SUBMISSION BY FIRST GAS LIMITED ON NPDC’S PROPOSED DISTRICT PLAN

To: District Council Address: Private Bag 2025, New Plymouth 4342 Email: [email protected]

Submitter Details Please note that all information provided in your submission, including your personal information, will be made publicly available.

Name of submitter: Zane Wood On behalf of: First Gas Limited Postal address: Private Bag 2020, New Plymouth 4340 Email address: [email protected] Phone number: 06 769 8247 – 027 287 7248 Contact person: Zane Wood – Senior Land and Planning Advisor

Trade Competition Can you gain an advantage in trade competition in making this submission? Yes ☐ No ☒

Are you 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. Yes ☐ No ☒

Council Hearing Do you wish to be heard in support of your submission? Yes ☒ No ☐

If others make a similar submission would you consider presenting a joint case with them at a hearing? Yes ☒ No ☐

Submission The submission points, reasons and decisions sought are set out in the attached document.

Note: Any attachments to your submission should only be supporting information, not the submission.

______22.11.2019 Signature of the person making submission Date or the person authorised to sign on behalf of the person making submission

Page | 1

Submission by First Gas Ltd

Proposed Plan

22 November 2019

Page | 2 Submitter Details

Organisation: First Gas Limited

Postal Address: First Gas Limited Private Bag 2020 New Plymouth 4340

Email: [email protected]

Phone: Tel: +64 6 769 8247

(Signature of person authorised to sign on behalf of Firstgas Ltd)

22 November 2019

Title and address for service of person making comment:

Firstgas Ltd

Attention: Zane Wood

Address: First Gas Limited Private Bag 2020 New Plymouth 4340

Page | 3 1 Introduction to First Gas Ltd

First Gas Limited (‘Firstgas’) purchased the gas transmission network from Vector Gas Ltd on 20 April 2016. Firstgas now owns and operates approximately 2500km of high-pressure natural gas transmission pipelines throughout the North Island, and is also a Requiring Authority under the Resource Management Act 1991 (‘RMA’). Firstgas’ ownership includes the ancillary above and below ground infrastructure required to operate the gas network. Collectively this system is known as the Gas Transmission Network.

In addition to the Gas Transmission Network, Firstgas also operates more than 4,800kms of gas distribution networks across the North Island, although none of its distribution network is located within the New Plymouth District.

In RMA context Firstgas’ assets and operations deliver significant benefits to the wider North Island. The transmission (and distribution) of natural gas provides for economic growth, enables communities, business and industry to function and provides for people and communities’ social well-being and their health and safety. The Gas Transmission Network is both regionally and nationally significant.

Within the New Plymouth District, Firstgas owns and operates the following components of the Gas Transmission Network:

◼ Transmission Pipeline ◼ Delivery Point (Above Ground Asset)

Delivery Points are above-ground compounds where high-pressure gas in the transmission network is converted to low-pressure for distribution. Delivery Point stations often emit (venting or flaring of gas) to regulate the pressure.

Firstgas’ assets in the area are illustrated in Figure 1-1 below.

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Figure 1-1: Firstgas Ltd pipelines and above-ground assets in the New Plymouth District

Page | 5 2 Firstgas Interests in the Proposed New Plymouth District Plan

2.1 Background

Prior to purchasing the Gas Transmission Network in 2016, former owners and operators relied on the legal gas easement to both enable the operation, maintenance and upgrade of the network and protect the asset from others’ activities. Reliance on this land instrument, as opposed to planning instruments, has not always secured good outcomes for Firstgas. For example, there have been many recent instances where:

◼ Legal and / or physical vehicular access has been compromised through subdivision and land use development. ◼ Activities that are sensitive to the Gas Transmission Network have been authorised to establish and operate in too close a proximity to the network, thereby creating reverse sensitivity effects.

2.2 General Approach to RMA Processes

Consequently, since purchasing the Gas Transmission Network, Firstgas has become active in RMA processes through submissions. The outcomes sought have generally been to:

◼ enable the operation, maintenance, upgrade development and/ or removal of its assets and operations, including vehicular access; and ◼ protect its assets and operations from others’ land-use and subdivision activities (including through legal and physical vehicular access).

To assist this, Firstgas has worked on a suite of ‘model provisions’ specific to the Gas Transmission Network which are sought for inclusion within district plans, the objective being to achieve North Island wide consistency and fulfill its own operating obligations under AS2885 (Australian Standard AS 2885 Pipelines – Gas and Liquid Petroleum).

2.2.1 Operation, maintenance, replacement, upgrade, removal and development

Firstgas’ gas network is regionally and nationally significant infrastructure in that it delivers significant benefits to people and communities social and economic well-being, as well as provide for their health and safety. In light of the benefits provided by the network, the safe, efficient and effective operation, maintenance, replacement, upgrade, removal and/ or development of the network needs to be provided for in land use planning frameworks, while ensuring adverse effects generated by those activities and operations are appropriately managed. This is sought to be delivered through enabling objective and policy frameworks and enabling rules and activity statuses.

2.2.2 Protection from third party works

Firstgas is required to ensure the protection and integrity of the pipeline is maintained to ensure the safety of the public, property and the environment. Pipelines are required to meet the safety and operational requirements of the Health and Safety in Employment (Pipelines) Regulations 1999 and the operating code Standard AS2885 Pipelines – Gas and Liquid Petroleum (AS2885).

Third party interference is one of the main risks to the safety and integrity of the underground pipelines. Activities which may affect the Gas Transmission Network need to take into account the location and protection requirements of the pipelines and other infrastructure. Activities in the vicinity of the Gas Transmission Network need to be carried out in a way which does not compromise the safe and efficient operation of the network, including the ability to legally and physically access the network with the necessary machinery to undertake works.

Firstgas is seeking to manage third party interference through the requirement of a resource consent for a range of activities including the subdivision of land containing, or in close proximity to, the Gas Transmission Network, land use related setbacks for certain activities.

Page | 6 2.2.3 Consistent outcomes sought in District Plan reviews

Firstgas works proactively with local authorities through district plan reviews to seek to embed both enabling and protective provisions in district plans, and in this context is grateful to New Plymouth District Council for the opportunity to provide comments through the Draft District Plan process.

Specific and consistent outcomes sought across the North Island are:

◼ Mapping of the Gas Transmission Network, inclusive of Delivery Points on planning maps. ◼ An enabling objective, policy and rule framework for operating, maintaining, upgrading the Gas Transmission Network. ◼ A restricted discretionary activity for the subdivision of land containing the Gas Transmission Pipeline, with the matters of discretion including any technical advice from Firstgas. ◼ Permitted activity land use development and activity set back standards from the Gas Transmission Network, inclusive of above ground gas stations. ◼ Reverse sensitivity policy provisions related to the Gas Transmission Network.

2.3 Proposed New Plymouth District Plan

The Gas Transmission Network traverses the General Residential Zone, General Rural Zone, Rural Lifestyle Zone, Settlement Zone, Open Space Zone and the Special Purpose – Future Urban Zone within the New Plymouth District Plan.

It is noted the Gas Transmission Pipeline is appropriately illustrated on the Planning Maps, however Firstgas does seek some alterations to the maps to include the Delivery Points which form a critical part of the Gas Transmission Network and require additional planning consideration.

2.3.1 Designated Assets

Firstgas is a Requiring Authority under Section 167 of the Resource Management Act and has two Designation in the Proposed New Plymouth District Plan. Please see the below exert from the Proposed New Plymouth District Plan:

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Firstgas supports the Rollover of these Designations in the Proposed New Plymouth District Plan. We shall submit a separate letter to confirm our intent to Rollover these Designations.

3 Regional Policy Statement – Region

The District Plan must ‘give effect’ to a Regional Policy Statement (RPS). The operative RPS for the Taranaki Region Includes the need to:

• Provide for the safe and efficient operation of network utilities and other infrastructure of regional significance.

The RPS for the Taranaki Region includes the following key objectives which have a direct influence on District Plan content as it relates to Firstgas’ assets and activities within the district:

Provision Wording

ENE To promote the exploration, development, production, To promote the exploration, Objective 1 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 adve a manner that avoids, remedies or mitigates adverse effects on the environment. ENE To increase efficiency in the exploration, development use, production, transmission and Objective 3 distribution of use, production, transmission and distribution of energy

Page | 8 Provision Wording

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. ENE Policy 3 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. 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. 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.

‘Giving effect’ to the RPS essentially means that the District Plan must implement the RPS through its provisions, and ultimately will ensure that:

◼ Firstgas’ regionally (and nationally) significant assets are able to be safely, effectively and efficiently operated, maintained, upgraded, replaced, removed and / or developed while appropriately managing adverse effects, including reverse sensitivity; and, ◼ the adverse effects of development in proximity to Firstgas’ regionally (and nationally) significant assets are avoided or mitigated depending upon the context in which the development occurs.

4 General Response Attachment 1 details the outcomes that Firstgas would seek. In summary, Firstgas seeks that: ◼ The Gas Transmission Network is enabled to be safely, effectively and efficiently operated, maintained, replaced, upgraded, removed and developed (i.e. recognised and provided for) through an enabling activity status; ◼ The Gas Transmission Network is recognised as having functional and operational requirements and constraints, including in respect of its location; ◼ There may be some occasions where works undertaken by Firstgas generate adverse environmental effects; ◼ That the adverse effects of third-party development or activities in close proximity to the Gas Transmission Network are managed to the extent that adverse effects on the network are avoided or appropriately mitigated; ◼ Firstgas is identified as an affected party in the event resource consent is required in respect of potential effects on assets owned and operated by Firstgas especially land use changes and subdivision, or alternatively the matters of discretion or assessment criteria include technical advice from Firstgas; and ◼ The identification of the Gas Transmission Network, including Delivery Points which form part of the network, on the District Plan Maps to ensure visibility of the network for plan users.

Page | 9 First Gas The specific submissions and the decisions sought for NPDC’s Proposed District Plan are as follows:

Attachment 1: Detailed Response by First Gas Ltd

The following table sets out the decisions sought by First Gas Ltd (Firstgas), including specific amendments to provisions of the New Plymouth District Council Draft District Plan (the Plan). These amendments are shown as underline (for new text sought) and strikethrough (for deletion).

Draft Plan Provision Support/Oppose/A Reasons Relief Sought mend/Add

Part 1 – Introduction and General Provisions

Interpretation – Definitions

Earthworks Amend Firstgas Ltd seek exclusions to be incorporated in the definition as this is the most efficient Amend the ‘earthworks’ definition as follows: and effective method of enabling temporary earthwork related activities. Once a pipe has been maintained or upgraded, the land surface is restored. Earthworks: means the alteration or disturbance of land, including by moving, removing, placing, blading, cutting, contouring, filling or excavation of earth (or any matter constituting the land including soil, clay, sand and rock); but excludes a. gardening, b. cultivation, and disturbance of land for the installation of fence posts, c. thrusting, boring, trenching or mole ploughing associated with pipe laying and maintenance d. the construction, repair, upgrade or maintenance of pipelines e. a geotechnical bore

Gas Transmission Pipeline Add Firstgas seeks the inclusion of additional terms which are required to implement rules Add a new definition: Corridor sought in the Plan related to the Gas Transmission Network. The definitions provide clarity on terms and how those terms relate to outcomes sought. The area of land within 10m from the centreline of the Gas Transmission Pipeline.

Page | 10 Draft Plan Provision Support/Oppose/A Reasons Relief Sought mend/Add

Gas Transmission Network Add Add a new definition which reads:

Gas Transmission Network: Pipelines for the transmission of natural or manufactured gas or petroleum at a gauge pressure exceeding 2,000 kilopascals, including any associated above or below-ground fitting, appurtenance, fixture or equipment required for the conveyance of the product or material in the pipeline and/or for its safe, efficient or effective operation.

Gas Transmission Pipeline Add Add a new definition which reads: Assessment

Gas Transmission Pipeline Risk Assessment means an assessment prepared by a suitably qualified person nominated by the owner of the gas transmission pipeline on behalf of a Network Utility Operator, which as a minimum:

a. establishes the minimum separation distances for the safety as between the Network Utility Operator’s Utility Structures and the gas transmission pipeline; b. determines other minimum separation requirements such as for operation, maintenance and repair of the Utility Structure, the gas transmission pipeline and any other Utility Structures in the road and motorway corridors; c. demonstrates compliance with applicable legislation, standards and codes of practice which provide minimum depths and separation distances for Utility Structures;

Page | 11 Draft Plan Provision Support/Oppose/A Reasons Relief Sought mend/Add

d. summarises the outcome of consultation with the gas transmission owner and operator; and e. e) discuss risk issues with the Transport Corridor Manager and ensure these are managed appropriately in the design.

Gas Transmission Sensitive Add Add a new definition which reads: Activity Means those activities that are particularly sensitive to the Gas Transmission Network, including but not limited to:

◼ medium and high-density residential activities; ◼ retirement villages; ◼ hospitals and healthcare facilities; ◼ educational facilities; ◼ community facilities, including museums, stadiums and halls; ◼ leisure and entertainment facilities, including shopping malls and movie theatres; ◼ marae; ◼ custodial corrections activities; ◼ entertainment facilities; ◼ visitor accommodation; ◼ hazardous facilities and infrastructure (excluding those that are ancillary to gas transmission); and ◼ other venues or areas where larger numbers of people are intermittent and in larger numbers than the general location/area.

Regionally Significant Add Firstgas seeks that the definition of ‘Regionally Significant Infrastructure’ be added to Add a new definition which includes: Infrastructure reference the complete Gas Transmission Network along with other core regional infrastructure, including but not limited to electricity network, telecommunication network, Regionally Significant Infrastructure: means regionally three waters. significant infrastructure including:

Page | 12 Draft Plan Provision Support/Oppose/A Reasons Relief Sought mend/Add

a. The Gas Transmission Network; …

Part 2 – District Wide Matters HAZS - Hazardous Substances

New Restricted Add Firstgas seeks that the Plan adopt a precautionary approach to hazard risk management. Addition of a new rule to the Hazardous Substances section, Discretionary activity The use of explosives near the Gas Transmission Network poses a health and safety, and environmental risk should the activity not be properly managed. It is sought that the Plan which reads as follows: apply a new rule, which requires that the use of explosives within 100 metres of the Gas Restricted Discretionary Activities Transmission Network be assessed as a restricted discretionary activity. The use of explosives within 100 metres of the Gas Transmission Network Matters of discretion are restricted to:

a. The risk of hazards affecting public or individual safety, and the risk of property damage; b. Measures proposed to avoid or mitigate potential adverse effects on the Gas Transmission Network; c. Technical advice from the owner and operator of the Gas Transmission Network, including an assessment of the level of risk; d. The outcome of any consultation with the owner and operator of the Gas Transmission Network; and e. Whether the use of explosives could be located a greater distance from the Gas Transmission Network

Page | 13 Draft Plan Provision Support/Oppose/A Reasons Relief Sought mend/Add

Part 2 – District Wide Matters

Energy, Infrastructure, and Transport

Objectives NU-01 – 03 Support The infrastructure objectives are generally supported in terms of the outcomes they seek Retain as drafted related to infrastructure.

Policies NU-P01 – P08 Support The infrastructure policies are generally supported in terms of the outcomes they seek Retain as drafted related to infrastructure.

NU-39 Support with Firstgas is generally supportive of a permitted activity status for earthworks within the Gas Activity status: PER amendment Transmission Pipeline Corridor providing the potential risk and effects in relation to the Where: pipeline and those working in the vicinity of the pipeline are well understood. This has led 1. the stability or integrity of the gas transmission to the recommended inclusion of Gas Transmission Pipeline Risk Assessments (as defined) to be included in the compliance process. pipeline is not compromised; and 2. the earthworks do not involve: a. any permanent alteration to the profile, contour or height of the land within the corridor; or b. the planting of trees within 10 metres of the gas transmission pipeline; and 3. for any works within a gas pipeline easement area, a Pipeline Easement Permit is obtained, and a copy of the permit is provided to the Council prior to the commencement of the works; 4. Earthworks and land disturbance within the land transport corridor must not be within 3 metres of a gas transmission pipeline, except where undertaken in accordance with a Gas Transmission Pipeline Risk Assessment; or 5. Earthworks and land disturbance outside the land transport corridor must not be within 20 metres of a gas transmission pipeline, except where undertaken in accordance with a Gas Transmission Pipeline Risk Assessment.

Note: 1. Clauses (2) to (5) above do not apply to land disturbance undertaken as part of normal

Page | 14 Draft Plan Provision Support/Oppose/A Reasons Relief Sought mend/Add agricultural, horticultural or domestic cultivation activities, or the maintenance and repair, including sealing, of a road, footpath, driveway or farm track. 2. Clause (2) does not apply to earthworks or land disturbance undertaken by a network utility operator within a road reserve. 3. If a resource consent application is made under this rule, the owner and operator of the Gas Transmission Pipeline 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-R40 Support in part and Firstgas supports this rule in principle but seeks that the activity status for subdivision of a Restricted Discretionary Activities amend site that contains a Gas Transmission Pipeline corridor be a Restricted Discretionary Activity. Subdivision of land in any zone containing the Gas Transmission Pipeline Corridor and / or within 30m of a site containing any above-ground part of the Gas Transmission Network.

Retain the matters over which discretion is restricted as drafted.

NU-R41 Support in part Firstgas supports this rule in principle but seeks that the separation of the sensitive activity Amend as follows: or the erection of buildings for sensitive activities require a further separation from the Gas Transmission Pipeline Network to ensure health, safety and environmental risks are Restricted Discretionary Activities appropriately managed.

Gas Transmission Sensitive Activities within 60 metres of the Gas Transmission Pipeline Network.

Matters of discretion are restricted to:

Where: 1. The gas transmission sensitive activity does not involve the use, storage or disposal of hazardous substances with explosive or flammable intrinsic properties, except when the use, storage or disposal of such substances is ancillary to gas

Page | 15 Draft Plan Provision Support/Oppose/A Reasons Relief Sought mend/Add transmission activities or in domestic scale quantities.

Matters of discretion are restricted to:

a. The extent to which the proposed activities are likely to compromise the stability or integrity of the gas transmission pipeline and the operation, maintenance and upgrading of the pipeline. b. The risk of hazards affecting public or individual safety, and the risk of property damage. c. Measures proposed to avoid or mitigate potential adverse effects on the gas transmission pipeline. d. An assessment of any risks to the environment that are likely to arise from the activity being located in proximity to the gas transmission pipeline. e. The outcome of any consultation with the owner and operator of the gas transmission pipeline. f. The extent to which vehicular, physical and legal access to the gas transmission pipeline is maintained g. Whether any possible alternative locations or methods for undertaking the activity exist.

Part 2 – Subdivision

SUB-R2 Support This rule is supported in conjunction with the subdivision rules within the Network Utilities Retain as drafted chapter under Part 2: District Wide Matters

NOTE: include reference that further subdivision rules apply

in the Utilities Chapter, where potentially adversely affecting infrastructure.

Page | 16 Draft Plan Provision Support/Oppose/A Reasons Relief Sought mend/Add Part 2 – District Wide Provisions - Earthworks

Permitted Activity Rule Add Firstgas seek the addition of a Permitted Activity Rule to enable earthworks required for Add a new Permitted Activity Rule, which reads as follows: certain activities which are acceptable near a Gas Transmission Pipeline up to a depth of 400mm. 1. Earthworks within the Gas Transmission Corridor up to a depth of 400mm for the purpose of the installation of driveways, utility services, post holes and Cultivation/planting:

a. provided the earthworks are limited to land disturbance that: I. is not associated with the planting or removal of trees within 6 meters of the gas transmission pipeline; II. does not exceed a maximum depth of 400mm within 6 metres of the gas transmission pipeline; III. does not involve the use of heavy vehicles or machinery, including hydraulic or air operated machine mounted rock breakers; IV. does not involve vibration or compaction; V. does not compromise the stability or integrity of the gas transmission pipeline; and

b. for any land disturbance within a gas pipeline easement: provided a Pipeline Easement Permit has been obtained and a copy of the Permit is provided to the Council at least 15 working days prior to the commencement of the land disturbance; or

c. for any land disturbance not within a gas pipeline easement area: provided written notice of the work is provided to the gas transmission pipeline owner and operator and the Council at least 20 working

Page | 17 Draft Plan Provision Support/Oppose/A Reasons Relief Sought mend/Add days prior to the commencement of the land disturbance.

2. For any earthworks within 10 – 20 metres of the gas transmission pipeline: provided at least 20 working days prior to the commencement of the earthworks, written notice of the work is provided to the gas transmission pipeline owner and operator and the Council.

New Restricted Add Firstgas seeks that the risks posed by earthworks near a gas transmission pipeline be Add a new restricted discretionary activity, which reads as Discretionary Activity Rule managed, through a rule which requires consent as a restricted discretionary activity for follows: earthworks within the Gas Pipeline Corridor which are not listed as a Permitted Activity and / or exceeds a depth of 400mm. Any earthworks within the Gas Transmission Pipeline Corridor which does not comply with the Permitted Activity

standards / exceeds a depth of 400mm

Matter of discretion to include the following:

a. The risk of hazards affecting public or individual safety, and the risk of property damage. b. Measures proposed to avoid or mitigate potential adverse effects on the gas transmission pipeline. c. Technical advice, including an assessment of the level of risk. d. The outcome of any consultation with the owner and operator of the gas transmission pipeline.

Part 3 – Area Specific Matters (comments apply to all areas within which the Gas Transmission Network is located)

Restricted Discretionary Add Add new rule in all relevant zones (identified in Section 2.3) Activities Land use development, in particular residential dwellings and sensitive activities located which triggers a Restricted Discretionary consent for: too close to the Gas Transmission Network can result in a number of issues for both

Firstgas and the proposed development / activity and pose significant risk. Such land use 1. Any habitable structure or building within 20m of the centreline of the Gas Transmission Pipeline. development and subsequent activity may pose risks to people and property. In addition,

Page | 18 Draft Plan Provision Support/Oppose/A Reasons Relief Sought mend/Add

such development and activity may adversely affect the operation of the Gas Transmission 2. Any habitable structure or building within 30m of a site containing any above-ground part of the Gas Network and be inconvenient and expensive not only to Firstgas but also to consumers. Transmission Network.

3. Any Gas Transmission Sensitive Activity within Land use development may include the establishment of buildings and structures, as well 60m of the Gas Transmission Network. as the establishment of ‘sensitive activities’ near the Gas Transmission Network which may inhibit operations. With matters of discretion as follows:

a) The extent to which the building or structure New land use development on land containing, adjoining and near the Gas Transmission avoids or mitigates conflict with the Gas Network can be developed, provided the necessary requirements and considerations are Transmission Network, including construction related activities. taken into account. Larger scale urban development, often facilitated through subdivision, b) The extent to which the building or structure may provides greater opportunities for ‘designing-in’ the Gas Transmission Network. compromise, restrict or prevent legal or physical access to the Gas Transmission Network. c) Risks relating to health or public safety, including the risk of property damage. d) The potential for reverse sensitivity effects. e) Technical advice provided by the owner and operator of the Gas Transmission Network.

Planning Maps

Retention of the Gas Support with Firstgas supports the inclusion of the gas pipeline and gas transmission pipeline corridor Amend planning maps to include above ground infrastructure. Transmission Pipeline amendment on the planning maps and seeks that above ground assets, e.g. such as delivery points Corridor and amend to where high pressure gas to converted to low pressure, is also illustrated. The assets are include above ground assets sought to be captured by the rule framework and therefore are sought to be illustrated.

Co-ordinates of the Gas Transmission Network in its entirety can be provided on request.

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First Gas Limited 42 Connett Road West, Bell Block 22 November 2019 Private Bag 2020, New Plymouth, 4342 New Zealand

P +64 6 755 0861 F +64 6 759 6509

New Plymouth District Council Liardet Street Private Bag 2025 New Plymouth 4340

Dear New Plymouth District Planning Team,

Thank you for your letter dated the 24 September 2019 with reference 8128511 noting the current Designations First Gas in the Proposed District Plan.

I am writing to confirm that First Gas Limited wishes to roll over its Designations (FGL-1 and FGL-2) through the District Plan review process.

Please contact me if you require further information regarding this request.

Yours faithfully FIRST GAS LIMITED

Zane Wood Senior Land & Planning Advisor

DDI 06 769 8247 M 027 287 7248 [email protected]

3209049 © First Gas Limited Page 1 Uncontrolled copy when printed