Our purpose is to preserve New Zealand's whitewater resources and enhance opportunities to enjoy them safely.

Submission on a Resource Consent Application to operate an irrigation intake at Klondyke

RESOURCE MANAGEMENT ACT 1991 SUBMISSION ON APPLICATION FOR A RESOURCE CONSENT

To: Canterbury Regional Council

From: New Zealand Recreational Canoeing Association
C/o Maree Baker
Conservation Officer

Address: PO Box 284
WELLINGTON

Consent Nos. CRC011237 and CRC011239-CRC011255

  1. The NZRCA opposes the application of Rangitata Diversion Race Management Ltd for resource consents to construct and operate an irrigation intake structure and to take up to 30.7 cubic metres per second of surface water from the Rangitata River via the Klondyke intake structure.
  2. The particular parts of the application the NZRCA opposes are:
    • Damming and diversion of the Rangitata River
    • Disturbance of the Rangitata River bed
    • Erection of structures in the Rangitata River bed
    • The taking of water from the Rangitata River.
  3. The reasons for making this submission are:
    1. The New Zealand Recreational Canoeing Association (hereinafter NZRCA) is the national representative organisation of canoe clubs and individual recreational kayakers 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. Currently there are approximately 20 member clubs with a membership of approximately 800 individual paddlers. The total number of canoeists in New Zealand is estimated to exceeds the number of members of the NZRCA and the total number of participants in the sport continue to increase. Outdoor recreation programmes at polytechnics along with many high schools and outdoor education centres now all include canoeing in the syllabus.
    3. The NZRCA is committed to achieving the long-term sustainable management of New Zealand's water resources. We are a nationally recognised body that has continued to be actively and constructively involved in resource management processes throughout the country.
    4. We believe that Rangitata Diversion Race Management Ltd's application will continue to adversely affect the amenity values of the Rangitata River. The natural character and wildness of the river will be adversely affected, as will the navigability and recreational values, particularly at periods of low flow.
    5. The Rangitata is a popular river for whitewater kayaking, and is used extensively and regularly by individual canoeists, canoe clubs, and outdoor education institutions, especially those from the Otago and Canterbury regions. The section of river from the Klondyke down to the Peel Forest Campground offers an accessible white water experience in a wild and natural area. It is considered a good beginner to intermediate Grade II kayaking trip. Overall, this section of the river is a notable recreational resource.
    6. The recreational experience described in (e) above relies on safe passage for kayakers and adequate river flows. These attributes are affected by the consents sought. However, the effect of these applications on the Rangitata's canoeing values is not considered in the Assessment of Environmental Effects. To our knowledge there has also been no consultation with canoeing organisations concerning the applications. The NZRCA also has no record of information received from nor discussions with the applicant or their consultants.
    7. Renewal of these consents will continue the adverse effects on the recreational values of this section of the Rangitata River. It is our view that these effects should be properly assessed in the renewal of these consents.
    8. Safety is also a consideration for the Association. Activities associated with disturbance of the river bed and construction of structures on and adjacent to the river bed have the potential to pose safety risks to canoeists, kayakers and other river users. As no consultation has taken place, and insufficient details of the proposal have been provided, we have been unable to assess whether or not such safety risks are inherent in the proposal.
    9. The Association's concerns about low flow may be able to be addressed through appropriate conditions to avoid, remedy or mitigate the adverse effects of reduced river levels. Such mitigation conditions might include:
      • Release dates at certain times to allow kayakers to enjoy the river at its full natural flow; and/or
      • Other measures to address the loss of recreational kayaking amenity and the loss of wild & scenic values, particularly at times of low flow.
    10. The Association's concerns about safety may be able to be addressed through appropriate conditions to avoid, remedy or mitigate the adverse effects of disturbance and structures. Such mitigation conditions might include:
      • Information to paddlers and paddler groups about the occurrence of such works; and/or
      • Appropriate timing of such works.
    11. The NZRCA would appreciate the opportunity to discuss these options with the applicant prior to any hearing of these consents.
  4. Statutory Considerations
    1. The Resource Management Act 1991 sets a clear threshold for the assessment of resource consent applications. Relevant statutory considerations are outlined below. It is our assessment and submission that these tests are not met by this proposal:
      • "s 5 (2) Purpose In this Act, "sustainable management" means managing the use, development, and protection of natural and physical resources in a way , or at a rate, which enables people and communities to provide for their social, economic, and cultural wellbeing and for their health and safety while -
        (a) Sustaining the potential of natural and physical resources ( excluding minerals) to meet the reasonable foreseeable needs of future generations; and
        (b) Safeguarding the life-supporting capacity of air, water, soil, and ecosystems; and
        (c) Avoiding, remedying, or mitigating any adverse effects of activities on the environment
      • s 6 Matters of National Importance - In achieving the purpose of this Act, all persons exercising functions and powers under it, in relation to managing the use, development, and protection of natural and physical resources , shall recognise and provide for the following matters of national importance:
        (a) The preservation of the natural character of the coastal environment (including the coastal marine area), wetlands, and lakes and rivers and their margins, and the protection of them from inappropriate subdivision, use and development.
      • s 7 Other Matters - In achieving the purpose of this Act, all persons exercising functions and powers under it, in relation to managing the use development and protection of natural and physical resources, shall have particular regard to -
        (c) The maintenance and enhancement of amenity values
        (f) Maintenance and enhancement of the quality of the environment."
  5. The NZRCA wishes the consent authority to make the following decision:
    • Decline the applications for the consents cited unless conditions that fully address the Association's concerns can be provided.
  6. The NZRCA does wish to be heard in support of our submission

Maree Baker
Conservation Officer
New Zealand Recreational Canoeing Association

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