Electricity Engineers’ Association (EEA) Submission on the National Code for Utilities' Access to the
Transport Corridors – Re-Consultation Version
Introduction
1.
This submission is from:
Electricity Engineers’ Association (EEA)
P O Box 5324
WELLINGTON
Ph 64 4 473 8600.
If you require further information on this submission please contact Peter Berry at peter@eea.co.nz.
2.
The EEA provides the industry with leadership, coordination, expertise and information on
technical engineering, asset management, and health and safety issues affecting the electricity
supply industry (ESI) in New Zealand the industry. We have over 300 members and 35 corporate
members from electricity generation and retailing companies, transmission and distribution network
companies, engineering consultants, contracting companies, equipment suppliers, and other
companies providing services to the ESI. Our electricity network utilities members have a significant
number of their assets located in transport corridors while our contractor and consultant members
play a vital role in service deliver through the design, construction, maintenance and repair of such
assets located in transport corridors.
The EEA also produces minimum best practice engineering, technical and safety Guidelines and
Standards for use within the ESI and for use by industries that work near electric utility assets. EEA
has membership on various national and international Standards committees; and monitors changes
in legislation covering the technical and safety requirements for the ESI and contributes to discussion
on such changes that are put forward by Government.
General Comments
3.
EEA supports the Code in general.
4.
We consider that the Code generally fulfils the purposes set out in Section 9 and the
requirements as set out in Section 10 of the Utilities Access Act 2010.
5
To assist in successful implementation of the Code we would support the NZUAG being an
active focal point for any Code type issues; and tasked with providing an ongoing coordinating and
education role to support the Codes application (including monitoring of disputes and the general
performance of the Code); and being responsible for ongoing Code review and updating.
The issue of underground and above ground assets located in transport corridors and Road Safety
was highlighted by the Automobile Association in its submission to the CRG. It is our view that the
Code provides a balanced process to ensure road safety issues are included as part of the
requirements for utilities access to transport corridors. The on-going enhancement of public safety
is an important outcome from the new Code so we believe it is an on-going role for NZUAG to
facilitate future monitoring and discussion on the Code and road safety issues.
Accordingly we would recommend that the NZUAG establish under its auspices a road corridor
safety committee involving utilities, RCAs and transport safety interest groups.
6.
We have reviewed the revised sections and considered feedback from our Members. We
have also discussed a number of the issues with the Electricity Networks Association (ENA) and we
endorse and support their submission to you.
The following are our comments for your consideration:
Definitions: Major Works, and Works.
We agree with this change and the comments in the ENA submission.
Section 2.4.1: Quality plans
We agree with this change, but only as an interim position which should be reviewed within 3
years of the publication of the Code.
EEA believe the Code should flag now that Government/NZUAG would expect organisations
undertaking work in the transport corridors to operate and maintain quality systems. Project based
quality plans are a natural iteration of a quality system. We do not believe it is appropriate for
organisations to have a choice of operating either a quality system or project based quality plans…
they should have both. Part of the outcome of the Code is to deal with quality concerns around
completed work in the transport corridor and both quality systems and project quality plans
together will better achieve is outcome.
Section 2.7.1: Co-ordination
Agree.
Section 3.5.2 – Future proofing.
The EEA strongly oppose the wording in this section as we believe the suggestion by the CRG to
introduce the idea of ‘neutral’ duct colours will significantly reduce workplace and public safety, is
potentially economically inefficient and could impact upon technical performance of utilities
where separation distances are not maintained.
The standardisation of utility ducting colours via the DOL Guide has significantly lessened the use of
non-standard colours and improved public and worker safety.
We do not support “random future proofing”. If future proofing is required it should be based on
projected utility requirements and appropriately coloured ducts installed. If not used within the
projected time frame the parties concerned either agree to leave them in situ or they become
redundant and may then be removed by the party that requested and funded their installation.
Any ducting must be fit for purpose. Gas ducting is specialised ducting and no other ducting can be
used to transport pressurised gas. Electrical ducting may require additional mechanical safety
protection or that barriers be placed above it for protection and thermal backfill for technical
performance. This would have to be included at the time of installation otherwise additional
excavation would be required to adequately protect the “neutral” ducting thus negating the value of
installing “neutral” ducting. The cost of this and additional measures needed to identify/verify the
content of the neutral ducts (as they may look like the ducting in Appendix 8 of the DoL Guide) is
likely to be higher than the original placement of the “neutral” ducting.
One of the key drivers for the DoL Guide for Safety with Underground Services was the plethora of
random duct colours being installed/used by utilities and others. This meant when excavating
workers could not identify from the duct colour what service was contained in the duct. Duct
colours were assigned to utility activity in 2002 and these colours are now recognised and used (see
Section 34 of the DoL Guide). As this plethora of different visually undefined duct colours was a
safety legacy concern Appendix 8 of the DoL Guide was produced as an historical reference to assist
future workers in working safely.
To again be suggesting the installation of undefined coloured utility ducting which could contain any
utility service will in our view reverse many of the positive safety outcomes we have seen from the
2002 DoL Guide.
Section 4.1.2: Agreement to modify processes
Agree.
Section 4.3.1: This links with topic 1, the definitions.
Refer to comments in definitions.
Section 4.5.2: Standard template for Reasonable Conditions
Agree
Section 5.1.5:
Agree.
Section 5.2.1: General procedures for locating underground utilities
EEA believe this Section must cross reference Section 3.2 of the Code to ensure that persons using
this part of the document are aware of the requirements elsewhere.
We do not support Section 5.2.1.2 which states that parties locating underground services if they
agree, do not have to follow the DoL requirements in Department of Labour Guide for Safety with
Underground Services (2002) and that they do not have to have an observer watching the work.
We believe that this is a degradation of safety and suggest that the section require that they must
have an alternative documented process and procedures in place which achieves no less than the
safety outcomes required by the DoL minimum practice Guide.
Section 6.4(e): Wrongly located utilities
We support the ENA submission.
Section 8.2.2: While this Section has been clarified, the Committee wishes to have feedback on
whether the sectors consider these are sensible and useful measures
If you require any further information or wish to discuss any aspect of our submission please contact
the undersigned.
Thank you for the opportunity to make this submission.
Peter Berry
Executive Director
Electricity Engineers' Association of New Zealand (EEA)
Ground Floor, Engineers House, 158 The Terrace, PO Box 5324, Wellington, New Zealand.
Phone 64 4 473 8600; Fax 64 4 473 8601; Email peter@eea.co.nz; Web www.eea.co.nz.