7. Adequacy of Information

7.1 Introduction

The review of the adequacy of information provided by Transpower in the NOR was undertaken in respect to s 171(b) of the RMA, in particular with regard to the effect of electric magnetic fields and the adequacy of the landscape assessment. The adequacy of information provided by Transpower in the resource consent applications was undertaken in accordance with s 104(1). Submissions received during the notification period were also reviewed to ascertain further information gaps.

7.2 NOR Adequacy

Transpower have provided a comprehensive and detailed assessment of the proposal and have considered a range of alternatives and potential effects. This has included a large amount of detailed information contained in 17 volumes or parts. Naturally, for a proposal of this size and given the interest that it has generated, there will always be disagreement on the level of detail provided on particular issues and the conclusions reached about particular issues. By applying a broad judgement to the information provided, there are no matters that stand out to us as reasons to seek further information at this stage. As is common with major infrastructure proposals of this type, we can however expect differing opinions and judgement to be reflected in evidence presented for various parties at a hearing. We consider that the information supplied with the NOR is sufficient to proceed at this stage, but note that it will need to be supported by evidence at the hearing.

7.2.1 Electric and Magnetic Fields

As noted earlier, we have sought specific advice from Dr J Dockerty (Epidemiologist and Public Health Physician) on EMF issues. He has reviewed the NOR documentation to assess the adequacy of information in respect to the potential health effects of the proposal. In summary, Dr Dockerty concluded that the information presented by Transpower was generally of high quality however the EMF figures stated in the NOR documentation only refers to compliance with the ICNIRP Guidelines and there is a gap in the information in respect to the assessment of possible health effects.

In this regard, Dr Dockerty requested that calculations be provided for both the 220 kV and 400 kV, to estimate the following:

• Overhead lines – the actual magnetic field strengths (µT) at the edges of the easement (65 m from the centre, approximately 1 m above ground), assuming:
  • Normal loading.
  • Peak loading.
• Substations - the magnetic field strengths (µT) at the distance of the closest occupied house to each substation and at the edges of the security fences assuming:
  • Normal loading.
  • Peak loading.
• Underground cables – the magnetic strengths (µT) at ground level at the distances of the closest occupied houses to the cables (assuming there is no field contributed from other sources) for:
  • Normal loading.
  • Peak loading.

Dr Dockerty further concluded that there were no obvious material errors which would invalidate the conclusions of Transpower.

We consider that the above information should be provided as soon as possible to all parties, to enable independent evaluation of it prior to the hearing. However, we do not consider this to be a matter requiring that the hearing be delayed while the information is collated and circulated.

7.2.2 Landscape Assessment

The assessment of landscape effects undertaken by Transpower was reviewed by Stephen Brown (Stephen Brown Environments Ltd). Overall Mr Brown considered that the ACRE and associated work undertaken by Transpower provided a comprehensive and wholly adequate foundation for assessing and reaching conclusions about the visual / landscape effects of the proposal. Mr Brown further stated that if any additional work was required, it is likely to relate to a different experts interpretation of specific effects on specific locations, and alternative assessment methodologies. However, he expected that this was not something that Transpower could be expected to address.

In respect to prominence, the relative scale, intervening features and structural character of the lines and substation facilities was addressed in the NOR documentation. Matters not addressed include proximity, relative elevation of the structures and the effects in relation to colour contrasting, silhouetting and reflectance.

One criticism cited by Mr Brown was that there was a lack of maps and aerial photographs provided with the proposal, in particular, maps detailing the alternative routes that were originally assessed as part of the NOR documentation. This matter is a relatively minor detail that can be addressed by way of evidence during the hearing process.

7.3 Resource Consent Applications

Similarly to the NOR documentation, Transpower have provided a relatively comprehensive and detailed assessment of the overall proposal and have considered the relevant statutory documents in relation to the resource consent applications. However, limited information has been provided with respect to the potential effects of the activities for which consent has been sought. It is noted that the activities for which resource consents have been sought are typically controlled by standard consent conditions in both regions, unless they are undertaken in particularly sensitive locations. Both the Auckland an Waikato Regional Councils have published guidelines (such as TP90; Environment Waikato design guidelines) for dealing with a number of the issues that could potentially arise with the proposed activities.

Again, by applying a broad judgement to the information provided, there are no matters that stand out to us as reasons to seek further information at this stage. While we consider that the likely effects of the activities for which resource consents have been sought will be minor, the applicant should address these matters further in evidence. In addition, and as noted above in Section 5.2.3, the applicant should identify relevant consent conditions and provide details for the proposed construction management plan for the hearing.

7.4 Part II Matters

As set out in Sections 4.1.2 and 5.1.2 of this report, the evaluation of the NOR and resource consent applications for the Transpower proposal are all subject to Part II of the RMA.

At the highest level, we are satisfied that Transpower have supplied sufficient information to enable the Board to make an overall broad judgement as to whether or not the confirmation of the requirement (in its current form, or modified and/or subject to conditions) and granting of the resource consents will promote the purpose of the RMA. As noted earlier, there will be differing opinions as to the level of environmental effects and the extent to which the proposal either upholds or threatens any of the matters of national importance or other matters specified in s 6 - 7 of the RMA, or whether treaty principles have been taken into account (s 8).

For example, there may be particular “outstanding natural landscapes”, such as that identified in the Waipa District near Lake Karapiro, or on the slopes of the Hunua Ranges in the Auckland Region where there will be differing opinions as to whether or not the proposal would be an appropriate development. It is likely that the maintenance and enhancement of amenity values (particularly in relation to landscape and visual effects) will be a significant issue for consideration at the hearing as noted earlier. Equally, there may be, for example, sites of particular Maori spiritual, cultural or traditional value that should be protected that may be identified in evidence to the hearing. The impact consideration of these matters will have in terms of the overall broad judgement required in terms of s 5 of the RMA will be a matter of fact and degree, and in our view can only be determined following consideration of all of the evidence to be presented to the Board.

7.5 Submissions

A review of submissions received in respect to Transpower’s proposal is outlined in Section 6.2 of this report. During that review, any submissions that noted or requested missing and / or inadequate information in the NOR documents and resource consent applications were recorded.

In that regard, insufficient information as identified by the submissions is as follows:

• The applications do not contain sufficient information to accurately assess the effects of the proposal on specific properties.
• No full visual impact of the line, and not enough information regarding the location and size of the proposed pylons and substations.
• Insufficient safety data to support Tranpower’s claims that there will be no adverse health effects caused by the 400 kV lines.
• More information required on the alternative routes considered by Transpower (both above and underground).
• A more accurate costing of the proposal is required and should be made public so submitters are better informed as to what factors have been taken into account in the costing of the proposal.
• Clarification is required in respect to the easement-purchasing process and compensation process undertaken to date.
• Clarification of what visual aids (such as flashing lights or coloured balls) would be used on pylons around Ardmore Aerodrome.
• Further information required on the extent of vegetation clearance for the easements (with particular regard to forestry).
• Insufficient information and detail is contained within the NOR Documents to satisfy Transpower’s request that the requirement for outline plans under Section 176A of the RMA be waived.
• Uncertainty over the real impacts of high voltage underground cables.
• Duration and disruption of the construction stage is unclear.

In respect to the above additional information requested by submitters, information pertaining to health effects can be addressed through additional information requirements as requested by Dr Dockerty. In addition, there are likely to be differing opinions as to the nature or extent of any potential health effects. In this regard, we consider that these matters would be best addressed through evidence from those with differing opinions (supported by appropriate specialist evidence) at the hearing.

The landscape and visual assessment are comprehensive and further information in that regard is not deemed necessary. However, it is recognised that different specialists in this field will express different opinions regarding the proposal as a whole, or in relation to specific aspects of the proposal. These matters are best addressed through evidence adduced at the hearing.

With respect to the comment that there is insufficient information to support dispensation/waiving the requirement for an outline plan under s 176A of the RMA, we note that the nature and scope of the works proposed within the proposed designations are described in significant detail in the Transpower NOR. While there may be a need for:

• Any future works within the designation that have not yet been described in detail (such as any modifications that may be proposed in future); or
• Any significant modifications to or departures from the present proposal;
• Construction of 400kV switchboards and implementation of any upgrading associated with that;

to be the subject of Outline Plans submitted under s 176A of the RMA, the NOR itself incorporates detail consistent with an Outline Plan for the project as presently envisaged. Consideration could be given requiring Transpower to provide landowners the detail of the works proposed for each individual property along the route before the work is carried out, but, if approval was forthcoming, this would more appropriately be the subject of the easements required for the route (backed up with a condition in the designation requiring this).

As discussed in Sections 4.2.4 and 6.2.3 of this report, we consider that Transpower have given adequate consideration to an alternative range of sites, routes and methods to the proposal and that no further information is required in that regard.

Requests for more detail of costings, and clarification in respect to the easement-purchasing and compensation process are not specifically relevant to the RMA assessment.

Further information requests in respect to the type of visual aids that will be used, the extent of vegetation clearance and the duration and disruption expected during the construction phase are specific matters that should be clarified with individual submitters and can be addressed through evidence at the hearing.

7.6 Section 141 Matters

As detailed in Section 3.1, the Minister called-in Transpower’s proposal on the grounds that the proposal was a matter of national significance and met particular criteria under S 141B(2). The adequacy of information provided by Transpower in respect to the reasons cited by the Minister for calling-in the applications is discussed below.

Notification of the applications aroused significant public interest as evident in the number of submissions lodged. Key issues raised by the submissions (as outlined in Section 6.2) are landscape effects and health effects of EMF’s. These have been discussed in the documentation provided by Transpower, and as outlined in Section 7.2.1 of this report, further information in respect to public concerns on the effects of EMF’s is recommended. Landscape/visual effects are one of the significant or irreversible changes to the environment that the proposal will bring about, as discussed in the documentation provided by Transpower. In respect to the adequacy of information provided in the applications about significant or irreversible changes to the environment, there will always be disagreement on the level of detail provided on particular issues and the conclusions reached about particular issues. As outlined in Section 7.5, information requirements on specific aspects of the proposal can be provided in evidence at the hearing.

The project does involve the significant use of natural and physical resources. A key issue in this regard will be landscape/visual effects and effect on significant outstanding natural landscapes. Again, by applying a broad judgement to the information provided in respect to these issues, there are no matters that stand out to us as reasons to seek further information at this stage.

Transpower has provided sufficient information in respect to the planning provisions for each region and district that the applications apply to, and in this regard, is sufficient for the hearing.

Transpower propose to use 400kV AC transmission lines which are new voltage to the main transmission network in New Zealand, and in this regard they have provided information about the structure, design and operation of the transmission line, and actual and potential effects. As discussed in Section 7.2.1, sufficient information in respect to possible health effects for both the 220kV and 400kV should be provided prior to the hearing for the Board’s consideration.

The resource consent applications themselves do not raise any particular issues in relation to the specific reasons for which the Minister called-in the proposal, but the resource consents are integral to the project as a whole and should be viewed as such.

7.7 Summary

The NOR documentation provided by Transpower provides a comprehensive assessment of the effects of the proposal. There are a few matters of detail that require further information (particularly in respect to health effects of EMFs, and proposed consent conditions). In this regard, the further information requested by Dr Dockerty should be provided to enable a robust assessment of possible health effects. The effects of resource consent activity have been given limited consideration by the applicant and this needs to be addressed in further detail in evidence to the Board. There is no reason to stop the application process at this stage as any further information requests can be addressed during the hearing.

The submissions received following public notification of the proposal have been reviewed. The key issue raised in submissions pertained to the potential health effects associated with EMFs, alongside a number of other environmental, economic, cultural and social concerns. The reviewers concluded that some further information could be provided with respect to some aspects of the EMF assessment in the proposal. While a number of other information gaps were also raised by submitters, none are considered sufficient to stop the application at this stage. These issues should be addressed in evidence at the hearing, in particular by the applicant.

We note that we do not make any comment as to the accuracy or validity of the information provided in the documentation supplied by Transpower. The veracity of the supporting information should be determined through the evidence adduced to the hearing and resource consent applications