Submission by Transpower New Zealand Ltd on the Proposed New Plymouth District Plan
21 November 2019
Filepath SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 FORM 5 SUBMISSION BY TRANSPOWER NEW ZEALAND LIMITED ON THE PROPOSED NEW PLYMOUTH DISTIRCT PLAN 2019 UNDER CLAUSE 6 OF THE FIRST SCHEDULE TO THE RESOURCE MANAGEMENT ACT 1991
To: Proposed New Plymouth District Plan 2019
New Plymouth District Council By email: [email protected]
Name of Submitter:
Transpower New Zealand Ltd
Address for Service and Correspondence
Wratt Resource Management Planning Ltd Attn: Carolyn Wratt 62 State Highway 2 RD1 Pokeno 2471 Email: [email protected] Ph: 0275 745 245
This is a submission to the Proposed New Plymouth District Plan
Transpower could not gain advantage in trade competition through this submission
The specific provisions of the proposed plan that the submission relates to are:
Refer attached submission which outlines the specific provisions, sought amendments, reasons and decisions sought.
Transpower NZ Ltd wishes to be heard in support of its submission.
Signature of submitter [or person authorised to sign on behalf of the submitter.]
Date: 22 November 2019
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 SUBMISSION BY TRANSPOWER NEW ZEALAND LIMITED ON THE PROPOSED NEW PLYMOUTH DISTRICT PLAN
Overview The following provides specific submission points from Transpower New Zealand Limited (“Transpower”) on the Proposed New Plymouth District Plan (“PNPDP”). The submission has been prepared to assist the Council in ensuring the planning framework under the PNPDP appropriately recognises and provides for the National Grid. Specifically, from Transpower’s perspective, the provisions of the PNPDP need to ensure that it: Gives effect to the National Policy Statement on Electricity Transmission 2008 (“NPSET” or “NPS”); Recognises the need to sustainably manage the National Grid as a physical resource of national significance; Recognises the benefits of the National Grid at local, regional and national levels; and Provides for the effective operation, maintenance, upgrading and development of the National Grid. In general, the approach adopted in the PNPDP is broadly supported by Transpower; specifically, the provision of a framework of objectives, policies and rules that recognises and appropriately provides for the National Grid. In particular, the inclusion of provisions specific to the National Grid are supported, and the provision of a buffer corridor management approach. However, Transpower considers that a number of amendments are still required to better reflect the direction and scope of the NPSET in the PNPDP.
Introduction to Transpower Transpower is the State-Owned Enterprise that plans, builds, maintains and operates New Zealand’s National Grid, the high voltage transmission network for the country. The National Grid links generators directly to distribution companies and major industrial users, feeding electricity to the local networks that distribute electricity to homes and businesses. The National Grid comprises towers, poles, lines, cables substations, a telecommunications network and other ancillary equipment stretching and connecting the length and breadth of the country from Kaikohe in the North Island down to Tiwai in the South Island, with two national control centres (in Hamilton and Wellington). The National Grid includes approximately 12,000 km of transmission lines and substations, supported by a telecommunications network of some 300 telecommunication sites, which help link together the components that make up the National Grid. Transpower’s role and function is determined by the State-Owned Enterprises Act 1986, the company’s Statement of Corporate Intent, and the regulatory framework within which it operates. Transpower does not generate electricity, nor does it have any retail functions. Transpower’s Statement of Corporate Intent for July 2019 to July 2022, states that: Transpower is central to the New Zealand electricity industry, connecting New Zealanders to their power system through safe, smart solutions for today and tomorrow. Our principal commercial activities are:
- As grid owner, to reliably and efficiently transport electricity from generators to distributors and large users, and
- As system operator, to operate a competitive electricity market and deliver a secure power system
In line with this role, Transpower needs to efficiently maintain and develop the network to meet increasing demand, to connect new generation, and to seek security of supply, thereby contributing to New Zealand’s economic and social aspirations. It has to be emphasised that the National Grid is an ever-developing system, responding to changing supply and demand patterns, growth, reliability and security needs. A key part of this is connecting new renewable energy generation to the National Grid – Transpower expects demand for electricity to increase over time as New Zealand transitions to a zero-carbon economy, and Transpower is uniquely placed to help enable that transition. Transpower therefore has a significant interest in contributing to the process of developing an effective, workable and efficient district plan where it may affect the National Grid, including possible future changes. The National Grid has operational requirements and engineering constraints that dictate and constrain where it is located and the way it is operated, maintained, upgraded and developed. Operational requirements are set out in legislation, rules and regulations that govern the National Grid, including the Electricity Act 1992, the Electricity Industry Participation Code, the New Zealand Electricity Code of Practice for Electricity Safe Distances (NZECP 34:2001), and the Electricity (Hazards from Trees) Regulations 2003. It is important to note that Transpower’s role is distinct from electricity generation, distribution or retail. Transpower provides the required infrastructure to transport electricity from the point of generation to local lines distribution companies, which supply electricity to everyday users. These users may be a considerable distance from the point of generation. Transpower therefore has a significant interest in contributing to the process of developing an effective, workable and efficient District Plan where it may affect the National Grid in the New Plymouth District, including possible future changes.
New Plymouth District Transmission Assets Transpower has a number of overhead transmission lines, substations and telecommunications assets within the New Plymouth District, comprising the following: New Plymouth Substation; Carrington Street Substation; Huirangi Substation; Motunui Substation; Junction Road Switching Station; Junction Road National Grid Line; Carrington Street – Stratford A 110 kV high voltage transmission line on towers; New Plymouth – Stratford A 220 kV high voltage transmission line on towers; Carrington Street – New Plymouth A 110 kV high voltage transmission line on towers; Carrington Street – Huirangi A 110 kV high voltage transmission line on towers; Motunui Deviation A 110 kV high voltage transmission line on towers; Huirangi – Motunui A 110 kV high voltage transmission line on towers; McKee - Tee A 110 kV high voltage transmission line on pi-poles.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 The substations and switching stations are subject to designations that Transpower has requested be “rolled-over” as part of the Plan review process (clause 4 of the First Schedule of the Resource Management Act 1991 (RMA)). At the time of lodgement of this submission, as part of The North Taranaki Regional Supply Project, Transpower is involved in the process of removing its substation at Port Taranaki. The substation is to be decommissioned at some stage in the future with a process currently being undertaken on where to permanently locate the lines that currently lead to the port.
Attached as Appendix 1 is a map of Transpower’s assets in the New Plymouth District.
Statutory Framework The National Grid is nationally (and regionally) significant infrastructure that is recognised in the RMA context by the National Policy Statement on Electricity Transmission 2008 (NPSET) and the Resource Management (National Environmental Standards for Electricity Transmission Activities) Regulations 2009 (NESETA).
National Policy Statement on Electricity Transmission The National Policy Statement on Electricity Transmission was gazetted on 13 March 2008. The NPSET confirms the national significance of the National Grid and establishes national policy direction to ensure decision-makers under the RMA duly recognise the benefits of transmission, manage the effects of the National Grid and appropriately manage the adverse effects of activities and development close to the Grid. The NPSET only applies to the National Grid – the assets used or operated by Transpower – and not to electricity generation or distribution networks. A copy of the NPSET is attached as Appendix 2. A key reason for introducing the NPSET in 2008 was to resolve the inconsistencies that resulted from the variable provision for the National Grid in RMA plans and policy statements. This variance was despite the fact that the National Grid is largely the same across the country. In promoting the NPSET, central government accepted the importance and benefits of a nationally consistent approach to decisions on transmission activities. The preamble of the NPSET highlights that the National Grid has particular physical characteristics and operational/security requirements that create challenges for its management under the RMA, and it is important there are consistent policy and regulatory approaches by local authorities. The NPSET sets a clear directive to councils on how to provide for National Grid resources (including future activities) when drafting all their plans. Thus, district councils have to work through how to make appropriate provision for nationally and regionally significant infrastructure in their district plans. The single one objective of the NPSET is as follows: To recognise the national significance of the electricity transmission network by facilitating the operation, maintenance and upgrade of the existing transmission network and the establishment of new transmission resources to meet the needs of present and future generations, while:
a. Managing the adverse environmental effects of the network; and
b. Managing the adverse effects of other activities on the network.
The NPSET’s 14 policies provide for the recognition of the benefits of the National Grid, as well as the environment effects of transmission and the management of adverse effects on the National Grid. The policies have to be applied by both Transpower and decision-makers under the RMA, as relevant. The development of the National Grid is explicitly recognised in the NPSET. Policy 1 of the NPSET provides that decision-makers must recognise and provide for the national, regional and local benefits of sustainable, secure and efficient electricity transmission. Explicit reference is made to the benefits of security of supply, efficient transfer of energy, development and use of new electricity generation, and enhanced supply. Polices 2 to 9 provide RMA decision-makers direction for managing the environmental effects of transmission activities. Recognition of the development of the National Grid is also required in Policy 2 of the NPSET, in that “decision makers must recognise and provide for … the development of the electricity transmission network”. Policy 2 is as follows: In achieving the purpose of the Act, decision-makers must recognise and provide for the effective operation, maintenance, upgrading and development of the electricity transmission network.
Policies 3 to 5 contain matters to which decision-makers must consider or have regard, including: the constraints imposed on avoiding, remedying or mitigating adverse effects by the technical and operational requirements of the network the role of the route, site and method selection process in avoiding, remedying or mitigating adverse effects for new or major upgrades of transmission infrastructure, and the enablement of the reasonable operational, maintenance and minor upgrade requirements of established electricity transmission assets. Policies 6 to 8 relate to Transpower’s responsibilities under the NPSET, with Policy 6 promoting the reduction of existing adverse effects where substantial upgrades of transmission line infrastructure are undertaken. Policies 7 and 8 relate to circumstances in which the effects of transmission infrastructure could be reduced, minimised or avoided in urban and rural environments. Policy 9 specifically relates to standards for dealing with electric and magnetic fields. Policy 8 of the NPSET directs that within rural environments, planning and development of the National Grid should seek to avoid adverse effects on certain identified environments (being outstanding natural landscapes, area of high natural character and recreation values and amenity and existing sensitive activities) areas. The wording of NPSET policy 8 (“should seek to avoid”) does not impose an absolute requirement for the National Grid to avoid all adverse effects. Rather, the NPSET recognises total avoidance is not always possible given the technical and operational requirements of the National Grid (as recognised in Policy 3 of the NPSET). Policy 8 is as follows: In rural environments, planning and development of the transmission system should seek to avoid adverse effects on outstanding natural landscapes, areas of high natural character and areas of high recreation value and amenity and existing sensitive activities.
Policies 10 and 11 of the NPSET provide the primary direction on the management of adverse effects of subdivision, land use and development activities on the transmission network. These policies are critical matters for a District Plan to address. Policy 10 is as follows: In achieving the purpose of the Act, decision-makers must to the extent reasonably possible manage activities to avoid reverse sensitivity effects on the electricity transmission network and to ensure that operation, maintenance, upgrading, and development of the electricity transmission network is not compromised.
Policy 11 relates to the development of buffer corridors, and is as follows: Local authorities must consult with the operator of the national grid, to identify an appropriate buffer corridor within which it can be expected that sensitive activities will generally not be provided for in plans and/or given resource consent. To assist local authorities to identify these
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 corridors, they may request the operator of the national grid to provide local authorities with its medium to long-term plans for the alteration or upgrading of each affected section of the national grid (so as to facilitate the long-term strategic planning of the grid).
Policy 12 requires the identification of the transmission network on territorial authority planning maps. Policies 13 and 14 relate to the long-term strategic planning for transmission assets. Under Policy 14, regional councils must include objectives, policies and methods to facilitate long-term planning for investment in transmission infrastructure and its integration with land uses. Sections 55 and 75(3)(a) of the RMA requires that district plans must ‘give effect’ to a National Policy Statement. Case law has established that the words "give effect to" means to implement, which is a strong directive, creating a firm obligation on the part of those subject to it1. It is therefore a requirement that local policy reflects national direction and that the local policy is effective in helping support the integrated management of natural and physical resources within the district, as well as across the region as a whole.
Resource Management (National Environmental Standard for Electricity Transmission Activities) Regulations 2009 The Resource Management (National Environmental Standard for Electricity Transmission Activities) Regulations 2009 (“NESETA”) came into effect on 14 January 2010, providing a national framework of permissions and consent requirements for the operation, maintenance and upgrading of National Grid lines existing at 14 January 2010: it does not apply to substations or electricity distribution lines, and nor does it apply to the construction of new transmission lines (which are typically designated). Activities covered by the NESETA are activities relating to the operation, maintenance, upgrading, relocation or removal of an existing transmission line, including:
a construction activity use of land or occupation of the coastal marine area
activities relating to an access track to an existing transmission line undergrounding an existing transmission line. Under Section 44A of the RMA, local authorities are required to ensure there are no duplications or conflicts between the provisions of the NESETA and a proposed plan. That said, there are situations where the NESETA Regulations defer to a district plan. It is therefore importance that the relevant district plan provisions (particularly in respect of ‘natural areas’) are consistent with the intent and effect of the NESETA Regulations.
Regional Policy Statement for Taranaki 2010 In terms of a regional context, the operative Regional Policy Statement for Taranaki (1 January 2010) ("Operative RPS") is of relevance. Section 75(3)(c) of the RMA, requires that a District Plan must ‘give effect’ to any RPS. Transpower considers the following provisions of the RPS to be particularly relevant to the issues raised in this submission: - ENE Objective 1 which promotes the exploration, development, production, transmission and distribution of energy to meet the energy supply needs of the region and New Zealand in a manner that avoids, remedies or mitigates adverse effects on the environment. - ENE Objective 3 which seeks to increase efficiency in the exploration, development, use, production, transmission and distribution of energy. - ENE Policy 1 which requires provision to be made for the exploration, development, production, transmission and distribution of energy in Taranaki to enable people and communities access to an adequate supply of energy and thereby to provide for their economic and social wellbeing and for their health and safety. Policy 1 seeks to ensure that Taranaki has an adequate supply of energy to meet the needs of people and communities in Taranaki and New Zealand. These energy needs may be met from either non-renewable or renewable sources. - ENE Policy 2 requires efficiency in the use, production and transmission of energy to be encouraged as far as practicable having particular regard to a number of identified matters. The matters most relevant to Transpower are (f) research into, and development of, alternative energy sources and more energy efficient methods (both traditional and alternative) in the production and transmission of energy; and (g) the respective roles, functions, and responsibilities of particular agencies. Policy 2 seeks to encourage energy efficiency, thereby reducing the possibility of energy demands exceeding the economically or physically available supply of energy. Efficient use of energy is defined as consuming the minimum amount of energy for the maximum desired output. - ENE Policy 4 is specific to electricity transmission and requires that provisions be included that appropriately recognise the importance of corridors to facilitate the ongoing operation, maintenance, upgrading and development of energy transmission and the need to protect such corridors from activities that impede their efficient operation. Policy 4 recognises that the National Grid is a dynamic and linear inter- regional network. With structures of such a significant scale there is a reduced ability to avoid, remedy or mitigate adverse effects. Corridors are important for the efficient transmission of energy. The operation, maintenance and future development of the transmission network can be significantly constrained by the adverse environmental impact of encroaching activities and development (reverse sensitivity). Recognition of the existing transmission line corridors within the Taranaki region would ensure that non-compatible land uses are kept away from the lines and any potential adverse effects on the lines are avoided, remedied or mitigated thereby ensuring that the corridors can continue to meet the ongoing energy needs of the community. Additionally, it will ensure that adverse effects of the transmission lines are avoided, remedied or mitigated and that the security of electricity within the district and beyond is maintained. Policy 4 highlights the need to recognise this issue in resource management and is also directly promoted by Policies 2 and 5 of the National Policy Statement on Electricity Transmission (NPSET) 2008. - SUD Policy 1 which seeks to promote sustainable development in urban areas by providing for regionally significant infrastructure and integrating the maintenance, upgrading or provision of infrastructure with land use. - INF Objective 1 which provides for the continued safe and efficient operation of the regional’s network utilities and other infrastructure of regional significance (including where this is of national importance), while avoiding, remedying or mitigating adverse effects on the environment. - INF Policy 1 which requires provision to be made for the efficient and effective establishment, operation, maintenance and upgrading of network utilities and other physical infrastructure of regional significance (including where this is of national importance) and provision for any adverse effects of their establishment to be avoided, remedied or mitigated as far as is practicable. The explanation to Policy 1 uses the National Grid as an example. The explanation considers that the limear nature of the National Grid determines its form, shape and location across a number of different environments throughout New Zealand. When new transmission lines are proposed, technical, operational and security requirements associated with the transmission network can limit the extent to which it is feasible to avoid or mitigate all adverse environmental effects. Consequently in some cases it may be more appropriate for new transmission lines to traverse parts of a sensitive environment to achieve a route with lower overall adverse effects. These situations will need to be determined on a case-by-case basis.
1 Environmental Defence Society Inc v the New Zealand King Salmon Co Ltd [2014] NZSC 38, [2014] 1 NZLR593 (King Salmon) Most recently, reaffirmed in Royal Forest and Bird Protection Society of NZ Inc V Bay of Plenty Regional Council [2017] NZHC 3080 [12 December 2017]
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 - INF Policy 2 which requires the adverse effects of subdivision, use and development on the safety, efficiency, operation, maintenance and upgrading of the region’s network utilities and on other physical infrastructure of regional significance (including where this is of national importance) to be avoided or mitigated. Policy 2 ensures that any adverse effects of subdivision, use and development, which would reduce the safe and efficient operation of network utilities and other regionally significant infrastructure, are avoided or mitigated. - INF Policy 3 which requires buffer corridors to be identified so that development incompatible with the National Grid is not located within such corridors. This policy thereby ensures reverse sensitivity effects are avoided. The explanation to this Policy recognises the operation, maintenance and future development of the transmission network can be significantly constrained by the adverse environmental impact of encroaching activities and development (reverse sensitivity). Identifying appropriate buffer corridors under Policy 3 would ensure that non-compatible land uses are kept away from the lines and that any potential adverse effects of third party activities on the transmission network are appropriately managed to ensure the ongoing operation, maintenance, upgrading and development of the electricity transmission network is not compromised. Activities that may have reverse sensitivity effects on the safe and efficient operation of regionally significant infrastructure should locate in areas where that infrastructure will not be affected. - INF Policy 4 requires new land use generated by growth and development and the associated local, regional and national infrastructure to service that growth to be integrated and planned alongside one another. This is to avoid either constraints being imposed on necessary growth and development by the lack of supporting infrastructure or to avoid unsustainable demands being placed on infrastructure to meet new growth. This policy is to ensure that necessary growth and development is properly and appropriately serviced and also to ensure that unsustainable demands are not placed on Infrastructure. In terms of methods of implementation, the following are relevant to achieving these objectives and policies by territorial authorities: - ENE METH 10 Include provisions in district plans district plans district plans that make appropriate provision for the exploration, development, production, transmission and distribution of energy - INF METH 9 Include in district plans district plans district plans, and conditions in resource consents, provisions or conditions resource consents that provide for the establishment and continued operation of regionally significant infrastructure (including where this is of national importance), and the control of adverse effects of subdivision, use and development of land on that infrastructure. - INF METH 10 Include in district plans appropriate provisions (including designations) for network utilities and other infrastructure of regional significance (including where this is of national importance), and the procedures to be followed when proposing to undertake activities in proximity to these network utilities and infrastructure. - INF METH 11 Recognise the maintenance of existing maintenance of existing infrastructure, including the trimming and infrastructure, removal of plants where these pose a risk to the continuation of infrastructure operations in riparian margins, as an essential component for the supply of electricity to communities. - INF METH 16 Encourage the use of corridors for public network utilities where feasible and practical and where the use of corridors does not conflict with specific coverage objectives of a utility provider so as to contain the geographic effects on amenity values of such utilities to a defined and limited area. The use of corridors should also recognise that conflicts can occur between various utilities. - INF METH 17 Take into account current infrastructure current infrastructure corridors in resource management decision making; avoid, remedy or mitigate any incompatible use or activity affecting those corridors and include appropriate protection and recognition of existing infrastructure corridors in district plans and on planning maps. - INF METH 18 When considering an application for resource consent, notice of requirement or a change or variation to a district or regional plan that is likely to affect a transmission corridor, local authorities shall consult with or notify the operator of the consult with or notify the operator of the National Grid. - INF METH 19 Give effect to the New Zealand Code of New Zealand Code of Practice for Electrical Safe Distances (NZECP34:2001) prepared under the (NZECP34:2001) Electricity Act 1992, when establishing rules and considering applications for building structures and other activities near overhead electric lines support structures or conductors. The RPS provisions are outlined in full in Appendix 3. It is considered important that the PNPDP provides for National Grid activities in order to give effect to the operative RPS.
Other Regulations Regulation 10 of the Resource Management (Forms, Fees, and Procedure) Regulations 2003, section 2(i) further acknowledges the importance of Transpower's National Grid assets, requiring Transpower to be directly served notice of applications or reviews that are publicly notified and that may affect the National Grid.
Specific Submission Points Transpower is broadly supportive of the Proposed District Plan. However, there are some amendments sought by Transpower in this submission that would give effect to the NPSET and the Regional Policy Statement.
The main points raised in this submission are: Lack of clarity as to how the network utility structures are managed and situations where a single activity could be covered by multiple rules. For example a network utility structure could be addressed by a rule specific to network utilities as well as rules for buildings and structures; Ensuring there is an explicit activity status on every rule;
The need for additional clarity with definitions; Refinement of objectives, policies and rules to meaningfully give effect to the National Policy Statement for Electricity Transmission; Clarification of the role and function of strategic objectives;
Addition of a new section containing all the provisions associated with the National Grid; Relocation of all network utility rules into the network utility chapter;
Ensuring that the activity status is appropriately enabling for network utilities to give effect to the Regional Policy Statement for Taranaki; Recognition of and cross referencing to the National Grid provisions in each of the zone chapters to address landuse activities, buildings and subdivision near the National Grid;
Ensuring development in the structure plan development areas gives appropriate regard to the National Grid; Confirmation of Transpower’s designations; and
Amending the planning maps to just show the National Grid line, not the National Grid Corridor.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific submission points are included below and for the avoidance of doubt, include any consequential relief to the specific relief sought. Amendments sought through this submission are shown as red underlined or strikethrough text.
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Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment All of Plan
Activity status Amend Many activities within the Plan do not have an explicit activity status. For example LRZ-R31 and LRX-R35. It may be Add an explicit activity status for every rule. that the colour of the rule indicates the activity status however this is not clear and should not be implied Each activity should have an explicit activity status that is clear of ambiguity.
A green colour implies that no concept is necessary, and similarly an absence of an explicit activity status might be interpreted as not requiring a consent.
Another example is HH—R13 is stated as a controlled activity but is coloured green which could imply to plan users a permitted activity status. Hyperlinks to definitions Amend The hyperlinks to definitions are really helpful, however some words are incorrectly identified as a defined term. Amend the hyperlinks to defined terms so they are correct and relevant. For example “significant” often has a hyperlink to the defined term “sign” which is obviously not relevant.
Amend Many terms are not hyperlinked to their definition such as “indigenous vegetation disturbance”. Add hyperlinks to all defined terms.
Part 1: Introduction and General Provisions / How the Plan Works
Paragraph 4 Amendment Section 32 is an incorrect reference. Section 32 sets out the requirements for evaluation reports, rather than Amend paragraph 4 of How the Plan Works as follows: Section 32 of the Act sets out the functions that territorial authorities have in terms functions of territorial authorities or matters to be considered in district plans. of how the Act is put into effect. The Plan has been prepared in accordance with the Section 321 of the Act sets out the functions that territorial authorities have in process defined in Section 32 of the Act. terms of how the Act is put into effect. Sections 72-77 of the Act sets out the purpose and contents of district plans. The Plan has been prepared in accordance with the process defined in Section 32 of the Act. Explicit explanation of the activity status of activities not listed Amend There currently is no statement in the Plan clarifying the activity status where an activity is not specifically listed. Add a statement in Part 1 Introduction and General Provisions / How the Plan For example, the natural hazard chapter only contains 7 different hazard layers, but not every rule addresses all 7 works that if an activity is not listed in the Plan, it is deemed to be a permitted overlays. While some chapters have a default rule which covers any activity not otherwise addressed in that activity as follows: chapter, many (particularly the chapters in Part 2 District-wide matters) do not have a default rule. This results in ambiguity and a lack of clarity as to what the activity status for an activity is. There needs to be a rule that explains Any activity that is not listed as Permitted, Controlled, Restricted Discretionary, that if an activity is not listed, it is deemed to be a permitted activity. Discretionary or Prohibited is a permitted activity.
It is acknowledged that the activity will be covered by another rule such as a zone rule, or in the case of a network OR utility it will be addressed in the network utility chapter. Add a rule to each chapter in Part 2 District-wide matters that do not have a default catch-all rule as follows: Any activity that is not listed as Permitted, Controlled, Restricted Discretionary, Discretionary or Prohibited is a permitted activity.
Explanation of the approach where an activity is covered by more than one rule Amend In this Plan there are scenarios where a single activity is potentially covered by more than one rule. This is Add a statement in Part 1 Introduction and General Provisions / How the Plan particularly the case for network utilities which could arguably be addressed by a network utility rule, a building Works as follows, and update the zone chapters to make it clear when Network rule, and earthworks rule and a structure rule. There needs to be a statement which makes it clear that the most Utility provisions apply, specific rule applies as presently drafted, it is not clear which rules apply. The clarity is not assisted by references within the Overview to the Network Utilities Chapter that “As this chapter contains district-wide provisions relating If an activity is covered by more than one rule within a chapter, then the rule to Network Utilities, the rules and effects standards in the zone chapters are not intended to apply to Network that applies is the rule that is more specific for the relevant activity. Utilities (unless otherwise specified, and with the exception of the Special Purpose - Airport Zone and Special Purpose - Port Zone)”, and “It is important to note that in addition to the network utilities chapter and the underlying zone chapter, a number of Part 2: District-wide Matters chapters also contain provisions that may be relevant for network utilities”. It is not then clear throughout the plan which zone chapter provisions apply. This point is addressed further in a submission point below.
In accordance with the definition of “network utility” all activities associated with network utilities should be covered by that term, negating the need to consider additional rules for structures and buildings. Part 1: Introduction and General Provisions / Interpretation
Definition of functional need Support Transpower supports the inclusion of a definition for “functional need” that is consistent with the RMA. Retain the definition of “functional need” as notified. has the same meaning as FUNCTIONAL NEED in section 2 of the RMA (as set out in the box below) means the need for a proposal or activity to traverse, locate or operate in a particular environment because the activity can only occur in that environment.
Filepath SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment Definition of Indigenous vegetation disturbance Amend The definition is circular and is not clear that removal is included. Amend the definition of “indigenous vegetation disturbance” as follows: means disturbance, damage to and/or destruction or felling of indigenous means disturbance, damage to and/or destruction, removal, modification, vegetation, including trees, shrubs, grasses and other plants by any means including trimming or felling of indigenous vegetation, including trees, shrubs, grasses and cutting, burning, crushing or spraying. other plants by any means including cutting, burning, crushing or spraying. Definition of Infrastructure Support Transpower supports the proposed definition of ‘Infrastructure’, specifically clause (d) and the reference to lines Retain clause (d) of the definition of ‘infrastructure’ as notified. (d) facilities for the generation of electricity, lines used or intended to be used to and support structures to convey electricity. convey electricity, and support structures for lines used or intended to be used to convey electricity… Definition of Living activities Support Transpower supports the inclusion of a wide range of residential activities and forms in the definition for Living Retain the definition of “living activities” as notified. means: activities, particularly the inclusion of residential activities. This is significant because of the inclusion of “living • Residential activities; activities” within the definition of “sensitive activities” and the alignment of this with the NPSET defined term. • Residential units; • Minor residential units; • Multi-unit developments; • Pa/Marae; • Papakāinga housing; • Retirement villages; • Boarding houses; and • Supported residential care.
Definition of Major healthcare activities Support Transpower supports the inclusion of a wide range of healthcare and medical activities in the definition for “Major Retain the definition of “major healthcare activities” as notified. means the use of land and/or buildings for the primary purpose of providing healthcare activities”, particularly the inclusion of hospitals. This is significant because of the inclusion of “major medical, surgical, mental health, oral health, maternity, geriatric and convalescent healthcare activities” in the definition of “sensitive activities” and the alignment of this with the NPSET defined or hospice services to the community. This includes, but is not limited to: term. • hospitals; • medical and psychiatric assessment, diagnosis, treatment, rehabilitation and in-patient care services, including operating theatres; • outpatient departments and clinics; • medical research and testing facilities, including diagnostic laboratories; • medical training and education; • ambulance facilities; • first aid and other health-related training facilities; • rehabilitation facilities, including gymnasiums and pools; • palliative facilities; • hospice facilities; • residential care facilities; • secure facilities; • mortuaries; • operations and maintenance support services, including laundries, kitchens, cafeterias, refreshment facilities, generators, substation, storage facilities and workshops; • temporary accommodation, e.g. for families and carers of patients and for staff providing medical treatment; • spiritual facilities; • any ancillary activity to a major healthcare activity. Definition of National Grid Support with Including a definition of “National Grid” is supported as it provides clarity for plan users as to what is the National Amend the definition of “National Grid” as follows: has the same meaning as given in the National Policy Statement on Electricity amendments Grid. The definition is largely consistent with that provided in the NPSET 2008. Transmission (2008). It is identified as the "National Grid Line" on the planning has the same meaning as given in the National Policy Statement on Electricity maps. The reference to the National Grid being identified as the National Grid line on the planning maps should be Transmission (2008). It is identified as the "National Grid Line" on the planning amended as the definition of National Grid also includes substations and the reference to line may be confusing. maps. Definition of National Grid Corridor Support with Transpower supports the inclusion of a definition for “National Grid Corridor” as the definition gives effect to the Amend the definition of “National Grid Corridor” as follows: is identified on the planning maps, and means the area measured either side of the amendments NPSET by clearly articulating the framework within which land use, subdivision and development needs to be centreline of the aboveground National Grid Line as follows: managed. This enables NPSET Policies 10 and 11 to be given effect. National Grid Subdivision Corridor is identified on the planning maps, and means the area measured either side of a. 16m for the 110kV lines on pi poles. The subdivision ‘National Grid Corridor’ width of 37m (maximum) is based on the distance from the centreline the centreline of the aboveground “National Grid” transmission Llines, as b. 32m for the 110 kV lines on towers. between the support structures to a point where the conductor would swing under possible high wind conditions, follows: c. 37m for the 220 kV transmission lines. and is the swing of the 95th percentile span across the country, as well as other variables. It is important that the swing of conductors can be taken into account in the subdivision process so that the allotment(s) can be safely a. 16m for the 110kV lines on pi poles. developed and used. This is why differing widths are provided for different voltage lines. b. 32m for the 110 kV lines on towers. c. 37m for the 220 kV transmission lines. The Corridor is wider than the Yard and it should be noted that the Corridor and Yard overlap.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment However, while generally supported, four amendments are sought as follows: 1. The National Grid Corridor applies to subdivision, and amending the term will more accurately reflect this. 2. Clarification of the applicability of the National Grid Corridor in terms of underground cables or transmission lines designated by Transpower. 3. Additional clarity as to how the centreline is calculated. 4. Minor amendments to ensure the measurement is taken off the physical electricity transmission line, rather than the lines on the planning maps which may not be entirely accurate.
The National Grid Subdivision Corridor does not apply to underground cables or any transmission line (or sections of lines) that are designated by Transpower. The measurement of setback distances from National Grid lines shall be taken from the centre line of the transmission line and the outer edge of any support structure. The centre line at any point is a straight line between the centre points of the two support structures at each end of the span.
AND
Amend all references to “National Grid Corridor” to “National Grid Subdivision Corridor” within the Plan Definition of National Grid Yard Support with Transpower supports inclusion of a definition for National Grid Yard as the definition gives effect to the NPSET by National Grid Yard means the area located 12 metres in any direction from the outer edge of a National amendments clearly articulating the framework within which land use, subdivision and development needs to be managed. This means the area located within: Grid support structure, and the area located 12 metres either side of the centreline enables NPSET Policies 10 and 11 to be given effect to. (a) 12 metres in any direction from the outer visible edge of a “National Grid” of any overhead National Grid line on pi poles or towers. The National Grid Yard support structure foundation; and does not apply to underground cables or any transmission lines (or sections of line) The “National Grid Yard”, is a 12m width calculated as the distance from the centreline between the support (b) the area located 12 metres either side of the centreline of any overhead that are designated. structures to the point where the conductor would swing under everyday conditions (noting that maintenance is “National Grid” transmission line on pi poles or towers. The National Grid Yard not generally undertaken in high wind conditions). does not apply to underground cables or any transmission lines (or sections of line) that are designated. The measurement of setback distances from National However, while generally supported, four amendments are sought to the definition as follows: Grid lines shall be taken from the centre line of the transmission line and the 1. Clarification that the National Grid Yard applies to the area within the specified distance from the structure or outer edge of any support structure. The centre line at any point is a straight line line. between the centre points of the two support structures at each end of the span. 2. Clarification of the applicability of the National Grid Corridor in terms of underground cables or transmission lines designated by Transpower. 3. Additional clarity as to how the centreline is calculated. 4. Minor amendments to ensure the measurement is taken from the visible edge of the support structure foundations.
The image of the single poles can be deleted as there are no Transpower transmission lines on single poles within New Plymouth District.
Definition of Network Utilities or Network Utility Support Transpower supports the inclusion of a definition for “network utilities or network utility”, the definition is Retain the definition of Network Utilities or Network Utility as notified. means a project, work, system or structure that is a network utility operation currently circular and not helpful to users of the Plan. Amendments are sought to make the definition more undertaken by a network utility operator. meaningful and useful. The definition needs to be broad to avoid the situation where a network utility activity is captured by several component rules (such as buildings and structures). Definition of Network Utility Operator Support Transpower supports the inclusion of a definition for “network utility operator” in accordance with the RMA on the Retain the definition of “Network Utility Operator” as notified. basis Transpower is an electricity systems operator and therefore captured by the definition. has the same meaning as NETWORK UTILITY OPERATOR in section 2 of the RMA (as set out in the box below) means a person who— …
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment (c) is an electricity operator or electricity distributor as defined in section 2 of the Electricity Act 1992 for the purpose of line function services as defined in that section; or
Definition of Operational need Support Transpower supports the inclusion of a definition for “operational need” in accordance with the RMA. In Retain the definition of “Operational need” as notified. particular, the recognition of the technical characteristics or constraints is important as this reflects Policy 3 of the has the same meaning as OPERATIONAL NEED in section 2 of the RMA (as set out in National Policy Statement for Electricity Transmission. the box below) means the need for a proposal or activity to traverse, locate or operate in a particular environment because of technical, logistical or operational characteristics or constraints. New definition of Outstanding natural landscapes Amend Transpower seeks inclusion of a definition for this term to provide clarity as to where these areas are. Add a definition for “Outstanding natural landscapes” as follows: means all landscapes identified as an Outstanding Natural Landscape on planning maps, and contained in SCHED8: Schedule of Natural Features and Landscapes. New definition of Outstanding natural character Amend Transpower seeks inclusion of a definition for this term to provide clarity as to where these areas are. Add a definition for “Outstanding natural character” as follows: means all landscapes identified as an Outstanding Natural Character on planning maps, and contained in SCHED10: Schedule of Outstanding Natural Character Areas. Definition of Reverse sensitivity Support with Transpower supports the inclusion of a definition for reverse sensitivity to provide clarity. This is a term that is Amend the definition of “Reverse sensitivity” as follows: means the potential for the operation of an existing lawfully established activity to amendments used in Policy 10 of the NPSET and a definition will assist Plan users in understanding the term in the context of the be compromised, constrained or curtailed by the more recent establishment or National Grid. Reverse sensitivity is not just applicable to the operation of the National Grid (as the activity), the Reverse sensitivity alteration of another activity which may be sensitive to the actual, potential or structures themselves may be compromised by inappropriate land uses, subdivision and development (including means the vulnerability potential for the operation of an existing lawfully perceived environmental effects generated by an existing activity. earthworks). established activity or structure to be compromised, constrained or curtailed by the more recent establishment or alteration of another activity which may be Even though the definition of “environment” in the RMA includes social, economic and cultural conditions, the use sensitive to the actual, potential or perceived environmental effects generated of the word “environment” does not reflect the full spectrum of effects possible. by an the existing activity or structure. Definition of Sensitive activities Support The National Policy Statement for Electricity Transmission contains a definition of “sensitive activities”, and all of Retain the definition of “sensitive activities” as notified. means the use of land and/or buildings for: the items in the definition in the NPSET are included in the proposed New Plymouth District Plan definition. The • living activities; definition of “sensitive activities” in the NPSET also includes hospitals, which appear within the definition of “Major • educational facilities; healthcare activities”. Transpower therefore supports the definition of “sensitive activities” as notified as this • community facilities; provides a comprehensive set of activities which will give effect to the NPSET policies regarding sensitive activities. • major healthcare activities; and/or • visitor accommodation. Definition of Significant natural area Support Transpower supports the definition on the basis it applies to the area as identified on the planning maps. Such Retain the definition of “Significant natural area” as notified. means all indigenous vegetation identified as a significant natural area on planning identification assists plan users and provides clarity on the application of the PNPDP provisions that relate to the maps, and contained in SCHED6: Schedule of Rural Significant Natural Areas and/or definition. SCHED7: Schedule of Urban Biodiversity Areas. New definition for Temporary infrastructure Amend It would be helpful to have a definition for temporary infrastructure to support the rules (Rule NU-R6) which Include the following definition: recognises and enables short term use of infrastructure. This is particularly important to enable the continuing Temporary infrastructure operation of key infrastructure, especially when there is a natural hazard event. This enables resilience of the community. Short-term structures and activities undertaken by a network utility operator as defined by the Resource Management Act 1991, including the operation of generators such as diesel-powered generators. Definition for Underbuild Support with There are areas where there is existing lawfully established buildings under the National Grid and Transpower Amend the definition for “Underbuild” as follows: means land where a building or buildings are located beneath any part of the amendments support the inclusion of a definition to provide clarity to Plan users. However the definition needs to be amended overhead National Grid lines to apply to lawfully established buildings and acknowledge that existing buildings may be partially located beneath means land where an existing building or part of a buildings has been lawfully the National Grid lines. established are located within the National Grid Yard beneath any part of the overhead National Grid lines The definition needs to focus on the National Grid Yard rather than the lines to match the management approach in the Proposed District Plan which focuses on the National Grid Yard in terms of buildings and sensitive activities. Definition for Upgrading Support with Transpower supports inclusion of a definition for clarity, and to give effect to INF Policy 1 of the Regional Policy Amend the definition for “Upgrading” as follows: for network utilities, means increasing the carrying capacity, efficiency, security, or amendments Statement for Taranaki. However, the definition as notified focuses on the location of existing structures and does safety of a network utility, where it does not result in a permanent change to the not provide any clarity on the addition of structures which may be required to support an upgrading. This results in for network utilities, means increasing the carrying capacity, efficiency, security, location of a structure. confusion as to what the activity status would be. or safety of a network utility, where it does not result in a permanent change to the location of a structure. In addition, this definition currently conflicts with Rule NU-R3 which allows realignment or relocation of structures within 5m of the existing alignment or location and also allows additional poles. New definition for “customer connections” Amend The term “customer connections” is used in rule NU-R5 (as well as many others) but it is not clear from the context Add a definition for “customer connection” of the rule who is the customer and what the activity is that is the focus of this rule. Transpower consider including
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment a definition for this term will improve clarity of the rule. Network utility operators are often customers of other network utilities eg the relationship between electricity generation, transmission and distribution companies.
New definition for “National Grid Substation Corridor” Amend This term is used in Rule NU-R35 and NU-R37 but there is no explanation of what this is or how it is calculated. The Add a definition for “National Grid Substation Corridor” as follows: inclusion of a definition would complement the suite of definitions associated with the National Grid. A corridor marked on the planning maps measuring 12m from the secured yard of the Transpower substations at Carrington Street and Huirangi. This corridor is to manage reverse sensitivity and other effects of any new sensitive activities around these sites.
Part 2: District-wide matters / Strategic Direction
Urban Form and Development UFD-24 Amend It is not appropriate for productive, versatile land within rural areas to be protected. “Protection” implies they can Amend UFD-24 as follows: Productive, versatile land and natural, physical and cultural resources located within not be used, in which case there is no purpose in protecting them, as the value of productive versatile land lies in rural areas that are of significance to the district are protected and maintained. what it can be used for. The objective as drafted fails to recognise that some activities such as infrastructure, which Productive, versatile land and natural, physical and cultural resources located can be of a linear nature, requires/is best placed in a rural location. within rural areas that are of significance to the district are protected and maintained used effectively. New Strategic Objective Amend The recognition of the importance network utilities is a District-wide issue and should be addressed as a Strategic Add a new strategic objective UFD-25 as follows: Objective. Because this issues spans all zones, overlays and environment, this issue needs to be recognised at a strategic level. Network utilities and their benefits are recognised and provided for
This will give effect to INF Objective 1 and INF Policy 2 in the Regional Policy Statement for Taranaki. New Strategic Objective Amend The management of reverse sensitivity is a District-wide issue and should be addressed as a Strategic Objective. Add a new strategic objective UFD-25 as follows: Because this issues spans all zones, overlays and environment, this issue needs to be recognised at a strategic level. Avoid reverse sensitivity effects, particularly protecting the National Grid and The proposed plan does not address reverse sensitivity in a whole-of-district way. network utilities
In addition, there is really clear direction the Regional Policy Statement for Taranaki about reverse sensitivity with regards to NU’sncluding references to regionally significant infrastructure will give effect to INF Objective 1 and INF Policy 2 in the Regional Policy Statement for Taranaki. Including specific references to the National Grid will give effect to NPSET Policies 10 and 11. The role of the objectives in the Strategic Directions chapter Amend The role of the objectives contained in the Strategic Directions chapter needs to be clarified in the Plan. Is there a Add text at the start of the Strategic Directions chapter which clarifies the role hierarchy of objectives where the objectives in the Strategic Objectives are “super objectives” which trump all of the Strategic Objectives as follows: other objectives? Or are they objectives with the same status and importance as any other objective in the Plan? The Strategic Objectives have the same status as all other objectives in the Plan, but provide guidance across the District.
Part 2: District-wide Matters / Energy, Infrastructure and Transport / Network Utilities
New section on National Grid to Part 2: District-wide Matters / Energy, Amend Given the importance of the National Grid, a National Policy Statement which is uniquely focused on the National Add a new section NG to Part 2: District-wide Matters / Energy, Infrastructure Infrastructure and Transport Grid and specific policies regarding the National Grid in the Regional Policy Statement for Taranaki, the most and Transport which contains appropriate response is a specific section within Part District-wide Matters / Energy, infrastructure and Transport which addresses with the National Grid. This would complement and be consistent with the approach to the ENGY Objectives; section which addresses the NPS on Renewable Electricity Generation in a single comprehensive location within Policies; and the Plan. This approach will be a more efficient approach in that all matters associated with the National Grid can be located in one section. Rules relevant to both the operation and development of the National Grid itself, as The National Grid has two aspects to it: well as subdivision, buildings, structures and land use activities in close proximity a) the physical infrastructure itself, and to the National Grid. b) managing the uses around the National Grid to enable operation, maintenance, development and upgrading AND The National Grid objectives, policies and rules are unique from other network utilities in that other landowners Any consequential amendments, such as references in other parts of the Plan to within the District have obligations and need to be cognisant of the National Grid when undertaking subdivision, “Network Utilities” buildings and activities anywhere near the National Grid.
A single comprehensive section will enable a framework of objectives, policies and rules relevant to the National Grid. This will also enable efficient cross-referencing to this section for subdivision, buildings and landuses near the National Grid. NU – Network Utilities Amend The guidance provided by the Ministry for the Environment on the National Planning Standards acknowledges that Relocate all objectives, policies and rules that are specific to network utilities there are many structures and activities that could potentially be covered by more than one chapter. With the into the Network Utilities chapter. exception of structures and activities in close proximity to the National Grid and gas transmission lines, the only users of the Network Utilities Chapter will be network utility providers. It is far more efficient for all provisions associated with network utilities to be transferred from the respective chapters into the NU chapter.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment NU – Network Utilities Overview Amend The NPSET is critical in the management of the National Grid – both in terms of the operation, maintenance and Amend NU – Network Utilities Overview as follows: development of the physical infrastructure itself, but also management of structures and land uses in close Network utilities are critical to the social, economic, and cultural well-being of proximity to the National Grid. Given that this is a National Policy Statement and the objective of that National Network utilities are critical to the social, economic, and cultural well-being of people and communities and the quality of the environment at a national, regional Policy Statement, it is appropriate to include recognition of the National Grid in the introductory paragraphs. This people and communities and the quality of the environment at a national, and/or local level. Without the connections enabled by transport networks (land, sea is consistent with the approach used in the ENGY Overview which references the National Policy Statement for regional and/or local level. Without the connections enabled by transport and air), piped networks (water, wastewater and stormwater reticulation), Renewable Electricity Generation. networks (land, sea and air), piped networks (water, wastewater and transmission and distribution networks (electricity, gas and liquid fuels) and stormwater reticulation), transmission and distribution networks (electricity, gas telecommunication networks (wired and wireless), few other forms of activities and liquid fuels) and telecommunication networks (wired and wireless), few could be undertaken. While it is recognised that network utilities have national, other forms of activities could be undertaken. While it is recognised that regional, and local benefits, they can also have adverse effects on surrounding land network utilities have national, regional, and local benefits, they can also have uses and the environment which need to be managed. adverse effects on surrounding land uses and the environment which need to be managed. This chapter includes: 1. provisions specific to network utilities (i.e. to provide for and manage the adverse The importance of the National Grid has been recognised in the development of effects of network utilities), except for the transport network (which is provided in the National Policy Statement for Electricity Transmission 2008 (NPSET), the the Transport chapter), and Resource Management (National Environmental Standards for Electricity 2. provisions to manage the effects of other activities on network utilities (including Transmission Activities) Regulations 2009 and the Regional Policy Statement. the National Grid and Gas Transmission Pipelines). The NPSET provides that the district plan must recognise the national significance of the electricity transmission network (the National Grid) by facilitating its operation, maintenance, upgrading and development, while managing both the adverse effects of the network, and managing the adverse effects of other activities on the network. The Taranaki Regional Policy Statement 2010 recognises the National Grid (and other types of utilities) as infrastructure of regional significance and requires that district plans shall provide for its continued safe and efficient establishment and operation. Development in close proximity to the National Grid requires careful management, as it can lead to adverse effects on its operation, maintenance, upgrade and development.
This chapter includes: … Overview Support with Transpower supports the principle of this statement (which Transpower understands to be that the zone Amend the following text in the Overview section of the Network Utilities amendments provisions within Part 3 do not apply) as it ensures the Proposed Plan is clear as to the relationship between the chapter as notified: As this chapter contains district-wide provisions relating to Network Utilities, the objectives, policies and rules for network utilities and those of the zones. As the network utilities chapter is located rules and effects standards in the zone chapters are not intended to apply to within the “District-wide Matters” section of the Proposed District Plan, this is an appropriate approach and As this chapter contains district-wide provisions relating to Network Utilities, the Network Utilities (unless otherwise specified, and with the exception of the Special ensures clarity and effectiveness of the Plan. However, the wording could be amended to be more definite as the objectives, policies, rules and effects standards in the zone chapters or Purpose - Airport Zone and Special Purpose - Port Zone). wording “not intended to apply” is open to interpretation. development areas are do not intended to apply to Network Utilities (unless otherwise specified, and with the exception of the Special Purpose - Airport Zone Based on the above interpretation, the objectives and policies of the zones are also not relevant to network and Special Purpose - Port Zone). utilities, and the text needs to recognise this to avoid ambiguity. ….
Overview Amend The Proposed Plan is not clear as to the relationship between the objectives, policies and rules for network utilities Add the following text to the Overview section of the Network Utilities chapter: and those for more general activities such as “buildings” and “structures”. Arguably there is considerable duplication in the Plan. An example is that a structure associated with a network utility in the Natural Features and Where there are specific provisions for network utilities, the objectives, policies Landscapes chapter could also be covered by all the structure and building rules in that chapter (due to the and rules throughout the District Plan for more general activities such as definition of “structure” including the definition of “building”). “buildings” and “structures” do not apply.
It would be helpful and improve clarity and effectiveness of the Proposed Plan if this situation is clarified in the Network Utility chapter. Cross references to other relevant District Plan provisions Amend For the following reasons: this text in the overview lack clarity, is open to interpretation and is confusing in how it Either: relates to other chapters: It is important to note that in addition to the network utilities chapter and the Amend the plan so all provisions associated with network utilities are underlying zone chapter, a number of Part 2: District-wide Matters chapters also - This text conflicts with the text in the Overview which states that the zone chapters are not transferred from the respective chapters into the NU chapter contain provisions that may be relevant for network utilities, including: intended to apply to the management of network utilities (other than the Special Purpose - ………. Airport Zone and Special Purpose - Port Zone). OR
- The text refers to Part 2 District wide matters Chapters and then lists the chapters, but some of Amend the plan to make it explicitly clear what provisions apply to Network those listed are not District Wide matters but other matters under Part 2 (e.g. Subdivision, Utilities Historic and cultural values). OR - The text refers to other chapters that may be relevant. Is it not clear what chapters (and specific policies and methods) are relevant. No guidance is provided within the respective chapters. It Amend the text in the Network Utilities Chapter - Cross references to other relevant District Plan provisions as follows:
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment could be assumed the only provisions are those that specifically reference network utilities but this is not clear and open to interpretation and conjecture. It is important to note that in addition to the network utilities chapter and the underlying zone Special Purpose - Airport Zone and Special Purpose - Port Zone
chapters, a number of Part 2: District-wide Matters chapters also contain
provisions that may be are relevant for network utilities, including: Transpower seeks amendments to ensure the Plan is clear and effective in its management of network utilities. Energy - The Energy Chapter contains provisions to provide for and The guidance provided by the Ministry for the Environment on the National Planning Standards acknowledges that manage the effects of renewable and non-renewable energy activities. there are many structures and activities that could potentially be covered by more than one chapter. With the Transport - The Transport Chapter includes: exception of structures and activities in close proximity to the National Grid and gas transmission lines, the only Provisions to provide for the transport network, including design users of the Network Utilities Chapter will be network utility providers. It is far more efficient for all provisions standards. associated with network utilities to be transferred from the respective chapters into the NU chapter. This is the most efficient and effective approach for ensuring that network utility operators capture all the relevant rules. This Provisions to manage access to the transport network. approach provides certainty for the network utility operators, Council’s planners and the community. Provisions to avoid physical obstructions to take-off, approach, landing or departure paths and runway protection areas through the ‘Airport Flight Path Surface’. Provisions to manage health and safety effects in close proximity to the railway. Natural Hazards - The Natural Hazards Chapter contains provisions for activities within hazard areas. Historic Heritage - The Historic Heritage Chapter contains provisions for activities near archaeological sites or heritage items Notable Trees - The Notable Trees Chapter contains provisions for activities near scheduled trees Sites and Areas of Significance to Māori - The Sites and Areas of Significance to Māori Chapter contains provisions for activities near scheduled sites or areas of significance to Māori Ecosystems and Indigenous Biodiversity - The Ecosystems and Indigenous Biodiversity Chapter contains provisions to protect areas of significant indigenous vegetation and significant habitats of indigenous fauna Natural Features and Landscapes - The Natural Features and Landscapes Chapter contains provisions for activities within outstanding natural features and landscapes Waterbodies - The Waterbodies Chapter contains provisions for activities near significant waterbodies or natural waterbodies Subdivision - The Subdivision Chapter contains provisions requiring compliance with NZS 4404:2010 Land Development and Subdivision Infrastructure and Land Development and Subdivision Infrastructure Standard Local Amendments Version 3 (which focuses on installation of three waters and transport infrastructure, and sets minimum requirements of technical performance and quality for the subdivision and development of land and infrastructure). Coastal Environment - The Coastal Environment Chapter contains provisions for activities in the Coastal Environment Area and coastal hazard areas Earthworks - The Earthworks Chapter manages the adverse effects of earthworks on the environment, including visual amenity effects, land stability effects, health and safety effects, damage to property and the creation or increase in the risk of natural hazards. Noise - The Noise Chapter contains provisions to locate, design, construct and operate sensitive activities to manage noise and health and safety effects in close proximity to the state highway, railway, airport, port, and Major Facilities. Cross references to other relevant District Plan provisions Support Transpower supports the clarification that the Network Utilities chapter applies to network utilities as well as Retain the following text as notified in the Network Utility chapter under the This chapter includes: manging the effect of other activities on network utilities. This is an appropriate approach and gives effect to INF heading Cross references to other relevant District Plan provisions: Objective 1 and Policies INF 1 and 2 of the Regional Policy Statement for Taranaki. It is also an appropriate 1. provisions specific to network utilities (i.e. to provide for and manage the adverse approach to giving effect to the National Policy Statement for Electricity Transmission. This chapter includes: effects of network utilities), except for the transport network (which is provided in the Transport Chapter), and Transpower considers it is appropriate to acknowledge the National Grid in this text due to Policies 10 and 11 in 1. provisions specific to network utilities (i.e. to provide for and manage the 2. provisions to manage the effects of other activities on network utilities (including the National Policy Statement for Electricity Transmission. adverse effects of network utilities), except for the transport network (which is the National Grid and Gas Transmission Pipelines). provided in the Transport Chapter), and 2. provisions to manage the effects of other activities on network utilities (including the National Grid and Gas Transmission Pipelines).
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment Other relevant regulations Amend The explanation of “existing transmission line” as contained in the National Environmental Standards for Electricity Amend NU – Network Utilities / Other relevant regulations as follows: Transmission Activities is not entirely correct. The Interpretation contained in the NESETA defines existing Additional regulatory requirements, separate to the District Plan, are also relevant transmission line as: Additional regulatory requirements, separate to the District Plan, are also to network utilities, including: (a)means a transmission line that was operational, or was able to be operated, at the commencement of these relevant to network utilities, including: regulations; and 1. The requirements of the Resource Management (National Environmental (b)includes a transmission line described in paragraph (a) that is altered or relocated in accordance with these 1. The requirements of the Resource Management (National Environmental Standards for Electricity Transmission Activities) Regulations 2009 (NESETA) apply regulations; and Standards for Electricity Transmission Activities) Regulations 2009 (NESETA) directly to the operation, maintenance, upgrading, relocation or removal of (c)includes a transmission line that, in accordance with these regulations, replaces a transmission line described in apply directly to the operation, maintenance, upgrading, relocation or removal transmission line(s) that were operating or able to be operated on or prior to 14 paragraph (a) of transmission line(s). An existing transmission line includes those that were January 2010 and remain part of the National Grid. In the case of conflict or operating or able to be operated on or prior to 14 January 2010, and any of perceived conflict with any provision of this plan, the NESETA provisions shall The word “upgrading” has been hyper-linked to the definition of the term in the Plan. However, the term those that are altered, relocated or replaced in accordance with these prevail. “upgrading” is separately defined in the NESETA so this hyper-link need to be removed as it is not correct. regulations. and remain part of the National Grid. In the case of conflict or perceived conflict with any provision of this plan, the NESETA provisions shall prevail. Other relevant regulations Support Transpower supports the explicit recognition of the NZECP 34:2001 New Zealand Electrical Code of Practice for Retain recognition of the NZECP 34:2001 New Zealand Electrical Code of Electrical Safe Distances (NZECP 34:2001) and the Electricity (Hazards from Trees) Regulations 2003 and the need Practice for Electrical Safe Distances (NZECP 34:2001) and Electricity (Hazards Additional regulatory requirements, separate to the District Plan, are also relevant to comply with these regulations. from Trees) Regulations 2003 as notified. to network utilities, including:
4. Compliance with the NZECP 34:2001 New Zealand Electrical Code of Practice for Electrical Safe Distances (NZECP 34:2001) is mandatory under the Electricity Act 1992. All activities regulated by the NZECP 34:2001, including any activities that are otherwise permitted by the plan, must comply with this regulation. 5. Compliance with the Electricity (Hazards from Trees) Regulations 2003 is mandatory. All activities regulated by these regulations, including any activities that are otherwise permitted by the plan, must comply with this regulation. NU-O1 Support The objective is framed appropriately to recognise the benefit of network utilities, and aligns with the Retain Objective NU-O1 as notified. Effective, resilient, efficient and safe network utilities that: requirements of INF Policy 1 of the Regional Policy Statement for Taranaki for efficient and effective network 1. provide essential and secure services, including in emergencies; utilities. 2. facilitate local, regional, national or international connectivity; 3. contribute to the economy and support a high standard of living; 4. integrate with development, infrastructure and other activities; and 5. enable people and communities to provide for their health, safety and wellbeing. NU-O2 Support with INF Policy 1 of the Regional Policy Statement for Taranaki requires provision for any adverse effects of their Amend Objective NU-O2 as follows: The adverse effects of network utilities on the environment are avoided, remedied or amendments establishment to be avoided, remedied or mitigated as far as is practicable. The objective needs to be amended to mitigated, while recognising: more fully reflect the RPS policy and Policy 3 of the NPSET. The adverse effects of network utilities on the environment are avoided, remedied or mitigated as far as is practicable, while recognising: 1. the functional need and operational need of network utilities; The recognition of the benefits in clause (2) aligns with Policy 1 of the NPSET. 2. that positive effects of network utilities may be realised locally, regionally or 1. the functional need and operational need of network utilities; nationally. Policy 3 of the NPSET requires consideration of the constraints imposed on achieving avoiding, remedying or 2. that positive effects the benefits of network utilities which may be realised mitigation of adverse environmental effects by the technical and operational requirement of the network. This is locally, regionally or nationally. specific to the National Grid and needs to be recognised by the objective. The definition of “operational need’ includes technical constraints so it is important that the objective retains recognition of the functional need and operational needs of network utilities. NU-O3 Support with INF Policy 2 of the Regional Policy Statement for Taranaki requires the adverse effects of subdivision, use and Amend Objective NU-O3 as follows: The efficient operation, maintenance, repair or upgrading of network utilities is not amendments development on the safety, efficiency, operation, maintenance and upgrading of the region’s network utilities and constrained or compromised by other activities on other physical infrastructure of regional The safety, efficiency, operation, maintenance, repair, or upgrading, or significance (including where this is of national importance) to be avoided or mitigated. The objective could be development of network utilities is not constrained or compromised by other amended to more closely reflect the Regional Policy Statement policy. activities subdivision, use and development.
Policy 10 of the National Policy Statement for Electricity Transmission requires that activities be managed to avoid reverse sensitivity effects on the electricity transmission network and to ensure that operation, maintenance, upgrading, and development of the electricity transmission network is not compromised. Objective NU-O3 aligns with this. New objective Amend The proposed objectives in the Network Utilities section of the Plan fail to give appropriate effect to the NPSET. Add the following new objective to the Network Utilities chapter: While it is not expected that the Proposed District Plan repeat the provisions of the NPSET, similarly the objective and policies in the NPSET are mandatory and Section 75(3)(a) requires district plans to give effect to any national NU-OX policy statement. The national significance of the National Grid is recognised, and the National Grid is protected and provided for. The National Grid has two aspects to it: a) the physical infrastructure itself, and b) managing the uses around the National Grid to enable operation, maintenance, development and upgrading of the National Grid
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment
The additional objective sought will address the first aspect of the NPSET.
New objective Amend The proposed objectives in the Network Utilities section of the Plan fail to give appropriate effect to the NPSET. Add the following new objective to the Network Utilities chapter: While it is not expected that the Proposed District Plan repeat the provisions of the NPSET, similarly the objective and policies in the NPSET are mandatory and Section 75(3)(a) requires district plans to give effect to any national NU-OX policy statement. The National Grid is protected from reverse sensitivity effects, and the operation, maintenance, upgrading and development of the National Grid is not The National Grid has two aspects to it: compromised. a) the physical infrastructure itself, and b) managing the uses around the National Grid to enable operation, maintenance, development and upgrading of the National Grid
The additional objective sought will address the second part of the NPSET. NU-P1 Support with Transpower supports the recognition of the benefits of network utilities. In order to meaningfully give effect to the Transpower’s preference is for a new National Grid specific policy NU-xx (refer Recognise the benefits of network utilities by: amendments NPSET, the National Grid should be specifically addressed in this policy. later submission point). Should this not be granted Transpower seeks amendment to Policy NU-P1 as follows: 1. allowing the development, upgrade, operation, maintenance, repair or removal of Transpower prefers the approach of including a new Policy NU-Pxx as outlined below in this submission that is network utilities, including: specific to the National Grid, however if that submission point is not accepted then Transpower seeks amendments Recognise the benefits of network utilities by: a. the effective safe, secure and efficient transmission or distribution of to NU-P1 to recognise the National Grid and give effect to the NPSET. electricity, gas or liquid petroleum; 1. allowing enabling the development, upgrade, operation, maintenance, repair b. effective, reliable and future-proofed communications networks and or removal of network utilities, including: services; a. the effective safe, secure and efficient transmission or distribution of c. effective, resilient, efficient and safe water, wastewater and stormwater electricity, gas or liquid petroleum; treatment systems, networks and services; b. effective, reliable and future-proofed communications networks and 2. allowing investigation, monitoring and navigation activities associated with services; network utility operations; and c. effective, resilient, efficient and safe water, wastewater and 3. providing for the functions and responsibilities of network utilities, including as stormwater treatment systems, networks and services; lifeline utilities during an emergency. 2. allowing investigation, monitoring and navigation activities associated with network utility operations; and 3. providing for the functions and responsibilities of network utilities, including as lifeline utilities during an emergency.; and 4. enabling the operation, maintenance and upgrade of the existing National Grid and the establishment of new electricity transmission resources NU-P2 Support with The objective as it is currently worded is passive, whereas INF Policy 4 of the Regional Policy Statement for Amend Policy NU-P2 as follows: amendments Taranaki is highly directive. The RPS requires that new land use generated by growth and development and the Encourage the coordination of network utilities planning and delivery with land use, associated infrastructure to service that growth should be Encourage the coordination of Land use, subdivision, development and urban subdivision, development and urban growth so that future land use and network integrated and planned alongside one another. In addition, SUD Policy 1(e) of the Regional Policy Statement for growth must be coordinated with network utilities planning and delivery with utilities are integrated, efficient and aligned. Taranaki requires integrating the maintenance, upgrading or provision of infrastructure with land use. This is a land use, subdivision, development and urban growth so that future land use directive from the National Policy Statement for Urban Development Capacity also. and network utilities are integrated, efficient and aligned. NU-P3 Support with Transpower supports Policy NU-P3 as it recognises technological advances. Given the 10-year life of the Plan and Amend Policy NU-P3 as follows: amendments the rapidly-changing technological advances, the recognition of flexibility is supported. Minor changes are sought Support network utilities in adopting new technologies that: to the policy to make is more meaningful. Support network utilities in adopting Provide flexibility for network utilities to 1. improve access to, and efficient use of, networks and services; use new technologies that: 2. allow for the re-use of redundant services and structures; 1. improve access to, and efficient use or development of, networks and services; 3. increase resilience, safety or reliability of networks and services; 2. allow for the re-use of redundant services and structures; 4. result in environmental benefits and enhancements; or 3. increase resilience, safety or reliability of networks and services; 5. promote environmentally sustainable outcomes including green infrastructure 4. result in environmental benefits and enhancements; or and the increased utilisation of renewable resources 5. promote environmentally sustainable outcomes including green infrastructure and the increased utilisation of renewable resources New policy Amend Transpower considers an additional policy is needed that recognises the range of influences and considerations Add the following new policy to the Network Utilities chapter (or National Grid that are associated with the development, operation, maintenance, repair, replacement and upgrading of chapter): infrastructure. The policy gives effect to Policies 1, 2, and 3 of the NPSET. Policy NU-Pxx Transpower supports Policy NU-Pxx being specific to the National Grid as opposed to regionally important infrastructure, given the policy is in specific response to, and to give effect to, the NPSET, which is a higher order Specific to the National Grid: policy document. 1. Recognise and provide for the operation, maintenance or upgrading of Insertion of this new policy is Transpower’s preference, but if this is not accepted the submission outlines other existing National Grid infrastructure. amendments to policies to reflect the NPSET. 2. Recognise and provide for the development of the National Grid, while managing potential adverse effects on the environment by:
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment a. having regard to the extent to which adverse effects have been avoided, remedied or mitigated by route, site and method selection; and b. recognising the operational needs and functional needs of the National Grid; and c. seeking to avoid adverse effects of the development of the National Grid on areas of Historic and Cultural Values overlays and Natural Environment Overlays as identified in the district plan.
Other than in the Coastal Environment, Policy NU-Pxx prevails over other provision in the plan. NU-P4 Support with While undergrounding of infrastructure is desirable, operational or functional needs of the infrastructure may Amend Policy NU-P4 as follows: amendments mean that undergrounding will not result in an optimal outcome – either for the functionality of the network or in Manage the adverse effects of network utilities, including effects on natural and terms of minimising adverse effects. In addition, there may be constraints to the structures being placed Manage the adverse effects of network utilities, including effects on natural and physical resources, amenity values, sensitive activities, and the health, safety and underground such as the presence of Maori sites of significance, soil characteristics or geology. physical resources, amenity values, sensitive activities, and the health, safety wellbeing of people and communities by: and wellbeing of people and communities by: Due to the way that the National Grid is funded and delivered, it may not be possible to underground new National 1. controlling the height, bulk and location of network utilities; Grid lines even if it is technically feasible. The extent to which it is appropriate for new National Grid assets to be 1. controlling the height, bulk and location of network utilities; 2. requiring compliance with recognised standards or guidelines for the potential located underground is determined by complex variables, including direction from the Commerce Commission. 2. requiring compliance with recognised standards or guidelines for the potential adverse effects of noise, vibration, radiofrequency fields and electric and magnetic Transpower would not always be able to meet this policy for new infrastructure, due to matters beyond its control. adverse effects of noise, vibration, radiofrequency fields and electric and fields; magnetic fields; 3. requiring the undergrounding of network utilities in new areas of urban Because of the operational and functional design of network utility structures, it is not always possible to adopt a 3. requiring encouraging the undergrounding of network utilities in new areas of development; sensitive design and integrate the network utility into the site, existing built form or landform. Structures often urban development, unless: 4. mitigating adverse visual effects through landscaping and/or the use of recessive need height to maximise coverage or reduce the number of individual structures. The policy needs to be more a. The adverse effects on the environment are greater than placing the colours and finishes; and flexible to recognise these constraints. infrastructure above ground; 5. requiring network utilities to adopt sensitive design to integrate network utilities b. A natural or physical feature or structure renders underground within the site, existing built form and/or landform and to maintain the character The reference to “where practicable” is due to the Regional Policy Statement Policy INF 1 which states placement impractical or undesirable; or and amenity of the surrounding area. “….provision for any adverse effects of their establishment to be avoided, remedied or mitigated as far as is c. There are significant operational, functional, technical, cultural or practicable”. economic reasons that require the infrastructure to be above ground; 4. mitigating adverse visual effects through landscaping and/or the use of recessive colours and finishes; and 5. requiring encouraging network utilities to adopt sensitive design to integrate network utilities within the site, existing built form and/or landform and to maintain the character and amenity of the surrounding area where practicable.
OR
Amend Policy NU-P4 as follows:
Manage the adverse effects of network utilities, including effects on natural and physical resources, amenity values, sensitive activities, and the health, safety and wellbeing of people and communities by:
1. controlling the height, bulk and location of network utilities; 2. requiring compliance with recognised standards or guidelines for the potential adverse effects of noise, vibration, radiofrequency fields and electric and magnetic fields; 3. requiring the undergrounding of network utilities in new areas of urban development (other than the National Grid) ; 4. mitigating adverse visual effects through landscaping and/or the use of recessive colours and finishes; and 5. requiring encouraging network utilities to adopt sensitive design to integrate network utilities within the site, existing built form and/or landform and to maintain the character and amenity of the surrounding area where practicable.
NU-P5 Support with This policy appropriately gives effect to INF Policy 1 in the Regional Policy Statement for Taranaki, by recognising Transpower’s preference is for a new National Grid specific policy NU-Pxx (refer amendments that it is not always practicable to avoid, remedy or mitigate adverse effects, particularly when there are technical above submission point). Should this not be granted, amendments are sought to Ensure that network utilities avoid, remedy or mitigate adverse effects on the and operational requirements associated with network utilities. the Policy NU-P5 as follows: environment, while recognising the functional need or operational needs of the network utility, and having regard to: NU-P5(1) gives appropriate effect to Policy 4 of the NPSET. The retention of the words “operational needs” is Ensure that nNetwork utilities should avoid, remedy or mitigate adverse effects important given that the definition of that term in this Plan includes technical constraints and requirements. This on the environment as far as is practicable, while recognising the functional aligns with Policy 3 of the NPSET. need or operational needs of the network utility, and having regard to:
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment 1. the extent to which adverse effects have been addressed through site, route or The reference to “as far as is practicable” is due to the Regional Policy Statement Policy INF 1 which states 1. the extent to which adverse effects have been addressed through site, route method selection and/or the extent to which the network utility is constrained by “….provision for any adverse effects of their establishment to be avoided, remedied or mitigated as far as is or method selection and/or the extent to which the network utility is constrained functional or operational needs; practicable”. by functional or operational needs; 2. the necessity of the network utility, including: 2. the necessity of the network utility, including: a. the need to quickly repair and restore disrupted services; Transpower prefers the approach of including a new Policy NU-Pxx as outlined elsewhere in this submission that is a. the need to quickly repair and restore disrupted services; b. the impact of not operating, repairing, maintaining, upgrading, removing specific to the National Grid, however if that submission point is not accepted then Transpower seeks amendments b. the impact of not operating, repairing, maintaining, upgrading, or developing the network utility; to NU-P5 to recognise the National Grid and give effect to the NPSET. removing or developing the network utility; 3. the time, duration or frequency of adverse effects: 3. the time, duration or frequency of adverse effects: 4. the location of existing network utilities, including: The new clause (5) gives effect to NPSET Policy 5. 4. the location of existing network utilities, including: a. the complexity and connectedness of the networks and services; a. the complexity and connectedness of the networks and services; b. the potential for co-location and shared use of network utility corridors; The new clause (6) gives effect to NPSET Policy 7. b. the potential for co-location and shared use of network utility corridors; and and 5. anticipated outcomes for the receiving environment, including the role, function The new clause (7) gives effect to NPSET Policy 8. 5. anticipated outcomes for the receiving environment, including the role, and predominant character of the underlying zone. function and predominant character of the underlying zone. 5. enabling the operational, maintenance and minor upgrade requirements of the National Grid; 6. seeking to avoid adverse effects of the development of the National Grid.
NU-P6 Support with Transpower supports the intent of NU-P6. Although NU-P6 partially addresses Policy 10 and 11 of the NPSET, and Amend Policy NU-P6 as follows: amendments. INF Policy 3 of the Regional Policy Statement for Taranaki, Transpower considers that the wording needs to be Require activities within the National Grid Yard and National Grid Corridor to be amended to more fully reflect the intext of these higher order planning directives. INF Policy 3 of the RPS states Require activities Subdivision, use and development within the National Grid undertaken so that it: that “development incompatible with the National Grid is not located within buffer corridors” and thereby Yard, and National Grid Subdivision Corridor and National Grid Substation 1. ensures that the safe and efficient operation, maintenance, repair, upgrading or ensuring that “reverse sensitivity effects are avoided”. Policy 10 of the NPSET also seeks to “avoid reverse Corridor must to be undertaken so that it: development of the National Grid is not compromised sensitivity effects” to ensure that the “operation, maintenance, upgrading, and development of the electricity 1. ensures that the not compromise the safe and efficient operation, 2. avoids establishment or expansion of activities sensitive to transmission lines in transmission network is not compromised”. The amendments sought to NU-P6 more appropriately give effect to maintenance, repair, upgrading or development of the National Grid is not the National Grid Yard these two documents. compromised 3. achieves compliance with the New Zealand Electrical Code of Practice for 2. avoids the establishment, changes to or expansion of sensitive activities Electrical Safe Distances (NZECP 34:2001) The Plan contemplates a National Grid Substation Corridor and this is marked on the planning maps, but there is sensitive to transmission lines and intensive indoor primary production within 4. provides security of supply and/or maintains the integrity of National Grid assets no policy framework to support the rules such as NU-R35 and NU-R37. the National Grid Yard and National Grid Substation Corridor 5. maintains ongoing access to conductors and support structures for maintenance 3. manage subdivision within the National Grid Subdivision Corridor and and upgrading works Clause 4 is intended to provide directions for controls on earthworks. National Grid Substation Corridor to avoid subsequent land use activities from 6. manages all activities to avoid exposure to health and safety risks from the compromising the operation, maintenance, upgrading and development of the National Grid Transpower seeks other amendments as outlined to improve the clarity and readability of the policy. National Grid 7. limits, as far as practicable, potential for reserve sensitivity effects on the National 4. managing the location of development around National Grid transmission Grid. lines to ensure that the safety and efficiency of the National Grid is not compromised; 3 5. achieves complyiance with the New Zealand Electrical Code of Practice for Electrical Safe Distances (NZECP 34:2001) 4 6. Provides maintain security of supply and/or maintains the integrity of National Grid assets 5 7. Maintains ongoing access to conductors and support structures for maintenance and upgrading works 6 8. Manages all activities to avoid exposure to health and safety risks from the National Grid 7 9. Limits, as far as practicable, avoid potential for reserve sensitivity effects on the National Grid. NU-P8 Support This policy is aligned with INF Policy 2 of the Regional Policy Statement for Taranaki which requires the adverse Amend Policy NU-P8 as follows: effects of subdivision, use and development on the safety, efficiency, operation, maintenance and upgrading of the Ensure new sensitive activities are appropriately located and/or designed to region’s network utilities to be avoided or mitigated. Transpower supports the recognition and management of Ensure new sensitive activities are appropriately located and/or designed to minimise reverse sensitivity effects on network utilities, where necessary, including reverse sensitivity with regards to network utilities through a policy framework and considers this is an efficient minimise reverse sensitivity effects on network utilities, where necessary, by requiring compliance with NZECP 34:2001. way to achieve INF Policy 2 of the Regional Policy Statement. including by requiring compliance with NZECP 34:2001.
Reverse sensitivity effects are not just limited to sensitive activities however and Transpower seeks amendments to broaden the applicability of this policy. New policy Amend Recognising the benefits of network utilities is an effective was to achieve INF Objective 1 and INF Policy 2 of the Add the following new policy to the Network Utilities chapter: Regional Policy Statement for Taranaki. In addition, Policy 1 of the NPSET requires decision-makers to recognise and provide for the national, regional and local benefits of sustainable, secure and efficient electricity NU-PY transmission. A new policy focused on the benefits of network utilities will give effect to these higher order planning documents. Recognise the positive social, economic and environmental benefits of network utilities to the community and require these to be considered in assessing the adverse effects of proposals.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment New policy Amend A new policy is necessary which acknowledges the constraints to a network and that in some situations there is Add the following new policy to the Network Utilities chapter: very little choices available for location or methods. This policy gives effect to Policies 3 and 8 of the National Policy Statement for Electricity Transmission. It is gives effect to INF Objective 1 and INF Policy 1 of the Regional Policy NU-PZ Statement for Taranaki. Recognise that the National Grid may require a location within sensitive natural environments where there are no practicable alternatives available, and the network utilities will result in significant social and/or economic benefits NU rules Amend This approach of referring to policies as matters over which discretion is restricted is not best practice planning. Delete all references to NU-P4 and NU-P5 in all Restricted Discretionary rules in All of the rules that relate to Restricted Discretionary activities refer to policies NU- Not all of the sub-clauses in these policies will be relevant or appropriate. A better approach is for the relevant the Network Utilities chapter, and replace these with relevant and appropriate P4 and NU-P5 as matters over which discretion is restricted. clauses in NU-P4 and NU-P5 to be inserted into the matters over which discretion is restricted. matters over which discretion is restricted. NU-R1 Amend The activity status is not explicitly stated. In terms of giving effect to INF Objective 1, this should be a permitted Amend Rule NU-R1 as follows: activity with no standards, reflective of Section 10 of the RMA in terms of an existing use. Operation, maintenance and repair, or removal of above and underground network Operation, maintenance and repair, or removal of above and underground utilities and ancillary vehicle access tracks The provision of a permitted activity rule for the ongoing operation, maintenance, repair and removal of existing network utilities and ancillary vehicle access tracks infrastructure is supported as it recognises existing infrastructure and provides for its ongoing use. Activity status: PER
A permitted activity status is consistent with the activity status provided within the NESETA. NU-R2 Support with Retain the permitted activity status for underground network utilities in Rule amendments Transpower supports the permitted activity status for underground network utilities. NU-R2 Underground network utilities (including customer connections), and upgrading of underground network utilities, not provided for by another rule in this table It is not clear whether this rule relates to undergrounding of existing network utilities, or new network utilities that Amend Rule NU-R2 as follows: are to be located below ground. The rule needs to be clear. All zones New Uunderground network utilities (including customer connections), and Only two of the Network Utility Effects Standards are appropriate to underground network utilities – being radio upgrading of underground network utilities, not provided for by another rule in Activity status: PER frequency and electric and magnetic fields. this table
Where: The matters set out in NU-P4 and NU-P5 are not relevant. All zones 1. all structures that are no longer required for network utility purposes are removed within six months of being replaced or becoming redundant; and Activity status: PER 2. all Network Utilities Effects Standards are complied with. Where: Activity status where compliance not achieved: RDIS 1. all structures that are no longer required for network utility purposes are removed within six months of being replaced or becoming redundant; and Matters over which discretion is restricted: 2. all Network Utilities Effects Standards are complied with. The radio frequency standards in NU-S3 are complied with; and 1. The functional and operational needs of, and benefits derived from, the network 3. The electric and magnetic fields in NU-S4 are complied with. utility, including the potential impact on the levels of service or health and safety if the work is not undertaken. Activity status where compliance not achieved: RDIS 2. The extent and effect of non-compliance with any relevant Network Utilities Effects Standards and the matters of discretion for the infringed Effects Standard(s). Matters over which discretion is restricted: 3. The matters set out in NU-P4 and NU-P5. 1. The functional and operational needs of, and benefits derived from, the network utility, including the potential impact on the levels of service or health and safety if the work is not undertaken. 2. The extent and effect of non-compliance with any relevant Network Utilities Effects Standards and the matters of discretion for the infringed Effects Standard(s). 3. The matters set out in NU-P4 and NU-P5. NU-R3 Support with A permitted activity status for the upgrading of existing infrastructure is supported as it appropriately recognises Retain the permitted activity status for NU-R3 Upgrading of aboveground amendments existing infrastructure and enables its ongoing use in accordance with INF Objective 1 in the Regional Policy network utilities Upgrading of aboveground network utilities Statement for Taranaki. Activity status: PER Specific to the National Grid, the NESETA provides for various ‘upgrade’ works as permitted activities. While there Where: are some inconsistencies with the conditions within NU-R3 and the NESETA, given the NESETA prevails over the PNPDP provisions, NU-R3 is of limited relevance to the National Grid. 1. the realignment, relocation or replacement of a line, pipe (excluding a liquid petroleum or gas transmission pipeline), telecommunication pole, pole, tower, conductor, switch, transformer or ancillary structure is within 5m of the existing alignment or location; Support with The approach of referring to policies as matters over which discretion is restricted is not best practice planning. Amend the matters of discretion for NU-R3 as follows: 2. a pole is not replaced with a tower; amendments Not all of the sub-clauses in Policies NU-P4 and NU-P5 are relevant or appropriate. A better approach is for the 1. The functional and operational needs of, and benefits derived from, the 3. a replacement pole, tower or telecommunication pole does not exceed the height relevant clauses in NU-P4 and NU-P5 to be inserted in the matters over which discretion is restricted. network utility, including the potential impact on the levels of service or health of the replaced pole or tower or telecommunication pole by: and safety if the work is not undertaken. a. more than 15 percent; or
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment b. the maximum structure height for the underlying zone set out in NU-S1; 2. The bulk, height, location and design of the network utility, including any 4. the diameter or width of a replacement pole or telecommunications pole: associated buildings or structures. a. does not exceed twice that of the replaced pole at its widest point; or 3. The amenity values of the respective zone and the extent to which any b. where a single pole is replaced with a pi pole, the width of the pi pole adverse visual amenity effects can be avoided, remedied or mitigated. structure must not exceed three times the width of the replaced pole at its 4. Site reinstatement and replanting widest point; 5. The duration, timing, and frequency of adverse effects. 5. a replacement tower's footprint does not exceed the width of the tower by more 6. The extent and effect of non-compliance with any relevant Network Utilities than 25 percent; Effects Standards and the matters of discretion for the infringed Effects 6. there are no additional towers; Standard(s). 7. an additional pole, up to a maximum of two poles, is necessary to achieve the 7. The matters set out in NU-P4 and NU-P5. The location of existing network conductor clearances required by NZECP 34:2001; utilities, including the need for connected networks and services. 8. the realignment, relocation of replacement of any other network utility structure or building: a. must be within 5m of the alignment or location of the original structure or building b. must not increase the footprint of the structure or building by greater than 30 percent; and 9. all Network Utilities Effects Standards are complied with.
Matters over which discretion is restricted:
1. The functional and operational needs of, and benefits derived from, the network utility, including the potential impact on the levels of service or health and safety if the work is not undertaken. 2. The bulk, height, location and design of the network utility, including any associated buildings or structures. 3. The amenity values of the respective zone and the extent to which any adverse visual amenity effects can be avoided, remedied or mitigated. 4. Site reinstatement and replanting 5. The duration, timing, and frequency of adverse effects. 6. The extent and effect of non-compliance with any relevant Network Utilities Effects Standards and the matters of discretion for the infringed Effects Standard(s). 7. The matters set out in NU-P4 and NU-P5. NU-R4 Vehicle access tracks for network utilities Support with A permitted activity status for the vehicle access tracks to support network utilities is supported as it appropriately Retain the permitted activity status for access tracks associated with network amendments recognises the importance of network utilities and enables its ongoing use in accordance with INF Policy 1 in the utilities in Rule NU-R4 All zones Regional Policy Statement for Taranaki. Activity status: PER
Note: Support with The NESETA provides for access tracks to an existing transmission line as a permitted activity (outside natural Amend Rule NU-R4 as follows: Earthworks for vehicle access tracks for network utilities are provided for in EW-R9 amendments areas). While there are some inconsistencies with the conditions within NU-R4 and the NESETA, given the NESETA and there are additional rules in the Overlay Chapters that may be applicable. prevails over the PNPDP provisions, NU-R4 is of limited relevance to the National Grid. The rule would however Vehicle access tracks for network utilities apply to substations, and new electricity transmission lines that have been installed after 14 January 2010. All zones Activity status where compliance not achieved: N/A Activity status: PER Transpower considers it is more efficient for all rules regarding vehicle access tracks to be combined into the Network Utility chapter rather than being scattered across other chapters in the Plan. As network utilities are Where: linear and may span several titles, the focus should be on the amount of earthworks open at any one time rather 1. the total earthworks area open at any one time, does not exceed 500m2; than the depth or volume. Thus the standards of Rule EW-R9 should be imported into Rule NU-R4 and the EW-R9 2. the earthworks area is progressively stabilised, filled and/or recontoured as deleted. soon as practicable;
Activity status where compliance not achieved: RDIS
Matters over which discretion is restricted:
1. The functional and operational needs of, and benefits derived from, the works, including the potential impact on the levels of service if the work is not undertaken. 2. Effects on land stability and amenity values resulting from the timing and duration of works.
Note: Earthworks for vehicle access tracks for network utilities are provided for in EW- R9 and there are additional rules in the Overlay Chapters that may be applicable.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment
AND
Delete Rule EW-R9. NU-R5 Aboveground customer connections Amend The rule does not provide clarity of what activity is intended to be controlled. It is likely that the rule is intended to Amend Rule NU-R5 to be clearer about the activity which it is seeking to control. control individual service connections to a site but the rule as it is currently drafted is not clear that this is the (1) Residential Zones intent. If this is the intent, then the permitted activity status is supported. AND Commercial and Mixed Use Zones Include a definition for “customer connections”. Activity status: PER
Where:
1. the connection does not include a new tower; 2. the connection does not exceed three additional poles; and 3. all Network Utilities Effects Standards are complied with.
Activity status where compliance not achieved: RDIS
Matters over which discretion is restricted:
1. The purpose, necessity and location of the aboveground customer connection. 2. The potential adverse visual effects of the aboveground connection, including impacts on the amenity values of the locality, and any contribution to cumulative adverse effects. 3. The extent and effect of non-compliance with any relevant Network Utilities Effects Standards and the matters of discretion for the infringed Effects Standard(s). 5. The matters set out in NU-P4 and NU-P5.
(2) Rural Zones Special Purpose Zones General Industrial Zone Open Space and Recreation Zones
Activity status: PER
Where:
1. all Network Utilities Effects Standards are complied with. Activity status where compliance not achieved: RDIS
Matters over which discretion is restricted:
1. The purpose, necessity and location of the aboveground customer connection. 2. The potential adverse visual effects of the connection, including impacts on the amenity values of the locality, and any contribution to cumulative adverse effects. 3. The extent and effect of non-compliance with any relevant Network Utilities Effects Standards and the matters of discretion for the infringed Effects Standard(s). 4. The matters set out in NU-P4 and NU-P5. NU-R6 Temporary network utilities Support with A permitted activity status for temporary activities is supported as it recognises that in some circumstances, Retain the permitted activity status for temporary network utilities in Rule NU- amendments temporary infrastructure is required to either support existing infrastructure or facilitate the development of new R6 Activity status: PER infrastructure.
Where: A permitted activity status reflects Regulation 17 of the NESETA. 1. the temporary network utility operates for a maximum of 12 months; 2. all temporary network utilities and associated buildings and structures are removed from the site on completion of the works; and Support with The matters over which discretion is restricted should be focused on the area of non-compliance with the Amend NU-R6 Temporary network utilities as follows: 3. all Network Utilities Effects Standards are complied with. amendments standards. There are no standards which control the scale of the temporary network utility so the matters of discretion need to relevant for both large and small scale activities. Activity status: PER Note: References to Policy NU-P4 and NU-P5 are not appropriate as matters of discretion, and have limited relevance to Where: Where relevant, the area must be reinstated in accordance with conditions specified this activity. 1. the temporary network utility operates for a maximum of 12 months; in the National Code of Practice for Utility Operators' Access to Transport Corridors.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment 2. all temporary network utilities and associated buildings and structures are Activity status where compliance not achieved: RDIS removed from the site on completion of the works; and 3. all Network Utilities Effects Standards are complied with. Matters over which discretion is restricted: Note: 1. The functional and operational needs of, and benefits from, the temporary network utility, including the potential impact on the levels of service or health and Where relevant, the area must be reinstated in accordance with conditions safety if the work is not undertaken. specified in the National Code of Practice for Utility Operators' Access to 2. The bulk, height, location and design of the network utility, including any Transport Corridors. associated buildings or structures. 3. The amenity values of the respective zone and the extent to which any adverse Activity status where compliance not achieved: RDIS visual amenity effects can be avoided, remedied or mitigated. 4. The extent and effect of non-compliance with any relevant Network Utilities Matters over which discretion is restricted: Effects Standards and the matters of discretion for the infringed Effects Standard(s). 5. The matters set out in NU-P4 and NU-P5 1. The functional and operational needs of, and benefits from, the temporary network utility, including the potential impact on the levels of service or health and safety if the work is not undertaken. 2. The bulk, height, location and design of the network utility, including any associated buildings or structures. 3. The amenity values of the respective zone and the extent to which any adverse visual amenity effects can be avoided, remedied or mitigated. 4. The extent and effect of non-compliance with any relevant Network Utilities Effects Standards and the matters of discretion for the infringed Effects Standard(s). 5. The matters set out in NU-P4 and NU-P5 5. The necessity of the temporary network utility. 6. The time, duration or frequency of adverse effects. 7. The location of existing network utilities, including the need for connections to existing networks and services.
NU-R7 Substations (including switching stations) not enclosed by a building Amend This activity does not have an explicit activity status, and clarification of the activity status is sought. Amend Rule NU-R7 to make the activity status clear as follows:
As outlined earlier in this submission relating to higher level policy documents, the PNPDP is required to give effect NU-R7 New Substations (including switching stations) not enclosed by a building to the NPSET. Policy 8 of the NPSET directs that within rural environments planning and development of the National Grid should seek to avoid adverse effects on certain identified environments (being outstanding natural All zones landscapes, area of high natural character and recreation values and amenity and existing sensitive activities) areas. The wording of NPSET Policy 8 (“should seek to avoid”) does not impose an absolute requirement for the Activity status: PER National Grid to avoid all adverse effects. Rather, the NPSET recognises total avoidance is not always possible given the technical and operational requirements of the National Grid (as recognised in Policy 3 of the NPSET). On this basis, given the locational constraints and the national significance of the National Grid (as provided for in the NPSET), Transpower supports an enabling activity status for new substations and switching stations associated with the National Grid.
For clarity, it is recommended that this activity cover new substations and switching stations to distinguish from the rule for upgrades.
NU-R10 New network utilities in existing buildings Support with A permitted activity status is considered appropriate for new network utilities in existing buildings, particularly Retain the permitted activity status for new network utilities in existing amendments given the absence of effects. This allows for adaptive re-use of existing buildings. buildings in Rule NU-R10 All zones
Activity status: PER Support with Transpower consider that all new network utilities should comply with NU-S3 Radio frequency fields and NU-S4 Amend Rule NU-R10 New network utilities in existing buildings as follows: amendments electric and magnetic fields. Activity status where compliance not achieved: N/A All zones
Activity status: PER
Where: 1. Effects standard NU-S3 Radio frequency fields is complied with; and 2. Effects standard NU-S4 electric and magnetic fields is complied with.
Activity status where compliance not achieved: N/A Non complying
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment NU-R18 Aboveground network utilities (including network utility buildings and Support with Transpower supports the permitted activity status for small aboveground network utilities. This is an appropriate Retain Rule NU-R18 (including network utility buildings and enclosed enclosed substations) not provided for by another rule in this table amendments way to achieve INF Objective 1 and INF Policy 1 of the Regional Policy Statement for Taranaki. substations) not provided for by another rule in this table as notified, with the exception of Matter of Discretion (7) All zones Transpower also supports the cascade to restricted discretionary activity upon non-compliance with any of the standards. AND Activity status: PER References to Policy NU-P4 and NU-P5 are not appropriate as matters of discretion, and are largely already Amend Matter of Discretion (7) for Rule NU-R18 (including network utility Where: covered by the matters of discretion. buildings and enclosed substations) not provided for by another rule in this table as follows: 1. the maximum building and structure height for the underlying zone is complied with, or the building does not exceed a height of 10 metres, whichever is greater. Matters over which discretion is restricted: 2. the building does not exceed a footprint of 20m2. 3. the building is set back 2 metres from any site boundary in a Residential Zone; and 1. The functional and operational needs of, and benefits from, the network 4. all Network Utilities Effects Standards are complied with. utility, including the potential impact on the levels of service or health and safety if the work is not undertaken Activity status where compliance not achieved: RDIS 2. The extent and effect of non-compliance with any relevant rule or standard and any relevant matters of discretion in the infringed rule(s) or standard(s). Matters over which discretion is restricted: 3. The bulk, height, location and design of the network utility, including any associated buildings or structures. 1. The functional and operational needs of, and benefits from, the network utility, 4. The amenity values of the respective zone and the extent to which any including the potential impact on the levels of service or health and safety if the adverse visual amenity effects can be avoided, remedied or mitigated, including: work is not undertaken a. any innovative design that integrates the network utility within the 2. The extent and effect of non-compliance with any relevant rule or standard and site, existing built form and/or landform in a way that assists to any relevant matters of discretion in the infringed rule(s) or standard(s). maintain the character and amenity of the surrounding area. 3. The bulk, height, location and design of the network utility, including any b. whether the use of landscaping and/or recessive colours and associated buildings or structures. finishes can assist to mitigate any adverse effects. 4. The amenity values of the respective zone and the extent to which any adverse 5Whether the works may result in public health and/or safety risks. visual amenity effects can be avoided, remedied or mitigated, including: 6. The extent, nature and effects of earthworks and vegetation clearance and a. any innovative design that integrates the network utility within the site, any related adverse ecological effects. existing built form and/or landform in a way that assists to maintain the 7. The matters set out in NU-P4 and NU-P5. The location of existing network character and amenity of the surrounding area. utilities, including the need for connections to existing networks and services. b. whether the use of landscaping and/or recessive colours and finishes can assist to mitigate any adverse effects. 5Whether the works may result in public health and/or safety risks. 6. The extent, nature and effects of earthworks and vegetation clearance and any related adverse ecological effects. 7. The matters set out in NU-P4 and NU-P5. NU-R20 Network utilities emitting electric and magnetic fields Oppose This is not an activity in of itself; rather it is a standard which all network utilities must comply. A more appropriate Delete Rule NU-R20 Network utilities emitting electric and magnetic fields approach would be to require all activities specifically to comply with NU-S4 by including it as a standard on each All zones activity. Many of the activities that must “comply with all the network utilities effects standards” already have this AND requirement. Activity status: PER Add to every network utility activity a requirement to comply with Network Transpower notes that the NESETA already contains electric and magnetic field standards for existing transmission Utilities Effects Standard NU-S4 (other than those activities which already must Where: assets. comply with all of the Network Utilities Effects Standards). compliance with NU-S4 is achieved.
Activity status where compliance not achieved: NC NU-R21 Network utilities generating radiofrequency fields Oppose This is not an activity in of itself; rather it is a standard which all network utilities must comply. A more appropriate Delete Rule NU-R21 Network utilities generating radiofrequency fields approach would be to require all activities specifically to comply with NU-S3 by including it as a standard on each All zones activity. Many of the activities that must “comply with all the network utilities effects standards” already have this AND requirement. Activity status: PER Add to every network utility activity a requirement to comply with Network Utilities Effects Standard NU-S3 (other than those activities which already must Where: comply with all of the Network Utilities Effects Standards). compliance with NU-S3 is achieved.
Activity status where compliance not achieved: NC NU-R22 Electricity lines and associated support structures (including poles and Support with This rule as it is currently drafted would apply to underground and overhead electricity lines. Amendments are Amend Rule NU-R22 as follows: towers) that convey electricity of 110kV or above amendments sought to increase the clarity of application of the rule. Given that rule NU-R2 applies to all underground network utilities, it is appropriate for this rule to focus on aboveground electricity lines. Aboveground Eelectricity lines and associated support structures (including poles All zones and towers) that convey electricity of 110kV or above, A restricted discretionary activity status is supported for electricity lines and support structures at or over 110kV Activity status: RDIS carrying capacity aboveground. All zones
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment
Matters over which discretion is restricted: Linear electricity networks will span more than one site, so matter of discretion (3) needs to be amended to reflect Activity status: RDIS this. Matter of discretion (3) also needs to be relevant to the practicalities of the network and recognise that 1. The functional and operational needs of, and benefits from, the network utility, landscaping will not address adverse effects associated with electricity lines and structures. Matters over which discretion is restricted: including the potential impact on the levels of service or health and safety if the work is not undertaken. There are no standards to which the activity must comply, therefore this needs to be reflected in the matters of 1. The functional and operational needs of, and benefits from, the network 2. The bulk, height, location and design of the network utility, including any discretion. utility, including the potential impact on the levels of service or health and safety associated buildings or structures. if the work is not undertaken. 3. The amenity values of the respective zone and the extent to which any adverse The approach of referring to policies as matters over which discretion is restricted is not best practice planning. 2. The bulk, height, location and design of the network utility, including any visual amenity effects can be avoided, remedied or mitigated, including: Not all of the sub-clauses in Policies NU-P4 and NU-P5 are relevant or appropriate. A better approach is for the associated buildings or structures. a. any innovative design that integrates the network utility within the site, relevant clauses in policies NU-P4 and NU-P5 to be inserted in the matters over which discretion is restricted. 3. The amenity values of the respective zone and the extent to which any existing built form and/or landform in a way that assists to maintain the adverse visual amenity effects can be avoided, remedied or mitigated, including: character and amenity of the surrounding area. Policies 7 and 8 of the NPSET contain matters which must be considered in urban and rural environments. These a. any innovative design that integrates integration of the network b. whether the use of landscaping and/or recessive colours and finishes should be reflected in the matters of discretion. utility within the site, existing built form and/or landform in a way that can assist to mitigate any adverse effects. assists to maintain the character and amenity of the surrounding area. 4. Whether the works may result in public health and/or safety risks. b. whether the use of landscaping and/or recessive colours and 5. The extent and effect of non-compliance with any relevant rule or standard and finishes can assist to mitigate any adverse effects. any relevant matters of discretion in the infringed rule(s) or standard(s). 4. Whether the works may result in The level of public health and/or safety risks. 6. The matters set out in NU-P4 and NU-P5. 5. The extent and effect of non-compliance with any relevant rule or standard and any relevant matters of discretion in the infringed rule(s) or standard(s). 6. The matters set out in NU-P4 and NU-P5. 5. Compliance with recognised standards or guidelines for the potential adverse effects of noise, vibration, radiofrequency fields and electric and magnetic fields; 6. The extent to which adverse effects have been addressed through site, route or method selection; 7. The necessity of the network utility; 8. The location of existing network utilities, including the need for connection of the networks and services; 9. The level of adverse effects on urban amenity, particularly town centres and areas of high recreational value or amenity and existing sensitive activities; 10. The level of adverse effects in rural environments on outstanding natural landscapes, areas of high natural character and areas of high recreation value and amenity and existing sensitive activities.
NU-R32 Buildings or structures within the National Grid Yard (where under-build or Support with Transpower supports the provision of permitted activity rules which is based on the corridor management Amend Rule NU-R32 as follows: development exists) amendments approach. The 12m width for land use (identified as the National Grid Yard) is calculated as the distance from the centreline between the support structures to the point where the conductor would swing under everyday NU-R32 Buildings or structures within the National Grid Yard (where under-build Residential Zones conditions (noting that maintenance is not generally undertaken in high wind conditions). or development exists) General Industrial Zone Open Space or Recreation Zones This approach is consistent with Policies 10 and 11 in the NPSET. Residential Zones Major Facility Zones General Industrial Zone In terms of development within existing urban zones where a site has existing under-build, Transpower supports Open Space or Recreation Zones Activity status: PER the recognition of existing sensitive land uses and the approach that such existing activities and structures are Major Facility Zones permitted, as well as new non-habitable and non-sensitive structures or buildings in these situations. Amendments Where, on sites where under-build or development within the National Grid Yard are sought to the rule to clarify the intent of the provisions. A standard is also inserted requiring that any new Activity status: PER was existing as at [date that the Proposed Plan becomes operative] and where the structures or buildings not permanently physically impede existing vehicular access to a National Grid support building or structure maintains safe electrical distances required by NZECP34:2001 structure. Such a condition would ensure physical access is maintained to the line and assets to enable the ongoing Where, oOn sites where there is existing under-build or development within the in all National Grid line operating conditions, provided that: operation, maintenance and upgrade of the National Grid. National Grid Yard was existing as at [date that the Proposed Plan becomes operative] and where the proposed building or structure maintains safe 1. Under the National Grid conductors (wires): electrical distances required by NZECP34:2001 in all National Grid line operating a. any alterations or additions to an existing building or structure for a conditions and does not permanently physically impede existing vehicular access sensitive activity do not involve an increase in the building height or to a National Grid support structure, provided that: footprint; and b. any new or relocated building or structure is not for a sensitive activity; 1. Under the National Grid conductors (wires) Within the National Grid Yard: or a. any alterations or additions to an existing building or structure for a c. it is a network utility undertaken by a network utility operator (other sensitive activity does not involve an increase in the building or than for the reticulation and storage of water in canals, dams or reserviors structure height or footprint; or including for irrigation purposes). b. any new or relocated building or structures, or additions is not for a 2. Around the National Grid support structures, the building or structure is at least sensitive activity; or 12 m from outer visible edge of any National Grid tower or pole and associated stay c. it is a network utility undertaken by a network utility operator (other wire, unless it is one of the following: than for the reticulation and storage of water in canals, dams or reserviors reservoirs including for irrigation purposes). or
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment a. a network utility undertaken by a network utility operator (other than e. it is an accessory building or structure (excluding buildings for the reticulation and storage of water in canals, dams or reservoirs containing sleeping areas) for a sensitive activity; or including for irrigation purposes); or f. fences are less than 2.5m in height. b. a fence no greater than 2.5 m high and: i. no closer than 5 metres to the nearest National Grid pole; or 2. Around the National Grid support structures, the building or structure is at ii. no closer than 6 metres to the nearest National Grid tower; or least 12 m from outer visible edge of any National Grid tower or pole support c. a building or structure where Transpower has given written approval in structure and associated stay wire and not permanently physically impede accordance with clause 2.4.1 of NZECP34:2001. existing vehicular access to a National Grid support structure, unless it is one of the following: a. a network utility undertaken by a network utility operator (other Note: than for the reticulation and storage of water in canals, dams or reservoirs including for irrigation purposes); or If a resource consent application is made under this rule, Transpower will be b. a fence no greater than 2.5 m high and: considered an affected person in accordance with Section 95E of the Act and notified i. no closer than 5 metres to the nearest National Grid pole; of the application, where written approval is not provided. or ii. no closer than 6 metres to the nearest National Grid Activity status where compliance not achieved: NC tower; or c. a building or structure where Transpower has given written approval in accordance with clause 2.4.1 of NZECP34:2001.
Note: If a resource consent application is made under this rule, Transpower will be considered an affected person in accordance with Section 95E of the Act and notified of the application, where written approval is not provided.
Activity status where compliance not achieved: NC NU-R33 Buildings or structures within the National Grid Yard (where under-build or Support with Transpower supports the provision of permitted activity rules which is based on the corridor management Amend Rule NU-R33 as follows: development does not exist) amendments approach. The 12m width for land use (identified as the National Grid Yard) is calculated as the distance from the centreline between the support structures to the point where the conductor would swing under everyday NU-R33 Buildings or structures within the National Grid Yard (where under-build All zones conditions (noting that maintenance is not generally undertaken in high wind conditions). or development does not exist) not covered by Rule NU-R32
Activity status: PER This approach is consistent with Policies 10 and 11 in the NPSET. All zones
Where, in the zones not listed NU-R32, or on-sites where under-build or Within Rural and other zones not covered by Rule NU-R32, Transpower is satisfied that there are some activities Activity status: PER development within the National Grid Yard did not exist at [date that the Proposed that are appropriate within the National Grid Yard due to their nature and small scale, and because they will not Plan becomes operative] and where the building or structure maintains safe compromise the operation, maintenance or any upgrade of the network itself. Certain structures (such as rural hay Where, in the zones not listed NU-R32, or on-sites on sites where under-build or electrical distances required by NZECP34:2001 in all National Grid line operating barns, pump sheds and implement sheds) are less problematic within 12m of the line (noting that they will still development within the National Grid Yard did not exist at [date that the conditions, provided that: need to be set back 12m from National Grid support structures) on the basis they are unlikely to “build out” a line. Proposed Plan becomes operative] and where the proposed building or structure The notified provisions allow for paddocks, fencing (as high as deer fences), landscaping and small sheds, and maintains safe electrical distances required by NZECP34:2001 in all National 1. Under the National Grid conductors (wires): larger farm buildings in proximity to conductors not used for intensive farming purposes. Grazing, cropping, and Grid line operating conditions and does not permanently physically impede a. any alteration or addition to an existing building or structure for a car parking activities are not restricted. existing vehicular access to a national grid support structure, provided that: sensitive activity does not involve an increase in the building height or Conversely, examples of development that has severely restricted or blocked Transpower’s ability to effectively footprint; or access its assets include dairy sheds, piggeries, poultry sheds and commercial hothouses and glass houses, as well 1. Under Within the National Grid Yard conductors (wires): b. it is a network utility undertaken by a network utility operator (other as sensitive activities. These activities can cover an extensive area of land, and it may be expensive to disrupt or a. any alteration or addition to an existing building or structure for a than for the reticulation and storage of water in canals, dams or reservoirs require these activities to be relocated while Transpower carries out work on its transmission assets. Amendments sensitive activity does not involve an increase in the building height or including for irrigation purposes); or are sought to the rule in the form of reformatting/restructuring to clarify the intent of the provisions. footprint; or c. it is a non-habitable building or structure for farming activities in rural b it is a network utility undertaken by a network utility operator (other zones (but not including any building for intensive indoor primary A standard is also inserted requiring that any new structures or buildings not permanently physically impede than for the reticulation and storage of water in canals, dams or production, commercial greenhouses or milking/dairy sheds); or existing vehicular access to a National Grid support structure. Such a condition would ensure physical access is reservoirs including for irrigation purposes); or d. it is a yard for milking/dairy sheds; or maintained to the line and assets to enable the ongoing operation, maintenance and upgrade of the National Grid. c. it is a non-habitable building or structure for farming activities in e. it is an artificial crop protection and support structure. rural zones (but not including any building for intensive indoor primary Transpower does not have any single pole supporting structures within New Plymouth and is not intending any production, commercial greenhouses or milking/dairy sheds, although 2. Around the National Grid support structures, the building or structure is at least new ones. The rule can be simplified to remove references to single pole support structures. ancillary buildings associated with these uses are permitted); or 12 m from outer visible edge of any National Grid tower or pole and associated stay d. it is a yard for milking/dairy sheds; or wire, unless it is one of the following: e. it is an artificial crop protection and or crop support structure 1. a network utility undertaken by a network utility operator (other than (excluding commercial greenhouses and PSA structures); or for the reticulation and storage of water in canals, dams or reservoirs f. it is a fence less than 2.5m in height. including for irrigation purposes); or 2. a fence no greater than 2.5 m high and: 2. Around the National Grid support structures, the building or structure is at i. no closer than 5 metres to the nearest National Grid pole; or least 12 m from the outer visible edge of any National Grid tower or pole ii. no closer than 6 metres to the nearest National Grid tower; or support structure foundation and associated stay wire, and not permanently 3. a building or structure where Transpower has given written approval in physically impede existing vehicular access to a National Grid support structure, accordance with clause 2.4.1 of NZECP34:2001. unless it is one of the following:
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment 3. Around National Grid support structures, it is an artificial crop protection or crop 1 a. a network utility undertaken by a network utility operator (other support structure between 8m and 12m from a pi-pole or single pole support than for the reticulation and storage of water in canals, dams or structure and any associated guy wire (but not a tower), that: reservoirs including for irrigation purposes); or a. is not more than 2.5m high; 2 b. a fence no greater than 2.5 m high and: b. is removable or temporary, to allow a clear working space 12 metres i. no closer than 5 metres to the nearest National Grid pole; from the pole when necessary for maintenance and emergency repair or purposes; and ii. no closer than 6 metres to the nearest National Grid tower c. allows all weather access to the pole and a sufficient area for support structure; or maintenance equipment, including a crane. 3 c. a building or structure where Transpower has given written approval in accordance with clause 2.4.1 of NZECP34:2001. Note: 3. Around National Grid support structures, it is an artificial crop protection or If a resource consent application is made under this rule, Transpower will be crop support structure between 8m and 12m from a pi-pole or single pole considered an affected person in accordance with Section 95E of the Act and notified support structure (but not a tower) and any associated guy wire (but not a of the application, where written approval is not provided. tower), that: Activity status where compliance not achieved: NC a. is not more than 2.5m high; b. is removable or temporary, to allow a clear working space 12 metres from the pole when necessary for maintenance and emergency repair purposes; and c. allows all weather access to the pole and a sufficient area for maintenance equipment, including a crane.; and d. meets the requirements of the NZECP34:2001 for separation distances from the conductor.
Note:
If a resource consent application is made under this rule, Transpower will be considered an affected person in accordance with Section 95E of the Act and notified of the application, where written approval is not provided.
Activity status where compliance not achieved or activity not specifically provided for: NC NU-R34 Earthworks within the National Grid Yard Support with Transpower supports the provision of permitted activity rules which is based on the corridor management Amend Rule NU-R34 as follows: amendments approach. The 12m width for land use (identified as the National Grid Yard) is calculated as the distance from the All zones centreline between the support structures to the point where the conductor would swing under everyday NU-R34 Earthworks and vertical holes within the National Grid Yard conditions (noting that maintenance is not generally undertaken in high wind conditions). Activity status: PER All zones This approach achieves Policies 2 and 10 of the NPSET in that it protects the integrity of the National Grid and the Where, within 12 metres of a National Grid support structure: ability to operate it. It also achieves INF Policy 2 and 3 of the Regional Policy Statement for Taranaki by ensuring Activity status: PER that the adverse effects of subdivision, use and 1. for National Grid support poles and any stay wires, the depth of the earthworks is: development on the safety, efficiency, operation, maintenance and upgrading of the National Grid is avoided. Where, within 12 metres of a Earthworks or vertical holes within the National a. no greater than 300mm within 2.2m of the pole or stay wire; or Grid Yard where support structure: b. no greater than 750mm between 2.2m and 5m of the pole or stay wire; Transpower supports the provision of permitted activity earthwork provisions on the basis such activities can compromise the National Grid and are a form of development contemplated by the NPSET. Amendments are 1. for National Grid support poles and any stay wires, the depth of the 2. for National Grid support towers (including any tubular steel tower that replaces sought to Rule NU-34 to simplify the rule and also recognise that the risks to the National Grid extend beyond earthworks is: a steel lattice tower), the depth of the earthworks is: those addressed by NZECP34. a. no greater than 300mm within 2.2m of the pole or stay wire; or a. no greater than 300mm within 6m of the outer edge of the visible b. no greater than 750mm between 2.2m and 5m of the pole or stay wire; foundation of the tower; or The National Planning Standard definition of earthworks specifically excludes the disturbance of land for the b. no greater than 3m between 6m and 12m of the outer edge of the installation of fence posts. For this reason, the rule needs to be amended to cover vertical holes. 2. 1. for around National Grid support structures (including any tubular steel visible foundation of the tower; and tower that replaces a steel lattice tower), the depth of the earthworks or vertical 3. the stability of the National Grid support structure is not compromised; hole is: 4. physical and practical access to the National Grid support structures is a. no greater than 300mm within 6m of the outer edge of the visible maintained; and foundation of the support structure; or 5. the earthworks do not result in a reduction in the ground to conductor clearance b. no greater than 3m between 6m and 12m of the outer edge of the distances, below what is required by Table 4 of NZECP34:2001. visible foundation of the support structure; and 3.2. the stability of the National Grid support structure is not compromised; Note: 4 3. physical and practical access to the National Grid support structures is maintained; and 1. Clause (1) or (2) above do not apply to earthworks or land disturbance: 5 4. the earthworks or vertical holes do not result in a reduction in the ground to a. undertaken by a network utility operator (other than for the reticulation and conductor clearance distances, below what is required by Table 4 of storage of water in canals, dams or reservoirs including for irrigation purposes); NZECP34:2001. b. undertaken as part of normal agricultural, horticultural or domestic cultivation, or repair, sealing or resealing of a road, footpath, driveway or farm track; Note:
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment c. involving vertical holes not exceeding 500mm in diameter, provided they: a. are more than 1.5m from the outer edge of the pole structure or stay 1. Clause (1) or (2) above do not apply to earthworks or land disturbance: wire; or a. undertaken by a network utility operator (other than for the reticulation and b. are a post hole for a farm fence or horticulture structure more than 6 m storage of water in canals, dams or reservoirs including for irrigation purposes); from the visible outer edge of the tower or support structure foundation; b. undertaken as part of normal agricultural, horticultural or domestic or cultivation, or repair, sealing or resealing of a road, footpath, driveway or farm d. are works for which a dispensation has been granted by Transpower under track; NZECP34:2001. c. involving vertical holes not exceeding 500mm in diameter, provided they: a i. are more than 1.5m from the outer edge of the pole support 2. If a resource consent application is made under this rule, structure or stay wire; or Transpower will be considered an affected person in accordance with Section 95E of b ii. are a post hole for a farm fence or horticulture structure more the Act and notified of the application, where written approval is not provided. than 6 m from the visible outer edge of the tower or support structure foundation; or Activity status where compliance not achieved: d. are works for which a dispensation has been granted by Transpower under NZECP34:2001. RDIS (for non-compliance with clause (1) or (2)) 2. If a resource consent application is made under this rule, Transpower will be NC in all other circumstances. considered an affected person in accordance with Section 95E of the Act and notified of the application, where written approval is not provided. Matters over which discretion is restricted: Activity status where compliance not achieved: 1. Effects on the operation, maintenance, upgrading and development of the National Grid RDIS (for non-compliance with clause (1) or (2)) 2. The risk to the structural integrity of the National Grid support structure(s). 3. Any impact on the ability to access the National Grid Matters over which discretion is restricted: 4. The risk of electrical hazards affecting public or individual safety and the risk of property damage. 1. Effects on the operation, maintenance, upgrading and development of the 5. The outcome of any consultation with the owner and operator of the National National Grid Grid. 2. The risk to the structural integrity of the National Grid support structure(s). 3. Any impact on the ability to access the National Grid 4. The risk of electrical hazards affecting public or individual safety and the risk of property damage. 5. The outcome of any consultation with the owner and operator of the National Grid. Technical advice provided by the National Grid owner (Transpower); 6. Any effects on National Grid support structures including the creation of an unstable batter;
NC in all other circumstances. NU-R35 New sensitive activities, including the erection of buildings for sensitive Amend Transpower supports the establishment of the National Grid Substation Corridor and considers this is an effective Amend Rule NU-R35 as follows: activities, within the National Grid Substation Corridor approach to achieving Policies 10 and 11 of the NPSET. However Policy 10 of the NPSET states that “manage activities to avoid reverse sensitivity effects on the electricity transmission network”. Avoiding reverse sensitivity NU-R35 New sensitive activities, including the erection of buildings for sensitive All zones effects is most effectively achieved by a non complying activity status for new sensitive activities in close proximity activities, within the National Grid Substation Corridor to the substation to limit the number of surrounding sensitive activities. Activity status: RDIS All zones The rule as it is currently drafted applies only to new sensitive activities and there is no companion rule that Matters over which discretion is restricted: applies to the extension of existing sensitive activities. For clarity, the rule is sought to be amended to address this 1. Any alteration or addition to an existing building or structure for a sensitive scenario. activity within the National Grid Substation Corridor that does not increase the 1. The extent to which the efficient operation, maintenance, upgrading and building height or footprint. development of the substation may be adversely affected. 2. The extent to which the building's location, design and layout enables appropriate Activity status: PER separation distances between sensitive activities and the National Grid lines and the substation. 3. The results of any detailed investigations to determine appropriate separation 2. Any alteration or addition to an existing building or structure for a sensitive distances between sensitive activities and the substation. activity within the National Grid Substation Corridor that increases the building 4. Any other measures proposed to avoid or mitigate potential adverse effects, height or footprint. including reverse sensitivity effects, on the substation. 3. Any new sensitive activity or building constructed for a sensitive activity 5. The risk of electrical hazards affecting public or individual safety, and the risk of within the National Grid Substation Corridor. property damage. Activity status: RDIS Note: Matters over which discretion is restricted:
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment If a resource consent application is made under this rule, Transpower will be 1. The extent to which the efficient operation, maintenance, upgrading and considered an affected person in accordance with Section 95E of the Act and notified development of the substation may be adversely affected. of the application, where written approval is not provided. 2. The extent to which the building's location, design and layout enables appropriate separation distances between sensitive activities and the National Activity status where compliance not achieved: N/A Grid lines and the substation. 3. The results of any detailed investigations to determine appropriate separation distances between sensitive activities and the substation. 4. 3. Any other measures proposed to avoid or mitigate potential adverse effects, including reverse sensitivity effects, on the substation. 5. 6. The risk of electrical hazards affecting public or individual safety, and the risk of property damage.
Note:
If a resource consent application is made under this rule, Transpower will be considered an affected person in accordance with Section 95E of the Act and notified of the application, where written approval is not provided.
Activity status where compliance not achieved: N/A NU-R36 Subdivision of land within the National Grid Corridor Support with Transpower supports the rules for subdivision within the National Grid (Subdivision) Corridor. Subdivision within Amend Rule NU-R36 as follows: amendments the National Grid Subdivision Corridor would be a restricted discretionary activity where the newly created lots are All zones capable of accommodating all building platforms outside the National Grid Yard. Where the subdivision application NU-R36 Subdivision of land within the National Grid Subdivision Corridor is unable to demonstrate that this can be achieved, a non-complying activity status would apply to the subdivision. Activity status: RDIS All zones A restricted discretionary activity status for subdivision provides an appropriate incentive to design subdivision Where: layouts that avoid building sites within the National Grid Yard. Subdivision is considered the most effective point at Activity status: RDIS which to ensure future reverse sensitivity effects, maintenance access issues, and adverse effects of transmission 1. it is demonstrated that all resulting allotments are capable of accommodating a lines (including amenity issues) are avoided. This can be achieved by designing subdivision layouts to properly Where: building platform for the likely principal building(s) and any building(s) for sensitive accommodate transmission corridors (including, for example, through the creation of reserves and/or open space activities outside the National Grid Yard (other than where the allotments are for where buffer corridors are located). Slightly amended wording is sought to the matters of discretion to ensure all 1. it is demonstrated that all resulting allotments, except allotments for access roads, accessways and network utilities); and effects on the National Grid are considered fully. or public work, are capable of accommodating a building platform for the likely 2. the layout of allotments and any enabling earthworks shall ensure that physical principal building(s) and any building(s) for sensitive activities wholly outside the access is maintained to any National Grid support structures located on the An exemption is provided for access lots and public works. National Grid Yard (other than where the allotments are for roads, accessways allotments, including any balance area. and network utilities); and 2. the layout of allotments and any enabling earthworks shall ensure that Matters over which discretion is restricted: physical access is maintained to any National Grid support structures located on the allotments, including any balance area. 1. The extent to which the subdivision allows for the ongoing efficient operation, maintenance and upgrading of the National Grid, including the ability for continued Matters over which discretion is restricted: reasonable access for inspections, maintenance and upgrading. 2. The location of any future building platform as it relates to the National Grid Yard. 1. The extent to which the subdivision allows for the ongoing efficient operation, 3. The extent to which the subdivision design allows for sensitive activities to be maintenance and upgrading and development of the National Grid, including setback from the National Grid. the ability for continued reasonable access for inspections, maintenance and 4. The nature and location of any vegetation to be planted in the vicinity of the upgrading. National Grid. 2. The location of any complying future building platform as it relates to the 5. The ability of future development to comply with NZECP 34: 2001 New Zealand National Grid Yard. Electricity Code of Practice for Electricity Safe Distances. 3. The extent to which the subdivision design allows for sensitive activities to be 6. The risk of electrical hazards affecting public or individual safety, and the risk of setback from the National Grid. property damage. 4. The nature and location of any vegetation to be planted in the vicinity of the 7. The outcome of any consultation with the owner and operator of the National National Grid and how such landscaping will impact on the operation, Grid. maintenance, upgrade and development (including access) of the National Grid. 5. The ability of future development to comply with NZECP 34: 2001 New Zealand Electricity Code of Practice for Electricity Safe Distances. Note: 6. The risk of electrical hazards affecting public or individual safety, and the risk of property damage. If a resource consent application is made under this rule, Transpower will be 7. The outcome of any consultation with the owner and operator of the National considered an affected person in accordance with Section 95E of the Act and notified Grid. of the application, where written approval is not provided. 8. The risk to the structural integrity of the National Grid. 9. The extent to which the subdivision design and consequential development Activity status where compliance not achieved: NC will minimise the potential reverse sensitivity on and amenity and nuisance effects of the National Grid asset.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment Note:
If a resource consent application is made under this rule, Transpower will be considered an affected person in accordance with Section 95E of the Act and notified of the application, where written approval is not provided.
Activity status where compliance not achieved: NC NU-R37 Subdivision of land for sensitive activities within the National Grid Support with Transpower supports the rules for subdivision within the National Grid Substation Corridor. Amend Rule NU-R37 as follows: Substation Corridor amendments A restricted discretionary activity status for subdivision provides an appropriate incentive to design subdivision NU-R37 Subdivision of land for sensitive activities within the National Grid All zones layouts that avoid building sites within the National Grid Yard. Subdivision is considered the most effective point at Substation Corridor Activity status: RDIS which to ensure future reverse sensitivity effects, maintenance access issues, and adverse effects of transmission lines (including amenity issues) are avoided. This can be achieved by designing subdivision layouts to properly All zones Matters over which discretion is restricted: accommodate transmission corridors (including, for example, through the creation of reserves and/or open space Activity status: RDIS where buffer corridors are located). Slightly amended wording is sought to the matters of discretion to ensure all 1. The extent to which the subdivision allows for the ongoing efficient operation, effects on the National Grid are considered fully. Matters over which discretion is restricted: maintenance and upgrading of the National Grid, including the ability for continued reasonable access for inspections, maintenance and upgrading. At the point of subdivision, it is not always known what the resulting land use activity will be on the newly created 1. The extent to which the subdivision allows for the ongoing efficient operation, 2. The extent to which the subdivision design allows for sensitive activities to be lot. For this reason, amendments to the rule are sought. maintenance and upgrading of the National Grid, including the ability for setback from the National Grid. continued reasonable access for inspections, maintenance and upgrading. The ability of future development to comply with NZECP 34: 2001 New Zealand 2. The extent to which the subdivision design allows for sensitive activities to be Electricity Code of Practice for Electricity Safe Distances. setback from the National Grid. 3. The risk of electrical hazards affecting public or individual safety, and the risk of 3. The ability of future development to comply with NZECP 34: 2001 New property damage. Zealand Electricity Code of Practice for Electricity Safe Distances. 4. The outcome of any consultation with the owner and operator of the National 4. The risk of electrical hazards affecting public or individual safety, and the risk Grid. of property damage. 5. The outcome of any consultation with the owner and operator of the National Grid. Note: 6. The location of any future building platform as it relates to the National Grid.
If a resource consent application is made under this rule, Transpower will be Note: considered an affected person in accordance with Section 95E of the Act and notified of the application, where written approval is not provided. If a resource consent application is made under this rule, Transpower will be considered an affected person in accordance with Section 95E of the Act and notified of the application, where written approval is not provided. NU-R38 Sensitive activities, including the erection of buildings for sensitive activities, Support with Transpower supports the control of sensitive activities is based on the corridor management approach. The 10- Amend Rule NU-R38 as follows: within the National Grid Yard amendments 12m width for land use (identified as the National Grid Yard) is calculated as the distance from the centreline between the support structures to the point where the conductor would swing under everyday conditions (noting NU-R38 Sensitive activities, including and the erection of buildings for sensitive All zones that maintenance is not generally undertaken in high wind conditions). activities, within the National Grid Yard
Activity status: NC Transpower supports the provision of a non-complying activity status for new sensitive activities, or additions to All zones existing sensitive activities, Note: A non-complying activity status is considered the most effective means of giving effect to the NPSET’s objective of Where the activity within the National Grid Yard is: managing the adverse effects of the network and managing the adverse effects of other activities on the network. 1. establishment of a new sensitive activity in an existing building; or This rule applies to the establishment of a new sensitive activity in an existing In particular, a non-complying activity status: 2. construction of a new or relocated building for a sensitive activity; or building, or any change of land use to a sensitive activity. (a) Most appropriately recognises and provides for the effective operation, maintenance, upgrading and 3. establishment of a new sensitive activity in a new building; development of the network, as required by NPSET Policy 2; 3. any change of land use to a sensitive activity; or If a resource consent application is made under this rule, Transpower will be (b) Is the best method to manage other activities to ensure the operation, maintenance, upgrading, and 4. increase in the footprint of an existing sensitive activity. considered an affected person in accordance with Section 95E of the Act and notified development of the network is not compromised, as required by Policy 10. of the application, where written approval is not provided. (c) Recognises the policy directive within Policy 11 to identify an appropriate buffer corridor within which it can be Activity status: NC expected that sensitive activities will generally not be provided for. Activity status where compliance not achieved: N/A Note: Policy 10 contains the phrase ‘avoid reverse sensitivity effects’ and ‘to ensure that the operation, maintenance, This rule applies to the establishment of a new sensitive activity in an existing upgrading and development of the electricity transmission network is not compromised’. Policy 11 gives a clear building, or any change of land use to a sensitive activity. direction that ‘sensitive activities will generally not be provided for in plans and/or given resource consent’. The use of the words ‘avoid’ and ‘ensure’ and the phrase ‘will generally not be provided for’ provide a strong direction If a resource consent application is made under this rule, Transpower will be that can only be achieved by way of a non-complying activity status. considered an affected person in accordance with Section 95E of the Act and notified of the application, where written approval is not provided. Amendments are sought to provide clarity for the rule itself, rather than by way of a note which has no statutory weight. Activity status where compliance not achieved: N/A
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment New rule for quarries or landfills within a site that has the National Grid Yard Amend Because of the operational requirements associated with a quarry or a landfill, the risk to the National Grid needs Add a new rule to the Network Utilities chapter as follows: to be carefully assessed. There is the potential for a decrease in distance between the conductors and ground level as well as the potential for destabilisation of the support structure foundations. In order to achieve Policy 10 of the NU-RY Quarrying activities or landfill on sites containing the National Grid Yard NPSET, Transpower seeks an additional rule which addresses quarries or landfill on sites that contain the National Grid Yard. The entire site is captured due to the potential for the activity to move around within the site. All zones
RDIS Matters of Discretion 1.Effects on the operation, maintenance, up-grading and development of the National Grid. 2.The risk to the structural integrity of the affected National Grid support structure(s). 3.Any effect on the ability of the network utility operator with responsibility for the National Grid transmission line to access the National Grid. 4.The risk of electrical hazards affecting public or individual safety, and the risk of property damage.
Activity status where compliance not achieved: N/A
Part 2: District-wide Matters / Hazards and Risks / Hazardous Substances
New policy – HAZS-P10 Amend Hazardous facilities have the potential to cause risk to the National Grid. The Plan does not contain any policy or Add the following new policy to the Hazardous Substances chapter: rule framework to control the location of hazardous facilities in relation to the National Grid. HAZS-P10 An “avoid” policy is considered the most effective means of giving effect to the NPSET’s objective of managing the Avoid locating significant hazardous facilities within the National Grid Yard and adverse effects of the network and managing the adverse effects of other activities on the network. In particular, a National Grid Substation Corridor to ensure that operation, maintenance, non-complying activity status: upgrading, and development of the electricity transmission network is not (a) Most appropriately recognises and provides for the effective operation, maintenance, upgrading and compromised. development of the network, as required by NPSET Policy 2; (b) Is the best method to manage other activities to ensure the operation, maintenance, upgrading, and development of the network is not compromised, as required by Policy 10.
HAZS-R9 Significant hazardous facilities within the National Grid Yard Support and Hazardous facilities have the potential to cause risk to the National Grid. The Plan currently does not attribute an Amend Rule HAZS-R9 as follows: amend activity status to this activity. In addition, the rule is limited to the National Grid Yard, but should be extended to include the National Grid Substation Corridor. HAZS-R9 Significant hazardous facilities within the National Grid Yard or National Grid Substation Corridor A non-complying activity status is considered the most effective means of giving effect to the NPSET’s objective of managing the adverse effects of the network and managing the adverse effects of other activities on the network. All zones In particular, a non-complying activity status: (a) Most appropriately recognises and provides for the effective operation, maintenance, upgrading and Activity status: NC development of the network, as required by NPSET Policy 2; (b) Is the best method to manage other activities to ensure the operation, maintenance, upgrading, and If a resource consent application is made under this rule, Transpower will be development of the network is not compromised, as required by Policy 10. considered an affected person in accordance with Section 95E of the Act and notified of the application, where written approval is not provided. Policy 10 contains the phrase ‘avoid reverse sensitivity effects’ and ‘to ensure that the operation, maintenance, upgrading and development of the electricity transmission network is not compromised’. The use of the words Activity status where compliance not achieved: N/A ‘avoid’ and ‘ensure’ provide a strong direction that can only be achieved by way of a non-complying activity status.
Part 2: District-wide Matters / Hazards and Risks / Natural Hazards
NH-P2 Support with Due to operational or functional requirements, some network utilities need to be located in areas of natural hazard Amend Policy NH-P2 as follows: amendments risk. The policies need to recognise this necessity. A new policy specific to network utilities is a more effective Manage the activities that can occur in identified natural hazard areas, or areas means of achieving Proposed Objective NU-O1. Manage the activities that can occur in identified natural hazard areas, or areas which have significant potential to be affected by a natural hazard, including: which have significant potential to be affected by a natural hazard, including:
1. building activities; 1. building activities; 2. earthworks; 2. earthworks; and 3. subdivision; and 3. subdivision; and 4. network utilities. 4. network utilities
AND
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment Add a new policy to the Natural Hazards chapter as follows:
Provide for network utilities in natural hazard areas where: 1. There is a functional need or operational need to locate there; and 2. any significant risks to people, property and the environment are mitigated as far as practicable.
NH-P4 Amend Due to operational or functional requirements, some network utilities need to be located in areas of natural hazard Amend Policy NH-P4 as follows: risk. The policies need to recognise this necessity in accordance with INF Policy 1 of the Regional Policy Statement Require activities locating in identified natural hazard areas, or areas which have for Taranaki. For example, by necessity stormwater infrastructure will be located in areas of high hazard risk. Require activities locating in identified natural hazard areas, or areas which potential to be affected by a natural hazard, to demonstrate any risks to people, have potential to be affected by a natural hazard, to demonstrate any risks to property and the environment will be minimised to an acceptable level, having people, property and the environment will be minimised to an acceptable level, regard to the effects of the activity, and: having regard to the effects of the activity, and:
1. the extent to which the activity will increase the risk of the hazard or the risk of 1. the extent to which the activity will increase the risk of the hazard or the risk damage to existing activities on the site or on adjacent sites, including increased of damage to existing activities on the site or on adjacent sites, including flood depths and velocities; increased flood depths and velocities; 2. the increasing risk of natural hazards from climate change; 2. the increasing risk of natural hazards from climate change; the cumulative effects of multiple activities on the risks associated with natural the cumulative effects of multiple activities on the risks associated with natural hazards; hazards; 3. the impact on the functioning of any relevant natural system; 3. the impact on the functioning of any relevant natural system; 4. the permanency of the activity and whether any building or structure can be 4. the permanency of the activity and whether any building or structure can be relocated outside of the hazard area; relocated outside of the hazard area; 5. whether the activity will intensify the use of the area or the number of people that 5. whether the activity will intensify the use of the area or the number of people are likely to occupy the site, thereby potentially increasing the level of exposure to that are likely to occupy the site, thereby potentially increasing the level of life-safety risk; exposure to life-safety risk; 6. whether any methods can be adopted to avoid or mitigate the effects of the 6. whether any methods can be adopted to avoid or mitigate the effects of the hazard through building or site design; hazard through building or site design; 7. ensuring new development is located and designed to mitigate the potential for 7. ensuring new development is located and designed to mitigate the potential natural hazards, and does not accelerate or worsen any material damage to that for natural hazards, and does not accelerate or worsen any material damage to land, or displace to other land or structures, resulting from erosion, subsidence, that land, or displace to other land or structures, resulting from erosion, debris flow, surface water flooding; and subsidence, debris flow, surface water flooding; and 8. the ability to monitor the hazard on an ongoing basis. 8. the ability to monitor the hazard on an ongoing basis.; and 9. Recognising the operational need and functional need for network utilities to be so located.
NH-R3 Maintenance of existing tracks, drains, structures or roads, including Amend While the use of an access track and earthworks associated with that access track is covered by the NESETA, Amend Rule NH-R3 as follows: associated earthworks or vegetation clearance Transpower supports the permitted activity status for maintenance of existing tracks and structures within the proposed natural hazard overlays. Maintenance of existing tracks, drains, structures or roads, including associated Flood Plain Area earthworks or vegetation clearance Flood Detention Area/Spillway The rule should be self-contained however and should not refer to other standards which will be covered by Stormwater Flooding Area another rule. Flood Plain Area Fault Hazard Area Flood Detention Area/Spillway In order to achieve the objectives in the Network Utility chapter, there is no need to apply the status of the activity Stormwater Flooding Area Activity status: PER of the underlying zone. Network utilities cross a multitude of zones and it is inappropriate to require compliance Fault Hazard Area with these. However, this rule applies to activities that are not network utilities and therefore it is appropriate to Where: have a specific permitted activity for maintenance of existing tracks, drains, structures or roads, including Activity status: PER associated earthworks or vegetation clearance associated with network utilities. 1. the activity does not alter the location of or result in an extension to the existing Where: track, drain, structure or road; The rule should be split so that one part is purely focused on the maintenance of existing tracks, drains, structures 2. the earthworks and vegetation clearance are permitted under all relevant rules in or roads, including associated earthworks or vegetation clearance in the natural hazard overlays associated with 1. the activity is associated with a network utility. the Overlay Chapters; and network utilities (as opposed to these activities associated with other landuses). This part of the rule should be 3. the activity is permitted under all relevant rules in the underlying zone. relocated into the network utilities chapter so that network utility activities are considered comprehensively in one chapter. Activity status: PER Activity status where compliance not achieved: RDIS In the Overview of the Network Utilities chapter it states that network utilities will not be subject to the rules and Where: Matters over which discretion is restricted: standards of the zones. The way Rule NH-R3 is crafted at the moment requires network utilities to be permitted under all relevant rules in the underlying zone which contradicts the statement in the Network Utilities chapter. 1. the activity does not alter the location of or result in an extension to the 1. The functional or operational need to undertake the vegetation clearance or This is potentially due to the fact that Rule NH-R3 applies to network utilities as well as a number of other existing track, drain, structure or road; earthworks. activities. For this reason, Transpower considers the rule should be split into one rule for network utilities, and 2. the earthworks and vegetation clearance are permitted under all relevant 2. The nature and extent of the hazard risks to people or property. another separate rule for all the other activities currently covered by NH-R3. rules in the Overlay Chapters; and 3. the activity is permitted under all relevant rules in the underlying zone.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment 3. Cumulative effects and the potential for the activity to create, transfer or intensify Activity status where compliance not achieved: RDIS hazard risks to adjoining sites, and any mitigation measures proposed to mitigate the effects of the hazard. Matters over which discretion is restricted: 4. Potential impacts on flood detention capacity or the rate and direction of overland flow paths, including consequential scouring or accelerated erosion. 1. The functional or operational need to undertake the vegetation clearance or 5. The extent and effect of non-compliance with any other relevant rule or standard earthworks. and any matters of discretion in any infringed rule(s) or standards. 2. The nature and extent of the hazard risks to people or property. 3. Cumulative effects and the potential for the activity to create, transfer or intensify hazard risks to adjoining sites, and any mitigation measures proposed to mitigate the effects of the hazard. 4. Potential impacts on flood detention capacity or the rate and direction of overland flow paths, including consequential scouring or accelerated erosion. 5. The extent and effect of non-compliance with any other relevant rule or standard and any matters of discretion in any infringed rule(s) or standards.
OR
Add a new rule to the Network Utilities chapter as follows: Rule NU-RV Maintenance of existing tracks, drains, structures or roads, including associated earthworks or vegetation clearance in natural hazard overlays associated with a network utility
Flood Plain Area Flood Detention Area/Spillway Stormwater Flooding Area Fault Hazard Area
Activity status: PER
Where: 1. the activity does not alter the location of or result in an extension to the existing track, drain, structure or road.
Activity status where compliance not achieved: RDIS
Matters over which discretion is restricted:
1. The functional or operational need to undertake the vegetation clearance or earthworks. 2. The nature and extent of the hazard risks to people or property. 3. Cumulative effects and the potential for the activity to create, transfer or intensify hazard risks to adjoining sites, and any mitigation measures proposed to mitigate the effects of the hazard. 4. Potential impacts on flood detention capacity or the rate and direction of overland flow paths, including consequential scouring or accelerated erosion.
NH-R11 Network utilities, including upgrading existing network utilities Amend Only network utility operators will be using this rule, therefore for efficiency and increased usability of the Plan this Relocate Rule NH-R11 into the Network Utilities chapter of the Plan. (1) Flood Plain Area rule should be relocated into the Network Utilities chapter. This will mean that all the network utility provisions are Flood Detention Area/Spillway together. Stormwater Flooding Area
Activity status: RDIS Oppose Transpower opposes a restricted discretionary activity status for upgrading network utilities in the natural hazard Amend Rule NH-R11 as follows: Matters over which discretion is restricted: overlays and considers this activity status is inappropriately stringent. NH-R11 NU-RY Aboveground Nnetwork utilities, including upgrading existing 1. The functional or operational need to locate the network utility within the hazard Rule NU-R3 contains standards for upgrading network utilities as a permitted activity and the scale of those aboveground network utilities area. standards is not significant. As these structures are existing, there is likely to be no effects in terms of exacerbation (1) Flood Plain Area 2. The suitability of the site to accommodate the activity. of natural hazards or risk associated with upgrading network utilities unless the structure is moved or the size of Flood Detention Area/Spillway 3. Cumulative effects, and the nature and extent of the hazard risks to people or the footprint of the structure increased. Even then, it is only the natural hazard overlays associated with flooding Stormwater Flooding Area property, including the potential for the activity to create, transfer or intensify that are likely to be relevant. hazard risks to adjoining sites. Where: 4. Potential impacts on flood detention capacity or the rate and direction of The standards for allowing upgrading of network utilities as a permitted activity means that these will have no 1. upgrading aboveground network utilities does not involve increasing the overland flow paths, including consequential scouring or accelerated erosion. effect on the fault hazard, nor will there be any increased risk to the security of the network utility. Given the footprint of the existing structure or building
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment 5. The ability to mitigate the effects of the hazard, including through any one or limited parameters for upgrading of network utilities as a permitted activity in Rule NU-R3, Transpower considers more of the following: foundation design; site layout; geotechnical setbacks; upgrading network utilities in Fault Hazard Areas is more appropriate as a permitted activity. The focus of this rule Activity status: PER building design; minimum floor levels; or the use, maintenance or enhancement of in terms of Fault Hazard Area should be on new network utilities, not upgrading existing. natural features on the site. 6. The potential to relocate or remove buildings and/or structures to alternative Rule NH-R11 duplicates Rule NH-R2, in that NH-R2 is specific to underground network utilities but Rule NH-R11 Where: locations. relates to all network utilities. To avoid duplication and confusion with rule NH-R2, Transpower considers Rule NH- 1. new aboveground network utilities structures or buildings are located in the R11 should be focused on new aboveground network utilities and upgrading that increases the risk by increasing natural hazard overlay; or Activity status where compliance not achieved: N/A the footprint of the existing structure. 2. upgrading of aboveground network utilities that involves a new or relocated structure or building in the natural hazard overlay; or (2) Fault Hazard Area There is no value in having a matter of discretion which refers to compliance with other rules or standards. If more 3. upgrading of aboveground network utilities involves increasing the footprint than one rule applies to an activity, the activity status will be the most stringent but this does not negate the need of the network utility structure or building. Activity status: RDIS to consider the other rules to which the activity relates. Activity status: RDIS Matters over which discretion is restricted: Transpower would support a restricted discretionary activity status for new network utilities in the natural hazard overlays. Matters over which discretion is restricted: 1. The functional or operational need to locate the network utility in the hazard area. 1. The functional or operational need to locate the network utility within the 2. The nature and extent of the hazard risks to people or property. hazard area. 3. The susceptibility of any buildings or structures to the effects of ground shaking 2. The suitability of the site to accommodate the activity. and displacement from earthquakes. 3. Cumulative effects, and the nature and extent of the hazard risks to people or 4. Whether the activity will intensify the use of the area, or the number of people property, including the potential for the activity to create, transfer or intensify that are likely to occupy the site. hazard risks to adjoining sites. 5. The ability to mitigate the effects of the hazard, including through any one or 4. Potential impacts on flood detention capacity or the rate and direction of more of the following: foundation design; site layout; geotechnical setbacks; overland flow paths, including consequential scouring or accelerated erosion. building design; minimum floor levels; or the use, maintenance or enhancement of 5. The ability to mitigate the effects of the hazard, including through any one or natural features on the site. more of the following: foundation design; site layout; geotechnical setbacks; 6. The extent and effect of non-compliance with any other relevant rule or standard building design; minimum floor levels; or the use, maintenance or enhancement and any matters of discretion in any infringed rule(s) or standards. of natural features on the site. 6. The potential to relocate or remove buildings and/or structures to alternative Activity status where compliance not achieved: N/A locations.
Activity status where compliance not achieved: N/A
(2) Fault Hazard Area
Where: 1. upgrading existing aboveground network utilities
Activity status: PER
Where: 1. new network utilities structures or buildings are located in the Fault Hazard overlay
Activity status: RDIS
Matters over which discretion is restricted:
1. The functional or operational need to locate the network utility in the hazard area. 2. The nature and extent of the hazard risks to people or property. 3. The susceptibility of any buildings or structures to the effects of ground shaking and displacement from earthquakes. 4. Whether the activity will intensify the use of the area, or the number of people that are likely to occupy the site. 54. The ability to mitigate the effects of the hazard, including through any one or more of the following: foundation design; site layout; geotechnical setbacks; building design; minimum floor levels; or the use, maintenance or enhancement of natural features on the site. 6. The extent and effect of non-compliance with any other relevant rule or standard and any matters of discretion in any infringed rule(s) or standards.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment Activity status where compliance not achieved: N/A
Part 2: District-wide Matters / Historic and Cultural Values / Entrance Corridors
ECOR-P5 Amend The Transpower network crosses Junction Road (SH3) so falls within the Entrance Corridor. In addition there are Amend Policy ECOR-P5 as follows: other network utility structures which will need to be located in the Entrance Corridor including the road itself and Ensure activities within or on sites adjoining entrance corridors maintain the visual street lighting. The policy needs to achieve Objective NU-O1 and give effect to INF Objective 1 and INF Policy 1 in Ensure activities within or on sites adjoining entrance corridors maintain the amenity, attractiveness and the quality of the arrival experience of entrance the Regional Policy Statement for Taranaki. visual amenity, attractiveness and the quality of the arrival experience of corridors having regard to: entrance corridors having regard to: Rule ECOR-R4 could apply to network utilities due to the broad definition of the term “building activities”, 1. the location, form, bulk, scale and orientation of structures on the site, including therefore the policy framework needs to recognise that network utilities are appropriate within this corridor. This 1. the location, form, bulk, scale and orientation of structures on the site, whether structures are sufficiently set back from boundaries; is also particularly relevant given the policy also relates to adjoining sites which means the policy has potentially including whether structures are sufficiently set back from boundaries; 2. whether structures complement and integrate with the surrounding topography very wide application to a range of land uses. 2. whether structures complement and integrate with the surrounding and landscape; topography and landscape; 3. the type, scale, location, design and direction of signage and its visibility within 3. the type, scale, location, design and direction of signage and its visibility the entrance corridor; within the entrance corridor; 4. the maintenance or enhancement of views of notable/landmark built features 4. the maintenance or enhancement of views of notable/landmark built features and natural features, including Mount Taranaki; and natural features, including Mount Taranaki; 5. the cultural (including tangata whenua) values of the entrance corridor, where 5. the cultural (including tangata whenua) values of the entrance corridor, relevant and whether these will be compromised; where relevant and whether these will be compromised; 6. whether visually prominent trees, planting and/or landscaping that contribute to 6. whether visually prominent trees, planting and/or landscaping that contribute the amenity of the area will be retained; and to the amenity of the area will be retained; and 7. the extent to which planting and landscaping mitigates adverse effects on visual 7. the extent to which planting and landscaping mitigates adverse effects on amenity and the quality of the arrival experience along the entrance corridor. visual amenity and the quality of the arrival experience along the entrance corridor; and 8. recognising and providing for the operational needs and functional needs of network utilities. ECOR-R4 Building activities (excluding demolition or removal of a structure) on sites Amend The Transpower network crosses Junction Road (SH3) so falls within the Entrance Corridor. In addition there are Add a new rule regarding the Entrance Corridors chapter to address network adjoining an entrance corridor other network utility structures which will need to be located in the Entrance Corridor including the road itself and utilities in the network utilities chapter as follows: street lighting. The rule needs to achieve Objective NU-O1 and give effect to INF Objective 1 and INF Policy 1 in the All zones Regional Policy Statement for Taranaki. ECOR-R4A Network utilities within an entrance corridor or on sites adjoining an entrance Activity status: PER There are no rules in the Entrance Corridors chapter specifically relating to network utilities which makes the corridor activity status highly uncertain. Where: All zones 1. all Entrance Corridor Effects Standards are complied with. In the absence of any specific rules for network utilities, Rule ECOR-R4 could apply to network utilities due to the broad definition of the term “building activities”, so it is appropriate for network utilities to be excluded from this Activity status: PER Activity status where compliance not achieved: RDIS rule. A range of network utilities are essential for the health and safety of the community. 1. All operation, upgrading, maintenance, repair or removal of existing network Matters over which discretion is restricted: The rule framework uses inconsistent terminology as Standard S1 refers to structures and the rule refers to utilities building activities. 2. New underground network utilities 1. Potential adverse effects on the visual amenity, attractiveness, streetscape and quality of the arrival experience along the entrance corridor. Activity status where compliance not achieved: N/A 2. Whether the scale, intensity and/or character of the activity is appropriate in the context of the adjoining entrance corridor environment. 3. The extent and effect of non-compliance with any Entrance Corridor Effects All zones Standards and any matters of discretion in any infringed Effects Standard(s). Activity status: PER
Where:
1. New aboveground network utilities comply with Entrance Corridor Effects Standard ECOR-S1. This standard does not apply to structures associated with the transport network.
Activity status where compliance not achieved: RDIS
Matters over which discretion is restricted:
1. Potential adverse effects on the visual amenity, attractiveness, streetscape and quality of the arrival experience along the entrance corridor.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment 2. Whether the scale, intensity and/or character of the activity is appropriate in the context of the adjoining entrance corridor environment. 3. The extent and effect of non-compliance with any Entrance Corridor Effects Standards and any matters of discretion in any infringed Effects Standard(s).
AND
Locate the new rule in the Network Utilities chapter.
Part 2: District-wide Matters /Historic and Cultural Values / Historic Heritage
HH-P14 Support with Allowing for the maintenance and repair or upgrading of existing network utility structures is an appropriate way Amend Policy HH-P14 as follows: amendments to achieve to Objective NU-O1 and give effect to INF Objective 1 and INF Policy 1 in the Regional Policy Statement Allow the following activities on or adjacent to an archaeological site provided they for Taranaki. However “operation” of network utilities also needs to be provided for. Allow the following activities on or adjacent to an scheduled archaeological site do not compromise the site's historic heritage values: provided they do not compromise the site's historic heritage values: The policy should be broadened to include new network utility structures as there is already a requirement in the 1. land disturbance; policy that the structures “do not compromise the site's historic heritage values”. 1. land disturbance; 2. demolition or removal of existing buildings and structures; 2. demolition or removal of existing buildings and structures; 3. alterations to existing buildings and structures; By including the word “scheduled”, it gives the policy more certainty. 3. alterations to existing buildings and structures; 4. maintenance and repair or upgrading of existing network utility structures; and 4. operation, maintenance and repair or upgrading of existing network utility 5. erection of signs. structures; and 5. erection of signs. HH-P16 Support with The policy as it is currently written is not certain enough, given the “avoid” requirement within the policy. There Amend Policy HH-P16 as follows: amendments are technologies available which will allow archaeological sites to be identified. The definition of “archaeological Ensure that activities on, adjacent to or affecting archaeological sites or on land site” includes places buildings and structures. The inclusion of the words “reasonable cause to suspect” introduces Ensure that activities on, adjacent to or affecting archaeological sites or on land where there is reasonable cause to suspect an archaeological site may exist avoid a high level of uncertainty into the policy. where there is reasonable cause to suspect an archaeological site may exist adverse effects on the site, or where avoidance is not possible, appropriately remedy avoid adverse effects on the site, or where avoidance is not possible, or mitigate adverse effects, having regard to: It is appropriate that the policy recognise that in some instances avoidance of adverse effects is not possible and appropriately remedy or mitigate adverse effects, having regard to: ensure that adverse effects are appropriately remedied or mitigated. … 1. the particular cultural and/or historic heritage values present and their setting; 2. the reduction or loss of historic heritage values, including the ability to interpret the place and its relationship with other heritage features/items and/or archaeological sites; 3. the site's sensitivity to change or capacity to accommodate change without compromising the historic heritage values of the archaeological site and surrounds; 4. any opportunities to enhance historic heritage; 5. any assessments or advice from a suitably qualified and experienced heritage expert and/or archaeological expert; 6. the outcomes of consultation with Heritage New Zealand Pouhere Taonga; and 7. where the site is also a site or area of significance to Māori, the relevant objectives and policies in the Sites and Areas of Significance to Māori Chapter. HH-R13 Amend Only network utility operators will be using Rule HH-R13, therefore for efficiency and increased usability of the Relocate Rule HH-R13 into the Network Utility chapter Plan this rule should be relocated into the Network Utilities chapter. This will mean that all the network utility Maintenance and repair or upgrading of a network utility structure, including provisions are together. There can be cross references to the Historic Heritage objectives and policies within the associated earthworks, on or within 50m of a scheduled archaeological site Network Utility chapter.
All zones Amend The relationship of this rule with other rules in the chapter is not clear. For example there are multiple other rules Clarify the relationship between R13 and the other rules within the chapter. Activity status: CON that could arguably apply to network utilities such as alterations to a structure, land disturbance etc. It needs to be made clear that the only activity that applies to network utilities near archaeological sites is this one which is Where: specific to network utilities.
1. for the maintenance and repair, or upgrading of an aboveground structure, any associated earthworks involves an area of no more than 0.3m2 to a maximum depth of 450mm at the base of the aboveground structure, provided the earthworks are limited to an area that has previously been disturbed by the existing network utility Amend While Transpower is not necessarily opposed to a controlled activity status, given the standards, it is questionable Review the appropriateness of the activity status in terms of whether a since 15 August 2005 (the date the previous plan became operative); or whether a permitted activity status would be more appropriate. A permitted activity status would meaningfully permitted activity status would better reflect the objectives and policies. 2. for the maintenance and repair, or upgrading of an an underground structure, the achieve Objective NU-O1 and give effect to INF Objective 1 and INF Policy 1 in the Regional Policy Statement for associated earthworks involves an maximum area of 10m2 or a maximum volume of Taranaki. All of the standards have the effect of avoiding or minimising any adverse effects on the archaeological 5m3 of land, provided the earthworks are limited to an area that has previously been site. disturbed by the existing network utility since 15 August 2005 (the date the previous plan became operative); or It is also noted the colour of the activity does not match the activity status nor the Section 32 evaluation. Paragraph 7.3.2 of the Section 32 evaluation states that maintenance and repair or upgrading of a network utility
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment 3. for installing customer connections to an existing network, provided any structure, including associated earthworks, on or within 50m of an archaeological site is a permitted activity. associated earthworks are limited to the extent that is necessary to install the However it was notified as a controlled activity. connection; or 4. for the trimming of trees or vegetation, providing it is required for the purpose of Amend The text above the rules relating to archaeological sites states that: Amend Rule HH-R13 as follows: protecting the integrity of a structure or is otherwise undertaken in accordance with For the purposes of these rules, "on a scheduled archaeological site" means: the Electricity (Hazards from Trees) Regulations 2003; and HH-R13 NU-RX 5. notice of the works is provided to tangata whenua and Heritage New Zealand a. for sites with a verified extent, anywhere within the verified extent; or Pouhere Taonga 10 working days prior to any earthworks commencing; and b. for sites without a verified extent, anywhere within a 200m radius of the site's mapped centroid Maintenance, and repair or upgrading of a network utility structure, including 6. all underlying Zone Effects Standards are complied with. marker; or associated earthworks and vegetation works, on or within 50m of a scheduled c. for sites that have "silent file" status, these sites are accurate to the land parcel and the extent of the archaeological site site will be treated as the area within a 200m radius of the site's centroid marker. Matters over which control is reserved: All zones The combination of the 200m assumed radius plus 50m for network utilities as required by HH-R13 is excessive, 1. Date of previous disturbance. particularly for those sites with a verified extent. Given how a scheduled archaeological site is defined in the plan, Activity status: CON PER 2. Area and depth of earthworks for aboveground structure. it is submitted the 50m setback is not required. 3. Area and volume of earthworks for underground structure. Where: 4. Extent of earthworks for new customer connections. The matters over which control is reserved are not appropriate as the rule itself specifies the parameters. For 5. Trimming of trees and vegetation. example, standard 1 contains a maximum area and maximum depth for earthworks. The matters of control include 1. for the maintenance and repair, or upgrading of an aboveground structure, 6. Provision of works notices to tangata whenua and Heritage New Zealand Pouhere areas and depth of earthworks. Matters over which control is reserved should not address matters for which there any associated earthworks involves an area of no more than 0.3m2 to a Taonga. is a standard. Given the thoroughness of the standards, a permitted activity status is more appropriate. maximum depth of 450mm at the base of the aboveground structure, provided 7. Any advice received from tangata whenua to manage the effects of the proposed the earthworks are limited to an area that has previously been disturbed by the maintenance works. The underlying zone standards are not relevant to network utilities, and are not a requirement of the rules for new existing network utility since 15 August 2005 (the date the previous plan became network utilities in the Network Utility chapter. operative); or Activity status where compliance not achieved: DIS 2. for the maintenance and repair, or upgrading of an an underground structure, the associated earthworks involves an maximum area of 10m2 or a maximum volume of 5m3 of land, provided the earthworks are limited to an area that has previously been disturbed by the existing network utility since 15 August 2005 (the date the previous plan became operative); or 3. for installing customer connections to an existing network, provided any associated earthworks are limited to the extent that is necessary to install the connection; or 4. for the trimming of trees or vegetation, providing it is required for the purpose of protecting the integrity of a structure or is otherwise undertaken in accordance with the Electricity (Hazards from Trees) Regulations 2003; and 5. notice of the works is provided to tangata whenua and Heritage New Zealand Pouhere Taonga 10 working days prior to any earthworks commencing; and 6. all underlying Zone Effects Standards are complied with.
Matters over which control is reserved:
1. Date of previous disturbance. 2. Area and depth of earthworks for aboveground structure. 3. Area and volume of earthworks for underground structure. 4. Extent of earthworks for new customer connections. 5. Trimming of trees and vegetation. 6. Provision of works notices to tangata whenua and Heritage New Zealand Pouhere Taonga. 7. Any advice received from tangata whenua to manage the effects of the proposed maintenance works.
Activity status where compliance not achieved: DISRDIS
Matters over which discretion is restricted: 1. Area and depth of earthworks for the network utility 2. The reduction or loss of historic heritage values 3. Provision of works notices to tangata whenua and Heritage New Zealand Pouhere Taonga. 4. The site's sensitivity to change or capacity to accommodate change 5. Any advice received from tangata whenua to manage the effects of the proposed maintenance works.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment New rule for new network utilities and associated earthworks Amend At present, there is no rule in the Historic Heritage chapter which addresses new network utility structures within a Add a new rule regarding new network utilities and associated earthworks scheduled archaeological site. For certainty, there needs to be such a rule. within a scheduled archaeological site as follows:
It should be located in the network utility chapter so that all rules associated with network utilities can be NU-RY considered comprehensively. New network utilities and associated earthworks within a scheduled archaeological site
All zones
Activity status: RDIS
Matters over which discretion is restricted: 1. the reduction or loss of historic heritage values, including the ability to interpret the place and its relationship with other heritage features/items and/or archaeological sites; 2. the site's sensitivity to change or capacity to accommodate change without compromising the historic heritage values of the archaeological site and surrounds; 3. The operational need and functional need for the network utility; 4. Consideration of the need for connectedness with other network utilities; 5. The extent to which any adverse effects have been avoided, remedied or mitigated by the route, site and method selection.
AND
Locate the new rule in the Network Utilities chapter. HH-R17 Amend The rule should include new structures and operation in order to meaningfully achieve Objective NU-O1 and give Amend Rule HH-R17 as follows: effect to INF Objective 1 and INF Policy 1 in the Regional Policy Statement for Taranaki as a consequential Earthworks on or within 50m of a scheduled archaeological site, including amendment of the changes sought in this submission to Rule HH-R13. Earthworks on or within 50m of a scheduled archaeological site, including earthworks associated with the clearance of trees and the erection of new earthworks associated with the clearance of trees and the erection of new structures, but excluding land disturbance provided for in HH-R10 and earthworks The rule references will need to be amended if the rules are relocated into the Network Utilities chapter as structures, but excluding land disturbance provided for in HH-R10 and associated with the maintenance and repair or upgrading of a network utility requested. earthworks associated with new, and the operation, maintenance, and repair or provided for by HH-R13 upgrading of a network utility provided for by HH-R13 NU-RX and NU-RY Clarify how the terminology used within the rules relates to the areas identified on the planning maps, as the planning maps identify extent areas but this terminology is not used in the rules, instead reference is made to 50m.
Part 2: District-wide Matters / Historic and Cultural Values / Notable Trees
TREE-P2 Support Transpower supports Policy TREE-P2, particularly clauses (2) and (3). Retain Policy TREE-P2 as notified, particularly clauses (2) and (3)
Allow trimming and maintenance, earthworks and root pruning in the root Transpower supports the recognition that works on or near a scheduled tree may be necessary to comply with the protection area of a scheduled notable tree where it is necessary to: Electricity (Hazards from Trees) Regulations 2003. The purpose of the regulation is to protect the security of the supply of electricity, and the safety of the public (as set out in the Regulations). The Regulations apply to both 1. prevent a serious threat to people or property; or overhead and underground conductors so trimming and root pruning must be enabled to ensure compliance with 2. enable the ongoing provision of essential infrastructure; or the Regulations. 3. comply with the Electricity (Hazards from Trees) Regulations 2003; or 4. improve, maintain or monitor tree health; and Recognition of the Regulations in Policy TREE-P2 is appropriate. any adverse effects are avoided or, where avoidance is not practicable, appropriately remedied or mitigated. The trimming, maintenance, earthworks and root pruning of a notable tree for the purposes of the on-going provision of essential infrastructure is an appropriate way to achieve Objective NU-O1 and give effect to INF Objective 1 and INF Policy 1 in the Regional Policy Statement for Taranaki.
TREE-P5 Support Transpower supports Policy TREE-P5, particularly clauses (2) and (3). Retain Policy TREE-P5 as notified, particularly clauses (2) and (3)
Avoid the removal, partial removal or destruction of a scheduled notable tree, Transpower supports Policy TREE-P5, particularly the recognition that the removal, partial removal or destruction unless: of a notable tree may be necessary to comply with the Electricity (Hazards from Trees) Regulations 2003. The purpose of the regulation is to protect the security of the supply of electricity, and the safety of the public (as set 1.it is necessary to prevent a serious threat to people or property; out in the Regulations). Recognition of the Regulations in Policy TREE-P5 is appropriate. 2.it is necessary to enable the ongoing provision of essential infrastructure;
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment 3. it is necessary to ensure compliance with the Electricity (Hazards from Trees) The removal, partial removal or destruction of a notable tree for the purposes of the on-going provision of Regulations 2003; and/or essential infrastructure is an appropriate way to achieve Objective NU-O1 and give effect to INF Objective 1 and 4. the tree is rendering the site incapable of reasonable use. INF Policy 1 in the Regional Policy Statement for Taranaki.
TREE-R2 Trimming and maintenance of a scheduled notable tree Support with Transpower supports Rule TREE-R2, particularly standards 1(b) and 1(c). The trimming and/or maintenance of a Retain Rule TREE-R2 Trimming and maintenance of a scheduled notable tree, amendments notable tree for the purposes of the on-going provisions of existing or authorised infrastructure is an appropriate particularly standards 1(b) and 1(c) Activity status: PER way to achieve Objective NU-O1 and give effect to INF Objective 1 and INF Policy 1 in the Regional Policy Statement for Taranaki. AND Where: The purpose of the Electricity (Hazards from Trees) Regulations 2003 is to protect the security of the supply of Delete matter of discretion (3) from Rule TREE-R2 Trimming and maintenance of 1. the trimming and/or maintenance is necessary to: electricity, and the safety of the public (as set out in the Regulations). Enabling trimming and maintenance to a scheduled notable tree as follows: a. prevent a serious threat to people or property; or achieve compliance with the regulations as a permitted activity is appropriate. b. enable the ongoing provision of existing or authorised infrastructure; or Matters over which discretion is restricted: c. comply with the Electricity (Hazards from Trees) Regulations 2003; or Clause (3) of the matters of discretion is redundant given that enabling the ongoing provision of existing or d. improve, maintain or monitor tree health; authorised infrastructure is expressly stated as a standard for the activity to be permitted. There is no value in this 1. The impact that the proposal will have on the integrity, ongoing viability, and 2. prior to the work being undertaken, the Council or a Council approved matter of discretion. values of the scheduled notable tree. arboricultural contractor has certified that the work is necessary in accordance with 2. Whether arboricultural best practice, including opportunities to minimise loss (1) above; and or damage to the tree, will be implemented as far as practicable. 3. the work is undertaken or supervised by the Council or a Council approved 3. In relation to infrastructure, whether there is an operational or functional arboricultural contractor. need for the trimming and/or maintenance, including the potential impact on the levels of service if the work is not undertaken. Activity status where compliance not achieved: RDIS
Matters over which discretion is restricted:
1. The impact that the proposal will have on the integrity, ongoing viability, and values of the scheduled notable tree. 2. Whether arboricultural best practice, including opportunities to minimise loss or damage to the tree, will be implemented as far as practicable. 3. In relation to infrastructure, whether there is an operational or functional need for the trimming and/or maintenance, including the potential impact on the levels of service if the work is not undertaken. TREE-R5 Removal, partial removal or destruction of an unsafe or unsound Oppose Policy TREE-P5(3) recognises that the removal, partial removal or destruction of a notable tree may be necessary to Amend Rule TREE-R5 Removal, partial removal or destruction of an unsafe or scheduled notable tree comply with the Electricity (Hazards from Trees) Regulations 2003. However this policy approach is not reflected in unsound scheduled notable tree as follows: Rule TREE-R5. The purpose of the regulation is to protect the security of the supply of electricity, and the safety of Activity status: PER the public (as set out in the Regulations). Activity status: PER
Where: Rule TREE-R5 needs to be amended to align with Policy TREE-P5 and to enable removal, partial removal or Where: destruction of a notable tree as a permitted activity where it is necessary to comply with the Electricity (Hazards 1. the scheduled notable tree is unsafe or unsound as certified by the Council and in from Trees) Regulations 2003. 1. the scheduled notable tree is unsafe or unsound as certified by the Council accordance with the International Society of Arboriculture Tree Risk Assessment and in accordance with the International Society of Arboriculture Tree Risk Form; and Assessment Form; or 2. the removal, partial removal or destruction of the tree is undertaken by the 2. the removal, partial removal or destruction of the notable tree is needed to Council or a Council approved arboricultural contractor. comply with the Electricity (Hazards from Trees) Regulations 2003; and 2 3. the removal, partial removal or destruction of the tree is undertaken by the Activity status where compliance not achieved: NC Council or a Council approved arboricultural contractor.
Activity status where compliance not achieved: NC
Part 2: District-wide Matters / Historic and Cultural Values / Sites and Areas of Significance to Maori
SASM-P3 Support with Transpower supports Policy SASM-P3, particularly clause (4). The acknowledgement of existing network utilities Amend Policy SASM-P3 to recognise the operation of existing network utilities amendments on, or adjacent to scheduled sites and areas of significance to Māori, and the need to maintain, repair and upgrade as follows: Allow the following activities to occur on, or adjacent to scheduled sites and areas of existing is an appropriate way to achieve Objective NU-O1 and give effect to INF Objective 1 and INF Policy 1 in the significance to Māori, while ensuring their design, scale and intensity will not Regional Policy Statement for Taranaki. Allow the following activities to occur on, or adjacent to scheduled sites and compromise cultural, spiritual and/or heritage values, interests or associations of areas of significance to Māori, while ensuring their design, scale and intensity importance to tangata whenua: The policy needs to be amended to include “operation” to more fully align with Objective NU-O1 and give effect to will not compromise cultural, spiritual and/or heritage values, interests or INF Objective 1 and INF Policy 1 in the Regional Policy Statement for Taranaki. associations of importance to tangata whenua: 1. Land disturbance; 2. demolition or removal of existing buildings and structures; 1. Land disturbance; 3. alterations to existing buildings and structures; 2. demolition or removal of existing buildings and structures; 4. maintenance and repair or upgrading of existing network utility structures; and 3. alterations to existing buildings and structures;
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment 5. erection of signs. 4. operation, maintenance and repair or upgrading of existing network utility structures; and 5. erection of signs.
SASM-R4 Maintenance and repair or upgrading of a network utility structure, Amend Only network utility operators will be using Rule SASM-R4, therefore for efficiency and increased usability of the Relocate Rule SASM-R4 into the Network Utilities chapter including associated earthworks, on or within 50m of a scheduled site or area of Plan this rule should be relocated into the Network Utilities chapter. This will mean that all the network utility significance to Māori provisions are together. There can be cross references to the Sites and Areas of Significance to Maori objectives and policies within the Network Utility chapter. All zones
Activity status: CON Amend While Transpower is not necessarily opposed to a controlled activity status, given the standards it is questionable Review the appropriateness of the activity status in terms of whether a whether a permitted activity status would be more appropriate. A permitted activity status would meaningfully permitted activity status would better reflect the objectives and policies. Where: achieve Objective NU-O1 and give effect to INF Objective 1 and INF Policy 1 in the Regional Policy Statement for Taranaki. All of the standards have the effect of avoiding or minimising any adverse effects on the archaeological 1. for the maintenance and repair, or upgrading of an aboveground structure, any site. associated earthworks involves an area of no more than 0.3m2 to a maximum depth . of 450mm at the base of the aboveground structure, provided the earthworks are Amend The text above the rules states that: Amend Rule SASM-R4 as follows: limited to an area that has previously been disturbed by the existing network utility For the purposes of these rules, "on a scheduled site or area of significance to Māori" means: SASM-R4 NU-RZ since 15 August 2005 (the date the previous plan became operative); or Maintenance and repair or upgrading of a network utility structure, including 2. for the maintenance and repair, or upgrading of an underground structure, the a. for sites with a verified extent, anywhere within the verified extent; or associated earthworks, on or within 50m of a scheduled site or area of associated earthworks involves a maximum area of 10m2 or a maximum volume of b. for sites without a verified extent, anywhere within a 200m radius of the site's mapped centroid significance to Māori 5m3 of land, provided the earthworks are limited to an area that has previously marker; or been disturbed by the existing network utility since 15 August 2005 (the date the c. for sites that have 'silent file' status, these sites are accurate to the land parcel and the extent of the All zones previous plan became operative); or site will be treated as the area within a 200m radius of the site's centroid marker. 3. for installing customer connections to an existing network, provided any Activity status: CON PER associated earthworks are limited to the extent that is necessary to install the The combination of the 200m assumed radius plus 50m for network utilities as required by SASM-R4 is excessive. connection; or Given how a scheduled site or area of significance is defined in the plan, it is submitted the 50m setback is not Where: 4. for the trimming of trees or vegetation, providing it is required for the purpose of required. protecting the integrity of a structure or is otherwise undertaken in accordance with 1. for the maintenance and repair, or upgrading of an aboveground structure, the Electricity (Hazards from Trees) Regulations 2003; and The matters over which control is reserved are not appropriate as the rule itself specifies the parameters. For any associated earthworks involves an area of no more than 0.3m2 to a 5. notice of the works is provided to tangata whenua and Heritage New Zealand example, standard 1 contains a maximum area and maximum depth for earthworks. The matters of control include maximum depth of 450mm at the base of the aboveground structure, provided Pouhere Taonga 10 working days prior to any earthworks commencing; and areas and depth of earthworks. Matters over which control is reserved should not address matters for which there the earthworks are limited to an area that has previously been disturbed by the 6. all underlying Zone Effects Standards are complied with. is a standard. Given the thoroughness of the standards, a permitted activity is more appropriate. existing network utility since 15 August 2005 (the date the previous plan became operative); or The underlying zone standards are not relevant to network utilities, and are not a requirement of the rules for new 2. for the maintenance and repair, or upgrading of an underground structure, Matters over which control is reserved: network utilities in the Network Utility chapter. the associated earthworks involves a maximum area of 10m2 or a maximum volume of 5m3 of land, provided the earthworks are limited to an area that has 1. Date of previous disturbance. previously been disturbed by the existing network utility since 15 August 2005 2. Area and depth of earthworks for aboveground structure. (the date the previous plan became operative); or 3. Area and volume of earthworks for underground structure. 3. for installing customer connections to an existing network, provided any 4. Extent of earthworks for new customer connections. associated earthworks are limited to the extent that is necessary to install the 5. Trimming of trees and vegetation. connection; or 6. Provision of works notices to tangata whenua and Heritage New Zealand Pouhere 4. for the trimming of trees or vegetation, providing it is required for the purpose Taonga. of protecting the integrity of a structure or is otherwise undertaken in 7. Any advice received from tangata whenua to manage the effects of the proposed accordance with the Electricity (Hazards from Trees) Regulations 2003; and maintenance works. 5. notice of the works is provided to tangata whenua and Heritage New Zealand Pouhere Taonga 10 working days prior to any earthworks commencing; and Activity status where compliance not achieved: DIS 6. all underlying Zone Effects Standards are complied with.
Matters over which control is reserved:
1. Date of previous disturbance. 2. Area and depth of earthworks for aboveground structure. 3. Area and volume of earthworks for underground structure. 4. Extent of earthworks for new customer connections. 5. Trimming of trees and vegetation. 6. Provision of works notices to tangata whenua and Heritage New Zealand Pouhere Taonga. 7. Any advice received from tangata whenua to manage the effects of the proposed maintenance works.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment Activity status where compliance not achieved: DIS RDIS
Matters over which discretion is restricted: 1. the reduction or loss cultural, spiritual and/or historical values, interests or associations of importance to tangata whenua 2. the extent to which the activity may compromise tangata whenua's relationship with their ancestral lands, water, sites, wāhi tapu, and other taonga, and/or the ability to protect, maintain or enhance sites of significance to tangata whenua; 3. The operational need and functional need for the network utility; 4. Consideration of the need for connectedness with other network utilities; 5. The extent to which any adverse effects have been avoided, remedied or mitigated by the route, site and method selection.
New rule for new network utilities and associated earthworks Amend At present, there is no rule which specifically addresses new network utility structures within a Site or Area of Add a new rule for network utilities and associated earthworks within a Site or Significance to Maori. For certainty, there needs to be such a rule. Area of Significance to Maori as follows:
It should be located in the network utility chapter so that all rules associated with network utilities can be SASM-RZ considered comprehensively. New network utilities and associated earthworks within a scheduled site or area of significance to Maori
All zones
Activity status: RDIS
Matters over which discretion is restricted: 1. the particular cultural, spiritual and/or historical values, interests or associations of importance to tangata whenua that are associated with the site which may be affected; 2. the extent to which the activity may compromise tangata whenua's relationship with their ancestral lands, water, sites, wāhi tapu, and other taonga, and/or the ability to protect, maintain or enhance sites of significance to tangata whenua; 3. The operational need and functional need for the network utility; 4. Consideration of the need for connectedness with other network utilities; 5. The extent to which any adverse effects have been avoided, remedied or mitigated by the route, site and method selection.
AND
Locate the new rule in the network utilities chapter.
SASM-R8 Amend As a consequence of amendments sought by Transpower to other rules regarding network utilities in sites and Amend Rule SASM-R8 to have the correct rule references for the exclusion for areas of significance to Maori, Rule SASM – R8 will need to be amended to ensure that any particular network earthworks associated with network utilities Earthworks on or within 50m of a scheduled site or area of significance to Māori, utility activity or structure is not covered by multiple rules with different activity statuses. including earthworks associated with the clearance of trees and the erection of new structures, but excluding land disturbance provided for by SASM-R1 and earthworks associated with the maintenance and repair or upgrading of a network utility provided for by SASM-R4 Amend The activity status of the rule is not clear. Provide an explicit activity status for Rule SASM-R8.
Part 2: District-wide Matters / Historic and Cultural Values / Viewshafts
VIEWS-P3 Amend Policy VIEWS-P3 needs to be amended to recognise that network utility and infrastructure structures may be Amend Policy VIEWS-P3 as follows: required within the viewshafts to protect the health and safety of communities. Recognition of the need for Ensure that any structure that exceeds permitted height limits within a viewshaft is network utilities in the viewshafts policy is an appropriate way to achieve Objective NU-O1 and give effect to INF Ensure that any structure that exceeds permitted height limits within a appropriately located and does not result in inappropriate adverse visual effects on Objective 1 and INF Policy 1 in the Regional Policy Statement for Taranaki. viewshaft is appropriately located and does not result in inappropriate adverse the viewshaft, having regard to: visual effects on the viewshaft, having regard to:
1. the extent to which the additional height of the structure will encroach upon the 1. the extent to which the additional height of the structure will encroach upon core part of the view and/or compromise the visual coherence or integrity of the the core part of the view and/or compromise the visual coherence or integrity of viewshaft and its view; the viewshaft and its view;
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment 2. the focal elements that will be affected and the ability to interpret the view; 2. the focal elements that will be affected and the ability to interpret the view; 3. the reduction or loss of amenity, vegetation and/or landscaping values; 3. the reduction or loss of amenity, vegetation and/or landscaping values; 4. the particular cultural, spiritual and/or historical values, interests or associations 4. the particular cultural, spiritual and/or historical values, interests or of importance to tangata whenua that are associated with the viewshaft which may associations of importance to tangata whenua that are associated with the be affected by the over-height structure; viewshaft which may be affected by the over-height structure; 5. the outcomes of any consultation with tangata whenua, in particular with respect 5. the outcomes of any consultation with tangata whenua, in particular with to mitigation measures and/or opportunities to incorporate mātauranga Māori respect to mitigation measures and/or opportunities to incorporate mātauranga principles into the overall scale, form, composition and design of the structure, to: Māori principles into the overall scale, form, composition and design of the a. minimise adverse visual effects on any cultural, spiritual and/or structure, to: historical values, interests or associations of importance to tangata a. minimise adverse visual effects on any cultural, spiritual and/or whenua that are associated with the viewshaft; and historical values, interests or associations of importance to tangata b. acknowledge and reflect the importance of the viewshaft to tangata whenua that are associated with the viewshaft; and whenua. b. acknowledge and reflect the importance of the viewshaft to tangata 6. the view's sensitivity to change or capacity to accommodate change; whenua. 7. whether the additional height of the structure will enhance the quality of the view 6. the view’s sensitivity to change or capacity to accommodate change; through its design; and/or 7. whether the additional height of the structure will enhance the quality of the 8. whether the proposed structure and/or additional height of the structure has a view through its design; and/or functional or operational need to be located within the viewshaft, any alternative 8. whether the proposed structure and/or additional height of the structure has locations for the structure on the site and the permenancy of the structure. a functional or operational need to be located within the viewshaft, any alternative locations for the structure on the site and the permenancy permanency of the structure; 9. the extent to which any adverse effects associated with any network utilities have been avoided, remedied or mitigated by the route, site and method selection, and the operational need and functional need; and 10. necessity of network utilities for people and communities to provide for their: a. social, economic, and cultural well-being and b. health and safety VIEWS-R1 Amend Most of the chapters in the Plan have specific network utility rules but this chapter does not. This means that the Provide clarity in the Viewshafts chapter as to whether the rules apply to Building activities (excluding demolition or removal of a structure) on sites within an rule framework and activity status is not clear. network utilities through adding a reference to network utilities identified viewshaft OR
Add a specific rule for network utilities as VIEW-R2.
VIEWS-R1 and VIEWS-S1 to S18 Amend There are multiple matters of discretion that apply under the rule, the effects standards and references to policies. Amend VIEWS-R1 and VIEWS-S1-18 so that the matters over which discretion is This creates confusion. restricted are clear and contained in one place.
Amend In addition, the effects standards reference Policy VIEWS-P3 as matters of discretion. This is not best planning Amend VIEWS-R1 and VIEWS-S1-18 so that the matters of discretion are spelled practice – matters of discretion should be clear and expressed without the need for cross referencing elsewhere in out and do not reference a policy. the Plan.
VIEWS-R1 Support A restricted discretionary activity status is appropriate for building activities in an identified viewshaft that do not Retain the restricted discretionary activity status in VIEWS-R1 for building Building activities (excluding demolition or removal of a structure) on sites within an meet the effects standards. activities that do not comply with the Viewshaft Effects Standards. identified viewshaft
Part 2: District-wide Matters / Natural Environmental Values / Ecosystems and Indigenous Biodiversity
ECO-P4 Oppose The Regional Policy Statement for Taranaki does not take a stance of “avoiding” the removal of indigenous Amend Policy ECO-P4 as follows: vegetation, instead it seeks to “main, enhance and restore” indigenous biodiversity (e.g. BIO Objective 1, BIO Policy Avoid the removal of indigenous vegetation in significant natural areas and/or in the 1, BIO Policy 3, BIO Policy 5). The Regional Policy Statement for Taranaki also seeks to “avoid, remedy or mitigate” Avoid the removal of indigenous vegetation in significant natural areas and/or in Coastal Environment, unless it is necessary: adverse effects on indigenous biodiversity (e.g. BIO Policy 2) the Coastal Environment, unless it is necessary:
1. for the maintenance and repair of existing tracks, fences and farm drains; The New Zealand Coastal Policy Statement has a different tiered approach of: 1. for the maintenance and repair of existing tracks, fences and farm drains; 2. for the maintenance and repair existing infrastructure and network utilities; 1. avoiding adverse effects on rare and threatened taxa (Policy 11(a)); 2. for the operation, maintenance, and repair or upgrade of existing 3. To avoid loss of life, injury, or damage to property; 2. avoiding significant adverse effects on indigenous vegetation and habitats of indigenous species; and infrastructure and network utilities; 4. to undertake plant and animal pest control; 3. avoiding, remedying or mitigating adverse effects on indigenous vegetation and habitats of indigenous species. 3. to avoid loss of life, injury, or damage to property; 5. to provide for tikanga Māori and allow for the collection of vegetation for cultural 4. to undertake plant and animal pest control; purposes; or Given the latest case law on the use of the word “avoid” and the absence of direction to “avoid” removal of 5. to provide for tikanga Māori and allow for the collection of vegetation for 6. to meet the requirements of a conservation covenant. indigenous vegetation in significant natural areas in the higher policy documents, it is recommended that the cultural purposes; or
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment policy be amended to take a more moderate stance. There may be activities that do require removal of a small 6. to meet the requirements of a conservation covenant. amount of indigenous vegetation, and the avoid position of this policy would effectively prohibit that.
As notified, the non-complying activity status of Rule ECO-R1 combined with the “avoid” policy position of ECO-P4 amounts to prohibition.
Because of the different approach in the Regional Policy Statement and New Zealand Coastal Policy Statement, the policy needs to be amended to separate out the approach in terrestrial environment from the coastal environment (to which the New Zealand Coastal Policy Statement applies).
Allowing for the maintenance and repair of existing network utility structures is an appropriate way to achieve to Objective NU-O1 and give effect to INF Objective 1 and INF Policy 1 in the Regional Policy Statement for Taranaki. However “operation” and “upgrade” of network utilities also needs to be provided for. New policy Amend BIO Policy 7 I the Regional Policy Statement for Taranaki states: Transpower’s preference is for a new National Grid specific policy NU-Pxx (refer earlier submission point). Should this not be granted Transpower seeks a new In the maintenance and enhancement of indigenous biodiversity in Taranaki consideration will be given to policy to the Ecosystems and Indigenous Biodiversity chapter as follows: the social and economic benefits of appropriate use and development of resources ECO-P8 The explanation to the policy clarifies that Policy 7 recognises the need to consider the social and economic benefits of appropriate use and When considering any adverse effects on a significant natural area or development of resources in achieving the Regional Policy Statement’s objectives and policies to maintain and indigenous vegetation by the National Grid, have regard to: enhance indigenous biodiversity values in Taranaki. The balancing of biodiversity values and community benefits 1. any social benefits of the activity to people and communities; will need to take into account the 2. any economic benefits of the activity; issues, objectives and policies for biodiversity set out in this section of the Statement and the relevant provisions of 3.. the efficient operation of infrastructure, particularly the operational and other sections. functional needs of infrastructure; and 4. the extent to which any adverse effects have been avoided, remedied or The current suite of objectives and policies for ecosystems and indigenous biodiversity do not reflect the need to mitigated by the route, site and method selection. consider any social and economic benefits of using the resource.
It is likely that the occasionally new network utility will be required within an area of significant natural area or indigenous vegetation. In order to meaningfully give effect to INF Objective 1 and INF Policy 1 in the Regional Policy Statement for Taranaki and proposed Objective NU-O1 and NU-O2, that consideration is given to the technical and operational needs of network utilities.
This approach also give effect to Policy 4 of the National Policy Statement for Electricity Transmission.
Transpower’s preference is for a new policy NU-Pxx, but this is an alternative approach should that relief not be accepted. ECO-P6 Amend Policy ECO-P6 as follows: Sections 2.1 and 2.2 of the document Guidance on Good Practice Biodiversity Offsetting in New Zealand, 2014 Ensure that where biodiversity offsets are proposed to manage residual adverse refers to significant residual adverse effects: Ensure that where biodiversity offsets are proposed to manage significant effects from an activity on indigenous vegetation: residual adverse effects from an activity on indigenous vegetation: “Measurable conservation outcomes resulting from actions designed to compensate for significant where possible, all other adverse effects have been appropriately avoided, remedied residual adverse biodiversity impacts…” and 1. where possible, all other adverse effects have been appropriately avoided, and mitigated; remedied and mitigated; the goal of the biodiversity offsets is no net loss and, preferably, a net gain of “A mitigation hierarchy to be followed, i.e. offsetting significant residual effects after appropriate 2. the goal of the biodiversity offsets is no net loss and, preferably, a net gain of biodiversity; avoidance, minimisation and on-site rehabilitation activities have taken place…”[emphasis added] biodiversity; the conservation outcomes are measurable and positive; 3. the conservation outcomes are measurable and positive; the offset is not proposed to compensate for more than minor adverse effects on It is recommended that the policy be amended to align with this document. 4. the offset is not proposed to compensate for more than minor adverse effects highly vulnerable and irreplaceable biodiversity components; and on highly vulnerable and irreplaceable biodiversity components; and the biodiversity offsets are in accordance with best practice, including but not 4. the biodiversity offsets are in accordance with best practice, including but not limited to New Zealand Government guidance on biodiversity offsetting. limited to New Zealand Government guidance on biodiversity offsetting. ECO-R1 Indigenous vegetation disturbance within a scheduled significant natural Support with Retain Rule ECO-R1 as a permitted activity area, not otherwise provided for in this table amendments Transpower supports the permitted activity status for vegetation disturbance to enable the maintenance and repair of existing tracks, infrastructure, including network utilities, as set out in clause (2). This is an appropriate All zones approach to giving effect to INF Objective 1 and INF Policy 1 in the Regional Policy Statement for Taranaki and Proposed Objective NU-O1 and NU-O2. Activity status: PER
Where the vegetation disturbance is:
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment Support with Amend the standards for Rule ECO-R1 as follows: 1. within an area subject to an Open Space Covenant under the Queen Elizabeth II amendments The standards would benefit from recognising the operation of network utilities as well as the maintenance, repair National Trust Act 1977, a Ngā Whenua Rahui Kawenata, a Conservation Covenant and upgrade. Standard (2) is currently trying to address a number of very different activities and it is Where the vegetation disturbance is: under the Reserves Act 1977 or the Conservation Act 1987 or a Heritage covenant recommended that these be split out for clarity. under the Heritage New Zealand Pouhere Taonga Act 2014 and the vegetation 1. within an area subject to an Open Space Covenant under the Queen Elizabeth disturbance is provided for in that covenant or order; and/or In addition, it is appropriate for network utilities activities to include operation and upgrade. This is an appropriate II National Trust Act 1977, a Ngā Whenua Rahui Kawenata, a Conservation 2. necessary for the maintenance and repair of existing tracks, fences, drains, approach to giving effect to INF Objective 1 and INF Policy 1 in the Regional Policy Statement for Taranaki and Covenant under the Reserves Act 1977 or the Conservation Act 1987 or a structures and infrastructure, including network utilities; and/or Proposed Objective NU-O1 and NU-O2. Heritage covenant under the Heritage New Zealand Pouhere Taonga Act 2014 3. necessary to remove vegetation that endangers human life or existing buildings or and the vegetation disturbance is provided for in that covenant or order; and/or structures; and/or 2. necessary for the maintenance and repair of existing tracks, fences, drains, 4. required for the construction of new fences and trap lines for conservation structures and infrastructure, including network utilities; and/or purposes to exclude stock or pest animals, and associated pest management work; 3. necessary to remove vegetation that endangers human life or existing and/or buildings or structures; and/or 5. gathering plants in accordance with Māori customs and values; and/or 4. required for the construction of new fences and trap lines for conservation 5. the removal or clearance of manuka or kanuka only, which is under 25 years old. purposes to exclude stock or pest animals, and associated pest management work; and/or Activity status where compliance not achieved: NC 5. gathering plants in accordance with Māori customs and values; and/or 5. the removal or clearance of manuka or kanuka only, which is under 25 years old. and/or 6. necessary for the maintenance, operation, repair or upgrade of network utilities and infrastructure, including associated tracks. Amend Amend Rule ECO-R1 so that the activity status where compliance with the It is quite a jump in activity status to go from Permitted to Non-Complying. The policies should be strong enough to standards is not achieved is Discretionary rather than Non-Complying ensure that an application for inappropriate clearance of significant natural area is able to be declined. It is considered that a discretionary activity is sufficiently stringent.
This will match the rule cascade in rule ECO-R2.
ECO-R2 Indigenous vegetation disturbance in the Coastal Environment Area Support with Relocate Rule ECO-R2 into the Coastal Environment chapter amendments This rule is specific to the Coastal Environment and is therefore more logically located within the Coastal Rural Zones Environment chapter.
Activity status: PER Support with Retain Rule ECO-R2(2)(c) as a permitted activity amendments Transpower supports the permitted activity status for vegetation disturbance to enable the maintenance and Where: repair of existing tracks, infrastructure, including network utilities, as set out in clause (2)(c). This is an appropriate approach to giving effect to INF Objective 1 and INF Policy 1 in the Regional Policy Statement for Taranaki and 1. the extent of indigenous vegetation disturbed and/or cleared per site does not Proposed Objective NU-O1 and NU-O2 of this Plan. exceed an area of 100m2 in area in any five year period; and 2. the vegetation disturbance is necessary for: Support with Amend Rule ECO-R2 as follows: a. conservation activities; amendments Upgrading of network utilities should be included. For clarity it is recommended that network utilities and b. customary activities; infrastructure be given its own clause in this rule. Indigenous vegetation disturbance in the Coastal Environment Area c. the operation and/or maintenance and repair of existing pasture, fences, drains, structures, network utilities and infrastructure, including However, the term “disturbed” is not defined and therefore makes the rule uncertain. Transpower seeks that the Rural Zones existing roads or tracks (including walking or cycling tracks); or term be replaced by a more meaningful and clear description of the activity that matches the defined term d. the avoidance or loss of life, injury or serious damage to property. “indigenous vegetation disturbance”. Activity status: PER
Activity status where compliance not achieved: DIS Limiting the area to be disturbed is an appropriate way of achieving Policy 11(b) in the New Zealand Coastal Policy Where: Statement. 1. the extent of indigenous vegetation disturbed disturbance and/or cleared per Transpower seeks insertion of a new standard that allows trimming or removal of indigenous vegetation in the site does not exceed an area of 100m2 in area in any five year period; and Coastal Environment Area where this is necessary to comply with the Electricity (Hazards from Trees) Regulations 2. the vegetation disturbance is necessary for: 2003. a. conservation activities; b. customary activities; c. the operation and/or maintenance and repair of existing pasture, fences, drains, structures, network utilities and infrastructure, including existing roads or tracks (including walking or cycling tracks); or d. the operation, maintenance, repair or upgrading of network utilities and infrastructure; de. the avoidance or loss of life, injury or serious damage to property 3. the trimming or removal of the indigenous vegetation is needed to comply with the Electricity (Hazards from Trees) Regulations 2003;
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment New Rule Amend Add a new rule which addresses new network utilities that require the removal There currently is no rule which specifically covers the removal or trimming of indigenous vegetation or within a or trimming of indigenous vegetation or within a scheduled significant natural scheduled significant natural area for new infrastructure. Infrastructure often has constraints that other activities area: do not. In order to give effect to INF Objective 1 and INF Policy 1 in the Regional Policy Statement for Taranaki, Transpower seeks inclusion of a new rule. ECO-RZ
As the rules are currently crafted, the removal or trimming of vegetation or indigenous vegetation or within a Indigenous vegetation disturbance within a scheduled significant natural area scheduled significant natural area for new infrastructure would be covered by catchall Rule ECO-R1 and would be a for new network utilities and associated tracks non-complying activity. When considered alongside the “avoid” policy direction of ECO-P4, it would amount to a prohibited activity. This does not give effect to the network utility provisions of the Regional Policy Statement, nor All zones does it match the policy direction of the Indigenous Biodiversity provisions in the Regional Policy Statement. Activity status: RDIS Although this new rule is focused on natural environmental values, it is recommended that this be located in the Matters over which discretion is restricted: Network Utility Chapter so that all rules regarding network utilities can be considered comprehensively. 1. The operation need, technical and functional needs of the infrastructure. 2. Whether any proposed indigenous vegetation disturbance associated with the activity will result in loss of habitat that supports or provides a key life function for 'threatened' or 'at risk' indigenous species. 3. The extent to which unavoidable adverse effects of the proposed indigenous vegetation disturbance associated with the activity on areas of significant biodiversity can be remedied or mitigated. 4. The local, regional and national benefits of the infrastructure.
AND
Locate this rule in the Network Utilities chapter. New Rule Amend Add a new Rule in the Network Utilities chapter which addresses new network There currently is no rule which specifically covers the removal or trimming of indigenous vegetation or within the utilities that require the disturbance of indigenous vegetation in the Coastal coastal environment area for new infrastructure. Infrastructure often has constraints that other activities do not. In Environment: order to give effect to INF Objective 1 and INF Policy 1 in the Regional Policy Statement for Taranaki, Transpower seeks inclusion of a new rule. ECO-RZ
As the rules are currently crafted, the disturbance of vegetation in the Coastal Environment Area would be Indigenous vegetation disturbance in the Coastal Environment for new network captured by catchall Rule ECO-R2 and would be a discretionary activity. This does not give effect to the network utilities and associated tracks utility provisions of the Regional Policy Statement, nor does it match the policy direction of the Indigenous Biodiversity provisions in the Regional Policy Statement. All zones
Although this new rule is focused on natural environmental values, it is recommended that this be located in the Activity status: RDIS Network Utility Chapter so that all rules regarding network utilities can be considered comprehensively. Matters over which discretion is restricted:
1. The operation need, technical and functional needs of the infrastructure. 2. Whether any proposed indigenous vegetation disturbance associated with the activity will result in loss of habitat that supports or provides a key life function for 'threatened' or 'at risk' indigenous species. 3. The extent to which unavoidable adverse effects of the proposed indigenous vegetation disturbance associated with the activity on areas of significant biodiversity can be remedied or mitigated. 4. The local, regional and national benefits of the infrastructure.
AND
Locate this rule in the Network Utilities chapter.
Part 2: District-wide Matters / Natural Environmental Values / Natural Features and Landscapes
Other relevant regulations Amend Transpower seek clarification that the policies apply even though there are no applicable rules. If they do, Amend the provisions in the Natural Features and Landscapes chapter to clarify Transpower supports a new National Grid policy NU-Pxx as it recognises the National Grid. The statement also whether the policies apply to the following outstanding natural landscapes The following outstanding natural landscapes are protected by other legislation requires clarification as to whether district plan rules apply to the site as the statement be interpreted that which have no rules attributed to them: including the Conservation Act 1987, the National Parks Act 1980, the Marine absolutely no rules apply to the site when it is suspected it is only the Natural Features and Landscapes rules which Mount Taranaki and the Kaitake and Pouakai mountain ranges, which Reserves Act 1971 and Sugar Loaf Islands Marine Protected Area Act 1991, and as do not apply. are located within the Egmont National Park boundaries. such there are no District Plan rules that apply to them: Paritutu, Ngā Motu (Sugar Loaf Islands) and Tapuae are located within the Ngā Motu/Sugar Loaf Islands Marine Protected Area and the Tapuae Marine Reserve.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment Mount Taranaki and the Kaitake and Pouakai mountain ranges, which are located within the Egmont National Park boundaries. Transpower seek clarification that the policies apply even though there are no Paritutu, Ngā Motu (Sugar Loaf Islands) and Tapuae are located within the Ngā applicable rules. If they do, Transpower support its National Grid policy NU-Pxx Motu/Sugar Loaf Islands Marine Protected Area and the Tapuae Marine Reserve. as it recognises the National Grid. Transpower also seeks clarification if other rules in the DP apply to these areas, and rewording to reflect the intent Amend Transpower seek clarification that the policies apply even though there are no applicable rules. If they do, Amend the provisions in the Natural Features and Landscapes chapter to clarify Transpower supports its new National Grid policy NU-Pxx as it recognises the National Grid. whether other rules elsewhere in the Plan apply to the following outstanding nature landscapes which have no rules attributed to them in this chapter: Mount Taranaki and the Kaitake and Pouakai mountain ranges, which are located within the Egmont National Park boundaries. Paritutu, Ngā Motu (Sugar Loaf Islands) and Tapuae are located within the Ngā Motu/Sugar Loaf Islands Marine Protected Area and the Tapuae Marine Reserve.
NFL-P3 Amend Transpower consider that Policy NFL-P3 should enable the repair, maintenance and upgrade of network utilities as Transpower’s preference is for a new National Grid specific policy NU-Pxx (refer a specific activity. This would be an appropriate way to give effect to INF Objective 1 and INF Policy 1 of the above submission point). Should this not be granted Transpower seeks Allow activities within outstanding natural features and landscapes where: Regional Policy Statement for Taranaki. Transpower has assets which go through the Sugar Loaf Islands amendment to Policy NFL-P3 as follows: outstanding natural landscape. Recognition of, and provision for, the operation, upgrade, repair and maintenance 1. they are for existing land uses, conservation activities, customary activities, of the existing National Grid is an appropriate way to give effect to Objective 1 and Policy 2 of the National Policy Allow activities within outstanding natural features and landscapes where: natural hazard mitigation activities, or the alteration, maintenance or removal of Statement for Electricity Transmission. existing buildings or structures; and 1. they are for existing land uses, conservation activities, customary activities, 2. they do not adversely affect the special values and characteristics of outstanding Transpower’s preferred position is the new policy NU-Pxx, but this is alternative relief should that submission point natural hazard mitigation activities, or the alteration, maintenance or removal natural features and landscapes not be accepted of existing buildings or structures; and 2. they are for the operation, maintenance, upgrade, and development of the National Grid; and 2 3. they do not adversely affect the special values and characteristics of outstanding natural features and landscapes NFL-P5 Support with Transpower supports NFL-P5(5) and (6) although seeks amendments to simplify and focus the clauses of the policy. Amend Policy NFL-P5(5) and (6) as follows: amendments Ensure that activities within outstanding natural features and landscapes, including Ensure that activities within outstanding natural features and landscapes, their the scale, location and design, recognise and maintain the values and including their the scale, location and design, recognise and maintain the values characteristics of the outstanding natural feature and landscape, having regard to: and characteristics of the outstanding natural feature and landscape, having regard to: 1. the particular landscape values and characteristics of the outstanding natural … feature or landscape at the local, regional or national level, including ecological and 5. the purpose of the activity and whether it has an operational, technical, scientific significance, the presence of threatened and regionally distinctive native functional need to locate within an outstanding natural feature or landscape;, species and waters with strong biotic associations and 2. the degree and significance of actual or potential adverse effects (including 6. whether it is an anticipated feature of the environment; cumulative effects) on the values and characteristics of the natural and geological 6 7. the benefits derived from the proposed activity at the local, regional or features of the natural landscape, and the efficacy of measures to avoid, remedy or national level; and mitigate such effects; … 3. the particular cultural, spiritual and/or heritage values, interests or associations of importance to tangata whenua as kaitiaki and mana whenua that are associated with the outstanding natural feature and landscape and the potential impact on those values, interests or associations; 4. the outcomes of any consultation with and/or cultural advice provided by tangata whenua, including with respect to mitigation measures and opportunities for tangata whenua’s relationship with ancestral lands, water, sites, waahi tapu and other taonga to be maintained or strengthened; 5. the purpose of the activity and whether it has an operational, technical, functional need to locate within an outstanding natural feature or landscape, and whether it is an anticipated feature of the environment; 6. the benefits derived from the proposed activity at the local, regional or national level; and 7. the degree of modification to the existing outstanding natural feature or landscape and its sensitivity or vulnerability to change.
Part 2: District-wide Matters / Subdivision
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment Overview Support with The National Grid Subdivision Corridor is an essential way to give effect to Policy 10 of the National Policy Retain the reference to the National Grid Corridor within the Overview of the amendments Statement for Electricity Transmission. This cross reference to the National Grid Subdivision Corridor is important Subdivision chapter, although amend this to be “National Grid Subdivision Cross references to other relevant District Plan provisions for plan users considering subdivision. Corridor”.
It is important to note that in addition to the zone chapters, a number of other Part 2: District-Wide Matters chapters also contain provisions that may be relevant for certain subdivisions, including:
. Network Utilities - The Network Utilities Chapter contains provisions for subdivision of land within the Gas Transmission Pipeline Corridor or the National Grid Corridor. New Objective Amend INF Policy 2 of the Regional Policy Statement for Taranaki requires the following: Transpower’s preference is for amendment to Policy NU-P6 (refer earlier submission point). Should this not be granted Transpower seeks , a new The adverse effects of subdivision, use and development on the safety, efficiency, operation, maintenance objective in District-wide Matters / Subdivision as follows: and upgrading of the region’s network utilities and on other physical infrastructure of regional significance (including where this is of national importance) will be avoided or mitigated. SUB-O4 Subdivision avoids or mitigates adverse effects on the safety, efficiency, Subdivision at its most basic form is simply lines on a map, however subdivision enables intensification of activities operation, maintenance and upgrading of the National Grid and other network and structures. In order to give effect to this policy, a new objective is appropriate in the Subdivision chapter that utilities seeks an outcome whereby subdivision avoids or mitigates adverse effects on the safety, efficiency, operation, maintenance and upgrading of the National Grid and other network utilities.
If the amendments sought by Transpower to Policy NU-P6 are not implemented, then this is the alternative relief. .
SUB-R1 Boundary adjustment Amend Amendment is sought to include a new matter of control specific to the National Grid to refer to all adverse Add a new matter of control to Rule SUB-R1 as follows: effects, rather than only reverse sensitivity effects. This is because the National Grid can be directly impacted by 6. Management to ensure the National Grid is not compromised and reverse All zones the activities of others (such as, earthworks that undermine structures). The amendments sought by Transpower sensitivity effects are avoided. better reflects Policies 10 and 11 of the NPSET and in particular addresses the management of activities in the Activity status: CON National Grid Yard, as well as the National Grid Subdivision Corridor.
Amend Amendment is sought to include a new matter of control specific to the National Grid to refer to all adverse Add a new matter of discretion to Rule SUB-R1 as follows: Where: effects, rather than only reverse sensitivity effects. This is because the National Grid can be directly impacted by 7. Management to ensure the National Grid is not compromised and reverse
the activities of others (such as, earthworks that undermine structures). The amendments sought by Transpower sensitivity effects are avoided. 1. the boundary adjustment does not alter: better reflects Policies 10 and 11 of the NPSET and in particular addresses the management of activities in the a. the permitted activity status of any existing permitted activities occuring on the allotments and/or the ability of an existing permitted activity to continue to comply National Grid Yard, as well as the National Grid Subdivision Corridor. as a permitted activity under the rules and standards in this Plan; and/or b. the extent or degree to which any consented or otherwise lawfully established activity occuring on the allotments does not comply with a rule or standard in this Plan; and 2. in the Rural Production Zone, the boundary adjustment does not result in additional potential for residential units as a permitted activity; and 3. all Subdivision Effects Standards are complied with.
Matters over which control is reserved:
1. The size, design and layout of lots that would exist after the boundary adjustment, including the effects of any additional permitted activity development potential resulting from the reconfigured layout. 2. Legal and physical access to and from lots affected by the boundary adjustment. 3. Protection, maintenance or enhancement of natural features and landforms, historic heritage, sites of significance to tangata whenua, archaeological sites or any other identified features. 4. Where relevant, compliance with Council’s Land Development and Subdivision Infrastructure Standard Local Amendments Version 3. 5. The matters referred to in sections 108 and 220 of the Act. Activity status where compliance not achieved: RDIS
Matters over which discretion is restricted:
1. The extent and effects of any non-compliance with a rule or standard, and where relevant, the matters of discretion in any infringed rule(s) or standard(s).
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment 2. The size, design and layout of lots that would exist after the boundary adjustment, including the effects of any additional permitted activity development potential resulting from the reconfigured layout. 3. Legal and physical access to and from lots affected by the boundary adjustment 4. The extent to which the boundary adjustment will ensure that natural features and landforms, waterbodies, indigenous vegetation, historic heritage, sites of significance to tangata whenua, archaeological sites or identified features are protected, maintained or enhanced. 5. Where relevant, compliance with Council’s Land Development and Subdivision Infrastructure Standard Local Amendments Version 3. 6. The matters described in Section 108 and 220 of the Act.
SUB-R2 Subdivision of land solely to create an allotment that is for the purpose of Support Transpower supports the creation of new lots for the purpose of network utilities as a controlled activity. This is an Retain the activity status of SUB-R2 as notified. public works, network utilities, reserves or access appropriate approach to achieve Objective NU-O1 and give effect to INF Objective 1 and INF Policy 1 in the Regional Policy Statement for Taranaki. All zones
Activity status: CON Support with Transpower supports the creation of new lots for the purpose of network utilities as a controlled activity with no Amend Rule SUB-R2 as follows: amendments minimum lot size or minimum dimensions. This is an appropriate approach to achieve Objective NU-O1 and give Where: effect to INF Objective 1 and INF Policy 1 in the Regional Policy Statement for Taranaki. SUB-R2 Subdivision of land solely to create an allotment that is for the purpose of public works, network utilities, reserves or access 1. the creation of any lot does not limit or interfere with any existing allotment's physical and/or legal access to a road. However some of the matters over which control is reserved are not appropriate for network utility subdivisions, especially as they do not give rise in of themselves for additional demand on Council services (and therefore All zones
Matters over which control is reserved: negate the need for financial contributions, bonds etc as contained in Section 108 of the RMA). Activity status: CON
Subdivision of a site with historic heritage, sites or areas of significance to Maori etc are not valid concerns for 1. The size, design and layout of lots for the purpose of public works, network subdivision and the landuses are covered by other rules. Where: utilities, reserves or access.
2. Legal and physical access to and from lots. 3. Protection, maintenance or enhancement of natural features and landforms, Given that the only standard to comply with is physical and/or legal access to a road, the matters over which 1. the creation of any lot does not limit or interfere with any existing allotment's discretion is restricted need to be based on (and relevant to) non-compliance with that standard. physical and/or legal access to a road. waterbodies, indigenous vegetation, historic heritage, sites of significance to tangata whenua, archaeological sites or identified features. Matters over which control is reserved: 4. Where relevant, compliance with the Council’s Land Development and Subdivision Infrastructure Standard Local Amendments Version 3. 1. The size, design and layout of lots for the purpose of public works, network 5. The matters referred to in sections 108 and 220 of the Act. utilities, reserves or access.
2. Legal and physical access to and from lots. Activity status where compliance not achieved: RDIS 3. Protection, maintenance or enhancement of natural features and landforms,
Matters over which discretion is restricted: waterbodies, indigenous vegetation, historic heritage, sites of significance to tangata whenua, archaeological sites or identified features.
1. The size, design and layout of lots for the purpose of public works, network 4 3. Where relevant, compliance with the Council’s Land Development and Subdivision Infrastructure Standard Local Amendments Version 3. utilities, reserves or access. 2. Legal and physical access to and from lots. 5 4. The matters referred to in sections 108 and 220 of the Act.
3. The extent to which the subdivision will ensure that natural features and Activity status where compliance not achieved: RDIS landforms, waterbodies, indigenous vegetation, historic heritage, sites of significance to tangata whenua, archaeological sites or identified features are Matters over which discretion is restricted: protected, maintained or enhanced. 4. Where relevant, compliance with Council’s Land Development and Subdivision 1. The size, design and layout of lots for the purpose of public works, network Infrastructure Standard Local Amendments Version 3. 5. Those matters described in section 108 and 220 of the Act. utilities, reserves or access. 2. Legal and physical access to and from lots. 3. The extent to which the subdivision will ensure that natural features and landforms, waterbodies, indigenous vegetation, historic heritage, sites of significance to tangata whenua, archaeological sites or identified features are protected, maintained or enhanced. 4. Where relevant, compliance with Council’s Land Development and Subdivision Infrastructure Standard Local Amendments Version 3. 5. Those matters described in section 108 and 220 of the Act. 6. Any effects associated with limiting any existing allotment's physical and/or legal access to a road
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment SUB-R3 Subdivision of land to create an allotment within a Future Urban Zone Amend INF Policy 2 of the Regional Policy Statement for Taranaki requires the following: Add the following matters over which control is reserved to Rule SUB-R3 to give effect to INF Policy 2 of the Regional Policy Statement for Taranaki: Future Urban Zone The adverse effects of subdivision, use and development on the safety, efficiency, operation, maintenance and upgrading of the region’s network utilities and on other physical infrastructure of regional 5. Any effects on network utilities; Activity status: CON significance (including where this is of national importance) will be avoided or mitigated. 6. The ability and sufficient capacity to provide appropriate infrastructure; and 7. Potential reverse sensitivity effects on existing network utilities. Where: Subdivision at its most basic form is simply lines on a map, however subdivision enables intensification of activities and structures. In order to give effect to the RPS policy, additional matters of control are required which: 1. one allotment is created from the parent title with a minimum lot size of 20ha; 1. enable consideration of any effects on network utilities; and 2. ensure there is the ability and sufficient capacity to provide appropriate infrastructure; and 2. all Subdivision Effects Standards are complied with. 3. addresses potential reverse sensitivity effects on existing network utilities.
Amend Amendment is sought to include a new matter of control specific to the National Grid to refer to all adverse Add the following matter over which control is reserved to Rule SUB-R3 to give Matters over which control is reserved: effects, rather than only reverse sensitivity effects. This is because the National Grid can be directly impacted by effect to Policy 10 of the National Policy Statement for Electricity Transmission: the activities of others (such as, earthworks that undermine structures). The sought text better reflects Policies 10 1. The extent to which the site layout and design and location of a building platform and 11 of the NPSET and in particular addresses the management of activities in the National Grid Yard, as well as Management to ensure the National Grid is not compromised and reverse will affect the ability to comprehensively develop and use the Future Urban Zone in the National Grid Subdivision Corridor. sensitivity effects are avoided. future for urban growth purposes. 2. Legal and physical access to and from lots. Amend It is also not clear where the “Future Urban Zones” are located as the term is not used on the Planning Maps. It is Clearly identify the Urban Development Areas and Future Urban Zones on the 3. Protection, maintenance or enhancement of natural features and landforms, assumed these areas are identified as “Development Areas” on the planning maps. If this is the case, consistent Planning Maps and use consistent terminology. waterbodies, indigenous vegetation, historic heritage, sites of significance to terminology should be used. tangata whenua, archaeological sites or identified features. 4. The matters referred to in section 108 and 220 of the Act.
SUB-R4 Subdivision of land to create allotment(s) within the Rural Production Zone Support Transpower supports matters over which control is reserved (11). These matters of control are an appropriate way Retain the matters over which control is reserved (11) for Rule SUB-R4. (except where rule ECO-R6 applies) to give effect to INF Policy 2 of the Regional Policy Statement for Taranaki.
(1) Rural Production Zone
Activity status: CON Amend Amendment is sought to include a new matter of control specific to the National Grid to refer to all adverse Add a new matter of control to Rule SUB-R4 as follows: effects, rather than only reverse sensitivity effects. This is because the National Grid can be directly impacted by 13. Management to ensure the National Grid is not compromised and reverse Where: the activities of others (such as, earthworks that undermine structures). The amendments sought by Transpower sensitivity effects are avoided. better reflects Policies 10 and 11 of the NPSET and in particular addresses the management of activities in the 1. one allotment, with a minimum lot size of 4,000m2 is created from the parent National Grid Yard, as well as the National Grid Subdivision Corridor. title, provided there is a balance area remaining from the Record of Title subject to subdivision of at least 20 ha; and 2. all Subdivision Effects Standards, (except SUB-S1(1) for the allotment provided for by clause 1 of this rule) are complied with.
Matters over which control is reserved:
1. The size, design, shape, location and layout of lots. 2. Efficient use of land and compatibility with rural character and the role, function and predominant character of the Rural Production Zone. 3. Where relevant, consistency with the Subdivision Design Guide. 4. The protection, maintenance and/or enhancement of natural features and landforms, waterbodies, indigenous vegetation, historic heritage, sites of significance to tangata whenua, archaeological sites or identified features. 5. The measures to avoid, remedy, or mitigate any adverse effects on the particular cultural, spiritual and/or heritage values, interests or associations of importance to tangata whenua as kaitiaki and mana whenua that are associated with the land being subdivided. 6. The subdivision design and layout, and the design and location of building platforms and access to minimise earthworks and land disturbance, and integrate built form into the natural landform. 7. Provision of appropriate infrastructure and services, including water supply (including firefighting water supply), wastewater systems, stormwater control and disposal, telecommunications and electricity in accordance with Council’s Land Development and Subdivision Infrastructure Standard Local Amendments Version 3. 8. Use of sustainable stormwater management and water sensitive (low impact) design principles. 9. Effects on the stability of land and buildings, and potential to create new or exacerbate existing natural hazards.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment 10. Management of construction effects, including traffic movements, hours of operation, noise, earthworks and erosion and sediment control. 11. Management of potential reverse sensitivity effects on existing land uses, including network utilities, rural activities or significant hazardous facilities. 12. The matters referred to in sections 108 and 220 of the Act.
SUB-R5 Subdivision of land to create allotments within the Rural Lifestyle Zone Support Transpower supports matters over which control is reserved (11). These matters of control are an appropriate way Retain the matters over which control is reserved (11) for Rule SUB-R5. to give effect to INF Policy 2 of the Regional Policy Statement for Taranaki. (1) Rural Lifestyle Zone
Activity status: RDIS
Amend Amendment is sought to include a new matter of control specific to the National Grid to refer to all adverse Add a new matter of control to Rule SUB-R5 as follows: Where: effects, rather than only reverse sensitivity effects. This is because the National Grid can be directly impacted by 13. Management to ensure the National Grid is not compromised and reverse the activities of others (such as, earthworks that undermine structures). The amendments sought by Transpower sensitivity effects are avoided. 1. no more than four proposed allotments being created have a lot size of less than 1 better reflects Policies 10 and 11 of the NPSET and in particular addresses the management of activities in the ha in area; and National Grid Yard, as well as the National Grid Subdivision Corridor. 2. every allotment has a minimum lot size of 4,000m2; and 3. for each allotment that has a lot size between 4,000m2 and 1 ha in area, a corresponding allotment of over 1 ha in area is provided; 4. all Subdivision Effects Standards are complied with; and 5. SUB-R5(2)(1) does not apply.
Matters over which discretion is restricted:
1. The size, design, shape, location and layout of lots including allowance for sufficient separation distances between buildings to maintain rural lifestyle character. 2. Efficient use of land and compatibility with rural character and the role, function and predominant character of the Rural Lifestyle Zone. 3. Where relevant, consistency with the Subdivision Design Guide. 4. Protection, maintenance and enhancement of natural features and landforms, waterbodies, indigenous vegetation, historic heritage, sites and areas of significance to Māori, archaeological sites or other identified features. 5. Whether the subdivision has the potential to compromise cultural, spiritual and/or historic values and interests or associations of importance to tangata whenua, and if so, the outcomes of any consultation with tangata whenua, including with respect to: a. opportunities to incorporate mātauranga Māori principles into the design and/or development of the subdivision; b. opportunities for tangata whenua’s relationship with ancestral lands, water, sites, wāhi tapu and other taonga to be maintained or strengthened; and c. options to avoid, remedy or mitigate adverse effects. 6. Whether the subdivision design and layout, and the design and location of building platforms and access will minimise earthworks and land disturbance, and integrate built form into the natural landform. 7. Provision of appropriate infrastructure and services, including water supply (including firefighting water supply), wastewater systems, stormwater control and disposal, telecommunications and electricity in accordance with Council’s Land Development and Subdivision Infrastructure Standard Local Amendments Version 3. 8. Use of sustainable stormwater management and water sensitive (low impact) design principles. 9. Effects on the stability of land and buildings, and potential to create new or exacerbate existing natural hazards. 10. Management of construction effects, including traffic movements, hours of operation, noise, earthworks and erosion and sediment control. 11. Management of potential reverse sensitivity effects on existing land uses, including network utilities, rural activities or significant hazardous facilities. 12. The matters referred to in sections 108 and 220 of the Act.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment SUB-R6 Subdivision of land to create allotment(s) within other zones Support Transpower supports matters over which control is reserved (11). These matters of control are an appropriate way Retain the matters over which control is reserved (11) for Rule SUB-R6. to give effect to INF Policy 2 of the Regional Policy Statement for Taranaki. Commercial and Mixed Use Zones Residential Zones General Industrial Zone Open Space and Recreation Zones Special Purpose Zones (except Future Urban Zone) Support Amendment is sought to include a new matter of control specific to the National Grid to refer to all adverse Add a new matter of control to Rule SUB-R6 as follows: effects, rather than only reverse sensitivity effects. This is because the National Grid can be directly impacted by 14. Management to ensure the National Grid is not compromised and reverse
Activity status: CON the activities of others (such as, earthworks that undermine structures). The amendments sought by Transpower sensitivity effects are avoided. better reflects Policies 10 and 11 of the NPSET and in particular addresses the management of activities in the
National Grid Yard, as well as the National Grid Subdivision Corridor. Where:
1. all Subdivision Effects Standards are complied with.
Matters over which control is reserved:
1. The size, design, shape, location and layout of lots. 2. Efficient use of land and compatibility with the role, function and predominant character of the zone. 3. Consistency with the Subdivision Design Guide, and in the residential zones. the Residential Design Guide. 4. The subdivision layout and accessibility from and connections to surrounding neighbourhoods. 5. Protection, maintenance or enhancement of natural features and landforms, historic heritage, waterbodies, indigenous vegetation, sites of significance to tangata whenua, archaeological sites, or identified features. 6. The measures to avoid, remedy, or mitigate any adverse effects on the particular cultural, spiritual and/or heritage values, interests or associations of importance to tangata whenua as kaitiaki and mana whenua that are associated with the land being subdivided. 7. The subdivision design and layout, and the design and location of building platforms and access to minimise earthworks and land disturbance, and integrate built form into the natural landform. 8. Provision of appropriate infrastructure and services, including water supply (including firefighting water supply), wastewater systems, stormwater control and disposal, telecommunications and electricity in accordance with the Council's Land Development and Subdivision Infrastructure Standard Local Amendments Version 3. 9. Use of sustainable stormwater management and water sensitive (low impact) design principles. 10.Effects on the stability of land and buildings, and potential to create new or exacerbate existing natural hazards. 11.Management of construction effects, including traffic movements, hours of operation, noise, earthworks and erosion and sediment control. 12. Management of potential reverse sensitivity effects on existing land uses, including network utilities or significant hazardous facilities. 13. The matters referred to in sections 108 and 220 of the Act.
Activity status where compliance not achieved: DIS
Part 2: District-wide Matters / General District-wide Matters / Coastal Environment
Overview Amend The Transpower designated New Plymouth substation and associated transmission lines are located within the Amend the Coastal Environment chapter to clarify what provisions apply to Coastal Environment. On the basis that the Coastal Environment chapter provisions are relevant to the Network Utilities. The New Plymouth District coastline stretches some 100km from the Mokau River in management of network utilities, as sought in an earlier submission point, Transpower seeks clarity as to the the north to the Hangatahua (Stony) River in the south. The natural character, relationship between the Network Utilities Chapter and the Coastal Environment Chapter, specifically what landscape and associated values of the coastal environment contribute to the provisions are relevant in the coastal chapter for Network Utilities. district's distinctive and unique character. Our coast is important to our lifestyle, however it is under increasing development pressure which can impact on coastal values.
New Plymouth District Council is responsible for managing activities on land (the landward side of Mean High Water Springs (MHWS)), and the Taranaki Regional Council is responsible for activities in the Coastal Marine Area (seaward of MHWS).
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment Integrated management is necessary to manage activities that cross the jurisdictional boundary between regional and territorial authorities.
CE-P2 Conditional On the basis the text of the policy accurately reflects the NZCPS, Policy CE-P2 is supported. However, Transpower Subject to the insertion of a new National Grid specific Policy CE-Pxx, Policy CE- support seeks recognition of the National Grid within the Coastal Environment Chapter to give effect to the NPSET. As P2 is not opposed. Protect natural character in the Coastal Environment by ensuring: national policy statements, both the NPSET and NZCPS sit at the top of the RMA plan hierarchy with neither document technically having supremacy over the other. On this basis the relationship between the directives 1. any adverse effects on the natural characteristics, processes and values which within these two documents needs to be carefully assessed in that some NZCPS policies provide for ‘avoidance’ contribute to Areas of Outstanding Natural Character are avoided; outcomes, while the NPSET is largely ‘enabling’ with a ‘seek to avoid’ directive within high value natural areas. To 2. any significant adverse effects on the natural characteristics, processes and values address the relationship and manage the tensions between the National Policy Statements, detailed and specific which contribute to other coastal natural character are avoided; and National Grid policies are recommended. The Southland RPS and Bay of Plenty Regional Coastal Plan have also 3. any other adverse effects on the natural characteristics, processes and values adopted specific ‘seek to avoid’ National Grid policies, and a similar policy approach is which contribute to coastal natural character are avoided, remedied or mitigated. emerging through recently issued consent orders in relation to proposed district plans (Whangarei and Opotiki). On this basis, Transpower does not oppose Policy CE-P2, provided that the new policy CE-Pxx is accepted.
CE-P3 Support with Transpower supports Policy CE-P3 which recognises that some activities due to their operational need are Retain Policy CE-P3 in terms of its recognition of operational need and its amendments appropriate in the coastal environment. Reference to “functional need” would give effect to the NZCPS. recognition of activities that are appropriate in the coastal environment Allow activities within the Coastal Environment which: In relation to the National Grid, Transpower seeks reference to the National Grid. AND 1. appropriately avoid, remedy or mitigate adverse effects on natural processes, coastal natural character, landscape, amenity, historic, cultural and/or ecological Amend Policy CE-P3(3) to recognise that Port Taranaki cannot operate in values; isolation and requires the support of necessary infrastructure as follows: 2. mitigate any significant hazard risks to people, property and the environment to an acceptable level; Allow activities within the Coastal Environment which: 3. have an operational need to be located in the coastal environment, such as Port Taranaki; and/or 1. appropriately avoid, remedy or mitigate adverse effects on natural processes, 4. provide for papakāinga, marae and associated development. coastal natural character, landscape, amenity, historic, cultural and/or ecological values; 2. mitigate any significant hazard risks to people, property and the environment to an acceptable level; 3. have an operational, or functional need to be located in the coastal environment, such as Port Taranaki or the National Grid; and/or 4. provide for papakāinga, marae and associated development. CE-P5 Oppose Subject to the insertion of a new National Grid specific Policy CE-Pxx, Policy CE- As a general comment. policy CE-P5 sets a particularly high bar as it is an “avoid” policy and goes well beyond the P5 is not opposed. Avoid activities within the Coastal Environment that are likely to result in adverse policy position of the New Zealand Coastal Policy Statement. As notified, even a less than minor adverse effect effects on coastal natural character, landscape, amenity, historic, cultural and could not be consented due to the directive to avoid adverse effects of any magnitude. ecological values and/or that will be vulnerable to risks from coastal hazards and If Policy CE-Pxx is not accepted, Transpower seeks amendment to Policy CE-P5 climate change and/or that are likely to create or increase hazard risks to people, Transpower seeks recognition of the National Grid within the Coastal Environment Chapter to give effect to the to focus on “significant and permanent” adverse effects. property and the environment, including: NPSET. As national policy statements, both the NPSET and NZCPS sit at the top of the RMA plan hierarchy with neither document technically having supremacy over the other. On this basis the relationship between the 1. significant hazardous facilities; directives within these two documents needs to be carefully assessed in that some NZCPS policies provide for 2. quarries; ‘avoidance’ outcomes, while the NPSET is largely ‘enabling’ with a ‘seek to avoid’ directive within high value 3. large scale renewable electricity generation activities; natural areas. To address the relationship and manage the tensions between the NPS’s, detailed and specific 4. petroleum exploration and petroleum production; and National Grid policies are recommended. The Southland RPS and Bay of Plenty Regional Coastal Plan have also 5. hazard sensitive activities. adopted specific ‘seek to avoid’ National Grid policies, and a similar policy approach is emerging through recently issued consent orders in relation to proposed district plans (Whangarei and Opotiki).
On this basis, as it applies to the National Grid, Transpower does not oppose Policy CE-P5, provided that the new policy CE-Pxx is accepted.
Should sought Policy CE-Pxx not be accepted, Transpower seek amendment to CE-P5 to focus on “significant and permanent” adverse effects.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment New policy Amend In order to give effect to Policy 2 of the National Policy Statement for Electricity Transmission, new policies are Add the following policy to the Coastal Environment chapter: required to recognise the National Grid within the coastal environment. CE-PY
To recognise and provide for the operation, maintenance and upgrading of existing National Grid infrastructure in the coastal environment.
New policy Amend Transpower seeks recognition of the National Grid within the Coastal Environment Chapter to give effect to the Add a new policy to the Coastal Environment chapter as follows: NPSET. As national policy statements, both the NPSET and NZCPS sit at the top of the RMA plan hierarchy with neither document technically having supremacy over the other. On this basis the relationship between the CE-Pxx directives within these two documents needs to be carefully assessed in that some NZCPS policies provide for ‘avoidance’ outcomes, while the NPSET is largely ‘enabling’ with a ‘seek to avoid’ directive within high value Specific to the National Grid, where the National Grid has a functional need or natural areas. To address the relationship and manage the tensions between the National Policy Statements, operational need to locate in the coastal environment, manage the adverse detailed and specific National Grid policies are recommended. The Southland RPS and Bay of Plenty Regional effects arising from the development of the National Grid by: Coastal Plan have also adopted specific ‘seek to avoid’ National Grid policies, and a similar policy approach is emerging through recently issued consent orders in relation to proposed district plans (Whangarei and Opotiki). (a) seeking to avoid adverse effects on identified areas of Historic and Cultural Values overlays and Natural Environment Overlays within the Coastal Environment as identified in the district plan; (b) utilising the more modified parts of the areas identified in (a) where the route, site and method selection process has considered the avoidance of areas listed in (a) is not practicable; (c) where it is not practicable to avoid adverse effects on the values of the areas listed in (a) above because of the functional needs or operational needs of the National Grid, remedy or mitigate adverse effects on those values; and (d) avoiding, remedying or mitigating other adverse effects to the extent practicable.
Recognising that in some circumstances, adverse effects on the areas listed in (a) must be avoided.
Policy CE-xx prevails over others in the Coastal Environment Chapter. CE-R2 Below ground network utilities (including customer connections and Support with This rule is specific to the network utilities and is therefore more logically located within the Network Utilities Relocate Rule CE-R2 into the Network Utility chapter. maintenance and repair), installation of underground pipelines and cables, and amendments chapter. This will allow all rules associated with network utilities to be considered comprehensively. associated earthworks and vegetation disturbance Support Transpower supports the permitted activity status for underground network utilities in the coastal environment. In Retain the permitted activity status under Rule CE-R2 for underground network All zones terms of natural character and the requirements of the New Zealand Coastal Policy Statement, there will be only utilities within the coastal environment. temporary effects during construction, and no long lasting effects on natural character. This approach is an Activity status: PER appropriate way to give effect to INF Objective 1 and INF Policy 2 of the Regional Policy Statement for Taranaki by providing for network utilities, while minimising any adverse effects through standards. Where: Amend The standard regarding compliance with the rules of the underlying zone is not appropriate as all network utility Amend Rule CE-R2 as follows: 1. the network utilities are located underground, except where attached to bridge rules and standards should be in the network utility chapter as it is a District-wide chapter. There should be no crossings; and reliance on the underlying zone rules for network utilities. This approach is reflected in the text at the start of the Below ground network utilities (including customer connections and 2. the maximum width and depth of any trench is one metre; and Network Utilities chapter which states: maintenance and repair), installation of underground pipelines and cables, and 3. the maximum length of a trench open at any one time is 50m; and associated earthworks and vegetation disturbance 4. as soon as it is practicable after the trenching has been completed, the As this chapter contains district-wide provisions relating to Network Utilities, the rules and effects earthworks area are stabilised, filled and/or recontoured and the existing ground standards in the zone chapters are not intended to apply to Network Utilities (unless otherwise specified, All zones level is reinstated; and and with the exception of the Special Purpose - Airport Zone and Special Purpose - Port Zone). 5. the earthworks and vegetation disturbance are permitted under all relevant rules Activity status: PER in the Overlay Chapters; and There is no need to refer to other overlay chapters as there is often more than one rule that applies to an activity. 6. the activity is permitted under all relevant rules in the underlying zone. One permitted rule for a particular activity does not trump all the others which may apply. Part 1 of the Proposed Where: District Plan explains that where there are multiple rules that apply to an activity, the most restrictive activity Activity status where compliance not achieved: DIS status will apply. 1. the network utilities are located underground, except where attached to bridge crossings; and 2. the maximum width and depth of any trench is one metre; and 3. the maximum length of a trench open at any one time is 50m; and 4. as soon as it is practicable after the trenching has been completed, the earthworks area are stabilised, filled and/or recontoured and the existing ground level is reinstated; and 5. the earthworks and vegetation disturbance are permitted under all relevant rules in the Overlay Chapters; and 6. the activity is permitted under all relevant rules in the underlying zone.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment
Activity status where compliance not achieved: DIS
CE-R3 Maintenance and repair of above ground network utilities Support with This rule is specific to the network utilities and is therefore more logically located within the Network Utilities Relocate Rule CE-R3 into the Network Utility chapter. amendments chapter. This will allow all rules associated with network utilities to be considered comprehensively. All zones
Activity status: PER
Support with Transpower supports the permitted activity status for maintenance and repair of network utilities in the coastal Retain the permitted activity status under Rule CE-R3 for maintenance and Where: amendments environment. In terms of natural character and the requirements of the New Zealand Coastal Policy Statement, repair of network utilities within the coastal environment.
there will be no effects others than while the maintenance or repair is being carried out. This approach is an 1. the activity is permitted under all relevant rules in the Overlay Chapters; and appropriate way to give effect to INF Objective 1 and INF Policy 2 of the Regional Policy Statement for Taranaki by 2. the activity is permitted under all relevant rules in the underlying zone. providing for network utilities, while minimising any adverse effects through standards.
Activity status where compliance not achieved: DIS Support with The standard regarding compliance with the rules of the underlying zone is not appropriate as all network utility Amend Rule CE-R3 as follows: amendments rules and standards should be in the network utility chapter as it is a District-wide chapter. There should be no reliance on the underlying zone rules for network utilities. This approach is reflected in the text at the start of the Maintenance and repair of above ground network utilities and associated access Network Utilities chapter which states: tracks
As this chapter contains district-wide provisions relating to Network Utilities, the rules and effects All zones standards in the zone chapters are not intended to apply to Network Utilities (unless otherwise specified, and with the exception of the Special Purpose - Airport Zone and Special Purpose - Port Zone). Activity status: PER
There is no need to refer to other overlay chapters as there is often more than one rule that applies to an activity. Where: One permitted rule for a particular activity does not trump all the others which may apply. Part 1 of the Proposed District Plan explains that where there are multiple rules that apply to an activity, the most restrictive activity 1. the activity is permitted under all relevant rules in the Overlay Chapters; and status will apply. 2. the activity is permitted under all relevant rules in the underlying zone.
Access tracks are often part of existing infrastructure and therefore the rule should reflect that maintenance of Activity status where compliance not achieved: DIS these are also permitted.
For maintenance and repair, the overlays rules are not relevant. CE-R9 Aboveground network utilities (including upgrading) Support with This rule is specific to the network utilities and is therefore more logically located within the Network Utilities Relocate Rule CE-R9 into the Network Utility chapter. amendments chapter. This will allow all rules associated with network utilities to be considered comprehensively. All zones
Activity status: RDIS
Where: Support with Transpower supports the restricted discretionary activity status for new network utilities in the coastal Retain the restricted discretionary activity status under Rule CE-R9 for new 1. the height of any new structure located in the coastal environment (including amendments environment and upgrade of existing aboveground network utilities. This approach is an appropriate way to give aboveground network utilities and upgrading of network utilities in the coastal masts and support structures) does not exceed 7m. effect to INF Objective 1 and INF Policy 2 of the Regional Policy Statement for Taranaki by providing for network environment. utilities, while minimising any adverse effects through matters of discretion. Matters over which discretion is restricted:
1. Whether there is an operational need for the network utility to be aboveground Support with Access tracks are often part of existing infrastructure and therefore the rule should reflect that maintenance of Amend Rule CE-R9 as follows and located within the coastal environment. amendments these are also reflected in the rule. Aboveground network utilities (including upgrading) and any associated access 2. Effects on natural character, landscape, visual qualities and amenity values, areas tracks of coastal vegetation and habitat of indigenous coastal species, and proposed Some of the matters over which discretion is limited are not appropriate and are covered by other rules in the measures to avoid, remedy or mitigate adverse effects. plan. Examples of this include rules for earthworks in and around sites and areas of significance to Maori. It would All zones 3. Effects on Sites and Areas of Significance to Māori and Historic Heritage and be unnecessary duplication to include them as matters of discretion in this rule. proposed measures to avoid, remedy or mitigate adverse effects. Activity status: RDIS 4. Effects on cultural, spiritual and/or historic values and interests or associations of Rules NH-R2 and NH-R11 already address network utilities in the natural hazard areas, and Rule CE-R27 addresses importance to tangata whenua and the outcomes of any consultation with tangata network utilities in the coastal hazard area so there is no need for Matter of Discretion (5). Where: whenua as kaitiaki. 5. Effective management of natural hazards risks, having regard to: Given the need for connectedness with network utilities, it is appropriate to consider what other effects have been 1. the height of any new structure located in the coastal environment (including a. taking a risk-based approach to hazard management, including avoided, remedied or mitigated by choosing this particular site or route within the coastal environment. masts and support structures) does not exceed 7m. consideration of climate change and sea level rise; and b. whether the activity would accelerate or worsen natural hazard risks. Matters over which discretion is restricted:
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment Activity status where compliance not achieved: DIS 1. Whether there is an operational need or functional need for the network utility to be aboveground and located within the coastal environment. 2. Effects on natural character, landscape, visual qualities and amenity values, areas of coastal vegetation and habitat of indigenous coastal species, and proposed measures to avoid, remedy or mitigate adverse effects. 3. Effects on Sites and Areas of Significance to Māori and Historic Heritage and proposed measures to avoid, remedy or mitigate adverse effects. 4 3. Effects on cultural, spiritual and/or historic values and interests or associations of importance to tangata whenua and the outcomes of any consultation with tangata whenua as kaitiaki. 5. Effective management of natural hazards risks, having regard to: a. taking a risk-based approach to hazard management, including consideration of climate change and sea level rise; and b. whether the activity would accelerate or worsen natural hazard risks. 4. The extent to which any adverse effects have been avoided, remedied or mitigated by the route, site and method selection.
Activity status where compliance not achieved: DIS New permitted rule for repair, maintenance and upgrading network utilities within Amend While Rule CE-R27 addresses network utilities, there is no need for the following activities associated with existing Add a permitted activity rule to enable repair, maintenance, upgrading, or new the Coastal Flooding Hazard Area network utilities to be managed within the coastal flooding hazard area through a resource consent: underground network utilities in the coastal flooding hazard area: 1. Repair 2. Maintenance; CE-RX Repair, maintenance, upgrading, or new underground network utilities 3. Upgrading; and within the coastal flooding hazard area 4. New underground network utilities All zones There are no effects in terms of these activities exacerbating an existing risk, or increasing the risk to others. Network utilities are often required to be located in the coastal hazard overlay because of their very nature, such Activity status: PER as stormwater outfalls etc. A permitted activity that enabled these activities is an appropriate way of achieving INF Objective 1 and INF Policy 1 of the Regional Policy Statement for Taranaki. AND
There are other rules in the Network Utilities chapter which establish the standards for upgrading so there is no Locate the new rule in the Network Utilities chapter. need to repeat those in this rule.
This rule should be located in the Network Utilities chapter so that all rules related to network utilities can be considered comprehensively. CE-R27 Network utilities (including upgrading) Amend Relocate Rule CE-R27 into the Network Utilities chapter. This rule should be located in the Network Utilities chapter so that all rules related to network utilities can be All zones considered comprehensively.
Activity status: RDIS Oppose While Rule CE-R27 addresses all network utilities activities, there is no need for the following activities associated Amend Rule CE-R27 to focus on new aboveground network utilities as follows: with existing network utilities to be managed within the coastal flooding hazard area through a resource consent: Matters over which discretion is restricted: 1. Repair CE-R27 New aboveground Nnetwork utilities (including upgrading) 2. Maintenance; 1. The operational need to locate the network utility within the hazard area. 3. Upgrading; and All zones 2. The suitability of the site relative to the activity. 4. New underground network utilities 3. Cumulative effects, and the nature and extent of the hazard risks to people or Activity status: RDIS property, including the potential for the activity to create, transfer or intensify There are no effects in terms of these activities exacerbating an existing risk, or increasing the risk to others. hazard risks to adjoining sites. Network utilities are often required to be located in the coastal hazard overlay because of their very nature, such Matters over which discretion is restricted: 4. Potential impacts on flood detention capacity or the rate and direction of as stormwater outfalls etc. A permitted activity that enabled these activities is an appropriate way of achieving INF overland flow paths, including consequential scouring or accelerated erosion. Objective 1 and INF Policy 1 of the Regional Policy Statement for Taranaki. Therefore the focus of this rule should 1. The operational need or functional need to locate the network utility within 5. The measures proposed to mitigate the effects of the hazard, including ground be new aboveground network utilities. the hazard area. strengthening and foundation design, site layout, geotechnical setbacks, building 2. The suitability of the site relative to the activity. design and minimum floor levels, and the use, maintenance and/or enhancement of 3. Cumulative effects, and the nature and extent of the hazard risks to people or natural features on the site. property, including the potential for the activity to create, transfer or intensify 6.The potential to relocate or remove buildings and/or structures to alternative hazard risks to adjoining sites. locations. 4. Potential impacts on flood detention capacity or the rate and direction of overland flow paths, including consequential scouring or accelerated erosion. Activity status where compliance not achieved: N/A 5. The measures proposed to mitigate the effects of the hazard, including ground strengthening and foundation design, site layout, geotechnical setbacks, building design and minimum floor levels, and the use, maintenance and/or enhancement of natural features on the site.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment 6.The potential to relocate or remove buildings and/or structures to alternative locations.
Activity status where compliance not achieved: N/A
New permitted rule for repair, maintenance and upgrading network utilities within Amend While Rule CE-R36 addresses network utilities, there is no need for the following activities associated with existing Add a permitted activity rule to enable repair and maintenance of network the Coastal Erosion hazard Area network utilities to be managed within the coastal flooding hazard area through a resource consent: utilities in the coastal erosion hazard area: 1. Repair; and 2. Maintenance. CE-RX Repair or maintenance of network utilities within the coastal erosion hazard area There are no effects in terms of these activities exacerbating an existing risk, or increasing the risk to others. Network utilities are often required to be located in the coastal hazard overlay because of their very nature, such All zones as stormwater outfalls etc. A permitted activity that enabled these activities is an appropriate way of achieving INF Objective 1 and INF Policy 1 of the Regional Policy Statement for Taranaki. Activity status: PER
This rule should be located in the Network Utilities chapter so that all rules related to network utilities can be AND considered comprehensively. Locate the new rule in the Network Utilities chapter. CE-R36 Network utilities (including upgrading) Oppose While Rule CE-R36 addresses all network utilities activities, there is no need for the following activities associated Amend Rule CE-R36 to focus on new network utilities and upgrading existing with existing network utilities to be managed within the coastal flooding hazard area through a resource consent: network utilities as follows: All zones 1. Repair; or 2. Maintenance; CE-R36 New Nnetwork utilities (including and upgrading existing network Activity status: DIS utilities) There are no effects in terms of these activities exacerbating an existing risk, or increasing the risk to others. Activity status where compliance not achieved: N/A Network utilities are often required to be located in the coastal hazard overlay because of their very nature, such All zones as stormwater outfalls etc. A permitted activity that enabled these activities is an appropriate way of achieving INF Objective 1 and INF Policy 1 of the Regional Policy Statement for Taranaki. Therefore the focus of this rule should Activity status: DIS be new network utilities and upgrading existing network utilities.
Amend This rule should be located in the Network Utilities chapter so that all rules related to network utilities can be Relocate Rule CE-R36 into the Network Utilities chapter. considered comprehensively.
Part 2: District-wide Matters / General District-wide Matters / Earthworks
EW-P1 Support Transpower supports the recognition of earthworks associated with new and existing network utilities as being Retain the parts of Policy EW-P1 that enable earthworks associated with the appropriate. construction, maintenance and repair and/or upgrade of: Allow earthworks that are associated with the construction, maintenance and repair … and/or upgrade of permitted, anticipated and/or existing authorised activities, while (9) network utilities, including new and extended vehicle access tracks. ensuring the scale, volume and effects of earthworks are appropriate, including those for: Support Amendments are sought to make the policy clearer. There is no point in restricting the earthworks to just activities Amend Policy EW-P1 as follows: which are permitted as this causes unnecessary complexity with interpretations of rules. If an activity requires a 1. fences, poles, pile or service connections; resource consent it is more appropriate for earthworks to be addressed through standards or matters of control or Allow earthworks that are associated with the construction, maintenance and 2. gardening, planting or any vegetation and/or the construction or maintenance of discretion. repair and/or upgrade of permitted, anticipated and/or existing authorised the garden amenities; following activities, while ensuring the scale, volume and effects of earthworks 3. sport and recreation activities; are appropriate, including those for: 4. conservation activities; 5. replacement or removal and/or installation of underground petroleum storage … systems associated with service stations; 9. network utilities, including new and extended vehicle access tracks ; 6. interments in a burial ground, cemetery or urupā; 7. the transport network; 8. walking and cycling tracks and leisure activities; 9. network utilities, including new and extended vehicle access tracks ; 10 building activities authorised by a building consent; 11. silage pits in the rural production zone; or 12. vehicle access tracks associated with agriculture, pastoral and horticultural activities in the rural production zone. EW-R9 Earthworks for network utilities, including vehicle access tracks for network Support with This rule should be located in the Network Utilities chapter so that all rules related to network utilities can be Relocate Rule EW-R9 into the network utilities chapter utilities amendments considered comprehensively.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment All zones Support with Transpower supports the permitted activity status for earthworks associated with network utilities. This is an Retain a permitted activity status for new and existing network utilities as amendments effective means of achieving INF Objective 1 and INF 1 of the Regional Policy Statement for Taranaki. expressed in Rule EW-R9 Activity status: PER
Where:
1. the total earthworks area open at any one time, does not exceed 500m2; Support with However the effects standards are not appropriate for earthworks for infrastructure. For example, EW0S1 requires Amend Rule EW-R9 as follows: amendments there to be no instability at or beyond the boundary of the site where the earthworks occur. Network utilities often 2. the earthworks area is progressively stabilised, filled and/or recontoured as soon as practicable; span a very large number of sites and underground network utilities will most definitely cross site boundaries. EW-R9 Earthworks for network utilities, including vehicle access tracks for network utilities 3. all Earthworks Effects Standards are complied with. Similarly EW-S2 contains standards around the cut depth or fill height based on the building setbacks for the zone.
For the reasons outlined above this is not appropriate for network utilities, particularly underground network All zones Activity status where compliance not achieved: RDIS utilities.
Matters over which discretion is restricted: Activity status: PER EW-S4 is not appropriate as there may need to be concreting or gravel around a network utility which does not
1. The functional and operational needs of, and benefits derived from, the works, match the surrounding area. Where: including the potential impact on the levels of service if the work is not undertaken. 2 2. The extent to which the land disturbance or earthworks will compromise Only EW-S4 Control of silt and sediment and EW-S5 Accidental discovery protocol are relevant to network utilities. 1. the total earthworks area open at any one time, does not exceed 500m ; 2. the earthworks area is progressively stabilised, filled and/or recontoured as archaeological sites and Māori historic heritage and/or whether any adverse effects This rule is specific to the network utilities and is therefore more logically located within the Network Utilities soon as practicable; on historic heritage can be appropriately remedied or mitigated.. chapter. This will allow all rules associated with network utilities to be considered comprehensively. 3. Compliance with EW-S4; 3. Effects on land stability and amenity values resulting from the timing and 4. Compliance with EW-S5. duration of works. 4. Management of visual amenity effects through landscape treatment, site Some of the matters over which discretion is limited are not appropriate and are covered by other rules in the 3. all Earthworks Effects Standards are complied with. plan. Examples of this include rules for earthworks in and around sites and areas of significance to Maori. It would reinstatement and screening. 5. The extent and effect of non-compliance with any 6. Earthworks Effects Standards be unnecessary duplication to include them as matters of discretion in this rule. Activity status where compliance not achieved: RDIS and any relevant matters of discretion in any infringed Effects Standard(s). 6. The matters in EW-P3 - EW-P7 and NU-P5 It is not best practice planning to include policies as matters of discretion. Matters over which discretion is restricted:
1. The functional and operational needs of, and benefits derived from, the works, including the potential impact on the levels of service if the work is not undertaken. 2. The extent to which the land disturbance or earthworks will compromise archaeological sites and Māori historic heritage and/or whether any adverse effects on historic heritage can be appropriately remedied or mitigated.. 3 2. Effects on land stability and amenity values resulting from the timing and duration of works. 4 3. Management of visual amenity effects through landscape treatment, site reinstatement and screening. 5 4. The extent and effect of non-compliance with EW-S4 or EW-S5. any Earthworks Effects Standards and any relevant matters of discretion in any infringed Effects Standard(s). 6. The matters in EW-P3 - EW-P7 and NU-P5
Part 2: District-wide Matters / General District-wide Matters / Signs
SIGN-P1 Support Transpower supports recognition that signs are needed for health and safety and to meet legislative requirements Retain Policy SIGN-P1 as notified under other acts. Allow signs that support the safe functioning of the transport network and address health and safety and other legislative requirements, including:
1. traffic and railway signs; and 2. official signs. SIGN-R2 Official signs (excluding traffic and railway signs) Support Transpower supports recognition that signs are needed for health and safety and to meet legislative requirements Retain Rule SIGN-R2 as notified under other acts. All zones
Activity status: PER
Where: 1. the sign is required to meet legislative requirements, such as health and safety legislation; and/or 2. the sign provides information or instruction relating to public safety, such as equipment use, property entrances or for security purposes, and is no larger than reasonably necessary to convey the information.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment
Note: This rule is not subject to any Effects Standards in the District Plan.
Activity status where compliance not achieved: CON
Matters over which control is reserved: 1. The location of the sign. 2. The size and height of the sign.
Part 3: Area Specific Matters / Residential Zones / Low Density Residential Zone
Cross references to other relevant District Plan provisions Amend The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply across the District. Amend the cross references to other relevant District Plan provisions in the Low Density Residential Zone as follows: It is important to note that in addition to the provisions in this chapter, a number The cross reference to other District Plan provisions does not acknowledge the network utility chapter, and in of other Part 2: District-Wide chapters also contain provisions that may be particular omits references to the objectives, policies and rues associated with the National Grid. The National Grid Cross references to other relevant District Plan provisions relevant for activities in the Low Density Residential zone, including: provisions are unique as they apply to buildings, landuses, earthworks and subdivision across the District. Without cross referencing them, there is a chance that they get overlooked. It is important to note that in addition to the provisions in this chapter, a . Transport - The Transport Chapter contains provisions relating to number of other Part 2: District-Wide chapters also contain provisions that may transport matters, including traffic generation (TRAN-R8). The National Planning Standards state that zone chapters must include cross-referencing to relevant provisions be relevant for activities in the Low Density Residential zone, including: . Historic Heritage and Sites and Areas of Significance to Māori - under the Energy, Infrastructure and transport heading. Residential areas can contain archaeological sites and sites and areas of Network Utilities [or National Grid] - The Network Utilities [or National Grid] significance to Māori. Specific provisions for the protection of these sites It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure plan users Chapter contains provisions for buildings and landuses within the National Grid are located in the Sites and Areas of Significance to Māori Chapter and are aware of the National Grid rules. Yard and National Grid Substation Corridor, as well as the operation, Historic Heritage Chapter. maintenance, upgrade and development of the National Grid. . Viewshafts - Viewshafts within the Residential zones are managed by If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to the Viewshafts Chapter. the National Grid chapter. . Subdivision - The Subdivision Chapter contains provisions which manage subdivision of land in the Residential Zones. . Earthworks - The Earthworks Chapter manages the adverse effects of earthworks on the environment, including visual amenity values and stability of land plus adverse health and safety effects, damage to property and the creation or increase in the risk of natural hazards. . Light - The Light Chapter contains specific provisions relating to light spill and the management of effects on residential areas. . Noise - The Noise Chapter contains specific controls in relation to noise, including effects standards NOISE-S1 (maximum noise levels). . Signs - To ensure signs are compatible with an area, their scale, number, illumination, motion and placement are managed by the Signs Chapter
Part 3: Area Specific Matters / Residential Zones / General Residential Zone
Cross references to other relevant District Plan provisions Amend Amend the cross references to other relevant District Plan provisions in the The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply across the District. General Residential Zone as follows: It is important to note that in addition to the provisions in this chapter, a number of other Part 2: District-Wide chapters also contain provisions that may be relevant for The cross reference to other District Plan provisions does not acknowledge the network utility chapter, and in Cross references to other relevant District Plan provisions activities in the General Residential zone, including: particular omits references to the objectives, policies and rues associated with the National Grid. The National Grid provisions are unique as they apply to buildings, landuses, earthworks and subdivision across the District. Without It is important to note that in addition to the provisions in this chapter, a . Transport - The Transport Chapter contains provisions relating to cross referencing them, there is a chance that they get overlooked. number of other Part 2: District-Wide chapters also contain provisions that may transport matters, including traffic generation (TRAN-R8). be relevant for activities in the General Residential zone, including: . Historic Heritage and Sites and Areas of Significance to Māori - The National Planning Standards state that zone chapters must include cross-referencing to relevant provisions Residential areas can contain archaeological sites and sites and areas of under the Energy, Infrastructure and transport heading. Network Utilities [or National Grid] - The Network Utilities [or National Grid] significance to Māori. Specific provisions for the protection of these sites Chapter contains provisions for buildings and landuses within the National Grid are located in the Sites and Areas of Significance to Māori Chapter and It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure plan users Yard and National Grid Substation Corridor, as well as the operation, Historic Heritage Chapter. are aware of the National Grid rules. maintenance, upgrade and development of the National Grid. . Viewshafts - Viewshafts within the Residential zones are managed by the Viewshafts Chapter. If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to . Subdivision - The Subdivision Chapter contains provisions which manage the National Grid chapter. subdivision of land in the Residential Zones. . Earthworks - The Earthworks Chapter manages the adverse effects of earthworks on the environment, including visual amenity values and stability of land plus adverse health and safety effects, damage to property and the creation or increase in the risk of natural hazards.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment . Light - The Light Chapter contains specific provisions relating to light spill and the management of effects on residential areas. . Noise - The Noise Chapter contains specific controls in relation to noise, including effects standards NOISE-S1 (maximum noise levels). . Signs - To ensure signs are compatible with an area, their scale, number, illumination, motion and placement are managed by the Signs Chapter.
Part 3: Area Specific Matters / Residential Zones / Medium Density Residential Zone
Cross references to other relevant District Plan provisions Amend Amend the cross references to other relevant District Plan provisions in the The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply across the District. Medium Density Residential Zone as follows: It is important to note that in addition to the provisions in this chapter, a number of other Part 2: District-Wide chapters also contain provisions that may be relevant for The cross reference to other District Plan provisions does not acknowledge the network utility chapter, and in Cross references to other relevant District Plan provisions activities in the Medium Density Residential zone, including: particular omits references to the objectives, policies and rues associated with the National Grid. The National Grid provisions are unique as they apply to buildings, landuses, earthworks and subdivision across the District. Without It is important to note that in addition to the provisions in this chapter, a . Transport - The Transport Chapter contains provisions relating to cross referencing them, there is a chance that they get overlooked. number of other Part 2: District-Wide chapters also contain provisions that may transport matters, including traffic generation (TRAN-R8). be relevant for activities in the Medium Density Residential zone, including: . Historic Heritage and Sites and Areas of Significance to Māori - The National Planning Standards state that zone chapters must include cross-referencing to relevant provisions Residential areas can contain archaeological sites and sites and areas of under the Energy, Infrastructure and transport heading. Network Utilities [or National Grid] - The Network Utilities [or National Grid] significance to Māori. Specific provisions for the protection of these sites Chapter contains provisions for buildings and landuses within the National Grid are located in the Sites and Areas of Significance to Māori Chapter and It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure plan users Yard and National Grid Substation Corridor, as well as the operation, Historic Heritage Chapter. are aware of the National Grid rules. maintenance, upgrade and development of the National Grid. . Viewshafts - Viewshafts within the Residential zones are managed by the Viewshafts Chapter. If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to . Subdivision - The Subdivision Chapter contains provisions which manage the National Grid chapter. subdivision of land in the Residential Zones. . Earthworks - The Earthworks Chapter manages the adverse effects of earthworks on the environment, including visual amenity values and stability of land plus adverse health and safety effects, damage to property and the creation or increase in the risk of natural hazards. . Light - The Light Chapter contains specific provisions relating to light spill and the management of effects on residential areas. . Noise - The Noise Chapter contains specific controls in relation to noise, including effects standards NOISE-S1 (maximum noise levels). . Signs - To ensure signs are compatible with an area, their scale, number, illumination, motion and placement are managed by the Signs Chapter.
Part 3: Area Specific Matters / Rural Zones / Rural Production Zone
Cross references to other relevant District Plan provisions Amend Amend the cross references to other relevant District Plan provisions in the The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply across the District. Rural Production Zone as follows: It is important to note that in addition to the provisions in this chapter, a number of other Part 2: District-Wide chapters also contain provisions that may be relevant for The cross reference to other District Plan provisions does not acknowledge the network utility chapter, and in Cross references to other relevant District Plan provisions activities in the Rural Production zone, including: particular omits references to the objectives, policies and rues associated with the National Grid. The National Grid provisions are unique as they apply to buildings, landuses, earthworks and subdivision across the District. Without It is important to note that in addition to the provisions in this chapter, a . Transport - The Transport Chapter contains provisions relating to cross referencing them, there is a chance that they get overlooked. number of other Part 2: District-Wide chapters also contain provisions that may transport matters, including traffic generation (TRAN-R8). be relevant for activities in the Rural Production zone, including: . Historic Heritage and Sites and Areas of Significance to Māori - Rural The National Planning Standards state that zone chapters must include cross-referencing to relevant provisions areas are rich in historic heritage and can contain archaeological sites and under the Energy, Infrastructure and transport heading. Network Utilities [or National Grid] - The Network Utilities [or National Grid] sites and areas of significance to Māori. Specific provisions for the Chapter contains provisions for buildings and landuses within the National Grid protection of these sites are located in the Sites and Areas of Significance It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure plan users Yard and National Grid Substation Corridor, as well as the operation, to Māori Chapter and Historic Heritage Chapter. are aware of the National Grid rules. maintenance, upgrade and development of the National Grid. . Ecosystems and Indigenous Biodiversity - The rural area is vast in indigenous vegetation and habitat. Provisions related to this are contained If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to in the Ecosystems and Indigenous Biodiversity Chapter. the National Grid chapter. . Natural Features and Landscapes - Many of the district's outstanding landscapes and natural features are located within rural areas and these are managed by provisions in the Natural Features and Landscapes Chapter. . Waterbodies - Rural areas are traversed by many rivers and streams, which are managed by provisions in the Waterbodies Chapter. . Subdivision - The Subdivision Chapter contains provisions which manage subdivision of land in the Rural Production Zone.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment . Coastal Environment - The Rural Producation Zone abuts the coastal environment, which is managed by provisions in the Coastal Environment chapter. . Earthworks - The Earthworks Chapter manages the adverse effects of earthworks on the environment, including visual amenity values and stability of land plus adverse health and safety effects, damage to property and the creation or increase in the risk of natural hazards. . Light - The Light Chapter contains specific provisions relating to light spill and the management of effects on rural areas. . Noise - The Noise Chapter contains specific controls in relation to noise, including effects standards NOISE-S1 (maximum noise levels). . Signs - To ensure signs are compatible with an area, their scale, number, illumination, motion and placement are managed by the Signs Chapter.
Part 3: Area Specific Matters / Rural Zones / Rural Lifestyle Zone
Cross references to other relevant District Plan provisions Amend Amend the cross references to other relevant District Plan provisions in the The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply across the District. Rural Lifestyle Zone as follows: It is important to note that in addition to the provisions in this chapter, a number of other Part 2: District-wide Matters chapters contain provisions that may be relevant The cross reference to other District Plan provisions does not acknowledge the network utility chapter, and in Cross references to other relevant District Plan provisions for activities occurring within the Rural Lifestyle Zone, including the specific Overlay particular omits references to the objectives, policies and rues associated with the National Grid. The National Grid Chapters referred to within this chapter and: provisions are unique as they apply to buildings, landuses, earthworks and subdivision across the District. Without It is important to note that in addition to the provisions in this chapter, a cross referencing them, there is a chance that they get overlooked. number of other Part 2: District-wide Matters chapters contain provisions that . Transport - The Transport Chapter contains provisions relating to may be relevant for activities occurring within the Rural Lifestyle Zone, including transportation matters, including traffic generation (TRAN-R8). The National Planning Standards state that zone chapters must include cross-referencing to relevant provisions the specific Overlay Chapters referred to within this chapter and: . Historic Heritage and Sites and Areas of Significance to Māori - Rural under the Energy, Infrastructure and transport heading. areas are rich in historic heritage and can contain archaeological sites and Network Utilities [or National Grid] - The Network Utilities [or National Grid] sites and areas of significance to Māori. Specific provisions for the It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure plan users Chapter contains provisions for buildings and landuses within the National Grid protection of these sites are located in the Sites and Areas of Significance are aware of the National Grid rules. Yard and National Grid Substation Corridor, as well as the operation, to Māori Chapter and Historic Heritage Chapter. maintenance, upgrade and development of the National Grid. . Subdivision - The Subdivision Chapter contains provisions that apply to If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to subdivision within the Rural Lifestyle Zone, including SUB-R5. the National Grid chapter. . Earthworks - The Earthworks Chapter manages the adverse effects of earthworks on the environment, including visual amenity values and stability of land plus adverse health and safety effects, damage to property and the creation or increase in the risk of natural hazards. . Light - The Light Chapter contains specific provisions relating to light spill and the management of effects on rural lifestyle areas. . Noise - The Noise Chapter contains specific controls in relation to noise, including effects standards NOISE-S1 (maximum noise levels). . Signs - To ensure signs are compatible with an area, their scale, number, illumination, motion and placement are managed by the Signs Chapter.
Part 3: Area Specific Matters / Commercial and Mixed Use Zones / Local Centre Zone
Cross references to other relevant District Plan provisions Amend Amend the cross references to other relevant District Plan provisions in the The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply across the District. Local Centre Zone as follows: It is important to note that in addition to the provisions in this chapter, a number of other Part 2: District-Wide chapters also contain provisions that may be relevant for The cross reference to other District Plan provisions does not acknowledge the network utility chapter, and in Cross references to other relevant District Plan provisions activities in the Local Centre zone, including: particular omits references to the objectives, policies and rues associated with the National Grid. The National Grid provisions are unique as they apply to buildings, landuses, earthworks and subdivision across the District. Without It is important to note that in addition to the provisions in this chapter, a . Transport - The Transport Chapter contains provisions relating to cross referencing them, there is a chance that they get overlooked. number of other Part 2: District-Wide chapters also contain provisions that may transport matters, including traffic generation (TRAN-R8). be relevant for activities in the Local Centre zone, including: . Historic Heritage and Sites and Areas of Significance to Māori - Local The National Planning Standards state that zone chapters must include cross-referencing to relevant provisions centres can contain heritage buildings or items, archaeological sites under the Energy, Infrastructure and transport heading. Network Utilities [or National Grid] - The Network Utilities [or National Grid] and/or sites and areas of significance to Māori. Specific provisions for the Chapter contains provisions for buildings and landuses within the National Grid protection of historic heritage are located in the Historic Heritage Chapter It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure plan users Yard and National Grid Substation Corridor, as well as the operation, and Sites and Areas of Significance to Māori Chapter. are aware of the National Grid rules. maintenance, upgrade and development of the National Grid. . Subdivision - The Subdivision Chapter contains provisions which manage subdivision of land in the Commerical and Mixed Use Zones. If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to . Earthworks - The Earthworks Chapter manages the adverse effects of the National Grid chapter. earthworks on the environment, including visual amenity values and
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment stability of land plus adverse health and safety effects, damage to property and the creation or increase in the risk of natural hazards. . Light - The Light Chapter contains specific provisions relating to light emissions and the management of effects on local centres areas. . Noise - The Noise Chapter contains specific controls in relation to noise, including effects standards NOISE-S1 (maximum noise levels) and NOISE- S3 (noise insulation standards). . Signs - To ensure signs are compatible with an area, their scale, number, illumination, motion and placement are managed by the Signs Chapter.
Part 3: Area Specific Matters / Commercial and Mixed Use Zones / Large Format Retail Zone
Cross references to other relevant District Plan provisions Amend Amend the cross references to other relevant District Plan provisions in the The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply across the District. Large Format Zone as follows: It is important to note that in addition to the provisions in this chapter, a number of other Part 2: District-Wide chapters also contain provisions that may be relevant for The cross reference to other District Plan provisions does not acknowledge the network utility chapter, and in Cross references to other relevant District Plan provisions activities in the Large Format Retail Zone, including: particular omits references to the objectives, policies and rues associated with the National Grid. The National Grid provisions are unique as they apply to buildings, landuses, earthworks and subdivision across the District. Without It is important to note that in addition to the provisions in this chapter, a . Transport - The Transport Chapter contains provisions relating to cross referencing them, there is a chance that they get overlooked. number of other Part 2: District-Wide chapters also contain provisions that may transport matters, including traffic generation (TRAN-R8). be relevant for activities in the Large Format Retail Zone, including: . Historic Heritage and Sites and Areas of Significance to Māori - Large The National Planning Standards state that zone chapters must include cross-referencing to relevant provisions format retail areas can contain heritage buildings or items, archaeological under the Energy, Infrastructure and transport heading. Network Utilities [or National Grid]- The Network Utilities [or National Grid] sites and/or sites and areas of significance to Māori. Specific provisions for Chapter contains provisions for buildings and landuses within the National Grid the protection of historic heritage are located in the Historic Heritage It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure plan users Yard and National Grid Substation Corridor, as well as the operation, Chapter and Sites and Areas of Significance to Māori Chapter. are aware of the National Grid rules. maintenance, upgrade and development of the National Grid. . Subdivision - The Subdivision Chapter contains provisions which manage subdivision of land in the Commerical and Mixed Use Zones. If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to . Earthworks - The Earthworks Chapter manages the adverse effects of the National Grid chapter. earthworks on the environment, including visual amenity values and stability of land plus adverse health and safety effects, damage to property and the creation or increase in the risk of natural hazards. . Light - The Light Chapter contains specific provisions relating to light emissions and the management of effects arising from light overspill. . Noise - The Noise Chapter contains specific provisions relating to noise emissions, including effects standards NOISE-S1 (maximum noise levels). . Signs - To ensure signs are compatible with an area, their scale, number, illumination, motion and placement are managed by the Signs Chapter.
Part 3: Area Specific Matters / Commercial and Mixed Use Zones / Mixed Use Zone
Cross references to other relevant District Plan provisions Amend Amend the cross references to other relevant District Plan provisions in the The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply across the District. Mixed Use Zone as follows: It is important to note that in addition to the provisions in this chapter, a number of other Part 2: District-Wide chapters also contain provisions that may be relevant for The cross reference to other District Plan provisions does not acknowledge the network utility chapter, and in Cross references to other relevant District Plan provisions activities in the Mixed Use Zone, including: particular omits references to the objectives, policies and rues associated with the National Grid. The National Grid provisions are unique as they apply to buildings, landuses, earthworks and subdivision across the District. Without It is important to note that in addition to the provisions in this chapter, a . Transport - The Transport Chapter contains provisions relating to cross referencing them, there is a chance that they get overlooked. number of other Part 2: District-Wide chapters also contain provisions that may transport matters, including traffic generation (TRAN-R8). be relevant for activities in the Mixed Use Zone, including: . Historic Heritage and Sites and Areas of Significance to Māori - Mixed use The National Planning Standards state that zone chapters must include cross-referencing to relevant provisions areas can contain heritage buildings or items, archaeological sites and/or under the Energy, Infrastructure and transport heading. Network Utilities [or National Grid] - The Network Utilities [or National Grid] sites and areas of significance to Māori. Specific provisions for the Chapter contains provisions for buildings and landuses within the National Grid protection of historic heritage are located in the Historic Heritage Chapter It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure plan users Yard and National Grid Substation Corridor, as well as the operation, and Sites and Areas of Significance to Māori Chapter. are aware of the National Grid rules. maintenance, upgrade and development of the National Grid. . Subdivision - The Subdivision Chapter contains provisions which manage subdivision of land in the Commerical and Mixed Use Zones. If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to . Earthworks - The Earthworks Chapter manages the adverse effects of the National Grid chapter. earthworks on the environment, including visual amenity values and stability of land plus adverse health and safety effects, damage to property and the creation or increase in the risk of natural hazards. . Light - The Light Chapter contains specific provisions relating to light emissions and the management of effects arising from light overspill. . Noise - The Noise Chapter contains specific provisions relating to noise emissions, including effects standards NOISE-S1 (maximum noise levels)
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment . and NOISE-S3 (noise insulation standards). . Signs - To ensure signs are compatible with an area, their scale, number, illumination, motion and placement are managed by the Signs Chapter.
Part 3: Area Specific Matters / Commercial and Mixed Use Zones / Town Centre Zone
Cross references to other relevant District Plan provisions Amend Amend the cross references to other relevant District Plan provisions in the The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply across the District. Town Centre Zone as follows: It is important to note that in addition to the provisions in this chapter, a number of other Part 2: District-Wide chapters also contain provisions that may be relevant for The cross reference to other District Plan provisions does not acknowledge the network utility chapter, and in Cross references to other relevant District Plan provisions activities in the Town Centre Zone, including: particular omits references to the objectives, policies and rues associated with the National Grid. The National Grid provisions are unique as they apply to buildings, landuses, earthworks and subdivision across the District. Without It is important to note that in addition to the provisions in this chapter, a . Transport - The Transport Chapter contains provisions relating to cross referencing them, there is a chance that they get overlooked. number of other Part 2: District-Wide chapters also contain provisions that may transport matters, including traffic generation (TRAN-R8). be relevant for activities in the Town Centre Zone, including: . Historic Heritage and Sites and Areas of Significance to Māori - Town The National Planning Standards state that zone chapters must include cross-referencing to relevant provisions centres can contain heritage buildings or items, archaeological sites under the Energy, Infrastructure and transport heading. Network Utilities [or National Grid] - The Network Utilities [or National Grid] and/or sites and areas of significance to Māori. Specific provisions for the Chapter contains provisions for buildings and landuses within the National Grid protection of historic heritage are located in the Historic Heritage Chapter It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure plan users Yard and National Grid Substation Corridor, as well as the operation, and Sites and Areas of Significance to Māori Chapter. are aware of the National Grid rules. maintenance, upgrade and development of the National Grid.. . Subdivision - The Subdivision Chapter contains provisions which manage subdivision of land in the Commerical and Mixed Use Zones. If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to . Earthworks - The Earthworks Chapter manages the adverse effects of the National Grid chapter. earthworks on the environment, including visual amenity values and stability of land plus adverse health and safety effects, damage to property and the creation or increase in the risk of natural hazards. . Light - The Light Chapter contains specific provisions relating to light emissions and the management of effects arising from light overspill. . Noise - The Noise Chapter contains specific provisions relating to noise emissions, including effects standards NOISE-S1 (maximum noise levels) and NOISE-S3 (noise insulation standards). . Signs - To ensure signs are compatible with an area, their scale, number, illumination, motion and placement are managed by the Signs Chapter.
Part 3: Area Specific Matters / Commercial and Mixed Use Zones / City Centre Zone
Cross references to other relevant District Plan provisions Amend Amend the cross references to other relevant District Plan provisions in the City The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply across the District. Centre Zone as follows: It is important to note that in addition to the provisions in this chapter, a number of other Part 2: District-Wide chapters also contain provisions that may be relevant for The cross reference to other District Plan provisions does not acknowledge the network utility chapter, and in Cross references to other relevant District Plan provisions activities in the City Centre zone, including: particular omits references to the objectives, policies and rues associated with the National Grid. The National Grid provisions are unique as they apply to buildings, landuses, earthworks and subdivision across the District. Without It is important to note that in addition to the provisions in this chapter, a . Transport - The Transport Chapter contains provisions relating to cross referencing them, there is a chance that they get overlooked. number of other Part 2: District-Wide chapters also contain provisions that may transport matters, including traffic generation (TRAN-R8). be relevant for activities in the City Centre zone, including: . Historic Heritage and Sites and Areas of Significance to Māori - The City The National Planning Standards state that zone chapters must include cross-referencing to relevant provisions Centre contains heritage buildings and items, archaeological sites and under the Energy, Infrastructure and transport heading. Network Utilities [or National Grid] - The Network Utilities [or National Grid] sites and areas of significance to Māori. Specific provisions for the Chapter contains provisions for buildings and landuses within the National Grid protection of these sites are located in the Historic Heritage Chapter and It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure plan users Yard and National Grid Substation Corridor, as well as the operation, Sites and Areas of Significance to Māori Chapter. are aware of the National Grid rules. maintenance, upgrade and development of the National Grid. . Viewshafts - Viewshafts within the CIty Centre are managed by the Viewshafts Chapter. If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to . Waterbodies - The City Centre is traversed by rivers and streams, which the National Grid chapter. are managed by provisions in the Waterbodies Chapter. . Subdivision - The Subdivision Chapter contains provisions which manage subdivision of land in the Commerical and Mixed Use Zones. . Coastal Environment - The City Centre Zone abuts the coast. The coastal envrionment is managed by provisions in the Coastal Environment Chapter. . Earthworks - The Earthworks Chapter manages the adverse effects of earthworks on the environment, including visual amenity values and stability of land plus adverse health and safety effects, damage to property and the creation or increase in the risk of natural hazards. . Light - The Light Chapter contains specific provisions relating to light emissions and the management of light overspill effects.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment . Noise - The Noise Chapter contains specific controls in relation to noise, including effects standards NOISE-S1 (maximum noise levels) and NOISE- S3 (noise insulation standards). . Signs - To ensure signs are compatible with an area, their scale, number, illumination, motion and placement are managed by the Signs Chapter.
Part 3: Area Specific Matters / General Industrial Zone / General Industrial Zone
Cross references to other relevant District Plan provisions Amend Amend the cross references to other relevant District Plan provisions in the The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply across the District. General Industrial Zone as follows: It is important to note that in addition to the provisions in this chapter, a number of other Part 2: District-Wide chapters also contain provisions that may be relevant for The cross reference to other District Plan provisions does not acknowledge the network utility chapter, and in Cross references to other relevant District Plan provisions activities in the General Industrial zone, including: particular omits references to the objectives, policies and rues associated with the National Grid. The National Grid provisions are unique as they apply to buildings, landuses, earthworks and subdivision across the District. Without It is important to note that in addition to the provisions in this chapter, a . Transport - The Transport Chapter contains provisions relating to cross referencing them, there is a chance that they get overlooked. number of other Part 2: District-Wide chapters also contain provisions that may transport, including traffic generation (TRAN-R8). be relevant for activities in the General Industrial zone, including: . Entrance Corridors - The Entrance Corridors Chapter contains provisions The National Planning Standards state that zone chapters must include cross-referencing to relevant provisions relating to activities on sites adjoining entrance corridors. under the Energy, Infrastructure and transport heading. Network Utilities [or National Grid] - The Network Utilities [or National Grid] . Historic Heritage and Sites and Areas of Significance to Māori - Industrial Chapter contains provisions for buildings and landuses within the National Grid areas can contain archaeological sites and sites and areas of significance It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure plan users Yard and National Grid Substation Corridor, as well as the operation, to Māori. Specific provisions for the protection of these sites are located in are aware of the National Grid rules. maintenance, upgrade and development of the National Grid. the Sites and Areas of Significance to Māori Chapter and Historic Heritage Chapter. If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to . Waterbodies - The Waterbodies Chapter contains provisions relating to the National Grid chapter. activities occuring adjacent to waterbodies. . Subdivision - The Subdivision Chapter contains provisions which manage subdivision of land in the General Industrial Zone. . Earthworks - The Earthworks Chapter manages the adverse effects of earthworks on the environment, including visual amenity values and stability of land plus adverse health and safety effects, damage to property and the creation or increase in the risk of natural hazards. . Light - The Light Chapter contains provisions relating to light spill and the management of effects on adjoining residential areas. . Noise - The Noise Chapter contains specific controls in relation to noise, including effects standards NOISE-S1 (maximum noise levels). . Signs - The Signs Chapter contains provisions relating to signs within the General Industrial zone.
Part 3: Area Specific Matters / Open Space and Recreation Zone / Natural Open Space Zone
Cross references to other relevant District Plan provisions Amend Amend the cross references to other relevant District Plan provisions in the The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply across the District. Natural Open Space Zone as follows: It is important to note that in addition to the provisions in this chapter, a number of other Part 2: District-Wide chapters also contain provisions that may be relevant for The cross reference to other District Plan provisions does not acknowledge the network utility chapter, and in Cross references to other relevant District Plan provisions activities in the Natural Open Space zone, including: particular omits references to the objectives, policies and rues associated with the National Grid. The National Grid provisions are unique as they apply to buildings, landuses, earthworks and subdivision across the District. Without It is important to note that in addition to the provisions in this chapter, a . Transport - The Transport Chapter contains provisions relating to traffic cross referencing them, there is a chance that they get overlooked. number of other Part 2: District-Wide chapters also contain provisions that may generation (TRAN-R8) and transport. be relevant for activities in the Natural Open Space zone, including: . Historic Heritage and Sites and Areas of Significance to Māori - Open The National Planning Standards state that zone chapters must include cross-referencing to relevant provisions space areas can contain archaeological sites and sites and areas of under the Energy, Infrastructure and transport heading. Network Utilities [or National Grid] - The Network Utilities [or National Grid] significance to Māori. Specific provisions for the protection of these sites Chapter contains provisions for buildings and landuses within the National Grid are located in the Sites and Areas of Significance to Māori Chapter and It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure plan users Yard and National Grid Substation Corridor, as well as the operation, Historic Heritage Chapter. are aware of the National Grid rules. maintenance, upgrade and development of the National Grid. . Subdivision - The Subdivision Chapter contains provisions which manage subdivision of land in the Open Space and Recreation Zones. If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to . Earthworks - The Earthworks Chapter manages the adverse effects of the National Grid chapter. earthworks on the environment, including visual amenity values and stability of land plus adverse health and safety effects, damage to property and the creation or increase in the risk of natural hazards. . Light - Some recreational activities can require night lights resulting in light spill that may not be able to be fully internalised. The Light Chapter
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment contains specific provisions relating to light spill and the management of effects on adjoining residential areas. . Noise - The Noise Chapter contains specific controls in relation to noise, including effects standards NOISE-S1 (maximum noise levels).
Part 3: Area Specific Matters / Open Space and Recreation Zone / Open Space Zone
Cross references to other relevant District Plan provisions Amend Amend the cross references to other relevant District Plan provisions in the The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply across the District. Open Space Zone as follows: It is important to note that in addition to the provisions in this chapter, a number of other Part 2: District-Wide chapters also contain provisions that may be relevant for The cross reference to other District Plan provisions does not acknowledge the network utility chapter, and in Cross references to other relevant District Plan provisions activities in the Open Space zone, including: particular omits references to the objectives, policies and rues associated with the National Grid. The National Grid provisions are unique as they apply to buildings, landuses, earthworks and subdivision across the District. Without It is important to note that in addition to the provisions in this chapter, a . Transport - The Transport Chapter contains provisions relating to traffic cross referencing them, there is a chance that they get overlooked. number of other Part 2: District-Wide chapters also contain provisions that may generation (TRAN-R8) and transport. be relevant for activities in the Open Space zone, including: . Historic Heritage and Sites and Areas of Significance to Māori - Open The National Planning Standards state that zone chapters must include cross-referencing to relevant provisions space areas can contain archaeological sites and sites and areas of under the Energy, Infrastructure and transport heading. Network Utilities [or National Grid] - The Network Utilities [or National Grid] significance to Māori. Specific provisions for the protection of these sites Chapter contains provisions for buildings and landuses within the National Grid are located in the Sites and Areas of Significance to Māori Chapter and It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure plan users Yard and National Grid Substation Corridor, as well as the operation, Historic Heritage Chapter. are aware of the National Grid rules. maintenance, upgrade and development of the National Grid. . Subdivision - The Subdivision Chapter contains provisions which manage subdivision of land in the Open Space and Recreation Zones. If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to . Earthworks - The Earthworks Chapter manages the adverse effects of the National Grid chapter. earthworks on the environment, including visual amenity values and stability of land plus adverse health and safety effects, damage to property and the creation or increase in the risk of natural hazards. . Light - Some recreational activities can require night lights resulting in light spill that may not be able to be fully internalised. The Light Chapter contains specific provisions relating to light spill and the management of effects on adjoining residential areas. . Noise - The Noise Chapter contains specific controls in relation to noise, including effects standards NOISE-S1 (maximum noise levels).
Part 3: Area Specific Matters / Open Space and Recreation Zone / Sport and Active Recreation Zone
Cross references to other relevant District Plan provisions Amend Amend the cross references to other relevant District Plan provisions in the The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply across the District. Sport and Active Recreation Zone as follows: It is important to note that in addition to the provisions in this chapter, a number of other Part 2: District-Wide chapters also contain provisions that may be relevant for The cross reference to other District Plan provisions does not acknowledge the network utility chapter, and in Cross references to other relevant District Plan provisions activities in the Sport and Active Recreation zone, including: particular omits references to the objectives, policies and rues associated with the National Grid. The National Grid provisions are unique as they apply to buildings, landuses, earthworks and subdivision across the District. Without It is important to note that in addition to the provisions in this chapter, a . Transport - The Transport Chapter contains provisions relating to cross referencing them, there is a chance that they get overlooked. number of other Part 2: District-Wide chapters also contain provisions that may transport matters, including traffic generation (TRAN-R8). be relevant for activities in the Sport and Active Recreation zone, including: . Historic Heritage and Sites and Areas of Significance to Māori - Open The National Planning Standards state that zone chapters must include cross-referencing to relevant provisions space areas can contain archaeological sites and sites and areas of under the Energy, Infrastructure and transport heading. Network Utilities [or National Grid] - The Network Utilities [or National Grid] significance to Māori. Specific provisions for the protection of these sites Chapter contains provisions for buildings and landuses within the National Grid are located in the Sites and Areas of Significance to Māori Chapter and It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure plan users Yard and National Grid Substation Corridor as well as the operation, Historic Heritage Chapter. are aware of the National Grid rules. maintenance, upgrade and development of the National Grid. . Subdivision - The Subdivision chapter contains provisions which manage subdivision of land in the Open Space and Recreation Zones. If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to . Earthworks - The Earthworks Chapter manages the adverse effects of the National Grid chapter. earthworks on the environment, including visual amenity values and stability of land plus adverse health and safety effects, damage to property and the creation or increase in the risk of natural hazards. . Light - Some sport and active recreation activities can require night lights resulting in light spill that may not be able to be fully internalised. The Light Chapter contains specific provisions relating to light spill and the management of effects on adjoining residential areas. . Noise - The Noise Chapter contains specific controls in relation to noise, including effects standards NOISE-S1 (maximum noise levels).
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment
Part 3: Area Specific Matters / Special Purpose Zone / Future Urban Zone
Cross references to other relevant District Plan provisions Amend Amend the cross references to other relevant District Plan provisions in the The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply across the District. Future Urban Zone as follows: It is important to note that in addition to the provisions in this chapter, a number of other Part 2: District-wide Matters chapters contain provisions that may be relevant The cross reference to other District Plan provisions does not acknowledge the network utility chapter, and in Cross references to other relevant District Plan provisions for activities occuring within the Future Urban Zone, including the specific Overlay particular omits references to the objectives, policies and rues associated with the National Grid. The National Grid Chapters referred to within this chapter and: provisions are unique as they apply to buildings, landuses, earthworks and subdivision across the District. Without It is important to note that in addition to the provisions in this chapter, a cross referencing them, there is a chance that they get overlooked. number of other Part 2: District-wide Matters chapters contain provisions that . Transport - The Transport Chapter contains provisions relating to may be relevant for activities occuring within the Future Urban Zone, including transportation matters, including traffic generation (TRAN-R8). The National Planning Standards state that zone chapters must include cross-referencing to relevant provisions the specific Overlay Chapters referred to within this chapter and: . Historic Heritage and Sites and Areas of Significance to Māori - Future under the Energy, Infrastructure and transport heading. urban areas may contain archaeological sites and sites and areas of Network Utilities [or National Grid] - The Network Utilities [or National Grid] significance to Māori. Specific provisions for the protection of these sites It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure plan users Chapter contains provisions for buildings and landuses within the National Grid are located in the Sites and Areas of Significance to Māori Chapter and are aware of the National Grid rules. Yard and National Grid Substation Corridor, as well as the operation, Historic Heritage Chapter. maintenance, upgrade and development of the National Grid. . Subdivision - The Subdivision Chapter contains provisions that apply to If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to subdivision within the Future Urban Zone, including SUB-R3. the National Grid chapter. . Earthworks - The Earthworks Chapter manages the adverse effects of earthworks on the environment, including visual amenity values and stability of land plus adverse health and safety effects, damage to property and the creation or increase in the risk of natural hazards. . Light - The Light Chapter contains specific provisions relating to light emission and the management of light spill effects. . Noise - The Noise Chapter contains specific controls in relation to noise, including effects standards NOISE-S1 (maximum noise levels). . Signs - To ensure signs are compatible with an area, their scale, number, illumination, motion and placement are managed by the Signs Chapter.
Part 3: Area Specific Matters / Special Purpose Zone / Major Facility Zone
Overview Amend The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply across the District. Add a cross reference section to the overview of the Major Facility Zone as follows: The cross reference to other District Plan provisions does not acknowledge the network utility chapter, and in particular omits references to the objectives, policies and rues associated with the National Grid. The National Grid Cross references to other relevant District Plan provisions provisions are unique as they apply to buildings, landuses, earthworks and subdivision across the District. Without cross referencing them, there is a chance that they get overlooked. It is important to note that in addition to the zone chapters, the Network Utilities [or National Grid] Chapter contains provisions for land within the The National Planning Standards state that zone chapters must include cross-referencing to relevant provisions National Grid Yard and National Grid Subdivision Corridor, as well as the under the Energy, Infrastructure and transport heading. operation, maintenance, upgrade and development of the National Grid.
It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure plan users are aware of the National Grid rules.
If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to the National Grid chapter.
Part 3: Area Specific Matters / Special Purpose Zones / Port Zone
Port Zone and the precinct approach Amend A Transpower substation and associated transmission lines are located within the Port site. The substation is to be Add maps of the Port Zone, Port Precinct, operational areas and sub-precinct decommissioned at some stage in the future with a process currently being undertaken on where to permanently areas to make it clear as to the geographical extent of each. locate the lines that currently lead to the port. The North Taranaki Regional Supply Project process is looking at the various options with a temporary connection to made at the port between the two existing transmission lines.
Although the description of the precincts identifies Port Operation C as being traversed by the National Grid, there is a confusing array of references to Port Zone, Port Precinct, areas and sub-precinct areas. Even the combination of the planning maps and Figure 101 does not make clear the geographical extent of each and the map is of poor quality.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment Cross references to other relevant provisions Amend A Transpower substation is located within the Special Purpose Zone – Port, and the National Grid transmission Add the following text to the cross references section in the Port Zone chapter: lines connect within the port area. On this basis the Network Utility chapter provision are relevant to the Port Zone. Network Utilities [or National Grid] - The Network Utilities [or National Grid] Chapter includes provisions for activities within the National Grid Yard and If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to Subdivision Corridor, as well as the operation, maintenance, upgrade and the National Grid chapter. development of the National Grid.
OR
If Transpower’s submission point to add rules into the Special Purpose Port Zone is accepted, add the following text to the cross references section in the Port Zone chapter:
Network Utilities [or National Grid] - The Network Utilities [or National Grid] Chapter includes provisions for activities within the National Grid Yard and Subdivision Corridor, as well as the operation, maintenance, upgrade and development of the National Grid.
PORTZ-P3 Support with Transpower supports the identification of appropriate activities as a policy to guide development of PREC4 – Port. Amend Policy PORTZ-P3 as follows: amendments Port Operation Area C and D are traversed by the National Grid, and a substation is located in Area A so the policy Allow activities in appropriate areas within the Port Zone that are compatible with needs to recognise the National Grid as an appropriate activity, including the effective operation, maintenance, Allow activities in appropriate areas within the Port Zone that are compatible the role, function and character of the zone and the sub-precinct areas identified in upgrading and development of the National Grid. This approach will give effect to Policy 2 of the National Policy with the role, function and character of the zone and the sub-precinct areas PREC4 - Port Precinct, while ensuring their scale, design and intensity is appropriate. Statement for Electricity Transmission. identified in PREC4 - Port Precinct, while ensuring their scale, design and intensity is appropriate. The Network Utilities chapter states that the chapter contains district-wide provisions relating to Network Utilities. Compatible activities include: The rules and effects standards in the zone chapters are not intended to apply to Network Utilities (unless Compatible activities include: otherwise specified, and with the exception of the Special Purpose - Airport Zone and Special Purpose - Port Zone). 1. customary activities in all sub-precinct areas: This means that any rules regarding network utilities in the Special Purpose Zone – Port will apply. 1. customary activities in all sub-precinct areas: 2. port activities in all sub-precinct areas; 2. port activities in all sub-precinct areas; 3. port mixed use commercial, recreation and community activities in the Mixed Use 3. port mixed use commercial, recreation and community activities in the Mixed Port Area; Use Port Area; 4. helicopter facilities, including helicopter take-off and associated fuelling and 4. helicopter facilities, including helicopter take-off and associated fuelling and service facilities in Port Operational Areas A and B and the Mixed Use Port Area; and service facilities in Port Operational Areas A and B and the Mixed Use Port Area; 5. industrial activities in the Port Operational Areas A, B and C and the Port Industry and Area. 5. industrial activities in the Port Operational Areas A, B and C and the Port Industry Area.; and 6. the effective operation, maintenance, upgrading and development of the National Grid. New rule Amend The Network Utilities chapter states that the chapter contains district-wide provisions relating to Network Utilities. Add the following new rules to the Special Purpose Zone Port to enable The rules and effects standards in the zone chapters are not intended to apply to Network Utilities (unless activities and structures associated with the National Grid: otherwise specified, and with the exception of the Special Purpose - Airport Zone and Special Purpose - Port Zone). This means that any rules regarding network utilities in the Special Purpose Zone – Port will apply. National Grid
A Transpower substation is located within the Special Purpose Zone – Port, and there are National Grid 1. Operation, upgrading, maintenance, repair and removal of National Grid transmission lines within the Port Zone. While the NESETA applies to existing National Grid assets, provision should structures be made in the plan for new development that is not provided for in the NESETA. 2. New underground structures
Activity status: PER
3. New aboveground structures
Activity status: RDIS
Matters over which discretion is restricted:
1. The functional and operational needs of, and benefits from the National Grid; 2. The bulk, height, location and design of the network utility, including any associated buildings or structures. 3. The amenity values of the Port Zone and the extent to which any adverse visual amenity effects can be avoided, remedied or mitigated, including:
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment a. integration of the National Grid within the site, existing built form and/or landform in a way that assists to maintain the character and amenity of the surrounding area. b. whether the use of recessive colours and finishes can assist to mitigate any adverse effects. 5. Compliance with recognised standards or guidelines for the potential adverse effects of noise, vibration, radiofrequency fields and electric and magnetic fields; 6. The extent to which adverse effects have been addressed through site, route or method selection; 8. The location of existing National Grid assets, including the need for connection of the networks and services;
Part 3: Area Specific Matters / Development Areas / Carrington Structure Plan Development Area
Overview Amend The National Grid and its associated Subdivision Corridor apply along the northern boundary of the structure plan Add the following text to the Overview in the Carrington Structure Plan area. Development Area: The National Grid is located along the northern edge of the structure plan area. The National Grid Yard is calculated 12m width for land use and the National Grid Subdivision Corridor is 32m from The National Grid Yard and National Grid Subdivision Corridor apply either side the centreline of the lines due to the support structures being towers. Building platforms must be located outside of the centreline of the National Grid lines and any development must give effect the National Grid Yard. This approach is consistent with Policies 10 and 11 in the NPSET. to these. In addition, access to the National Grid must be maintained.
This approach: The provisions regarding development within the National Grid Yard and (a) Most appropriately recognises and provides for the effective operation, maintenance, upgrading and National Grid Subdivision Corridor apply to the Carrington Structure Plan development of the network, as required by NPSET Policy 2; Development Area and are contained in the Network Utilities [or National Grid] (b) Is the best method to manage other activities to ensure the operation, maintenance, upgrading, and chapter. development of the network is not compromised, as required by Policy 10. (c) Recognises the policy directive within Policy 11 to identify an appropriate buffer corridor within which it can be expected that sensitive activities will generally not be provided for.
Policy 10 contains the phrase ‘avoid reverse sensitivity effects’ and ‘to ensure that the operation, maintenance, upgrading and development of the electricity transmission network is not compromised’. Policy 11 gives a clear direction that ‘sensitive activities will generally not be provided for in plans and/or given resource consent’. The use of the words ‘avoid’ and ‘ensure’ and the phrase ‘will generally not be provided for’ provide a strong policy direction.
Structure planning must consider the natural and physical resources of the land, including its values, the location and scale of infrastructure, constraints to development and identify the future pattern of significant land uses based on a consideration of alternatives.
The overview for the Carrington Structure Plan Development Area does not acknowledge the presence of the National Grid, nor the significant constraint to development along that boundary.
It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter and/or provide specific reference to the National Grid provisions to ensure they do not get overlooked.
If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to the National Grid chapter. Overview Amend The National Grid and its associated Yard and Subdivision Corridor apply along the northern boundary of the Add a cross reference section to the overview of the Carrington Structure Plan structure plan area. Development Area as follows:
The overview for the Carrington Structure Plan Development Area does not acknowledge the presence of the Cross references to other relevant District Plan provisions National Grid, nor the significant constraint to development along the northern boundary. It is important to note that in addition to the zone chapters, the Network The National Planning Standards state that zone chapters must include cross-referencing to relevant provisions Utilities [or National Grid] Chapter contains provisions for landuse activities, under the Energy, Infrastructure and transport heading. buildings and subdivision of land within the National Grid Yard and National Grid Subdivision Corridor, as well as the operation, maintenance, upgrade and It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure they do not development of the National Grid. These apply to the Carrington Structure Plan get overlooked. Development Area.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to the National Grid chapter.
New policy Amend The National Grid and its associated Yard and Subdivision Corridor apply along the northern boundary of the Add a new policy to the Carrington Structure Plan Development Area as follows: structure plan area. Given the proximity of the National Grid which will affect the urban form of the northern edge of the structure plan area, it is appropriate to include a policy which recognises this. Development in the Carrington Structure Plan Area will: 1. avoid adverse effects on the National Grid; Structure planning must consider the natural and physical resources of the land, including its values, the location 2. be designed to avoid buildings within the National Grid Yard; and scale of infrastructure, constraints to development and identify the future pattern of significant land uses 3. maintain access to conductors and support structures; and based on a consideration of alternatives. This structure plan does not appropriate recognise nor respond to the 4. not compromise the safe and efficient operation, maintenance, repair, National Grid, which is a significant constraint to development. upgrading or development of the National Grid.
A new policy is an appropriate method for giving effect to Policies 10 and 11 in the National Policy Statement for Electricity Transmission.
Part 3: Area Specific Matters / Development Areas / Junction Structure Plan Development Area
Structure Plan extent Amend The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply to the north-western Amend the north-western and western boundaries of the Junction Structure boundary of the structure plan area. The Carrington Road Substation is located on the corner of Carrington Street Plan Area on Figure 109 Structure Plan to be located 32m from the centreline of and Tarahua Road and there are a number of transmission lines feeding into this substation from the south- the National Grid Line. eastern direction. It is inappropriate to indicate this area as suitable for residential development when the National Grid is located within the structure plan. It incorrectly indicates this area is suitable for residential development. AND
Structure planning must consider the natural and physical resources of the land, including its values, the location Amend the north-western and western boundaries of the Junction Structure and scale of infrastructure, constraints to development and identify the future pattern of significant land uses Plan Area on the planning maps to be located 32m from the centreline of the based on a consideration of alternatives. This structure plan does not appropriate recognise nor respond to the National Grid Line. National Grid, which is a significant constraint to development.
The National Grid Yard is calculated 12m width for land use and the National Grid Subdivision Corridor is 32 from the centreline of the lines due to the support structures being towers. Building platforms must be located outside the National Grid Yard. This approach is consistent with Policies 10 and 11 in the NPSET.
This approach: (a) Most appropriately recognises and provides for the effective operation, maintenance, upgrading and development of the network, as required by NPSET Policy 2; (b) Is the best method to manage other activities to ensure the operation, maintenance, upgrading, and development of the network is not compromised, as required by Policy 10. (c) Recognises the policy directive within Policy 11 to identify an appropriate buffer corridor within which it can be expected that sensitive activities will generally not be provided for.
Policy 10 contains the phrase ‘avoid reverse sensitivity effects’ and ‘to ensure that the operation, maintenance, upgrading and development of the electricity transmission network is not compromised’. Policy 11 gives a clear direction that ‘sensitive activities will generally not be provided for in plans and/or given resource consent’. The use of the words ‘avoid’ and ‘ensure’ and the phrase ‘will generally not be provided for’ provide a strong policy direction.
Overview Amend The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply along the north- Add the following text to the Overview in the Junction Structure Plan western and western boundaries of the structure plan area. Development Area: The National Grid is located along the north-western and western edge of the The overview for the Junction Structure Plan Development Area does not acknowledge the presence of the structure plan area. The National Grid Yard, National Grid Subdivision Corridor National Grid, nor the significant constraint to development along that boundary. and National Grid Substation Corridor apply either side of the centreline of the National Grid lines and around the substation. Any development must give effect It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure they do not to these. In addition, access to the National Grid must be maintained. get overlooked. The provisions regarding development within the National Grid Yard, National If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to Grid Subdivision Corridor and National Grid Substation Corridor apply to the the National Grid chapter. Junction Structure Plan Development Area and are contained in the Network Utilities [or National Grid] chapter.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment Overview Amend The National Grid and its associated Yard and Subdivision Corridor apply along the north-western and western Add a cross reference section to the overview of the Junction Structure Plan boundaries of the structure plan area. Development Area as follows:
The overview for the Junction Structure Plan Development Area does not acknowledge the presence of the Cross references to other relevant District Plan provisions National Grid, nor the significant constraint to development along the northern boundary. It is important to note that in addition to the zone chapters, the Network The National Planning Standards state that zone chapters must include cross-referencing to relevant provisions Utilities [or National Grid] Chapter contains provisions for landuse activities, under the Energy, Infrastructure and transport heading. buildings and subdivision of land within the National Grid Yard and National Grid Subdivision Corridor, as well as the operation, maintenance, upgrade and It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure they do not development of the National Grid. These apply to the Junction Structure Plan get overlooked. Development Area.
If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to the National Grid chapter. New policy Amend The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply to the north-western Add a new policy to the Junction Structure Plan Development Area as follows: and western boundary of the structure plan area. The Carrington Road Substation is located on the corner of Carrington Street and Tarahua Road and there are a number of transmission lines feeding into this substation from Development in the Junction Structure Plan Area will: the south-eastern direction. Given the proximity of the National Grid which will affect the urban form of the north- 1. avoid adverse effects on the National Grid; western and western edges of the structure plan area, it is appropriate to include a policy which recognises this. 2. be designed to avoid buildings within the National Grid Yard; 3. maintain access to conductors and support structures; and Structure planning must consider the natural and physical resources of the land, including its values, the location 4. not compromise the safe and efficient operation, maintenance, repair, and scale of infrastructure, constraints to development and identify the future pattern of significant land uses upgrading or development of the National Grid. based on a consideration of alternatives. This structure plan does not appropriate recognise nor respond to the National Grid, which is a significant constraint to development.
A new policy is an appropriate method for giving effect to Policies 10 and 11 in the National Policy Statement for Electricity Transmission.
Part 3: Area Specific Matters / Development Areas / Patterson Structure Plan Development Area
Overview Amend The National Grid and its associated Yard and Subdivision Corridor apply along the south-western boundary of the Amend the Overview in the Patterson Structure Plan Development Area as structure plan area. The overview recognises that the National Grid traverses the southern boundary, however it is follows: The Patterson Structure Plan has the following key characteristics: incorrect to say that the National Grid provides a buffer between the residential and rural interface. The Patterson Structure Plan has the following key characteristics: 1. topographical variation, including rolling to steep topography; 2. a minimum lot size of 600m²; 1. topographical variation, including rolling to steep topography; 3. high tension National Grid powerlines traversing the southern boundary of the 2. a minimum lot size of 600m²; site, providing a buffer between the residential and rural interface; 3. high tension the National Grid powerlines traversesing the southern boundary 4. stands of native vegetation including a pond which will be retained and protected of the site, providing a buffer between the residential and rural interface; through the development of the structure plan area; 4. stands of native vegetation including a pond which will be retained and 5. internal roading layout connections; and protected through the development of the structure plan area; 6. an archaeological feature, being Dingles Blockhouse. 5. internal roading layout connections; and 6. an archaeological feature, being Dingles Blockhouse.
Overview Amend The National Grid and its associated Subdivision Corridor apply along the south-western boundary of the structure Add the following text to the Overview in the Patterson Structure Plan plan area. Development Area: The National Grid Yard is calculated 12m width for land use and the National Grid Subdivision Corridor is 32m from The National Grid is located along the south-western edge of the structure plan the centreline of the lines due to the support structures being towers. Building platforms must be located outside area. The National Grid Yard and National Grid Subdivision Corridor apply either the National Grid Yard. This approach is consistent with Policies 10 and 11 in the NPSET. side of the centreline of the National Grid lines and any development must give effect to these. In addition, access to the National Grid must be maintained. This approach: (a) Most appropriately recognises and provides for the effective operation, maintenance, upgrading and The provisions regarding development within the National Grid Yard and development of the network, as required by NPSET Policy 2; National Grid Subdivision Corridor apply to the Patterson Structure Plan (b) Is the best method to manage other activities to ensure the operation, maintenance, upgrading, and Development Area and are contained in the Network Utilities [or National Grid] development of the network is not compromised, as required by Policy 10. chapter. (c) Recognises the policy directive within Policy 11 to identify an appropriate buffer corridor within which it can be expected that sensitive activities will generally not be provided for.
Policy 10 contains the phrase ‘avoid reverse sensitivity effects’ and ‘to ensure that the operation, maintenance, upgrading and development of the electricity transmission network is not compromised’. Policy 11 gives a clear direction that ‘sensitive activities will generally not be provided for in plans and/or given resource consent’. The use of the words ‘avoid’ and ‘ensure’ and the phrase ‘will generally not be provided for’ provide a strong policy direction.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment
Structure planning must consider the natural and physical resources of the land, including its values, the location and scale of infrastructure, constraints to development and identify the future pattern of significant land uses based on a consideration of alternatives.
While reference is made in the overview to the National Grid, it does not acknowledge the significant constraint to development along the south western boundary.
It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter and/or provide specific reference to the National Grid provisions to ensure they do not get overlooked.
If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to the National Grid chapter. Overview Amend The National Grid and its associated Yard and Subdivision Corridor apply along the south-western boundary of the Add a cross reference section to the overview of the Patterson Structure Plan structure plan area. Development Area as follows:
The overview for the Patterson Structure Plan Development Area does not acknowledge the presence of the Cross references to other relevant District Plan provisions National Grid, nor the significant constraint to development along the northern boundary. It is important to note that in addition to the zone chapters, the Network The National Planning Standards state that zone chapters must include cross-referencing to relevant provisions Utilities [or National Grid] Chapter contains provisions for landuse activities, under the Energy, Infrastructure and transport heading. buildings and subdivision of land within the National Grid Yard and National Grid Subdivision Corridor, as well as the operation, maintenance, upgrade and It would be helpful to hyperlink to the National Grid provisions in the Network Utility chapter to ensure they do not development of the National Grid. These apply to the Patterson Structure Plan get overlooked. Development Area.
If Transpower’s request to have a specific National Grid chapter is accepted, then the reference will need to be to the National Grid chapter. New policy Amend The National Grid and its associated Yard and Subdivision Corridor apply to the south-western boundary of the Add a new policy to the Patterson Structure Plan Development Area as follows: structure plan area. Given the proximity of the National Grid which will affect the urban form of the south-western edge of the structure plan area, it is appropriate to include a policy which recognises this. Development in the Patterson Structure Plan Area will: 1. avoid adverse effects on the National Grid; Structure planning must consider the natural and physical resources of the land, including its values, the location 2. be designed to avoid buildings within the National Grid Yard; and scale of infrastructure, constraints to development and identify the future pattern of significant land uses 3. maintain access to conductors and support structures; and based on a consideration of alternatives. This structure plan does not appropriate recognise nor respond to the 4. not compromise the safe and efficient operation, maintenance, repair, National Grid, which is a significant constraint to development. upgrading or development of the National Grid.
A new policy is an appropriate method for giving effect to Policies 10 and 11 in the National Policy Statement for Electricity Transmission.
Part 3: Area Specific Matters / Designations
Carrington Substation TPR-2 Support Formerly N33. Retain TPR-2 as a designation and its identification on the planning maps.
Pursuant to Schedule 1 (Clause 4) of the Resource Management Act 1991 (RMA), Transpower gave notice on 27 February 2019 that its existing designations under the Operative New Plymouth District Plan are required to be included in the Proposed New Plymouth District Plan without modification.
Support with Details of the site location for the designation will improve accuracy and certainty of the Proposed District Plan. Include the following site information for the designation: amendments 365 Carrington Street, New Plymouth Lot 1 DP 16781 (1.673 ha), CT TNJ1/72, Parcel ID 4623545 Huirangi Substation TPR-3 Support Formerly N34. Retain TPR-3 as a designation and its identification on the planning maps.
Pursuant to Schedule 1 (Clause 4) of the Resource Management Act 1991 (RMA), Transpower gave notice on 27 February 2019 that its existing designations under the Operative New Plymouth District Plan are required to be included in the Proposed New Plymouth District Plan without modification.
Details of the site location will improve accuracy and certainty of the Proposed District Plan. Support with Details of the site location for the designation will improve accuracy and certainty of the Proposed District Plan. Include the following site information for the designation: amendments 347 Waitara Road, Huirangi Pt Lot 1 DP 6453 (1.3001 ha), CT TNH3/826, Parcel ID 4668130
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment Motunui Substation TPR-4 Support Formerly N35. Retain TPR-4 as a designation and its identification on the planning maps.
Pursuant to Schedule 1 (Clause 4) of the Resource Management Act 1991 (RMA), Transpower gave notice on 27 February 2019 that its existing designations under the Operative New Plymouth District Plan are required to be included in the Proposed New Plymouth District Plan without modification. Support with Details of the site location for the designation will improve accuracy and certainty of the Proposed District Plan. Include the following site information for the designation: amendments 443 Main North Road, Motunui, Waitara Lot 1 DP 16686 (2.417 ha), CT TNJ1/191, Parcel ID 4637636
New Plymouth Outdoor Switchyard TPR-1 Support Formerly N32. Retain TPR-1 as a designation and its identification on the planning maps.
Pursuant to Schedule 1 (Clause 4) of the Resource Management Act 1991 (RMA), Transpower gave notice on 27 February 2019 that its existing designations under the Operative New Plymouth District Plan are required to be included in the Proposed New Plymouth District Plan without modification. Support with Details of the site location for the designation will improve accuracy and certainty of the Proposed District Plan. Include the following site information for the designation: amendments 195 Breakwater Road, New Plymouth Lot 1 DP 17775, (3860 m2) Parcel ID 4610979
Junction Road Switching Station TPR-5 Support Formerly N67. Retain TPR-5 as a designation and its identification on the planning maps.
Pursuant to Schedule 1 (Clause 4) of the Resource Management Act 1991 (RMA), Transpower gave notice on 27 February 2019 that its existing designations under the Operative New Plymouth District Plan are required to be included in the Proposed New Plymouth District Plan without modification. Support with Details of the site location for the designation will improve accuracy and certainty of the Proposed District Plan. Include the following site information for the designation: amendments Lot 3 DP 440643 (53.2198ha), Identifier 547950
Junction Road National Grid Line TPR-6 Support Formerly N67. Retain TPR-6 as a designation and its identification on the planning maps.
Pursuant to Schedule 1 (Clause 4) of the Resource Management Act 1991 (RMA), Transpower gave notice on 27 February 2019 that its existing designations under the Operative New Plymouth District Plan are required to be included in the Proposed New Plymouth District Plan without modification Support with Details of the site location for the designation will improve accuracy and certainty of the Proposed District Plan. Include the following site information for the designation: amendments Lot 3 DP 440643 (53.2198ha), Identifier 547950
Part 4: Appendices and Schedules / Subdivision Design Guide
Subdivision Design Guide Amend The National Grid and its associated Yard, Subdivision Corridor and Substation Corridor apply across the District. Amend the subdivision design guide to recognise the National Grid as a Transpower considers that the subdivision design guide needs to be amended to more fully reflect the intext of the constraint to development, and that subdivision design needs to accommodate higher order planning directives. That is, maintaining the ability to operate, maintain, develop and upgrade the the National Grid Yard, Corridor and Substation Corridor. electricity transmission network and avoid reverse sensitivity effects on the National Grid. INF Policy 3 of the RPS states that “development incompatible with the National Grid is not located within buffer corridors” and thereby ensuring that “reverse sensitivity effects are avoided”. Policy 10 of the NPSET also seeks to “avoid reverse sensitivity effects” to ensure that the “operation, maintenance, upgrading, and development of the electricity transmission network is not compromised”.
The amendments sought to the Subdivision Design Guide will alert developers to the existence and constraint of the National Grid and promote planning development right from inception that appropriately gives effect to the Regional Policy Statement for Taranaki and the National Policy Statement for Electricity Transmission.
Part 4: Appendices and Schedules / Residential Design Guide
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Specific Plan Provision Support/ Reasons for Submission Relief Sought Oppose/ Amendment Residential Design Guide Amend The National Grid and its associated Yard and Substation Corridor apply across the District. Transpower considers Amend the residential design guide to recognise the National Grid as a that the residential design guide needs to be amended to more fully reflect the intext of the higher order planning constraint to development, and that development design needs to directives. That is, maintaining the ability to operate, maintain, develop and upgrade the electricity transmission accommodate the National Grid Yard and Substation Corridor. network and avoid reverse sensitivity effects on the National Grid. INF Policy 3 of the RPS states that “development incompatible with the National Grid is not located within buffer corridors” and thereby ensuring that “reverse sensitivity effects are avoided”. Policy 10 of the NPSET also seeks to “avoid reverse sensitivity effects” to ensure that the “operation, maintenance, upgrading, and development of the electricity transmission network is not compromised”.
The amendments sought to the Residential Design Guide will alert developers to the existence and constraint of the National Grid and promote planning development right from inception that appropriately gives effect to the Regional Policy Statement for Taranaki and the National Policy Statement for Electricity Transmission.
Planning Maps
National Grid Substation Corridor Support Transpower supports the identification of a 12m National Grid Substation Corridor on the Planning Maps beyond Retain the identification of a National Grid Substation Corridor on the Planning the boundary of the Carrington Street and Huirangi Substations. Maps
Ensure that the National Grid Substation Corridor marked on the planning maps measures 12m from the boundary of the substation site. National Grid Amend Transpower supports the identification of the National Grid on the Planning Maps. This is a requirement of Policy Retain the identification of the National Grid on the Planning Maps 12 of the National Policy Statement for Electricity Transmission. AND However, given the need for provisions that also relate to the National Grid Yard, Transpower is concerned that only mapping the subdivision corridor may confuse plan users and imply a greater extent of regulation. Amend the planning map legend from “National Grid Line” to “National Grid” Transpower’s understanding is that Policy 12 is given effect to when the centre line of a transmission line is mapped (this is consistent with the National Planning Standards – Mapping Standard Direction 2). On this basis the AND preference is for rules to relate to the defined distances in the definitions rather than relying on mapped National Grid Line and Corridors. Transpower is concerned for potential misinterpretation of the distances when the maps Delete the National Grid Corridor from the planning maps are used at a granular level. It may also remove the onus on plan users to ground truth the position of the National Grid Yard on individual sites as part of assessing compliance with the District Plan. Significant Waterbodies Amend Transpower supports the identification of Significant Waterbodies but notes they are not shown on the planning Identify Significant Waterbodies on the planning maps. maps as outlined in the definition.
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Appendix 1: Map of Transpower Assets in the New Plymouth District
Filepath SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019
Appendix 2: National Policy Statement on Electricity Transmission 2008
Preamble
This national policy statement sets out the objective and policies to enable the management of the effects of the electricity transmission network under the Resource Management Act 1991.
In accordance with section 55(2A)(a) of the Act, and within four years of approval of this national policy statement, local authorities are to notify and process under the First Schedule to the Act a plan change or review to give effect as appropriate to the provisions of this national policy statement.
The efficient transmission of electricity on the national grid plays a vital role in the well-being of New Zealand, its people and the environment. Electricity transmission has special characteristics that create challenges for its management under the Act. These include:
Transporting electricity efficiently over long distances requires support structures (towers or poles), conductors, wires and cables, and sub-stations and switching stations. These facilities can create environmental effects of a local, regional and national scale. Some of these effects can be significant.
The transmission network is an extensive and linear system which makes it important that there are consistent policy and regulatory approaches by local authorities.
Technical, operational and security requirements associated with the transmission network can limit the extent to which it is feasible to avoid or mitigate all adverse environmental effects. The operation, maintenance and future development of the transmission network can be significantly constrained by the adverse environmental impact of third party activities and development.
The adverse environmental effects of the transmission network are often local – while the benefits may be in a different locality and/or extend beyond the local to the regional and national – making it important that those exercising powers and functions under the Act balance local, regional and national environmental effects (positive and negative).
Ongoing investment in the transmission network and significant upgrades are expected to be required to meet the demand for electricity and to meet the Government’s objective for a renewable energy future, therefore strategic planning to provide for transmission infrastructure is required.
The national policy statement is to be applied by decision-makers under the Act. The objective and policies are intended to guide decision-makers in drafting plan rules, in making decisions on the notification of the resource consents and in the determination of resource consent applications, and in considering notices of requirement for designations for transmission activities.
However, the national policy statement is not meant to be a substitute for, or prevail over, the Act’s statutory purpose or the statutory tests already in existence. Further, the national policy statement is subject to Part 2 of the Act.
For decision-makers under the Act, the national policy statement is intended to be a relevant consideration to be weighed along with other considerations in achieving the sustainable management purpose of the Act.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 This preamble may assist the interpretation of the national policy statement, where this is needed to resolve uncertainty.
1 Title
This national policy statement is the National Policy Statement on Electricity Transmission 2008.
2 Commencement
This national policy statement comes into force on the 28th day after the date on which it is notified in the Gazette.
3 Interpretation
In this national policy statement, unless the context otherwise requires:
Act means the Resource Management Act 1991.
Decision-makers means all persons exercising functions and powers under the Act.
Electricity transmission network, electricity transmission and transmission activities/assets/infrastructure/resources/system all mean part of the national grid of transmission lines and cables (aerial, underground and undersea, including the high-voltage direct current link), stations and sub-stations and other works used to connect grid injection points and grid exit points to convey electricity throughout the North and South Islands of New Zealand.
National environmental standard means a standard prescribed by regulations made under the Act.
National grid means the assets used or owned by Transpower NZ Limited.
Sensitive activities includes schools, residential buildings and hospitals.
4 Matter of national significance
The matter of national significance to which this national policy statement applies is the need to operate, maintain, develop and upgrade the electricity transmission network.
5 Objective
To recognise the national significance of the electricity transmission network by facilitating the operation, maintenance and upgrade of the existing transmission network and the establishment of new transmission resources to meet the needs of present and future generations, while: managing the adverse environmental effects of the network; and managing the adverse effects of other activities on the network.
6 Recognition of the national benefits of transmission
Policy 1
In achieving the purpose of the Act, decision-makers must recognise and provide for the national, regional and local benefits of sustainable, secure and efficient electricity transmission. The benefits relevant to any particular project or development of the electricity transmission network may include: maintained or improved security of supply of electricity; or efficient transfer of energy through a reduction of transmission losses; or
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 the facilitation of the use and development of new electricity generation, including renewable generation which assists in the management of the effects of climate change; or enhanced supply of electricity through the removal of points of congestion. The above list of benefits is not intended to be exhaustive and a particular policy, plan, project or development may have or recognise other benefits.
7 Managing the environmental effects of transmission
Policy 2 In achieving the purpose of the Act, decision-makers must recognise and provide for the effective operation, maintenance, upgrading and development of the electricity transmission network.
Policy 3 When considering measures to avoid, remedy or mitigate adverse environmental effects of transmission activities, decision-makers must consider the constraints imposed on achieving those measures by the technical and operational requirements of the network.
Policy 4 When considering the environmental effects of new transmission infrastructure or major upgrades of existing transmission infrastructure, decision-makers must have regard to the extent to which any adverse effects have been avoided, remedied or mitigated by the route, site and method selection.
Policy 5 When considering the environmental effects of transmission activities associated with transmission assets, decision-makers must enable the reasonable operational, maintenance and minor upgrade requirements of established electricity transmission assets.
Policy 6 Substantial upgrades of transmission infrastructure should be used as an opportunity to reduce existing adverse effects of transmission including such effects on sensitive activities where appropriate.
Policy 7 Planning and development of the transmission system should minimise adverse effects on urban amenity and avoid adverse effects on town centres and areas of high recreational value or amenity and existing sensitive activities.
Policy 8 In rural environments, planning and development of the transmission system should seek to avoid adverse effects on outstanding natural landscapes, areas of high natural character and areas of high recreation value and amenity and existing sensitive activities.
Policy 9 Provisions dealing with electric and magnetic fields associated with the electricity transmission network must be based on the International Commission on Non-ioninsing Radiation Protection Guidelines for limiting exposure to time varying electric magnetic fields (up to 300 GHz) (Health Physics, 1998, 74(4): 494-522) and recommendations from the World Health Organisation monograph Environment Health Criteria (No 238, June 2007) or revisions thereof and any applicable New Zealand standards or national environmental standards.
8 Managing the adverse effects of third parties on the transmission network
Policy 10 In achieving the purpose of the Act, decision-makers must to the extent reasonably possible manage activities to avoid reverse sensitivity effects on the electricity transmission network and to
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 ensure that operation, maintenance, upgrading, and development of the electricity transmission network is not compromised.
Policy 11 Local authorities must consult with the operator of the national grid, to identify an appropriate buffer corridor within which it can be expected that sensitive activities will generally not be provided for in plans and/or given resource consent. To assist local authorities to identify these corridors, they may request the operator of the national grid to provide local authorities with its medium to long- term plans for the alteration or upgrading of each affected section of the national grid (so as to facilitate the long-term strategic planning of the grid).
9 Maps
Policy 12 Territorial authorities must identify the electricity transmission network on their relevant planning maps whether or not the network is designated.
10 Long-term strategic planning for transmission assets
Policy 13 Decision-makers must recognise that the designation process can facilitate long-term planning for the development, operation and maintenance of electricity transmission infrastructure.
Policy 14 Regional councils must include objectives, policies and methods to facilitate long-term planning for investment in transmission infrastructure and its integration with land uses.
Clerk of the Executive Council
Explanatory note This note is not part of the national policy statement but is intended to indicate its general effect
This national policy statement comes into force 28 days after the date of its notification in the Gazette. It provides that electricity transmission is a matter of national significance under the Resource Management Act 1991 and prescribes an objective and policies to guide the making of resource management decisions.
The national policy statement requires local authorities to give effect to its provisions in plans made under the Resource Management Act 1991 by initiating a plan change or review within four years of its approval.
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 Appendix 3: Regional Policy Statement for Taranaki 2010 – Relevant Provisions
4 USE AND DEVELOPMENT OF RESOURCES
UDR OBJECTIVE 1 To recognise the role of resource use and development in the Taranaki region and its contribution to enabling people and communities to provide for their social, economic and cultural wellbeing.
UDR POLICY 1 Recognition will be given in resource management processes to the role of resource use and development in the Taranaki region and its contribution to enabling people and communities to provide for their economic, social and cultural wellbeing.
7 NATURAL HAZARDS
CCHPOLICY 1 Avoid or mitigate adverse effects on the environment arising from climate change by recognising and providing for: (a) the development and protection of the built environment and infrastructure in a manner that takes into account the potential effects of rising sea levels and more variable and extreme weather patterns; ….
11 NATURAL HAZARDS
HAZ POLICY 4 The appropriateness of works and activities designed to modify natural hazard processes and events will be assessed by reference to: … (d) the effectiveness of the works or activities and the practicality of alternative means, including the relocation of existing development or infrastructure away from areas of natural hazard risk.
14 ENERGY
ENE OBJECTIVE 1 To promote the exploration, development, production, transmission and distribution of energy to meet the energy supply needs of the region and New Zealand in a manner that avoids, remedies or mitigates adverse effects on the environment
ENE OBJECTIVE 2 To promote the use and development of renewable sources of energy in a manner that avoids, remedies or mitigates adverse effects on the environment..
ENE OBJECTIVE 3 To increase efficiency in the exploration, development use, production, transmission and distribution of energy.
ENE POLICY 1 Provision will be made for the exploration, development, production, transmission and distribution of energy in Taranaki to enable people and communities access to an adequate supply of energy and thereby to provide for their economic and social wellbeing and for their health and safety.
ENEPOLICY2 Efficiency in the use, production and transmission of energy by users of natural and physical resources will be encouraged as far as is practicable and appropriate having particular regard to:
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 (a) energy requirements of urban form, subdivision patterns and site orientation; (b) the design, location and operation of buildings and other structures; (c) transport modes and patterns; (d) use of appropriate energy saving technologies in industrial, commercial and residential situations; (e) waste management including the minimisation, recovery, re-use and recycling of solid wastes and other contaminants, provided that the energy required to carry out these measures is less than that required to produce new products or materials; (f) research into, and development of, alternative energy sources and more energy efficient methods (both traditional and alternative) in the production and transmission of energy; and (g) the respective roles, functions, and responsibilities of particular agencies. … …
ENE POLICY 4 Provisions shall be included that appropriately recognise the importance of corridors to facilitate the ongoing operation, maintenance, upgrading and development of energy transmission and the need to protect such corridors from activities that impede their efficient operation.
15 THE BUILT ENVIRONMENT
SUD OBJECTIVE 1 To promote sustainable urban development in the Taranaki region.
SUDPOLICY 1 To promote sustainable development in urban areas by: … (d) providing for regionally significant infrastructure; (e) integrating the maintenance, upgrading or provision of infrastructure with land use;
INF OBJECTIVE 1 To provide for the continued safe and efficient operation of the region’s network utilities and other infrastructure of regional significance (including where this is of national importance), while avoiding, remedying or mitigating adverse effects on the environment.
INF POLICY 1 Provision will be made for the efficient and effective establishment, operation, maintenance and upgrading of network utilities and other physical infrastructure of regional significance (including where this is of national importance) and provision for any adverse effects of their establishment to be avoided, remedied or mitigated as far as is practicable.
INF POLICY 2 The adverse effects of subdivision, use and development on the safety, efficiency, operation, maintenance and upgrading of the region’s network utilities and on other physical infrastructure of regional significance (including where this is of national importance) will be avoided or mitigated.
INF POLICY 3 Buffer corridors shall be identified so that development incompatible with the National Grid is not located within such corridors and thereby ensuring reverse sensitivity effects are avoided.
INF POLICY 4 New land use generated by growth and development and the associated local, regional and national infrastructure to service that growth should be integrated and planned alongside one another to avoid either constraints being imposed on necessary growth and development by the
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN Transpower New Zealand Limited November 2019 lack of supporting infrastructure or to avoid unsustainable demands being placed on infrastructure to meet new growth.
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