F.R.A.A.N. Final Submission
Submission and Response to the EIS, supplement, and Process, regarding the Proposed Badgerys Creek Airport, and proposals for the NSW airport solution and alternative Badgerys Creek site proposal.
All colour buttons are thumbnails and expand when clicked upon.
3) "Kick off"
5) FRAAN Alternative NSW Airport Solution
10) Lyons/Satolas airport
11) 5 Basic Points
11) EIS upgrade proposal
12) Unfair EIS process
16) Colour Plate - Badgerys Site
17) Colour Plate - Holsworthy Site
18) Hazard and Risk
19) Other risks - Electricity Grid 20) Other Risks - Gas line, water line, Chlorine holdings
21) Colour Plate - Electricity Grid
22) Colour Plate - Electricity Grid and High Risk Crash zone combined
23) Colour Plate - Photo Sydney West Substation
25) Other immediate associated risks
27) Colour Plate - Photo Water Pipelines
28) Colour Plate - Chloramination Plant Warragamba Dam
31) Colour Plate - Chloramination Plant Silverdale
32) Colour Plate - Prospect Reservoir Water filter plant
33) Colour Plate - High pressure Gas Pipeline
34) Hazard and Risk and Water
35) rainwater tanks, list of impact from EIS book 7, O'Hare airport, fish as food.
37) Colour Plate - Water catchment-Warragamba,
38) Colour Plate - water Road side stand-pipes.
39) Meteorology - Wind shear and Hazard - Fog and Wind.
42) Long Bore Shooting Range - Parliament ignored
43 - 45) insert plate - 1992 Standing Works Committee report
46) No Small Airport.
47) airspace safety gazette request.
49) Colour Plate - Airspace Management Map.
50) Airspace management - flight paths
51 - 52) Colour Plate - Aircraft flight tracks from KSA
53) Interaction with other Airports - "the Push for Option A"
55) Colour Plate - Flight path map from EIS
56) Obstacle Limitation Surface plans
57 - 61) Colour plates - obstacle limitation surface plans
61) Colour Plate - Flight track interference with KSA
62) Toxic Waste
63) Hazard Recreation - Model Park
64) Colour Plate - Model Park
65) Other recreational facility loss
66 - 69) Colour plates - recreational facilities
71) Jobs - other airport job statistics
72,73) Schools, "where will the children learn?"
74) Noise and flight frequency - ANEF/ANEC comparisons
76 - 77) Colour Plates - 1985 ANEF, 1998 ANEC - the same!
78) Noise - Housing construction
79) MISSING PEOPLE, KSA 70dBA over west, noise modelling wrong- flight paths -zones - Apparent shocking bias
80 - 85) Colour Plates -70dB zone comparisons - KSA,option A Badgerys, Holsworthy option B- numbers affected
87) People/housing developments/plans
89 - 90) Colour Plates - New Housing Development - VERY IMPORTANT article- Growth Centre, Wilton vs Badgerys
91) The Growth Centre - Gazette 156, the Secret Behind Badgerys Creek
95) Colour Plate - Growth Centre Boundary
96) South Creek Valley Sector - Political controlling power
98) Other political influences
99) FRAAN's own political experience
101) Colour Plate - ALP Flyer given out at Holsworthy
102) CSIRO site
103) Heritage Items Missing
104) AIR - Bell Report - NRDC report - Athens and other basin cities - Polluters
111) Flora and Fauna
112 - 116)Colour Plates - Eels migration to Warragaba - courtesy of Aust Geographic
118) FRAAN Alternative proposal for the Badgerys Creek site - the Cumberland Plains National World Environment Education Centre.
121) End note - thanks.
122) Appendix - permission from Aust Geogaphic, Rasons Against ver 18, Aircraft Crashes, Burragorang valley before the dam.
Fairfield Residents Against Airport Noise (FRAAN) is a totally resident based organisation of community members who have operated as an anti-Badgerys Creek Airport organisation since mid 1995. Our membership is made up of local people who have been fighting this airport for several decades; other members of the community who are aghast at the prospect of anything as dangerous and illogical as this proposed airport, and who fight for the rights of the community and the future of their own children; and new members of the community who have built new homes in the area, only to learn later how seriously they have been deceived by the "strategies for dealing with negative perceptions" process used to convince them that no airport would ever be built, so they wouldn't fight against it. We represent a wide cross section of different professions, trades and skills, however we all have one thing in common and that is that we are honest people with families of our own to bring up, and we are people who genuinely care for our environment, for other people, and their well being and safety.
All of Sydney.
None of us can really afford the massive costs associated with fighting this airport proposal, be that in form of time lost away from our families, financial cost, or straight out effort - however we have no choice, for we have to fight against something so intrinsically evil as this proposal is.
We have had members come, and go, whether it be from life's interventions, outside manipulation of our process, inside manipulation by non-genuine members (early) or just sheer unbearable frustration with the idea of this proposed airport and the interminably long process which has accompanied it.
At our core however, we are passionate and honest to our cause, and we are very strong. We will not give up our fight, for we fight for what we all know in our hearts is right. The entire Badgerys Creek airport process, right from it's very original inception is terribly wrong.
We are not connected or affiliated with any political group or organisation of any nature, and have never been at any time.
We have been active in fighting against this proposed airport in many various fashions, however our goal is to communicate our message in as intelligent, fun, and dynamic a manner as we are able, but with a focus on not disrupting other people from going about their own honest business.
Our general modus-operandi is to research and learn as hard and best as we are able, and then to educate with that knowledge as well and effectively as we can. This book is a result of that learning effort. Please read it carefully and without prejudice, and appreciate the effort that a great number of people have made on behalf of their community.
Our charter is to not only halt the progress of this proposed airport, but to also introduce as much positive content and alternative as we can into the debate, and help to change and improve various components of the investigation process for the betterment of all Australians in the future.This book is written in as light and easily read manner as could be written on such a serious topic, we have included many colour plates to make it easier and quicker for the reader to understand.
Please read on and enjoy.
- We are very thankful that a new EIS (Environmental Impact Study leading to an Environmental Impact Statement) has been conducted on the proposed airport at Badgerys Creek, and that we have had an opportunity to be a part of the process. This new EIS has found categorically that an Airport of any magnitude is unallowable at Badgerys Creek.
As poor as the EIS has proved to be, it never-the-less clearly shows that an airport must never be built at Badgerys Creek.
Nothing can more clearly encapsulate the essence of the Badgerys Creek airport proposal than the final paragraph of Bishop Kevin Manning of the Catholic Diocese of Parramatta submission when he wrote: "Regardless of whether or not there would be economic "benefits" accruing to such a site, the overall impact of the airport on the well being of significant numbers of individuals is likely to be negative. This is unacceptable in an absolute sense and even more so, when the current level of disadvantage experienced by many in the region is noted. The unacceptability of the proposal from a social justice perspective is further heightened when consideration is given to those in the community on whom the airport is likely to impact on most - young children, students of non-English speaking background, the elderly and the sick. Those who are most vulnerable in the community and in need of greatest community support and protection are those who are likely to experience the greatest (negative) impact of locating an airport at Badgerys Creek. This proposal clearly does not respect the common good."
A company of the magnitude of PPK have performed their EIS, and at the end of it all, they have not come out with a clear and reasonable preference from three options - we submit therefore, that this proposal is unsustainable.
It is patently obvious that virtually no-one wants an airport at Badgerys Creek; we have often found that those who do, have vested interests, or are generally seriously misinformed. We are aware that there has been a campaign of "strategies to deal with negative perceptions" which has led a great many people in Western Sydney (and Greater Sydney) to honestly believe that the proposed airport would never be built, and is not seriously on the agenda. Thousands, if not hundreds of thousands of families have built their new homes close to the proposed site and in proposed flight paths, honestly believing that the proposed airport would never be built - because that is what they have been told.
- F.R.A.A.N. advises the Government that we have no doubt what-so-ever that in the event that this proposal should be given the go ahead, a very great many people who have so far remained silent will activate - against the proposal, and those who would allow it, including the Government itself.
We have spent a great deal of time with the community in general, and are absolutely sure of the above statement, based on our very frequent experience.
The people of Sydney do not want it; with very few exceptions the politicians of Sydney do not want it (and those who do, have questionable motives); Pilots are scared of the site and do not want an airport there; airline operators do not want an airport at the site; the local Government Association representing Local Governments from all over NSW overwhelmingly voted against the proposal on Feb 27, 1998; learned professionals and professors alike have come out against it; churches do not want the airport; schools do not want it; the Federation of Parents and Citizens Associations of New South Wales and the Teachers Federation do not want it; the Total Environment Centre; the Friends of the Earth, the Democrats, the Greens..... the list of organisations and People who do NOT want an airport in Western Sydney is almost endless - most importantly, children do not want it - it is a topic of fear at local schools.
- We are left with one single Western Sydney Council vehemently pushing for the airport: Liverpool City Council; who are noted in the EIS (book 2 page 9-17, 9-18) as having land adjacent to the proposed site, and who are closely associated with local very powerful and large developers and businessmen, who also have major land holdings very close to the site, and figure prominently in local economic development boards etc., pushing for the development.
- Even here, we are confident that if Liverpool Council were to put a motion of support or otherwise, to the council itself, the support for an airport would dissolve in that one vote.
- There are few Federal Politicians (from both sides of politics) who genuinely favour the development, and it is fair to say that those who do, are probably ignorant of the facts surrounding this development.
Certainly the EIS performed by PPK is sorely deficient in determining and describing the facts, and even so, those serious negative impacts that have been noted, are rarely if ever noted in the summary document, or even in the body of the main report.
- It is unlikely that Politicians who would make this executive decision on the commencement or otherwise of this proposal, would have time to read the extensive volume of technical paper supporting the EIS main report and summary, and as such the main body of evidence must be supplied in these summary style reports, which is not the case.
PPK should be ashamed of their performance, particularly in view of the criticism of the 1985 Kinhill Stearns EIS on the proposed airport, or of the third runway EIS at Kingsford Smith Airport. In consideration of these, one would have expected this company to provide an EIS which was complete in detail, accurate in description, first class in methodology, and totally honest. They cannot take credit for any of the above.
PPK have been often advised of many if not all of the major potential impacts of this proposal, and yet they have chosen to ignore them. It is fair to say that the process of community consultation has been rendered a perfidious one by this company, since concerns of the community, professionals and Government alike have all but been ignored.
To put this in perspective, $12 million of taxpayers money has been spent on an EIS for an airport, that has not even determined whether or not a pilot can fly an aircraft from an airport at Badgerys Creek.
If it were not so serious, this would be laughable.
- This is discussed in more detail in the meteorological section of this submission.
They have even chosen to ignore the queries and observations of Parliament itself. Proof of this to follow.
History has shown us that this must be a ministerial decision - the 1989 Perich court case shows that clearly, when the Judge noted that the decision was "not a point of law, it is a ministerial decision."
The Liberal Party sits in command of our country at the moment, no longer in opposition they are the power of the country, and the time has come for a decision - kick the stool, or cut the rope, but a decision - please.
Please find our own alternative for a Sydney airports solution within the next 3 pages. The remainder of the document presents the clear evidence against this Badgerys Creek proposal (with an exciting conclusion).
ALTERNATIVE AIRPORT SOLUTION
Currently, all freight and aircraft users from NSW wide have no choice other than to travel to, or from Sydney because this is the only internationally capable airport available to them.
We consider that even if the numerous other air quality (and other environmental) reports (including their recommendations) commissioned by various Governments are continued to be ignored, as they have been since at least 1973, it is obvious that Sydney's expansion will be ultimately limited by the physical constraint created by the Blue Mountains.
It is equally obvious that future growth will therefore be to the north, south and west of Sydney, outside the basin, as is already happening on a massive scale, particularly to the north.
If the only internationally capable airports in NSW are located within the Sydney basin, then it stands to reason that all international and domestic aircraft users from Sydney itself, as well as all of those from Newcastle (and the massive population growth north of it) and south of Sydney too, (including their respective fresh food and industrial freight needs) will have to travel to Sydney to access a major airport. In short, every person in NSW, who has a need of a major aircraft service will have to travel into the Sydney basin to do so, as they must do now.
Given the expected increase in future aircraft movement, this will act towards choking the Sydney basin in a variety of ways, most of which would obviously be negative in environmental, social and economic terms. The only major regional access to Sydney, via road, is the Great Western Highway to the West, the Hume Highway to the South, and the Pacific Highway to the North; roads which already suffer from choking with traffic moving into and out of Sydney. For instance, there is only one bridge crossing the Hawkesbury river to the north of Sydney, and it chokes to a standstill on a regular basis during normal use, let alone during periods of high use such as holiday periods.
How could these roads ever cope with such a huge increase in demand in the future?
We believe the following to present a workable solution to Sydney's airport problems.
F.R.A.A.N. wishes to forward a potential solution to Sydney's and NSW's airport problems.
We believe there is a solution to the airport problem, and one that would serve NSW's freight and expanded population needs, and relieve massive pressure off KSA. We believe that the problem is being viewed from an incorrect perspective in as much as the problem is really one for NSW rather that Sydney alone. With this in mind:
Why not use Williamtown (Hunter Region) Canberra and Central NSW airports together (which will inevitably be international airports any way) linked to Sydney by fast transport methods? We can do this virtually immediately. This would leave us time to find a real solution to the Sydney airport problems, outside the Sydney basin.
The Australian Bureau of Statistics indicates that KSA (Kingsford Smith Airport) total aircraft movements for the 1997-1998 year were: International aircraft - 45,849; Domestic aircraft - 103,788; and Regional aircraft - 98,828. Extrapolated, this means a total of 248,465 aircraft movements per year, or 681 aircraft per day, or (given a 17hr operating window - 11pm to 6am curfew KSA) 40.04 aircraft movements per hour.
We point out that the proposed Badgerys Creek airport project would be the biggest capital works project in Australia's near agenda, however, for the first time a major capital works project with the ability to destroy lives, rather than enhance them. We remind the reader that not all passengers want to get off at Mascot - a large percentage simply transfer from one aircraft to another. There is no real reason why this could not take place at any other airport, at any other location in this country.
* We believe that it is inevitable that an internationally capable airport will be constructed at Williamtown airport at Newcastle , or other site in the Hunter region.
-Williamtown currently operates as a non- curfew airport, and is essentially already internationally capable. Current runway length is 2,438 metres.
-A simple customs clearance facility , a tin shed, is all that is required to bring the airport into immediate international status.
-This airport (or other international airport in the Hunter region) would alleviate a great deal of pressure from KSA (Kingsford Smith Airport ;Mascot), by handling a of all types of aircraft, regional, domestic and international.
- It will be able to accommodate future population growth north and north west of Sydney.
- It should be able to service the Hunter Region and north and north western sector of NSW, including it's considerable freight output needs.
- Currently a great deal of freight (such as Hydroponic Crop and Wines etc) from the Hunter Region and northern NSW is road transported into Sydney eventually to KSA, over the one bridge over the Hawkesbury River. This already freezes during long weekends etc. It is inevitable that future increases of this into Sydney only airports, will unnecessarily clog the main northern arterial road leading into the Sydney basin, as the skies over our heads would clog with aircraft, and our environment clog with pollution.
- This airport would alleviate a great deal of heavy vehicle traffic within the Sydney basin environment.
- We point out that Newcastle within the Hunter Region has a serious unemployment problem of about 14% and they are about to lose several mines and the BHP site, all big local employers. Obviously unemployment rates in the region will skyrocket. The Abi Group has indicated that they will build an airport (anywhere within the Hunter Region) at their own cost, and without use of taxpayers money. They will also fund fast rail between Sydney and Newcastle.
A fast rail connection between Sydney and Newcastle is required for the future, and we believe that it is inevitable that this will occur anyway. There is already existing, a high speed road link between Sydney city and Newcastle. A high speed "wave cutting" style of ferry could also be implemented if larger numbers of people must be brought to Sydney, and we have spoken to several tourists who have nominated that they would love nothing more than to finish their journey with an exciting trip such as this would provide.
Noise impact should not be a problem. Long term residents from Newcastle report that there is no problem with noise impact from overflight of the city, from aircraft currently operating from the existing airport at Newcastle/Williamtown. There is nothing much louder than an FA18 Hornet flying at low levels such as operates from the airport now, so these people should know. Those few people who would be noise impacted from expanded operations from the airport, already would be by the loud military aircraft (and the considerable civilian operations) operational from the airport now, and these people if not already, should be highly compensated and moved to a non affected area. Operations from this airport are generally in and out over sea, and should always remain that way.
Given that currently the highest percentage of Sydney airport users are from north Sydney, it is entirely conceivable that they would consider travelling north to Newcastle along the freeway, or fast rail service, rather than to Sydney. It is not conceivable that they would want to travel to an airport at Badgerys Creek, or to an airport south of Sydney. There is an oft noted premise that aircraft passengers all have a desire to come to Sydney, and this is simply not true. Ask most business persons, or local holiday makers from Coffs Harbour for instance, and they will almost certainly respond that they loathe having to come to Sydney to catch an aircraft. They simply want to visit offshore holiday destinations, or conduct their business within Melbourne or Adelaide etc. and then come home, without the hassle of getting into and out of Sydney. Likewise, tourists we have interviewed have indicated that they really do not mind where they land, as long as there is a fast and convenient method to travel to Sydney and other cities from that site. They are after all, tourists - they are here to visit and look at our beautiful country as well as our cities.
These people north of Sydney deserve a reasonable airport/aircraft available service in the future anyway. Newcastle/Williamtown would also serve as an northern airport/aircraft backup protector for Sydney, or a southern replacement airport (should that ever happen) in the future.
* Canberra airport is now being made Internationally capable, as was also inevitable.
- The fast rail connection between Canberra and Sydney is already a foregone conclusion, and we would hope that it would be the beginning of a continued service reaching onwards to Melbourne and further.
- The international airport at Canberra would be able to accommodate needs of the population growth of southern NSW, and ACT.
- It will be able to meet freight requirements for the south and south western sector of NSW.
- It too, will alleviate a large number of road transport freight vehicles from the Sydney basin roads, and the Hume Highway leading up to Sydney.
- It will be able to alleviate large numbers of all types of aircraft from KSA, and regional aircraft coming from southern NSW could go to Canberra airport instead to link up with other services.
* Parkes has indicated that they would desperately like to upgrade their airport to an international status freight dedicated airport, and an airport in Central NSW is inevitable and must happen.
- They indicate that this would cost about $76 million, which is not a great cost.
- An internationally capable airport in Central NSW would alleviate a fair percentage of regional and other aircraft, including internationals, from KSA, given it's central location.
- It would be an absolute boon for tourists, since red plains, kangaroos and emus are what they expect to see in Australia; like coming into Sydney and it's bridge and opera house, landing into central NSW would be a very exciting experience for the tourist - there would be a genuine reason for a tourist to want to land at a central NSW international airport - unlike Badgerys Creek.
- It would handle the considerable if not massive volumes of freight currently being road transported into Sydney to KSA, over the one western major road over the Blue Mountains. This freight (far greater than 200,000 tonnes) is almost all perishable product(from inland NSW) and so needs to be transported out by aircraft.
- The area is a natural road and rail transport hub already, and is on the Transcontinental rail line.
- It is centrally located to the eastern states of Australia.
- Future planning, with a central NSW hub style airport/fast rail interchange (similar to Lyons/Satolas, 300 miles south of Paris) would have the potential capability to service by fast rail (or current heavy rail) hub radiated plan; Qld, NSW, ACT, Vic and SA, given it's central location.
- Given that at least 30% of passengers at KSA simply cross the tarmac from one aircraft to another, there is no reason why this could not happen at an airport in central NSW.
- An airport in central NSW would create a multitude of genuine jobs, and bring back to life the central region of NSW, which is at present is a dying region with little prospect for growth.
- Parkes have indicated that they are able to deliver freight to 82% of the Australian population within 9 - 12 hours, with the existing transport network available to them now. Future radiated fast rail connection would reduce this service time even more.
We feel that the example of the Lyons-Satolas fast rail interchange/international airport 300 miles south of Paris, is perfectly capable of being replicated if not greatly improved in Australia, with foresight and long term logical planning in mind, and with considerable advantage and usability over the Satolas model. It would have the ability to expand to service our future needs, it would give us a "back door" short cut transport hub, to service tourists, freight and normal Australian transit passengers - far into our future.
Tourist forecasts promoted by the Government as the reason for the urgent development of the proposed Badgerys Creek airport are spurious in their own right. :- The 1998 Australian Tourist Council's quarterly summary notes that; "....inbound visitors growth has almost ceased, at present running at an annual growth rate of under 3 percent down from 15.5 percent recorded in mid November 1997." It then notes that "...the slowing of inbound visitor numbers to Australia has been well documented, particularly since the Asian crisis became evident." Tourist growth has however, been evidently slowing since mid 1994; the Asian crisis has simply accelerated the trend from about the middle of 1997."
Likewise, the constant reference to job creation (which we note is promoted in a great part from those persons best described as financial "beneficiaries" of the proposed airport)is spurious since no matter where an airport would be placed, jobs for Australians would be created.
The EIS indicates that a million tonnes of cargo will be expected at the Second Sydney airport. Presumably this would be trucks from NSW wide converging into the Sydney Basin, and leaving from it. It is inconceivable that an off-shore airport will be able to accommodate this demand. Likewise it is inconceivable that one single roundabout at Badgerys Creek will be able to handle this traffic volume, or for that matter, one small airspace over a grown city handle the volume of aircraft traffic expected in the future.
Given the earlier noted statistics, these airports would obviously work to immediately alleviate a major portion of the load on Kingsford Smith Airport, and would do so well into the future. They would also serve to meet the future demands of NSW aircraft users, and would remove an enormous percentage of heavy vehicles of our already choked roads.
A Second Airport.
A second, or even replacement Sydney airport, outside the Sydney basin can be more carefully planned and considered for with the considerable time made available by the afore mentioned proposals.
- Since there will be a fast rail connection between Sydney and Canberra, a future replacement airport or 2nd Sydney airport could be constructed at a number of places along this route, which would offer the advantage of future expansion to meet future growth as needed. We personally favour Marulan to the north of Goulburn for this purpose since it is already an intersection of major highways, and a rail head as well. There is no great population level or growth in the area, and if this site should be chosen, as should any other site for that matter, residential development must be prevented in the large surrounding area well prior to any airport being constructed. Large plantings of trees around such a site would ensure that no urban growth encroached the site, and would act as a noise buffer and a soft put down area against the event that an aircraft should fail during take off or landing.
Australia has an immense advantage over the rest of the world in that we have seen the mistakes made by other countries and their Governments, and also their successes. We have the invaluable chance to avoid repeating the mistakes made by them, and the massive associated costs, particularly of those "basin" cities such as Los Angeles, Tokyo, Mexico and Athens. We also have a huge advantage over them, in that we have extensive amounts of useable non-critical land space available to us, well away from large areas of human population and environmentally critical locations. We note that no other country in the world is considering to build an airport such as the Badgerys Creek option(particularly A and B) currently being entertained, and certainly not one that puts immense risk on their only major water supply, their electricity supply, the health and well being of the entire city area, or at the expense of increasing what is already very poor air quality. The Badgerys EIS notes that Athens is moving it's airport outside of it's basin area because of air pollution (and obviously safety) concerns generated by it.
We ask you to please consider very carefully the genuine logical and long term realities and implications of placing a second airport within the Sydney basin, and the needs of the population outside of the basin area, ie - greater NSW itself.
Please refer to the plate on the next page. It is;
- An Aviation Week & Space Technology article which shows the nature of Lyons - Satolas airport in Europe.
Insert Lyons - Satolas article.
F.R.A.A.N. wishes to make five basic points.
1) The Auditors (SMEC) EIS draft and supplement response reports should be considered as an integral part of this submission, and must be fully considered in any deliberations/decisions made by this Government (or any other) regarding this proposed airport. Their commissioned sub-reports must also be fully regarded. The very fact that they have slammed the EIS and it's summary so seriously, clearly indicates that the EIS investigation process, particularly in this instance, is shockingly flawed and wrong.
2) The Federal EIS process under the "Environment Protection (Impact of Proposals) Act 1974" has proved to be a totally unreliable predictor of impacts of proposals on the environment (including people). The very foundation of the problem is the lack of strength exhibited in the Act, and this is where the change must be. We are aware that Minister Hill has initiated a new environmental legislation, however we ask that this Government ensure that clearly provides the same checks and balances as we have provided within our own submission, for the benefit of Australian people, business, and politics who must decide on any development, based on it's genuine merits or deficiencies.
We believe that the current EIS process must not be used in Australia again, until such times as the process has been upgraded.
Please find below, our proposed upgrade of the Act which we believe will overcome the current problem:-
a) guarantee the accurate assessment of impacts of a proposal on the environment and people, through comprehensive monitoring, with steep penalties for adverse variations from predicted impacts.
b) guarantee reliability, transparency and honesty in the process.
c) guarantee full disclosure of all working paper to the community, or if absolutely secret in nature, to an independent auditor.
d) guarantee that all community information and input, at all stages of an EIS, is fully and properly regarded.
e) the "quantitative" method of assessing public submissions should not be used since it is entirely probable that individual submissions which differ from mainstream are likely to contain specific data and questions of local and direct significance.
f) guarantee that the community is allowed an absolutely adequate period of time and resources to investigate an EIS after it's release.
g) guarantee that those persons or companies (including Ministers and bureaucrats from Government Departments) inputting into the formal EIS must identify themselves to each component, and must be held fully responsible and accountable for the information they supply, including deliberately misinforming and/or neglecting to supply important information to the EIS and/or process.
h) guarantee that a full and proper cost benefit analysis is included as part of an EIS.
i) ensure that any EIS be based on a full regional cumulative and flow on assessment of impact basis.
j) ensure that any main report, including summary, include all relevant and important information, both negative and positive, in plain English style.
k) provide an independent auditor to each future EIS to provide a failsafe, and to be able to professionally determine whether or not there has been a breach of rules, and if so, by whom.
l) provide a mechanism to allow publicly funded appeals on both the merits and the procedures of an EIS.
m) A mandatory public enquiry must be triggered either by any proposed development with a total budget in excess of $50 million, or by a petition signed by 2,000 people. - This public enquiry must have the rights, powers and protections of a judicial enquiry.
3) This EIS process has been extremely unfair.
a) The time allowed to conduct an EIS on the biggest capital works project currently on the Australian agenda, with the potential to destroy millions of lives, was far too short to allow a thorough job. To clarify; the EIS for the Federal Highway, Lake George deviation was carried out over two years; for the upgrade of an existing road!
- The Badgerys draft EIS was really finished in about 6mths, Holsworthy dumped and promised to be removed from the process, and a promise made to release the EIS immediately the Holsworthy component had been stripped out.
- We are presented with an EIS supplement which has serious deficiencies once again, and has still avoided impacts (Eg Long bore shooting range, critical service infrastructure zone in the high risk area, air quality impact, etc.) clearly indicated to PPK via a number of processes (public consultation process, official submissions, letters etc)
- We are presented with a series of EIS summary documents which have not shown the major points of concern about an airport at Badgerys Creek, shown in the main reports, and technical documents. (Eg night noise impact maps, Obstacle limitation surface plans, "Growth Centre" Gazette etc.)
b) Extraordinary bias is obvious throughout the EIS and the process itself.
- To clarify; maps and photo's through the EIS itself, and right throughout the process, have been differently presented, (eg see photo of site boundaries on the front page of the main report vs the map on pg 15 of summary - north western corner boundary, or the differences displayed between presentation of Holsworthy options vs the Badgerys options in the PPK November 1996 "Proposals" brochure) with mis-information exceptionally common in the Badgerys material. - We were presented with an EIS which did not have all of the Holsworthy material removed.
c) The very fact that the EIS was released immediately prior to Christmas 1997 is and was, unfair in the extreme. This caused far too insufficient a period of time for the community to access and absorb, then respond to the process. Likewise, it is intrinsically unfair that the community (who would be the sufferers) have no official opportunity to address the failings of the EIS supplement.
d) The summaries which have been made widely available to public are insufficient in detail for the average person to ascertain what the impact would be on his own, or future family's life. Eg - a local business person is unable to determine exactly what the impact on his business or personal life will be. People entirely reliant on roof water supply still have no idea what the impact on their water supply would be. (Even if they have access to the technical data/reports). Pilots still have no idea whether or not this would be a safe site to operate from, because there has been no vertical profiling carried out for the EIS etc. etc.
e) Even though there is more than 70% of people in the outer western Sydney area surrounding the proposed site, who are of "non English speaking background" (NESB), there is no real information made available to them in their own language. The Govt. and PPK have been asked repeatedly to do so, but have chosen to effectively not inform these people. It is interesting that (NESB) may sit a drivers licence test in any of about ten languages, but they may not read about a proposal that might well totally destroy their home value, business, life and family.
f) Technical data behind the "Planning and Design Summary Report" was not supplied with the EIS, - nor were the Auditors (SMEC) own technical reports made freely available.
4) We are most concerned that PPK have an apparent conflict of interest, since the parent company WMI owns the Pacific Waste facility at Badgerys Creek, a business which would benefit immensely from an airport at Badgerys Creek.
- In view of the extra-ordinarily poor quality of the EIS, PPK's proven penchant for ignoring extremely important negative factors and risks, and their potential conflict of interest, we are of the opinion that the supplement issued by PPK should be viewed with a perspective toward possible serious manipulation towards understatement of impacts, in favour of local big business concerns, developers, and political power gain.
5) The information centre which used to be at Badgerys Creek, on Badgerys Creek Road, was moved into Liverpool, once the Holsworthy proposal was initiated. This Liverpool location was totally against the desires of the public, since Liverpool had shown such clear bias towards the construction of an airport at Badgerys Creek, and vehement objection to the Holsworthy proposal, even though both sites fall within the Liverpool Municipal Boundary, indicating that any benefit/profit from an honest airport proposal would still go to that council. After the decision to drop Holsworthy from the process was made, the information centre at Liverpool was closed, however, no new centre was ever opened for the public to be able to obtain information on the Badgerys proposal. In short, the western Sydney public have no way of obtaining proper information on this proposal now that the supplement has been released. We feel that this is extremely unfair, particularly considering the severity of the impacts that these people (and their businesses) would be subjected to, if the airport were to be constructed.
* During the consultation phase of the EIS process, serious "accidents" occurred; a public information day held at the Kemps Creek public school was advertised in the St George and Sutherland Shire Leader - a newspaper which is not at all local to the Kemps Creek/ Western Sydney area.
- An information day held at the Fairfield Forum was advertised in the Christmas edition of a local Fairfield paper, which was not distributed. The consultation event was also held during the school/Christmas holiday period, and so was not reflective of normal numbers of people at that shopping mall, and a reduced number of persons were able to be involved, or informed. - PPK promised that they would do a mail out of information to the communities closely surrounding the site. This never occurred.
- Promises were made by PPK that full information packages in various languages would be made available to the very large component of Non English Speaking Background (NESB) people who make up the area in the outer western Suburbs area. Although there were some basic flyers in varied languages these were at best a token effort at providing information to these people, and so a very large section of the surrounding population remain uninformed of the impacts of the propose airport on themselves and their businesses etc.
The Badgerys Creek Airport proposal is like a noose around the neck of western Sydney, and for that matter, all of Sydney. It has been like this since 1975, but at no time has the noose been tighter than it is at present. For many years the residents local to Badgerys Creek have effectively been 'standing on a stool with a noose around our necks' - the time has come to "cut the rope'......please make a conclusive decision against the proposal so that the people of western Sydney can get back to living their lives with some self direction in what to plan and do with their homes and lives.
We are confident that this cabinet will come to a clear and precise decision, with all fair and reasonable concern.
(Nb. - F.R.A.A.N. Wishes to make it absolutely clear that we do not want an airport anywhere within the Sydney Basin)
We would also ask the reader to note, as they read this submission, how often there is a totally illogical push towards option A or B when there are exhibited such clear and absolutely major problems with this particular alignment, particularly when compared over the north/south aligned option C.
Please refer to the following two colour plates, as a comparison. They clearly indicate the fairly typical nature of bias shown throughout the EIS.
1) PPK EIS overhead photograph of the proposed Badgerys Creek site.
2) PPK EIS overhead photograph of the proposed Holsworthy site.
HAZARD AND RISK.
This new EIS has an extremely serious deficiency in as much as it has not in any manner, genuinely investigated the effects of secondary risk and hazard, neither has it seriously and genuinely investigated the primary risks and hazards.
F.R.A.A.N. feels that the many serious risks which would be created, constitute the most important and serious threat presented by this airport proposal.
- There is the obvious hazard and risk of an extremely serious increase in air pollution in an already very dangerously air polluted basin environment.
- There is the extreme risk of polluting or poisoning an entire cities water supply.
- There is the extreme risk of destroying our vital services - electricity, gas, water service pipelines, and major roads which would allow people to escape from the Sydney wide catastrophe which would follow.
- There is considerable risk in driving a convoy of about 65 fuel tankers per day (for the first stage of the development) through relatively dense urban population, on roads already noted as being choked.
- Since the airport would be at the rear of the city and suburbs which constitute the Sydney region, and at the foothills of the mountains, aircraft would be flying over virtually all suburbs of Sydney, therefore putting the people of Sydney itself under considerable increased risk of an aircraft crashing into the suburb in which they live, or infrastructure on which they depend.
We have attached a list of aircraft crashes around our world in the appendix of this submission. As sad as it may be, please read it before deciding on this airport proposal. It is extracted as a part of the file only, in order to reduce the size of this submission - the internet site is located at the top of each page, where the rest of the massive file can be accessed.
- Please take note of the distances that most of these aircraft have crashed; usually so close to an airport, and often in line with the runways.
- Please note how often they have hit hills and mountains close to airports, please be aware that there are hills to the north east, and mountains to the west of Badgerys Creek, which cannot be avoided by flightpath, particularly by option A or option B.
- Please note that many of these crashes, if equated to the Badgerys Creek site would have been into the critical infrastructure area incorporating the water pipeline, gas pipeline and NSW electricity station 10km from the end of the runways, or dense residential areas, or into extremely large and volatile industrial areas such as Smithfield/Wetherill Park.
- Please note the frequency of birdstrike being the cause of crashes, and know that there are many dams, water storages etc, and garbage tips (which will become even more so given the amount of quarries in the area) which are magnets for birds. Bats although understated in the Badgerys EIS, are very common in the area.
- Please note how often fog and thunderstorms have been the cause of a crash - both common meteorological events that Badgerys Creek is well known for.
- Please know that PPK have used fog and meteorological data, based on a two year period only, from a facility that has taken its records from between 9am and 3pm only, the time when fog (and storms) are least likely. Please believe the local people; the site does suffer from electrical storms, and from very heavy fogs.
- Please note the countries and areas where these accidents have occurred; they involve most airports in the world.
- We remind the reader that an airport is an extremely long term operation, amplifying the possibility of serious repercussions if this airport were to be built; explained in the rest of this work.
- The airport site is entirely land locked, with the mountains behind it, and the people of Sydney between it and the sea.
- There are hills and mountains in very close proximity to the proposed airport site.
- There are our most vital services very close to the site, in areas where aircraft are most likely to crash.
- We have privatised our own airlines, leading to a much reduced standard of aircraft safety, due to the need to maximise profit, and remain competitive.
- We now have a great many new airlines flying into Australia, many of whom are proved to be unreliable in safety standards.
- We have a small airspace environment (Sydney Basin) in which to try and fit a great many different types of aircraft - over a city.
- The area in question where the Australian International Pilots Association have expressed their real fear of encountering wind shear, would lead an aircraft into trouble over our water supply in lake Burragorang.
- PPK have based their assessment of risk on outdated Australian statistics, and not world.
- There is risk of serious increase in on-ground vehicular accidents due to very high road use increase, of mixed vehicles - in an area which DOES suffer from an extremely high incidence of fog, and also very serious road congestion already.
- Tomorrows aircraft may be able to negotiate fog to land, but there are many old aircraft still flying not so equipped, which would use this proposed airport. This will be unavoidable and would thus seriously increase the potential for disaster.
- Motor vehicle drivers may well have to put their heads out of the window to find the line at the edge of the road (as occasionally happens now) in heavy fogs, and do not have the advantage of technology to help them negotiate through fog.
- Approximately 80,000 extra vehicles, including heavy freight vehicles, per day, all trying to squeeze through one poor roundabout shown at the site, and compete on roads noted in the EIS as already being at their capacity.
- Please note again, that the site is genuinely landlocked, between the mountains to the west and hills and urban suburbs to the east - there is no quick escape out to sea.
MAJOR SERVICE SUPPLY INFRASTRUCTURE - RISK
Please refer to the next three colour plates. We have overlaid the high crash risk area map from the EIS, over an electricity grid supply map (supplied by TransGrid), and the local substation electricity suppliers - to all of Sydney; to most of NSW, as well as part of Northern Victoria.
- As can be seen in these accompanying maps the Sydney West Electricity division station is directly in line with runways from the proposal 10klm out, in the high crash risk area. Please also note (as we have marked on the map) the extremely close proximity of the Moomba-Sydney high pressure gas line (part only) and the Warragamba-Prospect water supply line, as well as the M4 tollway and Great Western Highway. It should also be noted that the water pipeline between Warragamba and Prospect is gravity fed, and breach of the pipeline above Sydney West electricity would probably take out the electricity division station anyway by way of the resultant high volume water flow.
- These facilities in combination have been often notified to PPK via written submission, and vocally via community consultation meetings held by PPK. This is ignored in the EIS.
- Recent experience in Auckland, New Zealand, and in Queensland, are graphic examples of how immensely important electricity is to today's society.
- We have likewise seen, also in 1998, the catastrophic effects of the poisoning of the Sydney water supply, and the loss of the Victorian gas supply.
These have all been serious, but at least affected population and business were able to boil their water, and loss of gas and electricity to their respective communities was short term with the ability to use available alternative energy. The long term loss of all water, or gas and/or electricity supply to Sydney, (and other areas of NSW) such as this risk presents would be absolutely catastrophic.
- It is entirely conceivable that Sydney could find itself without water, natural gas supply, and electricity supply, in one single event.
It must also be noted that PPK, contrary to their promise to use world based statistics have used Australian statistics only, to determine the size of the high risk crash area, for this proposed international airport, and as such the impact zone should certainly be shown far larger than that which PPK has presented. Never-the-less this shown extreme high risk area shown in the EIS overlays all three service facilities. - There is no comment or investigation into the potentialities of damage to these facilities in the EIS.
- Please note that the photo page is of the Sydney West Electricity Station at Horsley Park. There is the Kemps Creek Station (see electricity grid map) also critical to our power supply, even closer to the proposed site and major electricity easements straddling the runway alignments of all options, to consider as well, also critical to the NSW/Sydney electricity supply.
Please refer to the next 3 colour plates,
1) The NSW state high voltage electricity grid (supplied by TransGrid)
2) The local electricity grid - supply stations and EIS high risk aircraft crash zone combined.
3) Photos of Sydney West Electricity at Horsley Park.
As noted, the Sydney West electricity division station is the supplier of the bulk of electrical supply not only to Sydney, but also to greater NSW. Please note that the line marked 5A1 and 5A2 on the attached electricity grid map running to Kemps Creek, is a 500kV supply.
FRAAN has been advised that the Sydney West Electricity facility is absolutely critical to supply of electricity within the Grid, because of it's hub nature, and that complete supply restoration would take an extremely long time if this facility were to be seriously compromised. We are also advised that failure of this facility would have serious repercussions on major electrical generators well outside of the greater Sydney area due to overload, over speeding and subsequent breakdown. We are advised that after any rebuild or re-route, such an event would cause a situation where generators would have to "black start" - ie. one generator started at a time, brought on line, all over NSW, over an extended period of time.
The EIS does not mention in any way, what the repercussions would be, if this facility were to be damaged or destroyed, either by some form of low level fuel deposit over the site, or if it were to be involved in an aircraft crash. The site is within 10 kilometres, and in line with the end of the runways, and within the high risk aircraft crash zone identified in the EIS.(see Vol 1, fig 19.5). We note again, that modelling for crash risk was based on Australian statistics, and not on World wide statistical modelling.
PPK have been asked repeatedly to use world experience as a base for the EIS, since this is proposed as an international airport, and because of the privatisation of our airlines, and their current and future need to maximise profits leading to lower maintenance standards, thereby placing them in a parallel situation with the rest of the world.
Again we note that PPK have been advised about the proximity of Sydney West power many times, by F.R.A.A.N., and the community in general.
- As earlier noted, the Kemps Creek major substation is also in alignment with proposed Badgerys runways, and is within 5 km. of the site. The Kemps Creek facility is also critical to the electricity grid supply. There is a major easement between the two mentioned electricity stations, directly in line with all runway alignments. None of these facilities, or their potential impacts have been identified in the EIS. The supplement has noted, although well hidden, (vol 3,page 16-13) that "full restoration of the facilities, however, could take months or years". Point proven. This therefore, is a risk far too great to take. Once again, sense does not prevail. The EIS supplement (pg 16-13) notes that "In option C no substations are located within the one crash per 100,000 years per square kilometre contour."
Our question; why then the continued insistence on option A and B when it is proved to be so extra-ordinarily dangerous compared to option C (which we still never-the-less oppose entirely)? Why have PPK chosen not to include this massive danger in table 16.2 right next to this page, instead of hiding it amongst the dense text?
It is obvious that if the major percentage of the Sydney electricity supply were to be removed, the repercussions could be immense, and long term.
Obvious impacts would be:
* severe economic cost and loss to business.
* potential for serious loss of human life, via critical infrastructure failure, such as traffic lights, emergency services, loss of heating/cooling capacity to homes and businesses during temperature extremes (particularly for the aged and infirm), persons trapped in lifts for long periods, etc.
* Total loss of transport infrastructure ability including rail and airport operations.
* It is unlikely that supply could be fully restored before frozen foods thawed, likewise loss of electricity supply would render electric cooking apparatus useless.
FRAAN were unable to find another airport in the world at which aircraft flew (particularly "fly by wire - electrically controlled" new aircraft) over such a large electricity hub, at low levels.
FRAAN often asked PPK to investigate the possibility of E.M. (Electro magnetic) interference with aircraft operations (hand held toys, phones, laptops are interfering with aircraft control - discussed later) against the event that this facility might seriously affect safe operations of Aircraft, or other safety of the proposed airport. (We have recently been verbally advised by the Australian International Pilots Association, [22nd February, 1999] that these EM related problems with aircraft are found on modern 'fly by wire' faulty aircraft and usually occur during take off and landing phases). We asked this of PPK since aircraft would fly extremely low over an extremely powerful five hundred KV power line, not far off the ends of the runways on the eastern side of the site, and/or the Kemps Creek major receiver and distributor and Sydney West electricity at Horsley Park; all so close to the proposed airport, and all such obviously big producers of EM.
- FRAAN can find no comment or investigation on any possible effects from ground based EM, or impacts to this site in the EIS or in the supplement either.
OTHER IMMEDIATE ASSOCIATED RISK.
- Immediately next to the Sydney West electricity site, lie the two water supply pipelines (both different diameters) which serve greater Sydney with at least 70% of its water supply. What would happen if the pipelines up hill from Sydney West Electricity were breached? Surely this would compromise Sydney West by the resultant rush of water from the breached lines? What would happen if the electricity hub were taken out, would that affect the pipeline itself? Could either of these facilities individually, or together, also affect the high pressure gas line as well?
- Within 2.5 kilometres of these noted infrastructures are the Great Western Highway, and the M4. These are Sydney's only major Western "escape" roads.
- The proposed airport would also fly aircraft at low levels over the Moomba Sydney Gas line (also very close to the proposed site itself) and Prospect Reservoir (and it's chlorine holdings, and our new French water filter).
In short, this corridor essentially represents the entire backbone of Sydney's critical infrastructure. It is entirely conceivable that over a long period of airport operational time, one aircraft could well impact into this area, possibly taking out all of the above noted services in one go. If one compares impact areas of overseas aircraft accidents, one can see that this area (corridor) in relation to an airport has often been impacted. Likewise, the area of damage caused by impact is seen to be large enough in many instances, to show that all of these services could be damaged by one crash.
Nothing could cripple Sydney more than to remove its electricity supply, water supply, gas supply and Western
escape roads, either individually, or all in one turn.
- Remember, an airport is a facility that is long term, and constantly growing, as are all of it's operations.
If these facilities were to be "taken out in one hit", almost 1/5 of Australia's population (Sydney) could be "locked in" to a catastrophic environment, given that major escape roads to the North and South and West of Sydney would undoubtedly lock up with traffic congestion due to panic. (Just as the writers Grandfather once said could happen - about 1966)
- F.R.A.A.N. notes that the South West alignment of the proposed option A and B runways (and the cross runway option C) indicates concentrated flight paths over Warragamba Dam as well, including it's associated major chlorine holdings.
These risks cannot be allowed.
It is inconceivable that a proper and honest EIS could omit to address impact to infrastructures' of such immense importance.
Nb; FRAAN notes that there is an often put argument that this risk would only be "one in a million", or that "there are petro-chemical works at Kurnell in line with KSA". We regard this as an extremely poor argument since poor planning from the past does not justify repetition of any kind today, or at any time in the future. We also point out that each week, several people within Australia win a big lottery. Professionals in other trades, such as Powder men, would never dare fire any explosive charge if they thought that there was any chance of extreme danger, be it one in a million, or even one in ten million for that matter. Politicians carry an even greater responsibility.
Please note the colour plates included over the next two pages.
1) The water service supply pipelines between Warragamba and Prospect Reservoir. (Please note Sydney West Electricity in the background)
2) The Chloramination Plant and holdings at Warragamba Dam itself.
Chlorine and Ammonia = Chloramination
- This first of the last two photos shows the two supply pipelines as they cross underneath Wallgrove Road, at Horsley Park. You will note that in the background is the Sydney West Electricity Supply Station, which is virtually next to the pipelines themselves.
- We are advised by Sydney Water that destruction of any part of the line, leading to breach will take a minimum of 3 - 6 months to repair/replace due to the need to manufacture new replacement pipeline, before even being able to fit and replace on site. Sydney water advise us that they have virtually no spare pipeline in stock.
- Sydney would find itself in dire straights in this event, since it would have to rely on the upper canal from the Nepean Dam to supply its water, and this canal is totally insufficient to meet our needs, particularly if this should occur in a hot summer period. It is also open to air over a long distance (Cataract to Prospect) making it unreliable from a pollution stand point.
- The next photo shows the water filter plant at Warragamba Dam itself. This supplies water to the local region only, but it must also be noted that there is also a local supply Chloramination plant included at the site. This is where chlorine, and ammonia, are added to the local water supply. Impact with a plant of this nature has the potential to release a chlorine gas cloud of fatal consequence to a large area of the local region.
There are other local supply Chlorination plants at;
- Orchard Hills
- Lower Blue Mountains
- North Richmond
None of these have been identified in the EIS, or the effect of their primary loss, or secondary risk impact.
Please note the next three colour plates.
The first is of the major chlorine addition plant, at Warragamba, on Silverdale Road, down line from the dam itself. This is where chlorine is added direct to the pipelines themselves.
- Major stores of Chlorine can be stored there, including gaseous forms. This has the potential, (if breached) to send a chlorine gas cloud down river, with potential fatal results to the Penrith and surrounding area.
The second, is part of the Chlorination plant to the major Sydney water supply at Prospect Reservoir.
- Major stores of Chlorine and Ammonia are stored here, with the potential for horrendous secondary impacts if breached.
- This facility also hosts the new French water filter, along with massive pump stations.
- The reservoir itself, even after load strengthening work to the weak retaining wall has the potential to easily breach in the event of impact, leading to a major catastrophe for Sydney and its water supply. (Pumping points, filter plant, and chlorine/ammonia holdings would probably be destroyed in the event of breach of the Prospect Reservoir.)
The third colour plate, is of the Moomba-Sydney high pressure gas line.
- This line is not buried far beneath the surface, about 1.5 metres.
- We have seen a number of high pressure gas line breaches in the past few years, in various countries, each time with spectacular and sometimes horrendous results. The October 1998 loss
of gas supply to Victoria is a graphic but mild example of what can happen.
- The gas line is directly in flight path of the proposed airport, all options but particularly options A & B, and within the noted high risk crash area.
- It should be noted that this pipeline traverses through a large area of 'Pn Picton, mass movement land slip soil', and that AGL overfly the pipeline by helicopter every several days, particularly after a period of heavy rainfall when the soil is most likely to slip. Could the heavy vibration from a constant, long term overflight of low flying jet aircraft cause this soil to slip after a heavy wetting? Who knows - no comment in the EIS.
There is no notification of the primary, or secondary repercussions in the event of breach of any of these items, in the EIS.
HAZARD and RISK and WATER.
The EIS technical paper on "Geology, Soils and Water" (book 7), indicates that there would be extreme problems with this airport, and our water supply. It tells us that these waters are classified "Class S." - "Class S waters are specially protected waters under the clean waters act 1970 which prohibits the discharge of any waste into these waters" (Pg 4-8).
- Page 4-1 indicates that; "Class S waters (which include water supply reservoirs) do not permit any discharges.."
It tells us that; "the constituents of aircraft fuel are petroleum derived and are light weight and insoluble in water." (Pg 7-15) "This would ensure that any dumped fuel reaching the surface would stay on the surface of water bodies such as Lake Burragorang."(Pg 7-14)
It tells us that; "crashes into storage waters or catchments would have the potential to affect raw water quality, particularly if near offtake points. Sydney water has the ability to adjust vertical offtake level, and could control floating material such as fuel, by booms. It does not have the facilities for treating or removing fuel spills. The water filtration plants drawing water from these reservoirs do not have processes for fuel removal."
The EIS also states that this problem can be overcome by drawing water from lower in the holding - however, there is a serious problem with this, apart from the myriad of environmental problems caused by fuel contamination:-
- FRAAN is advised that water at the Dam wall is known to move from 3 - 30 units of turbidity
when it rains. To quote Sydney Water on site staff; "if you fall in the water at the wall, you will never come up - you will just go round and round." Therefore fuel at the top may well be deep cycled as well - down to the offtake point.
Pages 10-1, and 10-2 indicate that "toxicants and contaminates" would have a major potential influence, which may lead to "acute and chronic toxicity with a potential for bio-accumulation." In other words, store in our bodies and slowly accumulate. It also says that the significance of residual impact would be: "Local impact but potential for residual regional impacts".
Of course, aircraft pilots do not intentionally dump fuel if they can help it, but aircraft can accidentally dump, or vent fuel when pressure in the fuel tanks (for example) forces pressure valves open to relieve the pressure, or when the vents simply fail. Other things happen to aircraft as well, apart from the fact that their routine jet exhaust is enormously polluting anyway.
Most International Pilots using an airport at the proposed site would probably have no idea what-so -ever, just what the large body of water below was, and just how important it really is to the population of Sydney; almost a quarter of Australia's population. Peter Skinner, then President of the Australian Pilots Association, said at a meeting at Mount Pritchard Community Club one night, (minutes available) that if he were to find his aircraft in crash situation he would probably naturally aim at the Lake, as a soft landing, to try and save the lives of his charge - his passengers. And he lives in Sydney! An "out of towner" pilot would hardly be expected to do anything different. A modern 747 jet liner can carry over 200,000 litres of aviation kerosene in its tanks.
At a meeting with the Member for Chifley, at Blacktown one night, an unidentified chap hopped up and informed us all that one (1) litre of Aviation Kerosene was sufficient to completely cover Prospect Reservoir. We have no reason to disbelieve him, since it only takes 2 or 3 drops of kero into a cows drinking trough to kill all mosquito larvae. The kero must then be removed (skimmed) for the health of the beast.
The EIS does not say a word about what would happen to the fish within the water supply, especially stocked, and absolutely necessary to keep the water fresh and viable, but the answer is obvious.
- If the insects die, the fish will die - in the water we drink.
- Oil also prevents oxygen from entering water, and can lead to "dead water".
The EIS also tells us that: "Damage to the sewage system could occur if a plane crashed into a sewage treatment plant, or above ground sewer such as the South Western Suburbs Ocean Outfall Sewer (SWSOOS). In either case, large volumes of untreated sewage would discharge to local water ways, and possibly surcharge through domestic fittings. Damage to the sewage system would be expected to have environmental impacts as well as potential human health implications." (Page 6-14)
It indicates that: "There is insufficient data available to identify specific impacts to groundwater due to construction." (Pg 7-6)
(PPK seem to have a considerable problem with "insufficient data" throughout the entire EIS!)
As a side note to the topic of water, the same page indicates: "food consumption" concerns from aerial "pollution, effluent discharges" with the "potential influence" of "pathogens and contaminants" are "not able to be quantified", likewise significance of residual impact is "not able to be quantified."
The EIS also indicates on page 7-13, that "The potential risk to domestic rainwater tanks was also not able to be fully quantified." "It is recommended that further data be collected and modelling undertaken into the transfer of particulate emissions into water tanks to assess the relative importance of aircraft emissions."
The conclusion of the section "water quality impacts predicted for Badgerys Creek options " (Pg 10-4) makes interesting reading, particularly if you are a proponent of the airport;-
- removal of stream habitat;
- potential regional impacts from sediment releases;
- local ecological impacts from reduced stream variability;
- regional impacts from effluent discharges, particularly from nutrient addition;
- potential human health impacts from effluent discharges, aerial fall-out into rainwater tanks;
- potential regional impacts from increased salinity; and
- potential regional impacts for recreation, fishing and agricultural uses.
Unfortunately this has not been shown in the main reports, or the summary, and these are the documents that politicians would read to base their decision on. Like-wise generally speaking, the public, and local businesses, do not have access to this information either.
FRAAN is sure that there are more than a few farmers who would be interested to know that the proposed airport has "potential regional impacts for......agricultural uses."
Studies in the U.S. by the Illinois EPA, has shown that O'Hare airport is a major polluter into local creeks emptying into the Des Planes river, thereby polluting the river itself .
- Of course, it is unlikely that O'Hare has the cities drinking water supply next to the airport site itself, as Badgerys Creek airport proponents are contemplating.
- If there is a disaster where we need a back up reserve of fresh food (there are immense volumes of fish in the dam - don't forget, the dam holds almost 4 times the volume of water as Sydney Harbour), - Lake Burragorang is our refrigerator - but what happens if the disaster is the Dam and/or the Lake itself ?
Please refer to the next two colour plates.
- The first is of a typical warning sign in the large region surrounding the Lake Burragorang.
- Please note that the lake has 9,000 square kilometres of direct catchment. In other words, what lands on the ground goes directly into the lake.
- The second plate is of a roadside water standpipe.
- There are a number of these west of Kemps Creek because local residents rely on roof water catchments for their drinking water supply and use these standpipes for back up water supply.
- Unfortunately the EIS is unable to say what the effect will be on these families water supply, rather it indicates that more studies must be conducted before an answer is given. Given that people who live near other airports around the world report dark residues on their window sills and outdoor furniture, that eventually stains them permanently, F.R.A.A.N. feels that once again, the answer is obvious.
METEOROLOGY - Wind Shear and Hazard.
"FOG AND WIND"
Hospitals are built for patients and doctors. Without them there would be no point in building hospitals.
An airport is built for aircraft and pilots.
In the 1995 Senate Select Committee report ( "Falling on Deaf Ears" ) pg 323, the Australian International Pilots Association suggested that Badgerys Creek was not suitable on two grounds;
- Fog. "..The incidence of fog there is significant..."
PROBLEM. - The EIS Vol 3, pg 10-3, used data collected from 9am and 3pm only. It does note however that "fog occurs most frequently before or around sunrise", and most locals will tell you that fog is very common, between 9pm and 9am, and usually less than 100 - 200 metres visibility. The EIS vol 3, pg 10-3 states "... the minimum landing standards for runways equipped with an instrument landing system is about 800 metres visibility.....minimum take-off standard is about 500 metres visibility."
Therefore the EIS summary document pg 27 statement that ".....it is unlikely that airport operations will be affected significantly by fog" - is demonstrated to be clearly and absolutely wrong.
- Wind Shear. "Falling on Deaf Ears" (regarding wind shear from wind blowing over the nearby Blue Mountains) Pg 324 states; "..it is effectively like water crashing over a reef - and there are significant down vectors that come out of that turbulence". ie - Winds coming over the mountains forming an area of dangerous turbulence on the proposed airport side of the mountains and over the mountains themselves. (it should be noted that wind shear is the major cause of aircraft crash in the world)
The 1995 "Falling on Deaf Ears" report pg E25 recommended that "...long term wind data be compiled and published immediately.."
The EIS Main Report 1, pg 14-9 noted that; "wind shear and mechanical turbulence affect aircraft of all sizes and are not able to be measured or predicted as readily as other phenomena, without additional observational data and study" also; "many of the conclusions reported need to be reviewed and validated when site specific data are obtained."
- Will we collect this data from Black Box flight recorders from crashed aircraft then?
PROBLEM. - The just released EIS Auditors (SMEC) 1999 report pg 29 states; "No data on the vertical structure or profile of the atmosphere in the vicinity of the airport and surrounds was collected. Given the time that has elapsed since the commencement of the Draft EIS the omission of this KEY DATA is disappointing." (Our emphasis.)
$12 million of taxpayers money has been spent on an EIS that has not even determined whether or not it is safe for a PILOT to fly an AIRCRAFT out of an AIRPORT at Badgerys Creek! Who is pulling whose leg?
Please note too, that if an aircraft were to experience wind shear problems, this could lead them into crash situations into the nearby Warragamba Dam or its 9,000 sq km direct catchment area, the Orchard Hills Military Munitions Holdings facility, or the small zone North East of the site, that encompasses our water supply pipelines, gas supply pipelines and NSW electricity hub. (high risk crash zone-EIS vol 3, pg 16-9) Lack of this data has serious implications for operations at Sydney airport too.
In total, this must be sufficient reason to say that the EIS clearly prohibits the construction of an airport at Badgerys Creek.
The EIS main report, pg 14-7 also notes that; "the proximity of Badgerys Creek to the Great Dividing Range would only give a short lead time for thunderstorm warnings associated with thunderstorm cells generated over the range", and then, even though PPK admit to a lack of general meteorological data; "higher storm probability areas are located to the east of Badgerys Creek" and that the proposed site area is less affected than areas to the west of the ranges.
- This is like being asked if we want to fall from a 10 story building, or a 12 story building, since no matter what option, aircraft must fly through all of these areas.
- From the writers' long term local perspective (who lives to the east of Badgerys), the area south west of Horsley Park seems far more prone to lightning strike than from any other direction, and my family has always called storms marching across the plains from the mountains "Black Panthers".
The belief and reasoning behind such high electrical activity to our south west is that this is attributable to a geological dyke of iron laden basalt beneath the proposed airport site.
Certainly, we have considerable home movie film footage of intense storm activity in that area. As an ex-rock driller there is certainly no way that I would put a steel drill rod down into the ground, in the Badgerys area of the world during a storm. In recent history, a member of the "hoof beats" horse riding club lost two horses in one electrical storm due to lightning strike - She lived on Victor Ave, Kemps Creek, next to the proposed airport site.
We would remind that in either case, even if the EIS were to be correct with the storms being to the east of the proposed site, aircraft must unavoidably fly very low through this zone, thus through this EIS noted area of storms, over high ground laced with power lines on ridge tops etc etc.
We would point out that although there has been good rain this past summer, there have been many spectacular electrical storms in the Sydney area, but particularly to the west/south west of the Horsley Park/Mt. Vernon escarpment. Storms seem to be at least as prevalent, if not far more, during dry summer periods.
This is 1999 - the airport was first presented proper, in 1985, and seriously investigated in 1975. There has been ample time to gather this critical data, particularly for vertical profiling and storm and fog activity, if one was serious about genuinely operating a safe airport from this proposed site.
F.R.A.A.N. questioned this meteorological lack, particularly of wind shear, of Mr. Mark Keogh, EIS project manager at PPK, at an EIS briefing meeting in February, 1998. He could not supply any effective response except a shrug of the shoulders.
We put the question again;- how can one possibly view this EIS as reliable, or think to proceed with an airport, when the very concern that the most important operators from an airport, namely the pilots themselves, has been not addressed?
FRAAN feels that we could pre-empt the findings of a study on the incidence of windshear, on the basis that pilots are very highly trained, and must be by nature observant and careful people. If they have identified a major wind shear problem scenario from a proposed Badgerys Creek Airport, then it is probably there.
An airport must be able to operate entirely safely for it to be a success; this proposed airport is everything but safe, as is the EIS and the process itself.
If we were not building this airport for aircraft and pilots, then who were we building it for?
LONG BORE SHOOTING RANGE - PARLIAMENTARY QUESTION IGNORED.
The following three plates relate to a long bore shooting range, located on Silverdale Road, Silverdale. They are an excerpt from the 1992 Parliamentary Standing Committee on Public Works, and a photo of the entrance road sign.
1) Front cover of the 1992 Parliamentary Standing Committee on Public Works - Minutes of Evidence Volume 3.
2) Page 794 of the minutes of evidence, Parliamentary Standing Committee on Public Works
3) Photo of the entrance road and sign into the Long Bore Shooting range.
F.R.A.A.N. understands that it is permissible to discharge any calibre firearm at this approx. 60 acre (27ha) Silverdale range. We could not obtain photos of the inside of the range, but there are many "pock" marks along the top edge of the firing range, indicating that stray bullets do sometimes clear the firing range, into the air. We also note that there is very serious local conjecture that a helicopter which crashed into Lake Burragorang in 1996, killing it's pilot, may well have been disabled by a bullet, quite possibly from this very facility. We believe that the surviving co-pilot reported that the helicopter just "suddenly stopped". The aircraft has not been recovered to confirm the cause of the crash.
Referring to the second of the three plates that we have included, Mr Taylor was correct.
We point out that this facility, including the reference to it in the "Parliamentary Standing Committee on Public Works" "Minutes of Evidence", was put to PPK on a number of occasions, both written and orally by FRAAN. We also point out that the EIS guidelines included a requirement to incorporate the 1992 report in the EIS.
There is no mention of it, in the EIS, nor in the supplement.
The technical paper on Hazard and Risk, does however indicate that the military firing range at Orchard Hills, much further away from Badgerys Creek and more in line with option C, would have to be relocated to Holsworthy or elsewhere. This being the case, why is there no mention of the other shooting ranges in line with either option A or B?
We wish also to point out that there is more than one shooting range near the proposed airport; the one above noted at Silverdale; the Hibertus indoor range at Luddenham (already relocated once from the original site, and will be reacquired for option B or C); and a skeet shooting range (shotgun) at Kemps Creek which is undergoing a multi million dollar upgrade for the 2000 Olympic games. It is very close to the proposed airport site, and presumably would be unable to function after operations at a proposed Badgerys Creek Airport commenced.
This would also represent a serious waste of taxpayers money.
Again, there is no comment in the EIS.
NO SMALL AIRPORT.
We feel that it is also worth noting that the 1992 Standing Works Joint Committee report (22nd Sept 1992 pgs 582, and 584 to 586) also clearly indicates that there is no need for a small general purposes airport in Sydney, such as the option first proposed. We wonder therefore, why it is that there is now an insistence on building a small airport at the site since it is clearly not required, and which would represent expenditure of an enormous sum of taxpayers money for an airport that no-one wants apart from local business beneficiaries.
F.R.A.A.N. WISHES IT TO BE NOTED and ENACTED UPON :
Re: Air space safety, restricted air space.
REGARDLESS OF ANY IMPENDING DECISION TO CONSTRUCT AN AIRPORT AT BADGERYS CREEK.
Please refer to the current Airservices Australia Sydney air space management maps, (or "Visual Terminal Chart" - please see next colour plate) flight zones R536A and R536B, and R521. These are restricted air spaces over the Orchard Hills munitions holdings, and Lucas Heights Atomic reactor, respectively. Aircraft may not fly over these sites at low level, as obviously they should not, because of the extreme danger that these particular sites exhibit in relation to their widespread impact or danger to the rest of Sydney.
It has come to our attention that there is no restriction placed on overflight of;
1) - Warragamba Dam Wall (and it's local chlorine/ammonia holdings)
2) - Prospect Reservoir and it's attendant massive chlorine and ammonia holdings.
3) - The Sydney West Electricity substation at Horsley Park, which effectively supplies the bulk of electricity service not only to Sydney, but likewise to greater NSW (also the direct surrounding area is in combination with the Moomba-Sydney Gas line and water service pipelines)
4) - The Kemps Creek electricity substation.
Given the clear precedents set by air space safety zoning over Lucas Heights and Orchard Hills, we find it inconceivable to see that ordinary aircraft are allowed to fly at low levels over other such critically important elements of our infrastructure, as above noted. Damage to any of these facilities has the plain potential to create devastating volumes of damage and harm to greater Sydney, or even the entire of New South Wales.
For the general safety of all of Sydney, the implementation of restricted flight zones over the above noted three areas is an immediate and urgent matter.
We point out that there are many small aircraft which also fly over these facilities, often low "too have a look", sometimes even to use as visual reference points to practice stunts over.
We also note that there is airspace map provision for identifying air space where model aircraft are flown at a height of greater than 300ft (there is an area noted immediately north of the M4 and south of the Great Western Highway, near Penrith). - There is however no current airspace notification of such a risk area at the "Sydney Society of Model Engineers" model operations site on Luddenham Road, Badgerys Creek. This is very near to the proposed Badgerys Creek airport site. Members of the society and guests, are known to often fly model aircraft at considerable heights, from this model operations site.
Again, all of the above danger areas have often been put to PPK by F.R.A.A.N., in order to facilitate a full consideration of the possible and potential impacts of an airport at Badgerys Creek. Amazingly somehow, all have been omitted from consideration in the EIS.
Please refer to the next colour plate:
It is an excerpt from the current Sydney airspace management map. (Please note the red circle height restricted zones over Lucas Heights Atomic reactor, and Orchard Hills Munitions holdings.)
AIR SPACE MANAGEMENT/FLIGHT PATHS.
Please refer to the "flight track" colour plates on the next two pages; the 18th and 19th March, 1998, supplied by the FAC, indicating jet aircraft and others, mostly from KSA.
They are of two full day operations of aircraft over Sydney, although only of aircraft fitted and operating with secondary radar transponders.
- Bankstown Airport for instance is the busiest in Australia, and the fifth busiest in the world in aircraft movement terms, and yet most of the aircraft using it do not leave a flight track. (See the faint maroon tracks underneath the major green and red tracks from KSA)
The EIS has not considered or reported on the interaction with other airports in the Sydney Basin. FRAAN feels that this is an inexcusable lack, for an EIS that is supposed to help all to decide whether or not an airport at Badgerys Creek is genuinely viable, or safe in operation.
FRAAN feels that no matter who or how reported, one look at these flight track maps, clearly indicates that the "long term operating plan" currently in use at KSA, or the "share the noise" program of directing aircraft in multiple flight tracks over Sydney cannot be sustained, if an airport were to be built at Badgerys Creek.
We feel that return to the "Bennelong Funnel" or parallel track nature of operation from KSA must be an unavoidable result of an airport at Badgerys Creek, particularly from option A or option B. Please inform Mr. Hockey, member for North Sydney and proponent for an airport at Badgerys Creek, as well as the Councils' north and south of KSA who complain so vociferously about aircraft noise, and worked so hard to obtain the long term operating plan, to direct noise away from them. Prime Minister Howard and Brendan Nelson should also be highly concerned by this as well.
We also feel that the flight tracks indicated in the EIS and its supplement are unreasonable or possibly even unworkable, particularly given the 'obstacle limitation surface plan' showing that essentially all aircraft would have to fly to the east of the site over Sydney. We feel that further, a "Western Sydney Funnel" would also be created as well. Moreover, we note that there would also be a necessary lowering of aircraft operating heights, due to criss crossing of flight paths from aircraft operating from a combination of (proposed) Badgerys Creek, Hoxton Park, Bankstown and Kingsford Smith airports. (See vol 3, chapter 20) . This would lead to insufferable low flight aircraft noise over almost all of Sydney, along with considerable airspace risk - over the heads of some four and a half million Australians.
Please refer to the next two colour plates.
1) Sydney aircraft flight tracks from 18th March, 1998.
2) Sydney aircraft flight tracks from 19th March, 1998.
(Please note, that Bankstown airport operations can also be seen [although faint] but note too, that it is the busiest airport in Australia in operational numbers. Most of its aircraft operations are not seen on flight track maps)
INTERACTION WITH OTHER AIRPORTS.
It would seem a remarkable thing for any person or company to investigate the viability of an airport site proposal without addressing it's impact on interaction with other airports and flightpaths, and yet that is essentially what we are presented with, in the draft EIS. After considerable criticism, it has been addressed in the supplement, although not in any detail, and still with total disregard for Bankstown airport and other airports in the Sydney region.
If the reader would view the flight track maps we have presented in this submission on pages 51 and 52, and see how wide spread KSA flightpaths are, we feel you will see the obvious and necessary need to address interaction with other airports, if this EIS were to be valid in any way.
Chapter 20 of the vol 3 supplement goes into some detail of runway configurations, and notes absolutely clearly, how unsuitable option A or option B is in regard to their flightpath interference with Kingsford Smith Airport, and the other Sydney airports.
"The Push for Option A"
The Fairfield Champion (Aug 11) ran an editorial article, on the front page of the paper, indicating that only 750 people attended a rally at the Club Marconi and that Fairfield therefore wanted this airport. This is in fact spurious nonsense, and serious misinformation. There were at least 1,500 persons who attended the rally, and we note that once the auditorium was filled, the doors were closed and no other persons allowed to enter. We are aware that in fact there were a number of persons who have since complained that they were unable to get into the meeting and so went home.
In an article in the Sydney Morning Herald, Friday 13th August, transport writer Mr R. Wainright has noted that: "Mr Anderson is expected to take Options A and B from the EIS document to the Cabinet......An industry source said: "The penny doesn't seem to have dropped yet that failure to build Badgerys Creek means that, within five years, the blue-ribbon electorates of Warringah, MacKellar and Wentworth will have a massive increase in noise from heavy jet movement.""
In fact the EIS vol 3 pg 20- 4 says:
"In the case of Badgerys Creek options A or B, the extended centre lines of the parallel runways to the north-east of the airport cross the northern extended centre lines of the parallel runways at Sydney Airport in the vicinity of Hornsby. Whilst air traffic management procedures would be devised to separate air traffic for each airport as much as possible, there would still be a need for many flight paths to merge or cross. This would result in the need for complex procedures to be provided in order to segregate the aircraft from each airport, although this might not be conducive to the provision of the smooth flow of air traffic.
Under option C, the number of potential coflictions would be reduced greatly because the Badgerys Creek aircraft would be operating to and from parallel runways that are in turn almost parallel with those at Sydney Airport. The traffic patterns would probably always be in the same direction, leading to a harmonius flow of air traffic."
- Regarding operations at Sydney airport the EIS says "Such as scenario would also require the lowest aircraft to maintain an altitude of about 3,000 feet (914 metres) over built up areas to the north-west of Sydney until established in the centre line and on final approach at about 10 - 12 nautical miles (about 18 - 22 km) from the runway threshold."
The reader should also note that the obstacle limitation surface plans provided in the EIS "Planning and Design Summary Report" fig 2.2 and 2.7 (option A and B) show that the mountains behind the Badgerys site are too high to clear. Therefore virtually all aircraft using Badgerys Creek option A or B would have no choice other than to fly in and out of the Badgerys site (at the very back of the Sydney basin) to the north east - over the Sydney population. It should also be noted that the EIS does not include data for flight path interference with Bankstown airport (5th busiest in the world in terms of aircraft movement) which is on a different runway alignment again to both Badgerys and KSA.
The EIS section 20.3.3 discusses multi airport environments overseas, and notes that New York and London have airports which have parallel runways to each other. When Tullamarine airport was developed in Melbourne the runways were aligned in similar directions.
Why then would anyone consider to build an airport at Badgerys Creek on the option A or B alignment?
FRAAN feels that this airspace interference problem from what is now "option A" must surely have been known in 1985. Our question then is: why did the ALP government proceed to acquire land for an airport on this alignment when it was clearly known that an airport on this alignment would not work in relation to other Sydney airports, as is shown by other airport design precedents from around the world?
In response to Mr Wainrights "industry source" we retort that Blind Freddy can see that if an airport were to be built at Badgerys Creek particularly option A or B, then the long term operating plan currently in use at KSA will have to be abandoned as is, and that KSA airport return to it's earlier narrow northern approach and departure modes. This will mean that the blue ribbon electorates of Warringah, Mackellar and Wentworth will in fact become black ribbon seats of intense aircraft noise impacts, if Badgerys is built. The liberal seat of Parramatta would also be noise devastated, as would the seat of Mitchell, and probably Bradfield and Bennelong. (See maps chapter 20, EIS supplement book 3) FRAAN has calculated that in fact a minimum of 8 Federal Liberal electorates will be noise devastated, directly or indirectly, by Badgerys Creek option A or B.
In fact the only real advantage to option A or B at Badgerys Creek (particularly option A) is that these are the only options that would not destroy the private extra-ordinarily high density urban-industrial ghetto city planned to be built north and south of the Badgerys site. (See EIS supplement vol 3, chapter 7) The reader should also recall the Labor State Government Gazette 156 "Growth Centre Gazette" secretly published 22nd December, the Friday before Christmas Monday 1995, which essentially gazettes all available land north and south of the proposed site, to come under the control of a "Development Corporation" (currently "in limbo", and presumably re-activated if an airport were to be given the 'green light'.)
At a meeting (held within the Liverpool Council building 22 May, 1997) with the South West Sydney Regional Development Organisation, Chairman Mr Roy Medich (a major landholder near Badgerys) clearly indicated that he and the organisation would accept only option A. We are aware that this is also the position of the Greater Western Sydney Economic Development Board who are also very much pro Badgerys and represent major local landholders or business "beneficiaries".
It is poor that the EIS summary does not show any of the earlier noted maps and thus properly show the genuine impacts and problems associated with this proposal. FRAAN feels that this lack of basic critical information within the widely distributed EIS summary is a deliberate attempt to mislead the general public, and politicians, as to the real impacts of this proposed airport, in order to push the case for the procedure of this proposed airport and it's associated developments.
The EIS supplement clearly shows its own particular favouritism of Options A and B. As an example volume 3 section 7.3.2 shows "Land Use Influences of Option A and B". It does not include any component of option C land use influences, even though this is clearly the alignment of runway which would have least impact on greater Sydney, critical service infrastructure overflight, water supply overflight, or major interference with operations from other Sydney airports.
Perhaps this airport proposal would be better named the "Collins Class Submarine" airport proposal