Melbourne Airport Environs Safeguarding 19 Standing Advisory Committee ‐ Issues and Options Paper
Full Name: Frank Rivoli Organisation: Affected property: Attachment 1: https://engage.vic.gov.au/download_file/48231 Attachment 2: Attachment 3: Comments: see attached submission
Submission Cover Sheet The Hume residents Airport Action Group (Inc) is making this submission on behalf of thousands of residents residing in the suburbs located east of Melbourne Airport. Our submission is to provide community views to the Melbourne Airport Environs Safeguarding panel and a response to the Issues Option paper.
Community Response to Aircraft Noise The last known study commission by the commonwealth was in 1982. “Aircraft Noise in Australia, a Survey of Community Reaction.”, NAL Report No.88, February 1982 (A.J Hede & R.B Bullen)
The time is past due for another survey, considering the changes in aircraft movement volumes and residential development near airports. The example from the Perth Airport Third Runway MDP, Health study suggest the 1982 study is being referred to in current airport planning, The draft Perth Airport Third Runway MDP, Health study lists research documents from Ising and Kruppa 2004 study into health impacts from aircraft noise which refers to 1982 study by (A.J Hede & R.B Bullen), a document which is out of date and should and may not provide reliable relevant data based on current and future aviation growth. We encourage the panel to make a recommendation for a new survey to gauge community reaction to aircraft noise.
Aircraft Noise The area of flight operations over the suburbs of Broadmeadows, Jacana, Dallas, Attwood, Westmeadows, Gladstone Park and Gowanbrae are overflown by runways from both Essendon and Melbourne Airports and additional to jets aircraft is Helicopter operations. The current and proposed runway east of Melbourne Airport and runways North of Essendon Airport have intersecting flight paths over our houses. The Melbourne Airport Environs Strategy only refers to the ANEF noise contours from Melbourne Airport. A combined ANEF should be calculated for this area, and may also be required for parts of Moonee Valley. Failing to detail the accumulated aircraft noise from all sources flying over our houses underestimates the noise impact on residential areas. Residents have measured aircraft noise in lounge and bedroom around 55dBa and greater, this noise measurement was taken pre-covid and is noise from the airport, not runway path. The airport noise is generated by all aircraft taking off in the south and north direction. This noise is not reflected in the ANEF Contour. There are a vast number of residential dwellings, east of the airport built prior to airport master plans and publication of ANEF noise contours, therefore aircraft noise is not attenuated and penetrates into our homes.
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Policy Failure Since the Melbourne Airport Environs Area Strategy Plan, 2003 came into effect a significant number of residential dwellings have either been renovated or re-established as multi units per lot under the flight path of a future East/West runway. The Melbourne Airport 2003 master plan showed the noise contours based on the ultimate capacity till 2023(Fig1). Melbourne Airport has no declared aircraft movement capacity limit therefore the Melbourne Airport Environ Strategy has little prospect of ensuring residential development will not prejudice the airport development. The extent which ANEF contours have grown in 15 years can be seen in (Fig2), since 2003 and up to the current times the planning scheme has approved residential building permits using the 2003 ANEF contours. This has left residents exposed to harmful impact from aircraft noise.
Fig 1 – Showing residential development along Camp Rd. Broadmeadows.
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Fig 2 – Showing extended ANEF contours since 2003 airport master plan.
Declaration of aircraft movement capacity for Melbourne Airport.
The Airport Act 1996, section 195 states a minister may make a written declaration setting out the declared reasonable capacity for an airport. This is the first step in orderly airport development. It will provide certainty for Government, Airport Operators, Stakeholders, Business and community. It will strengthen the planning scheme and would remove the planning issues from variable un- capped airport capacity.
Deemed to Comply provisions set out in the MAES 2003 Item 5.1 of the MAES 2003 recommended the State Government formulate “deemed to comply” construction standard as an alternative to fill assessment of noise exposure and attenuation requirements. The application of “Deemed to Comply” is not an alternative to a full assessment of noise exposure and attenuation building requirements. The MAES 2003 has left people exposed to aircraft noise, it has failed to develop relevant building standard material to justify, “Deemed to Comply”. We provide the following example taken from an acoustic assessment for a residential dwelling located in Keilor, approximately 4 Kilometre from the proposed North/South third runway. The location is within the 25ANEF contour, and is un-acceptable for residential as per AS2021. The assessment was completed in 2002.
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As2021 recommends the following indoor sound level for residential house.
• Sleeping and lounge 50dB(A) • Other Habitable Spaces 55dB(A) • Bathrooms, Toilets, Laundries 60dB(A) • Some Building construction Items recommended to achieve AS2021 requirement are: Windows
• Glazing to Bedroom 10mm thick laminated or toughened • Kitchen / Family rooms 10mm thick laminated or toughened
Windows should be fixed and sealed and should close against a compressible acoustic seal.
Ceilings Bedrooms, Lounge should be lined with 2 layers of 10mm thick plaster board over laid with 100mm thick, 24kg/m² Cellulose ceiling insulation. Contrast this with the standard construction materials used in existing houses built in this area before the Melbourne Airport Environs Strategy of 2003.
• 3-4mm Window Glass is fitted to all areas, Bedrooms, Lounge, Kitchen, Family Room, Toilet, Laundries • Single layer of 10mm Plaster board to all rooms
Typically houses built prior to MAES 2003 have the following construction
• 3-4mm Window Glass is fitted to all areas, Bedrooms, Lounge, Kitchen, Family Room, Toilet, Laundries • Single layer of 10mm Plaster board to all rooms • Houses were not fitted with insulation as part of the building code, however thermal insulation is fitted at owner request. • Unsealed windows • Wall insulation not required
We cannot find supporting evidence which shows existing houses can be assessed as deemed to comply. The result of the Deemed to Comply method has left residential houses up-protected from aircraft noise. Strengthening airport safeguarding through land use controls, without implementing the necessary building requirements to make existing homes fit for purpose as per AS2021, continues to over burden our communities and ensures their low socioeconomic status will continue.
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Compensation The panel of the MAES 2003 did not support a recommendation compensation for injurious affection and loss of development rights. Reasons given was compensation for injurious affection was outside the scope of the MAES and compensation for loss of development rights is inappropriate. Since 2003 the subject of compensation has received attention by the High of Australia and the Australian Human Rights Commission, perhaps this issue should be re-visited.
Solutions There is considerable effort put into information on how to best describe aircraft noise. The information come in various forms such as the Melbourne Airport Noise tool, ANEF contours and the N-Contours. It is difficult to see how this information can resolve specific issues of noise impact. Its aim is to inform the recipients of aircraft noise on the minimum level of disturbance, none of which addresses the noise distribution at source. Legislators and planners which assess areas suitable for residential development. Develop solutions for those residents who have had their homes rendered not fit for purpose by airport development, these include: 1. Offer a buyout scheme for those who choose to leave the area. 2. Offer to insulate and bring up to current building code standard. 3. Legislate a capacity cap for Melbourne Airport, taking into account its location is land locked in all directions and the surrounding residential development. 4. Strength the building code and permit system for residential dwelling in areas affected by aircraft noise. 5. Remove the Deemed to Comply methodology to assess housing noise attenuation.
Hume Residents Airport Action Group 22 June 2021
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