Environmental Impact Statement: Flawed Rationale

Blue Mountains Greens Western Sydney Airport EIS Submission [December 2015]
Submission for: Western Sydney Airport Draft Environmental Impact Statement
Topic: ‘The Need for an Airport?’

Blinkered Rationale: There is no ‘Need’ for a Second Airport

The Western Sydney Airport EIS commences with an utterly blinkered justification for another aviation stinkhole in Sydney when there is one very viable and environmentally justifiable alternative in High Speed Rail already planned and able to be constructed in the same time-span as Badgerys Creek.

The EIS provides 5 basic reasons why the second airport is ‘needed’ i.e. ‘necessary for residents to endure’:

  1. Growth in aviation passenger usage over the past two decades
  2. Demand pressure upon present facilities: Kingsford Smith Airport/Mascot
  3. Growth of population in Western Sydney with transport needs
  4. A boon to the economy of Sydney/NSW/Australia via tourism
  5. Provision of badly needed jobs for the western Sydney region

This submission will analyse each of these justifications and demonstrate the antiquated logic behind them, obviating the need for the principal alternative being adopted internationally: High Speed Rail.

1. Growth in aviation passenger usage over the past two decades

The EIS openly admits its main purpose on p.34 being the ‘need’ driven principally by the increasing demand for aviation services in the Sydney region and goes on to provide a host of statistics to show increasing passenger movements at Mascot, with the underpinning reasons given as increasing wealth among travellers, especially Asian travellers, and falling costs of aviation fares driven by cheap fuel, more efficient aircraft and wider competition among low-cost airlines.

At no stage does the EIS consider pitfalls in the ‘exponential rise’ of aviation usage, central among these being the reliance on carbon fuels (kerosene, benzine, jet gasoline, diesel etc) for future growth in the aviation industry, and the consequent pending possibility of ‘peak oil’ and/or a sudden increase in carbon fuel pricing due to diminishing supply over time. The much touted alternatives of sustainable crop-fuels and hydrogen would take decades to introduce beyond 2030 and would be considerably more expensive than the current pricing structures.

Nor does the EIS consider the possibility of burgeoning business and personal connection over the Internet, an avenue of communication vastly cheaper than long-distance aviation travel which precludes the need to carry out business deals ‘in person’ and increasingly allows people to experience international connections in ever more meaningful ways.

The EIS also overlooks the decline in regional air travel throughout Australia. Once a growth industry, a plethora of local/regional airlines have come and gone because the projected ‘markets’ for such flights in small country towns have not been sustained during difficult times for rural Australia. The ‘Fly-In/Fly-Out’ mining ventures are now in decline because the economic conditions do not suit – something for Badgerys Creek proponents to ponder should the Chinese economy shrink further over future decades.

The oft repeated tourist ‘pressure upon Kingsford Smith/Mascot’ mantra can be dealt with summarily with the statement from Sydney Airport management itself which confessed it can “…handle the doubling of passenger movements to 74.3 million by 2033.” (Source: Daily Telegraph 28-04-2015)

At present, even considering the continued existence of the curfew, KSA Mascot is operating at 60% capacity. The “massive increase” in passenger numbers since the Howard government abandoned the previous attempt to impose a second airport in 2000 has resulted in a mere 3% increase in flights overall.

2. Demand pressure upon present facilities: Kingsford Smith Airport/Mascot

One of the misleading aspects of the many figures quoted in the EIS, ‘tourist numbers’ and ‘visitors to NSW’ is the fact that Domestic and International passenger movements are often conflated into the one category. This is because everyone generally concedes that overseas trips to and from Australia necessarily rely on aviation (99%) – so we tend to forget the domestic situation.

When we examine the passenger movements in and out of KSA Mascot however, a different picture emerges…

Passengers at Mascot (in and out)

The stunning impression from this bar graph is clear: by far the busiest air route in Australia is the Sydney-Melbourne route – reportedly the second-busiest air corridor in the world. It takes 25% of the air traffic to and from KSA. The top 5 routes are domestic, and three of those five are along the Eastern seaboard. If we include Coffs Harbour, Canberra, Ballina, and Albury with  those other three destinations (Melbourne, Brisbane, Gold Coast) we are approaching 17 million of 24 million passenger movements for 2015, or 70%!

The problem of ‘tourist pressure’ on Sydney Airport, therefore, isn’t international tourist numbers at all, but domestic travellers – travellers who have been channelled into aviation or vehicular car transport as their only ‘rapid transit’ options, when there is a mode of travel equally as rapid (almost certainly quicker), safer, vastly more comfortable, and which carries zero carbon emissions in its operation, namely, High Speed Rail.

Dismissing the 2013 HSR proposal which quoted an overall cost of $114b for completion in 2030 as ‘too expensive’, the EIS made no effort to update more recent quotes nor examine the exponential strides in HSR construction made in China over the past 5 years. During the past five years China has laid 16,000km of High Speed Rail and networked a country the same size as Australia and with even greater logistical difficulties. (Wikipaedia, 2015)

The spread of high-speed rail has forced domestic airlines in China to slash airfares and cancel regional flights. The impact of high-speed rail on air travel is most acute for intercity trips under 500 km (310 mi). By the spring of 2011, commercial airline service had been completely halted on previously popular routes such as Wuhan-Nanjing, Wuhan-Nanchang, Xi’an-Zhengzhou and Chengdu-Chongqing.  Flights on routes over 1,500 km (930 mi) are generally unaffected. As of October 2013, high-speed rail was carrying twice as many passengers each month as the country’s airlines.

(Wikipaedia, 2015)

Local HSR research company, ‘Beyond Zero Emissions’ (BZE), has revised the cost of construction of the Eastern Seaboard rail line to $84b, but that is the total length of the line from Melbourne-Sydney-Brisbane and involves full track construction, project management and rolling stock of some 87 trains operating in and out of Sydney every 10 minutes in peak times.

If the Sydney-Melbourne link was built as the first stage, the cost would reduce to $44b, with a further $6b taken off if the line entered via the ‘back door’ of Sydney, at Badgerys Creek.

Clearly, the outset costs of HSR are higher than the projected Western Sydney Airport bill of $6-8b, but considering the long-term costs of air pollution, carbon emissions, health care, water purification, angry residents and vehicular traffic chaos, a large initial outlay seems much more judicious. According to BZE, carbon emissions created in construction would be offset within five years.Clearly, the outset costs of HSR are higher than the projected Western Sydney Airport bill of $6-8b, but considering the long-term costs of air pollution, carbon emissions, health care, water purification, angry residents and vehicular traffic chaos, a large initial outlay seems much more judicious. According to BZE, carbon emissions created in construction would be offset within five years.

Therefore, using HSR would mean 3 million fewer passengers using KSA Mascot in 2030, and a reduction of 82 flights per day, taking all “pressure” off Sydney’s major international airport and providing an exciting new alternative for domestic and international travellers wishing to see more of regional Australia.

3. Growth of population in Western Sydney with transport needs

It is undeniable that western Sydney’s demographic explosion will continue into the next two decades – particularly focussing on the ‘Northern Road’ corridor running from Campbelltown/ Narellan through to Badgerys Creek, Penrith-Castlereagh and then on to Richmond-Windsor. One of the coy secrets of the EIS is that land denoted as ‘South West Growth Centres’ currently containing Oran Park and Harrington Grove, is earmarked for urban development northward beyond Bringelly Road and within 5kms of the proposed WSA at Badgerys Creek… (see map below)

Western Sydney Airport Site and Infrastrucutre

Under this scenario it is certainly feasible that the ‘Northern Road Corridor’ would carry an extra 500,000 residents and that it will provide most of western Sydney’s demographic growth over the next two decades. However, these people are being ‘locked in’ to a vehicular traffic nightmare and are being offered a ‘maple-leaf’ piece of infrastructure to satisfy their transport needs – an airport.

A Deutsche Bank report (businessinsider.com.au July 8 2015) found that forecast passenger numbers from the region for Badgerys Creek were far too ambitious. Western Sydney, with a current 2015 incomes average below $50,000 a year, would not supply strong regular users of an air travel service at WSA, which would have to be subsidised for at least a decade if it was to survive.

Proposed and much touted roads infrastructure surrounding the airport would do nothing to improve life amenity for residents of the Northern Road Corridor, since expansions of the Northern Road itself, Elizabeth Drive (‘M-12’) and Bringelly Road all lead to established Motorways (M-4 and M-5) that are already becoming ‘car-parks’ moving commuters to the CBD and their destinations at a morbidly slow average rate: more roads – more vehicles – more accidents – more injuries and deaths (Source: ‘22% Rise in Road Fatalties‘ ABC News 04-02-2015). The lack of a rail link, even of ‘slow suburban rail’ (e.g. Leppington-Badgerys Creek-St. Marys) does not help the situation, but certainly would not solve much even if it were provided.

Compare the demographic facts above with the following: 60% of Australia’s population resides within 50 kms of the proposed High Speed Rail route – that’s more than 13 million people within an hour’s access to rapid transport all along the South-Eastern zone. 46% of all of Australian regional travel lies within this corridor!

Can we begin to break out of the fixation of ‘big cities’ being fed by big airports and start to rebuild the beautiful regional zones around Wagga, Albury, Taree, Port Macquarie, Grafton and Lismore, both as unique ‘production zones’ as well as being international tourist destinations in rural Australia? There is far too much population pressure on the Brisbane-Sydney-Melbourne triumvirate and insufficient attention paid to regional amenity.

Meanwhile, the residents of western Sydney might be more appreciative if $6b of NSW government revenue was spent on finding a rapid transit route (‘bullet train’?) tunnel from Badgerys Creek to the CBD non-stop, within 30 minutes. It would surely allow them to feel more a ‘part of Sydney’ than having to endure a second rate stink-hole noise-box such as another airport, and endure traffic for between one and two hours as they do now.

4.  A boon to the economy of Sydney/NSW/Australia via tourism

The EIS simply has NOT explored the supposed ‘tourist benefit’ of an airport located at Badgerys Creek, some 50kms from Sydney CBD. There are many tourist numbers and dollar figures quoted but none relate to any specific advantage to the location of Western Sydney Airport. The EIS does, in fact, reassert that…

Sydney (Mascot) Airport is Australia’s busiest regular public transport airport and will continue to be the major focus for international and domestic airlines operating in and out of Sydney.

(EIS Vol 1 p.107)

Passengers do not “decide” the landing location of their booked flights, airlines do. But airlines must respond to complaints, and to ticket demand. If any foreign tourist had their choice of flight into Sydney, they would surely prefer to land near the major hotels, the Harbour Bridge and Opera House, Bondi beach and all the other ‘tourist sites’ of the CBD. That is why it is a ‘CBD’ in the first place. They would not prefer, after a long endurance flight from Europe, the USA or China to land at a place where there is a further 1-2 hour taxi journey to that self-same CBD – this would lead to complaints.

Proponents of the Western Sydney Airport need to beware the type of excessive optimism that drove authorities in Montreal to direct airlines to use the new (in 1975) ‘Mirabel Airport’, 55kms from Downtown Montreal and lacking any linking rail infrastructure, instead of the older, closer, and more popular ‘Dorval Airport’. The result was an overall decline in visitors to Montreal, who now preferred to stop at Toronto, and a general decline in aviation usage at both Dorval and Mirabel airports, the latter being the biggest loser. The whole project was an abject failure due to poor resourcing at the outset.

There is no guarantee whatsoever that Western Sydney Airport will be a success simply because it is plonked amidst a big population. Other factors – not in the least connected to population or ‘jobs’ determine tourist choice and behaviour. The EIS indulges in a great deal of wishful thinking.

5. Provision of badly needed jobs for the western Sydney region

Unemployment, especially youth unemployment, has been a persistent feature of life in western Sydney ever since its rapid expansion in the 1960’s and 70’s. Urban housing tended to develop way ahead of transport and industrial infrastructure, so that job-seekers generally had to head eastwards to secure employment, by car. Thus most announcements designed to curry favour relating to Western Sydney incorporate the lure of ‘jobs’ – Badgerys Creek Airport is no different.

The upside claim of the EIS of 61,000 ‘direct and indirect jobs’ (out of an extra population of 500,000, remember) is already challenged by a (still optimistic) Deloittes report for the Business Chamber of Commerce which forecast 46,000 ‘direct and indirect jobs’… All, actually, quite problematic stargazing which depends entirely on that most unpredictable mechanism: ‘market forces’. We are told that Western Sydney Airport will not survive in a competitive profit-making environment with a curfew, meaning it must have a ‘market advantage’. Surely this is an alarm bell ringing.

In its first five years BCA will primarily be a freight airport. Freight aircraft are the oldest and loudest – will Badgerys Creek survive its first five years as a reputed stinkhole and emerge as a swan of International Travel Excellence?

In this context it is well worth studying the experience of Melbourne’s ‘second airport’, which has been deliberately overlooked by proponents of WSA for very good reason – the comparisons are very close, indeed. A similar “…world class centre of Aviation Excellence” has been operating out of Melbourne’s ‘Avalon Airport’ since 1997 and like Badgerys Creek is around 50kms from the CBD and without a rail link. Despite the fact that Melbourne is growing faster than Sydney and Avalon is located near a major industrial centre at Geelong, it is struggling to survive, increasingly as a freight airport.

In 2015, the Victorian government was obliged to supply a $12m ‘lifeline’ and the LinFox Group (its owner) a further $14m to entice ‘Jetstar’ to continue landing there. ‘Virgin’ has already gone and QANTAS showed its faith by closing down its maintenance workshop at Avalon and moving to Singapore. Likewise Western Sydney Airport will also require either a $1b government subsidy or extra passenger levies to maintain its first 10 years’ operations. (Source: Deutsche Bank Report, 2015) The ‘direct and indirect jobs’ at Melbourne’s second airport are looking very insecure right now, and there is absolutely no evidence provided by the EIS to convince us that Badgerys Creek’s ‘market performance’ will be any healthier.

What kind of jobs? Mainly behind-the-counter retail, and transport-storage. Forget ‘high-tech’, ‘value-added’ jobs often mentioned as a sideways sweetener – these are already earmarked for Pymble, North Sydney and Pyrmont in the CBD, again, that’s why it’s the CBD. The Commonwealth Bank even abandoned Parramatta to head ‘back into town’! The buildings around Western Sydney Airport will be warehouses which connect to vehicular semi-trailer traffic – thus most jobs will be stacking, unpacking and storage, and automation will mean these will not be plentiful. QANTAS CEO Allan Joyce has enjoined Western Sydney Airport developers not to ‘goldplate’ Badgerys Creek – he wants it cheap, easy, and second-rate.


Basically, this airport is not ‘necessary’ at all. Multiple airport cities like Tokyo (36m), New York (24m), and London (8.5m) have populations way bigger than Sydney’s 5 million. The attempt to stampede the residents of Western Sydney and Blue Mountains into an ‘urgent need’ to develop a second airport at Badgerys Creek is political in its intent and its singular benefactors are the developers themselves – not just of the airport site itself, but of the massive urban surge happening around it.

As the process of this EIS is progressing more and more holes are appearing in the Swiss Cheese of the airport’s justification. The noise is not ‘minimal’, the air pollution and CO2 emissions are much worse than admitted and threaten everyone’s health, the infrastructure promised goes nowhere for the long suffering residents of Western Sydney, who will get little use from this airport, and much pain.

This submission urges the Western Sydney Airport authorities to cut their losses, invest taxpayers’ billions into long term solutions for their isolated and abused suburban amenity by beginning to build a High Speed Rail Hub at Badgerys Creek and provide a transport alternative that we can all be proud of.

Authorised by Andrew Blake for The Greens NSW, 1/275 Broadway GLEBE NSW 2037.