He was giving evidence on behalf of the Waiareka Valley Preservation Society, which opposes the plant being built by Holcim (New Zealand) Ltd in the valley, and suggested the company had not adequately assessed alternative sites, including on land near the Pukeuri freezing works.
Mr Whitney assessed alternative sites and said Pukeuri would have "significant advantages" over the one owned by Holcim on Weston-Ngapara Rd, where a cement plant would have a significant adverse effect on the Waiareka Valley.
The valley site was not suitable for a large-scale industrial plant such as a cement plant, he said.
"What is proposed is a large-scale industrial activity, which has long been considered an industry which requires segregation because of noxious or dangerous aspects."
Pukeuri had substantial flat land potentially available for a cement plant.
It was next to State Highway 1 and the main trunk railway, and strategically located for transporting raw materials.
The plant would be located in close proximity to North Otago's other major industrial complex, the Pukeuri freezing works.
It would overcome constraints with respect to hours of operating, particularly rail and truck transport at night.
Mr Whitney acknowledged a disadvantage was the need to transport limestone, siltstone and tuff from quarries in the Waiareka Valley, but rail would be available.
It would be efficient to be close to those resources but that was not essential.
The new plant had economic benefits, but these would be the same irrespective of where it was built in the district.
He concluded resource consents granted early last year by the Otago Regional Council and Waitaki District Council should be declined.
Mr Whitney also raised planning issues, the effect on the valley's Arcadian landscape, heritage values, the supply of coal once the deposits at Ngapara ran out, a plant height factor and traffic effects.
