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Lack of transparency

The MDP avoids full disclosure on a number of issues, including total induced flight emissions, climate risks to airport operations, competitor risks to airport growth forecasts, and public engagement.
What the Third Runway Major Development Plan does disclose on these issues is included in Part A – The Project, specifically, Chapter A2: Need for the project and Chapter A6: Stakeholder engagement, in Part B – Airport, specifically, Chapter B5: EcologyChapter B11: Greenhouse gas emissions, and Chapter B13 Climate change and natural hazard risk, and in Part E – Management framework, specifically, Chapter E3: Offset management strategy and Chapter E5: Risk management.


Total induced flight emissions

The MDP under-reports global warming caused by the GHG emissions that the Third Runway enables.

The Third Runway preliminary draft Major Development Plan:

• Excludes an assessment of total flight emissions. It says “Full flight emissions from aircraft … have been excluded from the assessment of operational emissions” (see B11.4.4) and “GHG emissions associated with the airspace are largely out of Melbourne Airport’s control” (see B11.4.1)

If we accept this denial of complicity, we are accepting that any enabler of an acknowledged harm is not responsible for that harm. A drug dealer is not responsible for the harm caused to the drug user. No more plaudits for Border Force drug busts!

• Excludes emissions other than direct CO2 emissions. The MDP says that outputs from the Aviation Environmental Design Tool exclude emissions other than direct CO2 emissions (see B11.4.6.2 Aircraft Landing take-off cycle). These excluded emissions contribute twice as much warming as CO2 alone (1).

Ignores a Major Impact Severity assessment for the Third Runway. The GHG emissions increase from the operation of the Third Runway will be around 16,000 kilotonnes in 2046 (see Too warming footnote 10), or 2.7% of Australia’s total annual GHG emissions. Yet the MDP says a GHG emissions increase from the operation of the Third Runway that is greater than 0.1% of Australia’s total annual GHG emissions (excluding LULLUCF) would be a Major Impact “and a significant and irrecoverable estimated financial liability”, and a “financial liability [that could] include capital costs [and] negative reputation and media attention globally, with follow on effects including political implications, [with a probability that the] project is significantly delayed or cancelled” (see MDP Severity criteria  Table B11.1). 

Climate risks to Airport operations

• The MDP avoids full disclosure of the climate risks of the IPCC RCP8.5 scenario. The MDP assessed climate risks to the operation of the Third Runway under the RCP8.5 scenario (see B13, Climate Change and Natural Hazard Risk). RCP8.5 is a high-emission, business-as-usual scenario leading to a catastrophic atmospheric CO2 concentration of 940ppm by 2100, pushing global heating way past the end-of-society-as-we-know-it Hothouse earth of +4ºC (2). Yet, extraordinarily, the MDP concludes that “Climate change is unlikely to create new risks for the operation of M3R” (see B13.6.1.2). And its “assessment shows that none of the risks from climate change or natural hazards is rated as high or extreme, and that no impacts are rated as major adverse” (see B13.6.2). It assesses there to be no potential impacts from the IPCC RCP8.5 scenario that “have been found to represent significant or high risks to the operation of the airport.”

• A specific example of this disclosure avoidance is the MDPs risk assessment for high temperatures. It assesses the Risk Event of “high temperatures leading to lower air density, reducing aerodynamic lift and jet engine power output enough to prevent takeoff” in 2070 for RCP8.5 as Medium Level, having Moderate consequences, and as probably not likely! (see Table B13.26) Yet this event is already being experienced around the world at 1.1ºC of warming (3).

• The Melbourne Airport Corporation, and its shareholders, are in breach of their acknowledged duty to disclose climate risk. The MDP fails to include a full and honest assessment of low probability events that have existential consequences, such as a high-emissions, business-as usual-scenario. 

Competitor risks to Airport growth forecasts

• High speed rail ignored. The MDP excludes any assessment of the risk to the airport’s business growth forecasts from the development of a high speed rail service up the east coast from Melbourne to Sydney and Brisbane. This is irresponsible given that establishing a High Speed Rail Authority is federal Labor policy (4). 

Environment assessment transparency

• No Environmental Impact Statement. The potential environmental impact of a new runway anywhere is huge, yet an Environment Impact Statement for Melbourne’s new north-south (or 3rd) runway was not undertaken by the Department of Agriculture, Water and the Environment (AWE), on 2 March 2021, after the exposure draft of the Major Development Plan (MDP) for a Third Runway was referred to them by the Department of Infrastructure, Transport, Regional Services and Communications (ITRSC). The environment department of AWE deferred to Section 160 of the Environment Protection and Biodiversity Conservation Act (EPBC 2021/8886). Section 160 provides an accredited referrals and approvals pathway for developments regulated by the Commonwealth under, in this case, the Airports Act, like the 3rd runway that, require an approved Major Development Plan. Under this pathway, any environmental assessment is done by the development proponent, in this case Melbourne Airport. The draft MDP, that includes this self-assessment of environmental impacts, is submitted by Melbourne Airport to the transport department of ITRSC for ministerial approval (after the public consultation process is completed). At this stage ITRSC is required to seek only the environment department’s advice on the draft MDP, as the environment department and environment minister have no approval role. Approval powers rest solely with the transport minister.

• Transparency of the manner and extent to which the environment impacts are addressed is dramatically lessened when, under the MDP process, only the matters listed under Section 91 of the Airports Act are to be self-assessed by the proponent. An independent, fully resourced and transparent assessment is avoided for environmental characteristics and impacts, including the effects of the 3rd runway on communities and the ‘environment’ in its broadest sense, for example, in relation to noise, air quality, airport hazards and risk, public health, economic and social/community issues.

Reliance on Section 91 prevents the public from knowing what exactly is being assessed over what time period and by what method, the level and detail of analysis and modelling that is undertaken, the alternatives to the 3rd runway, and the full suite of possible options for managing environmental impacts. It also creates uncertainty about the public availability of detailed technical studies that would normally be appended to an EIS.

• Melbourne Airport responsible environmental management concerns. In 2019, PFAS escaped the airport estate, contaminating waterways that feed into the Maribyrnong River. The community have been unable to find out who paid for the clean-up, what it cost, or how much contamination there is on the land in the Keilor Valley south of the airport.

Public engagement

• Proper process ignored. This is the first time an Australian airport released a Master Plan (MP) and a Major Development Plan (MDP) for public comment concurrently. Previously, and logically, each 5 year MP has been released, assessed and approved before any subsidiary MDPs is released, as was the case for Sydney, Brisbane and Perth airport Master Plans and runway MDPs. If a flaw in the MP is revealed during its public assessment that alters aspects of any proposed works later requiring an MDP, then a simultaneously released MDP will be automatically out of date and need updating prior to its publication for public assessment.

The public consultation periods managed by Australia Pacific Airports (Melbourne) (APAM) for its preliminary draft Melbourne Airport 2022 Master Plan (MP) and its preliminary draft Third Runway Major Development Plan (M3R MDP) were not of 60 days as specified in the Airports Act 1996, sections 79 (1A)(1)(iiia)(iv) & 92 (1A)(2A)(a)(b).

The public consultation period for the preliminary draft MP and the current draft M3R MDP was a total of 72 business days. As such those wishing to provide feedback to the current draft M3R MDP were not given sufficient time — the required business days as specified in the Act — to adequately address their concerns about all heath, noise, amenity and environment impacts in their submissions.

The are no provisions within the Airports Act 1996 which approves running public comment periods concurrently for airport master plans and airport major development plans.

• Lack of time. In effect the public were given the correct 60 days to assess the MP and a subsequent 12 days to assess the M3R MDP, in breach of the Act.  


• A brutally honest, comprehensive and independent climate risk assessment is needed

• A broad competitor risk assessment must be undertaken

• An EIS is needed to independently assess how the Third Runway will impact total flight emissions and endangered woodland. See the Petition calling for these. 

• A Health Impacts Statement is needed to independently assess how the Third Runway will impact the health of those living under the new flight path. See the Petition calling for these.

• An Educational Impacts Statement is needed to independently assess how the Third Runway will impact the education and future prospects of children living or attending school under the new flight path. See the Petition calling for these.

• Delay presentation of the MDP to the federal transport minister until these transparent risk assessments are completed and open to public scrutiny.