Before the Independent Hearing Panel for Proposed Plan

Under the Resource Management Act 1991

In the matter of the Proposed New Plymouth District Plan

And

In the matter of Submissions (S565) and Further Submissions (FS129) by Transpower Limited

STATEMENT OF EVIDENCE OF CAROLYN WRATT FOR HEARING 1 [PLANNING] 17 June 2021

1 Planning Hearing Evidence by Carolyn Wratt - Transpower NZ Ltd

1 INTRODUCTION

1.1 Qualifications and Experience

1 My full name is Carolyn Wratt.

2 I am a Principal Policy Planner and Director of the consultancy firm Wratt Resource Management Planning Ltd.

3 I hold the degrees of Bachelor of Science (Geography and Resource Management) (1997) and Masters of Science (Hons) in Coastal Geomorphology and Resource Management (1999), both from the University of . I am a full member of the New Zealand Planning Institute and an accredited Resource Management Commissioner under the Ministry for the Environment programme Making Good Decisions.

4 I have over 22 years experience in planning – both regulatory and policy, including working primarily for local and regional authorities around New Zealand. In my capacity as both a consultant and council planner, I have provided policy advice to a number of clients. Of most relevance I have assisted various councils with their district plan reviews including Hamilton City Council, , Council, Council, Council, District Council and City Council. Most recently I am assisting the Hearing Panel for the Proposed District Plan. I have appeared as an expert planning witness numerous times for infrastructure providers, including Water Ltd.

5 Specific to Transpower New Zealand Limited (‘Transpower’), I assisted with preparing the submissions and further submissions to the Proposed New Plymouth District Plan (PDP) and my evidence is given in support of those submissions.

6 I confirm that I have read the Code of Conduct for expert witnesses in the Environment Court Practice Note 2014 and that I have complied with it when preparing this evidence. Other than when I state that I am relying on the advice of another person, this evidence is within my area of expertise. I have not omitted to consider material facts known to me that might alter or detract from the opinions that I express.

7 My evidence covers all the submission points lodged by Transpower to the Strategic

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Directions chapter, and is covered by the following s42A reports:

(a) Strategic Direction - Historic and Cultural (Joanne Ritchie)

(b) Strategic Direction – Natural Environment (Rachelle McBeth)

(c) Strategic Direction – Urban Form and Development (Sarah Edwards, Louise Wai, Lauren O’Byrne, Louise Wai and Campbell Robinson)

1.2 Scope of Evidence

8 My evidence will address the following:

(a) The planning background for Transpower’s submission, and an outline of the need to provide sufficient recognition of the national significance of the National Grid, particularly in the context of the National Policy Statement on Electricity Transmission 2008 (“NPSET”);

(b) Key issues in the PDP in relation to relief sought by Transpower;

(c) My responses to the recommendations within the Section 42A Report on Transpower’s submission points; and

(d) Issues raised by other submitters relevant to the National Grid.

1.3 Summary of Evidence

9 Transpower owns and operates the National Grid, which transmits electricity throughout New Zealand from energy generation sources to distribution networks and direct-connect customers. Within the Taranaki Region, Transpower’s assets include a number of transmission lines and associated infrastructure such as substations which will be described by Ms Rebecca Eng in her corporate statement.

10 The need to operate, maintain, upgrade and develop the electricity transmission network is recognised as a matter of national significance through the National Policy Statement on Electricity Transmission 2008 (“NPSET”). This significance

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applies universally across the country regardless of the nature of the specific National Grid asset. There are three broad aspects to the NPSET which must be given effect to in local authority plans, as below.

10.1 Enabling the National Grid: Policies and plans must provide for the effective operation, maintenance, upgrading and development of the National Grid. This includes recognising the national benefits. In terms of its existing assets, Transpower undertakes a wide range of maintenance activities across its entire asset base. Typical maintenance activities include earthworks, vegetation trimming and clearance, and support structure maintenance activities.

10.2 Managing the effects of the National Grid: Policies, plans and decision makers must take in to account the characteristics of the National Grid, its technical and operational constraints, and the route, site and method selection process when considering the adverse effects of new National Grid infrastructure on the environment.

10.3 Managing the effects on the National Grid: A significant resource management issue in the district and across New Zealand is inappropriate development, land use and subdivision in close proximity to the National Grid, which can compromise its operation, maintenance, development and upgrade. Under the NPSET, policies and plans must include provisions to protect the National Grid from other activities. Specifically, the NPSET requires that district plans include a buffer corridor around National Grid lines within which “sensitive” activities should generally not be given resource consent and other activities that have the potential to compromise the National Grid or generate reverse sensitivity issues are managed. The three primary reasons for restricting activities within the buffer corridor are electrical risk; annoyance caused by transmission lines and reverse sensitivity; and restrictions on the ability for Transpower to access, maintain, upgrade and develop the lines, as well as compromising the assets themselves.

11 Transpower’s submission to the Strategic Directions sought specific refinements, as opposed to seeking wholesale changes. In particular, Transpower supported inclusion of provisions specific to the National Grid and enabling infrastructure.

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12 I have reviewed the s42A Report recommendations and focus on the areas where I do not agree with the recommendations. These can be summarised as:

(a) The status of objectives in the Strategic Directions chapter and the relationship of those with the objectives in other chapters;

(b) Enabling the National Grid and infrastructure in the Strategic Directions;

(c) Clarification as to what the heritage and cultural values in HC-1 are being protected from; and

(d) The use of rural resources in UFD-24.

13 Overall, I consider the provisions recommended in the s42A Report, as modified by my recommended changes, would give effect to the NPSET, RPS and NPS-UD. In my view, they provide an effective policy and regulatory framework in which to recognise and provide for the operation, maintenance, upgrade, and development of the National Grid and will enable efficient implementation of the PDP.

14 My evidence should be read together with the evidence of Ms Eng who addresses the nature of Transpower’s assets in the region.

2 HIGHER LEVEL PLANNING POLICY DOCUMENTS

2.1 National Policy Statements

15 National policy statements are at the top of the hierarchy of planning instruments under the RMA. Of particular relevance to the PDP and Transpower’s submission is the NPSET and the Resource Management (National Environmental Standards for Electricity Transmission Activities) Regulations 2009 (“NESETA”), the New Zealand Coastal Policy Statement 2010 (“NZCPS”), the National Policy Statement on Urban Development 2020 (“NPS-UD”), and to a lesser extent the National Policy Statement for Freshwater Management 2020 (“NPS-FM”). The NPSET does not appear to have been given effect to within the Strategic Directions, whereas the other NPSs appear to have driven the drafting, as is evidenced in some of the S42A rationale. It is not clear why the NPSET is not addressed in the Strategic Directions; a matter which I address later in this evidence.

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2.1.1 National Policy Statement Relationship

16 Developed at a national level, I understand all the national policy statements (“NPS’s”) sit at the top of the RMA plan hierarchy with no document having supremacy over the other. It is noted the NPS’s do not themselves stipulate or provide direction on the relationship or standing between the various NPS’s and on this basis and in the absence of any explicit direction, the council is then challenged in how to give effect to the multiple NPS’s. In my experience to date (in reconciling the NPSET and NZCPS) the relationship between the directives contained within the various NPS’s needs to be carefully assessed and a policy framework developed to address the tensions in such a way that gives effect to all the policy statements (where they are relevant). Key to reconciling the tensions is looking at the specific directives and their wording and providing a policy framework to guide decision makers.

17 An overview of the respective NPS’s and relevance to the NPSET is provided as follows:

2.1.2 The National Policy Statement on Electricity Transmission 2008

18 The NPSET directs the management of the electricity transmission network under the RMA. A copy of the NPSET is appended to my evidence as Appendix A.

19 Section 75(3) of the Resource Management Act (“RMA”) requires that a district plan must ‘give effect’ to the NPSET which is a strong statutory directive. Therefore, the NPSET must be implemented when drafting district policy and plan provisions and must be considered in making decisions on submissions, resource consent applications and designations.

20 The NPSET confirms the national significance of the National Grid and establishes a clear national policy direction that recognises the benefits of electricity transmission, the effects of and on the National Grid, and the need to appropriately manage activities and development under and in close proximity to it.

21 The Preamble to the NPSET includes useful background, or rationale, for the NPSET. It states that “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”. It notes that the National Grid has particular physical characteristics and

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operational/security requirements that have been challenging to manage under the RMA and acknowledges the potential significance of some effects of transmission lines (including the inability for these effects to be avoided or mitigated), along with the significant constraints that others’ activities and development can place on the network. It also notes that the adverse effects of the National Grid are experienced at a local level, while the benefits are primarily regional or national, requiring a balanced consideration of effects.

22 The NPSET is comprised of one objective and 14 policies, all of which address the environmental effects of transmission and the management of adverse effects on the National Grid. There are three broad aspects to the NPSET which must be given effect to in local authority policies and plans, as follows:

1. Enabling the National Grid: Policies and plans must provide for the effective operation, maintenance, upgrading and development of the National Grid. This includes recognising its national benefits.

2. Managing the effects of the National Grid: Policies, plans and decision makers must take in to account the characteristics of the National Grid, its technical and operational constraints, and the route, site and method selection process when considering the adverse effects of new National Grid infrastructure on the environment.

3. Managing the effects on the National Grid: Policies and plans must include provisions to protect the National Grid from other activities. The NPSET requires that district plans include a buffer corridor around National Grid lines within which “sensitive” activities including residential buildings, hospitals and schools will generally not be provided for in plans and/or be given resource consent.

23 The sole 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:

• Managing the adverse environmental effects of the network; and

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• Managing the adverse effects of other activities on the network.

24 This objective recognises that the electricity transmission network itself potentially gives rise to adverse effects, and, conversely, that other activities can potentially adversely affect the network.

25 The NPSET policies give direction on how to achieve the objective by providing for the recognition of the benefits of electricity transmission, as well as the management of the environmental effects of electricity transmission and the adverse effects of other activities on the transmission network. As such, the NPSET policies impose obligations on both decision-makers and Transpower itself.

26 Policy 1 specifies 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 and facilitating the use and development of new electricity generation, including renewable generation in the management of the effects of climate change.

27 Policies 2 to 9 relate to management of the environmental effects of electricity transmission. In particular, Policy 2 states:

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.

28 Policies 3 to 5 contain matters which decision-makers must consider, including technical and operational constraints, the route, site and method selection process, and operational requirements. Policy 6 seeks to reduce existing adverse effects where appropriate, while Policies 7 and 8 relate to effects on urban and rural environments respectively. Policy 9 specifically relates to health standards.

29 Policies 2 to 9 are particularly relevant to the PDP as they provide the policy framework for managing the environmental effects of electricity transmission in recognising and providing for the ongoing operation and development of the National Grid.

30 As outlined in the evidence of Ms Eng, Transpower is conscious that the anticipated decarbonisation of New Zealand’s economy is likely to ultimately require sustained

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investment in Transpower’s assets to connect to and reliably distribute new forms of electricity generation. In my opinion, it is important that, in context of the NPSET, the PDP provides an appropriate and enabling framework for the ongoing operation, maintenance, upgrading and, also importantly, the establishment of new National Grid assets. Such a framework would in my opinion, give due effect to the NPSET.

31 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, and act as the primary guide to inform how adverse effects on the National Grid are to be managed through planning provisions. The policies are directive in nature.

32 Policies 10 and 11 are therefore 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.

33 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 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).

2.1.3 New Zealand Coastal Policy Statement 2010

34 The statutory purpose of the NZCPS is to state objectives and policies “in order to achieve the purpose of [the RMA] in relation to the coastal environment of New Zealand”.

35 The policies in the NZCPS establish a comprehensive regime for managing the effects of activities on the coastal environment (noting the coastal marine area is not governed by the PDP). Policy 6 specifically addresses activities in the coastal

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environment, with some marine activities addressed more explicitly in Policies 8 and 9. Policy 7 addresses the need for a strategic planning approach. Policies 11, 13 and 15 address high value natural areas. Critically, those policies require adverse effects of activities on the ‘highest value’ natural areas to be avoided.

2.1.4 National Policy Statement on Urban Development 2020

36 Under the National Policy Statement on Urban Development 2020 (“NPS-UD”), New Plymouth District Council is identified as a Tier 2 local authority, and New Plymouth as a Tier 2 urban environment. Numerous actions will be required on the part of the council to give effect to the NPS-UD, many of which in my opinion are beyond the scope of this PDP process.

37 In terms of the relationship between the NPS-UD and the NPSET, consideration needs to be given to the explicit wording within the two NPS’s. While the NPS-UD provides a clear ‘enabling’ policy directive for intensification, the NPSET in my opinion provides a more directive policy framework through Policy 10 and 11 which require a buffer corridor to be provided within which sensitive activities will generally not be provided for (Policy 11), and to avoid reverse sensitivity effects on the National Grid network and ensure it is not compromised (Policy 10). These are strong directives. I further note the NPS-UD identifies the National Grid and the NPSET as ‘qualifying matters’ in relation to the Policy 3 NPS-UD directive, thereby recognising the national significance of the National Grid.

2.1.5 National Policy Statement for Freshwater Management 2020

38 The National Policy Statement for Freshwater Management 2020 (“NPSFM”) and National Environmental Standards for Freshwater Management 2020 (“NES Freshwater”) form part of a wider ‘Action for Healthy Waterways’ package. The one objective and 15 policies of the NPSFM form a clear policy directive to enhance water quality and the ecological health of water bodies. The relevance of the NPSFM and NES Freshwater to Transpower in the context of the PDP is limited to earthworks and vegetation clearance within proximity of a wetland. In my opinion, no direct conflict exists at a NPS level noting that the National Grid is afforded a discretionary activity status for such works under the NES Freshwater and, although it would be applied at a regional level, NPSFM Subpart 3 Specific Requirement 3.22 recognises the National Grid as an exception from the policy’s ‘avoid’ requirement.

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2.2 The Resource Management (National Environmental Standards for Electricity Transmission Activities) Regulations 2009

39 The NESETA addresses the objectives and policies of the NPSET, particularly the policies related to the existing transmission network, by providing a national framework of permissions and consent requirements for activities involving existing high voltage electricity transmission lines (but not substations). The relationship between the NESETA and the district plan is such that the NESETA prevails. However, for some activities (including earthworks and vegetation removal), the NESETA defers to the district plan provisions.

2.3 Taranaki Regional Policy Statement 2010

40 The Taranaki Regional Policy Statement (“RPS”) was made operative in 2010. Section 75(3)(c) of the RMA requires that a District Plan must give effect to any Regional Policy Statement. Relevant provisions from the RPS are attached as Appendix B, with brief commentary on these provisions provided in the following paragraphs.

41 The ENE objectives and policies seek to promote the transmission of energy to meet the energy supply needs of the region as well as New Zealand in a manner that avoids, remedies or mitigates adverse effects on the environment. ENE Policy 4 requires that provisions 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. The policies recognise that the National Grid involves structures of a significant scale and therefore there is a reduced ability to avoid, remedy or mitigate adverse effects. 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).

42 There is one INF objective which seeks to provide for the continued safe and efficient operation of the region’s network utilities and other infrastructure of regional or national significance while avoiding, remedying or mitigating adverse effects on the environment. This is achieved by the following policies:

INF POLICY 1

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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 lack of supporting infrastructure or to avoid unsustainable demands being placed on infrastructure to meet new growth.

3 TRANSPOWER RESPONSES TO THE S42A RECOMMENDATIONS

3.1 Hierarchy of objectives

43 Given the way the Strategic Directions chapter and submissions have been compartmentalised, I address the over-arching submission that is applicable to the Strategic Directions before addressing the more specific matters.

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44 Submission 565.39 sought to clarify the status of the objectives in the Strategic Directions and whether there is any primacy in the objectives. I have been working with the Ministry for the Environment and councils translating their district plans into the National Planning Standards, as well as with councils reviewing their district plans using the National Planning Standards. My understanding of the role of the Strategic Directions is to home matters which do not fall neatly into one of the other chapters, for example historic heritage, subdivision, residential zones etc, and instead are broader than a single zone or matter. The National Planning Standards describe the Strategic Direction chapter as comprising1:

(a) an outline of the key strategic or significant resource management matters for the district

(b) issues, if any, and objectives that address key strategic or significant matters for the district and guide decision making at a strategic level

45 The MfE guidance document explains that the Strategic Direction heading provides a location for the high-level direction that district councils are working towards for their city and/or district.2 With regards to the PDP, it is not clear how Council has interpreted the role of Strategic Directions, and whether they are objectives that:

(a) Trump all others due to their importance in the development of the District; or

(b) Do not fall neatly into one of the other chapters in the PDP because they cover multiple issues / zones.

46 For example, HC-2 relates to values of historic heritage and sites and areas of significance to Maori, whereas there are specific chapters for these matters (HH Historic Heritage and SASM Sites and Areas of Significance to Maori respectively). Similarly UFD-23 relates to primary production and rural industry, which could arguably be addressed in RPROZ Rural Production Zone. The PDP therefore does not seem clear on what the role of the objectives in the Strategic Directions is, and any primacy (if there is any), which will not be helpful for implementing the Plan. I note that the other recently notified proposed district plans have not really addressed

1 National Planning Standards 2019, Section 7(1) District-wide Matters Standard, 2 Guidance for District Plans Structure and Chapter Standards, Ministry for the Environment, April 2019, Page 6

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this matter either.

47 Thinking ahead to implementation, I consider it is necessary for the PDP to expressly clarify the status of the objectives contained in this chapter in relation to the objectives in all the other Plan chapters. There is the potential for a proposal to meet the objectives of a certain chapter, but fail to meet the objectives in the Strategic Direction chapter and it would be helpful for the PDP to clearly explain the relationship between the objectives in the Strategic Objectives chapter and the rest of the PDP chapters. I consider objectives are a statement of outcome so there should be no hierarchy. Section 32 of the Resource Management Act (“RMA”) requires an examination of the extent to which the objectives of the proposal being evaluated are the most appropriate way to achieve the purpose of this Act. There is no requirement to assess objectives against other objectives. I consider that all objectives in the Plan should have the same status and recommend a statement is included in the Plan clarifying this. Without such a statement, there will be confusion with implementation of the PDP. The current explanatory text does not clarify the situation:

It is intended that all other objectives and policies in the District Plan are to be read and achieved in a manner consistent with the strategic objectives.

48 I therefore recommend adding the following text at the start of the Strategic Directions chapter which clarifies the role of the Strategic Objectives as follows:

The objectives in the Strategic Directions chapter have the same status as all other objectives in the Plan, but provide guidance across the District.

3.2 Strategic directions for Infrastructure

49 Regardless of the uncertainty of the status and relationship of the objectives in the Plan, Transpower’s submission sought the inclusion of objectives in the Strategic direction related to the National Grid and infrastructure, and its further submission supported the amendments sought by Two Degrees (submission 569.22 and FS 129.27). I have approached this issue from an infrastructure perspective, rather than network utilities, given that all the language in the NPSs and the RPS refers to “infrastructure”. The s42A report author rejected these submissions on the basis that the Network Utilities and Transport chapters already address these issues and there is no need to address them at a Strategic Directions level. However, the authors

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also considered the PDP recognises this importance in Strategic Objectives UFD-13 and UFD-19, which suggests some conflict in their position. With respect I disagree with both of these statements. There are three national policy statements which directly address infrastructure in different ways:

a. National Policy Statement on Electricity Transmission;

b. National Policy Statement for Renewable Electricity Generation; and

c. National Policy Statement on Urban Development.

50 The NPSET confirms the national significance of the National Grid and establishes a clear national policy direction that recognises the benefits of electricity transmission, the effects of and on the National Grid, and the need to appropriately manage activities and development under and in close proximity to it. The NPSET makes it clear that the need to operate, maintain, develop and upgrade the electricity transmission network is a matter of national significance. This matter is not recognised in the Strategic Directions, nor the Network Utilities Chapter where the National Grid is primarily addressed.

51 I do not address the National Policy Statement for Electricity Generation as this is more relevant to other submitters who will undoubtedly cover it. One of the key requirements in the NPS-UD is the need for urban development to be integrated with infrastructure. While UFD-13(7) seeks to achieve cohesive, compact and structured development that utilises existing infrastructure and/or can be efficiently serviced with new infrastructure3 and UFD-19(7) seeks development is adequately serviced by infrastructure, there is no equivalent support at the strategic level which enables the provision of that infrastructure, particularly infrastructure of national significance. These infrastructure outcomes have a very local focus, and do not address the particular benefits of the National Grid that go beyond local to regional and national scales. This matter is not addressed in the objectives in the Network Utilities chapter either.

52 This concept is embedded in RPS INF Policy 1 which requires that provision will be made for the efficient and effective establishment of network utilities, and explicitly

3 Objective 6, National Policy Statement for Urban Development

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includes infrastructure of national importance.

53 As I have set out above, my experience with the objectives in the Strategic Directions chapter is that they are intended to address matters which span multiple zones, or multiple matters, and in my opinion the National Grid and infrastructure do both of these. If the Panel decide that the Plan does have a hierarchy of objectives, then the inclusion of these matters in the Strategic Directions becomes even more critical. Either way, I consider that infrastructure, and particularly that with national significance like the National Grid, needs to be addressed in the Strategic Directions chapter. The PDP Strategic Directions omit reference to the National Grid as a matter of key strategic or resource management significance for the district, and indeed infrastructure more generally. I consider amendments are needed to give effect to the NPSET, the NPS-UD and the RPS. For these reasons, I support the inclusion of the following objectives in the Strategic Directions chapter:

1. The social, economic, environmental and cultural benefits of infrastructure are recognised and provided for, and its safe, efficient and effective development, upgrade, maintenance and operation is enabled; [569.22, FS129.27]

2. The adverse effects of infrastructure on the environment are managed, having regard to the economic benefits and the technical, functional and operational needs of infrastructure. [569.22, FS129.27]

3. Avoid reverse sensitivity effects, particularly protecting the National Grid and infrastructure [565.40]

4. The significance of the National Grid is recognised, and sustainable, secure and efficient electricity transmission is provided through and within the District [565.38].

54 Recognising the importance of infrastructure is a District-wide issue and should be addressed as a Strategic Objective. Given the directives of the NPSET, NPS-UD and the RPS, I consider these objectives should be included as a minimum. Similarly, the management of reverse sensitivity effects on infrastructure is a District- wide issue and should be addressed as a Strategic Objective, and yet the proposed plan does not address reverse sensitivity in a whole-of-district way.

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55 Including specific references to the National Grid will give effect to NPSET Policies 10 and 11. The additions will also give effect to INF Objective 1 and INF Policy 2 in the RPS. In addition, there is clear direction in the RPS about reverse sensitivity with regards to network utilities including references to regionally significant infrastructure.4

56 There are options for the location of such objectives in the Strategic Directions chapter. While the Urban Form and Development sub chapter is one option, the objectives do not fit perfectly in this chapter as the National Grid and infrastructure is not necessarily constrained to the urban environment, albeit that the National Grid and infrastructure is needed to support urban development (as well as development beyond the district and region). I suggest that a new sub-chapter is created. I have looked at other proposed district plans that have notified recently under the National Planning Standards, and objectives enabling infrastructure are included in their Strategic Directions chapter under the following sub-headings:

(a) Functioning City (Proposed District Plan)

(b) Infrastructure, Risk, and Resilience (Proposed Selwyn District Plan)

57 I am attracted to the sub-heading “Integrated and Functioning District” as infrastructure is critical to an integrated and functioning District. This is distinct from the Urban Form and Development sub-chapter which is a mandatory requirement of the National Planning Standards, and which, in my opinion, should have a focus on urban environments.

3.3 Historic and Cultural

58 Transpower supported the amendments sought by Kainga Ora to HC-1 [563.140 and FS129.021] to include “social and cultural well-being” which I note has been recommended to be included by the s42A report author. Transpower also supported amendments to make it clear as to what the heritage and cultural values are to be protected from. Without this explanation included in the objective, the objective simply requires that heritage and cultural values are protected. This is a very inflexible outcome and would not enable good outcomes such as re-use and re- purposing of historic heritage buildings, or enable development where it is

4 INF Policy 2 and INF Policy 3,

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appropriate. I note that the HIS Objective 1 of the RPS states:

To protect the historic heritage values in the Taranaki region from inappropriate subdivision, use and development, and where practical enhance those values. [emphasis added]

59 While I can understand not wanting to duplicate verbatim the objectives and policies of the RPS, I consider that the amendments sought by Kainga Ora will more fully give effect to HIS Objective 1 of the RPS. For this reason, I support the following amendments to HC-1:

The district's heritage and cultural values contribute to the district's sense of place, and identity, social and cultural wellbeing, and are recognised and protected from inappropriate subdivision, use and development

3.4 Natural Environment

60 Transpower submitted in opposition to the submission from The Royal Forest and Bird Protection Society of New Zealand Incorporated (RFB) [487.34 and FS 129.22] due to the broad nature of its relief which was “Review strategic objectives to ensure consistency with Part 2 of the RMA”, and not knowing how this decision requested would manifest. However the second part of the submission from RFB sought the following changes:

For the purposes of preparing, changing, interpreting and implementing the District Plan all other objectives and policies in all other chapters of this District Plan are to be read and achieved in a manner consistent considered with these strategic objectives.

61 The s42A author rejected this change on the basis that the use of ‘consider’ (instead of ‘achieved’) weakens the intent of the strategic objectives and lacks guidance.5 I consider this issue is central to the hierarchy and role of the objectives in the Strategic Directions chapter. As outlined above, I support all objectives in the plan having an equal status and therefore support this amendment sought by RFB.

62 Transpower supported submission [487.32a] from RFB seeking changes to NE-5 to

5 Section 42A Strategic Direction – Natural Environment, Rachelle Lee McBeth, 4 June 2021, paragraph 60

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add “while avoiding, remedying or mitigating adverse effects on the environment”. Although this amendment was recommended to be rejected by the s42A report author, I agree with the addition of these words, and consider they more fully reflect the wording of s5 of the RMA.

63 I note that the s42A author has recommended substantial changes to NE-5. I have real concerns about the use of the word “restored” due to the considerable uncertainty as to the interpretation of “restore”. What moment in time should the environment be restored to? I do not understand how it can be given full effect to in either an urban setting or rural setting. The directive to “restore” would be unrealistic and challenging to achieve, particularly where development has substantially altered the character of the environment. It is wholly inappropriate for a resource consent application to seek to “restore” an environment or “to bring back to a previous, original, or normal condition”. This approach does not align with the RPS policy directive to “recognise the appropriate management of other natural areas, features or landscapes” in NFL Policy 2.

64 The amended NE-5 seems to attempt to combine a number of concepts, and the result is an objective which is not clear in the outcome it is seeking. It attempts to address:

a. A well-functioning natural environment;

b. Sustaining and restoring the natural environment;

c. Enabling people to provide for their social, economic and cultural well-being;

d. Present and into the future; and

e. Resilience to the effects of climate change

65 I would support a focused objective which is clear in its purpose as follows:

A well-functioning and resilient natural environment is sustained that provides for the social, economic and cultural well-being of communities and for the needs of future generations while avoiding, remedying or mitigating adverse effects on the environment.

19 Planning Hearing Evidence by Carolyn Wratt - Transpower NZ Ltd

66 The submissions from Department of Conservation [550.30] and RFB [487.33] sought inclusion of new strategic objectives to address various matters. Transpower opposed these submissions as it was not clear from the relief sought how the inclusion of these objectives would affect Council’s obligation to give effect to the NPSET. The s42A report was not clear in its recommendation as the author agreed with strengthening the PDPs’ strategic direction in respect of the natural environment values more generally, to ensure there is an appropriate balance struck between the strategic direction in the SD-UFD chapter which guides development, and those in the SD-NE chapter6. However only one new objective is proposed to the Strategic Directions chapter, being NE-NEW1. In the absence of any clear recommendation from the s42A report author, it is difficult to provide an expert opinion on the implications.

3.5 UFD-24

67 Transpower’s submission sought that objective UFD-24 be amended so that productive, versatile land and natural, physical and cultural resources located within rural areas that are of significance to the district are “used effectively”, rather than “protected and maintained”. I am aware that the Panel’s decision may be affected by the content of the imminent National Policy Statement for High Quality Soils, but I note that the s42A author has relied on the draft which has no legal status. In the absence of this document, I consider is not appropriate for productive, versatile land within rural areas to be protected. “Protection” implies that the productive, versatile land and natural, physical and cultural resources located within rural areas cannot be used, in which case there is no purpose in protecting them, as the value of these resources lies in what they can be used for. The objective as drafted fails to recognise that some activities such as infrastructure, which can be of a linear nature, requires/is best placed in a rural location. I am particularly aware of UDR objectives and policies in the RPS which envisages resource use:

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

6 Section 42A Strategic Direction – Natural Environment, Rachelle Lee McBeth, 4 June 2021, paragraph 85

20 Planning Hearing Evidence by Carolyn Wratt - Transpower NZ Ltd

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.

68 Upon closer inspection of UFD-24, I consider the objective could be split into two; with one focused on productive and versatile soils, and a second that more broadly addresses the natural, physical and cultural resources located within rural areas. I prefer the focus on “soils” rather than “land” as I consider it is the soils which have particular value.

69 I therefore recommend the following objectives:

UFD-24

Highly productive soils are retained for their productive values

UFD-NEW

The natural, physical and cultural resources located within rural areas that are of significance to the district are used effectively

70 In my consideration of the objectives in the Strategic Objectives Chapter, I noted that many of them are long and complex and attempt to include a number of different matters or concepts which will make them hard to assess future proposals against. Where the Panel have scope afforded by submissions, I support any amendments to make the objectives short, clear and concise statements of outcome.

71 The amendments I have outlined in this evidence will, in my opinion, ensure that the PDP gives appropriate effect to the national policy statements and RPS. The amendments I have discussed will result in establishing clear strategic objectives and a plan that is easy to implement.

Carolyn Wratt

18 June 2021

21 Planning Hearing Evidence by Carolyn Wratt - Transpower NZ Ltd

Appendix A – National Policy Statement on Electricity Transmission

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: i) maintained or improved security of supply of electricity; or ii) efficient transfer of energy through a reduction of transmission losses; or iii) 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 iv) 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 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.

Appendix B - Response to s42A Report Officer Recommendations

Sub Ref PDP Relief Sought in Transpower Submission s42A Report Response to s42A Report Reference Recommendation Recommendations FS 129.21 HC-1 Support Reject The amendments will make it clear as to Transpower supports the inclusion of inappropriate subdivision, use and what the heritage and cultural values are to development to make it clearer as to what the heritage and cultural values are to be protected from. Without this explanation be protected from. This wording more accurately reflects HIS Objective 1 in the included in the objective, the objective Taranaki Regional Policy Statement. simply requires that heritage and cultural values are protected.

I seek the following amendment: The district's heritage and cultural values contribute to the district's sense of place, and identity, social and cultural wellbeing, and are recognised and protected from inappropriate subdivision, use and development

FS 129.22 Strategic Oppose Accept in part I seek the following amendment: Directions Transpower opposes this submission point on the basis that the relief is broad and For the purposes of preparing, changing, there is insufficient information to understand the implications on the District Plan interpreting and implementing the District and whether it will give effect to the National Policy Statement on Electricity Plan all other objectives and policies in all Transmission other chapters of this District Plan are to be read and achieved in a manner consistent considered with these strategic objectives. I consider this issue is central to the hierarchy and role of the objectives in the Strategic Directions chapter. I support all objectives in the plan having an equal status and therefore support this amendment sought by RFB. FS 129.23 NE-5 Support Accept in part No changes are recommended by the Transpower supports the retention of strategic Objective NE-5 and the additional s42A. wording to reflect Section 5 of the Act.

FS 129.24 New Oppose submission from Department of Conservation Accept in part No changes are recommended by the strategic Transpower considers that “enhance” is beyond that directed by the Resource s42A. objective Management Act in Section 7(d) intrinsic values or ecosystems and Section 6(b) the protection of outstanding natural features and landscapes. In addition, Section 6 of the RMA does not necessarily direct protection, and instead is in relation to managing use, development and protection. FS 129.25 New Oppose submission from Royal Forest and Bird Accept in part No changes are recommended by the strategic Transpower is concerned that some of the Strategic Objectives proposed in the s42A. objectives relief do not give effect to the National Policy Statement for Electricity Transmission. 565.39 Strategic Add text to the Strategic Directions Chapter to clarify the role of the strategic Reject The PDP therefore does not seem clear on Directions objectives as follows: what the role of the objectives in the The Strategic Objectives have the same status as all other objectives in the Plan, Strategic Directions is, and any primacy (if but provide guidance across the District. there is any), which will not be helpful for implementing the Plan. I note that the other recently notified proposed district plans have not really addressed this matter either. Thinking ahead to implementation, I consider it is necessary for the PDP to expressly clarify the status of the objectives contained in this chapter in relation to the objectives in all the other Plan chapters. I seek the following addition: The objectives in the Strategic Directions chapter have the same status as all other objectives in the Plan, but provide guidance across the District.

FS 129.26 UFD-19 Support Accept The s42A only recommended minor This submission aligns with the National Policy Statement for Urban changes to the objective Development and ensuring the integration of landuses with infrastructure 565.42 UFD-24 UFD-24 Reject I consider is not appropriate for productive, Amend strategic objective UFD-24 as follows: versatile land within rural areas to be protected. “Protection” implies that the productive, versatile land and natural,

Productive, versatile land and natural, physical and cultural resources located physical and cultural resources located within rural areas that are of significance to the district are protected and within rural areas cannot be used, in which maintained used effectively case there is no purpose in protecting them, as the value of these resources lies in what they can be used for. I seek the following amendment: UFD-24 Highly productive soils are retained for their productive values UFD-NEW The natural, physical and cultural resources located within rural areas that are of significance to the district are used effectively 565.40 New New strategic objective Reject The management of reverse sensitivity strategic Add a new strategic objective as follows: effects on infrastructure is a District-wide objective UFD-X issue and should be addressed as a Strategic Objective, and yet the proposed Avoid reverse sensitivity effects, particularly protecting the National Grid and plan does not address reverse sensitivity in network utilities a whole-of-district way. I seek the following amendment: 3. Avoid reverse sensitivity effects, particularly protecting the National Grid and infrastructure [565.40] 565.41 Transpower New strategic objective Reject One of the key requirements in the NPS-UD Add a new strategic objective as follows: is the need for urban development to be UFD-X Network utilities and their benefits are recognised and provided for integrated with infrastructure. While UFD- 13(7) seeks to achieve cohesive, compact and structured development that utilises existing infrastructure and/or can be efficiently serviced with new infrastructure and UFD-19(7) seeks development is adequately serviced by infrastructure, there is no equivalent support at the strategic level which enables the provision of that

infrastructure, particularly infrastructure of national significance. I seek the following amendment 1. The social, economic, environmental and cultural benefits of infrastructure are recognised and provided for, and its safe, efficient and effective development, upgrade, maintenance and operation is enabled; [569.22, FS129.27]

FS 129.27 New Support Reject One of the key requirements in the NPS-UD strategic It is considered that the new strategic objectives give effect to the Taranaki is the need for urban development to be objectives Regional Policy Statement provisions regarding infrastructure and the National integrated with infrastructure. While UFD- Policy on Electricity Transmission. 13(7) seeks to achieve cohesive, compact and structured development that utilises existing infrastructure and/or can be efficiently serviced with new infrastructure and UFD-19(7) seeks development is adequately serviced by infrastructure, there is no equivalent support at the strategic level which enables the provision of that infrastructure, particularly infrastructure of national significance. I seek the following amendment 1. The social, economic, environmental and cultural benefits of infrastructure are recognised and provided for, and its safe, efficient and effective development, upgrade, maintenance and operation is enabled; [569.22, FS129.27] 2. The adverse effects of infrastructure on the environment are managed, having regard to the economic benefits and the technical, functional and operational needs of infrastructure. [569.22, FS129.27]

3. Avoid reverse sensitivity effects, particularly protecting the National Grid and infrastructure [565.40] 4. The significance of the National Grid is recognised, and sustainable, secure and efficient electricity transmission is provided through and within the District [565.38].

3.6 Appendix C – Relevant provisions from the Taranaki Regional Policy Statement 2010

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.

ENE POLICY 2 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: (a) energy requirements of urban form, subdivision patterns and site orientation; (b) the design, location and operation of buildings and other structures; … (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.

Territorial authorities may wish to consider the following methods: ENE METH 10 Include provisions in district plans that make appropriate provision for the exploration, development, production, transmission and distribution of energy.

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 lack of supporting infrastructure or to avoid unsustainable demands being placed on infrastructure to meet new growth.

INF METH 1 Maintain a regional plan or plans with objectives, policies and methods addressing adverse environmental effects on the safe and efficient operation of the region’s network utilities and on other infrastructure of regional significance

INF METH 5 Recognise the maintenance of existing infrastructure including the trimming and 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 6 Take into account 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 7 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 National Grid.

INF METH 8 Give effect to the New Zealand Code of Practice for Electrical Safe Distances (NZECP34:2001) prepared under the Electricity Act 1992, when establishing rules and considering applications for building structures and other activities near overhead electric lines support structures or conductors.

INF METH 9 Include in district plans, and conditions in resource consents, provisions or conditions 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 infrastructure, including the trimming and 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 12 Include in district plans, long-term council community plans and conditions of resource consents, provisions or conditions that require the location, intensity, structure, and staging of new land use generated by growth and development to support and coordinate with the sustainable provision and funding of local, regional and national roading and other infrastructure. This includes by way of financial contributions and/or development contributions.

INF METH 13

Include in district plans appropriate provisions requiring structure or concept plans for large scale urban land use changes.

INF METH 14 Include in district plans appropriate provisions requiring new land use to demonstrate how it will be serviced by transport and other infrastructure.

INF METH 15 Include provisions in district land transport programmes that promote the safety and efficiency of district roading infrastructure including promoting integrated land use and transport planning, travel demand management and the use of alternative transport modes.

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 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 National Grid.

INF METH 19 Give effect to the New Zealand Code of Practice for Electrical Safe Distances (NZECP34:2001) prepared under the Electricity Act 1992, when establishing rules and considering applications for building structures and other activities near overhead electric lines support structures or conductors.