3. Aspects of the Proposed District Plan that may impact upon the operation of properties that the NZFS Commission owns.

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2 Objective 8.1, Policy 8.5, Rule and Rule Aspects of the Proposed District Plan that may impact upon the operation of properties that the NZFS Commission owns. Rules: Rule 4.6.7, Rule , Rule , Rule 4.5.4, Rule and Rule Background: In achieving the sustainable management of natural and physical resources under the RMA 1991, decision makers must have regard to the health and safety of people and communities. Furthermore, there is a duty to avoid, remedy or mitigate actual and potential adverse effects on the environment. The NZFS Commission has a responsibility under the Fire Service Act 1975 to provide for structural firefighting activities in a safe, effective and efficient manner. As such, the NZFS Commission monitors development occurring under the RMA 1991 to ensure that, where necessary, appropriate consideration is given to fire safety. The NZFS Commission s main areas of concern are the provision of a water supply and access which will enable the New Zealand Fire Service (NZFS) to operate effectively and efficiently. This is best achieved through compliance with the New Zealand Standard for the provision of firefighting water supply and access, known as the New Zealand Fire Service Firefighting Water Supplies Code of Practice SNZ PAS 4509:2008 (the NZFS Code), which sets out standards for water supply and access design which meet the operational requirements of the NZFS for both reticulated and non-reticulated areas. At present, the NZFS Commission would submit on notified resource consent applications for subdivision and development in the Hurunui District, mainly when development is planned in areas where it is not possible to connect to a reticulated water supply. Typically, the NZFS Commission s submissions request that, should consent be granted, the Council impose a consent notice or condition requiring the consent holder to provide adequate firefighting water supply and access for firefighting appliances to any new non-reticulated residential, commercial or industrial structures when constructed. The NZFS Commission would like to take this opportunity to promote the inclusion of firefighting provisions such as these within the relevant sections of the Proposed District Plan, with the aim of enabling the NZFS Commission to carry out its requirements under the Fire Service Act 1975 more effectively in the protection of lives, property and the surrounding environment. 2

3 The NZFS Commission s submission is: The specific amendments, additions or retentions sought are outlined below: 1. Provision of adequate firefighting water supply - Rule (22), Rule 5.5.8, Rule 4.5, Rule 4.12, Rule 4.17, 4.21 and Rule (3) The NZFS notes that rules are in place that requires the provision of firefighting water supply in relation to the Rural Zone and subdivision. In this respect the NZFS supports the retention of Rules and Rules However the District Plan is silent on new development within the Residential Zone, Commercial Zone, Industrial Zone and Open Space Zone which are not reticulated. Accordingly NZFS request a new standard be put in place for these situations. However, while the NZFS Commission is required to respond to structural fires within its Districts, it may also be required to respond beyond its Districts when needed. Therefore, in order to be able to respond effectively to fire emergencies in all areas, it is important that dwellings and any commercial and industrial buildings located in areas where connection to a reticulated water supply is not possible are also provided with a dedicated firefighting water supply. As set out in Appendix A of this submission, there are a range of options under the NZFS Code which can be selected depending on suitability to the individual situation, and the NZFS is open to discussing other possible forms of compliance with developers (especially where larger non-reticulated developments are proposed). In addition, Rule (3) Potable and firefighting water supply, while headed up firefighting water supply, does not include an appropriate standard for this standard. Accordingly a new standard is required to ensure that the rule appropriately addresses firefighting water supply. Given the above, the NZFS Commission makes the following requests. 3

4 Table 1: Aspects of the relating to the provision for the operation of NZFS facilities Section of the Specific Provision of the Chapter 3 - Rural Rule : (a) At the time a residential dwelling is erected on any building that is not provided with sufficient fire fighting water supply via the Council/ s reticulated water supply a fire fighting water supply that complies with the following is to be provided: (i) A minimum of 20,000 litres shall be maintained at all times as a static fire fighting reserve. Alternatively, a 7,000 litre fire fighting reserve is to be made available for each dwelling in association with a domestic sprinkler system installed in each dwelling to an approved standard as outlined in SNZ 4517:2002; (ii) If water supply is to be provided via a tank(s) a fire fighting connection in accordance with Appendix B SNZ 4509:2008 is to be located within 90 metres of any proposed dwelling on the site. In Support Retain as notified. 4

5 Section of the Specific Provision of the order to ensure that connections are compatible with New Zealand Fire Service equipment the fittings are to comply with the following standards: - Either for flooded sources 70mm Instantaneous Couplings (Female) NZS 4505:2007, or for suction sources 100mm Suction Couplings (Female) NZFS 4505:2007 is to be provided. - Flooded and suction sources must be capable of providing a flow rate of 25 litres/sec at the connection point/coupling. - The Fire Service connection point/coupling must be located so that it is not compromised in the event of a fire. The reserve capacities and flow rates stipulated above in a) and b) are relevant only for single family dwellings. In the event that any proposed dwelling provides for 5

6 Section of the Specific Provision of the more than single family occupation then the applicant should consult with the New Zealand Fire Service as larger capacities and flow rates may be required; (iii) The connection point/coupling/fire hydrant shall have a hardstand area adjacent to it to allow for a New Zealand Fire Service appliance to park on it. The hardstand area shall be located in the centre of a clear working space with a minimum width of 4.5 metres. Access shall be maintained at all times to the hardstand area; (iv) Couplings are not required where underground tanks or tanks that are partially buried (provided the top of the tank is no more than 1 metre above ground) can be accessed by an opening in the top of the tank; and (v) The fire fighting water supply tank, hard standing area and/or the sprinkler system 6

7 Section of the Specific Provision of the must be installed prior to the occupation of the building; (b) Other habitable buildings At the time any other habitable building is erected on a building platform a fire fighting water supply in accordance with either a) and b) below must be provided: (i) A sprinkler system compliance with SNZ 4517:2002 is provided; or (ii) Other fire fighting water supply in compliance with the NZFS Code of Practice (SNZ PAS 4509:2008), including c) through e) above and a fire fighting connection in accordance with Appendix B SNZ PAS 4509:2008 located within 90 metres of any proposed habitable building and is to be provided. Chapter 5 - Rule Services Support Retain as notified Subdivision (b) Any allotment created shall comply with New Zealand Fire Service Fire Fighting Water Supplies Code of Practice SNZ PAS 4509:2008; 7

8 Section of the Specific Provision of the Residential Zone Rule 4.5 Insert a new standard as follows: Rules x. Water supply for fire fighting Provision shall be made for sufficient water supply and access to water supplies for fire fighting consistent with the New Zealand Fire Service Fighting Water Supplies Code of Practice (SNZ PAS:4509:2008), where by all residential units must be connected to the Council Business Zone Rule 4.12 Insert a new standard as follows: Rules x. Water supply for fire fighting Provision shall be made for sufficient water supply and access to water supplies for fire fighting consistent with the New Zealand Fire Service Fighting Water Supplies Code of Practice (SNZ PAS:4509:2008), where by all commercial units must be connected to the Council Industrial Zone Rule 4.17 Insert a new standard as follows: Rules x. Water supply for fire fighting Provision shall be made for sufficient water supply 8

9 Section of the Specific Provision of the and access to water supplies for fire fighting consistent with the New Zealand Fire Service Fighting Water Supplies Code of Practice (SNZ PAS:4509:2008), where by all commercial units must be connected to the Council Open Space Rules Rule 4.21 Insert a new standard as follows: x. Water supply for fire fighting 5.42 Standards for controlled activities Rural (3) Provision shall be made for sufficient water supply and access to water supplies for fire fighting consistent with the New Zealand Fire Service Fighting Water Supplies Code of Practice (SNZ PAS:4509:2008), where by all commercial units must be connected to the Council Insert a new standard as follows: (a) Any new allotment must be serviced by a supply of potable water (as defined in Chapter 20) which is capable of yielding at least 900 litres per day. (b) Any allotment created shall comply with New Zealand Fire Service Fire Fighting Water Supplies Code of Practice SNZ PAS 4509:2008 9

10 2. Provision of adequate firefighting access Objective 8.1, Policy 8.5, Rule and Rule Adequate access to both the source of a fire and a firefighting water supply are essential to the efficient operation of the New Zealand Fire Service. The requirements for firefighting access are also set out in the NZFS Code and should be considered in conjunction with the type of water supply option chosen to comply with the NZFS Code. As development in non-reticulated areas will generally require on-site water supply, it is necessary that access suitable for firefighting appliances is provided in order to gain access to both the water supply and the source of the structural fire. A fire fighting appliance requires access which is 4 metres in width and 4 metres in height, with a gradient that does not exceed 16%, as specified in the NZFS Code. Appendix B of this submission includes a leaflet produced by the NZFS Commission to demonstrate the importance of ensuring that an access way is designed to facilitate fire appliances. In order to allow for appropriate fire appliance access where required the following requests are made: 1. Amend Rule Table 2: Aspects of the relating to the provision of access for firefighting appliances Section of the Specific Provision of the Chapter 8 - Objective 8.1: Support Retain as notified. Transportation A safe and efficient transport network that services the current and future needs of all users. Chapter 8 - Policy 8.5: Support Retain as notified 10

11 Section of the Specific Provision of the Transportation To require on-site parking, loading, manoeuvring and access to provide for the needs of each activity while maintaining the safety and efficiency of the road network. Chapter Minimum access way and roading requirements Support in As described above in Section 2 of this submission, fire service Transportation - Table 8.3 Width standards for private right-of-way & part appliances require unimpeded access to water supplies. private roads Therefore, the NZFS request that Table 8.3 be amended as follows: Table 8.3 Width standards for private right-ofway & private roads No. of actual Legal Carriageway or seal or potential width width lots m m m 5.5m 11

12 Section of the Conditions for permitted activities Specific Provision of the Minimum access way and roading requirements Insert new standard as follows: (f) Where any onsite water supply for firefighting is provided, access to the supply onsite shall comply with the accesway dimensions set out in the New Zealand Fire Service Firefightning Water Supplies Code of Practice SNZ PAS 4509: Provision for operation of NZFS properties Rules 4.6.7, Rule , Rule , Rule 4.5.4, Rule and Rule In order to effectively carry out their operations, the NZFS requires facilities which meet certain specifications and the ability to carry out essential activities at these facilities. There are currently eight fire stations located within the Hurunui District, shown in the table below. There are no immediate plans for any major alterations of these stations or for any new stations at this stage. Fire Station Address Zone Amberley Volunteer Fire Station Markham Street Business 1 Waipara Fire Station Glenmark Drive Residential 1 12

13 Waikari Fire Station 87 Princes Street Business 1 Hawarden Fire Station 7 High Street Business 1 Culverden Fire Station 12 Mountainview Road Business 1 Cheviot Fire Station 6 McQueen Road Business 2 Waiau Fire Station 18 Cheviot Street Residential 1 Hanmer Springs Fire Station 39B Amuri Avenue Business 1H (Hanmer Springs) In terms of height requirements, fire stations will generally be single storied buildings within 8-9 metres in height. Hose drying towers may also be required in some cases, which can be around metres in height. Noise will also be produced by operational activities such as cleaning and maintaining equipment and training activities as well as noise produced by emergency sirens. Training may take place anywhere between 7.00am and 10pm. Cleaning and maintenance of equipment would generally take place during the day; however it may also be required after a call-out which could occur at any time. Generally, the NZFS Commission has assessed that fire station activities will be capable of meeting the standards set out in NZS 6802:2008 (Table 3 Guideline residential upper noise limits), with the exclusion of noise created by emergency sirens. However, in respect of Rule 4.11 it is noted that this rule potentially includes fire stations and to clarify this situation as an exception. To further assist with the provision of these essential buildings and activities, the NZFS Commission makes the following requests. 13

14 Table 3: Aspects of the relating to the provision for the operation of NZFS facilities Section of the Specific Provision of the Chapter 4 Settlements Rule Retain as worded given that compliance 4.6 Standards for (a) All activities shall be designed and conducted so as to Support with this rule will assist the NZFS to carry permitted activities ensure that the following noise limits are not exceeded, at or out their duties effectively and efficiently. outside the boundary of the site: 55 dba Leq(1hr) 7am 7pm daily; 45 dba Leq(1hr) 7pm 7am daily; and 75 dba Lmax All days between 10pm and 7am; (e) Exemptions the above noise limits shall not apply to activities within roads or emergency services call out sirens. 14

15 Section of the Specific Provision of the Chapter 4 - Settlements Rule (a) All activities shall be designed and conducted sio as to ensure that the following noise limits are not exceeded, at or outside the boundary of the site: 55 dba Leq(1hr) 7am 7pm daily; 45 dba Leq(1hr) 7pm 7am daily; and 75 dba Lmax All days between 10pm and 7am; (e) Exemptions the above noise limits shall not apply to activities within roads or emergency services call out sirens. Support Retain as worded given that compliance with this rule will assist the NZFS to carry out their duties effectively and efficiently. Chapter 3 - Rural Rule Noise Limits: Support (k) Exemptions the above noise limits will not apply to the Retain as worded given that compliance following activities: with this rule will assist the NZFS to carry out their duties effectively and efficiently. (iii) Emergency services call out sirens. 15

16 Section of the Specific Provision of the Residential Zone Rules Height Support Retain as notified 4.5 Permitted activities The maximum height for any building or structure shall be 8m from the natural ground level, exept to the east of the Gore Bay Height Control Line, as shown on Map G in the Planning Maps, where the maximum height shall be 4.5m. Business Zone Rules Height Support Retained as notified 4.11Permitted activities The maximum height of any building or structure is 9m. Business Zone Rules Servicing hours Amend as follows: 4.11 Permitted activities Within 50m of a Residential site, there shall be no servicing of Within 50m of a Residential site, there activities or operation of vehicles, other than those activities shall be no servicing of activities or associated with residential activities, between 10pm and 7am operation of vehicles, other than those Monday to Sunday inclusive. activities associated with residential activities, between 10pm and 7am Monday to Sunday inclusive (fire fighting activities and appliances are exempt). 16

17 The NZFS Commission seeks the following decision from the consent authority: That, if the Proposed District Plan is approved, the above retentions, amendments and additions requested by the NZFS Commission be included in the final wording. The NZFS Commission has qualified staff, experienced in all aspects of this submission, and would be happy to assist and/or advise in any way possible. The NZFS Commission wishes to be heard in support of their submission. (Signature of person authorised to sign on behalf of New Zealand Fire Service Commission) 03/07/2015 Date 17

18 APPENDIX A Alternative methods to achieve compliance with the NZFS Code in non-reticulated areas: The NZFS Commission considers that the best method to comply with the NZFS Code is the installation of a domestic sprinkler system in accordance with Fire Sprinkler Systems for Houses NZS 4517:2010. Domestic sprinklers provide a highly effective means of early fire suppression which minimises property damage and the effects on the environment. Domestic sprinklers quickly apply water directly to the source of the fire and are the most reliable method to control a fire, particularly in areas that are some distance from the nearest fire station. The NZFS Code recommends that a standard dwelling with an installed domestic sprinkler system requires a minimum dedicated water supply of 7,000 litres. This water storage can be provided within a potable water tank through including a reserve supply with a cut-off valve to maintain 7,000 litres at all times as shown in Figure 1 below. Another means of complying with the NZFS Code is the installation of a dedicated firefighting water supply to be used by the New Zealand Fire Service in the event of an emergency. The NZFS Code stipulates that a dwelling without a domestic sprinkler system requires at least 20,000 litres of dedicated water storage within 90 metres of a building, depending on the surrounding fire hazards. As well as the minimum water storage, the NZFS Code identifies other associated requirements, such as a compliant 100 mm female round thread coupling with an on/off valve, and sufficient access to the water supply for fire appliances as well as a hard-standing surface within 6 metres of the coupling for fire appliances to park on. In certain cases, this water supply may be able to be shared across multiple properties. Aside from dedicated static water storage tanks or the installation of domestic sprinkler systems, there are other water sources that can achieve compliance with the NZFS Code. Such alternative sources can be water from any year-round source such as dams, swimming pools, stream water, seawater, etc., provided that source is adequately available for use by the New Zealand Fire Service and it meets the other requirements of the NZFS Code that includes a hard-standing area for fire appliances. The NZFS Commission has qualified staff, experienced in this area, and are happy to assist and advise with the fire safety aspects of any proposed subdivision and/or development in order to achieve the best outcome for all parties. 18

19 Figure 1: 19

20 APPENDIX B Access for fire appliances in rural areas: 20