BEFORE A BOARD OF INQUIRY EAST WEST LINK PROPOSAL IN …€¦ · members of the Board of Inquiry,...
Transcript of BEFORE A BOARD OF INQUIRY EAST WEST LINK PROPOSAL IN …€¦ · members of the Board of Inquiry,...
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