Table 2: Summary of Comments on Part 1 - Issues and Options

This Document is Archived

Summary of Submissions on the Draft Report of the Reference Group on Electricity Transmission

Reference Group on Electricity Transmission

[ Last Updated 22 August 2006 ]

Issue	Submitter	Summary of submission	Comment
2 - Background	Environment Waikato	Inference that RMA responsible for lack of investment in transmission is unsupported by facts.	The report merely records the PWC stocktake findings where the RMA was identified as an issue for future investment. Minor modification to text recommended.
4.2 - Description of impacts of transmission lines	Environment Waikato	The focus is on rural issues. Should look separately at rural and urban issues	No comment is provided on what the "urban" issues are that might be different from those listed. Not clear what is missing. Most issues listed are common to both rural and urban contexts.
	Historic Places Trust	Recognise full range of historic heritage effects by (a) replacing reference to "disturbance of archaeological sites and sites of cultural significance" with "disturbance of historic heritage including damage to archaeological sites, historic places and areas, and sites of significance to Māori, including their surroundings". Acknowledging (i) effects on transmission items of heritage value such as damage to historic substations or pylons caused by upgrade works (ii) disturbance to archaeological or historic sites (iii) effects on heritage vales (including visual impacts on the setting and surroundings of any historic heritage site or area; (iv) effects on cultural heritage values, including effects on any site or areas of significance to Māori.	Acknowledging these issues will require the report to offer suggestions as to how these should be addressed (or justify why they should not be addressed). Although the HPT does not request specific policies in the NPS, it clearly does request that the NPS address these wider heritage issues. The risk of this has been discussed in the "general" section of the summary.
	MP Alexander	Thermal upgrades will increase tension on lines and potential for cascading of lines to occur with component failure. Also, an increase in capacity of lines will give rise to health and safety issues (through step and touch potentials) that are not raised in the Draft Report.	It is unclear whether these are issues that can or ought to be address through the RMA. Further advice may be required.
Section 4.3.2 - Transpower's approach to new build projects	New Era Energy	Transpower's proposed designations are not wide enough and therefore compensation is not broad enough to reflect effects/constraints on land owners. Designations should be expanded beyond just preventing non compatible activities and instead reflect the full range of effects of the lines (and not be limited to the narrow easement required by Transpower).	Under section 177 (2) a local authority can recommend that a requiring authority modify a requirement. Therefore a local authority could, already, recommend that a requirement be approved subject to it being widened. While theoretically it may be possible to require (via an NPS) local authorities to only recommend requirements (designations) that are wide enough to internalise all effects, it would seem impractical for local authorities adopt (and for requiring authorities to comply with) such an approach . Internalising all effects within the designated area would in many cases be unfeasible. For example, the designation required to internalise the visual effects of a transmission line would be enormous. The policy suggested by the submitter would have practical and cost implications well beyond transmission. This is clearly a grey area of law and practice. Currently, practice seems to be that major effects are internalised within the boundaries of a designation but some effects are experienced outside of a designation. The land use effects that go beyond the boundary cannot be controlled by rules in plans other than through rules that address reverse sensitivity (require, for example, noise attenuation measures on new houses built in close proximity to the designation). Non land use effects (e.g. discharges) may be managed by rules in regional plans. Agreeing with the point made by the submitter would set a major precedent.
Section 4.3.3 - Transpower's approach to maintenance and upgrade projects	New Era Energy	When maintenance becomes an upgrade should not be limited to when there is a visible change in appearance. Other issues such as EMF levels, noise and coronal ion discharge ought to be considered. This is an issue that will likely soon be tested in the Environment Court (early 2006).	Report currently does not discuss this point. As the submitter notes this will soon be considered by the Environment Court. A note to that effect could be added to the paper for completeness.
Section 4.3.5 - Transpower as a requiring authority	New Era Energy	Transpower should designate all existing lines allowing access to compensation and other benefits.	This would require (a) re-examination of the issues addressed by the Electricity Act; and (b) legislation to force Transpower to seek designations. The reasons why the pre-1988 line issue ought not to be reopened are already discussed in the Draft Report.
Section 4.4 - Property Rights	New Era Energy	Property rights/compensation issues are cloudy. New legislation is required for acquisition and compensation specifically targeted at transmission lines.	See above.
Section 4.4.2 - property rights associated with pre-1988 network	MEUG	Report does not address whether some minor changes to Electricity Act (sections 22 and 23) would clarify position	This is addressed by Appendix 2 of the Draft Report.
	MEUG	Further work on relationship between electricity Act and RMA re existing lines is warranted (including reviewing decisions of Courts)	Paper could report on one or two environment Court cases that address this issue (including Counties Power A088). However a review of cases (including the Counties Power case) suggests that there is little value to be added.
Section 4.5.2 - NZECP 34	MP Alexander	This code of practice is outdated given new scientific information on health and safety issues. Code not adhered to by Transpower	Need to check with relevant authority but NZECP 34 was re-issued in 2001.
	WR Storey New Era Energy	NZECP 34 only deals with electric shock. The effects of emissions (EMFs, coronal ions) are much more dangerous. Safety issues of concern include stray voltage, line droop and pylon climber protection. Transpower's complaint system is slow and cumbersome.	Concerns could be referred to the Energy Safety branch of MED which would be in a better position to comment on the extent to which there are safety issues not addressed by NZECP 34 or other means. Transpower's complaint systems is not a matter that the Reference Group can comment on.
	MEUG	Unsatisfactory aspects of NZECP 34 and Trees Regulations are identified but the opportunity to identify satisfactory solutions has not been taken	The Draft report does (in subsequent sections) propose various options for resolving issues identified. The NES proposed is one such option. No specific issues with the Trees Regulations were identified. While it is understood that some landowners (particularly forestry owners) have concerns, these are outside the core issues to be addressed by this process.
Section 5.1.4 - Transmitting energy requires pylons, conductors and cables	New Era Energy	Strongly disagree that transmitting energy requires pylons, conductors and cables. Underground transmission using HVDC is becoming well established elsewhere.	Reference to "cables" in the Draft Report covers the point made.
Section 5.2 - Issues associated with RMA management	Environment Waikato	Transpower is in no different a position than any one else when it comes to consultation	Disagree. Transpower's position is different because (a) of the number of affected parties associated with linear projects; and (b) the complications caused by the need to secure easements.
Section 5.2.3 - management of visual affects	New Era Energy	Object to statement that little can be done to avoid amenity and landscape impacts at the individual property level. Under-grounding would be welcomed. We need to ask what premium (if there is a premium) we need to pay to manage these visual effects.	The footnote (45) to the statement in Draft Report notes under-grounding as an option but also notes that for technical and financial reasons under-grounding is possible only in specific locations and in limited circumstances.
Section 5.2.3 - management of EMFs	New Era Energy	ICNIRP is outdated. The 100 microtesla standard is 250 times higher than the 0.4 microtesla level that is shown to significantly increase the risk of certain health problems.	Although it does not comment specifically on this issue, the Draft Report notes that there are issues with ICNIRP and for that reason recommends a new NES. The detail of the appropriate standard can be debated in the process of preparing that NES.
Table 1 - Generic evaluation of option	Environment Waikato	Advantages listed seem to come from the perspective of Transpower	Disagree. Advantages such as "no new costs on local authorities" or "low cost for government" or "allows communities and stakeholder groups to debate issues and seek solutions that suit local circumstances" are not necessarily advantages from Transpower's perspective. Could be formatted so that each stakeholder group's perspective is set out but seems unnecessary.
Table 2 - Evaluation of options against issues	Historic Places Trust	Amend to ensure full range of historic heritage values is considered and the archaeological authority process under the Historic Places Act 1993 is recognised by accidental discovery procedures (ADP).	The suggestion is that the NPS include guidance on processes to be followed in case of archaeological site discovery that complies with the Historic Places Act 1993. Not clear that NPS could do this since it is related to obligations under the HPA not the RMA.
Section 6.2 - Affected party status (also executive summary and conclusion)	Wellington City Council	Potential for undue restriction and uncertainty. Should be tied to a specific performance condition (e.g. where activity is within 30 metres of the centreline of a transmission line)	This is a matter of detail to be considered in the drafting process.
	Taranaki Regional Council	Support guidance on when Transpower should be an affected party
	Dr Mike Patrick Federated Farmers	Support change to Forms, Fees and Procedures regulations to identify Transpower as an affected party.
	Westpower	It is not clear if this would relate to all networks (i.e. including local lines). If it did not it would cause fragmentation in approach.	Report should be amended to clarify that the proposal only relates to "transmission" as defined.
	Contact Energy	Obligation in Regulations already exists. May be the local authorities need reminding of their obligations in this regard.	There is an existing general obligation to "serve notice" on those "who in the opinion of the consent authority may be adversely affected by the granting of the application". However the proposal is to make the obligation to serve notice on Transpower more explicit - as it is for certain other parties (such as iwi authorities, or the Historic Places Trust).

Jump to main page content.

Printed: 25/11/2009