3. Key Themes by Category of Submitter
A number of key themes emerged from the summary and analysis. Some of these are common across all categories of submitter. Others are particular to, or more commonly expressed by, one category of submitter.
3.1 Local Authorities (and Other Public Agencies)
Most of the local authority/public agency submitters offer support in principle to national intervention on transmission. However, support is guarded and contingent on other matters. Common points made by this group include:
- Questioning whether the Draft Report provides sufficient justification. (Although it is not clear what form of justification would satisfy these parties);
- Concerns about the cost of an NPS on local authorities and whether there are alternative means (such as a change to Part 2 of the RMA, non statutory guidelines, revisiting the Electricity Commission' s Grid Investment Test (GIT)) that might better achieve outcomes or achieve outcomes at lower cost;
- Questioning whether the prospect of compensation to affected landowners and/or communities should be revisited;
- A desire for greater emphasis to be placed on managing the effects of transmission on the environment and communities and a greater recognition of the responsibility Transpower has to internalise or minimise adverse effects notwithstanding that reverse sensitivity impacts should be recognised.
The Historic Places Trust wants broader recognition of historic heritage, recognition of some transmission assets as historic heritage worthy of protection and fuller regard to the Treaty of Waitangi
Many of these submitters request and expect close involvement in the drafting of the NPS and NESs noting their interest (and final support or opposition) will be dependent on the detail.
3.2 Landowners and Landowner Groups
There is little support for an NPS or NES from landowner submitters. What support there is (from, for example, Perry Group), is conditional on access to compensation (with various changes to the compensation regime suggested).
Federated Farmers, New Era Energy, M Patrick and WR Storey are opposed to an NPS. The reasons are varied but include concerns about smoothing the process for an activity that will be detrimental to the environment (in the case of New Era Energy) and lack of identified need or justification (with several raising concerns similar to those raised by some local government submitters). WR Storey suggests that it would be preferable to have an NPS on energy rather than dealing with transmission in isolation.
WR Storey, New Era Energy and MP Alexander all question the scope of NZECP 34 and by implication its suitability as a basis for an NES. New Era Energy promotes under grounding of lines (Manukau City also suggested that the Draft Report needed to address the under-grounding issue).
There is a little more support from landowners for other instruments. Both Mike Patrick and Federated Farmers support (i) a change to the Forms Fees and Procedures Regulations to identify Transpower as a party to be served notice of applications and; and (ii) the use of the Building Act to enforce NZECP 34.
Perry Group, on the other hand see the enforcement of the Building Act as unnecessary since they advocate that Transpower should be made to secure designations wide enough to allow internalisation of all effects (on all lines).
3.3 Professional Bodies
The professional bodies are divided on their support for the NPS/NES proposals. There is strong support from the New Zealand Geothermal Society, the New Zealand Electricity Engineers Association (NZEEA) and the Institution of Professional Engineers (IPENZ). However, the New Zealand Law Society and the New Zealand Planning Institute (NZPI) question whether there is sufficient justification (notwithstanding that they support the use of NPSs/NESs in principle).
The Law Society questions why a change to Part 2 of the Act is not given more consideration.
IPENZ and NZEEA both question the scope of the NPS suggesting that an NPS should be kept at a high level and avoid technical issues. IPENZ suggests that the NPS should endorse energy efficiency and demand management.
The NZPI offers little specific comment but generally seeks more consideration and analysis.
3.4 Industry and Industry Bodies
Generators, Transpower and the two distribution company submitters all support (in broad terms) the proposals. There is no challenge to the justification for an NPS/NES from these submitters. On the contrary, submissions broadly restate and expand upon justification set out in the Draft Report, notably:
- the local costs and national benefits associated with transmission; and
- inconsistency between the standards and approach of local authorities over the course of a single project.
Several industry submitters suggest that benefits could be clarified and offer suggestions on the benefits that should be recognised. These include environmental benefits associated with supporting renewable generation which are not currently well recognised in the report.
There is some discussion about the scope of the NPS and in particular (a) whether it should focus on electricity more generally (i.e. be combined with generation); and (b) whether it should be limited to Transpower's network (to the exclusion of distribution lines and lines owned by generators).
The one exception to industry support for an NPS is the Major Electricity Users Group2 (MEUG) which does not support an NPS but does support the three NESs.
Industry submissions generally provide more direct comment on the policy options included in the report than other submitters.
There is strong support for recognising positive effects and managing effects on the transmission network. However, both Meridian and MRP oppose NPS policies in relation to managing adverse effects of the transmission network (relating to route selection) noting that these effects are local and can be managed adequately at the local level. Most other industry submissions are silent on this point.
Both the NESs proposed are supported by all industry submitters although MRP considers that these should be combined into a single NES. There is also strong support for an NES on EMF and use of the Building Act to enforce NZECP 34.
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