Submission on applications for Resource Consents under Section 96 of the Resource Managment Act 1991
From: New Zealand Recreational Canoeing Association
c/o Maree Baker
All applications by Genesis Power Ltd relating to the Tongariro Power Development scheme received by Manawatu-Wanganui Regional Council. (101275-101296, 101299, 101302-101307, 101309 and 101310)
All applications by Genesis Power Ltd relating to the Tongariro Power Development scheme received by Waikato Regional Council. (103863, 103864, 103866, 103867, 103869-103871, 103877-103885, 103887, 103893, 103897-103902, 103904, 103905)
Statement of Submission.
The NZRCA oppose the application of Genesis Power Limited for the Water permits, Discharge permits and Land use consents to use the water from rivers and streams that flow from the Ruapehu/Ngauruhoe Tongariro mountain system and related catchments to generate electricity.
The particular parts of the application the NZRCA opposes are:
- the damming of rivers and streams; and
- the diversion of water; and
- the discharge of water; and
- the disturbance to river beds.
The reasons for making this submission are:
- 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 represents both individual members and affiliated member clubs. Currently there are approximately 20 member clubs affiliated to the NZRCA.
- The NZRCA has the delegated authority to represent the NZ Canoe Federation on conservation issues.
- The NZRCA is committed to long-term sustainable management of New Zealand's water resources. The NZRCA is a nationally recognised body that has continued to be actively and constructively involved in resource management processes.
- The NZRCA (and its predecessor the New Zealand Canoeing Association) has been an active participant in the consultative process leading up to these applications, managed by Genesis Power Ltd, and its predecessor the Electricity Corporation of New Zealand Ltd. In participating in the consultation process, the NZRCA has welcomed the opportunity to discuss issues relating to further investigations and mitigation options.
- We believe the proposal as it stands in the Assessment of Environmental Effects will have adverse effects on the recreational amenity values, natural character, flora and fauna and landscape and amenity values of the various catchments affected by the Tongariro Power scheme. These adverse effects are not adequately mitigated by the consent conditions proposed by Genesis Power Limited.
- The Ruapehu/Ngauruhoe Tongariro mountain catchment system and related waterbodies have significant value for recreational canoeing, kayaking and rafting ranging from regionally significant to nationally outstanding, and these values are adversely affected by the proposal. Specifically affected water bodies include but are not necessarily limited to:
- Whangaehu river,
- Moawhango river,
- Upper Tongariro river,
- Lower Tongariro river,
- Whakapapa river,
- Whanganui river.
The effects on these water bodies are not adequately mitigated by the proposed consent conditions.
- It may be possible to mitigate the adverse effects of the proposal with a combination of the mitigation measures, including but not necessarily limited to the following:
- Scheduled weekend recreational releases at a variety of flows but of at least 35 cumecs on the upper and lower Tongariro;
- Guaranteed minimum flow of 20 cumecs on the lower Tongariro;
- Scheduled weekend natural flows on the Whakapapa;
- Assurance that proposed "flushing" flows on the Moawhango are able to be managed and scheduled to maximise use by recreational kayakers and rafters;
- Implementation of willow and debris clearance programme on Moawhango to remove dangerous obstructions to river flow and to remedy the absence of natural flows;
- Publicly available flow information and flow predictions on river sections used by kayakers, by means of 0800 freephone, internet and auto email, given the unpredictability of flows on a controlled river;
- Suitable warning signs provided and maintained by Genesis at all diversion barrages, Rangipo Dam and Tree Trunk Gorge "get-ins" and any artificial structures;
- Guaranteed access to the kayaking public over any roads and structures owned or managed by Genesis which are required to enable access to the rivers;
- Negotiations by Genesis with private landowners, with a view to guaranteeing access for recreational river users over private land;
- Provision of services to offset the loss of recreational amenity values on adversely affected water bodies and the non-avoidance of these adverse effects, including:
Appropriate external mitigation project; and/or
- (i) The applicant's proposal does not adequately avoid, remedy or mitigate the adverse environmental and specifically the effects of the proposal on canoeists, kayakers and rafters.
- (ii) Active promotion of releases and natural flow weekends.
- Statutory Considerations
The following statutory provisions of the Resource Management Act set the threshold for the assessment of resource consent applications. It is our submission that the proposal does not achieve the following:
Section 5 - Purpose
"s 5 (2) 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 reasonably 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."
Section 6 - Matters of National Importance
"In achieving the purpose of this Act, all persons exercising functions and powers under it, in relations 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:
d) The maintenance and enhancement of public access to and along the coastal marine area, lakes, and rivers."
Section 7 - Other Matters
"In achieving the purpose of the 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:
b) The efficient use and development of natural and physical resources:
c) The maintenance and enhancement of amenity values:
f) Maintenance and enhancement of the quality of the environment."
The NZRCA wishes the consent authorities to make the following decision
Decline the application
We do wish to be heard in support of our submission.
We reserve the right to be heard in conjunction with other submitters.