aa nos env 2.100 16 Redacted.pdf

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Environmental Management of Changes to
Aircraft Operations
Standard
AA-NOS-ENV2.100
Version 16
Effective 08 March 2022

Prepared:
s47F

Senior Environmental Specialist
Endorsed:
Environment & Sustainability - s47F

Approved:
Chief Safety & Risk Officer - s47F

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1
Purpose
The purpose of this Standard is to prescribe the requirements for environmental impact
assessment (EIA), social impact analysis (SIA) and community engagement that must
be met, prior to implementing changes to aircraft operations.
These activities shall be collectively referred to as environmental change management
within this document
2
Scope
This Standard applies to all proposed changes to air traffic management practices
(proposals) that may involve a change to aircraft operations.
Proposals include, but are not limited to, the following changes:
  new, or amendment to an existing, instrument approach;
  new, or amendment to an existing, flight path or air route;
  re-classification of airspace;
  change to preferred runways;
  change in time of day of operation (e.g. amendments to tower hours of operation
– the time of day that a tower operates may alter the flight path used by aircraft);
  change that allows use of a flight path/airspace by a different type or quantity of
aircraft.
Note:
A tactical decision of an air traffic controller to alter the track of an individual
aircraft does not constitute a proposal.
2.1
Out of Scope
This Standard does not necessarily apply to other business revenue (OBR) work
undertaken by Airservices. For OBR work, an approach shall be determined by the
Chief Service Delivery Officer, to assess the potential application of the Environmental
Protection and Biodiversity Conservation Act 1999, and the potential environmental
impact of the work.
Refer to Appendix A for applicable changes and Appendix C for further information
regarding OBR work.
3
Objectives of environmental change management
Recognising that safety is our most important consideration, the main objectives of
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environmental change management for aircraft operations are to:
1.
meet our legislative obligations to:
a.
avoid ‘significant’ environmental impacts resulting from any Airservices
action, and ensure appropriate regulatory consideration and impact
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assessment, as required under the Environmental Protection and
Biodiversity Conservation Act 1999 (the EPBC Act).
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b.
ensure air traffic management practices are conducted in a manner that
protects the environment, as far as is practicable, as required under the
Airservices Act 1995;
c.
meet applicable Ministerial Directions relating to aircraft noise management;
2.
minimise our business risks by maintaining effective community engagement and
sound corporate citizenship in aircraft noise management;
3.
provide a standardised and rigorous approach to assessing the impacts of
changes to aircraft operations, as a demonstration of organisational due diligence
in environmental management (in compliance with the requirements of our
Environmental Management System (EMS) - as described in
AA-NOS-ENV-0001);
4.
assist in achieving organisational environmental, sustainability and community
management commitments (as described in our Environmental Policy
C-POL0030);
5.
assist in achieving efficiency outcomes for our customers, through improved flight
paths and associated reductions in fuel costs and emissions.
4
Principles and mandatory requirements
4.1
Change process collaboration
Environmental change management is a collaborative process involving impact
assessment (environmental, social and reputational); risk assessment and
management; and community engagement.
These management elements shall be conducted collaboratively and concurrently by
relevant parties throughout the change lifecycle, such that flight paths are designed and
implemented in a manner that minimises environmental and community impacts to the
greatest extent practicable.
4.2
Requirements for all proposals
All proposed changes to our air traffic management practices that may affect aircraft
operations shall:
1.
be undertaken in accordance with this Standard and subordinate procedures,
while being commensurate and scalable to the complexity of the change;
2.
be assessed for environmental and social impacts prior to implementation
3.
be designed to avoid environmental and social impacts to the greatest extent
practicable (whilst prioritising operational safety);
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4.
involve community engagement prior to the final decision, where potential social
or environmental impacts are identified;
5.
be reassessed1 prior to implementation, if the proposal has already been impact
assessed in accordance with this Standard and:
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a.
has subsequently been substantially modified or;
b.
over 24 months has elapsed since the original assessment.

1 ‘Re-assessment’ is scalable depending on the extent of the given variation to the change, and may only consist of validation of original
inputs and assumptions.
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6.
seek to achieve an outcome that balances the needs of the environment,
community and aviation industry stakeholders.
4.3
Information systems
The Corporate Integrated Reporting and Risk Information System (CIRRIS)
Management of Change (MOC) module must be used to record case workflows and due
diligence activities associated with a change proposal.
The Environment & Sustainability Principal Advisor is accountable for ensuring that
CIRRIS accurately codifies the screening and assessment criteria and logic described
at Appendix A of this Standard.
If CIRRIS functionality is unavailable, the Accountable CSDO Manager shall ensure that
change proposals are documented in a manner that conforms to the criteria and
process steps outlined in this Standard.
4.4
Proposals with potential ‘significant impact’
Wherever practicable, Airservices shall seek to avoid changes with the potential to
result in ‘significant impact’ to the environment, as defined under the EPBC Act.
Where avoidance of potentially significant impact is not practicable (e.g. due to a clear
safety imperative), the Chief Service Delivery Officer shall seek advice from the
Commonwealth Environment Portfolio Minister (the Environment Minister), in
accordance with Sections 28 and 160 of the EPBC Act, prior to implementing the
change. Refer to Section 6.3 for further information regarding advice and assessment
requirements under the EPBC Act.
4.5
Development of procedures
Airservices business groups with accountabilities for planning and implementing
changes to aircraft operations shall develop procedures and other supporting
documents that describe:
  the internal business processes required to enact the requirements of this
Standard (including interactions with other business groups and external
stakeholders);
  the relevant methodologies for undertaking environmental impact assessments,
social impact analyses and community engagement (as required by this
Standard), and how they will collaboratively inform flight path design.

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5
Accountabilities
5.1
Overall change implementation
The following abbreviations for accountable personnel are used throughout this
standard:
CEO:    Chief Executive Officer
CSDO:  Chief Service Delivery Officer
CCXO:  Chief Customer Experience Officer
CSRO:  Chief Safety & Risk Officer
The CSDO group holds ultimate accountability for ensuring that no change proposal is
implemented without completion of the appropriate environmental change management
requirements, in accordance with this Standard.
In practice this means:
  managing the change process to ensure that all assessment and management
elements are completed and approved by relevant managers;
  accepting or rejecting risk assessments produced during the environmental
change management process (in accordance with the Risk Management
Standard AA-NOS-RISK-0001, and the Environmental Risk Management
Procedure ENV-PROC-0004);
  approving implementation of the change once all environmental change
management requirements (as described in this Standard and any change
specific plans) have been met.
The Accountable CSDO Manager is the point of accountability for the overall
success of a change. The Accountable CSDO Manager is either:
  the Head accountable for the operations to which the change pertains; or
  the Chief Service Delivery Officer (if the proposed change represents a risk in
the ‘High’ risk class (in accordance with AA-NOS-RISK-0001) as indicated by the
environmental or social impact analysis and/or the airport risk rating2).
Environmental change management shall be integrated with the overall change
governance framework.  Accountable managers from all business groups involved in
the change process must be informed of potential environmental and community
risks and benefits from a proposed change at relevant decision points throughout the
change lifecycle3; including the design and initial proposal stage.  Refer to ATS-
PROC-0147 Airspace Change Process Procedure.
The CEO holds the ultimate approval authority for change implementation.  The
airspace change governance process must ensure that the CEO is kept informed of the
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change program and of any high risk changes prior to implementation.
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2 To enable this, CSDO group shall maintain a risk in CIRRIS which describes ongoing environmental risks associated with noise
management at specific Airports, in addition to assessing the risk of the particular change.
3 ATS-PROC-0147 establishes the Airspace Governance Panel (AGP) which meets the intention of this requirement.
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6
Environmental change management elements
There are five elements to environmental change management for airspace and/or flight
paths, as follows4:
1.  Environmental Change Screening (ECS)
2.  Environmental Impact Assessment (EIA)
3.  Advice and assessment under the EPBC Act (where required)
4.  Social Impact Analysis (SIA) and community engagement
5.  Risk Assessment and Management
These elements are further discussed in the following sections.
6.1
Environmental Change Screening
6.1.1
Purpose and context
Environmental Change Screening (ECS) enables early identification of change
proposals that are highly unlikely to result in any environmental or community impact
and can therefore be progressed without further detailed assessments (unless the
proposal relates to a ‘high’ risk airport – see Table 1 below).
ECS enables the Change Proponent to self-assess proposals against potential
environmental impacts at a high level using defined criteria (included in Appendix A).
6.1.2
Outcomes and Requirements
Table 1 prescribes the outcomes that must be achieved through ECS, as well as the
associated requirements for achieving the outcomes.

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4 After Environmental Change Screening is conducted, these elements may be undertaken concurrently (informing each other) and not
necessarily carried out in the order listed herein.
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c.  identify any benefits resulting from the change or required improvements to
processes and associated documentation.
9
Skills, qualifications, and awareness
Managers accountable for requirements described in this Standard shall:
  ensure that all staff involved in environmental management of proposed changes
have the necessary skills and/or qualifications and/or access to mentoring and
coaching from appropriately experienced personnel to effectively perform their
role;
  implement training and/or education and/or coaching programs to build required
capabilities and experience, as required.
10
Assurance assessments
Managers accountable for requirements described in this Standard shall conduct
periodic assurance assessments to confirm that associated requirements and
obligations are being met.
Additionally, the Chief Safety and Risk Officer (CSRO) Group shall conduct targeted
assurance assessments of key elements of the change management process on a
periodic basis.
On occasion relevant regulatory and/or oversight bodies may conduct assurance
assessments on our application of this Standard.
11
Documentation and recording
All artefacts required to acquit the requirements of this Standard (including EIAs, SIAs,
risk assessments CEPs and CERs) shall:
1.  be maintained on record in accordance with Airservices Records Management
Standard (AA-NOS-GOV-0004);
2.  be attached in CIRRIS (in the relevant Management of Change record);
3.  have key actions recorded in CIRRIS.

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1.2.1 Noise noticeability
Aircraft noise noticeability shall be determined in one of the following two ways, depending on
whether noise modelling is conducted as part of an EIA:
a)
EIA with noise
  50 dB(A) single event noise contours (LAmax) are modelled for
modelling:
urban areas; and 42dB(A) contours are modelled for rural areas,
  Any overflights of NSRs within the above contours are considered
to be ‘noticeable’.
  An area is identified 10km either side of the nominal flight path for
b)
EIA without noise
urban areas (representative of 50dB(A) noise levels), and 20 km29
modelling:
either side of the nominal flight path for rural areas (representative
of 42dB(A) noise levels), up to a maximum distance of 35 nautical
miles (nm) from the relevant runway threshold,
  Any overflights of NSRs within the above areas are considered to
be ‘noticeable’.
Note – where part of an existing procedure remains unchanged under the proposed change, that
part of the design is excluded from noticeability modelling or the other noticeability identification
process described above.
1.2.2 Determining newly overflown NSRs
A NSR is considered to be "newly overflown" if:

  The proposed change has been identified as ‘noticeable’, AND
  The NSR currently experiences negligible existing aircraft noise – i.e. less than one
overflight per day, during the daytime (i.e. 6:00 am – 11:00pm).
1.2.3 Outcomes of noise noticeability and newly overflown assessment
All proposed changes that are identified by the AEA team as being ‘noticeable’ or ‘newly overflown’,
must be communicated to the CE team to assist with effective, targeted community engagement
efforts.
This determination does not affect the outcomes of the ‘potential environmental significance’
assessment (described in Section 1.1 above), which shall be undertaken in all cases (where the
environmental change screening has determined an EIA is required).

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29 Based on a B737 on departure, as per modelled noise levels in AS2021:2015, it has been identified that generally at
2,500m from the centre line of the track (sideline), noise levels will be approximately 60dB(A). This is the maximum
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sideline distance at which 60dB(A) noise levels would be experienced. Based on geometric spreading of noise, it was
calculated that noise levels would be 50dB(A) at around 7,900m sideline and would be 42dB(A) at around 20,000m
sideline. The units of 42dB(A) for rural areas and 50dB(A) for urban areas have been selected as representative of
noticeability of noise, with consideration of state and territory EPA guidelines. See GHD literature review for additional
information. Furthermore, departure noise levels were utilised as overall these are higher than for aircraft on arrival. As
such, distances of 10km for urban and 20km for rural have been used as a conservative measure for noticeability and to
account for any potential variations in aircraft levels
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  70dB (A) is considered to be the external sound level below which no difficulty
with reliable communication from radio, television or conversational speech is
expected in a typical room with windows open;
  60 dB(A) equates to the indoor design guide level of 50 dB(A) specified in
AS2021:2015 Acoustics – Aircraft noise intrusion – Building siting and
construction for sleeping areas (with windows open)
Based on published literature33 a change in the A-weighted noise level is perceived by
the human ear as follows:
  Changes of up to 3dB(A) – not likely to be perceptible.
  Changes between 3dB(A) and 5dB(A) – may be perceptible.
  Changes between 5dB(A) and 10dB(A) – likely to be perceptible.
‘Number Above’ metrics
‘Number Above’ metrics (also known as ‘N Contours’) are an aircraft noise
characterisation mechanism used to map noise ‘zones’ around an aerodrome. They
show the number of noise events per day (or other time period) with LAmax levels above
a specified value.  For example, N70 contours would show the number of aircraft noise
events per day with LAmax greater than 70dB(A). N70 and N60 are particularly useful as
they express the number of noise events per day that may potentially affect listening
activities or sleep respectively, as described above. Use of these metrics was first
documented in the discussion paper ‘Expanding ways to describe and assess aircraft
noise’ produced by the (then) Commonwealth Department of Transport and Regional
Services in March 2000.

These metrics are also useful in assessing the impact of a change in noise exposure,
which may involve a change in the number of events exceeding a given noise level. The
magnitude of the change can be expressed as the percentage change in N60, N70 or
another relevant noise value. For further information refer to:
https://infrastructure.gov.au/aviation/environmental/transparent noise/expanding/4.aspx

Noticeability
The noticeability of a noise depends fundamentally on the relationship between the
highest noise level achieved (LAmax) and the existing background noise level. The
Noticeability methodology was developed with consideration of thresholds from
Australian state and territory regulations for industrial noise. Noise noticeability is
intended to identify NSRs which may notice changes in noise levels and therefore
should be considered for community engagement (even if not considered ‘potentially
significant under the EPBC Act).
b.
Fuel Burn and Emissions
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i.
Following a process outlined in ICAO 201134, which provides information on
common thrust settings and estimates of time-in-mode, and FAA 200035, using a

33 For example, Transport Noise Management Code of Practice – Volume 1 Road Traffic Noise, Queensland Department of Transport
and Main Roads 2013.
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34 ICAO (2011): Airport Air Quality Manual. Doc 9889, First Edition 2011
35 FAA (2000). Consideration of Air Quality Impacts by Airplane Operations at or Above 3000 feet AGL. Federal Aviation Administration,
FAA-AEE-00-01 DTS-34, September 2000.

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height-weighting factor for various stages of flight, it is estimated that the taxiing
of aircraft can account for as much as 90% of ground level emissions (i.e.. the
landing and take-off (LTO) cycle accounts for about 10% of aircraft emissions
during an entire flight). Further, FAA 2000 demonstrates that emissions from
aircraft at 3,000 ft have an impact on ground level pollutant concentrations two
orders of magnitude lower than emissions at 100 ft.
ii.
Aircraft emissions in the LTO cycle below 3,000ft (apart from taxiing emissions)
may have an impact on human health, as per ICAO:
https://www.icao.int/environmental-protection/Pages/local-air-quality.aspx
iii.
At the time of writing, the Australian Government did not have a policy regarding
increases in aviation CO2  emission that could be used for guidance in
establishing criteria for potential significance. Therefore a nominal figure of a
20% increase has been used (per proposed change).
c.
Biodiversity
i.
A recent review of 20 years of international research documenting the effects of
anthropogenic noise on wildlife36, including aircraft noise, has found the following:
o
The range of noise levels reported to induce annoyance in humans and
responses in terrestrial wildlife are similar, ie. 40-100 dB(A).
o
Noise sensitivity varies greatly and there is large variability in responses
to noise between species and individuals and at different locations.
o
Some species are more susceptible to disturbance from noise than
others because of auditory capabilities, social structure, life history
patterns or habitat.
o
While some species may develop a tolerance when overflights are
frequent or regular, others do not.
o
Physiological and fitness effects in wildlife have been documented at
noise exposure levels from 52 dBA for certain species (in particular
songbirds).
ii.
The noise level threshold of 60 dBA adopted for the criteria represents a
reasonably conservative noise threshold based on the findings of the published
literature (i.e. this threshold captures 60% of studies that have shown adverse
responses in terrestrial wildlife, including impacts on physiology and fitness) and
given the large variability in responses between species and individuals and at
different locations.
iii.
Biodiversity Sensitive Receivers (BSRs), are areas protected under the EPBC
Act or other areas that are likely to contain important habitat and are used as a
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proxy for EPBC Act listed threatened biota and migratory species and state-listed
threatened biota.
iv.
BSRs should be located and classified over at least a 10km buffer around the
proposed flight path/s to enable a comparison of the area of BSR affected by a
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change in noise with the extent of BSR in the locality.

36 Shannon, G., McKenna, M.F., Angeloni, L. M., Crooks, K. R., Fistrup, K. M., Brown, E., Warner, K. A., Nelson, M. D., White, C., Briggs,
J., McFarland, S., and Wittemyer, G. (2016).  A synthesis of two decades of research documenting the effects of noise on wildlife.
Biological Reviews 91: 982-1005.
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v.
The 10km buffer area in (iv) is consistent with the definition of ‘locality’ for EPBC
Act Protected Matter Searches.
5.
Impact Assessment Methodology
The EMS has included criteria for determining significant impact under the EPBC Act, since
2013 to the present, over which time the associated metrics and methodologies have been
validated through:
a.
discussion of changes being implemented at Community Aviation Consultation Group
(CACG) meetings at airports around Australia;
b.
ongoing analysis of aviation noise complaint data, and associated flight path
changes, from the Noise Complaints Information Service (NCIS);
c.
consultation with stakeholders (including the Aircraft Noise Ombudsman and the
Commonwealth Department of Infrastructure and Regional Development and Cities)
regarding noise complaints and noise impact assessments;
d.
a referral to the Commonwealth Department of Environment and Energy, under the
EPBC Act, for the Gold Coast Airport Instrument Landing System (ILS) Project
(which included discussion of the criteria and associated methodology to assess
potential significance of aviation noise impacts).
Over 200 airspace changes have been assessed for potential aviation noise impacts and
implemented by us since 2013, without later being found to represent ‘significant impact’
under the EPBC Act. Given this result, and the significant traffic growth experienced in
Australia since 2013, our assessment methodologies (and the criteria) can be seen to be
appropriate and relatively conservative.
6.
Continuous Improvement of the Criteria
As part of our continuous improvement efforts (and in response to feedback from the Aircraft
Noise Ombudsman), the significance criteria were reviewed and updated in 2018, with the
assistance of an external specialist consultant. As a result, a number of revisions were made
to the criteria in 2019: to more comprehensively address environmental values under the
EPBC Act; formally introduce concepts of ‘noise noticeability’; and to improve the clarity of
the environmental assessment methodology. This process also involved consultation with
the Commonwealth Department of Environment and Energy (DoEE), and the Department of
Infrastructure, Regional Development and Cities (DIRDC), regarding the appropriateness
and rigour of the criteria, and its overall environmental impact assessment process (for
changes to air traffic management practices).
Definitions
o  ‘Existing flight’ refers to any flight path that is either formalised or regularly used.
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  Formalised flight paths could include:
  Noise Abatement Procedures (NAPs), or flight paths prescribed in Letters of
Agreement (LoAs) with locals operators.
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Standard Approach Routes (STARs), and other approach procedures published in the
Aeronautical Information Publications (AIP) Departure and Approach Procedures
(DAP) plates.
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  Regional Routes and Domestic Routes published in the Designated Airspace
Handbook (DAH).
  Non-formalised paths could include a regularly used vectoring path or track shortening.
Regular usage is subjective to each individual airport and can include seasonal
variations. For example a path that is only used during certain meteorological conditions,
but is used consistently in those situations, would be considered an existing track.
o  Commonwealth Matters of National Environmental Significance (MNES) sites: sites that
represent Matters of National Environmental Significance – as listed in the EPBC Protected
Matters Search Tool.
o  Names and definitions for ‘rural’ and ‘urban’ will differ between councils and districts
throughout Australia, but there are generally similar zones corresponding to these. Where
there is doubt, advice should be sought from the local planning body.
o  The usage of the terms ‘day’ (6:00am to 11:00pm) and ‘night’ (11:00pm to 6:00am) is as per
the definition of night (11:00pm to 6:00am) used at Australian curfew airports (see
Commonwealth Sydney Airport Curfew Act 1995). We apply this definition consistently for all
environmental assessments, whether or not a curfew is in place at the specific airport

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Appendix C  Other Business Revenue – explanatory
notes
Other Business Revenue (OBR), otherwise referred to as ‘Unregulated Revenue’ or
Non-Airways Revenue, relates to the provision of goods or services other than those
which are provided by us as part of the regulated service that is subject to the Long
Term Pricing Agreement (LTPA) with customers. For the avoidance of any doubt, OBR
is a term applied to account for those Airservices activities not funded through Airways
Revenue.
OBR includes (but is not limited to):
  provision of charting services and other publications
  maintenance or provision of navaids under contract
  provision of air traffic services under contract (eg. for Solomon Islands and Nauru)
  delivery of training, and
  funds received for official development assistance (aid) activities.
For further information on OBR, refer to C-PROC0194
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