SUBMISSION BY THE BOARD OF AIRLINE REPRESENTATIVES OF NEW ZEALAND ON THE DRAFT QUEENSTOWN LAKES DISTRICT COUNCIL DRAFT PLAN Background to BARNZ BARNZ is an incorporated society comprising 19 member airlines operating scheduled and code share international and domestic services. Its members are: Full membership: Air Calin Air Pacific Air Tahiti Nui Cathay Pacific Airways China Southern Fieldair LAN Airlines Qantas Airways (incl Jetstar) Tasman Cargo Airlines Virgin Australia Air New Zealand (Group) Airwork Air Vanuatu China Airlines Emirates Korean Air Malaysia Airlines Singapore Airlines Thai Airways International Associate membership: Menzies Aviation (NZ) Ltd All of the international airlines which operate scheduled services into Queenstown Airport are members of BARNZ. The objectives of BARNZ include: the establishment of a recognised means of communication between member airlines, on the one hand, and other bodies whose interests or actions affect member airlines and the aviation industry, on the other hand; representation of members in matters affecting their common interests; and determining the position of members on legislative, judicial and administrative actions affecting the provision of air services and the representation of member airlines before decision-making bodies. One of the key areas of BARNZ s work relates to the management of noise issues around airports. Generally, airports are sited away from dense areas of population in order to avoid conflicts between aircraft operation and noise sensitive activities. BARNZ represents the airlines, and works with the airports, in preventing noise sensitive activities locating or developing within the air noise boundaries that surround the airports. This work involves interactions with the local and regional councils. BARNZ is also an industry representative on many of the community noise committees established by the airports. 1 P a g e
Queenstown Airport Queenstown Airport is the main airport serving the Queenstown Lakes District and to a large extent is the gateway to the southern South Island. It accommodates over 1.4 million passengers each year, and is New Zealand s fourth largest airport. Queenstown Airport has experienced exponential growth over the last ten years. International passenger volumes have increased ten-fold from 39 000 passengers in 2005 to 398 000 in 2015. Domestic passengers volume have also increased significantly, nearly doubling in the last ten years from 570 000 in 2005 to 1 001 000 in 2015. These passengers travel on some 5700 aircraft movements a year. More than 350 people work at the airport at over 60 different businesses. This activity significantly enables the tourism and ski field markets in Queenstown Lakes District, and therefore makes a critical contribution to the Queenstown regional economy. The New Zealand Airports Association has commissioned economic work which estimated that the annual economic benefit to the region enabled by the airport amounts to $275m. All of this activity is directly related to, and depends on, the operation of aircraft flying into and out of Queenstown Airport. Anything that may adversely affect aircraft activity at the Airport directly affects the activities of the airline members of BARNZ as well as the community. Restrictions on the activities of the airlines will in turn adversely affect businesses and jobs which rely on air services to and from Queenstown Airport. These figures by themselves demonstrate how important it is to the regional economy that Queenstown Airport operates efficiently. In order to be efficient, there should be as few restrictions on aircraft operations as are compatible with other activities taking place in Queenstown. The Queenstown Lakes District Council s efficient stewardship of this important asset is therefore critical. Key issue Protection of Airport from Reverse Sensitivity Reverse sensitivity is the term used to refer to the effects of the existence of an activity on other activities in their vicinity, e.g. the noise generated by airport operations on activities sensitive to airport noise. The establishment of noise sensitive activities in the vicinity of airports has the potential to create, and indeed already in some other locations has created, pressure for limits on airport activity including curfews and operational restrictions, e.g. Wellington and Sydney, Australia. Once noise sensitive activities are established in an airport area, the people affected, but not directly associated with the activity, are likely to complain about aircraft noise, even though they and the developers of the properties have always known that the property is subject to aircraft noise. Over the last 10 years airlines have invested in new operating technologies and quieter aircraft. Aircraft manufacturers are required by the International Civil Aviation Organisation standards and the airlines to achieve increasingly quieter aircraft specifications to ensure reductions in noise. In addition, Queenstown Airport is developing noise mitigation packages (insulation and ventilation treatment) for qualifying properties in the Air Noise Boundary. These costs are borne by Queenstown Airport in the first instance and are subsequently passed to the airlines via landing charges. The Queenstown Lakes District Council needs to ensure that the Proposed District Plan balances the needs of the community with the continued efficient operation of the airport. In particular, BARNZ considers that the Proposed District Plan needs to provide greater recognition of, and protection of the airport from, reverse sensitivity. 2 P a g e
The potential implications of reverse sensitivity cannot be understated. If new, more onerous restrictions were to be introduced affecting aircraft operations, there would be substantial implications for regional and national tourism and commerce. These would likely range from reduction in passenger and freight capacity through to higher passenger and freight charges and the possible creation of stranded airport assets as airlines seek to mitigate the effects of increased costs. Relief Sought: BARNZ considers that the current Proposed District Plan contains inadequate protection for the airport, as a regionally significant piece of infrastructure, from the risks of reverse sensitivity. There are four key changes requested by BARNZ to strengthen the protection of Queenstown Airport from reverse sensitivity: The addition of specific protection of regionally significant infrastructure from reverse sensitivity in the economic objectives and policies contained in the Strategic Directions chapter The strengthening of the objectives and associated policies in the Urban Development chapter limiting urban development to areas which will not create reverse sensitivities or otherwise detrimentally impact on regionally significant infrastructure Maintaining the current maximum site density of new development in the Outer Control Boundary at one dwelling per 450m2. (as per the operative plan Maintaining the current minimum allotment size of 600m2 within the Low Density Residential Zone and the OCB (as per the operative plan). BARNZ s submissions on specific provisions within the draft Queenstown and Lakes District Plan are as follows: Ref. Issue Submission Definitions The definition of Activities Sensitive to Include educational classrooms, Aircraft Noise (ASAN) omits to include educational buildings and educational classrooms, educational educational playgrounds within the buildings and educational playgrounds. These are clearly activities sensitive to definition of Activities Sensitive to Aircraft Noise. aircraft noise and they were included within the definition of ASAN in PC19. 3.2.1.5 BARNZ supports this objective to maintain and promote the efficient operation of the District s infrastructure, including designated Airports, key roading and communication technology networks. However BARNZ considers the objective needs to be further supported with specific policies specifically addressing the need to avoid reverse sensitivity which may be caused by sensitive activities establishing in areas which may cause restrictions to be applied to the operation and development of 3.2.2.1 An additional objective needs to be added to objective 3.2.2.1 specifically directing that urban development avoids Support objective 3.2.1.5. Add a new policy supporting objective 3.2.1.5: Avoid reverse sensitivity effects on significant infrastructure by requiring other urban subdivision, use and development to not occur in a location or form that constrains the use, operation, maintenance and upgrading of existing and planned significant Add an additional bullet to 3.2.2.1: in locations which avoid reverse sensitivity effects on significant 3 P a g e
the creation of reverse sensitivity effects on 3.2.2.1.3 Add a policy specifically directing that urban development avoids the creation of 4.2.1.2 There needs to be greater recognition within the Urban Development Objectives and policies of the need to avoid 4.2.3.1 There needs to be greater recognition within the Urban Development Objectives and policies of the need to avoid 4.2.3.8 This policy provides that land use within the Air Noise Boundary or Outer Control Boundary of the Queenstown Airport is managed to prohibit or limit the establishment of Activities Sensitive to Aircraft Noise. 4.2.4.2 There needs to be greater recognition within the Urban Development Objectives and policies of the need to avoid 4.2.4.3 This policy states Protect the Queenstown airport from reverse sensitivity effects, and maintain residential amenity, through managing the effects of aircraft noise within critical listening environments of new or altered buildings within the Air Noise Boundary or Outer Control Boundary. BARNZ questions the consistency of this policy (which refers to managing the effect of aircraft noise on new or altered buildings) with policy 4.2.3.8 which prohibits or limits the establishment of Activities Sensitive to Aircraft Noise in the Air Noise Boundary or Outer Control Boundary of Queenstown Airport. 7.4.11 This makes development within the Air Noise Boundary which is greater than one dwelling, unit or flat per site noncomplying. The Air Noise Boundary represents a predicted noise contour of 65 db Ldn. At other airports the development of new ASANs within this noise contour has been prohibited, which BARNZ considers would have been more appropriate. If new ASANs are Add an additional bullet to 3.2.2.1.3: that development occurs in locations and forms which avoid Add the words which avoids significant infrastructure to the end of policy 4.2.1.2. Add an additional bullet to 4.2.3.1: that development occurs in locations and forms which avoid BARNZ supports this policy. Add an additional bullet to 4.2.4.2: occurs in locations and forms which avoid reverse sensitivity effects on significant Amend policy 4.2.4.3 to read: Protect the Queenstown airport from reverse sensitivity effects, and maintain residential amenity, through: prohibiting or limiting the establishment of Activities Sensitive to Aircraft Noise in the Air Noise Boundary or Outer Control Boundary of Queenstown Airport; and managing the effects of aircraft noise within critical listening environments of new or altered buildings Between the Air Noise Boundary and the Outer Control Boundary BARNZ supports making development within the Air Noise Boundary which is greater than one dwelling, unit or flat per site noncomplying. 4 P a g e
being permitted within the Air Noise Boundary, then it is important to ensure that the density is limited through requiring a larger lot size and a larger area of land per dwelling, than for other areas in Queenstown not affected by aircraft noise. 7.5.3 This specifies the standard for acoustic insulation for new buildings and alterations and additions to existing buildings containing an ASAN within the Air Noise Boundary. BARNZ supports the requirement for acoustic insulation on new or altered ASANs in order to reduce potential Queenstown Airport. 7.5.4 This specifies the standard for acoustic insulation for new buildings and alterations and additions to existing buildings containing an ASAN between the Outer Control Boundary and the Air Noise Boundary. 7.5.6 This specifies the maximum site density for the Low Density Residential Zone of one dwelling per 300m 2 net site area, with an exemption for the Queenstown Heights Overlay Area, which has a larger net site area. BARNZ considers that 300m 2 is too great a level of density for development within the Air Noise Boundary and between the Outer Control Boundary and the Air Noise Boundary and will create increased Queenstown Airport. BARNZ supports this standard. BARNZ supports this standard. Add an additional exemption to 7.5.6 as follows: land within the Queenstown Airport Air Noise Boundary, or between the Outer Control Boundary and the Air Noise Boundary, where the maximum site density shall be one residential unit or dwelling per 450m 2 net site area. Chapter 17 BARNZ considers that the status quo in the operative plan should be maintained for land within the Air Noise or Outer Control Boundaries, which we understand is one dwelling per 450m 2. This can be achieved through providing for an exemption for land within the Air Noise Boundary or between the Outer Control Boundary and the Air Noise Boundary, along the same lines that an exemption is provided in the draft plan for the Queenstown Heights Overlay Area. Chapter 17 contains the provisions relating to the Airport Mixed use zone. This chapter commences by recording the importance of Queenstown Airport as the gateway to the District and in terms of it facilitating access and BARNZ supports chapter 17 in its entirety. 5 P a g e
economic activity in the local and broader regional economies as well as supporting the tourism industry. BARNZ supports the provisions of Chapter 17, especially the permitted status for any airport activity or airport related activity. 21.2.7 This policy and objective prohibits all new activity sensitive to aircraft noise on any rural zoned land within the Outer Control Boundary (which includes land within the air noise boundary) of Queenstown Airport 21.4.29 This portion of the activity table relates to activities within the outer control boundary (which includes the air noise boundary) of Queenstown Airport and gives effect to the policy and objective contained in 21.2.7 by making new activities sensitive to aircraft noise prohibited. 27.5.1 This activity table sets out the minimum lot size for subdivisions. For the low density residential zone a minimum lot size of 450m 2 is proposed. BARNZ considers that this is too small a minimum lot for land within the air noise boundary and/or the outer control boundary of Queenstown Airport. BARNZ supports this policy and objective. BARNZ supports prohibiting new ASANs on rural zoned land within the Outer Control Boundary. Add a new line to the activity table at 27.5.1 providing that land within the Queenstown Airport outer control boundary (which includes land within the air noise boundary) should have a minimum lot area of 600m 2. Designation for Queenstown Airport Ideally, no new ASANs should be permitted within this area due to its exposure to aircraft noise and the potential for reverse sensitivity effects on Queenstown Airport. However, if new ASANs are permitted, then a larger minimum lot size should be provided for so as to reduce the number of people exposed to aircraft noise. BARNZ understands that the operative plan provides for a minimum lot size of 600m 2 for low density land within the outer control boundary. Minimum lot size for land within the outer control boundary should continue to be 600m 2. The inclusion of a designation specifically relating to the activities and operation of Queenstown Airport is supported by BARNZ. BARNZ supports the Queenstown Airport. 6 P a g e