In the Environment Court ENV-2011-CHC-090 Christchurch Registry. Under the Resource Management Act Meridian Energy Limited

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1 1 In the Environment Court ENV-2011-CHC-090 Christchurch Registry Under the Resource Management Act 1991 and in the matter of direct referral of an application for resource consents by Meridian Energy Limited in respect of the Project Hurunui wind farm proposal under section 87G of the Resource Management Act 1991 Between Meridian Energy Limited and Hurunui District Council and Canterbury Regional Council Statement of Evidence in Chief of Russell John Maunder on behalf of Meridian Energy Limited January 2012

2 Table of Contents Introduction Page 01 Truescape Scope of work Page 02 Code of Conduct Page 04 Scope of Evidence Page 05 Viewpoint Locations Page 05 A3 TrueView Booklet Page 07 Digital Terrain Simulation Page 08 Timelapse simulation Page 09 Zone of Theoretical Visibility Page 10 Methodology and Limitations Page 11 Validation of Truescape Methodology Page 11 Site Visit Page 13 Capturing Survey Reference Points Page 14 Aligning Survey Reference Points Page 15 Building proposed Project in 3D Page 16 Final Simulation Page 18 Responses to issues in submissions Responses to issues in Officers report Conclusions Appendix 1 Page 19 Page 20 Page 20 Page 22 Truescape Credentials

3 1.0 Introduction: 1.1 My full name is Russell John Maunder 1.2 I am the Operations & Production Manager for Truescape Limited (Truescape) and I am the Project Manager for the Project Hurunui Wind simulations. 1.3 I am a computer simulation specialist and prior to joining Truescape I worked in the architectural visualisation industry for 6 years. I hold a Bachelor of Building Science (hons) from the Victoria University of Wellington and have 10 years experience in the 3D visual simulation industry. I have been involved in a number of different visualisation projects, some of which have been outlined below and range from photo-simulations for simple projects to full visually simulated 3D environments. These projects have been presented as part of consenting applications, permitting applications, and consultation across New Zealand, Australia and in the United States and Canada. Bluewater Wind, Offshore Wind Farm, Maryland, USA; Permitting Hearing; Bluewater Wind, Offshore Wind Farm, New Jersey, USA; Permitting Hearing BBP Alternative Energy, White Pines Project, Michigan, USA; Permitting Meridian Energy, Project Mill Creek, Council Hearing Shell Wind Energy Inc, New York State, USA; Preliminary Planning; Roaring 40s, Wind Farm; Australia, Consultation Statement of Methodology Page 1 of 22 JANUARY 2012

4 Acciona, Allendale Wind Farm; Australia, Planning Application; Meridian Energy, Project Central Wind, Council Hearing; Meridian Energy, Project Central Wind; Environment Court; WestWind Energy, Australia, Permit Application; Pacific Hydro, Yaloak South Wind Farm, Australia, Panel Hearing. Acciona Wind Farm Hearing, Adelaide Australia. The credentials of Truescape are attached to my evidence as Appendix I have played an integral part in refining the methodology behind the accurate simulation technology used to produce the simulations before the hearing panel today. Statement of Methodology Page 2 of 22 JANUARY 2012

5 2.0 Scope of Truescape Work on Hurunui Wind: 2.1 Meridian Energy Ltd (Meridian) engaged Truescape in September 2009 to produce computer simulated visual aids to assist with consultation, communication, and the visual assessment of Project Hurunui Wind under the direction of Mr Peter Rough of Peter Rough Landscape Architects Limited (now Rough and Milne Landscape Architects Limited). To this end, the following was generated: A series of Zone of Theoretical Visibility maps (ZTV); 5 Animated Timelapse simulations showing the proposed wind farm across the course of an entire day; A series of A3 simulations based on the TrueView technology that accurately show the proposed wind farm from public photo points; A series of Digital Terrain Model (DTM) simulations used to select locations for the photosimulations; A series of A3 simulations based on the TrueView technology that accurately show the proposed wind farm from private properties to assist with consultation. 2.2 Any visual assessment should only be made from the full size A3 TrueView Booklets viewed on site and correctly and at a distance of 0.8m or the timelapse simulations. 2.3 All A3 TrueView Booklet simulations include models of the proposed Project Hurunui Wind turbines, substation, access roads, and transmission lines as seen from each viewpoint location. Statement of Methodology Page 3 of 22 JANUARY 2012

6 2.4 The simulations are a tool to assist with the visual assessment of Project Hurunui Wind 2.5 The A3 TrueView Booklet simulations provide a geometrically accurate representation of scale when viewed at 0.8m from the image. This view has a single fixed focal point and a smaller field of view than the primary human field of view. 2.6 A reference photograph showing the full primary human field of view that is 124º horizontal and 55º vertical at each viewpoint location has been provided with each simulation. 2.7 The Digital Terrain Model simulations are static simulations generated entirely from the digital terrain model using the contour data. They are intended to provide guidance to assist the viewer in understanding, in very general terms, the location and visibility of the proposed wind farm. They do not represent the primary human field of view. 2.8 The scope of Truescape s work does not extend to the assessment or interpretation of the simulations for issues relating to the proposed wind farm s visibility and its landscape and visual effects. Mr Peter Rough addresses these issues in his statement. 3.0 Code of Conduct: 3.1 I confirm that I have read the Code of Conduct for Expert Witnesses contained in the Environment Court Consolidated Practice Note I agree to comply with this Code of Conduct. In particular, unless I state otherwise, this evidence is within my sphere of expertise and I have not omitted to consider material facts known to me that might alter or detract from the opinions I express. Statement of Methodology Page 4 of 22 JANUARY 2012

7 Scope of Evidence 3.2 Viewpoint Locations Location maps referencing simulations included in the graphic attachment that forms part of the statement of Peter Rough Location map referencing publically accessible simulations Statement of Methodology Page 5 of 22 JANUARY 2012

8 3.2.3 Location map referencing simulations at the Tipapa property. Location map referencing the Timelapse simulations Statement of Methodology Page 6 of 22 JANUARY 2012

9 3.3 A3 TrueView Booklet The A3 TrueView simulations in the graphic attachment comprising part of Peter Rough s evidence provides an easy to use on-site tool that shows the proposed wind farm project The simulations in the graphic attachment should be viewed at a distance of 0.8m to match the scale of the scene Each A3 simulation represents a portion of the full primary human field of view comprised of two sheets, a digital terrain model, and a transparent overlay showing foreground vegetation and buildings The information page attached to each simulation provides a reference photograph of the full primary human field of view seen at each viewpoint. Statement of Methodology Page 7 of 22 JANUARY 2012

10 3.4 Digital Terrain Simulation Digital Terrain Model simulations are an indicative depiction based on land form topography only and do not include clutter objects such as vegetation and houses etc The accuracy of the Digital Terrain Model Simulations fall within the accuracy levels of the terrain data that was used to generate them The 5m contour data has an accuracy of m and the 20m contour data has an accuracy of +- 10m Digital Terrain Model Simulations are static simulations generated using the contour data only. The turbines, access tracks, pylons, and substation are then placed accurately onto the model and the images are then generated. Statement of Methodology Page 8 of 22 JANUARY 2012

11 3.5 Timelapse Simulation The Timelapse Simulation depicts how the proposed wind farm will be experienced during the course of an entire day, and reflects accurately the exact sunlight and climatic conditions experienced at the time of photography The directional data of the wind is also captured, and is reflected in the movement of the turbines which are turning between 9-15 revolutions per minute whilst also positioning themselves into the prevailing wind in accordance with the wind data Capturing a photograph every 15sec during the course of an entire day allows all climatic conditions to be accurately communicated. Statement of Methodology Page 9 of 22 JANUARY 2012

12 3.6 Zone of Theoretical Visibility The ZTV maps are generated using industry standard software The model is based on terrain data only and does not account for any vegetation or built objects Statement of Methodology Page 10 of 22 JANUARY 2012

13 4.0 Methodology and Limitations 4.1 Validation of the Truescape methodology I have attached below some post construction analysis of the Project West Wind wind farm that compared a simulation submitted at the Mill Creek Council hearing built using the construction layout plan against the completed project. These simulations demonstrate the accuracy of the TrueView simulations. In particular, it can be seen that the size and placement of the turbines in this simulation is identical to the wind farm that was constructed. It should be noted that the turbines in the simulation seem more obvious than the actual turbines in the photograph due to the atmospheric conditions experienced on the day the photograph was taken The simulation and photograph were produced 2 years and 7 days apart and both are taken at the same time of day so as to produce the same lighting and shadow conditions. Statement of Methodology Page 11 of 22 JANUARY 2012

14 SIMULATION OF PROJECT WEST WIND PRE CONSTRUCTION (February 2008) PHOTOGRAPH OF PROJECT WEST WIND POST CONSTRUCTION (February 2010) Statement of Methodology Page 12 of 22 JANUARY 2012

15 4.2 The Site Visit: The site visit is undertaken to take the necessary photographs and ground mark the viewpoint position and identify additional reference points to enable the surveyor to survey fix the exact location of the camera A digital SLR 1:1 21 mega pixel camera is used to take the photography. This camera produces photographs at a resolution and clarity as good as current technology will allow when generating simulations. Statement of Methodology Page 13 of 22 JANUARY 2012

16 4.3 Capturing the Surveyed Reference Points To accurately create a TrueView photo simulation the exact position of the camera is survey-fixed by a surveyor Additional reference points are identified during the site visit so that the 3D model can be accurately placed into the photograph. These reference points include things like fences, vegetation, houses and roads. The surveyor is directed to each of these points. Statement of Methodology Page 14 of 22 JANUARY 2012

17 4.4 Aligning the Surveyed Reference Points The next step is to construct the 3D computer model. Using Autodesk 3ds Max 3D computer simulation software the survey-fixed photo and reference points are imported into the 3D model. A computer camera is created to simulate the camera that captured the original photographs, including matching the focal length. The simulated computer camera is then positioned at the same survey coordinates as the physical viewpoint positions. Statement of Methodology Page 15 of 22 JANUARY 2012

18 4.5 The photographs are then incorporated into the computer model. This is done by correctly aligning the computer camera to match the surveyed reference points to the reference objects, and to the terrain if required. 4.6 Building the proposed project in 3D: The proposed development is then modelled in 3D in accordance with all dimensions, site layouts, colours and textures. Statement of Methodology Page 16 of 22 JANUARY 2012

19 4.6.2 The 3D terrain model of the site has been generated using the land contour data. The proposed development (turbines, access tracks, substation, and pylons) have now been modelled in 3D and are now imported and positioned accurately into the scene The simulation software allows the sun to be simulated at the precise time the original photography was captured. This ensures the lighting of the turbines as well as the shadows they cast are an accurate depiction of how the Project would appear in the photograph at the same time of day and reflecting the same climatic conditions as those experienced at the time the photograph was taken. Statement of Methodology Page 17 of 22 JANUARY 2012

20 4.7 The Final Simulation In order to correctly place existing objects that are in front of the 3D model of the development, these foreground objects are overlaid, from the original photograph, onto the computer generated image using photo shop software The final simulation is then printed as an A3 document consisting of a transparent overly, a Digital Terrain Model showing labelled turbines and an information sheet providing viewpoint details and the context of the view. Statement of Methodology Page 18 of 22 JANUARY 2012

21 5.0 Responses to Issues in Submissions We note in submissions from G A H Mclean, A and W Harris and A J Hamilton question the accuracy of our simulations. In reply we reiterate that Truescape has been producing simulations for over 16 years where our simulations have been presented in many hearings both here in New Zealand and overseas. Our simulations have proved to be highly accurate. Many of our simulated projects have now been constructed so for verification of accuracy we have been able to compare the accuracy of our simulations to the real project after construction. We have included an example of such a comparison of a Meridian wind farm project on page 15 of this document. We also note that ME Mclean made a statement in her submission that the accuracy of the simulations are rubbish because the turbine height in their photos was the same height as the test tower. In reply we note that some turbines are higher and some lower than the test tower. We further note that the apparent height difference of any turbine relative to the height of the test tower will vary in each viewpoint due to the differing height and distance of each viewpoint from the objects being viewed. If we look at the simulation from Viewpoint 35 Robert Sloss Residence as an example, the height of the hub of turbine A6 sits just below the height of the top of the test tower which is as it should be from the perspective of this viewpoint. Statement of Methodology Page 19 of 22 JANUARY 2012

22 Turbine A6 Turbine Elevation = 526m Hub Height = 80m Blade tip height = 130.5m Test Tower Tower Elevation = Tower height = 80m 6.0 Responses to Issues in Officer s Report There are no matters identified in the Officer s report relating to visual aids which require a response. 7.0 Conclusions 7.1 I consider that the Zone of Theoretical Visibility (ZTV) diagrams and the Digital Terrain Simulations show the potential visibility of Project Hurunui Wind. Like the photo simulations they are a tool to assist with the assessment of Project Hurunui Wind. They do not reflect any screening from objects such as houses or vegetation. 7.2 I consider that the Animated Time Lapse simulation accurately depicts how Project Hurunui Wind and the surrounding landscape would be experienced when exposed to the same climatic conditions and lighting conditions as those experienced on the day of photography 7.3 I consider that the A3 TrueView booklet simulations are an accurate representation of how the Project Hurunui Wind would look under the same lighting and climatic conditions as those we experienced at the time of Statement of Methodology Page 20 of 22 JANUARY 2012

23 photography and when correctly viewed at 0.8m from the image. Russell Maunder 24 January 2012 Statement of Methodology Page 21 of 22 JANUARY 2012

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