1. Introduction

1.1 Background

In June 2005 the Ministry of Economic Development completed a stocktake and analysis of regional and district plans and policy statements prepared under the RMA. The aim of the study was to determine the extent to which existing planning documents consider the national benefits of network infrastructure. The study found that such benefits are not always provided for, and that national environmental standards have the potential to improve planning consistency.

The following month, the Government approved an industry-led approach to scoping national environmental standards for telecommunications. A Telecommunications Industry Reference Group was convened, with representatives from Telecom, Vodafone and TelstraClear, Local Government New Zealand, and the Ministry for the Environment, Ministry of Health and Ministry of Economic Development. After considering several options for national instruments, the reference group proposed four national environmental standards for radio-frequency fields and low-impact telecommunications facilities.

These proposals were submitted to the Ministry for the Environment, which is now leading the process for developing the proposed standards for telecommunications facilities. This discussion document contains the Ministry for the Environment’s perspective on the industry proposals.

Before preparing this discussion document, the Ministry for the Environment undertook a review of all district plans. The aim was to examine how district plans currently provide for radio-frequency fields and the telecommunications facilities identified by the Industry Reference Group as being suitable for national environmental standards. The review found that:

• provisions for telecommunications facilities in existing district plans are inconsistent across the country

• many district plans do not have clear provisions relating to infrastructure within the road reserve

• some district plans do not contain any rules for radio-frequency fields or rely on out-of-date standards.

The Ministry for the Environment also completed an initial economic appraisal of the proposed standards to provide an indication of the costs and benefits of implementing the standards. The results of this appraisal are summarised in section 4.

1.2 Purpose of this document

This discussion document has been prepared to:

• help you understand the proposal and its potential costs and benefits

• help you prepare questions and feedback for the consultation workshops (see section 6)

• guide you in making a submission.

To help you put together a submission, questions are posed on various aspects of the proposed standard that we specifically want you to consider, but you are welcome to provide feedback on any aspect of the standard that has not been covered by a specific question.

1.3 The process for developing national environmental standards

An outline of the process for developing a standard, including the informal and formal submission process, is shown in Figure 1.

Following Cabinet approval, the Telecommunications Industry Reference Group scoped the proposed standards. The Ministry for the Environment received the industry proposals in June 2006 and has analysed them to prepare this discussion document. Cabinet approval to initiate public consultation was received in December 2006. We are now in the formal public submission period, as indicated in Figure 1.

The public consultation period is your opportunity to make a formal submission on the standards. An eight-week submission period is provided to enable people to have formal submissions approved by committees or boards, if required.³ Details on how to make a submission are included in section 6. A summary of submissions will be published by the Ministry after the closing date.

1.4 When should a national environmental standard be developed?

The great majority of decisions made under the RMA are made at a local level (which is entirely appropriate), and deal with environmental effects (both positive and negative) that are experienced locally. However, local decision-making may not give appropriate weight to effects experienced more widely.

National environmental standards are instruments that can apply nationally in circumstances where it is considered that national positive or negative environmental effects are not being fully addressed by local decision-makers. National environmental standards can capture those wider benefits that may not be fully internalised in decision-making at a regional or local level. Such benefits include providing consistency of controls across the country, providing more certainty, and simplifying the process of policy formulation, monitoring and review. It is more likely that decisions about significant investments - particularly those that occur across several local authority boundaries - will be made when there is the certainty provided by national regulation at a national level.

Network infrastructure such as telecommunications is considered to be appropriate for considering the application of national environmental standards. A characteristic of network infrastructure is that the benefits conferred by the network are more widely dispersed than the costs. By capturing the wider benefits, the full implications of infrastructure development proposals for promoting sustainable management can be taken into account.

The case for developing national environmental standards for telecommunications infrastructure is made in the following section.

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