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In the Environment Court Wellington in the Matter IN THE ENVIRONMENT COURT WELLINGTON IN THE MATTER OF Appeal No. ENV-2007-WLG-000098 under sections 120 and 121 of the Resource Management Act 1991 (“the Act”) BETWEEN MOTORIMU WIND FARM LIMITED Appellant AND PALMERSTON NORTH CITY COUNCIL First Respondent AND HOROWHENUA DISTRICT COUNCIL Second Respondent ______________________________________________________________________ Brief of evidence by Dr Dave Bennett called by the Tararua-Aokautere Guardians Inc. ______________________________________________________________________ STATEMENT OF EVIDENCE OF DAVE BENNETT CALLED BY THE TARARUA- AOKAUTERE GUARDIANS INC. INTRODUCTION 1. I am presently a director of several public companies, namely: Trans-Orient Petroleum Ltd, TAG Oil Ltd, and Rift Oil Plc. The two former are Canadian companies involved in oil & gas exploration in New Zealand, while Rift is a British listed company involved in oil & gas exploration in Papua New Guinea. 2. In addition to these executive and directorial positions I also work as an Exploration and Energy Consultant. 3. I have a BA (Canterbury) : Natural Sciences (Physics/Maths); an MSc (Leeds): Exploration Geophysics, and a PhD (Australia National University): Geophysics. 4. In my work capacity I have acted as adviser to various NZ energy and electricity generation companies, and have played a significant role in the discovery of several of New Zealand’s existing oil and gas fields. 5. Of some relevance to this hearing is that I led the commissioning of a 1 MW power plant using associated gas from a Taranaki oil field; and that I have also chaired full day sessions of the annual NZ Electricity Conference, hence have a familiarity with the NZ electricity generation industry. 6. Also of relevance is that I have more than 30 years experience in applied seismology, which is closely allied to the field of acoustics, since it deals with propagation of pressure waves through solids and liquids, whereas acoustics concentrates on propagation through air. There is a considerable degree of overlap between the two disciplines, particularly regarding effects at the earth- air and water - air interface. I have considerable experience in conducting seismic surveys, where energy is propagated through the ground from explosive or vibratory sources. In this capacity and in the management of drilling operations I have had direct dealings with residents affected by noise 2 propagation affecting their residences in the form of audible noise and/ or vibration. In this capacity I have used NZ noise standards. 7. I am also a resident of the Makara Valley near Wellington, sited close to Meridian’s West Wind wind turbine complex, now under construction. I was elected by the Makara community onto the Project West Wind Liaison Group, which has an oversight role on the activities of Meridian in this development. 8. I have read and understand the conditions of conduct for being an expert witness. I comply with all criteria for being an expert witness. 3 EVIDENCE My evidence consists of three topics. Electricity Supply & Demand 9. A discussion of NZ's electricity demand and the electrical energy output of Motorimu wind turbines as opposed to the existing economic alternative - combined cycle turbines. This demonstrates that Motorimu's contribution to NZ electricity supply, in either the 75 or 113 turbine configuration, is small and will not contribute to security of supply Global Warming, GHG Savings and Kyoto Targets 10. A view on comparative Greenhouse Gas (GHG) emissions between wind and combined cycle turbine generators, which leads to the conclusion that the GHG savings of wind turbines are extremely small and can even be negative; hence that GHG is not a significant factor in considering wind farm developments, Noise from wind turbines 11. The section on turbine acoustic noise is complementary to the submissions of Mr Bob Thorne of Noise Measurement Services Pty Ltd. I provide evidence that demonstrates that turbine noise is a global problem (including New Zealand), by reference to papers at the recent Wind Turbine Noise conference which I attended. I also cite a case study I conducted which has some relevant pointers for Motorimu, as well as relevant literature. 12. A description is given of the history and shortcomings of New Zealand Standard NZS 6808, which is commonly relied upon to protect residents from excessive noise, but can be demonstrated to have failed. 13. I also provide evidence to complement Dr Phipps submission (S274 party). 4 Electricity Supply & Demand 14. The Motorimu proposal as now sought is described as 113 turbines and an installed capacity of 96.05MW. At a capacity factor of 0.35 over the 8760 hours of the year, and deducting a 10% maintenance downtime, such a complex would generate approx. 270 GWH (Gigawatt-hours) of electrical energy, as compared to NZ's present usage of approx. 44,000 GWH per annum ( on the basis of Meridian's own figures obtained under OIA, Te Apiti had an overall capacity factor of 34% for 2005 and 36.5% for 2006, so 35% for Motorimu is realistic). 15. NZ's electricity demand is growing by approx 2% per annum, so the Motorimu proposal as sought, represents only 0.6% of NZ's present demand or only 3-4 month's worth of demand increase. An individual turbine represents 0.005% (50 parts per million) of present NZ demand, or 1 day's worth of electricity demand increase. 16. NZ has a grid connected installed capacity well in excess of 8,000 MW, while the average load is approx 5,000 MW. The record NZ demand peak of 6919 MW was in July 2007. This coincided with a cold, still period when the wind contribution to meet high demand amounted to less than 30MW or 16% of installed wind capacity. Thus at a time of peak demand the contribution of windpower was very poor. High pressure systems, leading to cold still nights and still days, are frequently developed across the entire NZ landmass, let alone just the Manawatu region. Thus peak demand tends to coincide with low windpower output. 17. The recent closure of Contact's obsolete power station in New Plymouth has been offset by Contact's planned 300 MW ' peaking plant', to be located near its Stratford power station site. A declared intent of this new plant is to provide 'rapid start' support to wind power. This is necessary to maintain grid wide voltage and frequency control, given the known and documented risk of widespread and rapid wind power fluctuations. 5 18. From the above, it is clear that the Motorimu proposal ( in common with other wind farms) will not contribute significantly to NZ supply, NZ growth in demand or NZ security of supply. In Germany, for example, which has the highest installed capcity of windpower in the world, the major distributor, EON, considers that in order to meet increased demand, new thermal capacity must be installed at approx. 70% of the rate of windpower installation, to ensure security of supply, because of the uncertainty associated with windpower. In the Motorimu instance, the developer has claimed that the existing Huntly facility can provide backup to Motorimu's fluctuations, but in fact the old Huntly station is now firmly in the baseload category, and cannot generally be relied on in such manner. The new 'fast start' Contact 'peaking' station or the Genesis e3p would generally be required as backup. They have much smaller GHG emissions as discussed below. 19. Points 1.1 to 1.4 demonstrate there is plenty of scope to reject all of the additional turbines without any significant impact on NZ's security of electricity supply. The permitted 75 turbines have 2/3 of the energy generation and whatever GHG savings exist, of the 113 sought, so the impact of the additional turbines is trivial. 20. The developer has represented that the113 turbine proposal cannot be reduced as that will make the project unviable. I do not accept this. The same developer originally claimed that less than 127 turbines at Motorimu was uneconomic. The larger proportion of the capital expenditure on development will be in 'variable' rather than 'fixed' costs. In other words, most of the CAPEX is proportional to the number of turbines. Each turbine requires an access road, a foundation excavation, a concrete base, a tower, a turbine, a transformer etc. Similarly regarding operating costs, each turbine has its own maintenance costs. There are some fixed project costs ( ie not proportional to the number of turbines), such as the transmission line out of the site and the control station, but these are lesser. 6 21. In other words, deleting 30% of the 113 turbines and leaving it at the 75 permitted turbines would not make the project 30% less profitable. At a rough estimate it might reduce project DNPV relative to the 113 turbine option by around 10%. Of much greater impact on project DNPV are such variables as exchange rate and future electricity prices and the assigned value and amount of any carbon credits. 22. It would generally appear that the additional locations sought by the developer are in areas of higher windflow, but also higher visibility. All locations are not equal, and the 'better' sites from a windpower point of view tend to be the less desirable sites from an impact point of view. It is disingenuous to claim that the additional sites are necessary without referring to their impact relative to other sites. Each location should stand or fall on its own merits and demerits. Global Warming, GHG Savings and Kyoto Targets 23. The analysis presented here is approximate but sufficient to demonstrate that on this project, as indeed on all wind farms, the overall GHG savings, as compared to the available economic alternative, are negligible or even less than zero in certain circumstances.
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