EIS Noise Analysis Skewed to Favour Development of Western Sydney Airport

Blue Mountains Greens Western Sydney Airport EIS Submission [December 2015]
Submission for: Western Sydney Airport Draft Environmental Impact Statement
Topic: ‘Noise Analysis’

EIS Noise Analysis Skewed to Favour Development of Western Sydney Airport

Initially the EIS position on aircraft noise seems to allow for a wide scope of subjectivity
in understanding ‘noise impact’: The pattern of noise impacts that would result from operation of the proposed airport is complex, and depends on time of day, season, airport operating modes, weather conditions and potentially other factors. (EIS Vol 2 ‘Noise’ p19)

It is self evident that a person living at, for example, Sion Place Blaxland, where there is no ‘normal’ external noise except the croak of an occasional frog, i.e., for the most part ‘total silence’, and another person living at The Avenue, Warrimoo, where there is already heavy vehicular traffic noise from Coal Trucks and other semi trailers, as well as Rail Freight trains squeaking and rumbling round the ‘Warrimoo Bends’, and repeated sirens and ‘care’ helicopter flights into the bargain – it is self evident that these two addresses would have totally different reactions to the 200 (2030 figures) flights a day operating between 4,000 and 7,000 ft. above their heads.

The former would have their peace utterly shattered by aircraft noise they had never experienced before, that is, they would suffer a ‘traumatic contrast’, a ‘noise shock’. The latter could well argue that 24/7 aircraft noise on top of their current wallpaper din is the ‘straw that breaks the camel’s back’, and that they had already made sufficient sacrifice ‘for the good of the economy’ and for ‘progress’, given that they had originally moved to the Blue Mountains to escape urban noise and enjoy peaceful communion with a natural environment.

The EIS does not consider the different subjective circumstances of Airport Noise victims, and offers nothing to alleviate their fundamentally altered lives. At least roads and railways can potentially have ‘walled corridors’ to reduce impact; overhead noise coming from a multitude of directions is another matter. Simply asserting that ‘technology will solve noise impacts’ or relying on improvements in future aircraft is hardly ‘scientific analysis’.

Using pseudo-scientific data the EIS seeks to squeeze noise impact into a ‘One Size Fits All’ formula based upon ‘decibel levels’ on the dBA scale. It thus arrives at a sliding scale of noise impact based upon distance from the Airport and height. Most residential areas subject to fly-over noise lie in the 32km-16km radius and thus, according to the EIS, suffer noise between 54 and 75 dBA from take-off and landing 747’s and Airbus 320’s. (see Fig. 01-2 p.22)

This is then compared to a dBA scale which shows 70 decibels as the infamous “passing car”. It does not suggest the distance of the car from the listener, how long its passage lingers, the type of vehicle (V8 or 4 Cylinder, sedan or 4wd), or the speed at which it is travelling.

It is important to note, at this stage, that in the EIS itself there is no statement to say that this level of noise is acceptable for humans throughout a 24 hour day (especially at night) or that it is non-intrusive for humans – it simply states that a mere “1500 residents” close to the Airport may be adversely affected by the noise because their dBA levels are beyond 75.

There are a number of caveats that must be applied to this simplistic model. First, the altitude of the planes is measured from the ‘runway level’, which is pretty close to Sea Level. Thus, for communities such Blaxland-Warrimoo, over which most landing descents occur and which are both between 200 and 300 metres above Sea Level, one would need to deduct 1,000ft from the given height: 7,000ft becomes 6,000, and 4,000 becomes 3,000 and so on.

Second, depending on weather conditions, planes in descent are notoriously inconsistent with their altitude: to place them all in the same constant bracket is misleading. Many may be above the designated 7,000ft and descend faster, others may be at 3,000ft and linger longer at that altitude.

Third, given that the above events may well provide significant variations in flight altitudes, added to the fact that decibel levels do NOT increase on a simple arithmetic progression, but instead DOUBLE in loudness/impact EVERY 10 DECIBELS, one can appreciate how much 24/7 overflight noise may interrupt the activities of affected residents. One might hear a jet above at 54 dBA one minute, and another 5 minutes later at 74dBA. Clearly, the hearing differences between 60 and 70 dBA are crucially different between top and bottom of the decile.

Fourth. The American ‘Federal Aviation Authority’ (FAA) sets a maximal Aircraft Noise limit of 65dBA, beyond which aircraft noise is “…incompatible with residential communities”. Why is this standard not applied to Western Sydney Airport nor acknowledged in its EIS? Are Australian standards less stringent than those of the United States? If so, where does this place other ‘estimate’ criteria based on ‘Australian Standards’ elsewhere in the EIS?

Fifth, the assumption that flights above 10,000ft have ‘minimal impact’ upon human or animal hearing is more than questionable. Anecdotal evidence already being compiled and attested in the Upper Blue Mountains, (and no doubt forwarded to Air Services Australia as a multitude of complaints) at places such as Wentworth Falls, Katoomba and Lawson allude to many planes purportedly flying above that altitude being singularly intrusive with their noise. This clearly points to a total oversight of the subjective factors in noise impact, or a massively flawed model overall.

Finally, and most importantly, the dBA scale is an inadequate measure when applied to aircraft noise. It is a construct that eliminates extreme high and low sound frequencies to arrive at a ‘safe’, statistically ‘average’ criteria of sound on the human ear. It is rather like the judges’ scores at Olympic events such as Diving and Gymnastics, where the highest and lowest scores are eliminated to avoid corruption of the results. Nevertheless, the high and low scores ARE ‘there’, and they are part of the reality of that event, just as high and low frequencies exist in aircraft noise, and are quite crucial to the health of the listener.

Research revealing Low Frequency Noise (LFN) emanating from jet planes and other sources is injurious to health is plentiful (Leventhall,H.G. http://www.noiseandhealth.org/text.asp? 2004/6/23/59/31663; Oud, M., http://nl.linkedin.com/in/mireilleoud; Hodgen, K. web.mit.edu/aeroastro/partner/reports/ proj1/lfnreport-2007-001.pdf). All these suggest the human cochlear is damaged by exposure to LFN, especially among older people. Other illnesses such as heart disease, sleeplessness, and headache are also implicated in LFN, which is a sensation more ‘felt’ than ‘heard’. This frequency is not picked up by the dBA scale but better measured by a “dBC Scale” which does include extreme frequencies – something not used nor referred to in the EIS.

The EIS goes on to deal with two hypothetical ‘constructs’: the ‘Australian Noise Exposure Forecast’ (ANEF) and the ‘Australian Noise Exposure Concept’ (ANEC). Both were supposedly developed “…after a period of public consultation” (Vol 2 p 27) but there is no clear indication of the parameters of ‘those consulted’. They set up a chart that allows development of all manner of residential and commercial buildings as long as they fall under some magical noise tolerance number of “20” or “25” – this is convenient because Deparment of Infrastructure maps indicate massive residential and commercial/industrial development earmarked up to and further northward than Bringelly Road, right up to the near vicinity of the Airport.

In brief, the EIS admits the ANEF is a forecast and the ANEC is a concept. Therefore the figures used in Figure 10.2 p.27 are fallacious as they are nothing more than an ‘estimate’, ‘indicator’ or, in plain-speak, a ‘guess’ devised for development purposes. The figures can’t be held to, proven or applied. They are not like a speed limit or height limit on a road, and have no legal application – they simply allow developments to ‘indicatively’ occur if it is ‘appropriately ready’ to be near an Airport. How convenient.

So now to the myth of the mere “1500” to be impacted by severe aircraft noise. It is clear from the EIS Noise ‘Summary’ that this figure is a massively underestimated fiction:

For the loudest aircraft operations (long-range departures by Boeing 747 aircraft or equivalent), maximum noise levels over 85 dBA would be experienced at a small number of rural residential locations (this is the ‘1500’) close to the airport site in Badgerys Creek. Maximum noise levels of 70–75 dBA could be expected within built-up areas in St Marys and Erskine Park as a result of such worst case operations. The Boeing 747 is, however, being phased out of passenger services by most airlines. Maximum noise levels due to more common aircraft types such as Airbus A320 or equivalent are predicted to be lower at 60–70 dBA in built-up areas around St Marys and Erskine Park, and over 70 dBA in some adjacent areas to the south-west of the airport site, such as Greendale.

(Vol 2 p.19)

From their own maps, the EIS is vastly understating the impacts on surrounding residential areas such as Erskine Park: Horsley Park, St. Clair, Colyton and St. Marys also lie in the path for the ‘normal’ take-off noise distance of 70-80 Dba. (i.e. between 8 and 16 kms from the Airport as the crow flies). The suggestion that Boeing 747’s are being ‘phased out’ as passenger liners covers the fact, revealed in EIS charts showing ‘freight movements’, that 747’s become the prime freight carriers once they have depreciated beyond passenger usage. When old, their noise is worse and their air pollution more odious. The suburbs mentioned already contain tens of thousands of residents, several schools, recreational parks and shopping centres.

That is not all. Hundreds of thousands more home-buyers and businesses are destined to be settled in the ‘Northern Road’ corridor beyond Oran Park and Harrington Grove, within a 10-20km radius of Badgerys Creek inside the next decade. Will these people know what they are getting themselves in for, or will they fall for the ANEC/ANEF ‘appropriate development’ guidelines mentioned earlier?

Such ‘Airport Settlers’ will no doubt confront the same conundrum recently encountered by Tullamarine Airport in Melbourne. When originally developed as an Airport, Tullamarine was set in a Greenbelt paddock reasonably distant from residential settlement, but subsequent land releases brought housing quite close to the Airport itself and now an extra runway threatens to bring excess noise upon their heads. They are therefore demanding a curfew from Warren Truss and the Victorian government to mitigate their plight (‘The AGE’ August 3rd 2015).

Regardless of the numbers in the immediate vicinity of Western Sydney Airport, the EIS does not adequately address the absurdity of the present curfew situation. If, as the EIS argues, modern aircraft now and into the future are hardly noticeable to surrounding residents, why isn’t the curfew on Kingsford-Smith Airport lifted? If on the other hand there is some justice in the argument that Inner City residents suffer from aircraft noise and deserve a curfew and noise mitigation subsidies, why should they receive the curfew and the residents of Western Sydney not? Whether they are 16,000 or 500,000, should they not receive the same treatment on the basic principle of equality? Be given a ‘fair go’?

In reality, it is clearly political expediency and profit motive that rules this debate and once again the people of Western Sydney suffer the insult of a ‘cheap and nasty’, second-rate Airport… as Alan Joyce recommended, “not gold-plated”.

One such contemptuous lack of consideration lay in a short and abrupt message regarding ‘other aircraft’:

The proposed airport would be developed to address aviation passenger demand and does not make specific provisions for general aviation facilities, which may include helicopter flight support and tourist flight facilities. The potential noise impacts of general aviation operations such as helicopters are not assessed in this EIS.

(Vol 2 p22)

There is no doubt that in its bid to maximise profit from the Western Sydney Airport, its private owner (probably Sydney Airport Corporation) would seek to encourage tourist flights across the Blue Mountains Heritage Site. Past experience of such helicopter and small craft flights when fires and news events occur provides evidence that they fly loud and low, and their operations could become a major intrusive noise factor emanating from the Airport. Yet the EIS commissioned to provide information as to the projected levels of ‘other aircraft activity’ as well as the possible future of Bankstown Airport (reputedly the busiest airport in Sydney) has not bothered to research it.

Ultimately, there is one person in Australia who may be regarded an authority in the field of ‘Airport Noise’ because every day he fields the plethora of complaints about its impact upon residents around airports across the length and breadth of Australia. He is the ‘Aircraft Noise Ombudsman’, appointed by the Commonwealth Government. His name is Ron Brent and he wrote:

…aircraft noise… is very different from the noise created by railways or busy roads. The key differences are that aircraft noise will reach a much wider area, cannot be shielded by barriers along the route, and is not restricted to a narrow and predictable path…Noise from an aircraft in flight does not fall in a straight line, and is not limited to those directly under the aircraft. It spreads widely over an area that gets wider as the aircraft gets higher. It also gets quieter as the aircraft climbs. This means that the noise can reach more people once the aircraft is further from the airport, yet it can be many kilometres from the take-off point before the noise stops becoming intrusive for most people.

(Ron BRENT: ‘The Truth About Aircraft Noise’ 2013 p.2)

From anecdotal evidence assembled since the Western Sydney Airport was announced, gleaned from hundreds of people from various corners of western Sydney who already experience overflying aircraft, Roy Brent’s comments are far more accurate than the ‘gilded lily’ picture provided in the proposed Airport’s Environmental Impact Statement.

In fact, the lives of many hundreds of thousands of residents throughout the western Sydney basin and the Blue Mountains will be adversely affected by noise intrusion: at parks where families are trying to relax in peace, or when they must turn up their television to hear it adequately, or when their sleep is broken by a distant growl in the sky – the constant ebb and flow of low flying aircraft, in effect, the long term DOUBLING of airflights over Sydney, will inevitably have a profound and widespread impact, and yet this whole project is unnecessary.

Please reconsider this hastily cobbled plan to foist a second airport upon the citizens of western Sydney. Commence immediately the construction of a High Speed Rail line to Melbourne so that people can arrive there just as rapidly, but in comfort and without the nightmarish consequences accompanying an airport. Build us something the people of western Sydney can be proud of, with just as many jobs and greater long-term benefit.