DRAFT Submission to the Draft EIS - Divided into 4 separate submissions.
I have read through the EIS and as a resident of Greendale Road, Wallacia I am extremely concerned about the impact of the proposed RRO flight path which is going to create an unacceptable “significant and unavoidable level of noise exposure” in my own home (Part C of the EIS Summary). I am already losing sleep and my stress levels raised due to my concerns about the massive and undesirable changes the WSI operations will bring with the added anticipation anxiety of this unknown situation affecting our future. Should we move away now or wait and see or just accept whatever happens?
Our whole village community is going to be impacted. We have a small population of about 1600 and people here chosen this location for its quiet semi-rural appeal. We are used to hearing birds with the occasional roar of the big cats at Zambi wildlife centre. The traffic noise from Greendale Road is occasional and does not continue during the night. We do not want to have to move away from our home and large garden which is perfect for our family and lifestyle.
Being under or close to the flight path creates major problems of noise, air disturbance, air pollution, tank drinking water pollution, social disturbance, and a proven disadvantage to the health and wellbeing of our children.
We will NOT get used to the noise. Certainly not to begin with and as we just learn to accept it does not mean it has any less impact. As the noise increases in future “These changes, however, may remain of significance to some members of the community. “ - From the EIS.
Kingsford Smith Airport has a curfew. Any nighttime RRO flights there can use the ocean. We do not have one in Western Sydney. The solution is not to move the fights to another community. No one should be subjected to such incredible disruption to their lives.
2: There should be a NOISE ABATEMENT PROCEDURE advising Air Traffic Control to CANCEL the ‘RRO Early Right Turn Night Procedure’, when traffic permits, and instruct an initial 20 degree left turn.
3: Change the Early Right Turn Procedure to be: “at the latter of 500 feet above the ground or one nautical mile past the end of the runway” (or similar) to avoid overflying Wallacia village and consider a lesser right turn (say 10 degrees less) which would help and avoid Park River Close, Mulgoa.
Here are my concerns about about this unwanted and unacceptable situation affecting me and my community.
Noise.
From the website Aircraft Overflight Noise Tool
When RWY23 departure North Night and North East Night (RRO) is in use: Wallacia is directly under the flight path. An average of 7 departures up to a maximum of 10 departures could overfly this location when this runway operating mode is in use. The altitude above runway level is only 2500 -5000 feet. Properties close to the flightpath will still experience noise.
Day-evening movements :–(5.30am - 11pm) When Runway 23 is in use:
This location is within 4.7km of a WSI flight path :RWY23– Departure North Day.
When Runway 23 is in use: An average of 3 departures up to a maximum of 8 departure could overfly this location during the period when this runway operating mode is in use. The altitude above runway level is only 2500 -5000 feet.
Both scenarios show an average of 75 dBa
From the EIS, Wallacia noise prediction is to experience a noise level of 75 decibels (dBa) during typical overflight and as some aircraft can fly at a lower altitude according to the weather, the noise could be louder. At present Wallacia is regarded as the quietest at night time (Table 11.8) and will be one of the noisiest when the flights begin. Within the EIS all the negative impacts are calculated using average noise levels. Peak noise levels or frequency of noise events have not been taken into account in determining the severity of the impacts. People are not woken up at night by average noise.
Noise interferes with communication, disturbs sleep, and causes annoyance. Long-term exposure to relevant noise levels has been shown to be associated with negative health outcomes. Acute noise exposure can cause increases in blood pressure, heart rate, and cardiac output. Repeated noise-induced arousals reduce sleep quality through changes in sleep structure that includes delayed sleep onset and early awakenings, fewer deep and rapid eye movement sleep, and more time spent awake and in superficial sleep stages. Disturbed sleep leads to tiredness which can affect functions during the day with reduced work capability and the increased probability of accidents.
The EIS 11.5.1 states individuals and communities newly exposed to aircraft noise are likely to show an enhanced sensitivity to changes in the noise environment. Table 11.2 - Locations beyond each noise contour boundary may still be subjected to noise exposure from aircraft overflights. Even at low exposure levels, individuals may still experience annoyance, because individual reaction to aircraft overflight noise is highly subjective.
Considering that “Some aircraft may fly at a lower altitude depending on weather and operational conditions”. 65 dBA –70 dBA equates to conversation at 1 metre heading to the sound of a washing machine. “Every increase of 10 dB represents a doubling in perceived loudness”. How can we be expected to sleep with noise to the level of a washing machine or even a normal conversation going on? We do not watch TV, read a book, or have a conversation in a laundry room, because this is a level of noise that is not conducive with everyday activities. Similarly, we don’t have normal conversation in a room where a person is attempting to sleep and we do not have multiple normal conversations at once and talk over the top of our family members. Noise of 65 dBA –75 dBA will profoundly impact every single aspect of daily life.
“Falling on Deaf Ears” (FODE) Report of the Senate Select Committee on Aircraft Noise in Sydney November 1995 paints an alarming picture of long term complaints about noise and the inadequacy of the planning. The mistakes made with the introduction of the 3rd runway at Kingsford Smith airport are being repeated.
Respite
The EIS, Chapter 11, Aircraft Noise, page 69 (11.7.3.3 Detailed Respite Charts), identifies that under Runway 23 (for example), the village of Wallacia will only be afforded 1% respite from aircraft movements once the airport is at full capacity. As the WSI Noise Tool shows for some paths, a range of 2.5 to 5 kms either side of indicated path, can be assumed that the whole community will a have similar lack of respite from aircraft movements. The WSI Noise Tool shows that aircraft will fly over Wallacia at between 2500 feet and 5000 feet.
Runway 23 in 2055 at Wallacia school the percentage of days with respite
Day time 5.30am – 18.59 with maximum 9 planes 1%
Evening 19.00 – 11.29 100%
Night 11.30 – 5. 29 21%
Physical health
As already mentioned, long-term exposure to relevant noise levels has been shown to be associated with negative health outcomes. Noise exposure modifies the function of multiple organs and systems. Acute noise exposure can cause increases in blood pressure, heart rate, and cardiac output, likely mediated by the release of stress hormones. Studies show that these acute effects occur not only at high sound levels in occupational settings but also at relatively low environmental noise levels when concentration, relaxation, or sleep is disturbed.
We recognize, evaluate, and react to environmental sounds even while asleep. Repeated noise-induced arousals reduce sleep quality through changes in sleep structure that includes delayed sleep onset and early awakenings, fewer deep and rapid eye movement sleep, and more time spent awake and in superficial sleep stages. Several studies demonstrate that traffic noise causally disturbs sleep and, depending on noise levels, may impair performance, well-being and cardiovascular functions during the subsequent wake period.
From Section 20.5.2 Health Related Noise Impacts - Part C pg415
These health effects can include:
Mental health
Implementation of such a high concentration of flights over any communities and the lack of a curfew, will have incredibly detrimental effects on our mental health and will impose the risk of increased instances of stress, anxiety and depression. The unknown anticipation of this is already having a severe and adverse effect on our lives. It seems that our quiet, peaceful community has been taken advantage of due to our small population. This is unfair and inequitable and has already had a huge negative impact on residents’ mental health. The residents of Wallacia see their homes as a safe retreat from the demands of modern life and a place to restore their mental health. Flight operations 24 hours a day, 7 days a week, at between 2500 feet and 5000 feet with the added unpredictability of when and how often this will occur will create an incredible sense of unease.
If residents’ mental health is already suffering under proposed flight paths, it can be predicted that this suffering by way of instances of sleep deprivation, anticipation, stress, anxiety and depression, will only continue to increase once flights commence. It is imperative that the gravity of mental health concerns be recognised and that residents’ welfare, mental health and quality of life be prioritised. The solution is not to move the flight paths or the subsequent spill over to another community. No one should be subjected to such incredible disruption to their lives or experience such great risks to their mental health for the sake of conveniences or other interests.
Tiredness and irritability in family members can lead to domestic problems affecting the mental health of both adults and children. The reports that show that noise pollution reduces cognitive ability in school-age children, even long after they stop hearing it.
Property values
If I decide to sell my home and move away from the area my property is going to be devalued. It will eventually increase as the airport is established but that will not help me in the next few years as more properties come on the market and potential buyers are uncertain as to the future situation.
The evidence presented in numerous Australian studies, including the previously released WSA 2016 EIS Volume 4 Appendix P2 Property Values, within 4.1.2 Conclusion and Implications for this Study, clearly states multiple studies finding that properties which are exposed to 65 to 85 dBA of aircraft noise had seen average property reduction values of -10 % with some cases seeing up to -19%
Historical data supports this notion, as properties in such areas have consistently underperformed in comparison to surrounding regions. The primary reason for this underperformance is the significant issue of noise, particularly during the night, which directly affects residents' sleep and overall quality of life. Both noise and visual pollution will be experienced by property valuers and potential buyers,
The reduction in value affects our whole community. It is essential to consider the implications for renovators and new home builders who must account for flight paths resulting in higher costs for building materials to insulate against the less desirable night-time noise. The initial impacts of the proposed flight paths would not only be economic but also psychological, influencing the perception of buyers who may become less inclined to purchase homes in Wallacia.
Community Social structure
If long-term residents decide to move away, the social fabric of the community is disrupted as these are often the people who care about the community and are prepared to be involved and who understand the history. New families buying into the area take time to settle in and take an interest. In the short term it can be investors buying property and renting it to tenants who are unlikely to take an interest.
Weather
There is no information on the possible impacts of Climate Change. The Draft EIS is a prediction, a forecast and is only based on the last 10 years of weather data. The Draft EIS mentions ‘High temperatures can affect airport operations and temperature has an indirect relationship with air density. As temperature climbs the air becomes less dense and affects the climb performance of aircraft’. 3.3.1.4 Air pressure and temperature – Part A. Planes will need more distance to climb so will be at a lower height over our village. Given the increasing number of extreme weather patterns we are experiencing, due to climate change, why have there not been N60, N70, and LAmax contours created when the temperature reaches higher temperatures. In February 2020 the temperature in Wallacia peaked at 49.7°C.
Freight planes
There is nothing in the Draft EIS to explain the fleet mix or movement schedule. Many logistics companies will be setting up in the area to take advantage of the airport as well as the road network linkages on the M12, M4, M5, and M7. The Fedex distribution centre in Erskine Park is huge and more companies are likely to move their operations to WSI. If that is the case then what percentage of flights, especially at night, will be dedicated freight, and more importantly international freight with bigger and noisier aircraft?
Economics
The Draft EIS describes the economic and employment benefits to the local and Australian economy However, there is very little discussion on the negative impacts to individual household financial positions.
As residents of Wallacia and as self-funded retirees, my husband and I have concerns about the impact on our finances. Should the planned operations and flight paths of WSI stand as they are described in the Draft EIS then we may be forced to move away from Wallacia and our family home. This would mean moving away from the community we enjoy. To do so will impose a considerable financial burden.
The health system is already operating under increasing stress levels. There should be modelling that shows the cost to the economy due to accidents and lost productivity as a result of sleep deprivation.
A recent analysis of the economic cost of inadequate sleep in Australia (commissioned by the Sleep Health Foundation and completed by Deloitte Access Economics) reports that in 2016-17 financial year poor sleep caused $26.2 billion in financial costs and a further $40.1 billion in non-financial (loss of well-being) costs. The financial costs are predominantly due to lost productivity and to accidents.
In a media release on the 22nd December the BFPCA organisation published the findings of a study into the cost to the health system as a result of aircraft noise from Brisbane airport. The report estimates that aircraft noise related health issues will drain $18.9 billion dollars from the Queensland Health System by 2032. https://bfpca.org.au/health-study/
What will be the cost when there will be constant aircraft noise, no curfew and frequently interrupted sleep for Western Sydney residents?
Environmental
Western Sydney already has poor air quality and the EIS states that there will be no adverse affects. Implementing government suggested noise management strategies - including closing up vents and sealing gaps and keeping windows closed - are known to result in an increase in occurrences of mould and mildew in and around homes. Closing homes to fresh air to manage noise pollution will cause a dramatic change in air quality for residents living with breathing and respiratory conditions such as asthma and increase the likelihood of these conditions developing.
Air quality assessment shows no significant levels of pollution, except to the immediate northwest. As Wallacia is in this direction, there can certainly be windblown pollution or under certain weather conditions. However, even very small increases in carbon dioxide from the burning of aircraft fuel can increase the acidity of water which can affect those of us who rely on tank water for drinking. This is also detrimental to those of us who grow our own vegetables.
‘The project is not likely to have a significant impact on biodiversity’ However even a small effect can have long term consequences. Bird calls for mating and communication can be disrupted during the day and the night time noise can be unsettling for nocturnal animals. Our local wildlife is already under strain from loss of habitat and development.
Community engagement
As a final point of concern, there were no Community Information Sessions for Wallacia. The Pop-up stall at the Wallacia Festival in April 2023 was at my personal request and with the constant rain all day was poorly attended. We eventually got 2 staff members to attend a public meeting in our village hall, but only after complaints and follow ups from our Progress Association. As one of the suburbs most severely affected, we should have been given more respect for our community.
