Blue Mountains Greens Western Sydney Airport EIS Submission [December 2015]
Submission for:	Western Sydney Airport Draft Environmental Impact Statement
Topic:	‘The Greater Blue Mountains World Heritage Site – Impacts’

Impact upon Greater Blue Mountains World Heritage Area (GBMWHA)

Blue Mountains Greens make the following submission to oppose the proposed Western Sydney Airport’s impact upon the Greater Blue Mountains World Heritage Area. The Greens will establish a host of adverse impacts upon the GBMWHA, and prove that they will threaten the outstanding universal value of this area and thus endanger its classification under the auspices of UNESCO.

History of the proposed Western Sydney Airport (Badgerys Creek) in relation to the Greater Blue Mountains World Heritage Area.

While the currently proposed airport is not identical to previous proposals to develop an airport in Western Sydney, we are mindful of the history of the proposed Western Sydney Airport (Badgerys Creek) in relation to Western Sydney, the Greater Blue Mountains and the GBM World Heritage Area.

We understand that a second airport in the Sydney region has been considered periodically since 1946. Badgerys Creek was identified as the preferred site for a second Sydney airport in studies undertaken in 1979 and 1985, each of these occasions pre-dating the listing of the Greater Blue Mountains as a World Heritage Area in 2000.

In 1999, the International Union for Conservation of Nature (IUCN) assessed a nomination from the Australian Government for listing of the Greater Blue Mountains as a World Heritage Area. The IUCN decided that the nomination, as then presented, did not meet the criteria for World Heritage status. At this time, the IUCN considered three aspects relating to integrity that related to the Greater Blue Mountains nomination: previous land uses; boundary issues; and threats.

According to the ‘1999 World Heritage Nomination – IUCN Technical Evaluation The Greater Blue Mountains Area (Australia)’ (http://whc.unesco.org/archive/advisory_body_evaluation/917.pdf):

…One threat not mentioned in the nomination is the proposal for a new international airport at Badgerys Creek 10km from the eastern boundary of the GBM. IUCN has reviewed relevant portions of the draft Environmental Impact Statement as well as copies of submissions against the proposal by conservation and community groups. The proposed airport would maximise use of airspace over the Blue Mountains area resulting in aircraft noise levels of 70 to 80 decibels. Such flights would also be visually intrusive and adversely affect the natural quiet and ambience of this part of the GBM. The airport would also increase air pollution through vehicle traffic to the site and airborne fuel emissions and fuel dumping. As noted in the submission by the City of Blue Mountains, the World Heritage nomination of the GBM ‘… would be unacceptably compromised by the adverse impact… caused by aircraft flights over the Blue Mountains’. Other local governments and the State Government also oppose the project. A decision by the Commonwealth Government on construction of the new airport is expected to be announced in mid-1999.

In 1999 the IUCN did not approve the nomination but offered Australia the opportunity to submit a revised nomination while cautioning that it would need to take into account issues dealing with the Conditions of Integrity, including “the threats from the proposed new airport”. The IUCN also noted a number of impacts, including the potential for an airport at Badgerys Creek, which might compromise the integrity of the area.

In 2000, when the Greater Blue Mountains was again re-nominated, and this time accepted, for World Heritage Listing, it was understood that the proposed Badgerys Creek Airport development would not proceed and potential threats from the airport were not considered. In 2009, when the subsequent GBMWHA Strategic Plan was prepared it was still understood that the previously proposed Badgerys Creek Airport would not proceed – hence the GBMWHA Strategic Plan does not deal directly with likely threats from the proposed airport.

Convention concerning the Protection of the World Cultural and Natural Heritage

As a signatory to the Convention concerning the Protection of the World Cultural and Natural Heritage (http://whc.unesco.org/archive/convention-en.pdf), the Australian Government, as the State Party, has an international obligation to ensure the identification, protection, conservation, rehabilitation and presentation of the GBMWHA and its transmission to future generations. The GBMWHA Strategic Plan has been prepared to assist in meeting Australia’s international responsibilities under the World Heritage Convention. By agreeing to the content of the document, the Commonwealth and New South Wales Governments have made a commitment to abide by its principles and to implement the strategies outlined. The Blue Mountains Greens are concerned that significant aspects of the proposed Western Sydney Airport are contrary to the principles and strategies outlined in the GBMWHA Strategic Plan.

Operational Guidelines for the Implementation of the World Heritage Convention

The Operational Guidelines for the Implementation of the World Heritage Convention aim to facilitate the implementation of the Convention by setting forth the procedure for the protection and conservation of World Heritage properties.

The cultural and natural heritage is among the priceless and irreplaceable assets, not only of each nation, but of humanity as a whole. The loss, through deterioration or disappearance, of any of these most prized assets constitutes an impoverishment of the heritage of all the peoples of the world. Parts of that heritage, because of their exceptional qualities, can be considered to be of “Outstanding Universal Value” and as such worthy of special protection against the dangers which increasingly threaten them. (Operational Guidelines for the Implementation of the World Heritage Convention.)

Greater Blue Mountains World Heritage Area Statement of Outstanding Universal Value

Outstanding Universal Value means cultural and/or natural significance which is so exceptional as to transcend national boundaries and to be of common importance for present and future generations of all humanity. As such, “the permanent protection of this heritage is of the highest importance to the international community as a whole.” (Operational Guidelines for the Implementation of the World Heritage Convention.) The World Heritage Committee adopted the retrospective Statement of Outstanding Universal Value (SOUV) for the GBMWHA in 2013. (http://www.environment.gov.au/heritage/places/world/blue-mountains/values).

The SOUV notes that the GBMWHA was inscribed on the World Heritage List in 2000. Matters that contributed to the decision was that the property has ‘Outstanding Universal Value’, including fulfilment of two natural value criteria which specify that properties should:

• be outstanding examples representing significant on-going ecological and biological processes in the evolution and development of terrestrial, fresh-water, coastal and marine ecosystems and communities of plants and animals; and
• contain the most important and significant natural habitats for in-situ conservation of biological diversity, including those containing threatened species of outstanding universal value from the point of view of science or conservation.

Assessment of integrity and authenticity, as well as provisions for protection and management, also contributed to the assessed Outstanding Universal Value of the GBMWHA.

The SOUV states that additional regulatory mechanisms, such as the statutory wilderness designation of 65% of the property, the closed and protected catchment for Warragamba Dam and additions to the conservation reserves that comprise the area further protect the integrity of the GBMA. Of particular relevance to the current proposed Western Sydney Airport, the World Heritage Committee’s SOUV states that “Since listing, proposals for a second Sydney airport at Badgerys Creek, adjacent to the GBMA, have been abandoned”.

Greater Blue Mountains World Heritage Area Strategic Plan

The Greater Blue Mountains World Heritage Area Strategic Plan (http://www.environment.nsw.gov.au/parkmanagement/GBMWHAStrategicPlanFinal2009.htm) has been adopted by both Commonwealth and NSW Governments, as the basis for conserving and managing the GBMWHA in implementing the Convention and the Operational Guidelines.

The Strategic Plan includes a number of objectives relevant to the proposed Western Sydney Airport, including the following, relating to ‘integrity’ (p. 25):

Objective

To maintain, and where possible, improve the current and future integrity of the GBMWHA.
Desired outcomes
Adjoining land uses are compatible with the conservation and presentation of World Heritage values.
Wilderness and wild rivers are formally identified, declared and protected.

Management Response

1.8 Maintain and enhance the wilderness and wild river quality and values of the GBMWHA through formal declaration and appropriate management programs

‘major impacts’ (p. 27):

Objective

To reduce the potential for major impacts to adversely affect the integrity of the GBMWHA.
Desired outcomes
Developments and activities with an unknown but potentially significant impact on the World Heritage and other values of the GBMWHA are either modified to minimise the risk of impact on these values or do not proceed (!)

‘biodiversity’ (p. 28):

Objective

To conserve the GBMWHA’s biodiversity and ensure the ecological viability and capacity for ongoing evolution of its World Heritage and other natural values is maintained.
Desired outcomes
Terrestrial and aquatic ecosystems and their associated ecological processes, species, populations and genetic diversity are all protected and conserved in-situ

‘landscape, natural beauty and aesthetic values’ (p. 33):

Objective

To protect the landscape, natural beauty and aesthetic values of the GBMWHA

Desired outcomes

Recreational and tourist overflights do not interfere with the natural quiet, biodiversity and GBMWHA aesthetic values

Management Response

7.5 Continue to work with the relevant agencies, aviation industry and military to implement and monitor the existing Fly Neighbourly program to ensure that any impact of aircraft on the GBMWHA (especially wilderness areas), park visitors and neighbouring communities is minimised.
7.6 Seek the establishment of a Restricted Area under the Air Services Regulations to provide statutory restrictions on tourist flights over the GBMWHA.

The noise impacts on residents and the Greater Blue Mountains World Heritage Area – discounted

The proponent must consider how to prevent significant aircraft noise impact on the natural quiet of the World Heritage Area. There is a considerable amount of science and regulation methodology that the re-exhibited draft EIS must consider to effect the protection of the natural quiet of declared wilderness within the World Heritage Area.

The Greens are disappointed that the draft EIS dismisses the impacts of the proposed Western Sydney Airport upon the Greater Blue Mountains World Heritage Area as being not significant, rather than undertaking an adequate assessment of the potential impacts. The incomplete noise assessment in the draft EIS follows the apparent bias in EPBC referral documentation that claimed aircraft noise from the proposed Western Sydney Airport would not be ‘a new source of impact on the World Heritage values’ (Referral 2014/7391 section 1.3(a)).

We consider there is strong evidence to indicate impacts on the World Heritage Area will be highly significant.

The noise generated by the proposed Western Sydney Airport will also affect hundreds of thousands of western Sydney residents who are currently little affected by aircraft noise. Western Sydney’s residents in the suburbs of St Marys, Erskine Park, Mt Druitt, Whalan, Emerton, Ropes Crossing and St Clair will be significantly affected by aircraft noise if a second Sydney airport is built at Badgerys Creek. Unfortunately aircraft noise policies and regulations in Australia do not specify limits to apply to aircraft regarding overflight noise occurring at sensitive receptor locations (Marshall Day Acoustics, 20 Nov 2015, Western Sydney Airport draft EIS, overflight noise peer review, page 20).

The proposed airport has been not designed to protect sensitive receptors in the above suburbs, such as schools and hospitals, from unacceptable noise. Noise policy and regulation must be developed and applied by the proponent to protect sensitive receptors from overflight noise.

Probable effect of complaints about aircraft noise impacts on flight paths and operating modes

By 2030 the draft EIS predicts that there will be 63,302 air traffic movements per year, rising to a maximum of 185,000 by 2050 when work for a second runway will be initiated. In response to community aircraft noise objections, the western Sydney airport lessee will almost certainly divert aircraft noise to the unsettled areas nearest to Badgerys Creek – the national parks of the Blue Mountains.

As specified above, the proposed airport will result initially in tens of thousands growing to hundreds of thousands of aircraft movements a year. The actual rate of air traffic growth is a matter of conjecture and partly determined by the airport lessee, particularly if they also lease Kingsford Smith Airport. It may be that the airport lessee will divert planes currently arriving in the current Sydney airport curfew and shoulder periods to the proposed Western Sydney Airport in order to make the new airport more financially viable. The No Aircraft Noise group are calling for these aircraft diversions in submissions to the draft EIS. This request is unfair to western Sydney residents and condemned by NSW environment groups.

If these unethical aircraft diversions from Kingsford Smith Airport are allowed, air traffic movements will grow more quickly than modelled in the draft EIS. Associated noise and air pollution will rapidly exceed the prediction levels given in the draft EIS. Rapid increases in pollution levels will be unacceptable to the local community.

If air traffic grows quickly, resident objections will more aggressively seek maximum use of airspace to the west, eroding the peace and solitude of the Blue Mountains wilderness. On take-off, aircraft will crawl up into the sky over the Blue Mountains, spreading aircraft noise (55-70 dBA) over these pristine areas.

Effect of aircraft noise on Blue Mountains tourism economy

Aircraft noise from the proposed airport is going to significantly detract from a visitor’s experience of nature during any visit to the Greater Blue Mountains World Heritage Area (GBMWHA), which is a major national and international attraction receiving over three million visitors a year (NPWS, January 2009, Greater Blue Mountains World Heritage Area Strategic Plan, Sydney, DECC, page 14). The draft EIS has failed to assess the economic impact of increased noise on the Blue Mountains tourist economy.

Blue Mountains tourism is known to be sensitive to adverse environmental impacts, as was demonstrated by the significant downturn in visitor numbers following the 2013 bushfires. The post-fire downturn halved tourism income despite the fact that most of the popular tourist areas were free of bushfire impacts.

Nature-based tourism will be adversely impacted, especially as the Blue Mountains are proposed to be subjected to aircraft noise 24 hours a day. The impact, including economic impact, of aircraft noise associated with the proposed Western Sydney Airport on nature-based tourism in the Blue Mountains must be assessed in the re-exhibited draft EIS and action taken to mitigate this significant impact. If action is not taken to mitigate potential noise and visual impacts, then the nature-based tourism upon which the Blue Mountains economy depends will decline.

Modelling of aircraft noise has underestimated impact on the World Heritage Area

Measurements of aircraft noise arising from existing airport operations report that at 5,000 feet aircraft noise is generally higher than the modelled 55dB LAmax for the proposed airport. This overflight noise level prediction for the Greater Blue Mountains World Heritage Area is an underestimate (Marshall Day, page 18). For example, the Airbus A319, a medium sized aircraft, generates 69.7 dBA at 4,800 feet while climbing and the Airbus A321, another medium sized aircraft, generates 60.2 dBA at 6,000 feet while descending (Nats Limited, 2015 http://www.nats.aero/environment/aircraft-noise/).

Nats Limited, a company in the United Kingdom, provides a range of Lmax data for aircraft. Lmax is a measure of the loudest part of a flight passing overhead. Nats Limited has published Lmax for a number of current aircraft at a range of heights. These measurements for aircraft are all louder than the 55dB LAmax estimate at 5000 feet for all aircraft reported other than small regional jets with 50 seats. Even turbo-prop jets are louder than 55dB LAmax when passing overhead. Twin engine single isle jets at 5000-6000 feet generate 60-63 dB Lmax ascending and 57 to 59 dB Lmax descending. ‘Normal’ sized jets, such as twin isle jets with two engines, generate 64-67 dB L max ascending at 5000-6000 feet. So the assumed 55dB LAmax for modelled aircraft noise certainly appears to understate noise levels (http://www.nats.aero/environment/aircraft-noise/representative-aircraft-lmax-data/).

While the draft EIS has questionably modelled aircraft noise levels, according to peer reviewers Marshall Day Acoustics the 55dB LAmax level is likely to be comparable to typical noise levels associated with ambient noise sources in the GBMWHA. Marshall Day considers it is generally not appropriate to assess aircraft noise intrusion by comparing sound pressure levels; the characteristics of aircraft noise and natural sounds are very different, and are interpreted in very different ways (Nats Ltd., p18)

The claim in the draft EIS that the natural background noise within the World Heritage Area is comparable with 55dB LAmax is also inconsistent with measures of indigenous sound levels in United States wilderness (US Dept. of Agriculture, Forest Service, July 1992, Report to Congress – Potential Impacts of Aircraft Overflights of National Forest System Wildernesses, Prepared pursuant to Section 5, Public Law100-91, National Park Overflights Act of 1987, page 2-6). In the US, ambient sound levels in wilderness areas varied considerably over time and place from 27dBA to 47dBA (Ibid, page 2-7). A review of this United States 1992 noise data suggests that the assumed background noise level used in draft EIS for GBMWHA is too loud.

In fact, actual noise measurements in Blue Mountains National Park demonstrate that the assumed background noise for the World Heritage Area is too loud. Background noise levels (L_{A90, 15min}) of the Blue Mountains National Park measured during daytime in remote areas but nearby walking tracks is 23 to 27dBA. At the same areas during gusty wind events the background noise levels increased to 45dBA (Dr Urszula Mizia, July 1994, Proposal for Noise Control Criteria for Aircraft Flying over National Parks and other environmentally sensitive areas). These noise levels are not comparable to the predicted 55dB LAmax both in loudness and character.

Reviewers Marshall Day believe that… the potential for a large number of audible events below 50 – 55 dB LAmax is therefore considered to represent a potentially significant and widespread impact within the GBMWHA (Marshall Day Acoustics, 20 Nov 2015, Western Sydney Airport draft EIS, overflight noise peer review, p. 19). Since the modelled aircraft noise levels were understated when compared with measured noise levels emitted by aircraft leaving from existing airports (Ibid, p.18), aircraft noise impacts from aircraft overflight arising from the proposed airport must have a unique and significant impact on the naturally quiet environment of the World Heritage Area.

Need for noise criteria for the World Heritage

The Federal Government has legislative and treaty obligations to protect the Greater Blue Mountains World Heritage Area.

The Greater Blue Mountains World Heritage Area is a refuge from noise for park visitors and should remain so. The World Heritage Area must be provided with adequate protection of its peace and quiet by the Department of Infrastructure and Regional Development through the determination process under the Environment Protection and Biodiversity Conservation Act.

The Department must develop noise criteria in relation to the World Heritage Area. The Department has failed in this duty to mitigate noise as the draft EIS provides only aircraft overflight numbers, and does not predict aircraft noise levels over the World Heritage Area arising from the proposed airport. It also appears that the proponent’s consultants did not measure a range of background noise levels in the World Heritage Area, but instead assumed aircraft noise level of below 50-55dB LAmax is comparable to ambient background noise levels. This conclusion is wrong. The draft EIS asserts that aircraft noise does not exceed background noise levels and is further asserted that aircraft noise arising from airport traffic would be not significant. These conclusions are also wrong.

In the United States of America the National Parks Service has taken steps to protect natural quiet by ensuring no aircraft noise is audible in parts of the Grand Canyon National Park. This case study provides important information to assist with the environmental assessment for the proposed airport.

Impacts of Aircraft on National Parks – the United States regulator experience in protecting natural quiet

Since the 1990s, the United States Congress commissioned acoustic studies and wilderness user surveys to find ways to maintain natural quiet in wilderness areas (US Dept. of Agriculture, Forest Service, op. cit.). A report to Congress dated July 1992 on the Potential Impacts of Aircraft Overflights of National Forest System Wilderness found that park managers considered aircraft overflights were a problem damaging visitor enjoyment. The perception of noise in national parks is related to the fact that parks tend to be quieter than urban settings and the potential for noise pollution by aircraft is thereby much greater. The draft EIS for Western Sydney Airport has made no such considerations.

In the Grand Canyon National Park frequent tourist aircraft overflights were damaging natural quiet. Regulatory action was taken to address the issue with the passage of the 1987 National Parks Overflights Act (Public Law 100-91) that requires restoration of natural quiet and visitor experience in Grand Canyon National Park. In February 2011, the National Parks Service released a Draft Environmental Impact Statement for Special Flight Rules Area in the Vicinity of Grand Canyon National Park with 120 days for public comment. These proposed flight rules are to further protect natural quiet of the national park. These US rules provide a detailed and relevant regulatory model to control aircraft overflights in the vicinity of the World Heritage Area and must be applied to the proposed Western Sydney Airport.

The US Federal Aviation Authority has made specific regulations in the Grand Canyon for “flight free” zones to an altitude of 14,500 feet msl above the park (Special Federal Aviation Regulation No. 50-2 – Special Flight Rules in the Vicinity of the Grand Canyon National Park, AZ). The purpose of the US draft EIS was to expand the application of the Special Flight Rules Act in the vicinity of Grand Canyon National Park and increase area where no aircraft noise is heard. Specific aircraft noise impact mitigation measures were achieved through specifying flight corridors and defining natural quiet between these corridors.

The re-exhibited draft EIS for proposed Western Sydney Airport must identify flight free zones to ensure aircraft noise is not heard in the Greater Blue Mountains World Heritage Area. Prudent and feasible methods for achieving protection can be developed from the Grand Canyon National Park case.

The shortcoming identified by the draft EIS peer reviewers regarding the absence of definitive guidance on assessment techniques for measuring aircraft overflight noise in sensitive wilderness areas (Marshall Day Acoustics, 20 Nov 2015, Western Sydney Airport draft EIS, overflight noise peer review, p. 19) are addressed by the US National Parks Service (National Park Service, U.S. Department of the Interior, 2011 Feb., Special Flight Rules Area in the Vicinity of Grand Canyon National Park Actions to Substantially Restore Natural Quiet Draft Environmental Impact Statement, DES 10-60) The proposal to restore national quiet in the Grand Canyon National Park is a relevant regulatory model that must be applied in the re-exhibited draft EIS. There is no excuse for the proponent not to make use of this body of work.

We recommend that the assessment methodologies applied in the United States of America to the regulation of aircraft noise over wilderness be applied to this environmental assessment for the proposed airport.

We further request that all prudent and reasonable alternatives regarding the regulation of aircraft noise over the Greater Blue Mountains World Heritage Area must be examined in relation to the proposed airport.

The environmental impact statement must consider and make an assessment of aircraft noise impacts in relation to proposed flight paths on the World Heritage property. The environmental impact statement must then consider ways to mitigate this impact by variation of flight paths so as to protect the natural quiet in wilderness areas.

Impacts on World Heritage and inadequate assessment, minimisation and mitigation

The proposed Western Sydney Airport at Badgerys Creek will result in severe and unacceptable noise impacts on the Greater Blue Mountains World Heritage Area, Burragorang State Conservation Area, Bents Basin State Conservation Area, Kanangra Boyd Wilderness, Nattai Wilderness, the southern half of the Wollemi wilderness and the Grose Wilderness.

The proponent must use measured levels of natural quiet in Blue Mountains national parks and adopt measures of airport operations and airport design to protect it. Noise modelling undertaken for the Greater Blue Mountains World Heritage Area did not consider how to minimise noise impacts. Such impacts on park visitors and wildlife were instead incorrectly dismissed by the draft EIS as not significant.

The failure of the draft EIS to adequately consider the impact on visitors to the Greater Blue Mountains World Heritage Area, despite impacts on World Heritage values being Controlled Actions under the Environment Protection and Biodiversity Conservation Act, 1999, is unacceptable. The World Heritage Area must be provided with adequate protection from aircraft noise, to secure its peace and quiet.

Under the NSW Wilderness Act 1987, large sections of the Blue Mountains National Parks must be managed by the NSW National Parks and Wildlife Service to provide the experience of solitude and natural quiet. Maintenance of natural quiet in the Blue Mountains National Parks and wilderness areas is incompatible with frequent 24 hour a day overflights by commercial aircraft that may arise from operation of the proposed Western Sydney Airport. Peace and solitude will be lost over those parts of the World Heritage Area subjected to frequent aircraft overflights.

The Federal Department of Infrastructure and Regional Development has a duty of care toward the World Heritage property and the appropriate use and enjoyment of its declared wilderness areas.

The draft EIS has given no expert consideration of the noise levels of particular flight path designs for the new airport upon World Heritage Area, its wilderness areas and other sensitive sites in the Blue Mountains National Parks and Reserves, such as its lookouts and campgrounds.

Given the status of the Blue Mountains as a World Heritage Area, and the potential for intrusive impacts, further assessment of this sensitive receiver location is warranted. In particular, further data must be obtained that demonstrates the relative merits of alternative aircraft arrival management procedures which avoid concentration of aircraft movements over the Greater Blue Mountains World Heritage Area (Ibid, p. 19).

The Department of Infrastructure and Regional Development, as the proponent of the airport, has an obligation to consider practical measures which may be taken to prevent, control, abate or mitigation noise pollution under the Civil Aviation Act, 1998 (see s. 9A (2) – performance of functions). The Department must discharge this responsibility in regard to noise pollution for the proposed airport before the determination of the re-exhibited draft EIS.

Impacts of proposed Western Sydney Airport on GBMWHA

The Greens are particularly concerned about likely impacts in the Blue Mountains Local Government Area and the GBMWHA as a consequence of the numbers of aircraft flights that are proposed to pass over the Blue Mountains. The Draft EIS states that the number of aircraft per day expected to utilise the proposed airport will increase from 198 in 2030, to 554 in 2050, and will peak at 1110 a day in 2063. It is thus anticipated, that in the long term (2063), the proposed airport will support up to 85 aircraft movements an hour, that is, more than one per minute of both the day and night.

The Draft EIS states that flights will be as low as 5000 ft in the lower Blue Mountains and that the associated noise from each flight will be dependent, in part, on the type of aircraft involved. We have noted that aircraft from Sydney Airport which currently pass over the lower Blue Mountains do so at heights of approximately 15, 000 feet and higher. Noise from these existing, and at present relatively infrequent, overflights can be intrusive, particularly when heard from the relatively quiet space of the natural areas of the GBMHWA.

The Draft EIS states that flight paths shown in the Draft EIS are indicative only. The Draft EIS presents a high degree of uncertainty in regard to the proposed development: it is yet to be determined whether aircraft flights over the Blue Mountains will be concentrated over urban/rural areas adjacent to the GBMWHA, over the bushland and wilderness areas of the GBWHA, or will be alternated between rural/urban and World Heritage areas. According to the Australian Government Department of Infrastructure and Regional Development (the proponent of and consent authority for the development), the uncertainty regarding flight paths will not be resolved until after construction of the proposed airport. Such uncertainty makes it difficult to adequately assess the likely impacts on the GBMWHA.

Taking account of the SOUV and the Strategic Plan, we have particular concerns in regard to the following likely areas of impact of the proposed Western Sydney Airport on the GBMWHA:

Presentation of the values of the GBMWHA

The Australian Government, as a signatory to the World Heritage Convention, is required to act positively to present the values of the GBMWHA. The visual intrusion and noise impacts of frequent overflights over the World Heritage Area and neighbouring areas will detract from visitor experiences. While some attention is given in the Draft EIS to impacts on major tourism sites, such as Echo Point and Govetts Leap, the impacts on other visitor sites closer to the proposed airport, for example Euroka Clearing, Murphy’s Glen, Portal Lookout, Portal Waterhole, Woodford-Glenbrook Fire Trail (a major cross-country bike track), Tunnel View Lookout, Red Hands Cave, Jellybean Pool, Blue Pool, Toby’s Glen, Ingar Swamp, Kings Tableland, Blue Gum Swamp Creek, Erskine Creek, Faulconbridge Point, Sassafras Gully etc, are either glossed over or not considered at all in the Draft EIS. We believe that the ability to present the values of the GBMWHA across the World Heritage Area in its entirety will be unacceptably compromised by the proposed development.

Degradation of integrity of GBMWHA

The wilderness and wild river values, the opportunities for quiet and solitude, are integral to the integrity of the GBMWHA. The GBMWHA Strategic Plan (p. 33) states that “The GBMWHA’s wilderness qualities have particular aesthetic value to local communities and park visitors alike. The undisturbed natural environment is one of the important qualities that attracts residents to live in areas adjoining the GBMWHA. Potential threats to the appreciation of the area’s aesthetic values include inappropriate lighting as well as overflights by helicopters, low-flying jets and other aircraft. A Fly Neighbourly program has been established in the Blue Mountains National Park to minimise impacts of aircraft but this needs to be reviewed and stronger and more extensive controls applied”.

(We again note that, when the Strategic Plan was prepared, it was understood that the proposal to build a second airport at Badgerys Creek had been abandoned due to the then considered unsuitability of the location. Consequently, the Strategic Plan does not take account of the impacts of a major international/domestic airport on adjoining land.)

The construction and operation of the proposed Western Sydney Airport would clearly be contrary to the spirit and intent of the Strategic Plan… “stronger and more extensive controls” … required to minimise impacts of aircraft. We consider that the wilderness values of the GBMWHA (statutory wilderness declaration of 65% of the property), which provide for significant protection of the integrity of the GBMWHA, will be degraded by the very high number of aircraft movements proposed to pass over the area 24 hours a day.

Reduced amenity

The noise and visual pollution associated with the high number of planned overflights in the Blue Mountains will lead to an unacceptable reduction in the amenity of both the areas surrounding the GBMWHA and the GBMWHA itself. Minimisation of noise levels in residential and rural areas at the expense of noise levels in the World Heritage Area is not acceptable. Conversely, minimisation of noise levels in the World Heritage Area at the expense of noise levels in adjacent residential and rural areas is also not acceptable.

Impacts on biodiversity from aircraft overflight noise

The GBMWHA is recognised at international level because of its outstanding biodiversity – it is home to approximately 40 frog, 80 reptile, 280 bird and 60 mammal species in addition to numerous fish and a vast but yet unknown number of invertebrate species.

Anthropogenic noise is an important environmental stressor for wildlife. Chronic and frequent noise can interfere with animals’ abilities to detect important sounds, whereas intermittent and unpredictable noise is often perceived as a threat (Francis, C.D. and Barber, J.R. 2013. A framework for understanding noise impacts on wildlife: an urgent conservation priority in Frontiers in Ecology and the Environment 11:pp 305-313). The assessment of the impact of aircraft overflight noise on wildlife is difficult – studies of noise impacts, particularly on Australian species, are scant and the physiological and behavioural effects of noise vary greatly between species and individuals.

The Draft EIS (Appendix K1) documents a number of negative impacts that noise may have on fauna and acknowledges that some aircraft noise would occur over portions of the GBMWHA closest to the airport. We remain concerned that there is considerable uncertainty and an unacceptably high level of risk in regard to the impact of aircraft noise on the diverse fauna of the GBMWHA.

Impacts of reduced air quality including fuel jettisoning and emissions from aircraft on biodiversity and water quality

Construction and operation of the proposed airport will contribute to on-going degradation of air quality in the Western Sydney region. While fuel jettisoning is predicted to occur rarely it will occur on occasions. Toxic emissions from overflying aircraft are on-going and will impact on the GBMWHA and Sydney’s Drinking Water Catchments (chiefly Lake Burragorang and Prospect Reservoir, although to a less extent at Katoomba and at Blackheath) on a daily basis.

Impacts of increased greenhouse gas emissions

Anthropogenic Climate Change is recognised as a Key Threatening Process at both State and Federal government level. The proposed airport will generate greenhouse gas emissions during construction and operation (2.5 million tonnes of co2 per year, or greater than 2% of Australia’s Transport carbon emissions) and will thus contribute to further climate change. The integrity of the outstanding biodiversity of the GBMWHA is threatened by climate change.

Bird and bat strike

The Draft EIS provides only a very preliminary assessment of the risk of bird and bat strike (strikes may occur within the GBMWHA). We note that the consultant who undertook the bird and bat strike risk assessment (Appendix I) had scope to undertake a single 3 day survey only but recommended (page 42, Appendix I) that monthly surveys be undertaken over one year to “provide a more robust understanding of bird and bat abundance and distribution in the airport study area [25 km radius of airport]”. We are concerned by the inadequacy of the Draft EIS in regard to assessment of risks to the GBMWHA.

Notification of World Heritage Committee

We note the requirement in paragraph 172 of the Operational Guidelines to the World Heritage Convention which require notification to the World Heritage Committee regarding major constructions which may affect the Outstanding Universal Value of a property on the World Heritage List. Such notification should be given as soon as possible and prior to drafting basic documentation. We assume that notification to the World Heritage Committee has already been made.

We strongly recommend that, in addition to a copy of the Draft EIS, copies of submissions from conservation and community groups in regard to the project be now also sent to the World Heritage Committee. We believe that this would assist the World Heritage Committee in their appraisal of the project, as it did in 1999, when the IUCN considered a previous Western Sydney Airport proposal and reviewed both relevant portions of the draft Environmental Impact Statement and copies of submissions against the proposal by conservation and community groups.

Significant local biodiversity impacts have been poorly compensated

There are four major defects with the biodiversity offset package. The offset areas are not adequate in size, some are not genuine ecosystems, some are double dipping by counting reserves and do not consider or protect all threatened species on the Badgerys Creek airport site.

The key on site biodiversity impacts of the proposed Western Sydney Airport are the loss of 90 ha of Cumberland Plain Shale Woodlands and Shale Gravel Transition Forest critically endangered ecological community; and the loss of 120 ha of habitat critical to the survival of the Grey‐headed Flying‐fox, a vulnerable species (EMM Consulting, 19 Nov 2015, Western Sydney Airport EIS, Biodiversity Assessment Peer Review, p. E.2.) The offset outcome proposed to replace the lost endangered ecological community and bat habitat is extremely poor.

The proposed offsets are ‘notional’ and inadequately compensate for the loss of Cumberland Plains Woodland. About 300 hectares of Cumberland Plain Woodland are needed to meet BioBanking and Federal EPBC policy offsets but only 180 hectares are available. In addition to the significant shortfall in area, no specific offset sites have been identified and the actual sites purchased may be different from the ones assessed. In other words, the proposed offsets are another ‘proof of concept’ program in the draft EIS that has major defects.

While we do not support the concept of biodiversity offsets, the Department of Infrastructure and Regional Development must take the steps necessary to ensure sufficient offset sites are identified before seeking approval of Stage 1 of the proposed airport to ensure viability of these compensation measures. It has not done so.

There are also serious defects with the proposed offset sites. For example, the proposed Ropes Creek and South Creek offset sites are not remnant woodland communities. These sites are areas of pasture that have been planted with lines of trees. Such garden landscapes are not endangered ecological plant communities. Such plantings are unsuitable to propose as offsets for the loss of high quality remnant Cumberland Plains Woodland. Further, it is not acceptable to propose 340 hectares of existing reserves as part of the identified offset areas. Protected areas must not be available for biodiversity offsets. Protected land offsets would be a redundant compensation arrangement that will not improve conservation outcomes. Such arrangements may replace recurrent funding of reserve management with offset funds. It is a dud deal and creates an expectation in land managers that reserves can find additional funds for management by clearing endangered ecological communities. We oppose biodiversity offsets partly because these arrangements can accelerate the loss of threatened ecosystems and wildlife while creating the opposite impression.

There are also no offsets proposed for the vine Marsdenia viridiflora subsp. viridiflora. There should be.

Impacts of aircraft noise on wildlife

The impact of aircraft noise on wildlife has been little studied. Noise pollution can affect plant pollination and disrupt seed dispersal by birds (Francis, C.D. et. al. 12 April 2012, Noise pollution alters ecological services: enhanced pollination and disrupted seed dispersal, in Proceedings of the Royal Society). In the absence of full scientific knowledge, the Grand Canyon National Park draft EIS examined areas where aircraft noise would be audible to humans and examined the range of wildlife that could hear aircraft noise within those areas (National Park Service, U.S. Department of the Interior, 2011 Feb., Special Flight Rules). Species of ‘special status’, such as the peregrine falcon and California condor, were considered separately.

Using human impacts as a surrogate for wildlife impacts in the absence of full scientific knowledge enables these impacts to be brought into consideration in the environmental assessment of aircraft overflights. The re-exhibited draft EIS must adopt this approach so as to protect wildlife from aircraft noise.

Bushfires: Impacts both to and from the Proposed Airport Site

The Blue Mountains Greens oppose the draft EIS as the subject of bushfire impact is only confined to mitigation measures for the proposed site. The issue of fire is dealt with in a 2 line paragraph on (Vol 2 Ch 16 P.295 at S.16.4.2.9 “may be an impact on flora and fauna at the site and in the locality”)

There is no mention of mitigation of risk of bushfire from outside the proposed airport site, or of the impact of fire escaping from the proposed site during construction and operational stages to the areas outside of the proposed facility, other than a brief mention relating to the areas immediately adjacent to the site boundary. There is no mention of increase in risk from dumped aviation fuel, emissions and unburnt fuel on surrounding residential areas and vegetated areas, nor in the adjacent GBMWHA or BMCC areas.

There is no mention of the impact on the proposed airport site of the implications of a Bushfire emergency from outside the site as per the 2001 Mt Hall Bushfire emergency where the fire front crossed the dam and impacted on Warragamba, Wallacia, Mulgoa, Silverdale and Badgerys Creek. (The RFS and NPWS have mapping related to this Bushfire emergency period.)

There is no statement in the draft EIS of an accidental ignition of combustible fuels or the resulting fire from aircraft incidents (p.296) that may lead to injury or mortality of flora and fauna at the site or in precinct.

We note that there is only a brief reference in passing to adopt operating procedures from McArthur Bushfire District Fire Management Risk Plan.

We provide reference to an important historic note from The Parliamentary and Coronial findings regarding the 2001/02 Mt Hall Section 44 Bushfire management operations. Both inquiries drew attention to the issue that there was no reference to adjoining individual bushfire district Bushfire Risk Management Plans, regarding cross-referencing of operations at the interface of each adjoining fire district where the impact of and from bushfire may cross fire district boundaries, leading to poor inter-district coordination by bushfire districts particularly at the periphery of boundaries where the proposed airport site is located.

The conclusions of both inquiries recommended that this issue be properly addressed for any future emergencies of consequence where such an impact from fire would occur. To our knowledge this has not been formally adopted.

This leads us to make the recommendation that any final EIS Western Sydney Airport must include mandatory input to properly address the issue of Bushfire impact both to and from the proposed airport site – not only from the McArthur RFS Bushfire District, but also including the adjoining Penrith, Blue Mountains, Blacktown and Hawkesbury RFS Bushfire Districts.

Additionally input must be invited from the relevant NSW Fire and Rescue districts to also be placed on notice to address this most important and serious omission of this issue.

Conclusion

The Blue Mountains Greens oppose the proposed Western Sydney Airport.

The ‘Assessment of significance of MNES [Matters of National Environmental significance]’ states (Appendix D of Draft EIS, page 1):

The Greater Blue Mountains World Heritage Area (GBMWHA), is located around 10 km to the west of the airport site and may be affected by potential direct impacts. A detailed assessment of significance of impacts on the GBMWHA will be included in a Final Draft of this report after a multidisciplinary workshop is held to help identify and assess potential impacts

We are aware that the GBMWHA Advisory Committee, a key stakeholder, was not consulted during the preparation of the Draft EIS and Airport Plan, despite a commitment by the Australian Government that key stakeholders should be engaged during the preparation of the Draft EIS and Airport Plan. The GBMWHA Advisory Committee should be involved in any such workshop regarding impacts on the GBMWHA.

We note that the guidelines issued by Environment Minister Hunt’s delegate for the preparation of the draft environmental impact statement made specific reference to the Greater Blue Mountains World Heritage Area to ensure that there would be a thorough consideration of potential impacts from the project on the Greater Blue Mountains World Heritage Area (letter dated 13 August 2015 from The Hon Greg Hunt MP Minister for the Environment to Professor Richard Mackay, Chair, Greater Blue Mountains World Heritage Advisory Committee). The fact that the Draft EIS indicates that a properly detailed assessment of impacts on the GBMWHA has not yet been made clearly shows that the Draft EIS has not adequately assessed likely impacts on the World Heritage Area.

We are of the opinion that the proposed Western Sydney Airport is likely to cause the degradation of the outstanding, internationally recognised values of the GBMWHA. Given the likely adverse impacts on the GBMWHA, approval of the proposed Western Sydney Airport is not in keeping with the Australian Government’s international obligations.

We are also opposed to the impact that the proposed Western Sydney Airport will have on Sydney’s water quality with potential flight-paths and associated convergence points adjacent to Lake Burragorang and Prospect Reservoir respectively, in the take-off and landing sequence of both the “05” and “23” operating modes proposed.

We are of the opinion that the proposal will adversely affect the health of the residents of Western Sydney, particularly those living in residential areas in the adjacent precincts of the proposed airport and directly under the “indicative’ flight-paths. Increased pollution and smog levels will all have increasing detrimental impact on residents’ health.

We are opposed to the proposal because of inadequate strategic planning for the Western Sydney Region, including inadequate provisioning for appropriate road and rail easements to connect and/or to by-pass the proposed airport facility and associated infrastructure, resulting in greater levels of congestion and transport gridlock than already exist. There is no provision for an aviation fuel easement and line connecting the airport to existing aviation fuel assets, adding to further unacceptable congestion and freight movements of dangerous goods, adding further risk to those travelling along poorly planned roads .

This Airport must be stopped and the construction of High Speed Rail begun, forthwith.

Authorised by D. Hayden for The Greens NSW, 19A/1 Hordern Place Camperdown NSW 2050