Landscape Assessment of Amateur Radio Activities · 1.2 Amateur Radio Activities 10 1.2.1...
Transcript of Landscape Assessment of Amateur Radio Activities · 1.2 Amateur Radio Activities 10 1.2.1...
Kāpiti Coast District Council Proposed District Plan
PROPOSED DISTRICT PLAN Chapter 3 – Natural Environment
Landscape Assessment of Amateur Radio Activities
January 2016 FINAL
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DOCUMENT CONTROL
REV NO. DATE REVISION DETAILS AUTHOR Review
0 19/11/2015 Draft Lisa Rimmer
Brad Coombs
1 26/11/2015 Final Draft LR KCDC
2 20/01/2016 Final LR Issue
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CONTENTS
GLOSSARY OF TERMS
EXECUTIVE SUMMARY
PART 1 BACKGROUND REVIEW 1.1 Project Brief 8 1.1.1 Landscape Assessment Methodology 9 1.2 Amateur Radio Activities 10 1.2.1 International, National and Local Context 10 1.2.2 Amateur Radio Configurations 11 1.3 Amateur Radio Submissions 12 1.4 Policy Context 13 1.4.1 Resource Management Act and NZCPS 13 1.4.2 Greater Wellington Regional Policy Statement 15 1.4.3 Kāpiti District Plan 16 1.4.4 Other District Plans 17 1.5 Case Law 18
PART 2 ASSESSMENT FINDINGS AND RECOMMENDATIONS 19
2.1 Kāpiti Coast District Landscapes and Built Environment 19 2.2 Landscape and Urban Design Effects 21 2.2.1 Natural Character 22 2.2.2 Outstanding Natural Features and Landscapes & Special Amenity Landscapes 22 2.2.3 Amenity and the Quality of the Built Environment 22
2.2.4 Cumulative Effects 25 2.2.5 Effects of ARA 26
2.3 Recommended Provisions 27 2.3.1 Permitted activities 29 2.3.2 Restricted Discretionary Activities 35 2.3.3 Discretionary Activities 35 2.3.4 Summary 37
APPENDICES | 1-4
Amateur Radio Configurations Kāpiti Amateur Radio Society Inc Submission SEV Provisions Case Law Review
GRAPHIC SUPPLEMENT| Figures 1-13
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GLOSSARY OF TERMS
ARA Amateur Radio Activities
HNC High Natural Character
HF High Frequency
KARS Kāpiti Amateur Radio Society Inc
KCDC Kāpiti Coast District Council
MBIE Ministry of Business Innovation and Employment
NZCPS New Zealand Coastal Policy Statement
NZART New Zealand Association of Radio Transmitters Inc
ONF/L Outstanding Natural Features and Landscapes
ONC Outstanding Natural Character
PAS Permitted Activity Standard
RBI Rural Broadband Initiative
PDP Proposed Kāpiti Coast District Plan
RPS Greater Wellington Regional Policy Statement
RMA Resource Management Act
SAL Special Amenity Landscapes
SEV Submitter Engagement Version of the PDP (issued June 16th)
UHF Ultra High Frequency
VHF Very High Frequency
WCC Wellington City Council
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EXECUTIVE SUMMARY Isthmus has been asked to provide a landscape and urban design assessment of amateur radio
activities (ARA) in the Kāpiti Coast District. This assessment follows on from submissions
received by the New Zealand Association of Radio Transmitters Inc (NZART, submission No
203) and the Kāpiti Amateur Radio Society Inc (KARS, submission No. 452) on the proposed
Kāpiti Coast District Plan (PDP). These submissions seek specific consideration of amateur radio
activities (ARA) in the PDP with 20m and 30m support structures (masts) and antenna to be
permitted in urban and rural areas, respectively.
Part 1 of the assessment addresses:
types of ARA configurations that are likely to be found or established in the District;
the details of the NZART and KARS submissions and the permitted activity standards (PAS)
sought;
The policy context and best practice guidance for the assessment of effects and ARA
management including: legislative matters; the Greater Wellington Regional Policy
Statement (RPS); recent case law decisions; the submitter engagement version (SEV) of the
Plan; and ARA provisions adopted by other Councils;
Following this background study, Part 2 addresses:
the landscape and built environment values to be managed in Kāpiti;
assessment of likely landscape and urban design effects of ARA in rural and urban
environments for different types of viewing audience; and
plan provisions recommended to integrate ARA into the Kāpiti Coast landscape.
Effects
In rural areas, the likely effects of ARA will be on natural character, perceptual values and
views of identified landscape areas as well as the visual amenity of properties in close
proximity. In urban areas, the risks relate to visual amenity from close views and the overall
quality and pattern of the built environment.
Effects for particular ARA will vary depending on the range of location and design factors and
the potential for cumulative effects. In general terms, for the permitted activity standards
(PAS) proposed in the submissions, and excluding ‘priority one and two’areas of greater risk
identified under Section 6 and 7 of the RMA:
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The effects on close views in residential areas are likely to be high or very high1. This is due
to both the scale of the ARA and the number of configurations proposed.
The effects on distant views and the quality of the urban environment in residential areas
are likely to be moderate to high. There is very little visual context for 20m or taller
structures in the urban environment in Kāpiti. These structures are likely to be prominent
and appear out of place.
The effects on close views in rural areas are likely to be moderate or moderate to high.
Thirty meter support structures are taller than most national transmission line towers in
the District and combined with broad antenna these are likely to be dominant and appear
obtrusive to near neighbour’s.
The effects on distant views in rural areas are likely to be low to moderate or moderate.
Provisions
The review recommends permitted, restricted and discretionary activity standards to integrate
ARA into the Kāpiti landscape. PAS recommended for the height and number of support
structures in each Zone or identified area in the PDP is summarized in the table below.
Please Note: additional recommendations for controls over support structure components,
antenna and guy wires, setback etc. are detailed in Sections 2.3.1 to 2.3.3.
1 Best practice assessment methods typically use a 7 point scale (very low, low, low to moderate, moderate, moderate to high, high, very high) to summarise the extent of adverse effects on landscape values and the quality of the built environment. In Resource Management Act terminology ‘very low’ effects are ‘less than minor’ and ‘low’ effects are ‘minor’ or ‘less than minor’. ‘More than minor’ effects are ‘low to moderate’ through to ‘very high’.
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Summary of recommended PAS for Support Structures (refer to 2.3.1 to 2.3.2 for additional recommendations)
Zone/Area Recommended PAS for support structures - no’s & dimensions
Rural Hills, Rural Plain - up to 6 ground mounted support structures less than 120mm in diameter with a maximum height of 9m (including antenna) - up to 1 ground mounted support structure with a diameter greater than 120mm and maximum height of 20m (including antenna) - up to 1 building mounted panel or dish or wire type antenna with a maximum height 5m above the permitted building height
Rural Residential, Rural Dunes, Rural Eco Hamlet
- up to 6 ground mounted support structures less than 120mm in diameter with a maximum height of 9m (including antenna) or - up to 1 ground mounted support structure with a diameter greater than 120mm and maximum height of 15m (including antenna) - up to 1 building mounted panel or dish or wire type antenna with a maximum height 5m above the permitted building height.
Living Zones - up to 3 ground mounted support structures less than 120mm in diameter with a maximum height of 9m (including antenna) or - up to 1 ground mounted support structure with a diameter greater than 120mm and maximum height of 12m (including antenna) - up to 1 building mounted panel or dish or wire type antenna with a maximum height 3m above the permitted building height
Special Amenity Landscapes Restricted Discretionary Activity recommended
HNC, ONC, ONF/L, Ecosites, Historic Heritage Places and Features, Geological Sites and Waahi Tapu, Working Zones, Open Space Zones, Fault and Flood Avoidance Zones
Discretionary Activity recommended
Non complying activity status is not recommended for ARA, in terms of landscape and urban
design matters. PAS, restricted discretionary and discretionary controls are considered
adequate to require appropriate location and design measures to avoid inappropriate effects,
and, where these measures can not be provided, Council has the option to decline consent.
Overall, however, the most appropriate activity status for ARA will be determined through a
consideration of all Part 2 matters under the RMA. This Part 2 assessment will consider
matters that are outside the scope of a landscape and urban design appraisal, such as
operational requirements and public benefits. This is likely to have an impact on the final PAS
Council proposes and may result in a more conservative management approach than is
recommended in this report. Increased controls would inevitably reduce the effects on
landscape and built environment values, and in general terms, would be supported by this
assessment. Differing controls for ARA and network utilities are recommended for some areas
in this assessment. This is consistent with a best practice cautionary approach and the
consideration of relevant Section 6 and 7 matters under the RMA. Further distinction in the
final recommended controls for ARA and network utilities may also result from the Council’s
Part 2 RMA assessment.
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PART 1 BACKGROUND
1.1 Project Brief
Following submissions on the Kāpiti Coast Proposed District Plan (PDP), Isthmus have been
asked to provide a landscape and urban design assessment of amateur radio activities (ARA) in
the Kāpiti Coast District.
The PDP was notified in November 2012 without specific recognition of ARA, as per the
operative Kāpiti Coast District Plan. Under this PDP the rules and standards for Network
Utilities (Chapter 11) would apply to ARA. The permitted activity standard (PAS) heights for
network utilities are 12m in Living and 18m in Rural Zone; as set out in the submitter
engagement version (SEV) of the PDP (issued June 2015). The submissions from the New
Zealand Association of Radio Transmitters Inc (NZART, submission No 203) and the Kāpiti
Amateur Radio Society Inc (KARS, submission No. 452) seek provisions for amateur radio
activities2 to be a permitted activity up to a height of 30m in Rural Zones and 20m in all other
zones.
ARA activities have been considered in a number of recent District Plan reviews. In general,
there is a shift to providing specific provisions, with varied approaches and PAS adopted, in
some cases, following decisions in the Environment Court.
2 Refer to Section 1.2.2 below. In general terms an amateur radio configuration requires an antenna or aerial (referred to as antenna in this assessment) to send and receive radio signals and a support structure to elevate the antenna. Antenna can be wire, dish or panel type. Antennas vary markedly in terms of size. Wire antenna may have numerous components with horizontal and/or vertical configurations and can be directional (where the antenna can be aimed or adjusted to improve performance).The support structure can be either a steel frame/pedestal attached to a building or a ground mounted pedestal or mast. Slender masts are typically supported by guy wires. Taller and broader support structures, often lattice type, can also be used; some of which are self-supporting. On larger support structures, a small rotator motor may also be attached to allow a directional type antenna to be adjusted.
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This assessment follows on from Isthmus’ work to assist Council in the District Plan review and
PDP submission response process on landscape and coastal environment matters. This work
included the identification of Outstanding Natural Features and Landscapes (ONF/L) and
Special Amenity Landscapes (SAL) and areas of High Natural Character (HNC) and Outstanding
Natural Character (ONC)3 ; as described in more detail under Section 1.4 (Policy Context) and
2.1 (Kāpiti Coast District Landscapes and Built Environment), below.
1.1.1 Landscape Assessment Methodology
The assessment methodology includes:
Assessment of background information
Review of the submissions, further submissions and engagement to date, relevant national,
regional and local policy context, background reports including the 2012 Landscape Study
identifying ONF/L and SAL, the 2012 Coastal Environment Study, sections of the PDP and SEV
and the Tauranga City and Wellington City case law decisions.
Fieldwork
Carry out field work to complement the 2012 Landscape Study and Coastal Environment Study
including rural and urban areas and to review of the characteristics and quality of the built
environment. Observe existing ARA in the Kāpiti Coast District from publicly accessible areas.
Follow up desktop review and analysis
Analysis to confirm the potential landscape and urban design issues (effects), relevant
measures to avoid, remedy and mitigate effects and particular areas of risk.
Recommendations
Provide advice and recommendations on elements of appropriate plan provisions for:
Amateur radio support structures including heights in rural and urban environments.
Other amateur radio equipment (e.g. dishes and wire antenna boom and cross elements)
including sizes/dimensions.
3 The 2012 Kāpiti Coast District Landscape Study provided a technical assessment of the Districts most important landscape areas (ONF/L and SAL) under the Resource Management Act and the operative RPS. These areas are mapped in the PDP and their landscape values are described in Chapter 3 Schedules. The 2012 Kāpiti Coast District Coastal Environment Study and subsequent assessment carried out through the review of the PDP provided a technical assessment of the Districts inland extent of the coastal environment and areas of Outstanding Natural Character and High Natural Character under the New Zealand Coastal Policy Statement, 2010 and the operative RPS. Copies of these reports are available from Council.
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Identify whether there should be any areas/precincts/zones where amateur radio activities
would be inappropriate and the reasoning for this.
Assess how equipment/configurations could be integrated into the existing Kāpiti Coast
landscape and potential and cumulative effects managed.
Recommend possible assessment criteria to be considered for non-permitted activities in rural
and urban environments.
Internal Quality Assurance and Issue to KCDC
1.2 Amateur Radio Activities
1.2.1 International, National and Local Context
The New Zealand Association of Radio Transmitters (NZART) represents amateur radio
interests to the Ministry of Business Innovation and Employment (MBIE) and the International
Amateur Radio Union (IARU). The MBIE allocates radio frequencies and administers licenses
required by amateur radio operators. MBIE is a signatory to the International
Telecommunications Union convention and regulations (as cited in the NZART submission).
This defines the amateur service as:
“1:56 A radio communication service for the purpose of self-training,
intercommunication and technical investigations carried out by amateurs, that is, by
duly authorised persons interested in radio technique solely with a personal aim and
without pecuniary interest.”4
NZART has approximately 1800 members and represents 4800 license holders nationwide.
KARS has approximately 25 members and cites a further 75 licensed operators in the District. 5
Further information as to the range of uses and wider benefits of amateur radio is provided in
the NZART and KARS submissions. In summary, this includes experimentation and
development leading to technical advancement along with public benefits due to roles in
international communication, civil emergencies, search and rescue operations and various
community projects and events. These matters will be considered by Council under Part 2 of
the Resource Management Act (RMA) but are outside the scope of a landscape and urban
design assessment.
4 ITU Radio Regulations – Article 1, Definitions of Radio Services. Accessed November 2015 at: http://www.ictregulationtoolkit.org/en/toolkit/notes/PracticeNote/2824
5 KCDC Submitter Meeting Notes July 22nd
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1.2.2 Amateur Radio Configurations
A description of typical ARA configurations and technical requirements is summarised in
Appendix 1 following a review of the information provided in the NZART and KARS
submissions and recent Environment Court case decisions (refer to Section 1.5 below).
Kāpiti Coast District ARA Configurations
Photographs taken from publicly accessible locations in the District are included in the
attached Graphic Supplement. Most installations are simple in construction; using slender pole
type support structures with doublet, whip type or small array antenna and have a total height
less than 8m. Roof mounted ARA, are typically less than 2m above the ridgeline. A larger
configuration is located at the Kāpiti Coast Museum (see Figure 10) with a guyed lattice
support structure and Yagi type antenna; with an approximate overall height of 12m. Two
lower self supporting lattice structures are located on Paekakiriki Road, with an approximate
overall height of 8m. A further example, located in a residential property in Porirua (outside of
the Kāpiti Coast District), is shown in Figure 11. This configuration has an overall height of
approximately 15m including a Yagi type antenna approximately 5m wide.
Similar structures
Reference to structures of a similar form and scale is relevant to a landscape and urban design
assessment, as ARA form part of the wider built environment. Smaller scaled ARA
configurations, generally less than 8m in height, are similar to domestic structures such as
television aerial and flagpoles. PAS sought in the submission are not of this scale (refer to
Section 1.3 below). ARA above 8m in height (permitted building height in residential and rural
areas) are most usefully compared to infrastructure elements of a similar form including
vertical support structures with elevated horizontal and/or vertical cross members i.e. power
poles, street lights and other network utilities. Power poles and street lights are typically 8-
12m in height. Network utilities, such as cell phone towers are typically less than 20m (the
permitted height in residential areas is 12m). Rural Broadband Initiative (RBI) structures are
generally around 25m and require consent as a discretionary activity, as shown in the
simulated view in Figure 12. This structure has a total height of 25m (excluding the lightning
rod) with antenna attached to a 5m diameter headframe. Lattice type structures, typically
used in ARA will appear less bulky when viewed at this distance, as does the 220kV
transmission tower in this view. Larger national transmission line towers, as shown in Figure
12, feature along the coastal plain and through residential areas of the District, but are more
commonly found and recognized as part of the visual context in the Rural Hill Zone. These
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network utilities vary in height, width and construction type. The lattice type tower shown in
Figure 12 is approximately 22m in height and the 110kV poles approximately 12m. In general
terms this setting would provide a more appropriate landscape context for larger ARA to be
located; as part of an existing pattern of structures with a similar scale and form. This
simulated view illustrates that there are a range of factors that will influence visual dominance
and effects including distance, topography and visual context. For example where the 12m
high 110kV poles appear to be taller and of a similar width to the 25m RBI structure, as they
are closer to the viewer. Other factors, known to influence visual dominance resulting in
additional landscape and urban design effects are discussed in more detail in Section 2.2.3
below.
1.3 Amateur Radio Submissions
Submissions received from the NZART (no 203) and KARS (no 452) raise similar concerns about
the lack of specific provisions for ARA in the PDP and the ‘default’ application of Chapter 11
PAS to ARA or, alternatively, the building height, yard and recession plane rules that apply to
specific zones. Less restrictive PAS are sought, with reasons cited including differing
operational requirements (compared to network utilities), consideration of the public good
services, the costs of resource consents processes and, in their opinion, community
acceptance of the nature and extent of effects.
The details of the KARS submission is summarized is Appendix 2.
In summary, PAS are sought for most areas of the District that would provide for up to six ARA
configurations per lot with support structures less than 9m in height. One larger structure with
a diameter of 600mm above 8m and total height of 20m or 30m in rural areas could be
constructed as of right and all configurations could be located in close proximity to the
boundary and penetrate the recession plane. Dish antenna would be limited to 1.2m in
diameter above 5m. There are no controls proposed for wire type antenna. Additional ARA
configurations could be attached to buildings to a height of 20m. In ‘sensitive’ areas, such as
ONF/L, the same development would be provided for as a controlled activity – consent must
be granted- and, in rural areas, a second larger scale ARA is to be consented as a controlled
activity.
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Further submissions Further submissions were received from Rob Crozier and Joan Allin (no 29) and Heritage New
Zealand (no 175).
Rob Crozier and Joan Allin’s further submission opposes the KARS submission in relation to
Chapter 11.
Heritage New Zealand further submission supports the KARS submission insofar as the
effects on historic heritage are avoided.
1.4 Policy Context
Policy instruments most relevant to the assessment of ARA landscape and urban design effects
include the Resource Management Act (1991, RMA), the New Zealand Coastal Policy
Statement (NZCPS, 2010), the operative Greater Wellington Regional Policy Statement (RPS)
and the SEV.
1.4.1 Resource Management Act 1991 and NZCPS, 2010
Sections 6 and 7 of the RMA are relevant, as structures of the scale and form proposed in the
NZART and KARS submissions are likely to impact on both matters of national importance and
‘other matters’.
Section 6 requires, as a matter of national importance, the following matters to be recognized
and provided for:
(a) the preservation of the natural character of the coastal environment (including the
coastal marine area), wetlands, and lakes and rivers and their margins, and the
protection of them from inappropriate subdivision, use, and development:
(b) the protection of outstanding natural features and landscapes from inappropriate
subdivision, use, and development:
Natural character and landscape management are further prioritized by the NZCPS policies 13
and 15 and apply to areas within the coastal environment; as identified in the SEV. Council has
identified areas of ONF/L as well as ONC and HNC on the SEV maps (see Part 2 for a more
detailed description) to assist in the management of these ‘first tier’ landscapes and high
priority areas of natural character. This is also required by policies in the RPS.
Schedules included in Chapter 3 of the SEV describe the physical, perceptual and associative
factors identified in the ONC and ONF/L areas (as described in more detail in the Landscape
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Study and Coastal Environment reports6). These matters are required to be assessed under the
RPS to identify and evaluate ONC and ONF/L . The schedules also provide a baseline
description of values to be considered in ongoing management.
Other ‘matters of national importance’ are addressed in the identification of the District’s
heritage schedule of Ecosites, Historic Heritage Places and Features, Geological Sites and
Waahi Tapu.
Together these areas comprise the District’s most valued natural and cultural environments.
Best practice management anticipates more conservative PAS for these areas (see Section
1.4.3 below); as they address matters of national importance. This includes greater controls
over buildings and structures as required to ensure Council is able to manage any effects and
meet its responsibilities under the RMA, NZCPS and RPS (Policies 3 and 25).
Under Section 7 of the RMA ‘other matters’ particular regard must be given to:
(c) the maintenance and enhancement of amenity values;
(f) the maintenance and enhancement of the quality of the environment.
Under Section 2 of the Act:
Amenity values means those natural or physical qualities and characteristics of an
area that contribute to people’s appreciation of its pleasantness, aesthetic coherence,
and cultural and recreational attributes.
Environment includes:
(a) ecosystems and their constituent parts, including people and communities; and
(b) all natural and physical resources; and
(c) amenity values; and
(d) the social, economic, aesthetic, and cultural conditions which affect the matters
stated in paragraphs (a) to (c) or which are affected by those matters
Whilst section 7c) and 7f) apply to all landscapes, under the operative RPS (Policy 27), Councils’
may also identify SAL or ‘second tier landscapes’; as included in the SEV maps and Chapter 3
schedule. These areas (as described in more detail in Part 2) are highly valued by communities
6 Copies of the 2012 Coastal Environment and Landscape Study can be requested from Council.
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for their unique combination of physical, perceptual and associative attributes that contribute
to amenity.
Plan provisions for SAL’s are typically less restrictive, given their ‘second tier’ status under the
RMA. Under the SEV, the underlying zone PAS apply to permitted activities for SAL areas. For
restricted discretionary and discretionary activities, the schedule of values forms a ‘matter to
be considered’.
Section 7f) applies to both rural and urban zones. That is, particular regard should be given to
both the quality of the natural and the built environment. In practice, these more general
matters (and the District wide consideration of s7c) are addressed in the expected outcomes
and policies for particular zones; as these set the stage for anticipated development and
amenity values in particular areas (see Section 1.4.3 below).
1.4.2 Greater Wellington Regional Policy Statement Policies 3, 25 and 27 are relevant to HNC, ONC, ONF/L and SAL. In addition, the RPS considers
more general matters associated with the design of urban and rural environments under Policy
54 and 56. This includes reference to the overarching principles of the New Zealand Urban
Design Protocol and District Plan measures to ensure all development is well designed. Such
matters are to be considered in all Zones within a District and will be addressed in expected
outcomes and by provisions that aim to reduce effects on landscape, natural character and the
quality of the built environment.
In summary
Together these higher order planning instruments establish a hierarchy of first and second tier
landscape and urban design matters to be considered when assessing the effects of ARA.
First tier - matters of national importance to recognize and provide for:
Natural character including areas of HNC and ONC under Section 6a) of the RMA and
the NZCPS;
ONF/L under Section 6b) of the RMA and the NZCPS;
Second tier - other matters to have particular regard for:
SAL and general amenity values under Section 7c) of the RMA; and
The quality of natural and built environment, under Section 7f) of the RMA.
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1.4.3 Kāpiti District Plan
Plan areas
The SEV Planning Maps, and respective Chapter definitions, zone descriptions, schedules and
policies, identify areas with particular landscape, natural character and heritage values and
those anticipating high amenity and/or low impact development. That is: ‘first and second tier’
areas for management identified in response to Council’s responsibilities under the RMA,
NZCPS and RPS (refer to Section 1.4.1 and 1.4.2 above). More active management methods
are required in best practice plans in these areas, including greater controls for built
structures. This is to ensure Council gives effect to the higher order policy instruments and
achieves expected outcomes detailed in policies for landscape values and the quality of the
built environment.
These areas include:
Natural and Cultural Features - ONF/L, the coastal environment, areas of HNC and ONC,
Ecosites, Historic Heritage Places and Features, Geological Sites and Waahi Tapu. These are
‘first tier’ areas for management under Section 6 of the RMA and the NZCPS. SAL areas are
identified are ‘second tier’ areas for management under Section 7c).
Zones reserved for high amenity and/or low impact development are relevant to general
‘second tier’ Section 7c and Section 7f matters:
- In the Living Zones a high level of amenity and a low level of nuisance is expected in all
areas. There is an additional focus on amenity outcomes for the General Precincts
(Waikanae Garden Pekawy, Ferndale, Waikanae Golf, Drive Extension), the Low Density
Housing Precincts, the Beach Residential Zone and the Ngarara Zone;
- In the Rural Zones particular regard to landscape, amenity and natural character values is
anticipated in the Rural Dunes and Rural Eco Hamlet Zones. Development in the Rural Hills
Zone is to avoid visual effects on the Rural Dunes, Rural Plains and State Highway 1.
- In the Working Zones a high level of amenity is envisaged for all areas and business
activities are anticipated as the primary use.
- Open Space zones the general character of all open space zones is defined by the
relatively low presence of buildings and structures and by the presence of areas that
facilitate passive and active recreation.
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SEV provisions
Existing controls for network utilities are relevant matters to consider, given the scale and
form of ARA sought in the submissions. Building height controls provide a useful summary of
the general scale of structures that will contribute to the visual context for ARA . Setback and
subdivision controls for each zone are also informative; as measures used to ensure expected
outcomes are achieved for landscape, amenity and urban design. A summary of the SEV
provisions proposed for these matters is included in Appendix 3. In general:
Network utility structure PAS for masts are 12m in residential areas and 18m in rural
zones. Additional controls apply in ONC and HNC areas, ONF/L, ecological sites, geological
sites and where historic heritage features are identified. Network utility masts over 12m
are a discretionary activity in ONF/L.
Building height PAS are generally 8m in rural, residential and open space areas and less
than 12m (3 storeys) in Working Zones. Setback and recession plane rules apply in most
areas. Additional controls for buildings apply to HNC, ONC, Ecosite and ONF/L areas.
Buildings in ecosites are a discretionary activity.
1.4.4 Other District Plans A review of the ARA controls applied in other Districts is useful background to this assessment,
particularly where there are similarities in landscape and built environment context; as in the
Horowhenua and combined Wairarapa Districts.
In the Wellington region:
Porirua City Council, Hutt City Council and Upper Hutt City Council specifically exclude ARA
from the ‘Utility Network’ sections of their plans and do not address this activity elsewhere.
The combined Wairarapa District Plan provides for an ARA configuration with a total height of
12m in Residential areas and 20m in Rural Zones.
Wellington City Council includes specific provisions for amateur radio in the Utility Section of
the District Plan through Plan Change 74 and following an Environment Court Decision (March
2013). PAS adopted are generally in line with PAS for buildings; typically 8m (refer to Appendix
4 for a more detailed description of the provisions and the case law decision).
Horowhenua District Council, at the boundary of the District and region, has set a 13.5m limit
for ARA in residential areas and 20m in rural areas.
PAS for height in other Districts are generally 15 to 20.
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In Summary:
Council Height/zone
Christchurch City 17 metres
Far North District 20 metres (except for Russell township which is historically significant, where that height requires a Discretionary consent)
Grey District 20 metres
Hamilton 20 metres
Horowhenua 13.5 metres in Residential Areas and 20m in Rural Zones
Napier 17 metres
North Shore City 15 metres (primary support structures) 9 metres (secondary support structure)
Selwyn District 20 metres
Tauranga City District 20 metres in Rural and Rural Residential Zones
Waikato District 15 metres in Living Zone 20 metres in Country Living Zone (maximum of 3 such supporting structures in both zones)
Wanganui District No limits to height or number of supporting structures
Wairarapa Combined 12 metres in Residential Areas and 20 metres in Rural Zones
Wellington City As per building height PAS (generally 8 metres in Residential Zones)
1.5 CASE LAW
Case law reviewed includes the Tauranga City Council 2012 decision referred to in the KARS
and NZART submission and the Wellington City Council appeal to Plan Change 74 2013. These
proceedings resulted in very different approaches to the management of ARA with PAS in
Taraunga City set at 20m for Rural and Residential areas and Wellington City settling on a
much more conservative approach; the PAS for building height (typically 8m). A summary
review of the decisions and comment on landscape and urban design matters is included in
Appendix 4.
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PART 2 ASSESSMENT FINDINGS AND RECOMMENDATIONS
2.1 KAPITI COAST DISTRICT LANDSCAPES AND BUILT ENVIRONMENT
The characteristics of the District’s landscapes and built environment set the scene for
assessment of ARA effects; as the physical context into which these structures are to be
integrated and where they are more, or less, likely to ‘fit’.
In broad terms the landscapes and patterns of settlement of the District are defined by land
type :
Kāpiti Island and the smaller islets are characterized by regenerating coastal forest,
prominent topography, and steep west facing cliffs with limited built structures linked to
conservation initiatives and eco-tourism.
On the mainland, there is a deep coastal plain with dune land and river corridor
landscapes. These areas are characterised by undulating topography, modified landcover
with minor areas of remnant lowland forest and smaller scaled wetland and estuary
landscapes . Most residential and business activities (Living and Working Zones) are
located in these lowland landscapes. The larger settlements, at Paraparaumu and
Waikanae, are located in the broader dune lands developed in the lee of Kāpiti Island and
along the Waikanae River. Beach side settlements to the south of Peka Peka, are a further
feature (originally established to support the coastal coach route) and are popular with
Wellington commuters. In the southern half of the District this has meant a transition
from economic productive landuse to smaller scaled lifestyle lots (Rural Residential, Rural
Dunes and Rural Eco Hamlet Zones.)
A series of escarpments, from Paekakariki to Hemi Matenga (combining Open Space, Rural
Hill and Residential land), mark the edge of the coastal plain in the southern half of the
District and form a backdrop to the main settlement areas. Where there is built
development along these landforms it is particularly prominent; such as on the Raumati/
Mataihuka escarpment backdrop to Paraparaumu. This is because the undulating
landscapes of the coastal plain provide open views to these areas, as landmarks and
valued features in views from urban areas.
To the north of Hemi Matenga escarpment, the Otaki River flood plain creates a broader
and flatter landscape (generally to the east of State Highway 1) with larger scale
productive landuse (Rural Plains zone) located on fertile silt based soils. Reduced pressures
for growth have resulted in a coarser grain of settlement on the plains and the dune land
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landscapes (Rural Dune zone) to the east of SH1, when compared to the southern half of
the District. Development at the smaller beach side settlements of Te Horo, Otaki Beach
and in the Otaki township, have also progressed at a slower rate and have a more rural
vernacular, being generally outside the ‘commute extent’ for Wellington.
Narrow gorge landscapes and enclosed valleys feature in the upper reaches of the river
systems and behind the coastal escarpments with rural residential type settlement (Rural
Hills zone).
The landscapes of the Akatarawa and Tararua ranges. Along the foothills, these feature
mixed landuse, including forestry and more extensive farming with significant areas of
regenerating indigenous forest (Rural Hills zone).
Beyond the foothills, the broadscale landscapes of the Akatarawa and Tararua ranges; the
main backdrop to the District. These areas are largely uninhabited (Rural Hills, Open Space
Conservation zones), clothed in indigenous forest from lowland to alpine types with
prominent peaks, such as Mt Hector at 1529m above sea level, forming landmarks that can
be viewed in many areas of the District.
Overall, low density and low-level commercial development has been maintained in these
landscapes, despite relatively rapid growth rates in recent years. Most buildings in the District
are one or two storeys high (up to 10m). Larger structures are typically the result of required
infrastructure, such as utility networks (generally 10-12m high), with larger national grid
transmission line structures (over 20m) being located through the coastal plain and foothills of
the District (see Section 1.2.2 above for a more detailed description of similar structures and
Section 1.4.3 for a summary of built environment PAS).
In general terms, these broader patterns of landscape and built environment mean that the
effects of ARA, as proposed in the KARS submissions, are likely to require active management.
This is mainly because the characteristics of the coastal plain, with its undulating terrain,
sparse patterns of vegetation and low-lying buildings, do not provide an adequate visual
context or existing pattern of larger structures and/or screening elements to reduce effects. In
open, flatter landscapes with low-level development, larger structures are more prominent.
This means they can be viewed from greater distances, by more people and will appear as
distinct structures, when compared to the general pattern of low -level development. This will
increase the potential for adverse effects. In addition, locations with greater elevation in the
coastal plain, for example, along a dune ridgeline or on the backdrop of escarpments would
increase the structures prominence and the likelihood of adverse effects.
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Important landscape areas, requiring more active management of ARA effects, have been
identified under the RMA , NZCPS and RPS (refer to Section 1.4.1 above) and are mapped in
the SEV. This includes areas of HNC and ONC (Waikanae Estuary and Kāpiti Islands) located in
the coastal environment and ONF/L7 located in duneland, river and escarpment areas and in
the Akatarawa and Tararua ranges. Along with other heritage features, these comprise the
District’s most valued or ‘first tier’ areas for landscape management.
SAL8 or ‘second tier’ landscapes are identified in the SEV. Whilst these areas have not been
assessed as ‘outstanding’ under the RMA, they are highly valued for their unique combination
of values and contribution to the District’s amenity; where best practice requires the effects of
structures to be more actively managed.
Areas where ARA are more likely to ‘fit’ in the District are generally defined by the Rural Plains
and the Rural Hills zone (excluding the escarpment backdrop that are identified as ONF/L or
SAL). These areas provide the most appropriate context for ARA type activities, as the
landscapes are of a coarser grain, include a greater pattern of utility type structures and, in the
foothills, there are screening elements such as intervening landform and vegetation that will
help reduce effects.
2.2 LANDSCAPE AND URBAN DESIGN EFFECTS
A landscape and urban design effects assessment will consider the nature and extent of the
proposed structure (refer to Section 1.2.2 and 1.3), the physical context or receiving
environment in which it will be located (described in part in Section 1.4.3 and summarized in
Section 2.1 above) and the policy context (refer to Section 1.4).
Considering these matters together:
In rural areas, the likely effects of ARA will be on natural character, perceptual values and
views of identified landscape areas as well as the visual amenity of properties in close
proximity. In urban areas, the risks relate to visual amenity from close views and the overall
quality and pattern of the built environment. Potential cumulative effects are a further matter
to be managed in close views and the wider visual context. In summary:
7 Eleven ONF/L areas have been identified in the SEV: Waiorongomai Dunes, Otaki River Mouth, Otaki River Gorge, Tararua Ranges, Kāpiti Islands, Ngarara Dunes, Waikanae Esturay, Hemi Matenga Escarpment, Akatarawa Corridor, Pakekakariki Escarpment.
8 Sixteen SAL areas have been identified in the SEV: Waitawa – Waiorongomai Dune Lakes, Northern Beaches, Waitohu Stream Mouth, Pukehou, Rangiatea and Pukekaraka, Lower Otaki River, Hautere Totara Grove, Otaki Gorge Foothills, Te Hapua Sea Cliff, Te Hapu Dunes, Lower Waikanae River, Reikorangi Village, Otaihanga Foothills and Nikau Escarpment, Mataihuka Escarpment, Southern Beaches, Wainui.
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2.2.1 Natural Character
Buildings and structures are generally accepted to have an adverse effect on natural character,
even where their footprint is relatively small. These effects will be primarily due to perceptions
and visual dominance. Height, and a range of other location and design factors (refer to
Section 2.2.3 below), will influence dominance. Reference to existing controls for buildings and
network utilities is also relevant. Restricted discretionary rules apply to areas of HNC and ONC
in the proposed provisions in the SEV with matters to consider including “scale, location and
design of buildings or structures” .
2.2.2 Outstanding Natural Features and Landscapes and Special Amenity Landscapes
ONF/L’s are identified through a consideration of natural science, sensory and shared and
recognized factors. Natural character values will be at least moderate in an ONF/L with
potential effects of ARA to be managed along with any adverse impact on perceptual matters
such as existing views from public roads and urban areas. Controls applied to other structures
in the SEV to protect these values include restricted discretionary and discretionary standards.
Network utilities are a restricted discretionary activity in ONF/L areas. Above 12m, network
utilities are discretionary. In the SEV, all buildings are discretionary in ONF/L areas unless
under 6m tall and 54m2. Controls in SAL are generally limited to the underlying rules for each
Zone. However, network utility structures are a restricted discretionary activity and require a
consideration of the effects on identified values; as detailed in the PDP schedules.
2.2.3 Amenity and the Quality of the Built Environment
Potential effects on amenity and the quality of Kāpiti Coast District built environment will
result from changes to existing views and the pattern of structures with a similar scale and
form. Similar structures will be utilitarian type such as power poles and network utilities. There
will be a range of location and design (appearance) factors that will influence effects and these
may be different for each viewing audience type. Overall, a landscape and visual effects
assessment would evaluate how well the ARA ‘fits’ into the existing environment and, or
detracts from the amenity9 or quality of the built environment. Relevant policies for an area
would also be addressed, as they provide guidance on the expected outcomes for amenity and
identified risks around cumulative effects.
Location factors
9 Amenity, as defined in the RMA - “natural or physical qualities and characteristics of an area that contribute to people's appreciation of its pleasantness, aesthetic coherence, and cultural and recreational attributes”.
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This will include a consideration of:
Visual catchment – the area where the ARA may be able to be seen from and the scale of
the viewing audience. A smaller visual catchment will mean the viewing audience is
reduced. Topography and built or natural screening elements will have an impact on this;
in general terms ARA will have a greater visual catchment in flat open spaces or when
located on the tops of hills or discrete landforms. Height will increase the visual catchment
and the total viewing audience.
Topography – where a structure is elevated above the viewer, it will appear more
dominant, particularly if it projects above the landforms or ridgeline behind it. Structures
set below a viewer may also have increased effects, where the broader antenna is lifted up
into the typical field of view.
Existing visual context. In particular, the extent with which existing structures of a similar
scale, form and function provide an appropriate setting. Where there is a broader range of
larger and more utilitarian type vertical structures, such as in rural environments, larger
ARA will have reduced effects. Visual context will also determine the potential for
cumulative effects, as described in more detail below.
Type of view and how well this is recognized or valued in the District. Structures impacting
on views of Kāpiti Island, for example, will have greater adverse effects on visual amenity.
In a more everyday context, views to and from the street, indoor and outdoor living areas
or with a sunny aspect are likely to be more highly valued. In practical terms, for example,
this will mean that if ARA are located in the rear yard of a residential lot effects will be
reduced.
Distance and setback – increased distance between the viewer and structure will reduce
effects, as the apparent height and the portion of the view it takes will be diminished.
Relatively small differences in viewing distance, as provided by setback controls, can make
a difference. Dominance will not be diminished by increased height, particularly if the
structure is lifted above the natural field of view. An increase in height will also increase
the total viewing audience.
Frequency of the view –changes to permanent views e.g. from residential dwellings will
result in greater adverse effects compared to fleeting views, as experienced from moving
vehicles. However, changes to views from identified routes, such as State Highway 1,
would have greater weight in the assessment as required by policies in the PDP.
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Design factors
This will include a consideration of:
Bulk and scale – dimensions of the overall structure as well as the individual components.
The ARA dimensions will influence the size of the visual catchment, how easily the
structure can be seen at a distance and how dominant or cluttered it appears in close
views.
Coherency and visual clutter – the range of components that make up a structure. Simple
forms with fewer components and angles will be less dominant. Larger ARA will be visually
‘busy’ particularly when combined with smaller installations on the same lot. Clutter,
resulting from vertical, horizontal and angled elements, guy wires, slender poles combined
with lattice support structures and variable antenna, will increase adverse effects on visual
amenity and the built environment.
Contrasting colours – will stand out against other built forms, land or sky. Network utilities
are typically dark grey, as this is seen to be recessive against varying land and sky
backdrops.
Viewing audience
The total size and types of viewing audience will have an influence on the overall effects of an
ARA:
The greater the viewing audience, the greater the overall effects. The total viewing
audience will increase where the height of the support structure is greater than the PAS
for other structures and, or, the ARA is located on elevated land.
Viewing audience types for ARA will combine close and distant views from:
- roads and footpaths for motorists, cyclists and pedestrians;
- open space areas for cyclists and pedestrians;
- residential dwellings for neighbouring properties and distant properties in the visual
catchment with an open view to the site;
- other commercial activities;
In general, the potential effects of ARA will be greater in close views, for residents and
motorists, cyclists and pedestrians from public spaces (roads, parks). However, broader
patterns of built form and views from a distance are likely to be important where the ARA
height is increased or located on a prominent location, such as the escarpment backdrop to
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the District’s town centres. In addition, changes to both close and distant views will contribute
to an assessment of cumulative effects.
2.2.4 Cumulative Effects
Larger ARA will form part of a pattern of utility type structures in the District and therefore
there is the potential for cumulative effects on landscape and built environment values. Best
practice cumulative effects assessment guidance is summarized in a paper prepared for
Horizons Regional Council10. This includes references to a number of Environment Court cases,
a working definition of cumulative effects - as being ‘additive, concerned with effects of the
proposal in combination with existing structures- and a generally accepted approach to
assessment. In terms of landscape and urban design matters, a project specific approach is
used; with specific policies and identified natural character and landscape areas providing a
focus to the areas of increased risk. The SEV identifies particular risks around the management
of cumulative effects in Policy 3.8 for:
“ecological sites, geological sites, outstanding natural landscapes, key indigenous tree species,
significant indigenous vegetation, significant habitats of indigenous fauna and rare and
threatened vegetation species .”
An assessment of cumulative effects are required to manage the effects of use and
modification of historic heritage in Policy 10.6.
Policy 5.31 requires cumulative effects to be considered when assessing the appropriateness
of non-residential activities in Living Zones.
Policy 8.10 addresses the risk of cumulative effects from “the proliferation of buildings and
structures in a given open space zone.”
In practice, PAS for all built structures and the factors to consider in restricted discretionary
activities provide an important management tool to limit cumulative effects.
For ARA, the risks occur at two scales; that of the neighbourhood (in close views); and for the
wider visual catchment and built environment. On a particular site, there is a risk that the
addition of a further support structure and antenna, while relatively insignificant on its own,
will ‘tip the balance’ and over utilize the visual amenity resource for neighbours, motorists,
pedestrians and cyclists travelling along the street. The risk of close view cumulative effects
10 Simpson and Grierson, Philip Milne (2009). When is enough, enough? Dealing with cumulative effects under the Resource Management Act. Accessed October 2015 at https://www.horizons.govt.nz/assets/new-uploads/about-us/one-plan/submitters-expert-evidence-2/general-hearing/Attachment-to-TAG-Witness-Statement-Dealing-with-cumulative-effect-under-the-RMA-Rec-29-June-2009.pdf
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will be increased by additional support structures and antenna and where groups of ARA are
located along the same street.
An assessment of cumulative effects in the wider context will consider the numbers of existing
ARA activities and other similar structures in broad views from public viewpoints. In this case,
increased height is far more likely to contribute to cumulative effects, as this will mean that
the structure can be viewed in combination with other similar structures and from a greater
range of viewpoints. Cumulative effects will arise where the addition of the ARA into the
existing views results in a ‘step too far’ for the resource to be managed including, as
appropriate, natural character, identified landscape values, amenity and the quality of the
built environment.
2.2.5 Effects of ARA
Effects of particular ARA will vary depending on a range of location and design factors and the
potential cumulative effects. A 7 point scale is often used in a best practice landscape
assessment to summarize the scale of effects from: very low, low, low to moderate,
moderate, moderate to high, high, very high. In RMA terminology ‘very low’ effects are aligned
with effects that are ‘less than minor’ and ‘low’ effects with ‘minor’ or ‘no more than minor’
effects. All other points on the 7 point scale are aligned with effects that are ‘more than
minor’; where it is reasonable to assume Council will require greater controls to ensure
appropriate management.
In general terms, for the PAS proposed in the submissions11 and excluding consideration of
areas with greater risk identified under Section 6 or 712 of the RMA :
Living Zones
The effects on close views in residential areas are likely to be high or very high. This is due
to both the scale and number of ARA configurations proposed.
The effects on distant views and the quality of the urban environment in residential areas
are likely to be moderate to high. There is very little visual context for 20m or taller
structures in the urban environment in Kāpiti with most buildings being relatively low scale
and under 8m in height and other structures (light and power poles, utility network masts)
11 In summary: 20m in Living Zones and 30m in Rural Zones with dish antenna up to 1.2m in diameter where 5m above the ground and no controls on wire type antenna width. Refer also to Section 1.3
12 HNC, ONC, SAL and ONF/L, Ecosites, Historic Heritage Places and Features, Geological Sites and Waahi Tapu
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generally under 12m. Twenty metre ARA, as requested in the submissions, are likely to be
prominent and appear out of place in the Kāpiti urban environment.
Rural Zones
The effects on close views in rural areas are likely to be moderate or moderate to high.
Thirty meter support structures are taller than most national transmission line towers in
the District and combined with broad antenna these are likely to be dominant and appear
obtrusive to near neighbor’s.
The effects on distant views in rural areas are likely to be low to moderate or moderate.
2.3 RECOMMENDED PROVISIONS
Recommendations for planning provisions to integrate ARA into the existing Kāpiti Coast
landscape have been informed by the background review and assessment of likely effects. Key
aspects to be drawn from this review include:
There is a need to address landscape and urban design effects of ARA as per similar
structures under the RMA, NZCPS and the RPS;
ARA sought by KARS and NZART are similar in form and scale to network utilities;
Building height and location controls provide a further relevant reference; as they address
the general scale of built forms anticipated in a zone or area and the measures required to
provide expected urban design outcomes;
Potential effects of ARA and network utilities relate to natural character, identified
landscape values, visual amenity, the quality of the built environment and cumulative
effects;
Existing controls for network utilities have been established to ensure effects are avoided,
and a reasonable level of service is provided. Following the consideration of all Part 2
matters, a resource consent is required for all network utility configurations over 20m;
including RBI type structures which generally require heights in excess of 20m to operate.
The potential effects of 20m+ structures in the District are considered significant enough
to warrant further scrutiny and management irrespective of their operational
requirements and public benefits.
ARA differ somewhat from network utility structures in terms of landscape and urban
design effects. Typically, they are less bulky – with lattice type support structures and wire
type antenna rather than monopoles and headframe mounted antenna. This reduces their
potential effects when viewed from a distance. However, at close range the effects are
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likely to greater, as they are likely to include a greater range of components with varying
alignment, resulting in visual clutter.
The risk of cumulative effects is greater for ARA, as they can be grouped on a site and in a
neighbourhood and are highly variable. Both close and distant view cumulative effects
would be relevant issues to address in the final PAS proposed.
The Kāpiti Coast District Plan provides good guidance as to the areas where the effects of
ARA could be an issue (HNC, ONC, ONF/L, Ecosites, Historic Heritage Places and Features,
Geological Sites and Waahi Tapu), due to impacts on identified natural and cultural values
and where there are particular hazards to avoid (Fault and Flood Avoidance Areas).
Expected outcomes for low impact development and amenity and identified priority uses
for some zones also mean that further scrutiny of ARA is warranted (Rural Residential,
Rural Dunes, Rural Eco Hamlet, Living, Working and Open Space Zones).
ARA activities are provided for in the Kāpiti Coast District with existing structures typically
less than 10m in height. High Frequency13 (HF) configurations are a specialist ARA with
greater height requirements for long distance communication. It is unclear how essential
HF and larger ARA type structures are to public good uses such as search and rescue, civil
defense and community radio.
ARA are diverse and subject to change due to technology advancements and
experimentation. It can be difficult to write provisions that cover all possible types or
configurations. To avoid ‘redundancy’ general location and design factors should be
referred to rather than specific types of ARA. Clarity around height and width limits will be
important, to ensure component and combined dimensions are readily distinguished.
Definitions for the components that make up an ARA should avoid reference to particular
brands and provide for new developments. As a starting point, the following can be
considered:
-ARA: “A radio communication service for the purpose of selftraining, intercommunication
and technical investigations carried out by amateurs, that is, by duly authorised persons
interested in radio technique solely with a personal aim and without pecuniary interest.” 14
13 HF – High Frequency antenna; as required for long distance communication, refer to 1.2.2 for further explanation.
14 ITU Radio Regulations – Article 1, Definitions of Radio Services. Accessed November 2015 at: http://www.ictregulationtoolkit.org/en/toolkit/notes/PracticeNote/2824
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- antenna: transmitting and receiving components of ARA, generally wire, panel or dish
type including, but not limited to, doublet, dipole, whip type, discone and boom mounted
multi directional types (also referred to as Yagi type antenna).
- support structures (for antenna): including but not limited to ground and roof mounted
timber and steel pedestal type structures, monopoles and lattice type structures (also
referred to as masts).
- guy wires (for support structures and antenna), as required to help secure support
structures and/or antenna.
2.3.1 Permitted Activity Standards
Effects of ARA can be managed through a range of permitted, restricted and discretionary
activity standards. With reference to the KARS submission:
2.3.1.1 Rural Areas
Rural Plains and Rural Hill Zones
These areas will be able to integrate a greater number of ARA and support structures with
increased height. This is because lot size (minimum 1ha, average 6 ha and 20ha) provides for
greater setback and existing large scale utility structures contribute to the visual context. With
appropriate PAS this means ARA are more likely to ‘fit’ into the larger scaled rural environment
than in other areas in the District.
PAS recommended:
Up to 6 ground mounted support structures less than 120mm in diameter and less than
9m in height total (including antenna) providing front/road and rear/side setbacks are met
(including antenna). One wire antenna per support structure to be a maximum of 1.5m in
width with components no more than 30mm in diameter or a continuous thin wire
between support structures. No dish or plate antenna to be attached.
Comment: Recommended support structure number and diameter are as requested by
the KARS submission. Setback controls are recommended to help reduce effects on visual
amenity for views from public roads and nearby properties. Setbacks of this order are
easily achieved in the Rural Hills and Rural Plains Zone.
A maximum of one support structure with a total height of 20m (including antenna)
providing front/road and side/rear yard setback standards are met (including antenna).
The maximum diameter of this support structure will be less than 600mm above 6m. One
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wire type antenna to be a maximum of 3m in width including all components and
maximum 30mm diameter for all components.
Comment: The total height permitted for network utilities in the Rural Hill Zone is 18m and
the maximum permitted height is 25m in the Industrial Zone. Twenty metres provides
some concession towards operational requirements for HF15, is in proportion with other
existing vertical elements (including infrastructure elements and larger scaled exotic trees)
and will ‘fit’ with the general scale or grain of the Rural Hills and Rural Plains environment.
A height of 30m is considered a ‘step too far’ and is not supported by recent case law or
adopted in any of the District Plans reviewed. The 600mm diameter limit is equivalent to
that set for network utility structures but in most cases less effects can be anticipated; as
where lattice type support structures are more commonly used.
A maximum antenna width of 3m would provide for Yagi type antenna and is similar to the
headframe (where several antennae are fixed to a circular structure as a permitted
activity) width of network utilities found in rural environments. Antenna greater than 3m
in diameter are likely to appear ‘top heavy’ and would require additional guy wires. This
would increase visual clutter.
Up to one dish or panel type antenna attached to ground mounted support structure at a
maximum height of 18.5m and a maximum diameter or 1.2m or area of 0.8m2 or up to one
dish or panel antenna, maximum diameter 2m or area of 2m2 attached to a ground
mounted support structure at a maximum height of 5m.
Comment: Maximum size of dish/panel antenna at 18.5m is in line PAS for network
utilities. Maximum size of dish/panel antenna at 5m height is consistent with Tauranga City
PAS and would set the top of the panel 1m below the permitted building height of 8m. The
limit recommended for number of wire type and dish/ panel antenna is to address
potential cumulative effects.
Up to one building mounted dish or panel type antenna with a maximum diameter of 2m
or area of 2m2 or one wire type antenna with a total width of no more than 3m. Any
building mounted antenna to be a total height of no more than 5m above the permitted
building height and to comply with Zone building setbacks. All building mounted support
structure components to be less than 120mm in diameter;
All antenna are included in the ground and building mounted total height limits;
15 HF – High Frequency antenna; as required for long distance communication, refer to 1.2.2 for further explanation.
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Guy wires should be no more than 10mm in diameter and shall not extend beyond the
boundaries;
All support structures, antenna, guy wires and other ARA components to be coloured dark
grey or galvanized steel; non reflective and recessive.
Further measures to be considered as PAS to reduce effects include:
Support structures must not be located on top of dominant ridgelines or dominant sand
dunes, or in such proximity to the ridgeline/dune ridge that more than 3 metres of the
height of the structure protrudes above the ridgeline, if silhouetted onto the skyline, when
viewed from any public place or road;
Comment: This provision is equivalent to that required for all Rural Zone buildings and
structures in PAS 7A.1.4
The location and design shall consider measures to reduce effects on natural character,
identified landscape values and amenity effects including:
- layout and design to avoid visual clutter by reducing the numbers and types of
configurations on any one lot;
- location to set support structures and antenna against a land backdrop and to screen ARA
from public views;
- reducing cumulative effects by limiting the number of ARA in close proximity.
Comment: Similar low impact ‘guidance’ is provided for development within the Rural Eco
Hamlet Zone e.g. PAS 7A.1.10.3 “Individual lots shall be landscape and planted to a)
visually reduce the bulk of the buildings. d) Protect or maximize visual privacy”. Whilst not
able to be assessed in a permitted activity, non statutory ‘design guides’ are not
uncommon, may be picked up voluntarily, can be discussed in general enquiries to
planning officers and are consistent with the matters recommended to be considered in
restricted discretionary activities set out in 2.2.2 below.
Rural Residential, Rural Eco Hamlet and Rural Dune Zones
There is greater potential for effects in these areas due to reduced average and minimum lot
sizes and proximity to urban areas (increased total viewing audience). A high level of amenity
and development to ensure well integrated structures is clearly set out in the policies for
subdivision and development, particularly for the eco hamlet and dune areas and in PAS for all
buildings and other structures. Options for setback are reduced and the potential for
cumulative effects is increased by lot density and viewing audience. This means that the
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number and height of ARA able to be successfully integrated without inappropriate effects is
reduced.
PAS recommended:
Up to 3 ground mounted support structures less than 120mm in diameter and less than
9m in height total (including antenna) providing front/road and side/rear setback
standards are met (including antenna). One wire antenna per support structure to be a
maximum of 1.5m in width with components no more than 30mm in diameter or a
continuous thin wire between support structures. No dish or plate antenna to be attached;
or
A maximum of one support structure with a total height of 15m (including antenna)
providing front/road and side/rear yard setback standards are met (including antenna).
The maximum diameter of this support structure will be less than 600mm above 6m. One
wire type antenna to be a maximum of 3m in width including boom and maximum 30mm
diameter for all components.
Comment: A reduced number of ARA configurations provides more certainty around
appropriate setback and limits visual clutter. Reduced height (compared to permitted
network utility structures of 18m) is recommended as more appropriate to the general
scale and grain of these areas in terms of landscape (generally rolling dune land) and
existing structures (building height 8-10m) and to be consistent with the low impact
development and amenity outcomes identified in the SEV policies for these areas.
Up to one dish or panel type antenna attached to ground mounted support structure at a
maximum height of 13m and a maximum diameter or 1.2m or area of 0.8m2 or up to one
dish or panel antenna, maximum diameter 2m or area of 2m2 attached to a ground
mounted support structure at a maximum height of 5m.
Up to one building mounted dish or panel type antenna with a maximum diameter of 2m
or area of 2m2 or one wire type antenna with a total width of no more than 3m and
maximum 30mm diameter for all components. Any building mounted antenna to be a total
height of no more than 5m above the permitted building height and to comply with Zone
building setbacks. All building mounted support structure components to be less than
120mm in diameter.
All antenna are included in the ground and building mounted total height limits.
Guy wires should be no more than 10mm in diameter and not to extend beyond the
boundaries.
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All support structures, antenna, guy wires and other ARA components to be coloured dark
grey or galvanized steel; non reflective and recessive.
‘Further measures’ as stated for Rural Hill and Rural Plains Zones are also recommended.
2.3.1.2 Living Zones
A high level of residential amenity and a low level of nuisance is sought in all Living Zones.
Small lot sizes and increased viewing audience, places further limits on the nature and extent
of ARA that can be successfully integrated. Permitted building heights (generally 8m) assume
greater relevance in residential environments. Structures above the typical building height will
assume greater dominance, particularly in close views, as buildings form the main point of
reference or visual context. Taller structures in this environment (network utilities and power
and light poles) are generally under 12m and provide a relevant context for ARA structures of a
similar height. However, to avoid effects that are inappropriate (‘more than minor’ in RMA
terminology) additional design and location controls will be required.
PAS recommended:
Up to 3 ground mounted support structures less than 120mm in diameter and less than
9m in height total (including antenna) providing 1.5m setback from all boundaries
(including antenna). One wire antenna per support structure to be a maximum of 1.5m in
width with components no more than 30mm in diameter or a continuous thin wire
between support structures. No dish or plate antenna to be attached; or
A maximum of one larger ground mounted support structure in rear or side yard only with
total height of 12m (including antenna) providing 1.5m setback from rear and side
boundaries (including antenna). The maximum diameter of this support structure will be
less than 300mm above 6m. One wire type antenna to be a maximum of 2m in width
including boom and maximum 30mm diameter for all components.
Up to one dish or panel type antenna attached to larger ground mounted support
structure at a maximum height of 10m and a maximum diameter of 1.2m or area of 0.8m2.
Up to one building mounted dish or panel type antenna with a maximum diameter of 1.2m
or area of 0.8m2 or one wire type antenna with a total width of no more than 2m including
boom and maximum 30mm diameter for all components. Any building mounted antenna
to be a total height of no more than 2m above the permitted building height and to
comply with zone building setbacks. Building mounted support structure components to
be less than 120mm in diameter.
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All antenna and other components of the ARA are included in the ground and building
mounted total height limits.
Guy wires should be no more than 10mm in diameter and shall not extend beyond the
boundaries.
All support structures, antenna, guy wires and other ARA components to be coloured dark
grey or galvanized steel; non reflective and recessive.
‘Further measures’ as stated above under rural zones are also recommended.
Comment: The recommended PAS would provide for taller ARA configurations than currently
exist in residential neighbourhoods. However, other structures such as street lights, power
poles and permitted network utilities will provide some visual context and help ensure they
can be integrated into the environment. Rear or side yard location for the larger support
structure will reduce effects; ensuring some screening when viewed from the street. Setback
controls recommended are as per the minimum side yard for Beach Residential areas. This is
easily achieved in most residential sections. In contrast, network utilities must be located 5m
from property boundaries in Living Zones. Limits placed on the number of ARA configurations
reduce the potential for cumulative effects and visual clutter. Overall, these controls will
provide for residential amenity and reasonable options for ARA enthusiasts to construct:
- three 9m ARA with, for example, whip or discone type antenna plus a further roof mounted
residential scale Yagi or dish/plate type antenna; or
- one 12m ARA in the rear or side yard with small scale co-located dish/plate type and Yagi
type antenna plus a further roof mounted antenna of a residential scale .
There is still a residual risk of cumulative effects should a number of nearby residents take ‘up
this offer’ and multiple configurations are installed as permitted activities along the same
street. Currently this risk is mitigated by low member numbers in the District.
A PAS of 12m is lower than what has been adopted in most of the District Plans reviewed with
the exception of Wellington City Council; where the PAS for ground mounted ARA in
residential areas is generally 8m (the PAS for building heights). However, as is more relevant to
Kāpiti landscape and built environment context, the Combined Wairarapa Plan has adopted a
12m limit and Horowhenua District Council settled on 13.5m in Residential Zones (the PAS for
network utility support structures in the Horowhenua District). In addition to height, other
design and location matters have been considered in the PAS recommended in this
assessment (see 2.1 above). Overall these recommendations provide for a much more
comprehensive set of controls that limit effects on landscape and built environment values.
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2.3.2 Restricted Discretionary Activities
For Special Amenity Landscape areas, a restricted discretionary status is recommended for
ARA.
Comment: This is to ensure effects on specific values identified in SAL are addressed in the
location and design of ARA; as perceptual values are often a strong contributing factor to SAL
(such as the escarpment backdrop to urban areas) and a risk posed by these structures. This is
consistent with the approach proposed for network utilities in the SEV.
In addition, restricted discretionary activity status is recommended for all ARA activities in
Rural and Living Zones which are not permitted.
Recommended matters over which Council should restrict its discretion are in line with the
network utility activities Rule 11A.3.4 with further consideration of cumulative effects:
1. Any positive effects to be derived for the activity
2. Any opportunities to reduce existing adverse effects on sensitive activities
3. Health and safety
4. Layout, design and location of proposed structure
5. Colour and materials of proposed structure
6. Visual, character and amenity effects
7. Public safety
8. Effects on Special Amenity Landscape values
9. Effect on natural character
10. Effects on historic heritage
11. Natural hazard risk management
12. Adequacy of the methods of mitigation/remediation or ongoing management.
13. Cumulative effects
Comment: Such an approach would ensure ARA are treated in the same way as similar
structures whilst recognizing the potential for increased cumulative effects.
2.3.3 Discretionary Activities
Discretionary activity status is recommended for ARA in areas where there are national
matters of importance to address, under Section 6 of the RMA, an area is clearly identified for
other uses in terms of urban design and where particular hazards exist:
Areas of HNC and ONC, ONF/L, Ecosites, Historic Heritage Places and Features, Geological
Sites and Waahi Tapu;
Open Space Zones;
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Working Zones; and
Flood and Fault Avoidance areas.
Comment:
Greater controls for ARA in HNC and ONC, ONF/L, Ecosites, Historic Heritage Places and
Features and Geological Sites and Waahi Tapu is consistent with recognizing and providing for
matters of national importance under Section 6 of the RMA and a best practice cautionary
approach. In contrast, the SEV applies restricted discretionary rules to network utilities in
these areas with discretionary rules limited to ONF/L areas for network utilities above 12m.
The general character of Open Space areas is defined in the PDP as having a relatively low
presence of buildings and structures. Greater controls for structures can therefore be
anticipated and are relevant to landscape and urban design matters; to ensure these areas
facilitate expected outcomes of passive and active recreation. Network utilities are a
permitted activity in Open Space Zones (12m) under the SEV.
PDP objectives and policies establish business activities as the primary use for Working Zones.
Best practice urban design would anticipate additional controls to be proposed for other ‘not
for profit’ activities such as ARA. Network utilities are a permitted activity in Working Zones
(15-20m) under the SEV.
Avoidance of hazard areas reflects best practice resource management.
In addition to landscape and urban design matters, there may be further differences proposed
in the final PAS for ARA and network utilities that result from the Council’s Part 2 assessment.
This is because Council needs to consider matters outside a landscape and urban design
assessment such as differing service requirements and public benefits. For example, stringent
location requirements/set distances between utility configurations are often identified as a
constraint in achieving an efficient network in a District. Based on the background review and
field survey of this assessment, this is less of an issue for ARA. Distances between
configurations in the District vary markedly (see Figure 2) and may be located in close
proximity, for example, where two amateur radio enthusiasts live on the same street. It is
therefore reasonable to assume that ARA have greater flexibility as to where they can be
located in the District and still function; are able to link to other radio receivers and
transmitters inside and outside the District.
Whilst outside the scope of this assessment, public benefits (such as varying roles in essential
services) will also be an important consideration for Council in determining any differences in
the final and most appropriate PAS for ARA and network utilities in the District.
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2.3.4 Summary
Recommended activity status and PAS for height and number of support structures are
summarized below. Differences in the recommendations for each zone or area are highlighted
in bold.
Please Note: Additional recommendations for support structure components, antenna and
guy wires, setback etc. and matters over which Council will restrict discretion are detailed in
Sections 2.3.1 to 2.3.4 above.
Summary of recommended PAS for Support Structures
Zone/Area Recommended PAS for support structures - no’s & dimensions Please Note: Additional recommendations for support structure components, antenna and guy wires, setback etc. are detailed in Sections 2.3.1 to 2.3.4 above
Rural Hills, Rural Plain - up to 6 ground mounted support structures less than 120mm in diameter with a maximum height of 9m (including antenna) - up to 1 ground mounted support structure with a diameter greater than 120mm and maximum height of 20m (including antenna) - up to 1 building mounted panel or dish or wire type antenna with a maximum height 5m above the permitted building height
Rural Residential, Rural Dunes, Rural Eco Hamlet
- up to 6 ground mounted support structures less than 120mm in diameter with a maximum height of 9m (including antenna) or - up to 1 ground mounted support structure with a diameter greater than 120mm and maximum height of 15m (including antenna) - up to 1 building mounted panel or dish or wire type antenna with a maximum height 5m above the permitted building height.
Living Zones - up to 3 ground mounted support structures less than 120mm in diameter with a maximum height of 9m (including antenna) or - up to 1 ground mounted support structure with a diameter greater than 120mm and maximum height of 12m (including antenna) - up to 1 building mounted panel or dish or wire type antenna with a maximum height 3m above the permitted building height
Special Amenity Landscapes Restricted Discretionary Activity
HNC, ONC, ONF/L, Ecosites, Historic Heritage Places and Features, Geological Sites and Waahi Tapu, Working Zones, Open Space Zones, Fault and Flood Avoidance Zones
Discretionary Activity
Non complying activity status is not recommended for ARA, in terms of landscape and urban
design matters. PAS, restricted discretionary and discretionary controls are considered
adequate to require appropriate location and design measures to avoid inappropriate effects,
and, where these measures can not be provided, Council has the option to decline consent.
Overall, however, the most appropriate activity status for ARA will be determined through a
consideration of all Part 2 matters under the RMA. This Part 2 assessment will consider
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matters that are outside the scope of a landscape and urban design appraisal, such as
operational requirements and public benefits. This is likely to have an impact on the final PAS
Council proposes and may result in a more conservative management approach than is
recommended in this report. Increased controls would inevitably reduce the effects on
landscape and built environment values, and in general terms, would be supported by this
assessment. Differing controls for ARA and network utilities are recommended for some areas
in this assessment. This is consistent with a best practice cautionary approach and the
consideration of relevant Section 6 and 7 matters under the RMA. Further distinction in the
final recommended controls for ARA and network utilities may result from the Council’s Part 2
RMA assessment.
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Appendix 1 AMATEUR RADIO CONFIGURATIONS
Radio Frequencies
Amateur radio antenna operate on low to terahertz frequencies within the radio spectrum (1Hz to
3000GHz) of electromagnetic spectrum. High frequency (HF) bands, Very High Frequency (VHF) and
Ultra High Frequency (UHF) bands are the most commonly used. HF is required for long distance
communication while VHF and UHF can be used to cover national and local transmissions including
hand held devices.
Antenna height
For HF (3-30MHz) antenna need to be elevated above the ground to ensure the transmitted waves
are reflected back to the earth’s surface from the ionized layer in the atmosphere. At very low
heights, the critical angle for reflection will not be achieved and the radio wave will pass through the
ionized layer. At non optimal heights the radio waves require more ‘hops’ or bounces to reach their
target (as shown in Figure 3 of Appendix 1 to the NZART submission). This can weaken the strength
of the signal. Options to boost the transmission power may increase interference with other
electronic equipment.
References cited in the KARS AND NZART submission (see Appendix 1 & 2 of the NZART submission)
set an optimal height for HF multiband1 antennas at 15-32m. The submissions also make reference
to a US Federal Preemption (PRB-1) which prevents planning authorities from limiting antenna
heights below 21m unless a restriction is required to achieve a clearly defined health, safety or
aesthetic objective.
In general, lower antenna heights are required for UHF and VHF as long as they are elevated above
the local terrain to ensure a clear horizon.
Antenna types
Antenna used by ARA are highly variable and broadly wire, panel or dish type (refer to Figure 1 in the
attached Graphic Supplement).
Wire antenna can range from a single slender horizontal or vertical element, through to a boom
mounted array with horizontal and/or vertical antenna elements (wires). In their simplest form,
antenna can be a series of wires mounted between poles, often called a Doublet configuration
(horizontal wires connected between two poles and tensioned via a pulley). Common commercial
units include Rubber Duckie and Whip Type (single vertical antenna) Dipole (horizontal antenna),
Discone (wire elements in a cone array) and Yagi (directional) antenna. HF Yagi antenna have wire
1 Multiband antenna - able to use different sections of the radio frequency spectrum
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elements on a horizontal plane whereas VHF and UHF arrays combine vertical and horizontal
elements. Larger Yagi type antenna can be multiband and fitted with a rotator motor, to improve
their performance. Heights and widths of larger antenna vary but are generally limited to what can
be raised manually; no more than 8m wide and 5m high. The receiving/transmitting elements are
relatively narrow, often no more than 20mm in diameter and the boom (on which the array is
mounted) less than 50mm.
Dish antennas used in ARA are often repurposed Sky television units less than 2m in diameter. KARS
note2 that dish antenna are less of an interest to its members but request dish antenna up to 1.5m in
diameter where they are attached more than 5m above the ground and 3m (in urban areas) and
4.6m (in rural areas) below 5m.
Lightning rods
Slender rods may be attached to the top of antenna to prevent lightning strike. These rods are often
difficult to discern against sky and land backdrops and are usually excluded from the calculation for
PAS heights on other structures.
Support structures
Building mounted ARA often use the same fixtures as television aerials.
Ground mounted dish antenna can be mounted on a pedestal type structure typically 4m in height.
Mast type support structures can be guyed or stand alone. Slender pole type support structures (less
120mm in diameter) will be guyed with wires. Above 8-10m, lattice type support structures are
more likely to be used (as they are easier to handle than a monopole), and will be guyed if less than
250mm in diameter. Smaller guyed support structures can be dismantled relatively easily, however
the preference is for permanent installations to provide ease of use.
Taller, self-supporting masts are typically lattice type and, where ladder access is provided, the
horizontal dimension between the lattice ‘legs’ needs to be at least 250mm. Tilt or telescopic
features are available for some support structures but are less preferred due to cost.
A range of support structures used in existing configurations on the Kāpiti Coast are illustrated in the
Graphic Supplement Figures 3-12.
2 KCDC Submitter Meeting Notes July 22nd
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Appendix 2 KĀPITI AMATEUR RADIO SOCIETY INC SUBMISSION
The details of the New Zealand Association of Radio Transmitters Inc (NZART) and the Kāpiti
Amateur Radio Society Inc (KARS) submissions have been reviewed in this assessment. There are
minor differences in the PAS sought. The KARS submission is summarized as follows:
Up to six supporting structures less than 120 mm in diameter and less than 9m in height. Local
thickening is permitted at pole joints;
A maximum of one mast or supporting structure greater than 120 mm in diameter. The
maximum height of the support structure shall be 20m in urban zones (Living and Working)3 and
30 m in rural zones 4;
The maximum horizontal diameter of any mast at heights above 8 m shall be 600 mm;
The minimum setback for any support structure from any boundary shall be 0.5 m;
Antennas and support structures (less than 120 mm in diameter) shall be permitted on buildings
to a maximum height of 20 m above ground level in the residential areas (Living Zones). In all
other areas a maximum height of 20 m; or the relevant permitted or actual building height plus 6
m (whichever is greatest);
Allow dish antennas up to a maximum diameter of 3 metres in urban areas and 4.6 metres in
rural areas, provided that they do not exceed 5 m in height above ground; with a minimum set
back from any boundary of 1 m;
Allow dish antennas more than 5 m above ground with a maximum diameter of 1.2 m; with a
minimum setback from any boundary of 1.5 m; and
Masts and associated support structures are not to be located on a sensitive natural features5 or
a historic heritage feature.
In addition, controlled activity status is requested:
In rural zones and subject to the size, height and set back restrictions above, more than one
mast or supporting structure greater than 120 mm in diameter be permitted; and
In all zones, masts and associated support structures be permitted to be located on a sensitive
natural feature.
3 Living Zones – Residential, Beach Residential, Ngarara Zone, Waikanae North Development Zone
4 Rural Zones – Rural Dunes, Rural Plains, Rural Hill, Rural Residential, Rural Eco hamlet and Future Urban Development
5 Sensitive natural features are now referred to individually in the SEV: as ecological sites, geological sites, outstanding natural features and
landscapes, special amenity landscapes, areas of outstanding natural character and high natural character, rare and threatened vegetation
species, key indigenous tree species and lookout points (including trig points and selected rest areas)
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Appendix 3 SEV PROVISIONS
Utility network controls
The existing controls for network utilities are relevant matters to. In essence, the proposed controls
summarise the measures used to integrate network utility structures into the landscape and built
environment without undue adverse effects.
Summary of network utility controls by Zone – SEV, Kāpiti Coast District Plan (Reference: Chapter 11 Infrastructure, Services and Associated Resource Use)
Zone Maximum height (excludes lightning rod - singular)
Antenna
Residential, Beach Residential, Ngarara, Waikanae North Development (Living Zones)
12m
(600mm diameter mast from 6m)
0.75m diameter
Rural Plains, Rural Dunes, Rural Residential, Rural Eco-hamlet, Rural Hills (Rural Zones)
18m
(600mm diameter mast from 6m)
1.2 diameter
Industrial (Working Zone) 25m (1.5m diameter mast)
5m diameter
Local Centre, Town Centre, Outer Business Centre (Working Zone)
15m (1.5m diameter mast)
0.75m diameter
District Centre (Working Zone) 20m (1.5m diameter mast)
0.75m diameter
All Open Space zones, Private Recreation and Leisure (Open Space and Private Recreation)
12m
(600mm diameter mast from 6m)
0.75m diameter
Airport (Working Zone) 20m (1.5m diameter mast)
5m diameter
The NZART and KARS submissions request taller masts in most zones, larger diameter dish antenna
and 6 smaller diameter support structures, less than 9m in height.
In addition, the PAS for network utilities require:
Masts (including antenna and support structures mounted on a building or freestanding) must
not be located on an ecological site, geological site, outstanding natural landscape, special
amenity landscape, area of outstanding or high natural character or historic heritage feature;
Masts must not be located within 5m from a property boundary in Living Zones (measured from
the outer edge of the mast, excluding the base of foundation), except along the boundary with a
legal road; and
Antenna located on buildings must comply with the recession plane controls in all Living Zones.
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All other network utility configurations are controlled as a restricted discretionary activity with
matters of discretion addressing: health and safety; layout; design and location of proposed
structure; colour and materials of proposed structure; visual, character and amenity effects; public
safety, effects of a geological site, special amenity landscape, or area of outstanding or high natural
character; effects on natural character and effects on historic heritage.
Masts (and other utility structures) in ONF/L areas are a discretionary activity over 12m in height.
Building and subdivision controls
Building height controls provide a useful summary of the general scale of built forms that will
contribute to the visual context for ARA, and therefore what might appear, in contrast, visually
dominant. Setback and subdivision controls provide a further summary of the controls used to
ensure expected outcomes for landscape, amenity and urban design.
Summary of building and subdivision controls by Zone – SEV, Kāpiti Coast District Plan (Reference: Chapter 5 Living Zones, Chapter 6 Working Zones, Chapter 7 Rural Zones, Chapter 8 Open Space Zones)
Zone Maximum height buildings-
Yard setback Subdivision
Residential, Beach Residential, Ngarara, Waikanae North Development (Living Zones)
8m main dwelling
6m Peka Peka Beach Character area
Front/Road - 3m, 4.5m Beach residential
Rear/side - 3m on front lot and 3m from one side and 1.5m all other side years
Rear/side- 3m to rear and sides if rear lot
Note: Precincts have specific PAS
Minimum – 450m2
Average – 600m2- 700m2
Focus infill areas 300m2
Rural Residential, Rural Eco Hamlet, Rural Dunes, Rural Plains, Rural Hills (Rural Zones)
8m for habitable building
10m accessory building
Front/Road – 10m
Rear/side – 5m
Note:
- in Rural Dunes Zone buildings shall not be located in ONL, ecosites or geological sites.
-buildings shall not be sited on top of dominant ridgelines or dominant dunes such that no more than 3m of the building protrudes above the ridgeline without a land backdrop when viewed from any public place
Rural residential – minimum average 1ha, minimum 4000m2
Paraparaumu North Rural Precinct – minimum average 2ha, minimum 1ha
Rural eco hamlet- minimum average 1ha and 1.5ha, minimum 4000m2
Rural Dunes – minimum average 4ha, minimum 1ha maximum for lots with dwellings.
Rural Plains –minimum average 6ha, minimum 1ha
Rural Hills Zone –
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minimum average 20 ha, minimum 1ha
Industrial (Working Zone) 12m (< 3 storeys) - Recession planes apply
Local Centre, Town Centre, Outer Business Centre (Working Zone)
12m (<3 storeys)
-Recession planes apply
District Centre (Working Zone) 12m (< 3 storeys)
Recession planes apply as setback
- Recession planes apply
- 4m setback from Living Zone
All Open Space zones, Private Recreation and Leisure (Open Space and Private Recreation)
4 -8m
- 5m from Living Zone
- 3m from all other Zones
Airport (Working Zone) To protect operational safety of airport
- Recession planes apply
In addition:
Buildings in areas of HNC and ONC are restricted discretionary activities (with matters of
discretion including scale, location and design, effects on natural character, visual amenity
effects, extent of earthworks, ecological and natural character effects, visibility from the beach).
Buildings in ONF/L will not be sited on top of the ridgeline or dominant sand dunes or hills such
that no more than 1m of the height of the building protrudes more than 1m. Buildings in ONF/L
shall be limited in height to 6m, less than 54m2 gross floor area and be non reflective and
recessive (excluding glazing).
Buildings in ecosites and within 5m of the boundary are discretionary.
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Appendix 4 CASE LAW REVIEW
Tauranga City Council (final decision 18th Sept 2012)
The proposed District Plan excluded specific consideration of ARA. Following submissions progressed
to Environment Court, the Plan provides for PAS in Residential and Rural Residential Zones as
adopted in the ‘General – Permitted Intrusion Rules’ section. There are no PAS provided for ARA in
the Rural Zone or other areas in the Plan. Note: wire antenna including Yagi types are referred to as
‘aerials’ and Dish type are referred to as ‘antenna’. In summary the Tauranga City Plan PAS provide
for:
No more than 6 support structures <115mm in diameter for wire aerials providing they are
below the maximum building height. No part of an aerial is to exceed the building height by
more than 2m. These slender support structures would typically be used for Doublet or Whip
type antenna as well as small scale Dipole and Yagi type antenna;
One support structure (pole or lattice type) per site no more than 9m in height with a diameter
of <600mm below 4m and 115mm above this. Building setback rules apply to the support
structure but not the aerial. It is unclear what the PAS is for the total height of the structure;
A further vertical aerial (support structure and antenna combined) per site to a maximum height
of 20m including guyed, lattice or tubular mast with maximum diameter below 9m of 1000mm
and 115mm above this (tubular masts can be 230mm at 9m and 115m at 20m). Guy wires
limited to 12mm diameter. There are no specific setback requirements for this installation. The
courts interim decision6 considers this will be self policing; in order to achieve the boundary
controls, the mast will need to be set back from the boundary;
Horizontal Yagi type can include wire element up to 14.9m in length attached to a boom up to
13m in length. Any elements of any aerial type are limited to 80mm in diameter. While this
means that the aerial elements will be relatively slender, and therefore less visible from a
distance, it is worth noting that the scale of this aerial is significant. By way of comparison, RBI
headframes are typically 5m in diameter;
Dish antenna are limited to 2m in diameter when attached to a building or 5m in diameter if
pedestal mounted on the ground;
Limits on overhang are generally to the site boundary (including guy wires) i.e. building setback
and recession plane rules don’t apply except for pedestal mounted dish antenna;
6 Tauranga Emergency Communications Group Incorporated & New Zealand Association of Radio Transmitters Incorporated versus Tauranga City Council. 2012 NZEnvC107. Interim Decision
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Ecology, ONF/L, important amenity areas and hazard areas, heritage, significant Maori and
archaeological sites are excluded from the PAS; and
All other ARA are restricted discretionary with requirement to consider bulk, form and scale of
support structures and aerials/antenna, visual dominance, visual amenity as viewed by adjacent
properties and surrounding neighborhood; design measures used including location, materials,
finish of materials and colour and access for maintenance to buildings on adjoining sites. For
pedestal ARA; the extent the proposal would result in loss of sunlight and daylight to
surrounding sites.
Environment Court Decision7 When looking at the effects of ARA, the court considered the following matters to be relevant [28-32]: Aerials are relatively common elements in residential areas of Tauranga. ARA activities may be
distinguished by scale;
Comment: A television aerial is typically less than 2m wide and 2m above the roofline. The scale
of antenna provided for in the PAS, with booms 13m in length and attached wire elements up to
14.9m, diminish the relevance of this comparison.
Effects will diminish with distance, neighboring properties are the most likely to be adversely
impacted. Raising the height of the aerial (antenna) would diminish its apparent size, as it
increases the distance to the viewer.
Comment: While distance will diminish effects from a particular viewpoint in the horizontal
plane, vertical shifts do not necessarily reduce effects. Taller structures, particularly those lifted
well above natural field of view, will appear more dominant and imposing. In addition, increasing
the height of support structures will typically increase the number of people that are able to
view the structure. This is likely to increase overall effects.
ARA while utilitarian in appearance are generally less bulky when compared to network utilities.
Comment: Visual clutter in close views is a further matter to consider. Network utilities may be
bulkier but are generally less cluttered or visually ‘busy’ as they are made up of fewer parts and
have less intricate angled components.
Setback is not necessary, as the turning circles required by larger antenna will be self policing
given that the aerial can not project over the boundary.
7 Tauranga Emergency Communications Group Incorporated & New Zealand Association of Radio Transmitters Incorporated versus Tauranga City Council. 2012 NZEnvC107. Interim Decision
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Comment: In my view, this is not assured, given the range of antenna types available. The PAS
provide for a 20m whip type antennae to be located directly adjacent to a boundary.
When considering Part 2 matters of the Act the court considered: [38-40 ]
There will be some amenity impacts, primarily for the adjoining neighbours; others are
disregarded as minimal.
Comment: Where structures are proposed that are significantly greater in height than permitted
buildings, effects on distant views and viewing audiences are generally not discounted as
minimal. The total scale of the viewing audience will contribute to an overall assessment of
landscape and urban design effects.
‘We are unable to see any part of Section 6 that applies to this application’.
Comment: Additional controls for structures including network utilities are commonly accepted
by the court in respect of Section 6a) and 6b) in so far as they relate to ONF/L’s and natural
character.
ARA is an ‘important part of the community particularly in times of emergency’ and as part of the
‘general community, and it too should be provided for, on a reasonable basis’.
Comment: Further clarification as to the ‘public good’ requirements for ARA is recommended.
ARA, including current uses of public benefit, are provided in the Kāpiti Coast District with
support structures and antenna that are generally less than 10m in height.
Wellington City Council Plan Change 74 (final decision 18th Sept 2012)
PAS in the WCC Plan are generally aligned with the permitted building height.
In summary:
There are no limits placed on slender support structures less than 102mm in diameter with guy
wires to be less than 10mm;
Larger support structures (greater than 102mm) are permitted if they are in keeping with the
permitted building height for that zone (generally 8m in Residential Zones). Maximum
horizontal diameter of the structure is 800mm and setback of 1.5m to all boundaries;
When mounted on buildings, support structures with a diameter less than 102mm are permitted
(excludes lattice type structures). In all Residential areas the maximum height of the antennae
permitted is 18m or the relevant permitted building height plus 5m in other areas. For
residential areas, the 18m height limit is likely to require a guyed pole and whip type antenna. In
other zones a more standard television type support structure could also be used to achieve
maximum of 18m or 5m above the permitted building height;
IGL_3582C2 KCDC Amateur Radio Landscape Assessment Report _ final January 2016
48
Dish antenna 4m in diameter are permitted 5m or less above the ground, otherwise 1.2m
diameter;
All other ARA are restricted discretionary in respect of maximum height of the mast and area or
diameter of the antenna, visual effects and siting, historic heritage effects, visual amenity and
landscape effects on identified ridgelines and hilltops, visual and character effects on the
seaward side of identified coastal roads next to the coastal marine area, cumulative effects
associated with co-siting and co-location, the visual amenity effects and siting of supporting
structures, antennas and other attachments.
Environment Court Decision8
In its final decision, the court agreed with the Council that [4] ‘radio masts and antennas of the kind
in question could well have not insignificant adverse effects on the city and suburban environment by
way of interference with views and amenity’. The court accepted the Council’s argument 9 that ARA
should be treated in the same way as all other activities in terms of potential effects.
In their response to the court’s interim decision the Council stated:
“The Council's view is that amateur radio masts are similar to the masts used to support utility
network apparatus, as an amateur radio mast is designed to support aerials, antennas and other
communications apparatus. Accordingly, it is submitted that amateur radio masts should be treated
in the same way as these masts“.
The court agreed with Council that the height and recession plane exclusions applied to chimneys,
flues, ventilation shafts, aerials, spires, flagpoles and other decorative features were irrelevant to
ARA. ARA can be easily distinguished from these structures by scale, the use of lattice type support
structures, complex antenna and guy wires to the boundary.
Comment: This decision emphasizes the relevance of accepted height controls for buildings and
network utility structures when determining PAS for ARA; as is consistent with the policy review
detailed in Section 1.4. In this case, and as a result of a broader Part 2 assessment, a more
conservative approach has been accepted (building heights are generally 8m). That is: in the context
of the Wellington City landscapes and built environment, the court has decided the potential effects
of ARA above 8m are such that they need to be actively managed, irrespective of operational
requirements and any public benefits.
8 New Zealand Association of Radio Transmitters Inc, Wellington Amateur Radio Club, Wellington VHF Group Inc versus The Wellington City Council. In the matter of: appeal under clause 14 of the First Schedule of that Act in relation to PC 74 (Telecommunication Structures) 2013. NZEnv C38.
9 In the matter of: appeal under clause 14 of the First Schedule of that Act in relation to PC 74 (Telecommunication Structures) Memorandum of counsel on behalf of the Wellington City Council. 20th February 2012
Kāpiti Coast District Council Proposed District Plan
PROPOSED DISTRICT PLANChapter 3 – Natural Environment
Landscape Assessment of Amateur Radio Activities
Graphic SupplementJanuary 2016
Final
CONTENTS
Figure 1 Amateur Radio Antenna TypesFigure 2 Photograph Location PlanFigure 3 67 Blue Gum Road, ParaparaumuFigure 4 30 Vaucluse St, ParaparaumuFigure 5 87 Realm Dr, ParaparaumuFigure 6 124 Realm Dr, ParaparaumuFigure 7 7 Aburoc Rd, ParaparaumuFigure 8 27 Regent Dr, ParaparaumuFigure 9 45 Ruahine St, ParaparaumuFigure 10 9 Elizabeth Street, WaikanaeFigure 11 1359 Paekakariki Hill RoadFigure 12 46 Pope Street, Mana Porirua CityFigure 13 Simulated view of Rural Broadband Initiative, 25m.Figure 14 Photomontage methodology statement
Revision Record
Issue Purpose Written Review Date 0 Draft LR BC 19/11/20151 Final Draft LR KCDC 26/11/20152 Final LR Issue 20/01/2016
Dish type antenna, building mounted
Panel type antenna, building mounted
January 2016 Job 3582 Drawn by: JP
Checked by: LR Rev: FINAL
FIGURE 1 - AMATEUR RADIO ANTENNA TYPES
Rubber duckie type antenna Discone type antennaDipole type antenna Whip type antenna
HF Yagi type antenna with rotator motorHF Yagi type antenna UHF/VHF Yagi type antenna UHF/VHF Yagi type antenna
Doublet type antenna
Pg 4
January 2016 Job 3582Drawn by: JP
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Landscape Assessment of Amateur Radio Activities Graphic Supplement
FIGURE 2 -PHOTOGRAPH LOCATION
3
4
4Key
Figure 3 -12 ARA in Kapiti Coast District
56
7
8
9
10
11
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Pg 6
Landscape Assessment of Amateur Radio Activities Graphic Supplement
FIGURE 3 - NO. 67 BLUE GUM ROAD, PARAPARAUMU
Guyed pole support structure and whip type antennae
Pg 7
January 2016 Job 3582Drawn by: JP
Checked by: LRRev: FINAL
Photo | Nikon D700 + 50mm lens | Lisa RimmerReading distance for correct scale: 400mm Horizontal field of view approximately 110˚ (2 x A3 pages)Photomontages should be used as a guide to field observations
Pg 8
Landscape Assessment of Amateur Radio Activities Graphic Supplement
FIGURE 4 - NO.30 VAUCLUSE AVENUE, PARAPARAUMU, VIEWED FROM OPPOSITE 15 WHYTE STREET
Guyed pole support structure and doublet wire type antennae
Pg 9
January 2016 Job 3582Drawn by: JP
Checked by: LRRev: FINAL
Photo | Nikon D700 + 50mm lens | Lisa RimmerReading distance for correct scale: 400mm Horizontal field of view approximately 110˚ (2 x A3 pages)Photomontages should be used as a guide to field observations
Guyed pole support structure and doublet wire type antennae
Pg 10
Landscape Assessment of Amateur Radio Activities Graphic Supplement
FIGURE 5 - NO.87 REALM DRIVE, PARAPARAUMU
Roof mounted with whip and discone type antennae
Pg 11
January 2016 Job 3582Drawn by: JP
Checked by: LRRev: FINAL
Photo | Nikon D700 + 50mm lens | Lisa RimmerReading distance for correct scale: 400mm Horizontal field of view approximately 110˚ (2 x A3 pages)Photomontages should be used as a guide to field observations
Pg 12
Landscape Assessment of Amateur Radio Activities Graphic Supplement
FIGURE 6 - NO.124 REALM DRIVE, PARAPARAUMU
Roof mounted with whip type antennae
Pg 13
January 2016 Job 3582Drawn by: JP
Checked by: LRRev: FINAL
Photo | Nikon D700 + 50mm lens | Lisa RimmerReading distance for correct scale: 400mm Horizontal field of view approximately 110˚ (2 x A3 pages)Photomontages should be used as a guide to field observations
Pg 14
Landscape Assessment of Amateur Radio Activities Graphic Supplement
FIGURE 7 - NO.7 ABUROC DRIVE, PARAPARAUMU
Guyed pole support structure with whip type antennae
Pg 15
January 2016 Job 3582Drawn by: JP
Checked by: LRRev: FINAL
Photo | Nikon D700 + 50mm lens | Lisa RimmerReading distance for correct scale: 400mm Horizontal field of view approximately 110˚ (2 x A3 pages)Photomontages should be used as a guide to field observations
Pg 16
Landscape Assessment of Amateur Radio Activities Graphic Supplement
FIGURE 8 -NO.27 REGENT DRIVE, PARAPARAUMU
Pg 17
January 2016 Job 3582Drawn by: JP
Checked by: LRRev: FINAL
Photo | Nikon D700 + 50mm lens | Lisa RimmerReading distance for correct scale: 400mm Horizontal field of view approximately 110˚ (2 x A3 pages)Photomontages should be used as a guide to field observations
Roof mounted with whip type/rubber ducky antennae
Pg 18
Landscape Assessment of Amateur Radio Activities Graphic Supplement
FIGURE 9 -NO.45 RUAHINE STREET, PARAPARAUMU
Guyed pole and doublet wire type antennae
Pg 19
January 2016 Job 3582Drawn by: JP
Checked by: LRRev: FINAL
Photo | Nikon D700 + 50mm lens | Lisa RimmerReading distance for correct scale: 400mm Horizontal field of view approximately 110˚ (2 x A3 pages)Photomontages should be used as a guide to field observations
Guyed pole and doublet wire type antennae
Pg 20
Landscape Assessment of Amateur Radio Activities Graphic Supplement
FIGURE 10 - NO.9 ELIZABETH STREET, KAPITI MUSEUM
Guyed lattice support structure and Yagi type antennaUHF/VHF. Lightning rod to top of antennaa
Pg 21
January 2016 Job 3582Drawn by: JP
Checked by: LRRev: FINAL
Photo | Nikon D700 + 50mm lens | Lisa RimmerReading distance for correct scale: 400mm Horizontal field of view approximately 110˚ (2 x A3 pages)Photomontages should be used as a guide to field observations
Pg 22
Landscape Assessment of Amateur Radio Activities Graphic Supplement
FIGURE 11 - NO.1359 PAEKAKARIKI HILL ROAD
Self supporting lattice structure, co located Doublet, Dipole, Whip and Dish type antennae
Pg 23
January 2016 Job 3582Drawn by: JP
Checked by: LRRev: FINAL
Photo | Nikon D700 + 50mm lens | Lisa RimmerReading distance for correct scale: 400mm Horizontal field of view approximately 110˚ (2 x A3 pages)Photomontages should be used as a guide to field observations
Page left blank
Pg 24
Landscape Assessment of Amateur Radio Activities Graphic Supplement
FIGURE 12 - NO. 46 POPE STREET MANA, PORIRUA CITY
Guyed lattice support structure with Yagi type antennae
Pg 25
January 2016 Job 3582Drawn by: JP
Checked by: LRRev: FINAL
Photo | Nikon D700 + 50mm lens | Lisa RimmerReading distance for correct scale: 400mm Horizontal field of view approximately 110˚ (2 x A3 pages)Photomontages should be used as a guide to field observations
Pg 26
Landscape Assessment of Amateur Radio Activities Graphic Supplement
FIGURE 13- VIEWPOINT 2 | RURAL BROAD BAND PHOTO SIMULATION
Rural Broadband Initiative Network Utility 25m high
110kV transmission line poles, 12m high
220kV transmission line tower, 22m high
Pg 27
January 2016 Job 3582Drawn by: JP
Checked by: LRRev: DRAFT
Photosimulation : 3D Max Design 2013 | Alan EnglandReading distance for correct scale: 400mm Approximate distance to ‘project site’: Field of view approximately 110˚ (2 x A3 pages)Photosimulations should be used as a guide to field observations
Viewpoint : 2 1
Viewpoint
2 Viewpoint
Site
110kV transmission line poles, 12m high
220kV transmission line tower, 22m high
Pg 28
January 2016 Job 3582Drawn by: JP
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Landscape Assessment of Amateur Radio Activities Graphic Supplement
Photomontage Methodology Statement
• Photos were taken with a fixed lens on DSLR camera. Locations were fixed using reference points in the landscape and marked on site over an aerial photograph.
• A sequence of photos was taken from each viewpoint and stitched to form panoramas. Photos were overlapped by approximate-ly 30% and edges cropped prior to stitching to eliminate edge distortion.
• The completed photomontage is presented over two pages:
o The photos are produced to replicate correct scale at the nominated reading distance (in this case 400mm). o Each photomontage is printed across two facing pages to illustrate a field of view of approximately 110° at a reading distance of 400mm. This approximates the field of human binocular vision. (But not peripheral vision which extends to approximately 200°)
Notes on use of Photomontage:
• Stitched photographs in a photomontage are a useful tool but they cannot not precisely reproduce real life for the following rea-sons:
o 2D Photography flattens an image compared to binocular vision. o Photography is static, whereas the human vision can scan and remember information. o Photographs are passive, whereas the eye seeks out detail. o The human eye can see more contrast than can be reproduced through photography. o Physical resolution of photography and printing is less than that of the human eye.
Figure 01: The relationship between reading distance and real life scale.
400mm reading distanceFigure 03: Comparison of 35mm lens and 50mm lens
Two images from the same location. With 35mm and 50mm lenses perspective is influenced by field of view, not by lens focal length. The overlaid portion is identical.
Figure 02: Binocular vision is approximately 124°. Field of view is approximately 110° across 2 x A3 pages at correct scale image for 400mm reading distance (vertical field of view is approximately 33°)
FIGURE 14- PHOTOMONTAGE METHODOLOGY STATEMENT