Before the Independent Hearing Panel for Proposed New Plymouth District 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 New Zealand 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 Auckland. 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, Auckland Council, Kapiti Coast District Council, Selwyn District Council, Taupo District Council, Waitomo District Council and Christchurch City Council. Most recently I am assisting the Hearing Panel for the Proposed Waikato District Plan. I have appeared as an expert planning witness numerous times for infrastructure providers, including Wellington 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 2 Planning Hearing Evidence by Carolyn Wratt - Transpower NZ Ltd 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 3 Planning Hearing Evidence by Carolyn Wratt - Transpower NZ Ltd 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. 4 Planning Hearing Evidence by Carolyn Wratt - Transpower NZ Ltd 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. 5 Planning Hearing Evidence by Carolyn Wratt - Transpower NZ Ltd 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: