Brisbane Airport Corporation Submission - Terri Butler MP, Labor for Griffith

Brisbane Airport Corporation Submission

After surveying locals in the Griffith electorate and speaking to various stakeholders, I made the following submission to Brisbane Airport Corporation regarding Aircraft Noise.

This submission is made in my capacity as the Member for Griffith. I have attempted to state my constituents’ views, as discerned from the survey I conducted, and to propose, measured, balanced means of mitigating aircraft noise.  This submission does not necessarily represent the views of any political party.

27 June 2014


Brisbane Airport Corporation

Reply Paid 86075



By email:



 Dear Colleagues


Re: Submission in relation to the 2014 Preliminary Draft Master Plan


Thank you for the opportunity to make this submission.  

As the Member for Griffith my interest in the Master Plan relates to aircraft noise. As you know, my predecessor the Honourable Mr Kevin Rudd MP was a strong and vocal campaigner in relation to the effects of aircraft noise on communities in Brisbane’s inner south. His most recent public submission about the issue, made in November last year, refers to concerns about the effect of aircraft noise, including in relation to public health, [2] property values, and amenity generally. As the incoming federal representative I share Mr Rudd’s concerns. For those reasons this submission, provided in the context of the community consultation as to the Preliminary Draft Master Plan, focusses on the issue of aircraft noise.

The economic benefits of having a large, busy airport are undeniable. As has been acknowledged in the UK, a proportion of the large economic benefits provided by airport development should be used to mitigate local impacts.[3]

I appreciate that the Air Services Act 1995 (Cth) confers upon Airservices Australia the responsibility to minimise environmental impact, including noise. BAC must continue to cooperate with Airservices Australia, and other stakeholders, to seek to minimise environmental impacts.

The suggestions made in this submission are made in the spirit of seeking additional solutions, to better balance locals’ interests in amenity, liveability, and public health, with the greater public interest, such as the interest in reducing emissions, and the interest in obtaining the economic benefits of our airport


Aircraft noise will affect a growing number of Southsiders

Aircraft traffic is expected to continue to increase in the years 2014 to 2020 – that is, prior to the commencement of the New Parallel Runway. Residents and businesses presently affected by noise can expect noise to increase during that period.

Once the New Parallel Runway commences operation, it appears that residents and businesses located two kilometres west of those presently most affected will be similarly affected. For example, I understand those in Bulimba will experience aircraft noise to a similar extent as those living in Murarrie.


Southsiders have differing views about aircraft noise

To assess community sentiment, I have recently conducted a local survey. This survey was returned by voters of all persuasions– at the recent by-election, almost 40% of those who responded did not vote Labor, and more than 35% of respondents are swinging voters.

At their home, the people who responded find aircraft noise:

Unbearable                                  9.99%

Highly disruptive                        28.78%

Moderately disruptive              20.63%

Occasionally disruptive             19.32%

Not disruptive at all                   21.29%

As you can see, around two-fifths of people who responded found the noise highly disruptive or unbearable. And about the same proportion found it only occasionally disruptive or not disruptive at all.

For those who find aircraft noise disruptive, the time when they are disrupted the most is:

Day 6am- 5pm                            24.87%

Night 5pm-11pm                       54.12%

Night 11pm-6am                       21.02%

This issue is very important to a number of Southsiders. 15.97% of those who responded say they have made a complaint about excessive aircraft noise. And 37.41% of respondents say that this issue affects how they vote at elections.

As you can see from the above, Southsiders have differing views about aircraft noise. I submit that there is room to take a measured and balanced approach to aircraft noise. There are further improvements that could be made, and that could be factored into the Master Plan.


BAC should plan to mitigate noise at night

Night noise has adverse effects. Sleep disturbance can lead to short- and long-term difficulties.[4] Accordingly, BAC should incorporate into any planning measured, reasonable and balanced strategies to mitigate noise in the interests of those who live and work in our suburbs.

This is done at other airports. For example, Heathrow uses a combination of night restrictions, by imposing prohibitions on the noisiest classes of aircraft from being scheduled to land or take-off, and, for all other aircraft, imposing movement limits and noise quotas calculated by reference to the noise levels for the type of aircraft concerned.[5]

Revisit the idea of trialling a curfew

I have previously expressed support for a trial curfew, to avoid disruption at night. More than 60% of the locals who responded to my survey favour the introduction of a curfew.

The Deputy Prime Minister has decided against trialling a curfew. I submit that it would be prudent, and a reasonable balance between all of the competing interests, to revisit that decision, and to conduct a limited trial. For example, a curfew could be trialled on Sunday through Wednesday nights from 10 pm to 5 am.

In the event that BAC is not minded to pursue a trial curfew, it should nonetheless consider what additional noise mitigation strategies must be deployed.

Having regard to strategies deployed at other airports, I submit that:

  • flights ought to arrive and depart over the bay wherever possible;
  • there should be fair and balanced night time restrictions even if they fall short of a trial curfew; and
  • there should be financial incentives for airlines to reduce noise.

Aircraft should fly over the bay at night

I appreciate that aircraft are already asked – via the Noise Abatement Procedures - to use the Reciprocal Runway Operations (RRO) runway option (that is, to arrive and depart over the bay) at night.  The night periods for which RRO is in use are 10.00 pm to 6.00 am Monday to Friday, and 9.00 pm to 6.00 am on weekends.

In previous correspondence to me, BAC has stated that a decision was recently taken to allow over-bay RRO to be nominated earlier than required under the Noise Abatement Procedures, weather and traffic permitting. I ask that BAC, as part of its planning for noise mitigation, encourage the earlier use of RRO on each occasion that weather and traffic volume permits. I understand there is little or no record kept of the frequency with which this option (commencing RRO earlier in the evening) is used. Should resources permit it would be useful for Air Services Australia to be able to indicate that RRO has commenced as early as possible on the nights on which weather and traffic conditions have been favourable.

I understand the advice I’ve received, from BAC, to be that there are four circumstances in which the planes would fly over land instead of over the bay, even though RRO is in use:

  • When wind conditions stop planes from arriving or departing using RRO;
  • When rain conditions stop planes from arriving or departing using RRO;
  • When there are more than ten movements within any hour; and
  • When pilots exercise discretion not to use RRO.

Wind and Rain

Of course, weather cannot be controlled. I urge BAC to work with stakeholders to ensure that all stakeholders actively seek technology that increases the ability for aircraft to fly, safely, over the bay notwithstanding inclement weather.

Traffic volume

As to the third of those three circumstances – traffic volume – I submit that even if there remains strong opposition to a trial curfew, there ought to be scheduling arrangements that prevent more than ten movements being scheduled in an hour.

That will be particularly important between now and the date of operation of the New Parallel Runway, because traffic volume is going to increase, but the threshold of ten flights in any hour is, as I understand the

advice, going to remain relevant until the New Parallel Runway opens.  In previous correspondence to you I referred to Airservices Australia’s recent Noise Abatement Review, which stated as follows:[6]

“5. Forecast Growth of Traffic

Brisbane Airport has forecast total traffic growth of up to 3.5% per annum to 2015 and a further 2.8% per annum from 2015 to 2035. During the day, traffic levels do not impact on the use of the preferred runway, however at night the preferred runways can only be used when traffic levels are very low under the current runway configuration. As traffic levels increase over time, the opportunities to implement Reciprocal Runway Operations (i.e. arrivals onto Runway 19 and departures from Runway 01) will be reduced. However, it should be noted the proposed parallel runway should substantially increase the opportunity to manage aircraft over the bay with arrivals and departures on segregated runways.”

As I have said in my previous correspondence to BAC:

“…I’ve now had a chance to look at the chart you gave me that compares 2012 with 2020. I see that though there are presently, on the “typical busy day” in summer, only 7 movements per hour from 10 pm to 11 pm, in 2020 that’s expected to be 15 movements per hour. Presumably that means the number of movements will cross the threshold of 10 movements in a year between 2012 and 2020, meaning flights during that hour will be over land on each typical busy night.

As you can appreciate my concern is that there will be an increasing number of nights where, even if it is fine and there is very little wind, more movements will occur over land. (I appreciate that once the NPR operates the threshold of 10 movements per hour will increase significantly.)”

BAC’s response to me is that it has no further granularity on expected year on year growth beyond what has been provided to me.[7] In other words, there’s no information available about how frequently there will be more than ten flights in any sixty minute period overnight, between now and 2020.  However, BAC expects that:[8]

“the majority of demand growth in the night period will be in the shoulder hours and relates to last-wave return to Brisbane late-evening traffic and first-wave early-morning business traffic departures out of Brisbane…”

BAC also expects that is particularly influenced by daylight savings.

Though there is uncertainty, it seems that BAC expects that in the period between now and the New Parallel Runway commencing operation, traffic will increase so that on more occasions, the volume of traffic will prevent the use of RRO and therefore flights will arrive and depart over land instead of over the bay.

I submit that, to reduce the incidence of one of the circumstances that causes flights to arrive and/or depart over land, there ought to be a prohibition on scheduling flights where doing so would cause that threshold, of ten flights in any sixty minute period, to be exceeded.

It is acknowledged that delays and other unforeseen circumstances might still trigger the threshold, but a deliberate approach of taking all reasonable steps to prevent over-scheduling would assist.

Once the New Parallel Runway opens, and the threshold number of movements increases, the scheduling requirements ought to be altered accordingly.

Pilot discretion

Finally, the fourth circumstance that leads to flights arriving and departing over land instead of the bay even though RRO is in use, relates to pilot discretion.

As you know there is a degree of suspicion, in our community, that pilot discretion may be being exercised for purely financial reasons. I appreciate that BAC has provided me with advice to the contrary, and I do not intend to cast any aspersions in respect of pilots’ or airlines’ conduct. I also support the proposition that safety must be the first priority and that pilots must retain appropriate discretion in respect of their aircraft.

So that the public may have confidence that pilots’ discretion to fly over land is being exercised only when needed, I submit that BAC ought to work with stakeholders to ensure that pilots are regularly provided with unequivocal guidance about the safe and responsible exercise of their discretion, and the need to favour over-bay operations whenever safe to do so.


Impose fair and balanced night-time limitations

Heathrow has long had a voluntary agreement with airlines, to stop scheduling the noisiest types of aircraft at night.[9] I ask that BAC continuously work with stakeholders, including airlines, to seek an ongoing commitment to using, at night, the quietest technology reasonably available.

Similarly, as stated above, Heathrow deploys a combination of movement limits and noise quotas. A similar approach could be trialled in Brisbane, where classes of aircraft that are noisier are given higher quota counts, causing airlines to meet their quota sooner if noisier classes are used.

Consider financial incentives and penalties

I also understand that Heathrow offers lower landing charges for airlines that use their quietest fleet at that airport. They do so by imposing differential noise charges – the noisier the aircraft, the more expensive Heathrow’s airport charges.[10]

Again, BAC should ensure that there are similar financial incentives here, for airlines to use their quietest fleet.

In addition, to remove a perverse incentive, BAC should ensure it is not more cost efficient for aircraft to fly over land, than it is for aircraft to fly over the bay. Accordingly there ought to be financial penalties for flying over land, but only of the amount necessary to neutralise any cost difference.

BAC should plan to mitigate noise generally – day and night

It must be acknowledged that for inner city residents noise is a fact of life. However, noise should be mitigated, where possible, especially for those whose work or study keeps them in the affected areas during the day.

I am grateful to BAC for its work to make information about current and future flight paths available to present and intending Southsiders. I commend BAC for its partnership with the REIQ, aimed at making that information available to prospective home buyers.  Information is not, of itself, enough – BAC and other stakeholders need to actively work to mitigate noise.

I have previously been advised that RRO is not feasible during the day because of traffic volumes. That being the case, I have asked that BAC continue to work with stakeholders to identify what other, additional, noise mitigation strategies would be suitable at times when RRO is not feasible.

Schools and other vulnerable buildings need help mitigating noise

Of particular concern is the effect of noise on local schools and other vulnerable community buildings. In particular, there are real concerns about the impact of aircraft noise on school-aged children.[11] The UK Airports Commission Discussion Paper 05, Aviation Noise, of July 2013 stated:[12]

“2.30 The evidence surrounding cognitive impairment in children exposed to noise is somewhat clearer than that surrounding other noise impacts on children. Over 20 studies, both epidemiological and experimental, have shown negative effects of noise on reading ability and memory development in children. Several links between chronic noise exposure and children’s cognition have been suggested, including teacher and pupil frustration, learned helplessness, impaired attention, increased arousal, indiscriminate filtering out of noise during cognitive activities resulting in loss of attention, noise annoyance, and sleep disturbance. These impacts are magnified when learning activities are undertaken outdoors. Noise has been commonly shown to affect children’s central processing and language skills, reading comprehension, memory and attention ability. These effects could seemingly impair long term educational attainment, though this aspect is less well evidenced.

2.31 When considering cognitive impairment, the source of noise has also been found to be an important factor. The European RANCH study found that road traffic noise had no observed effect on children’s reading or memory (in fact episodic memory showed better performance in higher road traffic areas). With aircraft noise, however, the study showed that students suffered impaired reading comprehension and recognition memory. This is likely to be because of the transient nature of aircraft movements, with short term peaks in noise affecting concentration and providing distraction. On the other hand, it is more likely that children will habituate to road noise during school hours, as it is generally experienced at a more constant level.

2.32 The effects of noise on primary school children have been well evidenced, and are found to be particularly acute. The effects of noise on secondary school children have been found to be less acute, suggesting that the detrimental effects of noise exposure could diminish with age.”

(footnotes omitted)

Presently there are at least five local schools directly under flight paths that are routinely affected by noise (or would be absent their existing noise mitigation). Some of those schools need additional noise mitigation; others have noise mitigation that requires ongoing maintenance.

Once the New Parallel Runway is in operation, there will be at least four more schools – those two kilometres to the west of those presently affected – that will be subject to aircraft noise.

The Chicago Airport has a schools noise mitigation program entitled the School Sound Insulation Program.[13] That program has been in place since 1991 and involves sound mitigation measures including:

  • Window modifications;
  • Addition of acoustical insulation batts to ceiling assemblies;
  • Weather-stripping windows and doors;
  • Installation of new air conditioning and ventilation systems; and
  • Addition of vestibules at exterior doors.

The program is funded through combined Federal Aviation Authority and City of Chicago funds.

Heathrow has a Community Buildings Noise Insulation Scheme and provides up to £5 million per year for that Scheme. The Scheme supports: [14]

“…noise-sensitive buildings in the community. Noise sensitive community buildings eligible in this scheme are those with widespread use within the community, where people spend long periods of time, or where they are vulnerable (such as in hospital). These include hospitals, schools and colleges, nurseries attached to schools and hospices, nursing homes, registered nurseries, libraries and community halls.”

BAC should work with stakeholders to introduce a similar initiative in Brisbane’s suburbs. There should be a confidential method for affected schools to seek to participate in such an initiative. It may be considered appropriate to divert funds from the existing Passenger Movement Charge towards support for a local insulation program.

Residences need help mitigating noise

Residential assistance ought also to be considered. This is of particular importance to those who spend a significant proportion of time at home – such as retirees, and persons who perform paid and unpaid work at home, including in home businesses or undertaking home duties.

Again, the Chicago Airport provides a possible model for a home sound insulation program: the City levies a user charge on each airline ticket, and that funds the residential sound insulation program for local residences.[15]

And Heathrow’s scheme provides for free secondary glazing or half price double glazing plus loft insulation to external windows and doors (only).[16]

Closer to home, Sydney and Adelaide have each had residential noise mitigation programs. Infrastructure Australia records that:[17]

“The programs have been effective in reducing the impacts of aircraft noise on homes and public buildings under flight paths. At a combined cost in excess of $470 million, the Adelaide and Sydney airport noise programs have insulated 4,083 homes and 99 public buildings in Sydney; while in Adelaide, a further 648 homes and 8 public buildings have been insulated.”

BAC should work with stakeholders to introduce a noise insulation initiative for residences in Brisbane’s suburbs.

Aircraft technology should be geared towards reducing noise

I understand that there are moves to increase the number of aircraft that are able to use continuous descent approach – and that not all aircraft that regularly fly into Brisbane are equipped to do so. As part of its planning BAC should consider what incentives might assist airlines to increase their use of CDA.

Flight paths should take into account noise reduction

I understand that one way of reducing aircraft noise is to encourage aircraft to use the Rivertrack flight path, but that pilots unfamiliar with Brisbane are more likely not to use that path. Consideration ought to be given to how pilots can be made familiar with Brisbane. Similarly, consideration ought to be given to how to incentivise airlines to ensure their pilots are capable of using the Rivertrack flight path, for example by implementing charges where aircraft fly on different routes when they ought to be able to use the Rivertrack.


Conclusion and summary of suggestions

Thank you again for the opportunity to make this submission.  I commend Brisbane Airport Corporation on the work that has been done to create the 2014 Preliminary Draft Master Plan.

I also thank BAC for its timeliness and responsiveness in meeting my requests for information about aircraft noise. Though a number of people have assisted me in that way, I particularly record my appreciation to Ms Rachel Crowley and Mr Mark Willey.

This submission is made in my capacity as the Member for Griffith. I have attempted to state my constituents’ views, as discerned from the survey I conducted, and to propose, measured, balanced means of mitigating aircraft noise.  This submission does not necessarily represent the views of any political party.

In summary, I have made the following suggestions.

  1. BAC should revisit the suggestion of trialling a curfew. For example, a curfew could be trialled on Sunday through Wednesday nights from 10 pm to 5 pm.
  2. RRO is now available for use earlier than 10 pm (Monday to Friday) or 9 pm (weekends). There should be a concerted effort for that option to be taken up as often as conditions permit.
  3. Data should be kept, if resources permit, about how often RRO use has commenced earlier than 10 pm (Monday to Friday) or 9 pm (weekends).
  4. BAC should work with stakeholders to ensure that all stakeholders actively seek technology that increases aircraft ability to fly, safely, over the bay notwithstanding inclement weather.
  5. There should be a prohibition on more than ten movements being scheduled in any sixty minute period overnight. That threshold should increase appropriately once the New Parallel Runway is in operation.
  6. BAC should work with stakeholders to ensure that pilots regularly receive explicit guidance that they should fly over the bay at night whenever it is safe to do so, and that financial considerations should not, of themselves, be the basis to exercise discretion to fly over land.
  7. BAC should continue to work with stakeholders to seek their ongoing commitment to using the quietest technology reasonably available.
  8. As an alternative to a curfew, BAC should consider Heathrow’s noise restrictions (based on movement caps and noise quotas), and if feasible trial similar restrictions at Brisbane.
  9. BAC should consider Heathrow’s differential charges, where there are higher charges for noisier aircraft, and if feasible trial a similar approach at Brisbane.
  10. To avoid a perverse incentive, BAC should use financial means to ensure that it is not more cost effective to fly over land than over the bay at night.
  11. Schools and vulnerable community buildings should receive assistance to mitigate noise. Consideration should be given to using funds from the existing Passenger Movement Charge for that purpose.
  12. Residents – particularly those people who spend a significant proportion of time at home - should also receive assistance to mitigate noise.
  13. BAC should work with stakeholders to encourage airlines to increase their use of continuous descent arrivals.
  14. Consideration should be given to incentivising use of the Rivertrack, for example by implementing charges for airlines whose aircraft fly on different routes when Rivertrack is reasonably available.

Thank you again. If you require any further information please contact me.

Yours sincerely

Terri Butler MP

Federal Member for Griffith



[2] See also UK Airports Commission, Discussion Paper 05: Aviation Noise, July 2013, chapter 2, page 7 and following

[3] Heathrow Airport, “Environmental Noise Directive Noise Action Plan 2010-2015: the action plan – December 2010”, adopted May 2011, page 18
[4] See also UK Airports Commission, Discussion Paper 05: Aviation Noise, July 2013, chapter 2, page 12
[5] Heathrow Airport, above n 2, at 13
[6] Airservices Noise Abatement Review at page 9

[7] BAC’s letter of 17 June 2014

[8] BAC’s letter of 17 June 2014 at page 4

[9] Heathrow Airport, above n 2, at 2

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