In November 2006, Cabinet invited the Minister for the Environment to prepare a discussion document and a draft cost−benefit analysis on two national environmental standards (NES) for electricity transmission under the Resource Management Act 1991 (RMA). The proposed standards aimed to:
1.1 Background
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provide a consistent national framework for managing the effects of transmission activities (covering operation, maintenance and upgrading of the national grid), referred to as the transmission activities NES
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protect transmission lines from inappropriate activities that could put the integrity of the national grid at risk, referred to as the transmission risks NES.
1.1.1 The proposed standards
The transmission activities NES covers the operation, maintenance and upgrading of transmission lines, but does not cover substations or the construction of new lines. The proposed NES presents a framework for managing the adverse effects of transmission activities. It lists those activities that do not have significant adverse environmental effects as permitted activities – where resource consent would not be needed – along with terms and conditions designed to restrict the adverse effects of these activities. The proposed NES then sets out consent categories for activities that require resource consent. This proposed NES would only apply to the line owner and contractors carrying out work on behalf of the line owner.
The transmission risks NES provides controls on activities adjacent to transmission lines that could have adverse effects on the transmission infrastructure and could put the transmission network at risk. This proposed NES would only apply to third parties and would not apply to the line owner or contractors carrying out transmission activities on behalf of the line owner. The proposals prohibit high-risk activities and set out resource consent requirements for excavation, depositing material, buildings, subdivision and boat ramps under or adjacent to transmission lines. The proposals contained two options for controls on buildings:
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Option A, based on the New Zealand Electrical Code of Practice for Electrical Safe Distances (NZECP 34), which provides for risk zones around the conductors and support structures
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Option B, which proposes a 20-metre zone within which resource consent would be required.
Both proposed standards would apply to the high-voltage electricity transmission network, including line supports and conductors.
1.1.2 Feedback on the proposed standards
A discussion document setting out details of the proposed standards was released for public comment on 12 October 2007, and public notices of the submission period were placed in major newspapers on the same day. A copy of the public notice is included in Appendix 1 of this report. In brief, the notices informed people of:
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the subject matter of the proposed standards
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the Minister’s reasons for considering that the proposals are consistent with the purposes of the RMA
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how people could make a submission
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the deadline for submissions.
During the submission period four public workshops were held: in Auckland, Hamilton, Christchurch and Wellington. In addition, the Ministry for the Environment’s Talk Environment Roadshow travelled throughout New Zealand between 17 October and 2 November 2007. The Ministry visited 17 centres and facilitated 31 meetings with local government and the public. The meetings were attended by approximately 1,500 people, all of whom had access to a fact sheet that included information about consultation on the proposed national environmental standards. The submission period closed on 30 November 2007.
1.2 Purpose of this document
This document presents an overview of the submissions received on the two proposed NES for electricity transmission. Eighty-four submissions were received (see Appendix 2 for a list of submitters). The discussion document posed 16 questions for discussion (see Appendix 3). Submitters also raised additional issues, such as the need for guidance on implementing the standards.
This report is intended to provide a concise summary of the views expressed. It is not intended to analyse those views or make recommendations in response to the submissions, as this will be done in a separate report.
1.3 NES development process
An outline of the national environmental standards development process, including the informal and formal submission stages, 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 submission stage.
Figure 1: The NES development process
Text description of figure
This flow diagram of the NES development process starts with a Public process phase comprising a Reference group consult on scoping report. The next step is for Cabinet to approve preparation of NES, which leads to a Discussion document.
The Public process continues, comprising Public and iwi notification and a Submissions period.
This is followed by a phase of Analysis and report on submissions, preparation of section 32 analysis, and RIS: this is where the present NES is at.
The Final recommendations to the Minister are made, after which it is likely that Cabinet approve NES.
If so, the Public notification of report and recommendations is followed by Legal drafting of the standard.
Eventually, the Draft becomes regulation.
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1. Introduction
May 2008
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