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Submission re MRP Waikato Resource Consent

Resource Management Act 1991 Submission on a Resource Consent Application

To: Waikato Regional Council
PO Box 4010
Hamilton

Attention: Consents Administrator

New Zealand Recreational Canoeing Association (hereinafter NZRCA)
C/o Maree Baker
Conservation Officer
Wanganui

Applicant's name: Mighty River Power Ltd

Consent No

Details of Applications

A land use consent to authorise the use, upgrading and maintenance of structures on the bed of the Waikato River and associated bed disturbances for the purpose to the generation of hydroelectricity and operation of the Waikato hydro system.

A water permit and discharge permit to authorise the damming and diversion of, the take from, and the discharge of water and contaminants to the Waikato River (including any material or energy contained therein) for the purposes of water level control, the generation of hydroelectricity and operation of the Waikato hydro system.

A land use consent to authorise the use, upgrading and maintenance of ancillary structures (including boat ramps, monitoring equipment and booms) on or over the bed of the Waikato River for the purposes of access, monitoring and weed, oil and public safety management associated with the operation of the Waikato hydro system.

Location of Application: Bed of the Waikato River between Taupo gates and Karapiro dam.

The NZRCA opposes the application.

Submission

  1. Introduction

    1. The New Zealand Recreational Canoeing Association (hereinafter NZRCA) is the national representative organisation of canoe clubs throughout New Zealand. The NZRCA is an incorporated society and is affiliated to the New Zealand Canoe Federation, which in turn is affiliated to the International Canoe Federation.
    2. The NZRCA represents both individual members and affiliated member clubs. Currently there are approximately 20 member clubs affiliated to the NZRCA. The total number of canoeists in New Zealand greatly exceeds the number of members of the NZRCA and the numbers are continuing to increase. Outdoor recreation programs at polytechnics along with many high schools and outdoor education centres now all include canoeing in the syllabus.
    3. The NZRCA has the delegated authority to represent the New Zealand Canoe Federation on conservation issues.
    4. The NZRCA is committed to long-term sustainable management of New Zealand's water resources. The association is a nationally recognised body that has continued to be actively and constructively involved in resource management processes.
    5. The NZRCA has been an active participant in the consultative process subsequent to the release of the draft Assessment of Environmental effects in November 2000. In participating in the consultation process, the NZRCA welcome the opportunity to discuss issues relating to further investigations and information sharing, the development and formalising of an ongoing relationship between Mighty River Power, the NZRCA and the broader kayaking community, and the mitigation options.
    6. All members of the executive of the NZRCA are volunteers.
  2. History of relationship

    1. Prior to the lodging of these applications the relationship between Mighty River Power (and its predecessor ECNZ) with the kayaking community has been generally positive.
    2. In general terms, the relationship centres around the request and provision of particular river flows for specific sections of the Waikato River.
    3. Flows are requested by a variety of organisations, such as:
      1. school groups,
      2. commercial organisations,
      3. canoe clubs,
      4. multisport clubs,
      5. regional and national slalom competition,
      6. informal, regional and national rodeo competition.
    4. Appropriate flows are primarily requested for the section of the Waikato downstream of the Taupo Gates, and the section of the Waikato below the Aratiatia rapids.
    5. Set flows are requested for a variety of recreational and competitive events for the various kayaking disciplines, including events such as:
      1. Canoe Club trips (focusing on instruction and recreation)
      2. White water rodeo training and competition
      3. Slalom training and competition
      4. Down River racing training and competition
      5. Commercial instruction courses (both white water kayaking and multisport)
      6. Assessments relating to various kayaking and multisport qualifications
    6. The provision of flows requested has been less consistent and satisfactory subsequent to ECNZ vesting the Waikato Power Scheme in Mighty River Power. In particular difficulties were experienced in late 1999 in the build-up for the World Rodeo Championships, and in early 2000 for the NZ Freestyle Kayaking Committee for the New Zealand rodeo team trials (to travel to the World Championships in Spain).
    7. However, due to the recently commenced consultative process between Mighty River Power and the kayaking community the NZRCA is hopeful that the relationship between Mighty River Power and the kayaking community can be formalised and enhanced and that such difficulties will be able to be avoided in the future.
  3. Submission

    1. Waikato River environment

      The remaining free flowing sections of the Waikato River have significant value for recreational canoeing and kayaking, ranging from regionally significant to nationally and internationally outstanding.
    2. The specific sections of the Waikato that hold value for the kayaking community are:
      1. Cherry Island to Reid's Farm.
      2. Reid's Farm
      3. Huka Falls
      4. Aratiatia Rapids
      5. Aratiatia to Ngawaapurua Rapids
      6. Arapuni
      7. Below Karapiro Power Station
    3. Prior to the construction of the Waikato Power Scheme there existed numerous other sections of river with the flow, gradient, gorge and white water features that would have created a significant and unmatched intrinsically valuable resource.
    4. This application for the renewal of resource consents is the opportunity to redress the ongoing adverse effects of the current operation of the Waikato Power Scheme, as well as the potential effects of the proposed alterations to the management of the Scheme.
    5. NZRCA acknowledges that Mighty River Power has attempted to uphold the provision of requested flows initially established by ECNZ. However subsequent to the Waikato Power Scheme being vested in Mighty River Power there has been more inconsistency in the provision of requested flows, particularly for national and international events.
    6. NZRCA acknowledges that Mighty River Power are, to a certain extent, subject to the "spot" power market, and that this effects the day to day, hour to hour flows down the river. However this comparatively recent practice has meant that there are, in general, more inconsistent flows down the recreational sections of the river on weekends and public holidays. When the flows are of a level that is high enough to offer a recreational resource, the flows are generally subject to frequent and noticeable "ramping" up and down, which significantly detracts from the quality and character of the white water features and the overall experience.
    7. As a result of this practice there has been a noticeable adverse effect on the recreational resource that remains on the Waikato River. The overall river facility is less attractive for recreationalists.
    8. As a result of ongoing negotiation and consultation between the kayaking community and Mighty River Power, we believe that the parties are gaining a greater understanding of the dilemmas facing each party. We hope that through this process Mighty River Power have gained an understanding of how significant the remnants of the Waikato River are to the kayaking community of New Zealand, just as we have come to understand that for the majority of the time there are certain operational limits on the flow management of the Waikato.
    9. As a result of these discussions, we still believe that it is possible to adequately mitigate the adverse effects of the ongoing operation of the Waikato Power Scheme, on the white water recreational resource that remains, with appropriate resource consent conditions.

    10. Flow information

      It is also of note that the provision of accurate, up to date, flow information has been unreliable in recent years. The provision of accurate, up to date, flow information is not only important for safety reasons, it is also an appropriate aspect of mitigation, to ensure that when the river is at an ideal level for kayaking, this information is freely available and can be utilised to its full potential.
    11. The NZRCA acknowledges and appreciates that Mighty River Power have indicated they will take steps to address this concern.
    12. Safety

      Whenever there are artificial structures introduced to a dynamic river environment, this creates the potential for safety hazards. The NZRCA expects that appropriate signage and maintenance will continue to be undertaken to ensure that the general public are aware of the hazards, and that there are no unnecessary.
    13. Sustainable Management of infrastructure resource

      The NZRCA recognises that as an important component of the electricity generation infrastructure of New Zealand, the Waikato Power Scheme is also a resource that must be sustainably managed. The NZRCA recognises that from time to time the capacity of the nation to generate electricity is limited due to either environmental conditions (such as the water shortage being experienced presently) or other foreseeable or unforeseeable situations. Due to these factors it is clear that any consent condition requiring flows for recreational release must be subject to an appropriate condition allowing for emergency or other situations.

    14. The NZRCA also acknowledges that over time circumstances may change making particular resource consent conditions inappropriate. The NZRCA therefore suggests that a review clause also be included to ascertain on regular intervals the ongoing appropriateness of resource consent conditions.
  4. My submission would be met by the Waikato Regional Council making the following decision:

    Grant the requested resource consents with the following conditions:

    1. General Flow and amenity conditions:

      Between Taupo Gates and below Aratiatia Power Station: Consent holder to ensure that flows of between 180 and 250 cumecs during weekend/public holidays occur between 0900 and 1600 hours, totalling no less than 300 hours per year from Taupo Gates, and no less than 300 hours per year from Aratiatia.
    2. Monitoring compliance of the flow quota to be undertaken by the Consent holder.
    3. The Consent holder is to ensure that during weekend and public holidays, when the flow is between 180and 250 cumecs, that the ramping variation is of no more than 25 cumecs per hour.
    4. The Consent holder shall undertake enhancement of the riverbank amenity beside Ngaawapurua Rapids, by working with the kayaking community to construct appropriate tracks, ablution facilities and other appropriate amenity enhancement measures.
    5. Or such other general relief relating to the guaranteed provision of particular flows as the hearing committee deems fit.

    6. Specific Flows (requested flows for events)

      For national and international events the Consent holder shall provide at least 15 days per year of requested flows of between 50 - 250 (check this figure) cumecs from either the Taupo Control Gates or from the Aratiatia Power Station.
    7. The requested flows for national and international events shall be requested 6 months in advance.
    8. The requested flows for national and international events shall be for a maximum duration of 8 hours per day.
    9. The requested flows for national and international events shall be maintained at a consistent flow, with a flow variation of no greater than 5 cumecs of the requested flow.
    10. All requests for national and international events are to originate from one of the recognised national canoeing associations.
    11. For regional/club and other events the Consent holder shall provide at least 15 days per year of requested flows between 50-250 cumecs from either the Taupo Control Gates or from the Aratiatia Power Station.
    12. The requested flows for regional, club and other events shall be for a maximum duration of 6 hours per day.
    13. The requested flows for regional, club and other events shall be maintained at a reasonably consistent flow, with a flow variation of no greater than 20 cumecs of the requested flow.
    14. Or such other general relief relating to requested specific releases as the hearing committee deems fit.
    15. If, in the opinion of the Consent holder the following arise:
      1. National power demands due to exceptional circumstances such as prolonged drought, or major system failure;
      2. Adverse hydraulic conditions in the Waikato catchment due drought or floods;
      3. Unexpected equipment failure;
      then the Consent holder shall not be obliged to meet any of the scheduled releases requested provided for above at the scheduled time.
    16. However, if a requested flow is unable to proceed due to the above conditions, it shall be postponed, not cancelled. The Consent holder shall ensure that a subsequent release is scheduled within 12 months of the postponement of the original release to make up for the postponed release. The "make up" release shall not be included in the quota of releases for the following year, but shall be included over and above that quota.
    17. Further details of the operations and relationship between the consent holder and the kayaking community shall be covered by an agreed memorandum of understanding/management plan or similar.

    18. River Flow information

      The Consent holder shall ensure that an 0800 flow phone continues to be maintained for the Taupo Control Gates and below the Aratiatia power station.
    19. The Consent holder shall ensure that the flow information is current and accurate.
    20. The Consent holder shall provide an Internet website which displays current and 7 day historical flow information for the Taupo Control Gates and below Aratiatia power station.

    21. Safety

      The Consent holder shall provide adequate signage and other suitable maintenance and protection measures to ensure that any hazards associated with the Consent holder's structures and power stations are minimised.

    22. Erosion

      The Consent holder shall undertake an independent and ongoing routine regime to identify, monitor and assess possible erosion of the Ngaawapurua Rapids, in particular, to gauge whether the management of the flow regime is having an adverse effect on the erosion of the Ngaawapurua Rapids.
    23. Or such other general relief relating to the monitoring and mitigation of erosion as the Hearing committee deems fit.

    24. Review Clause

      If due to a change in circumstances it becomes apparent that the resource consent conditions outlined above have become inappropriate, either party shall be entitled to request that the Waikato Regional Council initiate a review of the relevant consent conditions.

    25. Mitigation for destruction of original river

      The Consent holder shall assist and support the kayaking community to investigate a suitable artificial white water feature which could be developed within the Waikato Region.
    26. The Consent holder shall provide appropriate financial or practical assistance in the investigation and creation of such an artificial white water feature.

    27. General

      Such other general relief that appropriately addresses any of the issues raised in this submission.
  5. I do wish to be heard in support of my submission
  6. If others present similar submission I would be prepared to present a joint submission, if I consider it appropriate.

Dated 5 September 2001

Maree Baker
Conservation Officer
New Zealand Recreational Canoeing Association

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