Sydney Airport Community Forum Inc

PO Box 104, Summer Hill 2130
Tel/Fax (02)9953-8250 [Chair] (02)9798-9606 [Secretary]

24 May 1999 – Revised version

Denis White
Chief Executive Officer,
PPK Environment & Infrastructure Pty Ltd
9 Blaxland Street,
Rhodes NSW 2138

Dear Mr White,

Comparison of Badgerys Creek and Wilton
Potential Sites for Sydney’s Second Airport

Sydney Airport Community Forum Inc (SACF Inc) represents around thirty airport community groups from Randwick to the Blue Mountains, and from Hornsby to Sydney’s South-West extremities. It was established as an alternative to the government-appointed committee of a similar name which is not representative of the communities affected. SACF Inc is the peak community body in respect of airport matters, with other ‘groups of groups’, such as the Coalition of Airport Action Groups and the Eastern Coalition of Airport Groups, recognising SACF Inc as the community’s true ‘peak representative body’.

Last month, in response to the Minister for Transport’s public statements that he was aware of the results of your yet-to-be-completed EIS supplement, we put out a media release addressing some of our concerns with the corruption of process involved with the Badgerys Creek EIS. That document is attached.

Our member organisations do not believe PPK is capable of conducting an independent EIS as required by the Environment Protection (Impact of Proposals) Act 1974 (C’th) and its Administrative Procedures by virtue of the fact that your parent organisation is one of the largest private landholders in the environs of the proposed airport site, and hence your group of companies has a direct multi-million dollar interest in the outcome of the decision. Hence we believe that you are not independent. Furthermore, the fact that a number of key public sector positions regarding environmental management/control of the aviation industry within Sydney are filled with staff seconded from your organisation (rather than the technically independent public sector) further compromises your independence.

In 1984-5 the then Minister for Transport publicly announced that consideration of future airport sites for Sydney would henceforth be limited (from the larger number considered to that time) to just Badgerys Creek and Wilton. That decision and public announcement clearly put Wilton on the public record as the most feasible alternative to Badgerys Creek. In the opening paragraph of the Summary Draft EIS you acknowledge that "detailed environmental assessments" were done for Badgerys Creek and Wilton, though you elected to not explicitly advise of the formal short-listing of these two sites. But in any event it is clear that Wilton was the prudent and feasible alternative, and that such information was available to your firm at the time of the EIS.

As you know, the government and the 1997 EIS was severely criticised by the government-appointed auditor of the process in the following respects:

1. Failure by government to include sites previously short-listed by the 1985 EIS [eg Wilton];
2. Initial inclusion by government of the "red-herring" site of Holsworthy, which had ranked 7^th out of 10 in the 1985 EIS;
3. Failure by PPK to properly consider the following major problems in its draft EIS:
4. 1. Failure to state objectives clearly;
   2. Failure to discuss previously considered alternative sites from the 1985 EIS;
   3. Inadequate flight path forecasting for impact assessment having regard to the interactions with airspace of the other Sydney Airports;
   4. Failure to consider noise contours below 20 ANEF and the entire range of noise impacts according to the guidelines – which followed the Parer Report of 1995;
   5. Failure to employ an adequate Airshed model for prediction of air-quality effects;
   6. Under-estimation of airport hazard risk;
   7. Failure to address the cumulative impacts of support infrastructure on noise, risk and air quality in the Sydney Basin;
   8. Failure to properly assess the impact of not proceeding with Badgerys and the range and scale of its interactions with existing airports, especially KSA;
   9. Inadequate economic analysis.
5. The auditor also criticised the lack of co-operation it had received from the Department of Transport, which resulted in it having to proceed with less information than was available to PPK.

[Source: SMEC Auditor’s Report Jan 1998]

The larger size airport now being considered and the subsequent residential development of Western Sydney has made Wilton even more feasible in the 15 years which have elapsed since its formal equal ranking with Badgerys Creek. Further, as the air quality study promised at the time of the Third Runway EIS was never undertaken by the Federal government, we must rely on overseas information in respect of air quality issues pertaining to aviation. The knowledge gleaned over the past 15 years as to airports and their attendant ground transportation (ie effects considered as a whole) has highlighted that an airport is one of a city’s largest point sources of hydrocarbon emissions. This means that an outside-the-basin site is now even more critical than when Badgerys Creek and Wilton were ranked equal 15 years ago. Moreover, your Summary Draft EIS noted "Most respondents expressed the view that the Second Sydney Airport should not be located within the Sydney basin". This desire for an outside-the-basin site reflects a clear change in public opinion since the time of the earlier detailed environmental assessments (refer paragraph 1.3.25 of SMEC Auditor’s Report). Finally, the decision to have a very fast train route pass right past Wilton is a very pertinent infrastructure decision not known at the time of the 1984-5 studies, and again this knowledge (if it were to be appropriately considered by you) would tip the scale significantly in favour of an outside-the-basin site in the near Southern Highlands.

All of your work on the EIS for Badgerys Creek is to-date silent on the issue of a comparison of Badgerys Creek to Wilton, because the government of the day has instructed you as contractors to not consider Wilton, which is in the middle of the electorate of the Minister for Finance, John Fahey. The peak community group seeks your assurance that the attached comparison (in its entirety) of Badgerys Creek and Wilton will be included in your Summary Supplementary EIS, in accordance with your statutory obligations.

Clearly your work has simplistically compared Badgerys Creek to only a ‘do nothing’ alternative. Even a patently bad site proposal will compare favourably to the continued expansion of Kingsford-Smith airport. But clearly that is not the question an EIS is intended to address. The question is "Is this site proposed by the proponent the most suitable of all feasible and prudent alternative sites?" In this regard, a few sections of the SMEC Auditor’s Report are worth noting:

"23.2.1 The key requirements of the EIS Guidelines for the economic aspects were:

15. 15. 15. This lack of community confidence in the process can be attributed to:

• • the exclusion from assessment of other airport sites;…

1. 1. examine any feasible and prudent alternative to the proposed action;
   2. describe the environment that is likely to be affected by the proposed action and by any feasible and prudent alternative to the proposed action;
   3. assess the potential impact on the environment of the proposed action and of any feasible and prudent alternative to the proposed action;
   4. outline the reasons for the choice of the proposed action…"[emphasis added]

The question you address in detail - which runway configuration to use at Badgerys Creek - is only assisting the proponent with its planning. It adds nothing to the fundamental question of whether the project at Badgerys Creek stacks up against prudent and feasible alternatives. You state in the EIS that it is being done in accordance with the Act, yet you have accepted the proponent’s instructions as to which sites to not consider for comparative analysis. Your analysis to date is analogous to considering only the alternative of people having to keep all human waste inside their homes, when considering a particular sewage treatment works proposal/site. Your earlier work also considered a site at Holsworthy, as instructed by the government, even though this site was only ever ranked 7^th of possible sites. But even if that was a lame excuse then (refer SMEC Auditor’s Report paragraph 1.3.13), once the government ruled out Holsworthy, it made it even more nonsensical for you to fail to consider options the government of the day (indeed particular ministers) would prefer not be considered. It is not as if the relevant material was not available, as comparative work was conducted in the earlier studies. If one simply updated the census data relevant to the respective areas, one would be in a position to update the population impact, which is clearly one of the major determinants. The relative air pollution clearance attributes of both sites has not changed since the analysis of 1984-5 (though the overall level of pollution has) and hence it would be just as valid to republish these facts as to each site’s major attributes.

We believe you as the consultants have a moral and professional obligation under the Environment Protection (Impact of Proposals) Act and its Administrative Procedures to consider all feasible and prudent alternatives. Indeed the whole purpose of an EIS is to ensure that such alternatives as the government of the day may not wish to consider are considered, for reasons of public interest. The EIS process is meant to be the primary means of ensuring against governments making unsound environmental decisions. Your actions and printed material available to date paints your organisation as a willing accomplice to the government’s defective decision-making process, rather than as a protector of the public’s position.

The following summary of major points of differentiation shows that Wilton is a site that any proposal needs to be compared against in a proper EIS. Where there are valid metrics (eg number of people affected, relative hours of travel time), our group agreed to use the ratio of such metrics to derive a relative score for each site. For example with a 1:14 ratio of numbers of people affected, one site received a score of 1/15^th of 100, while the other received a score of 14/15^ths of 100. As you have not provided current population numbers affected for Wilton in your work, we have used the 1984 figures for relative population levels. Current figures would exacerbate the ratio, showing Badgerys Creek is now significantly more than 14 times worse than Wilton. However, we have used the 1984 figures in the attached analysis. The 1984 study shows Wilton as being only 15km further from the city by rail (assuming the 2015 network). This also may have changed, but without comparative figures, we need to rely on the last work done considering both sites, and have used the figures of 5,000 people-hours travel time for Badgerys versus 7,000 people-hours for Wilton. Since those calculations, the announcement of a Very Fast Train proposal changes this significantly. A VFT may actually deliver a shorter travel time from the CBD to Wilton (compared to the conventional rail track from the CBD to Badgerys). Accordingly, we believe the relative travel time figures of 1984 (as used in our analysis for conservatism) would be far less favourable to Badgerys if now updated to take into account present circumstances and presently proposed infrastructure.

With factors which defy direct metrics, we surveyed the representatives of our constituent group members (representing the whole range of Sydney’s airport community groups) to derive values from Excellent (100%), Very Good (80%), Good (60%), Fair(40%) and Poor(20%). This is actually a six-value ranking system, as there was the implicit potential value of ‘no value(0%)’ even though this was not used. We decided that it was not possible to use any greater precision, yet we believed it was very necessary (due to past/continuing obfuscation) to explicitly score the sites’ relative merits.

Before making any alterations to our work, please write to us with your opinions or suggested corrections or email them to me at me@mypostbox.com. If there is some error of fact, we are more than happy to correct it. However, the attached table must be included in the Summary Supplemental EIS, both because it is the comparative site summary otherwise omitted, and because it represents the final feedback of the peak community group on the issue of the Badgerys Creek EIS.

Yours faithfully

Graeme Harrison BE(Syd), BSc(VUW), MBA(Harvard), FAIM, MNIA, MIEAust, MACS, MIEEE, MAIE, MACM, MIREE, AMAusIMM, JP

Vice-President – New Airport Site Selection

cc: The Managing Director, Snowy Mountains Engineering Corporation

COMPARISON OF THE TWO HISTORICALLY SHORT-LISTED SITES

last update 24 Oct 1999

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