BEFORE THE HEARINGS PANEL
Under the Resource Management Act 1991
In the matter of
The Proposed Kapiti Coast District Plan – Chapter 11 Infrastructure
And
Transpower New Zealand Limited (Submission 208 and Further Submission FS64)
Submitter
Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016
BARRISTERS AND SOLICITORS AJLBEATSON/ NJ GARVAN AUCKLANDLEVEL 22, VERO CENTRE,48 SHORTLAND STREET POBOX 4199, AUCKLAND 1140, DX CP20509, NEW ZEALAND TEL 64 9 916 8800 FAX 64 9 916 8801
Executive Summary
1. Transpower owns and operates the National Grid, which transmits electricity throughout New Zealand. There are five National Grid transmission lines in Kapiti,1 together with one substation. Current projects in the district include the Bunnythorpe – Haywards A & B Conductor Replacement Project, and the Mangahao – Paekakariki A & B Dismantling Project. This infrastructure plays a strategic role in New Zealand’s electricity transmission network.
2. The National Grid is critical to the social and economic wellbeing of Kapiti and our nation generally. It plays a fundamental role in our economy providing the necessary connection between generators and customers for the reliable operation of a $5 billion competitive wholesale electricity market to deliver electricity efficiently to consumers throughout New Zealand.
3. Transpower is also a ratepayer in the district and contributes $21,000 per annum in infrastructure rates subsidies (although this figure is likely to increase following the establishment of new infrastructure).
4. The National Grid assets in Kapiti are locally, regionally and nationally significant. The majority of the assets in this region were established and commissioned between 1924 (Mangahao - Paekakariki A&B 110 kV transmission line) and 1983 (Bunnythorpe - Wilton A 220 kV transmission line). The assets will endure for many decades, and possibly indefinitely, provided they can be properly maintained, and upgraded and developed as required.
5. Planning and developing an enduring National Grid requires prudent investment, long term transmission planning strategies such as corridors, and the application of new technologies. These factors, combined, will ensure the most can be made out of the existing infrastructure. In turn this will ensure long-term, durable outcomes for the National Grid in Kapiti and New Zealand.
1 The 110kV Mangahao – Paekakariki A and B Line is scheduled for removal by late 2016.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 1
6. Transpower wishes to see appropriate planning provisions included in the proposed Kapiti Coast District Plan (the Proposed Plan) to ensure that Transpower is able to operate, maintain, develop and upgrade the National Grid to enable a sustainable, secure and reliable supply of electricity nationally and to Kapiti. Transpower cannot rely on reactive controls intended to primarily manage safety (such as NZECP34:20001) and must respond proactively to the long term impacts of incompatible development near or under transmission lines.
7. There is the potential for adverse effects on, and from, the National Grid if development is not managed appropriately and in a considered way. These potential adverse effects include health and safety risks, reverse sensitivity effects, and constraints on the effective operation, maintenance, upgrading, and development of the National Grid. Transpower seeks that the potential for such effects is recognised and appropriately addressed in the Proposed Plan.
8. Corridors around the National Grid are necessary to:
a) Ensure the network can be efficiently operated, maintained, developed and upgraded by providing the working and access space to do this;
b) Ensure sensitive activities are generally not provided for in the area directly under lines;
c) Protect the safety of both the National Grid and people working or living close to it; and
d) Manage reverse sensitivity effects;
9. The relevant rules sought by Transpower are primarily to manage the impacts of incompatible activities near or under transmission lines, as well as to ensure safety and minimise the likelihood of interruptions to consumers from inappropriately managed activities near or under lines.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 2
10. There are significant economic constraints to undergrounding National Grid lines. I note that it would cost around $4-6B to underground the 2 400km of urban overhead lines (which are predominantly in Auckland). As a regulated monopoly, Transpower has no ability to pay these costs. Any line relocations or undergrounding to enable development would be at the developer's cost. However, I note that even when developers have the funds to pay, technical and operational considerations may preclude undergrounding as an option.
Introduction
11. My full name is Dougall James Campbell. I am the Environmental Policy and Planning Group Manager at Transpower New Zealand Limited (Transpower). My relevant experience, qualifications, and commitment to comply with the code of conduct are included in Appendix A of this evidence.
12. I confirm that I am authorised to give this evidence on behalf of Transpower.
13. I am familiar with the National Grid assets within Kapiti, namely, the 220kV Bunnythorpe – Haywards A and B lines, the Bunnythorpe – Wilton A Line, the designated lines D802 (which connect the Paraparaumu Substation to the Bunnythorpe – Haywards A Line and B lines), and the designated Paraparaumu Substation. I note that the former 110kV Paekakariki – Takapu Road A Line is no longer in existence and the 110kV Mangahao – Paekakariki A and B Lines are scheduled for removal by late 2016.
14. I have read the statement of evidence of Ms Pauline Whitney and have taken this into account when preparing this statement of evidence.
Scope of Evidence
15. My evidence will cover:
2 Undergrounding Transmission Lines in Urban Areas, Transpower, April 2013.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 3
(a) Transpower’s role;
(b) Transpower’s existing assets in Kapiti and their local, regional and national importance;
(c) Transpower’s projects in Kapiti;
(d) Effects of, and on, the National Grid, including earthworks, buildings and structures, sensitive activities, hazardous facilities, mobile plant, and subdivision;
(e) New Zealand Electrical Code of Practice for Electrical Safe Distances (NZECP34:2001);
(f) Transpower’s approach to Transmission Yards and Corridors;
(g) Economic constraints of undergrounding National Grid lines; and
(h) Conclusions.
Transpower’s role
16. Transpower is the State Owned Enterprise that plans, builds, maintains and operates New Zealand’s high voltage transmission network – the National Grid – which links generators to distribution companies and major industrial users. The National Grid comprises around 12,000 km of transmission lines and cables and some 167 substations. It extends from Maungatapere in the North Island to Tiwai in the South Island, transporting electricity throughout New Zealand.
17. New Zealand has become increasingly dependent on electricity. It is an intrinsic part of living and working in the 21st century. Electricity now accounts for about 26% of all energy used in New Zealand. Each year, $5 billion of electricity is traded on the wholesale electricity market.
18. Transpower's principal role is to ensure the reliable supply of electricity throughout the country. Transpower is not a generator of electricity and
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has no retail sales of electricity. It can be considered to be a 'freight company' for electricity, in that it transports bulk electricity from where it is generated by companies such as Meridian Energy and Mighty River Power to the local lines distribution companies which supply electricity to our homes, farms, communities and businesses. The Grid also directly supplies some major users of electricity (e.g. New Zealand Steel at Glenbrook and KiwiRail at Hamilton).
19. Transpower also manages New Zealand's power system in real time. In its role as System Operator, Transpower ensures electricity transmitted through the Grid is delivered whenever and wherever it is needed, 24 hours a day, seven days a week. The continued provision of National Grid infrastructure both within and throughout Kapiti is essential for keeping the lights on for homes, businesses, industries, schools, hospitals, and communities.
20. As a State Owned Enterprise, Transpower's principal objective is to operate as a successful business.3 It must operate within certain legislative constraints and report regularly to its shareholding Ministers. The transmission network is a natural monopoly. Transpower's investments in the National Grid and transmission charges are regulated by the Commerce Commission.
21. As noted in its statement of corporate intent, Transpower is required to deliver and operate a National Grid that meets the needs of users now and into the future.4 Prudent investment in the National Grid, long term transmission planning strategies, and developing technologies are crucial to ensure that the most can be made out of existing infrastructure. Managing development near or under transmission lines provides the necessary access to the Grid to allow required regular maintenance to be undertaken in a safe and efficient manner, and ensures a reliable and safe supply to consumers.
3 State-Owned Enterprises Act 1986, s 4. 4 Statement of Corporate Intent 2015/2016 https://www.transpower.co.nz/sites/default/files/publications/resources/transpower-sci-2012-13.pdf at 1.2.
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22. I have attached as Appendix B further detail illustrating the important role Transpower plays in helping deliver New Zealand’s and Kapiti’s social and economic goals.
Transpower’s existing assets in Kapiti and their local, regional and national importance
23. Transpower has the following existing 220kV National Grid assets within Kapiti:
(a) Bunnythorpe – Haywards A Line and B Line – single circuits on towers (BPE-HAY A and B Lines);
(b) Bunnythorpe – Wilton A Line – single circuit on towers (BPE-WIL A and B Lines); and
(c) Designated lines D802 (220kV single circuit lines connecting the Paraparaumu Substation to the Bunnythorpe – Haywards A Line and B lines).
24. The following Mangahao – Paekakariki A and B Line – single circuits predominantly on poles (MHO-PKK A and B Lines) also currently traverse Kapiti but are to be removed by late 2016 as a result of construction works associated with Transmission Gully.
25. There is only one National Grid substation within the district, being located on Valley Road, Paraparaumu. The substation is currently designated and identified in the Proposed Plan as D0801.
26. The Transpower assets supply a mixture of residential, rural and industrial loads in the southern Kapiti area at Paraparaumu, Raumati, Waikanae and Paekakariki. The load is predominantly urban with some light commercial demand, including a large number of retirement homes many with specialist care facilities. The major industrial loads are the Kapiti Coast District Council (sewage treatment), Paraparaumu Pak n'Save (supermarket), Unisys NZ Paraparaumu (data handling) and Paraparaumu hospital.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 6
27. A map showing these assets is attached as Appendix C to my evidence.
Transpower’s projects in Kapiti
28. I summarise the Grid Development projects that Transpower anticipates will be carried out in Kapiti over the next five years.
Bunnythorpe – Haywards A & B 220 kV Conductor Replacement Project
29. The existing conductor (the wire) on the Bunnythorpe – Haywards A and B transmission lines is almost 40 years old and requires replacement due to the accelerated wear on the conductor from the local coastal environment. The replacement conductor is slightly larger (about 3mm larger in diameter) and will provide better corrosion resistance, be more energy efficient and provide more capacity. The voltage of the lines will remain the same (220 kV).
30. Works on the project began in 2015 and are due to be completed in 2020. As well as the conductor replacement, enabling works such as foundation strengthening, tower strengthening, tower lifts, mid-span earthworks and some vegetation trimming/removal is required.
Mangahao – Paekakariki A and B 110 kV Dismantling Project
31. To enable the Transmission Gully Project, Transpower carried out upgrade works at its Paraparaumu Substation which were completed in early 2015. Subsequently Transpower’s Mangahao – Paekakariki A & B 110 kV transmission line was no longer needed. (This was also the situation with the former Paekakariki – Takapu Road 110 kV A transmission line which has already been dismantled). The dismantling of the line began in July and is due to be completed by December 2016.
Effects of, and on, the National Grid
Risks of transmission lines to people and property
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32. The main electrical hazard risk associated with high voltage transmission lines is receiving an electric shock. The risk and severity of electric shocks varies depending on the transmission voltage and type of exposure (e.g. direct human contact, mobile plant, or vegetation). Risks are most likely to be highest within 12 metres of a transmission line. However, some associated effects can be transferred further than this.
33. Lethal electric shocks can be caused by:
(a) earth potential rise;
(b) step and touch voltages;
(c) induction voltages;
(d) conductor drop;
(e) flashovers (coming into contact with the line conductors or where the electricity arcs from a conductor onto an object such as a structure or fence); and
(f) vegetation growing too close to a line and causing a flashover.
34. There are a number of other risks to people and property including damage due to fire and the risk of structure failure.
35. These hazards can occur as a result of third party activities (such as mobile plant or machinery) coming into contact with conductors, and excavations occurring too close to structures or mid-span thereby reducing clearance distances. All of these things can endanger safety and affect the operation of the Grid. I discuss these matters in further detail in Appendix D of my evidence and include photos of various events that have occurred causing injury to people and damage to property, and which have impacted significantly on electricity supply.
Earthworks
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36. Uncontrolled earthworks can undermine National Grid support structures or generate dust. This can result in the build-up of material on the National Grid lines and increase the wear on the equipment reducing its useable lifespan. Excavations or mounding mid-span can increase risks by reducing the clearance between the ground and conductors. Excavated areas or piles of earthworks soil can also restrict Transpower’s ability to access and locate the heavy machinery required to maintain support structures around the lines, and may lead to potential tower failure and significant constraints on the operation of the lines, such as power outages. For these reasons, Transpower seeks controls on earthworks near the National Grid.
37. Photograph 1 below shows earthworks that have occurred around a tower as part of development for a recent urban subdivision in Whitby, Porirua. The earthworks were well within 12m of the support structure.
Photo 1: Earthworks in Porirua, Wellington
38. As well as possibly undermining the stability of the tower structure, the earthworks in the photograph have also restricted vehicular access to the tower and the area where Transpower can place machinery
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required to maintain the tower. This compromises Transpower’s ability to maintain the existing transmission line.
39. Transpower worked with the developer to ensure that the constraints on the line introduced by the developer were mitigated and the long- term stability of the towers is retained. Such works are an example of how earthworks conducted close to the Grid can undermine Transpower’s ability to operate and maintain the network effectively and efficiently. Ultimately the manner in which Transpower carries out maintenance at this tower will need to change to address the effects.
Photo 2: Earthworks compliant with ECP34
40. The above photo illustrates earthworks that have been undertaken on a property that are technically compliant with NZECP34. It is considered that NZECP34 on its own does not give effect to the NPSET and Policy 10. As a result of the earthworks in the vicinity of the pole structure, Transpower’s ability to operate and maintain the network has been compromised. The batter slope may become unstable as a result of erosion and slipping. Access to the site is now severely restricted and there is no ability for Transpower to operate heavy plant on the elevated platform. On-going engineering checks will be required to monitor the effects of erosion and to check the stability of the foundations.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 10
Buildings and structures (including industrial and commercial operations)
41. People living or working in buildings under transmission lines also create significant difficulties when Transpower needs to do maintenance, upgrade and development work. A lot of work has to be done with the lines energised, which requires people to vacate buildings while the work is underway. Even when linesmen carry out work with the line de-energised (i.e. during a scheduled outage), there are risks to the people and property under the line. Replacing a conductor is the time when the risk of conductor drop is greatest.
42. In my opinion, buildings and structures, including intensive use buildings and industrial and commercial operations, should not be located in the 12m National Grid Yard, even if they comply with NZECP34. Buildings and structures pose a risk to the operation of the line, compromise Transpower's ability to maintain the line, and are a risk from electrical hazards. This includes buildings such as swimming facilities, dairy sheds, piggeries, poultry farms, commercial greenhouses, high level storage facilities, factories, industrial buildings of both a light and heavy nature, commercial operations that emit dense smoke, dust or chemicals and high density lifting operations involving forklifts, cranes, tip trucks and similar vehicles. These buildings and activities either are at greater risk of effects from the transmission lines, or put the line itself at greater risk.
43. One of the reasons why workplaces are unsuitable within the transmission corridor is the difficulty co-ordinating outages. Transpower works with landowners wherever possible, but outage planning is one area that is very difficult to schedule with absolute certainty. When there is clearance for an outage, and once the protective measures are completed (installation of hurdles and other safety measures), there may be only 3 hours to do the actual work before the power needs to be restored to the line again.
Sensitive activities and reverse sensitivity
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 11
44. Sometimes people who live near transmission lines are affected by their operation and on-going maintenance. Transmission lines can generate electrical discharge noise and electrical interference. Lines also have visual effects and perceived health and safety effects, although Transpower’s lines operate well within international standards on electric and magnetic fields.
45. From an engineering and risk management perspective, the longer the amount of time that a person is working or living close to high voltage electricity, the greater the risk of injury or damage to their property from a fault on the line (triggered by a lightning strike for example). Obviously, electrical interference could have serious implications for places such as hospitals or rest homes which rely on the proper functioning of electrical equipment 24 hours a day. Radio controlled and global positioning systems are known to be affected by the close proximity of transmission lines.
46. From a technical perspective, in my view, the area or distance from the lines within which complaints are most likely to occur, is the area to where the conductor swings out. For a 220kV line such as the BPE- HAY A and B Lines, this area is out to 37 metres either side of the centreline. As the distance from the phase conductor increases, nuisance effects such as noise and electrical interference are significantly diminished.
Hazardous facilities
47. Transmission lines can constrain new above ground hazardous facilities. There is the potential for unintentional ignition, issues relating to access and maintenance and the site must be designed so it is setback from the lines. While it is normal practice for new facilities handling flammable or combustibles to consider the location of existing site constraints, it is important from a risk management perspective for there to be a consenting requirement to ensure this occurs. The most obvious, and serious risk to manage (apart from direct contact) is
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failure from induced currents and voltages issues causing an ignition source, and therefore potential explosion of hazardous facilities.
48. There may also be above ground tanks directly under a line that are exposed to potential line fall event, even where they meet NZECP34. Other risks include electrical interactions between National Grid infrastructure and hazardous material infrastructure. These interactions include those from normal operation such as induced currents and voltages and those during faults or failure such as Earth Potential Rise (EPR). The impact of these interactions on above and below ground pipelines and tanks can include accelerated corrosion, transferred voltages, insulation/coating failure, and at worst failure.
49. In terms of underground hazardous facilities, under normal operation and if suitably identified, designed, and implemented there is limited risk of failure from induced current and voltage issues causing an ignition source, and therefore potential explosion of hazardous facilities. However, the limited risk does rely on these steps to be undertaken. For example, locating the underground tank breathers or LPG pressure relief vents in close proximity to the lines is not desirable from a possible explosion risk view if they could be located elsewhere. Likewise locating underground tanks directly under the lines without ensuring the correct earthing, coating and material selection significantly increases the risks associated with the tanks.
Mobile plant
50. Third party activities involving mobile plant or machinery such as straddle carriers, forklifts and cranes have the potential to reach up to, or above, the height of the conductors. It is essential that the use and location of this machinery is carefully considered.
51. The risks of incidents occurring will only increase if incompatible activities are intensified under or near lines. Controls such as constructing height barriers or safe forklift lanes under the line, the development of container storage plans that take account of conductor
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movement under wind and load, and on-going worker training to ensure the risks of working near live lines are understood, can be put in place to reduce the risk of incident. In a greenfield situation however there is the ability to eliminate this hazard by locating storage areas requiring the use of lifting mobile plant away from transmission lines.
52. For example, disruption to the National Grid was caused by inappropriate activity under a National Grid line when North Auckland and Northland experienced an outage in October 2009. This outage was the result of an intensive industrial/commercial activity operating under the line. The disruption was caused by a forklift carrying a container and hitting the 220kV transmission line between Otahuhu and Henderson. The incident significantly impacted power supply into Auckland and caused 280,000 customers to lose electricity, including the entire Far North District. It was lucky no one was killed. This also resulted in reverse sensitivity effects because Transpower had to raise a tower to prevent future similar incidents.
53. More recently, an incident occurred when a tractor carrying a crop auger on a local road hit the overhead High Voltage Direct Current (HVDC) line in Canterbury. The crop auger caught fire, and the HVDC line faulted a number of times. Again it was fortunate no one was injured. However, this incident, and others like it, are avoidable.
The need to regulate subdivision near transmission lines
54. The regulation of subdivision in the vicinity of the National Grid will enable Council to give effect to Policy 10 of the NPSET and to manage the potential effects of a subdivision on the operation/maintenance and upgrading of our network - including retaining an area for access to the network.
55. Subdivision within Kapiti should be regulated because:
(a) Transpower is not always recognised by councils or applicants as being affected by subdivision applications;
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(b) Transpower wants to avoid the creation of lots on which it would be difficult or impossible to construct a complying dwelling;
(c) The public has an expectation that at least one dwelling can be constructed on each legal title. The requirement to show a complying building platform is consistent with this;
(d) Subdivision can disrupt access to lines because it often precedes changes to land uses, including fences and driveways (which can prevent or facilitate access to land). This is the case even where buildings are more than 10-12m from a structure or 10-12m from the centreline of tower lines. By becoming involved in subdivision design, Transpower can ensure that its rights of access (secured under the Electricity Act) are protected;
(e) Transpower cannot rely on NZECP34 to protect the National Grid from the effects of subdivision, as it does not restrict the subdivision of land near lines, and it allows underbuilding;
(f) Subdivision also means Transpower will in the future need to manage its operations around a greater number of landowners and their activities. Appropriately designed development should result in less inconvenience for landowners; and
(g) Subdivision provides the framework for future land use, and is enduring. Integrated planning at the subdivision stage can avoid land use conflicts later. There is limited understanding of conductor movement by landowners and the public. The planning of building sites on subdivided land should take account of transmission line conductor swing early in the design phase so that an acceptable design solution is reached. Further, identification of a building platform at the subdivision stage provides the opportunity for Transpower and the Council to consider whether buildings can be sited so as to avoid reverse sensitivity effects arising from the visual, noise and other impacts of the National Grid (consistent with Policy 10 of the NPSET).
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56. Subdivision near the National Grid is regulated by councils around the country. For example, subdivision which fails to provide complying building platforms is non-complying in the Waimate District and the South Waikato District. Other councils with similar rural subdivision provisions include Central Otago District and Western Bay of Plenty.
New Zealand Electrical Code of Practice for Electrical Safe Distances (NZECP34)
57. NZECP34 is a mandatory safety code of practice developed under the Electricity Safety Regulations. NZECP34 seeks to protect persons, property, vehicles and mobile plant from harm or damage from electrical safety hazards by setting out minimum safe distances between conductors, and people, buildings and other structures. These distances differ depending on the voltage of the line, the length of the span between support structures, and the activity being undertaken adjacent or under the line. I provide further details about NZECP34 in Appendix E.
NZECP34 does not protect the integrity of the Grid
58. While NZECP34 may adequately provide for safe distances for smaller buildings and structures, the construction and location of new intensive development and buildings for sensitive activities may not always be sited in such a position that complements the operational or maintenance activities of the existing transmission line. Requiring consent for these intensive and sensitive activities gives Transpower the opportunity to provide advice on their construction, location and use.
59. NZECP34 does not address the other electrical safety hazards and the potential effects of the line on activities in close proximity to the line. NZECP34 does not prevent mid-span underbuild provided the minimum vertical clearances are not breached. This means even development (including underbuild) that complies with NZECP34 can constrain maintenance activities on lines, which can have consequential effects
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on safety and can result in increasing the number of people potentially at risk and exposed to adverse effects.
60. In other words, NZECP34 does not provide for all access, work space, step and touch hazards, and other matters I have discussed above where activities or infrastructure cause restrictions or create unsafe situations, especially during work activities on either Transpower’s assets or works by a member of the public under or near a line.
61. It is these effects that the NPSET requires be addressed in order to achieve sustainable management. NZECP34 is unable to address these effects, and it is perhaps not surprising therefore that NZECP34 is not referenced in the objective or any of the policies of the NPSET. Additional controls are required in the form of District Plan rules.
62. In addition, in Transpower’s experience, many people are unaware NZECP34 exists, let alone its minimum setback requirements. The document is also very technical and will often require engineering advice to interpret. While NZECP34 is a good base document for the determination of safe clearances, experience has found that the document is not well understood by the public or council staff. Even relatively sophisticated commercial entities often do not understand compliance requirements, let alone lay people.
63. NZECP34 does not provide an opportunity for the Ministry of Business, Innovation, and Employment (or Transpower) to be involved in consenting processes. At the consenting stage, unsafe or poorly designed developments can be screened and prevented. By comparison, Transpower only becomes aware of breaches of NZECP34 once developments are in place, when the cost of mitigating the associated risk is usually very high.
64. The transmission corridors sought by Transpower do not replace the requirement to comply with NZECP34 (as this is mandatory), although they do in some respects mirror and/or complement the requirements of that Code, and will raise awareness of it. This is an important step
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towards ensuring that the transmission lines can be safely and efficiently managed and operated, and that electrical safe distances are met. However, simply relying on NZECP34 would fail to give effect to Policy 10 of the NPSET.
Transpower’s approach to Transmission Yards and Corridors
65. In rural environments it is more likely that activities and development will occur that is compatible with transmission infrastructure. This is why, historically, Transpower located substations on the perimeter of population centres, away from settlements and intensive land uses. Overtime, through land rezoning and population growth, development has occurred around substations and lines and effects have occurred on neighbouring landowners, impacting Transpower’s operation and resulting in complaints to Transpower and requests to alter the way it operates the infrastructure.
66. Transpower does not oppose appropriate development around substations and near transmission lines but it is critical that this development occurs in an appropriate and safe way. This will ensure risks such as electricity shocks are minimised to the greatest extent possible, and will also ensure the infrastructure can continue to operate in the long-term, keeping the lights on for the community.
67. The National Policy Statement on Electricity Transmission (the NPSET) was implemented by the Government in 2008 to manage the operation, maintenance, development and upgrades required to maintain the Grid. Transpower recognises that in order to achieve this, it must recognise and take into account the special characteristics and adverse environmental effects the Grid may cause, as well as the adverse effects other activities may cause to it. The NPSET was implemented to assist with the management of these issues.
68. Ms Whitney’s evidence describes the NPSET, including the policies that address both the effects of activities carried out by Transpower,
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and the effects of other activities on National Grid lines. Policy 11 of the NPSET requires the identification of a “buffer corridor”.
69. Councils were required to implement the NPSET through appropriately recognising the National Grid in a District Plan by 10 April 2012. Transpower’s approach to implementing the NPSET across the country has been to require land use setbacks and subdivision rules and corridors to ensure the safe and sustainable management of the National Grid, third party activities, and landowner usage near the assets. These outcomes have been achieved through the on-going plan change processes undertaken by many district and city councils throughout New Zealand.
70. Transpower undertook a review of its provisions to give effect to the NPSET in 2012, and received various feedback from land users, interest group associations, Council officers and decision makers. Based on that feedback and our recognition of our stakeholder needs, Transpower now seeks, very much, a bare minimum approach. Our proposed corridors are the minimum areas we consider are able to achieve the majority of the issues we face. The proposed areas do not fully address such matters as amenity and reverse sensitivity.
71. Transpower acknowledges that beyond the minimum corridors sought councils may wish to impose additional controls.
72. The provisions Transpower seeks in Kapiti are generally consistent with provisions sought elsewhere around the country, including Waimate, Central Otago, Whangarei, and Western Bay of Plenty Districts. Hearings have recently been held in Southland and Invercargill Districts and decisions released. Both Councils have introduced rules to give effect to the NPSET which are beyond challenge.
Existing Overhead Transmission Lines
73. Transpower is seeking a National Grid Corridor for undesignated overhead transmission lines, to provide for:
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(a) A 12m corridor either side of the centreline, where specified activities are restricted (referred to as the National Grid Yard);
(b) A wider corridor out to 37m either side of the centreline for a 220kV line where subdivision is managed (referred to as the National Grid Corridor); and
(c) A 12m setback area around structures.
74. I discuss the reasons below why Transpower is seeking transmission corridors to apply to Kapiti.
75. Taking into account the safety risks, maintenance requirements and other matters I have discussed above, in my view, National Grid Yards and Corridors have the following important purposes:
(a) To ensure that sensitive activities such as residential development, schools, childcare and hospitals are generally not provided for near support structures and lines: Sensitive activities include the establishment of dwellings, schools and papakainga close to the Grid. The purpose of Policy 11 of the NPSET is to prevent sensitive activities such as these from being established near the National Grid.
(b) To enable safe and efficient access, maintenance and operations: National Grid Yards provide a relatively clear area for line workers to gain access a more efficient and safer access to the line and support structures for maintenance and operational requirements. A relatively clear corridor ensures that Transpower's ability to undertake some limited upgrading or developing of its lines is not compromised. National Grid Yards also limit the need for costly work-arounds (for example, bypass lines), when maintaining and operating the National Grid.
(c) To manage reverse sensitivity effects: Reverse sensitivity effects have significant cumulative potential which may lead to requests for constraints on existing National Grid lines. These effects
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occur when people undertake activities close to an existing line or structure. For example, National Grid lines can cause noise (especially in damp weather), reduced visual amenity, radio and television interference, perceived effects of electric and magnetic fields from the lines, and interference with landowners’ business activities beneath the lines. These effects often lead to requests by neighbouring land users to impose constraints on existing lines. These complaints and constraints are reverse sensitivity effects.
(d) To allow for any future potential upgrade requirements of the asset: For example, Transpower must be able to control “non- sensitive” large scale buildings and buildings that are intensively used (regardless of scale) under the lines, as these can inhibit upgrade activities. This reflects Policy 10 of the NPSET.
(e) To avoid safety hazards: Electricity transported at high voltages can cause serious, or even fatal, injuries to people who come close to lines. Structures and earthworks too close to a line can affect the stability of that line, and contribute to electricity outages. The presence of these structures can also increase the need for, and thereby risks associated with, mobile plant (e.g. container handling cranes) breaching safe electrical distances and coming into contact with lines.
(f) To provide the residential, rural, commercial and industrial electricity users in Kapiti with a reliable and secure supply of electricity: As outlined in Appendix B of this evidence.
(g) To protect the integrity of National Grid structures by reducing risks of damage to structures and their foundations: Structures and earthworks too close to a line can affect the stability of that line, and contribute to electricity outages. The presence of these structures can also increase the need for, and thereby the risk associated with, mobile plant (such as cranes and excavators) and other assets. Transpower wishes to ensure that safe
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 21
electrical distances are maintained so the risk of coming into contact with the lines is minimised.
(h) To protect the infrastructure corridor itself: As land uses become more intense, it is increasingly more difficult to identify routes for new assets. If a transmission line is compromised by encroaching land uses, it can sometimes be impossible to optimise the capability of existing lines (which defers the need to build new lines). If new lines are required, it can be difficult to identify an alternative route which would disrupt landowners less. Existing clear corridors are a finite resource, to be protected for the future. Giving proper effect to the NPSET will 'future-proof' the National Grid for the benefit of the Kapiti District.
(i) To alert landowners to the national importance of the National Grid and the restrictions it imposes on land use: The use of corridors allows people and property along the length of the lines to recognise both the scale and strategic nature of the resource. It also clearly indicates how they can manage their own activities.
(j) To provide the community, Council and Transpower with the knowledge and confidence that the lines are being managed in a safe and sustainable manner: To provide certainty as to how that management is being achieved within the NPSET framework.
76. Transpower values its relationship with councils, the community and landowners and endeavours to work with them to reach the best outcome for all parties concerned. Transpower works with councils around the country prior to, and after notification of proposed plans intended to give effect to the NPSET. Transpower continues to engage with councils once operative plan provisions are in place including involvement in the resource consent process.
77. Transpower seeks Proposed Plan provisions which will result in proactive dialogue between landowners, the Council, and Transpower to reduce the future occurrence of incompatible development under or
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 22
near transmission lines. Ms Whitney’s evidence outlines the specific provisions sought by Transpower in this regard.
Economic constraints of undergrounding National Grid lines
Undergrounding existing lines
78. From time to time, Transpower is requested to relocate or underground its assets to enable development. Relocating or changing the form of assets to enable development, can be at the request and funding of developers, the Council or road controlling authorities.
79. Recent examples of Transpower being requested to change the form of assets are:
(a) Highbrook - this involved the movement and undergrounding of high voltage infrastructure within the Highbrook industrial Development to the north-east of Otahuhu. Pragmatic early communication with the developer lead to integration of the National Grid into the development plans.
(a) Massey North town centre development - this involved the undergrounding 2km of the Albany to Henderson line to facilitate safe and cost effective development of land.
80. Transpower is also working through numerous requests to relocate its assets to enable roading projects in the Auckland Region. These requests include:
(a) The relocation of the OTA-PEN A 110kV transmission line in the Reeves Rd area. This relocation is to meet the requirements of the proposed Reeves Rd Flyover for the AMETI (Auckland – Manukau Eastern Transport Initiative) upgrade of the Panmure to Pakuranga Highway.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 23
(b) The relocation of tower 195 of the HLY-OTA A transmission line to enable Auckland Transport's proposed widening of Redoubt and Murphys Road in South Auckland.
(c) The relocation of the BOB-OTA A transmission line affected by the Southern Corridor widening of SH1 at the Takanini Interchange.
(d) The potential movement of a number of lines for the conceptual East-West link NZTA project.
(e) The relocation of the OTA-WKM A and OTA-WKM B transmission lines in the area of a new proposed housing development at Flat Bush.
81. While Transpower is willing to discuss and agree line moves with developers, it is essential that any such development activities are subject to appropriate controls that safeguard the National Grid infrastructure. For underground assets, a designation would be sought. Most National Grid line relocations would be consented under the Resource Management (National Environmental Standards for Electricity Transmission Activities) Regulations 2009.
82. Transpower would also not relocate its assets so that the conductors swung out over any buildings. In this regard, when moving its assets, including to enable another party’s development, Transpower would expect all buildings to be removed.
83. I note that it would cost around $4-6B to underground the 400km of 5 urban overhead lines (which are predominantly in Auckland). As a regulated monopoly, Transpower has no ability to pay these costs. Any line relocations or undergrounding to enable development would be at the developer's cost. Since 2000 developers (as the beneficiaries) have paid to underground lines at a cost of $40m. However, I note that
5 Undergrounding Transmission Lines in Urban Areas, Transpower, April 2013.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 24
even when developers have the funds to pay, technical and operational considerations may preclude undergrounding as an option.
84. Short cable sections can reduce the availability of an overall circuit, which may in turn require additional circuits to be installed earlier than would be necessary. Long sections of underground cable have a potentially detrimental effect on system reliability and security and are difficult and costly to repair.
85. The Commerce Committee, in response to a petition requesting that the House recommend to the Government that it commit to underground high-voltage transmission lines through urban areas, declined to recommend a national programme given the impracticability of undergrounding lines.6 While agreeing that underground cables are clearly aesthetically preferable, the Committee did not believe that a national programme to underground transmission lines is currently practicable because the cost is prohibitive.7 The Committee was satisfied that the evidence before it was sufficiently thorough, and drawing on this evidence noted that underground cables are seven to 10 times more expensive to install than overhead lines, and that some material components of undergrounding are significantly more expensive than their overhead counterparts.8 For example, underground cables cost $800 per metre, compared to overhead conductors which are $8 per metre.9
86. The Committee was also apprehensive about the underground lines’ lack of seismic reliability and slow maintenance and repair.10 Although underground lines are resilient to poor weather conditions, they are more susceptible to earthquakes and third-party damage, such as from
6 Commerce Committee “Petition 2011/95 of Carol Beaumont and 1,015 others, and Petition 2011/96 of David Holm and 1,801 others – Report of the Commerce Committee” (11 September 2015), page 4. 7 Commerce Committee “Petition 2011/95 of Carol Beaumont and 1,015 others, and Petition 2011/96 of David Holm and 1,801 others – Report of the Commerce Committee” (11 September 2015), page 4. 8 Commerce Committee “Petition 2011/95 of Carol Beaumont and 1,015 others, and Petition 2011/96 of David Holm and 1,801 others – Report of the Commerce Committee” (11 September 2015), pages 2 and 4. 9 Commerce Committee “Petition 2011/95 of Carol Beaumont and 1,015 others, and Petition 2011/96 of David Holm and 1,801 others – Report of the Commerce Committee” (11 September 2015), page 2. 10 Commerce Committee “Petition 2011/95 of Carol Beaumont and 1,015 others, and Petition 2011/96 of David Holm and 1,801 others – Report of the Commerce Committee” (11 September 2015), page 4.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 25
drilling.11 If underground cables do fail, it can take much longer to identify the precise spot of the fault and repair the problem (sometimes six to 12 weeks as opposed to two to three days for overhead lines).12 While underground cables improve visual amenity, the cable transition stations that link underground and overhead systems are unattractive and restrict above-ground developments.13 In relation to land use, underground lines often need clear corridors above them for maintenance and repair, similar in dimension to what overhead lines require.14
Undergrounding new lines
87. For new projects and works, Transpower has a policy of undergrounding any new lines required in urban areas. A recent example is the undergrounding of two circuits from Brownhill to Pakuranga as part of the North Island Grid Upgrade Project. The circuits were located primarily in road reserve and laid in trenches approximately one metre wide and two metres deep – one trench for each circuit. The trenches were then backfilled with special head conducting cement, before the road was resurfaced.
Conclusions
88. The National Grid is critical to the social and economic wellbeing of the Kapiti District and our nation generally. The NPSET requires that the National Grid be recognised in the Proposed Plan. It is imperative that Transpower is able to operate and maintain its transmission infrastructure in order to enable a sustainable, secure and reliable electricity supply. Preventing sensitive and incompatible activities from establishing under the transmission lines will assist the National Grid to
11 Commerce Committee “Petition 2011/95 of Carol Beaumont and 1,015 others, and Petition 2011/96 of David Holm and 1,801 others – Report of the Commerce Committee” (11 September 2015), page 2. 12 Commerce Committee “Petition 2011/95 of Carol Beaumont and 1,015 others, and Petition 2011/96 of David Holm and 1,801 others – Report of the Commerce Committee” (11 September 2015), pages 2 and 3. 13 Commerce Committee “Petition 2011/95 of Carol Beaumont and 1,015 others, and Petition 2011/96 of David Holm and 1,801 others – Report of the Commerce Committee” (11 September 2015), page 3. 14 Commerce Committee “Petition 2011/95 of Carol Beaumont and 1,015 others, and Petition 2011/96 of David Holm and 1,801 others – Report of the Commerce Committee” (11 September 2015), page 3.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 26
meet the needs of electricity consumers now and into the future, and do so in a manner that considers the environment and communities.
89. The National Grid corridors and associated provisions Transpower seeks in Kapiti are generally consistent with provisions sought elsewhere around the country, and have been carefully developed and reviewed following a range of site visits and consideration of the NPSET requirements.
Dougall Campbell 1 August 2016
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 27
APPENDIX A – RELEVANT EXPERIENCE AND QUALIFICATIONS
1. I am the Environmental Policy and Planning Group Manager at Transpower. My Group’s responsibilities include:
(a) Strategic planning. This planning is achieved through the development and implementation of Transpower’s Corridor Management Policy at a national level and local level;
(b) Delivering Transpower’s policy approach on environmental regulations, legislation and council planning documents;
(c) Ensuring the on-going and future protection of Transpower's network;
(d) Ensuring that all environmental approvals are obtained for Transpower’s physical works; and
(e) Managing third party interactions to ensure that Transpower’s interests are appropriately maintained.
2. I have been employed by Transpower for ten years, and during this time I have had experience working in various roles; including:
(a) As a Grid Programme Delivery Specialist. This role involved developing a lessons learned and continuous improvement strategy and process for Grid Projects;
(b) As the Environmental Planning and Stakeholder Manager on the Alliance Management Team of the Transpower Alliance. I was responsible for the environmental planning, strategy and policies, and processes to deliver and monitor all of the necessary environmental approvals for the 400kV capable overhead line section of the North Island Grid Upgrade Project (NIGUP). This is project traverses 185km from Whakamaru (North Taupo) to Brownhill Road (South Auckland);
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 28
(c) Carrying out stakeholder relationship responsibilities of the Transpower Alliance, ensuring that key stakeholders are informed, risks are identified and reputations are enhanced;
(d) As a Senior Environmental Planner/Environmental Project Manager for NIGUP. My responsibilities included developing strategy for consenting major projects, managing the environmental consortium appointed to deliver NIGUP, through to the final Notices of Requirement, managing the resource consent documentation and the Board of Inquiry process; and
(e) Providing planning advice to support the implementation of Transpower’s Grid Vision investigations and its System Integration investigations.
3. I have a Bachelor of Regional Planning Degree and a Diploma in Business Studies from Massey University. I have 19 years’ experience working as an environmental planner and I am a member (Grad Plus) of the New Zealand Planning Institute.
Code of Conduct
4. I confirm I have read the Code of Conduct for Expert Witnesses contained in the Environment Court Consolidated Practice Note 2014. As I am employed by Transpower, I acknowledge I am not independent; however I have sought to comply with the Code of Conduct. In particular, unless I state otherwise, this evidence is within my sphere of expertise and I have not omitted to consider material facts known to me that might alter or detract from the opinions I express.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 29
APPENDIX B – TRANSPOWER’S ROLE IN HELPING DELIVER NEW ZEALAND’S AND KAPITI’S SOCIAL AND ECONOMIC GOALS
Overview of New Zealand's Electricity System
5. Transpower is the State Owned Enterprise that plans, builds, maintains, owns and operates New Zealand's electricity transmission network - the National Grid. The National Grid, which extends from Maungatapere in the North Island down to the Tiwai Point Smelter in the South Island, is the physical infrastructure that transports electricity throughout New Zealand. It links generators to distribution companies and major industrial users throughout New Zealand.
6. The National Grid is critical infrastructure. To achieve these linkages, the National Grid comprises approximately 12,000 km of transmission lines and cables and 167 substations across the country. The National Grid is controlled by a telecommunications network with 300 telecommunication sites, which help link together the components that make up the National Grid. The National Grid is long and narrow linear infrastructure, reflecting New Zealand's topography. What happens at one point on the Grid can have consequences much further away, even in another region.
7. The National Grid comprises a high voltage backbone which runs the length of the country and links major generation (such as the geothermal power stations near Taupo) to major loads in large cities. The bulk of the backbone Grid was built around 60 years ago and comprises most of the 220 kV lines throughout New Zealand, along with the High Voltage Direct Current (HVDC) link between the North and South Islands.
8. Connected to this Grid backbone are regional Grid lines (also owned or operated by Transpower) which connect smaller generation stations and supply regional communities. The National Grid is an interlinked network. Electricity flows along transmission lines and varies in any instant, depending on actual generation at power stations and the
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 30
demand for electricity across New Zealand. As System Operator, in operating the electricity market, Transpower uses real-time information about electricity use by consumers and electricity generation available from generators to balance electricity demand and supply, ensuring optimum performance of the network.
9. A particular feature of the National Grid, and a key benefit for a sustainable New Zealand, is its ability to provide New Zealanders with access to renewable generation. Generally, renewable sources of generation are remote from the area of demand (i.e. from the electricity consumers). The National Grid provides connectivity between all sources of generation and consumers. The National Grid enables lower cost sources of electricity generation to be utilised and enables economies of scale in generation to be realised. It also lowers New Zealand's carbon emission liabilities. As such, the National Grid plays an important role in the sustainable management of natural and physical resources.
10. Many of New Zealand's larger population centres are located in the North Island, while a significant amount of hydro generation is located in the South Island. Power flow tends to be from south to north during normal rainfall years, delivering power from the hydro generation in the South Island to the North Island through the HVDC link, which also balances demand between the islands.
11. Most of New Zealand's population is located in regions where local generation is well short of the local demand – for example Northland, Auckland, Bay of Plenty, Hawke's Bay, Wellington, Marlborough, Nelson and the West Coast. Even those regions which produce surplus power have major population centres distant from the sources of electricity supply (e.g. Hamilton in Waikato, Christchurch in Canterbury, Dunedin in Otago and Invercargill in Southland). Therefore most of the country's power requirements must be transported some distance to the points of demand for residential and commercial use. Without the National Grid, consumers across New Zealand would be
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 31
dependent on locally generated electricity which would be more expensive and less reliable.
12. National Grid infrastructure is typically above ground, as it developed based on available technologies and the rights of acquisition for land for substations and line routes. High voltage underground networks were not constructed as the technology and economy at the time of construction did not support it. Even today, the economic comparison between underground and overhead line construction is between 12 and 18 times the cost on a per route kilometre basis.
13. However, since 2010, Transpower has installed a number of high voltage buried cables through built up areas of Auckland. The underground option was chosen at this time as the electricity system in Auckland was severely constrained and outages to enhance existing assets were not available without placing the security of supply to Auckland and to the north of Auckland at significant risk. The required new capacity was "new-build" and it was considered unlikely that consents would be obtained for a new overhead line (lattice towers) through urban Auckland, particularly as a route with a clear corridor would be unlikely to be identified.
14. Similarly, the historical development of Transpower's substations was based on internationally standard outdoor technology. Recently, indoor gas-insulated switchgear has become available, although it still carries a significant cost premium with little benefit of enhanced resilience. Transpower's recent substations have included both outdoor switchgear at the newly commissioned Pakuranga substation, and indoor Gas Insulated Switchgear (GIS) at the diversified Otahuhu substation. The decision to move to GIS was a deliberate decision made through the RMA process.
15. The National Grid substations form an exit point for the supply of electricity to the local lines distribution companies. The infrastructure of those companies such as 33kV feeder circuits (both underground and overhead) has also therefore been located in and developed around
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 32
the existing National Grid substations – constraints on the National Grid substations will have a major flow on effect to the local distribution of electricity.
16. Transpower's 2016 publication Transmission Tomorrow sets out Transpower's strategy for the future development of the Grid for the next 30 years and beyond.15 Transmission Tomorrow confirms Transpower's view that there is an enduring role for the National Grid. Transpower's lines and substations will be required for many years into the future to power the economy while enabling New Zealand's continued reliance on renewable forms of electricity generation, including from the power stations along the Waikato River, and the new geothermal stations commissioned near Taupo.
17. The assets in the National Grid are an extensive, linear, and connected system of lines and substations. Therefore, activities or changes on one part of the system can affect other parts. The National Grid operates in a regional or national scale in terms of the location of assets and the distances over which electricity is transmitted.
18. In terms of a brief summary, the National Grid:
(a) transports electricity across the country (connecting generation to consumers);
(b) supports New Zealand's national and regional economic growth;
(c) plays an essential role in maintaining reliability and security of supply of energy;
(d) provides a basis for investment decisions to be made by both suppliers and consumers of electricity;
(e) enables competition among suppliers and retailers of electricity, thereby providing the basis for reduction in electricity prices; and
15 A copy of Transmission Tomorrow is available at https://www.transpower.co.nz/resources/transmission- tomorrow
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 33
(f) assists the development of new electricity generation technologies, including renewable energy, by providing access to markets.
19. The National Grid has operational requirements and engineering constraints that both dictate and constrain the way it is managed. The operational requirements relating to the Grid are set out in various legislation, rules and regulations governing the National Grid, including the Electricity Act 1992 and the Electricity Industry Participation Code. I understand that the National Policy Statement on Electricity Transmission recognises the technical, operational and security requirements associated with the transmission network, and that these can limit the extent to which it is feasible to avoid or mitigate all adverse environmental effects of the National Grid.16
The economic significance of the National Grid
20. Transpower plays a fundamental part in New Zealand's economy. Transpower's principal role is to ensure the reliable supply of electricity throughout the country. Through its statement of corporate intent Transpower is required to deliver and operate a National Grid that meets the needs of users now and into the future.
National Electricity Supply
21. On-going investment in the National Grid is expected to be required to meet the demand for electricity and to meet the Government's objective for a renewable energy future. Therefore strategic planning to provide for National Grid infrastructure is required.
22. The supply of electricity is essential to the economic and social wellbeing of all New Zealand residents and businesses. It provides essential services such as light and heating to homes as well as meeting some emergency needs. Most businesses are reliant on electricity for aspects of their operation and therefore the supply of
16 See, for example, the Preamble, 4th bullet point; and Policy 3.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 34
electricity is essential for employment and economic prosperity at the national, regional and local levels.
23. The NPSET Evaluation under s 32 of the RMA stated:17
Demand for electricity is increasing with population growth, rising incomes and new technology powered by electricity. The combination of growing demand and the need to provide electricity in environmentally sustainable ways gives increased importance to the improvement, upgrade and extension of the New Zealand electricity transmission network, or national grid.
24. Nearly two million New Zealand households and businesses purchase more than $6 billion of electricity annually. Of these, approximately:
(f) 1.7 million or 86% are residential consumers;
(g) 160,000 or 8% are commercial consumers;
(h) 75,000 or 4% are rural18 consumers; and
(i) 40,000 or 2% are industrial consumers.
25. About 34% of the total electricity consumed in New Zealand is purchased by residential consumers, 36% by industrial consumers, 25% by commercial consumers and 5% by rural consumers.19
26. Growth in national electricity demand is expected to average 1.2% per annum over the next 15 years (2014-2029).20
27. The value of Transpower's property, plant and equipment is listed in its 2013/14 financial accounts as $4,451.3 million, whilst capital work in progress in 2012/13 was valued at $165.3 million.
17 National Policy Statement on Electricity Transmission, Evaluation under s 32 of the Resource Management Act; Ministry for the Environment; March 2008; (Executive Summary, page 10). 18 Agricultural, forestry and fishing. 19 Electricity Authority: http://www.ea.govt.nz/consumer/industry-overview/; 5 September, 2013. 20 2014 Annual Planning Report Incorporating the Grid Reliability Report and the Grid Economic Investment Report; Transpower New Zealand Limited; March 2014.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 35
28. Transpower estimates that around $1.5 billion of direct expenditure will be required over the next 5 years maintaining and operating the National Grid.21 This work will be facilitated by the protection of areas surrounding existing lines and support structures. Enabling Transpower’s existing lines to be used to their peak efficiency (unconstrained by other surrounding land uses) will minimise the need for new lines (or at least defer that need).]
29. Transpower primarily recovers its transmission costs via line company charges as it only directly supplies a small number of the country's major electricity consumers (e.g. the Tiwai Point aluminium smelter, the Kinleith Mill, the Glenbrook Steel Mill and KiwiRail).
30. Whilst the National Grid is important for all businesses and households, it is especially significant for large consumers who provide essential services (e.g. hospitals, ports and airports), and those that are the key drivers of employment, incomes and economic activity at the local, regional and national level (e.g. farms, manufacturing plants and retail centres). Interruption of supply to those users can have significant impacts on their activities.
31. The national, regional and local level economic benefits of the National Grid are significant, and Transpower's proposed approach to implementing the NPSET (designed to facilitate the efficient inspection, operation, maintenance, development and upgrade of the National Grid) will assist with the continuation of those benefits.
21 See Table 5.7, Page 83 of Setting Transpower’s Individual Price-Quality Path for 2015-2020. Commerce Commission; 29 August, 2014.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 36
APPENDIX C – MAP OF TRANSPOWER’S ASSETS IN KAPITI
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 37
B Manakau - E E T - M R P
-A E E -T Otaki M R Paraparaumu P
B - Y A A - H - Y E A B P H - - K B E K P P -A - B K O K H -P M O H M
A - IL W 1 - E P Waikanae B
Paraparaumu d x m . P 3
A Raumati _ Paraparaumu C D C K _ s t e s s A _ P T _ 8 3 0 6 1 p \ S D
X Legend M \ s p a Substation M t e s
s Paekakariki
A Transmission Line _ Z N
P by Voltage T _ l a n 110 kV Transmission Line o i g e
R 220 kV Transmission Line t c i r t s i External Disclaimer Major Road D
_ This document is produced for external release. Its conclusions are based 8
3 on the information currently available to Transpower and may change
0 District Boundary
6 as further information becomes available either internally or externally. 1 p \ s t c e j o r
P COPYRIGHT © 2016 TRANSPOWER NEW ZEALAND LIMITED. ALL RIGHTS RESERVED S I This document is protected by copyright vested in Transpower New Zealand Limited ("Transpower"). No part G
\ Transpower Assets l of the document may be reproduced or transmitted in any form by any means including, without limitation, a i electronic, photocopying, recording or otherwise, without the prior written permission of Transpower. No t a information embodied in the documents which is not already in the public domain shall be communicated in any p Prepared by: Geospatial & Drawings Kapiti Coast District Council S manner whatsoever to any third party without the prior written consent of Transpower. Any breach of the above \ : I
obligations may be restrained by legal proceedings seeking remedies including injunctions, damages and costs. : 0 5 10 Km h t a Projection: NZTM 2000 Scale: 1:150,000 Plan Size: A3L Date: 27/07/2016 Drawn by: aldrichh P B Manakau - E E T - M R P
-A E E -T Otaki M R P Paraparaumu B - Y A A - H - Y E A P H - B E P B
A - IL W 1 - E P Waikanae B d x m . P 3 A d e v o m e R _ s e n i L
_ Paraparaumu K K P _ O H
M Raumati _ Paraparaumu C D C K _ s t e s s A _ P T _ 8 3 0 6 1 p \ S D X M \ s p
a Legend M t e s s Paekakariki Substation A _ Z
N Transmission Line P T _ l a n by Voltage o i g e
R 220 kV Transmission Line t c i r t s i External Disclaimer Major Road D
_ This document is produced for external release. Its conclusions are based 8
3 on the information currently available to Transpower and may change
0 District Boundary
6 as further information becomes available either internally or externally. 1 p \ s t c e j o r
P COPYRIGHT © 2016 TRANSPOWER NEW ZEALAND LIMITED. ALL RIGHTS RESERVED S I This document is protected by copyright vested in Transpower New Zealand Limited ("Transpower"). No part G
\ Transpower Assets (after MHO-PKK-A & B lines removal) l of the document may be reproduced or transmitted in any form by any means including, without limitation, a i electronic, photocopying, recording or otherwise, without the prior written permission of Transpower. No t a information embodied in the documents which is not already in the public domain shall be communicated in any p Prepared by: Geospatial & Drawings Kapiti Coast District Council S manner whatsoever to any third party without the prior written consent of Transpower. Any breach of the above \ : I
obligations may be restrained by legal proceedings seeking remedies including injunctions, damages and costs. : 0 5 10 Km h t a Projection: NZTM 2000 Scale: 1:150,000 Plan Size: A3L Date: 27/07/2016 Drawn by: aldrichh P
APPENDIX D – RISKS ASSOCIATED WITH NATIONAL GRID TRANSMISSION LINES
Earth potential rise
1. Earth potential rise (EPR) is usually caused by an earth fault at a tower or pole. An earth fault occurs when an energised conductor comes into contact with, or flashes over to, the tower, pole, or any earthed object. This can occur through an insulation failure as a result of lightning, pollution or foreign objects.
2. During an earth fault, there is a significant current (2-20 times normal) flowing in the faulted line from the power source into the fault point. These fault currents are highest either near the electricity source (generator) or substation as the current returns through the ground. The return current causes momentarily high voltages to appear on both the tower and the ground around the base of the tower. The voltages are highest on the faulted tower or pole and decrease on the ground as you move further away from the faulted tower. In other words, the risks of EPR lessen with distance from the support structures. Voltages can appear on any conductive object on the ground (such as a fence) that bridges the voltage contours. The earth fault current causes EPR around the faulted tower, which in turn results in step and touch voltage hazards and transferred voltage hazards as discussed below.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 38
Photo 3: Fence and surrounding area affected by Earth Potential Rise, near Geraldine, South Canterbury
Step and touch voltages
3. Step and touch voltages can arise due to a fault at a tower or pole and, as explained above, momentarily raise the voltage at the tower or pole base and the surrounding ground. A step voltage hazard can occur when a step is taken in this area, or a person or animal is in contact with the tower or pole and standing on the ground, thus causing a voltage difference between the feet or between the feet and hands. Where conductive buildings, structures or fences, for example, are located close to the tower or pole, high current and voltage may transfer from the tower or pole, via the ground and travel some distance down these structures causing an electrical hazard some distance from the faulted tower or pole and causing the same effect.
Induction voltages
4. Induction voltages can cause irritation to a person or animal and nuisance from conductive materials such as fences, wires or large industrial buildings. Induction is caused through a magnetic coupling
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 39
between the conductors and any metallic wires or fences installed over longer distances, generally those running parallel to the circuit itself. People may experience inductive shocks between the metallic wires and ground.
5. Induction voltages can also be caused through a magnetic coupling between the conductors and inadequately earthed large metallic structures such as dairy sheds and barns. Submitters to the North Island Grid Upgrade Project (NIGUP) Board of Inquiry said that stray voltages led to loss of milk production and stress to animals and staff in dairy sheds in close proximity to the proposed line. Transpower mitigated these concerns on NIGUP by moving existing buildings away from the proposed line.
Conductor drop
6. The conductor can drop to the ground should a mechanical failure occur to the support structures, supporting insulators and hardware, or the failure of pressed mid-span joints. In addition, electrical failure can lead to the mechanical failure of the conductor or the pressed mid-span joints.
7. While it is rare for a support structure, conductor, or the conductor hardware to fail causing the conductor to drop to the ground, it can happen. Historically, the majority of line drops have occurred in rural areas, but there have been rare occasions where a line drop has occurred in an urban setting (where the generally more intensive and sensitive development places more people and property at risk). When a line drop does occur, the consequences can be fairly wide ranging for activities under the line. The photo below shows impacts within a dwelling, following a line drop. The internal electrical switchboard and appliances have been damaged by the significant transfer of voltages to earth from an adjacent transmission line.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 40
Photo 4: Electrical damage inside a house following a conductor drop
Photo 5: A conductor drop
8. As well as the electrical aspect of a conductor drop, there is also a mechanical aspect of a large load dropping. Conductors on a typical duplex 220kV line weigh approximately 3.0kg/m, therefore for a typical span the weight of the conductor at the point of impact could be as high as 750kg. 19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 41
Flashovers
9. A flashover is a major electrical discharge, usually in the form of an electric arc, which leaps or arcs from the conductor across the insulator string to the tower (or from the conductor to another object) resulting in a short circuit. Flashovers can occur from lightning strike, contamination of the insulator or when a person/object is too close to, or comes into contact with, the conductors.
10. Third party activities involving mobile plant or machinery such as excavators, hi-abs and cranes have the potential to reach up to, or above, the height of the conductors. It is essential that the use and location of this machinery is carefully considered to avoid contact with the conductor. Coming into close proximity to a live conductor and causing a flashover (i.e. the flashover will occur prior to contact) can:
(a) compromise the safety of the machinery operators or workers or members of the public in or near the machinery and result in electric shock;
(b) damage the machinery or the line itself; and
(c) affect the operation of the Grid and the security of supply.
11. I am aware of a number of incidents where machinery has caused a flashover between equipment and a conductor.
12. A shipping container being carried by a forklift came close to a 220kV line in the Onehunga area disrupting supply to North Auckland and Northland. It was extremely lucky that no one was killed or injured in this incident. The photos below show the forklift, the flat tyre sustained in the incident, and the damage done to the conductor. I note that since the incident that the new operator has significantly altered operations to eliminate the risk of container handling operations coming into contact with the lines, as shown in Photo 13 below. While I am comfortable with the efforts taken by the operator it would have been
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 42
preferable for the port to have been designed with appropriate setbacks from the line from the outset.
Photo 6: Forklift
Photo 7: Flat tyre sustained in the incident
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 43
Photo 8: Damage to conductor
Photo 9: Reconfigured Onehunga Inland Port
13. More recently, an incident occurred when a tractor carrying a crop auger on a local road hit the overhead HVDC line in Canterbury. The crop auger caught fire, and the HVDC line faulted a number of times. Again it was lucky no fatality occurred, but the incident caused operational issues for Transpower in our role as the System Operator controlling the voltage of the National Grid, and could have been avoided.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 44
Photo 10: Crop auger hitting an overhead line
Photo 11: Tractor carrying auger
14. A similar incident occurred several years ago where a fatality occurred after an auger hit an 110kV line over pasture land.
15. In 2013 a tip truck was spreading gravel on a life style block close to Hamilton when a flashover occurred to a 110kV line.
16. The risks of incidents such as these occurring increases if incompatible activities are intensified under or near lines.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 45
Vegetation
17. As explained in Appendix B above, the conductor (wire) sag (amount of droop) changes as it heats up with high electrical load (current). This change in sag impacts clearances to the ground, under-built structures and vegetation. This change in sag, and therefore clearance, is not visibly noticeable or well understood by the public, as the maximum loading conditions occur infrequently.
18. Trees growing close to a line, and which cause a flashover from the conductor to the tree, may cause:
(a) a circuit fault that affects the operation and supply of the Grid;
(b) injury or death to anyone who may be near the tree at the time of the fault; or
(c) damage to the tree, land or property.
19. I understand that vegetation clearances are not part of Transpower's request for a transmission corridor, however the effects of failing to comply with clearly specified vegetation growth distances provides a similar context to that of buildings or other activities.
20. If a tree touches or comes close to touching the high voltage conductors and causes a flashover, dangerous voltages may arise on the tree itself or in the ground area around the tree. These voltages have the potential to cause serious injury or death. Flashover to a tree where high voltages are involved can cause the tree to ignite and cause a wider fire hazard if the tree is near buildings or forests.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 46
Photo 12: Tree damage from fire caused by flash-over
21. It is therefore vital that trees and all other vegetation are trimmed or cut to ensure they do not encroach into a "Growth Limit Zone" around the conductors under all situations (i.e., taking into account the effect of wind on the conductors and trees, and the sag and swing of the conductors under various ambient temperatures and load). For voltages of 110kV and higher, the tree "Growth Limit Zone" is 4 metres from the conductors under worst case conditions.22 In practice, the regulations empower Transpower to give notice to trim a tree once it reaches a distance of 5m from the conductors.
22 Electricity (Hazards from Trees) Regulations 2003, Schedule 1, Table 1.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 47
Photo 13: Definition of Growth Limit Zone
Other hazards
22. Other hazards and issues associated with transmission infrastructure include equipment or structure failure, earthworks, electrical and wind noise, and the perceived effects of EMF.
Equipment or structure failure
23. Transmission lines, similar to buildings, are designed to withstand specified levels of climatic conditions (e.g. wind speed, snow thickness). If these levels are exceeded, it is likely that failure will occur. Failure events include broken or fallen conductors, collapsed towers (see the photo above) or any other substantial component failure which results in high risk of property damage or injury and electricity disruption. Transpower sets high design criteria for its infrastructure given the importance of supply to the country. Although the probability of a failure event is low, there is the possibility that injury or damage could occur if a person, animal or item of equipment is in the wrong place at the wrong time.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 48
Photo 14: Failed tower on the Benmore-Haywards A line
Electrical noise
24. Noise from a transmission line usually comes in two forms: mechanical noise and electrical noise:
(a) Mechanical noise can come from vibration which causes a rattle of the line hardware (insulator attachments, steel members) or from environmental events such as high winds (wind whistling through conductors or over steel works).
(b) Electrical noise usually comes from some form of electrical discharge, or leakage. This generally can be heard discharging down insulators when it starts raining after a long spell of fine weather. In some cases this corona discharge may be seen at
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 49
night when insulators are polluted and electricity is seen discharging down from the conductor to the tower steel.
Electric magnetic fields
25. In some areas of New Zealand, landowners/occupiers have raised concerns about electric and magnetic fields (EMF) from transmission lines. I note that Transpower's assets operate well within the limits in the International Commission on Non-ionising Radiation Protection Guidelines for limiting exposure to time varying electric magnetic fields(1Hz – 100kHz) (Health Physics, 2010, 99(6): 818-836 (known as the ICNIRP Guidelines)). These Guidelines are recognised by the Ministry of Health and the World Health Organisation.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 50
APPENDIX E – SUMMARY OF NZECP34
32. The tables within NZECP34 are firstly based on generic and conservative span length envelopes. More detailed calculations can be undertaken to remove the conservatism. These detailed calculations require specialist engineering expertise. For long spans, NZECP34 would likely prevent the construction of buildings even outside of the 12m corridor. When applying the tables within NZECP34, care must be exercised to ensure that both existing and proposed normal and construction or maintenance activities are considered.
33. Clause 2.4.1 of NZECP34 states that:
Except with the prior written consent of the overhead electric line owner, no building or similar structure shall be erected closer to a high voltage overhead electric line support structure than the distances specified in Table 1
34. Table 1 states:
Minimum safe distances between buildings and overhead electric line support structures
35. Additionally Table 2 provides minimum safe distances beneath conductors without engineering advice that range from 8.5-11m depending on span length.
36. Table 3 allows for this distance to building to be reduced to 6m. This needs to considered with caution as although it enables the finished building to be constructed, it does not consider maintenance and
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 51
operational activities associated with the building such as repairing roofing.
37. NZECP34 Section 9, Table 9 and Figure 6 provides details for the minimum safe approach distances of persons to live conductors of 6m measured from the end of their outstretched hand.
Photo 15: Minimum clearance combinations required to determine minimum safe distances of a new development
38. Regulation 17(3) of the Electricity (Safety) Regulations 2010 states that various people commit a criminal offence if they fail to maintain the safe distances specified in NZECP34, including a person who carries out or controls the construction, building, excavation, or other work and a person who owns or controls any line, works, fittings, building, structures, equipment, or machinery that is the subject of, or involved in, the infringing work.
39. However, to date, the Ministry of Business, Innovation and Employment, which has been tasked with enforcing NZECP34 has not, in my experience, taken a proactive enforcement or monitoring role. Regulating activities through the District Plan is likely to result in greater compliance, as well as enabling wider considerations to be taken into account as discussed below.
19856004_1 Statement of Evidence in Chief of Dougall Campbell for Transpower New Zealand Limited dated 1 August 2016 52