This submission was made by:
Name: Jonathan Hunt
Postal Address: PO Box 284, Wellington
Organisation (if applicable): New Zealand Recreational Canoeing Association, Inc.
Role/position (if applicable): Webmaster
18 February 2005
Q1. Which of the following best describes you or your organisation?
The NZRCA is a not-for-profit organisation, focussing on recreational and conservation advocacy with a strong safety emphasis. Formed as the New Zealand Canoeing Association in 1956, the NZRCA is a member of the NZ Canoeing Federation. Its purpose is to
preserve New Zealand's whitewater resources and enhance opportunities to enjoy them safely.
We have a specific interest in drowning prevention with respect to recreational kayaking and canoeing on New Zealand's rivers and lakes. Drownings in this domain tend to occur due to swims in whitewater, and/or entrapment by rock or tree.
Q2. How many people does this submission represent?
Q5. Overall, to what extent do you agree or disagree with the proposed goal 1. "Provision of effective leadership by the water safety sector and government"?
Q6. Please detail any wording changes, additions or comments you would like to make on goal 1.
However, effective leadership can only come from agencies working from a sound, direct understanding of the nature of risk in outdoor recreation. While there have been some solid efforts (eg. WSNZ) many governmental agencies have not provided good leadership:
The Taupo Harbour Master has attempted to prevent paddlers running Huka Falls, describing it as
total stupidity personified. Many more challenging rapids exist in the country and it is not acceptable to the NZRCA that arbitrary restrictions on recreation are imposed as an intervention for prevention of drowning.
The Police ordered a very experienced kayaker off the flooded Maitai River in 1998 . Again, the NZRCA believes it is unacceptable to restrict personal freedom due to unsubstantiated perceptions of risk on the part of authorities. Many rivers in New Zealand are only kayakable in flood, and flood conditions pose additional challenges that are attractive to experienced kayakers.
In the wake of a 2004 drowning on the Waiwhakaiho River, a New Plymouth Police Search Adviser reportedly advised,
If people are going to go they should wear lifejackets or tie the tube to themselves. While it is sensible for any person on a river to wear an appropriate lifejacket, it is extremely ill-advised to tie oneself to anything. The Police advice appears to transfer common practice of surfers to a river environment in which ropes or cords can create an entrapment hazard in association with trees or other obstacles. The NZRCA immediately responded with a media release, with Safety Officer Glenn Murdoch advising
You should never tie yourself to a kayak, boogie board or tube in a river.
The Maritime Safety Authority (MSA) have introduced the appalling Rule 91 (cited in the strategy has a
good example of a legislative framework(p24)). In the NZRCA's view, Rule 91 is shockingly poor regulation introduced without any consultation with recreational kayakers. It introduces a requirement for certified PFDs; however, after the NZRCA pointed out that no fit-for-purpose PFDs is use by New Zealand kayakers are certified, the MSA introduced a moratorium (to 2010) but the underlying issue remains. Other clauses in Rule 91 outlaw surfing on river waves (due to the 5 knot speed limit relative to the water). Rule 91 requires vessels to stick to the starboard side of a river channel; this is patently ridiculous when running difficult rapids. Rule 91 states that
a person in charge of a vessel on a river must not operate the vessel unless river and weather conditions permit safe operation of the vessel,without defining how this will apply to recreationalists and the fundamental issue of who gets to decide what is 'safe'? 
Some of the kayak accident reports issued by the MSA have been of extremely poor quality and display a fundamental lack of expertise in recreational canoeing and kayaking.
As documented in the response to Q22, there is currently insufficient recognition and leadership by government, mainly in the form of Regional Councils, with respect to artificial structures in river environments. There are many examples of artificial structures on rivers, whether for power generation, irrigation, flood control or protection for roading or property that create an unnecessary hazard to river users, particularly kayakers. More accountability and leadership is required from Regional Councils and related parties such as civil engineers (perhaps under the auspices of IPENZ) to (a) reduce the hazard presented by existing structures and (b) ensure no new hazards are introduced.
With reference to the Police and MSA interventions recounted above, there is an agenda that is willing to sacrifice the recreational amenity for the sake of safety, without recognising the role of risk in outdoor recreation. The NZRCA's strong view is that the recreational amenity must be preserved and recreational opportunities maintained (or increased), rather than diminished, through safety initiatives. Any curtailment in recreational opportunity must only occur as a last resort and only after full consultation with affected parties. In too many cases, authorities have chosen to impose their own interpretation of safety in complete disregard for the experience and judgement of those directly involved in outdoor recreation.
Q7. Overall, to what extent do you agree or disagree with the proposed goal 2. "Delivery of world-leading water safety services"?
Q8. Please detail any wording changes, additions or comments you would like to make on goal 2.
Q9. Overall, to what extent do you agree or disagree with the proposed Objective 1: To provide strategic direction and effective co-ordination?
Q10. Please detail any wording changes, additions or comments you would like to make on objective 1 (and its potential actions).
Q11. Overall, to what extent do you agree or disagree with the proposed Objective 2: To ensure an appropriate water safety infrastructure?
Q12. Please detail any wording changes, additions or comments you would like to make on objective 2 (and its potential actions).
A proposed action is to ,"encourage compliance with water safety laws and rules and undertake active enforcement of such laws and rules." The NZRCA is skeptical regarding the utility of compliance-oriented interventions, particularly when the laws and rules are seriously flawed (refer to previous comments on Rule 91 in Q6). In general, compliance and enforcement are of dubious utility to the development of personal responsibility, experience and judgement that is core to outdoor recreation. In our opinion, education and awareness-oriented interventions are more likely to be effective.
The NZRCA strongly agrees with the proposed action to strengthen capacity and capability. The NZRCA relies on volunteers for its operation, and this limits our ability to develop educational resources specific to our domain, conduct safety research and so on. Any assistance in building capacity is welcome.
Q13. Overall, to what extent do you agree or disagree with the proposed Objective 3: To ensure an appropriate level and distribution of resourcing?
Q14. Please detail any wording changes, additions or comments you would like to make on objective 3 (and its potential actions).
The NZRCA is a not-for-profit organisation funded primarily by subscriptions and donations from its membership. Previous funding for recreational (as compared to competitive) sports has largely disappeared due to the demise of the Hillary Commission and the creation of SPARC. The NZRCA would welcome additional funding in support of its mission.
The NZRCA has received significant support from WSNZ over recent years for the purpose of training in river safety and river rescue techniques (refer Q20).
The MSA has suggested that its ability to contract external kayaking expertise for accident investigations is in jeopardy due to funding constraints. The NZRCA is concerned that the MSA lacks sufficient funds to adequately fulfil its role.
Q15. Overall, to what extent do you agree or disagree with the proposed Objective 4: To enhance community and sector engagement in water safety initiatives?
Q16. Please detail any wording changes, additions or comments you would like to make on objective 4 (and its potential actions).
The NZRCA welcomes any initiatives to 'enhance co-operation and collaboration' between 'water safety partners and non-government organisations.' Although the MSA has statutory authority to investigate kayak/canoe accidents the NZRCA has expressed concern for some time about the MSA's limited competence in this domain. The relationship has been strained and the MSA has not agreed to a proposed joint Memorandum of Understanding with the NZRCA and NZOIA. The NZRCA would welcome improved collaboration with the MSA, or an alternate organisation better able to fulfil this statutory role.
Q17. Overall, to what extent do you agree or disagree with the proposed Objective 5: To provide quality water safety emergency rescue services?
Q18. Please detail any wording changes, additions or comments you would like to make on objective 5 (and its potential actions).
The NZRCA strongly supports the development of the Tasman Whitewater Response Unit and encourages the expansion of similar Whitewater Rescue Units (WWRUs) into other regions with active river recreation. There appears to have been good coordination and support with the Police and LandSAR. Encouragement and support of these initiatives is most welcome.
Q19. Overall, to what extent do you agree or disagree with the proposed Objective 6: To provide quality water safety education and awareness?
Q20. Please detail any wording changes, additions or comments you would like to make on objective 6 (and its potential actions).
For some years the NZRCA has distributed funding from WSNZ in the form of subsidies for members to attend river safety or river rescue courses. The syllabus aims to develop competencies in recognising river hazards, rescue scenarios and techniques, including river-based first aid .
The NZRCA regards this as an effective programme, but improvements could be made given increased organisational capacity and funding. Numerous other initiatives could be conducted given additional resources (for example, documentation and distribution of a NZ-oriented safety manual, development of video resources, increased data capture, investigation and analysis of kayaking-related incidents and accidents).
Q21. Overall, to what extent do you agree or disagree with the proposed Objective 7: To create safer environments in, on and around water?
Q22. Please detail any wording changes, additions or comments you would like to make on objective 7 (and its potential actions).
There is insufficient focus on hazards created by existing and new artificial structures in rivers:
I have personally kayaked past concrete reinforcing bars (rebar) jutting from debris used to protect the banks of the Otaki river. This is a lethal entrapment waiting to happen.
In 1997, a kayaker was swept through an irrigation culvert on the Waiau River .
A drowning occurred at Kawarau Falls by Lake Wakatipu. A contributing factor may have been a sign, intended for jetboats, that was followed by a kayaker which led to a powerful reversal that trapped and drowned the kayaker .
A kayaker recently approached Environment Canterbury (ECAN) about the risk to kayakers arising from the use of willows in wire to protect the river banks of the Waimakariri River. These river works create a significant preventable hazard for kayakers, but the kayaker's concerns were not addressed.
In all of the above cases, artificial structures in rivers have created, or contributed to, a drowning hazard. With good awareness and design, these hazards are largely preventable without restricting the recreational amenity.
The NZRCA recommends a national education and awareness campaign for Regional Councils and civil engineers to ensure safety of river users is recognised and incorporated into designs.
Many naturally occurring hazards are present in New Zealand rivers, including strainers formed by trees and logs, rock sieves, and powerful hydraulics. The NZRCA's general policy is that these are natural features of the wilderness environment and should not be interfered with. 'Sanitisation' of New Zealand's wild and scenic rivers is neither practicable nor desirable . The NZRCA prefers a risk management approach that preserves the recreational opportunity, based on awareness and education.
The NZRCA was very concerned by recent plans by Environment Bay of Plenty (EBOP) to move Rock 'A' on the Rangitaiki River with a digger. The sieve formed by Rock 'A' is a natural hazard and has contributed to several fatalities. The NZRCA was comfortable with the initial proposal to plug the gap using concrete, but was not supportive of plans to move the rock using a large digger, given that this might (a) create new hazards, (b) damage the surrounding environment, and (c) create a precedent for increasing human intervention in natural processes .
Given that natural hazards are an integral factor in New Zealand's rivers, particular risks may be reduced by minimally intrusive interventions such as signage. The NZRCA recommends funding and maintenance of signs for particular hazards, for example take-outs for Access 14 upstream of Tree Trunk Gorge and Access 13 upstream of Waikato Falls (both on the Tongariro River), warnings for Water of Leith, Lake Taupo and Lake Wakatipu control structures, and similar locations.
The NZRCA remains concerned about efforts of the NZJBA to remove existing 5 knot speed limits on popular kayak sections such as the Buller River. In principle the recreational resource is available for all to share, but there are serious practical concerns when it comes to kayaks sharing river space with jetboats. In the event of an accident is likely that the kayaker will come off worst. There have already been several incidents involving jetboats or jetskis vs kayakers. The NZJBA has yet to take our concerns seriously. We note that some jetboat safety signals are opposite kayaker signals creating a risk of misinterpretation, and that no protocol for keeping each group aware of the other has been developed .
Q23. Overall, to what extent do you agree or disagree with the proposed Objective 8: To improve our knowledge through water safety research and development?
Q24. Please detail any wording changes, additions or comments you would like to make on objective 8 (and its potential actions).
The NZRCA seeks to disseminate relevant lessons from MSA kayak accident reports to its members and the wider kayaking community, but the variable quality of many of these reports has limited their utility. The occasional accidents investigated by the MSA represent a significant opportunity for learning and it is of concern that the MSA has not consistently utilised whitewater kayaking experts and has expressed doubts about its financial ability to engage them in future. It is vital that the MSA or another organisation is empowered with sufficient funds and expertise to properly investigate canoe and kayak accidents.
The NZRCA has developed its own Incident/Accident Database  in order to provide a definitive record of whitewater kayak and canoe incidents, published in order to raise awareness of risks among the recreational canoeing community. The NZRCA would welcome additional funding for further database development including data capture, investigation and analysis of kayaking-related incidents and accidents and comparison to other countries. For example, it would be beneficial to ensure that all relevant findings from Coroner's records are incorporated in the database, and to have the resources to integrate metadata with other accident and injury databases in NZ.
Q25. Overall, to what extent do you agree or disagree with the eight objectives proposed for the draft Drowning Prevention Strategy?
Overall the NZRCA strongly agrees with the eight proposed objectives. However, they are sufficiently abstract to avoid controversy. The NZRCA has much greater interest in the proposed actions towards implementation of the objectives.
Q26. What, if any, potential gaps and overlaps are there in the objectives?
Q27. Overall, to what extent do you agree or disagree with the proposed focus on environments?
Neither agree nor disagree.
Q28. Please detail any wording changes, additions or comments you would like to make on the proposed focus on environments.
Inland waterways, comprising NZ's lakes and rivers are of primary concern to the NZRCA.
Q29. Overall, to what extent do you agree or disagree with the proposed focus on water-related activities?
Neither agree nor disagree.
Q30. Please detail any wording changes, additions or comments you would like to make on the proposed focus on water-related activities.
The NZRCA is most concerned regarding the subset of recreational boating comprising kayaking and canoeing, but not including sea-kayaking.
Q31. Overall, to what extent do you agree or disagree with the proposed focus on risk groups?
Neither agree nor disagree.
Q32. Please detail any wording changes, additions or comments you would like to make on the risk groups.
The risk groups need to be more fine-grained. For example, it could be that in recreational canoeing and kayaking visitors from overseas and educational groups (EOTC) are specific risk groups. More research is needed to confirm or deny this.
Q33. To what extent do you agree or disagree with the focus and content of the draft Strategy as a whole?
The NZRCA agrees with the focus and content of the strategy, but is mainly concerned with the effective translation of the strategy objectives into concrete actions.
Q34. Please provide any comments on the draft Strategy as a whole.
Overall, the NZRCA strongly opposes any interventions (p14) that may prevent drowning at the cost of diminished recreational opportunity.
The NZRCA has no solid data on participation rates (p17) ie. Number of whitewater canoeists and kayakers. We would welcome funding to carry out research on this topic, and would welcome research by other parties that addresses this issue.
Does the Water Safety Signage standard (p35) apply to inland waterways, and/or kayakers? If not, is there any merit to expanding its applicability?
Q35. Please provide any other general comments on the draft Strategy.
- Woman drowns at kayaking championships, 6 December 1999, The Dominion, p2.
- Kayak on the Maitai, Deanne Parker, 9 July 1998, Nelson Mail, p7.
- Man feared drowned as tubing ride turns to disaster, 2 February 2004, Taranaki Daily News.
- NZRCA Media Release, 3 February 2004, https://rivers.org.nz/media/NZRCAReWaiwhakaiho_20040203.pdf
- Rule 91 and its implications for kayakers, Tony Ward-Holmes and Jonathan Hunt, 14 October 2003, https://rivers.org.nz/article/rule-part-91
- River Safety Courses, http://rivers.org.nz/article/river-safety-courses
- Sanitising our wild places, Mark Jones, New Zealand Canoeing 04.2.
- Submission on Rock 'A', Rangitaiki River, Duncan Catanach, 10 March 2004, https://rivers.org.nz/article/submission-rock-a-rangitaiki-river
- Jetboats on the Buller, http://rivers.org.nz/article/jetboats-buller
- NZRCA Incident/Accident Database, https://rivers.org.nz/safety/db