7. Next steps in developing a national environmental standard

7.1  NES development process

Figure 5: The NES development process

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7.2  Making a submission

You are invited to make a submission on the proposed subject standards. Anyone can make a submission, and we would welcome your feedback.

Please include the following information with your submission:

• your name and postal address, phone number, fax number and email address (if applicable)
• the title of the proposed standards you are making the submission about
• whether you support or oppose the standards
• your submission, with reasons for your views
• any changes you would like made to the standards
• the decision you wish the Minister for the Environment to make.

You can post your submission to:

Electricity Transmission NES
Ministry for the Environment
PO Box 10-362
Wellington

or email to:

electricity@mfe.govt.nz

Your submission must be forwarded in time to be received no later than 5.00 pm on Friday 30 November 2007.

Note: your submission is public information and is subject to release under the Official Information Act. Please clearly indicate if any of your comments are commercially sensitive or if, for some other reason, you consider they should not be disclosed.

7.3  Discussion questions

Your submission can address any issue relating to the standards. However, the Ministry for the Environment would greatly appreciate specific comment on the following questions.

Submission questions

Question 1: Do you think national environmental standards are the most appropriate way of providing detailed national direction for management of the national grid?

Question 2: Do you agree with the objective? Do you think this objective meets the purpose of the RMA?

Question 3: Have we covered all the viable options for providing detailed national guidance under the RMA for the sustainable management of electricity transmission?

Question 4: Are the proposals for permitted activities likely to generate additional resource consent requirements?

Question 5: Should more activities be permitted than currently proposed? For example, earth peaks are permitted in many plans, and often increase the height of the tower by more than the 15% allowed in the proposed NES. Should earth peaks be permitted without a height allowance?

Question 6: Do you think the categories assigned to activities are appropriate? Are they too stringent, or too lenient? For example, putting existing overhead transmission lines underground is a restricted discretionary activity. Should this be a controlled or even permitted activity?

Question 7: Are the terms and conditions proposed to control the environmental effects of permitted activities appropriate? Are the matters over which the council can have control / discretion in assessing resource consents appropriate?

Question 8: Are there any other activities that should be listed in the transmission activities NES?

Question 9: Should the NES make any provision for activities to be ‘non-complying (for example, some activities in the coastal marine area)?

Question 10: Should the construction of new transmission lines be covered in the NES?

Question 11: Do you have any comments on the activities proposed to be covered by the transmission risks NES? Is this the most appropriate way to manage these activities?

Question 12: Do you have any comments on the proposed activity types (prohibited, controlled, non-complying, restricted discretionary)?

Question 13: Which building option do you prefer and why? What should be the cut-off point for managing ‘buildings’ (eg, all buildings and structures, only inhabitable buildings)? What about bridges and other structures? How could this be defined?

Question 14: Are there any other activities that should be managed to prevent risks to transmission lines? For example, damming and diverting water could endanger transmission support structures. Is this adequately controlled in regional plans now, or are additional provisions required?

Question 15: Have we accurately reflected the range of costs and benefits arising from the proposals for national environmental standards and who might bear the costs or receive the benefits? Are there any costs and benefits we have overlooked?

Question 16: Are our estimates of costs and benefits accurate? Do you have information on costs and benefits that could assist the second stage of our assessment (of the impacts of the final proposals)? Do you have any information on costs and benefits that we have been unable at this stage to quantify?