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Omata Tank Farm Operators Your Reference : Our Reference : 17458.02 22nd November 2019 Omata Tank Farm Operators SUBMISSION ON THE PROPOSED DISTRICT PLAN NEW PLYMOUTH DISTRICT COUNCIL To: New Plymouth District Council Private Bag 2025 New Plymouth 4340 Email: [email protected] Submitter: Omata Tank Farm Operators c/o Cam Twigley BTW Company Ltd PO Box 551 New Plymouth 4340 Phone: 06 759 5040 Email: [email protected] Omata Tank Farm Operators (OTFO) wish to be heard in support of this submission. I confirm that I am authorised on behalf of OTFO to make this submission. If others make a similar submission OTFO would consider presenting a joint case with them at a hearing OTFO are not directly affected by an effect of the subject matter of the submission that: (1) Adversely affects the environment; and (2) Does not relate to trade competition or the effects of trade competition. The specific parts of the Proposed Plan that this submission relates to are the provisions set out in Appendix 1. 1. Introduction Thank you for the opportunity to provide a submission on New Plymouth District Council’s Proposed District Plan. This submission follows a previous submission on the Draft District Plan submission process in 2018. The previous submission was made on behalf of a number of companies with interests in the Omata Tank Farm (OTF). These parties included Energy Infrastructure Limited, Methanex, Lattice Energy and New Zealand Oil Services Ltd (NZOSL). NZOSL operate their site on behalf of the leasee BP Oil who lease the site from Port Taranaki. Within the previous submission, these companies were referred to as the OTF Interest Group. For the purposes of this submission this group is now referred to as the OTFO. Another point to note is Lattice Energy is now referred to as Beach Energy. 2. About Omata Tank Farm The OTF is a hydrocarbon storage facility located to the west of New Plymouth accessed off Centennial Drive comprising a land area of approximately 87ha. The OTF consists of 14 storage tanks in a number of compound areas operated by the various parties outlined above. A number of pipelines tie into the OTF and distribute hydrocarbon products from the OTF to Port Taranaki. Many of the facilities within the OTF also receive tanker load ins and load outs. The OTF also includes Lloyds Ponds, which are a Significant Natural Area and a Regionally Significant Wetland, and Te Ngahoro Pa which is listed as a waahi taonga site in the operative New Plymouth District Plan and is registered as an archaeological site by the New Zealand Archaeological Association. The remainder of the OTF is predominantly pasture and is grazed by stock with landscape planting along the southern and eastern boundaries. 3. Background to Submission The Draft District Plan signalled a number of changes which would result in a more prescriptive and certain approach, with much more directive provisions on appropriate zones for activities. Within its previous submission, the OTF Interest Group supported this approach as it ensured the relevant planning provisions would enable their future activities and that their current operations would be protected with operational flexibility maintained. The OTF Interest Group made a number of submissions on various provisions that in their opinion required amendment. 4. Summary of Submission on Proposed District Plan Definitions OTFO seek that the definition of petroleum production makes it clear the petroleum production includes petroleum storage which is the primary activity that occurs at the OTF. Major Facility Zone OTFO, in most part, support the provisions within the Major Facility Zone section but seek changes to effects standards MFZ-S4 Landscaping Requirements as they are not practically achievable. OTF Precinct Plan OTFO notes that the Precinct Plan refers to Lattice Energy who has now changed their company name to Beach Energy. OTFO requests that this change is made to the Precinct Plan. OTFO also seeks changes to the Eplan maps to remove a section of the coastal environment overlay from the OTF and align the boundary with the Centennial Drive road boundary. OTFO also seek an addition to the Precinct Plan for a ‘no minimum building setback’ provision for practical HSE and security reasons. Noise OTFO seeks retention of the notional boundary measurement point for noise received by rural zoned sites on the basis that this is a more practical and effects-based way to manage noise in rural areas and there is no evidence of issues with this approach. 5. Overall Conclusion OTF are largely supportive of the Proposed District Plan provisions and seek relatively minor amendments. OTF thanks New Plymouth District Council for the opportunity to provide a submission on the Proposed District Plan and for their proactive engagement on the earlier draft version of the Plan. APPENDIX 1: DETAILED SUBMISSION ON PROPOSED DISTRICT PLAN PROVISIONS PROPOSED DISTRICT PLAN OPPOSE / SUBMISSION / REASONS RELIEF / DECISION SOUGHT SUPPORT / AMEND Definitions Petroleum Production Oppose OTFO wish to ensure that Amend to ‘any activity the definition is clear that undertaken for the purpose storage of petroleum of extracting and processing substances is included petroleum substances into a given this is the major usable product including activity that occurs at the storage of petroleum OTF. substances’ MFZ – Major Facility Zone Part 3: Area Specific Matters/Special Purpose Support OTFO support the OTF Retain Provision Zones - MFZ-O1-O4 and MFZ-P1-P9 objectives being identified within the and policies for the Major Facility Zone MFZ. OTFO support the objectives and policies which reflect the importance of OTF being a key piece of national and regional infrastructure and an important contributor to the energy industry. MFZ-R1-R4 covering primary land use activities, Support OTFO supports the Retain Provision ancillary activities, operation, maintenance and permitted activity status for repairs, upgrading and removal of major facilities, primary, ancillary, agricultural, pastoral and horticultural activities agricultural, pastoral and horticultural activities which incorporates all activities that are currently PROPOSED DISTRICT PLAN OPPOSE / SUBMISSION / REASONS RELIEF / DECISION SOUGHT SUPPORT / AMEND undertaken on the OTF land. MFZ-R5-R11 covering retail activities, business Support OTFO supports the Retain Provision service activities, commercial service activities, exclusion of these activities sensitive activities, medical and health services, from the MFZ as these sport and recreation activities and any other activity activities would create not otherwise listed in the MFZ table. conflict with OTF’s activities. MFZ-R12 covering building activities Support OTFO supports that Retain Provision building activities associated with the primary and ancillary OTF activities listed in the Precinct Plan should be permitted activities. Effects standards MFZ-S1 to MFZ-S3 covering Support OTFO supports that the Retain Provision maximum building height, height in relation to effects standards refer to boundary, minimum setbacks for buildings, outdoor the MFZ Precinct Plans storage areas and carparking areas. (PREC8 – Figure 95 for OTF Precinct) for guidance on what is permitted at OTF. Effects standard MFZ-S4 Landscaping Oppose It is not practical to provide Amend Provision requirements screening for any outdoor storage area at OTF from 1. Any outdoor public spaces due to HSE storage areas and security requirements. (excluding hydrocarbon tanks) for goods, materials, product, PROPOSED DISTRICT PLAN OPPOSE / SUBMISSION / REASONS RELIEF / DECISION SOUGHT SUPPORT / AMEND plant, machinery or equipment, and waste must be screened from view from any adjoining residential or rural zoned site or public space (including a public road) by either: a. landscaping and planting that reaches a minimum height of 2m, and a minimum width of 2m from the boundary, within two years of being planted; or b. a close-boarded, enclosed fence made of solid material with a minimum height of 1.2m and a maximum height of 2m MFZ Precincts – PREC8 – Figure 95 Oppose The planning maps have Amend Provision largely adopted the Centennial Drive road OTFO seeks that a road boundary as the coastal and coastal environment environment boundary. setback provision is added Many of the sites within the to the Precinct Specific OTF have buildings, Provisions on the OTF outdoor storage areas and Precinct Plan. OTFO seek carparking areas PROPOSED DISTRICT PLAN OPPOSE / SUBMISSION / REASONS RELIEF / DECISION SOUGHT SUPPORT / AMEND immediately adjacent to the that the setback is ‘no Centennial Drive road minimum setback’. boundary. Imposing a setback from the road and Amend Lattice Energy to coastal environment would Beach Energy. impose unnecessary regulations on existing and proposed activities at OTF. Hazardous Substances Overview Support The layer is a practical way Retain Provision to manage changes to the OTFO support the risk contour that may occur concept of a non- over time without the need District Plan layer to to go through a formal plan identify the location of change each time this may significant hazardous happen. facilities and communicate risk to the community. E Plan Maps Coastal Environment Overlay Oppose The planning maps adopt Amend Provision an arbitrary and unpractical boundary for the coastal Move coastal environment environment which overlay towards coast to encroaches significantly align with Centennial Drive into the OTF site. road reserve boundary (see Figure 1 below). PROPOSED DISTRICT
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