Those negative effects would not be outweighed by any positive effects in terms of providing additional housing in the Cromwell basin, David Whitney told commissioners yesterday.
It was the last day of a hearing for an application, plan change 13, to alter the Central Otago District Council's district plan and rezone allowing the development.
Mr Whitney told commissioners chairman Gary Rae, Gavin Lister and David McMahon it was his opinion the site was "manifestly not suitable" for the subdivision and development proposed.
Winton Group property developer Chris Meehan is seeking the plan change to allow the 900-lot River Terrace development to be built on land next to the Highland Motorsports Park, Central Motor Speedway and established orchards.
In his evidence Mr Whitney identified a number of adverse effects from the proposed development, ranging from a lack of integration with the town of Cromwell, reverse sensitivity effects, traffic issues, and loss of productive potential of the land.
He also noted "the estimated shortfall in supply of residential land at Cromwell can, in the long term, be achieved, in large part, by utilising other land currently in the Rural Resource Area within the urban limits of the town".
Mr Whitney said he did not refer to Cromwell having a "housing crisis" as the first reference made to a housing crisis in the context of PC 13 was when he heard the opening submission by counsel for the proponent Mr Warwick Goldsmith, and in Mr Meehan's summary evidence presented the next day.
Mr Whitney also took issue with the no-complaint covenant believing it would not be effective.
"You can have a situation where other people who don't actually own properties at River Terrace can make complaints on behalf of the residents. It is possible grandparents could get involved, or children of those in the proposed retirement village could complain," he said.
Mr Whitney told the commissioners he believed there was a real potential for purchasers of properties in the River Terrace subdivision not to fully appreciate the environment they were buying into before it was too late.
If purchasers bought their property on a day when Highlands Motorsport Park or Speedway were not operating, when the orchard frost fans, guns, spraying or burning were not happening, "a purchaser will be viewing lots within a block of land that is essentially an urban patch or island within the rural environment", he said.
Following Mr Whitney's submission, Mr Rae adjourned the hearing to await final written submissions and information before deliberation.
He concluded by saying the commissioners would give "all of the submissions put to us due consideration".
The decision is likely to take several months.