IN THE MATTER of the Resource Management Act 1991

AND

IN THE MATTER of a Board of Inquiry appointed under s149J of the Resource Management Act 1991 to consider a private plan change request made by Tainui Group Holdings Limited and Chedworth Properties Limited in relation to the Ruakura Development proposal ("Plan Change").

STATEMENT OF EVIDENCE OF ROY JOHN CLEMENT NOBLE IN RELATION TO TRANSPOWER'S ASSETS AND CORRIDOR MANAGEMENT FOR TRANSPOWER NEW ZEALAND LIMITED 26 MARCH 2014

J D K Gardner-Hopkins/ E J Hudspith Phone +64 4 499 9555 Fax +64 4 499 9556 PO Box 10-214 DX SX11189 Wellington

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CONTENTS

EXECUTIVE SUMMARY ...... 1 1. QUALIFICATIONS AND EXPERIENCE ...... 4 2. CODE OF CONDUCT ...... 5 3. SCOPE OF EVIDENCE ...... 5 4. DESCRIPTION OF TRANSPOWER ...... 6 Transpower's role ...... 6 Transpower's Divisions ...... 8 Safety – Transpower's key concern ...... 9 5. THE ROLE OF THE NATIONAL GRID ...... 10 6. BASIC COMPONENTS OF AN ELECTRICITY TRANSMISSION LINE ...... 11 Insulator sets ...... 16 7. TRANSMISSION ASSETS WITHIN THE PLAN CHANGE AREA AND SURROUNDING DISTRICT ...... 17 Lines ...... 18 Substations...... 20 8. DESCRIPTION OF PLAN CHANGE AREA ...... 21 9. RISKS TO PEOPLE AND PROPERTY ...... 23 Earth potential rise ...... 24 Step and touch voltages ...... 25 Induction voltages ...... 25 Conductor drop ...... 26 Flashovers ...... 28 Vegetation ...... 31 Equipment or structure failure ...... 33 Earthworks ...... 34 10. OPERATION AND MAINTENANCE OF THE NATIONAL GRID ...... 35 Patrols and Inspections ...... 35 Routine patrols ...... 36 Condition assessments ...... 36 Maintenance work equipment ...... 37 Maintenance work space and access ...... 40 Time necessary for maintenance work ...... 41 11. EXPECTED MAINTENANCE WORK WITHIN THE PLAN CHANGE AREA ... 42 Foundation work ...... 43 Pole and tower replacements ...... 44 Tower refurbishment ...... 45 Conductor work ...... 48

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Other maintenance work ...... 51 12. CO-ORDINATING OUTAGES WITH LANDOWNERS ...... 51 13. CO-ORDINATING OUTAGES WITHIN THE ELECTRICITY INDUSTRY ...... 52 Summary in relation to maintenance work ...... 54 14. EMERGENCY WORKS ...... 55 15. ACCESS...... 55 Complaints ...... 56 Reverse sensitivity ...... 57 Examples of reverse sensitivity effects ...... 57 Electrical noise ...... 59 Electric and magnetic fields ...... 59 16. GRID PLANNING ISSUES WITH LINES IN THE PLAN CHANGE AREA ...... 59 17. MANAGEMENT OF RISKS ...... 60 National Policy Statement on Electricity Transmission ...... 62 The reasons for transmission corridors ...... 63 What transmission Corridors and Yards will achieve ...... 65 18. THIRD PARTY ACTIVITIES NEAR TRANSMISSION LINES ...... 66 Activities which could be compatible with transmission lines ...... 67 Activities which should be avoided near transmission lines ...... 68 Why Transpower should be involved in considering proposals for subdivision of land near the National Grid ...... 71 Management of Risks within the Plan Change area ...... 72 19. ENGINEERING INPUT INTO CALCULATING THE WIDTHS OF TRANSMISSION CORRIDORS ...... 79 Electricity Transmission 12m Yard ...... 80 National Grid Corridor ...... 80 20. NZECP34 - PURPOSE AND LIMITATIONS ...... 81 21. TRANSPOWER'S COMMITMENT TO WORKING WITH LANDOWNERS AND STAKEHOLDERS ...... 83 22. CONCLUSIONS ...... 87

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EXECUTIVE SUMMARY

A. The Applicants are looking to bring a large area out of rural use and into a mix of urban activities, including an inland port operation. In broad terms Transpower does not oppose the proposal. However, we are asking the Board to modify the Plan Change to avoid the risks arising from inappropriate activities being undertaken under or near Transpower's existing National Grid infrastructure (which transmits electricity throughout New Zealand).

B. There are very real and severe health and safety risks, with the potential for significant economic impacts on the wider community - which can be avoided or mitigated by considered planning.

C. The Applicants are developing what is essentially a Greenfields site – so there is an ideal opportunity here for the Board to approve the right framework for development from the very start, ie one that eliminates the risk, at least where that risk is greatest, easily foreseen and could be avoided. While Transpower is seeking modest forms of corridor protection for all of its transmission lines in the Plan Change area, it is most concerned about the proposal to locate a container storage area (which would be serviced by a range of mobile plant, like forklifts, and potentially a rail siding) under its HAM-WHU A transmission line. Given the ultimate volumes anticipated (or hoped for) by the Applicants, there is a real risk of electric shock and damage occurring to the line - with all the consequential effects that arise from that. While Transpower designs and operates its assets as safely as possible, there are residual risks due to the extremely high voltages being carried on the lines. Electric shocks can be caused by earth potential rise, step and touch voltages, induction voltages, conductor drop and flashovers (which I will explain in more detail later). Hazards can be increased significantly by activities of third parties coming into contact with lines. We have specific experience of this where a serious incident occurred at a port in 2009 when a forklift hit a line. That resulted in the loss of electricity supply to approximately 600,000 electricity consumers in North and Northland for over two hours.

D. This risk can be eliminated by moving the inland port activities only a short way to the south and realigning roads, or otherwise reconfiguring the proposal. Another option is that the Applicants commit to a contract for

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undergrounding or relocating of the relevant section of the HAM-WHU A line, and for those works to be undertaken before the port development proceeds. This undergrounding or relocation would come at a cost to the Applicants, but it would avoid the risk of injury to their workers, the risk of damage to our infrastructure and the risk of electricity outages, and prevent substantial interruption to the Applicants' business in the future. The latter can arise when Transpower needs to enter property under the Electricity Act for maintenance and certain other activities. That can require the site to be vacated (for safety reasons), which can cause business disruption. Transpower is in discussions with the Applicants about the undergrounding of several sections of the National Grid lines, although no agreement has yet been reached (including in respect of the HAM-WHU A line).

E. If the Board does not consider it appropriate to avoid the risks Transpower is concerned about, some steps can still be undertaken to reduce the risks (primarily of electric shock) if the HAM-WHU A line remains above ground. However, this is not Transpower's preferred approach as the risks cannot be eliminated. Systems can be put in place to minimise the risk but these systems will not eliminate the risk completely. The HAM-DEV A line is also of concern as it is also located across a container storage area.

F. Aside from avoiding this particular conflict, Transpower wishes to see appropriate planning controls applied to protect its infrastructure more generally. That infrastructure includes the seven National Grid transmission lines and the Hamilton substation located adjacent to or within the Plan Change area. It is vital that Transpower is able to operate, maintain, develop and upgrade that infrastructure in order to deliver a reliable, secure and safe supply of electricity nationally and to Hamilton city, region and the upper . Physical access to transmission lines is required for all routine and urgent maintenance and Grid project works. The very nature of the works can significantly inconvenience people if they work or live near the line where the works are being carried out. Most importantly, maintenance and project work requires adequate working space around a tower or pole.

G. It is therefore essential that the district plan controls provide for a transmission corridor providing adequate access and working space at the towers or poles, and also mid-span. Prudently designing buildings or activities with the transmission line in mind (including beneath conductors) ensures vital Grid infrastructure is protected and can be

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maintained and upgraded when needed. "Under-build" (ie having buildings under Transpower's lines) may delay, or in some instances severely restrict, Transpower's ability to undertake maintenance or project work.

H. While the New Zealand Electrical Code of Practice for Electrical Safe Distances NZECP34:2001 ("NZECP34") provides some minimum protections, it does not ensure adequate, proactive management of these risks. For example, it does not ensure adequate access or work space, nor does it prevent under-build. In other words, structures, buildings and activities may comply with the minimum separation distances in NZECP34 but still create unsafe situations such as step and touch hazards. Under-build can restrict access and greatly increase the costs and time required to undertake work (for both Transpower and the landowner). Accordingly, additional and proactive management over and above NZECP34 is required to address the safety risks and other management requirements.

I. For example, Transpower seeks a National Grid Corridor. The width of that corridor can vary depending on the infrastructure, but is calculated through a "formula" intended to protect against conductor swing under possible high wind conditions. Within that Grid Corridor, Transpower simply wants to be involved in any subdivision proposal to ensure that the pattern of development is sensibly laid out so as to avoid risks associated with conductor swing, as well as to ensure access and crossing points (ie roads) are also well located.

J. Transpower also seeks a National Grid Yard. This is narrower than the Grid Corridor, and is to be set at 10 or 12m from the centerline (depending on the particular voltage and type of line) and 12m from the edge of support structures. Within this area, development is to be more limited, reflecting the increased safety risks and great need to keep that area clear of substantial buildings to allow for access and maintenance.

K. The relevant rules sought by Transpower are primarily to manage the longer term impacts of incompatible development or activities, near or under transmission lines, as well as ensure safety and minimise the likelihood of interruptions to consumers from inappropriately managed activities near or under lines.

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1. QUALIFICATIONS AND EXPERIENCE

1.1 My full name is Roy John Clement Noble.

1.2 I am the Asset Engineering (Lines) Manager with Transpower New Zealand Limited ("Transpower"). I have 29 years' experience in the design, construction and maintenance of high voltage transmission lines. I hold a New Zealand Certificate of Engineering (Civil).

1.3 My experience includes five years as South Island Transmission Line Maintenance Manager for a contractor for Transpower, followed by three years working in a transmission line design and project management consultancy.

1.4 I have worked for Transpower directly for 15 years, initially in a national engineering support role for maintenance works. I then transitioned into engineering design, construction and asset management roles for transmission line development and enhancement projects.

1.5 Between 2009 and 2012 I worked on the construction of the Brownhill- Whakamaru A (NIGUP) transmission line in the Waikato, firstly in the role of Programme and Property Manager, and then Operations Manager during the build phase. During this period I was based at an office at the Hamilton Substation, adjacent to the land described in the proposed Plan Change sought by Tainui Group Holdings Limited and Chedworth Properties Limited ("Applicants").

1.6 In my current role as Asset Engineering (Lines) Manager, I lead an Engineering team which develops long term maintenance and capital plans for lines throughout New Zealand, provides engineering support to maintenance works, compiles design and maintenance standards, and leads the design and engineering support for capital transmission line projects.

1.7 I am familiar with the Plan Change, and the National Grid assets within and adjacent to the Plan Change area which these proceedings relate to. I am authorised to give this evidence on Transpower's behalf.

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2. CODE OF CONDUCT

2.1 I confirm I have read the 'Code of Conduct for Expert Witnesses' contained in the Environment Court Consolidated Practice Note 2011. As I am employed by Transpower, I acknowledge I am not independent, however I have sought to comply with the Code of Conduct. In particular, unless I state otherwise, this evidence is within my sphere of expertise and I have not omitted to consider material facts known to me that might alter or detract from the opinions I express.

3. SCOPE OF EVIDENCE

3.1 My evidence will deal with the following:

(a) A description of Transpower and the National Grid.

(b) An overview of transmission line engineering, including the basic components of an overhead transmission line.

(c) Transpower's assets within and adjacent to the Plan Change area, and the role these play locally, regionally and nationally.

(d) Specific Grid capacity issues, maintenance requirements and development proposals in the Waikato, and upper North Island.

(e) The risks to people and property located near transmission lines, including the different types of electric shock that can occur.

(f) The kinds of work that are generally required to ensure the operation, maintenance, upgrading and development of the National Grid.

(g) The need for, and requirements of, emergency works, and why access to National Grid infrastructure is essential.

(h) The expected maintenance work for the National Grid lines in the Plan Change area.

(i) Examples of third party activities which restrict operation and maintenance of the National Grid.

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(j) The impacts of incompatible development and activities under transmission lines on maintenance and provision of a reliable supply to consumers.

(k) How risks to people and property can be managed, including through separation distances.

(l) How best to ensure activities allow for maintenance of, and access to, the National Grid.

(m) The relevance of the New Zealand Code of Practice for Electrical Safe Distances (NZECP34:2001) to access and maintenance issues.

(n) Transpower's commitment to working with landowners such as the Applicants.

4. DESCRIPTION OF TRANSPOWER

Transpower's role

4.1 Transpower is the State Owned Enterprise that plans, builds, maintains, owns and operates New Zealand's electricity transmission network - the National Grid. The Grid, which extends from Kaikohe in the North Island down to the Tiwai Point Smelter in the South Island, is the physical infrastructure that transports electricity throughout New Zealand.

4.2 New Zealand has become increasingly dependent on electricity. It is an intrinsic part of living and working in the 21st century. Electricity now accounts for about 26% of all energy used in New Zealand.1 Each year, $5 billion of electricity is traded on the wholesale electricity market. Transpower, whose main role is to ensure the delivery of a reliable and secure supply of electricity to New Zealand, has a fundamental role in the industry and in New Zealand's economy. Transpower's role is illustrated in Diagram 1 below.

1 Ministry of Business, Innovation and Employment Energy in New Zealand 2013.. This figure is for the 2012 calendar year.

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Diagram 1 - Role of Transpower

4.3 Transpower is not a generator of electricity and has no retail sales of electricity. It can be considered to be a 'freight company' for electricity, in that it transports bulk electricity from where it is generated by companies such as Genesis Energy and Mighty River Power to the local lines distribution companies which supply electricity to our homes, farms, communities and businesses. The Grid also directly supplies some major users of electricity (eg New Zealand Steel at Glenbrook and KiwiRail at Hamilton).

4.4 Transpower also manages New Zealand's power system in real time. In its role as System Operator, Transpower ensures electricity transmitted through the Grid is delivered whenever and wherever it is needed, 24 hours a day, seven days a week.

4.5 As a State Owned Enterprise, Transpower's principal objective is to operate as a successful business.2 It must operate within certain legislative constraints and report regularly to its shareholding Ministers. The transmission network is a natural monopoly. Transpower's investments in the Grid and transmission charges are regulated by the Commerce Commission.

2 State-Owned Enterprises Act 1986, s 4.

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4.6 Transpower is required to deliver and operate a National Grid that meets the needs of users now and into the future.3 Prudent investment in the Grid, long term transmission planning strategies, and developing technologies are crucial to ensure the most can be made out of existing infrastructure. As I will explain below, managing development near or under lines provides the necessary access to the Grid to allow required regular maintenance to be undertaken in a safe and efficient manner, and ensures a reliable and safe supply to consumers.

Transpower's Divisions

4.7 There are three key divisions in Transpower that are responsible for maintaining, developing and operating the National Grid.

4.8 The Grid Performance Division oversees the day to day operation and maintenance of the Grid. This includes ongoing condition assessment of the assets, routine patrols along lines, management of landowner relationships, and undertaking smaller replacement and maintenance project works.

4.9 The Grid Development Division (the Division I work in) is responsible for both identifying the short term Capex refurbishment and replacement programme as well as the future (20-30 year +) needs of Grid users from the perspective of both planned and potential investment in generation and expected growth in electricity demand. This Division prepares the Annual Planning Report ("APR") which I refer to below. The APR sets out the 10-15 year forecast of work required to provide the necessary future capacity of the Grid.

4.10 The third division, Grid Projects, is responsible for delivering key infrastructure projects, such as the recently commissioned new line through the Waikato from Taupo to Auckland, as well as the smaller capital refurbishment and repair projects.

4.11 Another Group within my Division, the Environment Policy and Planning Group, is responsible for environmental strategies and approvals. This Group works closely with all three Grid Divisions to ensure issues such as asset maintenance, capacity and property, as well as technical

3 Statement of Corporate Intent 2012/2013, https://www.transpower.co.nz/sites/default/files/publications/resources/transpower-sci- 2012-13.pdf at 5.

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engineering input, are factored into the resource management processes that enable the development of the physical Grid.

Safety – Transpower's key concern

4.12 Transmission infrastructure similar to that operated by Transpower is used throughout the world and is generally considered a safe and efficient way to transmit electricity. Transpower operates its assets as safely as possible and seeks to protect, to the greatest extent practicable, its staff, the public, consumers and property from exposure to injury or harm, damage, economic losses and nuisance.

4.13 Transpower puts safety and an injury-free workplace, ahead of all other company objectives. I believe Transpower's safety culture and initiatives make it a leader in this area. Safety is a fundamental organisational value that drives all that we do. Transpower takes an "Eliminate – Isolate – Minimise" approach to safety as required by the Health and Safety in Employment Act 1992. As required by section 15 of this Act, it is also Transpower's responsibility to ensure all practical steps are taken to ensure no actions (or inactions) harm other persons. It is our belief that all incidents are preventable provided sound practices and careful judgement and management are exercised. When incidents occur, Transpower informs the entire company through a "Safety Alert" and sets out the preventative steps that could have been taken to eliminate, isolate or minimise the incident.

4.14 Transpower has appointed a Director of Safety and has established a Central Safety Leadership Team ("CSLT") to ensure continuous improvement of Transpower's safety performance with a specific focus on behavioural safety management. This team oversees safety improvements, with a national focus to ensure an ongoing safe and healthy working environment. The team also provides a forum for recognition and shared learnings for all those working with Transpower's assets. The CSLT meets quarterly and is chaired by the Transpower CEO. It is attended by the Chief Executives of our Principal Service Providers, the companies that we contract for line maintenance and upgrade work.

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5. THE ROLE OF THE NATIONAL GRID

5.1 The National Grid is critical infrastructure. It comprises around 12,000 km of high voltage transmission lines, and 41,000 towers and poles, connecting 178 substations and switching stations across the country. The National Grid is long and narrow, linear infrastructure, reflecting New Zealand's topography. What happens at one point on the Grid can have consequences much further away, even in another region.

5.2 The Grid comprises a high voltage backbone which runs the length of the country and links major generation (such as the geothermal power stations near Taupo) to major loads in large cities. The bulk of the backbone Grid was built around 60 years ago and comprises most of the 220 kV lines throughout New Zealand, along with the High Voltage Direct Current ("HVDC") link between the North and South Islands.

5.3 Connected to this Grid backbone are regional Grid lines (also owned or operated by Transpower) which connect smaller generation stations and supply regional communities. The Grid is an interlinked network. Electricity flows along transmission lines and varies in any instant, depending on actual generation at power stations and the demand for electricity across New Zealand. As System Operator, Transpower uses real-time information about electricity use by consumers and electricity generation available from generators to balance electricity demand and supply, ensuring optimum performance of the network.

5.4 Without the National Grid, communities across New Zealand would be dependent on locally generated electricity which would be more expensive and less reliable. As such, the National Grid plays an important role in the sustainable management of natural and physical resources.

5.5 On a regional perspective, the National Grid in the Waikato serves two purposes. Firstly, providing the ability to utilise the electricity generated from the hydro stations along the and geothermal generators in the Taupo area. Secondly, it provides a secure source of electricity for both residential and industrial consumers in the Waikato region.

5.6 Transpower's 2010 publication "Transmission Tomorrow" sets out Transpower's strategy for the future development of the Grid for the next

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30 years and beyond.4 Transmission Tomorrow confirms Transpower's view that there is an enduring role for the National Grid. Transpower's lines and substations will be required for many years into the future to power the economy while enabling New Zealand's continued reliance on renewable forms of electricity generation including from the power stations along the Waikato River.

5.7 To meet the future needs for the Grid, Transmission Tomorrow identifies that Transpower must maintain its ability to use existing transmission corridors to the greatest extent possible. Availability of corridors for electricity transmission is the largest constraint in ensuring the National Grid can meet future needs.

5.8 The importance of corridors has also been recognised by Government policy makers. The National Policy Statement on Electricity Transmission ("NPSET"), introduced in 2008, requires Councils to give effect to its provisions in their district plans.5 This will be further covered in Mr Horne's evidence on planning matters.

5.9 Before turning to discuss the National Grid assets within the Plan Change area, I will provide a basic overview of transmission lines and their component parts, as I will refer to many of these technical terms throughout my evidence.

6. BASIC COMPONENTS OF AN ELECTRICITY TRANSMISSION LINE

6.1 Overhead transmission lines consist of five basic components:

(a) Conductors (wires);

(b) Structures (towers and/or poles);

(c) Insulator sets;

(d) Foundations; and

(e) Earthwires.

These components are all shown on Diagram 2 below.

4 A copy of Transmission Tomorrow is available at https://www.transpower.co.nz/resources/transmission-tomorrow 5 Transmission Tomorrow, Pages 42-43

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Diagram 2: Transmission line components

6.2 National Grid lines are typically named according to the substations they transmit electricity to and from. The HAM-WHU line within the Plan Change area, for example, transmits electricity between Hamilton and Waihou substations. The HAM-DEV A line is a deviation line running from Hamilton substation and connecting to the Otahuhu-Whakamaru C line to the east of Hamilton.

6.3 I note that all the lines in the Plan Change area, with the exception of the HAM-DEV A line, are "simplex" (one single conductor per phase6) and not "triplex" as shown in Diagram 2. The HAM-DEV A is a duplex line (two conductors per phase).

6 In most high voltage power systems each electrical circuit is made up of three phases (red, yellow and blue) with each phase at the same voltage within the circuit, e.g. 220kV. A phase can be a single conductor or a multiple sub-conductor bundle.

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Conductors

6.4 Conductors (wires) are the physical conductive connections that transport live electrical energy at high voltages between substations (that is, between generators and substation supply points). Conductors usually consist of a number of aluminium stranded wires wrapped around an internal stranded steel support wire. In some cases hard drawn copper is used but these conductors are being phased out as they age.

6.5 Conductors are arranged in different configurations and with different spacing between them depending on the structure types and circuit voltage. 220kV lines typically have a 5.5 metre and 110kV lines a 3.25 metre vertical conductor separation. Where conductors are duplexed (two conductors per phase), sub-conductor spacers are installed to separate the two wires to prevent the two parallel wires twisting and clashing, particularly in windy conditions.

6.6 The conductor sag (amount of droop) changes as the conductor heats up with high electrical load (current). This change in sag impacts clearances to the ground, under-built structures and vegetation. This change in sag, and therefore clearance, is not visibly noticeable or well understood by the public, as the maximum loading conditions occur infrequently. However, at these times the potential loss of circuits typically presents the greatest risk to Grid security of supply.

Structures

6.7 Structures support the conductors and earth wires above the ground or other obstacles to maintain safe electrical clearances. Structures take many forms; for example, self-supporting lattice steel towers, concrete and wood poles, and steel tubular poles ("monopoles"). All lattice steel structures inside or near public areas7 are fitted with climb deterrent devices to restrict unauthorised climbing. All structures have danger signs and a 0800 THE GRID number for emergency contact.

7 Public areas for the purpose of defining the requirements for climb deterrent devices are defined as: (a) In school grounds or within 500 m of a school; (b) In parks and reserves within urban areas; (c) Located on residential sections or within 500 m of urban area housing; (d) On land on which children can play adjacent to rural housing or within 500 m of rural housing, and (e) On open land which is also within 500 m of a road, path, walkway or street carrying pedestrian traffic, but not motorways or state highways where there is little likelihood of pedestrians

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6.8 Transmission line structures are designed for specific line characteristics, including voltage, conductor size, conductor tension, climatic conditions (wind and snow) and topographic criteria (span length, line angle and tower height). Upgrading of line capacity or replacement of conductors typically requires the strengthening of towers (addition of steel members), raising of towers (insertion of complete tower sections), and in some cases complete replacement of the structure to ensure modern design standards are met.

6.9 Transpower has a number of transmission line structure and configuration types in the Plan Change area including double circuit steel lattice towers, single poles and tubular steel monopoles. Below are photos of examples of towers and pole structure types located within the Plan Change area.

Photo 1 - HAM DEV A 503 Photo 2 - HAM-KPO A 80

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Photo 3 - HAM-MER B 152 Photo 4 - HAM-WHU A 5

Photo 5 - ARI-HAM A 303 Photo 6 - ARI-HAM B 133

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Photo 7 - HAM-MER A 54 Cable Photo 8 - HAM-MER A 63 termination

Insulator sets

6.10 Insulators electrically insulate the live conductors from the earthed structures and prevent any loss of energy to earth. Each phase on each structure requires an insulator set. The sets consist of insulators that may be manufactured from glass, ceramic porcelain or a composite material, and the steel hardware assemblies which attach the insulators to the structure and the conductors. In most cases the insulators are suspended from the pole or tower crossarms.

Foundations

6.11 Foundations form the base on which each tower sits. Foundations for steel lattice towers typically consist of three main designs:

(a) directly buried lattice steel (grillages), where a lattice steel configuration sits on a formed platform below the ground and the entire configuration is directly backfilled and buried;

(b) concrete encased buried lattice steel (grillages), where a corroded or understrength buried steel grillage is retrofitted with a buried concrete foundation; and

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(c) formed concrete foundations that connect the tower by either a bolted base plate arrangement or a concrete encased steel connection.

6.12 Poles are generally directly buried.

Earth wires

6.13 Earthwires are used to bond all conductive structures together and form a protective shield to help mitigate lightning strikes on the conductors. In some parts of the Transpower network, fibre optics are encased in the earthwire and serve as a communication system by utilising an internal fibre capability and providing signalling for protection systems and a communication link between substations.

6.14 Not all assets have full length earthwires installed. They are, however, typically installed in at least the first 5 structures out from all substations and generating sites. It is noted however that the 110kV pole lines entering the Hamilton Substation do not have earthwires installed as "surge arrestors" are fitted at the line termination within the substation.

7. TRANSMISSION ASSETS WITHIN THE PLAN CHANGE AREA AND SURROUNDING DISTRICT

7.1 There are seven National Grid transmission lines within the Plan Change area, as well as the Hamilton substation. These assets are all part of an interconnected network and all have a critical role in the supply of electricity to Hamilton and the broader Waikato region, as well as the Coromandel, Hauraki Plains, Thames and South Auckland. Map 1 below shows the transmission network system within the Waikato Region including the lines within the Plan Change area supplying power to and from Hamilton substation.

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Map 1 - Transmission Network in Waikato Region

7.2 A description of each line within the Plan Change area and its function and purpose is set out below, and the lines are also shown in the map at Annexure A.

Lines

HAM-DEV-A, 220kV, towers (commissioned 1973)

7.3 The Hamilton-Deviation A line is a 220 kV double circuit line (two separate electrical supplies together on one set of towers) into Transpower's Hamilton substation that connects Hamilton city, the wider Waikato region, Hauraki Plains, and Thames Valley including part of the Coromandel to the backbone Grid east of Hamilton city. The HAM-DEV- A connects with the double circuit Otahuhu-Whakamaru C (OTA-WKM-C) line that transports Electricity from the hydro and geothermal generation area around Taupo through to Auckland.

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7.4 The region served by this connection accounts for approximately 400MW of load, 8% of New Zealand's peak demand for electricity, and 170,000 electricity consumers. This includes residential, industrial and farming consumers as well as major dairy factories. It also enables generation at and Karapiro to be part of the national wholesale electricity market. This line is critical to supplying electricity to the region and for its economic and social well-being as a double circuit outage would lead to a black-out of large areas of the Waikato region.

HAM-MER-A, 110kV, predominantly poles (commissioned 1925)

7.5 The Hamilton-Meremere A line is a single circuit 110 kV line that connects directly to Arapuni Hamilton A line allowing some electricity generated at Arapuni Power Station to directly supply south Auckland from Transpower's substation at Bombay, bypassing the Hamilton substation.

HAM-MER-B, 110kV, towers (commissioned 1927)

7.6 The Hamilton-Meremere B line is a double circuit 110 kV line that connects Transpower's Hamilton substation to the Bombay substation in South Auckland. It allows electricity to flow from Hamilton to meet approximately half the electricity demand at Bombay substation or around 13,000 electricity consumers.

HAM-WHU-A, 110kV, towers (commissioned 1969)

7.7 The Hamilton-Waihou A line is a 110 kV double circuit line that connects Transpower's Hamilton substation to four substations that supply the eastern Waikato, Hauraki Plains, Thames Valley and the Coromandel. This region accounts for 3% of New Zealand's peak demand for electricity with around 57,000 consumers. This is a spur line and is the only connection to the National Grid. It is critical to the economic and social well being of the region it serves. This is also the line that is at most risk should the proposal proceed as notified, as there will be containers stacked high underneath the line with mobile plant operating on a 24 hour basis across, under and otherwise in close proximity to the line.

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HAM-KPO-A, 110kV, towers (commissioned 1947)

7.8 The Hamilton-Karapiro A line is a 110 kV double circuit line that connects Transpower's Hamilton substation to Karapiro power station and 35,000 consumers supplied from Transpower's Cambridge, Hinuera and Te Awamutu substations including the dairy factory in Te Awamutu. It is the only connection to the National Grid and critical to the economic and social well being of the region it serves. Karapiro Power Station can meet up to 2% of New Zealand's peak demand for electricity.

ARI-HAM-A, 110kV, poles (commissioned 1925)

7.9 The Arapuni-Hamilton A line is a single circuit 110 kV line that connects directly to Hamilton-Meremere A allowing some electricity generated at Arapuni Power Station to directly supply South Auckland from Transpower's substation at Bombay, bypassing the Hamilton substation.

ARI-HAM-B, 110kV, towers (commissioned 1929)

7.10 The Arapuni-Hamilton B line is a 110 kV double circuit line that connects Transpower's Hamilton substation to Arapuni enabling some of the generation at Arapuni power station to supply Hamilton substation. Arapuni Power Station can meet up to 3% of New Zealand's peak demand for electricity.

Substations

Hamilton Substation

7.11 Hamilton substation is a critical junction that connects four8 of the 110 kV lines and the 220 kV line to supply the wider Waikato, Thames Valley and part of South Auckland. This includes around 170,000 electricity consumers comprising residential, industrial and farming consumers as well as six dairy factories. It is also where electricity is transformed down to lower voltages for distribution to WEL Networks Limited to supply Hamilton city.

7.12 Transpower is in the process of installing an additional 220/33kV transformer at Hamilton Substation to provide further supply to WEL

8 The ARI-HAM A and HAM-MER A lines are joined near Hamilton Substation however are not connected to this substation.

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Networks and the future industrial and residential developments to the north and east of Hamilton.

8. DESCRIPTION OF PLAN CHANGE AREA

8.1 The area subject to the plan change is currently rural land. It is bounded by Transpower's substation, a new arterial road to the west, Ruakura Road to the south, Silverdale Road to the south east and the proposed Hamilton expressway to the east. The area includes an existing residential block to the north (not part of the plan change) and is bisected by the East Coast Main Trunk ("ECMT") railway line.

8.2 Access to Transpower''s lines is across open rural land subject to processes under the Electricity Act to maintain and carry out limited upgrading. There are currently no undue restrictions on our ability to maintain the specific assets within the plan change area. The existing activities are compatible. There are very few major buildings under the lines and with appropriate landowner notification, Transpower can access towers without undue difficulty.

8.3 Transpower's primary concern in relation to this Plan Change is the rezoning and intensification of existing rural land into new growth urban and industrial areas on land traversed by seven National Grid lines and a substation. Transpower is not opposed to this rezoning and intensification, however given the close proximity of the National Grid lines, the development must occur in a way that takes the lines into account and is fully mindful of the risks to and from them.

8.4 I understand from both the Plan Change application and the applicants' evidence, that the HAM-DEV A and HAM-WHU A transmission lines will traverse the proposed Ruakura Logistics Zone.9 This Zone will accommodate a busy inland port approximately 32 hectares in area and handling large scale freight movement between Tauranga, Hamilton, Auckland and Wellington. The Zone is intended to also contain storage, packing and warehousing buildings as well as container storage areas in close proximity to road and rail connections. A new rail siding is proposed of some 900 metres in length to facilitate the loading and unloading of predominantly containerised goods.10 I understand the

9 See Appendix D, Special Controls Ruakura Logistics Area. 10 Pohio, Evidence in Chief 26 February 2014, para 30.

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proposed siding is to be largely in the same location as the HAM-WHU A line.

8.5 These activities create significant risks to the safe and efficient operation of the National Grid assets within the proposed Logistics Zone, in particular the 110kV HAM-WHU A line and the backbone 220kV HAM-DEV A core Grid line, as well as the assets that connect to, and rely on, these assets.

8.6 The photo below show tower 6 on the HAM-WHU line. The ECMT is visible and the proximity of the HAM-WHU line to the railway can be seen.

Photo 9 — Tower 6 on the HAM-WHU line

8.7 I agree with Mr Boyle's statement in his evidence that with a development such as Ruakura, risk management is a key element.11 Mr Pohio also comments on the importance of establishing synergistic land uses in the Logistics Zone.12 Unfortunately, the Applicants' evidence has not proposed any measures to manage the risks associated with the National Grid assets traversing the Plan Change area.

8.8 As I will discuss below, the Applicants refer to discussions with Transpower about relocating or undergrounding certain lines, however no arrangements have been confirmed as yet.

11 Boyle, Evidence in Chief, 26 February 2014, para 59. 12 Pohio, Evidence in Chief, 26 February 2014, para 30.

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8.9 The risks to and associated with the assets can be summarised as follows:

(a) Safety risks (primarily, risk of electric shock);

(b) Impacts on security of supply dues to the increased risk of third parties contacting the lines causing outages;

(c) Threatened security of supply (power outages) due to Transpower's access to the lines being blocked or restricted and/or Transpower not being able to maintain, upgrade or develop the lines as required;

(d) Activities that are sensitive to transmission lines locating under and near to them (such as dwellings and schools);

(e) Risks from activities locating close to the lines and substation and then asking for the operation of the lines or substation to be constrained in some way;13 and

(f) Risks to the infrastructure corridors and Transpower's options for maintaining, upgrading and development of the lines.

8.10 In the next section of my evidence I will discuss safety risks, namely the risks to people and property from National Grid transmission lines. These risks are very real and explain why Transpower strives for a 'zero-harm' workplace and why it promotes safety-by-design, or in other words, proactive management. Following this section, I will discuss maintenance and access considerations for the National Grid.

9. RISKS TO PEOPLE AND PROPERTY

9.1 The main hazard associated with high voltage transmission lines is receiving an electric shock. The risk and severity of electric shocks varies depending on the transmission voltage and type of exposure (eg direct human contact, mobile plant, or vegetation). Risks are most likely to be highest within 12 metres of the line, however some associated effects can be transferred further than this.

9.2 Lethal electric shocks to can be caused by:

13 I understand this is sometimes called "reverse sensitivity".

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(a) earth potential rise;

(b) step and touch voltages;

(c) induction voltages;

(d) conductor drop;

(e) flashovers (coming into contact with the line conductors or where the electricity arcs from a conductor onto an object such as a structure or fence); and

(f) vegetation growing too close to a line and causing a flashover.

9.3 These hazards can occur as a result of third party activities (such as mobile plant or machinery) coming into contact with conductors, and excavations occurring too close to structures or mid-span thereby reducing clearance distances. All of these things can endanger safety and affect the operation of the Grid. I discuss these hazards in more detail below.

Earth potential rise

9.4 Earth potential rise ("EPR") is usually caused by an earth fault at a tower or pole. An earth fault occurs when an energised conductor comes into contact with, or flashes over to, the tower, pole, or any earthed object. This can occur through an insulation failure as a result of lightning, pollution or foreign objects.

9.5 During an earth fault, there is a significant current (2-20 times normal) flowing in the faulted line from the power source into the fault point. These fault currents are highest either near the electricity source (generator) or substation as the current returns through the ground. The return current causes momentarily high voltages to appear on both the tower and the ground around the base of the tower. The voltages are highest on the faulted tower or pole and decrease on the ground as you move further away from the faulted tower. In other words, the risks of EPR lessen with distance from the support structures. Voltages can appear on any conductive object on the ground (such as a fence) that bridges the voltage contours. The earth fault current causes EPR around the faulted tower, which in turn results in step and touch voltage hazards and transferred voltage hazards as discussed below.

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Photo 10 — Fence and surrounding area affected by Earth Potential Rise, near Geraldine, South Canterbury

Step and touch voltages

9.6 Step and touch voltages can arise due to a fault at a tower or pole and, as explained above, momentarily raise the voltage at the tower or pole base and the surrounding ground. A step voltage hazard can occur when a step is taken in this area, or a person or animal is in contact with the tower or pole and standing on the ground, thus causing a voltage difference between the feet or between the feet and hands. Where conductive buildings, structures or fences, for example, are located close to the tower or pole, high current and voltage may transfer from the tower or pole, via the ground and travel some distance down these structures causing an electrical hazard some distance from the faulted tower or pole and causing the same effect.

Induction voltages

9.7 Induction voltages can cause irritation to a person or animal and nuisance from conductive materials such as fences, wires or large industrial buildings. Induction is caused through a magnetic coupling between the conductors and any metallic wires or fences installed over longer distances, generally those running parallel to the circuit itself. People may experience inductive shocks between the metallic wires and ground.

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9.8 Induction voltages can also be caused through a magnetic coupling between the conductors and inadequately earthed large metallic structures such as dairy sheds and barns. Submitters to the North Island Grid Upgrade Project ("NIGUP") Board of Inquiry said that stray voltages led to loss of milk production and stress to animals and staff in dairy sheds in close proximity to the proposed line. Transpower mitigated these concerns on NIGUP by moving existing buildings away from the proposed line.

Conductor drop

9.9 The conductor can drop to the ground should a mechanical failure occur to the support structures, supporting insulators and hardware, or the failure of pressed mid-span joints. In addition, electrical failure can lead to the mechanical failure of the conductor or the pressed mid-span joints.

9.10 While it is rare for a support structure, conductor, or the conductor hardware to fail causing the conductor to drop to the ground, it can happen. Historically, the majority of line drops have occurred in rural areas, but there have been rare occasions where a line drop has occurred in an urban setting (where the generally more intensive and sensitive development places more people and property at risk). When a line drop does occur, the consequences can be fairly wide ranging for activities under the line. Photo 11 below shows impacts within a dwelling, following a line drop. The internal electrical switchboard and appliances have been damaged by the significant transfer of voltages to earth from an adjacent transmission line.

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Photo 11 — Electrical damage inside a house following a conductor drop

9.11 As well as the electrical aspect of a conductor drop, there is also a mechanical aspect of a large load dropping. Conductors on a typical duplex 220kV line weigh approximately 3.0kg/m, therefore for a typical span the weight of the conductor at the point of impact could be as high as 750kg.

Photo 12 — Conductor drop

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Flashovers

9.12 A flashover is a major electrical discharge, usually in the form of an electric arc, which leaps or arcs from the conductor across the insulator string to the tower (or from the conductor to another object) resulting in a short circuit. Flashovers can occur from lightning strike, contamination of the insulator or when a person/object is too close to, or comes into contact with, the conductors.

9.13 Third party activities involving mobile plant or machinery such as excavators, hi-abs and cranes have the potential to reach up to, or above, the height of the conductors. It is essential that the use and location of this machinery is carefully considered to avoid contact with the conductor. Coming into close proximity to a live conductor and causing a flashover (ie the flashover will occur prior to contact) can:

(a) compromise the safety of the machinery operators or workers or members of the public in or near the machinery and result in electric shock;

(b) damage the machinery or the line itself; and

(c) affect the operation of the Grid and the security of supply.

9.14 I am aware of a number of incidents where machinery has caused a flashover between equipment and a conductor.

9.15 A shipping container being carried by a forklift came close to a 220kV line in the Onehunga area disrupting supply to North Auckland and Northland. It was extremely lucky that no one was killed or injured in this incident.

9.16 The photos below show the forklift, the flat tyre sustained in the incident, and the damage done to the conductor.

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Photo 13 — Forklift

Photo 14 — Flat tyre sustained in the incident

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Photo 15 — Damage to conductor

9.17 More recently, an incident occurred when a tractor carrying a crop auger on a local road hit the overhead HVDC line in Canterbury early this month. The crop auger caught fire, and the HVDC line faulted a number of times. Again it was lucky no fatality occurred, but the incident caused operational issues for Transpower in our role as the System Operator controlling the voltage of the National Grid, and could have been avoided.

Photo 16 — Crop auger hitting an overhead line

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Photo 17 — Tractor carrying auger

9.18 A similar incident occurred several years ago where a fatality occurred after an auger hit an 110kV line over pasture land.

9.19 In 2013 a tip truck was spreading gravel on a life style block close to Hamilton when a flashover occurred to a 110kV line.

9.20 The risks of incidents such as these occurring increases if incompatible activities are intensified under or near lines.

Vegetation

9.21 Trees growing close to a line, and which cause a flashover from the conductor to the tree, may cause:

(a) a circuit fault that affects the operation and supply of the Grid;

(b) injury or death to anyone who may be near the tree at the time of the fault; or

(c) damage to the tree, land or property.

9.22 I understand that vegetation clearances are not part of Transpower's request for a buffer corridor, however the effects of failing to comply with clearly specified vegetation growth distances provides a similar context to that of buildings or other activities.

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9.23 If a tree touches or comes close to touching the high voltage conductors and causes a flashover, dangerous voltages may arise on the tree itself or in the ground area around the tree. These voltages have the potential to cause serious injury or death. Flashover to a tree where high voltages are involved can cause the tree to ignite and cause a wider fire hazard if the tree is near buildings or forests.

Photo 18 — Tree damage from fire caused by flash-over

9.24 It is therefore vital that trees and all other vegetation are trimmed or cut to ensure they do not encroach into a "Growth Limit Zone" around the conductors under all situations (ie, taking into account the effect of wind on the conductors and trees, and the sag and swing of the conductors under various ambient temperatures and load). For voltages of 110kV and higher, the tree "Growth Limit Zone" is 4 metres from the conductors under worst case conditions.14

14 Electricity (Hazards from Trees) Regulations 2003, Schedule 1, table 1.

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Diagram 3 — Definition of Growth Limit Zone

9.25 Other hazards and issues associated with transmission infrastructure include equipment or structure failure, earthworks, electrical and wind noise, and the perceived effects of EMF.

Equipment or structure failure

9.26 Transmission lines, similar to buildings, are designed to withstand specified levels of climatic conditions (eg wind speed, snow thickness). If these levels are exceeded, it is likely that failure will occur. Failure events include broken or fallen conductors, collapsed towers (see Photo 19 below) or poles, or any other substantial component failure which results in high risk of property damage or injury and electricity disruption. Transpower sets high design criteria for its infrastructure given the importance of supply to the country. Although the probability of a failure event is low, there is the possibility that injury or damage could occur if a person, animal or item of equipment is in the wrong place at the wrong time.

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Photo 19 — Failed tower on the Benmore-Haywards A line

Earthworks

9.27 Excavations adjacent to towers or poles can undermine the stability of the structure foundations, causing the structure to lean or, worse, collapse. Excavations or mounding mid-span can also increase risks by reducing the clearance between the ground and conductors.

9.28 I am aware of instances where earthworks carried out by third parties have created unstable batters, potentially threatening stability and causing significant safety risks as well as risks to security of supply. The photo below shows earthworks by a developer that were marginally within 6m from the outer edge of the tower. This cut impacted the structural integrity of the tower and I would far prefer to see earthworks managed out to 12m from structures.

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Photo 20 — Earthworks carried out by a developer in Whitby, Wellington

9.29 One of the reasons Transpower seeks the provisions and controls in its submission on this Plan Change is to mitigate the safety risks I have described above. I will discuss below how physical separation from transmission infrastructure greatly reduces the likelihood of harm or damage occurring to people or property. Another important reason for the provisions and controls Transpower is seeking is to ensure access for maintenance and emergency work. I discuss this further below.

10. OPERATION AND MAINTENANCE OF THE NATIONAL GRID

Patrols and Inspections

10.1 Maintaining the National Grid is a core part of Transpower's business. To ensure the Grid delivers a safe, secure and reliable electricity supply, all assets need to be patrolled and inspected on a regular cycle that reflects the asset's age and type, its environment and geographic location, and high risk areas (such as where lines are over major roads, rail and urban areas).

10.2 Transpower carries out two main types of inspection activities in order to determine maintenance, refurbishment or upgrade requirements.

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Routine patrols

10.3 A routine patrol involves viewing every asset annually, as a minimum, to identify any short term defects or situations that may affect the operation or safety of the Grid in the shorter term. Items identified on patrols include damaged or broken insulators, impediments on the conductors, broken climb guards, faded signs, vegetation growth, access issues, land subsidence, and developments or activities under or near the line that may affect its safe and reliable operation. The last of these points is most pertinent as it highlights the issue that any unsafe activities or developments under lines will only be identified by Transpower possibly only once per year, assuming that activity occurs on the day of the patrol. This is further reason to seek provisions in the Plan Change that will assist in a developer adopting safe operations and practices.

Condition assessments

10.4 A full condition assessment involves every line component being inspected and in some cases tested on a time based schedule (mainly 3 — 7 yearly depending on the asset type and environment). Condition assessments require access to all transmission line structures and conductors. From these detailed inspections, a work programme is developed to ensure components are replaced or refurbished well in advance of their failure point.

10.5 Routine patrols and condition assessments of poles and towers are carried out by field staff or contractors using a 4x4 ute or all-terrain vehicle to get as close as possible to the base of each structure.

10.6 Transpower undertakes mid-span inspections of conductors, conductor joints and hardware as part of the condition assessment programme. To date Transpower has tested 12,000 of the 60,000 mid-span joints on the network. Of the 12,000 tested, about 1% have shown to be out of specification and needing replacement. Conductor tests can be carried out by a remote controlled conductor robot that travels down the span taking images and data and relaying this to a computer on the ground. Alternatively, it can be done by linemen accessing the conductor via a conductor trolley or by helicopter. Helicopters are also used to take thermal images, high resolution photos, mid-span joint resistance tests or direct visual inspection.

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10.7 From routine patrols and condition assessment inspections, a wide range of maintenance work is identified and incorporated into a consolidated work program. The maintenance activities that occur most frequently are:

(a) foundation refurbishment and replacement;

(b) tower refurbishment including abrasive water blasting and painting;

(c) all aspects of tower, pole, conductor and insulator (and associated hardware) maintenance or replacement;

(d) maintenance of access tracks, bridges and culverts; and

(e) vegetation and tree control.

10.8 Some of these maintenance activities will be required on the lines within the Plan Change area in the next 20 years and are described in section 11 (Expected maintenance within the Plan Change area) of my evidence. However, all the maintenance activities listed above will probably be required on the lines at some point in the future. Transmission lines are enduring assets provided they are properly maintained.

Maintenance work equipment

10.9 The table in Annexure B indicates the maintenance tasks and equipment necessary for particular maintenance work (including that within the Plan Change area). Most of this work will occur on private land and, depending on the work, may involve the use of lifting machinery, stringing equipment, elevated work platforms or helicopters. Earth moving machinery, such as excavators or diggers, is required to expose or extract tower foundations or carry out pole replacement works. For substantial works a wide range of plant and equipment is sometimes necessary as seen in Photos 21 - 23 below.

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Photo 21 — Removal of copper conductor on Pakuranga- Penrose A line, Auckland

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Photo 22 — Crane being used for re-stringing – Central Otago area.

Photo 23 — Installation of pi-pole – Waikato area.

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Maintenance work space and access

10.10 Clear working space and good access is required particularly around the base of the towers/poles, and in some cases under conductors, to move the plant and equipment in and set it up correctly. Cordons must be installed around the work site to minimise hazards and restrict access to everyone other than the trained work party. When work is carried out on a tower or pole, the effective work area for health and safety purposes includes the spans either side of that structure. Accordingly, cordons are important and may cover a large area.

10.11 In some projects, such as wiring or where alterations are being made to towers or poles, hurdles may be required, or properties may need to be evacuated to protect against potential conductor drop hazards. Photo 24 below shows hurdles established at a work site. Hurdles (which need about 2.5m to 3m down each side of the lines to construct and later remove) are installed to protect traffic on access roads from risks associated with dropped conductors (mainly during re-stringing). Similar projects in urban and industrial developments have required the evacuation of inhabitants or workers for periods of up to a week.

Photo 24 — Typical hurdles installed to mitigate potential conductor drop during wiring

10.12 As I mentioned above, the area at the base of a tower or pole must allow sufficient work site space for plant and equipment. The 12 metre National

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Grid Yard Transpower seeks provides only just enough space for most of the planned maintenance work listed in Annexure B.

10.13 In some cases (as shown in photos 21 to 23) an operating or work area larger than the transmission buffer corridor is necessary. For example, lifting a 18.5 metre pole (which would be representative of the types of poles in the Plan Change) into position during pole replacement works requires:

(a) Space for a crane;

(b) At least 20 metres to lift the pole from its horizontal cartage position to its vertical position; and

(c) Extra space for the vehicle that transported the pole to the site.

10.14 However, Transpower acknowledges that large scale maintenance work, such as pole replacements, happen infrequently and a pragmatic approach needs to be taken. Provided there is reasonable access and a space of at least 12 metres around structures (and 10 or 12 metres either side of the centreline), most foreseeable maintenance work can be carried out. Where space is naturally or historically restricted, Transpower would consult with the landowner to find an alternate solution.

Time necessary for maintenance work

10.15 Depending on the location and maintenance work proposed, the time taken to travel to a site, establish and set up equipment and prepare and secure the site ready for the maintenance work, can be significant. It can take several hours simply to transport and establish cranes or excavators on site and set them up on a suitable platform (see Photo 25 below). It also takes time to apply safety devices and hold work briefings. There may be delays during the planned work periods because weather or environmental conditions may restrict crane or excavator operations due to safety concerns.

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Photo 25 — Reconductoring in an urban setting

10.16 Once the work has been carried out, the above measures need to be reversed (eg the equipment and cranes have to be removed from the site) which can also take considerable time. It is therefore most efficient to carry out the work during reasonable daylight hours on consecutive days. It is simply not efficient to carry out maintenance in short disruptive periods (for example, between arrivals of containers to the port, or in busy daylight hours). In addition, maintenance is generally discouraged at night because of the greater safety and health risks to line workers, particularly if they are working at height in the dark.

11. EXPECTED MAINTENANCE WORK WITHIN THE PLAN CHANGE AREA

11.1 My role within Transpower is to develop longer term asset management and development plans for the transmission line fleet.

11.2 Transpower's network has an aging asset base. The oldest assets in the Plan Change area are the ARI-HAM A and HAM-MER A lines which were both constructed in 1925 (88 years old). The newest asset in the Plan Change area is the 220kV HAM-DEV A line which was constructed in 1973 (40 years old). The average age of the assets in the Plan Change area is 71 years old.

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11.3 While these assets are aging, their condition is relatively good, mainly because of the environment they are located in and sound maintenance over the years.

11.4 Transpower's asset strategy for its transmission line fleet is that all lines have a perpetual life. Some Transpower lines are more than 85 years old. However, with ongoing repair and maintenance, it is planned that existing tower structures will have an enduring life, with future conductor replacements utilising the same structures where structurally capable.

11.5 Transpower's development and investment strategy is centred on maximising the utilisation of existing infrastructure, therefore maintaining the environmental footprint for as long as possible before the introduction of new lines. Transmission line structures can be maintained almost indefinitely by practices such as painting of towers, replacement of timber poles with concrete poles, concrete encasement of existing grillage foundations and replacement of insulators. Conductors are replaced and increased in size and, at times, in the number of conductors per phase to meet additional carrying capacity needs. This work can mostly be completed within the parameters of the Resource Management (National Environmental Standards for Electricity Transmission Activities) Regulations 2009.

11.6 To manage the increasing age, wear and corrosion of the assets in the next two decades or so, foundation works, wood pole replacements, conductor replacements and various maintenance activities (such as steel and bolt replacements, vibration damper replacements and insulator replacements) will be required for the Plan Change transmission assets.

Foundation work

11.7 Tower foundations within the Plan Change area includes grillage foundations, ie directly buried steel. Inspecting these foundations requires the whole foundation to be dug out on all four legs using earth moving machinery such as excavators. If the foundation needs to be replaced, the tower must first be supported via props or guy wires before excavation. Photo 26 below gives an indication of the amount of spoil and earthworks required for a typical grillage foundation strengthening project.

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11.8 A number of the grillages within the proposed plan change area have already been refurbished, and the remaining will be completed within the next 10 years.

Photo 26 — Grillage foundation replacement

Pole and tower replacements

11.9 Wooden pole structures need to be replaced usually after 40-50 years' service due to the wood splitting and decay (although in some environmental conditions wood poles last longer than this). Transpower's policy is to replace these poles with the more robust and permanent concrete poles. Pole replacement usually takes 1½ to 2 days per pole and involves:

(a) site preparation (track establishment, removing vegetation, benching, transporting plant, equipment and pole to site);

(b) excavation of soil to establish new pole foundations;

(c) lifting the new pole, usually by crane;

(d) transferring the conductors to the new pole, generally using an elevated work platform;

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(e) disestablishing and removing plant, equipment and old pole from site; and

(f) reinstatement or repair of any land damage.

11.10 Photo 26 above shows installation of a new pi-pole and reconductoring work. As is shown, on site are 3 cranes and a large truck and trailer capable of transporting the poles and equipment to site. A significant area of land is required, in excess of the 12 metre Yard that Transpower is seeking.

11.11 There are approximately six pole replacements that will need to be carried out in the Plan Change area within the next 10 years.

Tower refurbishment

11.12 Tower painting is a significant on-going maintenance project for Transpower. Painted transmission towers have a coating life of approximately 14-18 years. Once the galvanising on a tower reaches its end life (depending on the environment) the bare steel shows a combination of alloying with rust breakout in more corrosive areas. The longer a tower is left to corrode the more extensive the secondary preparation is, therefore increasing the cost of the painting work (additional steel and bolt replacement may also increase with time).

11.13 Tower painting can range from $50,000-$150,000 per tower, depending on its condition, location, size and type.

Photo 27 — Tower corrosion

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11.14 Tower painting can inconvenience people who live and work near towers. Abrasive blasting of towers prior to painting can cause material to be airborne, and people and property located near this operation need to be protected from this material. Photo 28 - 29 below show houses and cars being draped with polythene sheets as protection during abrasive blasting. As seen from these photos, all effects (such as debris and emissions of airborne particles) cannot be eliminated or fully mitigated through the use of the polythene sheets.

Photo 28 — Tower painting in an urban setting

Photo 29 — Tower painting in an industrial setting showing garnet debris falling onto cars

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11.15 By comparison, in areas where there is no under-build, methods such as geotextile matting laid under the structures, can more easily capture debris from tower painting15 as the Photo 30 below shows.

Photo 30 — Abrasive blasting in area with no under-build — Auckland area

11.16 In underbuilt areas, resource consents often require that less intensive blasting or painting processes are used. Not only does this increase costs (by $15,000 -$20,000 per structure) but also reduces the quality and life of the paint system. As a result, towers need to be painted more frequently (almost every 7 – 10 years, instead of every 14-18 years), leading to more frequent disruption of people living or working under the lines.

11.17 There are 10 to 15 towers that will require painting in the Plan Change area within the next 20 years.

15 Geotextile matting allows the water to soak through but contains the garnet and any other particle matter off the tower. Garnet is the material that is used in the abrasive blasting process. For a tower of around 450m2 requiring 55% preparation, 30-40 cubic metres of water is required and 1.5 tonnes of garnet.

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Conductor work

11.18 Transpower's maintenance work is not limited to structures, as conductor repair and replacement is a significant and key part of the transmission lines management. Conductors corrode or wear as they age, until reconductoring either part or all of the line is required. This work activity involves:

(a) Building, stringing and tensioning work sites to locate pullers and tensioners, laying down sites, storage, as well as an area for working;

(b) Accessing each tower to remove the existing insulators and install stringing equipment such as running blocks;

(c) Tower and foundation strengthening where necessary;

(d) The rewiring process (using the old conductor to pull out the new conductor);

(e) Sagging operations at each tower to ensure even and consistent sag profiles;

(f) Reinstalling the insulators, including clipping in the conductor; and

(g) Removal of plant and reinstatement of lands.

11.19 Access for maintenance work on simplex conductors presents some additional challenges compared to working on a duplex conductor. For example, access to simplex conductors is usually limited to ground base operation using elevated work platforms or cranes, or lowering the conductor to the ground. In some cases, it is possible to suspend linemen from helicopters but this involves long periods of helicopter time while the work is being carried out below. Photo 31 below shows maintenance work being carried out using helicopters.

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Photo 31 — Maintenance being carried out with the use of a helicopter

11.20 In the case of duplex conductors as on the 220kV HAM-DEV A line, access can be arranged using lineman conductor trolleys or helipods as shown in Photo 31 above. Conductor trolleys or helipods are suspended using both conductors of a duplex configuration to hold the trolley in place. The trolleys have four wheels which allows them to be moved along the spans between towers.

11.21 From time to time, Transpower needs to access the conductors at mid- span for inspection purposes or to carry out repairs. Mid-span damage can be caused by lightning or corrosion damage or could be caused by third party activities under the line from smoke or fires, vehicle or mobile plant, or vegetation touching causing flashovers.

11.22 Conductor repair methods include inserting new sections of conductors, new joints, mid-span repair joints or sleeves and removing impediments

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such as kites, balloons, and electric fence wires. In all cases access to the conductor is necessary.

11.23 Conductor replacement or mid-span conductor repairs include inserting new sections of conductors, new joints, mid-span repair joints or sleeves. This ideally requires a relatively clear area under the line where the works are being carried out. In some cases this may be the entire line.

11.24 Within the next 10 years there will need to be about 2km of conductor replacement within the Plan Change area.

11.25 Three of the 110 kV lines to the south of Transpower's substation (ARI- HAM A&B and HAM-KPO) still use the original copper conductor. Elsewhere in New Zealand this type of conductor has largely been replaced with more modern aluminium based conductors. The conductor near Hamilton however has remained serviceable due to the more benign environmental conditions in the Waikato. It is likely that this copper conductor will need to be replaced within the next twenty years requiring appropriate access to the lines.

11.26 Likewise the conductor on the other lines will need to be replaced in future as part of normal lifecycle maintenance of the lines. Appropriate provision for access for this work will need to be retained.

11.27 Mid-span under-build, particularly dwellings and buildings for intensive development (where people are most inconvenienced), not only creates significant additional costs for Transpower in carrying out any reconductoring or mid-span repair works, but there is also a real chance that this work could not be undertaken efficiently and alternatives (such as a new or bypass line) need to be considered. In some instances it may be necessary to consider evacuating people living and working under the line - at huge inconvenience and costs (to Transpower as well as individuals and businesses).

11.28 In an urban or industrial environment, the reconductoring operation can cause inconvenience to the public by restricting vehicle access and even access to public or commercial areas such as schools, businesses, and parks.

11.29 Some commercial and industrial activities not typically considered to be sensitive are disproportionately affected by the need to shut down during

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conductor repairs, and/or are affected by helicopter use. As noted earlier in my evidence, work sites, particularly when in a span when there is the potential of the inadvertent loss of control of load or machinery failure requires the area to be closed off to provide a safe work site. In the case of the proposed port operation, during helicopter works on a span, or the replacement of conductor in a span, Transpower would need to effectively close the complete area below the conductors while work was being undertaken to provide a safe work site.

11.30 In general Transpower tries to schedule its works, including any outages, to cause the least inconvenience to landowners and the public. However, as I will explain later in my evidence, this is not always possible.

11.31 Live line work is sometimes possible, but there are restrictions on the types of activities that Transpower's workers can do while a line is alive. Mid-span jointing, removing jumpers16 or conductors, lowering conductors to the ground for repairs, and some insulator replacements cannot be carried out while lines are live, either due to the nature of the work or due to restricted worker distances from live equipment. Live line work involves a highly trained work crew and requires the same access, work areas and crew numbers as the traditional de-energised work methods. Work in the substations is not normally done live due to the close and complex nature of the equipment.

Other maintenance work

11.32 In addition to the tasks described above, over the next 10 years there will need to be more than five insulator and hardware replacements, and ongoing vegetation management works within the Plan Change area.

12. CO-ORDINATING OUTAGES WITH LANDOWNERS

12.1 When Transpower needs to gain access to its lines it works with landowners to minimise the impact of work on their operations. However, this often requires co-ordinating with several landowners for a single outage for work along the length of a transmission line.

12.2 Landowner access requirements vary as activities under the length of a line are not the same. For instance, access restrictions for certain types

16 Jumpers are short lengths of conductor used to bridge between conductor spans usually at a terminal tower or pole.

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of farming or industry may be at different times to access restrictions for busy port activities.

12.3 The more the work on a line is fragmented to accommodate individual landowner access requirements, the more outages at different times are required to complete the work. Often a compromise is required. It is just not possible to accommodate the specific needs of every landowner.

12.4 Further restrictions, such as having to co-ordinate maintenance or upgrading between the daily movement of heavy machinery and containers at the port, along with other restrictions, would be simply impractical. The cumulative effect of allowing these activities under lines will be further restrictions on Transpower's ability to maintain and upgrade existing lines.

12.5 It is common sense to locate activities that cannot be easily shut down to enable work on transmission lines, or are likely to have reverse sensitivity effects, away from the lines so they will not need to be vacated for maintenance work or scheduled upgrade and development work.

13. CO-ORDINATING OUTAGES WITHIN THE ELECTRICITY INDUSTRY

13.1 Arranging outages is already a complex process to ensure an electricity supply is maintained during an outage and the lights are not turned off. Arrangements must be made, not only with maintenance contractors and landowners, but also with generators, major electricity users and local lines companies, to manage electricity demand within the remaining available Grid capacity when a line has been turned off to enable work.

13.2 The Grid is a network of lines, with most substations having two or more lines connecting them. If one line is turned off, then the electricity has to flow via other lines, without overloading them, while still supplying the consumers or connecting the generation at the substation.

13.3 The impact on the operation of the wholesale electricity market must also be considered. Removing lines can result in more expensive electricity generation being required to run or hydro storage being spilled.

13.4 The Electricity Industry Participation Code 2010 set by the Electricity Authority incorporates an Outage Protocol which sets out the process Transpower must follow for arranging planned outages of the Grid.

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13.5 The process includes preparing and consulting on an annual plan. The consultation must include conducting regional forums with interested electricity industry participants. Affected electricity industry participants may require Transpower to carry out a net benefits test to demonstrate the benefits of a planned outage outweigh the costs to electricity market participants for a planned outage in the outage plan.

13.6 Subject to limited exceptions, Transpower must notify (at least 40 business days in advance) and consult on any variations (cancellations or rescheduling) of the planned outages in the outage plan.

13.7 Planned outages may be cancelled at short notice by the System Operator, a separate division of Transpower that operates the power in a real time system under contract to the Electricity Authority. Cancellation is likely if the overall configuration of the power system prior to the outage creates a heightened risk that full electricity supply may not be maintained. This cancellation can be either due to other coincident outages of lines or generation, or forecast weather conditions. Cancelled outages are rescheduled; again requiring co-ordination with contractors, landowners, local electricity distribution companies, and generators.

13.8 Transpower typically carries out 2,000 to 3,000 planned outages each year on lines and equipment in substations. The outage planning system processes over 6,000 outages a year; in effect each outage is processed twice due to the restrictions and complexities in securing planned outages.

13.9 Limited outage windows make it difficult to maintain certain parts of the Grid, and therefore make it more likely that costly upgrades will be brought forward.

13.10 Outages to maintain the 220 kV Hamilton Deviation line (HAM-DEV) are restricted to the three months from March to May when the amount of electricity required is low enough to allow an outage while still ensuring Hamilton and the Waikato region can be supplied with electricity. Outages are limited to one circuit only, and are typically limited to only a few days during this period.

13.11 Outages to maintain the HAM-WHU A line are also restricted for similar reasons due to the nature of electricity demand in the eastern Waikato, Hauraki Plains, Thames Valley and Coromandel, especially the large

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dairy factories that require continuous supply to process milk products. As noted previously, this line is the only supply from the National Grid into this region.

13.12 Both lines are double circuit lines with two separate electrical supplies (circuit) on each side of the towers. During outages to maintain a circuit on one side of the towers, the supply is more vulnerable to interruptions as there is only one circuit left supplying electricity.

13.13 A fault on the remaining in-service circuit during maintenance will result in a loss of supply to consumers across the whole region (HAM-DEV A) or Thames Valley (HAM-WHU A) as there is no back-up supply capable of supplying all consumers in either case.

13.14 In both cases momentary fault on the remaining circuit during maintenance, for whatever reason, will result in an interruption to supply for a minimum of 1-2 hours until it is established it is safe to reenergise the circuit with consequential economic and social consequences to the region. A fault that damages the circuit may result in an outage of up to eight hours or more if the circuit being maintained has to be restored instead.

13.15 Both lines run through the proposed logistics area in the Plan Change where mobile plant (container crane carriers) and other vehicles will be working under the lines. Transpower's experience is that such operations pose a real risk of interruptions to consumers when a circuit on either line is out for maintenance, making the remaining circuit vulnerable and therefore threatening security of electricity supply.

13.16 This occurred in November 2009 when a forklift carrying a shipping container hit one 220kV transmission circuit on the Henderson-Otahuhu line in Auckland while the other circuit was out for maintenance. This resulted in a loss of power to appromiately 600,000 electricity consumers in North Auckland and Northland including the oil refinery at Marsden point.

Summary in relation to maintenance work

13.17 I consider that high density under-build, sensitive activities and intensive, frequent freight handling activity should not be undertaken within 12 metres of support structures, or 10 or 12 metres either side of the

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centreline of lines in the Plan Change area, especially where there is the opportunity to avoid this. This area is required for inspection and maintenance activities for the life of the line.

13.18 I further consider that the location of a proposed logistics area in the Plan Change where containers will be stored and mobile plant (container crane carriers) and other vehicles will be working under the lines poses a real risk of interruptions to consumers and to the safety of the workforce undertaking those operations.

14. EMERGENCY WORKS

14.1 The works described above are those Transpower has planned or are typical of the works expected to be necessary in Plan Change area. In addition, Transpower needs to be able to quickly access its lines at all times in order to find and fix faults. Businesses and communities are heavily reliant on electricity, so it is crucial that faults are identified and fixed as soon as possible. While Transpower's assets perform extremely well in storm events or natural disasters, excessive snow or winds do at times break or collapse Grid infrastructure and emergency repairs need to be carried out to get these back into production. During these times there is often a heightened requirement for electricity (for heating, or to assist with a recovery).

15. ACCESS

15.1 The transmission lines within the Plan Change area are typical of the lines operated and maintained by Transpower nationally. These lines are mainly located in, or across, private land where there are a variety of land use activities and geographic situations to consider.

15.2 Transpower has statutory rights to access its assets on private land under the provisions set out in the Electricity Act 1992. The Act provides for access to maintain, inspect and operate the National Grid. In some cases, Transpower has contractual or property rights to access new assets constructed on private land. It is important to note that my evidence is about the physical ability to access Transpower's assets. Issues regarding establishing legal access are distinct issues that are handled by other divisions in Transpower.

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15.3 In my view, it would be ideal to have unimpeded physical access to all transmission line structures. However, in a practical sense this is not always possible. Physical barriers and natural obstacles such as waterways, valleys, and undulating ground require Transpower to take alternative access options depending on the type and nature of the work required on the asset. Further intensive or sensitive development will add additional physical barriers, and thereby increase the costs associated with access. For example, dismantling fences and other structures, temporary bridging of waterways, evacuations and vegetation removal, all add to the cost of works.

Complaints

15.4 I have discussed above the importance of physical separation of third party activities from transmission lines for safety reasons, and also to ensure access to the assets for maintenance and emergency work. Space around structures and conductors is also required in order to carry out maintenance and other work such as reconductoring or upgrading a line. A further reason why physical separation is important from Transpower's perspective, is to reduce incidents of people who live and work nearby complaining about the line and requesting changes (ie limits or restrictions) to its operation. I briefly discuss these issues below.

15.5 The presence of a transmission line can give rise to perceived health concerns and visual amenity issues, even some distance from the line. Furthermore, sometimes people complain of electrical interference (such as a fuzzy television picture or electronic devices not working properly). In addition to general complaints arising from the presence of transmission infrastructure, Transpower also receives requests from landowners to underground existing overhead lines, raise conductors, or restrict future Grid works, particularly if they involve changes in visual appearance. Although the distances that these types of effects are experienced at vary according to the type of effect, I expect they are most noticeable within 12m of the centrelines.

15.6 At the NIGUP Board of Inquiry into a major new Transpower line, a number of submitters raised concerns about both potential mechanical and electrical noise, and the potential effect on milking dairy herds in close proximity to the lines, or operation of sensitive electronic equipment such as radio controlled systems. In most cases, these concerns were

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addressed by Transpower moving existing buildings away from the proposed line. These complaints are much more difficult to address where new activities locate close to an existing line, perhaps without understanding the effects that lines can have.

Reverse sensitivity

15.7 Reverse sensitivity effects are caused not only by residential activities which locate near lines, but also by commercial, industrial and farming operations which can be affected by electrical interference, or suffer animal welfare issues or business costs when maintenance and upgrading of lines occurs.

15.8 The area or distance from the lines within which reverse sensitivity effects can arise may vary according to the type of issue raised, but they are most noticeable in the area where the conductor swings out to. Depending on asset type, this area can be out to 39 metres either side of the centreline. This area where the conductor swings out to is discussed further below in relation to the corridors Transpower is seeking through the Plan Change.

Examples of reverse sensitivity effects

15.9 In 2007, Transpower undertook to increase the capacity of the existing 220kV Henderson-Otahuhu transmission line by increasing the current flowing through the lines to its rated capacity of 986MVA. This increase in capacity to that which the line was always capable of was necessary to ensure that the electricity supply to customers north of Auckland was secure, particularly during times of forced outage. The majority of work to uprate this line did not involve physical changes to the towers.

15.10 The consent application for the uprating was notified by Auckland City Council and attracted some 350 submissions. While submitters raised a range of concerns, many of the concerns related to the existing effects of the line. Submitters who lived further away from the transmission line sought to have the line relocated or undergrounded. Over the course of proceedings, the Council heard evidence from submitters and expert witnesses on perceived health effects, noise, safety (including the integrity of conductor joints), alternative transmission options, and electrical interference. Resource consent was granted by Auckland City Council, and appealed to the Environment Court at considerable cost to

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all involved. While the appeal ultimately settled, the consent sought and ultimately obtained placed restrictions on the use of the line. As a result of this, the line is only able to be operated at its design capacity during periods of forced outages – not at all times.

15.11 While that Environment Court case was resolved many years ago, the existence of those lines remains a concern to the local community. This is in part due to the visual effects and perceived health effects of the lines, but primarily due to the constraints that this line places on the ability to develop the underlying private land. Requests to underground the Henderson-Otahuhu line continue – as well as requests to underground other lines in its vicinity.

15.12 Most recently, the legislative constraints on Transpower's undergrounding were raised at a meeting in Onehunga on 9 September 2013. Despite these legislative constraints, there appeared to be an expectation from the community that the lines should be undergrounded in a period of 10- 15 years. These community expectations are strengthened by Auckland Council plans referring to strategies being developed to support undergrounding of National Grid lines. Given the very high costs and in some cases physical constraints on undergrounding, I expect that considerable resource will need to be provided by Transpower to respond to these issues.

15.13 Requests by the public to underground National Grid lines are not limited to the built up areas of Auckland. The undergrounding of lines was raised during a hearing in Central Otago in 2013. The decision states that the Council is firmly of the view that Transpower's line through Alexandra should be undergrounded or relocated away from the township. This statement was made despite the line being located in a greenfields area where there is the opportunity to develop around the lines, and Transpower having a clear right for it to continue there under the Electricity Act. Similarly, during a hearing in Whangarei in 2012, many landowners suggested the National Grid towers be raised to 70 metres – to remove any restrictions on landowner activities below the conductors.

15.14 These examples demonstrate why Transpower welcomes the direction in Policy 10 of the NPSET that councils manage activities to avoid reverse sensitivity effects (as well as direct effects) on the National Grid.

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Electrical noise

15.15 Noise from a transmission line usually comes in two forms: mechanical noise and electrical noise:

(a) Mechanical noise can come from vibration which causes a rattle of the line hardware (insulator attachments, steel members) or from environmental events such as high winds (wind whistling through conductors or over steel works).

(b) Electrical noise usually comes from some form of electrical discharge, or leakage. This generally can be heard discharging down insulators when it starts raining after a long spell of fine weather. In some cases this corona discharge may be seen at night when insulators are polluted and electricity is seen discharging down from the conductor to the tower steel.

Electric and magnetic fields

15.16 In some areas of New Zealand, landowners/occupiers have raised concerns about electric and magnetic fields ("EMF") from transmission lines. I note that Transpower's assets operate well within the limits in the International Commission on Non-ionising Radiation Protection Guidelines for limiting exposure to time varying electric magnetic fields (1Hz – 100kHz) (Health Physics, 2010, 99(6): 818-836 (known as the ICNIRP Guidelines). These Guidelines are recognised by the Ministry of Health and the World Health Organisation.

15.17 In the following section of my evidence I discuss the upgrade work scheduled for the lines within the Plan Change area.

16. GRID PLANNING ISSUES WITH LINES IN THE PLAN CHANGE AREA

16.1 Transpower's 2013 Annual Planning Report forecasts that electricity demand in the Waikato region will grow at an average rate of 1.7% over the next 15 years.17 This is higher than the national forecast of 1.5%.18

16.2 As I stated earlier, my role within Transpower is to develop longer term asset management and development plans for the transmission line fleet.

17 Transpower Annual Planning Report 2013, page 131. 18 Transpower Annual Planning Report 2013, page 131.

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16.3 There are three future development needs that impact on the lines and area affected by the plan change. They are:

(a) Accommodating future growth in electricity demand in the Eastern Waikato, Hauraki Plains, Thames Valley and Coromandel. The Hamilton-Waihou A line through the proposed logistics area to the east of Transpower's substation is near capacity. Transpower is currently exploring options for future capacity likely to be required within 5-10 years. This could include upgrading the line and/or a enhancing the capacity and security by building a new substation east of Hamilton.

(b) Additional capacity to meet future demand and improve reliability of supply from the core backbone grid into Hamilton. Within 10 to 20 years this could include an additional 220 kV connection or a greater reliance on the Hamilton- Waihou A 110 kV line in conjunction with a new substation east of Hamilton. This later option is consistent with Transpower's approach to maximise the utilisation of existing assets to minimise the environmental footprint of the Grid.

(c) Additional capacity is required into South Auckland. One option would place a greater reliance on the from the Hamilton- Meremere A and B lines which run through the proposed residential and industrial park areas in the Plan Change.

16.4 It is likely that all the above development plans will require the reconductoring of each line. The new conductor would be larger and have enhanced current carrying characteristic from the existing conductor. Replacement of conductor of this type requires the development of safe work zones beneath each line.

17. MANAGEMENT OF RISKS

17.1 Transpower manages risks when designing and constructing new assets and through continuous assessments and maintenance of the existing assets. When earth faults occur (rare though they are), the current is interrupted by protective devices at each end of the line to clear the fault in a fraction of a second. However, engineering solutions such as this are only part of the answer. It is also vital that third parties do not

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interfere with proper operation of the line and appropriate maintenance and upgrade work can be carried out when required.

17.2 This risk can be minimised by ensuring development is either avoided or is compatible with the lines. Where large scale development (such as subdivision) is proposed it should be designed to ensure that only appropriate activities occur under the lines (such as carparks, roads, stormwater infrastructure, or open space).

17.3 Proper design of any underlying activities, including consultation with Transpower, is essential to manage risk. The Onehunga example of the forklift carrying the shipping container and creating a flashover could have been avoided by ensuring that the activities under the line did not store containers and did not require forklifts to operate under the line. That is the outcome that Transpower is seeking for the Board to require here, as that would avoid or eliminate the risk.

17.4 In contrast, options to mitigate (but not avoid or eliminate) this risk would have been to apply height barriers or safe forklift lanes under the line, the development of container storage plans that take account of conductor movement under wind and load, and ongoing worker training to ensure the risks of working near live lines were understood. This could be secured here through requiring activities involving mobile plant in the Logistics Zone to obtain a resource consent (which would impose specific controls on the activities beneath the lines). While that would not be as safe as avoiding the activities in that area, that is the minimum that should be adopted by the Board in order to ensure that risks are minimised.

17.5 Development by others must take into consideration the "safety by design" concept when planning and designing a development (such as a structure or earthworks) near a Grid asset. The key points to consider for this are:

(a) The safety of workers during any construction or build stages of the development (eg builders, earth movers, and electricians);

(b) The safety of residents, workers and the public who may be working, living or recreating in the area after the development is competed;

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(c) The safety of the line maintenance workers who are required to access the Grid assets both during the development's construction and when it is completed;

(d) Whether the proposed development follows best practice for the construction industry; and

(e) Access to structures and lines by emergency vehicles.

17.6 The construction of infrastructure, structures and heavy lifting plant operations near or under a transmission line must be planned and installed considering a number of key elements:

(a) The location and configuration of the structures;

(b) The inductive voltages that may be present and possible mitigation measures that may need to be applied;

(c) The vehicle movements and height restrictions necessary to avoid entering the conductor flashover zone;

(d) The transferred voltage hazards; and

(e) The EPR issues associated with workers in and around transmission line structures.

17.7 However, as discussed earlier, notwithstanding these measures, I do not consider that it is appropriate for activities where groups of people are present for extended periods to establish under the line. It is better to avoid such activities too close to lines in order to minimise risk to people and property and potential disconnection of electricity to end consumers.

National Policy Statement on Electricity Transmission

17.8 The National Grid is a physical resource of national significance. Mr Horne's evidence describes the NPSET, which recognises that the efficient transmission of electricity via the Grid plays a vital role in the wellbeing of New Zealand, its people and the environment. The National Grid needs to be operated, maintained, developed and upgraded, but this needs to be done bearing in mind its special characteristics and the adverse environmental effects it causes, as well as the adverse effects

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other activities cause to it. The NPSET was created by the Government in 2008 to manage these issues.

17.9 The NPSET contains policies that address both the effects of activities carried out by Transpower, and the effects of other activities on National Grid lines. Policy 11 of the NPSET which Mr Horne will explain in greater detail, requires the identification of a "buffer corridor". In my evidence, I use the terms National Grid Yard (or "Yard") and National Grid Corridor (or "Corridor"), as these are defined in Transpower's submission on the Plan Change. That is:

(a) The Yard is a buffer area measured 10m either side of the centreline of a National Grid line on single poles19 and 12m either side of the centreline of a National Grid transmission line on towers, and 12m from the visible outer edge of any support structure.

(b) The Corridor is a buffer area measured 14m from either side of the centreline of a 110kV National Grid transmission line on single poles,20 32m from either side of the centreline of a 110kV National Grid transmission line on towers, or 37m from either side of the centreline of a 220kV National Grid transmission line. The controls sought in relation to the Corridor apply to subdivision.

17.10 I note that the area of the yard is relatively small compared to the total plan change area. The Yard is only around 22ha of land in total within the Plan Change area (out of 389.54 ha).21 This equates to approximately 5.6% of the total Plan Change area. The Yard for the HAM-WHU A line within the Ruakura Logistics Zone is only 3.4ha.22

The reasons for transmission corridors

17.11 A transmission corridor (ie Yard or Corridor) around National Grid lines has five important purposes:

(a) The first reason is to ensure that sensitive activities such as residential development, schools, childcare and hospitals are

19 I understand that this is slightly different to what is set out in Transpower's submission (which referred to pi poles) as explained in Chris Horne's evidence. 20 Again, the submission refers to 16m for pi poles, as explained in Chris Horne's evidence. 21 Based on Transpower calculations. 22 Based on Transpower calculations.

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generally not provided for near support structures and lines. This is the purpose for which the NPSET requires corridors.23

(b) The second reason for a transmission corridor is that a relatively clear area gives line workers easier access to the line and support structures for maintenance and operational requirements. Further, a relatively clear corridor ensures that Transpower's ability to upgrade or develop its lines is not compromised.

(c) The third reason is to manage reverse sensitivity effects. These occur when a person moves next door to, or carries out an activity near, an existing line or structure and seeks to put constraints on the line or structure because of its effects. These effects can arise in relation to issues such as noise (especially in damp weather), reduced amenity, line drip, interference with electrical equipment and perceived health effects from electric and magnetic fields from the lines. Reverse sensitivity effects have significant cumulative potential which may lead to requests for constraints on existing National Grid lines.

(d) The fourth reason, as I have described above, is that electricity transported at high voltages can cause serious, or even fatal, injuries to people who come close to lines. Structures and earthworks too close to a line can affect the stability of that line, and contribute to electricity outages. The presence of these structures can also increase the need for, and thereby risks associated with, mobile plant (eg container handling cranes,) breaching safe electrical distances and coming into contact with lines.

(e) The fifth reason is that a buffer corridor operates to protect the infrastructure corridor itself. As land uses become more intense, it is increasingly more difficult to identify routes for new assets. If a transmission line is compromised by encroaching land uses, it can sometimes be impossible to optimise the capability of existing lines (which defers the need to build new lines). If new lines are required, it can be difficult to identify an alternative route which would disrupt landowners less. Existing clear

23 Policy 11.

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corridors are a finite resource, to be protected for the future. Giving proper effect to the NPSET will 'future-proof' the National Grid for the benefit of Hamilton City, the wider Waikato and Thames Valley Regions.

17.12 While the above 5 reasons could apply to both the Yard and wider Corridor, Transpower's focus is primarily on the narrower Yard – restrictions on land use are important in this area. Transpower's interest in the Corridor is to ensure development is appropriately designed, for the reasons above, and to preserve the Yard.

What transmission Corridors and Yards will achieve

17.13 Transpower considers that, in order to give effect to Policies 10 and 11 of the NPSET, the Yard width (and supporting rule framework) needs to be wide enough to ensure the following:

(a) the integrity, operation and maintenance of the National Grid lines;

(b) management of factors such as amenity (noise, line drip) and reverse sensitivity (discussed above);

(c) adequate physical separation between transmission lines and buildings, structures and activities such as the operation of mobile plant for safety reasons;

(d) people and property along the length of the lines recognise both the scale and strategic nature of the resource;

(e) anticipated future operational requirements are provided for, including development of the lines; and

(f) sensitive activities are avoided.

17.14 Transpower proposes transmission Yards that are the minimum areas able to achieve the majority of these outcomes. The proposed areas do not fully address such matters as amenity and reverse sensitivity, and consequently further consideration is necessary of urban design, integrated management and prudent avoidance. This can be achieved at the subdivision stage. Transpower acknowledges that beyond the

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minimum corridor councils (or in this case the Board) may wish to impose additional controls.

17.15 I have explained above the reasons why Transpower is seeking transmission corridors, and the rationale applied by Transpower in identifying appropriate buffer areas. I have also outlined Transpower's approach in seeking to allow for the reasonable use of the underlying land to the extent that will also achieve key safety, operational and maintenance requirements.

17.16 Certain activities can be compatible with the efficient operation and maintenance of the National Grid. The transmission corridors and planning rules proposed by Transpower will allow compatible land use activities (eg roading, greenspace, and carparking) but restrain other incompatible ones (eg dwellings, major buildings and commercial activities). Below I discuss which activities can be compatible and incompatible with National Grid lines.

18. THIRD PARTY ACTIVITIES NEAR TRANSMISSION LINES

18.1 In rural environments, it is more likely that activities and development will occur that is compatible with transmission infrastructure. This is why, historically, Transpower located substations on the perimeter of population centres. Overtime, through land rezoning and population growth, development has occurred around substations and lines and effects have occurred on neighbouring landowners resulting in complaints to Transpower and requests to alter the way it operates the infrastructure.

18.2 Transpower does not oppose appropriate development around substations and near transmission lines but it is critical that this development occurs in an appropriate and safe way. This will ensure risks such as electricity shocks are minimised to the greatest extent possible, and will also ensure the infrastructure can continue to operate in the long-term, keeping the lights on for the community. Transpower is very willing to accommodate and support new development provided it takes the transmission assets fully into account.

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Activities which could be compatible with transmission lines

18.3 In my opinion, the following activities could be located within the transmission National Grid Yard and National Grid Corridor (noting that they will still need to comply with NZECP34, and will need to be set back away from the transmission support structures):

(a) Car parks, greenways, walkways, and roads.

(b) Alterations or extensions to existing buildings, provided they are not associated with a sensitive use (residential, medical, children), they do not create an electrical risk, and they do not prevent access to the lines (that is, the extension is on the far side of the building from the line).

(c) Network utilities, such as electricity distribution lines, where the companies are very aware of the requirements for working near electricity. Other network utilities, such as irrigation canals and sewage treatment facilities, should only be allowed once Transpower has confirmed that the utility (and any earthworks necessary to construct it) will not undermine the Grid support structures, restrict access to the lines, or otherwise create a hazard.

18.4 These activities are considered compatible with transmission lines because they do not introduce activities that bring intensive infrastructure or heavily frequented workplaces with long durations of exposure to the risks I have described above.

18.5 In the area beyond the National Grid Yard, but within the National Grid Corridor, development also needs to take the lines into account. In my opinion, there is no engineering reason why buildings, structures or earthworks cannot be located or carried out in this area, provided consideration is given to whether they:

(a) can be constructed safely;

(b) have a "safety by design" approach;

(c) give reasonable access to the lines; and

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(d) comply with the minimum safety distances set out in NZECP34 (which must be complied with anyway). As I explain below, depending on the transmission line span and height, NZECP34 could restrict construction of buildings beyond the National Grid Corridor.

Activities which should be avoided near transmission lines

Sensitive activities

18.6 From an engineering and risk management perspective, the longer the amount of time that a person is working or living close to high voltage electricity, the greater the risk of injury or damage to their property from a fault on the line (triggered by a lightning strike for example). I am aware of instances where electrical devices in a workplace (such as a timber treatment plant) have stopped working correctly due to alleged interference from a transmission line. Obviously, electrical interference could have serious implications for places such as hospitals or rest homes which rely on the proper functioning of electrical equipment 24 hours a day. Radio controlled and global positioning systems are known to be affected by the close proximity of transmission lines; such systems are being used more for communications and automated control systems in industrial processes.

18.7 People living or working in buildings under transmission lines also create significant difficulties when Transpower needs to do maintenance, upgrade and development work. I explained above how maintenance work becomes more difficult with buildings under and near lines, eg in the National Grid Yard. A lot of work has to be done with the lines energised, which requires people to vacate buildings while the work is underway. Even when linesmen carry out work with the line de-energised (ie during a scheduled outage), there are risks to the people and property under the line. Replacing a conductor is the time when the risk of conductor drop is greatest.

Earthworks

18.8 Excavations adjacent to towers or poles can undermine the stability of the structure foundations, causing the structure to lean or, worse, collapse. Excavations or mounding mid-span can also increase risks by reducing the clearance between the ground and conductors. Any excavations near

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lines need to comply with NZECP34, and to ensure that, we are seeking for a consent to be required for earthworks within 20m of our infrastructure.24

Buildings and commercial operations

18.9 In my opinion, intensive use buildings and commercial operations and structures should not be located in the 12m National Grid Yard, even if they comply with NZECP34. Intensive use buildings and commercial operations pose a risk to the operation of the line, compromise Transpower's ability to maintain the line, and are a risk from electrical hazards. This includes buildings such as high level storage facilities, factories, large scale industrial buildings, commercial operations that emit dense smoke, dust or chemicals and high density lifting operations involving forklifts, cranes, tip trucks and similar vehicles. These buildings and activities either are at greater risk of effects from the transmission lines, or put the line itself at greater risk.

18.10 One of the reasons why workplaces are unsuitable within the transmission corridor is the difficulty co-ordinating outages, as I have explained above. Transpower works with landowners wherever possible, but outage planning is one area that is very difficult to schedule with absolute certainty. When there is clearance for an outage, and once the protective measures are completed (installation of hurdles and other safety measures), there may be only 3 hours to do the actual work before the power needs to be restored to the line again.

18.11 If allowed to be constructed, highly intensive buildings such as high level storage facilities, factories, and large scale industrial buildings, would need to be either vacated during reconductoring operations or protected by the construction of high cost scaffolding and nets as shown in Photo 32 below (this is based on the assumption that the development allowed room for the construction of such structures). The scaffolding and netting constructed below to protect an undercrossing line cost in excess of $350,000 to construct and dismantle.

24 Evidence of Chris Horne, para 4.2(f).

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Photo 32 — Scaffolding protection structure for stringing conductor.

18.12 Reconductoring an existing line section in the proposed plan change area would likely take 4-5 days. Even smaller maintenance work typically takes 8-12 hours. So it is practically very difficult, if not impossible, for Transpower to work around a intensive industry operations without incurring large delays or costs to both parties.

18.13 It is unfortunate that substantial development has occurred beneath the lines in areas such as South Auckland. This has resulted in a far from ideal situation, and has provided many challenges to Transpower when trying to maintain its assets, at times delaying important maintenance works for more than two years. The NPSET has recently provided recognition of the national importance of transmission infrastructure. While there is little that can be done to reverse existing under-build, with NPSET it is hoped future under-build, particularly in a green fields development such as the proposed plan change area around Ruakura can be avoided.

Mobile plant

18.14 Third party activities involving mobile plant or machinery such as straddle carriers, forklifts and cranes have the potential to reach up to, or above, the height of the conductors. It is essential that the use and location of

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this machinery is carefully considered for the reasons noted earlier in my evidence.

18.15 The risks of incidents occurring will only increase if incompatible activities are intensified under or near lines. Controls such as constructing height barriers or safe forklift lanes under the line, the development of container storage plans that take account of conductor movement under wind and load, and ongoing worker training to ensure the risks of working near live lines were understood can be put in place to reduce the risk of incident. In a greenfield situation however there is the ability to eliminate this hazard as defined in the Health and Safety in Employment Act 1992 by locating storage areas requiring the use of lifting mobile plant away from transmission lines.

Why Transpower should be involved in considering proposals for subdivision of land near the National Grid

18.16 As I outlined above, buildings within the National Grid Yard could compromise or even prevent access to the lines. This is the case even where buildings are more than 12m from a structure, or 12m from the centreline of a National Grid transmission line. My evidence below discusses the width of the Yard and the method in which it has been calculated to take account of conductor swing under wind conditions. By becoming involved as an affected party in subdivision consents, Transpower can not only ensure that its rights of access (secured under the Electricity Act) are protected, but also proactively help secure suitable development configuration at the design stage.

18.17 As noted in my evidence, there is limited understanding of conductor movement by landowners and the public. I consider the planning of building sites on subdivided land should take account of the transmission line conductor swing with respect to conductor movement early in the design phase so that an acceptable design solution is reached.

18.18 In my opinion, Transpower's involvement in the subdivision process is a positive and constructive means of achieving layouts and arrangements that prevent future problems. Where subdividers are aware that Transpower is an affected party, they usually approach Transpower at an early stage to identify and resolve possible issues. This is also consistent

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with the "safety by design" concept that Transpower actively encourages (and which I discuss further below).

Management of Risks within the Plan Change area

18.19 In my view, the most significant safety concern presented by the Plan Change is the intensity of the freight movement and logistics operations proposed at the inland port, which will significantly increase the risk of an accident or other undesirable conflict event with the HAM-WHU-A line.

The photos below show large scale, intensive container port operations in Auckland occurring directly under and immediately adjacent to a National Grid line (the 220kV Henderson-Otahuhu line (HEN-OTA)).

Photo 33 — Operations directly under National Grid lines in Auckland

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Photo 34 — Operations immediately adjacent to National Grid lines in Auckland

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Photo 35 — Operations immediately adjacent to national Grid lines in Auckland

18.20 In my opinion, port operations of the scale and intensity shown in the above photos, should not take place under, or even near, transmission infrastructure. These photos are taken from the port site where the forklift hit the line in 2009 causing power outages (I describe this incident in section 13 (Co-ordinating outages within the electricity industry) above). The NZECP34 specifies minimum separation distances (including that structures have to be at least 12m away from the edge of support structures and mobile plant cannot come within 4m of conductors), however these distances can be very difficult for machine operators to calculate. It can be difficult to assess distances when standing on the ground looking up at a line. Engineering tools such as range finders can give accurate measurements, but without these, a person is generally using their best judgment of distances at the time.

18.21 Usually Transpower's contractors will patrol every line and structure once a year. As I mentioned earlier, Transpower has some 12,000km of lines through the country and some 41,000 structures. If an NZECP34 violation is discovered, then the Transpower contractor will discuss this with the landowner and come back to check the problem has been rectified. If a regular patrol does not discover any minimum distance violations, a breach could occur the following week but may not be picked up until the next patrol (which could be a year later) or perhaps earlier if

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maintenance work occurs on the line in the meantime. This means that it can be very difficult to enforce the minimum distances in NZECP34. Also, as I discussed earlier, the NZECP34 does not prevent mid-span underbuild provided the minimum vertical clearances are not breached. Underbuild can block Transpower's access to the line which is especially important for mid-span maintenance work, or any emergency work.

18.22 Prior to the 2009 incident occurring at the Auckland port, I understand that Transpower had written to the operators of the port in 2006/2007, documenting "near misses" and the hazards presented by the HEN-OTA lines. Transpower discussed various measures with the port operators including a laser level alarm system and the use of trucks rather than forklifts to move containers. I understand that in late 2007, Transpower asked the port operator to install adhesive markers or notices inside and outside the lifting machines reminding drivers to not breach the minimum 4m clearance distance between the machine and the transmission line. White painted guide poles were installed at the site to measure the maximum height that containers could be stacked. These poles are clearly visible on the third photo above but obviously the container height exceeds the height of the poles. In other words, the height limit indicated by the poles has not been adhered to. I understand that at the Auckland port, crossing areas for container lifting machines were marked on the ground and also in work plans which were given to the machinery drivers. Transpower's lines maintenance contractors visited the site regularly to monitor the hazard risk.

18.23 It is possible that the line tripped on two occasions prior to the 2009 incident due to a flashover but this was never determined conclusively. Immediately after the 2009 incident, the lines maintenance contractor was on site (within 15 minutes of the incident) and witnessed the tyre damage to the forklift and the damage to the conductor (see photos in section 9(Risks to people and property) above).

18.24 It is very fortunate no one was seriously hurt in the 2009 incident at the Auckland port. Obviously that site is an existing operation so the best we can do is try to minimise the risks. Transpower continues to work with the port operator to develop a safer working area at the site. Transpower contractors frequently monitor the container port to ensure safe clearances to the conductors are maintained. Transpower lines maintenance managers have advised me that there have been instances

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where the height limits indicated by white marker poles have not been complied with. I understand that every time a circuit is out of service for maintenance, and the second circuit is carrying extra load, our contractors have to undertake more frequent patrols to ensure clearances are maintained given the additional risks of a power outage with one circuit out. This is obviously costly for Transpower (and ultimately electricity consumers), and also very time-consuming for Transpower's contractors.

18.25 There are significant safety risks with locating and moving large steel containers under and near energised conductors especially with port operations of the scale pictured above and as proposed by the Applicants. As I mentioned earlier, a flashover can occur without direct contact with a line. It is my experience that many people operating intensive activities near transmission lines, do not have a realistic appreciation of the risks of using metal structures close to, or driving mobile plant under, high voltage transmission lines. Nor do they have a good understanding of the requirements of the NZECP34.

18.26 From the Applicants' evidence, I understand the proposed Ruakura Logistics Area could handle approximately 400,000 containers per year. The map I have attached as Annexure C shows Transpower's HAM- WHU and HAM-DEV lines overlaid on the Applicants' concept plan for the Logistics Zone 2030. The railway siding is proposed to be located under the HAM-WHU line, very close to structures 6, 7 and 8. The conductor- ground clearance at the lowest point is approximately 6.5m in span 6-7 and 11m in span 7-8 on this section of the HAM-WHU line although this depends on the particular sag of the line on a particular day. Sag is influenced by heat (ambient air temperature as well as how much electricity load is running through the line).

18.27 Annexure D also shows the relationship of the lines to the proposed inland port activities, and the areas covered by the National Grid Corridor and Yard.

18.28 I understand from the Applicants' plan change documents, that they are looking to stack containers up to 25m high in this area without obtaining a separate resource consent. A container is approximately 2.6m high so at most, only a couple of containers could be placed under the line (and in some points not at all) and still comply with NZECP34. This is because,

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as I explained earlier, mobile plant cannot approach closer than 4m to a conductor (so assuming the conductor clearance is 6.5m in span 6-7 and a 4m 'envelope' is required, a container of 2.6m could not be stored at that point). It is very possible that the ground level will change through the development so this would have to be factored in too. Even if there is clearance for one container to placed under the line, it is still possible that a forklift would not actually be able to lift the container overhead without breaching the minimum distances in NZECP34.

18.29 I also noted from the Applicants' evidence that it seems a container repair building may be proposed under the HAM DEV line. This is a critical, 220kV line supplying electricity to Hamilton city and elsewhere. I would not want to see frequent container movements occurring, or any building locating under, this line.

18.30 In my view, freight handling activity of this scale is not compatible with our transmission infrastructure. The conflict should be avoided by reconfiguring the layout of the proposed inland port facilities, or alternatively by the landowner paying for the undergrounding of the relevant part of the line. Those are the only measures that will avoid or eliminate the risk.

18.31 If the Board is not minded to avoid those risks, then consent should be required for activities involving mobile plant, so that appropriate measures can be adopted through conditions. For example, control could be exercised over measures such as access or crossing points, barrier arms or archways, signage, site management processes, markings indicating where containers can and cannot be moved, and regular training for operators.

18.32 Compatible development of green-field sites such as that which is proposed in the plan change area is possible, especially if those plans take account of Transpower infrastructure. An example of this is the industrial Highbrook Development in South Auckland (shown in the photos below) where the roads and industrial buildings were planned and constructed to minimise the impacts on Transpower's infrastructure. As can be seen from the photos below, even the road has been designed around a clear Yard and comparatively clear corridor.

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Photo 36 — Highbrook Development in South Auckland

Photo 37 — Highbrook Development in South Auckland

18.33 The Applicants refer to Highbrook as a model for how a modern, planned industrial business park should look and feel and they discuss in their evidence how they organised a tour of the area for stakeholders and members of the public interested in the Ruakura proposal.25

18.34 I note that Transpower's general management approach is different between existing urban areas and proposed new urban or industrial areas. Transpower has been pursuing a more restrictive form of resource consent (non-complying status) for buildings in greenfields areas which are being changed to urban land use, compared to brownfields, or existing urban areas. This is because in developed, or "brownfields" areas, we need to work with what is already there, although this may be far from ideal. However with a greenfields site, the opportunity is there to plan and manage risks proactively, ie, to get it right from the start.

25 Evidence in Chief of Tony McLauchlan, 26 Feb 2014, para 21.

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19. ENGINEERING INPUT INTO CALCULATING THE WIDTHS OF TRANSMISSION CORRIDORS

19.1 The distance a transmission conductor swings in the wind is dependent on the ambient temperature, the power being carried, the wind speed, the type and size of conductor, the tension the conductor is strung at, the supporting structure configuration (cross arm length) and the length of the span (distance between two towers or poles).

19.2 To calculate appropriate corridor widths, a set of standard line types, based on voltage and structural configuration have been developed. Following analysis, it was determined that the swing is most sensitive to the wind speed and span length.

19.3 An ambient temperature of 10ºC, a wind pressure of 100Pa (46km/hr), full electrical load and the conductor type applicable for the line type were assumed for each transmission corridor. A range of swings was then determined for each line type.

19.4 The width of transmission corridors was then determined by the swing of the 95th percentile span and access requirements for maintenance purposes. The 100th percentile span would have resulted in a much wider corridor, even though this is not necessary for the majority of spans.

19.5 The corridors are based on the existing assets, and have not been sized to provide for major rebuilds or new lines.

19.6 Photo 38 below illustrates the effect of conductors swinging out on the Benmore-Haywards A line. This is not uncommon when strong winds are blowing at right angles to the line. The amount of transverse conductor swing is not well understood be people outside the transmission line engineering community. The calculation of this swing is a complex calculation, however is essential to manage activities within the National Grid Corridor.

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Photo 38: — Conductor swing in high wind

Electricity Transmission 12m Yard

19.7 The 12m Yard is calculated as the distance from the centreline between the support structures (tower or pole) to the point where the conductor would swing under everyday conditions.26 These are the conditions when maintenance would be carried out, as work is not generally undertaken during high wind conditions. Structures and activities within the 12m Yard are effectively directly under the conductors under low winds.

National Grid Corridor

19.8 The National Grid Corridor is calculated as the distance from the centreline between the support structure (tower or pole) to a point where the conductor would swing under possible high wind conditions.27 Accordingly, the National Grid Corridor is much wider than the Electricity Transmission 12m Yard. Structures and activities within the Corridor could be under the conductors in high winds. The relevant distances from the centreline for the Corridor are as follows:

(a) 14 metres for 110kV transmission lines on single poles

(b) 16 metres for 110kV transmission lines on pi poles

(c) 32 metres 110kV transmission lines on towers (including tubular steel towers where these replace steel lattice towers)

26 Wind speed of 100 Pascals or 46km/hour. 27 Wind speed of 1000 Pascals or 147km/hour.

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(d) 37 metres for 220kV transmission lines

20. NZECP34 - PURPOSE AND LIMITATIONS

20.1 NZECP34 prescribes minimum safe distances for the construction of buildings and structures and for excavation near transmission line support structures and overhead lines. Compliance with NZECP34 is mandatory.

20.2 Clause 2.4.1 of NZECP34 states that:

"Except with the prior written consent of the overhead electric line owner, no building or similar structure shall be erected closer to a high voltage overhead electric line support structure than the distances specified in Table 1".

20.3 Table 1 states: Minimum Safe Distances Between Buildings And Overhead Electric Line Support Structures

Circuit Voltage Pole Tower (Pylon)

11kV to 33kV 2m 6m

Exceeding 33kV to 66kV 6m 9m

Exceeding 66kV 8m 12m

20.4 Therefore, in respect of circuits exceeding 66kV, NZECP34 requires that buildings must be at least 8m from a pole and 12m from a tower.

20.5 The distances in Table 1 are measured from the closest visible edge of the overhead electric line support foundation, and the nearest part of the outermost part of the building.

20.6 NZECP34 also specifies minimum safe distances between conductors and buildings and other structures. These distances differ depending on the voltage of the line, and the length of the span between support structures. The tables within NZECP34 are firstly based on generic and conservative span length envelopes, then more detailed calculations can be undertaken to remove the conservatism. These detailed calculations require specialist engineering expertise. For long spans, NZECP34 would likely prevent the construction of buildings even outside of the 12m corridor.

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20.7 Regulation 17(3) of the Electricity (Safety) Regulations 2010 states that various people commit a criminal offence if they fail to maintain the safe distances specified in NZECP34, including a person who carries out or controls the construction, building, excavation, or other work and a person who owns or controls any line, works, fittings, building, structures, equipment, or machinery that is the subject of, or involved in, the infringing work. However, to date, the Ministry of Business, Innovation and Employment, which has been tasked with enforcing NZECP34 has not, in my experience, taken a proactive enforcement or monitoring role. Regulating activities through the District Plan is likely to result in greater compliance, as well as enabling wider considerations to be taken into account such as the risk of underbuild blocking Transpower's access to its lines. Minimum safety requirements in NZECP34 neither seek to protect the integrity of the National Grid from the effects of third parties, nor prevent development (including sensitive and intensive development) from occurring directly underneath transmission lines.

20.8 I am aware that clause 5 of NZECP34 specifies 4 metres as the minimum distance that must be kept between live overhead lines and any part of any mobile plant or load carried by that plant (without Transpower's prior written approval). In my experience, the 4 metre distance is very difficult to monitor and enforce. Mobile plant operators such as fork lift drivers, concentrating on the load they are carrying, may not look up and be aware of live conductors as low as 7 metres above the ground.

20.9 While NZECP34 is a good base document for the determination of safe clearances, experience has found that the document is not well understood by the public. The document is based on safe clearances only and does not protect the integrity of the grid as detailed below.

NZECP34 does not protect the integrity of the Grid

20.10 NZECP34 requires a building to be no less than 8 metres from a pole and 12 metres from a tower.28 However it is questionable whether this Code applies to temporary structures such as stacked containers, stored materials or structures such as railway sidings.

20.11 In other words, NZECP34 does not provide for all access, work space, step and touch hazards, and other matters I have discussed above where

28 I note that in some instances, or for some activities, a greater separation distance is required.

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activities or infrastructure cause restrictions or create unsafe situations, especially during work activities on either Transpower's assets or works by a member of the public under or near a line.

20.12 It might be suggested that the Board can rely solely on the distances prescribed in NZECP34 to protect people and the Grid, and that there is no need to include controls in the Plan Change for this purpose. I am of the view that while NZEC34 may adequately provide for safe distances for smaller buildings and structures, the construction and location of new intensive development and buildings for sensitive activities may not always be sited in such a position that complements the operational or maintenance activities of the existing transmission line. Requiring consent for these intensive and sensitive activities gives Transpower the opportunity to provide advice on their construction, location and use.

21. TRANSPOWER'S COMMITMENT TO WORKING WITH LANDOWNERS AND STAKEHOLDERS

21.1 Transpower has a programme in place to foster its relationships with landowners, including a team of Landowner Relationship Advisors and Landowner Liaison Officers who are available to discuss issues with landowners. Transpower also regularly meets with representatives from organisations such as Federated Farmers to consider any issues raised by their members. For example, Transpower and Horticulture New Zealand have worked together to agree on the types of district plan restrictions on horticultural practices which are necessary to give effect to the NPSET. This agreement was recorded in a Memorandum of Understanding signed by Horticulture New Zealand and Transpower in May 2013.

21.2 Transpower does not typically own the land (or an interest in the land, such as an easement) on which transmission lines are located, and instead relies on provisions of the Electricity Act 1992 to access and inspect lines. Under that Act, Transpower has little direct control over activities underneath or next to lines that may otherwise affect access, safety or operational activities. Transpower relies on the safe practices of landowners, good judgement of councils, and the Resource Management Act 1991 process, to ensure that development is compatible with ongoing use of transmission assets.

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21.3 Open discussions with landowners, together with the ability to submit on plan changes and resource consent applications for proposals which have the potential to compromise the operation, maintenance, upgrading and development of the National Grid, are the best way to ensure development takes the National Grid into account. Line inspections often only uncover issues at a time when the actions needed to mitigate the effects on the National Grid are more expensive and disruptive.

21.4 Transpower seeks District Plan provisions which will result in proactive dialogue between landowners, the Council, and Transpower to reduce the future occurrence of incompatible development under or near transmission lines.

21.5 The Applicants' evidence (Mr Phillip Stickney) states that extensive engagement has been undertaken with Transpower over the options for the relocation of the line that traverses the residential area (HAM-MER A) to the north as well as the lines that cross the Logisitics Area.29 While I agree that some discussions have occurred,30 works completed to date consist of a high level response along with indicative costs of a number of options. High level estimates indicate relocation or undergrounding costs could range between $7 - $16 million for the section of the HAM-WHU line within the Plan Change area. The next step from here would be to commission a conceptual design report, followed by a detailed study to ensure that an undergrounding option (for instance) would not degrade system reliability. These subsequent investigative phases are both expensive and time consuming. Accordingly, we would only progress to this stage if the developer or landowner has agreed in writing to meet these costs. Transpower are meeting with the Applicant as early as tomorrow to progress some of the works. The problem is that the Plan Change timing does not meet the timing of finding a solution and getting commitment for it.

21.6 Mr Stickney also refers to engagement with Transpower on "advancing the site layout and the accommodation of freight handling activities near to, and under the 100kV and 220kV corridor that traverses the Logistics

29 Evidence in chief of Philip Stickney, 20 February 2014, para 30. I anticipate further discussions occurring in coming weeks on both relocating/undergrounding the line and to address conflicts 30 In the last year, there have been no discussions about the form of the Plan Change (for example the proposed layout or how freight will be moved under the line) other than two meetings which Transpower initiated. One of these meetings occurred post-notification and the other was a recent teleconference, after the Applicants' evidence was filed.

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Area".31 While I am aware of high level discussions on relocating or undergrounding the lines, I am not aware of any discussions about "advancing the site layout" or any discussions about how freight activities can be accommodated under the lines.

21.7 Transpower has attempted to discuss with the Applicants measures that will reduce the risks to, and from, the transmission assets within the Plan Change area. It is important that the proposed freight handling and related inland port activity can occur in a manner that is compatible with the safe and efficient operation of the National Grid infrastructure within the Area. Intensive and continual, permanent use of mobile plant and equipment presents serious safety risks as well as risks to security of supply.

21.8 As a general comment, I consider that the Applicants could have done more to assess the implications of, and plan around, the existing National Grid infrastructure in designing the proposed inland port. For example, Mr Tony Boyle provides evidence as an independent expert on container terminal, port operations and freight and logistics, yet he has not addressed how the proposed port activities could impact on the national grid lines running through the proposed inland port. In particular he explains that trains will initially be loaded and unloaded using "reach stackers", and later, as volume increases, the handling system will change from reach stacker to overhead gantry and the storage yard will be reconfigured to a high density gantry operation. To my mind, both of these proposed activities immediately raise concerns about coming into conflict with the lines.

21.9 Following this he states that: "these systems interface with all parties involved in the venture including security, border control agencies, freight forwarders, cargo owners, road and rail operators, marine terminals, shipping companies …. This visibility ensures total compliance with all relevant protocols".32 However, there is no mention of the "interface" with the National Grid lines, or how the NZECP34 will be complied with. In my view this is a significant and concerning omission.

21.10 In addition, I also consider that the consideration of effects on the National Grid in the Applicants' Assessment of Environmental Effects

31 Evidence in chief of Phillip Stickney, para 30. 32 Evidence in chief of Tony Boyle, para 21.

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("AEE") has been flawed. At section 7.9, page 105, the AEE states that "the 110kV Ham-Whu A line which traverses the Logistics Area will need to be relocated or placed underground in the future", and that it is likely to become a "significant constraint" by 2020. While this may be the Applicants' view, from my perspective it is the reverse: it is the proposed port operations which are likely to become a significant constraint on the operation, maintenance, upgrading and development of the pre-existing and lawfully established National Grid lines. The Applicants are seeking to change the existing land use, and need to design around the lines (as required by the NPSET).

21.11 This section of the AEE goes on to say that Transpower has advised that activities need to comply with the NZECP34 and applicable Transpower standards. However, new activities establishing under existing lines need to do more than simply comply with NZECP34. Consistent with the NPSET they also need to be designed so that they do not compromise the operation or maintenance of the Grid (eg by blocking access and creating safety risks), they need to ensure Transpower can carry out maintenance and upgrade work as required, and they need to ensure that sensitive activities are avoided and reverse sensitivity effects managed.

21.12 Finally, it is completely incorrect for the Applicants to suggest (as they do in the AEE) that concerns about maintaining the security of supply are "not a significant issue arising from the Plan change". Until there is firm written agreement to relocate or underground the HAM-WHU line, those concerns are very real to Transpower.

21.13 The most appropriate solution is to avoid the conflict and risk, by redesigning the proposal so as to have the risky container and mobile plant activities located elsewhere. However, if the container storage and mobile plant activity of the expected intensity is to occur, stringent mitigation measures have to be put in place, otherwise in my opinion, it will be a matter of when, rather than if, that an incident occurs. Mobile plant operators concentrating on the equipment they are manoeuvring do not always look up and see what obstructions are above them. At the very least, barriers or archways under the lines (preventing equipment from lifting above certain heights) and markings on the ground will go a long way to reducing some of the risks and should not, in my opinion, curtail the inland port's activities. However, it is Transpower's strong

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preference that these activities be located elsewhere, unless arrangements are made for the relevant line to be underground.

Working with developers

21.14 There are many examples of where Transpower has worked with developers to ensure development occurs appropriately around transmission infrastructure. Measures I am aware of include setbacks from substations, buffer areas such as wetlands and stormwater ponds, no-complaints covenants negotiated at the subdivision planning stage. Transpower has worked with developers to determine appropriate sound and visual barriers (such as hedging and bund fences) so that landowners are not exposed to unreasonable noise, visual and other effects from substations. Through working with developers Transpower can, in turn, continue to supply a reliable and cost-effective supply of electricity to the community while minimising our effects on our neighbours.

22. CONCLUSIONS

22.1 The National Grid is enduring critical infrastructure, both locally and nationally. Preventing sensitive and incompatible activities from establishing under the transmission lines, along with controls on activities that will occur near lines will assist the National Grid to be reliable, and to have a managed environmental footprint while serving future generations.

22.2 The line that the port presents the most risk to is the HAM-WHU line. In my opinion, activities can be managed around the other lines to avoid or adequately minimise risk but freight handling movement and other port activity of the intensity proposed by the Applicants, should not occur under or near the HAM-WHU line.

22.3 I do not consider that adequate measures can be put in place to appropriately manage the risks to and from this line. Discussions to date with the Applicants have not resulted in a decision to move this line. My reading of the Plan Change documents is that the application has proceeded on the assumption the HAM-WHU line will not be there by the time development commences. However, in the absence of an agreement of this kind, the presence of the line needs to be considered.

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22.4 Transpower has initiated some discussions with the Applicants on the relocation or undergrounding of the lines, including the HAM-WHU lines, however these have been very high level discussions to date, based only on desktop studies. Further engineering assessments are required in order to confirm the undergrounding or relocation of the lines. Until the Applicants commit to this further work being carried out, Transpower must approach the Plan Change request on the assumption that the lines, in particular the HAM-WHU line, are to be a part of the future inland port environment.

22.5 Accordingly, I support district plan restrictions on buildings and activities under the transmission lines in order to manage the issues and risks I have identified, and I support the inclusion of these in relation to the Plan Change. These restrictions will ensure the lines can be accessed, maintained, upgraded and developed in the future.

22.6 The NPSET obliges local authorities to provide for the long-term strategic planning of the National Grid. It is critical that a preventative approach is taken to the management of the transmission corridors and a proactive approach is taken to ensure safety for high risk activities regularly occurring under lines. In my view this ideally would mean locating the mobile plant activities away from the National Grid Yard.

22.7 At the very least, it is imperative that such activities, if the Board determines that they should occur beneath the lines despite Transpower's concerns, are subject to appropriate controls that safeguard the National Grid infrastructure and also the personnel on site who face serious safety risks if these activities are not properly managed.

Roy Noble 26 March 2014

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ANNEXURE A - LAND USE ALLOCATION PLAN: OVERLAID WITH TRANSMISSION LINES

2696844 v9 OTA-WKM-A OTA-WKM-C

OTA-WKM-B

HAM-MER-B

HAM-MER-A

HAM-WHU-A

HAM-DEV-A

Hamilton

ARI-HAM-A

ARI-HAM-B HAM-KPO-A

Legend Substation 220kV Overhead 110kV Overhead 110kV Underground This document is produced for external release. Its conclusions are based National Grid Yard (22ha) on the information currently available to Transpower and may change as further information becomes available either internally or externally. Plan Change Area Land Use Allocation map as per Boffa Miskell: http://www.epa.govt.nz/Publications/RDPC_Application_Drawings_Part_1A.pdf Figure 4. R1 boundary All areas and boundaries subject to final survey.

COPYRIGHT © 2014 TRANSPOWER NEW ZEALAND LIMITED. ALL RIGHTS RESERVED Transpower Transmission Network This document is protected by copyright vested in Transpower New Zealand Limited ("Transpower"). No part of the document may be reproduced or transmitted in any form by any means including, without limitation, Land Use Allocation Plan electronic, photocopying, recording or otherwise, without the prior written permission of Transpower. No information embodied in the documents which is not already in the public domain shall be communicated in any manner whatsoever to any third party without the prior written consent of Transpower. Any breach of the above obligations may be restrained by legal proceedings seeking remedies including injunctions, damages and costs. Projection: NZTM 2000 Scale: 1:20,660 Plan Size: A3P 200100 0 200 400 600 800 Meters 25 March 2014 90

ANNEXURE B - MAINTENANCE TASKS AND EQUIPMENT

Maintenance Frequency Approximate Number of Number and Task time on land people type of vehicles

Emergency As identified and Averages about 4 4WDS, a works, including needs priority. 30 min for fault transport fault response Generally inspection truck, EWP, and resulting Transpower fault purposes and Helicopter. repair works, response about 4 hour structure frequency on its average per fault stabilisation network works repair. following floods. out at about 0.2 visits per asset per year.

Patrol / Patrol -Normally Less than 1 hour 2 One ute or all Condition once per year. per structure terrain Assessment vehicle Condition Assessment normally 5 – 6 yearly.

Vegetation As required As required Varies Cherry- Maintenance following work picker, identification from chipper, light the annual truck, service patrols. truck Vegetation growths vary depending on tree species, weather and location. As an average Transpower would attend to most vegetation on a 2 to 3 year cycle.

Access and track As required 1 - 2 days on 1 - 4 Grader or maintenance following work average differ and identification from small truck the annual patrols.

Painting towers Approximately a About 23 weeks 4 - 10 Water 10-20 year cycle, per tower blaster, water although (weather tanker, air becoming much dependent) compressor, more frequent in other built up areas vehicles.

Foundation Once every 20 - About 3 / 4 days 4 4WDS, a refurbishment/ 30 years per tower transport strengthening truck , a differ, a concrete truck

2696844 v9 91

Maintenance Frequency Approximate Number of Number and Task time on land people type of vehicles

Insulator Approximately a About 1 day per 4 - 10 Lifting assemblies, 40 year cycle or tower (weather equipment, hardware, etc. as identified by dependent) elevated repairs and damage (rifle work platform replacements. shot, lightning) (EWP), hoists.

Tower Depends on About 3 days per 4 4WDS, and refurbishment environment and tower transport (For example, corrosion rates. truck. tightening bolts, Normally 30 year replace steel cycle. members)

Pole Approximately a About 1 - 2 days 4 - 6 4WDS, a replacements 40 year cycle per pole. transport truck, a differ, compactor.

Conductor Approximately a About 2 days per 4 4WDS, a repairs 40 year cycle span transport (Including joint truck, EWP, testing, repair Helicopter. and replacements)

2696844 v9 92

ANNEXURE C: INTERMODAL TERMINAL/LOGISTICS DRAFT 2030 MASTER PLAN - OVERLAID WITH TRANSMISSION LINES

2696844 v9 0009 0508

0008

0007 0507

HAM-WHU-A 0006

0005

0004

0506

HAM-DEV-A

0141 0082 0140 0139 0505

0081

0315 0504 0080 ARI-HAM-B 0314A

0314 0138 0313

0312 0079 0311 HAM-KPO-A 0310

0137 0309

0308A Legend 0078 0308 0136 Pole

Tower 0307 This document is produced for external release. Its conclusions are based 220kV Overhead ARI-HAM-A on the information currently available to Transpower and may change as further information becomes available either internally or externally. 0077 110kV Overhead Intermodal Terminal/Logistics map as per Boffa Miskel: http://www.epa.govt.nz/Publications/RDPC_Application_Drawings_Part_1C.pdf Figure 11. Parcel boundary 0306 All areas and boundaries subject to final survey.

COPYRIGHT © 2014 TRANSPOWER NEW ZEALAND LIMITED. ALL RIGHTS RESERVED Transpower Transmission Network This document is protected by copyright vested in Transpower New Zealand Limited ("Transpower"). No part of the document may be reproduced or transmitted in any form by any means including, without limitation, Intermodal Terminal / Logistics Draft 2030 Master Plan electronic, photocopying, recording or otherwise, without the prior written permission of Transpower. No information embodied in the documents which is not already in the public domain shall be communicated in any manner whatsoever to any third party without the prior written consent of Transpower. Any breach of the above obligations may be restrained by legal proceedings seeking remedies including injunctions, damages and costs. 100 50 0 100 200 300 400 Meters Projection: NZTM 2000 Scale: 1:6,596 Plan Size: A3L 25 March 2014 93

ANNEXURE D: SPECIAL CONTROLS RUAKURA LOGISTIC AREA - OVERLAID WITH TRANSMISSION LINES

2696844 v9 0004

0005 0010

0006 HAM-WHU-A National Grid Yard = 3.4ha 0009 HAM-WHU-A 0007

0140

0008 0508

0081 0139

0507

0314A 0504

0080 0506 0314 HAM-DEV-A

0505 0313 0138

ARI-HAM-B

0079 0312

0311

HAM-KPO-A 0310 ARI-HAM-A

0137

0309

0078

0308A

Legend 0308 Pole

Tower 0136 220kV Overhead

110kV Overhead 0077 0307 National Grid Yard National Grid Corridor This document is produced for external release. Its conclusions are based Plan Change Area on the information currently available to Transpower and may change as further information becomes available either internally or externally. R1 boundary Special Controls Ruakura Logistics Area map as per Boffa Miskel: http://www.epa.govt.nz/Publications/HCC_Prepared_Plan_Change_website.pdf Page 22. Parcel boundary All areas and boundaries subject to final survey. 0306

COPYRIGHT © 2014 TRANSPOWER NEW ZEALAND LIMITED. ALL RIGHTS RESERVED Transpower Transmission Network This document is protected by copyright vested in Transpower New Zealand Limited ("Transpower"). No part of the document may be reproduced or transmitted in any form by any means including, without limitation, Special Controls Ruakura Logistic Area electronic, photocopying, recording or otherwise, without the prior written permission of Transpower. No information embodied in the documents which is not already in the public domain shall be communicated in any manner whatsoever to any third party without the prior written consent of Transpower. Any breach of the above obligations may be restrained by legal proceedings seeking remedies including injunctions, damages and costs. 100 50 0 100 200 300 400 Meters Projection: NZTM 2000 Scale: 1:5,500 Plan Size: A3L 25 March 2014