NZDF Temporary Military Training Activities for Palmerston North City Council File No. N1447TMT Version 22 nd June 2014 Nigel Lloyd Director of Acoustic Services E-mail: nigel@acousafe.co.nz 98
NZDF Temporary Military Training Activities 1. Introduction Acousafe has been asked to review the noise information provided to Council by the New Zealand Defence Force ( NZDF ) regarding noise from Temporary Military Training Activities ( TMT ) with respect to Proposed Plan Change 15 for the Rural Zone. NZDF is seeking to place a generic requirement for their TMT in each District Plan. This generic requirement is based on a study undertaken by Malcolm Hunt Associates 1 ( The Hunt Report ). This review takes that report on face value. 2. NZDF Position NZDF has supplied a generic table for TMT as a Permitted Activity provided that it complies with the set-back requirements as set out in Appendix A. In a covering explanation dated February 2013 NZDF acknowledges that noise effects from temporary military training activities need to be appropriately controlled within the District Plan. NZDF wishes to make sure that the noise standards included in the Proposed Plan are up-to-date, appropriate for the type of noise generated, and relatively simple to understand and assess compliance with. To this end, NZDF has commissioned professional acoustic advice on appropriate standards to control noise effects from temporary military training activities. Based on this advice, NZDF has developed revised noise control permitted activity standards that it is seeking to have included in proposed district plans nationwide. NZDF summarised the revised standards as dividing noise sources from temporary military training activities into three categories: weapons firing and explosions; other mobile sources such as vehicles and earthmoving equipment; and fixed noise sources such as power generators and water pumping. Each of these noise sources has different noise characteristics, and therefore a different set of standards should apply for controlling noise. The division allows a more comprehensive and appropriate method for controlling noise from temporary military training activities. For weapons firing and explosives, the noise control standard used is separation distances between the activity and any dwelling, residentially zoned site, or building used for residential, educational or healthcare purposes. Four separation distances are specified a night time and daytime distance for firing of live ammunition and explosives, and a night time and daytime distance for firing of blank ammunition, which is less noisy than live firing. The distances have been arrived at after review and analysis of data measured from real military activities, to ensure that the sound levels received at the specified distance will be reasonable (generally less than 55 dba for daytime and less than 45 dba for night time). Using separation distance as a 1 New Zealand Defence Force, Re-Assessing Noise from Temporary Military Training in New Zealand, District Plan Recommendations MHA Reference 932-0F3, January 2013. 99
NZDF Temporary Military Training Activities 2 standard has the advantage of being an easy to comply with and easy to monitor standard. For mobile noise sources (other than weapons firing and explosives), compliance with the construction noise standards is recommended, as this standard most appropriately addresses this type of noise. For fixed noise sources, which can be located to ensure compliance with standards, dbl Aeq levels are specified, in line with NZS6802:2008 Acoustics Environmental Noise. This is considered the most appropriate way to control noise levels from these sources. NZDF has also considered noise from helicopters associated with temporary military training activities. NZDF proposes the use of NZS6807:1994 Noise Management and Land Use Planning for Helicopter Landing Areas to control this type of noise. Note on vibration: the acoustic advice received by NZDF also addresses vibration effects. In summary, the noise standards proposed are considered adequate to also address vibration effects. Therefore, no additional permitted activity standard is required in the Proposed Plan to address vibration effects from temporary military training activities. 3. Discussion The NZDF position was first heard by the Hearing on submissions to the Horowhenua District Plan. Nigel Lloyd advised Horowhenua District Council on the NZDF submission but was not called by Council to give evidence at that hearing. Mr Malcolm Hunt gave evidence on behalf of NZDF. What NZDF is seeking is for TMT to take place, as a Permitted Activity, if it can comply with the large setback distances from noise sensitive activities. These setback distances are required to ensure reasonable noise limits are not exceeded. The distances involved are: Live firing of weapons and single or multiple explosive events - 1,500m daytime and 4,500m at night. Daytime is 0700hrs to 1900hrs and night-time is 1900hrs to 0700hrs. Our understanding from the information provided in the Hunt Report is that these distances are based on the noisiest Category 2 equipment which is the Howitzer. When fired the Howitzer generates a noise level of 94dB L Amax (106dBZ Peak sound level) at a distance of 1,000 metres. For firing of blank ammunition the distances are reduced to 750 metres daytime and 2,250 metres night-time. These distances are conditional on a noise management plan being prepared (see Appendix A) and on the following noise limits being met Daytime (a) Daytime sound levels do not exceed a peak sound pressure level of 120dBC when measured at or within the 20 metre notional boundary 100
NZDF Temporary Military Training Activities 3 Night-time of any dwelling, residentially zoned site, building used for residential, educational or health care purposes. (b) Night time sound levels do not exceed a peak sound pressure level of 90dBC when measured at or within the 20 metre notional boundary of any dwelling, residentially zoned site, building used for residential, educational or health care purposes. The first issue to be decided is whether it is appropriate to roll out a standard set of desired provisions for incorporation into district plans generally. The point of the Palmerston North District Plan is that it allows consideration to be given to the protection of the local environment taking into account the particular circumstance of the Palmerston North District. What NZDF seeks is, at the extreme, to make the firing of a Howitzer a Permitted Activity in the district, both during the day and at night, notwithstanding the fact that it would be unlikely to be able to comply with the set-back provisions of its own performance standards. As an aside we note that the noise performance standards only protect noise sensitive activities and there is no consideration for the protection of stock and wildlife from high level impulsive noise. Ultimately we do not disagree with the provisions of the NZDF submission (excepting for night-time live firing). It does help to clarify the very high levels of noise that are associated with TMT and sets out the separation distances that are required to provide an adequate buffer to protect noise sensitive activities. What we are concerned about is that NZDF seeks to place these requirements in each of the District Plan sections. Our advice to the hearing committee for the Institutional Zone (PC11) was that: NZDF accepts that traditional military training exercises do not need to take place on an Institutional Zone site but states that the institutional zone is ideal for some types of training exercises, for example training by the bomb squad. Some military training needs to take place indoors, and in 'live' situations, such as might be found at an education facility. I agree that traditional military training should not take place inside the Institutional Zone which includes places of learning, including student accommodation, and hospitals. It can be seen from the NZDF Generic District Plan for Permitted Activity Noise Standards that the buffer distances required for the noise of live firing and firing of blank ammunition cannot be accommodated within sites in the Institutional Zone. One option is to put the NZDF Generic Table in the Plan which simply seems to basically prevent nearly all TMTA from occurring anywhere in the city. Clearly it is ludicrous to provide for the firing of Howitzers and mortars in the city precincts. NZDF recognises this fact. However I am concerned that placing the Generic Table in the Plan will expose it to ridicule. As far as the example given for the bomb squad operations this seems to be an appropriate activity (assuming that bombs are not actually going 101
NZDF Temporary Military Training Activities 4 to be detonated) and is likely to be able to be undertaken in compliance with the proposed District Plan noise limits, especially in the Institutional Zone which provides for cross campus controls and relies upon the institutions themselves to manage their noise. I therefore recommend that the noise limits for Temporary Military Training Activities in the city be the District Plan limits for each Zone. I continue to hold this opinion with respect to the TMT in the Central Areas, Business Zones and Residential Zone (the Central Areas and Business Zone Sectional Plan change hearings have passed). There would be remote areas of the Rural Zone where TMT might be appropriate but generally the areas are too densely populated to accommodate TMT (with respect to live firing). 4. Night-time Live Firing NZDF seeks to make live firing of weapons a permitted activity at night provided it complies with the peak sound pressure noise limit of 90dBC. While we accept that this is a strict noise limit we remain concerned with the context of weapons being fired at night upsetting residents who might be some distance from the activity. We consider that night-time live firing should not be a Permitted Activity. As a Discretionary Activity then other impacts could be considered (such as the impact on stock and wildlife) and an assessment made on community consultation that might be appropriate. Making live firing at night a Permitted Activity would also have implications for the permitted baseline. 5. Fixed Noise Sources The Generic Table seeks a stricter noise regime for fixed noise sources using the least stringent noise limits as recommended by NZS6802:2008 Acoustics Environmental noise. NZDF has requested these criterion and they contend they will provide a better protection to residents. The proposal is to establish noise limits at the notional boundary of any dwelling, residentially zoned site, or building used for residential, educational or healthcare purposes. I concur with this. The notional boundary is defined as a line 20 metres from any side of a dwelling or the legal boundary where this is closer to the dwelling. Rural noise limits in the District Plan apply at the site boundary rather than the notional boundary. This is to protect the amenity of adjacent land for its future use by noise sensitive activities. However because TMT is temporary, then it is appropriate to apply the noise limits at the notional boundary. 6. Mobile Noise Sources The proposal is to control mobile noise sources by reference to the noise limits set out in Tables 2 and 3 of NZS6803:1999 Acoustics Construction Noise, with reference to construction noise taken to refer to other, mobile noise sources. Table 3 applies to industrial or commercial areas and would therefore be appropriate for the Airport Zone. Given that TMT is provided for a maximum of 30 days at a time then we consider this to be an appropriate approach. 102
NZDF Temporary Military Training Activities 5 7. Helicopter Noise With respect to helicopters, the District Plan already applies NZS6807:1994 Noise Management and Land Use Planning for Helicopter Landing Areas through reference to NZS6802:2008. The Noise Standard for helicopter landing areas applies where ten or more flight movements occur in any month or where flight movements are likely to result in a maximum sound level (L max ) of 70dBA at night-time or 90dBA during daytime on any residential zone or within the notional boundary of any rural land. Otherwise Table 1 of NZS6807 contains a series of acceptable noise dose limits for day/night operations and L Amax limits for night-time. It is difficult to see how these limits and the process in determining them would be appropriate for short term helicopter activity by NZDF for temporary training purposes. However given that there is no alternative to NZS6807:1994 then it is recommended that this be accepted. 8. Recommendation Because of the advanced condition of the District Plan (with a number of Sectional Plan Change hearings having already taken place) it is recommended (in consultation with PNCC) that the Noise Standards for TMT be adopted specifically for the following Zones: - Rural Zone - Airport Zone - Flood Protection Zone, and - The various Recreation Zones. Our recommendation is that TMT be a Discretionary Activity. The recommended assessment criteria for TMT involving live firing of weapons, single or multiple explosive events and firing of blank ammunition are as follows: The noise impact on noise sensitive activities, stock and wildlife, including the peak sound levels resulting from impulsive noise. The provision of a noise management plan that specifically identifies the likely noise impacts for the area and describes the measures required to avoid or mitigate these. The programme for notification and communication with occupiers and owners of affected sites prior to the activities commencing, including updates during the event. The method for following up any complaints received during or after the event including communications with Council. Noise from mobile noise sources (excluding those set out above) including personnel, light and heavy vehicles, self-propelled equipment, earthmoving equipment would comply with the noise limits set out in Table 2 and Table 3 of NZS6803:1999 Acoustics Construction noise. Fixed stationary sources would comply with the following noise limits: Sound emissions from fixed (stationary) noise sources, excluding live firing of weapons and single or multiple explosive events, associated with Temporary Military Training Activities in the Rural Zone when 103
NZDF Temporary Military Training Activities 6 measured at any point within any land zoned for residential purposes or at the notional boundary of any noise sensitive activity in the Rural Zone (other than site from which the noise is emitted or a road) shall not exceed the following: 7:00am - 7:00pm 7.00pm to 10.00pm 10:00pm - 7:00am Night-time L max 10:00pm - 7:00am 55dB L Aeq(15mins) 50dB L Aeq(15mins) 45dB L Aeq(15mins) 75dBA L max Explanation: fixed (stationary) noise sources (other than firing of weapons and explosives) include noise sources such as power generation, heating, ventilation or air conditioning systems, or water or wastewater pumping/treatment systems. 9. Conclusions Temporary Military Training Activities generate high levels of noise and, at the extreme, it is not appropriate to provide for these as a Permitted Activity. Such activities require a more in-depth analysis which would be appropriately undertaken as a Discretionary Activity for example. There might be limited remote locations in the Rural Zone where such activities could take place using the separation distances identified by NZDF, such as in the Tararua Ranges, but generally the population density in the Palmerston North District does not allow the required separation distances to be achieved. As such the TMT that involve the highest category of activity (live firing or firing of blank ammunition) are appropriately dealt with as Discretionary Activities. This allows the implication of gunfire on neighbouring noise sensitive activities and the impact on stock and wildlife to be considered. Otherwise recommendations are made for control of mobile noise sources using the Construction Noise Standard (NZS6803:1999) and for control of stationary noise sources such as power generation and pumps etc. 104
NZDF Temporary Military Training Activities APPENDIX A NZDF Submission Seeking Permitted Activity Noise Standards for Temporary Military Training Activities 105
NZDF Temporary Military Training Activities 2 Rule x.x: Temporary Military Training Activities are permitted activities, provided they comply with the noise standards specified in Table x below. Table x Activity Noise Controls Temporary Military Training Activities Type of military noise source Standards Time (Monday to Sunday) Separation distance required to any dwelling, residentially zoned site, or building used for residential, educational or healthcare purposes 1. Live firing of weapons and single or multiple explosive events 0700 to 1900 hours At least 1500m Less than 1500m if conditions (a) and (c) below are complied with 1900 to 0700 hours At least 4500m Less than 4500m if conditions (b) and (c) below are complied with 2. Firing of blank ammunition 0700 to 1900 hours At least 750m Less than 750m if conditions (a) and (c) below are complied with 1900 to 0700 hours At least 2250m Less than 2250m if conditions (b) and (c) below are complied with 106
NZDF Temporary Military Training Activities 3 Conditions to be complied with if minimum separation distances for sources (1) and (2) cannot be met: (a) Daytime sound levels do not exceed a peak sound pressure level of 120 dbc when measured at or within the 20 metre notional boundary of any dwelling, residentially zoned site, building used for residential, educational or health care purposes. (b) Night time sound levels do not exceed a peak sound pressure level of 90 dbc when measured at or within the 20 metre notional boundary of any dwelling, residentially zoned site, building used for residential, educational or health care purposes. (c) The activity is undertaken in accordance with a Noise Management Plan prepared by a suitably qualified expert and approved by Council at least 15 working days prior to the activity taking place. The Noise Management Plan shall, as a minimum, contain: A description of the site and activity including times, dates, and nature and location of the proposed training activities. Methods to minimise the noise disturbance at noise sensitive receiver sites such as selection of location, orientation, timing of noisy activities to limit noise received at sensitive receiver sites. A map showing potentially affected noise sensitive sites and predicted peak sound pressure levels for each of these locations. A programme for notification and communication with the occupiers of affected noise sensitive sites, and Council, prior to the activities commencing, including updates during the event. A method for following up any complaints received during or after the event, and any proposed de-briefing meetings with Council. 3. Mobile noise sources, excluding sources (1) and (2) Compliance with the noise limits set out in Tables 2 and 3 of NZS6803:1999 Acoustics Construction Noise, with reference to construction noise taken to refer to other, mobile noise sources* Note: mobile noise sources (other than firing of weapons) include sources such as personnel, light and heavy vehicles, self-propelled equipment, earthmoving equipment 107
NZDF Temporary Military Training Activities 4 4. Fixed (stationary) noise sources, excluding sources (1) and (2) Time (Monday to Sunday) Noise level at the 20 metre notional boundary of any dwelling, residentially zoned site, or building used for residential, educational or healthcare purposes* 0700 to 1900 hours 55 db L Aeq (15 min) 1900 to 2200 hours 50 db L Aeq (15 min) 2200 to 0700 hours the next day n.a. 45 db L Aeq (15 min) 75 db L AFmax Note: fixed (stationary) noise sources (other than firing of weapons and explosives) include noise sources such as power generation, heating, ventilation or air conditioning systems, or water or wastewater pumping/treatment systems. 5. Helicopter landing areas Compliance with noise limits set out in NZS6807:1994 Noise Management and Land Use Planning for Helicopter Landing Areas.* * Noise levels shall be measured in accordance with NZS6801:2008 Acoustics Measurement of Sound 108