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F.R.A.A.N. Submission Continued - Part 2


Alias; - "The removal of the top of the Blue Mountains".

The next four pages are taken directly from the "Planning and Design Summary Report" by Airplan and the Department of Transport.

- We note that there is a serious penetration into the Obstacle Limitation Surface, at the Blue Mountains escarpment, next to the Warragamba Dam/Lake Burragorang.

- We note too, that PPK supplied flightpath maps for all options indicate concentrated flightpaths' over Warragamba Dam, and the noted area.

- The reader will also note that there is a need, indicated by the second airport planners, to "avoid hills or other obstructions", with an implication to remove them. Proof of this is shown on the next page.

- It is impossible to operate from this proposed site without flying over this area. From the point of view of the obstacle limitation surface plans, it also appears impossible to fly over this area. Hmm.

- When FRAAN was formulating it's EIS guidelines submission, we asked Pilot Peter Skinner, then President of the Australian International Pilots Association for his assistance, which he happily granted. At the meeting with Mr Skinner, he was asked whether or not, in a circumstance of a fully loaded aircraft, with full fuel load and at a temperature greater than 29 degrees Celsius, whether or not he would be able to safely clear the obstacle of the mountains. After considerable calculation, he was unable to answer in the positive.


Nb. We also note the page of the report (pg 6-14) indicating that "it is not possible to prepare 'final' flight paths for the second airport."

With this in mind, please recall this fact when viewing the tan areas shown in the EIS 70Db contour maps shown in the "Noise" section of this submission. (There is a red line surrounding ½ million people at least - who are omitted from the statistical base of the EIS.)

Please refer to the next 5 plates. They are;

1) page 6-14 of the Second Sydney Planning and Design Report.

2) Obstacle limitation surface plan for option A.

3) Obstacle limitation surface plan for option B

4) Obstacle limitation surface plan for option C.

5) Flight path interference map- Option B. (Supplement vol 3, fig 20.3)


The "Standing Works Committee On Public Works" - "State infrastructure Requirements for Sydney West Airport" Report states on page 317 under the title "Waste Disposal from the SWA Site.": - "The committees efforts to investigate waste disposal were hampered by the lack of clear strategies at this stage of the airports design....The 1985 EIS included minimal information about waste disposal."

On page 318 it notes; "Quarantine Waste is waste discharged from aircraft and shipping whose port of origin is outside Australia and which has the potential to spread undesirable pests to Australian agriculture." (Surely people as well!) "The Australian Quarantine Inspection Service (AQIS) is charged with the surveillance of waste management practices to ensure that the handling and disposal of such waste is undertaken in a safe and efficient manner." "The only incineration facility for quarantine waste in Sydney is the Waterloo incinerator which is operated by Waverley and Woollahra Councils under a joint agreement."

- This leads to a remarkable problem with the EIS, and the process itself.

- The Waverley high temperature incinerator has been closed down for a number of years now. There is no other to use.

This new EIS has noted in the Main Report, book 1 page 18-5, on the topic of quarantine waste; - "Quarantine wastes would be sterilised to permit co-disposal with general non-quarantine waste in an off site landfill."

- This EIS does not mention just HOW or where the waste would be sterilised, or which off site landfill, so the method indicated in the EIS, appears to fall a long way short of a desirable method of disposal.

Please note - New Scientist Magazine, May 17, 1997 indicates that sewage carried by aeroplanes is spreading viruses worldwide, according to a study conducted by a Mr Mark Sobsey, an environmental scientist at the University of North Carolina in Chapel Hill, and colleagues.

According to New Scientist, the North Carolina team tested 40 samples of sewage pumped from international flights landing at two major American airports. Among the 40 samples, 19 contained viruses that had survived exposure to disinfectant chemicals in the planes' sewage tanks.

The study was sponsored by the World Health Organisation and the U.S. Centres for Disease Control and Prevention. The sponsor asked that the researchers search the sewage for enteroviruses, in particular the polio virus.

The researchers found no sign of the polio virus, but did find a number of enteroviruses. To quote Mr Sobsey "The range of diseases that can be transmitted by the worlds airlines can be quite worrisome. We think there are probably bacteria and parasites as well."

He noted that conventional sewage treatment often eradicated 90% of viruses, while the remaining ten percent survive. "Alien viruses could be released into a country where they are not usually found."

FRAAN understands that waste from KSA is currently taken via ordinary truck, through dense residential areas, and deposited at the Castlereigh landfill. We feel that this is already an extremely dangerous and risky practise, and a volatile situation which must cease as soon as possible.

FRAAN would suggest that the method of disposal of quarantine waste, for any airport in Australia, should be absolutely failsafe. The method described in the EIS does not indicate any guarantee of this.


We note that there is provision in current Airservices Australia airspace management maps (or "Visual Terminal Chart" - see page 49) for identifying areas 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 no notification of such a risk area at the Luddenham Road "Sydney Society of Model Engineers" model operations site very near to the proposed Badgerys Creek airport site. Members of the society and guests, often fly model aircraft at considerable heights from this site.

PPK have been advised of this facility and it's operations, by FRAAN - there is no investigation of impacts from it, or to it, in the EIS and this problem is omitted in the supplement as well.

This facility is used by many people, to operate a wide variety of different types of model, including model aircraft, and ground and water based models.

Many of the models used are controlled by powerful radio transmitters, and there may be many different models operating at one given time, over and across the area of the facility.

Recent reports indicate that the new "fly by wire" control operations of a modern aircraft, can be seriously affected by radio activity from laptop computers, hand held games and mobile telephones etc.(for further information see Sydney Morning Herald, Fri Jan 16, 1998) It stands to reason that a facility of this nature, so very close to the proposed airport site, may well have a major bearing on the safe operations of low flying aircraft overhead, and of the airport operations itself.

There is no investigation or comment on or of this in the EIS, even though specifically asked for by FRAAN.

It is a well used recreational facility, and it appears obvious that at such close proximity to the proposed airport, (it is virtually across the road) may well be rendered unuseable - if so, at what cost?

It has some expensive on site infrastructure such as ; large and elaborate small gauge rail lines for operations of miniature steam trains (very powerful, they tow a passenger load of over 20 people), site sheds, tether car rink for very high speed petrol engine mini cars, man made water lake/canal for radio control boats and submarines etc.

The facility has a public open day on the last Sunday of every month. Models are also operated there on most weekends, and sometimes weekdays.

FRAAN recommends that the reader take along a picnic lunch (or buy from a very well equipped on site shop), a good pair of stout shoes (it's a big site) and the kids, and enjoy a very different and unusual day of recreation. It is not an expensive day out either.

Please refer to the colour plate on the next page. This is;

- The gateway into the Sydney Society of Model Engineers site, Luddenham Road.

Other recreational facilities.

There has been no real investigation into the affect on recreational facilities, near and surrounding the airport in the EIS and yet this area is a regarded as western Sydney's "Playground" .

There is no investigation into impacts on these facilities in the EIS, or the EIS supplement.

The State Government has now re-zoned what was originally the land acquired for the "Green Belt" as a recreation zone.

This plays host to;

- The Eastern Creek Raceway.

- The Olympic equestrian centre (currently under construction)

- Fairfield City Farm.

- Olympic cycle track

- The Western Sydney regional park

Other recreational facilities in the same area are;

- Wonderland - Walgrove Road, Horsley Park - incorporating "Australia Park"

- Greater Union Drive in Theatre - off Reservoir Rd., Prospect.

- Nurragingy Reserve - Doonside

- Featherdale Wildlife Park - Doonside

- Prospect Reservoir recreational parks - (eg Andrew Campbell Reserve)

Other recreational facilities surrounding the site are;

- Blaxland Crossing Reserve at Wallacia - Various reserves and parks along Nepean River.

- Bents Basin - off Silverdale Road - Nortons Basin - off Silverdale Road

- The Nepean River itself. - Warragamba Dam recreational reserves and parks.

- Tara Girl Guides facility at Silverdale. - numerous horse riding clubs

- A number of golf courses - 3 shooting clubs

- Sydney Society of Model Engineers - Model Park.- Luddenham Road

- El Cabalo Blanco - Camden Valley Way, Leppington

- Local parks and playing fields in most surrounding suburbs

- playing fields of schools

The reader will note that these are all outdoor facilities, for outdoor activities.

Most are within a 20 km radius of the proposed site, many are very close.

All would be seriously impacted upon by aircraft noise, amongst other negative effects - many would have to close.

Please refer to the following 4 colour plates. They are;

- a selection of general "snapshots" of high use western Sydney recreational facilities, near and surrounding the proposed site.

1-2) Wallacia-Blaxland Crossing Reserve.



3) Silverdale (please note that Tara Girl Guides is a camping facility for Jamberoos etc. Tents cannot be insulated)

4) Prospect-Campbell Reserve.


- The economic cost of this project will exceed $10 Billion.

- The development is therefore economically unsustainable.

- F.R.A.A.N. considers that the construction of an airport simply to cater for something as volatile and fickle as the tourist market, particularly since our economy often goes down with other countries, as unsound reasoning.

- The EIS has not investigated, or has omitted to note, any genuine and concise or proper cost benefit analysis. Our own submission, and a wide section of the other submissions into the Draft Guidelines (we have copies of most), were very specific in their request for a full cost benefit analysis.

- The "Location and Development of the Second Sydney Airport - Consultants Brief" Appendix B,

page 2, paragraph 4.2 indicated; "that a Financial feasibility study would be conducted in parallel with the EIS. The study will compare and assess the financial implications of establishing a major international/domestic airport at Badgerys Creek or Holsworthy, and address relevant defence issues. The results of the financial feasibility study will be considered by the Government in conjunction with the outcome of the EIS process."

F.R.A.A.N. wonders why this has not been conducted properly, since the logical first step approach to any business operation is to determine whether or not a proposal is actually financially feasible.

- The potential value of the land that will be sterilised by this airport - for future food production (it currently supplies about 80-90% of Sydney's fresh food supply), and for our children to live on in the future is not noted in the EIS, nor investigated - but the cost is obviously extremely high.

This area is some of, if not all of, the most arable land left in Sydney. To quote a Badgerys local (J. Vella - Martins Rd. Badgerys Creek) "Dad moved here because there was 3'-4' of soil before the clay. It was the best land we could find to work as a productive farm."

- Even more taxpayers money would be required to purchase the extra land required to make the operations of the airport viable, since it is a clear requirement for an airport at the site, to have a cross runway. - We note that purchase costs anticipated in 1985 have blown out shockingly; there is no reason to think that the same would not happen again, probably on an even greater scale.

- The potential monetary cost of recovering from the myriad of potential disasters that this proposed airport presents, is not noted in the EIS, but again, it is obvious that the costs would be simply unacceptable.(See electricity and water - Hazard and risks)

- The Kemps Creek shooting range is to have multiple millions of dollars spent on upgrading for use during the Olympic games. This money will be wasted if the future of the facility is rendered useless by this airport.

- Compensation and Relocation costs would undoubtedly be astronomical, considering the enormously wide variety, size and type of impacts that would be inflicted on infrastructure, business, homes, facilities, people, etc., whom and which would obviously have a right to such public monies.

Given that the EIS process has proved to be such an unreliable indicator of impact, (one only has to look at the result of the KSA third runway fiasco) it is fair to expect the same, and if not even far greater costs blow out, in the circumstance of this proposed airport, particularly given the size of the proposal.


- Mr Joe Hockey, then Chairman of the "Sydney Aircraft Community Forum", along with other active proponents of the proposed airport, and the EIS itself, appear to continue to argue the merits of an airport almost solely on the basis of jobs that it would create.(See Channel 2,"Stateline" Fri. 27th March, 1998)

- He forgot to mention that this is Australia, and no matter where the airport, Australians will have jobs from an airport. He forgot to mention that he uses electricity at his home, drinks water from Lake Burragorang, and breathes the same air we all breathe in Sydney.

- He forgot to mention how much taxpayers money (and time) has been burned away, and how much more will be burned away chasing a no win proposal.

It was noted during the program, that in fact western Sydney had a per capita production rate higher than the rest of Australia, and was 2nd to Japan in that rate.

He also forgot that he is the Federal member for North Sydney, and that since KSA will almost certainly have to revert to the "parallel track" nature of operation,(obvious, see earlier colour flight track pages) his constituents will experience a major increase in aircraft overflight, and consequent impacts, although they at least, would still have a night curfew.

(Please see the last section of this submission - we have a "clean" proposal that would create a great many jobs in western Sydney!)

- An FAC information sheet (Dept of Trans 11 Sept. 1995) stated that: "When Sydney West Airport opens in 1999 there will be jobs for airline staff, in the warehousing, road freight and air freight industries, in catering and accommodation, in the car rental and taxi industries, the fuel industry and in aircraft, electronics, vehicle, airfield and building maintenance." (We feel that this is a very complete list of job types) "The 1985 EIS estimated that these airport related activities could eventually reach between 500 and 900 jobs." (Our emphasis and brackets)

It also states: "The 1985 EIS for Sydney West Airport suggested that the project could create more than 20,000 jobs directly at the airport and indirectly in the region."

- The 'Greater Western Sydney Economic Development Board' (individual members of whom own large tracts of land near the site, or businesses that would benefit greatly from the proposed airport) indicates that it would create 350,000 jobs.

- This new EIS indicates that 63,000 jobs would be created and supported by the development of this airport.

Misinformation has been the benchmark of this proposal since it's original illogical inception.

- This new EIS figure of 63,000 jobs cannot be justified, and just doesn't make any sense.

Here is some REAL information.

- Heathrow employs approx. 3,600

- Denver International Airport moved 444,698 aircraft and 32,296,174 passengers in 1996, but employs under 23,000 workers.

- Seattle moved 395,216 aircraft (Badgerys is designed for a max 360,000 aircraft movements) and over 24 million passengers in 1996, but employs only 14,500 workers at the airport, and directly supports 6,000 off site jobs.("from Pilots to Sky Caps")

The EIS does not indicate how many people will lose their jobs, because of the proposed airport, but it is obvious that if a person cannot sleep (one aircraft every 6 minutes during the night - our houses are almost all open plan brick veneer) then very soon they will be unable to work.

There are a great many small, (and large - Inghams employs approx. 600 people) businesses that would have to close down ( not noted or investigated in the EIS) because of the severe impacts inflicted on them.

Once again, there is no investigation in the EIS, or comment, on how may jobs would be affected in a negative manner - even though PPK were asked many times to identify this volume.


FRAAN regards PPK's treatment of impact to local schools as a joke. FRAAN wrote to fifty four schools within a 15 km radius of the proposed site. Later we learned that there were a number of private schools etc that we had missed, some of them quite big. Eg the "Sacred Heart" school on the Northern Road at Luddenham.

The suburbs of Horsley Park and Mt Vernon alone, blow every number for every PPK nominated figure of impact noted in the EIS, out of the water. This is almost a contemptible lack by PPK. One can only conclude that PPK are expecting a nuclear explosion to happen in western Sydney by the year 2016, or possibly PPK know some new method for teaching children that no-one else has yet picked up on, for local schools that already exist in the area now are not represented correctly in the EIS, let alone for the future. We can say no more than "look in a phone book PPK" for you have made a very serious mistake. Given an operational figure of 917 flights per day, and with current nominated flight paths so far advised considered, there are a number of schools within high ANEC zones (which we know are shockingly understated) that would experience far more than the "0" overflight figure nominated by PPK. One has only to look at the schools in alignment with option A, the smallest of the options, to realise that a minimum of 13 schools will be shockingly affected. We feel the number will in fact be far higher due to inaccuracies in noise modelling.

Once again, comparison with the Holsworthy figures nominated in the purple summary document, withdrawn from public view immediately Holsworthy was dropped out of the game, to see serious bias, and apparent figure manipulation.

Our Children are our future, and PPK have treated these people with contempt.


The supplement to the EIS volume 3, page 16.8 shows a table of schools and child care facilities subjected to high risk levels relating to the map shown on the next page fig 16.1. (Please also note Warragamba Dam Wall within the zone)

Given that PPK were supplied with comprehensive lists of schools and other facilities from FRAAN and other community groups, the lack of inclusion of the following schools and care facilities is inexcusable.

Option A shows a total 5 facilities affected - Missing facilities are:

- Anowah centre for care of intellectually and physically disabled persons.

- Do Re Mi Day Care and Kindergarten

- Children's Cottage Kemps Creek

- Emmanaus Retirement Village

- Emmanaus Catholic College

- Trinity primary school

- Mamre Christian College

- a new high school (being constructed now) corner of Cross and Devonshire Rds - Kemps Creek

(the scale of the map is too general to determine accurately, but it is apparent that there would be some schools in Prospect and Seven Hills which would be affected)

Option B shows a total of 4 facilities affected - Missing facilities are:

- Horsley Park Public School

- Anowah centre for care of intellectually and physically disabled persons.

- Do Re Mi Day Care and Kindergarten

- Children's Cottage Kemps Creek

- Emmanaus Retirement Village

- Emmanaus Catholic College

- Trinity primary school

- Mamre Christian College

- a new high school (being constructed now) corner of Cross and Devonshire Rds - Kemps Creek

(again, the scale of the map is too general to determine accurately, but it is apparent that there would be some schools in Prospect and Seven Hills which would be affected)

Option C shows a total of 11 facilties - Missing facilities are:

- Leppington Public School

- Ederslie High School

- Mawarra Public School

(There are obviously schools omitted through St Marys, Dunheved and the Wilmot area. Again, the map is too general to give an accurate list)

Given that the EIS supplement shows development at the scale of 35 dwellings per hectare (see map EIS vol 1, fig 10.1, and chapter 7 EIS supplement) there would obviously be some form of learning facility for these people as well - unless PPK will have developed ESP learning methods by that time!

We note too, that the State Development Department has forecast 2.25 million people to live in Sydney's West by 2011, (article Daily Telegraph Feb 21, 1996) these people too appear to be omitted.


The EIS indicates that about 7% of flights would be in the night if a night curfew was not in place.



360,000 movements x 7% = 25,200 flights

Divided by 365 days per year = 69.04 flights per night

Divided by 7 hours (curfew 11pm-6am)= 9.86 per hour

Divided into 60 min. = 1 plane every 6.08 minutes


360,000 movements divided by 365 days = 986.30 flights per 24hrs

Less 69.04 flights (for curfew 7 hrs-KSA) = 917.26 flights per day

Divided by 17 hrs (24hr day -7 hr curfew) = 53.95 flights per hour

Divided into 60 min. = 1 plane every 1.112 minutes

The "Airplan" design summary report (pg 10-1) indicates that the expanding of the Master Plan would increase handling capacity by up to 50%. This would equate to about one aircraft every 4.05 mins during the night, and one aircraft every 49 seconds during the day.

Dear Politician, or reader, would you like someone to mow the lawn outside of your bedroom window every 6 minutes at night, and around your house and/or work place every 1 minute or so during the day, gradually increasing in frequency over time?

Politicians are strong in character, that's how they got to where they are, but we feel that even they would not be able to put up with this treatment for long before being seriously "affected".

It is very sad, that in Australia of all countries, the community has had to fight its own Government, who after all, represent the people themselves, for so many years, in order to protect itself.


(For fun) ANEF - Another noisy expensive failure. ANEC - Another nasty experience coming.

(For real) ANEF - Australian Noise Exposure Forecast. ANEC - Australian Noise Exposure Concept.

- Essentially there is no difference between ANEF and ANEC in manner of indication of noise prediction measurement or in indication of level of noise disturbance.

Option A can be used as an effective EIS comparison between todays EIS and the 1985 EIS (which was seriously discredited). Comparison shows that there is something seriously wrong with the process, and the new EIS.

- The methodologies used to determine the impact of noise on communities surrounding Kingsford Smith Airport (KSA) were proved after the event of the third runway EIS to be totally unreliable in genuinely predicting the impact, and the Govt. has had to spend considerable amount of monies to attempt to overcome the problems created. These have not been successful, and communities surrounding KSA continue to suffer abysmally from noise impacts, as do large areas of greater Sydney.

- It is incredible that exactly the same methodologies have been adopted to determine the impact of noise on communities surrounding the proposed Badgerys Creek Airport.

Please note that we earnestly believe that construction of an airport at Badgerys Creek would not mean the removal or downgrading of operations at KSA, but rather, would instead seriously exacerbate the existing problems currently experienced by KSA.

- The attached ANEF (ANEC) maps from the 1985 EIS and the 1997 EIS option A, provide quick visual proof of a major corruption and misleading describer of the noise impacts generated from this proposed airport. Please use Wallgrove Road (marked) as a visual indicator. (see next two pages)

* The 1985 ANEF was often described by S.White, then manager of the FAC (Federal Airports Corporation), at several public meetings, as being "seriously understated" because it had been drafted on the basis of "a level playing field, at sea level" and did not take into account topography or meteorological phenomena or common events.

- As he described, the airport (now option A or B and cross runway Option C) has large escarpments of land at either end of the runway alignments, and therefore aircraft would necessarily have to fly extremely low over these escarpments in order to "duck in" to land at the airport. Likewise aircraft would necessarily have to fly low over them during take off operations. Therefore the indicated noise over these escarpments was seriously understated.(Audio tape, and meeting minutes can be produced to substantiate this.)

- Please note that the original proposal was for a "General Purposes" Overflow Airport of 13 million passenger movements. The current proposal is for an "International" airport of 30 million passenger movements.

AS CAN BE SEEN, THE ANEC PRESENTED NOW FOR OPTION A, IS ESSENTIALLY NO LONGER/LARGER THAN THE ANEF SHOWN FOR THE 1985 PROPOSAL, after earlier criticism, the EIS supplement has simply added a 15ANEC zone to the outside of the original ANEC, thereby causing it to look larger to the untrained eye. This is not the case, the ANEC has not been modified and upgraded to correct the serious misrepresentation of noise impact on the North East/South West Communities. This is clearly shown when one considers the night time noise impacts shown in the EIS supplement vol 3, fig 9.1 which shows serious night noise impact to very large segments of the community from aircraft on the ground. This also shows the 2016 predictions of night time sleep disturbance figures (summary pg 56) to be an absolute nonsense. This is even more heightened when one considers the Auditors report noting that noise disturbance figures are understated by a factor of 8dB. (Noise level doubles approx every 8dB)


Please see the next two colour plates.

They are;

1) The ANEF FROM 1985

2) The new "option A" (same alignment etc) ANEC (effectively the same as ANEF), supposedly up modelled for this current EIS. (Supplement added 'diversionary' 15 ANEC not shown)


F.R.A.A.N. points out that the style of house prevalent in Western Sydney is of brick veneer construction. Those of double brick construction have brick ties between the walls; brick ties act as "taut string between two cups" transmitting noise from the outside wall of the house, through to the inner wall.

Inner city experience has shown that houses of the above noted styles of construction are virtually impossible to insulate against noise (to meet AS2021) - (which in it's own right has proved to be inadequate.)

We point out that those houses insulated, or otherwise, in the region surrounding KSA are generally solid block construction, in tenement style, with common walls adjoining other homes, or the homes are built closely to each other, helping to absorb noise. Often they are multi story, with sleeping quarters upstairs - which acts as an airspace noise insulator for the rest of the house during the day, and of course quiet during the late sleeping hours due to the 11pm curfew.

They have the advantage of a curfew, and with due respect to those poor people, they at least have the advantage of (usually) knowing that they are moving to live in an area close to an already existing major airport.

In deference to houses in Western Sydney: they are built on a cheaper construction method, have large yard areas surrounding them and are thus exposed to noise from all four sides, are mostly single story and so are not protected by any upstairs bedroom acting as an insulator, and are very ill equipped to handle the constant noise from a continual overflight of jet aircraft, particularly from a no curfew airport.

- New homes are not equipped to deal with loud constant noise either. Many of these new home owners have been lied to by councils (particularly Liverpool) and developers, and have been told that the proposed airport would not affect them. See people in Cecil Hills and the development along Cowpasture Road (as an example). This is obviously not true; one has only to look at the proposed flight paths, now that they are finally available after 18 odd years, to see that these people will be impacted.

Once again, we remind of Airplans' note that "final" flight paths cannot be determined for an airport.

We note too, that flight paths for KSA have altered, sometimes drastically, many times in the past 4 years alone.

The following five colour pages again indicate a major problem with the honesty and integrity of the EIS and the methodology used to determine impacts of noise on communities. Please view them carefully, they represent many many families and homes now - a great many more of each in the future.