|Blue Mountains Greens Western Sydney Airport EIS Submission [December 2015]|
|Submission for:||Western Sydney Airport Draft Environmental Impact Statement|
Health Impacts of Western Sydney Airport
Blue Mountains Greens make the following submission to oppose the proposed Western Sydney Airport at Badgerys Creek on the grounds that it unnecessarily threatens the health of people in the Blue Mountains and Western Sydney Regions.
A complete health risk assessment is not provided for water quality due to the limitations in water quality sampling (i.e. only 1997 data was available; no new data was collected for this EIS). Before this project can be approved a more complete assessment is required that includes a clear list of assumptions, a description of population affected, and an assessment of impacts on vulnerable receptor population groups.
The Summary and Conclusions for Appendix L2 Surface Water Quality notes:
Under the proposed Stage 1 Development conditions, with the proposed bio-retention basins in place, the results indicate that post-development loads would not be reduced to pre-development loads (NORBE), except for suspected solids.
Similarly, the results indicate that Stage 1 Development, with the bio-retention basins in place, would be unable to satisfy WSUD guideline targets, except for flows discharging from the site into Oaky Creek and Cosgroves Creek. For Badgerys Creek, where the percentage retention targets are not met, supplementary design would be provided during the detailed design, particularly in the residual catchment areas associated with Basin 2, Basin 4, and Basin 5.
The results indicate that for stage 1 development, ANZECC water quality objectives would not be achieved, except for suspended solids. This is not withstanding the general improvements in water quality concentrations relative to the existing environment, particularly in Badgerys Creek and South Creek.
The proposed airport is only 8km from Lake Burragorang, a water catchment area and 11 km from Warragamba Dam, providing drinking water for all of Sydney. The water catchment areas and these 2 bodies of water are vital to greater Sydney being able to function. Aircraft, whilst they rarely jettison fuel do have unburnt fuel emissions as they take off especially, and as they land. Under the right wind conditions this unburnt fuel will land on our water catchment areas and eventually wash into the dams. This is an oily substance that doesn’t mix with water and can’t be filtered out of the water before it enters the homes and businesses of all of Sydney. This substance contains known carcinogens that Sydney residents will wash in, water their vegetables with, cook with and drink.
The conclusions stated above raise questions that must be addressed to ensure the viability of these creeks and our water supply. It is unacceptable to simply say that guideline targets cannot be met.
Before this project can be approved the following areas of concern must be addressed and explained to the public for us to be allowed to comment. Our questions are:
- Will the proponent be putting in place additional controls (those recommended in the report or other controls) to ensure the water quality standards are met?
- Will an Environmental Protection Licence be issued from the NSW EPA during and post construction to monitor all of the likely water pollutants produced by the site?
- Why has the study only looked at a comparison with pollutants existing on site pre-construction? What about introduced pollutants such as hydro-carbons and the ways in which these pollutants will be controlled and monitored?
- The report does not detail the specific sources of the pollutants increased/ introduced to the site as a result of the airport’s construction and long term operations. This would be useful information to better understand how well the pollutants can be controlled i.e., does mitigation need to be reactive through water quality treatment or is there an opportunity to implement preventative control measures?
- Do you know any additions to water quality being affected by hydrocarbons?
- Why is there no data available to show the impacts on these valuable Sydney wide resources? If not from Australia, are there such studies from overseas countries where airports are located close to the water supply and catchment areas such as Warragamba and Prospect dams?
- If there are no studies, does it suggest that other countries would not place an airport within such a close radius to such water supplies?
The Independent peer review of the EIS undertaken for WSROC states:
Human health is a broad concept that encompasses more than the absence of disease. Health is a state of complete physical, social and mental wellbeing and not simply the absence of disease or infirmity and it is a resource for everyday life, not the objective of living; it is a positive concept, emphasizing social and personal resources, as well as physical capacities. This understanding recognises that though illness and disease (mortality and morbidity) are useful ways of measuring health, they need to be fitted within a broader understanding of health and wellbeing.
(WHO documents, 1946-1984)
The EIS has used the narrow Health Risk Assessment (HRA) rather than the broader Health Impact Assessment (HIA) that would address social equity and equality. An HIA has been found to be the more useful decision making tool by decision makers than the narrower HRA. In the Western Sydney area there are many people with below average socio economic status and they usually have poorer health outcomes because of this. A project of this size and its impacts on air quality, exposure to 24/7 noise, water quality, increased risk of traffic accidents, intergenerational equity, loss of recreational space, food security, worry over the impacts of the airport will impact more severely on these groups than community members with higher socio economic status. This makes the use of the HRA methodology incomplete and disadvantageous to large sections of the Western Sydney and the Blue Mountains population.
We request that that a HIA be conducted and the public allowed commentary on these results.
A study has shown that the airline and shipping industry will contribute 30% of global CO2 emissions by 2050. This gas is a key cause of climate change. The EIS tries to hide the impact this airport will have on climate change. It claims Greenhouse Gas Emissions from the Airport only amount to “0.1%” of Australia’s GGE’s in 2030, when this only measures Scope 1 and 2 emissions, that is, those vehicle exhausts on the grounds of the Airport and electricity bought from power companies for the functioning of its buildings. This is analogous to measuring the emissions of a coal-fired Power Station without the smoke, or a freeway without car exhausts!
Of course, when the greater than 2.5 million tonnes of CO2 emissions per year from Take-Off aircraft (i.e. ‘Scope 3’ emissions) are considered the percentage of GGE’s produced by WSA amounts to 2.2% of Australian transport emissions—quite a significant amount when one considers it is only one airport among many in the country. By 2060 the EIS Appendices admit GGE levels from Badgerys Creek will reach 21 million tonnes per year… staggering!
This is unacceptable as it is constantly in the news, especially recently with the world leaders’ agreement in Paris to reduce global emissions, that we need to limit the effects of climate change and yet this proposal is still forging ahead. Any additional greenhouse emissions should be avoided. This argument renders this airport proposal as unacceptable and should not proceed.
In the methodology there is discussion that air quality monitoring came from ambient monitoring stations in Liverpool, Bringelly, St Marys and Prospect among other sites. We note with interest that there are no monitoring stations at Badgerys Creek Airport itself. For a proposal that has been around since the 1970’s it should have been foreseen that air quality would need to be measured around the site. Obviously it wasn’t done so that negative impacts could not be reported.
In addition, risk assessment was for the population within a five kilometre radius of the airport. The EIS states that the residents of St Marys, Warragamba, Mt Druitt, Rooty Hill and Colyton all have low SEIFA scores and will be more vulnerable to the impacts of air pollution than other areas. However, these residents are outside the five kilometre risk assessment area and have been ignored. The air quality of the whole Sydney Basin will be affected by the proposed airport, since aircraft do not stop their engines when they pass five kilometres – gases still rise and fall, depending on their weight.
We request that a more detailed study of the air quality on the boundaries of the airport be undertaken before this airport is approved as well as providing a risk assessment of the population within a 40 kilometre radius of the proposed airport.
The Executive Summary states that there will be additional Human Deaths as a result of the development, due to the presence of Nitrogen Oxide in exhaust fumes (pages 34 and 35).This is completely unacceptable. How can a development be allowed that we know in advance will kill people?
The deaths appear to be confined to impacts from ozone. It is our understanding that PM2.5 and Air Toxics are likely to also cause significant health impacts, particularly in the long term.
We note this unsubstantiated statement on page 53: ‘Ongoing improvements in aircraft technology would continue to improve emissions from aircraft’.
What is this based on? What future improvement to aircraft engines is envisaged that will reduce output of toxic gases and particulates? For the distant future, it is clear that powering jet planes will be the province of burning carbon fuels—any substitutes are more than decades distant. Furthermore, the EIS estimate of a growth of eight times the level of Stage 1 (2030) by 2060 (Stage 2) would push all levels of the toxins mentioned into the ‘danger’ zone of current Australian Health standards – how can this be contained?
The Greens suggest it cannot, and so the WSA must be stopped, now.
Studies have shown that exposure to noise has the following effects
- sleep disturbance
- cardiovascular disease
- cognitive impairment
- hearing impairment
Upon assessing the number of flights we have ascertained the following…
In 2030: Flights as regular as 4 minutes apart at 5pm, longest reprieve of 30 minutes apart at 1am. 54 flights between 10pm and 6am.
In 2050: Flights as regular as 1 minute 22 seconds apart at 5pm, longest reprieve of 8 minutes 34 seconds apart at 1am. 145 flights between 10pm and 6am.
In 2063: Flights as regular as 46 seconds apart at 7am AND 5pm, longest reprieve of 7 minutes 30 seconds apart at 2am. 220 flights between 10pm and 6am.
This information is summarized below:
It is obvious that in 2030 with 54 flights between 10pm and 5am increasing to 220 flights in 2063 that there will be very little good quality sleep for the residents of Western Sydney and Blue Mountains. The EIS glosses over this fact and does not make the information readily available.
From these figures it is obvious that it will be impossible to gain a full night’s sleep. This doesn’t just apply to the people directly under the flight path it also applies to larger areas of the population as noise spreads and is perceived to be doubly loud at night as it is in the daytime. In addition the EIS does not take into account the very little background noise in many parts of Western Sydney and the Blue Mountains so any new sound such as airplanes or road traffic is more readily noticed and intrusive.
Studies have shown that even if you don’t fully awaken, noises at night trigger a fight or flight response. When the human body repeatedly experiences this response there is an increased rate of cardiovascular disease. The EIS states that people normally awaken up to 10 times a night. People won’t awaken up to 10 times a night with between 54 -220 flights between 10pm and 6am –they simply will not sleep properly at all! This will trigger both physical and mental health issues, since large parts of the population will not be getting the sleep their bodies need to regenerate and operate as efficiently as possible.
This raises the issue of social inequality. Residents under the flight paths of Sydney Airport are afforded a curfew under the Airport Curfew Act. This was for operational safety and noise abatement considerations as stated by Department of Infrastructure and Transport fact sheet on aircraft noise (http://sacf.infrastructure.gov.au/aircraft_ noise /files/Sydney_Airport_Curfew_Factsheet_June_2013.pdf). No such protection is being given to the residents of Western Sydney. Why does one section of the population deserve to be protected under legislation by a night time curfew and another section deemed not? They are being told by the Minister for Infrastructure they won’t get one. How can there be social equality when some of the most socio-economically disadvantaged people in Sydney are deemed to be undeserving of a curfew so that they must wear the health impacts of unrelenting aircraft noise? They don’t even deserve the consideration of safety mitigations. This attitude is totally unacceptable.
If aircraft are so quiet, a fact we dispute, then lift the curfew at Sydney Airport so that its capacity is increased so that this airport is unnecessary. If, as we suspect, aircraft aren’t so quiet and curfews should be imposed, then Western Sydney residents must be afforded the same protection as other Sydney residents and be given a curfew if this airport is built.
It is simply unfair that the disadvantaged population of western Sydney should be inflicted with additional health impacts on their lives that could be avoided. This then demands the economic case for Badgerys Creek Airport be re-evaluated.
We recommend that the economics section be redone to present the case for the airport to be operating under a curfew.
We also believe that many more people will be impacted by noise than stated in the EIS. Even at Windsor (32kms away), a 747 will be outputting noise at 65dBA. Many new developments have been slated for Claremont Meadows (Caddens), the new central ADI precinct, Marsden Park, which is under development and further slated as North West Growth. Thousands of homes will be going in under these paths. New development land values will crumble if they are under flight paths. In addition thousands of new businesses will be built in the Western Sydney Employment area. These premises will require extensive soundproofing due to their proximity to the proposed airport.
The EIS only models noise, it didn’t measure it. It is difficult for residents to truly comprehend the level of noise that they will be subjected to. Furthermore, these maps are deceptive as they only show noise directly under the flight paths, whereas jet planes will radiate noise and affect a broader area than just the range specified. The highlighted areas do not go below 60 dBA, at which conversation level noise will still be heard. This lack of colour does not signify not being able to hear a plane. The diagrams below illustrate the heights of aircraft on various points on the noise contours and the distance from the airport and the expected noise levels at those distances. These diagrams were taken directly from the EIS and some additional information included.
When looking at the flightpaths there are steep take offs and banking which increases noise levels. These more extreme manouevres don’t seem to be taken into account in the modelling, thus further making the diagrams inaccurate.
We ask that the residents of Blue Mountains and Western Sydney be subjected to the true noise levels that will be generated by aircraft. The whole 45% of Sydney air traffic needs to be flown for a period of two weeks over Blue Mountains/Western Sydney along the indicated flights paths as well as the existing flight paths used. During this test the planes should also fly close to the ground at the site of the proposed airport to simulate landing and take offs. If, as politicians are suggesting, ‘planes are so quiet, then there will be no complaints about aircraft noise to the Aircraft Noise Ombudsman and no voter backlash at the next Federal election. Whilst this will incur some expenditure it is small in comparison to the cost of the project. It is only fair that Western Sydney residents be given a small taste of the noise they will experience 24/7 before this airport proposal is signed off and approved.
Increased traffic accident risk
The statistics for travel to Sydney Airport is that 85% of all passengers travel by road. With the lack of a railway line this figure will 100% passenger travel by vehicles to the proposed airport. In addition there will be no fuel pipeline to the airport. This will result in somewhere between 30,000 to 100,000 extra fuel tanker trips per year on the roads of Western Sydney. In addition there are expected to be around half million extra residents in Western Sydney over the next 20 years. All these factors combined will result in massive traffic gridlock on Western Sydney’s already congested roads. It is also a fact that increased traffic brings about more traffic accidents.
While many of these traffic accidents won’t result in any significant or long term injury about 30% do. The EIS is lacking in any studies or modelling to determine the increase in traffic accidents, let alone those resulting in significant injury that impacts on the health and well-being of the accident victim.
Traffic accidents impact on productivity of workers. They may be unable to attend work due to injuries sustained in the accident or simply unable to get to work as public transport is non-existent or ineffective between their home and workplace.
The EIS should include an assessment of the following, the…
- increased risk of traffic accidents directly attributable to the increased vehicular activity due to the proposed airport
- increased risk of significant injury being sustained in said accident
- cost to our health system due to injuries sustained in an injury in point 2
- cost to business of lost productivity due to an injury in point 2
- loss of superannuation earnings and increased welfare costs if a person is injured to such an extent that they are unable to work ever again due an injury in point 2
- cost to businesses due to lost productivity because a worker is unable to attend work due to the temporary loss of their vehicle whilst it is being repaired and they have no alternative forms of transport to get to work.
Food security is an important consideration for many people. The Badgerys Creek area is agricultural land and is considered the “salad bowl” of Sydney. The building of this airport will result in the loss of the agricultural land and this very same “salad bowl”.
Besides adding an extra layer of worry for residents and thus a decrease in their emotional well being there is no consideration of the sustainability of losing valuable agricultural land providing fresh food on the outskirts of Sydney.
The EIS should address these issues before this project can be considered for approval by the respective Ministers.
Loss of recreational and green spaces
Many Western Sydney residents rely on areas such as Bents Basin and the Blue Mountains to access green spaces and recreational areas. Many residents enjoy a nature break that entails peace and quiet. The EIS mentions that there will be ‘minimal impact’ on these areas. There is no definition of what ‘minimal impacts’ means but the intrusion of aircraft noise 24/7 on these quiet areas is not minimal if you are going to enjoy nature, peace and quiet.
Many sports grounds used by local sporting bodies will be directly affected by noise from the proposed flight paths or whatever other flight paths might eventually be used. This means that practice sessions and weekend games will be impacted by noise. For many participants it will ruin their enjoyment of the game which could in the final analysis reduce their participation in sport, thus rendering an already obese nation even more unfit.
With rising levels of obesity and all its known health problems it is illogical to build an infrastructure that could result in people being less active. Health departments are always urging people to be more active and this airport could well produce the opposite effect. It is socially inequitable to deny the people of Western Sydney the quiet enjoyment of their sporting fields and green spaces that they have historically enjoyed.
We recommend that the EIS includes the impact on health and the attendant costs of the loss use of green spaces and recreational facilities.
The mitigation measures for air quality, noise and water quality are discussed in other chapters of the EIS. If you haven’t read the other chapters you would be unaware that any mitigation measures are proposed.
The EIS should include an outline of the above mitigation measures in the health section.
In addition mitigation measures that take into account the synergistic (combined) nature of the impacts on communities close to the airport should be developed. This would include consideration of impacts due to: noise, air quality, traffic, loss of amenity, changes in populations, perceived risk, and community identity.
The impact on health from the proposed airport is cumulative. The impact due to noise, air quality, loss of food security, water quality, loss of recreational peace, loss of green spaces and increased risk of traffic accidents should not be considered in isolation. The EIS should take a more holistic approach to the impact on health.
Lastly, it is obvious that the proposed airport will impact on the health of Sydney residents for the distant future. It is not a short term or an intermittent thing—it is constant, and it will continue to grow. This will result in higher medical costs for Western Sydney residents and the government. The government repeatedly tells the community that the health budget is burgeoning beyond budget constraints and it is only going to get worse as we have an increasing number of ageing people in our population. They have even gone so far to propose co-payments for health services that previously didn’t require payment by the patient to reel in these costs. This airport will only result in further blow outs in the nation’s health budget.
Let us act preventatively and reduce ill-health due to aviation forthwith, by building a ‘zero emissions’ High Speed Rail facility instead. It may be more expensive than a ‘cheap and nasty’ airport, but its long term benefits will be in more relaxed travellers and healthier residents.
It defies economic logic to say we have exorbitant costs in health care on the one hand and on the other, a different department pushing a proposal that will have significant long term additional costs for health. This reason alone should be enough to halt this proposal.
Authorised by Andrew Blake for The Greens NSW, 1/275 Broadway GLEBE NSW 2037.