Attachments

Back to Annual Report 2019-2020

Attachment 1 - ANO Complaint Statistics

The following summarises the ANO complaint statistics for 2019-2020.

  Total Airservices Defence Unidentified
Complaints carried forward from 2018-19 321 316 5 0
Complaints received 134 120 13 1

Total complaints handled in 2019-2020 455 436 18 1

 
Closed complaints – reviewed
No change possible - explanation provided 40 34 6 0
Change adopted by Airservices or Defence 310 306 4 0
Change adopted by airport operator 0 0 0 0
Change adopted by operator 0 0 0 0

Total complaints reviewed and closed 350 340 10 0


Closed complaints – not reviewed
Referred to agency to respond to directly 55 50 5 0
Complainant did not provide further information 8 8 0 0
Outside Charter scope 7 5 1 1

Total complaints not reviewed and closed 70 63 6 1


 
Complaints closed during 2019-20 420 403 16 1


 
Complaints carried forward to 2020-21 35 33 2 0


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Attachment 2 - Noise improvement opportunities

A focus of ANO investigations into complaints is to evaluate whether the handling agency fully explored the potential to improve noise outcomes and provided sound reasons for its determinations. The following table summarises potential noise improvement opportunities arising from complaints reviewed by the ANO or through ANO monitoring during the 2019-20 financial year.

Noise improvement opportunities considered during 2019-20.

Complaint received by ANO Description of initiative Current status
Jun 2017

Perth: changes to northern smart tracking approach path to reduce noise impacts for residents

This suggestion was first raised by residents during the consultation exercise prior to the new path being introduced in Sept 2015. At that time Airservices elected to implement the path as designed and undertook to look at the opportunity to reduce noise impacts as part of an upcoming post-implementation review. In the PIR, Airservices again deferred consideration of the change pending other change initiatives and referral to the Airport's technical noise working group.

The ANO continued to seek updates from Airservices. In early 2018, Airservices advised that its noise modelling and a targeted environmental assessment indicated its proposed modification to the smart tracking approach would provide the best overall aircraft noise outcome. However, it elected to not pursue the change immediately, pending Perth Airport's finalisation of its Master Development Plan for the new parallel runway. Airservices advised that this was "to enable a proper assessment of the impact of the MDP, and its associated new runway flight paths, on the proposed Smart Tracking approach modification.' This approach, Airservices advised, "ensures the proposed modification is not completed in isolation from the proposed flight paths for the new runway in Perth, potentially resulting in a requirement to further modify the Smart Tracking approach and unnecessarily burdening the community'. At the time, the anticipated timeframe for Perth's MDP approval was the first quarter of 2019.

The ANO was advised by Airservices in late 2019 that "Based on Ministerial approval of the new parallel runway MDP by the end of 2019, and subject to any caveats placed by the Minister on the associated airspace management plan for the new runway, Airservices aims to implement the smart tracking change in the second half of 2020. The change is currently active in the Airservices flight path change pipeline, with relevant pipeline activities underway towards achieving an implementation timeline of the second half of 2020.'

In April 2020 Airservices advised the ANO that it had conducted an investigation into the proposed change to determine if it would deliver a net overall noise improvement for the communities in the area including conducting a social impact analysis of the current and proposed change. The analysis of social and environmental impacts determined that the proposed flight path change:

  • does not provide an overall noise improvement for residents in the area, as measured by count of dwelling and population overflight
  • would have a negative impact by increasing operations over sensitive sites, including schools and educational facilities, childcare centres, religious facilities, hospitals and aged care centres
  • had potential to increase the aviation noise exposure of future housing developments in the vicinity.

Based on these findings Airservices advised it would not be proceeding with the proposed change.

July 2019 Lismore: changes to holding pattern

During the course of investigating a complaint about the noise from the existing holding pattern of small planes approaching Runway 15 at Lismore Airport, Airservices agreed that further consideration could be given to whether the opportunities exist to move the holding pattern away from the more populated areas.

This proposed change has now been placed onto Airservices' ATS change program for consideration when workloads allow. Airservices advised the ANO that it will correspond directly with the complainant with updates as the change consideration process progresses. The ANO will not be monitoring further.


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Attachment 3 - ANO assessment of action on recommendations

During the 2019-2020 financial year, the ANO continued to monitor one recommendation Defence had outstanding from the ANO's 2016 review and seven recommendations Airservices had outstanding from the ANO's 2018 Hobart review. All of these recommendations were closed during 2019-2020.

Further, in this financial year, the ANO began monitoring 17 new recommendations arising out of three new reports.

The following tables set out the status of all outstanding recommendations and the ANO's assessment of action against each. Recommendations that were previously reported as closed have been removed.

Review of Defence's Aircraft Noise Complaints Management System (November 2016)

Ongoing recommendations ANO assessment of agency response

Recommendation 3 – Defence should review the Defence Aircraft Noise web information and, taking account of comments in this report, make improvements to information provision, presentation and functionality.

Closed – Defence has advised that it is maintaining the Defence Aircraft Noise Website as a business as usual practice. It has launched its online complaint form, has reviewed and updated its web information and fixed any links to address the issues identified in the review.

Defence's new practice is to check a random page once a week and fix links and make updates as required. Defence bases are also regularly updating the information on their individual pages.

Defence advised that a full review of its website will be conducted in due course.


Airservices - Investigation into complaints about the introduction of new flight paths in Hobart (April 2018)

Ongoing recommendations ANO assessment of agency response

Recommendation 2: Airservices should review its environmental assessment criteria to ensure they are appropriate as a quantitative measure for analysis against the EPBC Act requirements and for assessment of social impact.

Closed – Airservices has reviewed its criteria and had them approved by Department of Environment and has identified the matters to be considered in Social Impact Assessments.

ANO considers that Airservices has addressed this recommendation.

Recommendation 3: Airservices should ensure that its additional analysis of social impact to form part of the Environmental Assessment:

  1. includes a clearly defined purpose;
  2. includes explicit commentary on social impact taking into account particular community history, context and sensitivities; and
  3. incorporates a critically analytical assessment of the potential impact on the community of proposed change referring to both qualitative and quantitative values.

Closed –  Airservices has provided sufficient evidence of actions taken including:

  • updating its National Operating Standard (V15, Jun 2019) to address these requirements
  • demonstrating this procedure in use through providing a recent example of a completed Environmental Assessment and Social Impact Analysis.

The ANO considers that Airservices has addressed this recommendation.

Recommendation 4: In undertaking its Environmental Assessments and preparing reports on those assessments, Airservices should:

  1. ensure that all assessment criteria, for both EPBC Act purposes and for assessment of social impact, are clearly explained in its documentation in a way that makes clear their purpose, whether they are primary or secondary, the assessment methodology, and the consequences that follow if a threshold is exceeded;
  2. explicitly document any assumptions made and explain the basis for each assumption;
  3. explicitly document its consideration of change proposals against its stated criteria;
  4. undertake a more nuanced assessment of whether a change is ‘significant' in social impact or under the EPBC Act requirements, taking into account both quantitative and qualitative values so that a non-binary and more informative approach is taken to assessment against criteria; and
  5. refer to or document all relevant information that forms the basis of its environmental assessment and conclusions in a single explanatory Environmental Assessment report.

Closed – Airservices has provided sufficient evidence of actions taken including:

  • updating its National Operating Standard (V15, Jun 2019) to address these requirements
  • demonstrating this procedure in use through providing a recent example of a completed Environmental Assessment and Social Impact Analysis.

The ANO considers that Airservices has addressed this recommendation.

Recommendation 5: Airservices should access, through recruitment or otherwise, skilled and experienced subject matter expertise in the practice of community consultation. Leadership should give prominent support to this expertise so as to promote its influence and effect on Airservices' better performance in community consultation.

Closed – Airservices has embedded the relevant skilled and experienced subject matter expertise through:

  • completing an internal restructure with the Airports and Environment team, Community Engagement team and Flight Path Design team all reporting to the same Environment & Community Manager
  • recruiting a new Environment and Community Manager (at a senior management level) with extensive community engagement experience and skills. The new Manager commenced in this role on 30 March 2020 and will report directly to a member of the Executive
  • recruiting and appointing other community engagement staff with strong backgrounds in modern community engagement principles
  • increasing the capability of the Community Engagement Team through training and access to community engagement specialists, expertise, tools and technology.

The ANO considers that Airservices has addressed this recommendation.

Recommendation 8: Airservices should ensure that, before deciding to propose a change and to commence to engage with a community about that change, it has acquainted itself with the context and recent history of that community and takes those matters into account, as far as practicable, in its decision making and in its engagement design.

Closed – Airservices' flight path change cross-functional flowchart describes a process that incorporates social impact analysis immediately after a high level preliminary concept design is produced and anticipates review and amendment, if necessary, of the design in the context of the social impact analysis.

The ANO considers that Airservices has addressed this recommendation.

Recommendation 9: Airservices should, as part of its community consultation activity, approach the assessments and other material on which it bases its consultations from a critically analytical perspective so as to ensure that all relevant matters have been considered and the information provided to the community is timely, correct, relevant, transparent, comprehensive, consistent and logically sound.

Closed – Airservices has pointed to the material produced for the community consultation on the Melbourne flight path changes.  This material demonstrates satisfaction of the recommendation.

Recommendation 12: Where Airservices identifies through complaints inconsistencies in information provided to residents and other stakeholders, Airservices should take early action to correct information given.

Closed – Airservices has pointed to a number of instances in which it has identified inconsistencies in information provided and taken effective action to correct the information. This material demonstrates satisfaction of the recommendation.


Defence - Compliance Audit of Australian Super Hornet Flying Operations at RAAF Base Amberley (October 2019)

Ongoing recommendations ANO assessment of agency response
Recommendation 1 – Defence should establish robust administrative systems that ensure it obtains the required approvals for changes to its activities prior to implementing those changes. These systems should ensure annual reviews are conducted that would enable the identification and early rectification of any non-compliances.

Ongoing - Defence has prepared a remediation action plan and has commenced actions to address this recommendation.

Recommendation 2 – Defence should re-instate or adopt new or additional record management practices to ensure it can demonstrate its compliance with the Conditions of Approval and the requirements of the plans and strategies required by these Conditions

Closed - Defence has demonstrated it has put in place an internal audit process of its Aircraft Noise Management including reviewing the Australian Super Hornet Noise Management Plan and sub plans and advised that record management associated with the ASH Plans and Sub plans will be audited to ensure compliance with the Conditions of Approval.

Recommendation 3 – Defence should:

  1. review its draft version 4.0 Noise Management Plan in light of the findings of this audit report, the questions and comments made to date by the Department of the Environment and Energy, and in consideration of any other changes or assumptions that may be now relevant;
  2. ensure the revised Noise Management Plan retains a level of detail that is appropriate to its purpose as a public account of Defence's planned noise management activities and includes an appropriate requirement to regularly review the plan in light of any outcomes of its Noise Monitoring Program;
  3. set out clearly the changes compared to the version 3.0 Noise Management Plan and outline the reasons for these; and
  4. re-submit the revised version 4.0 Noise Management Plan for approval in line with Condition 8 of its approval

Ongoing - Defence has prepared a remediation action plan and has commenced actions to address this recommendation.

Recommendation 4 – Defence should regularly review its Noise Management Plan, with consideration to be given to relevant matters, including but not limited to:

  1. any foreseeable variations approved by the SADFO-Amberley;
  2. any changes to Super Hornet flying operations limitations or planning assumptions, which occur as a result of evaluation of the noise monitoring outcomes and the complaints process detailed in the Noise Monitoring and Complaints Handling Strategy; and
  3. the results of audits of compliance with its Conditions of Approval for Australian Super Hornet Flying Operations

Ongoing - Defence has prepared a remediation action plan and has commenced actions to address this recommendation.

Recommendation 5 – Defence should use its Annual Super Hornet Noise Reports to explicitly evaluate noise outcomes against the noise modelling undertaken for the Public Environment Report 2009, and also for any subsequent approved noise modelling undertaken

Ongoing - Defence has prepared a remediation action plan and has commenced actions to address this recommendation.

Recommendation 6 – Defence should table its Annual Super Hornet Noise Reports at the Amberley Consultative Working Group (ACWG) meetings and ensure this is minuted

Ongoing - Defence has prepared a remediation action plan and has commenced actions to address this recommendation.

Recommendation 7 – Defence should regularly review its Noise Monitoring and Complaints Handling Strategy, with consideration to be given to relevant matters, including but not limited to:

  1. any changes to the Noise Management Plan and Noise Mitigation and Complaints Resolution Strategy;
  2. those arising through the complaints process detailed in the Noise Monitoring and Complaints Handling Strategy; and
  3. the results of audits of compliance with its Conditions of Approval for Australian Super Hornet Flying Operations.

Closed - Defence has conducted its annual review of its Noise Monitoring and Complaints Handling Strategy and has published it on its website.

Recommendation 8 – Defence should identify and implement an effective method for publicly reporting on its actions in response to recommendations made in relation to its Conditions of Approval for Australian Super Hornet Flying Operations.

Ongoing - Defence has prepared a remediation action plan and has commenced actions to address this recommendation.

Recommendation 9 – Defence should regularly review its Noise Monitoring and Complaints Handling Strategy, with consideration to be given to relevant matters, including but not limited to:

  1. any changes to the Noise Management Plan and Noise Monitoring and Complaints Handling Strategy;
  2. those arising through the complaints process detailed in the Noise Monitoring and Complaints Handling Strategy; and
  3. the results of audits of compliance with its Conditions of Approval for Australian Super Hornet Flying Operations.

Closed - Defence has conducted its annual review of its Noise Monitoring and Complaints Handling Strategy and has published it on its website.


Airservices – Investigation into complaints about the introduction of new flight paths in Sunshine Coast (April 2020)

Ongoing recommendations ANO assessment of agency response

Recommendation 1 – Airservices should develop a framework for third party proposed changes that:

  1. provides robust and dependable governance arrangements to manage its early and ongoing engagement with third parties
  2. establishes clear lines of accountability and documents these arrangements as they evolve
  3. ensures an effective consultative process, which includes monitoring the adequacy of any third party consultations being relied on.

Ongoing – The Airservices Board accepted this recommendation and advised it is agreed as necessary. A Third Party Proposed Changes Framework is planned for implementation by 30 September 2020.

Recommendation 2 – Airservices should, as soon as practicable, design an effective post-implementation review (PIR) process for the Sunshine Coast flight path designs, that does not perpetuate design constraints requiring alignment with EIS concepts, and which encompasses:

  1. consideration of identified community-suggested alternatives
  2. a community engagement process that provides for genuine opportunities for community contributions to influence decisions
  3. application of the latest version of Airservices' National Operating Standard (NOS) Environmental Management of Changes to Aircraft Operations (AA-NOS-ENV-2.100).

Ongoing – The Airservices Board accepted this recommendation and advised:

  • a PIR Terms of Reference (TOR) will be developed for discussion and agreement with the ANO by September 2020
  • to complete the PIR, it is necessary to gather 12 months of post-implementation operational data to enable assessment of actual operation against the assessed impact. It is therefore anticipated this PIR will be completed not later than 18 months after runway opening.


Airservices – Review of Airservices Australia's systems for community engagement – Final Report (April 2020)

Ongoing recommendations ANO assessment of agency response

Recommendation 1 – Airservices should finalise its internal review and restructure of its Environment and Community Group including establishing a fully developed and settled suite of procedures and policies for community engagement, with a scheduled review and evaluation mechanism.

Ongoing – the Airservices Board accepted this recommendation and advised the restructure has been completed and Airservices' development of policies and procedures is well progressed with completion planned for 30 September 2020.

Recommendation 2 – Airservices should continue to strive to ensure its community engagement practice is in line with modern standards and methods of community engagement and draws on experience in other industries and countries. In particular, Airservices should consider emerging methods of community engagement such as ‘deliberative engagement' as an effective tool on the broader spectrum of community engagement.

Ongoing – The Airservices Board accepted this recommendation and advised this recommendation is being addressed through Airservices' new Community Engagement Framework due for completion 30 June 2020. In addition, the Airservices' community engagement team has recently completed certificate training through the International Association for Public Participation (IAP2).

Recommendation 3 – Airservices should meet with the ANO on a quarterly basis in relation to its community engagement activities and its presentation and distribution of aircraft noise related information.

Ongoing – The Airservices Board accepted this recommendation and advised the Airservices' Environment and Community Manager has established a program of regular meetings with the ANO, and discussions have progressed in this regard.

Recommendation 4 – Airservices should finalise and publish its Community Engagement Framework as a matter of priority to reflect its improved community engagement processes including (but not limited to) better planning and timing, reach and reasons for decisions.

Closed – The Airservices Board accepted this recommendation and advised the Framework was  being progressed as a priority and due for completion by 30 June 2020. (Airservices consulted the ANO on a draft Framework in 2019-2020 and published the Framework on its website in August 2020).

Recommendation 5 – Airservices should use its existing network of aviation industry meetings and groups to engage and coordinate more with the aviation industry on planned community engagement activities, in particular accessing the industry's knowledge of local conditions and concurrent community engagement activities.

Ongoing – The Airservices Board accepted this recommendation and advised the use of these networks is agreed as a positive action and internal discussions are progressing to develop appropriate processes to ensure this occurs.

Recommendation 6 – Airservices should develop a framework for third party proposed changes that:

  1. provides robust and dependable governance arrangements to manage its early and ongoing engagement with third parties
  2. establishes clear lines of accountability and documents these arrangements as they evolve
  3. ensures an effective consultative process, which includes monitoring the adequacy of any third party consultations being relied on.

Ongoing – The Airservices Board accepted this recommendation and advised this is agreed as necessary. A Third Party Proposed Changes Framework is planned for implementation by 30 September 2020.


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Last Updated: November 5, 2020