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Red
= from the Briefing notes or other Ascot communiqué RESPONSE
TO “BRIEFING
NOTES FOR JANDAKOT TENANTS ON THE PROPOSED RELOCATION OF JANDAKOT
AIRPORT” “Discussions on the location and possible relocation of the Jandakot Airport are not new. In past years this issue has been debated and investigated by interested stakeholders” I have been an interested stakeholder of Jandakot Airport since 1993, and have never been made aware of, or consulted on “debate and investigation” of a possible relocation of the airport. I am however aware of The Airports Act 1996 (The Act) which states in Part 2 Division 1 Section 11 •
An airport-lessee
company has a statutory obligation to use the
airport site as an airport. • An airport-lessee company’s sole business will be to run the airport. It seems that the current airport-lessee company are not aware of this, and are in fact in the business of property devlopment. They have even chosen to misrepresent their interest in the Airport, by calling themselves “The Owners of Jandakot Airport”. The Airport is owned by the Commonwealth of Australia. After Ascot Capital’s real intentions were revealed in the media, we were told in the “Notice to Tenants” from John Fraser dated 29 June 2006, that “earlier this year an extensive study was initiated to establish a strategy for future development” which contradicted the Master Plan (with his name on it), contradicted the Act, and had had no consultation process with stakeholders. This “Extensive study” has not been made available to tenants.
REACHING
CAPACITY. Section 5 of the master plan shows that the years 1996 and 1998 had movements of 404,576 and 416,895 respectively. Considerably more than 400,469 for year ending June 2006. Figure 1 in the briefing notes assumes that the increase in growth from 2005 to 2006 will continue at the same rate as over the last year, however history shows that would not be the case. Aviation is a very cyclical industry, tending to run in seven year cycles. In the last years two schools have made significant increases to their training activities, but this is now likely to plateau. The chart given with the briefing notes ignores any historical data. Therefore I feel that to assume this growth rate will increase as it has in the last two years is not an accurate way to predict future usage. The following figure plots movements since 1995.
Jandakot
Airport movements 1995-2006 Reference:
Jandakot Airport Master Plan 2005, Airservices Australia website. What this graph shows is a success story of recovery from the multiple price hikes we have experienced since 1997, including the hike in fees from the privatization of the airport, Location specific Charging by Airservices, the GST, 9/11, fuel price increases etc. We are only just reaching, after eight years, the volumes we had prior to 1997. The full capacity is not 500,000 as stated in your notes, but calculated at 514,650 in the Master Plan. If the fourth runway were built, the tower would be able to nominate the most into wind runway, and it would not require a crosswind of more than 12 knots before the runway would be utilised. Assuming that ATC would wait for a 12 knot crosswind before changing runways to parallel 12/30 shows a total lack of understanding of how an airport functions. I quote John Fraser’s “Notice to Tenants” on 29 June 2006 which stated “Capital expenditure that is now needed for the efficient functioning and future growth of the airport will, if spent, be wasted WHEN [my bold] the airport is forced to relocate” In other words, they do not intend to “waste” capital on the fourth runway. The proximity of Perth Airport has never caused “constraints” in my business’s activity and I cannot see how this can be used as a reason to close the airport. Surely two major international airlines would not have invested in the infrastructure they have for the training of their next generation of pilots, if there was a risk that their operations would soon become “limited”?
This section seems to imply that Airservices and CASA are unable to provide a safe operating environment. This does them a disservice, and it is treading on rather dangerous ground to make such insinuations. CASA and Airservices Australia determine the safety of “minimal vertical clearances”. In all my years operating from Jandakot I have never encountered wake turbulence from overflying aircraft. Jandakot Airport may be unique in Australia having heavy jets flying over portions of the CTR. That does not mean it is unique in the world and is certainly not a reason to “relocate” it. The document claims that heavy jet aircraft have a clearance of “slightly more than a 500ft clearance”. To be credible, we would need to know exactly how many feet constitutes “slightly more than” and have references to this information. I have asked CASA Flying Operations Inspectors for a definition of “Slightly More Than” and they have not been able to give me any such definition. The Briefing Notes Figures 2 and 3 conveniently ignore the northern inbound traffic. For some reason Airservices data has been transposed onto “Google Earth” maps rather than give the correct information with the relevent references. They also plot the Kwinana Freeway and Roe Highway as a jet track into Perth airport from 0-1000 feet! This has been added to the correct figures from Airservices Australia which are shown below for the same period. I have also included the movement statistics that show that during this period 15 % of arrivals are on Runway 03 at Perth.
Figure
5: Track plots coloured by height for jet arrivals during
the period 2/3/2005 to 8/3/2005.
Figure
7: Track plots coloured by height for non-jet and helicopter arrivals
during the period 2/3/2005 to 8/3/2005.
Reference: A
I R S E R V I C E S A U S T R A L I A REPORT
No. 1427 NOISE
AND FLIGHT PATH MONITORING SYSTEM PERTH
QUARTERLY REPORT JANUARY
- MARCH 2005 PH05Q1
THE
ADDITION OF A PARALLEL RUNWAY AT PERTH AIRPORT Para 2. “A Study” – references required please! What Study, by whom and when? Even if a parallel runway were built at Perth it would be to the East of the current runway, further away from the Jandakot control zone. This, from the Perth Airport Master Plan shows no parallel runway even in 2024!
Violations
of Controlled Airspace Source:
Australian Transport Safety Bureau website According to
Figure 5 in your report there were about
47 VCAs in one week. Figure 5
does not show whether these VCAs were from Jandakot or Perth aircraft. If this was in fact a week, and all VCAs were from aircraft departing or arriving from Jandakot, this would make an annual total of 2444 VCAs from Jandakot alone.. This is inconsistent with the above figure which covers all VCAs in Australia. The VCA diagram in the briefing notes gave no indication of the callisgns, departure or destinations of the aircraft involved. There is no way of telling if these VCAs were from Jandakot or Perth traffic. When I asked the CASA FOIs at Perth if there really were 47 VCAs from Jandakot in one week, they replied they didn’t even get that many in a year. The three figures below give a comparison of VCAs at Perth to those at Melbourne and Sydney.
Reference http://www.airservicesaustralia.com/pilotcentre/training/flyingaround/perth.asp A380
AIRCRAFT The following press release from the Joint Aviation Authorities states that any allegations about A380 wake turbulence are, at this stage, “Pure Speculation”.
ADVANTAGES OF RELOCATING In
the introduction, bullet point 6, it states that
“capacity cannot be
increased by providing more infrastructure, ground space or runway
facilities”
even though the Master Plan provides for a fourth runway
which would alleviate congestion when the wind favours runway 12/30 In
the first paragraph of the
“Advantages of Relocating”
it states that
four runways will have a capacity of
“Around 515,000 movements per
annum”. This sounds very familiar to the Jandakot Master Plan’s
stated capacity of 514.650 movements per annum. So
how can this proposed new location give a capacity advantage over
Jandakot when the capacity is the same with four runways as we have now
for three? I
am interested in this
“increased flight ceiling
to allow for simultaneous training on higher performance
aeroplanes”
are we to have aircraft sharing a circuit at different
heights? Has a study been done on this by Airservices Australia that we
can refer to? The
report states
“The new airport will be developed to provide…..giving
security of tenure and an asset base” JAH
have already stated that all construction will be carried out by their
chosen construction company, and that tenants will only be able to rent
and not own their premises. How can this give
“Security of tenure and
an asset base”
and be seen as an advantage, if tenants have had their
owned property investments forcibly removed from them and replaced with
a rental?. A
shuttle bus to the railway is not much help, when the nearest station
will be around 25km away, at either Mandurah or Waikiki. All
of these advantages are heavily outweighed by the simple fact that the
location is too far away from the client base to be practical. POTENTIAL RISKS IF THE AIRPORT IS NOT RELOCATED “Rents
and fees at Jandakot will increase in line with market trends for
property in this location” This
location is an airport, and should not be compared to nearby industrial
areas, which have far superior facilities. For example, I am still
unable to get broadband connected to my premises due to a lack of ports
available at the exchange. There is no practical public transport to the
airport. The
rental values are only the opinion of their retained valuer, and have
been challenged by many tenants and experts. They have been increased by
outrageous amounts, some over 100%
Tenants do not have a choice of location from which to operate .
We can hardly be expected to believe that JAH will suddenly be
reasonable about rentals in a different location. To
justify increases in rents and fees we should be getting an increase in
the quality of the infrastructure, particularly the parking areas, and
the provision of a parallel runway 12/30. Yet we are told that
investment in infrastructure would be “wasted”. “The
costs associated with running an airport at capacity will increase” Surely,
any costs incurred by increased movements will be variable, not fixed
costs and therefore covered by greater revenue derived from landing
fees? “Major
flying schools…” flying schools both major and minor have provided
their own facilities to their own requirements. We know what we need and
we have it. Let us be the judge of that. What we need is for the airport
facilities to be maintained in accordance with the lease, an
Airport-lessee company run by aviation professionals who understand the
industry and who will co-operate and work with the tenants, and security
for planning and investment into the future. The
risk of flying schools relocating away from WA is far greater if the
airport is moved to a location too far away from customers and staff to
be practical. “The increasing restrictions on air traffic in Jandakot airspace may render Jandakot unuseable as a commercial/general aviation airport at times”.
As with the comments on the A 380, this seems to be pure speculation.
THE
PROPOSED LOCATION FOR THE NEW AIRPORT Not all clients and staff of the airport live in or south of the CBD. Many live in the Northern suburbs and travel time would be unacceptable. I understand any “land swap” would have to be like for like, ie like value of the land, like accesibilty to services, like environment. “It is just 20km from Mandurah, Australia’s fastest growing city” John Fraser of JAH stated in his “Notice to Tenants” dated 29 June 2006 gave as a primary justification for this relocation “The airport is in the midst of a densely populated area and moving the airport out of the city would be widely welcomed by residents” Residents of this area, with the exception of the prison inmates at Canning Vale prison, have a choice of where to live, and they have chosen to live in the vicinity of Jandakot Airport. On the other hand, Residents of Keysbrook have chosen to live in a quiet rural location. There is no reference to any study of what would or would not be welcomed by residents, or to noise complaint statistics. However the Western Australian Planning Commission Statement of Planning Policy No. 5.3 – Jandakot Airport Vicinity March 2006 states: 4.1.6
Notification on Title A notice on title advising of the potential for noise nuisance is to be required as a condition of any subdivision or planning approval, except where the proposed development and anticipated use of the premises are identified as acceptable for the relevant ANEF level with reference to the Development Site Acceptability Table in Appendix 1. 4.1.7
Advice to Prospective Purchasers Information should be given to prospective purchasers of noise-sensitive premises, about the potential for aircraft noise nuisance. Such advice should be provided by local government in conjunction with the issue of zoning certificates and/or property inquiries.
Now we are given a proposed site just 20km from Mandurah, quoted in your notes as “Australia’s fastest growing city” so how long would this new airport be viable before, according to JAHs rationale for moving Jandakot, (John Fraser, Notice to Tenants 29 June 2006) it would be “in the midst of a densely populated residential area and moving the airport would be widely welcomed by residents” [especially if the residents had moved there for a peaceful lifestyle away from the city before the airport came along] and relocation would once again become “inevitable” I understand there are already plans for a substantial Landcorp development called Amarillo on or close to the western boundary of the proposed location. To answer the above point, Jandakot Airport is not “in the midst of a densely populated area” it is surrounded by limited residential, but mostly Jandakot Regional Park, special rural properties, two prisons, golf courses, old sand mines, the Kennel Zone and major roads and power lines. The aerial photo clearly shows this.
POTENTIAL
OTHER SITES We
already have the ideal site. There are no other potential sites
available that would give the same proximity to the city. Reference:
Department of Planning and Infrastructure website
Reference: STATEMENT OF PLANNING POLICY No. 5.3 JANDAKOT
AIRPORT VICINITY MARCH
2006 1.
INTRODUCTION 1.1
Citation This
Statement of Planning Policy has been prepared under section 5AA of the Town
Planning
and Development Act 1928. It
applies to land in the vicinity of Jandakot Airport
which may be affected by aircraft noise. The policy may be cited as
Statement
of Planning Policy 5.3 Jandakot Airport Vicinity. 1.2
Importance of Jandakot Airport Opened in 1963, Jandakot Airport is the principal general aviation airport in Western Australia, and is one of the busiest airfields and largest aviation training bases in Australia. The primary function of Jandakot Airport is ‘air work’ aviation rather than passenger transportation. In addition to a range of business and private users, the airport also provides access for air service organisations such as the Royal Flying Doctor Service, CALM Forest and Bushfire Patrol and the WA Police Air Support.1 Jandakot
Airport is an important training base with flying training accounting
for around
50 per cent of the total aircraft movements. The three major flying
schools currently
operating at the airport are The Royal Aero Club (Inc), China Southern
West Australian Flying College and Singapore Flying College. A further
nine training
organizations provide flying training at the airport in a variety of
aircraft, including
helicopters. To complement the aviation tenants, numerous independent
businesses
are on location to service and repair aircraft.1 The airport is an important element of transport infrastructure, servicing both the region and the State as a whole. It also makes a significant contribution to the economy of the area in which it is situated, providing employment and a range of local economic opportunities.
TIMELINE
FOR THE NEW AIRPORT If
the new airport is to be operational before Jandakot can be closed, I
wonder where the Air Traffic Controllers will be based. Do Airservices
Australia have sufficient controllers to man both airports during
transition? Imagine
the chaos and disruption to business while this transition was being
carried out. Presumably compensation for consequential losses to
business has been factored into the feasibility? WHAT
WILL HAPPEN TO THE CURRENT SITE If
a “land swap” is to take place I understand that this has to be on a
“like for like” basis. Surely this “like for like” includes
proximity to the city and services, like land values, like environment
including the flora and fauna identified in the Master Plan… yet the
proposed site is just a swampy paddock. If the land in Keysbrook is so “like” Jandakot, then why do Ascot Capital not develop that area for housing and commercial, and leave Jandakot where it is? Why would the Commonwealth Government accept a swap of land of a reduced value? Would the Australian public appreciate OUR land being sold in this way? Would the State government allow them
to bulldoze the Bush Forever sites and contaminate the Jadankot Water
Mound with development? If
Jandakot Airport is seen as just another piece of real estate, then why
not build residential developments all over the golf courses, parks,
prisons, hospitals, Jandakot Regional Park, force out the Special Rural
and Kennel Zone residents and other areas as well? Where will it end?
Kings Park? Fremantle Harbour? Swanbourne Barracks? Subiaco Oval? It
would be a national disgrace if Ascot Capital were granted freehold of
the Jandakot Airport site and would set a precedent that would allow
rampant property development companies to dismantle essential and
irreplaceable infrastructure such as airports for their own gain, to the
detriment of the Australian people, and soon there would be no
infrastructure left. Any politician who supported this would have to have their motives closely examined in the public domain. DISADVANTAGES
OF RELOCATING This is a section I have added as there was no balancing argument in the briefing notes. Disadvantages of relocating include:
CONCLUSION The Directors of XXXXXX Pty Ltd and the proprietors of XXXXX Aviation do not support the proposed relocation as it would be detrimental to General Aviation and deprive the State of Western Australia of essential infrastructure within reach of Perth. To allow JAH freehold of the Jandakot Airport site would set an unacceptable precedent and place all transport infrastructure under threat from private development companies. Jandakot Airport needs to be run by aviation professionals and not persons with non aviation related motives for gaining leasehold of the site. It is in the interests of all Australians that this proposal is not allowed to proceed.
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