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Draft objections

Feel free to cut and paste from either set of objections below, in adding to your objection.  

I object to the development of a Third Runway on the following grounds.

Too noisy: Air transport has an impact on communities that may be more significant than we appreciate. Aircraft noise is not merely irritating. It is damaging to health, wellbeing, learning and cognitive function. In Australia, communities are subjected to levels of aircraft noise well beyond WHO recommendations and have no legal protection against it. There are no limits to the loudness or number of incidents around Melbourne Airport at any time of the day or night — no caps, no curfew — and no compensation is available to residents who are affected by aircraft noise.

Way too warming: The proposed Third Runway will contribute to increasing global heating emissions, right when we’re in a climate emergency and must rapidly reduce emissions across society.

Loss of woodlands: The proposed Third Runway will destroy endangered woodland, and any proposed compensating offsets are likely to be  ineffective.

Dodgy economics: Multiple costs are unaddressed by the Third Runway MDP. It overstates the benefits. Its flight demand assessment is delusional. And increasing emissions doesn’t align with investor sentiment.

Lack of transparency: The MDP avoids full disclosure on a number of issues. These include: under-reporting global warming caused by the GHG emissions that the Third Runway will enable; under reporting the impact severity of those emissions; ignoring competitor risks to airport passenger growth forecasts such as high speed rail; and requiring, for the first time, simultaneous approval of an airport Master Plan and a Major Development Plan.

I object to the development of a Third Runway on the following grounds.

These grounds relate specifically to Part B, Chapter B11: Greenhouse gas emissions of the Third Runway Major Development Plan.  

1. In the middle of the climate emergency we must rapidly reduce emissions across society. The IEA says we must stop developing new emissions sources. Governments around the world agree we should avoid more than 1.5ºC of warming, now inevitable from emissions to date. Our own federal government says it is aiming for emissions cuts of 26-28% by 2030, and most Australians are calling for more significant cuts. Climate Action 100+, the world’s largest investor led initiative on climate change, says that growth in air travel needs to be curtailed by keeping business travel to 2019 levels, capping long-haul flights of more than 6 hours for leisure reasons at 2019 levels, and shifting demand to high-speed rail infrastructure where possible. Lord Deben, the chair of the UK Climate Change Committee, which advises government, said in January 2022: “There is not any space for airport expansion.”  

2. The Third Runway will contribute to increasing global heating emissions, specifically total annual warming in 2046 from Third Runway flights will be around 16 million tonnes CO2-e — comparable to the 18 million tonnes CO2-e total annual warming currently from Australia’s dirtiest power station, AGL Energy Limited’s Loy Yang. This 55% increase in Melbourne Airport flight emissions is roughly 50 times the CO2-e acknowledged by Melbourne Airport: 0.348 million tonnes, excluding construction emissions of 422,094 t CO2-e. 

3. Third Runway enabled flights are the most emissions intensive form of transport, per kilometre and per hour. They will not be emissions free. Electric aircraft, for flights under 1,000 km, may be in service by 2050, but they won’t be emissions free until the electric grid is fully decarbonised. Alternative aviation fuels are not emissions free and emissions free flight is not possible in the near term. An offsetting flight emissions does not reduce emissions.

4. 1.5ºC of warming is now likely by 2030. And 2ºC of warming is now likely before 2050. Right now the Great Barrier Reef is in its death spiral and other tipping points to unstoppable warming are at hand. Just as we observe Total Fire Bans to minimise bushfire emergencies during fire season, so we must observe Total Runway Expansion Bans to minimise global heating during the climate emergency.  

5. As such, I demand that: the proposed Third Runway be halted because the impact of increasing global heating emissions is existential to society as we know it; and, an independent Environment Impact Assessment of the increased global heating emissions, be completed. 

How to object

Clicking the “Object here” button below takes you to the Melbourne Airport MDP Feedback form, where you can submit your objections.

Detailed objecting

You can provide detailed objections to any or all of the chapters of the MDP. See our advice here.

Third Runway Major Development Plan

Australia Pacific Airports (Melbourne) Pty Ltd (APAM) has prepared a Major Development Plan (MDP) as part of the assessment and approval process necessary to develop a Third Runway at Melbourne Airport.

Members of the public have until Monday 16 May 2022 to submit responses, objections and feedback to the Plan. The Plan is now at Step 2 of the approvals process illustrated below. Details of the subsequent steps are included in the What happens after public exhibition? Fact sheet.

If you have questions, for the Melbourne Airport Corporation, about the MDP, that you need answered before submitting your objection, you can  Ask a Question at
https://caportal.com.au/melair/virtual?hview=modalAskaQuestionM3R

The No 3rd Tulla Runway coalition is objecting to a Third Runway because of the various harms it creates. These include debilitating noise levels, growing greenhouse gas emissions, loss of endangered habitat, and a lack of public disclosure.

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