr Airport Development Plan (S/7, fig.7.2/7.1). GCA’s aviationdevelopment on the NSW Crown Reserve for Public Recreation/Conservation is not identified in the MP Land Use Plan (S/6, fig.6.1)
(d) – an Australian Noise Exposure Forecast (ANEF) for the areas surrounding the airport;
The MP provides no ILS associated ANEF over land of the new flight path, nor does the MDP provide an ANEF for the new flight path (the ANEFs provided in the MP/MDP are for the existing flight paths). The MDP states, “the assessment has found that the impact is considered to be significant due to the new flight path creating an increase in noise exposure in some areas” (pg.88).
An ANEF is the forecast of future noise exposure patterns around an airport. The noise impact assessment in the MDP has assumed the arrival flight data for 2012/13 – therefore already outdated.
The forecasts indicate a growth in aircraft movements per annum to more than double by 2031 (MDP pg.25). This has not been factored into the MP/MDP noise exposure.
Doubling the width of the runway strip brings it in line to the proper standards required by CASA for a Code 4E aerodrome. This will increase the operational capacity for larger long-haul aircraft as proposed in the MP (pg.85). This has not been factored into the MP/MDP noise exposure.
(f) – the airport-lessee company’s assessment of environmental issues that might reasonably be expected to be associated with the implementation of the plan;
The MP provides no assessment of environmental issues associated with the ILS development.
(g) – the airport-lessee company’s plans for dealing with the environmental issues mentioned in paragraph (f) (including plans for ameliorating or preventing environmental impacts).
The MP provides no plans for dealing with the environmental issues or plans for ameliorating or preventing environmental impacts associated with the ILS development footprint.
The MP does not identify the environmental features of the NSW Crown Reserve proposed for airport aviation development in the Environmental Strategy (S/13, fig.13.2).
Division 4, Section 91-Major Development Plans (MDP);a MDP is required for each major development at an airport which must be consistent with the final MP for the airport.
As detailed above the ILS MDP is NOT consistent with the final MP 2011 for GCA as required.
Airports (Environmental Protection) Regulations: Part 4 – Division 2, 4.04 General Duty to Preserve; (1)(b) there are no adverse consequences for (i) a species or ecological community listed as threatenedunder the EPBC Act. Division 3, 4.06 Offensive Noise; General duty to prevent offensive noise.
Airservices Act: Part 2, Division 9 – Manner in which ASA must perform its functions;2 (1) must exercise its powers and perform its functions in a manner that ensures that, as far as practicable the environment is protected from (b) the effects associated with the operation and use of aircraft.
CONSULTATION
Public Notices in newspapers in the area advising of the draft MDP for the ILS at GCA and seeking feedback during the public consultation period stated, “The ILS will assist aircraft landing in low visibility conditions and reduce the number of flights that are unable to land at Gold Coast during poor weather.” TheANACC and CACG meetings were advised the installation of the ILS was “for the purpose of improving the reliability of landings at GCA in adverse weather conditions.”
The formal notices and meetings have seriously misled the public and indeed relevant authorities of the true intent of use of the ILS at GCA. The real risk now exists that the lack of proper transparent information has undermined the opportunity to understand the full extent of the use of the ILS proposal and therefore be properly informed to provide relevant comment.
While the focus of the MDP is also that the ILS is “to improve the reliability of landings in adverse weather conditions”it does identify that the ILS will in fact “be able to be used at ANY time at the discretion of the pilot”, also for pilot training and re requirements for international heavy jets (pg.26).
The MDP (7.4 The Public Comment Period) states, “a range of stakeholder engagement activities areplanned during this period which include: Public displays; Staffed public information sessions” (pg.113).
While a number of these occurred on the Gold Coast, neither occurred in Tweed where there is to be permanent/irreversible destruction and alteration of hydrological regimes of an areaof a NSW river system significantly impacting on the economy, environment and human communities.
Airport managers’ correspondence with residents stated that GBAS “would still require the same flight path as is currently proposed for the ILS.” This is totally contrary to the ICAO GBAS Implementation May 2013 document (i.e. pg.13) and ASA information.
MDP 2.3 THE EXISTING SITUATION
Table 2.2 Precipitation at GCA (Pg.21)/Figure 2.8: Average Diversions by Month (pg.22) – This section presents GCA’s case for the ILS re wet weather and number of diversions and is in fact seriously inconsistent with rainfall records at the southern end of the runway,Tweed Heads West.
i.e. Table 2.2 presents the mean rainfall (mm)for Oct. as 90mm – mean number of days of rain as 10.2 and Fig. 2.8 as 9 diversions (2nd highest diversions by month).
Rainfall records for the southern end of the runway for Oct. 2014 is 9mm (max. daily 3mm) over 4days; Oct. 2013 is 35mm (max. daily 11mm) over 5days; Oct 2012 is 14mmover 1day.
The number (50) of claimed diversions per year from GCA lacks credibility and proper formal information on the number of diversions for landings from the north, number of diversions for landings from the south and the number of diversions for other reasons needs to be provided and made available to the public. The proposed ILS will not assist aircraft landing from the south, during severe thunderstorms or high winds associated with cyclones/lows. The introduction of the RNP procedures at GCA last year has improved landing minima at the airport and this further discredits GCA’s claims of 50 diversions. Even GCA’s claim of 50 diversions per year from 35,000 arriving flights is a very low percentage from total landings and therefore does not add up in a business/economic sense, particularly when you put into the equation aircraft landings that will not be assisted by the ILS.
COBAKI BROADWATER (CB) – LOWER TWEED RIVER ESTUARY
The ILS development footprint is on the coastal lowlands of the Lower Tweed River Estuary (CB) on both Commonwealth land and the NSW Crown Reserve for Public Recreation/Conservation. Substantial earthworks, fill and entire clearing of vegetation (including estuarine saltmarsh/mangrove/EECs) of the 300m x 300m Localiser footprint is proposed to occur on the NSW Reserve along the shore of the estuary,within the tidal zone. Construction of an access road (wall) is proposed around the entire footprint (pg.15/16/61). The CB is a Class 1 Fishery (primary nursery) critical for the survival of commercial/recreation fishing industries that significantly contribute to the economy. The natural resources of this significant/sensitive NSW river system also support tourism and the maritime industry that significantly contribute to the economy also.
The MDP fails to identify the CB and its ecosystems as a Class 1 Fishery. The degree of harm to this critical fishery habitat from the Localiser footprint will be permanent and irreversible and direct consequential impacts to the CB and downstream estuary will be a long-term environmental hazard.
Removal of this NSW SEPP 14 Coastal Wetland is inconsistent with the aim of the policy to ensure that coastal wetlands are preserved and protected in the environmental and economic interests of the State. These wetlands also act as the lungs of the estuary, cleansing and rehabilitation its key function – vital for the sustainability of the entire system.
Removal of the vegetation from the crucial riparian area of this estuary negates the filter/buffer service of mitigating some of the effects from emissions of aircraft operations in such close proximity.
Changes in water diversion/velocity due to the erection of solid structures within the wetlands and the subsequent wash/scouring will impact severely on adjacent protected ecosystems. Further direct consequential impacts will be sediment deposition/increased turbidity within this estuarine system impacting on the life cycle of the aquatic habitat.
FLOOD MODELLING
Theproposed access road(wall) is around the entire footprint on the NSW Reserve including along the shore of more than half the last remaining floodplain on the east of the estuary.The footprint also includes substantial fill for the ground pad with a reflective surface for the Localiser signal.
The MDP withheldall information on the completed flood modelling undertaken and levels of fill for the road and ground pad preventing any opportunity to comment on this significant matter and therefore the decision maker not properly informed. The proposed development will substantially alter hydrological regimes, particularly the flood pattern of Tweed Heads Westurban area and will significantly impact human communities. The MDP also fails to give any consideration to sea level rise and storm surges. The road will create a damming effect upstream in high rainfall events.
ACID SULFATE SOILS (ASS)
The MDP acknowledges some areas had “relatively high levels of net acidity approx. 5 times the action criteria level” (pg.52) and makes brief mention of elevated iron levels in the Localiser footprint (pg.56).Works in the Localiser footprint will result in the exposure of soil from excavation for realignment of the drainage channels, trenching for provision of services,movement of heavy machinery (pg.53) and removal of topsoil (pg.78).
The MDP fails to identify the northern portion of the Localiser footprint on the NSW Crown Reserve was severely impacted from previous altered hydrology from construction of the Tugun Bypass (Pacific Motorway M1) resulting in oxidation of soils and associated acidification/heavy metal contamination of groundwater (g/w) i.e. PH lowered to 1.43, Iron increased to 1740mg/L, Aluminium 381mg/L east of the tunnel and PH 1.85, Iron 442mg/L, Aluminium 55.4mg/L west of the tunnel. With the genie now out of the bottle this legacy remains as a long term environmental hazard with ongoing discharge events. The tunnel is within the Localiser footprint now immersed in acidic g/w conditions and to further exacerbate the acidity will result in increased impacts to its structural integrity.
The tunnel has terminated upstream freshwater g/w and surface water (s/w) flows to downstream(northern area of Locasliser footprint). The access road (wall) around the entire footprint will totally terminate tidal inundation, impeding g/w recharge capacity, seriously exacerbating existing ASS conditions and mobilizing the movement of slugs of contaminated g/w, significantly increasing severity of ASS leachate and toxicity levels entering the estuary. The access road (wall) and substantial fill with reflective surface (impervious) will permanently/irreversibly alter hydrological regimes resulting in further oxidation of soils and formation of ASS in the southern area of the footprint.
The removal of the topsoil in the Localiser footprint (adjoining the estuary) immediately exposes the soil to air where these layers are most prone to producing sulphuric acid when disturbed due to a high incidence of pyrites which break down rapidly. The toxic mix of acid and the dissolving of aluminium and other metals in the soil are extremely toxic to the environment, particularly the aquatic ecosystem of the estuary. The close proximity to the estuary leaves no room for error and impossible to manage.
MATTERS OF NATIONAL ENVIRONMENTAL SIGNIFICANCE (EPBC ACT)
The ILS development directly impacts on listed threatened species (habitat), including 2 listed critically endangered migratory bird species protected under Jamba/Camba Agreements and listed ecological community with furtherdirect consequential cumulative adverse impactsto adjacent species/habitat. The listed migratory bird roost/foraging site on the NSW Crown Reserve is to be totally destroyed.
Despite the Cobaki ecosystems recognised for its national significance and previous developments in this area requiring EPBC approvals the ILS development is deemed not a Controlled Action!
The ILS Referral included false/misleading information. The Referral to the Commonwealth for ASA (an agency of the Commonwealth) was prepared by the same company that prepared GCA’s ILS MDP so raises serious questions re independence and conflict of interest. As outlined above the proposed activities of ASA (a Commonwealth agency) will have a significant impact on the environment.
CONCLUSION
The ILS development on the NSW Crown Reserve is exempt from any land use laws/regulations, approvals or any oversights allowing for a law to itself process for the permanent and irreversible destruction of a highly significant and sensitive area of the Tweed River system along with the cumulative and long term adverse economic, social and environmental impacts.
The MDP and process has lacked proper, adequate and transparent information preventing proper informed comment and therefore the decision maker being properly informed.
The MDP is not consistent with GCA’s final MP 2011 as required under the Airports Act.
In the year 2015 this development defies the most basic fundamental principles of ASS management and sustainable management of our natural resources and also disregards many legislations, policies and regulations. No consideration has been given to the sustainability of the concrete M1 tunnel.
Our rivers underpin the health and economy of our communities and are a priceless natural resource and asset warranting the greatest respect for their long term sustainability.
The negative and long term economic, social and environmental impacts of the ILS for the Tweed and Gold Coast communities far outweigh any perceived benefits of the ILS.
The ILS is old technology and GCA needs to upgrade with 21st century technology consistent with Government policy and for aviation of the future.
The profits of a private company and its shareholders should not be the overriding consideration when the consequences of the ILS will have enormous adverse economic impacts on other industries and GCA has other and better options for new generation technology.
from Lindy Smith to Greg.Hunt.MP@aph.gov.au
