Submission on the Environmental Impact of Badgerys Creek Airport

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Submission on the environmental impact of Badgerys Creek airport.

Dr Anthony Green,

Visiting Principal Research Fellow, Microsimulation Risk Group,

University of Wollongong

17/12/15

EXECUTIVE SUMMARY

The Federal and New South Wales State Government have released a preliminary Environmental Impact Statement (EIS) on the operation of a new double runway class 1 airport by 2060. This follows a report in 2012 on the joint Study on Aviation Capacity in the Sydney Region and publication of preliminary plans for the new airport operation in 2014 together with the preliminary EIS for the proposed Airport.

This reports concentrates on the decision that an airport is actually needed within the Sydney Basin and the risks associated with siting this airport at Badgerys Creek which have not been adequately assessed within those documents.

The forecasts on aircraft flights were based on unrestrained projections. There is no interaction considered with other systems that would limit these forecasts. As a result all passenger numbers, aircraft movements and employment figures are over stated. Furthermore the loss to the economy from not building Badgerys Creek airport are not as great as stated and the cost benefit in building the airport is questionable. The unreliability of forecasts is demonstrated in the forecast for 2014 from 2010 which is 10% higher than the number of aircraft movements that actually occurred in 2014. KSA already has an additional 10% capacity compared to the forecasts.

The document also demonstrates that there was no cost benefit comparison with alternative forms of transport or with integrated transport systems. Since 42% of aircraft movements in 2014, were to Brisbane, Canberra, Coolangatta or Melbourne a cost benefit comparison of benefits and risks should have been undertaken involving integrated transport. While the paper did a cursory consideration of a High Speed rail link with a maximum speed of 320km/hr along the East Coast of Australia, it then dismissed it as being a different market rather than a full cost benefit comparison. It did not consider using an Ultrahigh Speed train system that has a maximum speed of more than 400km/hr. The faster train system will attract more passengers to make the switch from aircraft to train travel than the slower speeds. Furthermore the published costs of $B70 include the cost of rolling stock. Plans for Badgerys Creek cost benefit do not include the cost of aircraft. Thus any conclusions they draw between the two modes of transport are not valid.

A comparison of four scenarios for growth that includes Ultrahigh Speed rail show that the need for a new airport is not established until 2040 at the earliest (scenario 4) These four scenarios are the 2010 projection in the study, the 2014 actual figures projected at the same rate of increase as the study, the transfer of all East Coast passengers to rail and the transfer of 50% of East Coast travellers to rail. This latter scenario is likely to be conservative as experience in ultrafast rail internationally would suggest the take up is in the order of 60-70% based on rail speeds of 320km/hr and will increase to between 70-80% if the rail speed is increased to 400km/hr and would push out a need for an second airport to 2047.

The original study, however, did not take account of the uncertainties in sea level rise from climate change. CSIRO have estimated that the change could be as high as 1m by 2100, while scientists who study the collapse of the ice fields in Greenland and Antarctica give a range from 0.8 to 7m in the same timeframe. By 2040 with an Ultrahigh speed rail serving the East Coast, the uncertainties associated with sea level rise which will impact on the operation of KSA will have been resolved. A

2 more informed decision of siting a new airport can be taken that takes account of any population movement expected sea level rise over a lifetime design period of 100 years.

There is considerable benefit for Australia and NSW for fast tracking the building of an ultrafast rail line from Sydney to Brisbane and Melbourne that were not considered in the joint Study on Aviation Capacity in the Sydney Region. These benefits can be enhanced by parallel development of solar power to supply the energy for the trains and ultrafast Internet optical fibre along the rail corridor to allow job creation in the cities along the routes.

The travel times between centres will be similar or less than current air travel times and the experience in Europe with such services show that more work can be accomplished and it is more comfortable while being of similar cost to air travel.

A significant proportion of fast freight can be integrated into this rail network. A significant proportion of air freight is for the domestic market and destined for the major cities. All of this can be carried by Ultrahigh Speed train as the capacity per flight is limited and this type of containment can easily designed into the rail system.

The building of the train track requires specialised steel products for the track and the catenary wires. This could revitalise steel making in Western Sydney through local firms using Australian Iron ore or recycled product. (It does not have to go to China and back). This strategy also reduces the footprint of pollution emission and produces job opportunities in Western Sydney.

It can kick start a solar power industry in Australia using all Australian minerals and Australian expertise in this area. Four rows of solar panels is probably the maximum number of panels that would easily fit along the rail easement and would supply power back to the grid equivalent to half of Mount Piper Coal Fired power Station assuming 90 trains operate. The development of such a solar power industry in this country has the benefit of moving to a low carbon economy and has the potential for high exports while maintaining high employment.

Centres such as Goulburn, Albury Wodonga, and Queanbeyan would become viable growth centres relieving some of the pressure on Sydney and Melbourne. Parallel development of ultrafast Optical fibre links can build computer based industries in these growth centres.

In conclusion the need for building of a second Sydney Airport at Badgerys Creek has not been established and is not an option if NSW is to properly move to a low carbon based economy which is resilient and sustainable. It should be noted that the economics of the second airport proposal do not take account of CO2 production which is considered a pollutant and is not costed into any market economic model. This lack of basic accounting principles leaves the public to pick up the cost of damage rather than the investors and corporations who create the damage. The monies set aside by government or by private investors would be better spent at less risk in building ultrafast rail and solar power technology. This provides at least three different income streams which will pay for itself with higher returns on investment than an Airport.

The EIS purported to undertake a risk assessment of building the airport at Badgers Creek. There were, however, serious deficiencies in the method chosen that does not align with world’s best practice.

An airport is a major hazard installation in the same way as oil refineries or large Dangerous Goods stores. Aircraft are flying bombs particularly when fully loaded with fuel, and can impact on society in a variety of different ways, that lead to economic loss, death and injury and loss to society and the environment. As such there is a requirement that the benefits to the community outweigh the risks involved in the development of the airfield and this requires a risk framework that is commensurate with ISO35000; the international risk standard. There are a number of major deficiencies in the scope of this report that has resulted in an unreliable estimate of risk and impact on the major population centres of Western Sydney. Generally the risk in the EIS is only considered as a health and safety risk not as an economic risk or loss of social and natural environments.

There is no evidence in any of the planning or EIS documents that the full spectrum of risks have received proper consideration. There is also a failure to ensure this process includes alternative sites and scenarios where High Speed rail is part of the mix of opportunities. Reliance on previous studies for some of the impacts that are possible is not appropriate because the class of aircraft, their maximum thrust, cargoes and fuel loads are different from twenty years ago. There is also a failure to use the design capacity as the basis for the assessment of risk and there is little assessment of the interaction between the different phases of flight and the local environment which can lead to significant loss of life and utility in Western Sydney. In particular any loss arising from human behaviour is excluded from the study. These include deliberate acts such as terrorism, pilot suicide or accidental behaviours involving the interactions between Air Traffic Control, the designated flight paths and individual aircraft that can all lead to aircraft crashes. Consequently there is no discussion of the impact from such events.

A technical risk assessment for a second airport has to show that there is a net benefit to the community not the operators by demonstrating there is a reduction in risk to the community from the new airport together with other scenarios involving Ultrahigh Speed rail compared to continued operation at KSA. This involves setting criteria for a tolerable level of risk to the society and community commensurate with site and the land use surrounding the site together with a demonstration of a net benefit to the community taking account of any sudden shocks caused by the operation of the airport. This has not been done in the EIS or previous planning documents.

This type of risk assessment therefore requires a comparative study of the risks that includes KSA operating under different scenarios including taking account of sea level rise and implementing an Ultrahigh speed rail for 2030 with and without an alternative airport operating. A second airport risk assessment should use the stated design of 460,000 aircraft movements in 2060 and be compared on a like for like basis with airports outside of the Sydney basin such as in the Goulbourn district or one of the existing airports at Canberra or Newcastle all connected to Sydney by Ultrahigh Speed rail. There is no evidence that these comparisons have been made in any of the documents.

The risk methodology that has been used for the decision to build an airport is not consistent with modern good practice. The data on which the risks have been assessed from commercial failure, to locking of land use by the proposal, job creation from alternative strategies and economic stimulation as well as the impacts on the natural environment have not been analysed in a consistent way that is applicable to this complex environment.

4 to say the system being analysed is considered independent of other systems and there is no risk feedback from the other systems into the system being analysed or which amplify knock on effects into society. While this approach allows one to describe risk in terms of likelihood and consequence on a continuous spectrum, it is totally inappropriate in complex systems where different systems interact with each other and catastrophic outcomes can occur from these interactions.

In reality, this is a complex problem involving the economy, population growth, jobs availability, alternative land use, transport options, energy and water usage, and climate change. These systems all interact having feedbacks between them. Because they are not dealt with in a consistent framework typical of dealing with “wicked” problems, the case for building the airport in the first place has not been established.

An analysis the spatial relationship between the proposed flightpaths in the two modes of operation for 2060 and the current infrastructure critical for Sydney’s lifelines show there is a concentration of lifelines around the eastern creek area making it particularly vulnerable to any aircraft crash. Potential impacts includes the water supply, gas supply and electricity supply for Sydney. It will also include the fuel supply for the airport if it uses the Eastern Creek easement for the 330KV electrical supply. If this pipeline is moved west and crosses commonwealth land then the vulnerability to the Defence to the munitions site is increased. Within this area are also the dams at prospect reservoir and Warragamba and the water pipes lines and treatment plants holding major stocks of Chlorine between them. In addition a natural gas pipeline at 6900kPa pressures runs from Wilton to Horsley Park and then to Plumpton. Although the pipeline is underground it does surface at Horsley Park where there is a metering station. Also within this area but further to the south east is the Lucas Height nuclear medicine and nuclear storage facility.

The risk to these infrastructures and the subsequent impacts are not discussed. Furthermore acts of pilot suicide, terrorism and other behaviours by ATC have been specifically excluded from the study. These behavioural acts substantially increase the risk on these facilities. While past studies for example on Warragamba Dam and Lucas Heights have occurred, their risks have not been assessed in terms of the modern aircraft fleet or from deliberate acts.

The Eastern Creek electrical substation supplies about 25% of Sydney’s electricity supply, mainly to the industrial complexes around Eastern Creek, Prospect and Saint Marys as well as residential properties. The substation has a number of transformers that cannot be replaced within two years if they are all taken out in a single event such as an aircraft crashing or being flown into the site.

The loss of this facility would have an impact on Sydney’s GDP over a 2 year period because of the delay associated with replacing all the transformers on the site. The GDP for Sydney is of the order of $B320 per annum. The potential loss in one incident is therefore in the order of $B160 from loss of trade and this does not take account of the loss of jobs, family hardship and compensation that such a catastrophe would cause.

The duel water supply pipeline between Warragamba and Prospect passes within 400m of the Eastern Creek Electricity substation. Not only can it be taken out independently but also with the loss of the Eastern creek electricity substation. This would add to the social cost of loss for Western Sydney.

The flight paths fly directly over both Warragamba and Prospect reservoir within the normal angular spread of flightpaths. The impact of larger aircraft with higher thrust, compared with 1995, will collapse the earth embankment at Prospect and is likely to beach the dam wall at Warragamba. Modern aircraft can easily have an energy 50% of the dam buster bombs used in the Second World War to destroy the Ruhr dams but have at least 1000 times the momentum. Previous studies involved accidental crashes and not deliberate flying to cause damage. This poses a problem as the response by ATC and the RAAF from Williamstown airbase are two slow to stop this type of deliberate act. Flights from other airports such as KSA do allow enough time for a response to this type of threat.

Breach of the dam wall at Warragamba can result in water emerging at the end of Glenbrook Gorge in the order of half the Dam wall height if the Dam is near capacity at the time. This is approximately 70m in height some 2.5times the maximum ever observed at Penrith from flooding. The current population in Penrith, Hawskesbury, Blacktown and Baulkham Hills LGAs is currently 780,000. A conservative estimate of the number of people at risk from a collapse of the dam is approximately 350000 and may well be higher. The problem with this scenario is that the evacuation routes that are available in a flood are not available for this event and the timescale on which evacuation starts to occur is too long compared with the speed of rise in the waters. It is very likely that the number of deaths would tend toward the level of at risk population. In 2060 the population is expected to double increasing the number of people at risk and the subsequent death toll.

In addition Sydney will have lost its water supply.

Rupture of the gas pipes at the metering station at Horsley Park by an aircraft would cause a release which may not ignite immediately. A 10 tonnes vapour cloud would be able to form within a few minutes due to the pipe pressure and diameter which if ignited would cause damage within a five kilometre radius. This radius include the electrical distribution station and the chlorine plant at Prospect reservoir. This is another cascading impact.

A previous study on the impact of aircraft accidents on the nuclear reactor by CSIRO determined that it would survive such a crash, it was undertaken 25 years ago with a different aircraft mix than that proposed for this airport. Deliberate acts were not included in that assessment. Given that the site is now a repository for midlevel radioactive isotopes, there is no information in the public domain on whether an aircraft impact can disperse these isotopes into the atmosphere.

The waypoints for landing for both the one runway and two runway proposals are over the world heritage listed Blue Mountains. Aircraft crashes can lead to bushfires and bushfire can lead to aircraft crashes. The area of debris from a crash is likely to start large unconstrained bushfires that over summer can run before the wind (the area is prone to hot consecutive days of Strong North Westerlies) and cause extensive damage. The resident population at risk is 79700. A large bushfire in summer can travel the distance between Blackheath and Glenbrook in 2 hours if there is a strong North Westerly or Westerly blowing potentially affecting 80% of these residents.

There is very limited data on the number of cargo flights that will use the airport contained within the EIS. These aircraft have a different risk profile to other aircraft because of the nature of the cargo is different to that carried on passenger flights. Furthermore the terrorist risk is different from that of a passenger aircraft because of the potential use of the cargo load in an attack that can affect

6 the population, water supplies, food chain as well as using the aircraft as a weapon. These risks are not discussed.

The risk management method in this EIS purportedly uses a precautionary approach to risk. If this approach had been used properly it would have quantified all adverse impacts that can occur and then use the hierarchy of controls (ISO35000) to make a decision as to whether all the impacts can be controlled to a level that is acceptable. The acceptability criteria for what constitutes an unacceptable risk should use range of social, environmental and economic criteria. Only the use of a risk of death is evident in this EIS and even this is not used in a method which captures the full extent of shock losses to the population such as the collapse of Warragamba dam or destruction of the Eastern Creek Electricity substation.

Clearly the potential for these types of shock losses to occur from this site means that the loss to Western Sydney grossly exceeds the benefits of opening an airport by an order of magnitude.

To put this in perspective, consider two recent disasters consider the Fukushima Daiichi Disaster and the New Orleans inundation. The nuclear power plant was protected by a cement sea wall that was 5m high. The reinforcing of the wall to 10m, because modelling of the maximum potential Tsunami indicated that this height was needed, had been rejected by Daiichi management. This decision making was based on cost and political expedience rather than scientific assessment of the risk and its consequences.

The second example of the New Orleans inundation from Hurricane Katrina indicates the total economic loss from Katrina to be as high as $250 billion taking into account not just the damage, but the impact for disrupted gas production and general effect on national economic growth.

In both of these cases it is political intransigence that were a considerable factor in the ultimate loss. Siting of an Airport at Badgerys Creek has this potential for loss and can easily be avoided by not building the airport at this site. This both accords with the precautionary principle in risk and modern risk control hierarchies.

Of the sites that were supposedly considered for this airport, it is the only site where the type of catastrophic losses discussed above can easily occur due to critical facilities being within the normal distribution envelope for aircraft on final approach or on take-off, leaving no time for authorities to be alerted and take avoidance actions.

Badgerys Creek Airport is a disaster waiting to happen that will impact for at least 10 years on NSW and Australian economy and potentially kill 300,000 people.

Contents Executive Summary ...... 2 Introduction ...... 9 Deficiencies in Establisihing the Need ...... 9 The joint Study on Aviation Capacity in the Sydney Region ...... 9 Benefits in Alternative Transport Option to Counter Emissions Growth ...... 11 Western Sydney Airport Plan 2015 ...... 12 Deficiencies in Assessing Risks In the EIS ...... 13 What Should Constitute a Technical Assessment of Risk for a New Airport ...... 15 The Method Used in the EIS...... 16 Assessment of Impacts from Aircraft On Critical Infrastructure...... 19 Eastern Creek Electricity Substation...... 19 Sydney Water Supply ...... 19 Gas Pipeline from Wilton to Plumpton ...... 21 Lucas Height Nuclear Medical and Nuclear Storage Facility ...... 23 Blue Mountains World Heritage Area ...... 23 Cargo Transport ...... 23 Climate Change ...... 24 Application of a true precautionary principle ...... 25 Conclusion ...... 27

INTRODUCTION

The purpose of the EIS should be to demonstrate that there is benefit to the people of New South Wales that both exceeds the benefits of other alternatives for the investment and the risks in development and in operation are not going to lead to catastrophic impacts on society.

This report will concentrate on the need for the airport and the risks associated with siting this airport at Badgerys Creek which have not been adequately assessed within those documents.

DEFICIENCIES IN ESTABLISIHING THE NEED

The joint Study on Aviation Capacity in the Sydney Region The NSW and Federal Government 2012 report, the joint Study on Aviation Capacity in the Sydney Region, did not analyse alternative solutions to the problem of lack of capacity at Sydney Kingsford Smith Airport, considering only sites within 100km of Central Sydney and ignoring sites further away that could connect to Central Sydney by Ultrahigh Speed or Express rail similar to many cities internationally.

The projections used throughout this document for forecasting benefits are based on unrestrained projections. There is no interaction considered with other systems that would limit these forecasts. As a result all passenger numbers, aircraft movements and employment figures are overstated. Furthermore the loss to the economy from not building Badgerys Creek airport are not as great as stated and the cost benefit in building the airport is questionable.

The question as to what alternatives that would build economic security and resilience into NSW society and which meets the needs of a growing population and business was not addressed. The one option that was considered in the planning technical papers that has the potential to do this (the rest is really tinkering around the edges of the problem) is the building of an ultrafast rail link from Brisbane to Melbourne. The paper did consider a High Speed rail link with a maximum speed of 320km/hr but not an Ultrahigh S The faster train system will attract more passengers to make the switch from aircraft to train travel than the slower speeds. Thus the conclusions they draw are not valid.

Figure 1 shows four scenarios for weekly aircraft movements out of Sydney. The first is that in the 2012 report. The second is based on a survey of flights from Sydney in the week to 14th November 2014 in which there were 2900 flights out of Sydney of which 1207 went to Brisbane, Coolangatta, Canberra or Melbourne. This is 42% of aircraft movements in and out of Kingsford Smith Airport (KSA). Note that the total number of flights is also less than that forecast for 2015 by some 10% in a period of just 4 years. The rate of growth based in this second scenario used the same rate of

9 growth as the 2012 forecasts. The rate of growth is likely to be lower as is evidence by the shortfall in aircraft movements over the four year period.

The third scenario in Figure 1 shows the aircraft movements required if 100% of East Coast Air Traffic is replaced by an ultrafast train line. While there would be a period while this line is built (It can be done within 10 years and this is the projected timeline for building the first stage of Badgerys Creek Airport), the intersection with 1000 aircraft movements per week which would be the number for an operational Badgerys Creek Airport in 2025, does not occur until 2058 by which time ultrafast lines to Adelaide would push this date out further. The fourth scenario is that of a 50% uptake in ultrafast rail over air travel indicates that the need for a new airport would not be until 2040. This is likely to be conservative as experience in ultrafast rail internationally would suggest the take up is in the order of 60-70% based on rail speeds of 320km/hr and will increase if the rail speed is increased to 400km/hr. (High Speed Rail Study, phase 2). if the rail speed is increased to 400km/hr and would push out a need for an second airport to 2047.

Figure 1 Aircraft movements for four scenarios.

The other major problem with the 2012 Capacity Study is that infrastructure built in NSW is meant to have a design lifetime of 100 years. The study ignores this requirement. It is important because of the risks associated with climate change over that time period and hence the negative costs that will accrue from these impacts will significantly alter the cost benefit projections and hence whether Badgerys Creek should be put on the White Elephant list (ie a net drain on the public purse).

Building an Ultrafast rail link along the east coast in which the energy for the transport comes from zero emission technology such as solar, would make a significant contribution to Australia’s contributions to emission reduction agreed to in the Paris accord. The realignment of air transport, which emits CO2 directly into the stratosphere for flights above 10,000m, to ultrahigh speed rail, which can be designed for zero emissions, would supply power back to the grid equivalent to half of Mount Piper Coal Fired power Station assuming 90 trains operate. While current routes propose the northern branch goes up the coast, the viability of using the inland route of Tamworth, Armadale and Toowoomba should be investigated as the impact of climate change might make these centres better investment in economic growth.

Benefits in Alternative Transport Option to Counter Emissions Growth There are a number of benefits for Australia from building an ultrafast rail line from Sydney to Brisbane and Melbourne that were not considered in the joint Study on Aviation Capacity in the Sydney Region. These benefits can be enhanced by parallel development of solar power to supply the energy for the trains and ultrafast Internet optical fibre along the rail corridor to develop jobs based on computer technologies and communication.

1. The travel times between centres will be similar or less than current travel times. For example Sydney to Melbourne and Sydney to Brisbane will take about 2.5 hrs similar to the current time once travel to and from the airports at either end are taken into account. This time will decrease as the fourth generation trains come into service of speeds in excess of 400km/hr. The experience in Europe with such services show that more work can be accomplished and it is more comfortable while being of similar cost to air travel. 2. A significant proportion of fast freight can be integrated into this rail network. More specifically the international airfreight which is forecast to increase through KSA can be readily transferred and distributed along the eastern seaboard without the need for long distance road transport. This reduces major road freight and the damage it causes on the road infrastructure which is a significant on-going cost. 3. The building of the train track requires specialised steel products for the track and the catenary wires. This could revitalise steel making in Western Sydney through local firms using Australian Iron ore or recycled steel and iron (It does not have to go to China and back). These projects could also be exported for similar projects in Southeast Asia. This strategy also reduces the footprint of pollution emission. 4. It can kick start a solar power industry in Australia using all Australian minerals and Australian expertise in this area. Current solar panels produce about 320W per panel (recent research efficiencies of over 40% at UNSW can boost this to more than 400W per panel). Using the rail corridor to generate solar power would currently produce approximately 200MW between Sydney and Melbourne and a similar amount between Sydney and Brisbane if only one row was placed along the rail corridor. Since the operation of one train takes approximately 10MW, one row supplies enough power to operate 44 trains. This is more than current needs of 30 trains over the entire east coast but with growth is likely to require between 60 and 90 trains per day. Four rows of panels is probably the maximum number of panels that would easily fit along the rail easement and would supply power back

to the grid equivalent to half of Mount Piper Coal Fired power Station assuming 90 trains operate. The development of such a solar power industry in this country has the benefit of moving to a low carbon economy and has the potential for high exports while maintaining high employment. It also accords with Australian Government commitments agreed to at the recent Paris summit on climate change. 5. Centres such as Goulburn, Albury Wodonga and Queanbeyan would become viable growth centres relieving some of the pressure on Sydney and Melbourne. This would only be viable as long as there are reliable and sustainable electricity and water supplies. Solar power can also be used to generate fresh water from brackish and salty water while generating electricity. The development of a viable solar industry will assist in overcoming some of the water shortages that currently occur. Parallel development of ultrafast Optical fibre links can build computer and communication based industries in these growth centres. 6. There will be no need for new infrastructure that is fundamentally detrimental to the planet for the immediate future. Effects such as venting of aircraft fuel onto the blue gum stands in the Blue Mountains can be avoided as can oil spills which affect the water supply to Sydney. The reduction in air travel while only slight helps to move to a low carbon economy. Similarly the noise impacts will not be present.

In conclusion the building of a second Sydney Airport at Badgerys Creek is not an option if NSW is to properly move to a low carbon based economy which is resilient and sustainable. It should be noted that the economics of this proposal does not take account of CO2 which is considered a pollutant and is not costed into any market economic model. This lack of basic accounting principles leaves the public to pick up the cost of damage rather than the investors and corporations who have caused the damage. The monies set aside by government or by private investors would be better spent at less risk in building ultrafast rail and solar power technology. This provides at least three different income streams which will pay for itself with higher returns on investment than an Airport.

Western Sydney Airport Plan 2015 The objective of this plan was to ensure that the airport met the following objectives without considering the benefits of other forms or integrated forms of transport:

1. Improving access to aviation services for Western Sydney.

This could be achieved with better rail infrastructure throughout Western Sydney connecting this region with KSA. If Ultrafast High Speed rail is integrated into the airport solution then the site does not have to be at Badgerys Creek allowing development of the area for the industries needed for an innovative century and a zero emission and sustainable economy.

2. Resolving the long-term aviation capacity constraints in the Sydney Basin.

As stated above an ultrafast high speed rail service along the East Coast does not require a further airport until 2040 at the earliest. By this time the impacts of climate change on the rate of sea level rise will be more certain and hence the effect on population movement from Sydney because of this rise will be more predictable.

3. Maximising the economic benefit for Australia by maximising the value of the Airport as a national asset.

Maximising economic benefit is done by opening up all major cities along East Coast routes to Ultrahigh speed rail and developing Australian based support technologies to enhance Construction, Solar, Energy and Communication capabilities from locally based industry not from airport construction and operation.

4. Optimising the benefit of the Airport on employment and investment in Western Sydney.

The proposal sterilises the land for vested interests not economic benefit of the people of Western Sydney

5. Delivering sound financial, environmental and social outcomes.

This is just typical of “Utopian” speak. The financial risks have not been properly evaluated as it takes a business as usual approach to projection without interruption or without the impact into Sydney lifelines from building this airport, a strategy which is not consistent with modern risk management practices. The surrounding environment includes a world heritage area in the Blue Mountains over which aircraft will assemble for landing. The quantitative impacts of this on tourism, loss of habitat have not been discussed and the potential for the airport to be non- operational because of climate change has not been addressed. Socially it will not deliver any of the proposed benefits to Western Sydney. The only people to benefit will be the owners and operators and if they go into liquidation then it requires the public purse to bail them out.

DEFICIENCIES IN ASSESSING RISKS IN THE EIS

An airport is a major hazard installation in the same way as oil refineries or large Dangerous Goods stores. Aircraft are flying bombs particularly when fully loaded with fuel, and can impact on society in a variety of different ways, including economic, death and injury and loss of environment. As such there is a requirement that the benefits to the community outweigh the risks involved in the development of the airfield and this requires a risk framework that is commensurate with ISO35000; the international risk standard. There are a number of major deficiencies in the scope of this report that has resulted in an unreliable estimate of risk and impact on the major population centres of Western Sydney. Generally the risk in the EIS is only considered as a health and safety risk not as an economic risk or loss of social and natural environments.

The approach to the risk assessment for this preliminary plan is deficient in the method that was used and the lack of quantitative analysis of the risks that takes account of known mechanisms of loss and their impacts. Figure 2 is a schematic of these interactions. The inner ellipse corresponds to the stages of flight into and from an airport which interact with elements in the middle ellipse to produce impacts in the outer ellipse. All impacts should be judged in terms of economic loss, human loss and suffering and environmental loss and damage not just human loss.

There is no evidence in any of the planning or EIS documents that these risks have received proper consideration. There is also a failure to ensure this process includes alternative sites and scenarios where High Speed rail is part of the mix of opportunities.

Figure 2 Relationship between threats impacts and the different phases of aircraft operation.

Reliance on previous studies that are some 20 to 25 years old for some of the impacts that are possible is not appropriate because the class of aircraft, their maximum thrust, cargoes and fuel loads are different from twenty years ago.

There is a failure to use the aircraft movements based on the airport design capacity for 2060, instead of the limited capacity of the operation of 2030. The quantitative assessment of risk that has been undertaken excludes important aspects of risk of a crash. In particular:

• The impact of other airport operations and the impact of the new airport on those other operations. Even though it is stated that the flight paths have been chosen to avoid overlap from other airports, the risk of Air traffic Control (ATC) communications failure between aircraft in different stages of flight was not discussed. • The impact of domino or escalation effects on the consequences on an air crash which may significantly increase the societal and individual risk were not discussed. In particular the consequences of crashes into the following facilities were not addressed: o Warragamba Dam, Prospect Dam, the Chlorine treatment plants at Prospect, Warragamba and Orchard Hills and other effects on the Sydney Water supply. o The main electrical distribution substation at Eastern Creek o Sites having a significant quantity of Dangerous Goods in the Fairfield, Penrith, Blacktown, Liverpool and Campbelltown areas.

o The defence communications network centred at Glenbrook o The main gas monitoring station at Horsley Park and the other at Plumpton. o Hospitals, schools, universities and other designated sensitive sites within the area o The impact of bushfires and burnoff in the Blue Mountains on aircraft engine failure and consequence crash risk and impact. o The consequences of an aircraft crash in the Blue mountains on causing a major running bushfire o The consequences of adverse weather, particularly severe storm activity and downdraft on flightpaths and crash rates. o The effect of bird strikes on crash rates. o The effect of drone strikes of aircraft as well as terrorism and pilot suicide. o The effect of cargo on risk o The proposed oil pipeline from Plumpton to the Airport.

The conclusion that can be drawn from this document is that there are very serious deficiencies in the scope of any risk assessments that undermine the validity of this report as an assessment tool for decision making on the siting of the second Sydney airport.

This effect is compounded by omissions in quantifying many of the threats that result in aircraft crashes and their impact on the communities of Western Sydney. The methodology used is not discussed in sufficient detail and the data omitted that is used in formulating the distribution of aircraft along different flight paths does not allow independent assessment of the risks to challenge the validity of the results presented.

What Should Constitute a Technical Assessment of Risk for a New Airport A technical assessment of risk for a second Sydney airport has to show that there is a net benefit to the community by demonstrating:

• A reduction in risk to the community from the continued operation of Sydney Airport and the new airport together with other scenarios involving Ultrahigh speed rail. • A tolerable level of risk to the society and community commensurate with site and the land use surrounding the site. This needs to be repeated for all alternative sites under consideration • A net benefit to the community taking account of any sudden shocks caused by the operation of the airport.

To achieve this would require a comparative study of the risks that includes:

• Sydney Airport (Kingsford Smith) operating under different scenarios including taking account of sea level rise and implementing an Ultrahigh speed rail for 2030 with and without an alternative airport operating. • The second Sydney airport for its stated design of 460,000 aircraft movements in 2060 • Another option situated somewhere outside the Sydney basin that is a realistic site, for example in the Goulbourn district or one of the existing airport at Canberra or Newcastle.

Each assessment should quantify the risk from the interactions shown in Figure 2. There is no evidence that these comparisons have been made in any of the documents.

The Method Used in the EIS The EIS states that the review of risks primarily focuses on the stage 1 single runway operation using “primary legislation with regards to safety for both the Commonwealth and NSW is the Work Health and Safety Act 2011 (Cth) (Cth WHS Act) and the Work Health and Safety Act 2011 (NSW) (NSW WHS Act) respectively. These acts require that persons conducting a business or undertaking should eliminate risks, so far as is reasonably practicable (SFAIRP), and if this is not possible, reduce risks so far as is reasonably practicable. Persons conducting a business or undertaking (PCBUs) have an obligation to ensure that they comply with their duties and obligations. “

The primary focus on stage 1 ensures that any risks that are quantified are inappropriately analysed and do not take account of the full impacts on the community from the proposed operation in 2060.

The description of the methods continues with:

“The enactment of the WHS acts in 2011 has brought with it a change in philosophy for the identification and management of safety risks compared to previous practice. While this study is not being conducted to comply with WHS legislation (refer Section 1.5), the concepts of risk management in the WHS legislation have been considered in undertaking this risk assessment and as far as possible, this new approach has been adopted for this study.

Two primary paradigms of safety risk management, hazard and precautionary based approaches, have co-existed over the last few decades.

The hazard-based risk management approach requires that hazards be identified, and the risk (likelihood and consequence) associated with them be determined and then compared to acceptable or tolerable risk criteria. If the criteria are not satisfied, then risk treatments are applied until the criteria are satisfied.

The precautionary-based risk management approach aims to identify practical options that are available to address identified safety issues and then tests to see which options are reasonable in the circumstances and ought to be done, especially recognised good practices.

Both approaches aim for the same result. If all reasonable practicable precautions are in place for all hazards, then the risk associated with those hazards is as low as reasonably practicable. This is shown in the diagram below which summarises the key steps of the two approaches.”

The method adopted is totally inadequate for the proposed infrastructure and its impacts on the social, financial and environmental wellbeing of the State of New South Wales as it only uses a qualitative framework and there is no cost benefit analysis of any of the control options. The approach that has been used states that it uses risk guidelines used for infrastructure projects within the State. If this is true then the method used by the State is totally inadequate for all major infrastructure projects.

Given the failure of infrastructure projects in Sydney over the past few years, the approach used for risk is beneficial for public private partnerships as it allows ongoing exploitation of the public purse by contractors, benefiting the private over the public interest. Failures of the Airport line which went into receivership and was bailed out by the public purse and the double failure of the cross city tunnel again being supported by the public purse are just two examples of this lack of proper application of modern risk practices.

In risk decision making there are two types of systems that exist: “tame” and “wicked”. The myriads of papers on which the proposal risk have all been assessed use a “tame” framework for risk. That is to say the system being analysed is considered independent of other systems and there is no risk feedback from the other systems into the system being analysed or which amplify knock on effects into society. While this approach allows one to describe risk in terms of likelihood and consequence on a continuous spectrum, it is totally inappropriate in complex systems where different systems interact with each other and catastrophic outcomes can occur from these interactions.

The need for a new airport is highly dependent on what is envisioned for the year 2060 and natural changes to the environment:

1. How does population growth across NSW impact on the need for an airport? 2. How are sustainable jobs going to be created and where will they be? 3. What will the transport needs for this population if the economy is to grow? 4. Will the economy actually grow or will it stagnate? 5. How will sustainable food, water and electricity be supplied given that climate change impacts will occur over this time period? 6. How are shocks caused by feedback between different systems in the environment be avoided or mitigated?

Studies undertaken do not address these in a manner consistent with its complexity. The decisions arrived at are therefore invalid and flawed. The basis for any decision must be of benefit to all and not just to investors.

The basic assumption being made is that population growth is to be encouraged because it maintains economic growth in society. As the population of NSW and Australia is set to double by 2060 according to the Australian Bureau of Statistics (ABS) then it is assumed that the need for more

17 flights will correspondingly increase. This, however, does not take account of where the increase in people are going to live, where they will find work or how they will get from their home to their work and whether climate change will impact on current plans for these.

The NSW government has released a publication stating that the population growth will be absorbed in Western Sydney (Parramatta, Penrith, Richmond and Liverpool) as well as along the eastern coast such as Newcastle, Goulburn and Queanbeyan. To put some figures on this, the population of NSW is projected to rise from 7.5M to between 12M and 15.2M by 2060.

Currently Energy consumption in NSW is 1650PJ (Petajoules: 1 PJ=1015J) with 490PJ and 450PJ being used in electricity generation and transport respectively. Residential use accounts for about 130PJ with the rest being used in manufacture and commercial operations. Doubling of the population will double this energy consumption. Such an increase has to be tempered either by a realistic carbon price and transition to an emissions free economy. This includes being weaned off inefficient transport and fossil fuels in the Paris accord is to mean anything.

Similarly water requirements are not consistent with population growth. Currently 4200GL are consumed in NSW per annum of which agriculture uses some 2000GL. About 1000GL are used in losses within the reticulation and storage systems. 560GL are used domestically with the rest used commercially. If there is a 50% drop in losses then consumption will increase to about 7300GL by 2060. Given that the climate imposes a constraint on how much rain can be collected, there is a serious question about the sustainability of the water supply for the increased population.

These proposed population increases within the Sydney basin will put more pressure on Sydney lifelines: the supply of water, gas, electricity and communications.

Such considerations are important when it comes to projections of population centres and the cost of siting and building the airport. The projections used in the EIS are just unrestrained projections using a business as usual approach which is clearly not going to occur. Currently KSA is 10% underutilised from their own projections over just a 4 year period.

Badgerys creek is situated in an area where Sydney’s critical Infrastructure intersect (five of the ten critical infrastructures considered a high national security risk by the Federal Government – Defence, Electricity, Water, Gas and Communications converge in this area) that sets up a number of potential catastrophes for Sydney and its people. Security of lifelines to Sydney have not been considered in this EIS but their inclusion would immediate nullify the siting of this Airport at Badgerys Creek if the precautionary principle was properly applied.

Figure 3 shows the spatial relationship between the proposed flightpaths in the two modes of operation for 2060 and the current infrastructure critical for Sydney’s lifelines. There is a concentration around the eastern creek area which is particularly vulnerable to any aircraft crash. This is shown as a red ellipse. The impact of this is to the water supply, gas supply and electricity supply for Sydney. It will also include the fuel supply for the airport if it uses the Eastern Creek easement for the 330KV supply to eastern creek. If this pipeline is moved west and crosses commonwealth land then the vulnerability for the munitions site is increased. Within this area are also the dams at prospect reservoir and Warragamba and the water pipes lines and treatment plants holding major stocks of Chlorine between them. In addition a natural gas pipeline at 6900kPa

18 pressure runs from Wilton to Horsley Park and then to Plumpton. Although the pipeline is underground it does surface at Horsley Park where there is a metering station. Also within this area but further to the south east is the Lucas Height nuclear medicine and nuclear storage facility.

The risk to these infrastructures and the subsequent impacts are not discussed. Furthermore acts of pilot suicide, terrorism and other behaviours by ATC have been specifically excluded from the study. These behavioural acts substantially increase the risk on these facilities. While past studies for example on Warragamba Dam and Lucas Heights have occurred, they risks have not been assessed in terms of the modern aircraft fleet or from deliberate acts.

ASSESSMENT OF IMPACTS FROM AIRCRAFT ON CRITICAL INFRASTRUCTURE.

Since the EIS does not look at the impact of aircraft on critical infrastructure, I have analysed the possible outcomes of shock losses to critical infrastructure around the Eastern Creek area. This is something that should have been part of the EIS but is not.

Eastern Creek Electricity Substation.

The Eastern Creek substation supplies about 25% of Sydney’s electricity supply, mainly to the industrial complexes around Eastern Creek, Prospect and St Marys as well as residential properties. The substation has a number of transformers that cannot be replaced within two years if they are all taken out in a single event such as an aircraft crashing or being flown into the site. As the site is 10km from the runway threshold and less than two degrees angular dispersion (within the normal range of distribution of aircraft on approach or take off from the flight paths), there will be no response to such an event until after it has happened.

Sydney Water Supply

The area has two dams, at Warragamba and Prospect with a dual pipeline connecting the two.

The duel supply passes within 400m of the Eastern Creek Electricity substation. Not only can it be taken out independently but also with the loss of the Eastern creek electricity substation. This would add to the social cost of loss for Western Sydney.

Figure 3 Critical Infrastructure vulnerability long term operation: top – mode 5; bottom – mode 23

The flight paths fly directly over both Warragamba and Prospect reservoir within the normal angular spread of flightpaths. A deliberate targeting or an accident can impact on both dam walls. Warragamba dam is 143m high and is 8.5m thick at the top of the dam with a capacity of just over 2 Gigalitres. Prospect dam is an embankment dam 26m high with a capacity of 50.2 Megalitres.

The impact of larger aircraft with higher thrust and the mix of aircraft today compared with 1995 will collapse the earth embankment at Prospect and is likely to beach the dam wall at Warragamba. The aircraft can easily have an energy 50% of the dam buster bombs used in the Second World War to destroy the Ruhr dams but have at least 1000 times the momentum. Previous studies involved accidental crashes and not deliberate flying to cause damage. A deliberate act can precisely aim the aircraft at higher aircraft speed than normally using in commercial flying. This poses a problem as the response by ATC and the RAAF from Williamstown airbase are two slow to stop this type of deliberate act. Flights from other airports such as KSA do allow enough time for a response to this type of threat so that it can be averted.

Figure 4 is the estimated extent of flood in the Hawksbury Nepean river system, caused by a 1 in 200 year event where the dam wall and spillway are opened. The highest recorded flood corresponding to the 1 in 200 year event was in 1887 when the height reached 26.9m at Penrith and 18.6m at Windsor relative to the Australian Height Datum (AHD). The floods are caused by the gorge between Sackville and Wisemans Ferry which restricts water flow into the ocean.

The level of flood damage assumes that Warragamba dam wall does not fail. A large plane or piloted into the dam wall is likely to cause failure. The expected height of water emerging at the end of Glenbrook Gorge will be of the order of half the wall height if the Dam is near capacity at the time. This is approximately 70m in height some 2.5 times the maximum ever observed at Penrith. The current population in Penrith, Hawkesbury, Blacktown and Baulkham Hills LGAs is 780,000. A conservative estimate of the number of people at risk from a collapse of the dam is approximately 350000 and may well be higher. The problem with this scenario is that the evacuation routes that are available in a flood are not available for this event and the timescale on which evacuation starts to occur is too long compared with the speed of rise in the waters. It is very likely that the number of deaths would tend toward the level of at risk population.

Gas Pipeline from Wilton to Plumpton

The pipeline that runs underground from Wilton to Plumpton via Horsley Park operates at 69 atmospheres pressure (6900kPa). At Horsley Park there is a metering station where the gas pipeline is on the surface and the pipe diameter is reduced from 864mm to 508mm. The site is between the Eastern Creek Electricity Substation and Prospect reservoir.

Rupture of the pipes at the metering station by an aircraft would cause a release of LNG which may not ignite immediately. A 10 tonnes vapour cloud would be able to form within a few minutes which if ignited would cause damage within a five kilometre radius. This would include the electrical distribution station and the chlorine plant at Prospect reservoir.

Figure 4 Extent of a 1 in 200 year flood taken from the Hawkesbury-Nepean Flood Damages Assessment: Final Report, Molino Stewart Pty Ltd, September 2012. ARI is the average recurrence interval in years and PMF is the probable maximum flood.

Lucas Height Nuclear Medical and Nuclear Storage Facility

A nuclear waste storage for medium level radioactive isotopes is located at Lucas Heights, South East of the proposed airport. A research nuclear reactor operates there to produce radioisotopes for medical diagnosis.

A previous study on the impact of aircraft accidents on the reactor by CSIRO determined that it would survive such a crash, it was undertaken 25 years ago with a different aircraft mix than that proposed for this airport. Deliberate acts were not included in the assessment. Given that the site is now a repository for midlevel radioactive isotopes, there is no information on whether an aircraft impact can disperse these isotopes into the atmosphere.

Blue Mountains World Heritage Area

The waypoints for landing for both the one runway and two runway proposals are over the world heritage listed Blue Mountains. Aircraft accidents can lead to bushfires and bushfire can lead to aircraft accidents. The area of debris from a crash is likely to start large unconstrained bushfires that over summer can run before the wind (the area is prone to hot consecutive days of Strong North Westerlies) and cause extensive damage. The resident population at risk is 79700. A large bushfire in summer can travel the distance between Blackheath and Glenbrook in 2 hours if there is a strong North Westerly or Westerly blowing.

Not only can aircraft be the cause of such fires but the ash and fire plume will rise to between 3000m and 5000m above terrain. This is into the flight levels designated for the aircraft landing at Badgerys Creek and are of a particulate size and concentration to bring down aircraft as well as cause substantial disruption to the operation of the airport similar to recent disruption in Bali due to volcanic ash.

Cargo Transport

There is very limited data on the number of cargo flights that will use the airport. These aircraft have a different risk profile to other aircraft because of the nature of the cargo is different to that carried on passenger flights. Furthermore the terrorist risk is different from that of a passenger aircraft because of the potential use of the cargo load in an attack that can affect the population, water supplies, food chain as well as using the aircraft as a weapon.

The potential impacts of these different risks are not discussed.

Climate Change

Climate change will affect all the assumptions on which the forecasts have been based. Whether those assumptions used in the forecast are valid depend heavily on the actual rate of sea level rise. This area of climate science has the largest uncertainty as the models for simulating sea level rise do not have currently the feedbacks from ocean current circulation under glaciers in the Antarctic and Arctic and hence are under-estimating the retreat of glaciers. Furthermore, the models do not capture the demise of permafrost or clathrates in the Northern hemisphere which will drive faster ice melt.

A recent poll of researchers engaged in sea level and ice field science concluded that 80% expected sea levels to rise by 0.8m by 2100 with about 17% expecting greater than 2m rise and 1% a 7m rise in the same timescale assuming a business as usual scenario with no or little mitigation. Calculations based on a 2013 paper on Ice melting in the Antarctic would suggest that 1.4m of sea level rise has already been locked in by the year 2100.

A 1m rise is likely to impact on operations at KSA when the effects of high tides and storm surges are taken into account. There is also likely to be loss of property and infrastructure along the lower portions of the Kurnell Peninsula and the Parramatta River will impact on property and infrastructure.

The cost of the losses to infrastructure has been estimated as $B226 in Australia and almost 250,000 homes are at risk along with thousands of commercial buildings, 75 hospitals, five power stations,

120 ports and up to 35,000km of roads and rail lines. The total cost will be in excess of $B500 together with a reduction of 30% GDP (approx. $b500) because of the loss in infrastructure. This total loss of $B1000 is just from a 1.1m rise in sea level.

As the rise in sea level increases more and more infrastructure and property loss occurs along the NSW coast. With a rise of 7m the cost will rise dramatically. Most of Sydney CBD, the port facilities and airport in Port Botany together with flooding of rail and road tunnels, and loss of property around Parramatta and Liverpool will suffer inundation. The total cost for Australia is likely to be in excess of $B34000. At these levels it is not clear that mitigation measures that would be cost effective for a 1m rise which would still be cost effective and probably not worth doing if larger sea level rises by 2100 are expected.

Flooding from sea rise exacerbates the area affected on land. High tides and storm surges tend to be up to 1.5m higher than the average sea level. A 0.3m rise leads to impact 100m from the sea line due to erosion of the shore. Furthermore there is backup in storm drains which can cause flooding and backup of water table flows in periods of heavy rain that will give rise to flooding in areas not connected directly to the sea.

The proposed Badgerys Creek airport is at a datum of 90m above sea level (AHD) well above any sea level rise (if all the ice melted the sea level would rise approximately 70m and the shoreline to the north would be at the escarpment to the Blue Mountains at Emu Plains). The area does sit on the flood plain for the Nepean River and hence there is still the potential that with sea level rise the normal water table flows will be changed.

If these types of predictions are in anyway accurate a worst case will be about a 3.5m sea level rise by 2060, KSA will not be functioning. Furthermore inundation in Sydney will cause population movement and disabling of many of the transport routes.

An airport outside the Sydney basin would be a more stable option in the longer term as it can be located where the population of Sydney is to be translocated.

The number and severity of bushfire days is expected to rise in line with increasing temperatures. This impacts on the number of operational days of the airport and increases the crash risk.

Application of a true precautionary principle

The risk management method in this EIS purportedly uses a precautionary approach to risk. If this approach had been used properly it would have quantified all adverse impacts that can occur and then use the hierarchy of controls (ISO35000) to make a decision as to whether all the impacts can be controlled to a level that is acceptable. The acceptability criteria for what constitutes an unacceptable risk should use a range of social, environmental and economic criteria. Only the use of a risk of death is evident in this EIS and even this is not used in a method which captures the full extent of shock losses to the population such as the collapse of Warragamba dam or destruction of the Eastern Creek Electricity substation.

Those for which there is little control available should be used as the basis of whether the site is actually suitable in the first place. The level of detail contained within the risk appendix (Vol 4 Appendix H) does not give any indication that any of the risks from a fully operational Airport have been quantitatively considered. Figure 2 shows the interactions that were not considered.

Furthermore, the report only looks at the frequency of aircraft crashes from pilot error or mechanical failure and not the consequences, it does not include pilot suicide, air traffic control failures and terrorism or the true impact of all these events if they were to occur. It makes a mockery of the risk assessment process. The population of Western Sydney is unlikely to think that loss of the water supply, gas supply or electricity for two years is an acceptable outcome. Clearly the potential for these types of shock losses to occur from this site means that the loss to Western Sydney grossly exceeds the benefits of opening an airport by an order of magnitude.

To put this in perspective, consider two recent disasters consider the Fukushima Daiichi Disaster and the New Orleans inundation.

Steven Starr of the Physicians for Social Responsibility, the US affiliate of the International Physicians for the Prevention of Nuclear War, stated; “The precise value of the abandoned cities, towns, agricultural lands, businesses, homes and property located within the roughly 310 sq miles (800 sq km) of the exclusion zones has not been established. Estimates of the total economic loss range from $250-$500 billion US. As for the human costs, in September 2012, Fukushima officials stated that 159,128 people had been evicted from the exclusion zones, losing their homes and virtually all their possessions.”

The nuclear power plant was protected by a cement sea wall that was 5m high. The reinforcing of the wall to 10m, because modelling of the maximum potential Tsunami indicated that this height

25 was needed, had been rejected by Daiichi management. This decision making was based on cost and political expedience rather than scientific assessment of the risk and its consequences.

The second example was the New Orleans inundation from Hurricane Katrina. University of North Texas Professor Bernard Weinstein put the total economic loss from Katrina to be as high as $250 billion. (Source: Swiss Re, "Hurricane Katrina," January 25, 2007) That's because he takes into account not just the damage, but the impact for disrupted gas production and general effect on national economic growth.

In New Orleans, the levee wall to protect against floods and hurricanes that had been built in the 1950’s, had not been increased in height when modelling in the mid 1990’s became available linking the category of hurricane to the expected storm surge height. Political intransigence and using funds for other projects resulted in flooding of the city. The actual cost of Hurricane Katrina's damage in the city was between $96 and $125 billion, with $40-$66 billion in insured losses. Half of these losses were a result of flooding in New Orleans. An estimated 300,000 homes were destroyed or otherwise made uninhabitable. At least 118 million cubic yards of utter debris and devastation was left behind.

The hierarchy of controls in risk management states that if the loss is much larger than the benefits then the project causing those losses should not proceed. This is both a principle of risk management and a correct application to the precautionary principle. Since the potential losses from shock events runs into hundreds of billions of dollars any project that is likely to cause these should not proceed as the recovery time from such loses is at least a decade.

The plan to build an airport at Badgerys Creek is severely compromised by the concentration of existing critical infrastructure within the designated area that can lead to a shock losses of $B160 to $300 billion and deaths approaching 300,000 in Western Sydney and would take a decade for Sydney to recover from these types of incident.

The changes in the types of computer based threats on aircraft also increase this risk and current measures to avoid takeover of a plane do not work against these types of threat as they disable the pilot’s ability to control the aircraft. Boeing and Airbus are currently investigating how this can be stopped. It would take about 3 minutes for a response from Williamstown RAAF base to counter such a threat. Thus this is not a threat that is realistic for Kingsford Smith Airport but is one posed by Badgerys Creek Airport.

The risk is similar to the Fukushima nuclear disaster and the hurricane devastation to New Orleans, where both were protected by barriers which were inadequately designed for the threat which eventually occurred. It was even known prior to the events that these were inadequate but there was a lack of political will to change the barriers.

The conclusion drawn from this discussion is that the location at Badgerys Creek poses extreme risks to the economy of Sydney and high consequence of death in Western Sydney. It is clearly the wrong site because of the concentration of Sydney lifelines in the immediate surrounds.

CONCLUSION

There are serious deficiencies in the scope of risk assessment that undermine the validity of this EIS as an assessment tool for decision making on the siting of the second Sydney airport. This effect is compounded by omissions in quantifying many of the threats that result in aircraft crashes and involve human behaviours.

The methodology used is not discussed in sufficient detail and the data on which it is based is omitted. It is a tactic which does not allow a fully independent assessment of the risks to challenge the validity of the results presented.

However there are a number of conclusions which can be drawn from the limited data available.

The location for this airport is inappropriate and does not provide any benefit to the people of Western Sydney, in fact the type of shock losses that can occur negates the siting of the Airport at this location

The concentration of lifelines for Sydney in the Eastern Creek area makes this unsuitable for an Airport.

Badgerys Creek airport should not be built.

The original study on the need for the airport does not provide a cost benefit analysis of alternative methods of transport, climate change over the lifetime of the proposed facility and the inclusion of shock losses in the assessment.

What is needed is a comparative risk study to be undertaken that take accounts of both climate change and an integrated air-rail-road risk study of realistic infrastructure for the next 100 years. The benefit of this is that Sydney might actually get an integrated transport system that takes account of a change to a zero emissions and an innovative economy. Badgerys creek Airport is not needed if other options are properly considered in terms of economic benefit and their risk of failure.

Of the sites that were supposedly considered for this airport, it is the only site where the type of catastrophe losses discussed above can easily occur due to critical facilities being within the normal distribution envelope for aircraft on final approach or on take-off, leaving no time for authorities to be alerted and take avoidance actions.

Badgerys Creek Airport is a disaster waiting to happen that will impact for at least 10 years on NSW and Australian economy and potentially kill 300,000 people.