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
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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