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From: Saveour Airport Sent: Friday, 22 November 2019 2:02 PMTo: Stephen MitchellCc: Anna Shields; Anthony Patterson; Ashley Williams; Bruce Morris; Dean Saul; Kempsey Shire

Council; Leo Hauville; Liz Campbell; Mark Baxter; Sue McGinn; Craig Milburn; Gayleen BurleySubject: SKAAG Inc. Submission to draft FNAAttachments: Covering Letter - FNA Submission - 191122.pdf; SKAAG Master Submission - FNA - 191122.pdf;

Attachment A to FNA Submission - 191122.pdf

Hi Stephen, Please find attached re FNA: * Covering Letter * Submission * Attachment A Best regards,

‐‐ Regards from Save Kempsey Airport Action Group Inc Committee

Director, Corporate Kempsey Shire Council Secretary, SKAAG Inc. PO Box 3078 West Kempsey NSW 2440 22 November 2019 Dear Mr Mitchell, Subject: SKAAG Inc. Submission - Draft Fly Neighbourly Advice Please find enclosed submission from the Save Kempsey Airport Action Group Inc. in response to the draft Fly Neighbourly Advice (FNA) prepared by Council’s consultants, The Airport Group. Given that an FNA is an unenforceable voluntary code, SKAAG Inc. considers it an ineffective means of managing noise and low-level circuit training activity associated with commercial flight training operations. This view is based on AIAC’s history of non-compliance with previous conditions of consent and contractual agreements plus the fact that community groups at other airports with commercial flight training operations have found that FNA’s are effectively useless in addressing their concerns. SKAAG Inc. does acknowledge Council’s commitment to make compliance with the FNA a condition of any future airport hangar/terminal lease and/or conditions of use agreement as an enforcement mechanism for local operators. However, the effectiveness of this initiative depends on the scope of noise abatement measures included in the FNA. SKAAG Inc. continues to maintain that Kempsey Airport is unsuitable for commercial flight training operations given training syllabus requirements, the residential nature of the surrounding area and flight paths over key facilities with concentrated populations of school children and aged care residents. SKAAG Inc. will continue to oppose such flight training operations. However, SKAAG Inc. does look forward to working with Council to progress any alternative General Aviation initiatives that aim to make Kempsey Airport a more cost-effective, commercially viable and beneficial community asset. Please do not hesitate to contact should you require any further information, explanation or assistance. Yours sincerely,

CC: All Councillors

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Submission - Kempsey Shire Council SKAAG Inc. Response to Draft Fly Neighbourly Advice

Forward This submission to Kempsey Shire Council (Council) is made by the Save Kempsey Airport Action Group Inc. (SKAAG) in response to the draft Fly Neighbourly Advice (FNA) prepared by The Airport Group (TAG) regarding flying operations at Kempsey Airport.

This submission focuses primarily on commercial pilot training operations (particularly ‘circuit training’) and the need to have in place effective noise mitigation practices and measures to ensure operators fully comply with CASA regulations, particularly those regarding low flying aircraft.

It is important to note that SKAAG Inc. has no objection to what is generally considered ‘normal’ General Aviation (GA) operations at Kempsey Airport, that is where aircraft land having come from somewhere else or take off and go elsewhere. The only exception is aircraft conducting repetitive circuit training for the purpose of flight training.

FNA - The Chocolate Teapot of Aviation

FNAs’ are an unenforceable, voluntary set of ‘principles’ rather than a set of enforceable operating parameters. It is SKAAG Inc opinion that in the majority of cases, operators currently complying with regulations will continue to do so, and those that do not currently comply never will. As such, an FNA is useless as an effective noise mitigation tool. With the lack of effective noise abatement measures in this FNA and with the demonstrated unwillingness of Australian International Aviation College (AIAC) to comply with previous development consent conditions and contractual agreements, SKAAG has no confidence that this FNA will deliver any effective noise abatement outcomes for existing residents. This FNA reinforces the complete absence of noise abatement measures in Council’s endorsed NMP.

FNA - Audiences SKAAG acknowledges that the principal audience of this FNA are pilots operating in the vicinity of Kempsey airport and therefore the ‘Operational Summary’ at the front of the document must be clear, concise and uncluttered to be fit for purpose.

HOWEVER, the overall FNA must also recognise that residents living within the vicinity of the airport (5 km radius as endorsed by Council), as legitimate proponents, are also an audience and must be fully recognised as such and their concerns treated with equal respect within the ‘Main Body’ of the FNA.

As it stands, the ‘Main Body’ of the document is excessively focused on the aviation sector with little to no acknowledgement of the extent noise affected areas or concentrations of residential populations within 5 km of the airport, much less explanations as to how the FNA serves their needs in terms of providing practical noise abatement outcomes.

Areas of Concern ➢ Lack of clarity as to what flying activity is allowable below 1,000 feet.

➢ Insistence on using three noise sensitive ‘facilities’ as the only identifier of noise sensitive ‘areas.’

➢ Failure to recognise other areas identified in TAG’s NMP are noise sensitive areas.

➢ Failure to recognise that the three noise sensitive ‘facilities’ house concentrated numbers of occupants.

➢ Failure to identify & acknowledge ‘populous areas’ (CASA definition) or ‘built up areas’ (RMS definition)

➢ Unnecessary and unacceptable qualifications applied to some key noise mitigation measures.

➢ Exclusion of key noise mitigation measure sought by SKAAG.

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➢ Removal of key text from that in the previous iteration of the draft FNA, thus weakening the document.

➢ Failure to articulate the concerns of general aviation operators, other than flight training operators.

➢ Failure to acknowledge that flight training operators may need to amend their SOP’s.

➢ Failure to place a limit on the number of aircraft a training operator may have in the circuit at one time.

➢ Failure to include an obvious, critical measure of complaints relating to flight training operations.

Points of Objection - Operational Summary

As stated above, SKAAG acknowledges that the principal audience of this FNA are pilots operating in the vicinity of Kempsey airport and that the ‘Operational Summary’ must be clear, concise and uncluttered.

However, there are some weaknesses and omissions in the ‘Operational Summary’ that require rectification.

Objections

Actions Required

Noise Sensitive Areas & Figure 1: Unnecessary and unacceptable definition of ‘noise sensitive areas’ by using three (3) noise sensitive ‘facilities’ as the only identifier of noise sensitive ‘areas.’

Failure to acknowledge and identify other noise sensitive areas as defined by CASA as ‘populous areas’ or by RMS definition of ‘built up areas.’ These areas were partially identified by AIAC’s acoustic consultant’s report: GHD - Kempsey Airport - Aircraft Noise Assessment (February 2017) at Figures 3 to 9 to the extent that individual ‘receivers’ were marked. Copy of Figure 3 attached.

Amend text and Figure 1 to clearly identify the ‘populous areas’ located within 5km radius but particularly:

• Housing cluster 600 metres north east of RWY 04 threshold.

• Housing clusters to the north, north west and west of the airport.

Identify the other significantly impacted areas as per Noise Management Plan noise study.

Include AIP Aerodrome Chart for YKMP in FNA.

Add text to read: ‘See shaded areas on AIP Aerodrome Chart for YKMP’

Note for TAG:

The end of opening para at Noise Sensitive Areas

should reference Figure 1, not Figure 2.

Departing Aircraft: No reference to engine power & propeller pitch settings.

Add a sentence: ‘Operators should select engine power & propeller pitch settings consistent with the aircraft operations manual to achieve minimum noise level on take-off.’ Note: Exclude ‘where practicable’ qualification.

Simulated Engine Failure Practice: ‘Where practicable’ is an unnecessary and unacceptable qualification.

Remove qualification: Delete the words ‘Where practicable’

Additional Principles for Flight Training: This section refers only to expanded hours of operation as determined by Council.

Add the following noise abatement requirements:

• Maximum of two (2) training aircraft in the circuit at one time.

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This section fails to include practical noise abatement measures required by residents, specifically applicable to commercial flight training operators and their instructors.

• Training aircraft must join the circuit as legislated - no less than 500 feet above the circuit altitude for that leg.

• Training aircraft must comply with CASA Regulation 157 (Low Flying Aircraft) to avoid overflying ‘populous areas’

• Training aircraft are to be fitted with transponders (See 1.8.2).

• Training aircraft are to be fitted with mufflers/silencers.

• Simulated engine failure practice is to be conducted over the CASA designated Intermediate Training Area east of Kempsey

• Circuit training by twin engine aircraft is not permitted at YKMP.

Points of Objection - Main Body

Unlike the ‘Operational Summary’, the ‘Main Body’ of the FNA must include sufficient detail and explanations to provide residents with confidence that the intent (if not the effect) of the document is to provide effective noise abatement measures.

Further, should commercial flight training operators and their instructors choose to read the ‘Main Body, such detail and explanations may actually inform them as to why the fly neighbourly principles are important to residents within 5km radius of the airport.

The weaknesses and omissions in the ‘Main Body’ of the FNA as identified below require rectification.

Objections

Actions Required

1.4 Intention of the FNA: The statement refers only to operators flying to or from KPS. It fails to make specific reference to circuit training operators.

Amend the statement to read: ‘….. to or from KPS and flight training operators which may minimise …’

1.5 Proponents: Unnecessary and unacceptable change of text from previous iteration of draft FNA. The specific reference to ‘residents in the vicinity of Kempsey Airport and specific noise sensitive facilities’ has been replaced with a general reference to ‘residents of Kempsey’ - this further reinforces the perception that the people actually impacted by circuit training activity are of no particular importance compared to the wider Kempsey population who are unaffected and don’t give a toss.

Reinstate previous wording to read: ‘ …. are KSC, residents living in the vicinity of Kempsey Airport, (occupants) of noise sensitive facilities, and all locally ….’

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1.7 Matters of Concern:

1.7.1 Aviation Operations 1.7.2 Aviation Operators Lack of clarity through unacceptable over emphasis on ‘Aviation’, particularly re 1.7.1. where residents are not mentioned with respect to operations.

Amend sub headings to read: 1.7.1 Residents’ Concerns re Aviation Operations 1.7.2 Concerns of Aviation Operators

1.7.1 Aviation Operations: Unacceptable failure to include a dot point referencing low flying aircraft.

Insert a second dot point to read:

• Repeated low flying circuit training aircraft over ‘populous areas.’

(1.7.1) Noise Sensitive Areas: Using only the three (3) noise sensitive ‘facilities’ as the sole identifiers of noise sensitive ‘areas’ is unacceptable.

Amend text and Figure 2 to clearly identify the ‘populous areas’ located:

• Housing cluster 600 metres north east of RWY 04 threshold.

• Housing clusters to the north, north west and west of the airport.

Identify the other significantly impacted areas as per Noise Management Plan noise study.

Include AIP Aerodrome Chart for YKMP as an Attachment in the FNA.

Add text to read: ‘See shaded areas on AIP Aerodrome Chart for YKMP’

(1.7.1) Noise Sensitive Areas: No quantification of the concentrated populations in the three (3) noise sensitive facilities.

Quantify populations in the noise sensitive facilities:

• Booroongen Aged Care: > 180 (fluctuates)

• Aldavilla School: 345 students plus staff

• Greenhill School: 40 students plus staff

(1.7.1) Noise Sensitive Areas: Failure to acknowledge and identify other noise sensitive areas as defined by CASA as ‘populous areas’ or by RMS definition of ‘built up areas’; such areas clearly falling within 5 km radius of the airport as per Council’s endorsed NMP.

Include a sub heading called ‘Definitions’. Insert CASA’s definition of ‘populous area’ Insert RMS definition of ‘built up area’

See ‘Definitions’ later in this submission.

(1.7.1) Noise Sensitive Areas: (Page 3, Para 1) Lack of clarity in last sentence regarding ‘300 feet per nautical mile.’ Is this meant to mean descending at 300 feet per nautical mile?

Clarify. Apparently, it refers approach angle. Figure 2: Add a mark to identify 1.7 nautical mile from approach to RWY 22. Consider including AIP Approach Chart (RNAV RWY 22) as an Attachment in the FNA.

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1.7.2 (Concerns of) Aviation Operators: Absence of detail regarding the specific concerns of aviation operators at KPS other than citing a general concerns of flight training operators as an example.

Insert a list of concerns of aviation operators at KPS, other than flight training operators, that were expressed during TAG’s consultation processes. If no such concerns existed, then clearly state so.

1.8 Fly Neighbourly Principles for KPS: This section makes reference to NMP adopted by Council at Council Meeting of 25 June 2019. However, there is no indication as to what noise abatement measures were included in that plan. This is not surprising given no such measures were included - the NMP is incorrectly named as it is not a plan to manage noise.

Either list here the noise abatement measures that were contained in the NMP as endorsed by Council OR if no such practical measures were included, then say so here.

Note: It is acknowledged that Council did endorsed a circuit altitude of 1,000 feet, pending approval by CASA. Approval must be articulated in the final FNA.

1.8.1 Circuit Operations (all operators):

Standard Circuit Height of 1,000 feet is qualified by ‘with the exception of those aircraft that operate at circuit heights lower than 1,000 feet’

Clarification required. The exemptions must be listed.

Circuit Direction AIAC have been observed climbing into the circuit.

Training aircraft must join the circuit as legislated (no less than 500 feet above the circuit altitude).

1.8.2 All Other Operations:

Departing Aircraft No reference to engine power & propeller pitch settings.

Add a sentence: ‘Operators should select engine power & propeller pitch settings consistent with the aircraft operations manual to achieve minimum noise level on take-off.’

Overflying Noise Sensitive Areas Inadequate definition and identification of noise sensitive areas.

First sentence: Replace ‘Areas’ with ‘Facilities’. Add a sentence: ‘See Section 1.7.1’

Simulated Engine Failure Practice ‘Where practicable’ is an unnecessary and unacceptable qualification.

Remove qualification: Delete the words ‘Where practicable’ Add a sentence: ‘Pilots should use the designated Intermediate Training Area east of Kempsey for this exercise.’ Include a Figure using Google Earth to show the Intermediate Training Area as an Attachment to the FNA.

Take Off Point ‘Where practicable’ is an unnecessary and unacceptable qualification.

The word ‘encouraged’ is too weak.

Remove qualification: Delete the words ‘Where practicable’

Delete the word ‘encouraged.’

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Aircraft Noise Standards The reference to engine power and propeller pitch settings is unnecessary at this point providing this reference is included as above at ‘Departing Aircraft’ in both Operational Summary and Main Body.

See ‘Departing Aircraft’.

1.8.3 Flight Training Operations Unacceptable heading change from previous iteration which had set this section a level higher in the heading hierarchy and provided greater distinction between offensive Flight Training Operations and other acceptable GA operations.

Reinstate heading hierarchy to:

1.9 Flight Training Operations

and adjust all subsequent headings.

Number of Aircraft in a Circuit Postponing setting a limit of two (2) training aircraft in the circuit to a future date at the discretion of KSC is unacceptable. One aircraft produces an overflight every 6 minutes and very additional aircraft in the circuit halves the time between overflights: 2 aircraft = every 3 minutes, 3 aircraft = every 90 seconds, 4 aircraft = every 45 seconds between overflights. The Doppler effect produces a constant fluctuating drone. Residents have put up with this for 5 years - it is absolutely unacceptable and contravenes Council’s Community Strategic Plan. It is well past time to place limits on the number of training aircraft conducting repetitive circuit training at one time - limits are common at other airports.

Apply a limit of two (2) training aircraft conducting circuit training at one time.

Note: This is not intended to restrict other training aircraft from departing for and returning from the Intermediate Training Area or cross-country navigation training. This only becomes a problem is such aircraft join the circuit to conduct repetitive circuit training activities, thus adding to the 2 aircraft limit for circuit training.

Additional Principles for Flight Training: This section refers only to expanded hours of operation as determined by Council.

This section fails to include noise abatement measures required by residents, specifically applicable to commercial flight training operators and their instructors.

AIAC have been observed climbing into the circuit.

Include the following noise abatement measures:

• Training aircraft must join the circuit as legislated - no less than 500 feet above the circuit altitude for that leg (See Figure 3).

• Training aircraft must comply with CASA Regulation 157 (Low Flying Aircraft) to avoid overflying ‘populous areas.’

• Training aircraft are to be fitted with transponders (See 1.8.2).

• Training aircraft are to be fitted with mufflers/silencers.

• Simulated engine failure practice is to be conducted over the CASA designated Intermediate Training Area east of Kempsey

• Circuit training by twin engine aircraft is not permitted at YKMP.

A definition of ‘Populous Area’ needs to be included in the FNA as a reminder for pilots and to give residents some assurance that the issue is recognised.

Add 1.10 Populous Areas to heading hierarchy, include definitions found later in this submission and adjust all subsequent headings.

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Include AIP Aerodrome Chart for YKMP as an Attachment in FNA and add text to read:

‘See shaded areas on AIP Aerodrome Chart for YKMP’

1.9 Fly Neighbourly Advice Monitoring A critical complaints data element is missing. (If you can’t measure it, you can’t manage it)

Add a dot point at top of the list to read:

• ‘Number of complaints relating to flight training operations as a percentage of total complaints.’

1.10 Means of Monitoring the Adherence to Principles There is no means of public reporting.

Council to place monthly reporting data on its website, differentiating between flight training and other general aviation related complaints. Exclude aircraft and owner/operator identification.

1.14 Conclusion and FNA Review Process The first para incorrectly infers that there are (or will be?) noise abatement procedures or operating procedures included in the ERSA. The NMP DID NOT include any noise abatement or operating procedures other than those already embedded in CASA Regulations. Council received 175 submissions re the NMP, all opposing circuit training operations yet Council endorsed TAG’s recommendations to expand operating hours, include weekends and Public Holidays (except Christmas Day) for local operators and to encourage visiting operators. This clearly contradicts the wishes of every submission received and ignored the need to put noise abatement measures are in place.

A statement must be added to acknowledge that the ERSA for KPS does not currently include any noise abatement measures. Statement to read:

‘At time of adopting this FNA, it is acknowledged that the ERSA entries for KPS do not include any noise abatement measures.’

References:

• Attachment A to this submission.

• Council Meeting Agenda for 28/11/19 re QON1 from Councillor Morris.

________________________________ See Attachment A: SKAAG submitted a table of 13 noise abatement measures. Status in final draft FNA:

• 3 were included in full

• 3 were partially included or with qualifications

• 7 were excluded See QON1 Response: The response listed four (4) categories of reasons why some measures were excluded:

• Replicating existing legislative requirements

• Being impractical for any operator

• Breaching legislative requirements

• Creating unintended safety issues

Action Required: In the final report to Council, list those measures not included in full in the FNA under the relevant category outlined in the response to QON1 and explain why/how each measure meets the category as assigned.

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EXPLANATORT NOTES: Re QON1 Response: SKAAG acknowledges that Council will enforce compliance with the final FNA as a condition of any future hangar/terminal lease/or conditions of use agreement. However, this enforcement mechanism is only as good as the noise abatement measures included in the FNA and won’t apply to those flight training operators not subject to a contractual arrangement with Council. It is essential that the most restrictive but legislatively compliant noise abatement measures are included in the FNA with regard to commercial flight training operations, particularly as such measures will not appear in the ERSA.

Questions

Answers

Q1: Why did Council and/or TAG fail to directly consult with the Principals and/or P & C Association of Aldavilla and Greenhill schools or the NSW Department of Education in preparing the draft FNA?

Note: This is a ‘why’ question. Do not regurgitate the verbose, irrelevant and evasive material provided in answer to QON2 by Councillor Morris in Council Business Papers for 28/11/19.

Q2: Why did Council and/or TAG fail to directly consult with the management of Booroongen Aged Care facility in preparing the draft FNA? If yes, what was the feedback? If not, why not?

Note: This is a ‘why’ question. Do not regurgitate the verbose, irrelevant and evasive material provided in answer to QON3 by Councillor Morris in Council Business Papers for 28/11/19.

Definitions

CASA definition of Populous Area:

In the phrase ‘any city, town or populous area’: Populous area means ‘the space which, for the time being, is covered by, or occupied as accessory to buildings or houses collected together in a mass, and in sufficient numbers to be ordinarily designated as a city or town; and includes unbuilt-on lands which may lie within the ambit of such collected mass of houses or buildings’. This can include a piece of open land (for example, parks, sporting fields, golf courses) for recreational use in an urban area. The addition of ‘populous area’ to the words ‘any city, town’ defined above, effectively extends the area to built-up areas such as small townships.

NSW Roads & Maritime definition of Built Up Area:

A built-up area is an area in which there are buildings on the land next to the road, or there is street lighting, at intervals not over 100 metres for a distance of at least 500 metres or if the road is shorter than 500 metres for the whole road.

Implications for the FNA:

The following specific areas in the immediate vicinity of the airport meet the above-mentioned definitions and these must be clearly identified in the FNA Main Body:

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• Warne Drive/Campbell Place subdivision (650 metres north east of RWY 04 threshold)

• Hillview Drive/Haven Crescent/Park Road subdivision (immediately north west of the airport)

• Sherwood Road (south from Old Aerodrome Road)

• Ronella Drive and Airport Road

Further, as identified in the NMP Noise Study, there are other residential areas within 5 km of the airport that meet these definitions. These need to be identified as they also demand aircraft strictly comply with CASA Regulations - particularly Regulation 157 (Low Flying Aircraft).

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Attachment A

SKAAG Inc. Noise Abatement Measures

Circuit Training Operations at Kempsey Airport

Noise Abatement Measure

Reason

Included in draft

FNA?

1. Runway Departure Flight Paths & Altitudes: RWY 22: Pilots departing RWY 22 are to maintain runway heading until the aircraft has crossed over the Macleay River and is at 1,000 feet AGL before turning to cross wind leg or altering course to final destination.

RWY 04: Pilots departing RWY 04 are to maintain runway heading until the aircraft has crossed over Armidale Road, has passed the highly visible elevated water tower and adjacent motor racing track and is 1,000 feet AGL before turning to cross wind leg or altering course to final destination.

To attain height & distance from rural residential dwellings south & east of airport. To avoid overflying Aldavilla School and ‘populous areas’ north west & west of airport.

Partially included: • Altitude - Yes

• Flight Paths & Way Points - No

SKAAG now removes the way point requirement as this could make a bad situation worse.

2. Approach Flight Paths: Training aircraft joining Kempsey left-hand circuit must be 500 feet above the

published circuit altitude for that leg. AIAC have been observed climbing into the circuit.

To prevent training aircraft entering the circuit from below circuit altitude.

No

3. Circuit Altitude: 1,000 feet AGL minimum.

To ensure training aircraft comply with CASA standard.

Yes

4. Low Level Circuit Training: Low level circuit training not permitted.

To prevent excessively low-level circuits over Warne Drive/Campbell Place subdivision.

Yes

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5. Overflying Houses, Populous Areas & Noise Sensitive Areas: Avoid overflying ‘populous areas.’

To ensure training aircraft comply with CASA requirements.

No

6. Take Off Point: Start take-off at threshold end of RWY.

To achieve maximum altitude within airport.

Yes

7. Simulated Engine Failure After Take-Off: SEFATO’s are not permitted within circuit training area. Use CASA

allocated Intermediate Training Area east of Kempsey Township.

To move this offensive manoeuvre to a more appropriate area.

Partially included - but with qualification

8. Power/Pitch Settings: Select engine power & propeller pitch settings consistent with the aircraft

operations manual to achieve minimum noise level on take-off.

To minimise noise at take-off.

No [FNA refers only to P&P on approach]

9. Transponders: Training aircraft must be fitted with operational transponders and switched on whenever the aircraft is engaged in flight operations. Unserviceable transponders must be changed out prior to flight operations.

To enable residents to track & report offending aircraft.

Included - but with qualification

10. Mufflers: Training aircraft are to be fitted with manufacturer approved mufflers/silencers.

Noise abatement.

No

11. Maximum Number Training Aircraft in Circuit: Maximum of two (2) pilot training aircraft in the circuit at

any one time.

To minimise repetitive overflights.

No

12. Twin Engine Aircraft: Twin engine aircraft are not to be used for pilot training at Kempsey Airport.

Noise abatement.

No

13. Intermediate Training: All non-circuit training activity (excluding cross country navigational training) is to be

conducted in the CASA designated training area.

To relocate training activities that don’t need to be done at the airport.

No

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Donna Pearson

From:Sent: Wednesday, 13 November 2019 3:11 PMTo: Kempsey Shire CouncilSubject: FLY NEIGHBOURLY ADVICE

It is not surprising the title of the above "Advice" was changed from "Agreement". With reference to the final draft released on 25 October, which I consider to be a complete waste of time and money. Unless there is something enforceable in place there will always be problems. We, the locals, have no problems with the majority of aircraft using the airport. All except the flying school pilots know what they are doing. Regardless of the type of aircraft/helicopter they do not fly low and noisily over houses. They do what they have to do at the airport and leave again. It is so obvious AIAC have not and do not intend to ever fly neighbourly. It is as if they do not know about our concerns. I live in and have not seen the school making any attempt to fly at 1000 feet or cease simulated engine failure. I cannot be outside my house with a camera in my hand all the time to film evidence to prove to you and CASA what they get up to. You have never seriously addressed our concerns.

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Incoming paper/mail over customer service counter — file note Person/Business details (from) Who is it for Subject or file number it relates to

Date collected Service Officer

18 November 2019

General Manager Kempsey Shire Council c/- Customer Service Centre Tozer Street WEST KEMPSEY NSW 2440

Dear Sir

SUBMISSION REGARDING KEMPSEY SHIRE COUNCIL'S FLY NEIGHBOURLY ADVICE (FNA)

I wish to lodge an OBJECTION to the proposed Fly Neighbourly Advice (FNA) currently on exhibition.

The FNA is only a voluntary code of practice. It is not enforceable and therefore is nothing more than a piece of paper; it offers no peace of mind as it cannot effectively protect the interests of residents.

The noise study that was undertaken was a farce as they never flew as much until it was over. The diesel planes which are very noisy hardly flew at all during this time.

I have had the opportunity to observe over a lengthy period of time the reality of the situation. The planes frequently fly low over our home and often ease off then open the throttle. Some days it is so bad, we cannot stay at home.

Council and others are very strong in their views on mental health but do not seem to care about ours. It is very wrong that a small panel of people can make decision that has such an negative impact on our life and health.

Yours sincerely

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From: Sent: Saturday, 23 November 2019 9:21 AMTo: Kempsey Shire CouncilSubject: Submission FNA

I have the following objections regarding the FNA: While the NMP doesn’t include any practical ways to manage noise, the FNA is purely voluntary and not enforceable. The past has shown that AIAC has breached several agreements and residents had no measure to do anything about it. How does that change having a FNA? I don’t really understand under which circumstances flying is allowed below 1,000 feet. Can you please describe the exceptions clearly so residents and students know what they are. I find the wording like ‘where practicable’ or ‘if fitted’ inappropriate as it doesn’t describes what it actually implies. How would the residents or students know what it means?

Also some important noise mitigation measures for commercial pilot training aircraft and operations are missing: ‐There can only be a maximum of 2 training aircraft in the circuit at one time.

‐Training aircraft must follow CASA Regulations and not fly over ‘populous areas’ below 1,000 feet.

‐Training aircraft must be fitted with transponders.

‐Training aircraft must be fitted with mufflers/silencers.

‐Simulated engine failure practice must not be done at the airport, it should be done over the Intermediate Training Area east of Kempsey

Regards

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From: Sent: Saturday, 23 November 2019 9:24 AMTo: Kempsey Shire CouncilSubject: Submission FNA

I have the following objections regarding the FNA: While the NMP doesn’t include any practical ways to manage noise, the FNA is purely voluntary and not enforceable. The past has shown that AIAC has breached several agreements and residents had no measure to do anything about it. How does that change having a FNA? I don’t really understand under which circumstances flying is allowed below 1,000 feet. Can you please describe the exceptions clearly so residents and students know what they are. I find the wording like ‘where practicable’ or ‘if fitted’ inappropriate as it doesn’t describes what it actually implies. How would the residents or students know what it means? Also some important noise mitigation measures for commercial pilot training aircraft and operations are missing: -There can only be a maximum of 2 training aircraft in the circuit at one time. -Training aircraft must follow CASA Regulations and not fly over ‘populous areas’ below 1,000 feet. -Training aircraft must be fitted with transponders. -Training aircraft must be fitted with mufflers/silencers. -Simulated engine failure practice must not be done at the airport, it should be done over the Intermediate Training Area east of Kempsey Regards

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From:Sent: Wednesday, 27 November 2019 10:56 AMTo: Kempsey Shire CouncilSubject: submission - response to draft FNA

Submission to Kempsey Shire Council

Response to Draft Fly Neighbourly Advice

Once again the Kempsey Shire Council has put forward a proposal which dismally fails to address the concerns of its residents and rate‐payers impacted by the introduction of circuit training at the Kempsey airport. As the Fly Neighbourly Advice is voluntary and unenforceable, it would appear to be about as useful as the Noise Management Plan which fails to manage noise. Once again, I take the opportunity to voice my complete opposition to circuit training in the Macleay Valley. Once again, I expect it will fall on deaf ears. Yours faithfully

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From:Sent: Wednesday, 27 November 2019 11:08 AMTo: Kempsey Shire CouncilSubject: Submission Re FNAAttachments: Submission Re FNA.docx

Please find attached a Submission in regards to the FNA. Regards,

Submission to Council Re Fly Neighbourly Advice.

First and foremost I strenuously object to any form of Aircraft Circuit Training in the Macleay Valley.

Points of Objection Re FNA.

The Noise Management Plan (NMP) approved by Council in June did not include any practical ways to reduce circuit training noise. It is incorrectly named as it is not a plan to actually manage noise. The FNA appears just as useless given that it is purely voluntary and not enforceable. AIAC’s past breaches of contractual agreements indicates that they are unlikely to ‘fly neighbourly’ of their own accord. FNA’s have proven useless at other airports where residents are subject to repetitive circuit training for days and hours on end.

The way the main body of the FNA is written and the wording used is far too focused on the

‘aviation’ community. There is little reference to ‘residents’ and this diminishes the significance and importance of residents as one of the main ‘proponents’ of the FNA.

‘Qualifications’ applied to some important noise mitigation measures implies that it is OK to ignore these measures.

• Remove the ‘Where practicable’ qualification at Simulated Engine Failure Practice • Remove the ‘Where practicable’ qualification and the word ‘encouraged’ at Take-Off

Point. • Remove the ‘If fitted’ qualification at Transponder Usage

Some important noise mitigation measures for commercial pilot training aircraft and operations are missing.

• Maximum of 2 training aircraft in the circuit at one time. • Training aircraft must follow CASA Regulations and not fly over ‘populous areas’ below

1,000 feet. • Training aircraft must be fitted with transponders. • Training aircraft must be fitted with mufflers/silencers. • Simulated engine failure practice must not be done at the airport, it should be done over

the Intermediate Training Area east of Kempsey • Twin engine aircraft are not to be used for flight training at Kempsey Airport.

Thank you for this opportunity,

Regards,

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From:Sent: Thursday, 28 November 2019 1:40 PMTo: Kempsey Shire CouncilSubject: SUBMISSION FLY NEIGHBOURLY ADVICE (FNA)

I wish to lodge a submission of objection regarding Fly Neighbourly Advice currently on public exhibition. I believe that this document is solely focused on supporting the aviation community and therefore having negative impacts on the residents of Aldavilla. Daily AIAC thumb their nose at the residents with their appalling flying manoevres, stalls, anything they like, sooner or later there will be an accident from them.

which is apparently a noise sensitive 'facility' according to the FNA when in actual fact this is my house that I live in and have to be affected by AIAC circuit training daily which is an adhorent outcome for anybody. I have no objection to any other flight activity that comes from the airport. Please amend the FNA to indicate how many aircraft a training operator may have in the circuit at one time. Qualifications applied to some important noise mitigation measures implies that it is OK to ignore these measures: Remove the "Where practicable" qualification at Simulated Engine Failure Practice. Remove the "Where Practicable" qualification and the word 'encouraged' at Take‐Off Point. Remove the "if fitted" qualification at Transponder Usage. The FNA only appears to relate to AIAC, what about the concerns of the other operators that use this airport. Failure to emphathise that flight training operators should amend their Standard Operating Procedures to highlight and reinforce the FNA requirements. It should be that instructors and students understand the importance of the FNA requirements and that they need to comply with them. Please listen to residents that have concerns about the flight training college that operate from the airport and put in place some protection for them instead of allowing them to be target practice. Yours sincerely

28/11/2019

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From:Sent: Thursday, 28 November 2019 1:53 PMTo: Kempsey Shire CouncilSubject: SUBMISSION OF OBJECTION FOR FLY NEIGHBOURLY ADVICE

I wish to lodge a submission of objection regarding Fly Neighbourly Advice currently on public exhibition. I believe that this document is solely focused on supporting the aviation community and therefore having negative impacts on the residents of Aldavilla.

which is apparently a noise sensitive 'facility' according to the FNA when in actual fact this is my residence. There are other 'facilities' in this area, houses, schools, nursing home. Please amend the FNA to indicate how many aircraft a training operator may have in the circuit at one time. A maximum of 2 training aircraft in the circuit at one time. Qualifications applied to some important noise mitigation measures implies that it is OK to ignore these measures: Remove the "Where practicable" qualification at Simulated Engine Failure Practice, this must not be done at the airport or over houses near the airport, it should be done over the intermediate training area at east of Kempsey. . Remove the "Where Practicable" qualification and the word 'encouraged' at Take‐Off Point. Remove the "if fitted" qualification at Transponder Usage, these planes should all have their transponders on when flying, mufflers and silencers would be a godsend.. The FNA only appears to relate to AIAC, what about the concerns of the other operators that use this airport. Failure to emphathise that flight training operators should amend their Standard Operating Procedures to highlight and reinforce the FNA requirements. It should be that instructors and students understand the importance of the FNA requirements and that they need to comply with them. There appears to be one obvious measure of complaints relating to flight training operations is missing. There is no measure of complaints relating specifically to circuit training activity. This must be recorded and reported as a percentage of total complaints. Please listen to residents that have concerns about the flight training college that operate from the airport and put in place some protection for them instead of allowing them to be target practice. Please update the FNA to support residents. Yours sincerely

28/11/2019

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which is apparently a noise sensitive 'facility' according to the FNA when in actual fact this is their residence. There are other 'facilities' in this area, houses, schools, nursing home. Please amend the FNA to indicate how many aircraft a training operator may have in the circuit at one time. A maximum of 2 training aircraft in the circuit at one time. Qualifications applied to some important noise mitigation measures implies that it is OK to ignore these measures: Remove the "Where practicable" qualification at Simulated Engine Failure Practice, this must not be done at the airport or over houses near the airport, it should be done over the intermediate training area at east of Kempsey. . Remove the "Where Practicable" qualification and the word 'encouraged' at Take‐Off Point. Remove the "if fitted" qualification at Transponder Usage, these planes should all have their transponders on when flying, mufflers and silencers would be a godsend.. Cease twin engine aircraft to not undertake flight training from Kempsey Airport. The FNA only appears to relate to AIAC, what about the concerns of the other operators that use this airport. Failure to emphathise that flight training operators should amend their Standard Operating Procedures to highlight and reinforce the FNA requirements. It should be that instructors and students understand the importance of the FNA requirements and that they need to comply with them. Actually have a conscience about there behaviour and the impact on others when they are flying. There appears to be one obvious measure of complaints relating to flight training operations is missing. There is no measure of complaints relating specifically to circuit training activity. This must be recorded and reported as a percentage of total complaints. Yours sincerely

28/11/2019

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I experience the impact of flight training at my house daily, I maybe also termed a noise sensitive 'facility' according to the FNA when in actual fact this is a residence. There are other 'facilities' in this area, houses, schools, nursing home with people in them that are affected by this.. Please amend the FNA to indicate how many aircraft a training operator may have in the circuit at one time. A maximum of 2 training aircraft in the circuit at one time. Qualifications applied to some important noise mitigation measures implies that it is OK to ignore these measures: Remove the "Where practicable" qualification at Simulated Engine Failure Practice, this must not be done at the airport or over houses near the airport, it should be done over the intermediate training area at east of Kempsey. . Remove the "Where Practicable" qualification and the word 'encouraged' at Take‐Off Point. Remove the "if fitted" qualification at Transponder Usage, these planes should all have their transponders on when flying, mufflers and silencers would be a godsend.. Cease twin engine aircraft to not undertake flight training from Kempsey Airport. Lack of clarity as to what flying activity is allowable below 1,000 feet. The standard circuit height of 1000 feet includes the statement 'with the exception of those aircraft that operate at circuit heights lower that 1000 feet. Please state what those exceptions are and list them so that we know. The FNA only appears to relate to AIAC, what about the concerns of the other operators that use this airport. Failure to emphathise that flight training operators should amend their Standard Operating Procedures to highlight and reinforce the FNA requirements. It should be that instructors and students understand the importance of the FNA requirements and that they need to comply with them. Actually have a conscience about there behaviour and the impact on others when they are flying. There appears to be one obvious measure of complaints relating to flight training operations is missing. There is no measure of complaints relating specifically to circuit training activity. This must be recorded and reported as a percentage of total complaints. Yours sincerely 28/11/2019

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From:Sent: Thursday, 28 November 2019 2:10 PMTo: Kempsey Shire CouncilSubject: SUBMISSION: DRAFT FNA 2019

The Director Corporate Kempsey Shire Council PO Box 3078 West Kempsey NSW 2440 28 November 2019 Dear Mr. Mitchell SUBMISSION: KEMPSEY AIRPORT DRAFT FNA 2019 1. CIRCUIT HEIGHT ISSUES AND WHAT ARE EXCEPTIONS? Page 4,1.8.1 Standard Circuit Heights “At KPS, all aircraft conducting circuits are required to climb to 1,000 feet above the aerodrome elevation prior to making a turn onto cross-wind (with the exception of those aircraft that operate at circuit heights lower than 1,000 feet).” 1.1 How can circuit aircraft operate at lower than 1000feet “with exception”, and “Circuits below 500 feet AGL are not permitted?”. 1.2 “Exceptions are not defined or listed. These must be elucidated. The public as proponents are entitled to know what is happening above them. 2. CONFUSION ABOUT WHAT IS PERMITTED OR NOT. LOOK AT THE DEFINITION Page 4 Low Level Circuits “Circuits below 500 feet AGL are not permitted”. “Not permitted” implies being “enforceable” and contradicts “…is not enforceable and is a measure of goodwill” on Page1. KSC, please look up the definition of “not permitted” and reconsider your message you wish to convey when this FNA is “not enforceable”. Make up your mind to either use Airservices Australia FNA definition and remove the “not permitted” bits or call the document something else to include “not permitted” and enforce the rules. 3. EFATO’s TO BE DONE EAST OF KEMPSEY AS PER CASA Page 5, 1.8.2 Simulated engine failure practice “Where practicable, EFATOs should not be performed over Noise Sensitive Areas surrounding KPS.” TAG stated: “The practice Engine Failure After Take-Off (EFATO) is an essential part of a pilots training…during the climb after takeoff”. 3.1 This NNA does not mention the CASA designated area east of Kempsey for EFATO’s 3.1 This statement must be rewritten: EFATOs are NOT PERMITTED over “Noise Sensitive Areas surrounding KPS” and would contradict the “not enforceable” assertion as well. This FNA would therefore NOT be entirely voluntary and this point must be enforceable. 3.2 The EFATO procedure is entirely by aircraft operator choice. The instructor can choose to do this elsewhere. 3.3 Any ascending take off upwind leg flight path involving a EFAOT would always involve noise sensitive areas and must be banned. 3.4 That is one reason why high intensity circuit training is not appropriate for Kempsey Airport. 4. TRANSPONDERS MUST BE FITTED AND TURNED ON, MANDATORY. Page 5 1.8.2 Transponder Usage The statement: “If fitted to aircraft, transponders are to be turned on and operated in accordance with CAAP 166-01 V4.2 for all operations.” Should read: “All aircraft must have transponders fitted and turned on”.

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This must be mandatory, not an option, rules to be enforced thus contradict the “voluntary”. 5. AIAC MAINTAINS AIR SUPERIORITY AS USUAL WHILE KSC ENFORCES THE UNENFORCEABLE KSC Business Paper for 28 Nov 2019 meeting File F19/1945 QON1 page 37: “Furthermore, it should be noted that compliance with the FNA will be a condition within any new airport hangar/terminal lease and/or conditions of use agreement and therefore will be enforceable through this mechanism”. 5.1 Please explain the expected efficacy and details of the above “mechanism” to do the enforcing with a possible future operator arrangement while doing nothing about AIAC performance in the present. 5.2 Agreements have not worked in the past. AIAC has a bad history of well-known documented agreement breaches. AIAC will continue to do so and this agreement is useless without enforcement and penalties, while KSC looks in another direction. 6. DEPARTING AIRCRAFT MAKE MORE NOISE THAN LANDING. LANDING GETS MORE ATTENTION Page 4, 1.8.1 Circuit Operations (All operators) Departing aircraft on takeoff upwind leg flight path make much more noise over sensitive areas than approach to land. Departures should turn away from noise sensitive areas ASAP instead of maintaining direction over noise sensitive areas e.g. Aldavilla school, until 1000 feet before turn. Emphasis must be placed on this rather than the approach process which receives more attention as described in first paragraph Page 3. 7. POPULOUS AREAS ARE NOT DEFINED As defined by CASA, populous areas (which are noise sensitive) are not listed or displayed on the map in this draft FNA. The definition of a “populous area” and where populous areas are must be stated for all to understand. 8. NO AIAC TWIN ENGINE TRAINING AIRCRAFT! AIAC had spaces for twin engine aircraft parking in DA T6-16-444. AIAC maintained that it will “only be using DA-40 aircraft”. AIAC lied and cannot be trusted. KSC approved this DA and ignored the planned presence of these parking spaces. KSC cannot be trusted. 9. COMPLAINTS SYSTEM NOT ADEQUATE Page 8, 1.10 Means of Monitoring the Adherence to Principles 9.1 There is no written intent to separate circuit training incidents from other operations which must be treated separately. 9.2 Incident details must be publicly available and not just left with KSC. 9.3 The complainant must receive feedback regarding progress and resolution of the complaint. This is necessary so that the complainant knows that something has been done and what that is. 10. OPERATORS USING KEMPSEY AIRPORT ARE NOT INSTRUCTED TO AMMEND THEIR SOP’s FOR THIS AIRPORT Page 37, Operating Procedures Please address this anomaly so all operators know the rules. 11. REMOVE ALL THE WORDS “ENCOURAGE”, “WHERE PRACTICABLE” AND “SHOULD” FROM THE TEXT. Amend with e.g., must, duty, obligate, compulsory, required, binding, so there is no other option, apart from safety issues. 12. SAFETY ISSUES Other operators have safety issues with AIAC high intensity circuit training monopoly. Their safety issues are not discussed, the public have a right to know what risks may occur from above. Please oblige. 13. CIRCUIT TRAINING NUMBER AT ANY TIME IS NOT STATED Page 7 Number of Aircraft in a Circuit “Investigations into limiting the number of aircraft in a circuit at any given time may be conducted in future at the discretion of KSC and may form part of future updates to the FNA”. Number limit must be stated in this FNA now. It is not good enough to think about the matter sometime “in future”. Please address this and state only two at a time. 14. WE HAVE MORE NOISE BECAUSE THIS FNA ALLOWS INCREASED CIRCUIT TRAINING HOURS

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Page 7. “Hours of Operation Circuit training, as part of flight training operations, should only be conducted between the following hours”. 15. AIAC IS A VISITING OPERATOR, NOT A LOCAL OPERATOR Page iii “These Principles are based on Council resolution”1. Page 7 1.8.3 “The following Principles relate only to aircraft operating as part of a flight training school, including both local and visiting operators5.” KSC stated in the 25 June 2019 Business Paper second paragraph, page 11: “…and home to AIAC”. The only conclusion that can “reasonably” (Thank you for the quote, KSC.) be made is that this is a lie calculated to deceive the public into thinking that AIAC is a “local operator” (as a lessee of the KSC owned airport building) BUT: AIAC is not publicly regarded as a member of our community. There are no commodities, goods, products or services on offer. AIAC is not a franchise or a corporate branch within the shire that the public may relate to. There is no ‘shop front’ for the public. AIAC does not own an asset in Kempsey shire to harvest any value from. AIAC leases the KSC owned airport building for its own self-interest. AIAC activity/operations use the above airspace, where KSC has no control, to train its own foreign pilots. AIAC does not provide any recreational activity and “valuable economic contribution” has not yet been determined. AIAC is a foreign owned company that operates from a base in a different local government area, its web site shows “Australia's leading flight training organisation, based in Port Macquarie, NSW”’, a sign attached to the airport building shows only a phone number and web address. Public access is not available. Discussion at the 25 June meeting referred to benefitting local grown enterprise and written in the Business Paper as “local aircraft operators potentially provide a valuable economic contribution, service or recreational activity…”, but then is twisted to favour AIAC, the chosen one with unlimited resource and influence. KSC has a deep cosy relationship embedded in well documented earlier history of the relationship, hence the lie “home to AIAC”. This apparently deliberate bias is unfair to any local operator and fails the ‘pub test’. Admit that it “is reasonable” for AIAC NOT to be viewed as local. So, give a fair go for AIAC to have a go. Good one KSC. How good is that! Yeah. Yours faithfully

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From:Sent: Thursday, 28 November 2019 8:53 PMTo: Kempsey Shire CouncilSubject: AIAC Complaint

Dear General Manager,

I am writing in relation to the 'Fly Neighbourly Agreement'. I feel I must air a few points to you and 98% of the elected council members.

Firstly I was absolutely disgusted when during the recent fire emergency the AIAC was operating in the hazardous, smokey conditions. The helicopter and plane fire bombers should have been given top priority and should not have had to compete for air space.

Secondly, Kempsey Airport is totally unsuitable for commercial flight training operations. Flight paths and the subsequent noise over residential properties, schools, aged care facilities make a peaceful quality of life near impossible.The fact that council now makes property owners who are selling notify future tenants that they are within a 5km radius of the airport speaks volumes about the existing noise levels that we all have to endure.

The 'Fly Neighbourly Agreement' seems very hollow to me. This agreement does not take into account the amount of noise that residents have to put up with. It does not include any practical ways to reduce circuit training noise. I can not see how this agreement manages noise and have witnessed AIAC on many occasions disregard any neighbourly flying. We residents are still subjected to repetitive circuit training for hours and days on end. Schools and Age Care Residencies are noise sensitive areas and I am not sure that AIAC even considers the impact they are having when constantly overflying these facilities. The FNA should outline the CASA regulations about not flying below 1000 feet when flying over populous areas.

The 'Fly Neighbourly Agreement', at no time mentions anything about the number of training aircraft in a circuit at any one time. I find this a very dangerous omission for all involved.

In conclusion, I would like my complaint related to the existing flight training operations to be considered, recorded and reported with any other complaints that you receive. Every piece of correspondence you receive should be considered individually and not just reported as one collective response.

Yours Sincerely

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From:Sent: Monday, 28 October 2019 7:50 PMTo: Kempsey Shire CouncilSubject: Kempsey Airport Fly Neighbourly Advice

I am writing to voice my opposition to the Kempsey Airport Fly Neighbourly Advice currently open for comment. Reasons are as follows:‐

1/

The Fly Neighbourly Advice (previously ‘Fly Neighbourly Agreement’) is not enforceable therefore useless in enforcing non compliant flying and airport usage. If those abusers cannot be penalised then there really is nothing to stop un‐neighbourly activity.

2/

Consultation process was biased toward airport users and not a fair consultation from the community that are affected by the increased airport usage.

3/

Intention of the FNA which may minimise noise impacts originating from operations at the Airport is unacceptable, it should without doubt minimise any impact.

4/

Proponents should exclude Flight Training schools in particular to those that train pilots for foreign usage.

5/

Noise Sensitive Areas …..I consider it insulting that KSC does not consider its residents within the airport vicinity as not being a part of a Noise Sensitive Area.

All Homes, Colleges, Schools, Care Facilities should have utmost consideration.

6/

Aviation Operators and Circuit Operations can increase their flying height even more and also head straight to sea to avoid inconvenience to community and spend more time in areas that are not considered as problematic.

7/

Hours of Operation as advised in this FNA is totally unacceptable. Rate payers reside, eat, sleep and have recreational activities within the region of this rural aerodrome. Restricted day time use and a compromise of 2 later evenings per week with no commercial student activity during public holidays.

8/ Operation hours should reflect consideration for community as flyers (in the main) do not require flying at odd hours. Landing hours are different as you cannot refuse landing permissions. Students training can be restricted to daylight hours excepting those night flights twice a week as mentioned earlier.

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9/

All noise levels should be kept within the limits stated by the EPA guidelines and therefore enforced by KSC.

10/

Dangerous flying maneuvers such as low level circuits, simulated engine failure etc should be banned completely and only be conducted in safe environments such as out to sea.

Submission by re: Draft Fly Neighbourly Advice (FNA) for Kempsey Regional Airport

1. The FNA is inadequate. The Noise Management Plan (NMP) and ERSA entries approved byCouncil in June 2019 did not contain any practical ways to reduce circuit training noise and lowflying activity which remains the key concern of residents. It is essential that the FNA corrects thisomission.

2. The FNA is a voluntary code of practice and unenforceable so it is imperative that Kempsey ShireCouncil insists on full compliance as a condition of any future airport hangar/terminal lease and/orconditions of use agreement. Hopefully this mechanism will give the FNA, along with the NMPand ERSA entries, the necessary ‘teeth’ though it is concerning that it will not ensure complianceby those operating outside such contractual arrangements.

3. However the above anomaly means that commercial flight training operators who not covered bysuch contractual arrangements (but still using Kempsey Airport for Visual Flight Rule training and‘touch and goes’) are not obliged to consider the FNA and NMP. It is essential therefore thatCouncil develop and implement additional constraints to limit the impact of flight trainingoperations on the amenity, wellbeing and safety of residents living in the vicinity of the airport.

4. It is evident that the Operational Summary at the front of the FNA is specifically targeted at pilots

in its style and language. However this focus continues into the main body of the FNA which

places the ‘aviation’ community and its mindset at the forefront with minimal reference to

impacted residents. This imbalance is concerning noting that the purpose of any FNA is to make

aircraft operators consider the wellbeing of residents and other stakeholders. The final FNA

needs to place greater emphasis on the needs of residents to ensure flight training students and

their instructors fully understand the negative impact of their activities.

5. Marking three noise sensitive ‘facilities’ in line with the runway as the only noise sensitive ‘areas’

is also unacceptable. The impact of circuit training noise extends far beyond three dot points on a

map (It is also astonishing that the creator of this map also decided to isolate each of the three

sites - which are in close proximity to each other - separately rather than enclose them in the one

zone!) Other areas identified in TAG’s NMP as being subject to intrusive training aircraft noise

have been excluded from the FNA and these should be identified.

6. In particular, the CASA definition of ‘populous areas’ must be included in the main body of the

FNA and such areas clearly marked on associated figures and maps - it is worth noting that the

greatly expanded Mid North Coast Correctional Facility at Aldavilla, which is a direct neighbour of

the Airport, will accommodate more than 1000 inmates as well as hundreds of staff within its

perimeter and by definition could be classed as a ‘populous area’ albeit with unique security and

safety considerations as well.

7. Some of the noise mitigation measures that have been included in the FNA contain unacceptable

qualifications. ‘Weasel words’ such as ‘where practicable’ and ‘if fitted’ must be removed as the

onus must remain on the aircraft operator (of single and twin engined aircraft) to ensure these

measures are in place and repeated failure to do so should constitute a breach of conditions of

use.

8. At the time of writing - Wednesday 27 November 2019 - AIAC has three DA40s in the air

conducting multiple low altitude circuits. These aircraft, registrations VH-YPN, VH-YPJ and VH-

YPF, are both noisy and instrusive on residents and school students under their shadow. It is

therefore very concerning that the FNA does not include any limit on the number of aircraft

permitted in the flight training circuit at one time. This is an essential requirement in order to

reduce the repetitive Doppler effect resulting in a people being subject to constant but fluctuating

noise. Other airports have limits on the number of training aircraft in the circuit at one time. A limit

of two training aircraft for any flight training school should be imposed at Kempsey Airport along

with strict operating hours for both visiting and non- visiting aircraft. (ends)

(signed) (dated) Wed 27 Nov. 2019 21:07

from: saveour airport sent: friday, 22 november 2019 2:02 ...€¦ · should reference figure 1,...

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