10 March 2004
Attn: Jon Moore
Environment Bay of Plenty
PO Box 364
Re: Resource Consent for “Rock A” Rangitaiki River
The New Zealand Recreational Canoeing Association Inc. (NZRCA) is the national body representing recreational whitewater paddlers (i.e., kayakers and canoeists). We have only just recently (1 March) become aware of a report compiled by Ray Sperling of Proadventure.co.nz titled Management of “Rock A” Rangitaiki River (113k, PDF) who was contracted by Environment Bay of Plenty to consult on the issue. In this report organisations, or their representatives, are being asked to agree to the suggested action of moving “Rock A” to the river right.
At this stage the NZRCA opposes the application for the following reasons:
- Full consultation has not yet occurred
It is stated in the Sperling report that the consulting process is now complete and that all users were consulted in the process, including attendance by recreational users at the meeting on 22 December 2003. We would strongly suggest that full consultation has not taken place.
- Consultation was formally requested: The NZRCA has already considered this issue once before, and at the time expressed concern at any possible riverbed modification of the Rangitaiki River. I quote from our letter of 18 February 2003: "The NZRCA requests that it be consulted in any resource consent applications that are filed in relation to any modification of the Rangitaiki riverbed (including the removal of Rock A) and in any other work that is related to riverbed modification" [italics ours]. We were not formally asked to comment on the Sperling report, nor were we invited to the meeting held on 22 December 2003.
- NZRCA represents recreational users: Recreational whitewater kayakers from all over New Zealand regularly use the Rangitaiki River's “Jeff's Joy” run which contains the “Rock A” hazard. The NZRCA is the national body representing recreational whitewater paddlers. However, we do not know who represented “recreational” paddlers at the meeting of 22 December 2003 as detailed in the report.
- It is unclear that the proposed option is the only or optimal option
The NZRCA believes that it is not clear whether moving “Rock A” to river right is the only or optimal option at this point in time:
- Plugging the gap maybe still possible and is preferable: To our knowledge, only one attempt at plugging the gap has been made. It is not clear from the report that the gap could not be plugged with proper resourcing and reduced water flows. This option would also minimise modifications to the riverbed, while still eliminating the hazard.
- Unknown future consequences of moving “Rock A”: The future consequences of moving “Rock A” are still unknown. For instance, new hazards may arise that could be attributed to the new placement of “Rock A”, especially during high flows e.g., rock moves to a hazardous position during floods.
As a general comment, we would also suggest that removing all potential hazards from rivers is not a practical or sustainable solution, and that in the future EBOP look at other ways of reducing risk, particularly for commercial operators. For instance, we are aware of at least one rafting company that chooses not to paddle the rock garden containing “Rock A” at low water levels. Other rivers users are more likely to follow this risk management approach if appropriate signs are clearly visible at the "get-in" point. Finally, rivers are full of naturally occurring hazards and part of the attraction of kayaking is to exercise judgement and discretion in the navigation of hazards, not necessarily to eliminate them.
The NZRCA therefore seeks that the resource consent application be declined, given the lack of consultation and insufficient information provided.
The NZRCA wishes to be heard in respect of this submission. Should you wish to discuss the situation further, or inform the NZRCA of any further action that is being considered, please contact me.
North Island Conservation Officer New Zealand Recreational Canoeing Association