Many Sutherland Shire residents will be impacted if restrictions on aircraft movements at Sydney Airport are eased, the Productivity Commission will be told.
"The current regulations, enacted to protect the community from the adverse impact of aircraft noise, are vital to ensuring reasonable quality of life for shire residents," a submission by Sutherland Shire Council says.
A draft report by the Productivity Commission, released in February, suggested relaxing rules that limit aircraft movements during night time curfews and impose a cap on flights per hour.
The cap restricts total aircraft movements to 60-80 over any consecutive four 15-minute periods.
The draft report said the objective of managing the effect of aircraft noise on local residents should be balanced with reforms that benefit the community at large, including through improvements to the efficiency of the airport.
"Changes that increase the flexibility of the movement cap and that target noise outcomes more directly would most likely improve the operational efficiency of Sydney Airport as well as airlines," the draft report said.
"This could be done in a way that meets current noise objectives, but that reduces unintended consequences from the existing arrangements.
"Options include removing the cap on actual movements but retaining a cap on scheduled movements or adopting noise-based criteria for determining which aircraft are permitted to operate during the curfew, rather than the current prescribed list of aircraft types."
The Productivity Commission said it was seeking further information on the options before making a recommendation in its final report in June this year.
The council's submission, which was endorsed at its meeting on Monday night, says the draft report does not give due consideration to the cost of noise and emissions pollution on the economy, especially with respect to its broad impact on community health and general productivity.
"When the number of aircraft movements to Sydney KSA (Kinsgsford Smith Airport) approaches 80 movements per hour, the ability to apply noise sharing measures to aircraft movements across Sydney diminishes significantly," the submission says.
"For areas in Sutherland Shire in close proximity to Sydney KSA, such as Kurnell, Cronulla and Bundeena and the many other suburbs affected by aircraft flying at low altitudes on approach and departures paths, the ability for the community to avoid the impact from aircraft noise becomes increasingly more difficult.
"Although Sydney KSA has the capacity to operate at 90 aircraft movements per hour, enabling the movement cap to be exceeded is most likely to have an adverse impact on the community and is not supported.
"Suggestions by the commission that regulations be relaxed with respect to limiting aircraft movements during night time curfews and the application of the 15 minute rolling hour...are not supported."
The submission says the Falling on Deaf Ears Senate Select Committee report in 1995 and literature since then clearly demonstrate increased exposure to aircraft noise and associated sleep disturbance during curfew hours is likely to cause increased health impacts, and therefore a financial cost.
"Changes to the 15 minute rolling hour has the potential to further cluster aircraft movements and concentrate exposure to aircraft noise events as well as introduce increased uncertainty to the capacity and management of the air traffic system," the submission says.
"Concerns by the aviation industry and peak business organisations that current regulations can lead to increased noise impacts when major disruptions to aircraft movements occur is not supported.
"It is understood that when disruptive events occur [at present], aircraft are placed in a holding pattern over the ocean or land which ranges 83km to 222km from Sydney, minimising any noise impact on the community.
"When the number of aircraft movements exceed 60 movements per hour, the ability to manage these events effectively and flexibly diminishes."