Melbourne Environs Safeguarding 13 Standing Advisory Committee

Request to be Yes heard?: Full Name: Narelle Di Toro Organisation: Corporation Affected property: Attachment 1: MMB_MAESSAC_Submission.pdf Attachment 2: Attachment 3: Comments: Please see attached.

Submission Cover Sheet

28 September 2020

Mr Lester Townsend, Chair Airport Environs Safeguarding Standing Advisory Committee Planning Panels

Dear Mr Townsend

MELBOURNE AIRPORT ENVIRONS SAFEGUARDING STANDING ADVISORY COMMITTEE (MAESSAC) SUBMISSION BY MOORABBIN AIRPORT CORPORATION

Moorabbin Airport Corporation Pty Ltd (MAC) is the airport-lessee company and operator of Moorabbin Airport. In 1998, pursuant to the major ’ privatisation process, MAC obtained a long-term lease over Moorabbin Airport from the Australian Government.

The inclusion of the Airport Safeguarding Guidelines as a reference document in the State Planning Scheme was an important and welcomed advance for safety and aviation. MAC supports the Terms of Reference of MAESSAC and the opportunity to provide input into its deliberations.

Moorabbin Airport

Moorabbin Airport is a general aviation flight training airport and typically the second busiest airport in Australia by aircraft movements. Aviation activities include flight training, aviation maintenance and limited freight and charter. Moorabbin Airport supports 7% of total jobs in the and has seen $350 million invested into the site over the past 20 years. An additional $300 million is planned to be invested over the next 20 years to 2040 in aviation and non aviation precincts. As a project, Moorabbin Airport is on par with the largest current project in the City of Kingston - the $700 million Level Crossing Removal project.

Seventy percent of the airport is bordered by urban uses and the airport has been recognised as a State significant investment and jobs centre for aviation, industrial, retail and commercial activities. The Victorian Government has invested into sub regional road network improvements including the Dingley Bypass and the Mordialloc Freeway. Moorabbin Airport is now a destination site in South East Melbourne with over 6 million visitations a year.

Master Plan

The Airport Master Plan is the statutory planning document that establishes the strategic vision for the airport, provides for the future use and development of the airport site, aligns site uses with local communities and details compliance with environmental legislation. The Master Plan covers a 20 year planning period and is revised every five years as governed by the Airports Act 1996.

The 2015 Master Plan (MP15) was approved by the Australian Minister for Infrastructure and Transport on 2 August 2016. MAC is preparing its next Master Plan, which must be submitted to the Minister for approval by 2 August 2021. MAC has successfully delivered the MP15 over the last five years including: • Safe aviation activity, with flight movements growing at 2.5% (pre COVID); • Pilots trained increased 55% from 800 to 1,250; • Airport safeguarding guidelines incorporated into airport planning and building activity • Employment increased 60% from 3,300 to 5,400; • Investment of $350m since privatisation and an additional $300m+ to 2040 • Environment targets established for fifty actions; and • Ground transport improvement delivered being three new intersections, 2km of new internal road and 1 new access point.

The 2021 Master Plan (MP21) will be the fifth airport master plan and continues the airport focus on delivering safe flight training, airport infrastructure and services.

Moorabbin Airport Corporation – ABN No. 94 081 564 310 Airport Management Centre, 66 Bundora Parade, Moorabbin Airport Vic 3194. T. +61 3 8587 8000 E. [email protected] Page 1 of 5

Key Safeguarding Matters

The Airport’s Safeguarding Strategy is set out in chapter 11 of the MP15. Section 11.7, titled “Improving Airport Safeguarding”, discusses deficiencies of the current safeguarding framework and recommendations for how it could be improved. We recommend that the Advisory Committee review the MP15 to understand Moorabbin Airport’s place in metropolitan Melbourne and its importance in the aviation context and the challenges it faces in terms of airport safeguarding.

Effective airport safeguarding policies and planning controls are essential for the airport to deliver its important aviation function and for the City of Kingston to deliver its City Plan. Key issues for Moorabbin Airport are outlined below.

National Airport Safeguarding Framework

The National Airport Safeguarding Framework (NASF) needs to be fully implemented into the Victorian planning system. NASF is currently referred to as a policy document under the Planning Policy Framework’s airports policy (Clause 18.04-1S). The policy reference, while generally supportive, can be strengthened by requiring “on the ground” planning assessments, including aviation impact assessments, both on and off airport.

MAC apply all NASF principles to on airport development projects, including windshear and turbulence, public safety areas (PSA’s) and lighting. NASF is implemented on Moorabbin Airport through planning conditions of the Airport Lessee Consent and requires applicants to justify proposals with comprehensive technical assessments. MAC methods have been replicated by other airports and held in high regard by aviation regulators. For example, the PSA benchmark adopted for Moorabbin Airport is based on an international standard from which MAC created an airport best practice standard that other airports have adopted.

MAC are seeking recognition of NASF in planning schemes, including explicit planning controls for each of the NASF guidelines. Development applications that are off airport and proximate to the Airport’s airspace, for example within the footprint of the airports controlled airspace, should be required to undertake comprehensive technical assessments as part of the planning process. These tools, guidelines and assessments should inform planning application assessments within the City of Kingston.

MAC recommends the NASF to be fully implemented into the Victorian planning system.

Overlays

The Kingston Planning Scheme (KPS) applies the Airport Environs Overlay control and Schedule 1 to the overlay (AEO1) to parts of the municipality. The KPS adopts the endorsed Australian Noise Exposure Forecast (ANEF) 25 contour, as it stood on 22 December 1999.

The MP21 contains an ANEF that adopts an “Ultimate Capacity” of 375,000 aircraft movements and will result in the 25 ANEF contour contracting over the airport site. This is a 25% reduction in movements and is driven by aviation safety and airspace limitations. MAC will work with the City of Kingston to refresh the AEO1.

While the Airport’s prescribed airspace is protected by the Airports Act and Airports (Protection of Airspace) Regulations 1996, this is not widely known or understood by developers, the community or other stakeholders. The Design and Development Overlay Schedules 4 and 5 (DDO4 and DDO5) within the Kingston Planning Scheme provide some limited control over the height of structures that may impact on the Airport’s prescribed airspace. However, these controls do not cover all of the airport’s Prescribed Airspace and are outdated due to changes to the airport’s protected airspace. MAC has recognised the DDO’s in the MP15 and has worked with the City of Kingston regarding safe development heights surrounding the airport.

Better implementation of Prescribed Airspace requirements into the Victorian planning system is required. Purpose built planning controls for airspace protection are required.

MAC recommends: • AEO1 boundaries are set based on the endorsed ANEF contours in the current approved Master Plan; Page 2 of 5

• Comprehensive consultation between airport operators and the surrounding city regarding changes to ANEF inputs and adoption of an agreed timeframe for newly endorsed ANEFs to be adopted within relevant planning controls and overlays; and • A consistent approach to prescribed airspace protection at Moorabbin Airport being implemented through the Victoria Planning Provisions to better achieve compliant proposals including with prescribed airspace.

Zoning and the Urban Growth Boundary (UGB)

The Moorabbin Airport site should be within the UGB. The airport is a heavily engineered urban site with medium density activity including aviation, industrial, retail and commercial uses. 5,400 jobs are based at the airport as at 2020, an increase from 600 jobs in 1999 when the airport was privatised. Regionally significant retail hubs in the north east (DFO, Kingston Central Plaza) and east precincts (Costco, Decathlon) are urban uses. Moorabbin Airport, Grange Road, Redwood Gardens and Braeside combine to form the largest industrial use precinct in the City of Kingston.

A legacy justification for including the airport outside the UGB was perceived additional airport protections. This approach was appropriate when the airport was on the urban fringe in the 1940’s. Locating an airport within a place of low density and agricultural uses is an optimal planning outcome.

Given that seventy percent of the airport’s boundary abuts urban uses and with the airport site being surrounded on three sides with major arterial roads, it is more appropriate for the airport to be within the UGB. is within the UGB. The fact that Moorabbin Airport site is located outside the UGB, and therefore in a Green Wedge, conveys the wrong message about the role of the airport site in the metropolitan context.

A key requirement for the airport master plan is the ongoing integration of the airport with surrounding uses which are predominantly urban. The $417 million investment by the Victorian Government in the Mordialloc Freeway 250m east of the airport, results in the airport being less physically integrated with nonurban uses.

Locating the airport within the UGB will provide greater clarity for off airport development proposals, remove perceptions of the airport as a low density site and emphasise the need for off airport proposals to integrate with airport zoning including the use of cranes off airport. This will drive safer outcomes and better protect the airport as the City of Kingston continues to grow and better inform stakeholders of the current “out of scheme” designation in the KPS.

MAC recommends Moorabbin Airport is located within the Urban Growth Boundary (UGB).

Zoning On Airport

Moorabbin Airport has been planned, including using safeguarding principles, around airport infrastructure and aviation functions being located in the middle of the airport. The built form within Industrial and retail zones provide a noise buffer to off airport uses. Future industrial warehouse developments in precinct 4 of the MP15 of will further shield residential areas to the east.

MAC recommends MAESSAC support for the airport layout because it delivers safeguarding objectives.

Noise Contours

In accordance with NASF Guideline A, the ANEF contours, as a source of aircraft noise information, should be supplemented by information from other sources, such as flight path charts and “number above” contours, to provide a more detailed and accurate reflection of the potential aircraft noise effects around Moorabbin Airport. This information, combined with the ANEF contours, should be used to better inform planning and land use decisions around the Airport.

MAC recommends current N60/ N65/ N70 contours should be used as an additional consideration over and above the ANEF contours and the AEO1, particularly when changes to zoning are proposed near the Airport or its flight corridors.

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Assessment of Proposals

Airport safeguarding is complex and the assessment of planning proposals near the airport requires specific information and technical knowledge. Near airport planning proposals sent to MAC to assess often lack adequate information to demonstrate compliance with airport safeguarding requirements such as NASF guidelines. Referrals to MAC should include specific information regarding compliance with safeguarding requirements.

MAC recommends improved planning controls and a Planning Practice Note for airport safeguarding would assist permit applicants to better prepare applications and City planners to assess applications near the airport.

Consultation

MAC has implemented a comprehensive stakeholder engagement strategy including regarding airport safeguarding.

Stakeholders include three levels of Government, regulators, customers, industry and the community. Forums include the Community Aviation Consultation Group (CACG), the Moorabbin Airport Planning Consultation Group (MAPCG), Commonwealth Department briefings and compliance meetings, Airport Emergency planning meetings and community events. MAC will continue to consult with stakeholders, the next major consultation being the MP21 public consultation to be held in the first half of 2021.

A challenging issue remains how best can airports provide information to the most noise sensitive people so they better understand that aircraft noise may impact them. Approximately 25,000 residents live under our controlled airspace in a 11km diameter area. Each year MAC receives approximately 75 noise complaints and fewer than 10 safety related enquiries (Airservices receive 90). The vast majority of these residents were aware of the airport, our website and aviation information and the flight training role of the airport when they chose to live nearby and rarely if ever communicate with MAC on safeguarding issues.

This indicates the work MAC is currently undertaking is effective and any further improvements delivered by the safeguarding framework will enhance outcomes for the community.

Conclusion

Airport safeguarding is an important outcome for MAC and its Stakeholders. The City of Kingston has major opportunities arising from near term, off airport large projects that will benefit from greater planning certainty. These projects include: • Level crossing removals $700m; • Mordialloc Freeway $417m; • South Road mixed use development $142m; • Hawthorn AFL Head Quarters $130m; • Surf & Play Aqua park Dingley Village $100m; and • Proposed Suburban Rail Loop.

Thank you for the opportunity to make this submission. I confirm that MAC wishes to be heard at the public hearing in early 2021.

Yours Sincerely,

Paul Ferguson Chief Executive Officer

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