Chapter 3
Airservices Australia's engagement with communities
3.1
As the largest change in air traffic management practices in Australia
over the past decade, and the matter on which the committee received the
highest number of submissions, the Western Australian Route Review Project
presented a timely case‑study for the committee to inquire into the
effectiveness of Airservices Australia's engagement with communities
affected, or likely to be affected, by aircraft noise. The committee also
heard evidence and received submissions from other communities around Australia
regarding the effectiveness of engagement, and these are also explored in this
chapter.
Overview of the Western Australian Route Review Project
3.2
Over the past ten years, the airspace over Perth has become increasingly
congested and complex. The demand for air services has grown at an
unprecedented rate, with a 60 per cent growth in air traffic in the past five
years at Perth Airport alone. Since 2000, the strength of Western Australia's
resources sector has contributed to a significant increase in demand for air
services, particularly to regional Western Australia. Perth's second airport,
Jandakot Airport, is one of Australia's busiest airports. It is the only
general aviation airport in Perth and provides a base for pilot training,
tourism, charter flights and state government-run air services. Aviation
activity and particularly flight training activities at Jandakot Airport has
increased significantly over recent years and in 2009 Jandakot Airport recorded
the highest number of aircraft movements of any Australian airport.[1]
3.3
Coupled with this expanded growth, military use of restricted airspace has
also increased over the past decade. The result being that large areas of the
Perth metropolitan airspace are restricted for military use and are therefore
not readily available for commercial traffic. The committee heard that RAAF
Base Pearce, which is both a military and operational training air base, is the
busiest defence flying base in Australia.[2]
3.4
Noting this unexpected and unprecedented growth, the Civil Aviation
Safety Authority (CASA) conducted an audit of airspace use in Western Australia
in 2003 to ensure the ongoing safety of aviation operations. The CASA audit
found that changes were necessary to improve airspace safety. As a result, Airservices
Australia undertook a review of airspace use, flight routes and aviation
procedures across Western Australia. The review, known as the Western
Australian Route Review Project (WARRP), commenced in 2006. The review led to
changes in flight paths in November 2008 to improve safety, reduce complexity
and to more effectively manage the increased demand for air travel. The
Airservices Australia website describes the benefits of the flight path changes:
Aircraft are operating more safely in the Perth area. The
changes separated jets from slower turbo-prop and light aircraft, and removed
two-way routes on which aircraft arrived and departed simultaneously, creating
the potential for conflict.
Airspace has been configured to safely manage the ongoing,
increased levels of air traffic in WA and around Perth in particular.
Aircraft using the new procedures are using less fuel,
reducing CO2 emissions.[3]
Community consultation
3.5
During the WARRP and subsequent implementation of the flight path
changes, Airservices Australia applied a consultation process that had been
utilised nationally for airspace reviews. This involved consultation through
the extant airport community consultation forum, the Perth Airport Aircraft Noise
Management Committee (ANMCC).
3.6
The ANMCC is chaired by Perth Airport and comprises federal and state
members, representatives of local municipalities and community representatives
from high noise affected areas. The cities of Bayswater, Belmont, Canning, Gosnells,
South Perth, Swan and the shires of Mundaring and Kalamunda are represented on
the committee. Relevant federal and state agencies and representatives of the
aviation industry are also members of ANMCC. One of the key matters ANMCC
reviews are any changes to airspace management procedures being undertaken by
Airservices Australia. Each ANMCC member is expected to ensure the progress and
achievements of the committee are communicated to the organisation or group they
represent.[4]
3.7
The Airservices Australia website describes the community consultation
strategy as follows:
Airservices consulted those councils whose residents could be
most affected by the proposed changes. Under noise exposure guidelines, this is
generally in areas close to the airport where residents are most likely to be
affected by frequent, low-flying aircraft. Further away, aircraft are flying
at heights generally accepted not to cause significant noise (less than 70
decibels outdoors or less frequent overflights).
Airservices provided detailed information on new arrival and
departure routes, and potential noise implications, to the Perth Airport noise
committee in October 2006. We continued to update the committee on progress at
meetings throughout 2007 and 2008.
Detailed maps were published on the Airservices website and
comment sought from airlines, other airport and airspace users, Government and
the community.
We also took submissions, questions and feedback and provided
supplementary information via email and mail.[5]
3.8
Airservices Australia suggested to the committee that this strategy had generally
been satisfactory in communicating with communities regarding airspace, air
route and air flight path changes.[6]
The community aviation consultation forums had provided a central coordination
point and conduit through which information was communicated to communities.
Impact of the flight path changes
3.9
During an Estimates hearing on 20 October 2009, Mr Greg
Russell, Chief Executive Officer of Airservices Australia, provided an
overview of those communities most impacted by the flight path changes:
There are three key areas that seem to us to be more affected
by this particular air route change. In the hills district, the numbers that I
have seen on a daily basis for arrivals from the north connecting into the
southern end of the main runway—that is, the 03 end of the runway at Perth—have
moved from an average of between four and six flights a day pre November 2008,
before the change that occurred, to an average of about 16 flights a day. That
is dependent on wind conditions in particular as to which of those air routes
are used and when they are used, but the daily pattern is in that order of
magnitude, on average.
In Beechboro to the north, it is a similar number. There were
on average between two and four flights per day using the route that had
existed prior to this route review. That has risen to about 15 per day, albeit
some of them are in the early part of the morning serving mining traffic going
to the north of Western Australia.[7]
3.10
Although it was acknowledged that the changes to Perth's airspace had
been major, Airservices Australia suggested that the noise impact had not been
significant.[8]
The committee heard that this assessment was confirmed by independent noise
monitoring that Airservices Australia had undertaken, and was continuing to
undertake, in affected areas.
3.11
The committee received a considerable number of submissions which
described the serious impact of the flight path changes, with the majority of
these submissions arising from communities in the Perth Hills to the east of
Perth Airport. [9]
A number of these submissions suggested that the level of aircraft noise was
unacceptable.[10]
3.12
The committee heard that the Perth Hills offer residents a natural
bushland setting, with the terms 'peace and tranquillity' used to describe the area
in a number of submissions.[11]
The committee heard the ambient noise levels in the Perth Hills are very low,
which means that aircraft noise is particularly intrusive for residents.[12]
It was suggested that aircraft noise was more intrusive in the Perth Hills than
in built up areas where aircraft noise is but one source of noise.
3.13
The committee heard that the frequency of aircraft movements had
increased over some areas of Perth following the implementation of the flight
path changes. Dr Alan and Mrs Rosemary Lonsdale described the dramatic
increase in aircraft movements over their property in the suburb of Bickley in
the Perth Hills:
Until late 2008 we had experienced a relatively small number
of aircraft movements each day (perhaps 5-6 large aircraft and a similar number
of smaller commercial aircraft). Most of these were in the general vicinity and
did not pass directly over our house. Since early 2009, the number of aircraft
passing directly over our house has increased massively, by a factor of about
700 percent on some days. For example, on Monday 25 May 2009, over the 12 hour
period from 9.30 am to 9.30 pm, a total of 64 aircraft passed directly over our
house. The total for a full 24 hour period would be in excess of 80 aircraft
movements.[13]
3.14
The committee heard that the flight path changes had negatively impacted
many residents' quality of life, health and wellbeing. For example, Ms Karen
Ward wrote to the committee of her family's experiences:
Our family moved to the hills over 20 years ago to seek a
more peaceful tranquil environment and better air quality. With the new flight
paths we now have to endure not only aircraft noise but also jet fuel
emissions. We have experienced and are continuing to experience aircrafts
flying directly overhead and when the windows are opened or when we are
outdoors the smell of benzine triggers off asthma attacks. Not only do we get
the noise in the daytime but often we are awaken by loud aircraft noise taking
off after midnight, after 2 a.m and then quite regularly anytime from 5 a.m.
onwards. In the daytime the noise often drowns out phone conversation from
callers. Many a Qantas jets [sic] criss-cross directly overhead and it is
alarming to see them looming so large above.[14]
3.15
The committee also heard concerns that the flight path changes had
potentially devalued property and were having a detrimental impact on
businesses:
The problem for me is that I have now invested millions in a
business where I am offering rest, peace, recreation and tranquillity, and I do
not offer that anymore, so I am deeply concerned that my property values have
diminished, or will, and that my business is going to have problems. That is
based on this: if it is pretty unbearable now when we are reaching passenger
numbers that were projected only for 2015, what on earth is it going to be like
as the mining boom hits and Perth naturally grows? It is damaging my business
now when guests comment that it is a shame about the aircraft in the middle of
the night or when the aircraft have become quite excessive at the beginning of
the week or early in the morning, from five o’clock onwards.[15]
3.16
Although the committee notes that the timing and scheduling of flights is
controlled by aircraft operators, the committee received a number of
submissions which raised concerns regarding the disturbance caused by late
night and early morning aircraft movements. Ms Fiona Zahra noted the frequency
of aircraft movements during these particularly noise sensitive hours:
... planes begin flying over our house at 5.30am, by 7.00am we
have had 20 planes fly over and this continues on and off throughout the day
until 2.30am the following morning. I have counted in excess of 70 planes
roaring over our house and this is a place where we barely had any planes
flying over. On these days my children are woken at 5.30am and we are unable to
sleep through the night without being woken up by the noise...11.00pm, 11.30pm,
12.00am, 2.00am and then 2.30am. I cannot begin to explain the anger,
frustration and disappointment we feel, and to know that this is it for as long
as we live here.[16]
3.17
In responding to the suggestion that the flight path changes had
significantly affected local communities, Airservices Australia acknowledged
that Perth communities had been affected by the flight path changes. However, Airservices
Australia told the committee that it was the frequency of aircraft movements
which had increased and that the extent to which communities were being
impacted was dependent on an individual's perception.[17]
Summary of specific concerns raised regarding community engagement
3.18
Many submitters and witnesses raised concerns regarding the
appropriateness and effectiveness of community engagement during the WARRP and
subsequent implementation of flight path changes. As indicated in the
introduction, the committee heard similar concerns from communities around
Australia and where appropriate the experiences of other communities are also
explored in this chapter.
3.19
Community concerns can be broadly categorised by the following four
themes:
- the breadth and variety of consultation;
- the transparency of consultation;
- the presentation of complex aviation information; and
- the opportunity for review and to resolve complaints.
The breadth and variety of
consultation
3.20
Airservices Australia's reliance on the extant community aviation consultation
forum, ANMCC, as the primary mechanism for community engagement regarding the
WARRP and flight path changes was raised by a number of submitters as a concern:
It is not an effective process to set up a vaguely
representative stakeholder committee, which meets only quarterly, and then
expect all of the wider consultation to be carried out by those committee
members with “their constituents”, rather than by Airservices itself having an
obligation to consult with ALL stakeholders themselves. [18]
3.21
The committee heard that some key stakeholders were not represented on
the ANMCC and so were never informed about the proposed changes.[19]
For example, the committee heard that the City of Armadale and City
of Melville were not members of ANMCC even though they had been impacted by
aircraft noise.[20]
The City of Canning described the impact of this on the local community:
The lack of a forum to hear and to be heard has exacerbated
the problem and the community feels disempowered and disaffected as a result. Regular communication on anticipated flight path and traffic volume changes as
well as monitoring and reporting of noise impacts currently experienced by
residents would at least enable the community to be better informed.[21]
3.22
In a submission to the inquiry, Mr Graham McEachran suggested that
Airservices Australia had an obligation to consult with all stakeholders
directly and should have been required to advertise the matter widely, formally
inform all relevant stakeholder organisations, hold public meetings and invite
public submissions.[22]
3.23
In their submission to the inquiry, Airservices Australia acknowledged
that communities impacted by WARRP continue to express dissatisfaction with the
outcome of the review. Airservices Australia suggested that consultation could
be improved by improving local community understanding of the role, membership
and outcomes of the community aviation consultation forum:
Wider dissemination of information relating to the membership
of the committee and the outcomes of the discussions would improve community
engagement.[23]
3.24
In contrast to the consultation strategy utilised by Airservices
Australia for the WARRP, the committee heard positive comments regarding the
Perth Airport Runway Overlay Project undertaken in early 2010. The committee
heard that Perth Airport implemented a comprehensive program of communication
to ensure key stakeholders and communities were informed of the runway overlay
works and the associated changes to aircraft movements. The program of
communication included briefings with councils and shires most likely to be
impacted by the works, a direct mail campaign, advertising in local community
newspapers and advertising at a local shopping centre. It was suggested that this
program of communication was effective because of the breadth and variety of
communication methods, provision of regular updates on progress and the
simplicity of information presented.[24]
3.25
The committee also heard from other communities around Australia who
raised concerns regarding the effectiveness of community aviation consultation forums
as mechanisms to facilitate an open dialogue and free exchange of information.
For example, Mr Graham Ellis suggested that community consultation through the Jandakot
Airport Consultative Committee (JACC) had been ineffective, with no
consultative meeting for a period of 18 months and the most recent meeting only
lasting 15 minutes.[25]
Mr Ellis suggested that JACC did not provide substantial outcomes for the
community:
The JACC is an illusion, a front, giving the appearance of dialogue
between the noise impacted community and the aviation industry that provides no
substantial outcome, a game of smoke and mirrors.[26]
3.26
The Moorabbin Airport Residents' Association Inc raised similar concerns
regarding the Moorabbin Airport Consultative Committee:
The Moorabbin Airport Corporation Consultative Committee
(MACC) (of which Airservices Australia is a member) was set up to consult with
interested aviation parties and the community. It is widely praised as a
success by politicians and the Govt. as an example of genuine effectiveness.
Sadly, that is an illusion.[27]
3.27
In response to these suggestions, the Moorabbin Airport Corporation
suggested that the Moorabbin Airport Consultative Committee had achieved a
considerable amount during its tenure:
It has for the main served as a forum so that the activities
of general aviation can be explained to the community, and that the operators
and regulators of general aviation can understand the concerns within the
community. Regrettably however, consultation does not always mean agreement.[28]
Committee view
3.28
Given the complex nature of aviation information and the scale of the
changes proposed under WARRP, the committee considers that it was inappropriate
for Airservices Australia to delegate responsibility for disseminating
information to a community aviation consultation forum. The method of
consultation utilised should have been more varied and wide ranging to ensure
those communities likely to be affected by the changes were fully consulted,
understood the impact of the changes and were able to provide input into the
process.
3.29
As part of the reinvigoration of the community aviation consultation forums
announced under the government's National Aviation Policy Statement,[29]
the committee considers that these forums should be subject to regular review
to ensure their ongoing effectiveness. As part of this review process,
community stakeholders should be consulted to determine the degree of public satisfaction
with the forums and identify opportunities for continuous improvement.
The transparency of consultation
3.30
The committee heard evidence and received submissions that consultation
through the ANMCC was not open and transparent. In particular a number of
submitters expressed concern that three key documents were not provided to the
ANMCC, namely, an environmental assessment, a Civil Aviation Safety Authority
Safety Audit Report and an internal noise assessment.[30]
3.31
The committee heard that the environmental assessment was first
requested by the ANMCC at a meeting on 4 October 2006 and an officer from Perth
Airport wrote to Airservices Australia formally requesting the assessment
on 15 November 2006.[31]
The minutes of the 4 October 2006 meeting record that ANMCC requested
the environmental assessment reports be made available to committee members in
time to make comment prior to the flight path changes being adopted.[32]
At the ANMCC meeting on 21 February 2007 Airservices Australia undertook to
provide the committee with the environmental assessment.[33]
The environmental assessment was not released until 21 May 2010, following a
request by the Senate Rural and Regional Affairs and Transport References Committee.[34]
3.32
Mr John Macpherson, the Principal Environmental Noise Officer within the
Western Australian Department of Environment and Conservation and regular ANMCC
attendee, suggested that failing to release these documents hampered the
ability for communities to actively engage in a two-way discussion regarding
the proposed changes and options available:
I do not think we got enough information to be able to feel
that we really had our teeth into something where we could begin to say, ‘Now
we understand something well enough that we want to have an influence and
change it.’ I do not think we ever got to that point. With other environmental
assessments that I do, I get to that point—because we get the information and
we can say, ‘Hang on, I can see that there is a problem with this proposal; you
need to change something about it.’ I do not think we got to that point of
understanding it well enough to know whether we might have actually had an
influence in changing it.[35]
3.33
Further, the committee heard that without these documents, the
community's ability to review and assess the basis for the proposed flight path
changes was affected:
Details of the "safety argument" are generally
unavailable for "confidentiality" reasons and accordingly it is
difficult for the community to scrutinize or challenge the reasons being put
forward to justify an existing or proposed flight management measure.[36]
3.34
The committee observed that this failure to release pertinent
information to the ANMCC had lead some witnesses to doubt the underlying
reasons for the flight path changes. For example, Mr Anthony Anderson of
FairSkies speculated that Airservices Australia was 'hiding under the cloak of
safety':
I feel that Airservices Australia has grossly mislead [sic]
the community regarding the necessity of WARRP. They have always maintained, in
answer to all sorts of questions, that it was required for the safety reasons
raised in the CASA audit. Under Freedom of Information a copy of this audit was
obtained and the only 'safety' issues raised referred to the Runway 03
Instrument Landing System procedures and two RCAs were raised – RCA 0301-02 and
RCA 0301-04. That was in 2003 and Airservices Australia has been hiding under
this cloak of 'safety' ever since.[37]
3.35
In responding to Mr Anderson's suggestion, Airservices Australia noted that
a CASA re-audit of the Western Australian airspace indicated improved airspace
safety following the WARRP changes:
We have also seen a reduction in the number of air safety
incidents as a result. We have seen a 39 per cent fall in air safety incidents
since the changes were made, and that also includes a 23 per cent reduction in
airspace violations, which is pilots operating outside the control area and
wandering into places where they should not be. [38]
3.36
However, similar concerns were raised by the Sydney Airport Community
Forum. The Sydney Airport Community Forum suggested that Airservices Australia
should be more transparent, particularly with regard to publicly releasing
environmental assessments and providing more detailed explanation for the
non-attainment of Sydney's noise sharing targets. Without this information, it
was suggested that local communities are not fully informed and are unable to
conduct their own analysis.[39]
3.37
Due to the technical nature of operational documents such as
environmental, noise and safety assessments, Airservices Australia advised the
committee that they do not favour the public release of these documents. Airservices
Australia suggested that as there is implied knowledge with the material,
operational documents would not necessarily be meaningful to the reader. Instead,
Airservices Australia prefers experts to explain the results of specialised
reports to consultative forums.[40]
Committee view
3.38
The committee recognises that aviation operational documents can be
highly complex and not readily understandable by the 'lay person'. However the
committee notes that a lack of organisational openness and transparency can potentially
give rise to community scepticism and mistrust. Accordingly, the committee is
of the view that the complexity of information should not form the basis for
non-disclosure. Rather, a package of readily understandable information
regarding a proposed flight path change (including its potential impact on
local communities) should be made available and widely distributed to all
interested community stakeholders.
The presentation of complex
aviation information
3.39
Aviation information is complex and highly technical in nature. The
management of airspace involves the complex and dynamic interaction of many factors,
some of which are within Airservices Australia's control (e.g. flight paths)
and some of which are not (e.g. weather conditions, safety regulations).
3.40
In consulting with the ANMCC, the committee heard that Airservices
Australia did not provide information that could be readily understood by
community representatives. A number of witnesses suggested that the
information provided was above the technical level of the ANMCC community members.
It was argued that this affected representatives' ability to assess, review and
share the information provided with their community organisations.
For non-aviation industry ANMCC members the language used has
been too technical, the use of simple simulations, diagrams &/or maps was
not employed, information was misleading ...[41]
3.41
The committee notes that ANMCC did not seek clarification or additional
information from Airservices Australia prior to the implementation of WARRP.
However, the committee heard that because Airservices Australia gave the
impression that the changes were occurring well away from Perth Airport and
would not have a significant impact on communities, ANMCC members did not see
merit in dedicating time and resources to further reviewing and clarifying the
information.
3.42
The committee heard that Airservices Australia also provided information
regarding the WARRP on its website. The information consisted of aviation
diagrams showing arrival approaches and departure routes with arrows and
coordinates. The diagrams did not include clear markings of suburbs and did
not indicate the likely impact of the flight path changes on local communities.
3.43
Mr John Macpherson described the information provided:
... the nature of the information provided on the ASA website
describing the proposed flight path changes was too obscure and technical to be
of use to persons other than aviation experts. I visited the website several
times in response to circular emails advising that the site had been updated. However, I found that the information provided at that time consisted of a
'spaghetti' of flight paths with cryptic descriptive notes, overlaid on a map
that did not show landmarks that would have enabled potential noise-affected
areas to be identified.[42]
3.44
Upon review of the information that had been available on Airservices Australia's
website, the committee shared the view that it would have been difficult for
the public to understand the information in the form published.
3.45
Community members of the Sydney Airport Community Forum also noted the
challenge posed by the complex and technical nature of aircraft operations and
aircraft noise. To support the work of the Sydney Airport Community Forum,
between 2007 and 2009 the Federal Government funded an Aviation Community
Advocate. The community advocate provided the Sydney Airport Community Forum
and broader community with assistance, information and advocacy for the
community interest on aviation issues.
3.46
Mr Derick Frere, a community representative on the Sydney Airport
Community Forum noted the community advocate helped to 'level the playing
field'.[43]
Sydney Airport Community Forum community members further proposed that there is
an ongoing need for a trusted and independent community advocate to assist the
general community in asking the right questions, accessing information and
analysing and explaining information:
There is a need for a skilled resource to support the members
on SACF. The complex and evolving technical nature of airport operations, the
volume of information and data puts the members of SACF at a distinct disadvantage
relative to the full-time employees of Airservices and the industry. This is
particularly the case for the volunteer community members. There is a need for
a skilled and experienced individual to undertake research and analysis, to
investigate issues and importantly to assist and advise SACF and the community
in formulating proposals to ameliorate the impact of aircraft noise in Sydney.[44]
3.47
The Committee was told that due to budgetary constraints within the
Department of Infrastructure, Transport, Regional Development and Local
Government, funding was unable to be found to maintain the position in 2010.[45]
Committee view
3.48
The committee is of the view that the complexity of aviation information
can hinder the effectiveness of Airservices Australia's engagement with local
communities.
3.49
During the WARRP, the committee considers that the presentation of
complex and highly technical information hampered the ANMCC community
representatives' ability to independently assess and critically evaluate the data
and information provided by Airservices Australia. Information should have
been presented to the ANMCC and made available on the Airservices Australia
website in a form readily understandable to the 'lay-person'. The committee
recognises that there were opportunities for the ANMCC to clarify the
information provided and that these opportunities were not pursued. However,
the committee notes that, generally, community representatives did not have
aviation experience and therefore accepted advice from Airservices Australia on
face value.
3.50
Where significant or extensive changes to the management of airspace or
aircraft noise are proposed in the future, the committee considers the
effectiveness of community engagement and consultation would be enhanced through
the appointment of a community advocate or independent community adviser.
The opportunity for review and to
resolve complaints
3.51
The Noise Enquiry Unit (NEU) is Airservices Australia's nation-wide
complaints and information unit. It receives complaints and enquiries via
telephone, email and on-line and provides information on noise levels at major
airports and responses to aircraft noise complaints and enquiries. The NEU
also provides summary reports of enquiries and complaints it has received to
relevant airports, airlines and authorities. Airservices Australia told the
committee that the NEU has provided an opportunity for the public to seek quick
responses to aircraft noise complaints and enquiries. However, Airservices
Australia stressed that 'the NEU is not a resolution service, rather requested
information is provided to the public and summary reports or information are
provided to relevant airports, airlines and authorities as appropriate.'[46]
3.52
The committee heard that upon receiving an aircraft noise complaint, the
NEU records information regarding the concerns raised and provides information
to the complainant if requested. Airservices Australia then collates and
summarises complaints and periodically refers a summary report to airport
management. This report is used to inform discussions at community aviation
consultation forums and can highlight 'hot spots' of concern.[47]
3.53
The committee noted that although noise complaint information is
provided to community aviation consultation forums, these forums are for
consultation purposes only and are not decision-making bodies.[48]
The primary role of the community aviation consultation forums is not to
resolve complaints, but to ensure that community views are effectively heard by
the airport and to give members the opportunity to obtain information regarding
airport operations.
3.54
Witnesses expressed a range of concerns about the complaint registration
process. The committee heard that unless a caller specifically stated that
their call was a complaint it may not be recorded as such by NEU staff.[49]
Submitters also expressed concern that for the purposes of NEU statistics, one
call equals one complaint and that as a result there is concern among residents
that multiple disturbances are not accurately reflected in the statistics.[50]
Mr Glenn Jennison told the committee:
We believe the problem is getting worse and residents feel it
is becoming a total waste of time to even bother complaining. One call equals
one complaint, so it is no good ringing up and saying: I got woken up six times
last night at these times approximately. That should be registered as six
complaints, but it is registered as one complaint. You even have to say, ‘This is
a complaint, not an inquiry’, for it to be registered as a complaint, which
gets back to that point that few complaints are received.[51]
3.55
Airservices Australia confirmed that one call is recorded as a single
complaint and told the committee that while this does have an impact on the
statistics, it is a very minor impact. Airservices Australia subsequently
advised the committee that the NEU has applied the principle of 'one contact =
one complaint' to its complaints handling practices for the past 15 years. The
committee was told:
We are most interested in the issues that are complained
about and the number of people that lodge complaints, rather than the number of
complaints that are received or the number of flights being complained about.
In any contact with the NEU, the operator will try to discern from the
complaint/enquiry what the issues of concern are and ensure that all issues are
recorded. As such the practice of 'one contact = one complaint' is regarded as
the most effective means of discerning the issues and the extent of the impact.[52]
3.56
Airservices Australia advised the committee that it considers that the
NEU database provides an accurate reflection of the issues of concern and the
extent of the impact for those people who choose to contact the NEU. Airservices
Australia also advised that from 1 July 2010, it is making a database
modification to include a field for 'multiple aircraft, same issue' to address
'those that store up complaints before contacting the NEU and those that
complain about being overflown for lengthy periods of time'.[53]
3.57
Many submitters raised concerns regarding the NEU and the complaint
resolution process.[54]
Notwithstanding Airservices Australia's advice that the NEU is not a complaint
resolution service, the committee notes that there is a clear expectation
expressed in submissions to this inquiry that calls to the NEU should result in
some form of action.[55]
There was a general view put forward that the NEU and subsequent process
offered limited opportunity for positive outcomes and change for the
community. For example, Mr Ian Davies of FairSkies suggested:
The noise complaint process is a dead-end process as it is
now. It should include mechanisms to enable positive action for outcome
changes on behalf of the complainants if they are required.[56]
3.58
The committee received some evidence that suggested callers have been
referred to their local Council or local Member of Parliament.[57]
Ms Yvonne Renshaw told the committee:
I too have a litany of phone calls to Airservices Australia,
in which we were being very pleasantly acknowledged but getting absolutely
nowhere. Back in, I think, September of 2008-09, I eventually went back to them
and said: ‘Thank you for acknowledging my complaint many months ago, but I
haven’t got anywhere. What’s happened?’ They put me on to a councillor at
Mundaring council. When I followed that through, I found that that councillor
had not had anything to do with it for over two years. So I, in my small way,
also kept finding dead ends in terms of complaining.[58]
3.59
The committee also heard that some residents have sought to lodge
complaints directly with the airport or through their local Council. Councillor
Glenys Godfrey, Mayor of the City of Belmont, told the committee:
It has been pointed out by Airservices Australia that they
agree that, due to the lack of knowledge, many of the community complaints had
been directed to local government rather than Airservices Australia[59]
3.60
The Moorabbin Airport Residents' Association Inc was critical of action
taken after information is collected by the NEU, describing the process as 'an
example of the smoke and mirrors approach that exists'[60]:
ASA takes no further action after this – it does not require
the offending airport to report back on measures taken nor actively work with
them to address the noise complaints reported. There is no onus on the airport
to act on these statistics. They are just filed away and forgotten.[61]
3.61
The committee heard that the NEU did not always provide feedback to
individuals on the progress of their complaints and enquiries or any action to
address their concerns:
One of the major concerns is with the apparent lack of any
feed back from the complaints logged. For example if an aircraft does not
follow the expected flight path south and may do an early right turn (even
towards the 3LO aerial), causing excessive noise over Keilor. We could report
this but as far as we know Air Services do not follow through with the aircraft
concerned and certainly do not report back to the us any result of the follow
up.[62]
3.62
In the absence of any feedback, one submitter, Mr Leo Dobes suggested
that affected individuals may become discouraged over time from reporting any
incidents.[63]
3.63
The committee heard that there were opportunities to improve the
performance of the NEU with respect to its customer service and understanding
of locations, planning processes and significant airspace management changes
other than those relating to Sydney.[64]
The committee heard concerns about the helpfulness of the explanations provided
by the NEU.[65]
Submitters expressed concern that the as the NEU is located in Sydney, NEU
staff are not always familiar with the complainant's location or circumstances
and may on occasion give the impression that the complaint is not being taken
seriously.[66]
3.64
Submitters also expressed concern that the NEU is not staffed out of
hours or on weekends.[67]
Airservices Australia advised the committee that the NEU is staffed during
normal business hours and can be contacted via phone, fax, mail, email and the
Internet on a 24-hour basis.[68]
3.65
Airservices Australia advised the committee that there is disconnect
between community expectations and the role of the NEU. The committee heard
that the NEU is not intended to be a resolution unit but simply the interface
between the public and the organisation:
The aim is to provide information to complainants. We take
that information and assess trends that we use in terms of the way our air
traffic controllers operate. In some cases we will take that up with the
airline industry itself. We publish reports based around that data. Again, I
make the point, it is not a resolution of the issue and that is where some
members of the public perhaps think that it is.[69]
Committee view
3.66
The committee notes Airservices Australia's explanation of its approach
to the recording of complaints. The committee also notes the significant amount
of frustration expressed by submitters during this inquiry regarding the
mechanism through which complaints may be lodged and information and
explanations sought. The committee accepts that Airservices Australia does
receive a number of complaints that appear to be invalid in that they refer to
clearly incorrect flight data. The committee also notes that individual
complainants may generate a significant proportion of the overall complaints
logged. The committee is concerned however that individuals who seek to
register their concerns regarding aircraft noise should not be dealt with in a
manner that appears to trivialise the impact of aircraft noise on those
individuals. The committee welcomes the improvements that Airservices is
currently making to the databases and hopes that these will go some way to
alleviate the frustration of complainants.
3.67
Whilst acknowledging that it is not always possible to resolve
complaints to the satisfaction of complainants, the committee found it
concerning that there is no mechanism to ensure independent assessment and
review of complaints. The committee noted that the current process results in
the referral from Airservices Australia's Noise Enquiry Line to a forum which
has no decision making powers, no control over aircraft operations and
consequently, limited ability to affect positive change and resolve community concerns.
Although Airservices Australia can provide a wealth of information to concerned
residents and communities (through their Noise Enquiry Line and initiatives
such as Webtrak), the current structure does not appear to provide a mechanism
to readily bring about change.
3.68
The committee considers that Airservices Australia should endeavour
to respond more effectively to complainants and to resolve complaints where it
is within their ability to do so. Airservices Australia should explore
opportunities to enhance the management of aircraft noise to address community
concerns. One mechanism available to Airservices Australia would be the
continuous improvement and review of flight paths. Further, Airservices
Australia should work with the aviation industry to explore opportunities to
reduce the environmental impact of their operations on local communities, for
example through the introduction of new procedures and technologies to improve
aircraft noise outcomes for communities.
Airservices Australia's Communication and Consultation Protocol
3.69
The committee notes that since the WARRP and its implementation,
Airservices Australia has reviewed their community engagement processes and
developed a new Communication and Consultation Protocol ('the protocol'). The
protocol describes a phased community engagement strategy tailored to suit the
nature and quantum of the air traffic management change. It describes how,
when and what consultation is undertaken by Airservices Australia. There are
eight methods of consultation which can be undertaken depending upon the nature
of the air traffic management change: industry briefings and/or correspondence;
community aviation consultation forums; information on the Airservices
Australia's website; press advertising; direct mail to residents; an
information kit; public information sessions; and a consultation report.
3.70
Mr John Clarke, a member of the Sydney Airport Community Forum suggested
that the protocol described community communication rather than engagement. Mr
Clarke suggested that an effective community engagement strategy involves the
exchange of information and an open dialogue:
There is a lot of information out there around world’s best
practice on engagement with the community in terms of availability of
information, of actually listening to what the community is saying, as opposed
to simply providing a spin to a communication. I think that is a very important
point to make. The community on the issue of aircraft noise in Sydney—and I
believe elsewhere as well—needs to be engaged not communicated to. [70]
3.71
Although the committee did not receive a lot of evidence regarding the
protocol, it is not clear to the committee whether air traffic management
changes of a similar type to the WARRP would necessarily attract a greater
level of consultation under the procedures outlined in the protocol.
3.72
The committee noted Airservices Australia's advice that the protocol was
the product of consistent feedback received through airport forums and public
representations seeking clarity and transparency for our community consultation
and communication processes.[71]
3.73
However, the committee also noted the Sydney Airport Community Forum's
suggestion that the protocol had been developed without wide community
consultation and that the Forum was simply provided with a completed, printed
and published document:
So you can see the certain irony of the situation: SACF,
which is the means for community engagement in Sydney, or at least the first
step in that process, was ignored in the development of that protocol—in fact
we have been asking for it for six months—and yet we had tabled a completed
document. I do think that protocol itself leaves a fair bit to be desired,
because it is around communication with the community as opposed to engagement
with the community.[72]
3.74
In responding to the suggestion that the protocol had been developed
without consultation with community aviation consultation forums, Airservices
Australia advised the committee that the protocol was a 'living document' and
feedback would be welcomed as part of the continuous improvement of the
protocol.[73]
Committee view
3.75
Although the development of a protocol is a positive step, the committee
was particularly concerned that its development may not have been underpinned
by a full consultation process. The committee considers that Airservices
Australia should undertake regular and wide consultation as part of the
continuous improvement for the protocol. It is the committee's view that all
future iterations of the protocol should be developed following extensive
consultation with, at a minimum, the major airport community consultation forums
to ensure it meets the expectations and needs of the community.
3.76
Further, the committee is of the view that the protocol should more
effectively describe community engagement as opposed to community
consultation. In considering Airservices Australia's protocol and evidence
received during the inquiry, the committee came to the view that the protocol
should describe an engagement strategy characterised by an ongoing dialogue,
mutual understanding and open exchange of ideas and information. The protocol
must build community confidence that the engagement process seeks to achieve
positive outcomes and appropriately balances the views of communities with
those of the government and aviation stakeholders.
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