STATEMENT OF EVIDENCE OF CURT ROBINSON ON BEHALF THE AUCKLAND UTILITY OPERATORS GROUP

Transcription

1 BEFORE THE AUCKLAND UNITARY PLAN INDEPENDENT HEARINGS PANEL IN THE MATTER of the Resource Management Act 1991 and the Local Government (Auckland Transitional Provisions) Act 2010 AND IN THE MATTER of the Proposed Auckland Unitary Plan - Topic 042 C.1.1 Infrastructure STATEMENT OF EVIDENCE OF CURT ROBINSON ON BEHALF THE AUCKLAND UTILITY OPERATORS GROUP C:\Users\wrr\AppData\Local\Legal Desktop\LDRWDir\ docx 1 of 11

2 TABLE OF CONTENTS EXECUTIVE SUMMARY INTRODUCTION PROPOSED AUCKLAND UNITARY PLAN COUNCIL INDEPENDENT ACOUSTIC EXPERT REVIEW APPROPRIATE NOISE RULES FOR SUBSTATIONS AND DISTRIBUTION SUBSTATIONS ZONE SUBSTATIONS (WITHIN BUILDINGS) DISTRIBUTION SUBSTATIONS RECOMMENDED NOISE CONDITION C:\Users\wrr\AppData\Local\Legal Desktop\LDRWDir\ docx 2 of 11

3 EXECUTIVE SUMMARY A. I have read the proposed modifications to Topic 042 Infrastructure with respect to acoustics recommended by the Auckland Council Planner and independent expert and consider them to be too stringent. B. For zone substations I consider that a noise performance standard of 55 db L Aeq during the day and 45 db L Aeq during the night to be reasonable for zone substations measured within a residential boundary or the notional boundary of a rural property. Furthermore that a special audible character penalty shall be applied where appropriate. I consider that substations that comply with this noise limit would ensure a reasonable acoustic amenity to the neighbouring properties. C. There are some 30,000 distribution substations located on roads around Auckland and I am not aware of any significant complaints regarding noise emission. All distribution substations are designed to comply with a Australian/New Zealand Standard (AS/NZS 60076) which includes a sound power limit for the equipment. I consider this to represent compliance with the best practicable option to ensure that the emission of noise does not exceed a reasonable level as required by section 16 of the Resource Management Act. Distribution substations that meet this Standard, however, are unlikely to comply with the recommended noise limit. I have, therefore, recommended a noise limit that is similar to the National Environmental Standard for Telecommunications Facilities which are also located on roads. D. I have recommended a set of noise performance standards that I consider to be reasonable and that would ensure that the infrastructure activities would not give rise to adverse noise effects. C:\Users\wrr\AppData\Local\Legal Desktop\LDRWDir\ docx 3 of 11

4 1.0 INTRODUCTION 1.1 My full name is Curt Robinson. I am an acoustic consultant and an Associate at Marshall Day Acoustics Limited. 1.2 I hold a Bachelors Degree in Mechanical Engineering from the University of Auckland. I am a Member of the New Zealand Acoustics Society and the Institute of Acoustics in the United Kingdom. I have over 20 years of experience in acoustic engineering, including the preparation of noise performance standards for district plans, environmental acoustic modelling of industrial sites, assessment, prediction and acoustic modelling, and the recommendation of mitigation measures when appropriate. I have provided expert evidence on acoustic matters on a number of occasions to council hearings, the Environment Court and the Environment Protection Authority. 1.3 I have been engaged by the Auckland Utility Operators Group (AUOG) to provide evidence in respect to the proposed noise rules related to Topic 042 Infrastructure. 1.4 In the last 5 years I have undertaken or reviewed 10 substation projects in the Auckland Council District and a further 6 outside of Auckland. The assessments have included upgrading of existing zone substations or the application for a new substation. Furthermore I have undertaken a number of environmental measurements adjacent to existing substations. 1.5 In my evidence I will summarise the proposed noise rules relating to infrastructure in the PAUP and discuss the proposed amendments in the Auckland Council submission discussed in the evidence of the Council's planner Ms Singh and the Council's acoustic expert, Mr Styles. 1.6 I will also discuss in my evidence, where I disagree with the Council, noise rules that I would consider appropriate for infrastructure activities. 2.0 PROPOSED AUCKLAND UNITARY PLAN 2.1 As amended, the relevant policy from Part C.1.1 "Auckland Wide Objectives and Policies" reads: Page 4 of 11

5 "4. Require the development, operation, use and maintenance, removal, repair and upgrading of infrastructure to avoid, remedy or mitigate adverse effects including, on the: a. "Health, well-being and safety of people and communities within Auckland and beyond, including nuisance from noise, vibration, dust and odour emissions and light spill." 2.2 I agree with these objectives and policies with respect to noise. 2.3 Rule H , applying to noise from all substations, originally read: "5. Noise from substations must not exceed the following when measured in a residential zone a. L Aeq(15 min) 55 db between Monday to Saturday 7am 10pm and Sunday and Public Holidays 9am 6 pm b. L Aeq(15 min) 45 db and L AFmax 75 db at all other times c. Noise levels must be measured in accordance with New Zealand Standard on the measurement of environmental sound (6801:2008) and assessed in accordance with New Zealand Standard Acoustics environmental noise (6802:2008), except: i. The measurement of noise must not be subject to any tonal adjustments, ii. The noise level must be measured at 1 m from the facade of the closest residential building 3.0 COUNCIL INDEPENDENT ACOUSTIC EXPERT REVIEW 3.1 Mr Styles has provided evidence on behalf of the Council with respect to the Infrastructure noise rules and in summary, he considers that with respect to substations (Rule H.1.4) the rules are too liberal in terms of noise limits and the assessment points and that a revision is necessary. 3.2 Mr Styles considers that the notified limits of 55/45 db L Aeq are very high for a source that operates constantly. Furthermore, he considers that the special audible character penalty shall apply if applicable. Page 5 of 11

6 3.3 Mr Styles states that "I, therefore, see no reason for the application of noise limits that are any higher than the noise limits applying to any other activity" and recommends that noise from substations in zones or in roads shall not exceed the noise limits for the zone of the adjacent site/dwelling as provided for in Chapter H6.2.1 "Noise and Vibration". 3.4 For clarity that would be 50 db L Aeq between 7am and 10pm Monday to Saturday and between 9am and 6pm Sundays and 40 db L Aeq /70 db L Amax for all other times at the boundary of residential zones and the notional boundary for rural zones. 3.5 I note that for Industrial, Local Centres and Mixed Use zones the noise limits are more relaxed increasing to 70 db L Aeq at all times for Heavy Industry areas. 3.6 Mr Styles recommends that Rule H applying to noise from all substations be amended to: "3. Noise from substations in zones must not exceed the noise limits for the zone in which they are located when measured in accordance with the assessment methods for the relevant zone (as provided for in Chapter H6.2.1 Noise and Vibration). 4. Noise from substations in roads must not exceed the noise limits for the adjacent zone when measured in accordance with the assessment methods for the relevant zone (as provided for in Chapter H6.2.1 Noise and Vibration)." 4.0 APPROPRIATE NOISE RULES FOR SUBSTATIONS AND DISTRIBUTION SUBSTATIONS 4.1 I have reviewed both the proposed noise rules and Mr Styles evidence and consider that whilst the proposed rules may be too lenient, Mr Styles recommendations are too stringent for the following reasons. 4.2 There are two quite different types of equipment and infrastructure related to providing power to the community: the zone substations, generally located on a site and comprising of a number of on-load tap changing distribution substations located in separate bays. The site will also include a switch room, a workshop and an area for car parking. I understand that there are approximately 115 of these zone substations in the Auckland area and most sites have been designated with an associated noise rule. Page 6 of 11

7 4.3 In addition there are the distribution and power distribution substations that are located either in road reserves (the green enclosure) or on a power pole (the grey box). There are some 30,000 of these units in Auckland. 4.4 I consider that the zone substations and distribution substations should be treated separately and I shall discuss what I consider to be appropriate noise rules for each in the following sections. 5.0 ZONE SUBSTATIONS (WITHIN BUILDINGS) 5.1 I understand that there are some 115 substations located around Auckland. The main noise generators within substations are the transformers. The transformer noise level is relatively constant, although greater noise can be generated through the use of cooling fans and pumps which are activated during hotter periods or high demand times. I consider that a day and night noise performance standard is therefore appropriate. 5.2 I agree with Mr Styles that the special audible character penalty should be applied to these sites if applicable. I also agree that the noise assessment location should be at the adjacent site boundary or notional boundary for Rural zoned sites and that relaxed noise limits shall apply to Business zones. 5.3 I do not agree, however, that a noise limit of 55/45 db L Aeq for Residential and Rural zones is too high and I consider it to be entirely appropriate for the following reasons. 5.4 Substations are a critical part of infrastructure for the Auckland community. They may need to be located within residential areas to efficiently supply sufficient capacity and statutory voltages. New substations located in residential areas are generally constructed within buildings in order to achieve the noise performance standard. These designs include a 5 decibel penalty for special audible character which then is not often present due to the mitigation provided by the building. Page 7 of 11

8 5.5 Because of the 5 decibel special audible character penalty, a substation designed to meet a noise limit of 45 db L Aeq would need to comply with 40 decibels at the boundary whereas if the noise limit was reduced to 40 db L Aeq, as recommended by Mr Styles, then it would need to comply with 35 decibels at the boundary. This is unlikely to provide any noticeable acoustic benefit given the background noise in these zones. 5.6 For example, many dwellings throughout the District are installing heat pumps as an energy efficient heating source and external gas/heat pump powered hot water cylinders. Mitsubishi, who make the popular "super quiet" heat pumps, state in their technical specifications that the outdoor condenser for a mid to large size room (unit rated to 7 kw) generates 55 db L Aeq at 1m free-field. This is equivalent to 58 dba at 1 m when the condenser is located against a house. This condenser would meet 45 db L Aeq at 5 m and comply with a 40 decibel noise limit at 8 m. Rheem who make gas and heat pump powered external hot water cylinders state in their technical specifications that the unit makes less than 60 dba at 1m. Compliance with a 40 decibel noise limit would be at 10 m. 5.7 I consider that the acoustic environment in residential areas is changing and it is not reasonable to consider residential properties as passive noise receivers but as noise sources that contribute to the overall ambient noise level. 5.8 I recommend the changes be set out below: 3. Noise from substations in zones must not exceed the noise limits for the zone in which they are located when measured in accordance with the assessment methods for the relevant zone (as provided for in Chapter H6.2.1 Noise and Vibration)shall not exceed the following noise limits when measured within the boundary of a Residential zone site or within the notional boundary of a Rural zone site: a. 55 db L Aeq between Monday to Saturday 7am to 10pm and Sundays 9am to 6pm and b. 45 db L Aeq /75 db L Amax for all other times. c. Noise from substations in other zones shall not exceed the noise limits for the zone in which they are located as provided in Rule H6.2.1 Noise and Vibration. Page 8 of 11

9 Noise shall be measured and assessed in accordance with NZS6801:2008 "Acoustics Measurement of environmental sound" and assessed in accordance with NZS6802:2008 "Acoustics Environmental noise". 6.0 DISTRIBUTION SUBSTATIONS 6.1 All distribution substations are designed to an Australian/New Zealand Standard AS/NZS 60076:2014 "Power transformers", one of the associated Standards as part of this suite is AS/NZS :2009 "Power transformers Part 10: Determination of sound levels (IEC , Ed.1 (2001) MOD)". 6.2 The noise standard specifies a sound power performance for the transformers (as used in distribution substations) in Appendix ZA which states in ZA4 "Derivation": L WA (Reduced Maximum) = log(mva) for transformers > 0.75 MVA and is constant at 56 dba for all 0.75 MVA and smaller transformers. 6.3 I understand from the power companies that the largest distribution substation to be located in a road reserve in a residential area would be 500 kva (or 0.5 MVA). The maximum sound power level of these distribution substations would, therefore, be no more than 56 db L WA. In sound level terms this would be equivalent to 42 db L Aeq at 2 m and 39 db L Aeq at 3 m and 35 db L Aeq at 5 m. 6.4 In rural areas, distribution substations may need to be sized up to 1 MVA which would have a sound power level of 58 db L WA. The noise level from these substations would be 40 dba at 3 m and 35 dba at 6 m. 6.5 As it is likely that the distribution substations will have special audible character then the substations could comply with a 40 db L Aeq noise limit at 5 m from the cabinet in residential areas and 6 m in rural areas. 6.6 All distribution substations are designed and manufactured to an agreed international standard. I would consider that compliance with the noise performance standard would represent compliance with the best practicable option to ensure that the emission of noise does not exceed a reasonable level as required by Section 16 of the Resource Management Act. Page 9 of 11

10 6.7 The Unitary Plan has a rule for infrastructure equipment operating in the road reserve, Rule H c; this reads: "5. The Resource Management (National Environmental Standards for Telecommunication Facilities "NESTF") Regulations 2008 provide for:..c noise from telecommunication equipment cabinets located in the road reserve as a permitted activity, subject to the specified noise limits." 6.8 For clarity these are: Adjacent to a residential property: 50 db L Aeq between 7am and 10 pm and 40 db L Aeq /65 db L Amax for all other times. Adjacent to a non-residential property: 60 db L Aeq at any time and 65 db L Amax between 10pm and 7am. The sound is to be measured at 3 m from the cabinet or an adjacent property boundary, whichever is the furthest in accordance with NZS6801:2008 "Acoustics Measurement of environmental sound" and NZS6802:2008 "Acoustics Environmental noise". 6.9 AS/NZS :2009 sets a sound power limit of 58 db L WA for distribution substations rated at 1 MVA and at 56 db L WA for all substations less than 0.75 MV. These substations, located in residential and rural areas can, therefore comply with a noise level of 40 db L Aeq at 3 m. This is a measured level and not a rated level as it does not include an adjustment for special audible character. I consider this to be acceptable as the substations have been designed to meet a sound power limit specification in an approved Standard. Furthermore I am not aware of any significant noise complaints from the existing 30,000 distribution substations located in Auckland I therefore recommend that a noise performance standard be applied for a distribution substation that is similar to the NESTF. With the necessary amendments so as to apply to distribution substations, the rule would read as follows: 4. Noise from distribution substations in within roads, unformed roads and strategic transport corridors must shall not exceed 40 db L Aeq at 6 m from the distribution substation or at the nearest residential boundary or rural notional boundary, Page 10 of 11

11 whichever is the furthest. the noise limits for the adjacent zone when measured in accordance with the assessment methods for the relevant zone (as provided for in Chapter H6.2.1 Noise and Vibration) 7.0 RECOMMENDED NOISE CONDITION 7.1 In summary I recommend that the Rule H be modified to: 3. Noise from substations in zones must not exceed the noise limits for the zone in which they are located when measured in accordance with the assessment methods for the relevant zone (as provided for in Chapter H6.2.1 Noise and Vibration)shall not exceed the following noise limits when measured within the boundary of a Residential zone site or within the notional boundary of a Rural zone site: a. 55 db L Aeq between Monday to Saturday 7am to 10pm and Sundays 9am to 6pm and b. 45 db L Aeq /75 db L Amax for all other times. c. Noise from substations in other zones shall not exceed the noise limits for the zone in which they are located as provided in Rule H6.2.1 Noise and Vibration. 4. Noise from distribution substations in within roads, unformed roads and strategic transport corridors must shall not exceed 40 db L Aeq at 6 m from the distribution substation or at the nearest residential boundary or rural notional boundary, whichever is the furthest. the noise limits for the adjacent zone when measured in accordance with the assessment methods for the relevant zone (as provided for in Chapter H6.2.1 Noise and Vibration) 5. In respect of 3 and 4 above noise levels must be measured in accordance with NZS6801:2008 "Acoustics Measurement of environmental sound" and assessed in accordance with NZS6802:2008 "Acoustics Environmental noise". Page 11 of 11