Work at substations
Transpower owns and operates 167 substations in every district in NZ except Chatham Islands, Gisborne and Kaikoura. The vast majority of substations are designated but there are some that aren’t.
Designations – the basics
A designation is basically a form of spot zoning in a district plan. A designation authorises land use activity (e.g. earthworks, buildings, structures) provided the activity is carried out for the designated purpose. For example, we may not be able to build an office block under a designation if the purpose of the designation is limited to ‘National Grid substation’. In this instance, we would need to comply with the district plan’s rules to build the office. Any requiring authority can apply for a designation (eg Transpower, lines companies). The RMA does not recognise generators as requiring authorities. Designations are personal to the particular requiring authority. This means that you couldn’t rely on our designation to carry out earthworks for your switchyard upgrade at our site (just as we couldn’t rely on your designation to install a new Transpower owned and operated transformer!).
Designations have 2 major purposes. They provide long-term security for a substation and ensure maintenance and other work can be carried out efficiently (and not be subject to changes in district plan rules). The RMA says that no person can do anything within a designation that may ‘prevent or hinder the designation’ without the requiring authority’s written approval. This is why we assess and provide ‘s 176 RMA approvals’ to a lines company wanting to build a new switchyard fence or install new cabling for instance in their switchyard located within our designation. We provide s 176 approvals as part of the A & O process (access and occupation arrangements).
Territorial authorities review and update their district plans every 10 years. So designations also need to be reviewed and actively ‘rolled over’ into plans every 10 years. This is an opportunity to review the conditions on a designation and see whether they are still fit for purpose. However, if we tried to delete a noise condition for example, the council may decide to notify affected parties and this could open up the whole designation to a public consultation process!
Usually, before we can begin any construction work at a substation, we need to have an Outline Plan of Works (OPW) approved by the territorial authority. An OPW sets out specific details for the construction work eg. tower dimensions, gantry size etc. Sometimes a council will waive the requirement for an OPW.
Contaminated soils and archaeological approvals
All substations are listed on the Hazardous Activities and Industries List (HAIL). This means they are deemed to potentially contain contaminated soils. This means that most earthworks at substations need some form of assessment and approval under RMA contaminated soils regulations. They may also need an archaeological authority from Heritage NZ. Transpower has a new archaeological layer for the South Island in its asset map database, and we are developing a layer for the North Island. The relationship between designations and contaminated soils regulations is complex! The Environment team at Transpower can help explain the interface if you have any queries. They key point to note is that contaminated soils and archaeological approvals may still be required even though the site is designated.
All earthworks will also need to be pre-approved by a B4UDig permit (which can take up to 10 weeks to obtain from our service providers).
You may be aware that Transpower carries out its maintenance work on existing transmission lines in accordance with the National Environmental Standards for Electricity Transmission Activities (Regulations issued under the RMA). These National Environmental Standards do not apply to any work we carry out at a substation.
Please don’t hesitate to contact Transpower’s Environment Policy and Planning Group if you have any queries relating to work at National Grid substations. Please contact Dhilum Nightingale, Team Leader, Regulatory Environment on 04 590 6684.