1. Introduction

1.1 Background

Public notices were placed in major papers on 16 June 2007 informing of:

• the subject matter of the proposed NES

• the Minister’s reasons for considering the proposals are consistent with the purposes of the RMA

• how people could make a submission

• the deadline for submissions.

A copy of the public notice is included in Appendix A of this report.

Five workshops on the proposed telecommunications facilities NES were held: in Auckland, Manukau, Wellington, Christchurch and Dunedin between 20 and 26 June. Details of the proposals and how they would be implemented were made available during the submission period in the Ministry for the Environment report Proposed National Environmental Standards for Telecommunications Facilities.

The deadline for submissions was 5 pm on Friday 10 August 2007.

1.2 Proposed standard

The proposed standard, as notified for consultation, addresses four issues. The issues were set out in the discussion document in sections 3.3 to 3.6.

Section 3.3: Exposure to radio-frequency fields from wireless telecommunications infrastructure

This requires exposures to comply with NZS 2772.1: 1999 Radio-frequency Fields Part 1: Maximum Exposure Levels 3 kHz-300 GHz (‘the New Zealand Standard’), and proposes a process by which compliance with the New Zealand Standard can be verified.

Section 3.4: Telecommunications equipment cabinets within road reserves

This proposes that telecommunications cabinets in road reserves be permitted activities provided they meet restrictions as to height, volume, siting and clustering. Limits vary depending on whether the cabinet is to be located within a residential, open space or reserve area, or a rural or mixed-use area.

The proposed standard further provides that rules in district plans take precedence over the standard in certain circumstances (ie, when the site of the cabinet is adjacent to a building or place with heritage or landscape value, or where work is to be undertaken within the drip-line of a tree which would have otherwise required resource consent).

Section 3.5: Noise from telecommunications equipment located within road reserves

The proposed standard makes noise from a telecommunications cabinet a permitted activity provided that specified noise limits are complied with. Distinctions are made between daytime and night-time, and between residential, mixed-use, rural and open space areas, and business and industrial areas. The approach to be taken to measuring noise is also specified.

Section 3.6: Masts and antennas for wireless telecommunications networks within road reserves

This proposes that antennas and their support structures be permitted activities in the road reserve provided the mast or antenna meets certain requirements as to scale.

For cabinets, the proposed standard further provides that a rule in a district plan take precedence over the standard where there are heritage or landscape values identified in a district plan.

The discussion document noted that the exact wording of any standard will be legally drafted after government decisions.

1.3 National environmental standard development process

An outline of the NES development process, including the informal and formal submission process, is shown in Figure 1. The Ministry has completed the public process stage, and the release of this Report on Submissions marks the end of the submissions stage.

Figure 1: NES development process

Note that the NES development process differs from the district and regional plan and resource consent processes undertaken in accordance with the First Schedule of the RMA. The development of an NES does not involve hearings, and there are also no rights of appeal.

Text description of figure

1.4 Purpose

This document presents an overview of the submissions received on the proposed NES for telecommunications facilities.

• Chapter 2 is a summary of the key themes raised by submitters.

• Chapter 3 summarises general comments made by submitters.

• Chapter 4 summarises feedback from submitters on sections 3.3 to 3.6 of the discussion document.

• Chapter 5 summarises the further correspondence received by the Minister for the Environment.

This report is intended to provide a concise summary of the views expressed. It is not intended to provide an analysis of those views or recommendations in response to the submissions. This will be done in a separate report, which will be presented to Cabinet early in 2008.