Earlier this year we ran a couple of workshops on how to write a submission. Here is what Anna Carter, a professional Resource Management and Environmental Consultant advised. Anna studied at Massey University and completed a Bachelor of Resource & Environmental Planning 15 years ago and since then has worked at central and local government; and in a private consultancy providing resource management and environmental advice;
For the last four years she has had her own business Environmental Connections providing Environmental Advice to Regional Council, the District Council.
What I will be focusing on for this presentation – is how to write a really good submission
I will briefly touch on the issues and I can address in a general way questions people might have in respect to a particular issue – but I would encourage you to talk to experts and do your own research.
Start with the cover page. Tell them who you are, where you live, whether you have qualifications or experience in the matters you’re raising, and your contact details. Don’t write a novel, but make sure the necessary information is there.
You need to remember while you are writing this submission that it will be read by a “real live person”
The ‘reader’ will want to know that you are also a “real live person” and that your submission is “genuine”
How do you let them know you are a genuine person? You do so by letting them know your level of interest. So at the point where you write about yourself you need to tell them that:
Either you, your family and/or your property will be affected by the proposed Expressway; and/or
You are a member of the wider Kapiti Coast Community (i.e. you could be like me and live some way away from the Expressway) but consider the Expressway will affect your community; and/or the environment; and/or
You are an expert in a particular field (i.e. noise or water management etc) and you consider the Expressway will affect the environment specifically in the area you are an expert in; and/or
You can whakapapa back to the local iwi of the area and you have concerns about how the expressway will affect your iwi/hapu.
You need to summarise in one sentence whether you support, oppose or support with conditions and briefly say why. For example you might oppose it on the basis of noise, landscape amenity, and economic issues.
When thinking pragmatically about what might happen – it is also worth stating that while you Oppose the proposed Expressway, should the Board of Inquiry approve it – then you want them to ensure that they take into account conditions that you would like to see imposed. For example, you may want to see a solid noise wall where the expressway adjoins a residential zone; or you may want to ensure that high grade low noise asphalt is used where the expressway adjoins a residential area.
Just because you note in your submission that there are conditions you want to see imposed SHOULD it be approved does not take away from your first submission that the Expressway be declined. You are merely being pragmatic and recognising that the Board of Inquiry is an independent body that may approve it.
Who skim reads? There is a great chance your reader will be skim reading these submissions so:
Keep your submission BRIEF, TO THE POINT AND GET RID OF THE EMOTION
Don’t forget your reader – you want your reader to know that you are a rational, thoughtful person who has gathered their facts and are putting those before them
I keep my front page free from detail because you want the reader to know by glancing at that front page (if they go back to it) who you are; where your property is in relation to the Expressway and whether you support or oppose and/or support with conditions
I am not going to provide you with expert advice on each and every issue that comes out of this project
What I will do is touch briefly on most of the big issues and give you some pointers about what to write about
Because the issues are so many and we all have limited time you might want to think about picking the issues that really affect you and focus on those. You want to break your submission up based on the issues/effects you want to bring to the reader’s attention
Reading submissions is a bit like doing a jigsaw puzzle … they are constantly wondering as they read the submission how what you are saying fits against the proposal and against the legislation governing that proposal.
The decision makers have a number of matters that they must ensure are complied with.
The people making up the Board of Inquiry will be guided in their decisions by the Resource Management Act. That Act says that decision makers must balance the
social, economic and environmental effects while also recognising and providing for matters of national significance.
They are also required to have particular regard to a list of other matters including but not limited to:
- Efficient use of natural and physical resources
- The maintenance and enhancement of amenity values
- Intrinsic values of ecosystems
- Maintenance and enhance of the quality of the environment
- Finite characteristics of natural and physical resources; and
- The effects of climate change.
You would think listening to that list of other matters – that it is in the bag and there is no way a Board of Inquiry could approve the proposed expressway. But you would be wrong IF the New Zealand Land Transport Agency as able to show that they have been able to avoid those effects; or can mitigate the effects; or can remedy those effects someway. Your aim, in your submission, is to highlight to the Board exactly where NZTA is NOT able to avoid, remedy or mitigate those effects, and why.
The point of writing a submission is to highlight to NZTA the effects on your or your property, or the environment that you care about. In doing this you need to provide evidence of those effects, you need to describe how you will be affected; and you should also look at whether or not the proposed design as tried (or not) to remedy or mitigate those effects on your or your property.
With noise for example it is important to check the noise contour plans and mitigation measures proposed by NZTA.
Save Kapiti will put a link up to these technical papers on their website – but I would suggest that you put aside a couple of hours to scroll through NZTA’s technical papers looking at those papers which deal with issues affecting you.
This is the noise contour plan for the section of the Expressway through Waikanae.
This noise contour plan (which is Sheet 6 of 18 in the series EN-NV-105) represents a “do minimum” scenario. The ‘do minimum scenario’ has no or few solid noise walls.
In this plan you will see a light blue light adjoining El Rancho’s land which is a solid 2 metre high fence. Solid walls result in a 2 – 3 decible change in noise levels which a quite noticable.
The light green line represents a predicted noise level of 45 dB Leq (24 hrs)
Yellow line represents a predicted noise level of 50 dB Leq (24hrs).
Orange line represents a predicted noise level of 55 dB Leq (24 hrs)
Red line represents a predicted noise level of 60 dB Leq (24 hrs)
This is the noise contour plan sheet 14 of 18 in the series EN-NV-113 which shows the preferred mitigation options.
Can you see the difference in the noise contours with the Sound Wall in place. Look at the yellow line – it has moved westward by a significant margin.
I would be recommending to everyone writing a submission who are concerned about noise levels increasing – even those who oppose the Expressway – to note
that should the Expressway be approved that you would want to see noise walls or the preferred mitigation options. I would refer directly to the Noise Contour Sheet that affects your community or property (as I have here).
NOISE (as an example)
I will touch on noise in more detail as I can refer in part to a noise assessment that El Rancho commissioned.
PPF’s stand for Protected Premises and Facilities
NZTA have used the New Zealand Noise Standard 6808:2010 in assessing effects of noise.
Urban areas referred to in the NZ Standard are those urban areas as defined by Statistics New Zealand. For example El Rancho which is zoned rural is actually
within an urban classification for Statistics NZ purpose
The noise level predictions are based on traffic volumes of between 2,000 and 75,000 vehicles per day 10 years from the date the Expressway is constructed.
NZTA has adopted the New Zealand Noise Standard NZS 6806:2010. This standard sets criteria for road traffic noise and provides an accepted methodology for
assessment and mitigation of that noise.
Assessment of traffic noise is only undertaken at locations referred to as Protected Premises and Facilities (PPFs) and includes:
- Buildings used for residential activies including:
- Boarding establishments
- Homes for elderly persons
- Retirement villages
- In house age care facilties
- Buildings used as temporary accommodation in residentially zoned areas, including hotels, motels but excluding camping grounds
- Spaces within buildings used for overnight patient medical care; and
- Teaching areas and sleeping rooms in buildngs used as educational facitliies including tertiary institutions and schools and playgrounds located within 20m of those buildings
PPFs do not include residential accommodation in commercial or industrial premises; garages or ancillary buildings; and buildings for which no building consent has been obtained.
PPFs need to be located within 100 metres from the edge of the closest traffic lane where the PPF is located in an urban area. Urban areas are defined by Statistics NZ classification AND NOT zoning in a District Plan
- Inside Kauri Hall the dBA leq (24hr) noise level with a 1.1m high barrier will be 56dBA; with a 2m high barrier the noise level will be 54 dBA (24 Leq). With a 2 metre high barrier this is still an increase of 11 dBA (leq 24 hr). Kauri Hall is approximately 50 metres from the outside carriageway of the Expressway.
- Redwood Hall where we are now will have predicted noise levels of 53 dBA (leq 24 hour period) under both scenarios of a 1.1m or 2 m high barrier. That is an increase of 10 dBA which is twice as loud as currently.
- As we move further away from the Expressway the noise levels decrease.
- At the office the noise levels are predicted to be 52 dBA (with a 1.1 metre high barrier in place) and 50 dBA with a 2m high barrier in place. That is an increase of 7 dBA which will be clearly perceptible.
- While this is a significant increase in noise levels it must be assessed in terms of the receiving environment. Outdoors the maximum noise level will be just under 60 dBA which is about the level of “conversational speech”.
What is it that makes your environment, your community special? It is those elements, those characteristics that make up amenity. It may be the rural spaces , the lack of infrastructure (i.e. concrete structures), the many trees etc.
Sand dunes, ecological areas, the river and the coast are all significant landscapes. Which of these are special to you (to your community), to your sense of place? Will any of them be destroyed by the Expressway – how? Describe in your submission who they will affect your sense of place.
What is your current location? Are you located on a sand dune, in a sand dune hollow, within a flood plain area? Does your property currently experience drainage problems. Will the Expressway interfere with natural drainage patterns and could that adversely affect your property. The law requires that natural drainage patterns are maintained and that if a flood storage area is elevated then compensatory flood storage needs to be created elsewhere (outside that flood storage area). Investigate the stormwater plans NZTA have put on their website and see how the Expressway might affect your property – then let NZTA know!
Lets read what the District Plan says about new roads in the District:
A further study (the Kapiti Network Study) was conducted in 1995 by consultants for Council to investigate the Kapiti Coast District roading network…. Five options were examined:
Within 5 years a second, but not a third bridge across the Waikanae River would be justified on the basis of expected demand;
A local arterial road on the expressway route, connecting with the important employment foci of Paraparaumu Town Centre, Kapiti Road and Te Roto Drive will signficantly improve traffic flows within the Kapiti Coast;
The location of the second bridge should be on the alignment of the “Sandhills Expressway” route as part of a local arterial road initially providing a connection between Te Moana Road and the Paraparaumu Town Centre;
Extensions ringing the Paraparaumu Town Centre from State Highway 1 and linking the the local arterial road on the expressway are expected to be needed as traffic volumes increase over time.
In addition the study observed that it would be prudent to provide protection for a third bridge connection across the Waikanae River linking Paraparaumu/Otaihanga with Waikanae, wither into Queens Road across the Waikanae River estuary or into Weggery Drive further to the east of the estuary in the vicinity of Makora Road.
There are over 36 different technical reports relating to topics such as urban design, landscape effects, heritage effects, air quality, noise, vibration, social effects, effects on groundwater and hydrology, transport effects and ground settlement effects.
BUT PLEASE DO NOT LET THE AMOUNT OF INFORMATION AVAILABLE TO YOU PUT YOU OFF!!
I would suggest you list those key areas that are a concern to you and then pick up those technical reports relating to those effects. After reading those reports consider what you will write in your submissions.
Before you send your submission, get someone else to read it, looking for typos and spelling mistakes, for clarity of argument and that you’ve followed the layout requirements. If they can read it and understand what you want to say, then the Board of Inquiry will be able to as well. Save Kapiti members will be happy to receive your draft submission and comment on it for you, if you wish.