Requested information about a proposed telecommunications facility at Twizel.
I am asking Council to urgently clarify the legal and technical basis for the proposed telecommunications facility in close proximity to both educational facilities, and to avoid allowing the proposal to progress until the relevant compliance information has been provided to affected families.
The key issue is that this is not a new telecommunications facility being introduced into an otherwise unexposed area.
TELC already has an existing telecommunications installation in very close proximity to the centre. The proposed facility would introduce a second RF source into the same immediate environment, where infants, young children and school-aged children spend substantial periods of every weekday.
Under Regulation 55 of the Resource Management (National Environmental Standards for Telecommunication Facilities) Regulations 2016, the pre-commencement RF report for a new facility must take into account exposure from other telecommunications facilities in the vicinity.
I therefore ask Council to confirm whether the existing telecommunications facility near TELC has been included in the cumulative RF assessment for the proposed installation.
The RF assessment lodged with the resource consent application (see attached) makes the following statement about cumulative effects:
“In the case of the proposed Twizel Town radio communication facility the cumulative RF exposure from this site and other existing radio sites in the vicinity do not reach or exceed 25% of the Standard at any place where the public can reasonably access and that no monitoring will be required in terms of Clause 55(5) of the NES.”
Question | Response |
|---|---|
Please provide the following information and documentation: | Please note that at this time the Council has received an application for a resource consent and this is being processed. No decisions have yet been made regarding the application. |
1. The exact location and legal description of the proposed site, including the title reference, registered owner and current legal status of the land, and whether it is privately owned, Council-owned, road reserve, reserve land or subject to any other statutory designation. | The location is within Council road reserve (refer to the attached* application including site and land plans from Connexa). |
2. The exact planning pathway being relied upon for the proposal, including whether Council considers the facility to be a permitted activity under the National Environmental Standards for Telecommunication Facilities, a permitted activity under the Mackenzie District Plan, or whether resource consent, a Certificate of Compliance or any other approval is required. | The application requires consent under the National Environmental Standards for Telecommunications Facilities Regulations 2016 (NESTF) under Regulation 11 due to non-compliance with Regulations 26 and 27. It also requires a controlled activity resource consent under the Mackenzie District Plan (Rule INF-R14) – see the Isoplan |
3. A copy of the Regulation 55 pre-commencement RF report for the proposed facility. | We have not been supplied with this currently- Please contact Connexa for this information. |
4. Confirmation of which existing telecommunications facilities have been included in that assessment, specifically whether the existing installation close to TELC has been included in the cumulative RF exposure calculation. | See attached for the RF assessment lodged with the resource consent application - Please contact Connexa for this information. |
5. The predicted cumulative RF exposure at:
| Please contact Connexa for this information. |
6. Please provide those predicted exposure levels in V/m and W/m², and also as a percentage of the applicable public exposure limit. | Please contact Connexa for this information. |
7. The technical assumptions used in the modelling, including:
| See attached* for the RF assessment lodged with the resource consent application - Please contact Connexa for this detailed information. |
8. Confirmation of whether the predicted cumulative exposure reaches 25% of the maximum permitted level under NZS 2772.1 and, if so, what additional post-commencement reporting or monitoring will be required. | See attached* for the RF assessment lodged with the resource consent application - Please contact Connexa for further information. |
9. Details of any alternative sites considered for the proposed facility, including sites further away from TELC and Twizel Area School, and the reasons those alternatives were rejected. | Please contact Connexa for this information. |
10. Copies of any planning assessments, Certificates of Compliance, resource consent applications, Assessments of Environmental Effects, internal planning advice, site selection reports or other documents relating to the proposed facility. | A resource consent application has been lodged with the Mackenzie District Council. The full copy of the application is attached. The processing of the application is in progress, and is currently on hold as the processing planner has requested additional information. |
I am also requesting independent baseline RF measurements at both TELC and Twizel Area School before the proposed facility becomes operational, followed by independent measurements after commissioning. | Please contact Connexa for information you request. |
At TELC, those measurements should specifically include the under-two room, sleep areas and outdoor play areas. TELC cares for infants and very young children, including children under two, and I do not believe it is reasonable to rely only on a generic statement that the installation complies with national limits without showing the actual cumulative exposure at the places where those children spend their time. I appreciate that the operator may ultimately demonstrate compliance with the applicable New Zealand RF standard. However, that does not answer the more specific questions being raised here: Has this particular location, with an existing telecommunications facility already nearby and a second facility proposed beside two educational environments, been assessed cumulatively in the manner required by Regulation 55? | See response to 4 above. |
What are the predicted RF exposure levels where the infants and children actually spend their time? | Please contact Connexa for information you request. |
On what exact legal and planning basis is Council satisfied that the proposed facility may proceed? | Please note that at this time the Council has received an application for a resource consent and this is being processed. No decisions have yet been made regarding the application. |
Were reasonable alternative locations further away from TELC and Twizel Area School properly considered? | Please contact Connexa for this information. |
*Note: Due to their size, the attachments are available on request to LGOIMA@mackenzien.govt.nz
This is especially important because current scientific evidence does not establish that proximity alone determines risk, but nor does distance alone establish safety. Actual exposure depends on the configuration, power, direction, frequency and combined contribution of nearby installations.
For that reason, affected parents should be provided with site-specific cumulative exposure information rather than general assurances about telecommunications infrastructure.
Please treat this as a formal request for a written response and supporting documentation.
I would also ask Council to confirm who is responsible for assessing this proposal, whether any approval has already been granted, and whether there is still an opportunity for affected parents and the wider community to make submissions or objections before the proposal progresses further.
Additional response
[At the time of writing] the processing of the application has not got to a stage that the processing planner has made a determination of affected parties.