SUBMISSION BY WELLINGTON ELECTRICITY LINES LIMITED ON PROPOSED PLAN CHANGE 38 (WORKS AND NETWORK UTILITIES) TO THE UPPER HUTT CITY COUNCIL DISTRICT PLAN 30 January 2015 TO: Upper Hut City Council Private Bag 907, Upper Hutt 5140 BY EMAIL: askus@uhcc.govt.nz FROM: Wellington Electricity Lines Limited (“WELL”) PO Box 31049 Lower Hutt 5040 ADDRESS FOR SERVICE: Edison Consulting Group Limited PO Box 4269, Mt Maunganui South 3149 Attention: Tim Lester Phone: (07) 9588820 (Mob 021 993 223) tim.lester@edison.co.nz WELL Submission on UHCC PC38 1 About Wellington Electricity 1.1 Wellington Electricity Lines Limited (WELL) owns and operates electricity distribution network assets within the Wellington Region (Wellington City, the Hutt Valley and Porirua Basin). This network has a system length of 4,600km and serves around 165,000 connected consumers. 1.2 WELL is committed in its regulatory obligation to provide consumers in the region with an effective and secure supply of electricity, which in doing so provides a critical service to customers as well as a public good to local communities including hospitals, schools offices and residential dwellings. 1.3 WELL owns distribution substations, lines and cables located in public road reserve, as well as on private property and along easements. In addition to the distribution network, WELL has the ability to own and operate high voltage (up to 110kV) transmission lines, and associated structures. 1.4 In addition to the supply of low voltage connections to industrial, commercial and private customers, WELL also owns and operates high voltage sub-transmission infrastructure (11kV and 33kV) consisting of lines and substations. 2 WELL’s Submission to Proposed Plan Change 38 to the Upper Hutt District Plan 2.1 The purpose of Plan Change 38 (PC38) is to assist the Upper Hutt City District Council (Council) to carry out its functions pursuant to the Resource Management Act 1991 (RMA). 2.2 WELL is responsible for the sustainable management, development and protection of a physical resource (electricity infrastructure) in a way which enables people and communities to provide for their social, economic, and cultural well-being pursuant to Section 5 of the RMA. The benefits of WELL’s electricity assets across the City are further provided for in the RMA pursuant to section 7(b) and 1(ba). 2.3 Conceptually, WELL supports the purpose and intent behind PC38 as a consistent and up to date approach to the local regulation of network utilities is a worthwhile exercise. Moreover, WELL supports the concept behind a Network Utility section in the Upper Hutt City District Plan as a complete code (e.g., network utility provisions are not addressed individually in each land use zone). 2.4 While WELL is generally supportive of PC38, submission points have been made that are required to enhance relevant provisions and enable the importance of the critical electricity sub-transmission and distribution infrastructure across the City be recognised. The specific submission points, and relief sought, to address concerns are set out below in tabular format. WELL Submission on UHCC PC38 3 Key issues for Wellington Electricity 3.1 Key issues for WELL that have been submitted on in PC38 include (but are not limited to): Recognition that the distribution network contains sub-transmission Critical Electricity Lines and Substations. WELL’s electrical network interests. Appropriate and technically accurate definitions are provided. 4 Critical Electricity Lines and Transmission Interests 4.1 As stated in the Greater Wellington Regional Council’s Operative Regional Policy Statement (RPS): “…infrastructure, including energy generation, transmission and distribution networks, are significant physical resources. This infrastructure forms part of national or regional networks and enables communities to provide for their social, economic, and cultural wellbeing and their health and safety…”(page 34) 4.2 Such explicit recognition of the distribution (electrical) network’s regional importance should likewise be reflected in PC38 with such infrastructure being acknowledged as containing Critical Electricity Lines (CEL) and their associated Substations (i.e., Zone Substations) that carry regional significance. 4.3 WELL acknowledges that Council has substantively derived the PC38 definition for Regionally Significant Network Utilities from the RPS’s definition for Regionally Significant Infrastructure. Consequently, WELL consider that as the electricity distribution network has been excluded from the regionally significant definition in PC38, there is insufficient recognition of the critical importance that elements of the distribution network (namely the sub-transmission network) in the plan change. This in-turn has consequences in regard to effective protection against adverse effects such as reverse sensitivity, and the limited access WELL has in regard to mandatory developer consultation. 4.4 In consideration of this limitation, specific submission points have been provided to Council relating to a new section to be inserted into the District Plan that suitably acknowledges the function and operational requirements of Critical Electricity Lines. A draft section has been prepared for Council’s consideration and is intended to be incorporated into the District Plan as a part of PC38 (see Attachment A and Attachment B). 4.5 The requirement for a new Critical Electricity Line and Substation section is further justified given that WELL own and operate high voltage infrastructure within the City. As such lines are not owned by Transpower they consequently are not bestowed with protection that would be provided to Transpower under the National Environmental Standards for Electricity Transmission Activities, even though in principle the effects will be of a similar nature to Transpower assets. Without the adequate protection of WELL’s sub-transmission network’s Critical Electricity Lines, regulation of such high voltage network utilities will be difficult for both users of the District Plan, as well as for Council assessment purposes (i.e., interpretation and application of the Permitted Baseline). WELL Submission on UHCC PC38 5 PC38 Definitions 5.1 It is important that PC38 definitions provide clarity and certainty for network utility operators, as well as being reflective of technical and operational realities for network utility infrastructure. 5.2 WELL considers it paramount that all definitions in PC38 are accurate and appropriately encapsulating to ensure the ongoing and effective operation of their assets. Furthermore, WELL consider it important for the proposed definitions to be enabling for their operations to satisfy Council’s regulatory compliance, and to maintain this compliance across their network. 6 Individual Submission Points 6.1 The table below summaries each submission point and whether WELL supports, supports in part or opposes and the relief sought. 6.2 A number of submission points have been made that refer to a new section being included in PC38. This section relates to Critical Electricity Lines which is presented in draft and attached to this submission as Attachment A (Text) and Attachment B (Map). WELL appreciates that advancing and refining the attached section would be best achieved through a collaborative process with Council and other interested parties. WELL would be open to undertake such collaboration as part of the overall PC38 mediation process. WELL Submission on UHCC PC38 Specific Provision of PC 38 Oppose/Supports/ In part WELL Submission WELL Seeks The Following Decision From Council 35: Definitions Building Support WELL consider that the definition used for ‘Building’ correctly excludes network utilities and is supported by WELL. That Council Retain the current definition for ‘Building’ in PC38. Cabinet Support in Part The definition for Cabinet refers to a box-shaped structure that, amongst other things, can contain single electricity transformers and switch gear distributing electricity at a voltage up to and including 100KV. That Council Amend the Definition for Cabinet as follows: Whilst the function of cabinets containing electrical equipment has been accurately reflected in the definition, the voltage of 100KV is not industry standard, and therefore should be amended to state voltages up to and including 110kV. Critical Electricity Line WELL consider that proposed PC38 is limited in the recognition of electricity infrastructure that is not a component of the Transpower National Grid, or infrastructure that is used to distribute electricity to customers (homes or businesses). For completeness, and to effectively ‘fill the gap’ in PC38, a new section (and definition) is required to acknowledge Critical Electricity Lines that are associated with the subtransmission network within and across the City. Attachment A and B of this submission contains a draft section for PC38 that suitably recognises Critical Electricity “means a box-shaped structure which houses radio and telecommunication equipment, electrical equipment, equipment associated with the continued operation of network utilities, which includes single transformers and associated switching gear distributing electricity at a voltage up to, and including, 110kV.” Include a definition for Critical Electricity Line as follows: “Critical Electricity Lines means electricity infrastructure which directly conveys, or is intended to directly convey, large quantities of electricity from point to point. Typically such electricity conveyance is across cities, districts or regions between Grid Exit Points and Zone Substations. For the avoidance of doubt, Critical Electricity Lines includes assets which were part of the national grid but are no longer owned by Transpower, or existing and WELL Submission on UHCC PC38 Specific Provision of PC 38 Oppose/Supports/ In part WELL Submission WELL Seeks The Following Decision From Council Lines. new assets which perform the function of transmission or sub-transmission but are not owned by Transpower”. Line Support WELL consider that the PC34 definition for Line is appropriately referenced to the definition contained within Section 2 of the Electricity Act 1992 That Council Retain definition for Line. Maintenance Support WELL consider that the definition for Maintenance is suitable and adequately encapsulates operational requirements for the district’s transmission and distribution electricity assets. That Council Retain Definition for Maintenance. Minor Above Ground Line Support WELL consider that the inclusion of a definition for a Minor Above Ground Line is appropriate as it relates to customer connections to the district’s electricity dist9ribution network. That Council Retain Definition for Minor Above Ground Line. Minor Upgrading Support in part WELL request that Council amend the definition for Minor Upgrading to more suitably reflect minor activities such as the addition of circuits and conductors, as well as to include a support structure replacement to within 5m of the structure being replaces. That Council Amend the definition for Minor Upgrading by including a new provision for the addition of circuits and conductors on existing support structures. The addition of circuits and conductors will enable WELL to provide for growth and future demand for electricity across the District. By enabling additional circuits and conductors on existing support structures, adherence to proposed Policy 16.4.14 would be enabled as it will allow for network utilities to be co-located, hence mitigating visual impacts. That Council Amend the definition for Minor Upgrading to allow replacement support structures to be located within 5 meters of the structure being replaced. WELL notes that the Hutt City Plan Change (PC34) is currently underway with both PC 34 and PC 38 striving to be consistent with cross jurisdictional matters that relate to WELL Submission on UHCC PC38 Specific Provision of PC 38 Oppose/Supports/ In part WELL Submission WELL Seeks The Following Decision From Council network utilities. To assist in achieving this consistence, WELL consider that the support structure relocation provisions should reflective of PC34 - therefore a 5 meter allowance for replacement structures should be provided. Network Utility Support The proposed definition for Network Utility is suitable as it includes the provision, operation and maintenance of works for the conveyancing of electricity, as defined in section 2 of the Electricity Act 1992. That Council Retain Definition for Network Utility. Network Utility Structure Support WELL consider that the PC38 definition for Network Utility Structure is appropriate to encapsulate the various structure types associated with the District’s electricity transmission and distribution network. That Council Retain Definition for Network Utility Structure. Upgrading Support WELL consider that the PC38 definition for Upgrading is appropriate to encapsulate the various electricity operational activities undertaken by WELL. That Council Retain Definition for Upgrading. 16.2 Resource Management Issues 16.2.2 Support in Part WELL is concerned that issues associated with reverse sensitivity for Critical Electricity Lines (CELs) have not been adequately addressed in PC38. Council have associated issues of reverse sensitivity primarily with regionally significant network utilities with little regard, or inconsistent recognition, that such effects can impact network utilities not defined as regionally significant. An example of this inconsistence is in the explanation of Issue 16.2.2 where it is stated: That Council provide a definition for Critical Electricity Lines (CEL) which include the subtransmission network within the City. That Council include appropriate references throughout PC38 to CELs and provide appropriate Objectives and Policies to Reverse sensitivity can occur when sensitive or WELL Submission on UHCC PC38 Specific Provision of PC 38 Oppose/Supports/ In part WELL Submission WELL Seeks The Following Decision From Council inappropriate activities locate near to or intensify by existing network utilities and seek to or constrain the operation or expansion of these utilities. The City’s sub-transmission network is an element of electricity distribution that can be adversely effected by reverse sensitivity to the same degree as other high voltage transmission lines; however, as the sub-transmission line network has not been identified as Regionally Significant Infrastructure in the Greater Wellington Regional Policy Statement, proposed PC38 avoids addressing this effect on CELs. 16.3 Objectives 16.3.2 Support in Part WELL is concerned inconsistent references used in Objective 16.3.2, with its explanation confusing in that it refers to both high voltage electricity transmission lines, as well as the transmission of electricity on the National Grid. WELL own high voltage transmission assets that were previously owned by Transpower. However, as ownership of the asset has changed, acknowledgement in PC38 of high voltage transmission lines is applied interchangeably between High voltage (110kV or greater) transmission lines (which would include WELL assets), and the National Grid (Transpower Assets). Such ambiguity is confusing and in need of clarification. 16.3.4 Support in Part Objective 16.3.4 appropriately acknowledges that any adverse effects on the environment generated by network utilities will be managed appropriately. Whilst WELL agree with this objective, the ensuing explanation fails to That Council clarify the application of Objective 16.2.3 by removing the reference to the ‘national grid’ in the explanation. Or, alternatively; That Council include a new section in PC38 pertaining to the efficient regulation of the City’s Critical Electricity Lines as outlined in Attachment A and B to this submission. That Council Amend the explanation to proposed Objective 16.3.4 to include that the development and operation of network utilities may result in residual effects that cannot be WELL Submission on UHCC PC38 Specific Provision of PC 38 Oppose/Supports/ In part WELL Submission WELL Seeks The Following Decision From Council appropriately detail how this management is to occur. avoided, remedied or mitigated, and that such residual effects will be suitably offset by the public good that they provide. As stated in the explanation: “…it might not be entirely possible to avoid, remedy or mitigate all adverse effects associated with a network utility, meaning there will be some level of adverse effect on the surrounding environment that requires mitigation.” The wording used in the explanation is confusing as it reads that any effects that cannot be avoided remedied or mitigated will be required to be mitigated- which is somewhat contradictory. In acknowledging that the Resource Management Act (1991) is not a nil effects statue, consequently, the 16.3.4 Objective explanation should acknowledge that some residual effects may need to be accepted. 16.4 Policies 16.4.2 Support in Part Proposed Policy 16.4.2 is intended to recognises the national , regional and local benefits of regionally significant infrastructure. The third bullet point in the policy states that “People have access to electricity and gas to meet their needs.”. That Council Amend proposed Policy 16.4.2 as follows: People have access to are provided with electricity and gas to meet their needs. This statement is incorrect as the electricity distribution network provides access to electricity, rather than the defined Regionally Significant Network Utilities of PC38. The National Grid transports electricity across the region, and apart from large electricity customers, does not provide ‘people’ access to this electricity. 16.4.3 Support in Part WELL strongly supports the need to protect critical network utilities from the effects of encroaching reverse sensitivity. That Council include a definition for Critical Electricity Lines (CEL) in PC38; and subsequently WELL Submission on UHCC PC38 Specific Provision of PC 38 Oppose/Supports/ In part WELL Submission WELL Seeks The Following Decision From Council However, As currently focused, PC38 only recognises such an effect on defined Regionally Significant Network Utilities. include such CEL protection from reverse sensitivity as that provided to Regionally Significant Network Utilities by proposed Policy 16.4.3. WELL own and operate undesignated network utility assets that are critical not only to the City, but also the region (i.e., the high voltage sub-transmission networks). Such critical assets are to at risk from reverse sensitivity effects; and, similar to the defined regionally significant network utilities, should also be afforded the same level of protection. 16.4.7 Support WELL own and operate high voltage transmission assets (11kV, 33kV, 110kV) and support the management of subdivision and development within close proximity to such assets. That Council Retain proposed Policy 16.4.7 as it is currently worded. The wording of Policy 16.4.7 does not limit such management to the National Grid which is appropriate as development within such corridors will have similar effects, regardless of who the asset owner is. 16.4.8 Support in Part WELL agree with the intent within the statements contained within proposed Policy 16.4.8. However, it is considered that the explanation is not articulated explicitly enough in the policy in regard to the acceptance of residual adverse environmental effects (i.e., those effects that cannot be avoided, remedied or mitigated). That Council Amend proposed Policy 16.4.8 as follows: To recognise and provide for the: - - need for new and the maintenance and upgrading of existing network utilities; and technical and operational requirements and constraints of network utilities in assessing their location, design, development, construction and appearance; the possibility of residual effects that cannot be fully avoided remedied or WELL Submission on UHCC PC38 Specific Provision of PC 38 Oppose/Supports/ In part WELL Submission WELL Seeks The Following Decision From Council - 16.4.12 Support in Part 16.4.13 Support in Part mitigated, and benefits that network utilities provide to the economic, social and cultural functioning of the City, Region and Nation. WELL consider that proposed Policy 16.4.12 should be slightly amended in acknowledging that not all effects derived from the development and operation of network utilities can be avoided, remedied or mitigated as acknowledged in the preceding Policy 16.4.8. That Council Amend proposed Policy 16.4.12 as follows: Proposed Policy 16.4.13 contains an assumed drafting error as it refers twice to national standards. That Council Amend proposed Policy 16.4.13 as follows: Recognition to the International Commission on NonIonising Radiation Protection Guidelines for limiting exposure to time-varying electric, magnetic, and electromagnetic fields (up to 300 GHz) (Health Physics, 1998, 74(4): 494 –522) (ICNIRP Guidelines). “Ensure network utilities, in particular those emitting electric and magnetic fields, are designed, located, upgraded, operated and “Ensure that network utilities are designed, developed, constructed, located, upgraded, operated and maintained to the extent possible to avoid, remedy or mitigate any actual or potential adverse effects on the environment,” maintained to comply with relevant national environmental standards and to meet other nationally and internationally recognised standards.” 18 Residential Zone Rules; 19 Rural Zone Rules; 20 Business Zone Rules; 21 Open Space Zone Rules; 22 Special Activity Zone Rules 18.6; 19.6; 20.6; 21.5A and 22.30 Support in Part WELL consider that it is important that, as owner and operators of CELs, consultation is undertaken with them in relation to subdivision and other land use developments in close proximity to the sub-transmission network. That Council Amend the permitted and controlled activity standards to include the outcome of consultation of the CELs owner. That consequential amendments are made throughout the Residential Zone Rules. WELL Submission on UHCC PC38 Specific Provision of PC 38 Oppose/Supports/ In part WELL Submission WELL Seeks The Following Decision From Council 30 Rules for Network Utilities 30.1 Activities: Removal, Maintenance, Operation and Upgrading Support WELL support Rule 30.1 Activities in relation to Removal, Maintenance, Operation and Upgrading contingent upon the amendment sought to include additional circuits and conductors being included in the definition for Minor Upgrading. That Council Retain the Rules pertaining to Removal, maintenance, operation and upgrading in PC38. 30.1 Activities: Radio Communication, Telecommunication and Electricity Distribution and Transmission Oppose WELL oppose the provision in this rule that identifies all new and upgraded transformers as a discretionary activity in all zones. That Council Amend Rule 30.1 Activities: Radio Communication, Telecommunication and Electricity Distribution and Transmission as follows: Transformers vary in size according to voltage. The smaller transformers will be able to meet the permitted activity standards for all zones as specified in 30.4 and 30.5 (note: subject to road reserve area standards being increased to 2 5m as sought below). The definition for Cabinet includes transformers and switchgear, consequently their permitted activity rule for cabinets should also apply to transformers and switch gear that can be located within the cabinet. New and upgraded transformers, substations and switching stations (other than those encased within a cabinet and or those that are pole mounted and located within the Rural Zone or Open Space Zone), distributing electricity and ancillary buildings.“. In addition to the above - as currently worded the Table 30.1 rule provision would require resource consent (discretionary activity) for overhead transformers in All zones. WELL consider that the definition of “line” in Section 2 of the Electricity Act 1992, which is inherited as the definition of “line” in this plan change, includes overhead transformers, and therefore placement of an overhead transformer (pole mounted) on an overhead line, within the Rural or Open Space Zone, should be a permitted activity to reflect that overhead lines in these zones are also permitted activities. WELL Submission on UHCC PC38 Specific Provision of PC 38 Oppose/Supports/ In part WELL Submission WELL Seeks The Following Decision From Council It is unreasonable to have permitted activity overhead lines in the Rural and Open Space Zones only to then apply a mandatory resource consent requirement by virtue of the lines operational requirements. Standards for Permitted Activities 30.4 Maximum Height of Network Utilities Support WELL consider that the height standards for Lines, support structures and cabinets within and outside of the road reserve are appropriate. That Council Retain the standards contained in 30.4. 30.5 Maximum Size and Diameter of Network Utilities Support in Part WELL consider that the size and diameter standards for Cabinets located within the road reserve are, from an operational perspective, too restrictive. In order to be able to support the operation and function of underground distribution lines (permitted activities) a cabinet (containing a transformer and switch gear) requires an area footprint of 2 no less than 5m from a technical basis. Due to technical considerations, that Council Amend Standard 30.5 to enable road reserve Cabinets associated with electrical distribution networks to have an engineering envelope up 2 to 5m as permitted activities adjacent to all land use zones As shown in Attachment C, electricity distribution cabinets are common elements within the City’s road reserves and represent the only above ground structures associated with other wise permitted underground networks. The spatial dimensions for these industry standardised and prefabricated distribution cabinets are constrained in that they are required to fully contain transformers and switch gear regulating voltages at a level required by surrounding electricity users. The design and location, of the distribution cabinet are thoroughly considered prior to their positioning, thereby ensuring that pedestrian access and safety will not be compromised by the road reserve cabinet. 2 WELL support Standard 30.5 in that a 15m area for WELL Submission on UHCC PC38 Specific Provision of PC 38 Oppose/Supports/ In part WELL Submission WELL Seeks The Following Decision From Council cabinets not located within the road reserve is appropriate. 30.6 Separation Distance and Setback from Boundaries Support Proposed Standards contained in Section 30.6 are supported by WELL in so far that Lines (not being defined as a building) are excluded from the setback provisions. That Council Retain the separation and setback exemptions for cabinets and other network utility structures. 30.7 Specific Standards for temporary above ground lines Support WELL support the 6 month period for temporary above ground lines That Council Retain Standard 30.7 as currently worded. WELL Submission on UHCC PC38 Attachment A: Proposed New Section for PC38 Include a new section that relates to Critical Electricity Lines and Substations Description Definition “Critical Electricity Lines: means electricity infrastructure which directly conveys, or is intended to directly convey, large quantities of electricity from point to point. Typically such electricity conveyance is across cities, districts or regions between Grid Exit Points and Zone Substations. For the avoidance of doubt, critical electricity lines are sub-transmission assets which may have been part of the national grid but are no longer owned by Transpower and new assets which perform the function of transmission but are not owned by Transpower”. Critical Electricity Lines (CELs) and their associated Substations (Zone Substations) are key component of the electricity network within and across the Upper Hutt City District. To provide resilient electricity network the use and development of CEL’s and their associated Substations must be sustainable, secure and efficient. CELs and their associated Substations can be vulnerable to inappropriate subdivision or land use development’s proximity as such activities can restrict access and affect the ability to maintain the CELs (lines, cables and support structures). Similarly, trees planted too close to CELs and their associated Substations can disrupt supply. CELs and their associated Substations are critical to the quality, reliability and security of electricity supply throughout the district or region, and contribute to social and economic wellbeing, as well as health and safety. CELs located within Upper Hutt City include: 33kV circuit 1 between Haywards GXP and Trentham Zone Sub 33kV circuit 2 between Haywards GXP and Trentham Zone Sub 33kV circuits between Upper Hutt GXP and Brown Owl Zone Sub 33kV circuits between Upper Hutt GXP and Maidstone Zone Sub The locations of CELs, and their designated zone substations, are identified in the planning maps of the District Plan. For the purposes of this section of the District Plan, CELs: Supply essential public services such as the hospital, civil defence facilities or Lifeline sites; or Supply large (1MW or more) industrial or commercial electricity consumers; or WELL Submission on UHCC PC38 Supply 1000 or more consumers; or Are difficult to replace with an alternative electricity supply if they are compromised. Permitted Activity Land Use Land Use Permitted Activities Restricted Discretionary Activities Within 10m of the CEL centreline or the Activities that do not meet the requirements for designated boundary of a Substation: permitted activities are restricted discretionary Any building or structure that does not require activities. building consent Alteration of any building that does not exceed outside the envelope or footprint of the existing building Earthworks that: a. Are not directly above an underground cable(s); and b. Do not result in a reduction of existing ground clearance distances from overhead lines below the minimums prescribed in the New Zealand Code of Practice 34:2001 (NZECP 34:2001); and c. Are in accordance with NZECP 34:2001. Within 20m of the CEL centreline or the designated boundary of a Substation: Planting of trees other than shelterbelts, production forestry or commercial horticultural operations. Activities that fail to meet the above standards provided that prior to the commencement of any works: Written notification has been provided to the Council; and The proposed activity is being carried out in accordance with the Electricity Act 1992 and associated regulations (NZECP 34:2001, the Electricity (Hazards from Trees) Regulations 2003 (SR 2003/375), and the Electricity (Safety) Regulations 2010); OR The proposed activity is being carried out by a network utility operator or territorial authority in accordance with NZECP 34:2001. Restricted Discretionary Activities – Subdivision Subdivision within 30m of the centre line of a CEL, or within 30m from the designation boundary of a substation shall be a restricted discretionary activity. Notification WELL Submission on UHCC PC38 For restricted discretionary activities the relevant network utility operator will be considered an affected party under s 95E of the Resource Management Act, 1991. Assessment Criteria The use, design and location of buildings The mature size, growth rate, location, and fall zone of any associated tree planting, including landscape planting and shelterbelts; and Compliance with NZECP 34:2001; and Effects on public health and safety; and Effects on access to CEL’s and associated infrastructure for maintenance purposes. WELL Submission on UHCC PC38 Attachment B: Proposed New Section for PC38 - CEL and Substation Map WELL Submission on UHCC PC38 Upper Hutt Brown Owl Maidstone Trentham Haywards © Wellington Electricity Lines Limited. This plan is the property of Wellington Electricity Lines Limited. "Wellington Electricity" and the "we* image" are registered trade marks of Wellington Electricity Lines Limited. All rights reserved. The contents of this document may not be reproduced either in whole or in part by any means whatsoever without the prior written consent of Wellington Electricity Lines Limited. DISCLAIMER: Whilst care has been taken in the preparation of this plan, Wellington Electricity Lines Limited (Wellington Electricity) do not accept any liability for its accuracy and completeness and do not make any representation or warranty, express or implied, in relation to the same. These drawings are not to scale and may not show customer connections or obsolete lines. Works may have occurred in the vicinity which may not be represented in this plan at the date of issue. The information contained in this plan is supplied for reference purposes only; actual dimensions and locations on site may differ from those indicated. Any person undertaking excavation works is responsible for the location and protection of underground equipment. Without limiting the foregoing, where plans are more than two weeks old they should not be used; a new plan should be requested from Wellington Electricity. No excavation of any kind is to take place without locating Wellington Electricity's underground services. For underground service locations and obstruction plan requests call us on 0800 248 288. If you hit an electricity cable or overhead line call us immediately on 0800 248 148. If you hit any gas pipeline call the Fire Service on 111. Legend gxp Substation 33KV Cable 33KV Line THIS PLAN IS FOR DESIGN PURPOSES ONLY ELECTRICITY DESIGN PLAN No excavation of any kind is to take place without locating Wellington Electricity's underground services. For underground service locations and obstruction plan requests please call us on 0800 248 288. Title: Hutt City Plan Changes - Upper Hutt Nework W Printed by: ghousley Zone Substation N Date Printed: E Scale: 1:17000 Select autotext type S Attachment C: Road Reserve Cabinet WELL Submission on UHCC PC38