P O Box 154
russell protection society (inc)
Russell, Bay of Islands
8 November 2019
Intermediate Resource Planner
District Services, Far North District Planner
Submission of the Russell Protection Society to Application 2200223-RMALUC for a resource consent to establish a new Helicopter Landing Area breaching the Helicopter Landing Area, Screening for Neighbours – Non Residential Activities and Noise rules in the Coastal Living Zone at 23 Matauwhi Road, Russell. Our Society has the following concerns:
- Loss of Amenity
Russell is recognised as having a unique character in the Far North District Plan. The special Russell Township Zone sets the context by acknowledging that “Russell occupies a unique place in New Zealand’s past. The historic role of the settlement and its gradual evolution into what we today know as a quiet but popular tourist town have afforded it a special significance. In recognition of that significance, the Russell community has indicated a desire for resource management methods that maintain and enhance those characteristics of the natural and physical resources in Russell which contribute to its unique character, its heritage and amenity values”.
These provisions are not solely related to the heritage values in Russell, which are dealt with in more detail by other provisions in the Plan (Section 12.5A – Heritage Precincts), but rather the environment within which the people of Russell live. This requires that “the historic and amenity values of Russell could be adversely affected by development that is not sensitive to the physical and cultural environment of the town and its surrounds, and particularly the ability of the receiving environment to accommodate the effects of development”.
It acknowledges that “Russell is both a residential and a commercial centre and the relationship between these activities contributes to the character of the town. This character could be affected if the existing balance of activities is significantly altered”. It requires that activities and development occur in a way that is compatible with the historic heritage and amenity values of Russell, and where there are no significant adverse effects on the environment”. Further, it explicitly states “that a reasonable level of privacy and peaceful enjoyment be provided for residents”.
In summary, the FNDC recognises the special character of Russell, which combines peaceful residential areas located in a natural setting containing outstanding heritage values. The outdoor environment is typically enjoyed by residents who value their peace and quiet. The proposal does not meet the necessary setback from the Russell Township Zone, however this serves to obscure the fact that the effects of the helicopter noise would impact a much broader area of Russell village and not just the sensitive “Gateway Area” of Matauwhi Bay. The noise of helicopters in the location and of the scale proposed by the Applicant would serve to destroy this tranquillity for many and therefore result in a clear loss of amenity for the community of Russell. As noted above, this is not consistent with Council’s desired “Environmental Outcomes”.
- Lack of Adequate Information
The Applicant has supplied primarily “desktop” information which does not take proper account of the site’s topography, local climatic conditions and the nature of tourist helicopter operations. In particular, no on the ground or aerial noise propagation testing has occurred. It is evident that topography and prevailing climatic conditions, particularly wind direction, can have an influence on how noise spreads and how the decibel level and duration of it is perceived by surrounding residents. Those residents living in more elevated positions may find that the claimed 50 – 53db limit is often breached and over a longer periods of time.
The nature of helicopter tourism is that clients want to fly over interesting areas such as the historic Russell Township. Notwithstanding any initial proscribed “flight path”, the experience in Russell is that overflights from existing heliports at Eagles Nest and Moojibing (sp?) continue to annoy local residents. The FNDC is not in a position to monitor and enforce conditions in this respect, leading to questions as to whether the impacts on Russell’s existing amenity can be effectively controlled or mitigated.
- Question of Need
The proposed helicopter landing area serves to duplicate what already exists in two other locations on Russell Peninsula. There is also a landing area for emergency helicopters in Russell and hence there is limited public benefit that can be claimed for this proposal. The Applicant has not presented any plan or supporting infrastructure to indicate how the helicopter landing area would actually operate or what the market for such services is. Clients would have to be transported to Russell proper, involving vehicle movements on potentially dangerous sections of Matauwhi Road, where cars travelling in convoy from the Opua Ferry interact with the traffic from number 23 Matauwhi Road.
As noted in the District Plan, Russell offers the visitor a unique heritage experience. This experience is particularly enhanced by arriving by sea, by walking around the historic precincts and by experiencing a tranquil setting in which heritage values can be understood and appreciated. The noise and sight of modern helicopters introduces a discordant element into this setting and can serve to undermine the intrinsic values that attract tourists to Russell in the first place.
- Excessive Number of Flights/Time
The Applicant has sought up to 40 helicopter movements per week and 11 per day. This is considered excessive when compared with other landing sites on the Peninsula and even with the Paihia commercial heliport. The background noise to these movements would create an obtrusive element for Russell residents who are more used to the natural rhythms of the wind and sea. The permitted times of 7am to 10pm conflicts with some resident’s sleep patterns and their social activity in the evening after work. Young children who are put to bed in the early evening could also be affected. The impact of this chattering noise for so often and over such a long period of time is likely to have an effect on the enjoyment of local properties and in this way would detract from the existing amenity that they now enjoy.
- Impact on the Environment
The Applicant claims that there are no Kiwi on the site. This contradicts local knowledge which suggests that there is at least a breeding pair on the site and perhaps more since revegetation has progressed. These observations appear logical given that the site is mainly surrounded by DOC reserves. Noise can be a contributing factor in disrupting the breeding cycles of our native birds and sea birds can come in direct conflict with helicopter rotor blades. The site also has heritage values because of the ancient Pa located there and the frequent coming and going of helicopters would serve to compromise its current tranquil setting. As well as the physical environment, account should also be given of the social and cultural environment of the area. In this respect, the concerns of local residents must be considered as well.
- Need to Publicly Notify
The nature of the proposed activity is that it would potentially affect a large number of people. The level of that impact would also vary according to the location and each person’s circumstances. The only way for the Council to accurately determine what that impact may be is to publicly notify the Application so that the local community can provide first hand knowledge of how it would affect them. The Council is not in a position to consider whether the effects are more than minor without approaching the community and seeking their response. This response should help to clarify exactly what the local amenity is, how residents perceive it, and if and how this would be impacted and what the consequences of that loss would be as a result.
Russell Protection Society
Address for service as above