Chapter 3

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

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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