Proposed National Environmental Standard for On-site Wastewater Systems: Discussion Document

• Executive Summary
• 1 Introduction
• 2 Statement of the Issues
• 3 What are the Options?
• 4 Proposed National Environmental Standards for Telecommunications Facilities
• 5 Efficiency and Effectiveness of the National Environmental Standards
• 6 References
• Appendix 1: Proposed National Environmental Standards for Telecommunications Facilities
• Appendix 2: Final Form of National Environmental Standards as Agreed by Cabinet
• Appendix 3: Telecommunications Background
• Appendix 4: Theoretical Considerations
• Appendix 5: The Impact of Cellphone Towers on Property Values
• Appendix 6: Section 43 of the Resource Management Act 1991

Executive Summary

Telecommunications facilities are currently subject to resource management consenting processes that differ widely between the 73 territorial and unitary local authorities in New Zealand.  This creates costs and uncertainty for telecommunications operators seeking to extend their networks and improve the capacity and quality of their services.  The use of road reserves for aerials and cabinets is seen as critical to the industry, both for increasing coverage of wireless telecommunications and for improving the quality of landline services.

The Proposed National Environmental Standards for Telecommunications Facilities (referred to as the NES in this document) will generate significant cost savings to both industry and local government in terms of time, certainty and economies of scale through the use of standardised equipment across the whole country.  This will facilitate faster roll-out and access to new services, and more choice from competition amongst operators.  This will in turn benefit the economy and consumers while balancing community and environmental considerations.

Without the NES, roll-out of new services and enhanced capacity will face multiple resource consent application processes.  This will increase costs and potentially slow down the rate of roll-out and the availability of new services across the country.  With the NES, new facilities with minor environmental impacts¹ will be permitted activities that avoid the cost of obtaining resource consent.  The NES would specify (through performance standards) what constitutes minor impacts for radio-frequency fields, size of cabinets in road reserves, noise of cabinets in road reserves, and size of new and extended antennas in the road reserve.

The main costs and benefits of the NES are likely to be:

• benefits for industry in reduced costs and uncertainty in obtaining consents, assessing each district’s particular needs

• benefits for councils in reduced costs in processing consents (over and above what they recover from applicants through charges)

• benefits for consumers from faster roll-out and access to new services, and from more choice and competition among operators

• costs for government in supporting the introduction of the standard

• potential cost for the community in loss of local public participation in council control over environmental effects of activities in road reserves.

An independent economic appraisal, or cost-benefit analysis, was commissioned by the Ministry for the Environment.  The analysis was undertaken by a multidisciplinary team that included economists and resource management practitioners.  The analysis is, by its nature, national in scope and does not include detailed assessment of the impacts on each of the 73 district plans and locations upon which the NES will impact.  Nevertheless, local measures are likely to be important in achieving quality outcomes.

Total costs associated with the NES for Telecommunications Facilities were estimated at $4.8 million over 10 years.²  The majority of costs are attributable to costs for government in supporting the introduction of the standard.  The cost to communities from the loss of local input over telecommunications installations in road reserves are difficult to value; these are not included in the cost-benefit analysis.  However, the substantial quantified benefits are considered to outweigh the unquantifiable costs of:

a) reduced local flexibility/community participation in planning

b) effects on visual amenity.

The estimated total benefits attributable to the NES are estimated at $94.4 million over 10 years: the majority of the estimated benefits are attributable to cost savings to industry and local government, through a reduction in resource consent processing.  Additional benefits are attributable to the facilitation by the NES of faster roll-out of services and improved services and more choice for consumers.  The quantified analysis is robust to large changes in individual assumptions; however the analysis will still be sensitive to community impacts and those unquantifiable costs.

Some councils expect there will be costs for them in adjusting their plans and supporting documentation to avoid confusion with the NES.  There is no legal requirement for them to do this under the Resource Management Act, but such costs incurred by councils as a consequence of introducing the NES are appropriate to be included in the cost-benefit analysis.  Excluding such costs would further increase the net benefit.

Because the quantified net benefit is so large, the result of the quantified analysis is not sensitive to substantial changes in the input assumptions used.

 

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