How Do They Get Away With It - Scam Revealed
Submission To The Moorabbin Airport
2015 Draft Master Plan
(Contact details withheld)
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
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.
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
Non compliance with the Act
Civil Aviation Act 1988
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
(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.
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.
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.
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?
9) 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
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
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
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.
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.
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)
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)
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.
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
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
cost of aviation subsidies
true cost of environmental & amenity impacts
impact on existing business & employment in the area
impact on community asset values
impact for existing commerce in the area
& proposed use of the site versus efficient use of site
Jobs creation versus the most effective form of jobs creation from such a site.
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?
of disclosure: how will the airport
operator profit from the master plan it has written?
of the cogent arguments – how can the party with its hand in the cookie jar be
given responsibility for the preparation of the plan
of data – how much of the data can/has been verified and why isn’t it made
available for public inspection.
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.
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.
Employment Assertions Throughout The Document Are
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
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
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
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.
non-employment business economics of the plan are also grossly misleading for
many of the same reasons.
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
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
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.
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.
document should be clearly sectioned into parts:
a) airport and aviation management and
b) full economic analysis and
c) property development and business interests
and disclosure of the leasee
d) broader environmental sustainability and