Submission on Ruapuna Irrigation

NZRCA's submission on the Ruapuna Irrigation Limited resource consent application regarding the existing Rangitata diversion intake, compiled by Maree Baker.

To: Canterbury Regional Council

From: New Zealand Recreational Canoeing Association (hereinafter NZRCA)
C/o Maree Baker Conservation Officer

Consent Nos. CRC000793 & CRC000794

  1. The NZRCA oppose the application of Ruapuna Irrigation Limited for land use consents and water permits to disturb the river bed, construct and operate an irrigation intake structure and to take up to 8 cubic metres per second of surface water from the Rangitata River for irrigation and electricity generation.
  2. The particular parts of the application the NZRCA opposes are:
    • Disturbance of the river bed
    • Erection of structures in the river bed
    • The taking of water
  3. The reasons for making this submission are:
    1. The NZRCA is the national representative organisation of canoe clubs 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.
    2. The association represents both individual members and affiliated member clubs. Currently there are over 20 clubs affiliated to the NZRCA. The local NZRCA member clubs that are affected by this proposal are Otago Canoe and Kayak Club, Otago University Canoe Club, University of Canterbury Canoe Club, Waimanui Kayak Club Inc and White Water Canoe Club.
    3. The NZRCA is committed to long-term sustainable management of New Zealand's water resources. The Association is a nationally recognised body that has continued to be actively and constructively involved in resource management processes.
    4. We believe the proposal as it stands will have adverse effects on the amenity values of the Rangitata. The natural character and wildness of the river will be adversely affected, as will the navigability and recreational value, particularly at periods of low flow.
    5. The Rangitata is a popular river, used regularly by local canoeists, clubs, outdoor education institutions and individuals. The run from the Klondyke down to the Peel Forest Campground is a good beginner - intermediate grade two trip.
    6. The Rangitata from the Klondyke down is a regionally significant river, to the Otago and Canterbury regions. It offers an accessible white water experience in a wild and natural area.
    7. To our knowledge there has been no consultation with canoeing organisations, and in particular the NZRCA has no record of consultative information nor discussions with the applicant or their consultants.
    8. Consequently the recreational values that canoeists and kayakers attach to the Rangitata river have not been accurately assessed. Section 5.14 of the AEE states that 0.25m is a reasonable minimum depth for canoe passage. This and other statements about canoe usage have been made without consultation and do not accurately describe the adverse effects of the proposed activities on recreational canoeists. The recreational value of a river is not merely dependent on the ability to navigate without touching the bottom. The volume of flow creates white water features such as waves and holes. If there is not sufficient volume to create these features, then the values of the river are substantially decreased.
    9. The NZRCA disagrees with the statement in 5.14 of the AEE, that the proposed activities should not have any significant effect on canoe passage. No consultation or information exchange has taken place from which to make that assessment. It is possible that the taking of water from the Rangitata river will lead to significant adverse effects on the recreational values of the river, and this must therefore be properly assessed before considering granting resource consents.
    10. Activities associated with disturbance of the river bed and construction of structures on and adjacent to the river bed have the potential to pose safety risks to canoeists, kayakers and other river users. As no consultation has taken place, and insufficient details of the proposal have been provided, we have been unable to assess whether or not such safety risks are inherent in the proposal.
  4. Statutory Consideration

    (a) The following statutory provisions of the Resource Management Act set a clear threshold for the assessment of resource consent applications. It is our assessment and submission that these tests are not met by this proposal:

    • S 5 (2) Purpose In this Act, "sustainable management" means managing the use, development, and protection of natural and physical resources in a way, or at a rate, which enables people and communities to provide for their social, economic, and cultural wellbeing and for their health and safety while:
      (a) Sustaining the potential of natural and physical resources (excluding minerals) to meet the reasonable foreseeable needs of future generations; and
      (b) Safeguarding the life-supporting capacity of air, water, soil, and ecosystems; and
      (c) Avoiding, remedying, or mitigating any adverse effects of activities on the environment
    • s 6 Matters of National Importance
      In achieving the purpose of this Act, all persons exercising functions and powers under it, in relation to managing the use, development, and protection of natural and physical resources , shall recognise and provide for the following matters of national importance:
      (a) The preservation of the natural character of the coastal environment (including the coastal marine area), wetlands, and lakes and rivers and their margins, and the protection of them from inappropriate subdivision, use and development.
    • s 7 Other Matters
      In achieving the purpose of this Act, all persons exercising functions and powers under it, in relation to managing the use development and protection of natural and physical resources, shall have particular regard to:
      (c) The maintenance and enhancement of amenity values
      (f) Maintenance and enhancement of the quality of the environment
  5. The NZRCA wishes the consent authority to make the following decision:
    • Decline the applications for the consents cited
  6. The NZRCA does wish to be heard in support of our submission.

Maree Baker
Conservation Officer
New Zealand Recreational Canoeing Association