Submission on Called-in Resource Consent Applications (Tekapo)
Submission on Called-in Resource Consent Applications from New Zealand Recreational Canoeing Association
Lake Tekapo Resource Consents [Aoraki Water Trust (CRC0301390) and Opihi River Development Company Ltd (CRC905285a)]
Summary of Submission
The New Zealand Recreational Canoeing Association Inc. (NZRCA) is the peak national body representing recreational whitewater paddlers (i.e., kayakers and canoeists). Its purpose is to
preserve New Zealand's whitewater resources and to enhance opportunities to enjoy them safely. In essence, the NZRCA objects to the two resource consents ticked because we believe that they will put the current agreement (for loss of whitewater amenity on the Pukaki, Tekapo, Ohau and Waitaki Rivers), which was conducted in good faith between Meridian Energy and the Tekapo Whitewater Trust in 1990, in jeopardy. More specifically, according to the agreement, whitewater releases for the Tekapo River are based on certain minimum lake levels being met and it is likely that these levels will be less frequently met if the significant additional drawings proposed in these resource consents occur.
Prior to the construction of the Upper Waitaki power schemes, the Upper Tekapo River contained what was regarded as premium Grade 3 whitewater. Following the construction of the power schemes, all water (apart from planned or unplanned releases) on the Upper Tekapo has been diverted for power use. To compensate for this considerable loss of whitewater amenity an agreement between NZRCA / Tekapo Whitewater Trust was formed in 1990 as part of a resource consent process. The key components of the agreement were:
- An agreement to release water up to twelve times annually from Lake Tekapo down the Tekapo River at a suitable flow for kayaking. Importantly, there is no requirement for water to be released if the lake is below a certain minimum level
- An agreement to fund the construction of a canoe course that enhances some of the natural features of the Tekapo River bed.
The whitewater course and Tekapo releases are planned in advance and have been and continue to be well patronised by both recreational and competitive slalom paddlers from all round the country.
The resource consents in question - Aoraki Water Trust (CRC0301390) and Opihi River Development Company Ltd (CRC905285a) - request permission to draw up to 21 cumecs from Lake Tekapo continuously. This is a significant additional volume of water, and we believe that the approval of the resource consents is likely to significantly jeopardise the agreement reached previously as part of an earlier resource consent process.
The evidence, as we know it currently, suggests that the approval of the consents is likely to result in planned releases being cancelled due to the lake falling below the minimum level required for a release. We base this conclusion on several factors including the following:
- The mean annual hydrological inflow for the period 1977-2004 into Lake Tekapo was 86 cumecs. The implication is that if the two consents are approved, on a mean basis almost one-quarter of the mean inflow will be diverted for irrigation purposes. Ignoring all other water users, this is a significant proportion of the total inflow to Lake Tekapo.
- Water requirements for power generation currently take precedence over Tekapo River releases for whitewater paddling. Additional outflows for irrigation will further add to the likelihood of lake levels falling below minimum water levels.
- The irrigation season typically coincides with the recreational release season for paddlers, putting further pressure on lake levels (recreational releases start from Labour weekend i.e., late October, and the irrigation season typically starts from September).
- Lake levels typically are lowest at the end of winter/early spring (low mean inflow - e.g., 48 cumecs in July - and high generation demands) and fill with the spring/summer rains and snowmelt from October / November onwards (highest mean inflow is during December - 138 cumecs). The implication is that there are significant irrigation demands at a time when the lake is near its lowest. This is more likely to result in the lake falling below the minimum level required for releases.
- The lake is highly likely to fall below minimum levels in
dry years. For instance, for two months in 1991 mean inflow was only 27 cumecs. Lake levels will drop rapidly if irrigation outflows of 21 cumecs are drawn in addition to water requirements for power generation.
The NZRCA believes strongly that if these resource consents are approved then the current agreement with Meridian Energy will be significantly compromised as:
- The whitewater community is likely to lose releases, particularly in
dryyears, as the lake level is more likely to drop below the minimum level required for releases to occur as planned.
- The original agreement - for compensation for the loss of water amenity on the Tekapo, Pukaki, Ohau and Upper Waitaki Rivers - was made on the basis of resource consents current at the time. If the resource consents change and we suffer a further loss of whitewater amenity due to a reduced number of releases or a reduced flow, then a new agreement is the only fair way of proceeding.
- We have had no consultation from the two applicants for the resource consents, despite their applications having a considerable affect on current arrangements.
We are not prepared to support the applications in their current form unless formal assurances can be made that our current agreement will not be compromised.
We seek the following decision from the Minister
We seek the following decision to be made:
- Our strong preference is that the resource consents for Aoraki Water Trust (CRC0301390) and Opihi River Development Company Ltd (CRC905285a) be declined.
- If the consents are approved by the Minister, that the minimum required lake level be adjusted downwards to reflect the volume of water drawn by the two applications. In other words, we seek formal assurances can be made that the current agreement between Tekapo Whitewater Trust and Meridian Energy is not compromised (including the current number and flow of Tekapo River water releases for whitewater recreation) i.e., the status quo is retained.