Submission on an Application for Resource Consent
Section 96 of the Resource Management Act 1991
To: Consents Administration Section
Canterbury Regional Council, PO Box 345, Christchurch
Ph: (03) 365 3828, Fax: (03) 365 3194
Full Name: Jonathan Hunt
Address: PO Box 1062, Christchurch 8015
CRC981497 to excavate a combined volume of up to 1.9 million cubic metres of aggregate from the beds of the Clarence River.
CRC981498 to disturb the beds of the Clarence River by constructing a railway embankment, installing culverts and other structures, operating vehicles and machinery and stockpiling aggregate.
CRC981692 to divert surface water channels of the Clarence River.
Keywords: Clarence River, Wharekiri Stream, Miller Stream
I oppose the application of Tranz Rail Ltd. for a land use and water use resource consent, or order to quarry in the Clarence river bed and the removal of 1.9 million cubic metres of rocks and gravel.
I have been a recreational kayaker for ten years, and in that time I have kayaked extensively throughout New Zealand, and I have kayaked in the USA (twice) and Nepal. I have been a kayak instructor and was recently the Communications Officer for the NZ Recreational Canoeing Association (NZRCA) Inc. I kayaked the Clarence River over five days in 1990.
The particular parts of the application I oppose are those parts which relate directly to the works in and nearby the Clarence River, and which relate to the removal of rocks and gravel.
The reasons for making my submission are that the Assessment of Effects on the Environment does not consider the substantial recreational kayaking amenity that exists on the Clarence River, and does not avoid or mitigate the adverse effects that the applicant would introduce.
The only consultation with recreational groups appears to be based on commercial recreation interests (i.e. hunting and rafting companies). There does not appear to have been any assessment whatsoever of the impact on recreational canoeists/kayakers. (Section 8.7 p27, p31 and Section 10.3 p51).
The Clarence is one of the most important rivers in the country for recreational canoeing. It ranks with the Motu, Karamea, Landsborough, Kawarau and Buller as one of the great New Zealand rivers. It is particularly special in that only the Clarence River and Wanganui River offer extended multi-day trips without demanding rapids. This makes it a recreational amenity accessible to many people and worthy of protection. The Clarence is highly rated for its scenery and wilderness feeling, and kayakers travel from all around New Zealand to undertake expedition-style trips down the river.
The lower section from Glen Alton bridge to the SH1 bridge is a highly popular section of whitewater, both for groups at the end of an expedition and for local paddlers wanting a shorter trip. This is highlighted in the two main kayaking guidebooks in New Zealand.
In New Zealand's South Island Rivers: A guide for canoeists, kayakers and rafters (Graham Egarr, 1995), Graham writes, "Do not end the trip at the Glen Alton bridge, because between here and Highway 1 lie some delightful rapids and one long one in particular. The river flows quietly from Glen Alton, almost without rapids until Middle Hill, where the Miller and Wharekiri Streams flow in. Here the river gradient suddenly increases and a very long stony rapid with bouncy pressure waves will be encountered. At times this long rapid breaks into a number of rapids with short pools between, but at other times it flows continuously to give constant whitewater and an exhilarating end to a trip on the Clarence." (p136).
This is supported by the more recent New Zealand Whitewater: 100 great kayaking runs (Graham Charles, 1996) which states "The last section [from Glen Alton bridge] has some delightful shingle chute rapids with sizeable pressure waves making an exciting end to the journey." (p102-104).
The rapids are an important recreational resource. It is the very existence of rapids, which defines whitewater kayaking as a sport. Kayaking groups can spend hours playing and surfing on the pressure waves formed in these rapids. Kayakers tend to cluster around such river features and spend time at each one rather than travel directly downstream as rafters do.
I am concerned that the removal of such a massive quantity of material, particularly the large rocks required for a breakwater, from both the Clarence River bed and the tributary streams, will destroy the existing rapids for many years to come.
I acknowledge that the river is subject to flooding which alters the size and shape of rapids over a period of time. However because there are large rocks which resist the water, there will always be rapids somewhere along the stretch of water. The removal of material would remove the natural ability to reform rapids and would effectively destroy the lower Clarence as a whitewater recreational resource.
The applicant proposes to contour the river and leave some large rock sizes in streambeds to create rapids. This is not sufficient mitigation in my opinion. There would be fewer rapids due to the removal of material, nor would they be replenished after major flows or floods because of the removal of rocks from contributing streams. Without consultation there is no guarantee that the re-contoured river would provide the recreational amenity to kayakers that the natural river does. There is no guarantee that the rapids created by those rocks left behind would suit kayakers (as compared to rafters).
Also, if the work was to proceed there are a number of safety issues that arise. Because no consultation has been held with recreational kayakers there is no evidence that contractors would be aware of kayaking groups using the river, and there is also little likelihood of kayaking groups being aware of the workings ahead of time. The proposed notification process between the contractors and commercial rafters is unlikely to work for disparate kayaking groups who may travel from around New Zealand to undertake Clarence trips.
Condition #17 (p57) suggests a vehicle crossing (across the Clarence River bed) which could be either a gravel causeway or low-piped concrete ford. Either method would produce an obstacle that could be dangerous to kayaks. Presumably the causeway would have a culvert of some kind for the water to flow through; would this be open or screened, large or small? Concrete fords often form uniform hydraulic recirculations when water flows over them; these can trap debris and kayakers, and many deaths have occurred on fords and low-head dams in the USA.
I wish the consent authority to make the following decision:
Please decline the applications for the consents cited on the grounds of removal of an existing recreational resource (i.e. rapids in the lower Clarence) and inadequate mitigation.
Alternatively, the Canterbury Regional Council should direct the applicant to rewrite the Assessment of Effects to properly reflect the non-commercial recreational usage of the river, and make it a condition of the consent that the applicant undertake consultation with representatives of affected recreational groups (especially NZRCA and Marlborough Canoe Club), with a view to determining appropriate mitigation of adverse effects.
Ideas for mitigation may include:
- taking less rock so that the river recovers sooner.
- extract an even percentage of all rock sizes so that a disproportionate number of large rocks are not removed.
- re-routing vehicle access to avoid the need for a river crossing of any kind.
- ensuring contractors are aware of kayaking groups
- establishing and publicising an 0800 number so that kayakers can inform contractors of their journey intentions.
- placing warning signage at places where kayakers will see the signs (i.e. SH1 bridge, Glen Alton bridge and exit to lower Gorge, get in points near Acheron confluence in upper Clarence valley).
- consulting with kayaking representatives (i.e. NZRCA Inc. and Marlborough Canoe Club) about warning signage, river access, intentions notification, river contouring and rapid rehabilitation, and design of vehicle crossings
I wish to be heard in support of my submission, but it depends on the timing of such hearings.
Signed: Jonathan Hunt
Date: ____ / ____ / ____ (17 July 1998)