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Issues that may require changes to the NESTF but are still within its current scope
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- 7.2.1.2 Height/co-location
- 7.2.1.3 Technology outgrowing the envelope: the futility of ‘future proofing’ (subclause 4)
- 7.2.3 Regulation 4: telecommunications facilities generating radio-frequency fields: activity status
- 7.3 Wish list of expansions of the NESTF
7.2 Issues that may require changes to the NESTF but are still within its current scope7.2.1 Regulation 7: conditions controlling antennas and utility structures7.2.1.1 Aligning antenna and shroud lengthIndustry notes an inconsistency in that antenna sizes are currently limited to 2 m in length yet they may be concealed within a shroud 3 m in length. Removing this inconsistency was a high priority for Telecom, 2degrees and Vodafone. 7.2.1.2 Height/co-locationThree councils identified this issue as a necessary change, while Vodafone and 2degrees considered it a high priority. One of the barriers to co-location is the height restriction of Regulation 7. Adding an antenna to an existing utility structure (eg, a light pole/standard) is a permitted activity under the NESTF if the height of the replacement utility structure is no more than the original utility structure’s highest point, plus the lesser of 3m or 30 per cent (ie, if original height is 10m then an extra 3m additional height is permitted – 30 percent would be larger at 3.3m). In New Zealand the average light-pole height is 12m, which means the maximum height allowed under the NESTF is 15 m. In Europe the average pole height is 18m. Extra height could be used to co-locate infrastructure, which would result in fewer individual structures. However, these would house more infrastructure and have a greater visual impact, which is contrary to the intent of the NESTF, which is to allow ‘low-impact’ facilities. Here, ‘low impact’ refers to low-impact effect. During the 2009 stocktake views were mixed among council planners as to the effect of a smaller number of more visually intrusive structures compared to a higher number of less visually intrusive structures. Industry and some councils have expressed support for co-location, recognising that rules that increase the efficiency and ability to share existing locations reduce the need for new locations.
The dimensions of that envelope have now been superseded by those required for the 4G roll out and for multi-band antennas. These antennas are larger than those used for a single band, but fewer of them are required to cover a given area. Changes in the dimensions of the envelope would need to be made (if considered appropriate) to accommodate this new technology. 7.2.2 Regulation 6: conditions protecting trees and vegetation, historical heritage values, visual amenity values and the coastal marine areaThis regulation was included to allow councils to identify new, more stringent exclusions to the NESTF if they considered it appropriate. Soon after the introduction of the NESTF, Wellington City Council instigated a plan change so that telecommunications infrastructure in reserves adjacent to the coastline required resource consent. More recently, Hamilton City Council, in its proposed district plan, identified extensive areas of historical value and visual amenity value. A rule in the proposed plan makes all telecommunications facilities in roads adjoining these areas a restricted discretionary activity and over-rides the permitted activity status of the NESTF. Industry has expressed concern at this. It considers that the scale of these exclusions is beyond the scope of what was intended in the NESTF, which needs to be more tightly defined. 7.2.3 Regulation 4: telecommunications facilities generating radio-frequency fields: activity status7.2.3.1 The 25 per cent threshold (subclause 5)The problem is this, Regulation 4(5) states that if a facility is predicted to exceed 25 per cent of NZS 2772.1:1999 in an area which the public might reasonably access, the facility must be tested within three months of becoming operational. There are practical issues in conducting such testing in areas such as CBD rooftops or other areas with difficult access. Also, operators tend to be conservative in their modelling of exposures at some sites, so that sometimes predicted exposures are greater than 25 per cent of the maximum limit when actual exposures are less than 25 per cent. In these instances, where application of the 25 per cent rule is unduly increasing compliance costs, Martin Gledhill has proposed an alternative approach through the use of the new measurement standard AS/NZS 2772.2:2011. One of the benefits of the new standard is that it accommodates the uncertainty of measurement. Mr Gledhill suggests that, in certain circumstances, it would be sufficient to demonstrate that the exposure limits mandated by the NESTF are not exceeded when the level of uncertainty is taken into account. Post-build testing would then not be required. This is discussed further in appendix 6. In summary, the new measurement standard AS/NZS 2772.2:2011 offers an alternative approach to the 25 per cent rule, which could warrant further investigation. 7.3 Wish list of expansions of the NESTFIndustry has identified areas that would benefit from additional national consistency. These are yet to be considered by the Government. Consideration would be given to these in a future review of the NESTF.
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