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BEFORE THE Kapiti Coast District Council

IN THE MATTER OF The Resource Management Act 1991

AND

IN THE MATTER OF The Proposed Kapiti Coast District Plan, Chapter 6: Working Environment

STATEMENT OF EVIDENCE OF LAURA MCNEILL

1.0 QUALIFICATIONS AND EXPERIENCE

1.1 My name is Laura Rebecca McNeill. I am an acoustic consultant in the acoustical consulting practice of Marshall Day Acoustics (“MDA”). I hold the degree of Bachelor of Science (Honours) from the University of Auckland and I am a full member of the Acoustical Society of New Zealand.

1.2 For the past six years I have worked in the field of acoustics, noise measurement and control in New Zealand. My work has included noise control engineering work for various industries in New Zealand but with a specialisation in airport noise.

1.3 I have been involved with noise prediction and consulting advice for at least 7 airports in New Zealand. My experience has involved significant airport noise work including aircraft noise monitoring, noise calculations, computer modelling, noise boundary development, assessment of noise effects, analysis of and response to aircraft noise complaints and measurement and design of house insulation.

1.4 On this occasion I have been engaged by Kapiti Coast Airport Holdings Limited (“KCAHL”) to prepare evidence regarding their submission to the Kapiti Coast District Council (“the Council”) on the Kapiti Coast District Plan Review. Specifically changes sought to Chapter 6: Working Environment.

2.0 SCOPE OF EVIDENCE

2.1 Many of the changes sought by KCAHL have been accepted by Council officers. My evidence will focus on the issue still in question, namely the amendment of Rule 6G.1.13 to allow for noise sensitive development inside the Airport Zone (but outside the Aircraft Noise Notification Area (“NNA”)).

2.2 In this statement I will:

a) Briefly summarise the New Zealand approach to airport noise management and land use planning around airports including a summary of New Zealand Standards NZS 6805:1992 “Airport Noise Management and Land Use Planning” (“NZS 6805”) and NZS 6807:1994 “Noise Management and Land Use Planning for Helicopter Landing Areas” (“NZS 6807”)

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b) Discuss earlier feedback given on the aircraft noise rules and Aircraft Noise Contours contained in the Proposed Kapiti Coast District Plan (“Proposed Plan”)

c) Discuss the potential noise and reverse sensitivity effects of amending Rule 6G.1.13 of the Proposed Plan to allow residential activities to develop in the Airport Zone (beyond the NNA)

d) Propose potential mitigation measures for any noise sensitive activities developing in the Airport Zone (beyond the NNA) to ensure noise and reverse sensitivity effects are kept to a minimum

3.0 CONTEXT: NOISE MANAGEMENT & LAND USE PLANNING AROUND AIRPORTS AND HELIPORTS

3.1 Allowing noise sensitive activities in areas affected by aircraft and helicopter noise can result in adverse noise effects on residents and adverse reverse sensitivity effects on an airfield and its users. NZS 6805 and NZS 6807 provide a recommended approach to territorial authorities for implementing appropriate planning provisions for airports and heliports.

3.2 These Standards specifically relate to the noise from aircraft and helicopter operations (arrivals, departures, taxiing, touch and goes and circuits) and do not relate to noise from ancillary activities at the airport. NZS 6807 recommends that noise from ancillary activities is dealt with by the provisions of New Zealand Standard NZS 6802, the latest version of which is entitled New Zealand Standard NZS 6802:2008 “Acoustics - Environmental Noise” (“NZS 6802”). The changes to Rules 12D.1.19 and 12D.6.3, recommended in the Officer's Response dated 3 May 2016 following the Chapter 12 Hearing, ensures consistency with the Standards.

3.3 The two main objectives of NZS 6805 and NZS 6807 are to:

a) Establish maximum acceptable levels of aircraft or helicopter noise around an airport in the form of noise boundaries

b) Propose appropriate land use controls for noise sensitive development within high noise areas (i.e. within the noise boundaries)

3.4 NZS 6805 requires the prediction of noise contours for future aircraft operations at an airport, allowing for a reasonable degree of growth in aircraft activity. The standard recommends a minimum projection period of 10 years and typically 20 – 30 year forecasts are provided for at New Zealand airports.

3.5 The predicted future noise contours form the basis of noise boundaries, where typically the Outer Control Boundary (OCB) is defined by the 55 dB Ldn contour and the Air Noise Boundary (ANB) is typically based on the 65 dB Ldn contour.

3.6 Like NZS 6805, NZS 6807 requires the prediction of noise contours which form the basis of land use planning controls and noise limits. Helicopter noise is generally considered to be more annoying than fixed wing aircraft noise therefore the threshold for land use controls in NZS 6807 is 50 dB Ldn which is 5 decibels lower than in NZS 6805.


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3.7 The noise levels used for the noise boundaries can vary depending on the existing land use at the airport and other factors. At Kapiti Coast Airport:

The NNA is the largest extent of the 55 dB Ldn fixed wing noise contour and the 50 dB Ldn helicopter noise contour.

The OCB is the largest extent of the 58 dB Ldn fixed wing noise contour and the 53 dB Ldn helicopter noise contour.

The ANB is the combined 65 dB Ldn contour for fixed wing aircraft and helicopters.

3.8 The noise boundaries then form the basis of land use planning controls and airport noise limits. Table 1 and 2 in NZS 6805 recommend that within the ANB:

“new residential, schools, hospitals or other noise sensitive uses are prohibited. Steps shall be taken to provide existing residential properties with appropriate acoustic insulation to ensure a satisfactory internal noise environment. Alterations or additions to existing residences or other noise sensitive uses shall be permitted only if fitted with appropriate acoustic insulation”

3.9 Within the OCB:

“new residential schools, hospitals or other noise sensitive uses should be prohibited unless a district plan permits such uses, subject to a requirement to incorporate appropriate acoustic insulation to ensure a satisfactory internal noise environment. Alterations or additions to existing residences or other noise sensitive uses should be fitted with appropriate acoustic insulation and encouragement should be given to ensure a satisfactory internal environment throughout the rest of the building”

3.10 New noise sensitive activities developing outside the OCB are considered to be appropriate and require no additional acoustic insulation or other mitigation measures.

4.0 EARLIER INPUT FROM MDA

4.1 In February 2013, MDA was engaged by Kapiti Coast Airport Limited (“KCAHL”) to:

a) Re-examine the Aircraft Noise Contours contained in the Proposed Plan to take into consideration any changes that may have occurred in the forecasted aircraft types, movements and tracks since the original contour calculation

b) Review and provide commentary and advice on the appropriateness of the airport-related noise rules in the Proposed Plan (Chapters 2, 6 and 12)

4.2 Based on noise modelling of the future forecasted movements (provided by KCAHL), the airport noise boundaries did not need to be changed as they provided adequate protection to the airport and were sufficiently large to accommodate the projected future growth to 2026.


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4.3 With regard to the airport related noise rules in the Proposed Plan, we recommended a number of changes which informed submissions on the Proposed Plan and we also engaged with Malcolm Hunt regarding the noise rules in Chapter 12. Our suggested changes mainly sought consistency with NZS 6805 and NZS 6807 and tidying up the sound insulation controls for noise sensitive receivers in the OCB and ANB.

4.4 Most of our recommended changes were accepted in the SEV with a number being addressed and agreed upon in the Technical Officer's Report on Chapter 12, and with some residual concerns being addressed in the Officer's Response referred to above.

4.5 Our suggestion to move from a DnT,w type control to an internal noise criterion to align with other New Zealand airports was not implemented. However, I consider the accepted criteria satisfactory as the sound insulation controls that were implemented will provide adequate sound insulation to noise sensitive activities in the Aircraft Noise Areas.

5.0 REMAINING ISSUE: NOISE SENSITIVE DEVELOPMENT IN THE AIRPORT ZONE

5.1 In its submission, KCAHL have requested changes to Rules 6G.1.13 relating to noise sensitive development in the Airport Zone (beyond the NNA). I understand that the proposed change is requested to enable noise sensitive activities (residential) to develop on the western side of the main runway outside the NNA, and consistent with the approach to managing aircraft noise in the adjoining zones. This area is highlighted in blue on Figure 1 below. I understand that the most likely location for development would be to the southwest of the blue area at the end of Avion Tce. Figure 1: Potential Location of Noise Sensitive Development


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5.2 Development beyond the NNA would be exposed to noise levels of less than 55 dB Ldn from fixed wing aircraft and less than 50 dB Ldn from helicopters.

5.3 As discussed in Section 3.0, noise sensitive development outside 55 dB Ldn for fixed wing aircraft and outside 50 dB Ldn for helicopters is viewed generally as acceptable in NZS 6805 and NZS 6807 and no noise mitigation is required at these noise levels.

5.4 Therefore it is considered that development of noise sensitive activities in this area would be acceptable from an aircraft (and helicopter) operational noise perspective (and at those levels would not likely generate reverse sensitivity effects on KCAHL's operations), and no further sound insulation or other mitigation measures would be required.

5.5 However, noise from aircraft and helicopter operations are not the only noise that could potentially occur in the Airport Zone. There are various other activities in the zone, including ancillary activities to the airport which in the future have the potential to create noise and disturbance to adjacent noise sensitive activities.

5.6 It appears that the land on the western side of the runway is generally undeveloped with the only ancillary activities currently occurring in this area being the terminal to the north. Therefore the current noise levels are likely to be low for sites not near the terminal building.

5.7 However, this does not preclude noisy ancillary airport activities (such as aircraft maintenance) being established in the future. As the land is not proposed to be rezoned, noise sensitive activities allowed to build in the Airport Zone could potentially be exposed to high noise levels from ancillary airport activities, as Rule 12D.1.6 does not have noise limits for noise emissions from Airport Zoned sites to Airport Zoned sites. It is this potential noise effect that needs to be managed adequately to ensure that reverse sensitivity effects on the ancillary activities do not occur, and to ensure that people residing in the Airport Zone (beyond the NNA) are not exposed to an unreasonable level on noise from ancillary activities in the zone.

5.8 There are currently no rules in the Proposed Plan that control either the noise emissions from ancillary activities in the Airport Zone, or sound insulation criteria for noise sensitive receivers in the Airport Zone. There is need for a rule to ensure noise levels from ancillary airport activities received at noise sensitive developments in the Airport Zone (beyond the NNA) are acceptable.

5.9 In my view the best way to adequately manage and mitigate noise emissions from ancillary activities in the Airport Zone to noise sensitive activities in the same zone would be to set noise limits for noise emissions in the Airport Zone at the boundary of any site in that same zone that is used for noise sensitive activities.

5.10 This would mean amending Rule 12D.1.9 to include a noise limit for noise emitters in the Airport Zone at sites used for noise sensitive activities in that same zone. It is considered that the following amendments to Rule 12D.1.9 would be acceptable.


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Table 1: Recommended Amendment to Rule 12D.1.9

9. Noise from any activity other than aircraft operations or engine testing, construction, maintenance and demolition work within the Airport Zone.

1. Activities shall not exceed the following levels at the boundary of any adjoining Living Zone site, and the notional boundary of any residential building in any adjoining Rural Zone or the notional boundary of any building used for a noise sensitive activity in the Airport Zone but outside the Noise Notification Area in the Plan :

7.00am to 10.00pm 50 dBLAeq(15 min) 10.00pm to 7.00am 45 dB LAeq(15 min) During the night time hours (10.00pm - 7.00am) no noise event shall exceed 75 dB LAFmax

2. [Clause deleted]

3. All noise resulting from construction, maintenance or demolition work shall be measured and assessed in accordance with New Zealand Standard NZS 6803:1999 Acoustics – Construction Noise.

4. The following activities are exempt from standard 1 above:

A) Any warning device used by emergency services for emergency purposes

B) Noise from fixed plant that is used solely for emergency purposes. Examples of such equipment are alarms, standby generator sets that are used to supply electricity only at times of electrical supply failure, or for plant used only during life threatening situations such as smoke fans or sprinkler pumps and is not used to generate power for the national grid.

C) Vehicles on public roads or trains on rail lines, including at railway yards, railway sidings or stations and level crossing warning devices.

5.11 One other way to mitigate noise emissions from ancillary airport activities is by implementing sound insulation controls for the receiver. Sound insulation controls ensure that the internal noise environment in dwellings is acceptable, however they do not control the outdoor amenity and external noise environment. Thus it is my opinion that sound insulation is not a complete mitigation solution.

5.12 People generally have a desire to use their outdoor areas and an expectation to be able to spend time in the garden, entertain guests outdoors and leave doors and windows open during summer. In these situations, the level of ancillary noise exposure cannot be practicably mitigated by sound insulation rules.

5.13 On the basis that the recommended amendments to Rule 12D.1.9 are accepted, I consider that amending Rule 6G.1.13 to allow for residential development in the Airport Zone (but outside the NNA) would be acceptable from a noise perspective.


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6.0 CONCLUSIONS

6.1 I have reviewed KCAHLs request to amend Rule 6G.1.13 to allow for noise sensitive development on the western side of the main runway beyond the NNA.

6.2 I consider that it is appropriate to amend rule 6G.1.13 to allow noise sensitive development provided Rule 12D.1.9 is amended to limit the amount of noise emitted from ancillary activities in the Airport Zone to noise sensitive activities in the Airport Zone.


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APPENDIX A GLOSSARY OF TERMINOLOGY

Air Noise Boundary (ANB)

The boundary shown as such on the planning maps and which encompasses land within the predicted future noise contours of 65dBA Ldn for general aircraft (including both fixed wing and helicopter) operations.

Outer Control Boundary (OCB)

The boundary shown as such on the planning maps and which encompasses land that is subject to planning controls for noise sensitive activities. The Outer Control Boundary is derived from the predicted future noise contours of 58 dBA Ldn for general aircraft operations and 53 dBA Ldn for helicopter operations.

Airport Noise Notification Area (NNA)

The boundary shown as such on the planning maps and which encompasses land that is subject to higher than usual levels of aircraft noise which some people may find annoying.

Aircraft Noise Contours Referring to the Air Noise Boundary, Outer Control Boundary and Airport Noise Notification Boundary.

Noise Sensitive Activities Residential accommodation of all types, hotels, motels, pre-schools, schools, educational facilities, libraries, child care centres, and hospitals.

Noise A sound that is unwanted by, or distracting to, the receiver.

dB Decibel The unit of sound level. Expressed as a logarithmic ratio of sound

pressure P relative to a reference pressure of Pr=20 Pa i.e. dB = 20 x log(P/Pr)

dBA The unit of sound level which has its frequency characteristics modified by a filter (A-weighted) so as to more closely approximate the frequency bias of the human ear.

A-weighting The process by which noise levels are corrected to account for the non-linear frequency response of the human ear.

Ldn The day night noise level which is calculated from the 24 hour LAeq with a 10 dB penalty applied to the night-time (2200-0700 hours) LAeq.

NZS 6805:1992 New Zealand Standard NZS 6805:1992 “Airport Noise Management and Land Use Planning”

NZS 6807:1994 New Zealand Standard NZS 6807:1994 “Noise Management and Land Use Planning for Helicopter Landing Areas”

NZS 6802:2008 New Zealand Standard NZS 6802:2008 “Acoustics – Environmental Noise”

AS/NZS ISO 717.1:2004 Australian/New Zealand Standard AS/NZS ISO 717.1:2004 “Acoustics – Rating of sound insulation in buildings and of building elements. Part 1: Airborne Sound Insulation”

Sound Insulation When sound hits a surface, some of the sound energy travels through the material. ‘Sound insulation’ refers to ability of a material to stop sound travelling through it.

DnT,w + Ctr & Dtr,2m,nT,w + Ctr Weighted Standardised Level Difference A single number rating of the sound level difference between two rooms. Typically used to measure the on-site sound insulation performance of a building element such as a wall, floor or ceiling.

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APPENDIX B NOISE RULE EXCERPTS – SUBMITTER ENGAGEMENT VERSION

Rule 6G.1.13 Regarding Residential Activities in the Airport Zone


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Rule 12D.1.9 regarding noise emissions from the Airport Zone

This document may not be reproduced in full or in part without the written consent of Marshall Day Acoustics Limited

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MEMO

Project: Kapiti Coast Airport Private Plan Change 84

Document No.: Mm 00X

To: Kapiti Airport Holdings Limited Date: 26 January 2017

Attention: Brigid Kelly Cross Reference:

Delivery: [email protected] Project No.: 2013046A

From: Laura McNeill No. Pages: 3 Attachments: No

CC: Aidan Cameron Poul Israelson Brigid Kelly

Subject Airport Zone Activity Status – Noise Sensitive Activities

Introduction

It is understood that Kapiti Coast Airport Holdings Limited (KCAHL) is currently undergoing a private Plan Change to amend certain rules in the Kapiti Coast District Plan (District Plan). Marshall Day Acoustics (MDA) has been requested to provide advice on the noise related aspects of this Plan Change.

The noise related amendments relate to the activity status of noise sensitive activities within the Airport Zone between the Noise Notification Boundary (NNB) and the Air Noise Boundary (ANB) (refer Figure 1). Development of noise sensitive activities within the ANB or outside the NNB has already been dealt with in previous District Plan Review and Plan Changes. To give context, the rules relating to these boundaries currently:

Prohibit any noise sensitive activities developing within the NNB

Provide for noise sensitive activities to develop outside the NNB under a discretionary status

MDA considers that these controls are appropriate and align with the provisions of New Zealand Standard NZS 6805:1992 “Airport Noise Management and Land Use Planning” (NZS 6805).

Between the NNB and ANB, KCAHL seek to make the following amendment:

Amend Rule D.9.1.6(i) by removing the prohibited activity status of noise sensitive activities not specifically provided for as a permitted activity and provide for these as discretionary activities in Rule D.9.1.5

However, the Section 42A report recommends that the activity status is changed to non-complying instead of discretionary. Either way, amending the rule would allow noise sensitive activities to apply to develop in the blue shaded area shown on Figure 1 below between the green NNB and red ANB, albeit the application being more onerous under the non-complying activity status.

http://www.marshallday.com

mailto:[email protected]



Figure 1: Kapiti Coast Airport Aircraft Noise Areas

Noise Effects

Aircraft Noise

The aircraft noise levels between the NNB and ANB in this area would range from 55 - 65 dB Ldn from fixed wing aircraft. Table 2 of NZS 6805 recommends that “new noise sensitive uses should be prohibited unless a district plan permits such uses” within the 55-65 Ldn area. Our interpretation of this is that in the first instance, new noise sensitive uses should be prohibited.

However, the Standard recognises that in some situations, prohibition may not be pragmatic and therefore a fall back option is to acoustically insulate buildings. Situations where prohibition may not be pragmatic include where a noise sensitive land use is already well established and the land is almost fully developed or where there is extreme demand for developable land.

It is important to note that whilst houses between the NNB and ANB can be treated with acoustic insulation, most people prefer to be able to operate with open windows. In addition, the outdoor noise environment cannot be mitigated and would be compromised. This is why in the first instance prohibition is favoured.




Other Noise

Aircraft noise is not the only noise source that could occur in the Airport Zone. There are various other activities in the zone, including ancillary activities to the airport which in the future have the potential to create noise and disturbance to adjacent noise sensitive activities.

It appears that the land on the western side of the runway is generally undeveloped with the only ancillary activities currently occurring in this area being the terminal to the north. Therefore, the current noise levels are likely to be low for sites not near the terminal building.

However, this does not preclude noisy ancillary airport activities (such as aircraft maintenance) being established in the future. As the land is not proposed to be rezoned, noise sensitive activities allowed to build in the Airport Zone could potentially be exposed to noise from ancillary airport activities.

In my previous evidence I suggested that Rule 12D.1.6 be amended to limit noise emissions (to 50 LAeq day/ 45 LAeq night) from the Airport Zone to noise sensitive activities in that same zone. If this recommendation has been accepted it is considered that the noise levels from noise other than aircraft operations would be reasonable between the NNB and ANB.

Discretionary vs Non-Complying

As a principle we strongly advise against residential development between 55-65 dB Ldn as in our opinion this will cause problems for the airport in the future due to complaints from individuals and/or community action groups. This has occurred at many airports in New Zealand, Australia and internationally and in some cases has resulted in restrictions on the number and frequency of flights, curfews and other such limitations.

From a pure noise perspective, it would be our recommendation to keep the prohibited status currently in the plan. However, as mentioned above the Standard recognises that in some situations, prohibition may not be pragmatic and therefore a fall back option is to acoustically insulate buildings. To reiterate, situations where prohibition may not be pragmatic include where a noise sensitive land use is already well established and the land is almost fully developed or where there is extreme demand for developable land.

Malcolm Hunt has argued in his report that a non-complying status is preferable due to:

Potential noise from taxiing and engine testing

Noise from ancillary airport activities

With regard to engine testing and taxiing noise, we agree that there is the potential for noise effects from these noise sources. However, with regard to taxiing, we already have noise modelling of taxiing which shows that the effects do not extend beyond the NNB.

Noise from ancillary airport activities was dealt with in my previous evidence where an amendment to Rule 12D.1.9 was recommended to limit noise received at noise sensitive receivers in the Airport Zone from noisy activities in the same zone. Previously this rule only applied where noise sensitive activities were located in the rural or living zones. It is suggested that a similar amendment is made to the engine testing Rule referenced in Malcolm Hunts report.

Overall it is recommended that a non-complying activity status is preferred to discretionary. It is our opinion that a non-complying status sends a clear message to potential developers or residents that noise sensitive activities are not normal or expected in this zone rather than normalising such activity, which in our opinion would not be preferable to discretionary.

We trust this information is satisfactory. If you have any further questions please do not hesitate to contact us.
