of the Resource Management Act 1991 IN THE MATTER AND IN THE MATTER of submissions and further submissions by MIGHTY RIVER POWER LIMITED on PROPOSED PLAN CHANGE 15A: RURAL SUBDIVISION STATEMENT OF EVIDENCE OF MILES ROWE FOR MIGHTY RIVER POWER (TABLED) 1. My name is Miles Rowe. I am an Environmental Advisor at Mighty River Power Limited ('Mighty River Power' or 'the Company') responsible for resource management policy matters. I have held this role for over 9 years. I have 19 years of resource management experience gained in both local government and private sector. I hold a Bachelor of Science (Geology) from the University of Canterbury and a graduate Diploma in Applied Environmental Technology from Christchurch Polytechnic. I am a full member of the New Zealand Planning Institute. INTRODUCTION 2. Mighty River Power does not currently operate any windfarms in New Zealand. However, the Company holds consents for two windfarm developments - Puketoi in Tararua District and Turitea in Palmerston North. Both of these projects if constructed would have a combined capacity of up to 490 MW. 3. In addition, Mighty River Power holds all necessary land access agreement and transmission consents for these two windfarm projects. Both projects would be connected to the National Grid via the Linton Substation in Palmerston North. SPECIFIC SUBMISSIONS FOR PLAN CHANGE 15A: RURAL SUBDIVISION 4. Mighty River Power made a number of submission and further submissions on the provisions in Section 7 - Subdivision. Many of these submission points are specifically aimed at avoiding reverse sensitivity effects arising from subdivision activities in proximity to existing or consent windfarms and are addressed in the planner'S report for the Windfarms and Landscapes topic. 24 November 2015 Statement of Evidence of Miles Rowe for Mighty River Power 5. The matters submitted by Mighty River Power relevant to this hearing topic relate to the minimum lots size for the Rural Zone and the rural-residential subdivision overlay. Rural Zone Minimum Lot Size 6. The section 42A report presents a number of valid reasons for increasing the minimum lot size from 4 hectares up to 20 hectares in the Rural Zone. Mighty River Power is supportive of this approach as a means to avoid fragmentation of rural land and ad hoc development of rural residential activities in inappropriate localities. 7. 'Inappropriate localities' in this context can include, amongst other matters, dwellings established in proximity to windfarms, which in turn can lead to reverse sensitivity effects such as noise complaints. Reverse sensitivity effects is a significant and real issue for wlndfarm developments, as It is very difficult to avoid the effect once dwellings are allowed to establish in close proximity to consented windfarms. 8. Avoiding reverse sensitivity effects on consented and on existing renewable electricity generation activities is a matter that decision-makers are required to manage under Policy 0 of the National Policy Statement for Renewable Electricity Generation. 9. It Is noted that increasing the minimum lot size up to 20 hectares will not in Itself prevent dwellings from being established in close proximity to windfarms but it will assist (along with other planning tools) in removing the expectation of property owners or potential owners from having the ability to subdivide and develop small lots in close proximity to windfarms. Rural-Residential Overlav 10. One of the key reasons given in the section 42A report for reducing the extent of the rural-residential overlay is to manage reverse sensitivity effects on consented windfarms. In my view the reasons given in paragraph 6 to 9 above for the minimum lot size remain equally or more valid for reducing the extent of the ruralresidential overlay. 11. There may be grounds for granting additions to the rural-residential overlay but this should only be done where It can be demonstrated (amongst other matters) that it will not lead to reverse sensitivity effects on consented windfarms. Plan Change 15A: Rural Subdivision Page - 2- Statement of Evidence of Miles Rowe for Mighty River Power 24 November 2015 CONCLUSIONS 12. The section 42A report, at paragraph 4.133, states that: "... The shift to a 20ha minimum lot size and the significant reduction in the rural-residential overlay is in it itself a significant change which will reduce the likelihood of further reverse sensitivity effects on existing infrastructure. " 13. I concur with this statement and believe that the Council should not alter the 20 hectare minimum lot size or spatial extent of the rural-residential overlay set out in Plan Change 15A, except where it has carefully considered the consequences, including the potential for reverse sensitivity effects on consented windfarms. Miles Rowe 24 November 2015 Plan Cllange 15A: Rural Subdivision Page - 3-