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Submission re Waitaki Allocation Plan

To: Waitaki Catchment Water Allocation Board

From: New Zealand Recreational Canoeing Association

Date: 18 April 2005

Re: Draft Waikato Catchment Water Allocation Regional Plan

  1. Submitter Contact Details

    Duncan John Catanach
    North Island Conservation Officer
    New Zealand Recreational Canoeing Association
    PO Box 284, Wellington
    Phone: ###-###-####
    Email: niconservation@rivers.org.nz




  2. Submission Details

    Background on submitter

    The NZRCA is the national representative organisation of canoe clubs and recreational kayakers throughout New Zealand. The NZRCA is an incorporated society and is affiliated to the NZ Canoe Federation, which is in turn affiliated to the International Canoe Federation. The NZRCA has delegated authority to represent the NZ Canoe Federation on conservation/access issues.

    Background to submission

    Prior to the construction of the Upper Waitaki power schemes, the Upper Tekapo and Pukaki Rivers contained what was regarded as high quality Grade 3 whitewater. Following the construction of the power schemes, all water (apart from planned or unplanned releases) on the Upper Tekapo and Pukaki rivers has been diverted for power use.

    To compensate for this considerable loss of whitewater amenity an agreement between NZRCA and ECNZ (Meridian's predecessor) was formed in 1990 as part of a resource consent process. The NZRCA were also party to the collective agreement which supported ECNZ's applications for consents for the Waitaki Power Scheme. 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. This became a condition of ECNZ's consents.
    • An agreement to release water over two days a year from Lake Pukaki down the Pukaki River at a suitable flow for kayaking. This became a condition of ECNZ's consents.
    • An agreement to fund the construction of a canoe course that enhances some of the natural features of the Tekapo River bed.

    Subsequent to this the Tekapo Whitewater Trust was established to oversee the design, construction, operation and maintenance of the Tekapo whitewater course.

    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. Last year the national slalom competition was held on the Tekapo course.

    Summary of Submission

    The NZRCA opposes the draft Waitaki catchment water allocation regional plan. In 1990 NZRCA, ECNZ and other key submitters held meetings and commissioned reports to consider the environmental, recreational, social, cultural and economic values of the Upper Waitaki. Several provisions of the Draft Plan will put the outcomes envisaged by the 1990 agreement (for loss of whitewater amenity on the Pukaki, Tekapo, Ohau and Waitaki Rivers), which has been conducted in good faith between Meridian Energy and the NZRCA and Tekapo Whitewater Trust, in jeopardy.

    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 flows from the lakes to meet the new minimum flows and allocated volumes in the lower Waitaki proposed in this draft allocation plan occur.

    Unfortunately, full details of existing consents (e.g., minimum flows, allocation limits etc.) are not given in the plan. This makes a detailed examination of the water allocation plan difficult - it is particularly hard to give thorough comment on the proposed regime for specific water bodies. Consequently, the NZRCA reserves the right to change its submission should more detailed water allocation information become available at a later date.

    A non-exhaustive list of specific provisions that the NZRCA wishes to make comment on is given below.

    Number of Provision Support or Oppose Reasons for our submission
    Policy 16 and 17 Support The NZRCA supports any provision that encourages more efficient and effective usage of water as this will reduce the abstractive demand for water, particularly the policy that an irrigation application efficiency of at least 80% be assumed.
    Policy 28 Support in part

    The NZRCA supports any provision that encourages more efficient and effective usage of water e.g., clause a).

    Clause c) suggests that existing physical works associated with the consent by taken to account. We would only support this clause if the efficiency standards referred to in the plan or higher are met.

    Policy 31 Support The NZRCA supports any clause that discourages the taking, using, damming or diverting of water for irrigation purposes from or in the tributaries of Lakes Tekapo and Pukaki.
    Rule 2 Oppose

    The NZRCA opposes any minimum flow or allocation limit for water bodies downstream of Lake Pukaki and Tekapo outlets that is higher than existing consent levels as this will make it more likely to result in minimum lake levels for whitewater releases not being able to be met by Meridian. In particular the minimum flow regime in the lower Waitaki and Tekapo rivers are opposed.

    For instance, the draft plan appears to approximately double the minimum flows in the Lower Waitaki from what it is now. This means that water once stored in Lakes Tekapo and Pukaki will now have to be released to make up the higher minimum flows in the Lower Waitaki.

    Rule 3 Oppose The minimum lake level at Lake Tekapo has been increased from what is currently provided for in Meridian's resource consents and does not concur with what was agreed in 1990 between ECNZ, the NZRCA and other stakeholders. This, in combination with the Tekapo River minimum flow, will further reduce water available for either whitewater purposes or electricity generation.
    Rule 6 Oppose in part

    The NZRCA opposes any minimum flow or allocation limit for water bodies downstream of Lake Pukaki and Tekapo outlets that is higher than existing consent levels as this will make it more likely to result in minimum lake levels for whitewater releases not being able to be met by Meridian. In particular the minimum flow regime in the lower Waitaki and Tekapo rivers are opposed.

    The NZRCA supports 6(3) to the extent that it gives effect to making sourcing water for irrigation from Lakes Tekapo and Pukaki inappropriate (reflecting Policy 12.c)

    Rule 7 Support The NZRCA supports this rule which would prevent water from the Waitaki catchment being used with water bodies outside the Waitaki catchment. In particular, resource consents using water from the Waitaki catchment should not be used for irrigation schemes outside the Waitaki catchment area.
  3. Alterations to Draft Waitaki Catchment Allocation Regional Plan Requested

    The original agreement for compensation for the loss of water amenity on the Tekapo, Pukaki, Ohau and Upper Waitaki Rivers between the NZRCA and ECNZ was made on the basis of resource consents being applied for at the time, and granted on the basis of the collective stakeholder agreement. The draft allocation plan proposes to increase allocation limits and minimum flow levels below Lakes Tekapo and Pukaki.

    This is likely to result in a further loss of whitewater amenity to the whitewater community as the lake level, particularly in dry years, is more likely to drop below the minimum level required for releases to occur as planned. Furthermore Meridian is likely to have to hold back water for the provision of new minimum flows and conflicts may result with regards priorities in Meridian's consent conditions, eg. what comes first, the provision of minimum flows, recreational releases, allocated water or stored water?

    Consequently, the NZRCA is not prepared to support the draft water allocation plan unless formal assurances can be made that our current agreement (including the current number and flow of Tekapo and Pukaki River water releases for whitewater recreation) will not be compromised. It is likely that this will mean that existing consents are respected e.g., minimum flows and allocation limits are not above existing consents levels.

We wish to be heard in support of our submission

____________________________
Duncan Catanach
North Island Conservation Officer
New Zealand Recreational Canoeing Association


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