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                                                              How Do They Get Away With It - Scam Revealed

Submission To The Moorabbin Airport 2015 Draft Master Plan

June 2015

 (Contact details withheld)

A.      The Master Plan And Review Process Is Derisive To The Civil Aviation Act 1988

1)      Both the 2010 master plan and the one currently being reviewed propose significant ongoing and additional environmental compromise.  Some of this compromise is crudely mapped with aircraft noise contours.  This compromise is a direct function of the volume and type of aircraft activity.   The objectivity, reliability and relevance of the mapping data and techniques which have been used have been repeatedly questioned.  

 2)      Specialists in the areas of environmental and social impacts of noise recognise the profound acute effects of aircraft noise pollution.  These sorts of issues are not covered in the Master Plan.  For example what consideration should be given to practical matters such as people’s homes vibrating when powerful helicopters fly overhead at low altitude numerous times each day? A dozen such noise exposure experiences will not register on an aggregated noise contour map but it is unconscionable to endorse such community experience.  Is there a critical number of times a person can be woken from sleep before there is diminished health and or psychological state?  Does repeated noise insult sensitise the community and make the perceived experience worse than the measured phenomenon, and so forth.  Such issues are not addressed by the master plan.

 3)      There is a grave risk of abuse of power and the creation of social inequity and genuine suffering and loss of amenity in the current scheme because the community does not have a legislated voice regarding how aviation impacts on the environment.  The voice is held by and filtered through aviation interests.  In addition there are no minimum standards of community amenity and or environment as far as the impacts of aviation are concerned.

 4)      The design of CASA and Air Services Australia operations around aircraft safety   (“Safe Skies For All”) misses the other potent aspect of The Civil Aviation Act 1988 - namely environmental protection.  The Act should be central to the consideration of an airport master plan and so should the environmental implications.

5)      Non compliance with the Act

 Civil Aviation Act 1988

9A  Performance of functions

(1)  In exercising its powers and performing its functions, CASA must regard the safety of air navigation as the most important consideration.

(2)  Subject to subsection (1), CASA must exercise its powers and perform its functions in a manner that ensures that, as far as is practicable, the environment is protected from:

(a)  the effects of the operation and use of aircraft; and

 (b)  the effects associated with the operation and use of aircraft.

The Act states that once aircraft safety has been attended to there is a requirement to protect the environment.  It is not suggesting that the environment only becomes a consideration after both aircraft safety and aviation interests have been attended to.

6)      The Act does not suggest that airports and aviation can plan for expansion and then conveniently claim that safety and practicability preclude protection of the environment.  At present, the words “as far as is practicable” are being applied after changes which impact the environment rather than before the changes.  This is a seriously flawed execution of the Act.  To double the volume of aircraft at Moorabbin and then suggest that as far as practicable the environment is being protected, mocks the Act.  The writer believes the current interpretation of the Act is in fact illegal; probably negligent and that’s aside from obvious issues with ethics and probity.

7)      Clearly the CASA tagline is misguided and incomplete as is the management of aerodromes.  The Act requires “Safer Skies For All and Environmental Protection For All”.  The “all” in environment protection is a very potent everyday consideration for many thousands of people who live within the environmental shadow of the airport.

8)      Why is there nothing in the Air Services Master Plan guidelines requiring the consideration of these greater environmental issues?   How can aerodrome leasees be allowed to claim they have no control over what happens when aircraft leave the ground and yet make recommendations for increasing activity? How can government let the leasee make the recommendation for increases and then assert that it is simply sanctioning an existing mandate?

There are other issues too.  Aircraft using the Moorabbin Aerodrome are not required to adhere to specific flight paths.  For example, the writer has data showing VFR approach routes which look nothing like the CASA recommendations for that area of the Melbourne Basin.  What does this say about the reliability of noise exposure mapping from a chronic and acute community perspective?


B.      Largely Unregulated & Undefined Activity Is Unsustainable, Unfair And Dangerous

1)      There are many issues associated with aviation at the Moorabbin Airport which are not transparent by virtue of the necessary information not being readily accessible to the public and because industry flaws tend to be  shielded by the self interest.  This is typical of self management in any industry.  For example it is almost impossible for a member of the public to cause appropriate sanction for breaches of aviation regulations.  It is hard to acquire substantive data even if an event has been witnessed.  There are practical limitations like not being able to read aircraft markings or difficulty identifying aircraft type and so forth.  The paucity of issued aviation sanctions is not an indication of the impeccable standard of pilots as much as it is a lack of enforcement.  A laissee-faire attitude such as this is not suited to increased activity at the Moorabbin aerodrome which already has a poor safety record.

 2)      Webtrac which maps aircraft movements is touted as an information source for the community but it requires aircraft to use their transponders.  The writer estimates that as much of 70% of the aircraft movements at Moorabbin do not involve use of transponders moreover while AirServices Australia champions the service, CASA does not endorse it and  refutes public submissions which refer to it.  

 3)      Another issue relating to the lack of use of transponders by aircraft at Moorabbin concerns the  movement of aircraft from class D to class G airspace.  It is recommended that transponders be used in such a movement.  In practice this seldom occurs. Coincidentally such a transition point coincides with the recent aircraft crash into a Chelsea home.

 4)      There has been a noticeable increase in multi-engine fixed wing aircraft and helicopters at the Moorabbin aerodrome.  These are loud, imposing aircraft and they fly low in the airport control zone and along the coast.

 5)      There is a lack of sensitivity on the part of certain operators such as the operators of “war birds” and other loud and sometimes fast aircraft which do not moderate their speed or throttle in and around the aerodrome.

 6)      There are no standards for specific impacts on sensitive local resources.  For example the use of the coast and the highly sensitive recreational beaches and parkland areas for aircraft sightseeing and joy flights.

 7)      Formation flying is still practiced in the Moorabbin control zone.  A control zone by definition is a more hazardous area and formation flying is a more hazardous activity.  Moreover there are designated areas away from the control zone for such activities.  (Letter from resident )

 8)      There has been an increase in night time activity to and from the airport.  It is not appropriate to wait until this is intolerable to implement appropriate planning.  The negative effects of industrial noise on human rest and quality of life is well documented. 

9)      Because the aerodrome is located close to the coast and because aircraft can fly low over water, there is a propensity for some operators to fly low from the aerodrome to the coast. 

10)   There has been an increase in aircraft circling the control zone in order to attain altitude.  It is assumed this is for some sort of recreation.  Such activity creates a drone over a vast area for an extended period.

11)   The jet aircraft activity at Moorabbin has increased and there is a “slippage” of this activity routes over more sensitive areas.

12)   There is already significant congestion in particular areas such as the training circuits and the coastal route to and from Carrum.  These routes should not be expected to tolerate more activity.

13)   A fly neighbourly program exists but it is not taken seriously.  It is regularly cited as a contribution to the community but this is patronising and smokescreens the need for a real initiative with proper application and meaning.  To quote recent correspondence from Air Services Australia – they [pilots] don’t ignore it, they just choose not to comply with it.

14)   There is serious question about the ethics of an industry which plans its activities knowing that people will tolerate levels of risk up to 100 times (i.e. two orders of magnitude) above the level that they consider acceptable before they will assess a situation as dangerous enough to require some corrective action.  (Aeronautical Study of Melbourne 2011)

15)   Where in the master plan is there reference to the likely 17 fold increase in aircraft collisions caused by activity increases from 100,000 movements to 500,000 movements?  (Review of Submissions To The Office Of Airspace Regulation On The Utility of GAAP Review Report, 2009)

16)   Where is the Moorabbin master plan put into context in terms of sensible alternatives which will reduce community imposition.  For example aerodromes like Mangalore, Bendigo, Stawell, Edenhope, Warrnambool, Cohuna, and Latrobe which are currently used to train international commercial pilots.  This level of balanced discourse will not be evident in a master plan if there are self interests at stake and as such this is not constructive aviation planning.

17)   What are the implications of increased activity at an aerodrome where aircraft do not follow VFR guidelines such as the practice of aircraft ignoring the VFR guidelines for the Carrum approach route and instead flying over an activity centre and marine park?



C. The Plan Is A Contrived Public Relations Document For Economic Benefit  

If the master plan is to be taken seriously and it is not intended to be a self serving public relations exercise, and it wishes to make economic assertions, then those assertions should be balanced, substantiated and accurate.

What of the following:

·         The cost of aviation subsidies

·         The true cost of environmental & amenity impacts

·         Health economic Impacts

·         Net impact on existing business & employment in the area

·         Net impact on community asset values

·         Business impact for existing commerce in the area

·         Current & proposed use of the site versus efficient use of site

·         Proposed Jobs creation versus the most effective form of jobs creation from such a site.

·         Technical inconsistencies: projections using today’s dollars e.g. flight training is said to account for $50 million annually in exports today and is forecast to grow to more than $140 million over 20 years, what does this mean?

·         Lack of disclosure:  how will the airport operator profit from the master plan it has written?

·         Formation of the cogent arguments – how can the party with its hand in the cookie jar be given responsibility for the preparation of the plan

·         Transparency of data – how much of the data can/has been verified and why isn’t it made available for public inspection.

·         Real life:  The writer is personally aware of people who have been forced to sell their family home and leave the city in order to escape the environmental imposition of Moorabbin aviation.  Such an action is not taken lightly and is profoundly disruptive.  It also has significant direct and indirect costs. 

·         Planning overlays caused by the existence and evolving proposals of the airport continue to unfairly impinge on the economic rights and opportunities of the community and local business.



D.      Employment  Assertions Throughout The Document Are Contrived

The leasee is perpetuating assertions about its contribution to the sensitive issue of local employment possibly in an attempt to avert environmental worries.  It wants to take credit for a 5% contribution to local employment.  This is profoundly misleading.  Aside from construction contracts the leasee does not create significant employment; it erects empty buildings and manages an aerodrome.


1)      If the airport developments draw employees from other businesses in the city of Kingston, that is not an employment contribution, to the contrary it may be putting pressure on the viability of existing businesses and in effect threatening net employment in the city.

2)      If the airport draws white collar workers to leased offices like that of Simplot, it is not contributing to local employment, it is drawing already employed people to a new office situated at the airport.  Indeed many of these employees commute to and from the city of Kingston. 

3)      If the leasee as property developer builds an empty building shell and leases it to a business it is not creating employment when a tenant occupies that shell and runs its own business.

4)      If an aviation business locates at the Moorabbin Airport, more often than not, employment has not been created; it has been relocated from somewhere else.  To a large extent, aviation businesses have been shown to be unaffected by location.   

5)      If part of the purpose, justification or contribution of the property developer or the aerodrome is employment, then the employment opportunity cost of the current use of the site should be properly presented e.g. if the economic driver of the use of the site is the creation of incremental employment opportunities, then what is the real potential of the site, and what is the net employment opportunity cost or benefit of using the land as an aerodrome plus current style office and big box retail site?

6)      If leasee wants to champion its role or the role of the airport in contributing employment then its assertions need to be credible, informed, balanced and accurate; anything else is propaganda.

The non-employment business economics of the plan are also grossly misleading for many of the same reasons.


D.  The Need For A More Credible Planning Document

There is a requirement for more information and accurate and balanced information:

1)      A probity and discovery process relating to the activities and financial advantages and likely gains of the leasee/property developer

2)      A plan which looks at the activities, plans, costs, aviation investments and net benefits of the current and proposed aviation at the site in terms of both aviation and the environment.  The environmental aspect should meet the high standards that are applied to any important public environmental issue

3)      A reliable independent assessment of the quality of the plan arguments and submissions given that the document is inherently self serving.  Moreover it should not be the responsibility of a lay public to furnish the balancing arguments for the plan.

As a balanced and thorough planning tool for economic, airport management and environmental sustainability, the master plan fails.  There are numerous unsubstantiated assumptions and unreferenced data points, forecasts devoid of sensitivity analysis and an obvious bias toward the desired agenda of the leasee (Moorabbin Airport Corporation) which is also the author of the plan.

The document should be clearly sectioned into parts:

a)      airport and aviation management and investment

b)      full economic analysis and disclosure

c)        property development and business interests and disclosure of the leasee

d)       broader environmental sustainability and accountability