This is a submission on the Proposed Change 2 (Natural Hazards) to the Bay of Plenty Regional Council Policy Statement.

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2 SUBMISSION BY TRANSPOWER NEW ZEALAND LIMITED ON THE PROPOSED CHANGE 2 (NATURAL HAZARDS) TO THE BAY OF PLENTY REGIONAL COUNCIL POLICY STATEMENT To: Bay of Plenty Regional Council Delivered to: marieradford@boprc.govt.nz Name of Submitter: Transpower New Zealand Ltd This is a submission on the Proposed Change 2 (Natural Hazards) to the Bay of Plenty Regional Council Policy Statement. Address for Service: Transpower New Zealand Ltd Attention: Sarah Shand PO Box 1021 Wellington 6140 Phone (04) environment.policy@transpower.co.nz Transpower NZ Ltd does not wish to be heard in support of its submission but can be available if any clarification of this submission is required. Signature of submitter Date: 11 November 2014 page 2

3 SUBMISSION BY TRANSPOWER NEW ZEALAND LIMITED ON THE PROPOSED CHANGE 2 (NATURAL HAZARDS) TO THE BAY OF PLENTY REGIONAL COUNCIL POLICY STATEMENT 1. Introduction to Transpower 1.1 (Transpower) is the state-owned enterprise that owns and operates the National Grid or high voltage transmission network that carries electricity around the country. It connects power stations owned by generating companies to substations feeding the local networks that distribute electricity to homes and businesses. Some businesses that are intensive electricity users directly connect to the National Grid. The National Grid represents the asset base and includes towers, poles, lines, cables and substations, stretching and connecting the length and breadth of the country; with two national control centres (in Hamilton and Wellington). The National Grid is operated via a telecommunications network of some 300 telecommunication sites, which help link together the components that make up the National Grid. 1.2 One of Transpower s key objectives therefore is to maintain and develop the National Grid. As part of this objective, Transpower must plan and develop the network to meet increasing demand, and to connect new generation, which contributes to New Zealand s economic and social aspirations. 1.3 Transpower is described as a lifeline utility under Part B of the Civil Defence Emergency Management Act Under this legislation lifeline utilities are required to continue operating following a natural hazard event; and in the case of Transpower, ensure that a secure supply of electricity can be provided. Following the 21 February 2011 Christchurch earthquake Transpower was in a position to fully supply power within five hours and generally the National Grid infrastructure performed well. 2. National significance of the National Grid and guiding statute 2.1 The National Policy Statement on Electricity Transmission 2008 (NPSET) and the Resource Management (National Environment Standards for Electricity Transmission Activities) Regulations 2009 (NESETA) both recognise and confirm the national significance of the National Grid. The objective of the NPSET is as follows: To recognise the national significance of the electricity transmission network by facilitating the operation, maintenance and upgrade of the existing transmission network and the establishment of new transmission resources to meet the needs of present and future generations, while: a. Managing the adverse environmental effects of the network; and b. Managing the adverse effects of other activities on the network. 2.2 The NESETA manages the effects under the RMA of the operation, maintenance, development and upgrading of the National Grid transmission lines. Section 43E of the Resource Management Act 1991 (included as Appendix B) does not allow any bylaw to be more stringent than a National page 3

4 Environment Standard (NES) unless the NES expressly states that a bylaw may be more stringent. There is nothing in the NESETA that provides for any bylaw to be more stringent than the NESETA. 3. Bay of Plenty assets The following National Grid assets are within or traverse the Bay of Plenty region: Edgecumbe Substation Kawerau Substation Kaitimako Substation Matahina Substation Mt Maunganui Substation Okere Substation Owhata Substation Rotorua Substation Tauranga Substation Te Kaha Substation Te Matai Substation Tarukenga Substation Waiotahi Substation Poike Tee Arapuni - Edgecumbe-A 110kV transmission line Arapuni - Edegcumbe-B 110kV transmission line Atiamuri - Tarukenga 220kV transmission line Edgecumbe Kawerau A 110kV transmission line Edgecumbe Kawerau B 110kV transmission line Edgecumbe Tarukenga A 220kV transmission line Edgecumbe Waiotahi B 110kV transmission line Hairini Mt Maunganui A 110kV transmission line Hairini Mt Maunganui B 110kV transmission line Hairini Tauranga A 110kV transmission line Hairini Te Matai A 110kV transmission line Hairini Tarukenga A 110kV transmission line Kawerau Deviation A 220kV transmission line Kawerau Matahina A 110kV transmission line page 4

5 Ohakuri Edgecumbe A 220kV transmission line Okere Te Matai 110kV transmission line Owhata Deviation A 110kV transmission line Rotorua - Tarukenga A 110kV transmission line Te Kaha Waiotahi A 50kV transmission line Tarukenga - Deviation A 110kV transmission line Tarukenga - Deviation B 110kV transmission line Wairakei Whirinaki A 220kV transmission line A map showing the location of these assets has been included as Appendix A. 4. Specific comments on the Proposed Change 2 (Natural Hazards) 4.1 Transpower supports the inclusion of Objective 23 and Policy NH 10B: Exceptions to the natural hazard risk management strategy and the explanation provided. This policy recognises that avoidance of natural hazard areas may not always be practicable because of the particular location and operational constraints of electricity transmission. 4.2 In the future Transpower may be required to locate new infrastructure (for example a new pole or tower) within identified natural hazard areas. Even if the support structure is not within the natural hazard area the conductors (wires) may need to traverse a natural hazard area. Avoidance of these areas may not always be possible but known risks would be considered as part Transpower s route, site and method selection process. 4.3 Transpower is willing to liaise with Council about any concerns associated with the its infrastructure in natural hazard areas but wishes to express that all National Grid infrastructure is designed and built to Transpower specification standards which already take into account the known risk posed by natural hazards. 4.4 Transpower supports the definition of Lifeline utilities as it recognises Transpower s activities and National Grid infrastructure in the Bay of Plenty Region and reflects the definition provided for lifeline utilities in Schedule 1, Part B, of the Civil Defence Emergency Management Act Transpower also supports the protection of lifeline utilities as included in Objective 23. page 5

6 4.5 Relief sought i. Transpower seeks that the definition of lifeline utilities is retained without modification: Lifeline utilities means essential infrastructure services provided to the community such as water supply, wastewater networks and treatment facilities, transport facilities (including road, rail, airports and sea ports), telecommunication, television and radio facilities and structures, and energy facilities (including electricity generation and distribution, and gas and liquid fuels storage and distribution/retail). ii. Transpower seeks that Objective 23 is retained without modification: Avoidance or mitigation of natural hazards by reducing risk where necessary for people s safety and the protection of property and lifeline utilities. iii. Transpower seeks that Policy NH 10B is retained without modification: Despite Policies NH 6B, NH 7B, NH 8A and NH 9B, provide for the establishment, operation and maintenance of activities that have more than low natural hazard risk or which are located in high and medium natural hazard zones if the activity: (a) Has a significant social, economic or cultural benefit to the community it serves, or is a lifeline utility; and (b) Has a functional need for the location. In the circumstances described in (a) and (b) above, risk reduction measures (including industry standards, guidelines or procedures) must be applied to reduce risk to life and property to be as low as reasonably practicable. 5. Summary 5.1 Transpower supports the Councils approach to manage and provide for the activities of lifeline utilities in natural hazard zones in its proposed Change 2 (Natural Hazards) Regional Policy Statement. Transpower believes these provisions will support the ongoing operation, maintenance, and upgrade of the National Grid infrastructure in the Bay of Plenty region. page 6

7 Appendix A Map of Transpower assets within the Bay of Plenty page 7

8 Beach Te Matai 110kV Transpower Transmission Line 50kV Transpower Transmission Line Town Projection: NZTM 2000 District Turangi Omori Taupo Taupo District Mangakino Scale: 1:1,200,000 Plan Size: A4L Prepared by: Geospatial & Drawings National Park District CouncilRuapehu Boundaries Bay of Plenty Regional Boundary Highway Railway Owhango 400kV Transpower Transmission Line Taumarunui (! Tokaanu Substations within Bay of Plenty Region Benneydale Ohura220kV Transpower Transmission Line " ) Legend Waitomo District Piopio Te Kuiti 0 Taneatua Tuai Wairoa District Murupara 70 Kilometers Frasertown Transpower Assets in the Bay of Plenty Region 35 Opotiki District Wairoa Bay of Plenty Region Matahina Te Teko Waiotahi Whakatane Opotiki Edgecumbe Matata Whakatane District Kawerau Hastings District Owhata Tokoroa Rotorua Rotorua South Waikato District Rotorua District Otorohanga Okere Tarukenga Putaruru Arapuni Tirau Western Bay of Plenty District Te Awamutu Kihikihi Otorohanga District Cambridge Ohaupo Pirongia Waipa District Te Aroha Katikati Huntly Waihou Omokoroa Waitoa Rotowaro Taupiri Beach Morrinsville Ngaruawahia Gordonton Tauranga Mt Maunganui Glen Tauranga Massey Horotiu Waharoa Maketu Hamilton Te Puke Matamata Kaitimako Paengaroa Whatawhata Waikato District Rangiriri Whangamata Kerepehi Ngatea Hauraki District Waihi Paeroa Te Kauwhata Waihi Tuakau Pokeno Meremere Tolaga Bay Ruatoria COPYRIGHT 2013 TRANSPOWER NEW ZEALAND LIMITED. ALL RIGHTS RESERVED This document is protected by copyright vested in ("Transpower"). No part of the document may be reproduced or transmitted in any form by any means including, without limitation, electronic, photocopying, recording or otherwise, without the prior written permission of Transpower. No information embodied in the documents which is not already in the public domain shall be communicated in any manner whatsoever to any third party without the prior written consent of Transpower. Any breach of the above obligations may be restrained by legal proceedings seeking remedies including injunctions, damages and costs. Nuhaka Gisborne Ormond Te Karaka Gisborne District Te Kaha Te Araroa [