Submission on Horizon's One Plan

Submission by the NZRCA on Horizon Regional Council's One Plan

31 August 2007

Submitter's Details

Name of Submitter: New Zealand Recreational Canoeing Association

Contact Person: Duncan Catanach, North Island Conservation Officer

Postal Address: c/- PO Box 284, Wellington


Background to New Zealand Recreational Canoeing Association (NZRCA)

  1. Formed in 1957, 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 and access issues.
  2. Previously the NZRCA was known as the New Zealand Canoe Association, prior to the creation of the New Zealand Canoe Federation in 1995/1996.
  3. The NZRCA represents both individual members and affiliated member clubs. Currently there are 30 affiliated Clubs with a combined membership of around 2,500 kayakers plus another 65 individual members. The figure of 2,565 in no way adequately represents the sum total of kayakers in New Zealand, as there are many who do not belong to clubs, and who have not joined the NZRCA as individuals.
  4. The NZRCA, while a national organisation, has interest area governed by in the Horizon Regional Council as the region contains many nationally significant waterways e.g., Rangitikei, Manawatu, Wanganui rivers and their tributaries e.g., Mangahao River.

Do you wish to be heard in support of your submission - Yes

If others make a similar submission, would you consider presenting a joint case with them at a hearing? - Yes

We support the OnePlan with amendments

Amendments sought

The NZRCA seeks full and adequate recognition and consideration is given to the needs of recreational kayakers and canoeists on waterways particularly when resource consents are being considered or environmental standards, such as minimum water flows or quality standards are being set. More specifically:

  • Chapter 3, Objective 3.1 and Policy 3.1 and 3.3 seem to give strong preference to infrastructure and energy development. Infrastructure development can have considerable impact on recreational waterways and our recommendation is that the wording of the Council's policies and objectives should provide that infrastructure and energy development be subject to no special level of consideration, except to the extent provided for in national legislation such as the RMA.

The NZRCA would also like amendments to the plan (Chapter 6, Policy 6-12) to ensure that recreational paddling is explicitly recognised as a reasonable, justifiable and efficient use of water whether it is the natural flow of a river or whether the flow is controlled (e.g., as part of a dam release from a hydro facility). We would also note that within the Horizon's Council the use of water for recreational users has already been formally agreed as a suitable use of water e.g., water releases agreed as part of resource consents for the Mangahao power scheme.

The NZRCA is also concerned at the continuing decline in water quality and flows and would support any mechanisms that will lead to a strengthened and transparent monitoring and compliance regime to identify and penalise breaches of resource consent conditions or environmental standards as these breaches often affect recreational users significantly. We believe that the plan has this intent but does not go far enough in achieving these aims. More specifically:

  • Section 6.1.3 the only recreational activities itemised are swimming and fishing. This list is too narrow and we would recommend it include canoeing, kayaking and other water-based recreational activities.
  • Section 6.19 – Explicit mention should be made of minimum water quality levels as well as minimum water flows as a criteria for stopping or restarting water takes.
  • Policy 13.1 – This wording of this section is weak and non-prescriptive in cases of non-compliance. The NZRCA would prefer more explicit and stronger clauses, particularly where there have been previous instances of non-compliance.

We would note that we are aware of the contents of the Ruahine Whitewater Club's submission and in principle we would support many of their specific recommendations.

Yours sincerely,

Duncan Catanach

North Island Conservation Officer, New Zealand Recreational Canoeing Association