PO Box 3798, Auckland 1140 TELEPHONE +64 9 353 9700 FACSIMILE +64 9 353 9701 PARTNER RESPONSIBLE: RACHEL DEVINE

18137736 4 CMW Court

BEFORE A BOARD OF INQUIRY EAST WEST LINK PROPOSAL

IN THE MATTER of the Resource Management Act 1991 (RMA) AND IN THE MATTER of a Board of Inquiry appointed under s149J RMA to consider

notices of requirement and resource consent applications made by the New Zealand Transport Agency in relation to the East West Link roading proposal in Auckland.

STATEMENT OF EVIDENCE OF JAMES KENNEDY FLEXMAN FOR MERCURY NZ LIMITED

DATED 10 MAY 2017

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TABLE OF CONTENTS

Executive Summary ............................................................................................................ 2

Introduction ........................................................................................................................ 4

Scope of Evidence .............................................................................................................. 5

Mercury’s portfolio of electricity generation assets ....................................................... 7

The uniqueness of the Southdown Site ........................................................................... 8

The importance of security of electricity supply ........................................................... 10

The infrastructure and facilities at the Southdown Power Station .............................. 11

The extent to which the Southdown Power Station is affected by the proposed

designation ........................................................................................................................ 13

Mercury’s Solar Research and Development Centre at the Southdown Site ............. 15

East West Link proposal would compromise the ability to re-start the Southdown

Power Station .................................................................................................................... 16

Dust and vibration from the construction of the East West Link proposal ............... 17

The access required to, from and through the Southdown Site .................................. 18

Impact on Mercury’s ability to benefit from other infrastructure at the Southdown

Site ...................................................................................................................................... 20

Safety risks of constructing the East West Link proposal where NZTA currently

proposed ............................................................................................................................ 22

NZTA’s assumption the Southdown Power Station will not re-start .......................... 28

NZTA’s proposal to deal with adverse effects outside the Board of Inquiry process

............................................................................................................................................ 31

The relief Mercury is seeking ......................................................................................... 33

Attachment One – Extent the proposed designation affects the Southdown Site .... 35

Attachment Two – Plan of Southdown Power Station infrastructure ............... 36

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Executive Summary

1. When renewable energy resources are constrained, national electricity supply

is supported by non-renewable generation. With the sale of the Otahuhu

power station site for property development in 2016, the remaining thermal

generation capacity in Auckland is the thermal power generation station

(Southdown Power Station) located at Mercury NZ Limited’s (Mercury’s)

Southdown site (Southdown Site).

2. Following the Southdown Power Station closure in December 2015 the power

generation assets were put up for sale and following an international marketing

programme the three gas turbines were sold. The remaining assets remain on

the Southdown Site with critical assets (e.g. generators, gearboxes, oil

systems) being maintained in a working order. Due to the unique strategic

future options the Southdown Site offers for Auckland in terms of security of

electricity supply and for Mercury for the purposes of research and

development, the sale of the Southdown Site land was not considered. One

option, should the security of Auckland’s electricity supply be in doubt, is to re-

start and operate the Southdown Power Station. The benefit of having most of

the power generation assets and essential infrastructure remaining on the

Southdown Site is the station could be restarted in a reasonably short

timeframe (3-4 months).

3. If the East West Link proposal is constructed in the location currently proposed

it would compromise Mercury’s ability to re-start and operate the Southdown

Power Station. Having a New Zealand Transport Agency (NZTA) designation

across a large part of the Southdown Site would reduce Mercury’s flexibility to

efficiently use and develop electricity generation infrastructure at the

Southdown Site.

4. Dust and vibration from the construction of the East West Link in the location

currently proposed could adversely affect sensitive high voltage electrical

infrastructure at the Southdown Site, and constrain performance at Mercury’s

Solar Research and Development Centre, which is used to research solar and

battery storage technology performance.

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5. Mercury needs 24-hour access to the Southdown Site including access for,

and room to operate, heavy vehicles and mobile plant. It is unclear whether

adequate access could be achieved if the East West Link was located where it

is currently proposed.

6. Important Transpower New Zealand Limited (Transpower), KiwiRail and First

Gas infrastructure is also located at the Southdown Site. Mercury’s ability to

utilise and benefit from that infrastructure (including its ability to rely on that

infrastructure to re-start and operate the Southdown Power Station) would be

compromised if the East West Link proposal was constructed in the location

currently proposed.

7. Locating and constructing the East West Link highway and shared

pedestrian/cycle pathway in the airspace above the Southdown Site creates

significant potential safety risks for public using the highway, and workers

onsite which, to date, NZTA has not adequately assessed. Mercury seeks to

ensure risks are acknowledged and appropriate mitigation solutions are found.

The legacy of this development will mean a lifetime of co-location, which

means that it would have been ideal to deal with these issues at optionality

stages. It would be unacceptable not to assess the full suite of health and

safety risks now.

8. NZTA’s evidence appears to be based on the mistaken assumption that the

Southdown Power Station is ‘defunct’ and will never re-start. As a result,

NZTA has not appropriately taken into account the significant adverse effects

of locating the East West Link where it is currently proposed, including the

significant adverse effects on security of electricity supply and health and

safety. Nor has NZTA provided sufficient information to enable you, as

members of the Board of Inquiry, to determine whether the significant adverse

effects of locating the East West Link in the location currently proposed could

be adequately addressed.

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9. Contrary to suggestions in NZTA’s evidence that the significant adverse effects

relating to Mercury’s assets can be addressed at a later date (including in

property negotiations between NZTA and Mercury), those adverse effects need

to be considered by the Board of Inquiry before making a decision on the East

West Link proposal.

10. Mercury requests that the alignment of the East West Link in the vicinity of the

Southdown Site be altered so that it does not adversely affect its ability to re-

start and operate the Southdown Power Station and use and develop solar

generation infrastructure at the Southdown Site. If this request cannot be met

within the current proceedings, then Mercury requests the Notice of

Requirement and associated resource consents be declined.

Introduction

11. My full name is James Kennedy Flexman.

12. I have a Bachelor of Engineering with Honours from the University of Auckland

and a Masters of Business Administration from the University of Oxford, Said

Business School.

13. I am currently employed at Mercury as its Wholesale Markets Manager and

have held that position since February 2015. My responsibilities include

trading physical electricity in the wholesale electricity spot market, dispatching

electricity generated in Mercury’s hydroelectric power stations, buying and

selling financial electricity products (e.g. electricity futures contracts, options

and contracts for difference), portfolio management (e.g. making decisions

about what segments to sell the electricity Mercury generates into, and when),

commercial and industrial sales, managing volume and price risk, carbon

trading and the current and future operations at the Southdown Site.

14. My previous work experience includes roles as an Energy Manager and then

the General Manager – Fullcircle Recycling at Carter Holt Harvey.

15. I am very familiar with Mercury’s Southdown Site because I have been

responsible for deciding when the Southdown Power Station should be run and

then trading the output from the station prior to it being shut in December 2015.

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I am currently responsible for the ongoing maintenance and preservation of the

Southdown Power Station assets at the Southdown Site.

16. I am authorised to present this evidence on behalf of Mercury, in support of the

company’s submissions on the East West Link proposal.

Scope of this evidence

17. In my evidence I will:

(a) introduce Mercury, its operations and generation assets;

(b) explain why Mercury has decided to retain the option of re-starting and

operating the Southdown Power Station;

(c) describe the Southdown Site and explain why it is unique;

(d) explain the critical importance of security of electricity supply to local and

regional communities and the national economy;

(e) describe the infrastructure and facilities which make up the Southdown

Power Station and the extent to which that is located within, or in close

proximity to, the proposed designation for the East West Link proposal;

(f) explain what would be involved in re-starting the Southdown Power

Station;

(g) discuss Mercury’s Solar Research and Development Centre which is

also located at the Southdown Site and Mercury’s plans for the future

development of that centre;

(h) explain how constructing the East West Link proposal in the location

currently proposed would compromise Mercury’s ability to re-start and

operate the Southdown Power Station and adversely affect its ability to

use and develop the Solar Research and Development Centre;

(i) explain the issues that dust and vibration from the construction of the

East West Link proposal in the location currently proposed could cause

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at both the Southdown Power Station and Mercury’s Solar Research and

Development Centre;

(j) describe the kind of 24-hour access that is needed to operate and

maintain the infrastructure on the Southdown Site;

(k) discuss the activities and operations of Transpower, First Gas and

KiwiRail at the Southdown Site, the effects of the current East West Link

proposal on those activities, and the resulting risks to Mercury’s ability to

re-start and operate the Southdown Power Station and develop its other

assets on the Southdown Site;

(l) explain the safety risks that would arise if the proposed road and shared

pathway were located in close proximity to the Southdown Power Station

in the way NZTA is currently proposing and how, to date, NZTA has not

appropriately assessed those risks;

(m) discuss how NZTA’s evidence appears to be based on a mistaken

assumption that the Southdown Power Station will never re-start;

(n) express Mercury’s concerns that NZTA has not provided any information

which would enable the Board of Inquiry to determine whether the

significant adverse effects of locating the East West Link proposal in the

location currently proposed could be adequately addressed, and instead

proposes that a number of those effects be dealt with later outside the

Board of Inquiry process; and

(o) explain what Mercury is asking the Board of Inquiry to do to address its

concerns.

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Mercury has a diverse and expanding portfolio of electricity generation assets

which play a pivotal role in meeting national electricity demand and maintaining

New Zealand’s security of electricity supply – including the Southdown Power

Station and Solar Research and Development Centre

18. Mercury is a publicly listed company (mixed ownership model: with 51% of the

company required to be in Government ownership). It is the third largest

electricity generator in New Zealand, typically generating 15% to17% of New

Zealand’s electricity annually.

19. Mercury has a diverse and expanding portfolio of generation assets throughout

the North Island which, over the last 5 years, has generated an average of over

6600 gigawatt hours of electricity per year.

20. One hundred percent of Mercury’s currently active commercial electricity

generation comes from renewable sources – hydro and geothermal.

Mercury’s assets include:

(a) nine hydro generation stations on the Waikato River (with an operational

capacity of approximately 1052 MW);

(b) three 100% owned geothermal generation stations throughout the

central North Island (the Kawerau, Rotokawa, and Ngatamariki stations)

with a combined operational capacity of 216 MW; and

(c) two jointly owned geothermal generation stations in the central North

Island (the Nga Awa Purua and Mokai stations) with a combined

operational capacity of 250 MW.

21. Mercury also operates a Solar Research and Development Centre at the

Southdown Site and owns the Southdown Power Station.

22. While Mercury is proud of the fact that 100% of its currently active commercial

electricity generation comes from renewable sources, renewable electricity

generation is reliant on climatic factors, which can vary from year to year.

During periods when renewable energy resources are constrained, national

electricity supply is supported by non-renewable electricity generation. I

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discuss the importance of the security of electricity supply and the factors that

contribute to that security later in my evidence.

23. In March 2015 a decision was made to cease the operation of the Southdown

Power Station on 31 December 2015 due to market conditions not being

suitable. At that time the intention was to dismantle the station and sell it

offshore. A subsequent decision announced by Contact Energy in August 2015

to close the Otahuhu power station and sell the site to a property developer,

meant the Southdown Power Station is the sole remaining significant electricity

generation capacity located in Auckland. This has materially increased the

importance of the Southdown Site for future electricity generation and Mercury

has decided to retain the option of re-starting and operating the Southdown

Power Station.

24. Accordingly, Mercury has decided to continue to hold the necessary resource

consents and maintain the Southdown Power Station thermal electricity

generation equipment at the Southdown Site. This approach enables the

Southdown Power Station to be re-started and operated in the future if needed

to protect Auckland’s security of supply.

25. Mercury’s decision to retain the Southdown Power Station resource consents

and equipment took into account the fact that the Southdown Site is unique

within Auckland.

The uniqueness of the Southdown Site comes from the combination of its

central location and the extent of the significant infrastructure co-located at the

Southdown Site

26. The Southdown Site is situated on a four-hectare industrial property at the end

of Hugo Johnston Drive in Penrose. It is appropriately zoned Business Heavy

Industry for the activities Mercury is undertaking and wishes to undertake in the

future.

27. The Southdown Site is held in two parcels:

(a) Lot 1 DP 178102 (Southern Parcel) which contains the Southdown

Power Station, Transpower’s substation and other National Grid assets;

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First Gas’ high pressure gas line, and KiwiRail’s electrification

substation; and

(b) Lot 2 DP 178192 (Northern Parcel) which contains Mercury’s Solar

Research and Development Centre.

28. Notice of Requirement 1 for the East West Link proposal currently occupies

approximately half of the Southern Parcel as shown in Attachment One to this

evidence.

29. The significant infrastructure co-located at the Southdown Site rely on each

other to successfully function:

(a) the ability to utilise the electricity generation capacity at the Southdown

Power Station is reliant upon access to gas supply, via the First Gas

pipeline, in order to produce electricity;

(b) Transpower’s critical electricity transmission infrastructure at the

Southdown Site supports continuity of electricity supply and would

enable distribution of electricity generated at the Southdown Site in

future as well as the provision of ancillary services such as reactive

power support via the operation of the existing generators as

synchronous condensers; and

(c) KiwiRail’s substation at the Southdown Site receives electricity via

Transpower’s infrastructure and supports critical electricity supply to

Auckland’s electric rail services.

30. Part of the immense strategic value of the Southdown Site to Auckland arises

from the fact that it offers a number of future options, including re-starting and

operating thermal power electricity generation, research and development for

solar and battery storage, and potentially grid support activities. Because of

these attributes, I am of the opinion the Southdown Site is of long term

strategic value to the people of Auckland.

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Maintaining, and increasing, security of electricity supply is critical to local and

regional communities and the national economy

31. Maintaining, and increasing, the security of New Zealand’s electricity supply

reduces the risk of electricity outages, which have serious social and economic

consequences for local and regional communities and the national economy.

Security of electricity supply is essential at all levels of society and the

economy and essential to achieving economic growth.

32. It is particularly important in an area experiencing rapid growth such as

Auckland that the options for electricity generation infrastructure required to

support development are available and that such infrastructure is able to be

used and developed efficiently.

33. There are three main factors that contribute to security of supply:

(a) Generation capacity – ensuring generation capacity exceeds demand

at all times;

(b) Diversity of electricity supply – through a mix of renewable and non-

renewable fuel types to reduce exposure to climatic or economic

conditions; and

(c) Reliability of supply – by ensuring the electricity transmission and

distribution infrastructure is robust and reliable so that it is able to

transmit and distribute electricity throughout the country.

34. Taking away any one of the system elements contributing to the security of

electricity supply can lead to disruptions in the supply of electricity and a range

of resultant adverse social and economic impacts.

35. Imposing restrictions on an operators’ ability to operate existing electricity

generation capacity adversely impacts on the security of New Zealand’s

electricity supply. In addition, the ability to develop additional renewable

generation capacity (such as the development of solar power) positively

impacts on the achievement of New Zealand’s renewable energy targets.

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36. Kieran Murray’s evidence discusses the importance of flexible, standby,

generation plant to New Zealand’s, and Auckland’s, security of electricity

supply.

37. In the immediately following sections of my evidence I discuss Mercury’s

Southdown Power Station and Solar Research and Development Centre.

Later in my evidence I will discuss the effects of the East West Link proposal in

its currently proposed location on the First Gas, Transpower and KiwiRail

assets at the Southdown Site and the consequential impacts on Mercury’s

ability to re-start and operate the Southdown Power Station and develop other

assets at the Southdown Site.

When operating the Southdown Power Station uses three gas turbine

generators, connects to gas, water and electricity distribution/transmission

networks, and utilises a stormwater management system

38. The gas-fired power station at the Southdown Site was commissioned in 1996

and was expanded in 2007 (from 125 MW to 175 MW). Post expansion the

Southdown Power Station configuration was three gas turbine generators and

a combined cycle steam turbine generator. Without the use of the steam

turbine (which Mercury does not intend to use in future) it has a nominal

generation capacity of 135 MW.

39. A number of resource consents and other statutory authorisations are held for

the operation of the Southdown Site. The consents and authorisations held

are for:

(a) a land use consent to develop and operate a gas fuelled co-generation

plant at Southdown granted by the former Auckland City Council in April

1995. The land use consent was varied in January 2004 to erect and

operate an additional turbine (GE105) and to construct ancillary buildings

and storage tanks at the Southdown Site. It was varied again in 2012 to

allow for a more flexible mode of operation for the Southdown Power

Station (this land use consent has no expiry date);

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(b) a stormwater discharge permit granted by Auckland Council authorising

the discharge of stormwater to the environment, which expires on 31

December 2023; and

(c) an air discharge consent for the discharge of contaminants, including

nitrogen oxides (NOx) into the air from the Southdown Power Station

granted by Auckland Council in 2012, which expires in December 2037.

Firing the gas turbines also involves discharges of heat to air (as I will discuss

in more detail later in my evidence).

40. The Southdown Power Station needs access to three essential resources in

order to operate:

(a) gas;

(b) water; and

(c) access to an electricity distribution network.

41. When operating, the Southdown Power Station uses natural gas supplied via

First Gas’ high pressure pipeline from Taranaki to fire its turbines. The high

pressure gas line is located within and adjacent to the Southdown Site. To

retain security of gas supply, Mercury seeks to ensure its ownership of the land

providing access to the ‘point of connection’ to the gas line is retained.

42. The Southdown Power Station is reliant on access to sufficient quantities of

fresh water to operate. Water is currently being sourced from Watercare

Services via its reticulated supply network.

43. The Southdown Site has been developed to ensure stormwater is contained

onsite. The existing road surrounding the Southdown Power Station functions

as a bund, directing stormwater from paved areas and via underground pipes

to the western part of the Southdown Site where it is treated in stormwater

ponds, and then manually released to the environment on visual inspection.

This mitigates the risk of the mobilisation of contaminants and discharge of

contaminants via stormwater discharges. Mercury seeks that any disruption to

stormwater systems and plumbing is rectified.

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A significant amount of Mercury’s infrastructure and equipment for the

Southdown Power Station is located either within, or in the immediate vicinity

of, NZTA’s currently proposed designation

44. Southdown Power Station structures that are located within the proposed

designation (as identified on the plan at Attachment Two to my statement of

evidence) are as follows:

(a) wet surface air cooled condensors (WETSACC), which includes two

auxiliary cooling towers, which provide essential cooling support to

thermal power generation operations. Under NZTA’s currently proposed

road alignment, part of the WETSACC would be located directly beneath

the proposed road structure;

(b) the Mercury-owned gas delivery pipes and ‘point of connection’ to First

Gas’ main high pressure gas line are located in an area that, under

NZTA’s currently proposed road alignment, would be directly beneath

the proposed road structure;

(c) Gas Turbine Package 105 (Gas Turbine 105) and associated

infrastructure, including:

(i) a gas turbine support structure and fuel supply systems;

(ii) a generator; and

(iii) a gearbox;

which, under NZTA’s currently proposed road alignment, would be

located approximately 5 metres north of the proposed road structure;

(d) a chimney stack (which is an authorised point of discharge under the air

discharge consent for the Southdown Power Station);

(e) an oil bund which contains a lube oil skid (including pumps, filters, tanks,

valves), oil jacking pumps (for rotating equipment) and hydraulic starter

pumps;

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(f) an oil storage shed which is located in an area that, under NZTA’s

currently proposed road alignment, would be beneath the proposed road

structure – this is a hazardous substances storage facility that would be

displaced by one of the proposed supporting pillars for a bridge

structure;

(g) a stores building, located in an area that, under NZTA’s currently

proposed road alignment, would be under the proposed highway

structure;

(h) a stormwater treatment pond and point of discharge into Auckland

Council’s stormwater network which would be partially located within

NZTA’s proposed designation area; and

(i) an auxillary boiler and chiller building, which are no longer in use.

45. The width of NZTA’s proposed designation through the Southdown Site is

much greater than the width of its currently proposed roading alignment. The

impact of the East West Link proposal on Mercury’s infrastructure at the

Southdown Site could be even more significant than I have identified above if

NZTA moved the alignment for the East West Link proposal within the footprint

of its proposed designation, e.g. if at the detailed design stage the alignment

moved further north within the designation footprint.

46. As the Southdown Site currently stands re-starting the Southdown Power

Station would involve:

(a) procurement and installation of 3 gas turbine engines at the approved

locations;

(b) reconnection of the gas supply pipework;

(c) replacement of the steam injection system (for NOx control) on Units

GT101 and GT102 with a high pressure water injection system;

(d) procurement and installation of a water treatment plant for units GT101

and GT102 (the existing system is sufficiently sized for GT105 only);

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(e) recruitment and training of operators; and

(f) testing of all safety systems.

The timeframe for completing the above and restarting the station is estimated

at 3-4 months.

47. If the East West Link proposal is built where proposed, additional activities

would need to be completed to restart the Southdown Power Station. The

WETSACC (including the two auxiliary cooling towers shown in Attachment

Two would need to be demolished and replacement cooling infrastructure

installed. Mercury has no intent to recommence steam generation activities

onsite, (which is part of the WETSACC’s function) which means the total

cooling system capacity for the Station will be less in the future. However,

cooling systems are essential for thermal cooling to support gas turbine

operation. The site will need to be rehabilitated to a structural standard and

new cooling infrastructure installed.

48. It is estimated demolishing and making good the area around the WETSACC

and replacing the cooling infrastructure to match the requirements of the

restarted Southdown Power Station would add 6 months to the restart

programme.

49. If, however, the WETSACC demolition work (including the make good of the

area surrounding the WETSACC) was completed ahead of the construction of

the East West Link proposal then the extra timeframe for restarting the

Southdown Power Station would be reduced to 4 months.

Mercury also uses the Southdown Site to research solar and battery storage

technology

50. At the Solar Research and Development Centre located on the Southdown Site

Mercury is researching emerging solar and battery storage technology.

Mercury is undertaking trials of a variety of solar panels, DC to AC inverters,

newly developed performance enhancing surface coatings and control systems

at the centre. In the near future the Solar Research and Development Centre

will also undertake research into integrating the latest battery technologies with

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solar generation and electric vehicle charging, to show how a total ‘home

energy ecosystem’ can create, store and use energy. Mercury is also in the

investigation phase of a project to install a commercial scale battery at the

Southdown Site which will be directly connected to the National Grid via the

Transpower substation.

51. The centre currently includes three solar array structures and has an annual

output capacity of approximately 110,000 kWh. By the end of May 2017 three

different types of home scale battery storage systems will also be added to the

centre.

52. While, currently, the solar panels at the Southdown Site are not connected to

any distribution network, the existing co-location of Transpower’s substation on

the Southdown Site would make it very easy for solar arrays on the Southdown

Site to connect to the National Grid and the distribution network.

If the East West Link proposal is constructed in the location currently proposed

it would compromise Mercury’s ability to re-start and operate the Southdown

Power Station. The proposal also raises safety issues, which remain

unaddressed.

53. It would not be possible to install a gas turbine engine at the approved GT105

location as a minimum of 7m clearance is required to ensure heavy machinery

(e.g. cranes) has adequate space to install a gas turbine engine into the

approved GT105 location. Mercury has advised NZTA of this constraint but

recognises that moving the highway south would need to consider implications

on First Gas infrastructure, which is located to the south of the proposed

highway within the Southdown Site.

54. It is important that generation equipment is able to be reinstalled in the

authorised locations, as this will avoid having to redesign the thermal power

station activities, and the need for new resource consents, all of which have

significant time and cost implications. Kieran Murray outlines some of these

implications.

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55. As stated in paragraph 54 above, a minimum horizontal separation distance of

7 metres clearance from the road would satisfy Mercury’s minimum operational

needs. However, the close proximity of the proposed structure raises public

safety issues, which need to be assessed independently of the 7m clearance.

56. Mercury is also concerned that an increase in ambient NOx levels within the

locality could constrain existing emitters within the local heavy industry zone.

This issue is explained in Bruce Graham’s evidence.

Dust and vibration from the construction of the East West Link in the location

currently proposed could significantly adversely affect both the Southdown

Power Station and the Solar Research and Development Centre

57. Electricity infrastructure within the Southdown Site includes electrical

equipment that is sensitive to dust (specifically transformers, switchgear and

other high voltage equipment). Such equipment relies on being isolated from

earth by means of insulators. Insulators are high resistance components which

prevent the flow of current across their surface. When this current reaches a

critically high value, the insulator fails and an electrical breakdown occurs. The

presence and settlement of dust on an insulator negatively affects the

necessary insulation properties by reducing the insulators’ resistance. Lower

insulator resistance increases the likelihood of failures and outages to

customers. This equipment is essential for the functioning of the Southdown

Power Station and other electricity infrastructure (such as Transpower’s and

KiwiRail’s substations).

58. The solar panel arrays at Mercury’s Solar Research and Development Centre

are also sensitive to dust. If enough dust settles on solar panels, it would

prohibit sunlight penetrating photovoltaic cells. This would reduce generation

performance.

59. Dr Bruce Graham’s evidence further discusses the potential effects of the dust

generated from the construction of the East West Link proposal (including

concrete batching plant) on the local environment at the Southdown Site.

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60. Vibration generated during the construction of the East West Link in the

location currently proposed could also adversely affect operations at the

Southdown Site, including electricity substation switchrooms and the

Transpower control and relay room. Substations are equipped with protective

devices which eliminate, (or reduce the effects of) electrical faults. Protective

devices are found as protection relays in relay rooms, as well as on power

transformers (known as Buchholz relays). Earlier built substations are

equipped with first generation electromechanical type relays. These types of

relays are sensitive to vibration and may trip inadvertently under vibration

conditions. Similarly, the transformer Buchholz relay contain mercury switches

which are also sensitive to vibration.

Mercury needs 24-hour access to, from and through the Southdown Site and

has no certainty that such access could be maintained if the East West Link

was located where it is currently proposed

61. For Solar Research and Development Centre activities and the maintenance,

repair and, if security of supply is threatened, future operation of the

Southdown Power Station, Mercury needs both:

(a) daily access (including the ability for heavy vehicles) to turn into the

Southdown Site from Hugo Johnston Drive, to move throughout the

Southdown Site and to turn both left and right onto Hugh Johnston Drive

or any replacement road connected to the Southdown Site; and

(b) albeit less frequently, access to and from and access routes throughout

the Southdown Site for specialist heavy vehicles to enable movements

associated with the installation, removal and maintenance of electricity

infrastructure including transformers, gas turbines and generators.

62. The access for heavy vehicles and specialist heavy vehicles needs to ensure

that there are adequate clearances both:

(a) between the vehicles (and any loads they carry) and Transpower’s

National Grid lines to comply with New Zealand Electrical Code of

Practice for Safe Distances (NZECP 34:2001); and

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(b) between any road, shared pathway, bridge structure, power station

structures and buildings to allow access and use of any vehicles for

maintenance/repair works on the Southdown Site.

63. Mercury also has legal obligations to ensure that Transpower, First Gas and

KiwiRail retain access to their assets located at the Southdown Site at all

times.

64. The documentation lodged with the notices of requirement and resource

consent applications does not demonstrate how the existing vehicle access

into and within the Southdown Site will be retained, or modified, so as to retain

adequate and acceptable access. It also does not adequately demonstrate

how access to the Southdown Site would be maintained during construction of

the East West Link.

65. Nor is it clear from that documentation how vertical clearances from National

Grid lines within the Southdown Site would be maintained or whether laden

heavy vehicles used on the Southdown Site would be able to comply with

NZECP 34:2001.

66. These are not issues that can be adequately addressed later through NZTA

preparing management plans or undertaking detailed design at some later

date. NZTA needs to adequately demonstrate to the Board of Inquiry that it

would be possible and practicable to retain the necessary 24-hour and laden

heavy vehicle access to, and within, the Southdown Site.

67. Further, even if a design could be developed that would initially provide the

required access, NZTA having a designation across the Southdown Site would

mean that at any later time NZTA could potentially:

(a) rely on that designation to seek to change the layout of access to, or

through, the Southdown Site; and/or

(b) use its powers under section 176 of the RMA to seek to impose

restrictions on access to the Southdown Site if it considered that that

access could prevent or hinder the East West Link.

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68. Iain Carlisle’s evidence further discusses the potential impacts of the East

West Link proposal, if it is constructed in the location currently proposed, on

access to, from and through, the Southdown Site.

Mercury’s ability to benefit from the Transpower, KiwiRail and First Gas

infrastructure located at the Southdown Site would be compromised if the East

West Link proposal was constructed in the location currently proposed

First Gas’ high pressure gas pipeline is essential to enable Mercury to re-start

and operate the Southdown Power Station

69. As I discussed earlier in my evidence, the Southdown Power Station connects

to a high pressure gas pipeline owned by First Gas. The main gas line and

point of connection (currently isolated) are both located within the Southdown

Site. If the East West Link was constructed in the location currently proposed,

the point of connection and main gas line would be located beneath the road

structure. (This is evident by the First Gas “pigging station”, which is identified

in Attachment Two). Without secure access to the main gas line, Mercury

would be unable to re-start and operate the Southdown Power Station.

70. It is not clear from the information that NZTA has provided in support the East

West Link proposal whether the existence of the East West Link in this location

will necessitate this gas infrastructure to be modified nor how NZTA intends to

mitigate effects of its proposal to ensure Mercury is able to retain continuity of

access to the gas connection for the Southdown Power Station.

Access to the National Grid at the Southdown Site is essential to enable the

Southdown Power Station to re-start and operate and access to, and safe

clearances from, the National Grid assets need to be maintained

71. Transpower owns National Grid conductor lines and a substation located at the

Southdown Site. The National Grid conductor lines traverse the northern side

of the Southdown Site. An 11kV switchroom and Transpower control and relay

room are located near the eastern boundary of the Southdown Site, which is

located within the designation area, north of the proposed road structure.

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72. The Southdown Power Station connects to Transpower’s substation, which in

turn connects to the National Grid transmission network. Therefore,

Transpower’s infrastructure assets at the Southdown Site provide functional

support and essential services to the Southdown Power Station and are critical

assets to Mercury. Connection to the National Grid would also be important for

any other electricity, or electricity-reliant infrastructure that could be developed

on the Southdown Site in the future.

73. The currently proposed East West Link designation would cross over

Transpower’s easement for access to the Southdown Site. The East West

Link proposal does not include any indication as to how replacement access to

Transpower’s assets on the Southdown Site would be provided.

74. The effects of the East West Link proposal on Transpower’s conductor lines is

uncertain as there are no elevation drawings which show the proposed vertical

clearances between the existing National Grid conductor lines and the

proposed highway.

75. As discussed earlier in this evidence, it is not clear how the required vertical

clearances between Mercury’s assets within the Southdown Site and

Transpower’s conductor lines would be maintained or whether laden heavy

vehicles used by Mercury on the Southdown Site to maintain or operate the

Southdown Power Station would be able to comply with NZECP 34:2001.

76. While, from NZTA’s primary evidence, it appears that negotiations have been

progressing with Transpower, currently Mercury has not seen anything which

provides it with any assurance that the proposed East West Link alignment

would enable it to comply with NZECP 34:2001. Mercury’s preferred

requirement is that the minimum approach distance between any mobile plant

(or laden vehicle) and any live overhead electrical line (such as at the entrance

to the Southdown Site and on Hugo Johnston Drive) be ‘at least 4.0 m’. (This

would necessitate a total clearance between Transpower’s 220KV conductor

lines (which run East West across the Southdown Site) and the ground of 9.1m

due to the maximum height of a laden heavy vehicle being 5.1m). This is in

accordance with NZECP 34: 2001 Section 5.2.1. A least preferred option would

be a reduced minimum approach distance of 2.2 m. The latter is in accordance

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with Table 6 within Section 5.4. This reduced minimum approach distance

requires a consent from Transpower. Ian Carlisle’s evidence outlines

specifications of heavy vehicles and electrical infrastructure that will, from time

to time, need to be shifted.

The KiwiRail substation at the Southdown Site would need to re-locate under

the current East West Link proposal

77. KiwiRail owns and operates a substation yard on the Southdown Site which is

within the footprint of the proposed designation. This substation enables

electric trains to operate and is an important asset for Auckland’s transport

infrastructure. It also contributes to the efficient co-location of electricity

infrastructure at the Southdown Site.

78. If NZTA’s designation was confirmed in the location currently proposed, the

KiwiRail substation would need to be replaced prior to the existing substation

being decommissioned and dismantled. NZTA’s primary evidence suggests

that it is possible (but at this stage it is not certain) the KiwiRail substation

could be re-located within the Southdown Site. However, there is no

assessment in that primary evidence as to whether or not the re-location site

for the KiwiRail substation that NZTA is contemplating would adversely affect

the activities of other infrastructure providers on the Southdown Site. This is

particularly problematic as the Southdown Site is already constrained.

Locating and constructing the East West Link highway and shared pathway as

proposed in the airspace above the Southdown Site would create safety risks

for the general public and workers onsite which, to date, NZTA has not

adequately assessed

79. Mercury, its Board, leadership and people are committed to the safety and

health of everyone we work with. We are committed to excellence in the

management of our work environment, and procedures to provide for the

safety and health of all our team and surrounding communities. We have a

company goal of zero-harm.

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80. Mercury has concerns in relation to:

(a) the safety of future users of the proposed highway (including users of the

proposed shared pedestrian/cycle pathway) through, and in the vicinity

of, the Southdown Site;

(b) the safety of workers at, and visitors to, the Southdown Site during the

construction of the proposed East West Link; and

(c) the safety of workers at, and visitors to, the Southdown Site post the

East West Link construction caused by accidents on and/or debris falling

from the East West Link.

If the Southdown Power Station was re-started and operated there would be

safety risks to users of an East West Link highway/shared pathway in the

location that is currently proposed

81. Co-location of the proposed East West Link highway with the Southdown

Power Station raises a number of potential safety risks that require a proper

evaluation. Some of these risks are of low probability but of high

consequence. All of the parties who own and operate infrastructure on the

Southdown Site are obligated to manage safety risks to ensure public safety.

Such risks were not adequately assessed prior to selecting the proposed route.

The following potential risks have been identified and there may be others.

82. If the Southdown Power Station is re-started and operated then it will emit heat

in close proximity to the currently proposed location of the highway during

startups and shutdowns of Gas Turbine 105. The emission of heat is a normal

aspect of gas turbine operation and is necessary to eject excess air produced

by the air compressors during startups and shutdowns. Despite the heat

release presenting a relatively low risk to personnel (temperatures of the

released air is around 32°C) the highway would create a new risk which does

not currently exist due to the Southdown Site currently being remote from any

publicly used infrastructure.

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83. Operation of the Southdown Power Station could involve frequent start-ups

and shut-downs. Each time the plant starts-up it discharges natural gas and

creates a short duration but very loud noise. This is also part of standard gas

turbine operation and is caused by the gas relief valves opening to release

natural gas to the atmosphere. The location of the valves (and release points

of the gas) is on top of the gas turbine packages so if the East West Link

proposal proceeded in its current location they would be very close to the road

level of the proposed highway. To users of the highway/pedestrian walkway

the noise would likely sound like a loud rifle discharging and might startle users

and cause a significant distraction to drivers. The gas release would likely only

be detectable (via smell) to highway users when ambient air conditions meant

the released gas travelled in the direction of the highway and did not dissipate

quickly. However, a low probability but high consequence risk would arise if an

overheating vehicle were to stop on the highway adjacent to the Southdown

Power Station when a gas discharge was emitted and this moved towards the

vehicle. This would create an explosion risk.

84. Should the Southdown Power Station be restarted without the East West Link

proposal in place, the discharges of natural gas and the noise generated would

not present any material risk to people or plant and would, therefore, not

require any specific controls to be implemented.

85. Disc failure from operating, gas turbines and generator rotor end cap ruptures,

could result in a high energy explosion. Gas turbines rotate at very high

speeds (high pressure rotor at 11,000rpm and low pressure rotor at 3600rpm)

and should a catastrophic failure of a gas turbine occur components from

within the turbine casing could turn into fast moving projectiles and propagate

towards the proposed highway. Similarly, failure of the generator rotor end

caps (which hold the rotor bars within the generator in place) can lead to

excessive vibrations in the generator which can lead to generator bearing

failure and subsequent catastrophic failure of the generator. In this low

probability but high consequence scenario the generator rotor, spinning at

3600rpm and weighing approximately 14 tonnes, could also turn into a fast

moving projectile.

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86. If the East West proposal was located where it is currently proposed, any such

explosion could put human life at risk and potentially damage the structural

integrity of the proposed road/pathway.

87. Should the Southdown Power Station be restarted without the East West Link

proposal being located where it is currently proposed, the risks associated with

disc and/or generator end cap failure are considerably lower due to the current

remoteness of the Southdown Power Station from high intensity land uses.

88. Thermal power stations and electricity infrastructure activities (including battery

storage at the Solar Research and Development Centre) have inherent fire

and explosion risks due to the presence of a range of flammable products

being on site (e.g. high pressure natural gas and oil) and due to batteries

containing elements that chemically react together to release electrical energy

(and heat). Mercury (and other infrastructure providers located on the

Southdown Site) comply with all relevant statutory requirements and codes of

practice to reduce the risk of fire and manage any impacts should a fire

occur. These include limiting access to specific areas of the Southdown Site,

limiting access to parts of the Southdown Power Station when the gas turbines

are operating, and maintaining deluge and fire suppression systems

throughout the Southdown Site. These systems and controls would be

operable irrespective of whether the East West Link was built but ensuring the

safety of members of the public who have unrestricted access to a nearby

public highway and walkway following a fire or explosions that occurs despite

these controls needs consideration.

89. Mercury seeks that the Board of Inquiry require NZTA to undertake a full safety

risk assessment to identify and evaluate all of the potential risks that may arise

from co-location of the Project and the electricity related infrastructure on the

Southdown Site. The assessment should also specify mitigation measures

that can be implemented to mitigate those risks. If public safety cannot be

mitigated through design, Mercury recommends the Board decline the

Designation.

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90. As Damian Phillis discusses in his evidence, locating a high intensity land use

such as the East West Link proposal in such close proximity to a facility such

as the Southdown Power Plant is not appropriate from a risk management

perspective.

There would be safety risks to workers and visitors at the Southdown Site from

the construction of the East West Link project

91. The Southdown Site is a secure site (with a perimeter fence and controlled

entry) which is not accessible to the general public. Establishing temporary

construction access through, or adjacent to, the Southdown Site could

compromise security and make it easier for members of the public to access

the Southdown Site. Mercury would be unable to ensure that members of the

public illegally accessing the Southdown Site complied with its safe access

requirements. This would put the safety of both those members of the public,

and workers and other visitors at the Southdown Site, at risk.

92. There would also be significant safety risks to workers (including East West

Link workers) and visitors to the Southdown Site if East West Link construction

activities compromised the earth grid at the Southdown Site. The earth grid

provides protection to people (and electricity assets) in the event of an earth-

related electrical fault:

(a) The earth grid is an interconnected network of underground earthing

conductors. All electrical and metallic structures within the Southdown

Site are directly or indirectly electrically connected to the earth grid.

These include plant and equipment in both the power station and

substation areas.

(b) An earth-related electrical fault is a condition where current flows from

one or more live conductors to earth or ground. In other words – one or

more live conductors become bridged or shorted to earth or ground. This

fault current results in a voltage rise which is dependent on the

resistance of the current flow path.

(c) If an earth-related fault occurs at the Southdown Site, the earth grid will

protect the safety of people. The manner in which an earth gird protects

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personnel is that it provides an alternate low resistance path for earth

related fault currents to flow. So, when a person is in physical contact

with a plant item or metallic object containing fault current, the fault

current is diverted away from the body’s high resistance to the earth

grids low resistance path. A lower fault current will result in a lower

voltage across the person’s body; thereby reducing the probability of

electrocution.

(d) Any reduction to, or reconfiguration of, the earth grid at Southdown could

reduce the effectiveness of the grid, which would mean people onsite

would not be protected from a fault.

(e) Intrusive works associated with the construction of the East West Link in

the location currently proposed, such as driving piles for the proposed

bridge structure, would result in sections of the earth grid to be

electrically bypassed or disconnected. If sections of the earth grid are

disconnected or bypassed, this will reduce the resistivity of the overall

grid, meaning people on the Southdown Site may not be safe were a

fault to occur.

93. Further, metallic (conductive) infrastructure forming part of the proposed East

West Link could significantly adversely affect the earth grid performance.

94. Other potential electrical risks include:

(a) The First Gas pipeline, or metallic water, stormwater, or wastewater

pipes at the Southdown Site, being re-routed (either temporarily or

permanently) so that they run close to, or parallel with, an electrical

source. During an electrical fault involving an earth related fault, the fault

current returns to its source or generating point. During its return, it

attempts to flow along a path of least resistance. Metallic objects such as

a pipeline, have lower resistance than the earth path. Therefore,

pipelines appear attractive for the fault current to travel along. The

portion of fault current flowing along the pipeline will increase the touch

voltages on, and step voltages surrounding the pipeline. These voltages

depend on the magnitude of fault current, the proximity of the pipeline,

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and the resistance of the earth and resistance of the pipeline. If

sufficiently high, these voltages can be dangerous and sometimes fatal.

(b) Changing the layout of the existing fences at the Southdown Site which

are earthed to the earth grid. As discussed in (a) above, during an

electrical fault involving an earth related fault, the fault current returns to

its source or generating point. During its return, it attempts to flow along

a path of least resistance. Metallic objects such as fences have lower

resistance than the earth path. Therefore, fences appear attractive for

the fault current to travel along. The portion of fault current flowing along

the fence will increase the touch voltages on, and step voltages

surrounding the fence. These voltages depend on the magnitude of fault

current, the proximity of the fence, and the resistance of the earth and

resistance of the fence. If sufficiently high, these voltages can be

dangerous and sometimes fatal. Note that wooden or plastic fences have

high resistances and therefore do not pose a threat.

(c) Proposed excavations at 141-199 Hugo Johnston Drive for the

construction of the East West Link project would disturb an area known

to contain asbestos. This site is located approximately 120 metres from

the Southdown Site. Mercury is concerned that this disturbance would

create safety risks for workers and visitors at the Southdown Site. Bruce

Graham’s evidence discusses the risks from airborne asbestos and the

measures likely to be needed to safely undertake the proposed

excavations at 141-199 Hugo Johnston Drive.

NZTA’s evidence appears to be based on the mistaken assumption that the

Southdown Power Station will never re-start

95. In her evidence on NZTA’s assessment of alternative alignments for the East

West Link project, Amelia Linzey comments that:

(a) “consideration was given to the effects on utilities including the

significance of the ‘Mercury Energy site’ (referred to as Mighty River

Power site in the MCA workshop) …”

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(b) “[w]ith the exception of the issues raised by Stratex, in respect of

potential business disruption, nothing in [the submissions on the

alternatives assessment] changes the conclusions or opinions expressed

in my evidence.”

96. However, as discussed in Nick Grala’s evidence, it appears that in undertaking

its assessment of its initial long-list of 16 options for the alignment of the East

West Link proposal NZTA did not consider the impacts on Mercury’s

infrastructure and the Southdown Site.

97. While it was prior to my involvement with this project, I understand NZTA only

engaged with Mercury on the East West Link proposal after NZTA had

completed its assessment of the long-list of 16 options. The four options NZTA

presented to Mercury all passed through the Anns Creek area and all passed

over the Southdown Site to some extent.

98. Further, it appears that when NZTA undertook its final analysis of options for

the alignment of the East West Link proposal in the Anns Creek area it

undertook that assessment on the mistaken assumption that the Southdown

Power Station would never re-start.

99. The ‘Supporting Material for the Consideration Alternatives’ in technical and

assessment Report 1 accompanying the Assessment of Effects on the

Environment for the East West Link proposal, which Ms Linzey relies on,

includes the statements:

(a) “The current Anns Creek alignment (Detailed Business Case, DBC

Option 1) was chosen to avoid the Mighty River Power site. …

Subsequent information available suggests that the Mighty River Power

station is closing down and the property might be available for purchase.

This allows for alternative alignments to be investigated that could pass

through this property. Two subsequent options have been investigated

and presented.”1

1 Report 1, Appendix J, Workshop Information Packages, Page 2 of 15.

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(b) “The post-industrial character [of the Anns Creek area] is reinforced by

the presence of the defunct Mighty River Power Station” [emphasis

added]. 2

100. This mistaken assumption would explain why there are absolutely no

references to safety issues relating to the relative proximity of different

alignments to an operating thermal generation plant in that alternatives

assessment.

101. Similarly, Noel Nancekivell’s evidence states “[t]he Power Plant is currently not

being operated and the cooling towers will be demolished as part of the Project

as they are no longer required” [emphasis added].3

102. This mistaken belief that the Southdown Power Station is no longer required

has coloured Mr Nancekivell’s view that the best way to “balance [the]

constraints” on the alignment through the Anns Creek is to take the alignment

through, and demolish, part of the Southdown Power Station. There is nothing

in his evidence that discusses the safety implications for users if a highway and

shared path was located in close proximity to an operating thermal generation

power station.

103. As I have set out earlier in my evidence:

(a) there may be a need to re-start and operate the Southdown Power

Station; and

(b) retaining the option of being able to re-start and operate it is important

for the security of New Zealand’s (particularly Auckland’s) energy supply.

2 Report 1, Appendix L, MCA Outcomes for Alignment Options, East West Link – Multi-Criteria Analysis – Anns Creek

Outcomes Report, Natural Environment, Natural Landscape/Character assessment, no page number.

3 Statement of Primary Evidence of Noel Nancekivell on behalf of the New Zealand Transport Agency, para 10.34.

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104. In discussions between NZTA and Mercury that took place prior to NZTA

lodging its primary evidence, Mercury informed NZTA that it needs to retain the

ability to re-start and operate the Southdown Power Station. Given that, I am

surprised that NZTA has lodged primary evidence that fails to:

(a) acknowledge that during the final stage of its assessment of alternatives

for the alignment of the East West Link in the Anns Creek area it

assumed that the Southdown Power Station was defunct and would

never re-start; or

(b) re-assess the alternative alignments in that area given that it knows that

its assumption was incorrect.

NZTA is proposing that determining how to avoid, remedy or mitigate many of

the significant adverse effects of the East West Link proposal should occur

later, outside the Board of Inquiry process

105. The approach taken in NZTA’s evidence to works that would be needed at the

Southdown Site is that those are matters of detail which NZTA will sort out later

outside the Board of Inquiry process.

106. For example, Mr Nancekivell’s evidence states:4

“The relocation and/or protection of network infrastructure is a normal

part of construction for a project this scale. There are well-established

procedures across the industry associated with the relocation and/or

protection of network utilities. The Project Team has engaged with

network utility operators to identify where relocation and/or protection is

required during construction and operation of the Project. Any adverse

effects can be appropriate managed either by providing protection or

by re-locating the utility. Where practicable, the necessary mitigation

works will be undertaken as enabling works to the main Project

construction works. …”

4 Nancekivell above, para. 7.20.

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107. Similarly, Lesley Hopkins’ evidence states: 5

“There are well-established procedures across the industry to manage

potential adverse effects on network utilities. I consider that the

proposed Network Utilities Management Plan developed in liaison with

the relevant network utility operators is an appropriate tool to document

the procedures to be implemented during construction”.

108. While Ms Hopkins’ evidence contains proposed conditions for addressing the

Transpower National Grid lines, the KiwiRail substation and the First Gas

pipeline, there is nothing in the proposed conditions which specifically

addresses either the Southdown Power Station or Mercury’s Solar Research

and Development Centre.6

109. Mercury does not agree that addressing the impacts of constructing a project in

very close proximity to a thermal generation power station and a Solar

Research and Development Centre is a ‘normal’ part of a roading project. Nor

are there any ‘well-established’ procedures for addressing the effects of

roading projects on either thermal generation power stations or solar research

and development facilities.

110. Andrea Rickard’s evidence proposes that the effects of the project on

established activities that already have RMA authorisations (including the

Southdown Power Station) should be addressed after the East West Link

proposal is “confirmed” and as part of property negotiations.7 She is not only

proposing that this approach be adopted in relation to submitters where high

level agreements as to a proposed approach to addressing effects have been

reached, but also in relation to submitters, such as Mercury, where no

agreement has been reached.

5 Statement of Primary Evidence of Lesley Ann Hopkins on behalf of the New Zealand Transport Agency, 12 April

2017, para. 8.95. I note that NZTA is proposing that the Network Utilities Management Plan not require certification

from Auckland Council, Hopkins, para. 11.31.

6 Hopkins above, Attachment A pages 16-18.

7 Statement of Primary Evidence of Andrea Rickard, paras 23.6 and 23.7.

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111. Ms Rickard’s proposed approach would also inappropriately put Mercury on

the ‘back foot’ in property negotiations as:

(a) Mercury would have to negotiate with someone who already had an

RMA authorisation to seek to get the significant adverse effects that

would be caused by the East West Link project addressed; and

(b) if no property agreement could be reached, then there would be no

obligation on the NZTA to avoid, remedy or mitigate those effects.

112. Adopting this proposed approach would also mean that the issue of the

appropriate avoidance, remediation and mitigation of a range of significant

adverse effects on the existing environment (including effects on the

Southdown Power Station and Mercury’s Solar Research and Development

Centre) were not considered by the Board of Inquiry and instead became a

matter of negotiation between two interested parties. The Board could have no

certainty that what was included in a negotiated agreement between two

parties would appropriately address the impacts on all affected parties.

Mercury seeks a change to alignment of the East West Link in the vicinity of the

Southdown Site or for the notice of requirement and associated resource

consents to be declined

113. For the reasons set out in this evidence Mercury opposes the selected route

contained within Notice of Requirement 1: New designation from SH20 at the

Neilson Street Interchange to SH1 at the Mt Wellington ramps designation and

the associated resource consent applications.

114. Mercury requests that either:

(a) NZTA is required to provide the Board of Inquiry with a new assessment

of the options for the alignment of the East West Link project in the

vicinity of Anns Creek which takes into account:

(ii) the national and regional importance of both retaining the option

of being able to re-start and operate the Southdown Power

Station and the solar research and development activities carried

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out at the Southdown Site (including the potential for those solar

generation activities at the Southdown Site to be developed

further in future); and

(iii) the safety impacts of different alignments given that the

Southdown Power Station could be re-started in future; and

the East West Link proposal be modified so that the alignment of the

proposal through the Anns Creek area does not cross the Southdown

Site; or

(b) that the Notice of Requirement and related applications for resource

consents be declined.

James Kennedy Flexman

10 May 2017

Attachments:

(i) Attachment One – Extent to which the proposed designation affects the

Southdown Site

(ii) Attachment Two – plan of the Southdown Power Station infrastructure at the

Southdown Site

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Attachment One – Extent to which the proposed designation affects the Southdown Site

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Attachment Two – plan of the Southdown Power Station infrastructure at the Southdown Site