SUBMISSION BY

THE NSW GOVERNMENT

TO THE

COMMONWEALTH MINISTER FOR

THE ENVIRONMENT AND HERITAGE

CONCERNING

THE ENVIRONMENTAL ASSESSMENT FOR

THE PROPOSED SECOND SYDNEY AIRPORT

 

July 1999

 

EXECUTIVE SUMMARY i

  • NSW Government’s position i

    Purpose and scope of this submission i

    Conclusions of the EIS i

    Uncertainty about the proposal ii

    Major impacts and costs ii

  • INTRODUCTION 1

  • NSW Government’s position 1

    Purpose and scope of this submission 1

    Conclusions of the EIS 2

    Uncertainty about the proposal 2

  • NOISE IMPACTS 3

  • Noise management measures 3

    Residential properties 3

    Noise sensitive land uses 4

    Costing of noise insulation for noise sensitive uses 4

    Health impacts 5

    Impact on national parks and reserves 5

  • ABORIGINAL HERITAGE 5

    NATIVE FLORA, FAUNA AND THREATENED SPECIES 6

    WATER QUALITY 7

  • Water quality impacts 8

    Mitigation measures 8

    Sewage treatment options 9

    Health impacts 10

  • HAZARD AND RISK 12

  • Aircraft crashes 12

    Fuel supply 12

  • AIR QUALITY 13

  • Air quality impacts 13

    Health impacts 15

    Economic evaluation 16

  • TRANSPORT 16

  • Phasing of development and impact on infrastructure and services 17

    Travel demand management 18

    Alignment of the rail link to Badgerys Creek 18

    Rail services issues 19

    Estimated rail costs 20

    Road network implications 20

    Identified road upgrades 21

    Conclusion 21

  • ECONOMIC ISSUES 22

  • Cost and funding of off-site infrastructure 22
  • CONCLUSION 23

     

    EXECUTIVE SUMMARY

    NSW Government’s position

    The NSW Government is opposed to the development of an airport at Badgerys Creek and favours an airport outside the Sydney basin. The Government is particularly concerned about the impact on the health, environment and quality of life of Western Sydney residents.

    Furthermore, the Commonwealth continues to ignore the critical issue of funding for off-site infrastructure, such as road and rail construction, required to provide for an airport at Badgerys Creek. The EIS fails to assess the likely environmental impacts of the required off-site infrastructure and has seriously underestimated the cost of this infrastructure by about $3 billion.

    Although the EIS includes a benefit-cost analysis which concludes that the airport would have a net economic benefit of between $3 billion and $4 billion, , many important environmental impacts, in particular water and air quality impacts, were excluded from the analysis. As a consequence of this omission and the underestimation of infrastructure costs by about $3 billion, the benefit-cost analysis seriously overestimates the net benefit of the second airport.

    Purpose and scope of this submission

    The Final EIS for the proposed second airport at Badgerys Creek was released on 30 June 1999. The Final EIS has been submitted, with the final report of the Environmental Auditor, to Environment Australia, which has prepared an assessment report for submission to the Commonwealth Minister for the Environment.

    There will be major impacts outside the airport site, including implications for infrastructure and the physical environment. Consequently, the Commonwealth can only properly consider Environment Australia’s report on the EIS if the Minister for the Environment also considers detailed information about the impacts of the proposal outside the site.

    The purpose of this submission by the NSW Government is to provide detailed information about the impacts that a second airport at Badgerys Creek would have on Western Sydney and to recommend measures that should be implemented to mitigate against those impacts, if the Commonwealth decides to proceed with the proposal. Where possible, each section estimates the costs of mitigation, particularly where these costs could be imposed on the NSW Government.

    The submission also reviews the costing for infrastructure in the EIS, particularly the infrastructure that the Commonwealth may expect the NSW Government to develop. The revised estimates of infrastructure costs and the costs of mitigating environmental impacts have been developed by the relevant State agencies and NSW Treasury has collated them in Table 3 of the submission.

  • Conclusions of the EIS

    The EIS has concluded that Sydney Airport will reach capacity in the latter part of the next decade, unless there are significant changes to noise management policy and to airline operating procedures. While some short-term measures may defer the need for a new airport, new airport facilities for domestic and international services will be required in the Sydney Basin to meet the expected long- term demand for air travel. Failure to meet demand for air travel to and from Sydney would have a major economic impact on New South Wales.

    The EIS examines potential impacts based on an airport at Badgerys Creek capable of handling 30 million passengers per year, including a first stage capable of handling 10 million passengers per year. By comparison, Sydney Airport handled 21.3 million passengers in 1997-98. Air passenger numbers are forecast to increase to 35 million in 2009-10 and 49 million in 2021-22. Based on current trends, Sydney Airport would reach capacity in 2006-07, at 31 million passengers per year.

    Uncertainty about the proposal

    The Badgerys Creek airport’s role is not defined in the EIS. It states that the role would evolve over time in response to a wide range of economic, environmental, policy and operational considerations, which private sector interests would play an important part in defining.

    The EIS does not rank the three options considered for future development of the airport, nor does it make recommendations. It states that the EIS process is designed to assist decision-makers, rather than to make decisions.

    The failure to identify a preferred runway alignment and the lack of detail regarding the role and scale of the airport make it difficult to clearly identify the extent and significance of all the environmental impacts and the most appropriate methods to mitigate these impacts.

    While the EIS suggests that the benefits of the proposal are double the quantified costs, many important environmental impacts, in particular water and air quality impacts, were excluded from the economic analysis. Furthermore, many of the costs that were included, in particular the off-site infrastructure costs, were understated. This is unacceptable because the benefit/cost analysis therefore overestimates the net benefits of the second airport and overlooks significant environmental costs to the community.

    Major impacts and costs

    This section highlights the major impacts and costs that are identified in the proposed submission.

    Noise impacts

    A decision to proceed with an airport at Badgerys Creek would introduce a major new noise source in an area of Western Sydney that is semi-rural. All options canvassed in the EIS would cause aircraft overflight noise impacts, particularly in areas with a rural lifestyle. It is clear that the surrounding community will be affected by noise of a level that disturbs conversations in homes, educational centres, schools, hospitals and aged care facilities as well as disturbing sleep.

    For each airport option, the EIS has identified a number of schools, hospitals, childcare facilities and community facilities that could be affected by noise levels which would interfere with their operation. Even if the noise management measures proposed in the EIS were employed, the cost of noise insulation for just the State schools has been estimated to be $4.4 - 6.4 million for Options A and B and $33.6-40.0 million for Option C.

    Aboriginal heritage

    The EIS indicates that up to 94 known Aboriginal sites and 205 potential sites could be impacted by the proposal and development of any of the three options would result in the destruction of Aboriginal heritage. The Supplement states that this would constitute between 14 and 23 percent of the known Aboriginal sites in the region.

    Native flora and fauna

    The loss of significant areas of remnant vegetation and impacts on threatened species as a result of the airport proposal may compromise the ability of the affected ecological communities and threatened species to recover. This is a particularly important issue considering the small amount of remnant vegetation remaining and the existing development pressures in Western Sydney.

    The Commonwealth Government should provide up to $1.1 million for development of recovery plans for threatened species and endangered communities and for a translocation program for endangered species. The Commonwealth should also purchase land or donate Commonwealth land with similar attributes to compensate for the loss of about 150 hectares of remnant Western Sydney vegetation.

    Water quality

    There are threats to downstream water quality as nutrients, sediments and pollutants may not be fully captured by stormwater management controls such as detention ponds. The EIS lacks detail on proposed stormwater mitigation measures; therefore, it is not possible to determine the extent of any economic costs that might be incurred by the NSW Government.

    The proposed submission outlines mitigation measures that the Commonwealth should include in an Environmental Management Plan, if the airport proceeds. It is estimated that the Commonwealth will need to provide an extra $30 million for sewage treatment infrastructure to achieve ANZECC water quality guidelines. Furthermore, the Commonwealth will also need to fund trials on a pilot water treatment plant to assess whether pollution of Sydney’s water supply by aircraft emissions can be filtered out by the Prospect Water Treatment Plant.

    Hazards and risks

    Although the Final EIS provides further analysis concerning the risk of an aircraft crash into water supply and energy infrastructure, the information provided concerning the possible consequences of a crash into water supply infrastructure raises significant concerns for the NSW Government. There is a risk of almost one crash per 10,000 years where the aircraft crash damages the Sydney Water Supply Pipeline.Each of the airport options would have major flight paths crossing the Sydney Water Supply Pipeline, which transports water from Warragamba Dam to the Prospect Water Treatment Plant.

    Although the risk would appear to be low, tThe consequences of an aircraft crash into the Sydney Water Supply Pipeline would be the complete disruption of 70% of Sydney’s water supply. It is proposed, therefore, that any sections of the Water Supply Pipeline that are exposed to a significant risk should be buried at least 3 metres underground. The Commonwealth should fund such work, which is estimated to cost between $68 million and $114 million.

    Air quality

    The EIS appears to underestimate the impacts of motor vehicle emissions, in particular, emissions of nitrogen oxides (NOx). EPA recalculations of emission estimates provided in the EIS indicate that the emissions of hydrocarbons, nitrogen oxides and carbon monoxide may be up to one third higher than those projected in the final EIS.

    Increases in air emissions from the proposed airport would be due largely to vehicular movements associated with its operation and from local traffic using new roads for non- airport associated travel. The increase in vehicle kilometres travelled (VKT) is likely to present a serious, if not insurmountable pressure on VKT reduction targets set out in the NSW Government’s 25 year air quality management plan, Action for Air.

    Some of the predicted air quality impacts could be ameliorated by the provision of offsets such as a public transport system to the airport or funding for improved public transport systems within the Sydney area generally (see Transport). If the air quality impacts predicted in the EIS do eventuate, the Department of Health has estimated that there could be up to 100 extra hospital admissions per year for asthma at a cost to the State of $600,000 per year. The community costs from premature death due to the airport could be $325 million over 100 years.

    Transport

    The proposed airport could only operate successfully if there is major investment in land transport infrastructure that connects the airport into the regional transport networks. Furthermore, if the Commonwealth decides to proceed with an airport at Badgerys Creek, it would be fundamental that a rail link be provided to the airport from commencement of airport operation, together with supporting road-based public transport measures in order to meet NSW air quality and travel demand management objectives.

    The EIS fails to acknowledge that responsibility for funding the identified airport related road and rail improvements should rest with the Commonwealth Government, together with responsibility for roads assumed to be in place, such as the Western Sydney Orbital.

    State Rail estimates that the capital cost of rail construction and upgrading would be about $1,600 million, which would include a railway from Glenfield to Badgerys Creek for Stage 1 of the airport and a later extension to the Main Western Line at St Marys. The RTA estimates that the cost of road construction and upgrading would be about $2,400 million. However, this includes almost $1,000 million for the Western Sydney Orbital, which will be required even without the airport, but the airport would bring forward the need for it.

     

    Economic issues

    The EIS understates the total cost of off-site infrastructure necessary for the airport, and in particular those infrastructure items normally provided by the State Government. The figures stated in the EIS total $1.1 billion in off-site infrastructure for the ultimate airport development, capable of handling 30 million passengers per year. NSW Government agencies responsible for the provision of the relevant off-site infrastructure have provided costings which total $4.1 billion to $4.3 billion to service the ultimate development. These capital costs are summarised in Table 3 of the submission.

    The Final EIS contains a detailed benefit-cost analysis which concludes that the the order of magnitude of benefits to the community relative to total costs is of the order of 2:1, with a net economic benefit of between $3 billion and $4 billion Net Present Value. Although the approach taken to assess the overall net economic worth of the airport is considered reasonable, the EIS economic evaluation must be brought into doubt as a result of the more detailed costing of the off-site infrastructure, particularly for the Stage 1 level of operations.

    The total cost of off-site infrastructure used in the EIS economic assessment for Stage 1 was only $691 million. The increase in off-site infrastructure costs of over $3 billion, as a result of updated figures, significantly reduces the overall assessment of net economic benefit. Furthermore, many important environmental and health impacts were excluded from the economic analysis and, therefore, the net benefits were even more overestimated.

     

    INTRODUCTION

    NSW Government’s position

    The NSW Government is opposed to the development of an airport at Badgerys Creek and favours an airport outside the Sydney basin. The Government is particularly concerned about the impact on the health, environment and quality of life of Western Sydney residents.

    Furthermore, the Commonwealth continues to ignore the critical issue of funding for off-site infrastructure, such as road and rail construction, required to provide for an airport at Badgerys Creek. The EIS fails to assess the likely environmental impacts of the required off-site infrastructure and has underestimated the cost of this infrastructure by about $3 billion.

    Although the EIS includes a benefit-cost analysis which concludes that the airport would have a net economic benefit of between $3 billion and $4 billion, many important environmental impacts, in particular water and air quality impacts, were excluded from the analysis. As a consequence of this omission and the underestimation of infrastructure costs by about $3 billion, the benefit-cost analysis seriously overestimates the net benefit of the second airport.

    Purpose and scope of this submission

    The Final EIS for the proposed second airport at Badgerys Creek was released on 30 June 1999. The Final EIS has been submitted, with the final report of the Environmental Auditor, to Environment Australia, which has prepared an assessment report for submission to the Commonwealth Minister for the Environment.

    There will be major impacts outside the airport site, including implications for infrastructure and the physical environment. Consequently, the Commonwealth can only properly consider Environment Australia’s report on the EIS if the Minister for the Environment also considers detailed information about the impacts of the proposal outside the site.

    The purpose of this submission by the NSW Government is to provide detailed information about the impacts that a second airport at Badgerys Creek would have on Western Sydney and to recommend measures that should be implemented to mitigate against those impacts, if the Commonwealth decides to proceed with the proposal. Where possible, each section estimates the costs of mitigation, particularly where these costs could be imposed on the NSW Government.

    The submission also reviews the costing for infrastructure in the EIS, particularly the infrastructure that the Commonwealth may expect the NSW Government to develop. The revised estimates of infrastructure costs and the costs of mitigating environmental impacts have been developed by the relevant State agencies and NSW Treasury has collated them in Table 3.

  • Conclusions of the EIS

    The EIS has concluded that Sydney Airport will reach capacity in the latter part of the next decade, unless there are significant changes to noise management policy and to airline operating procedures. While some short-term measures may defer the need for a new airport, new airport facilities for domestic and international services will be required to meet the expected long- term demand for air travel. Failure to meet demand for air travel to and from Sydney would have a major economic impact on New South Wales.

    The EIS examines potential impacts based on an airport at Badgerys Creek capable of handling 30 million passengers per year, including a first stage capable of handling 10 million passengers per year. By comparison, Sydney Airport handled 21.3 million passengers in 1997-98. Air passenger numbers are forecast to increase to 35 million in 2009-10 and 49 million in 2021-22. Based on current trends, Sydney Airport would reach capacity in 2006-07, at 31 million passengers per year.

    Uncertainty about the proposal

    The Badgerys Creek airport’s role is not defined in the EIS. It states that the role would evolve over time in response to a wide range of economic, environmental, policy and operational considerations, which private sector interests would play an important part in defining.

    The EIS does not rank the three options considered for future development of the airport, nor does it make recommendations. It states that the EIS process is designed to assist decision-makers, rather than to make decisions. The decisions on the second airport will be made by the Commonwealth Government, based on the results of the EIS and other considerations.

    The failure to identify a preferred runway alignment and the lack of detail regarding the role and scale of the airport make it extremely difficult to clearly identify the extent and significance of environmental impacts and the most appropriate methods to mitigate these impacts.

    While the EIS suggests that the benefits of the proposal are double the quantified costs, many important environmental impacts, in particular water and air quality impacts, were excluded from the economic analysis. Furthermore, many of the costs that were included, in particular the off-site infrastructure costs, were understated. This is unacceptable because the benefit/cost analysis therefore overestimates the net benefits of the second airport and overlooks significant environmental costs to the community.

    The analysis of benefits is also particularly sensitive to the assumptions used. If demand growth for air travel is less than assumed or consumer travel patterns are more price sensitive than assumed then the economic viability of the second airport could be marginal.

    The NSW Government shares the view of the independent Auditor of the EIS process (SMEC) that the assessment of cumulative impacts remains inadequate. This is of particular concern for regional air quality given the significance of the proposal’s contribution to emission loads. The EIS claims that cumulative impacts would be mitigated or offset by a range of benefits and environment protection measures. However, the Commonwealth has not made commitments on many of these matters.

    The following sections outline the impacts that a second airport at Badgerys Creek would have on Western Sydney and recommends measures that should be implemented to mitigate against those impacts, if the Commonwealth decides to proceed with the proposal. Where possible, each section estimates the costs of mitigation, particularly where these could be imposed on the NSW Government.

     

    NOISE IMPACTS

    A decision to proceed with an airport at Badgerys Creek would introduce a major new noise source in an area of Western Sydney that is semi-rural.Western Sydney. All options canvassed in the EIS would cause aircraft overflight noise impacts, particularly in areas with a rural lifestyle. However, until the runway alignment, role and scale of an airport at Badgerys Creek are determined, it is not possible to identify the extent and locational incidence of the noise impacts with any certainty.

    It is clear that the surrounding community will be affected by noise of a level that disturbs conversations in homes, educational centres, schools, hospitals and aged care facilities as well as disturbing sleep.

    Noise management measures

    Further investigations undertaken for the Supplementary EIS indicate that for at least two of the options the impacts of aircraft noise on homes and public buildings could be significantly reduced by modifying flight paths and airport operations.

    Recommendation

    It is recommended that the Commonwealth Government assess more carefully the noise impacts and develop a meaningful noise management plan, in accordance with a consultation and communication strategy. The flight paths for the selected airport option should be planned and managed under the noise management plan in such a way that the noise impacts on populated areas are minimised.

    Residential properties

    Recommendation

    All residential properties in the area around the proposed airport exposed to a level of ANEC 35 (2016) or greater should be acquired, as suggested in the EIS.

    The Australian Standard 2021 suggests that areas exposed to ANEC 25 or greater would be unacceptable for residential premises. Residential premises exposed to noise within ANEC 25-35 should be compensated by noise insulation as suggested in the EIS.

    Noise mitigation measures to reduce ground running noise impacts need to include orientation of bays away from affected residential areas, establishment of noise barriers around the run up bays and no night time testing of engines.

    Noise sensitive land uses

    For each airport option, the EIS has identified a number of educational facilities (including schools, tertiary facilities and childcare centres), hospitals, and community facilities that could be affected by noise levels which would interfere with their operation. The EIS has used the criterion of 10 noise events per day of more than 65 dBA for schools and child care facilities and 10 noise events per day of more than 70 dBA for hospitals, nursing homes and retirement villages.

    The number of educational facilities identified in the EIS as being potentially exposed is estimated to be 20 for Options A and B and 75 for Option C. This number would be reduced if noise management measures recommended in the EIS were employed (such as redirecting flight paths). The facilities affected would be reduced to 14 for Option A, 11 for Option B and 26 for Option C.

    The major health institutions that would be affected by Option C, experiencing 10 to 20 daily noise events above 70dB(A), are Nepean Hospital (Kingswood), Camden Hospital, Governor Phillip Hospital (Penrith) and the Carrington Hospital and Nursing Home (Camden). These facilities should also receive noise insulation if this Option proceeds. No hospitals would be affected by the other Options.

    Recommendation

    It is recommended that the Commonwealth Government provide funding for educational facilities, hospitals and community facilities that would be subject to aircraft noise which exceeds the above criteria which would interfere with their operation. The funding should be sufficient to provide noise insulation that allows compliance with Australian Standard 2021-1994.

    Costing of noise insulation for noise sensitive uses

    The EIS suggests that voluntary acquisitions and acoustical treatment would cost between $21 million and $44 million. It appears that the figures reflect estimates for residential property acquisition and acoustical treatment for residential properties only. If this is the case then the EIS fails to include the cost of acoustical treatment for educational facilities, hospitals and community facilities. These factors again bring into question the reliability of the benefit/cost analysis in the EIS and its conclusion on the project’s economic viability.

    The NSW Government has undertaken a preliminary survey of those public schools and the TAFE identified in Appendix C2 of the Supplementary EIS. The operation of these facilities is wholly or partly funded by the NSW Government which should, therefore, receive funding from the Commonwealth Government for the provision of noise insulation.

    Recommendation

    It is recommended that the Commonwealth Government provide noise insulation funding for the TAFE and public schools based on the following estimates:

  • Option A - $4.4 million - $6.4 million

    Option B - $4.4 million - $6.4 million

    Option C - $33.6 million - $40.0 million

  • Health impacts

    Although the EIS calculates the numbers of people who will be affected by noise under different operational scenarios, the direct health effects attributed to noise are not considered. Sleep disturbance will also arise but again no direct health effects are calculable. The areas affected by a level of noise considered to impact on sleep or communication include up to 200,000 residents.

    Increased noise events are likely to result in learning difficulties, a diminished ability to perform tasks and communicate, and may cause psychological disturbance. An increase in the use of tranquillisers and sedatives is predicted.

    The general lack of information on the health risks due to increased noise levels makes it impossible to quantify the noise related health impacts that may be caused by the proposed airport.

    Recommendation

    It is recommended that the Commonwealth Government provide funding to NSW Health to conduct a controlled study on the health impacts of noise in the area surrounding the proposed airport.

    Impact on national parks and reserves

    The proposed airport would have significant noise impacts on National Parks and Wildlife Service reserves of national significance. The most severely affected would be the Blue Mountains National Park, Burragorang State Recreation Area, Bents Basin State Recreation Area, Mulgoa Nature Reserve and Western Sydney Regional Park. The EIS has underestimated the impacts on these reserves because it has used a noise criterion of 70 dBA despite recognising that people visiting natural areas are about 10 dBA more sensitive than those in residential areas.

    The potential noise impacts of options A or B on the Blue Mountains National Park could have a significant impact on the number of visitors, which is 3 million per year. This could also have a negative impact on the regional economy.

    Recommendation

    It is recommended that there should be further investigation of the diversion of flight paths to reduce the noise impacts on recreational use of natural areas, particularly if Option A or B is selected. Such an investigation should ensure that the noise problem is not merely shifted to another reserve or group of users.

     

    ABORIGINAL HERITAGE

    The EIS indicates that up to 94 known Aboriginal sites and 205 potential sites could be impacted by the proposal and development of any of the three options would result in the destruction of Aboriginal heritage. The Supplement states that this would constitute between 14 and 23 percent of the known Aboriginal sites in the region.

    The magnitude of the potential impacts of development of the Badgerys Creek airport site would have a significant and irreversible impact on Aboriginal heritage within the Western Sydney region. A consequence for the NSW Government of any airport option being approved would be:

  • increasing difficulty in achieving its conservation responsibilities of protecting a representative sample of Aboriginal heritage in the region;

    increasing pressure on local and regional planning processes to achieve Aboriginal heritage protection within the context of intense development demands.

  • Recommendation

    It is recommended that compensation for the loss of Aboriginal heritage should be determined through a process of negotiation with Aboriginal communities, funded and sponsored by the Commonwealth Government. This process would enable the Aboriginal community to identify the most appropriate and fair compensatory mechanisms and may include direct financial contributions to local Aboriginal community groups and identified traditional owners, together with employment opportunities associated with the airport development.

    The NSW Government also recommends that the Commonwealth provide contributions for the following, subject to Aboriginal community support:

  • acquisition and protection of land with similar Aboriginal heritage values for conservation (being both rare and representative places of heritage significance);

    rehabilitation of the remaining Aboriginal heritage places within the development lands;

    the establishment of a keeping place for any cultural material salvaged from the proposed development; and

    assistance with the Cumberland Plain Regional Aboriginal Heritage Strategy, which the NPWS is currently undertaking in collaboration with the Land Councils, Tribal Corporations, and Native Title Claimants of Western Sydney.

  • NATIVE FLORA, FAUNA AND THREATENED SPECIES

    The airport proposal would result in the destruction of :

  • between 121 and 149 hectares of Cumberland Plain Woodland which is listed as an endangered ecological community under both the NSW Threatened Species Conservation Act and the Commonwealth Endangered Species Protection Act;

    between 0.6 and 2.5 hectares of Sydney Coastal River Flat Forest, listed as an endangered ecological community under the NSW Threatened Species Conservation Act;

    the removal of a population of Pultenaea parviflora, which is listed as endangered under both the NSW and Commonwealth legislation;

    the extinction of a locally viable population of the Large Land Snail, which is listed as endangered under the NSW Threatened Species Conservation Act, and which has been assessed as being of State significance on the site;

    the destruction of part of the Badgerys Creek corridor under Options B and C, which has been assessed as being a wildlife corridor of regional conservation significance.

  • The loss of significant areas of remnant vegetation and impacts on threatened species as a result of the airport proposal may compromise the ability of the affected ecological communities and threatened species to recover. This is a particularly important issue considering the small amount of remnant vegetation remaining and the existing development pressures in Western Sydney.

    Recommendation

    The NSW Government strongly recommends that the Commonwealth Government make provision for the following ameliorative measures to ensure the conservation of threatened species and endangered ecological communities. These measures will contribute to long term planning objectives for the conservation of biodiversity within Western Sydney:

  • Recovery Plan development funding:

    The Commonwealth Government should provide funding for the preparation and implementation of recovery plans for threatened species and endangered ecological communities likely to be impacted by the proposed airport. It is estimated that the preparation and implementation of these recovery plans will be $0.5 to $1.0 million.

    Acquisition of compensatory lands and regeneration of native vegetation:

    The NSW Government’s preference is for in-situ conservation rather than revegetation or translocation. Should the airport proceed, however, the Commonwealth Government should purchase land or donate Commonwealth lands with similar environmental attributes and representativeness to compensate for the direct loss of up to 151.5 ha of Cumberland Plain Woodland and other remnant Western Sydney vegetation of conservation significance resulting from the proposal. The potential off-site conservation areas identified in the Supplement (p. 14-39) include the Holsworthy Military Area, RAAF Orchard Hills and Shanes Park.

    Alternatively, the Commonwealth Government should make a contribution towards the establishment of conservation areas within the regional open space in Western Sydney. However, this option could only provide compensation in the long term for the loss of mature Cumberland Plain Woodland and would require extra resources for the rehabilitation and regeneration of remnant vegetation.

    Translocation Program:

    The NSW Government considers that the Commonwealth Government should additionally fund the proposed translocation program of Pultenaea parviflora and Meriodolum corniovirens, should the development proceed. The estimated cost of such a program is in the order of $100,000.

  • WATER QUALITY

    It is the view of the NSW Government that there are threats to downstream water quality as nutrients, sediments and pollutants may not be fully captured by stormwater management controls such as detention ponds. The Supplement lacks detail on proposed stormwater mitigation measures; it is not possible, therefore, to determine the extent of any economic costs that might be incurred by the NSW Government.

    The costs of water quality impacts have not been included in the benefit/cost analysis because the EIS predicts that the proposal has no negative effect on water quality. This overlooks significant potential costs and undermines conclusions about the project’s economic viability.

    Water quality impacts

    In general, the likely impacts on water quality during construction of an airport at Badgerys Creek which were not identified, or less than adequately considered, in the EIS include:

  • pollution of local waterways from soil erosion;

    erosion and sedimentation of waterways from increased run-off;

    changes in hydrology and impacts on aquatic ecosystems from diversion and infilling of watercourses;

    toxicants entering waterways from the use of chemicals (flocculants) to precipitate suspended particles in pollution control dams;

    bank erosion of downstream waterways and impacts on water quality from increased flows in waterways;

    localised impacts on vegetation and surface waters from exposure of saline groundwater from perched water tables.

  • In general, the likely water impacts from the operation of an airport at Badgerys Creek which were not identified, or less than adequately considered, in the EIS include:

  • sediments, nutrients, and chemical pollutant loads (fuels, oils, other) entering waterways as a result of inadequate treatment of run-off by pollution control ponds;

    erosion of surrounding waterways due to an increase in volume and rate of stormwater run-off;

    increases in pollutant loads in South Creek from wastewater discharge;

    fuel derived pollutants from aircraft exhaust (e.g. polycyclic aromatic hydrocarbons (PAH), benzene) and fuel venting falling into water supplies, particularly Lake Burragorang, Prospect Reservoir and rainwater tanks;

    contamination of groundwater from fuel, oil or other chemical spills on site;

    cumulative impacts from long-term development of infrastructure in the vicinity of the airport; and

    decreased water quality through the lack of capacity for long-term reuse of effluent on-site.

  • Under any option, the construction of the airport would result in the filling of sections of a number of natural creeklines and replacement with stormwater drains. Under Option A, 5km of natural creekline will be removed but Badgerys Creek, which is considered of regional significance, will remain. Under Options B and C, almost 10km of natural creekline will be filled, including 5km of Badgerys Creek. All options, therefore, would have significant water quality impacts.

    Mitigation measures

    The EPA analysis clearly indicates that the measures proposed within the EIS will not deliver the predicted outcome of good water quality. If the mitigation measures outlined below are not undertaken then the proposal could have significant adverse impact on water quality in local waterways. This could compromise the improvements being made in South Creek and the greater Hawkesbury-Nepean river system through the Government’s Waterways Package and stormwater grants, as well as future initiatives under the NSW water reforms. The fact that the costs of reduced water quality are not reflected in the economic analysis of the project means that the net benefits of the airport are overstated in the EIS.

    Recommendation

    Additional mitigation measures to those outlined in the EIS are required to ameliorate the potential water quality impacts identified above. These include:

  • independent auditing of implementation of construction management plans to ensure proper, comprehensive sediment and erosion control measures and controls to mitigate erosion of downstream waterways;

    design of detention basins to be effective in removing pollutants while meeting flood mitigation requirements;

    development of alternatives for managing the use of flocculants in water pollution ponds to remove pollutants;

    development of a water cycle management plan (for stormwater, effluent and waste waters) for the operational phase that attempts to mimic natural flows in waterways;

    development of contingency plans to manage major spills prior to reaching water quality control ponds;

    further monitoring of baseline conditions in downstream waters (including receiving water quality and biological assessment) prior to construction and during operation, as well as monitoring of effluent quality from airport facilities;

    external review of proposed water quality monitoring with management actions being guided by the water quality criteria given in the Australian Water Quality Guidelines for Fresh and Marine Waters;

    discharges of treated sewage effluent to South Creek only when effluent holding ponds are at capacity and during times of high flow. The discharged water should meet the criteria contained in the Airports (Environment Protection) Regulation and the ANZECC Guidelines for Fresh and Marine Waters relative to any water quality objectives set for these waters under the NSW Water Reform process;

    consideration of possible connection of wastewater discharge to the Sydney Water’s sewerage system if there is insufficient capacity for sustainable reuse of effluent on-site;

    guidance of irrigation of effluent proposals by NSW EPA’s draft guidelines for the utilisation of effluent by irrigation (soon to be finalised) which includes health criteria and soon to be published National Water Quality Management Strategy "Draft guidelines for sewage systems - use of reclaimed water".

  • Sewerage infrastructure costs

    The level of phosphorus discharge into South Creek was identified as a major water quality issue in the NSW Government’s submission on the draft EIS. There remains a concern about the proposed level of phosphorus discharge which need to be reduced from the level outlined in the EIS(0.3 mg/l) to levels such that the in-stream water quality of the receiving waters meet the ANZECC Guidelines. To achieve an in-stream water quality consistent with the ANZECC Guidelines the phosphorus concentration in the effluent would need to be significantly reduced to 0.03 mg/l. The table below compares the cost of providing reverse osmosis treatment (identified in the draft EIS) to a two-stage lime treatment process.

    Sewage treatment options

    The sewage treatment options for the proposed airport were inadequately dealt with in the draft EIS. The level of phosphorus discharge into South Creek was identified as a major water quality issue in the NSW Government submission on the draft EIS.

    The Supplement proposes that tertiary sewage treatment would be provided on-site for at least Stage 1 of the airport development. While the treated effluent would generally be re-used, there would be occasions during or following wet weather when treated effluent would have to be discharged to Badgerys Creek. The Supplement claims that the proposed sewage treatment plant (STP) would be able to meet the EPA’s requirements for the nutrient levels in effluent discharged to Badgerys Creek.

    The benefit-cost analysis (Appendix J1), however, assumes that the STP will be part of the external infrastructure, ie an off-site STP. In particular, the costings for the sewage treatment plant are based on the process proposed in the draft EIS. However, the STP proposed in the draft EIS would produce effluent with nutrient levels that would be too high to achieve in-stream water quality consistent with the ANZECC Guidelines.

    Sydney Water has provided estimates of the cost of an off-site STP with adequate nutrient removal to achieve in-stream water quality consistent with the ANZECC Guidelines. For Stage 1 of the proposal the STP would cost $30 million and the additional cost to increase the STP capacity for the master plan development would be $20 million.

    In addition, Sydney Water was requested to provide an order of costs for the provision of a sewer carrier and effluent reuse facilitates based on an off-site sewage treatment plant (STP) for Option 1 (Regional Infrastructure Report Second Sydney Airport Project, p.21). The order of costs are order of costs is as follows:

  • Sewer carrier (9 km 900 mm diameter) $11.75M million

    Effluent reuse pumping station (50 L/s) $0.4Mmillion

    Effluent reuse rising main (9 km 300 mm diameter) $2.53Mmillion

  • Recommendation

    The NSW Government recommends that the sewage treatment plant (STP) serving the airport incorporate significant reductions in phosphorus from that proposed in the EIS to achieve in-stream water quality that meets the ANZECC Guidelines. If the Commonwealth requires wastewater from the airport to be treated at a Sydney Water STP, then sufficient funding will have to be provided to meet the above costs.

    Health impacts

    The issue of PAH emissions is of concern to the NSW Government in relation to drinking water quality. The EIS predicts that Tthe level of PAH predicted in the raw water is would be up toaround 10 nanograms/litre. This represents a breach of the 1996 Australian Drinking Water Guidelines and exposure to PAH above this level is considered an unacceptable cancer risk for a population. Since around 70% of the Sydney basin receives its drinking water from Lake Burragorang, it is estimated that there would be an increase of 40 fatalities due to cancer in the Sydney area over 100 years if water treatment is not effective in removing the PAHs. this potential impact is of significant concern to the community. It is essential that the community is given a guarantee that water treatment processes can remove PAH. These impacts on drinking water would be greatest for Options A and B.

    The EIS claims that PAH attached to particles in Lake Burragorang would be removed by filtration at the Prospect Water Treatment Plant. However, the basis for this claim is a batch trial that did not involve PAH pollution and was conducted on the pilot plant for the Prospect Water Treatment Plant. There has been no on-line testing during day-to-day operation to verify the EIS claim.

    Recommendation

    If Before the Commonwealth Government decides whether or not to proceed with Option A or B an airport at Badgerys Creek, it should fund a trial using the pilot water treatment plant to test the effectiveness of the Prospect Water Treatment Plant in removing PAH pollution. In the trial, the pilot plant would be used to process water seeded with PAH contaminated particles under a range of varying flow and water quality conditions.

    During operation of the airportIf it is decided to develop the airport, the Commonwealth should fund a monitoring program to test the PAH levels in Lake Burragorang when the airport is operating and the efficiency of the Prospect Water Treatment Plan in reducing PAH levels in the water supply.

    The use of first-flush devices or filters for rainwater tanks has been recommended in the EIS to remove pollutants such as PAH. The use of first-flush devices has been recommended by the NSW Health Department in the past in an attempt to minimise contamination of rainwater tanks. The problem relates to the level of consumer education with regard to upkeep of rainwater tanks, which has been shown to be poor.

    Recommendation

    It is recommended therefore that the Commonwealth Government fund an education campaign in areas of high aircraft emissions and a monitoring program for the water quality in rainwater tanks. If it is not feasible to achieve acceptable water quality in rainwater tanks, the Commonwealth Government should fund the provision of reticulated water supply to residents who currently rely on such tanks for their domestic water supply.

    The EIS discusses reuse of treated sewage effluent for the purposes of toilet flushing, air-conditioning make-up, fire services and irrigation. There are currently no guidelines that stipulate standards to be achieved for the purposes of reuse of effluent for air-conditioning make-up, fire fighting services, or toilet flushing (on a basis other than residential occupation). Accordingly the Environmental Management Plan should specify the guidelines which are intended to be followed for this application.

    There is no mention of management practices that will be implemented for risk minimisation in relation to reuse of effluent. The storage ponds as specified could pose problems in relation to growth of blue-green algae, due to their open nature, the high nutrient concentration within secondary effluent, and high temperatures in the region over summer. Deep bed gravity sand filters have been specified in the process treatment train. The effectiveness of such filters in removing parasites such as cryptosporidium and giardia to the acceptable limit is questionable.

    The tertiary treatment for precautionary discharges to Badgerys Creek mentions the use of ultraviolet (UV) disinfection of the effluent. The effectiveness of UV disinfection is currently being investigated with a study under way at one of the Sydney Water Corporation sewage treatment plants.

    Recommendation

    The NSW Government recommends that the comments above be considered in the preparation of the Environmental Management Plan for the second airport.

     

    HAZARD AND RISK

    Aircraft crashes

    The NSW Government’s submission on the draft EIS criticised the lack of discussion of the possible impact of an aircraft crash on major water supply infrastructure or on major energy supply infrastructure such as power lines, major electricity sub-stations or the Moomba to Sydney natural gas pipeline. Although the Supplement provides further analysis concerning the risk of an aircraft crash into this infrastructure, the information provided concerning the possible consequences of a crash into water supply infrastructure raises significant concerns for the NSW Government. Each of the airport options would have major flight paths crossing the Sydney Water Supply Pipeline, which transports water from Warragamba Dam to the Prospect Water Treatment Plant.

     

    Technical Paper No. 10 estimated that the risk of an aircraft crash into the Sydney Water Supply Pipeline exceeds one crash per 1,000 years per square kilometre for the main flight paths for Option C. This is equivalent to an actual risk of just less than one crash per 10,000 years where the aircraft crash damages the pipeline. Although the risk would appear to be low, tThe consequences of such an aircraft crash into the Sydney Water Supply Pipeline would be the complete disruption of 70% of Sydney’s water supply. Although the other 30% of Sydney’s water supply would still be available, the rationing of water would have to be so severe that it would be intolerable.

    Recommendation

    The NSW Government is not prepared to accept the risk of such a water supply disruption. If the Commonwealth decides to develop the airport, It is proposed, therefore, that any sections of the Water Supply Pipeline that are exposed to a significant risk higher than one crash per 10,000 years per square kilometre should be buried at least 3 metres underground. The Commonwealth Government should fund the cost of such work, which is estimated to cost:

    Option A - $91 million; Option B - $68 million; Option C - $114 million.

    Although the risk of an aircraft crash into other major water supply infrastructure is less,tThe consequences of an aircraft crash into other major water supply infrastructure could be as severe as a crash into the Water Supply Pipeline. Therefore, if the Commonwealth decides to proceed with Option A or B, it should ensure that the proposed flight paths are amended to minimise the risk of aircraft crashes into Warragamba Dam, Prospect Reservoir Dam or the Prospect Water Treatment Plant.

    Fuel supply

    In the draft EIS and the supporting technical reports, it was assumed that aviation fuel would be supplied to the airport by a pipeline and that this would be constructed as part of the Stage 1 development. The Supplement, however, includes an analysis of the hazards and risk of supplying fuel by road tanker for the Stage 1 development. This would require an average of up to 65 road tanker movements per day.

    The Supplement estimates that there could be between 3 and 5 road accidents per year involving fuel tankers. There would be a significant risk of fire in those accidents that resulted in rupture of a fuel tank. The main fatality risk for such events would be to other road users.

    While there is a discussion of the frequency of vehicle accident rates, no attempt has been made to quantify the risk of injury or fatality to other road users, either in absolute terms or in comparison to the base case option of supply of fuel by pipeline. This superficial analysis does not take into account higher traffic densities on the M4 than the alternative route, which could lead to greater fatalities notwithstanding the estimated lower crash rate. Further, without an assessment of the comparative risk between road and pipeline, it is impossible to judge whether or not the risk of transport by road rather than by pipeline is an acceptable alternative.

    The discussion of risk totally ignores the risk of environmental damage arising from fuel spillage. While the risk of fuel ignition is lower with aviation fuel than for gasoline, the risk of unignited fuel flowing into drains and environmentally sensitive areas would conversely be higher. For both route options, an assessment should be made of the risk of environmental damage from fuel spillage arising from accidents.

    Recommendation

    The NSW Government is opposed to the delivery of aviation fuel by road tanker in the quantities required for the Stage 1 development because of the potential hazard for other road users. It is recommended that a fuel pipeline to the airport should be constructed as part of the initial development.

     

    AIR QUALITY

    The information presented in the EIS does not allow precise quantification of the impacts of the proposal on air quality. In particular, the lack of data detailing the vertical structure of the atmosphere in Western Sydney remains the most significant impediment to estimating the potential impact on regional air quality. This was a key omission also raised by the independent Auditor.

    The EIS appears to underestimate the impacts of motor vehicle emissions, in particular, emissions of nitrogen oxides (NOx). EPA recalculations of emission estimates provided in the EIS indicate that the emissions of hydrocarbons, nitrogen oxides and carbon monoxide may be up to one third higher than those projected in the final EIS.

    Air quality impactsThe EIS estimates that the airport alone could generate up to 77,000 vehicle trips per day, with airport related development likely to generate significant additional traffic. This magnitude of traffic generation is greater than from any other single development in Western Sydney.

    Increases in air emissions from the proposed airport would be due largely to vehicular movements associated with its operation and from local traffic using new roads for non airport associated travel (induced traffic).

    The increase in vehicle kilometres travelled (VKT) is likely to present a serious, if not insurmountable pressure on VKT reduction targets set out in the NSW Government’s 25 year air quality management plan, Action for Air.

    Air pollutants, in particular ozone, nitrogen dioxide and particulates have been linked to a wide range of adverse health effects including heart disease, cancer, bronchitis and other respiratory problems. Increases in emissions are likely to result in increased hospital admissions, hospital attendances, restricted activity days and exacerbate the suffering of people with pre-existing medical conditions.

    The information presented in the EIS does not allow precise quantification of the impacts of the proposal on air quality. In particular, the lack of data detailing the vertical structure of the atmosphere in Western Sydney remains the most significant impediment to estimating the potential impact on regional air quality. This was a key omission also raised by the independent Auditor.

    Air quality impacts

    The EIS appears to underestimate the impacts of motor vehicle emissions, in particular, emissions of nitrogen oxides (NOx). EPA recalculations of emission estimates provided in the EIS indicate that the emissions of hydrocarbons, nitrogen oxides and carbon monoxide may be up to one third higher than those projected in the final EIS.

    Regarding specific air pollutants, the EIS admits to a 6% increase in emissions of oxides of nitrogen (NOx) in the Sydney basin. This represents about half as much again as all current industrial emissions in the Sydney basin, which would need to be accommodated by the airshed. This is a significant increase in NOx emissions and is likely to prevent the achievement of air quality goals set out in Action for Air and undermine the effectiveness of NOx reduction measures such as the NOx trading scheme, increased use of cleaner fuels, and improved transport choices. The proposal’s impact on total NOx emissions could also reduce the capacity of the airshed to accommodate other NOx emitting industry, thus restricting opportunities for economic growth in the region or forcing an acceptance that air quality in Sydney will have to deteriorate.

    Emissions such as NOx from vehicles and airport operations are precursors to ozone formation. Impacts from increased ozone concentrations are predicted to occur over large areas to the west and southwest which are largely unpopulated at present. Any future development in these areas would see a larger population affected by these increases.

    The final EIS shows that a large area will be affected by significant increases in nitrogen dioxide concentrations if the proposal proceeds. These results suggest that the number of days when concentrations exceed the health-based goal for nitrogen dioxide will increase. While it is understood that these are conservative estimates, it is still an area of concern for potential health impacts.

    The EIS assesses the impact of the proposal on concentrations of particulates less than 10 microns (PM10) against the health-based National Environment Protection Measure goal of 50 micrograms per cubic metre. The results show that there will be an increase in peak daily ground level concentrations of PM10 due to an airport and increased motor vehicle traffic. This will result in exceedences of the goal up to one kilometre from the boundary. This has the potential to impact on health of the population in this area as well as contributing to increases in particulate haze.

    There are also likely to be odour impacts from the sewage treatment plant on nearby residents due to its location on the border of the airport site.

    In summary, it is evident that an airport at Badgerys Creek would be a significant new source of air pollutants leading to increased exceedences, both in number and extent, of air quality goals including goals for ozone, nitrogen dioxide and particles (PM10). These impacts will be particularly experienced in western and south-western Sydney which already tends to be a receptor of polluted air from the Sydney region as a whole. If they were properly assessed the air pollution impacts would be likely to be significantly greater than the EIS reports.

    Recommendation

    Some of the above predicted impacts could be ameliorated by the provision of offsets such as a public transport system to the airport or funding for improved public transport systems within the Sydney area generally. To ensure that the proposal does not compromise the achievement of VKT reductions and air quality goals in Action for Air, the Commonwealth Government’s funding for the proposed airport should include provision for:

  • a heavy rail link between the proposed airport and the main Southern Line/East Hills Line by commencement of operation of the airport;

    a heavy rail link between the proposed airport and the Main Western Line by completion of the Master Plan development;

    a Western Sydney Orbital (incorporating a bus transitway) between Prestons and the M2, by commencement of airport operations; and

    provision of an aviation fuel pipeline by commencement of airport operations.

  • Health impacts

    Air pollutants, in particular ozone, nitrogen dioxide and particulates have been linked to a wide range of adverse health effects including heart disease, cancer, bronchitis and other respiratory problems. Increases in emissions are likely to result in increased hospital admissions, hospital attendances, restricted activity days and exacerbate the suffering of people with pre-existing medical conditions.

    Although the estimates of the impact of the increment in air quality now accords with international estimates of the impacts of air quality on health for most criteria pollutants, the EIS neglects to assess the impact of increased nitrogen dioxide emissions. NSW Health has however conducted a study in Sydney which demonstrates an 11% increase in asthma admissions for each 5pphm increase in NO2. Maps provided in the EIS indicate that as many as 500,000 people may experience an increase in ambient NO2 of at least 5pphm, which would result in a significant increase in the baseline asthma admissions for this population from 900/year to a maximum of 1000/year.

    Based on predicted levels of particulate increases the EIS estimates an increase of around 0.03 deaths per year. Additional hospital admissions per year for respiratory disease due to particulates are around 0.16. The EIS has not estimated the effect of increased particulate pollution on cardiovascular admissions, but it would be of a similar order of magnitude.

    Thus, overall the impact on hospital admissions each year for respiratory or cardiovascular disease could range from an increase of two to around 100, depending on the population-days exposure to the elevated nitrogen dioxide emissions. Each admission can be assumed to cost NSW Health around $6000, so the total cost to the health service could be as high as $600,000 per year.

    The EIS also predicts an increase in health effects due to sulphur dioxide of one additional admission/ year and one additional death each 2 years. Furthermore, the EIS predicts an increase of 9 extra cases of cancer per 100 years due to the impact of benzene in the air in the vicinity of the airport.

    There will also be a greater number of residents, especially those with asthma, who will experience an increase in episodes of breathlessness and wheeze, and miss more days from school and work, due to the increase in air pollution from the airport. Of particular note, in the extreme vicinity of the airport, the town of Luddenham, and particularly the public school there, will be subject to exceedences of National Environment Protection Measure goals for nitrogen dioxide, fine particulates and air toxics. The Supplement does not provide adequate information on the possible frequency of these exceedences of air quality goals, but it is essential that the air pollution levels in areas adjoining the site are monitored regularly during operation of the airport.

    Recommendations

    If the Commonwealth Government decides to proceed with development of the airport, it is recommended that Commonwealth funding be provided for regular air quality monitoring for areas in the vicinity of the airport, in particular those areas that the Supplement predicts would be exposed to levels of nitrogen dioxide, fine particulates or air toxics that exceed the NEPM goals.

    The EIS states several times that no literature is available to demonstrate the health effects of imposing new sources of air pollution on a population. The health impacts of noise are also poorly documented in the literature. Funding should be made available to NSW Health to conduct a prospective, controlled study on the health impacts of noise and air pollution. It is estimated that the budget for such a study would be $500,000.

     

    Economic evaluation

    While some attempt was made to quantify air-related health impacts in the Supplement, these impacts were not valued for the purpose of including in the benefit/cost analysis. In this regard, economic analysis of the proposal overlooks its significant health costs to the community.

    The benefit cost analysis estimates that up to 5 additional premature deaths each 100 years may occur as a result of increased air pollution due to the operation of the second airport. The NSW Government considers that the EIS underestimates the total cost impact as the predicted number of premature deaths appears far too low, especially given the recent studies on the mortality effects associated with particulate pollution in Sydney (Morgan 1998, Simpson and London 1997).

    The EIS itself predicts 65 additional premature deaths each hundred years due to the impacts of air pollution from the airport, if premature deaths due to increased sulphur dioxide levels are included. In addition to this, a further 40 premature deaths from cancer could occur if the PAH contamination of Lake Burragorang cannot be rectified by the Prospect Water Treatment Plant.

    The EIS estimates the value of each premature death at $5 million (based on Viscusi 1993).

    The NSW Government estimates, therefore, that the community costs due to the airport from premature death as would be a minimum of $325 million over 100 years.

     

    TRANSPORT

    It is clear from the technical studies undertaken as part of the EIS that the proposed airport could only operate successfully if there were major investment in land transport infrastructure that connected the airport into the regional transport networks. Furthermore,

    Furthermore, if the Commonwealth decides to proceed with an airport at Badgerys Creek, it would be fundamental that a rail link be provided to the airport from commencement of airport operation, together with supporting road-based public transport measures (e.g. bus transitways) in order to meet NSW air quality and travel demand management objectives.

    The Supplement fails to acknowledge that responsibility for funding the identified airport related road and rail improvements should rest with the Commonwealth Government, together with responsibility for roads assumed to be in place, such as the Western Sydney Orbital.

    There would be serious financial implications for the NSW Government in completing construction of a rail link in time for commencement of second airport operations based on the timeframe of 2006. Action for Transport 2010 contains a number of major rail and road infrastructure projects over that period, for example construction of the Parramatta Rail Link is also due for completion in 2006 and a number of other major construction projects would be under way.

    Phasing of development and impact on infrastructure and services

    The Supplement states that, due to the range of airport configuration options and air traffic operation variations, the ability to make detailed assessments of associated infrastructure and network improvements required to support the second airport is constrained.

    Further, the Supplement states that it would also be possible to develop the airport to Stage 1 (ie accommodating 10 million passengers per year) in a number of phases to reflect the rate of air traffic growth. This raises another level of uncertainty with regard to the viability of provision of a rail link from commencement of airport operation:

  • The early provision of the rail link is crucial to achieving a higher use of public transport, especially by airport employees, and the associated reduction in Vehicle Kilometres Travelled (VKT) and reduces air pollution.

    State Rail has indicated that that, in order to improve the financial viability of a rail link to Badgerys Creek at commencement of operation, a mode share target for rail of 25%, supported by associated travel demand measures, should be sought as opposed to the 16% estimated in the final EIS.

    Rail passenger services to Badgerys Creek may face abnormal operational losses during the 15-20 year ramp up period to full capacity and potentially the ramp up to Stage 1 operation. Current CityRail fare scales would provide revenue of $7.5 million or an operating loss of $33.7 million, which is a farebox return of 18 cents in the dollar on operating costs.

    The final EIS takes a simplistic view on the role that an airport operator might play in funding a rail link. Experience suggests that an operator would be unlikely to provide substantial funding without applying associated fares, which would not be conducive to achieving mode split targets.

  • Recommendation

    The NSW Government recommends that, in order to achieve air quality objectives and VKT targets, it is essential that a rail link be in place from commencement of airport operation, regardless of staging of airport development. If the staging of airport development will adversely affect the demand for rail passenger travel, it is recommended that the Commonwealth Government fund any shortfall in operating revenue, in addition to the capital costs.

    Travel demand management

    The Supplement acknowledges NSW VKT targets, through Action for Air and Action for Transport 2010, to constrain private vehicle use and addresses the role of rail and road-based public transport (including transitways) in reducing private vehicle use.

    In discussing management of vehicle demand in the Supplement, the measures of limiting car parking supply for employees and appropriate pricing of short and long stay parking are suggested.

    Recommendation

    The NSW Government’s position is that the Commonwealth Government will need to prepare a travel demand management plan which aims to maximise the mode split to public transport. The conflict between the allocation of car parking spaces at the airport (and the revenue these facilities generate) with the commitment to reducing the impact of traffic on Western Sydney will need to be managed as part of that plan. Measures for reducing VKT, such as active and extensive control of car parking for employees and travellers/ meeters/ greeters and promotion of the airport as a public transport preferred destination, should be required by the airport operators.

    The Supplement also considers the role of road-based public transport, particularly in the absence of a heavy rail link. In particular, it considers the integration of the Liverpool-Parramatta Transitway with a bus-based public transport system serving the airport.

    Recommendation

    The NSW Government’s position is that it is fundamental that a heavy rail link be in place at commencement of airport operation. However, it will also be essential that appropriate bus priority measures, including bus lanes where necessary, be provided on all major airport access roads to benefit local, regional and airport bus services.

    Alignment of the rail link to Badgerys Creek

    The final EIS includes the two alignments to the SSA previously detailed in the draft EIS, ie from Glenfield to Badgerys Creek via Rossmore (20km) or via South Creek Valley (25km). Further to submissions from Liverpool Council, an additional alignment partly co-located in the proposed Western Sydney Orbital (23km) was discussed (see attached for alignments).

    At this stage, the NSW Government considers the WSO alignment to be the least preferable of the three options. One reason is that the adoption of this route appears to duplicate the provision of public transport in the Hoxton Park area, given the development of the Liverpool to Parramatta Transitway. Furthermore, the WSO alignment would not offer such flexibility in train operations at Glenfield as the other two alignments.

    A major issue in selecting the rail alignment will be the extent to which the noise contours of the airport options would sterilise potential urban development along these routes. The noise modelling and contour maps within the EIS indicate significant impacts on potential development areas under the Option C runway alignment and during operation of the Option B cross runway.

    Recommendation

    The NSW Government is not in a position to recommend a preferred rail alignment and potential station locations until further detailed investigation. However, the WSO alignment is the least preferred option at this stage.

    If the Commonwealth decides to proceed with the airport, it will need to fund further studies to allow finalisation of the rail alignment from Glenfield to Badgerys Creek. Furthermore, the Commonwealth will need to provide funds for land acquisition for the selected rail corridor as soon as it is finalised.

    The EIS has discussed the long-term possibility of extending the proposed Glenfield-Badgerys Creek rail line to connect to the Main Western Line near St Marys. Although it is estimated that this link would cost about $310 million, it would not be required until the Master Plan stage of airport development. This cost is based, however, on a surface alignment and a corridor would need to be reserved within the next 3-4 years to avoid its sterilisation by private development. Land acquisition for this corridor is estimated to be about $50 million.

    Recommendation

    The Commonwealth will need to fund further studies to allow finalisation of the rail alignment from Badgerys Creek to the Main Western Line. Furthermore, the Commonwealth will need to provide funds for land acquisition for the selected rail corridor as soon as it is finalised.

    Rail services issues

    The Supplement states that it is outside the scope of the EIS to investigate rail operation issues. However, it does go on to address rail services and capacity issues in relation to operation of the rail link.

    There are extensive operational issues in providing appropriate rail service frequencies for the second airport, with financial implications for the Sydney rail network, which need to be highlighted for future financial analysis. These include:

  • impacts on capacity on existing lines, especially the East Hills and Cumberland Lines.

    the need for a CBD airport rail terminal and associated interchange facilities at Central due to insufficient track or signal capacity (compounded by station dwell times and increased pedestrian movements) at stations on the City Circle line - estimated cost: $35 million;

    further grade separation and track amplification to ensure operational reliability as a consequence of new services to the second airport.

  • Recommendation

    The Commonwealth Government would be required to meet the estimated capital costs of $590 million for associated rail network and service improvements to accommodate a rail link to the second airport.

    Estimated rail costs

    Table 1 indicates the forecast capital expenditure requirements for the construction of the rail line to the second airport.

    In addition, annual track maintenance, estimated at from $2.6 to $4.2 million annually (depending on the preferred airport option), for the proposed new line section would be incurred.

    Table 1 - Indicative Capital Costs ($Millions)

    Component SSA via South Creek SSA via Rossmore SSA via WSO

    Stage One

    SSA to Glenfield rail link 620 530 700

    Associated network and service improvements 590 590 590

    Total 1,210 1,120 1,290

    Masterplan

    SSA to Main Western Line rail link (including land acquisition) 360 360 360

    Grand Total 1,570 1,480 1,650

    Notes:

  • 1. Costs identified for the Glenfield to SSA Rail link includes the minimum infrastructure that will be required to commence services. The alignment via Rossmore is the cheapest of the alignment options to provide the base level of rail infrastructure that will be required.

    2. The associated network and service improvements item within Table 1 include potential capital costs that may be required as part of the SSA Line dependant on final operating plans and includes an SSA station, relocation of Glenfield station, a downtown SSA rail terminal, rolling stock and stabling.

  • Road network implications

    The EIS states that the cost of the 2006 and 2016 airport related road upgrades would be $550m (1997) out of a total $1.126b external infrastructure estimate. The suggested upgrade requirements and cost estimates are deficient in the following terms:

  • The traffic modelling has been undertaken on the assumption that specified road network improvements are in place by 2006. The most significant of these include the Western Sydney Orbital (WSO), M2 extension to Richmond Road, widening of Camden Valley Way, widening of Cowpasture Road and construction of the Werrington Arterial. Whilst the majority of the assumed road improvements are consistent with future RTA programs, three proposals are considered to be unlikely, are unfunded and compromise the accuracy of the modelling assumptions made in the EIS. These are the WSO, Camden Valley Way and the Werrington Arterial.

    The Werrington arterial is unlikely to be built by 2006, if at all, and should be discounted from the modelling. Similarly, the forecast upgrading of Camden Valley Way to four lanes by 2006 is unlikely as is the WSO (including the extension of the M2 Motorway to Richmond Road). Since these road improvements are not programmed, and are unlikely to be constructed by the State in the required time, the cost of bringing them forward must be added to the cost of road upgrades attributable to the airport.

  • In addition contradictory information provided in the EIS in respect of the WSO calls into question the accuracy of the transport modelling and therefore the adequacy of the required road upgrades identified in the EIS.

    Recommendation

    The Commonwealth Government should provide funding to bring forward the road upgrades that will be required to accommodate background traffic growth but are not programmed nor funded by the State. These include: Western Sydney Orbital, widening of Camden Valley Way and the Werrington Arterial (or another appropriate M2-M4 connector road, if required).

    The Commonwealth Government is also responsible for funding the airport related road upgrades required in addition to those above. The cost of these airport related road upgrades has been underestimated and should be reappraised by the Commonwealth.

    The required road upgrades should be funded and constructed in time for the operation of Stage 1 of the airport.

     

    Identified road upgrades

    Table 2 lists the RTA cost estimates for the identified airport related works in the final EIS. The total cost of airport related road upgrades (including construction of the WSO) has been estimated to be $2,259 billion (1999 dollars). This compares with the EIS estimate of $550 million (1997 dollars) for airport related road upgrades (excluding the cost of the WSO which is estimated at $860 million in the EIS). However, the EIS acknowledges that the costed airport related road upgrades are the "minimum" required to accommodate a second airport at Badgerys Creek.

    As mentioned above, the Supplement also considers the integration of the Liverpool-Parramatta Transitway with a bus-based public transport system serving the airport and is estimated at $170million providing for 17kms of dedicated bus only transitway.

    Conclusion

    The Supplement states that the financial analysis of the viability of the airport did not include external infrastructure costs, such as road and rail infrastructure, as the airport operator typically does not fund such infrastructure. It also states that determining the economic, operational and environmental viability of a rail link to Badgerys Creek is not within the scope of the EIS.

    This is still a significant failing in addressing the economic impact of the airport on the NSW Government. In addressing allocation of airport and related infrastructure, the final EIS concludes that a portion of airport-related infrastructure, including roads and transport, would be funded by the NSW Government.

    The Final EIS fails to acknowledge that responsibility for funding the identified airport related road and rail improvements should rest with the Commonwealth Government, together with responsibility for roads assumed to be in place, such as the Western Sydney Orbital.

    Table 2 - RTA Cost Estimates for Airport Related Road Upgrades ($ millions)

    Road Recommended Upgrade RTA Cost

    Roads required by 2006, only if airport built

    The Northern Road Upgrade and relocation of The Northern Rd (Bringelly Rd to M4) to 4 lanes 351

    Elizabeth Drive Upgrade of Elizabeth Drive (Northern Road to Wallgrove Road) to 4 lanes divided 268

    Bringelly Road Upgrade of Bringelly Road (Northern Road to Camden Valley Way) to 4 lanes 195

    Luddenham Road Construction of new 4 lane divided carriageway from airport to M4 192

    Connection of airport to the Liverpool-Parramatta Transitway Transitway along Elizabeth Drive and other nominated roads 170

    Total (Devonshire Road upgrade not costed) 1176

    Roads required to be brought forward to 2006 if airport built

    Western Sydney Orbital Construction of 4 lane motorway (M5 to Elizabeth Drive) 340

    Western Sydney Orbital Construction of 4 lane motorway (Elizabeth Drive to M2) 650

    Werrington Arterial (or other appropriate north-south link) Construction of 4 lane divided road between the M2 and the M4 100

    Camden Valley Way Upgrade of Camden Valley Way (Bringelly Road to Hume Highway) to 4 lanes 86

    Total 1176

    Required by 2016, only if airport built

    Elizabeth Drive Upgrade of Elizabeth Drive (Northern Road to Wallgrove Road) to 6 lanes 77

    Grand Total 2429

     

    ECONOMIC ISSUES

    Cost and funding of off-site infrastructure

    Cost

    The EIS understates the total cost of off-site infrastructure necessary for the airport, and in particular those infrastructure items normally provided by the State Government.

    The figures stated in the EIS total $691 million in off-site infrastructure for Stage 1 of the Airport’s development, ie an airport capable of handling 10 million passengers per year. An additional $435 million would be required for the ultimate master plan, capable of handling 30 million passengers per year (see EIS Table J1.5). Of those figures, $650 million of infrastructure required in Stage 1 is infrastructure that would normally be provided by the State. An additional $430 million in State-related infrastructure would be required to service the ultimate master plan.

    NSW Government agencies which could be responsible for the provision of the off-site infrastructure have provided costings which total $3.7 billion to $3.9 billion to service Stage 1 development of the Airport. An additional $428 million upgrade would be necessary to satisfy the ultimate master plan. These capital costs are summarised in the attached Table 3.

    In addition, extra operational costs of $37 - 38 million per annum (principally rail operating revenue shortfalls) are anticipated for Stage 1. Additional operational costs for the ultimate master plan are of indeterminate scope at this time.

    The chief reasons for the differences in figures in the EIS and those in the attached table, are:

  • more detailed consideration of rail infrastructure costs in terms of the implications for operation of the whole rail network;

    a difference in timing and cost of roadworks. The latest figures reflect the RTA’s assessment of necessary roadworks to service Stage 1, based on the information contained in the EIS; and

    the inclusion in the latest figures of the cost of burying the Sydney Water Supply Pipeline, as disruption due to an aircraft crash is considered an unacceptable risk for the State to bear.

  • Funding

    The EIS states that funding of construction of the airport and related infrastructure has not been determined. However in the context of the Commonwealth Government’s policy to privatise the airports in the Sydney basin, "it is unlikely that the Commonwealth would fund an airport at Badgerys Creek purely from taxpayer revenue".

    Further, the EIS states "it is also likely that a portion of airport-related infrastructure would be funded by the NSW Government." "In addition, a substantial part of any NSW Government expenditure could be expected to draw on Commonwealth taxpayer funds made available through the Commonwealth-State grants system".

    However, the NSW Government is of the view that all the items of infrastructure identified are required as a consequence of the proposed airport. If the Commonwealth were to decide to develop Badgerys Creek Airport, then the State should not have to fund the necessary off-site infrastructure costs, both capital and operating, to enable the airport to function.

     

    Economic assessment of the project CONCLUSION

    The Final EIS contains a detailed benefit-cost analysis which is based on accepted methodological procedures. Its conclusion is that the order of magnitude of benefits to the community relative to total costs is of the order of 2:1, with a net economic benefit of between $3 billion and $4 billion Net Present Value.

    Although the approach taken to assess the overall net economic worth of the airport is considered reasonable, the EIS assessment of the overall net economic benefit of the Badgerys Creek Airport must be brought into doubt as a result of the more detailed costing of the off-site infrastructure necessary to enable the airport to function, particularly for the Stage 1 level of operations.

    The total cost of off-site infrastructure used in the EIS economic assessment for Stage 1 was only $691 million. The increase in off-site infrastructure costs of over $3 billion, as a result of updated figures, significantly reduces the overall assessment of net economic benefit.

    Furthermore, many important environmental and health impacts, in particular water and air quality impacts, were excluded from the economic analysis. For example, the proposal’s impact on total NOx emissions could also reduce the capacity of the airshed to accommodate other NOx emitting industry, thus restricting opportunities for economic growth in the region. As a result of excluding some environmental and health impacts, the benefit/cost analysis overestimates the net benefits of the airport.