Impacts of WSA on nation’s most visited World Heritage Listed National Park potentially disastrous: Council submission to Draft EIS reveals

14 Dec 2015

Blue Mountains City Council’s submission to the Australian Government states that the potential impacts of the Western Sydney Airport at Badgery’s Creek on the Greater Blue Mountains World Heritage Area (GBMWHA) have been seriously overlooked with potentially disastrous consequences on its World Heritage values and the regional economy of the Blue Mountains.  

A wide ranging independent review of the draft EIS, commissioned by the Western Sydney Regional Organisation of Councils (WSROC) affirms Council’s concerns.
Council’s submission also states that the Australian Government has not taken into account current international trends in the management of aircraft noise in national parks when proposing to operate a 24 hour flight path over the Greater Blue Mountains World Heritage Area. 
Mayor of City of Blue Mountains, Cr Mark Greenhill said, “The City of the Blue Mountains is a special place of unsurpassed natural values which the draft EIS has failed to take into consideration.  It’s one of only two cities in the world within a World Heritage listed National Park and it’s also our nations’ most visited National Park, attracting 3.5 million visitors every year.  The assessment of the potential impacts on our community, nature based recreation, the tourism industry, our wildlife and on Aboriginal people’s connection to Country in the draft EIS has been found to be grossly inadequate and bordering on non-existent.”
Council Position
While Blue Mountains City Council is generally opposed to a second Sydney airport at Badgerys Creek an independent review of the Western Sydney Airport EIS confirms that the draft EIS is grossly inadequate and shows a complete disregard for the people of the Blue Mountains and Western Sydney as well as the Greater Blue Mountains World Heritage Area.
“The Council opposes flight path activity being concentrated over the Blue Mountains and the impact on our local community, quality of life and the environment”, said the Mayor. “The EIS is a rush job done in just 8 months.  The first one took more than two years.”
Currently, the merge point of arrivals is directly over Blaxland in the lower Mountains. Further, the draft EIS only looks at the first 5 years of operation for the airport – with the number of flights similar to that of Townsville Airport. The Mayor said that the EIS indicates that when a second runway is built and passenger numbers peak in years to come, “we will be dealing with something more like Dubai Airport.”
The Mayor said, “Aeroplanes will be flying over our homes and our World Heritage National Park 24 hours a day, 7 days a week. No curfew. No alternative flight paths have been considered in detail and noise pollution, air pollution, human health, and our precious wilderness and tourism economy were all glossed over in the draft EIS.”
At an Extraordinary Meeting on Tuesday 15 December, the Council will consider its draft submission on the EIS, and a number of recommendations, including:

  • That the Council writes to the Minister for the Environment, the Hon. Greg Hunt MP, INDICATING that the draft EIS is grossly inadequate for consideration of the environmental and livability consequences for such a major infrastructure project, and that as a result the draft Airport Plan for stage 1 not be determined;
  • That the Council asserts its opposition to the significant and irreversible impacts on the Blue Mountains environment and community identified in the draft Environmental Impact Statement, and confirmed in the independent peer review, that will occur from the proposed airport flight paths on the Blue Mountains communities and Greater Blue Mountains World Heritage Area;
  • That the Council writes to the Deputy Prime Minister and Minister for Infrastructure and Regional Development, the Hon. Warren Truss MP reiterating that the draft EIS lacked a full analysis of alternate flight paths options across Sydney, including noise impact assessments, considered essential for a project of this scale and community impact into the future;
  • That the Council writes to the Deputy Prime Minister and Minister for Infrastructure and Regional Development, the Hon. Warren Truss MP, seeking an assurance that the proposed and unacceptable concentration of aircraft and merge point above the Lower Blue Mountains, shown in the short-term plan of flight paths, will be ruled-out;
  • That Council writes to the Minister for Environment, the Hon Greg Hunt MP, seeking advice from UNESCO regarding the potential impact on the World Heritage listed area, prior to any determination of the draft Airport Plan;

“We do not accept that the draft EIS is adequate for a project of this scale.  It is imperative that the Australian Government commit to conducting a rigorous and detailed EIS, particularly given the airport is proposed to be operational 24 hours a day”, concluded the Mayor.
“The people of Western Sydney and the Blue Mountains deserve better. We believe the most significant proposal affecting the liveability of the Blue Mountains and Western Sydney for the next Century needs to be done properly.”
Value of the Tourism Industry
Council’s submission identified Tourism as one of the major industries in the Blue Mountains and key drivers of the regional economy. In the year ending June 2015, the Blue Mountains received approximately 3.5million visitors, expending $558 million.  Total value to the local economy by the tourism sector is estimated to be over $195 million with 13% of jobs being tourism based, with other key sectors such as retail trade being dependent on tourist activity.
“The draft EIS only considered the positive benefits of an airport in terms of attracting more visitors to the Blue Mountains,  but we are concerned that a concentration of flight activity will have the reverse effect with people choosing other quieter destinations as a result.
Whether it’s visiting a health spa, bush walking or camping - people will be forced to choose whether they pursue these activities under a flight path or select a quieter location elsewhere.  Our towns and community depends on tourism – it’s the lifeblood of our region.  We can’t afford to lose this vital industry”, said the Mayor.
Impact on park user experience
Research commissioned by the Council also states that a clear argument can be made that regular aircraft events of 50-55 decibels (db) would be clearly audible and distinct in the low background noise environment within the national park and would therefore significantly alter the natural soundscape. 
The submission also cites US research which shows that the characteristics of aircraft noise and natural sounds are very different and that recreational users are more sensitive to artificial noise intrusion.  A 2011 US study found that 95% of respondents thought providing a natural quiet environment where the sounds of nature were dominant was an important reason for visiting.
“The EIS states that there will be no real impacts on the users of the GBMWHA based on dba (noise) levels alone but that is not in the context of someone using the national park”, said the Mayor. “This US study shows us that ‘the natural quiet’ is an essential part of the visitor experience”.
Current international trends aircraft noise management
Council’s submission points to the US Government as a model of best practice where a range of  legislative measures have been introduced to manage and restrict aircraft noise in a number of national park settings in order to restore the ‘natural quiet’.  The world famous Grand Canyon has a target of no audible aircraft noise for 75% to 100% of each day in key areas across the park.
“The US are trying to restore peace and tranquillity across their National Parks and in one of their most prized World Heritage Listed locations – let’s learn from their mistakes and not introduce aircraft noise here from the outset”, said the Mayor.
Landscape and visual amenity
Visual amenity, lighting, sky glow and aircraft light effects on the night sky were also found to be ill considered.  “We are a region that’s highly valued in the day for our ‘blue haze’ and by astronomers and visitors for our dark skies at night.  We also serve as a backdrop to one of Australia’s most cosmopolitan cities. Any impacts are unacceptable for such an iconic location”, the Mayor added.
Impacts on wildlife
The EIS was also found to have made questionable assertions relating to the impacts on wildlife.  The EIS inferred that the response of one species could be extrapolated for the range of fauna across the GBMWHA. A closer examination of the study cited in the draft EIS also revealed that only one of the two types of ducks studied actually became habituated to noise while the other did not. 
Commenting on the study the Mayor said, “Council’s submission has identified more recent research which does show that an increase in noise levels will lead to changes in animal behaviour and distribution.  That research also shows that rises in background noise for animals can lead to an impact on the masking of signals for communication, navigation, prey detection, predator avoidance and environmental monitoring.  The Australian Government needs to go back to the drawing board on this one and do a proper job.”
Significant negative impact on Aboriginal culture and country
In a separate submission the Darug and Gundungurra Traditional Owner members of the Blue Mountains Aboriginal Advisory Council have expressed their concerns that the airport would have significant impacts on their Country and on their cultural beliefs and practices.  Some of the concerns highlighted in their submission include:

  • The consistent sound of aircraft flying over the bush in Darug and Gundungurra Country will affect the living beings that remain in our respective Countries, we believe this will particularly have an effect on birds with their calls to each other and to us being drowned out by jet engines;
  • The sounds of the living bush and how we hear, understand and learn from our Country and all that is within it will be adversely effected;     
  • The regular sound of aircraft will also impact on our ability to speak with our Country, including communicating with living and spiritual beings. 

A full outline of concerns raised is attached contained within Council’s submission refer pg 56.
Impact on the World Heritage listing
The draft EIS was also found not to have acknowledged the concerns originally raised by the International Union for the Conservation of Nature (UNESCO) in 1999 when the submission for World Heritage Listing was being considered. The Mayor said, “We know that the potential introduction of an airport at Badgerys Creek back in 1999 was cited as the reason for deferring the World Heritage listing in the first place. The airport was considered by UNESCO to be a factor which might compromise the integrity of the area.  Not acknowledging this in the EIS is a major failure and could pose a real threat to our World Heritage status if not taken seriously.’
Noise impacts greatly under-estimated
Additional research commissioned by Blue Mountains City Council suggests that when assessing aircraft noise intrusion in natural settings on the basis of noise levels alone is not appropriate and that the EIS  claims that large numbers of audible events below 50-55db are not significant, has not been sufficiently justified.  US studies have suggested that in low noise level environments characterised by natural sounds, the regularity and duration of intrusive man-made noise that is unexpected in the setting are considered to be more relevant measures when considering wilderness setting.
“Noise is a complex issue, particularly within a natural setting and when a 24hour airport operation is being proposed.  We can’t afford to take a narrow approach when assessing the potential impacts.  The noise studies needed to be broadened”, said the Mayor.
Airspace Architecture
The Council submission also asserts that the lack of evaluation of alternative flight paths is a flaw in the assessment and against the Australian Government’s own guidelines.
“The community is telling Council in no uncertain terms that this is unfair and unworkable.  We are calling for a review of unfair and inequitable flight paths, and for flight path options that exclude overflight of the GBMWHA and adjacent residential areas”, said the Mayor.
“The GBMWHA and National Park is loved by local residents, Australian and international visitors alike. We are promoted by the Australian Government as one of Australia’s ‘must see’ nature destinations and one of 16 National Landscapes.  We simply cannot afford to take any steps that will jeopardise this truly magical and special place.

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