Effectiveness of Aircraft Noise Management
This chapter explores aircraft noise management at Australia's major
capital city airports, General Aviation Aerodrome Procedures (GAAP) airports,
and at smaller privately owned and unregulated airports. The effectiveness of
the Australian Noise Exposure Forecasts (ANEF) system is also considered.
Noise sharing arrangements
During the inquiry, the committee heard that ensuring the fair and equitable
distribution of noise was a primary concern for communities and residents
A number of Perth residents suggested that in introducing new flight
paths following the Western Australian Route Review Project, Airservices
Australia had not pursued equitable noise sharing arrangements.
It was also argued that while the new flight paths may have minimised the total
number of people affected by aircraft noise, a small number of residents are now
subjected to a huge increase in flights and greatly increased noise
In responding to the suggestion that noise was not being shared equitably
in Perth, Mr Richard Dudley, General Manager Corporate and International
Affairs, Airservices Australia, suggested that:
The perplexing issue is that everyone thinks that they are
copping an unfair burden of aircraft noise, no matter what location they are in
around Australia. I have been intimately close to this issue for many years.
Here in Perth we have hot spots of noise to the north, south, east and west of
Perth aerodrome. There are people to the south who are concerned about aircraft
noise just as there are genuine concerns in the Hills district and to the
north-west. There are people to the south-east as well who have concerns about
aircraft overflights. People in this room will not believe me but we are
equitably distributing noise as far as practicable all around the Perth Basin.
During its Perth hearing, the committee received evidence that suggested
there may be opportunities to provide greater respite to residents through civilian
use of military airspace. The committee notes that the extant route structure
in Perth is constrained by military airspace. The committee heard the
Airservices Australia had actively and extensively consulted with military
airspace and air traffic management staff to identify mutually acceptable
outcomes and as a result, some minor changes to restricted airspace boundaries
had been made to facilitate the Western Australia Route Review Project.
The committee heard that unlike airports such as Williamtown in
Newcastle, NSW, which is a shared military and civilian facility, there are
constraints on the ability of RAAF Base Pearce (Pearce) to be used for civilian
flights and the extent to which this would amount to some mitigation of current
aircraft noise patterns. First the committee heard that civilian use of Pearce
would raise security issues and require a significant amount of investment in
terms of infrastructure, runway modifications and provision of safety services.
Second, the committee noted that there was some doubt as to whether
civilian aircraft taking off from Pearce would actually result in greater
sharing of noise impacts. Air Vice Marshal Brown told the committee that a
civilian jetliner taking off from runway 18 at Pearce would probably track over
the same residential areas as similar aircraft taking off from Perth Airport.
The committee noted that the particular circumstances surrounding the Pearce
and Perth Airport facilities and the close proximity of the two facilities do
appear to limit the opportunities for civilian use of Pearce at the current
time. However, the committee considers that there is merit in undertaking a
more complete investigation to determine the possible use of Pearce in the
future, particularly with a view to relieving some of the pressure associated
with high volumes of early morning traffic at Perth Airport.
For communities in the vicinity of Sydney Airport, noise sharing
arrangements have been formalised through the Long Term Operating Plan (LTOP).
The aim of the LTOP is to operate as many flights over water or non-residential
areas and where this is not possible, to share the burden of aircraft noise
over residential land as equitably as possible. The LTOP includes 10 runway
configurations (or modes of operation) and has noise sharing targets for the
amount of aircraft movements to the north, south, east and west of the
airport. The plan is designed to place as many flights as possible to the
south over water (55%), with the remaining spread between the north (17%), west
(15%) and east (13%).
The Sydney Airport Community Forum described the LTOP and the
achievement of its targets as being of critical importance to the people living
around Sydney Airport:
It is the achievement of those targets that will maximise the
benefit to the communities that live around Sydney airport. Unless those
targets are achieved, there will be an unfair distribution of noise for
residents who live around the airport.
The committee heard differing views regarding the effectiveness of
Sydney Airport's noise sharing arrangements. Whilst some submitters suggested
that Sydney's LTOP, if fully implemented, would share the noise equitably,
others suggested that it had not led to equitable noise sharing.
The committee heard that the runway configuration targets described in
the LTOP had not been met in the 13 years since their introduction. The
Australian Mayoral Aviation Council suggested that the targets must be met or
must be recast with effective measurable standards for which agencies can be
held accountable. It was further suggested that failing to achieve the targets
would lead to a loss of confidence in the plan:
Failure to ever deliver on the targets under the LTOP for
Sydney leads to the conclusion that, rather than being a noise management
strategy that is meant to be achieved, it may have become a meaningless
strategy and a matter of public expediency.
One submitter suggested that the LTOP was no longer an effective noise
management plan for Sydney Airport:
The Long Term Operating Plan (LTOP) of 1997 has passed its 'use
by date' due to traffic growth making noise sharing inoperative for long
periods each day. LTOP, the restriction to 80 movements per hour and the ring
fence around regional NSW services are no longer the most effective way to
reduce noise for nearby residents or deliver regional airline services.
In responding to these suggestions, Airservices Australia and Sydney
Airport underscored that the LTOP runway configuration usage targets are
intended to be just that, 'targets'. Mr Rodney Gilmour the General
Manager of Corporate Affairs and Human Resources at Sydney Airport suggested
that the overall LTOP plan had been substantially implemented:
What people focus on is a set of targets that it was
suggested ought to be targets that might be achieved. That is seen as the sole
part of the long-term operating plan. I think you have to see the 18 or 19
separate guidelines that are part of it.
The committee heard that there had been an improvement in managing LTOP
over recent months. For example, the committee heard that during the recent
Runway End Safety Area (RESA) project, there had been an increase in the use of
Simultaneous Opposite Direction Parallel Runway Operations (SODPROPS). The
Sydney Airport Community Forum noted that during this time there had been an
unprecedented level of utilisation of SODPROPS. In the twelve months following
the start of works, the level in every month, except November, was higher than
had ever been previously recorded and indeed in the four months June to
September 2009, the level exceeded 11 per cent. By comparison, in the ten
years prior to RESA, the average utilisation was only 1.8 per cent.
Although not within Airservices Australia's responsibility, the
committee did receive evidence regarding the maintenance of the existing
curfews at Sydney Airport and their establishment at Perth, Melbourne and
Due to the disturbance of late night and early morning flights in Perth,
a number of submitters recommended the introduction of a curfew at Perth
It was also suggested that a 24 hour freight hub would be inappropriate in
Canberra, and submitters also recommended the introduction of a curfew for the
Both Perth Airport and Melbourne Airport are opposed to the introduction
of curfews noting the significant operational and economic benefits that 24-hour
operation provides. Melbourne Airport has quantified the economic benefit a
24-hour operation provides:
At last count, which was in 2007-08 financial year, that came
out as being worth $309 million to gross state product—just the curfew itself— as well as about $77 million to the value of local production, and is worth
somewhere in the vicinity of 1,000 jobs locally and about 4,500 state-wide.
Perth Airport suggested that a curfew at Perth Airport was inappropriate
due to the city's geographic location. It was noted that Perth Airport was the
end-point on a number of international airline operations and operated domestic
'back of the clock' operations due to the distance from the east coast of
It was further suggested that the Sydney curfew had a bearing on aircraft
operations from Perth Airport.
In Sydney, the committee heard evidence from residents in support of the
retention of the curfew and aircraft movement restrictions.
To ease aircraft noise management challenges in Sydney, it was also suggested
that the development of a second Sydney airport should be progressed as a
matter of urgency.
Development of a second airport is a critical long-term noise
abatement action and is considered by Council to be the only 'permanent'
solution to the long-standing, ongoing issue of aircraft noise in the
Marrickville LGA and across Sydney.
The committee recommends Airservices Australia explore opportunities to
more effectively explain noise sharing arrangements to local communities and
develop options to address community concerns. The committee notes recent
improvements in the achievement of Sydney Airport's LTOP targets and encourages
Airservices Australia to build upon these gains.
Required Navigation Performance
Airservices Australia is currently working with airline operators to
develop and introduce Required Navigation Performance (RNP) for arrival and
departure flight paths at up to 28 major Australian airports over the next five
years. These procedures will enable aircraft to fly more accurately to and
from an airport and to operate with improved safety and efficiency. Airservices Australia
has conducted a trial of the procedures at Brisbane Airport and is
progressively testing and implementing the procedures at other Australian
airports, including Sydney and Melbourne.
The procedures have the potential to significantly reduce carbon dioxide
emissions. A trial of the technology and procedures at Brisbane Airport indicated
that RNP has the potential to reduce carbon dioxide emissions by 122,000 tonnes
and fuel usage by 39,000 tonnes per year.
The committee heard evidence that RNP could also lead to a narrowing of
flight corridors, which is of concern to those communities directly under the
more accurate flight paths:
The proposed implementation of narrow flight corridors by
Airservices Australia is not supported for Sydney Kingsford Smith Airport
(KSA). Although there are various operational advantages, the concentration of
aircraft movements over existing urban areas (as recently experienced by
residents in the Sutherland Shire) places a greater and unwarranted burden on
communities as well as compromising the principles of noise sharing across
The Chief Executive Officer of Airservices Australia, Mr Greg Russell
noted that RNP is currently being characterised as a measure which will
concentrate aircraft noise over communities. However, Mr Russell suggested
that the technology would enable Airservices Australia to more effectively
share aircraft noise.
The committee heard that RNP would provide greater flexibility in the design of
... [RNP] enables us to do things that we have not been able to
do previously, such as have curved approaches to the ends of runways. That
enables us to start to look at whether flight paths can be structured more over
industrial land and non-residential land, which we do not have the options for
at the moment.
The evidence the committee received regarding RNP suggests there is
community confusion regarding the impact RNP will have on the management of
aircraft noise. In the committee's view this underscores the importance of
effective community consultation and engagement. The committee notes that
Airservices Australia may not have enough confidence in the RNP concept tracks
currently being developed to effectively consult with the community.
However, the committee is of the view that delaying consultation and engagement
regarding RNP will lead to continued community misunderstanding.
Environmental principles and
procedures for minimising the impact of aircraft noise
The committee heard significant evidence regarding Airservices
Australia's Environmental Principles and Procedures for Minimising the
Impact of Aircraft Noise (the Environmental Principles) and whether there
are appropriate triggers for review under the Environment Protection and
Biodiversity Conservation Act 1999 (EPBC Act). The evidence received
principally related to whether the flight path changes proposed under the
Western Australian Route Review Project (WARRP) should have been considered
significant and therefore referred to the Minister for Environment Protection, Heritage
and the Arts for consideration.
The committee sought clarification from Airservices Australia regarding
whether Environmental Principles are applied consistently to airspace changes nationally
at every airport. Airservices Australia confirmed that it has applied the same
approach in the case of the WARRP as it has to airspace changes elsewhere.
Mr Kenneth Owen, Environment Initiatives and Services Manager, Airservices
Australia told the committee that:
The principles and guidance material that we use is applied
nationally. It was developed with a national approach back in 1997 and revised
in 2002. Since then it has been applied to wherever we do air traffic procedure
or flight path changes, such as we have done in Perth. We use those underlying
principles both in terms of developing the procedures and in terms of our
Mr Richard Dudley, Airservices Australia, told the committee that an
environmental assessment was undertaken in the case of the WARRP but that the
assessment did not point to the need for review under the EPBC Act. Mr
... an environmental assessment was undertaken looking at the
12 principles that we apply. None of those principles were deemed to be
significant. The significance of those are then a lead indicator to how much
and what type of consultation you might undertake in terms of explaining these
types of changes. The situation is that the Perth Hills, particularly around
Chidlow and Mundaring Shire, is around 30 kilometres from the end of the runway
threshold. It did not spark any sort of trigger in terms of the environmental
assessment nor in terms of impact of noise on the community for us to be
concerned about it needing further consultation through the established
committee hosted by the airport.
The committee notes that there appears to be general support for the Environmental
Principles. The main concerns raised went to whether or not the principles are
appropriately applied during the planning and implementation of all airspace changes,
and specifically whether they were applied appropriately in the case of the
WARRP and that outdated criteria were applied in that case.
The committee also heard that environmental assessment reports should be made
available on request.
The committee notes that in the case of the WARRP, members of the public had
sought access to the initial environmental assessment over a lengthy period of
time without success. Airservices Australia tabled the environmental assessment
during the committee's Melbourne hearing on 21 May 2010.
Airservices Australia is subject to paragraph 160(2)(b) of the EPBC Act 1999
which outlines a requirement that before an authorisation for 'the adoption or
implementation of a plan for aviation airspace management involving aircraft
operations that have, will have, or are likely to have a significant impact on
the agency must obtain and consider advice from the Minister for the
Airservices Australia’s Environmental Principles and Procedures publication,
last revised in 2002, contains no mention of the EPBC Act 1999 but sets
out the process and methodology to determine whether a matter triggers its
obligations under section 160 of the EPBC Act 1999. In his
evidence to the committee, Mr Richard Dudley stated that this
document 'did not spark any sort of trigger in terms of environmental
The committee received additional information that confirms that no
request for advice was submitted by Airservices Australia prior to the adoption
of the WARRP. A letter of 18 December 2009 from the Hon. Peter Garrett MP
to Mr Steve Irons MP states:
I have not received a referral under section 160 of the
Environment Protection and Biodiversity Conservation Act 1999 from Airservices
Australia to seek my advice regarding changes to Perth Airport flight paths. I
have asked my Department to examine this matter and to inform you directly of the
outcome of these enquiries.
The committee notes that the Environmental Principles state that a
height of 5,000ft AGL is considered to be the minimum acceptable altitude for
the avoidance of significant noise impact on residential populations by jet
aircraft. The justification for this minimum altitude is that 'the noise at
ground level from a climbing B747 at 5,000 ft AGL is about 75 dB(A)s
The committee notes that Airservices Australia applies a threshold of 70
decibels outside as an indicator of significant noise. Mr Owen explained to the
The criteria we applied when we assessed the WARRP and which
we still apply—and I do not deny that people feel that they are impacted—are
quite valid. We apply 70 decibels because in a normal dwelling, the type of
building you get around Perth, with the windows open you get 10 to 15 decibels
attenuation. That brings you down to 60 decibels inside and above that noise
level you start to get interference with watching television, talking on the
telephone or having a conversation. So 70 decibels outside gives a level inside
which should not have a serious impact on people going about their daily lives.
The monitoring we are undertaking is to determine the actual noise levels in
those locations and the number of times people experience high noise by day and
by night, in order to determine whether these noise levels are at a point that
would disturb people.
The committee received evidence that the determination of what
constitutes a significant level of aircraft noise is contextual. A level of
noise that might be considered insignificant in a residential area with a high
background level of noise may be intrusive and significant in a residential
area with a lower background level of noise. The committee heard that residents
in the outer Perth suburb of Roleystone considered that aircraft noise at 46
dB(A) becomes intrusive and is significant and that WARRP over flights have
been measured up to 65 dB(A) in the area.
The committee notes Airservices Australia's statement that having
undertaken an environmental assessment, the impact of the WARRP on the
residents in the Perth Hills did not suggest a need for further consultation.
However, the committee concurs with evidence received that suggests the sheer
scope of the changes proposed under the WARRP should have triggered a public
consultation strategy that included accessible and clear information and a
comprehensive noise assessment report. The committee also notes the suggestions
more broadly during this inquiry that the Environmental Principles and
Procedures should be independently reviewed, particularly with a view to
considering whether some flexibility can be built into the consideration of
what constitutes significant noise. The committee considers that the Aircraft
Noise Ombudsman could be charged with undertaking such a review.
Aircraft noise management at General Aviation Aerodrome Procedure (GAAP)
General Aviation Aerodrome Procedures (GAAP) airports support a diverse
range of activities from recreation flying, to agricultural and fire fighting
flying, to flight training and low capacity passenger carrying operations.
There are six GAAP airports in Australia: Archerfield (QLD), Moorabbin
(Victoria), Bankstown (NSW), Camden (NSW), Parafield (SA) and Jandakot (WA).
The noise profile at GAAP airports is different to that of Australia's
larger airports. Whilst aircraft are generally quieter, there are a
significantly higher number of overflights each day. Although small scale
compared with Australia's domestic mainline operations, figures show that GAAP
airports are among the busiest in Australia. In 2009, Jandakot Airport recorded
the highest number of aircraft movements of any airport in Australia, followed
by Bankstown, Moorabbin, Sydney and Parafield airports.
The committee heard a number of concerns regarding the management of
aircraft noise at GAAP airports, including the limited extent to which
Airservices Australia manages noise at such airports and the high proportion of
older, noisier aircraft that tend to use them.
The committee also notes that pilot circuit training is a source of
considerable concern to residents adjacent to GAAP airports, both in terms of
aircraft noise and safety.
Residents expressed frustration that suggestions for variations in training
flight paths appear not to be considered.
Airport representatives expressed concern that they are powerless to control
aircraft once they have left the airport land, but are often left to deal with
the concerns of residents who are overflown.
The Moorabbin Airport Residents' Association suggested that there was no
noise management strategy conducted by Airservices Australia at Moorabbin
Airport. The Association noted that aircraft movements at Moorabbin Airport
Excessive noise of training flights by ever-increasing
numbers of overseas students flying old, noisy planes, and helicopters flying
low and flouting regulations with impunity have fallen on deaf ears for years.
The committee notes that there appears to be significant agreement that
training flights are not appropriate over residential areas. The City of
Kingston told the committee:
Kingston is particularly concerned with the noise and safety
aspect of ‘circuit training’ which requires aircraft to move directly over
residential areas as identified in Section 7.5 of the Preliminary Draft Master
Plan. By contrast aircraft travelling to and from the airport have
significantly less impact on residential areas. Given the increase in trainee
activity, Council has consistently raised concerns on behalf of the Kingston
community regarding the appropriateness of training being conducted over a
densely populated urban area. Council believes that pilot training should be
relocated to a non urban area.
The committee notes that Airservices Australia's ability to manage
aircraft noise at GAAP airports is limited. The committee also notes that often
the ability to implement noise sharing arrangements is limited due to the
nature of general aviation operations.
The committee explored the circumstances in which airports such as
Moorabbin and Bankstown had been privatised and the relative responsibilities
of the various parties under the lease arrangements.
Airservices Australia told the committee that:
We monitor very closely the number of aircraft movements at
all of the major airports in Australia, not just the capital city airports.
Moorabbin is an important general aviation aerodrome in Australia. We exchange
information with the Civil Aviation Safety Authority and at the end of the day the
question of training flights at these aerodromes is something that needs to be
directed, in the first instance, to both the department and the Civil Aviation
CASA confirmed the evidence presented to the committee regarding the
high volumes of operations at the six GAAP airports in Australia. CASA told the
committee that 'somewhere between 23 percent and 24 percent of the flying
hours' is flying training of which a significant proportion is undertaken at
airports close to cities.
The committee notes that CASA is taking steps toward better management of the
risks associated with GAAP aerodrome procedures. At a Senate Estimates hearing,
Mr John McCormick advised the Rural and Regional Affairs and Transport
Legislation Committee that CASA had undertaken a review of GAAP aerodrome
procedures and had commissioned a further study with respect to providing a
greater level of safety in relation to training activities. He said:
On 21 July we gave directions to Airservices to limit the
number of aircraft in the circuit to six aeroplanes at any one time under the
control of a single air traffic controller. At most of these places they have
at least two runways that operate and those runways are parallel. So one
operation will be taking off with a left-hand circuit and the other operation
will be taking off with a right-hand circuit. Airservices, as a general
principle, has two different frequencies, two different controllers in the
tower controlling those two different circuits.
We allowed six in the circuit with the proviso that it could
go up to 13 if there was a departure aeroplane that was not to stay in the
circuit but go forward. Those directions to Airservices are on our website
still. On the second page of that first direction I think you will find we said
that at some stage when there are further mitigators in place we would review
the cap on the number of aeroplanes in the circuit. Our view would be to look
at what we could do with the future development of GAAP.
The committee also notes Mr Mrdak's advice that in its National Aviation
Policy White Paper the government has described these aerodromes as critical
national assets. Mr Mrdak said:
We do need all three levels of government to be thinking of
that in that way. Mr Doherty has recently undertaken the first of a series of
working groups with the states and territories in relation to how we actually
put in place safeguarding measures to prevent the sorts of increased risk we
might see as these airports continue to grow in terms of the development
outside those airport boundaries. So we have two processes in place: firstly
the process that CASA is operating with the airport operator about how you
increase the safety as the traffic grows, which is the fundamental role of
CASA, and then you have ourselves and the state and local governments who have
responsibilities in relation to off-airport planning to make sure we are taking
steps to safeguard these aerodromes.
The committee understands the significant concerns raised in relation to
aircraft noise and particularly safety arising from flight training. The
committee notes calls for the relocation of flight training to airfields away
from residential areas. The committee also notes that flight training is a
significant source of income for GAAP airports and there are certain benefits
and attractions to the users of GAAP airports to be located within easy reach
of population centres. The committee also notes that a number of the current
GAAP airports were originally located on the edge of cities.
Aircraft noise management at small, privately owned, unlicensed airports
The committee also received a submission regarding the management of
aircraft noise and property development at privately owned, unlicensed
airfields. In their submission to the inquiry, the Tyabb & District
Ratepayers Business and Environment Group Inc. (the Tyabb residents) suggested:
The difficulties of managing aircraft noise at major airports
are magnified at privately owned, unlicensed airfields, particularly in
Victoria, which mainly operate in a regulatory void and with no noise
monitoring or controls. 
The Tyabb residents expressed a number of concerns regarding the
operation of the Tyabb Airport, which it described as a predominantly
recreational airport, including: that a number of older and noisier aircraft,
including aircraft of historical significance or 'warbirds', operate out of
Tyabb Airport; that activity at the airport is at its greatest on weekends and
that the community has been unsuccessful in engaging the cooperation of the
airport operator to address issues such as these.
The Tyabb residents also expressed concern regarding the issuing of
aircraft noise exemption certificates. They said:
The system for the issuing and management of aircraft noise
certificates and the granting of noise exemptions certificates is ramshackle,
inconsistent and without focus or strategy.
The Peninsular Aero Club, which operates the Tyabb airport (the Club)
responded to the concerns raised by the Tyabb residents by advising the
committee that the Club believes 'that local community support is vital to the
future of the airport'. The Club told the committee that it has attended
meetings 'with TRBEG representatives, community representatives, Council
officers, and facilitators'.
The Club also advised that all pilots flying at Tyabb Airport are expected to
abide by a Fly Neighbourly Advice. However, the Club did concede that pilots
flying into Tyabb from other airports may inadvertently breach this advice on
occasion. As a result, the Club has sent a copy of the advice to all flying
schools and aero clubs in Victoria.
The Club provided the committee with details of its incident reporting and
complaints handling procedures.
The Club also provided details of the number and type of aircraft that
regularly operate out of the airport and the steps taken by the Club to inform
local residents about charity events hosted at the airport. The Club also
advised the committee that only a small number of aircraft operating out of the
airport could be considered 'noisy'.
The Club also advised the committee that, while a significant proportion of the
activities carried on in relation to the airfield are recreational, it is not
accurate to describe the airport as a private recreational facility. The
airfield supports a range of commercial and community services .
The committee notes that this particular situation falls outside the
role and responsibility of Airservices Australia. However, the committee was
interested to understand what role the Commonwealth has in respect of private
airfields and what avenues are available in the event that a private airfield
and a group of residents or a community fell into dispute with each other.
The committee notes advice provided by the Department of Infrastructure,
Transport, Regional Development and Local Government (DITRDLG) during the
2010-11 Budget Estimates that the Commonwealth does not have the same level of
control over private airstrips as it does over leased Federal airports. The
DITRDLG told the committee that:
The Civil Aviation Safety Authority sets the operational
safety standards for aerodromes no matter what the ownership. In the case of
the planning and environmental oversight of those airports, they are the
responsibility of the Victorian government.
Mr Mike Mrdak, Secretary, DDITRLG advised the committee that:
The issues you raise around Tyabb are very much caught up
with various state and local government planning issues in that they are
freehold land not controlled by the Commonwealth; they operate under state and
local planning requirements. The environmental issues around aircraft
operations in those locations are often looked at by state EPAs and the like in
relation to what they are prepared to allow to occur.
The Commonwealth role, as Mr McCormick said, is around the
safety of the operation of both the airfield and the aircraft involved—in terms
of CASA’s role, particularly the aircraft—and in relation to ensuring that the
aircraft operate in accordance with the airspace requirements in that location.
The committee notes that operations on privately owned airfields appear
to fall into a difficult category. The committee can well understand the
frustration felt when the relationship between residents and the operators of
an airfield break down. The committee would like to think that local councils
may be able to step in to facilitate some level of agreement regarding
reasonable use of the airfield that is sensitive to the interests of all
Australian Noise Exposure Forecasts
As the scientific measure of aircraft noise exposure levels around
aerodromes and the nationally recognised system used for land use planning, the
Australian Noise Exposure Forecast (ANEF) system provides a valuable and
complementary tool for the management of aircraft noise. By providing long
term forecasts of the likely noise exposure around aerodromes, the ANEF system
provides a measure of certainty for local communities, airport lessees,
developers and local planning authorities. It also provides an indication of
the likely response from communities to aircraft noise.
ANEF development and endorsement
As part of the Airport Master Plan development process, airport owner‑operators
are required to develop an ANEF report.
The committee heard that ANEF reports are normally prepared by specialist
consultants engaged by airport owner-operators, and take into account the
airport's commercial plans, intentions for development, assessment of industry
developments and prospects for growth. The report also includes aircraft
movement projections, runway configurations and airport operating hours.
Once developed, the draft ANEF report is provided to Airservices
Australia for a review of its technical accuracy. Airservices Australia
reviews and endorses the ANEF report in a manner approved by the Minister for
Infrastructure, Transport, Regional Development and Local Government (the
Manner of Endorsement).
In broad terms Airservices Australia must be satisfied that the type and number
of aircraft are operationally suitable for the airport, and that the forecast
numbers of aircraft movements, operating times and aircraft types are not
greater than the physical ultimate capacity of the existing or proposed
Airservices Australia's review does not consider whether the future
traffic projections are appropriate or reasonable, and does not review the
airport owner‑operator's prospects for growth or intentions for
Further, the Department of Infrastructure, Transport, Regional Development and
Local Government does not seek to assess or substitute its own judgement on
Summary of specific concerns raised
Whilst generally supported as an effective planning tool and
international best practice,
a number of submitters and witnesses raised concerns regarding the transparency
and objectivity of the ANEF development and endorsement process. Specifically,
submitters were concerned that there was no independent review of the
appropriateness of the commercial forecasts underpinning the ANEF reports
prepared by airport owner-operators.
Without independent assessment of the commercial forecasts and review of
whether the future projections are reasonable, the committee heard that airport
operators may overstate the forecasts at no disadvantage to themselves, but at
a potential cost to local communities:
Unfortunately, under current rules, the ANEF system is open
to manipulation by airport operators. The entire process of producing and
endorsing an ANEF is ‘in house’ – airport operators are free to make misleading
claims and assumptions that are not required to be tested by the approving
authority, or any other outside agency.
This was considered of concern given the ANEF report's possible influence
on the development of land in the vicinity of airports.
Mr Aaron Gadiel, Chief Executive Officer of Urban Taskforce Australia,
suggested that the ANEF reports have the potential to sterilise property
It sterilises a property right because typically if an ANEF
contour for an area exceeds 25 you cannot build a residence if there is not one
there already. If it is between 20 and 25 you can build a residence but it will
need to be modified. If it exceeds 30 you will not be able to build business or
office premises or entertainment facilities. If it is between 25 and 30 you
will need to build it with modifications. If it is above 20 you cannot build a
school and so forth. So that affects land value and it takes peoples’ property
The committee heard particular concerns regarding future development
around the Canberra Airport in Jerrabomberra and Tralee. It was suggested that
the Canberra Airport ANEF is based on optimistic and untested assumptions about
For example, operators of Canberra Airport when revising
their master plan made the assumption that Canberra airport will have the same
ultimate aircraft movements as Sydney’s Kingsford Smith Airport. Furthermore,
heavier aircraft movements at noise sensitive times were factored into the
assumptions. This overestimation of aircraft movements and bias to noisier
aircraft at sensitive times multiplies the impacts on the ANEF charts.
Essentially, unrealistic assumptions have the affect of over estimation of
impact and hence land use restriction.
It was also noted that as Australia's population increases and the rate
of urbanisation intensifies, housing pressure may further amplify the tension
between airport owner‑operators, the community and urban developers
regarding the ANEF system:
This is only going to be an increasing community concern and
there needs to be an open, transparent and accountable process where these
differences can be contested and properly resolved.
The committee notes that there is an obligation for airports to consult
with relevant stakeholders when developing Master Plans. However concern was
raised as to whether public submissions were seriously considered or acted
Before endorsement there is also a process of consultation
with relevant stakeholders. This is generally undertaken by the airport, and
evidence of such consultation must be provided by the airport when submitting a
draft ANEF chart. However, this consultation is fundamentally informative, and
it is not clear on what grounds a stakeholder could object to the proposed
ANEF, other than mistakes in the calculation procedures.
The committee received a number of submissions which recommended that
the ANEF system be subject to a more robust development and review process
where transparency, accountability and independence are the paramount
considerations. In its submission, Access Economics recommended an independent
expert undertake a peer review of ANEFs so as to balance non-aviation interests
with aviation interests and ensure the resulting land use restrictions pass a
Rather than [Airservices Australia], an independent expert in
forecasting should be tasked with peer reviewing the air traffic assumptions
and business aspirations underpinning the ANEF contours. This would avoid a
situation where ANEF contours impact on land use across large geographical
areas, yet are based on optimistic air traffic forecasts, such as those
produced by Canberra Airport. The independent expert should be given a wide
brief to strive to meet a professional best practice view on future air traffic
and fleet mix, rather than a narrow or technical brief.
Access Economics further recommended the task of assessing noise and
related land use policy may be more appropriately located under a more
independent department rather than the Transport Portfolio. In Access
Economics' submission, the Department of Environment, Water, Heritage and the
Arts or the Productivity Commission are suggested as possible alternate
departments/agencies to perform the role.
Other submitters have suggested that the Aircraft Noise Ombudsman or the
Department of Infrastructure, Transport, Regional Development and Local
Government, might undertake the independent review role.
Ms Margot Sachse, former President of the Jerrabomberra Residents
Association, said that the community would have confidence in ANEF reports if
there was an independent assessment process in place to review the assumptions
and verify that they were appropriate.
We would feel that our concerns had been put forward and that
what they were proposing was real and we would expect that, like in any
consultation processes – like we have here today – we could put our concerns
In the National Aviation Policy White Paper, the government acknowledged
that there was opportunity to improve the ANEF system and undertook to improve
the technical processes and independence associated with the assessment and
scrutiny of ANEFs.
However the committee did not hear of any practical measures Airservices
Australia or the Department of Infrastructure, Transport, Regional Development
and Local Government might be undertaking to give effect to this commitment.
Mr Mario Bayndrian, General Manager of Aviation at Bankstown Airport
Ltd, suggested that the ANEF system was not a highly sophisticated tool for
modelling the impact of aircraft noise in the vicinity of General Aviation
Aerodrome Procedure Airports:
Even the requirements and modelling done for the ANEFs is
really meant for larger jets with a smaller component of general aviation.
However, when your business is predominantly general aviation the ANEF becomes
a very blunt tool; therefore, the outcomes are not highly sophisticated. They
are correct. They meet the modelling. They are endorsed by Airservices
Australia, but I do not think they are refined enough for a general aviation
To refine the ANEF system for a general aviation application, Mr
Bayndrian told the committee that the categories of light aircraft needed to be
broadened and the system of developing ANEFs and master plans needed to be
streamlined to ensure the currency and accuracy of the final product.
The committee also received evidence regarding the effectiveness of the
ANEF system as a mechanism to inform the general public of the likely impact of
airport operations. The committee heard that the ANEF system was not well
understood by local communities:
Notwithstanding the longevity of the system, it is not well understood
by the community. For example, the ANEF contours have no direct relevance to
noise levels (decibels) but instead are the average daily noise exposure taking
account of anticipated volume and pattern of aircraft movements around
The Australian Mayoral Aviation Council noted the ANEF system can be
misleading as aircraft noise does not stop at the contour on a map. The
Australian Mayoral Aviation Council told the committee that the ANEF system is
a highly technical measure which provides imaginary lines on a map which
suggest that people or properties on one side of a line are substantially more
affected than those situated immediately on the other side of that imaginary
Mr Peter Fitzgerald, Executive Director of the Australian Mayoral Aviation
Council provided a practical example of this during a hearing in Sydney:
I, in another life, was the Mayor of Drummoyne in Sydney and
we had the 20-25 ANEF line go up the middle of a street in Drummoyne, so on
this side of the street there was no noise and it was all lovely. That is
nonsense. That is what we have had for a long period of time. If we are going
to look at a new cumulative noise measure, it has to be reducible to a single
event so that people can stand there with a sound meter and say, ‘That’s 85;
that’s 95.’ We all know it is an odd sort of number, but the other number is
The committee heard that recognition was needed in the appropriate
agencies that aircraft noise can be a significant problem at locations beyond
the ANEF contours, particularly in elevated terrain or in areas far from the
The committee also heard that the ANEF system's attribution of a
numerical value to the impact of noise events failed to adequately capture the
subjective nature of noise and the differing individual and community reactions
to noise events:
Any numerical representation of noise impacts cannot describe
the subjective impacts of noise. The ANEF assessment is inadequate to describe
impacts and should not be relied on for noise management.
This point was most clearly seen in Perth, where although the noise
event was not considered significant by Airservices Australia, the committee
received considerable evidence from residents and community organisations that
aircraft noise was having a serious impact on their lives.
The committee also heard requests from community members calling for a
review of ANEF contours in order to more equitably share aircraft noise in
their approaches and departures around Perth airport.
To improve community understanding of the impact of aircraft noise on
properties in the vicinity of airports, it was suggested that the requirement
for councils to place aviation overlays on titles for existing (or proposed)
noise sensitive areas be formalised.
Due to the highly technical nature of ANEFs, it was further suggested that
readily understandable information regarding aircraft noise should be developed
and publicly available:
It is therefore important to recognise that community
expectations in regard to aircraft noise are not necessarily best informed by
contours on a map, but through the provision of accurate, targeted and easily
understandable information about the impacts of aircraft noise.
The committee notes that as part of the White Paper, the government announced
a number of measures including the development of an effective national land
use planning regime, in cooperation with the states and territories. This
planning regime seeks to ensure future airport operations are not constrained
by incompatible development and to protect future communities from undue
aircraft noise exposure.
Aircraft Noise Insulation Programs have been implemented in Sydney and
Adelaide and funded by an industry levy. Eligibility for compensation under the
Aircraft Noise Insulation Program is determined according to noise exposure
indexes under the ANEF system.
Aircraft Noise Insulation Programs are identified as important measures
to minimise the impact of aircraft noise on the community in the White Paper:
The Government recognises the possibility that future major
civil airport operations and air traffic changes may place some residences into
high noise exposure zones. The Government will develop a framework, in
consultation with the industry, for an industry-funded program for civil
airports that ensures future insulation projects will be assessed and delivered
against world’s best practice attenuation initiatives. This will be consistent
with the approach taken at Sydney and Adelaide in introducing their noise
insulation programs which has provided for insulation measures for public
buildings in the 25 Australian Noise Exposure Index (ANEI), for houses in the
30 ANEI and for voluntary acquisition above the 40 ANEI. An improved framework
would incorporate, but not be limited to, these measures.
The government outlined its intention to expand the scheme in the White
Paper, concluding that it will:
develop a framework in consultation with stakeholders for an
industry funded noise amelioration program where future major civil airport
operations and air traffic changes place residences into high-noise exposure
The White Paper also acknowledged that there are a number of alternate
information tools that are effective noise descriptions. It was noted that to
assist local governments, planners and communities understand and take account
of aircraft noise exposure patterns, it is essential to provide a package of
readily understandable information regarding where, when, how often and how
many aircraft fly and how loud individual events are. To meet this need, the government
undertook to supplement the ANEF system with additional tools such as flight
path location and activity diagrams, and single event contours based on
The committee also heard that the Commonwealth is leading a group of state and
Commonwealth planning and transport agencies to improve the state and local
government planning processes around airports.
During the inquiry the committee focused its attention on the effectiveness
of ANEF processes. The committee did not form a view on circumstances relating
to specific airport ANEF reports, master plans or proposed developments.
The committee supports the retention of the ANEF system as a land
planning tool and the production of ANEF contours that are reasonable and
conservative. The committee noted that a conservative planning approach would
both protect the amenity of future communities and ensure the realisation of
the full economic benefits that airports offer. The committee notes the
ongoing challenges posed by noise‑sensitive development close to airports
in locations such as Sydney and is of the view that where there is an
opportunity to provide protection for future communities, steps should be taken
to do so.
However the committee considers that there are opportunities to
strengthen the processes underpinning the ANEF system. The government's
commitment to improving the technical processes and the independence associated
with ANEFs is acknowledged, however the committee notes that the significant
community, business and industry expectation for practical measures to give
effect to this commitment has not been met to date.
The committee considers that a robust evidence-based ANEF system must
include the independent review, of both the technical assumptions and
commercial forecasts which have informed the development of ANEF reports. In
considering strategies for independent review the committee noted one
suggestion that the basis for the assumptions and forecasts should be open to
public scrutiny and review.
However, the committee recognised that some information may be considered
commercially sensitive and confidential. The committee therefore considers
that an independent arbiter should have overarching responsibility for the
comprehensive and independent review of the technical assumptions and
commercial forecasts underpinning ANEF reports. The independent reviewer would
be responsible for ensuring due regard is paid to the views of all interested
parties including the airport owner-operators, local communities and their
representatives, and developers.
With regard to responsibility for agreeing the Airport Master Plans, the
committee suggests that the role of the Minister for Infrastructure, Transport,
Regional Development and Local Government might be broadened to include this
As part of the initiatives to improve the technical processes and
independence associated with the assessment and scrutiny of ANEFs, the
committee recommends Airservices Australia explore opportunities to improve the
ANEF system's effectiveness for modelling the impact of aircraft noise in the
vicinity of General Aviation Aerodrome Procedure Airports.
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