Frequently Asked Questions

Plane Sense Wellington Inc. has put together some Frequently Asked Questions, with expert legal and regulatory assistance, to help others understand our community's issue, on a more fully informed basis. If you have further questions, please don't hesitate to contact us.

Why should Wellington Airport have Consulted Residents first?

Plane Sense's response: The affected residents have always had a legitimate expectation that Wellington Airport, having public law responsibilities, would carry out such consultation prior to any proposal to divert aircraft over their suburbs. The consultation now offered was required by law prior to development of the DMAPS concept.

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When Wellington Airport and Airways implemented the flight path change there was no consultation. One day back in December 2022, a community that has close to 21k residents, woke up with an aircraft highway above their heads with decibel levels rocketing 30-40 decibels louder, with no notice. What's worse, the lane above their heads is the lane reserved for the concentration of 'road trucks'. Imagine Transmission Gully turning up out of the blue on residents' doorsteps one day and the response to questions, by the organisations involved, being, 'In cases like this public consultation isn’t normally undertaken', and 'a change in noise patterns is more disruptive than the noise level itself, so we hope that after a short time this becomes less noticeable'. The residents were then bounced around between Wellington Airport, Airways and the CAA for answers, with no reasonable explanation for why this happened the way it did.

Looking through the OIA documents Plane Sense received, we found references to community consultation as long ago as November 2021, but alongside that was mention that the local community could be a "roadblock", suggestions that "impact frequently comes down to perception, influenced by publicity", and "Airways would like this implemented in December this year. We (Wellington Airport) therefore need this work reasonably quickly!" Even the Airnoise Committee meeting minutes don't reference the DMAPs flight path change until March 2023, after implementation. The first communication went up on the Wellington Airport website on 20 December 2022, a day after the first known complaint was made. 

Plane Sense found documentation about a 2018 flight path change called PBN. The PBN flight path change was for arriving aircraft and included a full community consultation and collection of noise data - before and after a trial. We questioned Wellington Airport and Airways about this comparative process in a meeting, they appeared uncomfortable and said it was unfortunate there was no comparative data pre-DMAPs. In our 27 March 2024 meeting, when discussing Wellington Airport's next steps, it was noted by Plane Sense that the External Relations Manager said that any process would be done 'properly this time'.

Understandably, residents are angry about the lack of courtesy, consistency, professionalism and regard for our community and affected individuals. We believe the organisations have been cavalier with residents' health and well-being.

Why Should Airways have considered residents?

Plane Sense's response: Official Information documents obtained indicate that Airways and its subsidiary Aeropath Limited designed and promulgated DMAPS on technical grounds without regard to section 4(1)(c) of the State-owned Enterprises Act 1986, namely that it is required to be “...an organisation that exhibits a sense of social responsibility by having regard to the interests of the community in which it operates and by endeavouring to accommodate or encourage these when able to do so.” These words mean that Airways owed and still owes procedural fairness and substantive obligations to affected residents independently of the Airport’s obligations.

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In addition to Airways' responsibility to the community when planning and implementing the flight path change, Airways has been aware of residents' grievances since complaints began, with Wellington Airport referring residents to Airways since then. After establishing Plane Sense as a community group in March 2023, Plane Sense invited residents to copy us in on communications from both organisations to ensure this feedback was being captured, and we have also seen responses from both organisations. 

As volunteers, we have read heartbreaking accounts of the damage to the health and well-being of our neighbours, including young children, the elderly and the vulnerable. Complaints include a pouring of hearts from parents and carers asking for change. Despite Airways receiving these emails and attending the Plane Sense community meeting in June 2023, Airways continued to respond to residents with an inappropriate standard response about the benefits of DMAPs. Two weeks after the June 2023 community meeting, Plane Sense wrote the following to Airways and Wellington Airport, "Please also take this email as formal notice that on the basis of information that we are receiving, we are genuinely concerned that some people are so badly affected that they may harm themselves. In that regard we also ask that you cease responding to very personal accounts of suffering with messages about the benefits of DMAPS".  

Even if a scenario exists where Airways was unaware of the impact that the DMAPs flight path change would have on people in the community, by June 2023 they were most definitely aware. However, at Plane Sense's meetings with Airways and Wellington Airport, Airways has remained adamant that they will not consider an alternative to the current DMAPs flight path, even stating at previous meetings that they won't divert resources to exploring alternatives. Airways has also repeatedly said that it does not want to revert to the previous path. 

what about the safety, sustainability and emissions benefits?

Plane Sense's response: Official Information documents indicate that DMAPS was initiated and developed by Airways and Aeropath Limited technical staff without Chief Executive or legal supervision or Board approval and promulgated one year prior to formal regulatory approval by the Director of Civil Aviation in breach of Civil Aviation Rule 95.55. The Director’s officers identified safety risks due to closer gaps between aircraft and operations at lower altitudes over higher terrain than the original track over a greater expanse of Wellington Harbour. The claimed sustainability and efficiency of DMAPS was part of the theoretical justification for DMAPS but the practical achievement of these claims has not been disclosed. Northbound DMAPS departures to Auckland, for example, involve additional track miles due to the divergent track requirement.

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It has been concerning to read emails (obtained through the OIA process) raising safety concerns about DMAPs, including internal Airways communications. When reviewing risk management documentation, it was also concerning that the community's health and well-being did not feature as a risk. At our meetings with Airways, and in emails about the effect of DMAPs on residents' health and well-being, we have tried to explain to them that this is a very real risk of DMAPs. In June 2023 we sent the following, "Please also take this email as formal notice that on the basis of information that we are receiving, we are genuinely concerned that some people are so badly affected that they may harm themselves".

Wellington Airport and Airways make DMAPs sustainability claims. Plane Sense considers these claims as 'green-washing'. At our community meeting in June 2023, we presented the following based on information obtained by OIA:

Sustainability
• Airways publicised that DMAPs saves 847 tonnes of carbon emissions per year and equates this to cars (not aircraft), whereas OIA information stated 420 tonnes per annum in several documents.
• Putting 420-847 tonnes and 33,800kms savings into perspective (Plane Sense calculates to the best of our knowledge):
⚬ 33,800kms is just 1 return/2 long haul flights a year, out of 18k+ flights a quarter (Jan-Mar 2023)
⚬ or, $5k to offset 847 tonnes (Carbon Neutral Trust NZ), compared to $1.3m savings per year (June 2023)

Making claims that DMAPs was designed for sustainability purposes is ironic considering DMAPs is designed to increase aircraft movements, and the increased jet engine flights since 1 December 2022 are so far the less efficient Qantas Boeing 737 jets (April 2024).  

The planes have to fly over someone?

Plane Sense's response:: Newlands residents chose to live close to the standard instrument departure tracks for jet aircraft that have been in operation for approximately 60 years whereas the Khandallah, Johnsonville and Broadmeadows residents were taken by surprise by a radical DMAPS concept which in effect changed the north/south runway vector with adverse effects on their safety, health and wellbeing. Unlike Newlands the suburbs of Khandallah and Broadmeadows are located within the Wellington Airport noise abatement area which has been in Civil Aviation Rule Part 93 since 1997.

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Change is divisive, so it's frustrating that a proper consultation process didn't happen before the implementation of DMAPs. We are arguing a lack of fair process before change. If the residents had been consulted before the change, they could have had a say before the status quo for the last 60 years was altered. Those residents who knew a change in noise would be an issue for them and their health could have had their say and been considered. 

Which community is worse off with the path above them? Unfortunately, inadequate monitoring was done before the flight path change so we can't compare what was with what is. What we do know is that the process for change wasn't fair. We know that jet engine aircraft have to climb up and over Mount Kaukau/Tarikākā in our community, and that the topography and height above sea level is different. The distance (therefore height) of the planes as they turn over the water towards land and ambient noise, may also differ between the communities. We know that a Wellington Airport 2018 PBN flight path change document (page 9) states that (on the old departure path) "departures climb higher and more quickly (than arrivals) reaching 5000ft around the same point as shown in the picture". This picture shows departing aircraft at 5000ft over the water before reaching land. We also know that jet engine aircraft are climbing much lower than 5000ft over land in our community (2700ft above sea level at the point of the Khandallah sound monitor).  

Wellington Airport's proposal to consult both communities now is not a reasonable solution. For communities to be on an even keel they must revert the flight path back to its original path and start a fair and proper process. If a DMAPs-type procedure is required it needs to be developed taking into account the local community's best interests and properly consulted on - before implementation. Neither community is at fault here and neither should get the blame for change, essentially diverting the blame from Wellington Airport and Airways. The organisations are responsible for the process and decisions they made, the proposal has every potential of pitching neighbouring communities against one another unnecessarily.  That is not in the best interests of Wellingtonians. 

There are drawbacks to every option. you can't please everyone.

Wellington Airport (Media Release 10 April 2024): “Each option will have different benefits and drawbacks. It is unavoidable that aircraft will fly over residential areas under each option. 

Plane Sense's response: This statement is misleading as the greater the distance that aircraft are required to track out over the harbour the higher the altitude they achieve during standard climb profiles before flying over ANY residential areas. The current divergent track requirement compromises this basic noise abatement advantage which is inherent in the original runway 34 straight out departure track.

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It may well be possible to please everyone if Airways would consider an alternative to the current DMAPs procedure. Airports around the world use alternative procedures, however, Airways is adamant that they won't consider an alternative. DMAPs was developed with the knowledge that the community could be affected and approved knowing that more households could be affected than the original flight path. DMAPs wasn't designed with the local community's best interests in mind or to please anyone other than the organisations involved. 

Wellington Harbour has the geographical advantage of northerly and southerly departures over water until aircraft are high enough not to be a bother to anyone. Yet, DMAPs has jet aircraft laden with people, fuel for long distance, luggage and cargo, etc, turning left asap over land and a reserve, climbing out over the slopes of Wellington's peak mountain - Mount Kaukau at 445m above sea level. Which, when you think about it makes zero sense and poses a safety concern above the heads of 21k residents.

One of the issues here is that there was not a fair process for communities to engage in at the start. Wellington Airport's proposal to consult both communities now is not a reasonable solution. For communities to be on an even keel the flight path must revert to its original path and start a fair and proper process. If a DMAPs-type procedure is required it needs to be developed taking into account the local community's best interests and properly consulted on - before implementation. 

Why not engage with Wellington Airport's proposal? 

Wellington Airport's proposed options:

Plane Sense's response:
1. Wellington Harbour is not populated at all and there are no scheduled jet arrivals into Wellington Airport prior to 7am so this change could be implemented immediately. Since 1 December 2022 residents have endured at least 3 early morning departures between 6am and 7am when there has been no possibility of an aircraft having to make a missed approach or go around. The consultation proposal envisages this situation will continue for an unspecified but lengthy period until sometime after the consultation process is completed but with no assurance that any change will be implemented.

2. In view of the very unsatisfactory history of DMAPS, the more correct response from the Airport would be to immediately advise Airways that it is withdrawing its regulatory consent for the DMAPS tracks and require Airways to reinstate the original over water track. If any change is then contemplated consultation could proceed on the correct legal and factual foundation.

3.  Response: Apart from serious process failures during the development and implementation of DMAPS, the concept is substantively untenable as it involves unnecessarily directing jet aircraft over densely populated suburbs over high terrain through the middle of the Wellington Aerodrome noise abatement area prescribed by the Minister in Civil Aviation Rule Part 93. It is expected that the Airport and Airways will endeavour to repair the process failures during the proposed consultation procedure but if DMAPS is confirmed after consultation it would remain liable to be set aside by a Court as objectively unreasonable.

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Plane Sense has met with Wellington Airport and Airways many times since this began and have sent even more emails back and forth. They have made it clear that they do not want to revert back to the original flight path, and Airways has said it will not devote resources to investigate an alternative to DMAPs. At our last meeting Airways confirmed that these 3 options are the only 3 options they are exploring. Both organisatons have stated that the current status quo is their preferred option, so we question how genuine this consultation will be. We believe that option 1 is on the table for the organisations to settle on and is the easiest 'way out' for them, whilst appearing to consult after all. Only option 2 is viable for our community, we will not be engaged in a clash with our neighbours under the original path, to divert attention from the systematic organisational failures that have put us all in this position. 

Why isn't option 1 on the table for Plane Sense? Whilst the 6am-7am flights are hugely disruptive and cause residents to lose sleep and wake disorientated, one hour's reprieve isn't adequate compensation for having high levels of noise overhead all day, every day.  At our meeting with Wellington Airport and Airways on 27 March 2024, we suggested that this would just move the pain point by an hour. Residents want to be able to relax in their own homes morning, afternoon, evening and night. A 7am alarm on weekdays, weekends and public holidays isn't much better than a 6am alarm that goes off, especially when it then goes off throughout the day, 80 decibels at a time.

We have shift workers and members of the community who run businesses from home, plus those who are disturbed by the last flights of the day as much as the start. And we have young, elderly and vulnerable residents who have health conditions that are worsened by noise, lack of sleep and stress. These include dementia and brain injury sufferers who are disorientated and confused with loud noises, those with sound processing disorders, ADHD and those who are on the autism spectrum. Those with anxiety and PTSD from the Christchurch earthquakes, and those who have depression and need a consistent good quality of life.  Airways and Wellington Airport are aware of the vulnerability of residents in our community as they have been sent emails from these residents searching for understanding and support. These community members settled in our suburbs because it's in the noise abatement area and it was a peaceful sanctuary vital for their health and well-being. Plane Sense will not abandon our most vulnerable neighbours by opting for option 1. It shouldn't be in our hands to represent them but it is, and we will.

Wellington Airport Said it's looking into alternate options?

Plane Sense's response: This is a significant development in that Airways previously refused to investigate alternative options and told Plane Sense that they did not want to allocate limited resources for that purpose. A significant concern however is that the Airport is entirely dependent upon Airways and Aeropath for expert advice and their representatives at meetings have made statements demonstrating a closed corporate mind to any modification to DMAPS or reinstatement of the original track.

Drop down for Plane Sense's response.

Plane Sense says: Plane Sense has met with Wellington Airport and Airways many times since this began and sent even more emails back and forth. They have made it clear that they do not want to revert back to the original flight path, and Airways has said it will not devote resources to investigate an alternative to DMAPs. Both organisatons have stated that the current status quo is their preferred option, so we question how genuine this consultation will be.  

At our last meeting on 27 March, Wellington Airport said that it would put together a proposal for us to share with our members within ‘a day or so’, but that didn’t happen. Two weeks later, we received 30 minutes notice that Wellington Airport was issuing a media release about the proposed consultation. It is telling that a public relations press release came out instead of a statement we could take to our members at a community meeting (as discussed at that meeting). We believe this proposed consultation is a public relations exercise designed to try and reduce Wellington Airport's legal risk. If we engage with this proposal we have no control over the process and we don't have faith in the organisation's objectivity or moral compass at this stage. We have vulnerable members of our community to think about and we would prefer to let a judge, as an independent legal authority, decide based on facts rather than corporations with a vested interest.

Why not wait to find out the outcome of the consultation?

Plane Sense's response: The open-ended timing of the proposed consultation and then any subsequent change, if any, is of real concern given the situation that residents have already endured for some 16 months. The proposal being offered could extend over a year or more with overflights continuing and with no assurance that the original tracks would be reinstated anyway.

Drop down for Plane Sense's response.

Plane Sense says: That Wellington Airport has no proposed timing in place shows it really hasn't listened to residents at all. The DMAPs flight path change happened on 1 December 2022 (it was presented to them in November 2021). Wellington Airport approved DMAPs on 9 August 2022, just 24 hours after it received an email from Marshall Day stating 'initial outcomes' of a noise assessment (later proven to be wrong by a more comprehensive study in December 2023). 10 months after DMAPS was presented to Wellington Airport, 5 months after commissioning an acoustics report, Wellington Airport approved DMAPS with 'initial outcome' information, "with more to come" and an assurance from Marshall Day that "on paper" noise levels are "pretty low" and "the effects would be considered reasonable" despite "affecting more houses".  

We are now  16 months into this process (as of April 2024) with actual vs modelled sound data. Wellington Airport approved DMAPs within 24 hours of receiving inadequate sound data, yet it has taken 16 months for them to propose anything other than the current status quo (even with more comprehensive reporting to hand these last 4 months).

Whilst Wellington Airport was able to approve DMAPs quickly,  it took 7 months for them to agree and install sound monitors in the suburbs post-DMAPS. That only included post-implementation data, not pre-change data and not from 2 separate communities, which is what they propose this time. Also of note is Wellington Airport refused Plane Sense a monitor per affected suburb because they are expensive, we don't know whether there will be further delays due to monitors moving between locations over this process.

Meanwhile, Airways has been adamant that 1 December of any given year is of importance for flight path changes. In 2022,  it communicated to Wellington Airport that 1 September was the publishing cut-off for a 1 December implementation of DMAPS. That is 4.5 months away (from April 2024). Therefore if Plane Sense engages with Wellington Airport's proposed consultation, not only is an outcome uncertain and managed by a corporation with a vested interest, our residents can expect no change before December 2025 at the earliest (enduring at least 3 years of DMAPs), which is unacceptable.  It is worth bearing in mind that during this time the implementation of the DMAPs continues to have substantial legal and regulatory issues. 

What work is involved with Wellington Airport's Consultation?

Wellington Airport (Media Release 10 April 2024): Before public consultation begins work is required to:

Plane Sense's response: These are some of the aspects that Airways and Wellington Airport should have addressed prior to developing the DMAPS concept in accordance with global best practice set out in the Guidance on the Balanced Approach to Aircraft Noise Management published by the International Civil Aviation Organisation as ICAO Doc 9829. It needs to be ascertained whether Airways will be jointly consulting residents together with Wellington Airport given Airways’ independent statutory obligation in terms of section 4(1)(c) of the SOE Act as noted above.

What is DMAPs and Why does Airways recommend it?

Wellington Airport (Media Release 10 April 2024): DMAPs introduces a greater divergence between departure aircraft flight paths, and arrival go-around/missed approach flightpaths when the initial approach to land is abandoned for safety reasons.

Plane Sense's response: This is correct but DMAPS is an idiosyncratic and unnecessary procedure that is not used at other far busier overseas international airports. There are many alternative design and operational procedures available for go-around and missed approach situations that radar and tower controllers and pilots are very familiar with.

Wellington Airport (Media Release 10 April 2024): This enables gaps between arrivals to be reduced, while still enabling a departure to safely get airborne between arrivals - without the need for large passenger aircraft to maneuver visually in the event of a go-around or missed approach. 

Plane Sense's response: Reducing gaps involves increasing the risk of go-arounds and this involves safety risks relating to aircraft having to rapidly change configuration during a critical phase of flight. Performance-based satellite navigation procedures that are now a well-established feature of the NZ air navigation system means there is no requirement for jet aircraft to visually manoeuvre in the event of a missed approach or go-around anyway, although pilots can still elect to do this in suitable weather conditions. 

Wellington Airport (Media Release 10 April 2024):  In practice this increases capacity for arrivals and reduces holding time in the air, resulting in reduced flight times, fuel burn and CO2 emissions. 

Plane Sense's response: There are many well-established air traffic control operational and instrument design procedures that are available and in widespread use internationally that can achieve these outcomes without DMAPS and without causing the health and safety concerns inherent in the use of the DMAPS concept in Wellington. Airways and Wellington Airport should be aware of and willing to follow recommended global best practice as set out in the Manual of Operational Opportunities to Reduce Aircraft Noise, published in 2023 as ICAO Doc 10177.

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In the process of reviewing documents through the OIA process, the focus of DMAPs is the safety of missed approaches. Missed approaches are 1 in 270 flights. Therefore, the big space above our Wellington Harbour, where no resident lives, is mostly empty. Meanwhile, a concentration of aircraft departs out over land soon after take off. One of the legal issues with DMAPs is that it's nonsensical and can not be considered reasonable, especially with alternative systems available and used throughout the world. In OIA documentation, it is clear that not all internal parties agreed that DMAPs was the right solution anyway.

Residents wouldn't complain about the odd flight coming over because of an emergency - which is what we experience and happily accept with the Life Flight aircraft. But to experience the negative effects of a concentration of aircraft departing for an occasional go-around, doesn't make sense. It shows that Airways wasn't thinking of the best interests of the local community when designing these procedures, only what looked good on paper.

Wellington Harbour has the geographical advantage of northerly and southerly departures over water until aircraft are high enough not to be a bother to anyone. Yet, DMAPs has jet aircraft laden with people, fuel for long distance, luggage and cargo, etc, turning left asap over land and a reserve, climbing out over the slopes of Wellington's peak mountain - Mount Kaukau at 445m above sea level. Which, when you think about it makes zero sense and poses a safety concern above the heads of 21k residents. 

What area is affected by DMAPs?

Wellington Airport (Media Release 10 April 2024): In general, DMAPs has meant jet aircraft departing in a northerly wind track slightly further west than before. In practice this has meant fewer departures over Newlands and more over Khandallah and Broadmeadows. 

Plane Sense's response: To be more accurate 5 of the 6 current DMAPS standard instrument departures require aircraft to diverge 18 degrees left of the runway vector (to the west) shortly after takeoff to cross higher ground directly over Khandallah, Johnsonville and Broadmeadows at lower altitudes above mean sea level compared to the original non-divergent track over Newlands. Some aircraft still elect to do the more direct straight-out departure on the runway 34 vector over Newlands rather than follow the divergent DMAPS initial departure track.

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Whilst the Wellington Airport's commissioned Marshall Day reports refer to Johnsonville, Broadmeadows and Khandallah as the main 3 suburbs affected, Plane Sense has been made aware that residents in Ngaio, Crofton Downs and Ohāriū Valley are also affected. Whilst we negotiated a sound monitor to measure noise in Ngaio, by the time it was installed this only collected 2 months of data, so some of the assessment was incomplete. The additional 3 suburbs are not mentioned in Wellington Airport's media release and it's uncertain whether they will be included in any consultation.

Whilst not every resident in these suburbs is affected, it is important to note that at the sound levels reported in Marshall Day's latest December 2023 report, the WHO reports that 18% of people would be highly annoyed. That is almost 1/5 of the population of our suburbs. This includes residents who are susceptible to high levels of noise and who settled in a noise abatement area for that reason. Various Marshall Day experts, including the founder Christopher Day, have confirmed in evidence that the WHO curve is the most appropriate as it represents the latest research in the area.

Marshall Day's December 2023 report records a 4-5dB increase in sound (noting that dBs increase exponentially) and aircraft noise of up to 50dB Ldn. The Environment Court has confirmed that a 5dB increase is significant, and noise experts generally consider a 5dB increase to be "significant". Adverse health effects are associated with aircraft noise above 45dB Ldn, this is consistent with what residents are telling us. Marshall Day previously predicted noise levels would increase by 1-2dB and be 45dB Ldn. Wellington Airport declined to answer whether it would approve DMAPs today based on the knowledge it has now. 

Why don't planes fly south all the time, or over the harbour?

Wellington Airport (Media Release 10 April 2024): Aircraft are required to take off and land into the wind to increase wind flow over the wings (take-off) and reduce required speed (landing).

Plane Sense's response: This is correct (as a non-technical explanation) but when the wind is light and variable an available noise abatement procedure that the Airport and Airways could implement immediately is for all aircraft to depart only to the south over Cook Strait.

Wellington Airport (Media Release 10 April 2024):  Aircraft taking off and landing to the north already overfly Wellington Harbour but inevitably have to overfly land at some point.

Plane Sense's response: Wellington Airport has a significant natural geographical advantage for noise abatement procedures which has been compromised by requiring aircraft to diverge from the runway 34 vector shortly after takeoff and unnecessarily climb out over densely populated suburbs on high ground generating 70 – 80 decibels of noise in the Wellington Airport noise abatement area prescribed by the Minister in Civil Aviation Rule Part 93.

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Aircraft fly over our suburbs when there is a northerly wind. Wellington Airport states in documentation that this is 2/3s of the time.

Wellington Harbour has the geographical advantage of northerly and southerly departures over water until aircraft are high enough not to be a bother to anyone. Yet, DMAPs has jet aircraft laden with people, fuel for long distance, luggage and cargo, etc, turning left asap over land and a reserve, climbing out over the slopes of Wellington's peak mountain - Mount Kaukau at 445m above sea level. Which, when you think about it makes zero sense and poses a safety concern above the heads of 21k residents.

The DMAPs flight procedure has planes turning left sooner than on the previous flight path. We know that a Wellington Airport 2018 PBN flight path change document (page 9) states that (on the old departure path) "departures climb higher and more quickly (than arrivals) reaching 5000ft around the same point as shown in the picture". This picture shows departing aircraft at 5000ft over the water before reaching land. We also know that jet engine aircraft are climbing much lower than 5000ft over land in our community (2700ft above sea level at the point of the Khandallah sound monitor).  

Have flight paths changed for arriving aircraft?

Wellington Airport (Media Release 10 April 2024): No, this has not changed for several years. DMAPs only applies to jet aircraft departing to the north when there is a northerly wind.

Plane Sense's response: This is correct. Johnsonville, Broadmeadows and Khandallah residents have always experienced a certain amount of aircraft noise based upon aircraft conducting straight in southerly approaches and straight-out northerly departures over the harbour. But none of these residents could have ever contemplated the aberrant corporate and regulatory decision-making that has led to the present situation.

Why can't all aircraft fly over less populated areas after 7am?

Wellington Airport (Media Release 10 April 2024): Taking this indirect route isn’t possible for all flights after 7am for safety, efficiency and environmental reasons.

Plane Sense's response: For safety, efficiency and noise abatement reasons prior to 1 December 2022 jet aircraft have tracked directly out on the runway 34 departure vector for the last 60 years.

Wellington Airport (Media Release 10 April 2024): This proposed route could work before 7am given there are no arrivals before then, but after that time the airspace becomes busier and more complex.

Plane Sense's response: It is only for very short periods during the day that Wellington Airport becomes busy and there are many ATC operational, instrument design and gate management procedures that can deal with this situation without DMAPS, as occurs at international airports throughout the world. DMAPS has unnecessarily added to airspace complexity.

Wellington Airport (Media Release 10 April 2024): Flying longer, more indirect routes would also extend flight times, meaning increased fuel burn, cost and emissions – especially if this was required over all residential areas. Aircraft are allowed to fly over residential areas for this reason.

Plane Sense's response: This type of unsupported general comment indicates a reluctance to address DMAPS issues more accurately. For example, the most frequent departures from Wellington Airport are to Auckland and the northerly DMAPS divergence from the direct track to Auckland involves increased track miles, flight time, fuel burn, cost and emissions.

Drop down for additional commentary.

In the process of reviewing documents through the OIA process, the focus of DMAPs is the safety of missed approaches. Missed approaches are 1 in 270 flights. Therefore, the big space above our Wellington Harbour, where no resident lives, is mostly empty. Meanwhile, a concentration of aircraft departs out over land soon after take off. One of the legal issues with DMAPs is that it's nonsensical and can not be considered reasonable, especially with alternative systems available and used throughout the world. In OIA documentation, it is clear that not all internal parties agreed that DMAPs was the right solution anyway.

Wellington Harbour has the geographical advantage of northerly and southerly departures over water until aircraft are high enough not to be a bother to anyone. Yet, DMAPs has jet aircraft laden with people, fuel for long distance, luggage and cargo, etc, turning left asap over land and a reserve, climbing out over the slopes of Wellington's peak mountain - Mount Kaukau at 445m above sea level. Which, when you think about it makes zero sense and poses a safety concern above the heads of 21k residents.

The DMAPs flight procedure has planes turning left sooner than on the previous flight path. We know that a Wellington Airport 2018 PBN flight path change document (page 9) states that (on the old departure path) "departures climb higher and more quickly (than arrivals) reaching 5000ft around the same point as shown in the picture". This picture shows departing aircraft at 5000ft over the water before reaching land. We also know that jet engine aircraft are climbing much lower than 5000ft over land in our community (2700ft above sea level at the point of the Khandallah sound monitor). 

Therefore, Plane Sense is advocating for the urgent reinstatement of the previous flight path, where aircraft track over the water for a longer period, gaining height before flying over land and suburbs below. 

Why wasn't the public consulted to begin with?

Wellington Airport (Media Release 10 April 2024): Wellington Airport is required to manage noise within its air noise boundaries which only extend to surrounding neighborhoods – not the northern suburbs. It was determined that DMAPs would have no impact on these, which is technically the end of Wellington Airport’s responsibilities.

Plane Sense's response: This is a resource management law issue relating to the Wellington District Plan, but as a matter of aviation law the DMAPS tracks go through the middle of the Wellington Airport noise abatement area prescribed in Civil Aviation Rule Part 93 and DMAPS procedures could not have been implemented without the Airport’s written consent required by Civil Aviation Rule Part 173.201.

Wellington Airport (Media Release 10 April 2024): However, the airport went above and beyond their requirements by installing a noise monitor and commissioning experts to carry out a preliminary noise assessment. This found that while the change would be noticeable to some residents, it would be within reasonable limits.

Plane Sense's response: The preliminary noise assessment was clearly inadequate as the sole noise monitor was located close to the original flight track predictably producing minimal noise increase. Airport noise consultants are accustomed to using various noise measuring metrics and averaging principles to invariably conclude that all aircraft noise is “within reasonable limits”. These types of reports should be read with caution until peer reviewed by public health experts with clinical training and an understanding of the effects of noise on human health and wellbeing.

Wellington Airport (Media Release 10 April 2024): It was also determined that aircraft would not be flying in areas they hadn’t previously – i.e. planes have always overflown the northern suburbs to an extent.

Plane Sense's response: This statement deflects attention away from of the main issue, being the intense concentration of aircraft operating on defined tracks over residential areas according to instrument flight rules, compared to the occasional random overflights of aircraft operating in visual meteorological conditions.

Wellington Airport (Media Release 10 April 2024): Based on this information and responsibilities, public consultation wasn’t considered necessary.

Plane Sense's response: The Official Information documents obtained indicate that Airways was placing considerable pressure on Wellington Airport to give its immediate regulatory consent to the DMAPS procedures so that the new procedures could be implemented and take effect by Airways’ recommended global chart update deadline of 1 December 2022. As such, Wellington Airport was given no time to conduct adequate noise monitoring or consultation unless it delayed DMAPS for one year. Had Airways, Aeropath and Wellington Airport followed the ICAO Guidance on the Balanced Approach to Aircraft Noise Management in ICAO Doc 9829, it is unlikely that the DMAPS concept would have ever been progressed.

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The series of comments from Wellington Airport to justify not consulting with the community is just further evidence of the misunderstanding of its responsibilities within our Wellington community. As residents of our city, we have a moral obligation not to cause harm to one another. With all common sense, putting an aircraft highway above the heads of 21k residents, with the 'road truck' lane concentrating the heavy traffic in one direction, climbing up over the slopes of Mount Kaukau, from 6am in the morning, has repercussions.

Wellington Airport received an email just 24 hours before approving DMAPs, stating, "on paper" noise levels are "pretty low" and "the effects would be considered reasonable" despite "affecting more houses". Even the suggestion that more houses would be affected should have raised red flags and prompted further investigation. However, Airways' deadline for approval was looming and a delay would have resulted in Airways not meeting the 1 September deadline, for a 1 December implementation. The organisations were (and still are) single-minded in their view of 'DMAPs at all costs'.

Despite 16 months of ongoing feedback and a heartfelt outpouring of individuals' suffering, none of the organisations involved have gone above and beyond to rectify matters. Installing sound monitors in impacted suburbs was the least Wellington Airport should have done and before implementation too. Plane Sense had to negotiate the same number of sound monitors as the 2018 PBN trial, when a more comprehensive process took place. Airways then reneged on its offer of additional monitors to ensure one was installed in each suburb impacted. Wellington Airport would not help provide the raw data for Plane Sense to seek independent analysis for a fair and transparent comparison. When asked by Public Health to apologise for wrongdoing the organisations were defensive.

Wellington Airport in particular posts social media messages of being a socially responsible and community-minded organisation, including in April 2024 an initiative to support mental health. Meanwhile, residents are suffering the outcome of a decision they made and their response has been to pitch community vs community in a consultation battle. We believe this is to divert blame for change from the organisations involved.

Plane Sense would have more respect for Wellington Airport and Airways if they held their hands up and did the right thing for the community in which it operates. Instead, we have witnessed insensitive responses to vulnerable individuals promoting their decisions, which have come at the expense of others' health and well-being.  It's not good enough and our Wellington communities deserve more. 

What has been public feedback on DMAPs?

Wellington Airport (Media Release 10 April 2024): A number of residents in the northern suburbs, particularly Khandallah and Broadmeadows, have told us the noise has impacted them. The 6am departures have been highlighted as the most noticeable.

This feedback is not universal however and other residents in adjacent homes have told us they have not noticed or minded the changes.

The resident group Plane Sense has been regularly communicating with Airways and Wellington Airport, and in response we installed further noise monitoring and modelling in 2023. Temporary noise monitors were placed in Khandallah, Johnsonville, Broadmeadows and Ngaio to record data on aircraft noise levels.

Plane Sense's response: Some credit is due to Wellington Airport for being willing to install the noise monitors and producing the data, albeit subsequent to the implementation of DMAPS. This confirms the single noise events of aircraft overflights in the range of 70-80 decibels producing the distress being experienced by numerous residents as documented on the Plane Sense website. Urgent reinstatement of the original tracks is now the necessary action required by the organisations responsible for this situation.

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Whilst not every resident in these suburbs is affected, it is important to note that at the sound levels reported in Marshall Day's latest December 2023 report, the WHO reports that 18% of people would be highly annoyed. That is almost 1/5 of the population of our suburbs. This includes residents who are susceptible to high levels of noise who settled in a quiet noise abatement area for health and well-being reasons. Various Marshall Day experts, including the founder Christopher Day, have confirmed in evidence that the WHO curve is the most appropriate as it represents the latest research in the area. It's unreasonable to assume that every resident would naturally be triggered by noise levels in the same way, or suggest that the percentage of those who are triggered is insignificant.

Marshall Day's December 2023 report records a 4-5dB increase in sound (noting that dBs increase exponentially) and aircraft noise of up to 50dB Ldn. The Environment Court has confirmed that a 5dB increase is significant, and noise experts generally consider a 5dB increase to be "significant". Adverse health effects are associated with aircraft noise above 45dB Ldn, this is consistent with what residents are telling us. Marshall Day previously predicted noise levels would increase by 1-2dB and be 45dB Ldn. Wellington Airport declined to answer whether it would approve DMAPs today based on the knowledge it has now. 

The December 2023 Marshall Day acoustic report has some issues, but it generally supports the concerns of residents and differs from their initial findings pre-DMAPs:  

More aircraft fly over the suburbs than they did previously, with a concentration over the suburbs as a result of DMAPs.

Whilst Wellington Airport did install additional sound monitors in the suburbs to gather additional data on actual noise levels, it must be noted that it took 7 months to install monitors and gather data. They also reneged on the number of monitors offered (Airways offered 6 additional monitors at the June 2023 community meeting) and it's taken 16 months for Wellington Airport to review the situation and propose anything other than the status quo. This is in comparison to the 10 months it took them to approve DMAPs after Airways presented the new flight path procedure in November 2021.

Who will run Wellington Airport's Consultation?

Wellington Airport (Media Release 10 April 2024): Wellington Airport will lead the consultation with technical support from Airways.

Plane Sense's response: This is a significant issue as Airways initiated the so-called DMAPS concept and is still strongly committed to it. Wellington Airport is entirely dependent on Airways and Aeropath for technical support and advice. Wellington Airport cannot legally delegate its regulatory responsibility as a  Certificated airport, but it has contractually engaged Airways to fulfill many of its Civil Aviation Rule Part 139 responsibilities, including those relating to air traffic control and instrument procedure design.

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Plane Sense has met with Wellington Airport and Airways many times since this began and sent even more emails back and forth. They have made it clear that they do not want to revert back to the original flight path, and Airways has said it will not devote resources to investigate an alternative to DMAPs. Both organisatons have stated that the current status quo is their preferred option, so we question how genuine this consultation will be.

At our last meeting on 27 March, Wellington Airport said that it would put together a proposal for us to share with our members within ‘a day or so’, but that didn’t happen. Two weeks later, we received 30 minutes notice that Wellington Airport was issuing a media release about the proposed consultation. It is telling that a public relations press release came out instead of a statement we could take to members at a community meeting (as discussed at that meeting). We believe that this proposed consultation is a public relations exercise designed to try and reduce Wellington Airport's legal risk. If we engage with this proposal we have no control over the process and we don't have faith in the organisation's objectivity or moral compass at this stage. We have vulnerable members of our community to think about and we would prefer to let a judge, as an independent legal authority, decide based on facts rather than corporations with a vested interest.

How are the CAA implicated in the flight path change?

Plane Sense's says: The Director of Civil Aviation has a statutory duty to “Monitor adherence, within the civil aviation system, to any regulatory requirements relating to … public health”. Also, the Director has a regulatory role in approving the implementation of DMAPS. After pointing out non-compliance with the Civil Aviation Rules, the CAA gazetted the flight tracks in December 2023. This attempt to validate the procedures more than a year after they were published to flight crew does not have retrospective effect and, in our opinion, the purported validation may not be effective either.

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Through OIA requests and our advisors' conversations with the CAA, we believe that DMAPS wasn't officially approved through the correct process, therefore making DMAPS invalid. The CAA asked that Plane Sense refrain from legal action whilst they investigate matters. Discussions with the CAA about the Director's statutory duty to “Monitor adherence, within the civil aviation system, to any regulatory requirements relating to … public health” have resulted in the CAA claiming that the obligation is minimal. The Director has final responsibility for requiring compliance with aviation safety standards.

As stakeholders, where does the council sit with this?

It's not lost on us that the Wellington City Council currently (April 2024) owns a 34% share in Wellington Airport. Nor the irony of our rates going to support an entity that is stripping us of our right to peaceful enjoyment of our homes.

Plane Sense has been in touch with the Wellington Mayor and Councillors throughout the process. Whilst Councillor Diane Calvert has been a supportive representative of our community, coming along to every Airways and Wellington Airport meeting, asking tough questions on behalf of her representatives, Wellington's Mayor has been noticeably absent as the Council's representative on the Wellington Airport Board of Directors. This has been the case throughout, even when we copied Mayor Whanau into an email declaring our genuine concern for the well-being of residents at risk of harming themselves due to worsening health conditions.

This is of course disappointing and not our understanding of the purpose of local representation.  A suggestion of a rates strike has been raised by residents but we hope an obligation to represent and care for local communities will prevail before any such action becomes a popular outlet for frustration.

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