[Peetwo]

Doc Runacres Submission 56

Via RRAT webpages: 56 SAR Aviation Medicine (PDF 182 KB) 

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Moorabbin Airport
As discussed above, there has been pressure on Moorabbin Airport Corporation to provide
more aviation space, parking and hangars at the airport. This pressure has been largely
resisted and no investment in aviation space by Moorabbin Airport Corporation has been
undertaken since privatisation has occurred.

That is not to say that no investment has occurred at Moorabbin Airport, as some businesses
have been allowed to develop their own buildings. Further, as outlined in the 2004 Master
Plan, one hangar has been constructed and one has been converted from non-aviation to
aviation use. This is the total extent of aviation hangar construction since privatisation
occurred at Moorabbin Airport.

Concurrently, a tenant of Moorabbin Airport Corporation went into administration and was
liquidated. A sub-leasee was advised that there is no space for them at Moorabbin Airport
and their tenancy was to be terminated in November 2021. With no viable option available,
the tenant vacated Moorabbin Airport permanently.

I have a collection of names of aircraft owners seeking hangarage for their aircraft and the
demand for aviation space, specifically hangar and aircraft parking at Moorabbin Airport is
now at unprecedented levels.

The Airports Act Cwth (1996) (The Act)
On reviewing The Act, I note the first Object of The Act includes Section 3(a): “to promote the
sound development of civil aviation in Australia”.

Since privatisation, until 2029, when this proposed Master Plan is due to expire, Moorabbin
Airport Corporation boasts $800M invested into Moorabbin Airport, but only $25M of this
will be spent directly on aviation.

During the Second Reading of The Airports Bill, by the Honourable John Sharp, Minister for
Transport and Regional Development assured the Australian people that “The government is
thus committed to putting into place an appropriate regulatory framework to protect the
interests of current and future airport users and local communities” and “The government's
aim is to ensure there is no abuse of the potential market power of airport operators”.
As demonstrated Moorabbin Airport Corporation has done nothing to promote the
development of aviation in Australia and the Governments agenda has been thwarted by
Moorabbin Airport Corporation.

Moorabbin Airport Corporation is required under The Act to provide a Master Plan (Section
70(1)). Included as a purpose of the Master Plan is “…to reduce potential conflicts between
uses of the airport site…”.

The Moorabbin Airport Corporation Master Plan
I have read and reviewed the Moorabbin Airport Corporation Master Plans from 1999, 2004,
2010 and 2015 as way of background to this submission on the Draft 2021 Master Plan.

While nothing can be changed under these Master Plans, it is important to understand the
track record that the Moorabbin Airport Corporation holds. Under these Master Plans the
following aviation projects have been achieved:

• Runway 04/22 has been shortened
• Aviation hangar numbers have been reduced from 39 to 32
• Aviation leased land has decreased from 225,000m2 to 163,000m2 (though a possible
further 29,000m2 may come on line)
• A noise abatement sign (since gone) was placed near runway 17R
• The only major project funded by the Moorabbin Airport Corporation has been the
refurbishment of the terminal building, that happens to include the Moorabbin
Airport Corporation offices

Moorabbin Airport Corporation will espouse its investment in aviation by discussing runway
lights and runway and taxiway resealing. Please note that this is not investment in the airport.
This is routine repairs and maintenance, as required by any airport to maintain its certification
with the Civil Aviation Safety Authority and compliance with the International Civil Aviation
Organization.

It should be noted that under the 2015 Master Plan, the removal of seven hangars plus
parking apron was presented as a coloured box on a map. No further details were given and
the first real warnings of this occurring was when the airport provided an eviction notice to
the tenants of seven hangars, which sent shockwaves around the airport.

Further, the removal of seven hangars and subsequent construction of new warehouses and
a new road under the 2015 Master Plan warranted a Major Development Plan. The
Department of Infrastructure, and your office has not been able to provide any evidence such
a plan was provided.

On reviewing the 2021 Draft Preliminary Master Plan, a further coloured box on a map is the
only indication in the reduction of aviation precinct, resulting in another approximately seven
hangars being removed. With no replacement outlined for the seven previously removed
hangars, Moorabbin Airport is now looking at the having had fourteen of thirty-nine hangars
removed, with little or no replacement documented in the Master Plan.

Nothing in the 2021 Draft Preliminary Master Plan addresses:

• Expanding “non-flight training” aspects of general aviation
• That almost none of the previous proposed aviation projects have been undertaken
• How safety at the airport is being improved above the minimum
• How displaced aviation tenants will be managed
• How new aviation tenants will be accommodated

It should be noted that very little of the proposed aviation development from the 1999, 2004,
2010 and 2015 Master Plans has actually been conducted. These sections have largely been
regurgitated from Master Plan to Master Plan.

Corporate Responsibility
It is important to consider the broader picture of Moorabbin Airport Corporation, and its
owner, The Goodman Group.

• The Goodman Group is a $51 billion dollar, publicly listed (ASX), international
company. It boasts, in its 2020 annual report, an operating profit of approximately $1
billion.
The Goodman Group is a property developer, and Moorabbin Airport, approximately
20km from the Melbourne CBD, is prime land for redevelopment as anything other
than an airport.

• The Moorabbin Airport Corporation and Goodman Group have made it clear that they
have no interest in keeping Moorabbin Airport as an airport or supporting aviation,
new aviation tenants or appropriately managing existing tenants. As an example, all
aviation leases appear to have a redevelopment clause which outlines that, with six
months notice, tenants can be evicted to make way for new development. This lack of
security makes managing a business, from a long term perspective, unworkable.
• At the northwest aspect of runway 31L, south of Centre Dandenong Road, west of
taxiway Golf and east of the DFO buildings is “Toxic Mountain”, an area of
approximately 14,000m2. This area contains PFAS contaminated soil, moved there
from the airport environs approximately two years ago. The construction of Toxic
Mountain appears to be a permanent structure. It would appear that the
management and containment of this contaminated soil is contrary to the PFAS
National Environment Management Plan. This has been referred to both the
Environment Protection Authority Victoria and the Federal Department of Agriculture,
Water and the Environment requesting an investigation.
• No Major Development Plan has been made public for the recent development on the
western most aspect of the airport, resulting in the removal of hangars and airport
apron.

These are just a handful of transgressions that Moorabbin Airport Corporation and Goodman
Group have made at Moorabbin Airport.

I note rumours abound that Moorabbin Airport Corporation and Goodman Group are seeking
an early renewal of the option on their lease.

Conclusion
It is clear that Moorabbin Airport Corporation has failed and is failing to manage Moorabbin
Airport appropriately and is therefore in breach of its obligations. Further, there has been no
serious effort to assist, promote or develop general aviation. There is no space for existing
aviation tenants to expand or for new tenants to enter the airport. Moorabbin Airport
Corporation, and Goodman Group, have demonstrated that they are not responsible
corporate citizens and have failed Moorabbin Airport and its citizens, by shrinking the aviation
footprint, without due consideration to the Airports Act and by not investing in aviation.

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Well put that man...

MTF...P2