• Home
• Energy & Resources
• Environment
• National Guidance
• Archive
• Electricity Transmission
• Summary of Submissions
• 4. Overall Analysis

• Environment

• National Guidance

• Archive

• Electricity Transmission

Of the 29 submission received:

• 10 are broadly supportive of the proposals for an NPS and NESs in the Draft Report;
• 11 are supportive of intervention in principle but that support is conditional either on further justification, specific changes or agreement to detailed wording;
• 5 are opposed to the proposals for an NPS (though only 3 are opposed to NESs); and
• 3 submissions do not express a view either way commenting only on matters of detail.

Those broadly supportive are mostly associated with electricity industry. Their support is based on an assertion of the importance of the transmission network and a belief that the characteristics of the network make it vulnerable to unsympathetic or unresponsive management under the RMA.

Those offering conditional support for the NPS/NES package include most local authority submitters and several of the professional bodies. The conditionality is most often based on a belief that an NPS has not been justified, or that the singling out of transmission for attention (as opposed to other infrastructure) has not been justified. Other conditions relate to the need to preserve environmental standards and to ensure the Transpower retains an obligation to avoid, remedy or mitigate environmental effects.

The three submissions opposed to the NPS are from landowners or their representative. Again opposition is based on lack of justification but there is also a more deep-seated concern that Transpower would be advantaged by an NPS at the expense of landowners. That concern is in turn based on a belief that either (a) Transpower does not have to manage all the effects of its activity (regarding emissions and visual impacts); and/or (b) Transpower already has a privileged position and the compensation regime does not link appropriately to the RMA regime.

Other specific issues raised include:

1. The report gives insufficient regard to:
   1. the principles of the Treaty of Waitangi;
   2. the historic heritage values of parts of the transmission network;
   3. the impacts of transmission development on historic heritage;
   4. health and safety risks associated with an increase in capacity of lines;
   5. the adequacy of NZECP 34 as a basis for future regulation given the limited scope of issues it addresses;
   6. the relationship between the RMA and the Public Works Act;
   7. the under-grounding of lines;
   8. energy efficiency and demand side management;
   9. distribution lines and lines owned by generators.
2. Key differences of opinion about:
   1. Whether the NPS should address the effects of transmissions and in particular what it could or should say (if anything) about route selection;
   2. Whether and how the Grid Investment Test (GIT) should be described in the Report and linked to the NPS;
   3. Whether the ARPANSA standard on electro-magnetic fields will provide a good basis for a NES.
3. Additional specific comments on proposals are detailed in Table 2 and Table 3.

Most submitters welcome the opportunity for further involvement and recommend full public consultation.