Annual Report 2020-2021

  1. From the Ombudsman
  2. Governance and systems
  3. Complaints
  4. Community engagement and information provision
  5. ANO reviews
  6. ANO publications
  7. Financial results
  8. Appendix 1 ANO 2021-2024 Strategic Plan
  9. Appendix 2 ANO Complaint Statistics
  10. Appendix 3 ANO assessment of action on recommendations

    Full report 1mb

From the Ombudsman

This has been another year of significant change and challenge for the office of the ANO.

On the initiative of the Airservices Board, the ANO moved to a three year funding cycle commencing next year. A corresponding three year strategic plan was also developed and approved. In view of the recent surge in complaints and future major developments in aviation, such as Western Sydney Airport, the ANO's funding has also been increased.

A review of the ANO Charter was completed clarifying some procedures and reinforcing the independence of the ANO's role. The office also implemented a new complaint management system which will help improve efficiency and reporting capacity in future years.

I would like to thank both the Airservices' Board and Chief of Air Force for their support during the year.

The ANO has increased its interaction with Airservices regarding community engagement and commends Airservices' development in this area. While COVID-19 has restricted travel, the ANO has virtually attended and monitored numerous community engagement activities.

Complaints, of course, remain a core function of the ANO. This year the ANO:

There has been further turnover of ANO staff during the year with significant loss of experience and corporate knowledge. My thanks go to former staff who maintained the ANO's high standards under the pressure of an increasing workload, and to the new staff who have stepped into a challenging environment and risen to the occasion.

Kieran Pehm
Aircraft Noise Ombudsman
19 August 2021

ANO Structure as at 30 June 2021

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Governance and Systems


In October 2020, the ANO Charter was updated to clarify and reinforce the independence of the role. The ANO also submitted the ANO 2021-2024 Strategic Plan and Budget to the Chief of the Air Force and the Airservices' Board, which was endorsed as proposed. Refer to Appendix 1 to view the ANO 2021-2024 Strategic Plan.


The 2021-2024 ANO budget has been increased due to the recent surges in complaints that the ANO has experienced, including those related to Brisbane Airport's new parallel runway. With a large number of major aviation projects anticipated to be completed in the upcoming years, an assessment of predicted demand for the ANO's services suggests that service demand will likely remain the same or increase into the future. The ANO continues to develop the capacity to support the current and anticipated future demands for the service.


In May 2021, the Airservices' Board approved key performance indicators (KPIs) for the ANO. The approved KPIs included complaint handling targets for initial responses to complainants, provision of regular updates as investigations progress and for completion of complaint investigations. To support the tracking of the complaint management KPIs, a major upgrade to the ANO Complaints System (ANOCS) was completed in late June 2021. In addition to supporting KPI tracking, the ANOCS upgrade will also facilitate improved complaint management and reporting capabilities, including improved efficiency of the ANO office.


The completion of the ANOCS upgrade has enabled the ANO office to commence KPI tracking as of 1 July 2021. Reporting against the ANO KPIs will commence from the next quarterly report providing increased visibility of the workload and performance of the ANO office.


Additionally, the ANO office has introduced issue tracking to assist in identification of common complaint themes. Identification of these themes will enable relevant observations to be shared with Airservices or Defence, to assist the agencies to identify opportunities for further improvement in information sharing at the systemic level, in addition to feedback provided on individual complaints.

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Complaint statistics

The ANO received 570 complaints in 2020-21, which represents a significant increase in complaints received, compared to the 134 complaints received in 2019-20. The following image describes how the complaints were handled.

Figure 1: Complaint handling by the ANO between 1 July 2020 and 30 June 2021

*Calculations as part of preparation of this report identified a previous inaccuracy in the 2019-20 carryover numbers, which were previously reported as 35.

3.2 The ANO started the financial year with 36 open complaints and received a further 570 complaints during the period. Of the total 606 complaints handled in 2020-21, 324 were closed. Of these, 62 complaints were reviewed in detail, 247 were referred back to either Airservices or Defence to respond to directly, 3 were closed without review due to a lack of information from the complainant and 12 were closed as outside the scope of the ANO Charter. This left 282 open complaints carried forward into the 2020-21 financial year.
3.3 Appendix 2 provides a more detailed summary of ANO complaint statistics for 2020-21.

Table 1 below details the number of complaints reviewed compared with the total number of complaints handled over the last five years. This table demonstrates that in the past year, there ANO has had a higher than usual referral rate to Airservices and Defence, predominately related to the new flight paths for Brisbane. The Brisbane flight paths are discussed in detail in Section 5.

Table 1: Complaints reviewed versus total complaints handled over time

  Complaints handled* Complaints closed Complaints reviewed** Complaints reviewed %
2016-17 131 119 70 59%
2017-18 115 104 65 63%
2018-19 413 92 39 42%
2019-20 455 420 350 77%
2020-21 606 324 62 19%

*Complaints handled – includes all complaints received;
**Complaints reviewed – includes only those complaints investigated (others are not reviewed due to being out of scope or need to be referred to the agency in the first instance)


Table 2 below shows the changes in the annual and per month average for ANO complaints received over time.

Table 2: Complaints received by financial year, with % change from previous year

  Total fin. year Ave per month % Change
Jul 2016-Jun 2017 114 9.5 ↓ 55.1%
Jul 2017-Jun 2018 103 8.6 ↓ 9.6%
Jul 2018 –Jun 2019 402 33.5 ↑ 290.2%
Jul 2019 –Jun 2020 134 11.2 ↓ 66.7%
Jul 2020-Jun 2021 570 47.5 ↑ 425.4%
3.6 The increase in complaints received in 2020-21 compared to the previous financial year is predominately due to the large amount of complaints received relating to the new flight path at Brisbane Airport during the past year. In addition, the COVID-19 pandemic and associated lockdowns over the past year has also resulted in changes in people's routines, particularly for people working from home, resulting in increased awareness of aircraft noise also contributing to the increase in complaints to the ANO.

Table 3 and Figure 2 demonstrate a significant increase in complaints relating to the complaint handling and community engagement practices of Airservices compared to previous years. This included a significant number of complaints in relation to the introduction of new flight paths for Brisbane Airport and in particular, the community engagement activities. In 2019-20, a noticeable increase was observable related to Sunshine Coast Airport proposed new flightpaths. The ANO anticipates that it will continue to see periods of high complaint activity associated with any major change to aircraft operations, such as new runways or major airspace designs. As illustrated in Table 3 and Figure 3, complaints about Defence are at a similar level to last year.

Table 3: Complaints received by agency in 2016-17 to 2020-21

  Total Airservices % Change Total
% Change
2016-17 99 ↓ 59.1% 15 ↓ 25%
2017-18 96 ↓ 3.0% 7 ↓ 53.3%
2018-19 393 ↑ 309.4% 9 ↑ 28.6%
2019-20 120 ↓69.5% 13 ↑ 44.4%
2020-21 553 ↑ 460.8% 11 ↓ 15.4%

Note – The above table does not include the six unidentified 2020-21 cases where neither Defence nor Airservices were identified as the relevant agency.

Figure 2: Complaints received about Airservices, 2016-17 to 2020-21


Figure 3: Complaints received about Defence, 2016-17 to 2020-21

3.8 The ANO continued to engage with both Airservices and Defence in relation to complaint handling processes. In addition to formal feedback and outcomes associated with ANO investigations, the ANOs office continue to provide feedback and discuss opportunities for improvement with the agencies' complaint handling systems and processes. ANO staff have increased communication with both agencies, to maintain existing relationships with the agencies and contribute to continuous improvement opportunities.
3.9 During 2020-21, 12 of the 62 complaints reviewed led to a change (Table 4). The remaining 50 cases did not result in a change, however, the ANO, having investigated the issues, provided a detailed explanation to the complainant about why there was no practical change identified.

All 12 cases closed with a change adopted, related to Airservices. Of these cases, the majority resulted in Airservices providing additional information to the complainant directly or undertaking further discussion with the complainant, regarding a proposed noise improvement.

Table 4: Outcome of complaints reviewed by the ANO in 2020-21

Complaints reviewed and closed:   %
No change possible - explanation provided 50 80.6%
Change adopted by Airservices/Defence 12 19.4%
Change adopted by airport operator 0 0
Change adopted by operator 0 0

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Community engagement and information provision

4.1 In 2020-21, ANO staff continued to attend community and aviation industry meetings. Due to the COVID-19 pandemic and the limitations on travel for the Ombudsman and staff, this year meetings were attended via teleconference or an online meeting platform.
4.2 ANO staff attended 12 meetings or events involving industry and community stakeholders over the year. Of particular note, the ANO attended a meeting with the United Kingdom's Independent Commission on Civil Aviation Noise (ICCAN), an organisation established by the UK Government as an 'independent non-statutory advisory arms-length body asked to act as the credible and impartial voice on all matters relating to civil aviation noise'. This was the second meeting with ICCAN and offered a valuable opportunity to discuss international trends and practices in the management of aircraft noise.
4.3 Further to the industry and community stakeholder events above, ANO staff attended 11 airport Community Aviation Consultation Group (CACG) (or equivalent) meetings. Despite the increase in workload experienced by the ANO office this past year, the change to virtual meetings has enabled the ANO to maintain a high level of attendance.
4.4 Attending these meetings as observers provides the ANO staff with direct knowledge of emerging aircraft noise management issues as well as assisting to foster a broader understanding and awareness of the ANO's role and aircraft noise management issues. Additionally, ANO staff take the opportunity at these meetings to monitor the effectiveness of community engagement undertaken by Airservices including their presentation and distribution of aircraft noise-related information.

Airservices' Community Engagement

4.5 The ANO continues to work to build a constructive relationship with Airservices in discharging its responsibility to monitor Airservices' community engagement processes, presentation and distribution of aircraft noise related information.
4.6 As part of this process the ANO and Airservices have instigated an ongoing monthly meeting between the ANO Senior Advisors and Airservices' Community Engagement Senior Advisors. This meeting is one of a number of strategies that have been introduced to offer the opportunity for more active engagement by the ANO in the evolution of Airservices' community engagement projects throughout all stages of delivery.

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ANO reviews

5.1 Appendix 3 summarises the ANO's assessment of progress on all recommendations that were either open at the start of or made during this financial year.




In December 2020, the ANO commenced a multi-complaint review as pursuant to clause 47 of the ANO Charter. This review was instigated due to the large number of complaints the ANO's office received about Airservices since the opening of the new runway and the new flight paths at Brisbane Airport. The scope of this review includes the following in so far as that relates to aircraft noise:

  • Airservices' environmental assessment of the impact of the flight paths associated with the new runway at Brisbane Airport
  • Airservices' engagement with the community as part of the flight design process.
5.3 A draft report was provided to Airservices in July 2021 for a response under clause 59 of the ANO Charter. The ANO anticipates that the review will be finalised in the next reporting year.

East Melbourne

5.4 The ANO also commenced a multi-complaint review in 2019 of flight path changes over East Melbourne. The ANO completed its assessment of these complaints in October 2020 and referred it to Airservices to attempt resolution, as required under the ANO Charter.
5.5 The matter could not be resolved and the ANO finalised its report to the Airservices Board. Airservices Board accepted all 3 recommendations of the ANO.
5.6 The ANO published its Investigation into complaints about the introduction of new flight paths in East Melbourne, in July 2021. A summary of the recommendations is included in Appendix 3.


5.7 The ANO published its Investigation into complaints about the introduction of new flight paths in Hobart, in April 2018 with all recommendations closed in 2019-2020.
5.8 Further to the 2018 report, during the past year, the ANO completed an investigation into complaints about Airservices' implementation of new flight paths at Hobart Airport during 2018/19. This investigation was finalised in May 2021 and the outcome provided to the complainants.
5.9 No recommendations were made to Airservices, as a result of the investigation.

Sunshine Coast

5.10 The ANO published its Investigation into complaints about the introduction of new flight paths in Sunshine Coast, in June 2020. The ANO's report made two recommendations for improving Airservices' community engagement framework and practices which were accepted by the Board of Airservices.
5.11 Airservices presented information to demonstrate its actions to address one of the recommendations related to Airservices developing a framework for third party proposed changes. The ANO considered this submission and was satisfied it could be closed in October 2020.
5.12 The second recommendation is currently ongoing related to Airservices' conducting a post-implementation review (PIR) of the change. The ANO continues to receive updates from and observe the activities of Airservices in relation to the Sunshine Coast PIR.
5.13 Airservices has developed a much more comprehensive PIR process than previously applied including extensive opportunities for community engagement. The ANO has no concern about the time taken and indeed believes it necessary in order to establish good faith with the affected community.

Systemic Review of Community Engagement


In 2018 the Airservices Board requested the ANO conduct a systemic review of the effectiveness of the community engagement systems of Airservices as a result of significant concerns highlighted in the ANO's review of Airservices' introduction of new flight paths in Hobart. The systemic review examined Airservices' readiness to engage effectively with communities about aircraft noise issues:

  • arising through its own change initiatives
  • resulting from its own business as usual activities
  • specifically in the context of major airport infrastructure projects scheduled over the next decade.
5.15 The ANO made six recommendations arising out of these findings, which were accepted by the Airservices Board. The Review of Airservices Australia's systems for community engagement -Final Report was published on the ANO website on 30 June 2020.
5.16 Airservices presented information to demonstrate its actions to address all 6 recommendations. The ANO considered these submissions and considered the recommendations implemented in October 2020.

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Compliance Audit of Defence's Super Hornet Operations at Amberley

5.17 In October 2019, the ANO completed a comprehensive audit of Defence's compliance with the Conditions of Approval for its Australian Super Hornet Flying Operations at RAAF Base Amberley and submitted a report to the Chief of Air Force.
5.18 The ANO assessed Defence's level of compliance against each Condition of Approval and each requirement identified from the three associated approved plans. A finding on the level of compliance was made in line with the Compliance Finding categories defined in the Independent Audit and Audit Report Guidelines (2015 Guidelines) that were in force at the time the audit criteria and methodology were approved.
5.19 The ANO considered that Defence had complied with the intent of the Conditions of Approval in relation to managing the effects of aircraft noise on the community and the environment. However, it had some work to do to establish effective systems to facilitate the necessary administrative, records management and reporting frameworks required to substantiate its performance against these Conditions and made a total of 9 recommendations.
5.20 In May 2020, the ANO prepared an Addendum to the October 2019 report, based on advice from the Department of Agriculture, Water and the Environment ('the Department') that the 2015 Guidelines had been updated in July 2019. In the Addendum, the ANO noted that this update did not result in any amendment, addition or removal of the recommendations made in the original Audit report of October 2019 or its overall conclusion.
5.21 In July 2020, 6 recommendations remained open. Defence submitted further evidence demonstrating that it had addressed all the outstanding recommendations made by the ANO. The ANO considered the evidence submitted and closed the remaining 6 recommendations in October 2020.

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ANO publications


In addition to its quarterly reports and last year's annual report, the ANO published the following on its website during 2020-2021:

  • ANO Statement -Terms of Reference for Sunshine Coast Post Implementation Review (January 2021)
  • ANO Report on investigation into East Melbourne flight paths (July 2021)
  • Airservices' response to ANO Report on investigation into East Melbourne flight paths (July 2021)

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Financial results

7.1 The ANO operates autonomously in managing its financial accountabilities, with a three-year funding cycle which provides the office with the flexibility to manage expenditure peaks and troughs that may occur across financial years. In line with the ANO Charter, the ANO independently determines how funds and resources are allocated within the budget provided by Airservices and Defence.
7.2 During 2021-2021, the ANO's actual expenditure was 31% below the budget allocation. The total operating expenditure of the office was $543,670 against a total budget of $787,361.06. This under-spend compared to budget reflects reduced expenditure on travel costs throughout the financial year due to the restrictions imposed by COVID-19 and reductions in staff costs associated with position vacancies while recruitment activities were completed. Additionally, delays in the ANOCS upgrade to June 2021 resulted in the upgrade costs being applied in the July-September 2021 quarter. Given the uncertainty of the aviation sector, the ANO remains mindful of the need to be prudent with any expenditure into the 2021-2022 financial year.

Figure 4 below depicts the ANO budget and actual expenditure over the last five years.

Figure 4: ANO budget and actual expenditure 2016-17 to 2020-2021

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Last Updated: October 13, 2021