"Energy is needed and wind is the best option."
Meridian Energy had the final say during closing submissions of an Environment Court appeal hearing for its proposed $2 billion Project Hayes wind farm development yesterday.
Meridian counsel Hugh Rennie QC told the court why Project Hayes should get consent, highlighting the country's need for more electricity, and the appropriateness of a proposed 92sq km area on the Lammermoor Range for wind-energy generation.
Mr Rennie said in terms of transmission costs, an ideal electricity generation site would be in Queen St, Auckland, because there would be no cost of transporting the energy to demand.
He said obvious issues arose from choosing a site solely on transmission costs, hence the reason Project Hayes was proposed for an area swept by high winds in Central Otago, despite its distance from consumers.
"There's no other site in the South Island that can match the quality of Hayes in generation terms. The wind quality on this site has been recognised for 30 years, and tested almost regularly since then," he said.
Mr Rennie said wind on the site was an asset of the area, which land owners had "naturally" chosen to develop sustainably in conjunction with Meridian.
"If the appellants have any common theme, it's about the effect they say this project would have on people.They think Meridian is an unfeeling, mechanical creature stalking the landscape, when nothing could be further from the truth . . . Meridian is people," he said.
Mr Rennie emphasised Project Hayes would result in benefits to New Zealand as a whole, and not just to Meridian.
"This hearing has almost entirely been about landscape and amenity values, set against the needs of all New Zealanders. There is considerable dispute as to whether the site and its environments constitute an outstanding landscape," he said.
While making his oral submission, Mr Rennie said Meridian's principal closing submission would be made to the court in writing on or before February 27.
It would include matters of law and others not included in yesterday's oral submission, which was focused on aiding panel members while on site inspections of wind farms throughout New Zealand, he said.
"Our aim is to make points we think we will be helpful for you to consider when you make your site inspections," he said.
Judge Jon Jackson, commissioners Alex Sutherland and Heather McConachy, and deputy commissioner Ken Fletcher will visit the proposed Project Hayes site, as well as sites of other wind farms in New Zealand, before a decision on Project Hayes is made.
Maniototo Environmental Society lawyer Mike Holm also made his closing submission yesterday, incorporating arguments of other appellant parties into his submission, to prevent overlapping of similar material.
Mr Holm said Project Hayes was proposed for the wrong place within New Zealand and consent for the development should be declined.
"It is perhaps no surprise that many of the independent experts called had no role in the actual site selection.
If they had, it could only be concluded that they were all asleep at the wheel," he said.
Mr Holm said the adverse effects on the Lammermoor Range and surrounding areas impacted by the development could not be avoided, mitigated, or remedied.
There was also no restriction on future expansion of the development in any conditions of consent imposed by the Otago Regional Council and Central Otago District Council, he said.
Mr Holm said Meridian refused to supply adequate visual representations of Project Hayes to the CODC, after being requested to do so by the council, during an initial consent hearing.
"It's difficult to know whether this had any impact on the ability of the council to fully evaluate landscape and visual amenity impacts as fully as they might have needed," he said.
In terms of Crown support for Project Hayes, Mr Holm said the all-of-government submission did not take into account local effects such as landscape, and the "motherhood and apple pie", support should be given little weight, if any.
"The all-of-government submission was in essence a bland statement of general support for having more renewable energy in New Zealand, and the need to try and better New Zealand's performance with regard to Kyoto [Protocol] obligations," he said.
In conclusion, Mr Holm said the proposed 92sq km site was too precious, wind in New Zealand was too plentiful, and adverse effects of Project Hayes were too great, to allow such a development as proposed by Meridian.
Appellants Ewan Carr, John Douglas and Roch Sullivan also made closing submissions on behalf of their own appeals.
All outlined reasons why Project Hayes should be denied consent, citing evidence of few benefits, many adverse effects, and precedent for future applications.
In addition, Mr Carr said potential weather effects on the site had not been taken into account, Mr Douglas talked the effects on native bird populations, and Mr Sullivan highlighted concerns about transmission constraints and the unreliable energy resource which Project Hayes would generate.
Day 33
Panel: Environment Court judge Jon Jackson, commissioner Alex Sutherland, commissioner Heather McConachy, and deputy commissioner Ken Fletcher.
Yesterday's closing submissions: Maniototo Environmental Society counsel Mike Holm; Upland Landscape Protection Society, Gaelle dit-Piquard, and Ewan Carr counsel Ewan Carr; John, Sue, and Andrew Douglas counsel John Douglas; Roch Sullivan counsel Roch Sullivan; Meridian Energy counsel Hugh Rennie QC.
Quote of the day: "They think Meridian is an unfeeling, mechanical creature stalking the landscape, when nothing could be further from the truth," -Meridian counsel Hugh Rennie.
