NATIONAL CODE FOR UTILITIES’ ACCESS TO THE TRANSPORT CORRIDORS SUBMISSION FORM and GUIDANCE ON MAKING SUBMISSIONS A: GUIDANCE ON MAKING SUBMISSIONS: This form gives guidance and a structure for making submissions on the draft National Code for Utilities’ Access to the Transport Corridors. It is available in Word format on the NZUAG website: www.nzuag.org.nz 1 Written submissions Written submissions are requested in electronic form, but hard copies of submissions may be sent separately. Submissions are due with the Executive Officer of NZUAG by Friday 11 March 2011. Post 68 Curtis Street, Wellington 6012 submissions@nzuag.org.nz Email Fax 04 4758 413 Enquiries telephone 04 4758 439 2 Submissions made on behalf of Submissions may be made on behalf of an organisation, part of an organisation, or a group of organisations or by an individual. Submitters are requested to specify on whose behalf the submission is made. 3 Context for submissions Submitters are requested to make their submissions in the context of the Utilities Access Act 2010. http://www.legislation.govt.nz/act/public/2010/0098/latest/DLM2248926.html?search=ts_act_utilit ies_resel&p=1&sr=1 4 Solution focus Submitters who identify any gaps in the Code or potential problems are requested to identify the reason for any problem, and offer a possible solution for the gap or problem. 5 Presenting submissions in person Organisations/ individuals who wish to present their submissions in person will have the opportunity to do so in Wellington in February 2011. If you wish to present your submission in person in Wellington in April 2011 please check the box Thank you for taking time to make a submission on the Code. B: SUBMISSION FORMAT Note that submissions must be made in electronic format. Please choose one of the following three categories of submitter (i) Submission made on behalf of an organisation or part of an organisation: Organisation: GasNet Ltd.............................................................................................................. If submission is made on behalf of part of an organisation, which part: ……………………………………………………………………………………………………………………………………………………. Postal Address PO Box 7149, Wanganui 4540.............................................................................. Contact person Wayne Armishaw..................... Job title Engineering Manager………………………… Telephone 06 349 0132 (DDI)................................Mobile 0274 465 466…………………………………. Email wayne.armishaw@gasnet.co.nz………………………………………………………………………………. (ii) Submission made on behalf of a group of organisations: Organisations involved in submission.............................................................................................. ……………………………………………………………………………………………………………………………………………………… ........................................................................................................................................................ Contact person……................................................ Job title………………………………………………………... Telephone.............................................................Mobile……………………………………………………………. Email………………………………………………………………………………………………………………………………… (iii) Submission made by an individual Name of submitter......................................................................................................................... Telephone............................................................Mobile…………………………………………………………….. Postal Address................................................................................................................................. Area of interest in the Code………………………………………………………………………………………………….. ………………………………………………………………………………………………………………………………………….. ………………………………………………………………………………………………………………………………………….. Email…………………………………………………………………………………………………………………………………. 1 General comments on the Code [In addition to any other general comments that submitters may have, it would be helpful for submitters to indicate: • whether they support or oppose the Code in general; • whether they consider the Code fulfils the purpose set out in Section 9 of the Utilities Access Act 2010 (and, if not, the specific reasons as to where and why it does not fulfil that purpose); and • whether they consider the Code fulfils the content requirements set out in Section 10 of the Utilities Access Act 2010 (and, if not, the specific reasons as to where and why it does not fulfil those content requirements). Comments: GasNet, through its parent company Wanganui Gas Ltd made a commitment to working together in the roading corridor for the benefit of our customers and communities by becoming a signatory to the NZUAG Charter of Understanding in 2004. Through this commitment GasNet is supportive of the development of this National Code of Practice. 2 Comments on specific part of the Code Please use the following format for each topic you are commenting on Topic..Providing information............................................................................................... Page number..23...................paragraph.2.8.1 (1 c)............................................................. Comment: Detailed location information is current only at the time of issue. Only site specific detailed information will be provided to Utility Operators and Corridor Managers for the purpose of planning or construction. Large area or whole of network information will be not generally be made available. Recommended solution (if any) including specific wording: “ Provide site specific detailed information at other times, as required by Corridor Managers or other Utility Operators;” Reason for suggesting change: GasNet is not agreeable to providing complete sets of detailed plans to other parties because there is evidence that others parties retain the information for planning and construction after the information has lost currency. The recommended wording above clarifies that only site specific detailed information will be made available. Topic Recording depths...................................................................................................... Page number 23....................paragraph.2.8.1 (4)................................................................ Comment: Recording the depth of assets on site has traditionally been done by using the existing ground level as the datum, i.e. simple depths; the new requirement suggests that other methods need to be used. Other methods of depth measurement require specialist survey equipment not normally used on Utility work sites. It is not practical to use such equipment to obtain this information due to the prohibitive cost of contracting these services. We suggest that simple depths with respect to ground/ road surface levels be retained as the datum for measurement. While point assets can easily be measured for depth, the assignation of the same attribute to a line asset e.g. a gas pipe is not practicable; at best it is misleading. It suggests that for the entire length of that asset, the depth is the same. Along its route, pipe will generally be laid at a range of depths, primarily determined by Standard requirements, the construction method, the depth of other assets the pipe crosses along the route, and any additional cover / clearance requirements requested by other Corridor Managers or Utility owners. Depth measurements are currently taken at specific locations along the asset (pipe). The points at which measurements are taken are geographically referenced by horizontal dimensioning. Because of the continual changes in depth, we submit that this is the most practical method of recording depths for a pipe asset. It allows depths to be recorded at points of interest, e.g. connections, and locations where it is reasonably anticipated that other Utilities / Corridor Managers would require this information in future. Recommended solution (if any) including specific wording: “For buried assets in Transport Corridors, the Utility Operators must ensure that location records include a general depth of cover along the route of the asset and should record depth of cover at specific points of interest and where it is anticipated that other Utilities or Corridor Managers may require this information in future” Reason for suggesting change: Existing proposal is impractical and not cost effective. 3 Comments on format of the Code The Code has been formatted so that mandatory requirements (must do) are set out in standard font, and the best practice (should), optional procedures (may) and explanatory notes are in italics. Please advise whether this format is useful or you would prefer to have all the text in standard font. I prefer to have: (please delete one) 4 • All text in standard font • Best practice, optional procedures and explanatory notes in italics Oral Submission I/we do/do not wish to be heard in support of this submission. (delete as applicable) Thank you for your comments and input to the Code. Written submissions in electronic form are due with the Executive Officer of NZUAG by Friday 11 March 2011. Post 68 Curtis Street, Wellington 6012 Email submissions@nzuag.org.nz Fax 04 4758 413 Once submissions have been analysed, and the Code confirmed for referral to the Minister, NZUAG will be publishing a summary of submissions and its responses to these. NATIONAL CODE FOR UTILITIES’ ACCESS TO THE TRANSPORT CORRIDORS SUBMISSION FORM and GUIDANCE ON MAKING SUBMISSIONS A: GUIDANCE ON MAKING SUBMISSIONS: This form gives guidance and a structure for making submissions on the draft National Code for Utilities’ Access to the Transport Corridors. It is available in Word format on the NZUAG website: www.nzuag.org.nz 1 Written submissions Written submissions are requested in electronic form, but hard copies of submissions may be sent separately. Submissions are due with the Executive Officer of NZUAG by Friday 11 March 2011. Post 68 Curtis Street, Wellington 6012 submissions@nzuag.org.nz Email Fax 04 4758 413 Enquiries telephone 04 4758 439 2 Submissions made on behalf of Submissions may be made on behalf of an organisation, part of an organisation, or a group of organisations or by an individual. Submitters are requested to specify on whose behalf the submission is made. 3 Context for submissions Submitters are requested to make their submissions in the context of the Utilities Access Act 2010. http://www.legislation.govt.nz/act/public/2010/0098/latest/DLM2248926.html?search=ts_act_utilit ies_resel&p=1&sr=1 4 Solution focus Submitters who identify any gaps in the Code or potential problems are requested to identify the reason for any problem, and offer a possible solution for the gap or problem. 5 Presenting submissions in person Organisations/ individuals who wish to present their submissions in person will have the opportunity to do so in Wellington in February 2011. If you wish to present your submission in person in Wellington in April 2011 please check the box Thank you for taking time to make a submission on the Code. B: SUBMISSION FORMAT Note that submissions must be made in electronic format. Please choose one of the following three categories of submitter (i) Submission made on behalf of an organisation or part of an organisation: Organisation: GasNet Ltd.............................................................................................................. If submission is made on behalf of part of an organisation, which part: ……………………………………………………………………………………………………………………………………………………. Postal Address PO Box 7149, Wanganui 4540.............................................................................. Contact person Wayne Armishaw..................... Job title Engineering Manager………………………… Telephone 06 349 0132 (DDI)................................Mobile 0274 465 466…………………………………. Email wayne.armishaw@gasnet.co.nz………………………………………………………………………………. (ii) Submission made on behalf of a group of organisations: Organisations involved in submission.............................................................................................. ……………………………………………………………………………………………………………………………………………………… ........................................................................................................................................................ Contact person……................................................ Job title………………………………………………………... Telephone.............................................................Mobile……………………………………………………………. Email………………………………………………………………………………………………………………………………… (iii) Submission made by an individual Name of submitter......................................................................................................................... Telephone............................................................Mobile…………………………………………………………….. Postal Address................................................................................................................................. Area of interest in the Code………………………………………………………………………………………………….. ………………………………………………………………………………………………………………………………………….. ………………………………………………………………………………………………………………………………………….. Email…………………………………………………………………………………………………………………………………. 1 General comments on the Code [In addition to any other general comments that submitters may have, it would be helpful for submitters to indicate: • whether they support or oppose the Code in general; • whether they consider the Code fulfils the purpose set out in Section 9 of the Utilities Access Act 2010 (and, if not, the specific reasons as to where and why it does not fulfil that purpose); and • whether they consider the Code fulfils the content requirements set out in Section 10 of the Utilities Access Act 2010 (and, if not, the specific reasons as to where and why it does not fulfil those content requirements). Comments: GasNet, through its parent company Wanganui Gas Ltd made a commitment to working together in the roading corridor for the benefit of our customers and communities by becoming a signatory to the NZUAG Charter of Understanding in 2004. Through this commitment GasNet is supportive of the development of this National Code of Practice. 2 Comments on specific part of the Code Please use the following format for each topic you are commenting on Topic..Providing information............................................................................................... Page number..23...................paragraph.2.8.1 (1 c)............................................................. Comment: Detailed location information is current only at the time of issue. Only site specific detailed information will be provided to Utility Operators and Corridor Managers for the purpose of planning or construction. Large area or whole of network information will be not generally be made available. Recommended solution (if any) including specific wording: “ Provide site specific detailed information at other times, as required by Corridor Managers or other Utility Operators;” Reason for suggesting change: GasNet is not agreeable to providing complete sets of detailed plans to other parties because there is evidence that others parties retain the information for planning and construction after the information has lost currency. The recommended wording above clarifies that only site specific detailed information will be made available. Topic Recording depths...................................................................................................... Page number 23....................paragraph.2.8.1 (4)................................................................ Comment: Recording the depth of assets on site has traditionally been done by using the existing ground level as the datum, i.e. simple depths; the new requirement suggests that other methods need to be used. Other methods of depth measurement require specialist survey equipment not normally used on Utility work sites. It is not practical to use such equipment to obtain this information due to the prohibitive cost of contracting these services. We suggest that simple depths with respect to ground/ road surface levels be retained as the datum for measurement. While point assets can easily be measured for depth, the assignation of the same attribute to a line asset e.g. a gas pipe is not practicable; at best it is misleading. It suggests that for the entire length of that asset, the depth is the same. Along its route, pipe will generally be laid at a range of depths, primarily determined by Standard requirements, the construction method, the depth of other assets the pipe crosses along the route, and any additional cover / clearance requirements requested by other Corridor Managers or Utility owners. Depth measurements are currently taken at specific locations along the asset (pipe). The points at which measurements are taken are geographically referenced by horizontal dimensioning. Because of the continual changes in depth, we submit that this is the most practical method of recording depths for a pipe asset. It allows depths to be recorded at points of interest, e.g. connections, and locations where it is reasonably anticipated that other Utilities / Corridor Managers would require this information in future. Recommended solution (if any) including specific wording: “For buried assets in Transport Corridors, the Utility Operators must ensure that location records include a general depth of cover along the route of the asset and should record depth of cover at specific points of interest and where it is anticipated that other Utilities or Corridor Managers may require this information in future” Reason for suggesting change: Existing proposal is impractical and not cost effective. 3 Comments on format of the Code The Code has been formatted so that mandatory requirements (must do) are set out in standard font, and the best practice (should), optional procedures (may) and explanatory notes are in italics. Please advise whether this format is useful or you would prefer to have all the text in standard font. I prefer to have: (please delete one) 4 • All text in standard font • Best practice, optional procedures and explanatory notes in italics Oral Submission I/we do/do not wish to be heard in support of this submission. (delete as applicable) Thank you for your comments and input to the Code. Written submissions in electronic form are due with the Executive Officer of NZUAG by Friday 11 March 2011. Post 68 Curtis Street, Wellington 6012 Email submissions@nzuag.org.nz Fax 04 4758 413 Once submissions have been analysed, and the Code confirmed for referral to the Minister, NZUAG will be publishing a summary of submissions and its responses to these.