This submission is in response to the issues raised in "Making Every Drop Count", a discussion document for a National Agenda for Sustainable Water Management, from the Ministry for the Environment.
24 February 2000
Land and Water Group Ministry for the Environment
PO Box 10-362
Thank you for inviting submissions on the National Agenda for sustainable water management. This is a nationally important issue and one which the New Zealand Recreational Canoeing Association (hereinafter NZRCA) is happy to contribute to. As background, the NZRCA is the national representative organisation of canoe clubs and individual recreational canoeists 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.
Currently there are over 20 member clubs, as well as individual members, affiliated to the NZRCA. Outdoor recreation programs at polytechnics along with many high schools and outdoor education centres now all include canoeing in the syllabus also. Since the 1950's the NZRCA (then known as the NZCA) has represented the interests of white water canoeists. The NZRCA is committed to long-term sustainable management of New Zealand's water resources, for the benefit of instream users.
The NZRCA, and its predecessor the New Zealand Canoeing Association, is a nationally recognised body that has continued to be actively and constructively involved in resource management processes, including national water conservation orders (for example, Motu, Mohaka, Buller, Kawarau, and the Grey), regional policy statement, regional plans, and significant resource consent applications. The Association also leads programmes in safety and education. Further information on the Association's activities are available through its website (www.rivers.org.nz) and newsletter (New Zealand Canoeing).
The Association's comments on the Ministry's draft document are outlined below.
1.2 - Key findings
Admittedly the points in this section have been identified as areas of priority. However despite this qualification we believe the following comments are relevant:
- There is no overall vision linking the prioritised areas, beyond quantifiable improvement of particular factors. An overall vision/aim for water management may aid in the interpretation of the priority problem areas and the integrated search for solutions.
- Point 1 implies that everything is currently available for allocation, whereas in reality many areas are already over allocated. Over allocation of New Zealand's water resource needs to be addressed before a new allocation management system is established.
- Wild and scenic values, as protected by National Water Conservation Orders, (NWCO's) need to be identified as a priority area. It is our submission that such values, and NWCO's are very important factors in the management of New Zealand's river resources. The national legislation creating NWCO's was originally put there to address the inadequacies of the then existing legislation to protect nationally important water bodies. Therefore in some areas of importance, it is inappropriate to leave management to the regional allocation process. In our opinion this is a priority area that should be recognised, assessed and promoted.
- Furthermore the identified priority areas only describe human appreciation of rivers in terms of water quality and other quantifiable terms. It is our submission that the overall amenity/naturalness/ wild and scenic qualities of water bodies is also an area of priority that must be recognised, protected and enhanced.
2.1 - Environmental issues
It is stated on page 5 that "hydro electric development has all but ceased...". This is contrary to our perception. There are several hydro development proposals by local authorities, and hydro development proposals associated with irrigation projects, that are currently threatening some of New Zealand's valuable recreational rivers. It is apparent from our perspective that user groups and industries in particular still view rivers as a source of free commodity. Therefore these organisations are reluctant to participate in consultative group process when they make applications concerning water resources. In summary, the general attitude towards water resources is not as positive and enlightened as that presented in 2.1, and requires further education and management to be adequately addressed.
2.2 - System Issues
An aspect of the implementation of the RMA that has been omitted from this section is that water managers are having problems giving effect to sections 6 (a) and 7 (c) in terms of natural character and amenity protection respectively. The reason for this is that the judgements to be made are subjective, and the appropriate interest groups and affected parties often go unconsulted and/or may not be able, due to finances/resources, to make a strong representation.
2.2.1 - System Priorities
To address the above problem we ask that consultation with recreation groups be made a priority.
3.1 - Determining water available for allocation
Instream guidelines are potentially very influential in river management and as significant instream users, with an arguably unique and important perspective, we have not had any input. Furthermore there are some rivers where it is inappropriate to make them available for allocation at all and this conclusion may only be reached by appropriate consultation with instream user groups such as the NZRCA and its member clubs. We therefore sensibly support flow allocation decision processes but it must be guaranteed that the flow supports other instream users including white water canoeists, where relevant.
We support the protection and enhancement of aquatic ecosystems as it adds to the important wild and scenic qualities of water bodies and the overall experience.
4.1 In the Association's opinion the desired outcomes appear to be overly constrained. It would be beneficial to the interests of and use by communities if the outcomes take into account the natural values of the lowland streams, and provide some means of description and assessment of the water bodies.
We support the guideline on page 17 of aiming to develop a "best management practice guideline for riparian management for farmers". Rubbish in and nearby rivers and their catchments not only creates a potential health risk to natural functioning of waters bodies, but also a significant health and safety risk to instream users. Debris in river beds has the potential to snag/entrap and therefore injure or kill instream river users. The Association has commenced some work to build landowner and council awareness of these hazards. These hazards arise against a background where it is a national culture that New Zealand's rivers are places of 'safe disposal' for unwanted wire, car bodies, mining debris, fridges, etc. Our effort to date has been focused around the high white water use areas, such as Murchison, but we see this as an important national issue. A programme to educate and reduce this risk through improved landowner behaviour and the promotion of better waste disposal options is essential. Such measures would be strongly supported by the NZRCA.
4.3.1 - Lakes
We support the identification of icon lakes, on the condition that non-icon lakes are still sustained to a certain standard. We also submit that there is also a public expectation that there are icon rivers that must be well managed and protected from pollution, extraction and disruption. This public expectation is reflected in the establishment of the wild and scenic rivers legislation in the early 80s, and the existence and use of a number of NWCOs today. We suggest that a parallel set of desired outcomes and appropriate measures be established for the icon rivers of New Zealand.
5.1 - Contact Recreation
The recent and ongoing observation of poor practice of rural waste disposal and the threat that that presents to the natural character of water bodies as well as the health and safety of instream users is outlined above. We therefore support measures promoted for improvement of contact recreation.
MfE to co-ordinate development of guidelines and education measures and promote safe alternatives of rural waste disposal in consultation with District Councils, Regional Councils and Rural interest groups.
We strongly support the development of improved systems of water management, as long as they are designed to take into account the view and values of relevant interest groups, such as recreational groups.
6.7 - Information
We strongly support information sharing as described in this section. However it is important that the information sharing frameworks are developed to identify and include the natural character of water bodies and the instream user values associated with water bodies. If this is not incorporated the framework will be limited in its application and use and frustrate achievement of the strategy's goals, as amended by this and other submissions.
A specific place for NWCOs should also be included in the information network.
We also suggest that in the context of integrated management it would be beneficial to provide a place for information not directly related to water bodies, such as surrounding vegetation, surrounding uses, instream uses, and access issues.
I am happy to discuss these matters further, or provide clarification of the changes sought above.
New Zealand Recreational Canoeing Association