Submission on Pukaki Farming Company

Submission on Called-in Resource Consent Applications: Pukaki Farming Company Ltd. - CRC040327

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 NZRCA in 1990, in jeopardy. More specifically, according to the agreement, whitewater releases for the Pukaki River are based on certain minimum lake levels being met and it is likely that these levels will be less frequently met if resouce consents are approved which result in significant additional outflow or reduced inflow to Lake Pukaki.

Detailed Submission

Prior to the construction of the Upper Waitaki power schemes, the Pukaki 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 uses. To compensate for this considerable loss of whitewater amenity an agreement between NZRCA and Meridian Energy was formed in 1990 as part of a resource consent process whereby it was agreed that water would be released once annually from Lake Pukaki down the Pukaki 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.

The Pukaki River releases are planned in advance and have been and continue to be well patronised by recreational paddlers from all round the country.

The resource consent in question, Pukaki Farming Company Limited (CRC040327) requests permission to draw up to 2.7 cumecs from Lake Pukaki. While this is perhaps not a significant additional volume of water, a serious concern of the NZRCA is that these consents will be the first of many future applications to draw water (either from Lake Pukaki itself or reducing inflow into Lake Pukaki) for irrigation and other purposes, and that in time, if a significant cumulative volume of water is drawn it may jeopardise the agreement reached previously as part of an earlier resource consent process.

Our reasoning for this is that if approval is given in the future for an overall significant volume of water to be drawn (either reducing inflow into Lake Pukaki or water drawn from Lake Pukaki itself), it will potentially result in more planned releases being cancelled due to the lake falling below the minimum level required for a release. In particular we note that:

• Water requirements for power generation currently take precedence over Pukaki River releases for whitewater paddling. Additional outflows or reduced inflows for irrigation will further add to the likelihood of lake levels falling below minimum water levels, particularly during dry years.
• Lake levels typically are lowest at the end of winter/early spring (low mean inflow and high generation demands) and fill with the spring/summer rains and snowmelt from October / November onwards. 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 NZRCA believes strongly that if these resource consents are approved then the current agreement with Meridian Energy may be significantly compromised as:

• The whitewater community may lose releases in the future, particularly in dry years, 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 now or in the future, 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 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 be declined.
• If the consents are approved by the Minister, that the minimum required lake level be adjusted downwards to reflect the total volume of water proposed to be drawn by the applications listed. In other words, we seek formal assurances can be made that the current agreement between NZRCA and Meridian Energy is not compromised (including the current number and flow of Pukaki River water releases for whitewater recreation) i.e., the status quo is retained.
• A formal assurance that any future applications for drawing water from Lake Pukaki or reducing the inflow to Lake Pukaki from current levels will be dealt with in the same way.