6. Key Issues

6.1 Overview

As noted earlier, our assessment has not been undertaken as a detailed technical assessment of the relative merits of the various aspects of the proposal or the submissions, or as a technical audit of the proposals. Rather, it seeks to identify the key issues associated with the project.

A total of 1244 submissions were received at the Ministry during the submission period. By way of a summary, the submissions were as follows:

• Support 17
• Neutral 14
• Oppose 1160
• Mixed 40
• Not Stated 13

The overwhelming majority of submissions received were in opposition to Transpower’s proposal. Of particular note, over 300 submissions in opposition used a standard submission form, as provided in Appendix V. The main issues raised by submitters are outlined in Table 2 overleaf.

The submitters who were in support of the proposal (17 in total) cited security of supply and the availability of a reliable and affordable electricity as a reason for supporting Transpower’s application. A further submitter stated that there was more than adequate consideration of alternative routes.

6.2 Analysis of Key Issues

As outlined in Table 2 there were a number of issues raised in the public submissions on a wide variety of matters and from a wide variety of parties and interests. The analysis of public submissions undertaken for this report, and the information contained within the NOR documents and resource consent applications produced by Transpower identified the key issues relating to the requirements for the proposal as follows:

• Visual Intrusion/landscape effects.
• Electric and magnetic fields.
• Alternative options.

Table 2: Summary of issues raised by submitters.

*Note, this table identifies all of the issues raised by submitters (either in support, neutral or in opposition). Some submitters raised concerns over a number of issues but still supported or were neutral to the proposal, and likewise some submitters who opposed or were neutral to the proposal raised issues of support in their submission.

• Justification for the proposal.
• Economic effects.

Each of these effects is discussed further below.

We note that while our analysis of submissions did not separate submissions into those that were lodged in respect to the NOR or those in respect to the applications for resource consent (due to the general nature of submissions to the overall proposal), few submissions actually refer specifically to the resource consent applications.

The submitters also identified a number of other matters which, while they are of no less importance to the proposal, could more readily be addressed through specific conditions attached to any designation, should that be the Board’s decision. These include noise effects and construction effects. Other matters, such as inadequate compensation offered and effects on land value and penalties if mitigation is not carried out are not considered further here.

6.2.1 Visual Intrusion/Landscape Effects

The potential adverse effect of the proposal on visual and landscape values was cited in 193 submissions. The extent of adverse visual effects will vary at different points along the overhead transmission route and on individual properties, roads, small townships and landscapes to varying degrees. We also note that the alignment crosses an area identified as a ‘Special Landscape Character Area’ in the Waipa District Plan.

This proposal will result in significant visual effects and this will vary depending on the specific location and route. In this regard, there will be differing opinions (from both specialists in this field and lay people) as to the extent of the adverse effects and whether those effects can be appropriately avoided, remedied or mitigated, and whether the effects are contrary to s 171 (b)(ii) and s 104 (1)(a). We consider that this will be a matter of evidence to be presented at the hearing, and ultimately of judgment of the various opinions expressed.

6.2.2 Electric and Magnetic Fields (“EMF”)

The potential effect of EMFs on health is a key issue for this proposal. This issue was of foremost concern to submitters and was raised in 967 submissions (the majority of submissions in respect to EMF’s related to potential health effects while a small number related to electrical equipment interference). A further 900 submissions stated that the 65 m easement zone was too small in comparison to the height of the towers and the potential effects of EMF’s.

Transpower proposes to use the International Commission on Non-Ionising Radiation Protection (“ICNIRP”) Guidelines as a standard and will comply with the limits for general public protection. A possible weak link between magnetic fields and some childhood cancers has been identified but this is neither sufficiently confirmed nor of substantial enough potential on public health to affect current practice. Transpower considers that direct effects on farm, domestic or wild animals in the vicinity of the proposed transmission line are unlikely.

We consider that the effect of EMFs will be a significant consideration for the Board and further technical advice may need to be sought by the Board on this particular matter. It is noted that Dr Dockerty has recommended that further information be requested in relation to this matter as outlined in Section 7.2.1. This should be provided to all parties prior to the hearing.

6.2.3 Alternatives

A number of alternatives to the proposal were raised in the submission process and included, for example: the consideration of alternative generation and transmission options (865 submissions); use of the smaller scale 220 kV lines as opposed to the 400 kV lines (671 submissions); and an alternative underground option for all and / or part of the overhead section (93 submissions).

Transpower assessed a range of alternatives for the proposed project and found as follows:

• Electricity substitutes – not seen as a credible option that would defer the need for the proposal.
• Generation alternatives – local generation would not meet the electricity needs in 2010.
• Energy efficiency alternatives – problems with meeting peak demands in electricity.
• Demand-side management – as above, there are problems with meeting peak demands in electricity.

In summary, Transpower’s investigations of non-transmission alternatives indicated that they are either inadequate or uncertain to be able to meet demand in the short or long-term.

It is clear that Transpower have considered a range of alternative options. As noted earlier, in terms of the requirements of s 171 (1)(b) of the RMA, consideration has been given to a range of alternative sites, routes, or methods for achieving the objective of the requiring authority. We consider that the issue of alternatives should appropriately be tested by way of evidence to the hearing.

6.2.4 Justification for the Proposal

A high number of submissions (885) stated that demand growth projections for the Auckland region did not justify the proposal and that the line would not offer security of supply to the Auckland region. A further 852 submissions stated that Transpower provided false justification in respect to the chosen route and whether the line upgrade was required, and provided misleading and inaccurate costings in respect to the project.

As outlined in Transpower’s NOR documentation, Transpower undertook demand and generation forecasts against its current grid reliability standards and concluded that peak electricity in demand in the Auckland and the North Isthmus (including Northland) regions was forecast to grow to 2265 MW by 2010. Without further investment in the current network, this load would exceed the capacity of the existing grid supplying the Auckland and Northland region. To meet this demand, Transpower would either have to substantially invest in the current infrastructure by 2013, or be in a position to rely on alternatives to transmission before this date.

Transpower has justified its project in terms of meeting electricity requirements in the future within the NOR documentation (albeit this is absent from the resource consent applications), and in our opinion has demonstrated that the proposal is reasonably necessary for Transpower to achieve its stated objectives. However, the details of the Transpower proposal and the significance of the likely effects of the proposal in location will need to be tested by evidence presented to the Board, and an overall judgment in terms of s 171 and Part II of the RMA to determine whether or not the designation should be confirmed and on what terms it could be confirmed.

6.2.5 Economic Effects

The proposal will have a range of economic effects. This includes the effect on farming activities/practices such as the impact on aerial topdressing (loss of airstrips and the need for greater flying height over the line), loss of land associated with the towers, restricted land use activities within the designation area, and the impact on the use of underground or travelling irrigators. Further economic effects identified include the effect on development potential (particularly in respect to subdivision and provisions for urban expansion), adverse effects on land property values, tourism (such as accommodation facilities located in the vicinity of the line) and more generic adverse effects on New Zealand’s “clean green” image.

These issues are of particular importance to many submitters along the route, and reflect the specific effects that they are likely to face. We do not consider that there are any further “information request” issues associated with these matters, but note that they are likely to feature in the evidence heard by the Board.