Air Quality and Greenhouse Gases

Blue Mountains Greens Western Sydney Airport EIS Submission [December 2015]
Submission for: Western Sydney Airport Draft Environmental Impact Statement
Topic: ‘Air Quality and Greenhouse Gases’

Air Quality and Greenhouse Gases

Blue Mountains Greens make the following submission to the Environment Impact Statement public exhibition for the Western Sydney Airport at Badgerys Creek.

We hold grave concerns regarding this project and the threat it poses. We oppose Western Sydney Airport and are concerned that the proposed development is likely to have lasting adverse impacts on residents of Western Sydney and the Blue Mountains, their health, the region’s biodiversity values and its infrastructure, including Sydney’s drinking water supply catchments, as well as on the Outstanding Universal Value of the Greater Blue Mountains World Heritage Area (GBMHA),we believe that these adverse impacts have not been adequately considered in the Draft EIS.


An airport at Badgerys Creek will increase air pollution; spread intrusive levels of aircraft noise pollution through the Greater Blue Mountains World Heritage Area and residential areas; and increase the risks of illness in the western Sydney community due to this increased pollution. It will also intensify urban sprawl and add greatly to the traffic congestion of Western Sydney, as the draft EIS has failed to consider any detailed strategic planning for the kind of transport infrastructure that will be required to connect a new airport site. The entire content of the latest proposal appears to consist of a series unsubstantiated ad hoc statements gathered on the run after a last-minute decision to build an airport. It is based on a number of hitherto unsuitable proposals racked up over the last 6 decades. We oppose the proposed Western Sydney Airport for these reasons.

The draft Environmental Impact Statement (draft EIS) has come forward without adequate information to properly determine the proposal. On page 19 this is acknowledged: Decisions about airspace management… would be made by Airservices Australia and the Civil Aviation Safety Authority (CASA) closer to the start of airport operations. These decisions could require further environmental assessment processes, community and stakeholder engagement, and may be the subject of a future referral under the EPBC Act following detailed design. (EIS Vol 2 p.19)

Given that there is no possibility of framing appropriate conditions without adequate information about aircraft noise and air pollution arising from airspace management, the proposal should be deferred until this information is provided. This is confirmed on page 24 of the draft EIS where readers are advised that the Australian Noise Exposure Concept (ANEC) contours are likely to be used to define the development of Australian Noise Exposure Forecast (ANEF) contours once flight paths and operating modes are finalised and approved (our emphasis). The consideration of options for preferred flight paths and modes must be the core element of the re-exhibited draft EIS.

In effect, the draft EIS is the first stage of a staged proposal seeking approval of an airport concept plan that lacks detailed consideration of the environmental impacts that must be avoided, prevented and mitigated by appropriate conditions at the time of decision for the initial stage one airport proposal, not guesswork based upon ‘estimates’ and ‘possible flightpaths’.

The proposed airport concept plan must be refused consent as it lacks the necessary detail for approval. Options for flight paths, operating modes and orientation of the runway(s) must be considered in detail before stage one of the proposed Western Sydney Airport concept is determined. The best means of proceeding is to re-exhibit a further draft EIS with consideration of options, including a preferred option.

Alternatives to a second Sydney Airport must be examined in detail

The assumption in the draft EIS that there will be continued rapid growth in aircraft movements in the coming global low carbon economy is unlikely to prove correct. However, air traffic growth will peak due to major changes brought about by policies requiring a low carbon economy and adaptation to climate change. For example, in a few short years the National Broadband Network will provide communications technology that will dramatically push down demand for face-to-face meetings amongst senior management that currently generates a significant amount of domestic air travel demand. Digital technology will reduce domestic and to a lesser extent international air travel.

Furthermore, the feasibility of High Speed Rail was dismissed without any serious analysis.

Air pollution impacts on western Sydney residents

Two of the damaging toxins and carcinogens contained in Sydney’s air, benzopyrene and associated microscopic particles (Shabad, LM and Smirnov, GA, 1976, IARC Sci Publ, (13) 53-60, Aviation and Environmental Benzopyrene pollution), are copiously produced by large commercial aircraft. The draft EIS for the proposed airport predicts modelled exceedences for PM10 and PM2.5 particles in the longer term development, but does not consider benzopyrene generation that would be associated with the generation of these particles.

Air quality modelling for the proposed airport estimates for NO2 and PM2.5 pollution will exceed air quality standards when annual aircraft movements reach 63,302 per year. The draft EIS expects this will occur in 2030 (Katestone Environmental Pty Ltd, 17 November, 2015, Western Sydney Airport: Peer Review of Air Quality and Greenhouse Gas Assessment, prepared for Parsons Brinckerhoff, page iii and iv)

The biggest culprit of Sydney’s air pollution, car use (Current Air Quality in NSW – a technical paper supporting the clean air forum, 2010, Department of Environment, Climate Change and Water, Sydney, p.36) will be encouraged by the proposed second airport and associated development. The proposed Western Sydney Airport Stage One is predicted to generate 48,000 vehicle movements per day by 2030 and provide parking for 11,500 cars. The maximum vehicle usage for Stage One of the proposed airport could be three times that number of vehicle journeys, as the number of air traffic movements are estimated to triple by 2050.

No provision has been made in this proposal for a reticulated aviation fuel supply via pipeline nor has an easement for such a pipeline considered. As a result aviation fuel will delivered via road transportation adding considerably to the number of daily vehicle movements estimated and increasing the risk to residents and other road users of Western Sydney. As there has also been no provision for a future rail link to connect the airport for both freight and passengers, another huge impact in traffic movements will be felt by residents of Western Sydney and air passengers alike.

The net effect of large numbers of car and aircraft movements, increased smog, would accumulate in western Sydney where the proposed airport site is located. The modelling reports insignificant increases in air pollution in the draft EIS but this conclusion is not supported by existing air quality measurement data and what is known about air pollution trends with increased vehicle movements.

An independent air quality modelling report undertaken in 2014 concluded that controlling the growth in motor vehicle emissions represents a viable option for reducing peak ozone concentrations in the Sydney basin (Advisory Committee on Tunnel Air Quality, 2014 July, TPO2: Air Quality Trends in Sydney, Office of Environment and Heritage. Sydney, p.11). Yet the proposed airport seeks to accelerate vehicle usage in this region.

It is illogical to direct growth in aircraft and motor vehicle activity to an airport in western Sydney where ozone pollution levels already exceed the standard (Ibid, Ozone concentrations in the Sydney region have exceeded either or both of the Air NEPM ozone standards every year since 1994. Exceedences of both the 1-hour and 4-hour ozone standard occur more frequently in western Sydney). Increasing aircraft and motor vehicle traffic is wilful bad planning taken in the knowledge of growing ozone air pollution that was identified 40 years ago.

Further, peer reviewers identified that the draft EIS assessment of air quality has underestimated the potential impact of the proposed Stage One airport development by a considerable margin (Katestone Environmental Pty Ltd, 17 November, 2015, Western Sydney Airport: Peer Review of Air Quality and Greenhouse Gas Assessment, prepared for Parsons Brinckerhoff, p. iv). Stage One of the proposed airport has a capacity of 185,000 aircraft movements per year. Thus air pollution modelling must be performed for this level of vehicle usage so as to consider an appropriate ‘worst case scenario’.

Moreover, the modelling for the proposed airport for air pollution assumes that 48,000 vehicles movements per day will be generated by 2030, however 125,400 vehicle movements per day is the ‘worst case scenario’, the maximum predicted vehicle movements for Stage One. As ozone exceedences occur now at St Marys, the draft EIS air quality modelling has erroneously predicted that air and vehicle traffic movements associated with the proposed airport Stage One have virtually no effect on air pollution levels. This modelling outcome is wrong.

The modelled air pollution estimates must be understatements as future ozone pollution levels after the airport is built must dramatically increase. The proposed 125,400 motor vehicles per day from Stage One of the proposed airport have an impact on air quality and the modelling must be redone and peer reviewed to ensure the model predictions are realistic.

Given that Western Sydney already has exceedences of the ozone pollution standard, the increases for ozone pollution arising from the proposed airport will be unacceptable. Badgerys Creek is not an appropriate location for an airport due to unacceptable air pollution and must be refused consent.

The following key points relate to aircraft particulates from Submission by Residents to the Expansion of Schiphol Airport, The Netherlands 2013 (From various authors cited in at

  • The concentration of particulate pollutants seems to be inversely proportional to the distance from the airport: the further away you are from the airport platform, the lower the pollution is. Kerosene is the major compound in jet fuel and has a specific odour, especially before fuel combustion, which can be smelled >8 km from the airport.
  • The main polluting substances considered in this environment are nitrogen oxides, carbon dioxide, carbon monoxide, volatile organic compounds (VOCs) including polycyclic aromatic hydrocarbons (PAHs), sulfur dioxide, and fine and ultrafine particles (UFPs).
  • PAHs are dangerous. They have been measured and characterized for decades. Thus, it has been established that aromatic hydrocarbons are a significant part of jet exhaust pollution. Different types of volatile PAHs were identified using a sampler placed outside in a residential area very close to an airport. It is interesting to note that the concentration of the particulate phase measured near homes was similar to that at the end of runways.
  • It has been suggested that aviation can cause large-scale increases (>30%) of black carbon particles in the upper troposphere and lowermost stratosphere of regions highly frequented by aircraft. These particles are then disseminated in the atmosphere. UFPs represented 15–18% of the particulate concentration in an airport flight path atmosphere (Taiwan International Airport, Taipei, Taiwan) and this rate varied depending on the engine, the type of fuel and climate conditions.
  • Some studies suggest that soot particles could have adverse health effects, especially on the respiratory tract, because of their tiny size. Experimental studies have demonstrated that the elementary particle size in airports or close to aircrafts was between 23 and 36 nm. Recently, around Los Angeles International Airport (LAX; Los Angeles, CA, USA), aircraft UFP emissions with a median size of ∼11 nm were observed. This is consistent with the observation at LAX that there was a bimodal distribution of particle size showing peaks at ∼12 and 80–90 nm diameter.

Other papers we have researched seem to be older and more about strategies to reduce emissions around airports but most seem to indicate a 1:1million increase in the chance of cancers resulting within 8 km of an airport.

We also reference an article from LA Times, May 29, 2014, by Dan Weikel and Tony Barboza, based on the background material provided by researchers from the University of Washington for a submission to the EIS into the parallel runway proposal for Los Angeles airport: “Planes’ exhaust could be harming communities up to 10 miles from LAX”:

  • High levels of potentially harmful exhaust particles from jets using Los Angeles International Airport have been detected in a broad swathe of densely populated communities up to 10 miles east of the runways, a new air quality study reported Thursday.
  • The research, believed to be the most comprehensive of its type, found that takeoffs and landings at LAX are a major source of ultrafine particles. They are being emitted over a larger area than previously thought, the study states, and in amounts about equal in magnitude to those from a large portion of the county’s freeways.
  • It further concludes that areas affected by aircraft exhaust at major airports in the U.S. and other parts of the world might have been seriously underestimated.
  • Building on earlier air quality studies, environmental and preventive medicine experts from USC and the University of Washington found concentrations of the wind-driven particles over a 23-square-mile area that includes cities and unincorporated areas along LAX’s flight paths, including Lennox, El Segundo, Inglewood and parts of Los Angeles.
  • The findings raise health concerns, researchers say, because the minute particles, which result from the condensation of hot exhaust vapor from cars, diesel trucks and aircraft, have the potential to aggravate heart and lung conditions, including asthma and the development of blocked arteries.

The EIS itself admits the exhaust fume Nitrogen Oxide as one major health risk: Exposure to nitrogen dioxide would be the highest risk category resulting from airport operation, with between six additional deaths every 100 years and six additional deaths every 10 years in people over 30 years of age. (EIS, Vol 1, pp34-35)

If there are six or ten or fifty additional deaths over time who’s to say how much non-fatal disease is worsened? Chest complaints, coughs, chronic breathing problems? Western Sydney has one of the highest hospital admissions for asthma sufferers in Australia, where the cost of the disease is estimated at $28 billion a year—one of the ‘hidden costs’ of air pollution. Direct death is simply the tip of an iceberg, and why, in this day and age, should ANY death beyond the norm be tolerated at all?

Australia also lags behind the OECD in dealing with growing air pollution. (Source: OECD Report, The Cost of Air Pollution, 2010) Add the impact of a new airport to the already high number of days when Western Sydney is shrouded in fog or particulates from vehicle movements, industry and fires both natural and domestic, and the situation will certainly grow worse. The future scenario would be one of increased interruption of air traffic movements because of airport closures (already experienced in the operations at Sydney Kingsford Smith Airport) culminating in cancellation of flights or diversions to other national airports.

The EIS Carbon Emissions Scandal

Finally, the jaundiced determination of the draft EIS authors to paint a picture of utterly minimal (and unbelievable!) carbon footprints arising from the proposed WSA has led to grave errors in the EIS text, public exposure, suspect intervention and amendments, utter confusion, and thorough lack of credibility surrounding the document. For this reason alone it should have been withdrawn and re-exhibited. Obviously this has not happened.

It all began with the oft repeated claim, made throughout the EIS, that emissions from the Airport amounted to nothing more than 0.13 million tonnes or “0.10%”… greenhouse gas emissions estimated from the proposed Stage 1 development would represent approximately 0.10 per cent of Australia’s projected 2030 transport-related greenhouse gas emission inventory. For this reason, it can be concluded the greenhouse gas emissions from the proposed airport would not be material in terms of the national inventory. (Executive Summary, Vol 1, p.34)

On this occasion, the statement is made in the Executive Summary at the opening of the Draft EIS (the part that most people read), and it colours the perception for the whole document. It openly refers to “Scope 1 and 2” emissions, but not Scope 3. This is misleading because Scope 1 and 2 are simply measures of emissions from the grounds of the Airport (eg truck movements and electricity usage), whereas Scope 3 deals with the ‘raison d’etre’ of an Airport, namely jet plane takeoff exhausts.

Subsequently a member of the Blue Mountains Conservation Society found massive discrepancies in the ‘Air Quality and Greenhouse Gases’—Chapter 12—and informed politicians of them on December 2nd before exposing them in the local newspaper, the ‘Blue Mountains Gazette’. The discrepancies exposed were between an Appendix Table 8-1, with a total of 129, 462 tonnes of Scope 1 and 2 CO2 emissions, which were then ‘rounded off’ for the Draft EIS in Table 12-40 to a reduced figure of 111, 422.

More dramatically, the Appendix Table 8-2 revealed a Scope 3 total of 2,524,504 tonnes of CO2 emissions, which was then shown in the Draft EIS in Table 12-41, as a mere 2,187 tonnes, a reduction of over a thousand times. This was a dreadful error and it is hard to imagine how it could happen.

In the event, the errors were simply in the website ‘Chapter 12’, not the original overall hard copy, but after the news of this blunder had been published in the ‘Gazette’ and the call was made to withdraw the EIS, improve it, and then re-exhibit it, it was discovered that someone had entered the website (clearly the authors of the Draft EIS), and amended the errors. The record showed that this had been done on December 3rd, and it was as if there had been no error in the first place. There was no explanation or any apology for misleading the public.

A follow-up story in the ‘Penrith Gazette’ questioned the propriety of altering a government sponsored document designed to truthfully inform the public—still, there was no response from the Minister for Infrastructure, the local Member, Louise Markus, or the authors of the document themselves.

Yet the saga of misleading data on carbon emissions continued, because all the blunders were not erased. At the start of Chapter 12, the ‘Introductory Page’ makes the following statement: The Scope 1, Scope 2 and Scope 3 greenhouse gas emissions estimated for the proposed Stage 1 development would represent approximately 0.1 per cent of Australia’s projected 2030 transport-related greenhouse gas emission inventory. For this reason, it can be concluded that the greenhouse gas emissions from the proposed airport would not be material in terms of the national inventory. (EIS Vol 2 p.101)

You will note that this is an almost identical statement to that in the ‘Executive Summary’ except for one vital point: the ‘Scope 3’ emissions are included, but the same result, “0.1 percent of Australia’s projected greenhouse gas inventory” is achieved! The Draft EIS certainly wanted that figure to stay on the record, no matter what had been exposed earlier!

The confusing (obfuscating?) sequence of Tables on pp161 (Tables12.40 and 12.41  ) and 162 (Tables 12.42 and 12.43) might explain this ‘oversight’.

Table 12.40 adds up all the Scope 1 and 2 emissions which come to a total of 129,462 tonnes, then, below that, begrudgingly, they show the figure for Scope 3 emissions as 2,524,504 tonnes (more than 2.5 million, ‘rounded’).

Then, on the next page and Table, the 129,462 figure is ’rounded’ to give the total emissions for Scope 1 and 2 which is .13 million tonnes CO2–the figure they’re really talking about in the paragraph above (NO SCOPE 3!).

Then they measure the .13 figure against the next table which gives a breakdown of the different sectors’ contributions to Total Australian emissions–‘Transport’ amounts to 115 million tonnes in 2030, so of course .13 million tonnes only amounts to the oft quoted “0.1%” (irrelevant) figure.

By contrast, on any layman’s rough calculations, 2.5 million tonnes as a percentage of 115 million tonnes, amounts to more than 2% of annual CO2 emissions given off by one (just getting started) Western Sydney Airport! The mind boggles at what the % would be in 2060, when the total emissions are (quoted by the EIS in its Appendices) 21 million tonnes!

What is more, one is consequently led to wonder what the overall percentage of ALL airports across Australia might be in the ‘national inventory’ of Transport emissions—more likely than not, it is at least 10% and growing–an even greater reason for a zero emissions transport solution such as High Speed Rail.

In any case, the true total figure for Greenhouse Gas Emissions emanating from WSA in 2030 would more accurately be estimated as 2,653,966 tonnes or 2.2% of Australian Transport CO2 emissions for that year.

It is a pity so much effort was made to obscure these figures, since the repeated attempts to gild the WSA lily by omitting or misquoting Scope 3 emissions brought the credibility of the whole Draft EIS into question. This matter really does require some significant re-assessment since thousands of readers and respondents may have been totally misled on this crucial piece of data, and formed their opinions and submissions accordingly. It may well be that the errors and misquotes are legally challengeable.