5. Conclusion
Overall, there seems to be broad enough support from submissions received for the Reference Group to proceed to make the recommendations proposed in the Draft Report. However, in addition to a range of clarifying amendments, there are two parts of the Report that warrant further consideration as a result of submissions.
The first is section 5 of the Report which sets out the main justification. It is accepted that this section could be strengthened with better information on:
- Transpower's past experiences with resource consents and designations; and
- The level of consistency (and inconsistency) in district plan rules and other provisions that apply to transmission (and the level to which regional variation may be justified on environmental grounds).
However, no submitters provided a clear indication of precisely what information of argument would satisfy calls for greater justification. What may need to be made clearer is that the NPS/NES package is, to a large extent, about looking forward and responding to future (anticipated) issues rather than simply looking to rectify problems that have (or have not) occurred in the past. Given that Transpower has had a low level of new investment in the transmission network since the RMA came into existence, looking backwards is of limited value.
The second area for further Reference Group consideration relates to section 10 of the Report which deals with managing the adverse effects of the transmission network. The value that can be added on route selection in particular is challenged by some submitters while others see this as critical and seek further work and the development of detailed policies. This will be a difficult issue to reconcile and the Reference Group should seek further detailed advice on the future of this section.
The primary arguments against the main proposals of the Draft Report are based on concerns about compensation. However, these are outside the ability of an NPS to address and therefore outside the scope of the Reference Group process.
Nevertheless the Reference Group will need to consider whether its proposals may exacerbate concerns about compensation issues. Any such risk will need to be factored into the References Group's analysis.
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