The concept was first tabled at last year's resource consent hearing for the $1.5 billion development on 92sq km of the Lammermoor Range in Central Otago.
Dubbed phase two of Project Hayes, the addition comprised 113 turbines south and west of the Lammermoor Range site.
The extra turbines would be within the Dunedin City Council boundary, on land classed by the council as being of outstanding natural landscape.
Meridian counsel Andrew Beatson told the Project Hayes hearing this week phase two was a "non-starter" as it relied on a plan change by the DCC.
"But you can never say never," Mr Beatson said.
Project Hayes, which comprises 176 turbines, is before an Environment Court appeal hearing scheduled to finish at the end of August.