[Peetwo]

TICK TOCK goes the DFO disaster warning clock -   

There were ten in the bed –

P2 has provided a great deal of data relating not only to the proposed development of a new hospital at Tweed Heads, but to the general disregard for public safety in and around our aerodromes. This latest debacle has been caught in the slips – before ground is actually broken and the building ‘exists’. Unlike the DFO at Essendon which, like Topsy, grew and grew, without any adult supervision. Indeed, the responsibility ball was passed around so quickly that it is almost impossible to determine how the minister was prepared to sign the wretched approval and on who’s say so. Result five dead, a fire and the potential for carnage on a grand scale. I’ll say it again – ‘we’ were incredibly lucky that the Essendon crash of a five ton aircraft at better than 200 Kph, into a potentially busy shopping complex was NOT very nearly one of the worlds worst aviation disasters.

Doc. Gates is heavily involved in the proposed siting of a new hospital – P2 has provided the ‘words and music’ .– HERE.

One particular paragraph from Gates ../

"There are better solutions to the current problem such as a new location for the hospital.  Health claims it reviewed 30 potential sites for the hospital.  Surely one of these would be better than the current site? The State government needs to make the site evaluation process public so that we can see how the current site was chosen.  Public access to this process is critical to public confidence in our institutions and the political process for this controversial hospital site."  

/.. grabbed my attention. The sentence (my bolding) gets to the heart of the matter. I have asked a couple of folk, developer types I know, how the process really works. In short, it is not ‘corrupt’ in fact it is completely legal. It works like this: the sequence and timing of events is super critical, a bit like the three card trick, or; the shell game. Let’s say you own a parcel of land; then one day a Benz or Beemer pulls up at the farm gate and a fellah say’s “I’d like to buy that tract of land down there, by your Southern boundary”. You scratch your head for while, working out the value then add a healthy margin and state your price. “Deal” say’s the buyer and so it is done. Speculators DO NOT part with a bucket full of cash just because the view of the swamp appeals to their sense of nature and beauty. Now the local council (or whatever) announce there is to be a new hospital built on that land, the site has been deemed the ‘best’ spot for it. Cui bono?  

The only ‘problematic’ parts left are public protests and ‘safety’ concerns; but reports are written for those who pay for them, it is a wordsmiths business to shade and colour the reports, not actually ‘lying’ through their teeth, but eloquently shading the ‘awkward’ bits to seem ‘plausible’. Aye, tis a game worthy of Caligula; Machiavelli would have approved.

Before there is a major catastrophe (for the government) involving the deaths of the public or patients in a hospital; someone needs to get a rope on developments around airports. The British system, developed and researched by the USA into a scientific ‘formula’ for reducing and mitigating the risks of aircraft, the public and buildings colliding is freely available. Why can that code not be made into law? A honest man could sort it out – but where; in this godforsaken political environment do you find one that species?

Have been doing some digging of late and the more I dig the more disturbing the airport tale becomes. In order to simplify this unbelievable tale of corruption, where human greed simply overwhelms IMO the greater issue of mitigating the risk to public safety around airports, I propose to start from the present and working backwards on what I will dub the TOASI (timeline of airport safety ignorance).

One of the (potentially...err maybe?) good things that come out of Albo's GWEAP (Great White Elephant Aviation Paper) was the formation of the NASAG (National Airports Safeguarding Advisory Group). This group of Federal/State/Local Govt bureaucrats was tasked by the Rudd Labor Govt to set in motion the setting up of guidelines under the banner of the NASF (The National Airports Safeguarding Framework):

The National Airports Safeguarding Framework is a national land use planning framework that aims to:

• improve community amenity by minimising aircraft noise-sensitive developments near airports; and
  
  
• improve safety outcomes by ensuring aviation safety requirements are recognised in land use planning decisions through guidelines being adopted by jurisdictions on various safety-related issues.
  

The National Airports Safeguarding Advisory Group (NASAG), comprising of Commonwealth, State and Territory Government planning and transport officials, the Australian Government Department of Defence, the Civil Aviation Safety Authority (CASA), Airservices Australia and the Australian Local Government Association (ALGA), has developed the National Airports Safeguarding Framework (the Framework).

This process has taken nearly a decade to get close to some sort of consensus amongst the bureaucrats (Federal/State/Local)

This brings me to the present - 2 months ago our dopey NFI miniscule signed off on the NASF guideline on PSAs (Public Safety Areas) around airports: (ref here for links: https://infrastructure.gov.au/aviation/e...lines.aspx )

The new National Airport Safeguarding Framework (NASF) Guideline I on Public Safety Areas (PSAs) was agreed by Ministers at the Transport and Infrastructure Council on 9 November 2018.

PSAs are designated areas of land at the end of airport runways within which certain planning restrictions may apply. The new PSA Guideline was developed to mitigate the risk of on-ground fatalities from an aircraft incident, by informing a consistent approach to land use at the end of Australian airport runways.

In March 2018, the Transport and Infrastructure Senior Officials' Committee agreed to the National Airports Safeguarding Advisory Group (NASAG) publicly consulting on the new NASF Guideline - Managing the Risk in Public Safety Zones at the Ends of Runways.

This public consultation process commenced on 11 May 2018 and closed on 12 July 2018.
Submissions were considered by NASAG and used to inform further drafting of the Guideline.

 
 
"..In March 2018, the Transport and Infrastructure Senior Officials' Committee agreed to the National Airports Safeguarding Advisory Group (NASAG) publicly consulting on the new NASF Guideline - Managing the Risk in Public Safety Zones at the Ends of Runways....This public consultation process commenced on 11 May 2018 and closed on 12 July 2018...Submissions were considered by NASAG and used to inform further drafting of the Guideline..."    - Of interest here is that when you search the Dept website or Google any of the combinations around NASF consultation etc..etc you will not find any submissions from any relevant stakeholders. This would appear to indicate that although the Dept has said they have consulted there is NO public record of such consultation - WTF?  

However I did stumble across one letter of correspondence from AusALPA to 'Dear (Old) Lachie ( )' from the Dept which IMO absolutely nailed the significant and (disturbingly) still outstanding safety issues surrounding (inappropriately unsafe - ala YMEN DFO) urban development encroachment around airports...  

Ref: https://www.aipa.org.au/media/1136/17-10...-zones.pdf

AUSALPA COMMENTS ON THE NATIONAL AIRPORTS
SAFEGUARDING FRAMEWORK DRAFT GUIDELINE - MANAGING
THE RISK IN PUBLIC SAFETY ZONES AT THE ENDS OF RUNWAYS

The Australian Airline Pilots’ Association (AusALPA) represents more than 5,000
professional pilots within Australia on safety and technical matters and we welcome the
opportunity to contribute to improvements in aviation security in Australia.

AusALPA is the Member Association for Australia and a key member of the
International Federation of Airline Pilot Associations (IFALPA) which represents over
100,000 pilots in 100 countries. Our membership places a very strong expectation of
rational, risk and evidence-based safety behaviour on our government agencies and
processes. We regard our participation in the work of the Department of Infrastructure
and Regional Development (DIRD) as essential to ensuring that our aviation and
airports policy makers get the best operational safety and technical advice that is
completely independent of the vested commercial interests that currently dominate
Australia’s aviation regulation decision-making.

Our Commitment

More than any other stakeholders, our members sample the positives and negatives of
our approach to airport safeguarding every day. Consequently, AusALPA is committed
to the NASF and the Guidelines as well as the long-term strategy of a single broadbased
national approach to safeguarding aviation infrastructure at all levels of government across
Australia.

The Downside of Federalism

AusALPA is entirely sympathetic to the difficulties faced by DIRD in trying to influence
the States to adopt robust safeguarding measures for our aviation infrastructure. While
we understand that the States are wary of the economic consequences of various
safeguarding proposals, history already tells us that failure to act decisively and at the
first opportunity will not be forgiven in the aftermath of a major accident.

We were astounded to discover that the UK, following the recommendations of the
Committee on Safeguarding Policy (the Le Maitre Committee), has had Public Safety
Zones (PSZs) in place at major UK airports since 1958. The US has had the
equivalent prior to 1989 and the Netherlands reviewed their existing policy settings
following the 1992 El Al crash after take-off that killed 39 people on the ground.

While we note that DIRD has been trying to get agreement from the States on PSZs for
about a decade, AusALPA strongly suggests that the NASAG should closely ponder on
the irony that we in Australia will still not have national PSZ planning restrictions in
place some 60 years after the Le Maitre Committee in the UK provided all the
necessary public safety policy considerations. NASAG should take no comfort in
Australia’s good fortune in regard to major aviation accidents and certainly should not
continue to prevaricate in establishing a universally stringent set of safeguarding rules.

Our Major Concerns

Our major concerns in this particular safety/public risk debate are about the extent to
which both the economic consequences and the size of the affected population may be
understated in order to nudge the risk management aspects across the line.

Economic Consequences

The Covering Document states:

The introduction of a PSZ will not have any impact upon existing properties.
While it may be true that existing land use remains unaffected under this proposal, the
principled approach set out in the UK Department of Transport Circular 01/2010
Control of Development in Airport Public Safety Zones includes:

The basic policy objective governing the restriction on development near civil
airports is that there should be no increase in the number of people living, working
or congregating in Public Safety Zones and that, over time, the number should be
reduced as circumstances allow.

The proposed Guideline appears to be ignoring this issue as well as the fact that any
future planning restrictions will have a material effect on property values, especially
where lucrative redevelopment options will now be prevented. AusALPA suggests that
these economic consequences, while regrettable, are nevertheless necessary for the
greater public good.

Spatial Considerations

AusALPA is particularly concerned about this quote from the Covering Document and
its apparent influence on the Draft Guideline:

Data collated by the International Civil Aviation Organization indicates that, while
statistically very low, accidents that occur during the take-off or landing phase are
most likely to occur within 1km before the runway on landing or within 500m
beyond the runway end on take-off.

We are concerned because the dataset and the basis for these conclusions are not
identified in the document and are not readily found in extensive internet searches. For
example, the only ICAO work cited in the early NLR studies (see NLR CR-2000-147)
was a 1980 document, since withdrawn.

Our own research into the accident location data suggests that the unsubstantiated
“most likely to occur” statement is statistically and evidentially problematic, particularly
in regard to take-off overshoot and landing undershoot accidents. We have attached
two pages extracted from NLR CR-2000-147 that amply demonstrate the inaccuracy of
this unsubstantiated and misleading assertion.

The documented outcomes of the UK and Netherlands approach suggest that the 1:105
public risk boundary often extends to around three or four times this distance at high
traffic runways. We have attached a clear and relevant figure from NLR TP-2013-550
that of itself clearly illustrates that using 1000m as a filter for development
consideration as stated in paragraphs 56-59 of the Draft Guideline is, while better than
nothing, is a most inappropriate distortion of the public risk.

Is NASAG Showing Leadership?

While we note the politics of Commonwealth/State cooperation attendant upon land
use issues and we recognise the difficulties in even getting this far, AusALPA is
strongly of the view that the NASAG needs to free itself of excessive dependence on
past decisions and to avoid the “two bob each way” approach taken in this draft:

The approach to PSZs in Australia, through the proposed new NASF Guideline,
provides flexibility for state/territory governments to be proactive and identify and
map PSZs at airports, or take a reactive approach and consider public safety risk
on a case-by-case basis in response to development proposals in close proximity
to airport runways.

There needs to be acceptance of the history of poor safeguarding decisions in the past.
However, we need to move forward by ensuring that we take positive steps to reduce
the readily foreseeable risks. The introduction of a single uniform approach to PSZs for
all significant airports is one such step.

Queensland’s PSZ Legacy

AusALPA applauds Queensland for their leadership in airport safeguarding. We have
no doubt that the Queensland public has been far better served in regard to public risk
management at their airports than can be said of any other Australian State.

Nonetheless, the current approach to PSZs in Queensland is deficient to the extent that
it is inconsistent in applying land use restrictions to areas of identical risk. While
AusALPA would dearly like to understand the rationale for truncating the PSZ at 1000m
along the centreline beyond the threshold, the reality is that the full extent of the risk
contours have been known for decades and inappropriate development at 1001m on
the centreline may well be at far greater risk than developments located closer than
1000m but further off the centreline.

AusALPA therefore questions whether offering the Queensland example as a future
option for other States is defensible, given that NASAG knows the model is deficient.

Western Sydney Airport

AusALPA is disappointed that the Western Sydney Unit and DIRD were unwilling or
unable to negotiate with NSW to implement a full set of untruncated PSZs at Western
Sydney Airport, despite it being a greenfields site with essentially no legacy land use
planning problems.

In effect, the Commonwealth has undermined any future agreement to fully risk-based
PSZs by opting for a truncated zone which ignores the real risk contours. Moreover,
that decision opens the door for incompatible land use options just beyond 1000m that
may also fail the societal risk tolerance that is otherwise avoided by population density
controls.

The statement at paragraph 8 on page 13 of the Draft Guideline is demonstrably
untrue: the so-called 1000m ‘clearance zone’ does not “cover the area of highest safety
risk”.

International Standards

The covering document states that: “There is no international standard promulgated by
the International Civil Aviation Organization (ICAO) for PSZs.” However, while that
statement is accurate, it is not complete. ICAO does provide some guidance in
Chapter 5 Land Use Planning of Part 2 Land Use and Environmental Control of ICAO
Doc 9184 Airport Planning Manual (3rd edition). While that guidance in Doc 9184
basically describes only the Netherlands process, it also mentions other circumstances
where external risk assessment is required.

In any event, AusALPA views the ICAO approach as entirely supportive of the
production of appropriate risk contours, as distinct from “one size fits all” templates that
are of varying correlation with the real risk to the public.

US DoD Accident Potential Zones

While recognising the value of the Annex A to Attachment 3 to the Draft Guideline,
AusALPA does not believe that the illustrated public safety areas are appropriate for
the Australian NASF. The US classification of runways as the controlling variable is
naive and over simplistic – it is not consistent with Australian aviation infrastructure
usage or consequence modelling and the areas appear to significantly exceed that
required by the iso-risk contours.

World’s Best Practice

We recognise that there are a number of ways various jurisdictions approach PSZs.
Some approaches (US DoD, QLD) are clearly deficient while there remains some
debate about whether individual or societal risk assessments are preferable. However,
“world’s best practice” is most often a function of popularity rather than absolute quality
– NASAG should just choose a single approach to be uniformly applied across
Australia in the full knowledge that others will consider our choice to help elevate that
approach to “world’s best practice”.

Centralised Modelling of Risk Contours

AusALPA notes from the literature that NATS became the dominant provider of the risk
modelling and contour production for UK runways (and internationally on contract).
Competition and transparency issues aside, the immediate and obvious benefit in the
UK is that the outcomes were and are standardised. Similarly, we became aware that
from 2006 the UK Health and Safety Executive (HSE) “has been providing all planning
authorities in England, Scotland and Wales with on-line access to the (risk
assessment) software it has developed to generate its land use planning advice, known
as PADHI (Planning Advice for Developments near Hazardous Installations), so that
they can generate the health and safety advice more quickly and efficiently
themselves…”.

It seems to us that public safety would be enhanced and that PSZ decision-making
would be made more efficient and standardised if one agency (preferably DIRD)
became the sponsor and supplier of mutually acceptable iso-risk contours for all
Australian airports. AusALPA notes that, as we have limited aviation infrastructure
compared to the UK, the creation of a centralised source should neither be expensive
nor overly demanding.

Conclusions

AusALPA applauds the introduction of PSZs at all significant airports (not just exCommonwealth airports).
The PSZs should be defined by iso-risk contours generated by appropriate risk
modelling. While the current emphasis is on the assessment of individual risk, existing
inappropriate land use may mandate consideration of societal risk assessments as
well.

AusALPA does not accept 1000m as a valid parameter for truncating the length of
PSZs or as a filter for determining the need for development assessments.
AusALPA is disappointed that the Draft Guideline is not more focused on a single
uniform approach to defining PSZs.

AusALPA is disappointed that Western Sydney Airport has adopted a known deficient
PSZ template that ignores areas of equal risk and, by so doing, has undermined any
potential Commonwealth leadership in implementing PSZs.

AusALPA suggests that NASAG adopt a common risk assessment model such as used
in the UK and, further, that the model is maintained and operated by a single, mutually
accepted agency.

 If this is an example of the calibre of expert consultation submissions provided to the NASAG then one wonders why it is that they did not include an appraisal/review of why the AusALPA type criticisms and recommendations weren't embraced inside of the new 'Guideline I' - https://infrastructure.gov.au/aviation/e...-I-PSA.pdf -   

Hmmm...I think I smell a RRAT??   


MTF? - Much...P2