Meridian Energy's scientific analysis of its proposed $2 billion Project Hayes wind farm site was woeful, an Environment Court appeal hearing for the development was told yesterday.

Scientific consultant Brian Patrick, of Alexandra, gave evidence on the proposal as a witness for appellant Ewan Carr.

His evidence included planned mitigation measures and whether they were appropriate.

During cross-examination, Mr Patrick said Meridian's plan to store spoil, including soil taken from the site during construction, in various disposal sites on the proposed 92sq km property would unnecessarily threaten indigenous flora and fauna of the Lammermoor Range.

"If you store spoil on site, you will be covering up natural growth, and by having such large amounts of spoil sitting on site, further areas of flora and fauna will also be threatened.

"Through observation of the site over 26 years, to me it would be incredibly challenging and almost impossible to have adequate sediment traps in the area, and it would create too much of a significant risk," he said.

Mr Patrick said spoil exposed during construction should be trucked off the site to protect flora and fauna, despite the cost of such an undertaking, which he said would be tiny in relation to the overall development cost.

It was estimated about 100ha of spoil would need to be accommodated in sediment disposal sites on the project site, which was a huge amount to be covering indigenous flora and fauna, he said.

"Why are we dying in a ditch over the fact that spoil should remain on site. It's so easy to take off site . . . we've got trucks, we've got roads, let's just take the spoil off site and move on. It would be petty cash for Meridian," he said.

Mr Patrick acknowledged he was not an engineer and said adequate mitigation was a matter of opinion.

During further cross-examination, Mr Patrick criticised Meridian's methods of collecting scientific data at the site, which was used to plan mitigation.

"An ecological assessment already done [by Meridian] for the original resource consent hearing was totally inadequate. I have lost faith in the way Meridian did things in this case . . .

"I certainly don't trust the way Meridian organises its science . . . the way they did it was woeful," he said.

Mr Patrick also said stock should not be grazed on the proposed site after construction, although the property comprised sections of five farms.

"The farmers and property owners are going to get enough money from Meridian for the wind farm; they are not going to need money from sheep. Let's keep this site as good as we can," he said.

Mr Patrick also claimed the wind farm site was located far from the Lammermoor Range, and in fact was situated on lower parts of the Rock and Pillar Range.

"I have no idea why someone somewhere decided to name this site as being on the Lammermoor Range," he said.

Day 32

•Panel: Environment Court Judge Jon Jackson, commissioner Alex
Sutherland, commissioner Heather McConachy, deputy commissioner Ken
Fletcher.

•Yesterday's witnesses: Animator and software developer Craig McNaughton, scientific consultant Brian Patrick.

•Yesterday's closing submissions: CODC lawyer Graeme Todd, ORC lawyer Alastair Logan, Eric and Cate Laurenson, Ian and Sarah Manson, Riverview Settlement Trust lawyer Neville Marquet, CO Recreational Users Forum lawyer Jan Kelly.

•Scheduled for today: Closing submissions will continue.

•Quote of the day: "The upper Maniototo will have imported its very own new-age industrial revolution . . . there is nothing natural about this energy-production landscape." - Neville Marquet