Before the Hearings Commissioners at Palmerston North in the matter of: Notices of Requirement by the New Zealand Transport Agency under section 168 of the RMA for the construction, operation, maintenance and improvement of approximately 11.5km of new State Highway between Ashurst and Woodville to replace the closed section of State Highway 3 through the Manawatu Gorge and associated works, known as the Te Ahu a Turanga Manawatu Tararua Highway Project (‘the Project’) to: Palmerston North City Council Manawatu District Council Tararua District Council applicant: New Zealand Transport Agency submitter: Meridian Energy Limited Statement of Evidence by Paul Cedric Botha on behalf of Meridian Energy Limited Date: 15 March 2019 2 Introduction and experience 1. My full name is Paul Cedric Botha. I am a chartered mechanical engineer (CEng). I hold a bachelor’s degree in mechanical engineering and a master’s degree in energy studies. I am a member of the Institute of Mechanical Engineers (MIMechE) and a member of the Institute of Acoustics (MIOA). 2. I have worked in the wind energy industry for a continuous period of over 29 years. I have worked on wind energy projects in numerous countries including; New Zealand, Australia, the United Kingdom, the USA, China, the Philippines and Sri Lanka. 3. I am currently a director of Roaring40s Wind Power Limited. 4. Previously I held the role at Meridian Energy Limited (Meridian) as a Wind Technical Strategy Manager from 2003 to 2018. During that time, I was responsible for designing the layout of Meridian’s wind farms, including Te Apiti being the subject to this hearing, White Hill in Southland, West Wind and Mill Creek near Wellington, Te Uku east of Raglan and Projects Hayes, Central Wind, and Hurunui. In my role at Meridian I also undertook wind speed analysis and provided wind energy estimates of potential wind sites throughout New Zealand. I have undertaken similar roles while employed in the UK and working in several other countries with an international wind energy consultancy. These activities are now a key focus of Roaring40s Wind Power Limited. 5. I have been involved with wind turbine acoustics for 27 years which commenced at the time the first wind farms were commissioned in Wales, UK. While working for a wind farm consultancy I prepared numerous noise impact assessments for proposed wind farm developments and gave expert evidence at planning enquiries in Australia. At Meridian I was responsible for the noise impact assessments undertaken for Meridian wind farm developments and gave acoustics evidence to the Environment Court. 6. While in the UK I completed various investigations into wind farm sound and those reports were used in the development of the UK wind farm planning document ETSU-R97. I was a member of the committee which developed NZS6808:1998 and again on the committee which reviewed that document and compiled the 2010 version of that same New Zealand Standard. 3 7. I have attended a number of the International Conferences on Wind Turbine Noise held every two years and presented papers at a number of these. I have also presented wind turbine acoustics papers at the New Zealand Wind Energy Association conference and the International Symposium on Sustainability in Acoustics. I had a paper published in Acta Acustica United with Acustica, Vol 99 (2013) 537 544 titled “Ground Vibration, Infrasound and Low Frequency Noise Measurements from a Modern Wind Turbine”. 8. I confirm I have read the Code of Conduct for Expert Witnesses contained in the Environment Court Practice Note 2014 and agree to comply with them in giving evidence in this proceeding. Except where I state that I am relying on the evidence of another person, this written evidence is within my area of expertise. I have not omitted to consider material facts known to me that might alter or detract from the opinions expressed in this evidence. 9. In presenting this evidence I have also read the evidence prepared on behalf of Meridian by Tony Kyte of BBO, Christopher Jones of RCP and Lindsay Daysh of Incite. 10. I make this statement in support of Meridian’s request that should the Notice of Requirement decision be recommended that the conditions be imposed to appropriately address adverse effects arising from the new State Highway between Ashurst and Woodville bisecting an existing and operational wind farm and is required for Meridian to carry out its electricity generation business. 11. This statement of evidence provides: (a) Background; (b) Explanation of wind farms and design; (c) NZTA proposed route/corridor; (d) Effects of the proposed NZTA Project:- a. Temporary and construction effects; b. Post construction effects; i. Impact on wind flow, lifecycle loads on turbine and reduced output; ii. Civil works, access and crane platform requirements; iii. Buffer/setback; 4 iv. Plantings; v. Incompatible uses; c. Repowering; (e) Health and Safety; (f) Recommended mitigation; and (g) Questions raised in Third Minute from the Hearing Panel. Executive Summary 12. In summary, the proposed highway construction, through the Te Apiti wind farm, is going to impact the day to day operation of 31 of the 55 Te Apiti turbines located to the south of the Saddle Road. These impacts will largely be due to the proposed NZTA construction access routes off Saddle Road and through the wind farm. 13. Twenty-five of the turbines are connected to underground electrical feeders which are proposed to be modified in some way, having part of the electrical feeder relocated under the proposed highway. The re-configuration of these feeders is going to result in the direct loss of energy production and wind farm revenue. 14. Sixteen turbines and one of the two wind farm meteorological masts will be impacted long-term as their locations place them on the south side of the proposed highway, resulting in modified long- term access for day to day service and possibly separate over- dimensional load access. The increased wind farm access track lengths will have an impact on the on-going operational budget of the wind farm. 15. At least one turbine is proposed to be removed which will have a direct impact on the amount of renewable electricity generated from the Te Apiti wind farm. This impact will be long-term and beyond the life of the current operational turbine’s lifetime as the re-powering opportunity will be lost too. Since the proposal by NZTA is an outline, and includes an indicative alignment only, it is unsure whether further turbines may need to be removed. Such certainty will only be obtained once detailed engineering is completed along with the final alignment and design. 16. NZTA have yet to provide Meridian with over-dimensional wind farm access track routes, with sufficient design detail, that shows suitable access to turbines TAP01, TAP02 and TAP08. 5 17. The highway alignment has not been finalized however the indicative alignment shows cut batters of up to 34 m deep being located very close to existing wind turbine locations. The presence of those deep cuts through the wind farm are going to result in changes to the wind flow conditions (wind speed, turbulence intensity, inflow angle, wind shear and wind veer) with a reduction in the turbine lifetime and a reduction in wind turbine output. 18. Large spoil sites are proposed within the wind farm site and while the filling of valleys can have a beneficial effect, the height of those spoil sites has the ability to reduce the wind turbine wind speed and consequently the generation output of the wind farm. 19. Trees have the ability to both reduce the lifetime of the turbines and decrease the energy production through their impact on the wind flow conditions. The extensive tree planting proposed in the NOR application would have an impact on a significant number of turbines. There remains uncertainty around what planting is still being proposed by NZTA and therefore its impact on the long-term output of the Te APiti wind farm however I do note NZTA has agreed by Memorandum dated 1 March 2019 not to carry out planting to offset or compensate for terrestrial ecology on the Te Āpiti Wind Farm site1. 20. Meridian’s current consent for the Te Apiti wind farm allows for the 55 turbines to be located within 100 m of their consented locations. Meridian would like to continue to maintain the flexibility granted in that consent and therefore considers that a 60 m construction buffer be added to the 100 m turbine location allowance to create a turbine contingency zone of 160 m from the original consented locations. Background 21. The Te Apiti wind farm gained a resource consent in 2003 (see Appendix A) and wind farm construction commenced that same year after wind turbine and balance of plant procurement had been completed. Construction of the $190 million wind farm was completed in 2004 and it was fully commissioned in that same year. The wind farm comprises of 55 wind turbines, each of 1.65 MW capacity, originally manufactured by NEG-Micon of Denmark which was later purchased by the world’s largest wind turbine supplier Vestas. 1 See para [22], Pre-Hearing Meetings Report on behalf of the New Zealand Transport Agency 1 March 2019 6 22. The Te Apiti wind farm is located over 1,150ha of farmland owned by four separate land owners (including Meridian). Approximately 21km of roads were built within the site so as to allow the transportation of oversized loads and for the ongoing maintenance and servicing of the turbines. 23. The turbines have a rotor diameter of 72 m and a hub height of 70 m.