Submission on Proposed New Plymouth District Plan
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SUBMISSION ON PROPOSED NEW PLYMOUTH DISTRICT PLAN To: District Plan Team New Plymouth District Council Private Bag 2025 New Plymouth 4340 [email protected] / [email protected] Name of Submitter: Greymouth Petroleum Ltd Address for Service: Greymouth Petroleum Ltd 14 Connett Road West Bell Block New Plymouth Attention: Tanya Hansen Consenting & Land Manager [email protected] INTRODUCTION 1. This is a submission by Greymouth Petroleum Ltd (“GPL”) on the proposed New Plymouth District Plan (“proposed District Plan”). 2. GPL generally supports the proposed District Plan, however it considers there are provisions which require amendment/clarification. In relation to such provisions, GPL seeks the relief set out in Attachment A for the reasons also set out in the attachment. P +64 9 357 0600 | 78 Jervois Road, Ponsonby | PO Box 47516, Ponsonby, Auckland 1144 | www.chancerygreen.com GREYMOUTH PETROLEUM LTD 3. GPL is a New Zealand owned and operated company with its operations base in the Bell Block, Taranaki, and with commercial offices in Auckland. GPL’s business focus is the upstream petroleum industry, with production and development of, and exploration for, hydrocarbons at the top of its agenda. 4. GPL markets gas directly to key industrial and commercial customers through the third party owned open-access transmission system. The company is the principal supplier of gas to NZ’s only ammonia urea plant (owned by Ballance Agri-Nutrients – the co-operative owned by New Zealand’s farmers). Other industries requiring gas as fuel or feedstock include starch, dairy, cardboard and food packaging, brewery, peroxide, limestone, building products, meat, rendering, food and oils and methanol. 5. The company has a strong Taranaki Basin focus and its operating objective is to be the lowest- cost vertically-integrated operator. GPL Assets 6. GPL was formed in 2000, and in 2001 acquired the Kaimiro and Ngatoro producing oil and gas fields from Shell, following divestment obligations connected with Shell’s acquisition of Fletcher Challenge Energy. Thereafter, GPL had exploration success in North Taranaki with the discovery and development of the Turangi, Kowhai and Onaero overthrust fields. 7. GPL’s portfolio consists of six onshore mining permits and three onshore exploration permits. 2 8. GPL has reviewed every Block Offer developed by the Crown since 2000 and has been successful with 13 exploration permit awards (10 permits - onshore Taranaki, 2 permits - offshore Taranaki, 1 permit - offshore Great South Basin). Reserves and Production 9. GPL supplies approximately 10% of NZ’s daily gas production. Its production in 2018 was 3.5 mmboe (million barrels of oil equivalent). The company ranks second amongst NZ-owned petroleum production companies when measured on a remaining reserves basis, owning circa 17% of NZ’s gas reserves measured on a 2P (proven and probable) basis. GPL’s ratio of 2P gas reserves to annual production is the highest in NZ, currently ~20 years. GPL Operations in Taranaki 10. GPL is a significant contributor to the Taranaki regional economy. GPL’s Taranaki operations cover four separate service businesses which support development, exploration and production activities: • environmental services • coil and wireline services • drilling via its fleet of five drilling units • trucking services 11. These GPL activities directly employ over 150 staff and contractors and use the services of many local businesses and contracting firms. GPL purchases goods and services from (mainly) Taranaki suppliers to the value of approximately $65 million a year. GPL provides sponsorship to many different sporting groups and organisations within Taranaki and New Zealand and values giving back to the community. GPL also contributes $35 million in tax and royalty payments annually to the Crown. CONCLUSION 12. GPL seeks the relief sought in Attachment A and any necessary consequential or related/further amendments to the proposed District Plan to provide for the concerns expressed in its submission. 3 13. GPL wishes to be heard in support of this submission. If others make a similar submission, GPL would consider presenting a joint case with them at a hearing. 14. GPL could not gain an advantage in trade competition though this submission. Dated this 22nd day of November 2019 For and on behalf of GREYMOUTH PETROLEUM LTD __________________________ Karen Price / Steve Mutch of ChanceryGreen Legal Counsel for Greymouth Petroleum Mining Group 4 ATTACHMENT A: DETAILED SUBMISSION TABLE PROPOSED DISTRICT PLAN PROVISION(S) OPPOSE / SUBMISSION / REASONS RELIEF / DECISION SOUGHT SUPPORT Part 1: Introduction and General Provisions Interpretation: Definitions BUILDING Support GPL supports the definition as drafted to Retain the definition as drafted align with the National Planning Standards: has the same meaning as BUILDING in section 2 of the Definitions Standard. RMA (as set out in the box below): means a temporary or permanent movable or immovable physical construction that is: a. partially or fully roofed, and b. is fixed or located on or in land, but c. excludes any motorised vehicle or other mode of transport that could be moved under its own power. CONSTRUCTION WORK Oppose GPL supports the general form of the CONSTRUCTION WORK has the definition as drafted to align with section 2 of same meaning as given in Section 2 has the same meaning as given in Section 2 of the the (now repealed) Construction Act 1959, of the (now repealed) Construction Construction Act 1959 [for brevity not repeated here] acknowledging direction in the National Act 1959 (as set out below): Planning Standards for consistency in means any work in connection with definitions. However, the definition goes the construction, erection, beyond Section 2 of the Construction Act installation, carrying out, repair, 1959 in excluding petroleum exploration. GPL maintenance, cleaning, painting, considers that the reference to petroleum renewal, alteration, dismantling, or exploration should be removed to keep the demolition of: definition consistent with the Construction Act 1959 (meaning that petroleum exploration (a) Any building, erection, works may come within the definition of edifice, structure, wall, fence, or Construction Work). chimney, whether constructed wholly or partly above or below ground; PROPOSED DISTRICT PLAN PROVISION(S) OPPOSE / SUBMISSION / REASONS RELIEF / DECISION SOUGHT SUPPORT Given the Construction Act 1959 has been (b) Any road, motorway, harbour repealed, this should also be clarified in the works, railway, cableway, tramway, definition to avoid the potential for confusion. canal, or aerodrome; (c) Any drainage, irrigation or river control work; (d) Any electricity, water, gas, telephone, or telegraph reticulation; (e) Any bridge, viaduct, dam, reservoir, earth-works, pipeline, aqueduct, culvert, drive, shaft, tunnel, or reclamation; (f) Any scaffolding; and includes any work in connection with any excavation, site preparation or preparatory work carried out for the purpose of any construction work; and also includes use of any plant, tools, gear, or materials for the purpose of any construction work. but does not include petroleum exploration. ENERGY ACTIVITES Support GPL supports the definition for clarity in Retain the definition as drafted interpreting plan provisions. means the use of land and/or buildings for: • renewable electricity generation activities; and/or • oil and gas activities (petroleum prospecting, petroleum exploration and petroleum production). GAS TRANSMISSION PIPELINE Support GPL supports the definition for clarity in Retain the definition as drafted interpreting plan provisions. 2 PROPOSED DISTRICT PLAN PROVISION(S) OPPOSE / SUBMISSION / REASONS RELIEF / DECISION SOUGHT SUPPORT means a gas transmission pipleine with a pressure greater than 2,000 kilopascals. It is identified as the 'gas transmission pipeline' on planning maps. MAINTENANCE AND REPAIR Support GPL supports the definition as drafted, Retain the definition as drafted including with respect to network utilities. means in relation to buildings and structures, works that will restore or keep the building or structure in a good or sound condition by using the same or similar materials and retaining the existing form, proportions, finishes and characteristics. It does not include additions, or for buildings, any visible structural changes to the external façade. means, in relation to an identified heritage building, item or interior element, works that will restore or keep it to a sound condition by using the same or similar materials and retaining the existing form, proportions, finishes and characteristics. It includes seismic strengthening that is not visible on the exterior of a building or item, or on an interior element, as well as seismic strengthening carried out internally that is not visible from outside the building. means, in relation to a network utility, any work or activity necessary to continue the operation and/or functioning of an existing network utility. It does not include upgrading. means, in relation to the transport network, the repair, replacement or renewal of the transport network where the works do not alter the character, intensity and scale of the transport network. MAJOR FACILITIES: Oppose GPL supports the introductory wording of the Include the following GPL facilities in definition’s description of a Major Facility but the definition: means those facilities which are regionally or nationally seeks specific inclusion