Ronald Beatty, an electrical engineer with expertise in forensic data analysis, wants to give the court a lesson on reading graphs.
"I call this a load profile," he says. "We have 48 metered half-hour periods."
He's used red arrows to show the standing load overnight.
Then about 7.30am, the load starts to increase slightly, "because someone has got up and turned something on" or an automatic appliance has started.
The load has gone up from a bout 0.5kWh to about 0.75 to 0.8kWh.
The difference between those two figures tells us how much additional electricity was being applied, Beatty says.
You can take the shape and super-impose it over other days to see how regular the usage is, Beatty explains.
Harrison Smith moves the witness to his analysis of April 4 and 5, 2021.
Beatty is comparing Sunday March 14 to Monday April 5 (which was Easter Monday, hence the Sunday comparison).
On April 5, there was a standing load until about 6am, when there's a step increase.
Beatty's view is that Polkinghorne rose then and turned on some lights.
"It supports Dr Polkinghorne's statement that he got up and turned some lights on," he says.
About 8am, there's another increase. Beatty says his view is Polkinghorne got up and came down the stairs and – Brian Dickey objects, saying he couldn't know from the power data if he went down the stairs.
Justice Graham Lang agrees and Harrison Smith asks Beatty to stick to his opinion on what the deviations in the graph show.
The increase in load of about 6am was followed by a larger increase about 8am, too great to just be lighting. It needed to be other appliances turned on at 8am, he says.
Beatty can't tell us what appliances specifically were used, he says, but is able to use a list of appliances to determine whether or not they may have been used in that period.
"But it also relies on the history of data," he says, in that the load on Monday April 5 is not too dissimilar to the load on other days.
"It indicates a regular pattern of electricity consumption."
The increase about 8am is consistent with boiling an electric jug, he says.
On Sunday, April 4, there is quite widely divergent electricity consumption during the day and into the night, Beatty says.
During the night period, a big lump on the right of the usage graph, we don't know what's in there, Beatty says, but it's of such a size that it would support the dryer running, the dishwasher and washing machine.
The block at the right of the graph starts at 6pm and runs to 11.30pm.
"That is a lot of electricity to use," Beatty says.
To use that amount, all of those appliances would have to have run.
Smith moves to the April 5, 2021 usage graph, starting at midnight.
Beatty says you can see a minor change in the standing load up until 6am. Some of that would be the underfloor heating switching on and off with its thermostatic control.
Load from a refrigerator would also cycle, as the compressor switches on and off.
"And these variances create a little bit of a ripple," he says.
At 6am, there is an increase beyond the ripple. That tells us extra load was applied then, Beatty says.
It won't have been underfloor heating because that would have been seen earlier, he says.
At 8am, the average load remains higher than what it was overnight, telling us there was additional electrical load that turned on and stayed on, Beatty says.
Then at 8am, there's a "sharp increase in load", the first of two spikes.
That tells us, Beatty says, that someone has turned some more electrical load on.
At 8.30am, the load is turned off.
Asked if the 8am load could have been both the jug and the toaster, Beatty says "we just don't know".
"I noted that the setting on the toaster was down to very low," he says.
The police photo of the jug had condensation showing it had been run.
The photo of the toaster also showed it was set very low, he says.
"The time that the toaster would have actually been on would have been quite limited."
Smith asks about the condensation on the jug again and Justice Lang interjects, asking if he can comment on that as an expert, and Beatty says he can't.