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2020-10-12 GC Agenda - Item 9 - Attachment 1 - Aircraft Noise Ombudsman Report - Investigation
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12 October 2020
General Committee Agenda
Item 10 - Attachment 1
Investigation into complaints about the
introduction of new flight paths in
Sunshine Coast (April 2020)
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Section 2
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Section 3
Table of Contents
1 Executive Summary ................................................................................................. 1
Introduction .............................................................................................................. 1
Community engagement .......................................................................................... 1
Conclusions ............................................................................................................. 2
Recommendations ................................................................................................... 2
2 Introduction .............................................................................................................. 4
Methodology ............................................................................................................ 4
3 Consultation by Airservices – legislation, policy and procedural documents ............ 5
Legislation and legislative instruments ..................................................................... 5
Airservices’ public policies ....................................................................................... 6
Airservices’ internal procedures ............................................................................... 7
4 The development of flight paths at Sunshine Coast ................................................. 9
Background ............................................................................................................. 9
Airservices’ flight path design work ........................................................................ 10
Targeted Environment Impact Assessment (TEIA) ................................................ 10
5 Community Consultation ........................................................................................ 12
Joint Stakeholder Communication and Engagement Plan...................................... 12
Airservices’ Stakeholder Engagement Plan ........................................................... 12
6 Preparation for consultation ................................................................................... 15
Newspaper advertisements ................................................................................... 15
Letters to schools and other sensitive sites ............................................................ 16
Contact with known community groups .................................................................. 16
Emails to existing contacts within complaints database ......................................... 16
Mailout ................................................................................................................... 16
Airservices web-based information about its consultation ...................................... 17
7 Consultation in practice ......................................................................................... 18
Website information ............................................................................................... 18
Face-to-face consultation sessions ........................................................................ 19
Summaries of feedback ......................................................................................... 21
Stakeholder Round Table ...................................................................................... 22
Airservices’ proposed final design.......................................................................... 23
The ‘Engage Airservices’ platform ......................................................................... 23
Further representations ......................................................................................... 25
8 Complaints about the process................................................................................ 26
9 Conclusions ........................................................................................................... 27
10 Recommendations ................................................................................................. 30
Aircraft Noise Ombudsman
Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page i
Section 4
1 Executive Summary Introduction From 22 April to the end of July 2019, the Aircraft Noise Ombudsman (ANO) received 299 complaints regarding the proposed flight paths to support a new runway at Sunshine Coast Airport in May 2020. The proposed new runway was the subject of an environmental impact statement (EIS) and associated community consultation conducted in 2014/15 by Sunshine Coast Council. At that time, Airservices Australia (Airservices) agreed with the concept flight paths, developed by a private consultant and included in the EIS, but took no part in the community consultation. In April 2018, Airservices commenced detailed design work on the new flight paths, seeking to maintain alignment with the EIS, except where it identified variations that could reduce noise impacts in some communities to the north-west. Airservices engaged a consultant to conduct a Targeted Environmental Impact Assessment (TEIA) of its proposed flight path design. The TEIA recommended implementation of a community engagement plan that covered all areas predicted to experience future aircraft noise and gave residents an opportunity to raise concerns. Community engagement Airservices determined that it achieved this recommendation through reliance on the broader community update program being undertaken by the Sunshine Coast Airport Expansion Project along with its own targeted consultation only with those areas where its proposed flight paths varied from the concept flight paths in the EIS. There was no assessment by Airservices of the adequacy of the EIS community consultations in 2014/15 nor any consideration of population churn or other factors that may have changed in the community since the earlier consultation. Airservices’ consultation occurred during a six week period in March/April 2019. Airservices took responsibility for consultation in areas where the proposed flight paths deviated from those proposed in the 2014/15 EIS (the target area) and provided technical support for Sunshine Coast Council which was responsible for a community update program with the other affected areas (the general area). The community engagement did not go smoothly, with community awareness of the flight path proposals and consultation sessions heavily reliant on community members using their social media and own letterbox drops to reach interested individuals. Airservices’ early notice of the consultation period had suggested that the community in all affected areas would be consulted. Some two weeks into the consultation period, it became more specific that it was only consulting communities in the target area. This division of responsibilities between Airservices and the Sunshine Coast Council caused general public confusion about who was responsible for what. Airservices underestimated the extent of public interest and had to schedule multiple consultation sessions in groups limited to 50, due to the size of the venues it had hired. Complaints to the ANO reported no notice or lack of timely notice of meetings, inconsistent responses between Airservices and Sunshine Coast Council representatives and lack of clarity about who had responsibility for decisions. Aircraft Noise Ombudsman Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page 1
Section 5
Airservices collated and analysed the feedback received from all areas of the
community about the flight path designs, and undertook some additional briefings
and community updates with affected communities in the general areas after the
feedback period closed. Complaints by residents to Airservices about the process
were not responded to until well after the closure of the consultation period.
Airservices acknowledges that responses to complaints were not completed in a
timely manner, and advised the ANO that community submissions were first
analysed for feedback that could help shape the final flight path designs to ensure
that insights were provided to the flight path design team in a timely manner. When it
finally responded to complaints made about the process, Airservices described its
consultations as “successful”, which served to further anger complainants to the
ANO.
Conclusions
Airservices has a responsibility to engage with the community on the environmental
impact of aircraft operations. Although it did not evaluate or assess the community
engagement process under the EIS in 2014/15, Airservices relied on it to decide that
it had no responsibility to consult any further with residents in the general area in
2019. These areas would be captured by a community update program being
undertaken by the Sunshine Coast Airport Expansion Project. The consultation
process itself was not well communicated and caused public confusion about the
relative responsibilities of Airservices and the Sunshine Coast Council. This persisted
throughout the consultation period and after.
While Airservices was drawn into considering submissions from the general area by
the sheer volume of response, it became clear to those making submissions that they
had little chance of influencing the outcome. The predictable result was the
community outrage expressed in the complaints to the ANO.
Recommendations
Where Airservices proposes flight paths required by an airport (or other third party)
development, it needs to be involved early in the planning process and to clearly
specify its role and the terms on which its responsibility to engage with the
community on changes to aircraft operations will be managed.
Airservices should develop a framework for third party
proposed changes that:
(a) provides robust and dependable governance
arrangements to manage its early and ongoing
engagement with third parties
(b) establishes clear lines of accountability and documents
these arrangements as they evolve
(c) ensures an effective consultative process, which includes
monitoring the adequacy of any third party consultations
being relied on.
At the Sunshine Coast, Airservices can use its post-implementation review process
to re-engage with communities and consider community-suggested alternatives to
the flight paths that will be introduced in support of the new runway.
Aircraft Noise Ombudsman
Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page 2
Section 6
Airservices should, as soon as practicable, design an
effective post-implementation review (PIR) process for the
Sunshine Coast flight path designs, that does not perpetuate
design constraints requiring alignment with EIS concepts,
and which encompasses:
(a) consideration of identified community-suggested
alternatives
(b) a community engagement process that provides for
genuine opportunities for community contributions to
influence decisions
(c) application of the latest version of Airservices’ National
Operating Standard (NOS) Environmental Management
of Changes to Aircraft Operations (AA-NOS-ENV-2.100).
Aircraft Noise Ombudsman
Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page 3
Section 7
2 Introduction
2.1 On 22 April 2019, the ANO received the first complaint from a Sunshine Coast
resident about Airservices’ community engagement and provision of
information in connection with proposed flight path changes at Sunshine Coast
Airport consequent to the planned new runway. Over the next 30 days, the
ANO received a total of 274 complaints about issues associated with the
proposed changes and the consultation process undertaken by Airservices. In
total the ANO received 299 complaints to the end of July 2019.
2.2 On 30 May 2019, the ANO decided to commence a multiple complaints
investigation into flight path changes at Sunshine Coast and advised the
Airservices Board accordingly.
Methodology
2.3 In developing this report, the ANO:
considered each of the complaints received and any subsequent
information, insights and observations provided by complainants
reviewed all of the material Airservices made available to the community
requested specific information and answers to questions arising from
complaints or from the ANO’s review of Airservices’ material and carefully
considered the information and answers provided in response
conducted independent research and monitored discussions of the issues
in the media and on some social media platforms
met with affected residents, councillors and various staff of Airservices,
and observed a Stakeholder Round Table.
Aircraft Noise Ombudsman
Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page 4
Section 8
3 Consultation by Airservices – legislation, policy and
procedural documents
Legislation and legislative instruments
3.1 One of the functions of Airservices under section 8 (1)(d) of the Air Services
Act 1995 (Cth) is “carrying out activities to protect the environment from the
effects [and associated effects] of the operation of” aircraft.
3.2 Section 9 makes it clear that, in carrying out its activities, Airservices must
regard safety “as the most important consideration” and, subject to safety,
“must perform its functions in a manner that ensures that, as far as
practicable, the environment is protected from the effects [and associated
affects] of the operation and use of aircraft.”
3.3 Section 10 entitled “AA must consult and co-operate” requires Airservices to
consult, in the performance of its functions, with a number of relevant
government and industry bodies. Persons affected by aircraft operations are
not specified although “consumer and other relevant bodies” are.
3.4 Section 16 empowers the Minister to give written directions to Airservices, with
which it “must comply”. Ministerial Direction M37/99 requires Airservices to
carry out the following activities:
… (ii) Provide advice, information and data on environmental aspects of air traffic
management including aircraft movements, aircraft noise, aircraft engine emissions and
aircraft operations.
(iii) Initiate and participate in discussions, consultations, studies and research with the
aviation industry and the community in relation to environmental aspects of air traffic
management.
…(vi) Provide advice and information on aircraft environment related matters to, and
participate in, airport consultative committees at those Australian airports that have such
a committee.
…(xii) Provide advice, information, guidance and assistance at locations outside
controlled airspace on environmental aspects of aircraft operations, movements and
procedures to the Department, the aviation industry and the community.
3.5 Under section 17 of the Air Services Act 1995, the Minister issued a notice to
Airservices known as the Statement of Expectations for Airservices Australia
for the Period 22 May 2017 to 30 June 2019, which included:
4. Stakeholder Engagement
I expect that in performing its functions Airservices will:
(a) undertake effective and ongoing engagement with the community, industry and
Government on the development and implementation of significant changes by
Airservices to air traffic and ARFFS;
(b) engage constructively in processes where it can provide information, assistance or
advice for policy formulation, implementation and regulation undertaken by Government
agencies, both within and outside my portfolio;
Aircraft Noise Ombudsman
Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page 5
Section 9
(c) contribute to a coordinated approach to airport planning including appropriate
participation in, and providing information to, planning coordination forums, community
aviation consultation groups, and the National Airports Safeguarding Advisory Group;
and the Expectations for the period 15 July 2019 to 30 June 2021 were:
4. Stakeholder Engagement
I expect Airservices will continue to:
a) undertake effective and productive engagement with the community and industry
based on mutual understanding and respect.
b) communicate clearly and regularly with my Department and CASA, industry and the
community on the development and implementation of significant changes to air
navigation and ARFFS.
c) proactively provide information, assistance and advice to Government agencies for
policy formulation, implementation activities and regulation purposes.
d) contribute in the coordinated approach to airport planning including appropriate
participation in planning coordination forums, community aviation consultation groups,
and the National Airports Safeguarding Advisory Group.
Airservices’ public policies
3.6 Airservices Commitment to Aircraft Noise Management1 states that:
Safety is our number one priority, but we recognise that aircraft noise, a by-product of a
growing economy, is the most significant cause of adverse community reaction to
increased aviation operators. Our long-term goal is to minimise, and where possible
reduce, the impact of aircraft noise. This includes collaboration and consultation with
the community and aviation industry on proposed air traffic changes as well as working
with them to explore and employ smarter operating solutions.
We recognise the importance of proactive community engagement and public
participation when managing noise related issues.
To ensure this we will:
provide clear, timely and accessible information to the community on current aircraft
noise, future aircraft noise and aircraft operations
engage openly and constructively with the community, and consult in a timely
manner on aircraft noise and changes to the air traffic management (ATM) system
that impacts the community
actively investigate changes which deliver improved noise outcomes, including
review of ATM procedures
ensure transparency in our processes and actions which impact the community
3.7 Airservices’ Communications and Consultation Protocol2, says:
We are committed to providing information to stakeholders and the community on
significant changes that may affect them, and to incorporating stakeholder feedback into
our planning, decision-making and implementation processes.
1 Airservices Australia, Airservices Commitment to Aircraft Noise Management, November 2013, p. 5-6
2 Airservices Australia, Communications and Consultation Protocol, 4 July 2016, p.3-6
Aircraft Noise Ombudsman
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Section 10
…
Airservices is committed to open and timely communication and consultation. We
engage with the community in relation to a range of issues:
services (air traffic control and aviation rescue and fire fighting)
flight path changes, particularly if residents are newly overflown
airspace design
our infrastructure projects
managing and responding to safety and environmental issues.
According to the level of change and likely impact, different forms of communication and
consultation activities can be used. Airservices seeks to provide the community and
stakeholders with the opportunity to learn and understand how a change may impact
them, why it is necessary and to provide an opportunity for feedback, where practicable.
We commit to:
listening to the community and stakeholders
acknowledging and considering feedback (noting that some changes are required for
safety considerations)
communicating decisions and the reasons for them.
Airservices’ internal procedures
3.8 Airservices’ National Operating Standard (NOS) Environmental Management
of Changes to Aircraft Operations (AA-NOS-ENV-2.100)3 specified that:
All proposed changes to Airservices’ air traffic management practices that may affect
aircraft operations shall:
1. Be assessed for environmental impact prior to implementation;
2. Undergo stakeholder engagement planning [SEP] and stakeholder consultation prior
to implementation where potential community or environmental impacts are identified;
3. Be reassessed prior to implementation, if the proposal has already been impact
assessed in accordance with this NOS and:
a. has subsequently been modified or;
b. over 18 months has elapsed since the initial assessment process;
4. Be undertaken in accordance with this National Operating Standard (NOS) and
subordinate procedures;
5. Seek to achieve a noise outcome which balances the needs of the community and
aviation industry stakeholders.
3.9 The NOS also stated:
7. Community consultation under the SEP shall:
3 Airservices Australia, Environmental Management of Changes to Aircraft Operations (AA-NOS-ENV-2.100)
(NOS), Version 13: Effective 7 August 2018, p. 5
Note: Unless otherwise specified, in this report reference to the NOS means Version 13 of the NOS.
Aircraft Noise Ombudsman
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Section 11
a. Be targeted to all areas potentially affected by the change;
b. Provide justification for the change, explicitly describing how any potentially
negative impacts are balanced by benefits, and on what basis the chosen
approach is optimal compared to viable alternatives;
c. Describe timeframes for implementation, specific proposed flight paths, and likely
noise levels and associated impacts;
d. Consider the social, economic and cultural context of the communities being
consulted to ensure genuine engagement and accessibility of information.
8. The community shall receive all relevant information relating to a change proposal
within a reasonable timeframe, to provide them with the opportunity to effectively give
feedback prior to implementation.4
4 ibid, p. 16
Aircraft Noise Ombudsman
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Section 12
4 The development of flight paths at Sunshine Coast
Background
4.1 Sunshine Coast Airport, which is owned by Sunshine Coast Council and
operated by Palisade Investment Partners, planned to implement a new
runway in May 2020 as part of its Sunshine Coast Airport Expansion Project
(SCAEP)5.
4.2 On 31 January 2011, the project was referred by the Sunshine Coast Council
to the Commonwealth Minister for the Environment as part of the approval
process. Separately, on 6 September 2011, Airservices and the Civil Aviation
Safety Authority (CASA) advised the Minister that the project would require the
development of new flight paths and requested advice on the requirements
and criteria for an environmental assessment.
4.3 On 21 May 2012, a delegate of the Minister for the Environment decided that
the proposal, including airspace management, would be assessed by an
environmental impact statement (EIS) conducted by the Sunshine Coast
Council.
4.4 The EIS and the community consultation was based on concept flight path
designs developed by a private sector designer. The designer’s Airspace
Design Concepts Report6 of September 2012 noted that:
Four consultation meetings were held with Airservices Brisbane Centre staff from June
to August 2012 to further assess the suitability… and agree on the basic flight path
corridors…7
4.5 In providing its agreement in a letter from Airservices’ Aviation Relations
Manager to Sunshine Coast Airports’ Planning and Major Projects Manager on
23 October 2012, Airservices advised that:
Airservices recognises that ongoing community engagement associated with the
introduction of these projected flight corridors will be required and advise that
Airservices is willing to provide relevant support for this engagement where appropriate.
4.6 The Sunshine Coast Council conducted public consultation on its EIS from 29
September 2014 to 13 November 2014. On 18 February 2015, additional
information for the EIS was requested by the Queensland Coordinator-General
and as a result a further public consultation process was carried out from 2
November 2015 to 30 November 2015. Airservices had no involvement in
either consultation process.
5 See: https://www.sunshinecoast.qld.gov.au/Council/Planning-and-Projects/Major-Regional-Projects/Sunshine-
Coast-Airport-Expansion-Project
6 Leading Edge Aviation Planning Professionals (L.E.A.P.P), Sunshine Coast Airport Airspace Design Concepts
Report, issued 28 September 2012
7 ibid, p. 1
Aircraft Noise Ombudsman
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Section 13
4.7 On the basis of the EIS and additional information provided by the Sunshine
Coast Council, the Minister for Environment approved the project on 18 July
2016. A delegate for the Minister for Environment advised Airservices in a
letter dated 28 June 2016 that:
The EIS indicates that whilst some dwellings may be newly exposed or experience an
increase of aircraft noise, on balance there will be an overall reduction of dwellings
experiencing varying degrees of aircraft noise. On this basis, the Civil Aviation Safety
Authority and or Airservices Australia should give the relevant authorisation(s) should
they be engaged to do so or as they are required to do so.
In giving any authorisation, consideration should be given as to whether the
authorisation would result in changes to the Australian Noise Exposure Concept
(ANEC) or the Australian Noise Exposure Forecast (ANEF) contours (as applicable),
and or to the N70 contours compared to those presented in the EIS.
In particular, there should not be a significant increase in the extent and distribution of
the ANEC / ANEF contours in so much as it would potentially impact the health, safety,
welfare or quality of life of people and communities. There should also not be a
significant increase in the extent and distribution of N70 contours in so much as it would
potentially impact the health, safety, welfare or quality of life of people and communities.
This is to ensure that people and communities in the vicinity of the airport are not
exposed to aircraft noise patterns that are significantly different to those presented and
consulted on during the assessment process.
Airservices’ flight path design work
4.8 Airservices proposed to introduce flight paths for the new runway at Sunshine
Coast Airport, known as Runway 13/31, planned to be operational in 2020.
Airservices began its flight path design work in late 2017 when approached by
the Sunshine Coast Council. Detailed design work commenced in April 2018.
4.9 In determining the flight paths, Airservices set out to align its designs as
closely as possible to the concept flight paths defined in the EIS. While
seeking to align with the concept flight paths, Airservices did identify some
variations that it considered would deliver environmental benefits.
Targeted Environment Impact Assessment (TEIA)
4.10 Airservices engaged GHD, a professional services firm, to undertake a
Targeted Environmental Impact Assessment (TEIA V1)8, in accordance with
Airservices’ own methodology as described in its NOS9. This assessed
Airservices’ proposed flight path design, which it would take to the community
and other stakeholders for consultation and which would inform Airservices’
Stakeholder Engagement Plan (SEP).
4.11 The Executive Summary in GHD’s TEIA concluded that:
The findings of this targeted EIA are considered generally consistent with the findings of
the EIS as would be expected given the similarity of the proposed flight paths. Minor
discrepancies between the results documented in the targeted EIA and the EIS were
8 GHD, Airservices Australia Proposed change to flight paths at Sunshine Coast Airport Targeted environmental
impact assessment March 2019, Version 1: Effective 25 February 2019 (TEIA V1)
9 Airservices Australia, NOS, op. cit
Aircraft Noise Ombudsman
Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page 10
Section 14
considered to be mainly attributable to updated model inputs to better reflect current
airport operating conditions.
In consideration of the limited environmental impact predicted against AA-NOS-ENV-
2.100, in combination with the general consistency with findings of the EIS, it is not
considered likely for the proposed change to result in a significant increase in impact to
the health, safety, welfare or quality of life of people and communities. It is therefore
considered that the proposed change does not warrant further referral under the
Environment Protection and Biodiversity Conservation Act 1999.
It is nonetheless recommended that a community engagement plan be implemented
that encompasses the areas predicted to experience aircraft noise and informs
residents of the proposed change and provides an opportunity to raise concerns. 10
10 GHD, TEIA V1, op. cit
Aircraft Noise Ombudsman
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Section 15
5 Community Consultation
Joint Stakeholder Communication and Engagement Plan
5.1 In the case of the Sunshine Coast, leaving aside the EIS processes in
2014/15, community engagement about the proposed airspace and flight path
changes was undertaken jointly by Airservices, Sunshine Coast Airport and
Sunshine Coast Council.
5.2 The arrangements for the period of public engagement (20 March to 30 April
2019) were documented in a joint Stakeholder Communication and
Engagement Plan (SCEP)11.
5.3 The SCEP noted in its introduction that:
Airservices must meet a regulatory obligation to show evidence that affected
communities were engaged with how the designs would impact them.12
and defined Airservices’ engagement responsibility as:
Release of updated information:
Flight paths
Airspace design
Impact on communities (what will I see and hear?)13
Airservices’ Stakeholder Engagement Plan
5.4 Separately, and as required by its NOS14, Airservices had prepared its own
internal Stakeholder Engagement Plan (SEP)15. Version 1.0 of the SEP was
approved on 17 March 2019 by the Acting Executive General Manager, Air
Navigation Services, with the following caveat, among others:
The SEP also provides limited social, economic and cultural context of the communities
being consulted to ensure genuine engagement and accessibility of information,
however this will be addressed in future versions and other planning products. 16
11 SCAEP Stakeholder Engagement Working Group (SEWG) (comprising Sunshine Coast Council Airport
Expansion Project Team (SCC), Airservices Australia and Sunshine Coast Airport (SCA) Pty Ltd), Airspace change
and flight path design for Sunshine Coast Airport RWY 13/31 Stakeholder Communication and Engagement Plan
20 March – 30 April 2019 (SCEP), Version 5: WEDNESDAY 13/3/19 4.30pm
12 ibid, p. 3
13 ibid, p. 12
14 Airservices Australia, NOS, op. cit
15 Airservices Australia, Stakeholder Engagement Plan, Sunshine Coast Airport Airspace Changes, Runway 13/31
(SEP), Version 1.0: Effective 17 March 2019 (SEP V1)
16 ibid, p. 1
Aircraft Noise Ombudsman
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Section 16
5.5 Version 2.0 of Airservices’ SEP17 was approved effective 25 March 2019, five
days into the six week community engagement consultation period. It was
largely unchanged from Version 1.0 and included a detailed Suburb Analysis.
5.6 The SEP’s Executive Summary said:
Airservices will undertake consultation with impacted communities and industry
stakeholders to inform the final airspace and flight path design. 18
and stated its scope as follows:
The scope of this Stakeholder Engagement Plan (SEP) is limited to stakeholder
consultation activities required for the reconfiguration of airspace and flight path
changes as they differ from what is depicted in the EIS to what Airservices is proposing
at the Sunshine Coast Airport to support the operation of RWY 13/31.19
5.7 Airservices described its consultation approach in the SEP as follows:
SCC and SCA are facilitating engagement activities aimed to inform and update the
community on the development and implementation of Runway 13/31.
Airservices will undertake specific engagement and consultation activities with
communities effected (sic) by the proposed changes to flight paths that differ from those
depicted in the EIS.
5.8 In effect, Airservices’ consultation would be targeted to those areas which
were not considered under the EIS, with those communities that would be
affected by the flight paths that remained consistent with the EIS to be
captured by the SCC and SCA community update program.
5.9 The community update program is described in the Stakeholder
Communication and Engagement Plan (SCEP)20 as to be “run co-jointly
between the three principal parties: Airservices Australia, Sunshine Coast
Council and Sunshine Coast Airport Pty Ltd”21. Its aim is described as:
To deliver a jointly managed stakeholder engagement project to advise government,
industry and communities of the airspace change and flight path designs for the new
runway at the Sunshine Coast Airport 22
5.10 Airservices’ SEP made no assessment of the adequacy of the EIS
consultations by Sunshine Coast in 2014/15 as a basis for this consultative
approach. There was no analysis of the potentially changed composition of the
community or the impact that the passage of so many years might have on
community awareness of, comfort with or acceptance of the changes.
17 Airservices Australia, Stakeholder Engagement Plan, Sunshine Coast Airport Airspace Changes, Runway 13/31
(SEP), Version 2.0: Effective 25 March 2019 (SEP V2)
Note: Unless otherwise specified, in this report reference to the SEP means Version 2.0 of the SEP.
18 ibid, p. 4
19 ibid, p. 5
20 SCAEP Stakeholder Engagement Working Group (SEWG), op. cit
21 ibid, p. 11
22 ibid, p.3
Aircraft Noise Ombudsman
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Section 17
5.11 Noosa Council advised the ANO that the Noosa population had changed
significantly in the preceding five years:
Council has tracked our population turnover for at least twenty years using two different
information sources – ABS census statistics and electoral rolls. Both have produced
statistically consistent results in terms of our population churn in Noosa - approximately
10% per year. This means that for every four years, there is approximately 40%
population churn rising to 50% every five years.
5.12 The SEP included a map and specified its targeted consultation area in detail:
Airservices will provide on-site community specific consultation with communities to the
north-west of the airport, where the proposed design varies from the original design
concept. This consultation will be in addition to supporting the Sunshine Coast Council
led engagements.
Communities to the north-west where increased overflights associated with proposed
flight paths compared to the EIS include Cooroy Mountain, Cooran, Pomona, Doonan,
Pinbarren, Traveston, Cootharaba and Verrierdale. 23
23 ibid, p. 9
Aircraft Noise Ombudsman
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Section 18
6 Preparation for consultation
Newspaper advertisements
6.1 A week into the consultation period, Airservices placed a public notice in six
local papers:
Sunshine Coast Daily (27 March 2019)
Buderim Chronicle (28 March 2019)
Caloundra Weekly (28 March 2019)
Nambour Weekly (28 March 2019)
Coolum Advertiser (28 March 2019)
Coolum North Shore News (29 March 2019).
6.2 These notices were placed in the classifieds section of the papers in all but
one instance. This placement is unlikely to have come to many readers’
attention.
6.3 The newspapers selected serve audiences in locations largely outside the
area Airservices was intending to target with its consultations. Those
newspapers that best served the target area were the Noosa News, Noosa
Today, Cooroy Rag and the Eumundi Green, none of which were used by
Airservices to advertise its consultation. The Sunshine Coast Council
advertised the drop-in consultation sessions and information kiosks it was
running in areas outside the target areas in these publications, excepting in
the Cooroy Rag.
6.4 One complainant, who resides in the target area, complained after the
consultation period closed:
Back in March-April during the consultation period, the general public were not even
aware of the of the Targeted Area’s existence. Ideally in the future, this map [the map
included in subsequent Airservices reports showing the consultation areas] should be
included in meeting notices, in letterbox drops and all newspapers serving the Target
Area, so people might at least be aware of all the changes proposed and how they
differ from earlier designs. [emphasis in original]
The Cooroy Rag is the only newspaper based within ASA’s circled Target Area.
I have searched March-April back-editions of both Noosa Today and Cooroy Rag for all
advertisements placed in these papers, by ASA and Sunshine Coast Council (SCC).
There were no advertisements in these local newspapers before ASA’s community
consultation meetings in Cooroy, Pomona or Cooran.
6.5 This complainant also pointed out that:
The SCC did place a notice in Noosa Today on 14 March in advance of 5 coastal
meetings from Noosaville to Maroochydore, only for venues outside the circled target
area. Cooroibah, Tinbeerwah and other residents in the eastern hinterland, may have
chosen to attend the nearby Noosaville meeting. Therefore, they would have been
aware of the changes in sufficient time to allow them to make submissions. However, to
the west, notices in advance of any meetings inside the hinterland Target Area never
appeared. Consequently, most hinterlanders could quite rightly assume no
notices for meetings in the area, meant no changes in the area. [emphasis in
original]
Aircraft Noise Ombudsman
Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page 15
Section 19
6.6 The only advertisement placed by SCC in the Cooroy Rag appeared on 24
April 2019, on page 31 of the paper, when just one week of the consultation
period remained and after all on-site consultations sessions had been
completed. It made no reference to the new flight paths being over particular
suburbs, or that these were any different to those proposed in the concept
designs included in the EIS.
Letters to schools and other sensitive sites
6.7 The SEP listed a number of schools, hospitals and care facilities, which would
receive communication from Airservices about the proposed airspace change.
Most of these sites were outside the areas targeted by Airservices for
consultation, but were mostly those identified in the TEIA as being within
certain noise contours before opening and/or after opening scenarios.
Contact with known community groups
6.8 Airservices relied on the SCAEP contacting community groups and arranging
a briefing session to be held during the consultation period. Despite a long list
of invitees, only three community groups (Residents for Responsible
Development, Mudjimba Residents Association, Twin Waters West and
Surrounds) attended the session held at the Maroochy RSL, Maroochydore.
Invitations were sent by email to community group email addresses at 4.30pm
on the Friday before the scheduled briefing at 2-4pm on Wednesday 20
March.
Emails to existing contacts within complaints database
6.9 Airservices contacted those individuals with an email address who had been
registered in its complaints database; i.e. those who had submitted a
complaint in relation to Sunshine Coast Airport in the period 1 January 2016 to
20 March 2019. Emails were sent to 183 individuals. Only five individuals
within the suburbs Airservices was targeting with its consultation were
contacted.
Mailout
6.10 The SCAEP undertook a mail-out to approximately 45,000 households on 13
March 2019 advising of the consultation period and the upcoming consultation
sessions that were led by Sunshine Coast Council. Many complainants
reported not receiving this ‘To the Householder’ letter at all or received it too
late to make arrangements to attend the scheduled sessions.
6.11 A resident from within the target area advised:
We were not aware of any proposed flight path changes, consultation meetings, or the
“6-week” submission period. Like many other households in Noosa Shire, we found out
about the changes, long after submissions had closed.
No notices from ASA or Sunshine Coast Council/Airport arrived in our letterbox.
A post on Facebook by Noosa Shire Council is insufficient, not everyone uses
Facebook.
Strangely, no notices or advertisements appeared in our local newspapers, Noosa
News, Cooroy Rag or Noosa Today, which cover the target area
Aircraft Noise Ombudsman
Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page 16
Section 20
Airservices web-based information about its consultation
6.12 On 13 March 2019, a week before the consultation process, Airservices
posted the first of its relevant notices on its website which included:
Sunshine Coast Council, Sunshine Coast Airport and Airservices are committed to open
and timely communication and engagement with all stakeholders who may be affected
by the changes associated with the new airspace architecture required for RWY 13/31.
From late March 2019, Sunshine Coast communities will be invited to participate in a six
week engagement program on the proposed flight paths and airspace changes.
This follows previous community consultation conducted by the Sunshine Coast Airport
in 2014 for the Environmental Impact Statement (EIS) required for the Sunshine Coast
Airport Expansion Project.
Aircraft Noise Ombudsman
Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page 17
Section 21
7 Consultation in practice
Website information
7.1 Airservices used its website as a mechanism for communicating publicly about
its proposed flight path changes. This was an effective tool for
communications, which was updated regularly and provided a range of
relevant information and resources, including general and community specific
Fact Sheets and Frequently Asked Questions during the consultation period.
7.2 The 20 March update included a copy of the Fact Sheet titled “Sunshine Coast
Airport Proposed Airspace Change Runway 13-31”, which identified that:
In 2014, Sunshine Coast Council consulted with the community on early design
concepts, which included an Environmental Impact Statement approved by the State
Government. To support operation of Runway 13/31 in 2020, Airservices proposed
design has been modelled on the flight path design concept in the Environmental
Impact Statement.
To improve environmental impacts, Airservices proposed flight path design variations
from the design concept.
However, there was no reference in any material at this time that the
consultation was limited to only these variations or clear advice that the new
flight path design was necessarily constrained by the flight path design concept
in the EIS. Indeed, the fact sheet said:
Airservices Australia is proposing airspace changes at Sunshine Coast Airport to
support the operation of a new runway, known as Runway 13/31, which will be
operational in 2020.
These proposed designs use modern technology and aircraft capability to be as safe
and efficient as possible. Wherever possible, changes to the flight paths that would
deliver safety enhancements have been identified and these have been balanced with
minimising the effects of aircraft noise on the community, as far as practical.
Airservices is seeking feedback on the proposed flight path design to be considered as
part of the final airspace design.
7.3 On 4 April, Airservices released a “Frequently Asked Questions” document
which it committed to updating:
…as we progress consultation on the proposed airspace and flight path changes to
support operation of Runway 13/31 at the Sunshine Coast Airport
7.4 On 8 April, Airservices announced on its website the commencement of its
series of four consultation drop-in sessions and at the same time was specific
about the limited scope of the consultation. Almost mid-way through the
consultation period, this announcement was the first public indication that
Airservices’ consultation would be limited to the target area:
Airservices has designed proposed airspace and flight paths to support operation of the
new runway and these are modelled on the flight path design concept in the
Environmental Impact Statement. These designs include variations to improve
environmental impacts. Airservices is consulting on the variations to the flight paths
from the approved Environmental Impact Statement.
Aircraft Noise Ombudsman
Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page 18
Section 22
Airservices role is to consult with communities where the flight paths differ from the
flight paths in the Environmental Impact Statement, [emphasis added] and take
feedback on these variations.
7.5 Airservices continued to use its website after the consultation period closed to
update the public. This included the feedback reports, how it used the
feedback in determining a final design, the updated TEIA for the final design
and useful representations of timelines and the potential impacts of the final
design.
Face-to-face consultation sessions
7.6 Airservices scheduled four on-site community drop-in sessions in locations
identified as relevant to communities within its target area. It also made staff
(including senior flight path designers and senior air traffic controllers)
available to provide technical support to consultations undertaken by the
SCAEP team that had the stated purpose of updating the community about
general progress of the expansion project, including the proposed airspace
and flight paths.
7.7 Complaints to the ANO were critical of the conduct of the sessions, referring to
issues including:
No notification or a lack of timely notification about the sessions
Inconsistency in response and information provided by Airservices and
SCA/SCC staff
Lack of access to technical noise specialists
Lack of clarity about who had responsibility for decisions
The ‘drop in’ session format meant it was difficult to obtain information
Airservices representatives appeared unprepared for the number of
attendees and the level of concern being expressed.
7.8 For example, a Yandina Creek resident said:
…residents in [my street] were not supplied with information regarding the proposed
changes or information specific to this area. It was only after specific enquiries of the
relevant authorities that such information was made available in the past week [writing
on 29 April]. This is unacceptably close to the dead line for submission of objections.
7.9 Complainants raised concerns about a lack of access to technical noise
specialists. For example:
A common question at the community consultation sessions was, ’What about the
noise?’ and ‘How loud will it be?’ Representatives from both ASA and SCC did not have
the knowledge to adequately explain N60, N70, associated dB(A) levels, ANEC and
ANEF contours and the potential impacts on residents beneath the flight paths.
7.10 Complainants advised that these sessions did not help them access the
necessary information:
Attendees felt that questions were not fully answered in a meaningful manner to assist
them with their decision making.
Aircraft Noise Ombudsman
Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page 19
Section 23
A response heard frequently to questions about flight path routes resulting noise
impacts was ‘It’s in all the EIS’. The EIS alone is a document of nearly 3000 pages.
Telling residents to go back and have a look through the EIS to find answers to their
questions or to verify what they were being told seems an inadequate response from
both council and ASA representatives. This is supported by media coverage of the
outrage after each meeting. In some cases, the consultant turned their back on the
attendee and walked away. This poorly run process for gaining quality information has
totally failed.
7.11 Complainants raised a lack of clarity around responsibilities at these sessions.
There was concern about who could decide the flight paths and to what extent
Airservices or the Sunshine Coast Council had the final say. One complainant
reported:
At the Verrierdale ‘Drop In’ Airservices Australia stated they take the recommendation
from the Sunshine Coast Council on the flight paths and yet the Division 9 Councillor
stated it was an Airservices Australia decision. Others also received the same
information from Airservices and the Councillor, with one person trying to even have the
Councillor meet with Airservices.
7.12 Complainants also raised a lack of clarity about who could decide to extend
the consultation period with Airservices staff unclear if it was their decision to
make. One complainant reported that:
ASA told residents at the Coolum meeting that they should include a request for an
extension in their feedback and it would be considered. At the Verrierdale meeting the
following week ASA told residents that they would have to seek an extension from SCC.
It is our understanding that ASA is an independent Federal body and should therefore
be the decision maker in this scenario, however comments from SCC would suggest
otherwise. The question of authority and to whom residents should apply for an
extension of the community consultation period is still unresolved with 2 working days
left before feedback closes.
7.13 It appears that Airservices underestimated the level of public interest, but
made a serious effort to allow for the later sessions to manage the larger
numbers of interested residents arriving at venues designed for smaller
groups. This included the measures added to Airservices’ website on 10 April:
We will be inviting small groups of up to 50 through each venue at one time, which may
take up to 30-40 minutes.
This will enable us to provide information and take feedback on the proposed flight path
designs.
At times, there may be a waiting period and we appreciate your patience.
If you would prefer to not wait, you can access information and Fact Sheets under the
resources tab below, or submit your feedback:
Online via https://feedback.emsbk.com/asa
By mail to: Feedback c/o Noise Complaints and Information Service, PO Box 211
Mascot NSW 1460
7.14 The consultation period concluded on 30 April 2019. Airservices reports that it
received positive comments and feedback about the value of the on-site
sessions
Aircraft Noise Ombudsman
Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page 20
Section 24
Summaries of feedback
7.15 On 1 May, Airservices updated its website to advise that:
We have received a significant number of submissions and responses, and will be
consolidating them for consideration in the final design.
A Summary of Feedback will be released on Airservices website in due course.
7.16 On 10 May Airservices further advised that:
Due to the high number of submissions and correspondence received, we are unable to
respond individually.
7.17 On 7 June 2019, Airservices published the following update on its website:
In response to our community consultation activities, conducted between 20 March and
30 April 2019, we received a considerable amount of feedback, both from the areas
where we consulted on the proposed flight path variations (‘consultation areas’), and
from the broader Sunshine Coast community, where the flight path designs are
consistent with the concept flight paths in the approved EIS.
As a result, we have decided to release summaries of this feedback, and our
consideration of the feedback in the context of the final design development, in three (3)
stages:
Summary of Feedback – Part One (Consultation Areas): Summarises the
feedback received from the communities in the specific areas where we consulted
on proposed flight path variations, and provides an analysis of the themes within this
feedback (released 7 June 2019).
Summary of Feedback – Part Two: Summarises the general feedback received
from communities in the broader Sunshine Coast area, including an analysis of the
themes within this feedback (release date by end of June 2019).
Consideration of Feedback: A summary report on how we have considered the
feedback provided by the Sunshine Coast communities in shaping the final flight
path designs (release date in early July 2019).
7.18 On the same date, it released Summary of Feedback – Part One (Consultation
Areas)24. This report described the target area as encompassing a larger
region that had been identified in the SEP, and included the following suburbs:
Black Mountain Cooroy Mountain Pomona
Cooroy Pinbarren Tewantin
Lake Macdonald Ringtail Creek Tinbeerwah
Ridgewood Cooroibah
Cooran Doonan
24 Airservices Australia, Summary of Feedback Part 1: Sunshine Coast Proposed Airspace and Flight Path
Changes, 7 June 2019, p. 2
Aircraft Noise Ombudsman
Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page 21
Section 25
7.19 This report also included presentations of the feedback statistics which led to
some confusion and concern being expressed by complainants. For example,
Airservices treated one submission that raised five different complaints – e.g.
flight paths, noise, emissions, environment and process – as five “resident
submissions”. Of these five “resident submissions”, noise was counted as one
of the five, or 20% of “resident submissions”.
7.20 Using this method, the report stated that noise accounted for 24% of “resident
submissions”. However, 475 of the 917 people making submissions, or 51.8%,
raised noise as a concern. After complaints were received about this,
Airservices produced an updated version25 which essentially maintained the
original analysis.
7.21 The Summary of Feedback – Part Two26 was released on 28 June 2019,
summarising feedback from residents in the non-targeted or general areas.
The report noted 2,915 unique submissions were received. Using the same
analysis methodology as in Part One, it reported 35% raised flight paths, 17%
noise and 13% concerns about the community consultation associated with
the previous EIS.
7.22 While there were concerns raised about the way Airservices presented the
feedback, as outlined above, it must be recognised that this was a new and
developing process. It is clear that Airservices received a significant number of
submissions and faced a challenging task to absorb and synthesise the
substantial amount of feedback.
Stakeholder Round Table
7.23 On 5 July 2019, a Stakeholder Round Table was held, consisting of
stakeholders from Sunshine Coast Council, Noosa Shire Council, Sunshine
Coast Airport, Flight Path Forum Inc. and State and Federal Members of
Parliament. Airservices reported that the purpose of the Round Table, among
others was to:
Explore and discuss the Consideration of Feedback Report which includes the Final
Design prior to public release
7.24 The agenda for the Sunshine Coast Council Special Meeting of November
201927, described the Stakeholder Round Table meeting as follows:
The purpose of the meeting was to provide a better understanding of the regulatory,
technical, operational and community feedback resulting from the Airspace Community
stakeholder engagement associated with the delivery of the new Runway.
7.25 The then ANO attended the Round Table session as an observer and noted:
25 Airservices Australia, Summary of Feedback Part 1: Sunshine Coast Proposed Airspace and Flight Path
Changes (updated), 28 June 2019
26 Airservices Australia, Summary of Feedback Part 1: Sunshine Coast Proposed Airspace and Flight Path
Changes, 28 June 2019
27 Sunshine Coast Council, Agenda Special Meeting (Region Shaping Projects), 14 November 2019, p. 10:
https://d1j8a4bqwzee3.cloudfront.net/~/media/Corporate/Documents/Meetings/November%202019/Minutes%20Sig
ned%20141119%20OM.pdf
Aircraft Noise Ombudsman
Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page 22
Section 26
There was a significant media presence before the session
The bulk of the session was devoted to presentations by Sunshine Coast
Council and then by Airservices. Comparatively little time was left for
questions or statements by community representatives or other
participants
While questions by community representatives and others were heard and
responded to by Sunshine Coast Council and Airservices, it could not be
said there was any substantial “discussion” nor any progress made to
address the concerns of the community or to resolve outstanding issues
No final design or Consideration of Feedback Report was available and so
no final design nor any record of Airservices’ consideration of the feedback
received could be addressed or discussed.
Airservices’ proposed final design
7.26 Airservices published its Proposed Final Design and Consideration of
Feedback report on 16 July 2019, finalising its proposed flight path and
airspace designs for implementation at the Sunshine Coast.
7.27 Alternatives proposed by communities during the consultation period were
considered by Airservices. However, most were ruled out on the grounds that:
Alternative flight path designs submitted that were outside the approved EIS concept
flight paths were not able to be progressed at this time28
7.28 However, Airservices did consider nine alternative designs for potential
inclusion on a “register of possible alternatives for further consideration”. Of
these nine alternative designs, Airservices determined that one would be
placed on a Noise Improvement Register for further consideration in the future.
The ‘Engage Airservices’ platform
7.29 At the same time that Airservices published its Proposed Final Design and
Consideration of Feedback report, it launched its ‘Engage Airservices’
platform. This was a genuine initiative by Airservices to add an interactive tool
to its engagement activities, as the functionality became available and in
response to what it heard through its community engagement. Airservices
advised:
During our Sunshine Coast consultation, we received community feedback that you
would like an interactive platform and more resources to assist you in understanding the
flight path changes. Our new Sunshine Coast engagement platform includes:
an interactive map for the Sunshine Coast with the proposed final flight path designs
Community Specific Fact Sheets
Runway Operations infographic poster set, and
FAQs.
28 Airservices Australia, Proposed Final Design and Consideration of Feedback – July 2019, 16 July 2019, p. 27
Aircraft Noise Ombudsman
Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page 23
Section 27
Information on the ‘Engage Airservices’ platform can be accessed without registering,
however if you would like to submit a query or complaint, or put a comment on the
interactive map, you will need to register.
…
Queries
If you have queries about the Sunshine Coast Proposed Final Design and
Consideration of Feedback, you can submit them via ‘Engage Airservices’.
There is also a form to submit complaints related to community engagement.
Please note as consultation on this proposed flight path change is closed we are no
longer accepting feedback on the proposed final design.
7.30 While the ‘Engage Airservices’ platform allowed ten days for people to submit
queries and complaints through this portal, Airservices had closed the
consultation period and was not receiving feedback on the final design.
7.31 Airservices advised on its website that:
During the 10 day query period, we received a total of 2,400 visits to our Engage
Airservices engagement platform. We also had 119 queries and complaints submitted
and our documents were downloaded 1,670 times.
7.32 The ANO received complaints from some community members expressing
frustration that so little could be varied. Such concerns can be summarised as
follows:
What was the point of consulting when basically nothing has changed and
all suggested alternatives would be dismissed?
Airservices is just going along despite the community’s will and are just
doing the bidding of the SCC
No consideration given to any flight paths outside the EIS.
7.33 In recognition that the tool has the potential for improving information provision
in support of community engagements in future, one individual posted on the
Airservices interactive map within the Engage Airservices platform:
It would have been even better if I had this information, or at least been alerted to it,
when the original EIS was done, as clearly this was when the decision making took
place in relation to the route the flight paths would take
7.34 The platform had a moderation process which removed eight comments
posted by individuals on the basis that they “contained profanities” (1),
“identified a staff member by name” (1) or “were defamatory” (6). Some
individuals complained to the ANO that they “were not allowed” to repost after
receiving the advice that their post had been deemed defamatory. Airservices
advised that individuals had to repost within the query period and only two did
so. One complainant also took issue with the fact that this was the only direct
communication he received from Airservices during the consultation process:
…they don't have time to respond to all the submission complaints about their flight path
placements but they have time to let me know I am being censored it appears
Aircraft Noise Ombudsman
Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page 24
Section 28
7.35 The ANO also received complaints from some who used the interactive map
that they had asked questions in their post but never received a response:
ASA invited residents to participate in an interactive map allowing them to place a ‘pin’
on their property position. Their interactive map also allowed for comments and
questions and was set up about six months ago. To date there has been no response to
mine nor any of the other hundreds of participants comments or questions put to them
on this interactive map.
Airservices advised that:
Where it was clear that an individual had posed a question or raised a complaint
Airservices responded to that individual by email.
Further representations
7.36 Airservices submitted its Airspace Change Proposal, based on its final design
to CASA on 29 July 2019, but representations continued to be made by
affected residents. Airservices conducted numerous briefings and technical
workshops with community groups to assist the community with opportunities
to ask questions to gain an understanding of what would be implemented.
7.37 Discussions in August 2019 between Airservices’ technical specialists, the
Buddina community representatives and their Member of Parliament raised
alternative flight paths that would reduce the noise impacts on the community.
Airservices determined, however, that there was not time to fully consider
them until after the runway opening, but acknowledged it was worthy of further
consideration and potentially registering on its ‘Noise Improvements Register’.
7.38 Together with the one proposed alternative determined by the Proposed Final
Design and Consideration of Feedback report, Airservices committed to future
consideration of two alternative flight paths.
Aircraft Noise Ombudsman
Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page 25
Section 29
8 Complaints about the process
8.1 At a briefing on 1 May 2019 with senior Airservices officers, the ANO was
advised that Airservices did not intend to respond to the complaints it had
received and continued to receive, but had decided to treat all complaints
received as ‘feedback’.
8.2 The ANO continued to receive many complaints from community members
that their inquiries and complaints had not been responded to by Airservices.
On 13 June 2019, after Airservices had published its Summary of Feedback –
Part One report, Airservices confirmed its processes had given priority to
reviewing and analysing submissions. It advised:
We prioritised producing feedback reports because they will provide a chance for all
participants to get a sense of a broader range of ideas and concerns that were raised
during the consultation process and an understanding of how this feedback was
considered in the final flight path design. Given we are working to the runway
development project schedule, and the volume of feedback is significant this is
considered the most practical alternative to responding to each submission received
during the consultation.
8.3 In August Airservices advised the ANO that it intended to analyse all
communications from the community to identify complaints and respond to
them. Airservices advised that this analysis identified something in the order of
1000 submissions that included complaints and that responses would be sent
to all complainants identified. From late August through to late September (five
or more months after complaints were lodged) Airservices sent letters to these
complainants, acknowledging the complaint, reiterating the consultation
process, including referral to previously published documents, and recognising
that:
we will not be able to please everyone in this process and there will remain some
community members who are not satisfied with the outcome of the proposed flight path
designs.
8.4 Complainants expressed disappointment at this response, for example:
ASA’s response did acknowledge SCC’s letterbox drops may not have reached all
households. ASA’s response also inferred that they are aware of the botched
notification process, quote, “We understand that you may not have been aware of, or
received late notification regarding, Airservices consultation drop-in sessions.”
ASA efforts in this entire process have been woeful and they are hiding behind the
pretext of aircraft safety and operations, and bending to the will of the Sunshine Coast
Council and airlines whim are only interested in money with little concern or
consideration for the impact on residents and the environment whom live in the flight
path areas and will be most affected.
I must admit I feel completely despondent and that no one in government is listening.
Aircraft Noise Ombudsman
Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page 26
Section 30
9 Conclusions
9.1 Airservices has an obligation to inform, consult and constructively engage with
communities potentially affected by proposed flight paths before they are
implemented. Airservices asserts that it can rely upon consultation undertaken
by others in an EIS process to meet this obligation. Airservices must, however,
turn its mind to whether such a consultation was adequate. In this case,
Airservices took no part in the consultations that occurred as part of the EIS
conducted in 2014/15 by the Sunshine Coast Council and did not conduct its
own assessment of that process. It told the ANO that it accepted the approvals
of the Queensland Coordinator General and the Commonwealth Minister for
the Environment to be sufficient evidence that an appropriate process had
taken place.
9.2 Airservices aligned its flight path designs with those in the EIS but also
proposed variations to reduce overflight of some north-west and north-east
communities. However, it was not open to further variations in other areas as
proposed by the community, which could potentially deliver improved
environmental outcomes. Airservices took the position, as described in its
Proposed Final Design and Consideration of Feedback Report29:
Alternative flight path designs submitted that were outside the approved EIS concept
flight paths were not able to be progressed at this time.
9.3 While there had been a consultation process and approvals on the basis of the
EIS, it was apparent from the EIS documentation that the flight paths it
contained were concepts and potentially subject to change over time:
The changes proposed in this chapter represent the flight paths and airspace currently
envisaged by SCA to be adopted for operations on the proposed runway. However,
these concepts are preliminary and future developments in aircraft technology and
navigation systems, as well as development of the Brisbane basin air traffic
management network could result in changes to the proposed airspace. 30
9.4 Airservices’ internal procedure (NOS)31 requires the re-assessment of the
environmental impact of proposed flight paths if more than 18 months has
passed since its last assessment. GHD’s TEIA ensured this requirement was
met. However, the point made in the NOS is that a lot can change over 18
months, let alone over 4 to 5 years and this applies equally to planning the
stakeholder engagements as it does to considering the environmental impacts
associated with a change. The level of population churn in the areas affected
would have been one relevant consideration.
29 ibid, p. 27
30 Sunshine Coast Council, Sunshine Coast Airport Expansion Project – Environmental Impact Statement, 18
September 2014, p. D2-169
31 Airservices Australia, NOS, op. cit. - see paragraph 2.7 above
Aircraft Noise Ombudsman
Investigation into complaints about the introduction of new flight paths in the Sunshine Coast (April 2020) Page 27
Section 31
9.5 The consultative process carried out by Airservices in 2019, however, was
conceived on the basis that the EIS consultations in 2014/15 largely satisfied
its obligations and no further consultation by it was required with those people
potentially affected by aircraft noise in the areas covered by the previous
Sunshine Coast Council processes (the general area). Airservices determined
to directly consult only those potentially affected in areas where it had made
modifications to the 2014/15 concept flight path design (the target area).
“Consultation” with those affected in the general area, described by
Airservices as a community update program, and in Airservices’ SEP as
“activities aimed to inform and update the community on the development and
implementation of Runway 13/31”32, would be the responsibility of the
Sunshine Coast Council, with Airservices providing support.
9.6 This apparent division of responsibilities, produced confusion as the process
continued. Airservices and the Sunshine Coast Council each placed separate
public notices about upcoming consultation activities and complaints show
inconsistent information provided at community consultation sessions by
representatives of the two parties. Airservices did not anticipate the extent of
public interest and did take steps to respond to the changing circumstances. It
also considered the feedback received from general as well as the target
areas. However, Airservices’ decision to only consider varying its final design
from its proposed design where suggested alternatives were aligned to the
EIS concept paths meant that “consultation” with those in the general area
was effectively consultation in name only. The complaints to the ANO
demonstrate that public anger continued to grow through the process and
remained after the consultation period had closed.
9.7 Standards of best practice consultation for major infrastructure projects require
that those consulted have at least some potential to influence the outcome and
contribute to the final position. The International Association for Public
Participation (IAP2)’s Quality Assurance Standard for Community and
Stakeholder Engagement33 adopts the IAP2’s Core Values for public
participation, state that public participation:
is based on the belief that those who are affected by a decision have a right to be
involved in the decision-making process
includes the promise that the public’s contribution will influence the decision
promotes sustainable decisions by recognising and communicating the needs and
interests of all participants, including decision makers
seeks out and facilitates the participation of those potentially affected by or
interested in a decision
seeks input from participants in designing how they participate
provides participants with the information they need to participate in a meaningful
way
communicates to participants how their input affected the decision.
32 Airservices Australia, SEP, op. cit, p.6
33 International Association for Public Participation, Quality Assurance Standard for Community and Stakeholder
Engagement, 2015, p. 10
Aircraft Noise Ombudsman
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9.8 There was never any realistic prospect that residents in the general area,
despite the chance to provide their feedback, had any significant opportunity to
influence the proposed flight paths. This quickly became apparent to them
during the process and was the fundamental basis of the complaints to the
ANO.
9.9 Airservices’ evaluation of the feedback, in separate reports for the general and
target area, was that the consultation was “successful” based on the number
of activities and volume of response. This in itself gave rise to further
complaints. Complaints to Airservices about the consultation process were put
to one side and eventually responded to well after the end of the consultation
period.
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10 Recommendations
10.1 When Airservices becomes involved in changed flight path design as a result
of another party’s project, such as for a proposed runway, its obligation to
consult with the community about the environmental effects of aircraft
operations remain. Although this obligation may be discharged in cooperation
with others, the lack of effective coordination between Airservices and
Sunshine Coast Council in this case, makes it clear that any future
assessment of and consultation on environmental impact by Airservices
involving another party will require more careful consideration and, if joint
assessment is to occur, much more careful planning, commitment and
attention from those involved as well as effective governance mechanisms to
ensure that relative responsibilities are adequately discharged. To avoid
similar challenges in the future, Airservices needs to engage early in the
planning stages of third party-initiated projects and maintain an ongoing
interest as the projects progress.
Airservices should develop a framework for third party
proposed changes that:
(a) provides robust and dependable governance
arrangements to manage its early and ongoing
engagement with third parties
(b) establishes clear lines of accountability and documents
these arrangements as they evolve
(c) ensures an effective consultative process, which includes
monitoring the adequacy of any third party consultations
being relied on.
10.2 In considering the wide range of submissions it received and accepting further
representations after the consultation period closed, Airservices acknowledged
that there were some community-suggested alternatives that may offer better
noise outcomes and are worthy of further investigation. In the short timeframe
it had to finalise its designs for CASA approval ahead of the scheduled
implementation date, these could not be properly assessed. However,
Airservices committed to further considering these options as part of its Post
Implementation Review process.
Airservices should, as soon as practicable, design an
effective post-implementation review (PIR) process for the
Sunshine Coast flight path designs, that does not perpetuate
design constraints requiring alignment with EIS concepts,
and which encompasses:
(a) consideration of identified community-suggested
alternatives
(b) a community engagement process that provides for
genuine opportunities for community contributions to
influence decisions
(c) application of the latest version of Airservices’ National
Operating Standard (NOS) Environmental Management
of Changes to Aircraft Operations (AA-NOS-ENV-2.100).
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10.3 The ANO also acknowledges that some complaints it received raised concerns
about the effectiveness of Airservices’ noise impact assessment processes.
As many noted, the recommendations made by the ANO in its Investigation
into complaints about the introduction of new flight paths in Hobart (April 2018)
had not been fully implemented at the time Airservices undertook its activities
in the Sunshine Coast. Given this, and that those recommendations have now
been addressed by a substantially updated NOS, the ANO has not made
further recommendations on this issue, but continues to monitor Airservices’
progress towards improved environmental assessment procedures and
practices.
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