Amendment C154 10 December 2012 Statement of Evidence
Hume Planning Scheme Amendment C154
Panel Hearing 10 December 2012
Statement of Evidence: Town Planning and Airport Planning
Prepared by: frent Kneebush Principal Planner and Managing Director Kneebush Planning Pty Ltd
Prepared for: Australia Pacific Airports (Melbourne) Pty Ltd (APAM)
23 November 2012 Hume Planning Scheme Amendment C154
Table of Gontents
3 4
6
7
8 Appendices
Appendix 1 Curriculum Vitae: Trent Kneebush Appendix 2 Statement of Compliance: Planning Panels Victoria Guide to Expert Evidence Appendix 3 APAM's Submissions Hume Planning Scheme Amendment C154
I lntroduction
My name is Trent Kneebush and I am Principal Planner and Managing Director of Kneebush Planning Pty Ltd. I am a qualified town planner and airport planner with 25 years of experience in the planning field.
I hold a Masters of Arts in Town Planning and have completed various airport planning courses within Australia and internationally. My CV is attached at Appendix A.
I currently provide town planning and airport planning consultancy advice to Australia Pacific Airports (Melbourne) Pty Ltd (APAM) on an ongoing basis.
I received oral and written instructions from APAM and Corrs Chambers Westgarth to prepare a statement of evidence on the potential town planning and airport planning impacts of Amendment C154 on Melbourne Airport and APAM interests. Amendment C154 applies to 236 hectares of land located on Mickleham Road, Greenvale. The amendment provides for the development of 2,895 residential lots and approximately 8,000 residents close to Melbourne Airport. The subject land is located approximately 2lkm north-east of the airport.
My experience in airport planning and involvement in metropolitan area and regional planning issues over time provides me with the expertise to make this statement.
A Statement of Compliance with respect to the Planning Panels Victoria Guide to Expert Evidence is provided in Appendix B.
1.1 Summary of Evidence
The development of new residential areas near Melbourne Airport and its flight paths will increase the number of people potentially subjected to aircraft noise, thus exacerbating the reverse sensitivity effects of the airport. This will inevitably lead to increased noise complaints which could prejudice the curfew free status of the airport. Such an outcome would be contrary to the State Planning Policy for Melbourne Airport which includes express strategies which seek to ensure the effective and competitive operation of Melbourne Airport and to ensure that any new use or development does not prejudice the optimum usage of Melbourne Airport including its curfew-free operation.
It is generally acknowledged within the airports industry that the Australian Noise Exposure Forecast (ANEF) system, which is the basis of the airport's current published noise contours and associated planning controls (ie. the Melbourne Airport Environs Overlay), has a number of limitations. Experience has shown that the aircraft noise problem is not confined to areas inside the ANEF noise contours. Aircraft noise does not stop at a contour line on a map. ln fact most complaints relating to aircraft noise at Australian airports come from people who live outside the published ANEF noise contours (ie. outside the 20 ANEF).
It is now generally recognised that basing land use planning decisions solely on ANEF noise contours, without reference to other noise information, is likely to lead to less than optimal land use outcomes for airports and surrounding areas. This is consistent with advice contained in the recently adopted NationalAirports Safeguarding Framework (NASF) particulary Guideline A: Measures for Managing lmpacts of Aircraft Noise. Hume Planning Scheme Amendment C1 54
ln accordance with the requirements of the Airports Act 1996, APAM is currently in the process of preparing the 2013 Master Plan for Melbourne Airport. This will include plans for construction of the airport's third runway. A new ANEF chart, to replace the 2008 ANEF, will also be contained in the new Master Plan. As was the case with previous reviews of the ANEF, it is expected that the 2013 ANEF contours will change when compared to previous ANEF contours. This could involve expansion of the ANEF contours in some places. ln accordance with NASF Guideline A, the 2013 Master Plan will also include N60/N65/N70 noise contours as a supplementary tool for guiding planning decisions around the airport. This type of aircraft noise contour information has never been formally published before for Melbourne Airport.
Adopting a precautionary approach, I believe it is premature to be considering rezoning of land near Melbourne Airport and its flight paths until the 2013 Master Plan, including the new ANEF and N60/N65/N70 contours, is approved by the Commonwealth Government. lf the rezoning is to proceed in advance of approval of the Master Plan, I believe the amendment should incorporate appropriate measures to mitigate any potential reverse sensitivity effects associated with Melbourne Airport.
Further discussion and justification surrounding these key concerns is provided in Sections 5 and 6 of this statement. Hume Planning Scheme Amendment Cl54
2 Melbourne Airport
The following section is drawn from information contained in lhe Melbourne Airpori Master Plan 2008,lhe Melbourne Airport Economic and Social lmpact Assessment 2012 and other data provided by APAM.
2.1 Historical Development
The decision to establish Melbourne Airport on the Tullamarine site was made because the site was located close enough to be reasonably accessible to the city, but far enough away from established areas so as to be able to operate without constraint. lndeed, the site was considered to be "one of the best airport sites in the world"1. Melbourne's first major airport at Essendon was already constrained in its operation due to surrounding development, and a new airport site to serve Melbourne was required.
Following selection of the site in 1959, construction of the airport began in 1964. This comprised much of the core airport infrastructure we see today, including the two existing runways and the main terminal complex. The airport operated its first scheduled domestic flights in 1970, followed a year later by the first international flight. Since the 1960s it has been envisaged that the airport would ultimately have four runways.
For the fust27 years of its operation Melbourne Airport was operated by the Commonwealth Government, including the FederalAirports Corporation (FAC), a government owned business enterprise. The FAC ceased operating the airport in 1997 when the current lease commenced under the Airports Act.
On 2 July 1997, APAM became the airport-lessee company for Melbourne Airport, with the responsibility of managing the airport for a 50 year period up to 2047. APAM has an option to further extend this lease by a further 49 years to 2096. Under the lease APAM manages all of the airport site including the airside, terminal and landside precincts and the road network within the site.
2.2 Growth Trends and Forecasts
Since 1970 over 505 million passenger trips have started or finished at Melbourne Airport. Passenger traffic has grown at an average rate of 92% per year since 1972.
ln the past 14 years the number of passenger trips at Melbourne Airport has doubled from 14.2 million to 28,3 million. ln the 10 years from 2002to 2012 passenger trips at Melbourne Airport grew at an average rate of 5.4o/o pü year. ln the same 10 year period aircraft movements grew at an average rate of 1.1%o per year.
Melbourne Airport currently facilitates the movement of over 28 million passengers and 21 0,000 aircraft movements annually.
Over the next 20 years the number of passengers travelling through the airport is expected to grow to 64 million. Aircraft movements are expected to increase to 348,000 in 2033.
I Commonwealth Parliamentary Debates, House of Representatives, 8/1 1/1962 , page 2223 per Mr Jess (LaTrobe). Hume Planning Scheme Amendment C154
2.3 Economic and Soc¡al Benefits
Over 7.9 million visitors come to Victoria via Melbourne Airport each year, who subsequently spend approx¡mately $g.g billion via tourism expenditure which is nearly half of all tourism expenditure in Victoria annually. Each international aircraft landing at Melbourne Airport contributes approximately $240,000 to visitor spending in Victoria. ln addition to the passenger movements, freight is also a significant element of Melbourne Airport's activities with the facilitation of approximately 250,000 tonnes of freight moved annually, which is more than a quarter of freight facilitated by all Australian airports combined. This is expected to grow to over 390,000 tonnes over the next 20 years.
To enable lhe 24 hour operation of the airport and the efficient movement of passengers and freight, there are currently 14,300 jobs based at Melbourne Airport. The number of jobs directly generated by the airport is expected to grow to 23,000 by 2033. Melbourne Airport indirectly supports 43,000 jobs, which is expected to increase to 72,000 indirect jobs in 20 years.
Melbourne Airport's current contribution to Victoria's Gross State Product is estimated to be approximately $1.47 billion. This is expected to increase to $3.21 billion in 2033. At present the curfew-free status of Melbourne Airport allows for the movement of an extra 2 million passengers a year and adds $590 million to the Victorian economy through visitor spending. By 2033 the value of the curfew-free status will increase to an additional 5 million passengers a yeæ and visitor spending totalling $1.3 billion.
98% of local residents surveyed as part of the Economic and Social lmpact Assessment see Melbourne Airport as an important factor in connecting Melbourne with other cities.
2.4 Airport Master Plans
During the 1980's it was recognised there would be a need to expand Melbourne Airport. However, future runway locations as shown in the 1960s Master Plan were no longer appropriate due to environmental considerations and the Master Plan existing at that time provided for only limited landside development opportunities. ln response to long range traffic forecasts covering the period 1990 to 2050, the airport's previous operator (the Federal Airports Corporation) and the State Government jointly developed a long term strategy for the airport's development and management.
The Melbourne AirporT Strategy was formally endorsed by both Federal and State Governments in 1990 following a comprehensive Environmental lmpact Study (ElS) involving extensive community and industry consultation. fhe Melbourne Airporf Strategy provided a broad framework for orderly airport development, road and rail access and external land use controlto protect the 24 hour, curfew-free operation of the airport. A key feature of the Strategy was provision for future development of wide-spaced parallel north-south and east-west runways to optimise hourly and annual capacities and operational flexibility.
Following privatisation in 1997, and as a requirement of the Airports Act 1996, the 1998 Master Plan was developed. Subsequent Master Plans were prepared in 2003 and 2008. These Master Plans have all been consistent with the findings of the 1990 Melbourne Airport Strategy and have maintained the Airport Strategy's recommendations for a future Hume Planning Scheme Amendment C154
four runway airside system. Each Master Plan has also incorporated an ANEF chart based on aircraft movement forecasts available at the time.
The next (2013) Master Plan is currently being prepared and is due to be placed on public exhibition in March 2013 and submitted to the Commonwealth Minister for approval in the second half of 2013. The 2013 Master Plan will include a revised ANEF chart based on up{o-date aircraft movement forecast data.
2.5 Melbourne Airport Environs Overlay Land use controls for the areas around Melbourne Airport have been in place for approximately 20 years. The purpose of these controls is to ensure that the efficient operation of Melbourne Airport and its economic benefits to Victoria, both now and in the future, are not adversely affected by inappropriate land use and development in the noise- affected areas surrounding the Airport.
Land use controls for the areas around Melbourne Airport were first implemented by the State Government in 1992. This first land use control was called the Melbourne Airport Environs Area. The introduction of the Victoria Planning Provisions in 1996 introduced the Airport Environs Overlay (AEO) which was applied to land around Melbourne Airport based on the 1992 Melbourne Airport Environs Area controls. The AEO is a standard provision in the Victoria Planning Provisions that can be used by any airport in Victoria. ln May 2007 a new overlay, the Melbourne Airport Environs Overlay (MAEO), based on the 2003 ANEF contours, was introduced into the Victoria Planning Provisions. This overlay incorporated improved and enhanced provisions specifically for Melbourne Airport in accordance with the outcomes of the Melbourne Airpoft Environs Strategy Plan 2003.
The State Government has indicated that the MAEO boundaries will be reviewed after the 2013 Master Plan and updated ANEF chart have been approved. Hume Planning Scheme Amendment C154
3 APAMIS Position
APAM has expressed concerns about this amendment due to the proposed number of residential dwellings and the proximity of the land to the airport. Copies of APAM's original and second submissions are attached at Appendix 3. ln its submission dated 22 August 2012, APAM stated:
APAM has concerns about thís amendment as it may affect future operations at Melbourne Airport including the cuffew-free status of the gateway to Victoria. ln particular we are concerned that the amendment makes virtually no mention of the proximity of the subject land to Melbourne Airport or safeguarding of the airpoft. Whilst the subject land is outside the current Melbourne Airport Environs Overlay (defined by the 20 ANEF contour) if rs sf/ located very close to Melbourne Airport. Fu¡fhermore, the southern paft of the subject land virtually abuts the MAEO. As noted on the airport's ANEF cha¡ts, "aircraft norse does not stop at the 20 ANEF contouf'. This information was omitted from the explanatory report but is an important consideration for the future development of this land and would no doubt be of concern to future res¡denfs.
APAM's original submission also stated:
A significant propottion of the proposed lots and future residenfs will be affected aircraft noise in the future. lt is not considered that the amendment has taken the above issues into account, or measures úo minimise potential adverse effects from aircraft noise. At the very least the amendment documentation should acknowledge the proximity of the land to Melbourne Airpoft and address fhe rssue of potential aircraft norse. lt is vitally important that cognisance be taken of the fact that the noise contours considered in the MAEO are under review, and it is highly likely that there will be some adjustments to them. To the same end Melbourne Airpoft consrders it extremely important to consider that while the 20 ANEF rs fhe norse exposure level considered in the MAEO, there are still high levels of noise beyond that contour which future residenfs may not know. Any residential densification so close to the airport and the current MAEO willjeopardise the curtew free status of Melbourne Airport, which ls recognlsed from a planning perspective as a highly important consideration for Victoria as a whole.
APAM's second submission dated 3 October 2012 stated:
...it is clear from information currently available that the subject land is located (at the very least) within the margins of Melbourne Airport's noise affected areas. As a result, adopting a precautionary approach, Melbourne Airport recommends that the planning and design of the Greenvale Central Structure Plan area should take into account the Airpoñ's proximity and the potential for aircraft noise effects. We recommend that the density of future residential development should be limited and noise attenuation of dwellings should be required, pafticularly in the southern portion of the land which ls c/ose to the MAEO. We also recommend that all future purchasers of land in the structure plan area should be notified of the proximity of Melbourne Airpoñ and the potentialfor aircraft noise impacts. Hume Plann¡ng Scheme Amendment C1 54
4 Legislation and Policy Gontext
4.1 Commonwealth Legislation
4.1 .1 Airports Act 1996 (Cth)
Melbourne Airport is situated on Commonwealth Government land and as such, is subject to Commonwealth legislation to regulate both its own business operations and those of its business partners including airlines, tenants and retail concessionaires. The primary legislation governing the operation, planning and development of the airport is the Aþorfs Act 1996 ("Airports Act"). The Airports Act and associated Regulations are the statutory controls for ongoing regulation of activities on the airport land for both aeronautical and non-aeronautical purposes.
As part of the planning framework, the Airports Act requires Melbourne Airport, as lessee of the airport, to prepare a Master Plan for the airport every five years setting out the 20 year strategic vision for the growth of airport activities and development of the airport site.
4.2 Commonwealth Policy
4.2.1 National Aviation Policy White Paper The Australian Government recognises the need for careful land use planning around Australian Airports, to avoid potential amenity impacts and to minimise restrictions on airport operations. The Government has a direct interest in protecting and maintaining the operational capacity of airports, given the economic and social benefits they provide. ln 2009 the Australian Government released the Nafional Aviation Policy White Paper (released December 2009) which consolidates all aviation policy into one document, setting out the planning, regulatory and investment framework for aviation up until 2020. The White Paper was developed following feedback received on previous papers (Aviation Green Paper and lssues Paper), providing opportunity for community and stakeholder input into the process. ln relation to airport planning and development, the White Paper states:
Continual investment in and upgrade of the aviation infrastructure at Australia's airports is needed to continue to drive Australia's productivity and economic performance. ln order to achieve this, airports need to be afforded the best possib/e planning and consultative framework-to allow for the development of their core aviation busrness, while encouraging their integration with the communities that neighbour them.
Safeguarding airports is another key issue addressed in the White Paper. ln this regard the paper states:
Suitable locations for airports are scarce. ln the rnferesús of safety and public amenity there should be minimaldevelopment in the vicinity of airport operations. However, there is also a need for airports to be easily accessib/e to population centres. lnappropriate development around airports can result in unnecessaty constraints on airport operations and impacts on community safety. There is hence a need to ensure that construction and development are undertaken in a way that is Hume Plann¡ng Scheme Amendment C154
compatible with airport operations, both in the present and taking into account future growth.
Recognising the economic value and scarcity of airport sites, the White Paper announced that the Australian Government would work with jurisdictions on a national land use planning regime near airports and under flight paths, to minimise sensitive developments being located in areas affected by aircraft operations. This ultimately led to the formation of the National Airports Safeguarding Advisory Group and the development of the National Ai rpo rts S afeg u ard ing F ra mework.
4.2.2 National Airports Safeguarding Framework
A key initiative of the National Aviation Policy White Paperwas to develop a national land use planning regime to apply near airports and under flight paths. The National Airporfs Safeguarding Advisory Group (NASAG), comprising high-level Commonwealth, State, Territory and Local Government transport and planning officials, was subsequently formed to develop a National Airports Safeguarding Framework (NASF). ln February/March 2012 industry, local government and other interested stakeholders were invited to comment on a draft version of the Framework comprising several guidelines relating to particular airport safeguarding topics (including Guideline A: Measures for Managing lmpacts of Aircraft Norse). Subsequently, Commonwealth, State and Territory Ministers considered the Framework at the Sfanding Council on Transpoñ and lnfrastructure (SCOTI) meeting on 18 ltlay 2012. At that meeting the Ministers agreed to the Framework noting the Commonwealth's intention to seek a review by Standards Australia of Australian Standard AS 2021-2000: Acousfics Norse lntrusion-Building Sifing and Construction.
This national land use planning framework, when fully implemented, will assist in ensuring that existing and future airpoil operations and their economic viability are not constrained by incompatible development.
It is the responsibility of each jurisdiction to implement the Framework into their respective planning systems. The Victorian Government is yet to announce how it intends to implement the NASF into the Victorian planning system.
4.3 State Legislation
4.3.1 Planning and Environment Act 1987 (Vic)
Part 3C of the Planning and Environment 1987 recognises the particular significance of Melbourne Airport by enabling the Minister for Planning to prepare a Strategy Plan for the Melbourne Airport Environs Area.
ln 2003, the Minister for Planning approved lhe Melbourne Airport Environs Strategy Plan under the Act.
Amendments to planning schemes must be consistent with the approved Strategy Plan (section 46X).
A key outcome of the Strategy Plan was the introduction of the Melbourne Airport Environs Overlay (MAEO) in 2007. Hume Planning Scheme Amendment C1 54
4.3.2 Transport lntegration Act 2010 (Vic)
As an lnterface Body under the Transport lntegration Act 2010 (Vic), a plann¡ng authority, including the Growth Areas Authority, is required to have regard to the transport system objectives and decision mak¡ng principles under that Act. For the purposes of that Act, the transport system is defined to include airports and flight paths.
One of the transport system objectives is that the transport system and land use should be aligned, complementary and supportive to ensure that "land use declsions are made having regard for the current and future development and operation of the transporf system".
Amendment C154, as exhibited, made no mention of the potential impact on Melbourne Airport and its flight paths.
4.4 State Policy The Victorian Government recognises the economic importance of Melbourne Airport and provides support to its protection through the Sfafe Planning Policy Framework (SPPF). Specifically, the SPPF states that airports, like other infrastructure assets, need protection from incompatible land uses so that their capabilities are enhanced and services are maintained.
4.4.1 SPPF Clause 11: Settlement
Under Clause 11.04-2 of the SPPF, Melbourne Airport is identified as a Specialised Activity Centre. Specialised Activity Centres are important economic precincts that provide a mix of economic activities and generate high numbers of work and visitor trips.
Melbourne Airport's status as a Specialised Activity Centre supports its ongoing development as one of the most important transport and economic hubs in Victoria.
4.4.2 SPPF Clause 1B: Transport
The SPPF gives support to Melbourne Airport through Clause 18.04-1 which seeks to strengthen the role of the airport and protect its ongoing operation and curfew-free status. This objective is given effect to through the following strategies under Clause 18.04-1 which seek to:
Ensure the effective and competitive operation of Melbourne Airport at both national a nd i nte rn ation al level s.
Ensure any new use or development does not prejudice the optimum usage of Melbourne Airport.
Ensure any new use or developmenf does not prejudice the curtew-free operation of Melbourne Airport.
Protect the curfew-free sfaúus of Melbourne Airport.
Furthermore, Clause 18.05 of the SPPF, which relates to freight links, seeks to maintain Victoria's position as the nation's premier logistics centre. As previously stated, freight is a significant element of Melbourne Airport's activities.
These policies support the protection of Melbourne Airport as a key economic driver within Victoria's economy. Hume Planning Scheme Amendment C154
4.5 Local Policy
The Municipal Strategic Statement (MSS) contained within the Hume Planning Scheme prov¡des further support of the SPPF and State objectives.
4.5.1 Hume Planning Scheme
The Hume MSS recognises the significant role Melbourne Airport plays in the local, metropolitan and State economy, particularly as an employment node, and seeks to ensure that the development and curfew-free operation of the airport are protected (Clause 21.03-4).
The Hume MSS identifies the following strategies necessary to achieve this objective:
Ensure that development does not occur in the environs of Melbourne Airport that might prejudice its continuing role as one of Victoria's key economic asseús.
Continue to support fhe use of the Melbourne Airpoft Environs Overlays and land uses fhaf ensure Melbourne Airport remains curtew free to ensure sustained economíc benefits for Hume City, Melbourne and Victoria.
10 Hume Planning Scheme Amendment C154
5 Managing Aircraft Noise and Land Use
Aircraft noise is an unavoidable by-product of an airport's operation and, whilst modern aircraft technology is quieter now than in the past, this is still a considerable issue that requires attention. The consideration of aircraft noise effects (and ground-based noise) is essential when making land use planning decisions around airports, in order to minimise ímpacts on future communities and protect the ongoing operation of the airport. Noise impacts from airports are a particular concern for residential land uses which, due to the nature of the activities, are more sensitive to noise effects than other land uses,
5.1 ANEF and AS202l System
Since the early 1980's the Australian Noise Exposure Forecast (ANEF) system, in association with Ausfra lian Standard A52021 : Acousfics - Aircraft Norse lntrusion - Building Slúrng and Construcfion, has been used as the primary tool to measure aircraft noise at airports across Australia, providing information based on average daily community exposure levels. The ANEF noise contours have been applied at Melbourne Airport as a basis for determining the areas to be included in the Melbourne Airport Environs Overlay (MAEO), controlling development through intensity restrictions, development controls and acoustic attenuation requirements. The MAEO only applies to areas within the published ANEF noise contours (i.e., inside the 20 ANEF contour).
Experience has shown however, that issues arise when applying the ANEF system as a strict planning tool, where areas within the ANEF noise contours are regulated and areas outside are not. ANEF contours are, by their very nature, 'averages' providing information across a geographic area for an average annual day, and therefore they fail to provide a full reflection of the noise generated by aircraft at a particular time and at a particular location. They also do not address airport ground-based noise such as ground running and engine testing. What this means is that the contours cannot be treated as a 'line in the sand' delineating areas which may experience aircraft noise from those areas which may not. There will always be situations where, due to local conditions, flight paths and changes to aviation activities, areas will experience higher or lower noise levels than the averages provided by the ANEF contours, ln this regard, Australian Standard 452021 states:
This Standard is not intended to be applied for the purposes of assessing the effects of noise from aircraft. However, it should be noted that the erïecfs of noise from aircraft are not confined to areas where the noise exposure exceeds 20 ANEF and may occur at or below 20 ANEF.
AS202l also states:
The actual location of the 20 ANEF contour is difficult to define accurately, mainly because of variation in aircraft flight paths. Because of this, the procedure of Clause 2.3.2 may be followed for building sifes oufside but near to the 20 ANEF contour.
Clause 2.3.2 o'f A52021 relates to conditionally acceptable development where noise attenuation is required.
The Victorian Civil and Administrative Tribunal (VCAT) provided discussion in regard to this matter in the case of Moorabbin Airport Corporation Pty Ltd and Ors v Kingston City Council and Mirvac Victoria Pty Ltd 120021, where the Tribunal referred to the "fuzziness" of
11 Hume Planning Scheme Amendment C1g
the ANEF contour, highlighting the difficulty in accurately defining the limits of the ANEF contour.
The effect of this, as discussed in the Department of lnfrastructure and Transport's Discussion Paper Safeguards for airpofts and the communities around fhem, is the recognition that:
Aircraft norse does not stop at a contour line on a map.
Despite this, the ANEF noise contours have been used as the primary measure of aviation noise, and have been used as the basis of most planning tools used to regulate and guide land use decisions in and around Australian airports (including Melbourne Airport). There are no airport specific statutory restrictions on land uses outside the published ANEF contours, even in areas between the 15-20 ANEF contours; however, as discussed above, these areas are not devoid of aircraft noise.
Furthermore, in many situations the sole reliance on the ANEF as a planning regulator has led to misguided community expectations. People living outside of the ANEF noise contours are given an expectation that they will receive little to no aviation noise as they are outside of the identified noise contours. However, often this is not the case, as these areas may still experience low to moderate noise levels given the location of arrival and departure flight paths. The effect of this is that people may experience a level or duration of noise that they are not anticipating, leading to complaints received by Airservices or Melbourne Airport. The Commonwealth's Discussion Paper Expanding Ways to Describe andAssess Aircraft Norse highlights this concern and states:
Unfoñunately experience in recent years has demonstrated that the aircraft noise problem is not confined to areas inside the noise contours. ln fact most complaints about aircraft noise at Australian airports come from people who live outside the published ANEF noise (ie, the 20 ANEF). At Sydney Airport during 1998 approximately 90% of the complaints came from resldenfs of areas outside the 20 ANEF contour.
On page 210 of the NationalAviation Policy White Paper it states:
History and experience has shown that aircraft nolse does not stop at a contour, and aircraft noise complaints are coming increasingly from areas well outside the 20 ANEF value.
Best practice land use planning around airports and flight paths should ideally take into consideration the range of noise information relevant to the local community including the location of flight paths, types of aircraft activity, numbers and timing of aircraft movements, the intensity of noise events from those movements and the comparison to ambient norse /evels. The ANEF and the current building standard A52021 should not be applied by planners in isolation or without merit-based judgement.
The provision of sufficient information to the general public and local communities on aviation noise effects and the level of noise they can reasonably expect in certain areas is a critical issue. As noted in the Commonwealth's Discussion Paper Expanding Ways to Describe and Assess Aircraft Norse the most strident noise complaints come from people who believe they have been misled in some way. Providing the right information is therefore critical to allow members of the public to make their own assessments with regards to noise expectations. This is a particular issue for people moving into an area that is already established and is subject to aircraft noise (i.e. second and subsequent
12 Hume Planning Scheme Amendment C'154
owners). These people may not have experienced aviation noise previously or may be unaware of the true noise impacts on the area. Again, for the reasons discussed above, reliance on the ANEF contours as a sole measure of aviation noise and planning regulations is likely to give the wrong message to these people, leading to noise complaints. People who purchase properties outside of the ANEF contours and the MAEO may believe or interperet that these areas do not experience noise, however, this may not be the case given the location of properties in relation to the airport and flight paths. ln this regard it is considered inappropriate to allow residential development in areas potentially affected by aircraft noise without adequate safeguards. Evidence shows that noise complaints received by airports leads to restrictions placed on airpoñ operations. Sydney Airport is a prime example of noise complaints received from the community leading to the Australian Government introducing a curfew (introduced in 1995) preventing aircraft departures and arrivals between the hours of 11pm - 6am. Other examples include Perth and Brisbane Airports where, in recent years there has been increasing public pressure and in some cases political support for the investigation and introduction of curfews to address noise complaints received from local residents.
ANEF contours must also be recognised as dynamic and subject to continual change. Noise contour maps are created every 5 years with the current Melbourne Airport noise contour maps last generated in 2003 (which provide the basis for the MAEO) and again in 2008. They are currently being reviewed by consultants (in consultation with Airservices Australia) in association with the preparation of the 2013 Master Plan. lt is evident that between the mapping exercises conducted in 2003 and 2008, the noise contours changed, expanding in some areas and reducing in others. lf urban development is permitted to be built right up to the boundary of the MAEO, no buffer can be safeguarded and there is little room for movement or change over time.
At best, the ANEF I AS2O21 system sets minimums and in the end the system is only intended to mitigate the effect of noise within buildings (ignoring the effect on outdoor spaces). The adoption of those minimums as the only planning tool by which to protect and support a key infrastructure asset such as Melbourne Airport is considered inadequate. This is one reason why the Commonwealth Government has recently initiated a review of 452021.
It is on this basis that it is considered necessary for the ANEF information to be supplemented by information from other sources to provide a more detailed and accurate reflection of the potential aircraft noise effects at certain areas. This information, combined with the ANEF information, should be used to inform planning and land use decisions around Melbourne Airport.
Such an approach is consistent with the policy direction provided within the Commonwealth's White Paper and the NASF which recognise the need to complement the ANEF system with other assessment tools.
5.2 NASF Guideline A and Nxx Gontours As mentioned in Section 4.2.2 of this statement, the recently adopted National Airpofts Safeguarding Framework (NASF) includes a guideline relating to managing aircraft noise impacts. This guideline (Guideline A) was developed in response to the limitations of the ANEF I AS2021system outlined above.
NASF was endorsed by Commonwealth, State and Territory Ministers at the Standing Council on Transporf and lnfrastructure (SCOTI) meeting on 18 May 2012.
13 Hume Planning Scheme Amendment Cl54
NASF Guideline A recommends the consideration of alternative aircraft noise metrics, in addition to the ANEF contours (which form the basis of the MAEO), for the purpose of guiding strategic planning decisions around airports. The primary alternative metric recommended is the use of N60/N65iN70 contours. At least a portion of the subject land could be affected by noise contours derived from those alternative noise metrics but this is yet to be precisely determined.
The 'Melbourne Airport Contours' chart contained in Attachment 2 of Guideline A indicates that a portion of the subject land is located within the Airport's N60/N65/N70 contours. However, as stated in APAM's second submission, the following should be noted:
¡ These contours were prepared by the Commonwealth Department of lnfrastructure & Transport, not Melbourne Airport. . The contours are based on 2007/08 data - and are therefore based on old data. . At the bottom of the chart it states "This diagram has been produced for illustrative purposes only. lt has been neither verified nor endorsed by Airservices Australia or Melbourne Airport". o The contour for six or more events of greater than 60 dB(A) between 11pm and 6am (referred to in Guideline A) is not included on the chart. This additional contour is critical for Melbourne Airport given its curfew-free status.
Given the above, APAM advised extreme caution when using the N60/N65/N70 contours chart contained in NASF Guideline A Attachment2for land use planning purposes as it does not provide a complete and up-to-date picture of Melbourne Airport's aircraft noise contours, particularly relating to aircraft noise at night.
APAM further advised that it is currently in the process of preparing a new suite of noise contours (including a new and complete set of N60/N65/N70 contours) based on up-to- date data and forecasts in association with the 2013 Melbourne Airport Master Plan. The new contours currently being developed will be based on data approved by Airservices Australia. A draft of these new noise contours will be released for public comment with the draft2013 Master Plan in February/March 2013.
It is noted that the new contours are being developed by two consultants engaged by APAM. lt is a complex and intensive process, involving consideration of different assumptions and scenarios. The process also involves close consultation with Airservices Australia, who will eventually need to endorse the new ANEF. This process has been undenvay for several months and is still progressing.
14 Hume Planning Scheme Amendment C154
6 Assessment
The expansion of residential development towards Melbourne Airport, near to its ANEF contours and the MAEO, has the potential to impact on the airport's activities through reverse sensitivity effects, generating noise and amenity impacts on sensitive land uses leading to complaints and ultimately undermining airport operations and the curfew-free status of the airport.
At present APAM is in the process of preparing a new Master Plan for the airport and a new suite of noise contours based on up-to-date data and forecasts. This will include consideration of the impacts of the proposed third runway, which is proposed to be parallel to the existing east-west runway. Until this work is complete it is not possible to precisely determine the extent of impact on the land which is the subject of C154.
Based on my knowledge and experience, I believe there is a risk that when the new contours are completed they could affect a portion of this proposed residential area but I am unable to say precisely where that boundary will lie. Regardless of where the boundary lies, it is clear to me that there is a risk that at least some future occupants of land in this area could be affected to some extent by aircraft noise, possibly including ground-based noise. ln its second submission, APAM stated:
Neverthelesg rT ls clear from information currently available that the subject land is located (at the very least) within the margins of Melbourne Airport's noise affected areas. As a result, adopting a precautionary approach, Melbourne Airpoft recommends that the planning and design of the Greenvale Central Structure Plan area should take into account the Airport's proximity and the potential for aircraft noise effects. We recommend that the density of future residential development should be limited and noise attenuation of dwellings should be required, particularly in the southern portion of the land which is c/ose to the MAEO. We also recommend that all future purchasers of land in the structure plan area should be notified of the proximity of Melbourne Airpoft and the potentialfor aircraft noise impacts.
I agree with this statement. I agree that adopting a precautionary approach to the protection of Melbourne Airport, a nationally significant infrastructure asset, is appropriate. To do otherwise would be short-sighted, and could lead to poor urban planning outcomes such as those we see around many other airports (eg. Moorabbin, Essendon, Sydney etc). Adopting a "its better to be safe than sorry" approach is also in line with Commonwealth, State and Local policy relating to airport safeguarding.
15 Hume Planning Scheme Amendment C154
7 Summary and Conclusion
Melbourne Airport is a major contributor to the growth of Victoria's economy through tourism, air freight and business development, the benefits of which are recognised throughout Commonwealth, State and Local policy documents. The protection of the airpod's operations is therefore of critical importance in order to sustain these benefits in the long term.
APAM is currently in the process of preparing the 2013 Master Plan for Melbourne Airport. This will include plans for construction of the airport's third runway. A new ANEF chart, to replace the 2008 ANEF, will also be contained in the new Master Plan. As was the case with previous reviews of the ANEF, it is expected that the 2013 ANEF contours will change when compared to previous ANEF contours. This could involve expansion of the ANEF contours in some places.
However, it is now generally recognised that basing land use planning decisions solely on ANEF noise contours, without reference to other noise information, is likely to lead to less than optimal land use outcomes for airports and surrounding areas.
The 2013 Master Plan will also include N60/N65/N70 noise contours as a supplementary tool for guiding planning decisions around the airport. This type of aircraft noise contour information has never been formally published before for Melbourne Airport. At least a portion of the subject land could be affected by these noise contours but this is yet to be precisely determined.
Adopting a precautionary approach, I believe it is premature to be considering rezoning of land near Melbourne Airport and its flight paths until the 2013 Master Plan, including the new ANEF and N60/N65/N70 contours, is approved by the Commonwealth Government. lf the rezoning is to proceed in advance of approvalof the Master Plan, lbelieve the amendment should incorporate appropriate measures to mitigate any potential reverse sensitivity effects associated with Melbourne Airport. To do otherwise could result in a poor planning outcome for the airport and future residents.
'16 Hume Planning Scheme Amendment C154
8 References
Airports Act 1996. Australian Standard A52021: Acousfics - Aircraft Norse lntrusion - Building Siting and Construction.
Expanding Ways to Describe and Assess Aircraft Nolse, Discussion Paper, Commonwealth Department of Department of Transport and Regional Services, Canberra, March 2000.
National Aviation Policy White Paper, Commonwealth of Australian, Canberra, December 2009.
Going Beyond Noise Contours, Discussion Paper, Commonwealth Department of Transport and Regional Services, Canberra, October 2003.
Guidance Material for Selecting and Providing Aircraft Norse lnformation, Department of the Environment and Heritage and the Department of Transport and Regional Services, 2003.
Hume Planning Scheme.
Melbourne Airpori Economic and Social lmpact Assessmenf 2012, SGS Econimcs and Planning.
Melbourne Airport Environs Strategy Plan 2003.
Melbourne Airport Master Plan 2008, Australia Pacific Airports (Melbourne) Pty Ltd, 2008.
Moorabbin Airport Corporation Pty & Ors vs Kingston City Council and Miruac Victoria Pty Ltd, [2000] vcAT 1999/101300.
N ati o n al Ai rpo ris S afeg u a rd i n g F ra m ewo rk, 20 1 2.
Safeguards for airports and the communities around fhem, Discussion Paper, Commonwealth Department of lnfrastructure, Transport, Regional Development and Local Government, Canberra, June 2009.
Safeguarding Airporfs and the Communities Around Them, Deparlment of lnfrastructure & Transport website:
Victoria Planning Provisions, State Planning Policy Framework, Clause 18.04-l Melbourne Airport.
17 Appendix I Gurriculum Vitae - Trent Kneebush Trent Kneebush "r,o
SUMMARY
Trent is the Principol Plonner ond Monoging Director of Kneebush Plonning Ply Lld. Trent hos 25 yeors experience os o Town Plonner, both os o Council plonning officer ond o plonning consultont. Trent's bockground is in oll ospects of town plonning including slotutory plonning, strotegic plonning, development opprovols, outhorily negotiolions ond odvococy. He provides plonning odvice ond ossistonce lo o ronge of government ond privote sector clienls. He represents clients of plonning oppeols ond ponel heorings ond olso octs os on expert witness on plonning issues.
Trent is olso o quolified Airport Plonner ond he hos extensive experience working on oirport plonning projects such os oirport mosier plons, oirport development plons ond oirport sofeguording. He hos worked on oirport plonning projects for o ronge of oirports including Melbourne Airport, Milduro Airport, Cowro Airport, Bollorot Airport, Bendigo Airport, Homilion Airport ond Echuco Aerodrome. A highlight of his cirport plonning projecl experience to dote wos his key role in the preporotion of Melbourne Airport's 2008 Moster Plon.
Trent con olso prepore oircroft noise exposure conlours for oirports using ihe lntegroted Noise Model (lNM) ond lhe Tronsporent Noise lnformotion Pockoge (TNIP). Given his town plonning bockground he is olso oble to convert lhese noise contours inlo effective lond use plonning controls.
The combinotion of Trenl's town plonning ond oirport plonning quolificotions ond experience provides him with o unique skill set when it comes to plonning ond protecting oirports. He con deolwith bolh on-oirport ond off-oirporl plonning issues, ond he understonds how they inlerrelole. He hos recent experience preporing plcnning scheme policies ond controls for oirports ond their sunounds.
QUATIFICATIONS
. lntegroted Noise Model Version 7 Troining Course, 5-7 Moy 2010 . Aerodrome Reporting Officer Troining Course, 29-30 Morch 2010 . Groduote Certificote - Airport Plonning. Swinburne Universily of TechnologV,20OT . Moster of Arts - Town Plonning, Victorio University of Technology, ì995 . Groduote Diplomo - Urbon Plonning, Footscroy lnstitute of Technology, 1989 . Bochelor of Arts - Urbon Studies, Footscroy lnstiiute of Technology, 1987
EXPERIENCE
. Monoging Director / Principol Plcnner, Kneebush Plonning Ply Ltd, Dec 2009-Presenl . Associote / Monoger Plonning of Beco Pty Ltd, 2004-2009 . Senior Town Plonner / Associole, KLM Gerner Consulling Group, 1998-2004 o Town Plonner / Stolulory Plonning Coordinotor. City of Wyndhcm,1987-1998
PROFESSIONAL MEMBERSH¡PS
. Austrolion Airports Associolion ¡ Victorion Plonning & EnvironmenlolLow Associolion . Plonning lnsiiluÌe of Ausirolio SPECIATIST SKILTS AND EXPERTISE
. Plonning Permit Applicotions . Plonning Scheme Amendments . Plonning ond Environment Act 1987 . Victorio Plonning Provísions . VCAT Appeols & Ponel Heorings . Airport Moster Plons . Mojor Development Plons (Airports Act ì99ó) . Airport Sofeguording . Airport Noise Exposure Contours (lNM ond TNIP) o Plonning Policies ond Controls for Airports & Surrounds . Advococy ond Authority Negoliotions
AIRPORT PROJECTS
Trent hos worked on the following oirport plonning projects:
Airpori Moster Plons . Milduro Airport Moster Plon 2000 . Milduro Airport Moster Plon Review 2005 . Bollorot Aerodrome Moster Plon 2005 . Melbourne Airport Moster Plon 2008 . Sunshine Coost Mosler Plon Review 2008 o Echuco Aerodrome Moster Plcn 2010 . Cowro Airport Moster Plon 2010 . Homilton Airport Moster Plon 201I . Bollorol Airport Moster Plon 2012 o Flinders lslond Airport Moster Plon 2012 . Melbourne Airport Mosler Plon 2013 (Current Project)
Moior DevelopmenT Plons o Melbourne Airport - Apoc Drive On-Romp MDP (Approved) . Melbourne Airport - Essendon Footboll Club Focility MDP (Approved) . Melbourne Airport - Airport Drive Project MDP (Currenl Project) . Melbourne Airport - Southern Precinct Terminol MDP (Cunent Project) . Moorobbin Airporf - Commerciol Development MDP (Current Projecl)
Plonninq Scheme Amendments o Milduro Airport (Amendment C20) . Bollorot Airport (Amendmenl C74) . Bendigo Airporl (Amendment Cl8) . Echuco Aerodrome (Amendmenl C76) . Homilton Airporl (Amendmenl C24)
Airport Noise Sludies . Bollorol Aerodrome Noise Modelling Sludy 2010 . Homillon Airporl Austrolion Noise Exposure Forecost 201I . Geroldfon Airport Noise Exposure Forecost Study 201 ì . Bendigo Airport Austrolion Noise Exposure Forecos|20l2
Other Relevont Proiects . Bollorot Aerodrome & WesT Common Lond Use Concept Plon 2008 . Bcllorot Aerodrome & Wesl Common lnfrcstructure Moster Plon 2008 . Melbourne Airport Plonning Consultoncy Services 2005-Presenl Appendix 2 Statement of Gompliance: Planning Panels Victoria Guide to Expert Evidence STATEMENT OF COMPLIANCE
Planning Panels Victoria: Guide to Expert Evidence
Name: Trent Kneebush MPIA
Address: 7 Earlsfield Road, Hampton, Vic 3188
Qualifications: . lntegrated Noise Model Version 7 Training Course, 5-7 May 2010 . Aerodrome Reporting Officer Training Course, 29-30 March 2010 . Graduate Certifìcate - Airport Planning, Swinburne University of Technology, 2007 . Masters of Arts - Town Planning, Victoria University of Technology, 1995 . Graduate Diploma - Urban Planning, Footscray lnstitute of Technology, 1989 . Bachelor of Arts - Urban Studies, Footscray lnstitute of Technology, 1987
Experience: . Managing Director / Principal Planner, Kneebush Planning Pty Ltd, 2009-Present . Associate i Manager Planning, Beca Pty Ltd, 2004-2009 . Senior Town Planner / Associate, KLM Gerner Consulting Group, 1998-2004 . Town Planner / Statutory Planning Coordinator, City of Wyndham, 1987-1998
Expertise: I am a qualified Town Planner and Airport Planner and I have extensive experience working in the land use planning field and on airport planning projects such as airport master plans, airport development plans, airport safeguarding and airport noise contours. I have worked on airport planning projects for a range of airports including Melbourne Airport, Mildura Airport, Cowra Airport, Ballarat Airport, Bendigo Airport, Hamilton Airport, Flinders lsland Airport and Echuca Aerodrome. I was a key contributor to the preparation of Melbourne Airport's 2008 Master Plan and am currently assisting in the preparation of the airport's 2013 Master Plan.
Other Gontributors: None Scope of Report: I was requested (written and oral instructions) to prepare a statement of evidence dealing with the following matters:
1. The history and current status of strategic planning for Melbourne Airport;
2. Whether the strategic planning process that is currently undenivay is likely to identify all/part of the PSP area as being subjectto potential noise impacts, and if so, the extent of those possible impacts;
3. How this information will or should be relied upon in future strategic planning decision making (and how that decision making is related to the processes which are currently underway per [1]); and
4. A statement expressing your opinion as to whether approval of Amendment C154 without adequate regard to airport strategic planning issues would be a good planning outcome. amendment documentation' Facts, matters and ' Examination of the assumptions upon . Analysis of Melbourne Airport's 2008 Master Plan, Melbourne Airport flight paths, which the report ANEF contours and the MAEO' proceeds: ' Review of relevant Commonwealth, State and local policies. . Review of relevant government discussion papers and guidelines.
Documents, materials Refer to Section I of this report (References). lt was at my discretion (and informed and literature used in by members of APAM) to research and utilise any such mate¡al I considered relevant. making report: To the best of my ability I have obtained such relevant material and I have concealed none of it from Panel.
Summary of opinions Refer to Section 7 of this report (Summary and Conclusion). of expert:
Provisional opinions None unless specified in the report. not fully researched:
Questions outside Growth forecasts. Economic benefìts of Melbourne Airport. expert's expertise:
Report incompleteness None known' or inaccuracies
Declaration: I have made all the inquiries that I believe are desirable and appropriate and no matters of significance which I regard as relevant have to my knowledge been withheld from the panel. Appendix 3 APAMts Submissions MEtBOURNE AIRPORT 22 Augus|20l2
AIRPORT MANAGEMENT LEVEL 2, T2 MELBOURNE AIRPORT
Growth Areas Authority TOCKED BAG Ió Level 29 GLADSTONE PARK VICTORIA 3043 AUSTRALIA 35 Collins Street MELBOURNE VIC 3OOO TEL: (ól 3) 9297 1600 FAX: (óì 3) 9297 \886
w,melbourneoirporl.Gom.ou
Dear Sir/ Madam
Hume Planning Scheme Amendment Cl54 Greenvale Gentral Precinct Structure Plan
Australia Pacific Airports (Melbourne) Pty Ltd (APAM) wishes to make the following submission regarding the above mentioned Planning Scheme Amendment.
Melbourne Airport understands the amendment applies to land included in the Greenvale Central Precinct Structure Plan which incorporates 236 hectares centred on Mickleham and Somerton Roads. We understand that the amendment could allow the development of up to 2,800 new homes for 8,000 new residents.
APAM has concerns about this amendment as it may affect future operations at Melbourne Airport including the curfew-free status of the gateway of Victoria. ln particular w€ are concerned that the amendment makes virtually no mention of the proximity of the subject land to Melbourne Airport or safeguarding of the airport. Whilst the subject land is outside the current Melbourne Airport Environs Overlay (defined by the 20 ANEF contour) it is still located very close to Melbourne Airport. Furthermore, the southern part of the subject land virtually abuts the MAEO. As noted on the airport's ANEF charts,"aircraÍl noise does not stop at the 20 ANEF contour". This information was omitted from the explanatory report but is an important consideration for the future development of this land and would no doubt be of concern to future residents.
Most complaints relating to aircraft noise at Australian airports (including Melbourne Airport) come from people who live outside the published ANEF noise contours (Expanding Ways to Describe and Assess Aircraft Norse, Department of Transport and Regional Services, March 2000). lt is now generally recognised that basing land use planning decisions solely on ANEF noise contours, and associated planning tools, is likely to lead to less than optimal outcomes for airports.
1
Austrolio Pocific Airports (Melbourne) Ply. Ltd. A.C N. 07ó 999 114 A.B.N ó2 076 999 114
Melbourne AirporÌ is o lrode mork of Auslrolio Pocific Airporls (Melbourne) Ply, Ltd. APAM is concerned that the amendment does not address or respond to the following:
. The National Aviation Policy White Paper Flight Path to the Future (December 2009). On page 11 of the White Paper it states:
Airports are scarce and valuable transport hubs. ln rnosf cases their existence has pre-dated the spread of residential areas and it is not in Australia's overall national interest for existing airpoft operations to be threatened by new residential developments on greenfíeld sifes close to airports or under established flight paths. Best practice planning, both in terms of housing poticy and aviation policy, should not place residential developmenfs c/ose to airports under aircraft flight paths. For this reason, the Australian Government will work with state and territory governments to ensure that development near airports and under flight paths is compatible with the future safe operation and growth of airports.
On page 210 of the White Paper it states:
History and experience has shown that aircraft norse does not stop at a contour, and aircraft noise complaints are coming increasingly from areas well outside the 20 ANEF value.
Best practice land use planning around airports and flight paths should ideally take into consideration the range of noise information relevant to the local community including the location of flight paths, types of aircraft activity, numbers and timing of aircraft movements, the intensity of noise events from those movements and the comparison to ambieñt noise levels. The ANEF and the current building standard A52021 should not be applied by planners in isolation or without merit-based judgement.
The National Airports Safeguarding Framework (NASF), and in particular Guideline A: Measures for Managing lmpacts of Aircraft Norse. NASF was endorsed by Commonwealth, State and Territory Ministers at the Standing Council on Transport and lnfrastructure (SCOTI) meeting on 18 May 2012.
NASF Guideline A recommends the consideration of alternative aircraft noise metrics, in addition to the ANEF contours (which form the basis of the MAEO), for the purpose of guiding strategic planning decisions around airports. At least a portion of the subject land is likely to be affected by noise contours derived from those alternative noise metrics.
The COAG Reform Council Review of capital city strategic planning sysfems, in particular Criterion 3 Nationally significant infrastructure. This review notes that capital city strategic planning systems should provide for nationally significant economic infrastructure and the transport corridors that serve them (both new and upgrades of existing).
The Australian Standard AS 2021- 2000 Acoustics - Aircraft Noise lntrusion -Building, Siting and Construction (AS 2021 ).
AS 2021 acknowledges that areas outside but near to the 20 ANEF contour proposed for noise sensitive development should be in some cases treated as if they were within the 20 ANEF contour. The reason for this is based on evidence that around a third of the population may be seriously or moderalely affected by aircraft noise at the 15 ANEF contour. . State Planning Policy Framework Clause 18.04-'l: Melbourne Airport, which includes the following strategies:
o Ensure the effective and competitive operation of Melbourne Airport at both national and international levels. o Ensure any new use or development does not prejudice the optimum usage of Melbourne Airport. o Ensure any new use or development does not prejudice the curfewfree operation of Melbourne Airport. o Protect the curfew-free status of Melbourne Airport.
. The Melbourne Airport Environs Strategy Plan prepared under Part 3C of the Planning and Environment Act 1987. Sections 46X and 46Y of the Act require that planning scheme amendments and works cannot be inconsistent with the Strategy Plan.
. ln relation to the Transport lntegration Act 2010, the amendment makes no mention of the potential impact on Melbourne Airport and its flight paths. For the purposes of that Act, the transport system is defined to include airports and flight paths. ln addition to the above considerations, we are also note the following matters which are also important considerations in respect of Amendment C154:
At the same time SCOTI endorsed the NASF, the Commonwealth announced its intention to seek a review of AS 2021. This review, which is about to commence, could have significant implications for land use planning in areas around airports in Australia.
APAM is currently preparing the 2013 Melbourne Airport Master Plan in which the current ANEF contours will be reviewed. ln addition, planning has commenced for the airport's third runway which may also influence the noise contours, and may alter the existing Melbourne Airport Environs Overlay (noise contours)as identified in the Hume Planning Scheme.
Tlrc Melbourne Airport Environs Strategy Planis scheduled to be reviewed in 2013 to align with the 2013 Master Plan.
The proposed Planning Scheme Amendment and estimated number of future residents will have a significant impact on the surrounding road network. The increase in tratfic will have implications on both Mickleham Road including entry and exists, and Western Avenue and at peak periods will significantly impact the traffic flow on the Tullamarine Freeway. lt ís important to acknowledge the potential increased traffic in respect to this amendment will have efficiency implications that may impact on the road network to the airport.
Hume Planning Scheme C142, recently gazetted, rezoned land in Westmeadows for residential purposes. The subject land was partly affected by the MAEO. Through negotiation between the parties (including APAM) it was agreed that a Section 173 Agreement should be applied to all future residential lots within the rezoned area (including lots outside the MAEO) requiring:
o Notification of future landowners about potential aircraft noise; o A limit on the number of residential lots; and o All buildings to be used for residential purposes to be noise attenuated in accordance with Australian Standard AS 2021-2000.
Amendment C154 provides for the development of 2,895 lots and approximately 8,000 residents close to Melbourne Airport. A signfficant proportion of the proposed lots and future residents will be affected aircraft noise in the future. lt is not considered that the amendment has taken the above issues into account, or measures to minimise potential adverse effects from aircraft noise. At the very least the amendment documentation should acknowledge the proximity of the land to Melbourne Airport and address the issue of potential aircraft noise. lt is vitally important that cognisance be taken of the fact that the noise contours considered in the MAEO are under review, and it is highly likely that there will be some adjustmenls to them. To the same end Melbourne Airport considers it extremely important to consider that while the 20 ANEF is the noise exposure level considered in the MAEO, there are still high levels of noise beyond that contour which future residents may not know. Any residential densification so close to the airport and the current MAEO will jeopardise the curfew free status of Melbourne Airport, which is recognised from a planning perspective as a highly important consideration for Victoria as a whole.
Melbourne Airport has convened the Planning Consultation Forum (PCF), in response to the Aviation White Paper, to foster high level strategic discussions between the airport, and Commonwealth, State and local government representatives to improve the coordination of planning for the airport site and surrounding areas. The Aviation White Paper states "the PCF allows airport and government representatives to discuss issues and exchange information on airport planning and operations and on the implications for the airport of development in the surrounding areas". To date the PCF and Melbourne Airport have not been formally advised of, or invited to commenl on the Hume Planning Scheme Amendment C154, Greenvale Central Precinct Structure Plan. lt is important that the forums set up for engagement of this nature are utilised to their fullest.
APAM would like to discuss this amendment with the Growth Areas Authority to ensure that the impact of aircraft noise is properly addressed and potent¡al impacts on future residents are minimised.
Please contact Trent Kneebush, APAM's Planning Consultant, on 0409 944 898 to arrange a meeting to discuss this submission. APAM wishes to be heard at any panel hearing that may be held regarding this amendment.
Yours faithfully
Bryan Thompson
General Manager
Asset and lnfrastructure Planning
Copy to: Marianne Richards - Department of Transport John Ginivan - Department of Planning and Community Development Michael Sharp - Hume City Council ftIETBOURNE AIRPORT 3 October 2012 AIRPORÏ MANAGEMENT LîIEL 2. T2 MELBOURNE AIRPORT
LOCKEO BAG Ió Mr Tim Peggie GLADSTONE PARK Growth Areas Authority VICTORIA 3043 AUSTRATIA Level 29 TEL: (ól 3) 9297 1600 35 Collins Street FAX: {óì 31 9297 1886 MELBOURNE VIC 3OOO m.mêlbourneqlrporl.(om.ou
Dear Tim
Hume Planning Scheme Amendment Cl54 Greenvale Central Precinct Structure Plan
I refer to our meeting on 27 September 2012 regarding the above amendment and our submission in relation to that amendment.
At our meeting you requested further information to explain our concerns and the issues raised in our submission. To this end, please find attached a copy of the 'Melboume Airport Safeguarding Discussion Paper' that was prepared early this year and presented to the Planning Coordination Forum (PCF)in February.
We would also point you to our submissions to the Logical lnclusions Advisory Committee and that Committee's final report. 'Airports' was one of six key threshold issues that the Committee identified as relevant to its considerations. Some key quotes from the Committee's report, in terms of airport safeguarding issues, were:
"lt is unclear to the Committee what planning logic allowed new urban development (such as Hillside) on land surrounding the Airport." "Given that the ANEF that underpins the MAEO is subT'ecf to review, it does not seetn a secure basis for determining the extent of urban development near the Airport." "Any fufther encroachment of residential development towards the Airport should be avoided. The Committee agrees with APAM that aligning the UGB to noise contours is nof appropriate."
Picking up on one of our key concems, the Committee describes how "there is a vacuum between the policy objective of not prejudicing the operations of the AirporT, and what this means in terms of restrictions on developmenf". This supports the recommendations of the 'Melbourne Airport Safeguarding Discussion Paper' that was presented to the PCF in February. This is why the PCF and DPCD are in the process of setting up a Melbourne Airport Safeguarding Working Group to look into ways in which the current planning controls relating to airport safeguarding could be improved.
Melboume Airport is concerned that residential development within the C154 area will be affected by aircraft noise. Whilst the subject land is located outside the MAEO, this does not
1.
Auslrolio Pocific Airporls (Melbourne) Ply. Lld. A.C.N. 076 999 114 A.B.N. ó2 076 999 114
Melbourne Airporl is o lrode mork of Auslrolio Pocific Airporls (Melbourne) Ply. Lld. mean ¡t will not experience aircraft noise. As stated in our original submission, most complaints relating to aircraft noise come from people who live outside the published ANEF contours, often a significant distance. ln this case, the subject land is located relatively close to the airport and its flight paths which is reflected by the fact that the southern portion of the land abuts the MAEO,
Given the recognised deficiencies of the ANEF system, Guideline A of the 'National Airports Safeguarding Framework, Measures for Managing lmpacts of Aircraft Noise' recommends the use of N60/N65/N70 noise contours as a supplementary tool for guiding planning decisions around airports. The 'Melboume Airport Contours' chart contained in Attachment 2 of Guideline A indicates that a portion of the subject land is located within the Airport's N60/N65/N70 contours. However, the following should be noted:
. These contours were prepared by the Commonwealth Department of lnfrastructure & Transport, not Melbourne Airport. . The contours are based on2007l08 data - and are therefore based on old data. . At the bottom of the chart it states "This diagram has been produced for illustrative purposes only. lt has been neither verified nor endorsed by Airservices Australia or Melbourne Airport". . The contour for six or more events of greater than 60 dB(A) between 11pm and 6am (referred to in Guideline A) is not included on the chart. This additional contour is criticalfor Melbourne Airport given its curfew-free status,
Given the above, we advise extreme caution when using the N60/N65/N70 contours chart contained in NASF Guideline A for land use planning purposes as it does not provide a complete and up-to-date picture of Melbourne Airport's aircraft noise contours, particularly relating to aircraft noise at night.
We are currently in the process of preparing a new suite of noise contours (including new and complete set of N60/N65/N70 contours) based on up-to-date data and forecasts in association with the 2013 Melbourne Airport Master Plan. The new contours currently being developed will be based on data approved by Airservices Australia. A draft of these new noise contours will be released for public comment with the drarft 2013 Master Plan in February/March 2013.
Nevertheless, it is clear from information currently available that the subject land is located (at the very least) within the margins of Melbourne Airport's noise affected areas. As a result, adopting a precautionary approach, Melbourne Airport recommends that the planning and design of the Greenvale Central Structure Plan area should take into account the Airport's proximity and the potential for aircraft noise effects. We recommend that the density of future residential development should be limited and noise attenuation of dwellings should be required, particularly in the southern portion of the land which is close to the MAEO. We also recommend that all future purchasers of land in the structure plan area should be notified of the proximity of Melbourne Airport and the potential for aircraft noise impacts.
The decision of VCAT in Moorabbin Airport Corporation Pty Ltd & Ors v Kingston City Council and Mirvac Victoria Pty Ltd (1999/101300) supports this recommendation. ln that case VCAT determined that noise attenuation was appropriate for dwellings on land outside but near to the 20 ANEF contour. Furthermore, Australian Standard A52021-2000 'Acoustics - Aircraft Noise lntrusion - Building Siting and Construction' states:
"The actual location of the 20 ANEF contour is difficutt to define accurately, mainly because of variation in aircraft flight paths. Because of this, the procedure of clause 2.3.2 may be followed for buitding sites outside but near to the 20 ANEF contour."
Clause 2.3.2 of AS2021 relates to conditionally acceptable development where noise attenuation is required.
Our recommended approach for addressing potential aircraft noise impacts on the subject land is consistent with the outcomes of 'Hume Planning Scheme Amendment C142'wnich was referred to in our original submission. C142 included a requirementfora Section 173 Agreement that will be registered on all of the future residential lots (including lots outside the MAEO) requiring:
o Notification of future landowners about potential aircraft noise; ¡ A limit on the number of residential lots; and . All buildings to be used for residential purposes to be noise attenuated in accordance with Australian Standard AS 2012-2000.
We trust this further submission clarifies your queries in relation to our original submission. However, should you require any further information please contact Trent Kneebush, APAM's Planning Consultant, on 0409 944 898.
APAM wishes to be heard at any panel hearing that may be held regarding this amendment.
Yours faithfully
Bryan Thompson General Manager Asset and lnfrastructure Planning
Copy to: Marianne Richards - Department of Transport John Ginivan - Department of Planning and Community Developmenl Michael Sharp - Hume City Council
T t