Consents Administration Section

Environment Canterbury

PO Box 345

CHRISTCHURCH

July 2006

Dear Sir/Madam,

Name of submitter: New Zealand Recreational Canoeing Association (NZRCA)

The NZRCA is the national representative organisation of canoe/kayak 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/access issues.

This is a submission on applications from Central Plains Water Trust for various resource consents applying for water abstraction and use within the Central Plains area.

We oppose the applications in their entirety, and particularly:

· CRC061940: to divert water in the Rakaia River towards the intake structure

· CRC021091: to take water from the Rakaia River for water enhancement (sic) schemes in the Central Plains area

· CRC061941: to divert water in the Waimakariri River towards the upper intake

· CRC061943: to divert water in the Waimakariri River towards the lower intake

· CRC061972: to use water from the Waimakariri River (lower and/or upper intake)

The reasons for our opposition are set out in the following sections of our submission. We provide additional information emphasising some of the key issues specifically facing recreational paddlers in terms of the Central Plains Irrigation Scheme.

We seek the following decision from the consent authority: Decline all applications.

We wish to be heard in support of our submission. We would consider presenting a joint case at the hearing if others make similar submissions.

We would prefer to refer to the scheme in question as the Central Plains Irrigation Scheme, as opposed to the Central Plains Water Enhancement Scheme, since in our view we do not believe the scheme to exhibit any potential for enhancement of a public water resource.

Yours faithfully,

Kieron Thorpe

Conservation Officer, South Island

New Zealand Recreational Canoeing Association

P.O. Box 284, Wellington

conservation@rivers.org.nz

1. Reasons for Our Submission

The proposed Central Plains Irrigation Scheme will significantly detract from the paddlesports value of the Waimakariri and Rakaia Rivers.

The proposed reduction of flow will impair the value, navigability and safety of the river environments. The intention of the scheme is to remove approximately 45% of the median flow of the Waimakariri river, and nearly 13% of the median flow of the Rakaia. Such a massive reduction in flows will have a huge affect on both the Waimakariri and the Rakaia from a paddlesports perspective.

The scheme was initially presented as a water harvesting scheme that would skim water from the river during times of flood, and was granted requiring authority status on that basis. Since requiring authority status was secured, it has become increasingly obviously that the scheme is intended to be a primarily run of river system, drawing water from the river during times of low to medium flows. We object strongly to such a total ‘about face’ of the entire abstraction concept.

The construction, operation and maintenance of water abstraction works and irrigation canals will impair the value, navigability and safety of the natural river environment. The preliminary drawings of the abstraction works show little concern for the safe passage of paddlers and other non-combustion powered river users. The proposed abstraction systems will, beyond the drastic loss of amenity, present a very real safety risk to paddlesports and could easily result in loss of life.

Three Assessments of Environmental Effects prepared in 2001 (2) and 2006 (1) make little mention of the widespread use of these rivers for canoeing and kayaking, and little mention of the many severe detrimental effects of the proposed scheme on paddlesports.

The Assessments of Environmental Effects released in 2001 also state that “canoeists/kayakers... require a minimum water depth of...0.1 metres”. This is a categorically wrong statement and illustrates the extent of ignorance exhibited by Central Plains Water Limited and its consultants on paddlesports.

Furthermore, CPWL has made no attempt to improve its knowledge of paddlesports issues.

Consultation with the NZRCA, Arawa Canoe Club and the Whitewater Canoe Club (two of the largest such clubs in New Zealand) has been non-existent, despite a recent press release dedicated to grand claims of multiple recreational benefits the scheme will deliver. This press release detailed a specific, high profile recruitment by CPWL "to talk to a range of recreational groups to find out if there are any opportunities that could be worked into the final design of the irrigation scheme.” As of this date, and to our knowledge, no such talks have occurred.

We therefore have no choice but to conclude that CPWL has no intention of either educating itself on paddlesports issues, or of undertaking the slightest investigation into recreational opportunities, let alone actually developing any.

Furthermore, were we to believe CPWL’s stated intentions, any recreational mitigation suggested by the Assessments of Environmental Effects is nevertheless vague, ill-informed, irrelevant and quite clearly the result of very little genuine deliberation.

The suggestion that the recreational potential of flatwater environments such as the proposed irrigation canals and storage lake is sufficient mitigation for the destruction of a natural swiftwater resource is frankly insulting to most river sport enthusiasts.

2. A History of Paddlesports on the Waimakariri and Rakaia Rivers

2.1. Introduction

The Waimakariri River (Cold, Rushing Water) is the most heavily used river for recreation purposes in Canterbury. Its proximity to Christchurch has ensured its popularity for many years, though to have been first used for paddlesports in the 1880s. The Rakaia River has also been paddled since the 1880s.

Both the Waimakariri and Rakaia are braided through the Canterbury Plains and as such offer a special paddling experience. Their constantly changing gravel beds can completely alter the course of the river overnight. This, couple with the relatively benign nature of a typical rapid, adds greatly to their value as training environments since it is a stark reminder to all its paddlers to heed one of our fundamental maxims: “every trip is on a new river”.

The Waimakariri and Rakaia rivers are best described as swiftwater environments as opposed to whitewater environments. Swiftwater rivers can be defined as exhibiting strong currents but few violent and/or highly dangerous rapids. These rivers are ideal learning environments, as they exhibit relatively swift currents and numerous opportunites to practise the fundamental skill of crossing from slack water to fast water and vice versa (eddy turns), yet few real dangers such as boulder sieves, undercut rocks or ‘keeper’ hydraulic jumps.

Their proximity to Christhchurch and difficulty level of Class 2 (on a scale of 1 to 6) makes the Waimakariri and Rakaia rivers perfect environments for developing our future athletes.

Should the considerable amenity value of the Waimakariri and Rakaia rivers be compromised, the nearest rivers of similar nature are the Rangitata and Waitaki. The State Highway bridge over the Rangitata is approximately 120km from Christchurch. The State Highway bridge over the Waitaki is approximately 220km from Christchurch.

2.2. Private Trips

The demands of the proposed irrigation scheme are in direct opposition to the needs of over 1000 citizens of Christchurch alone.

Many people paddle on the Waimakariri purely for fun or as part of a training regime. Numbers naturally increase during the summer, a time of naturally low flows and high irrigation demand.

Given that in Christchurch alone there are over 600 members of canoe and kayak clubs and up to 500 individual paddlers, it is estimated that approximately 100 of these would paddle the Waimakariri at least once a week. Therefore an estimated five thousand or more personal river experiences would be threatened annually.

The AEEs lodged by CPWL make no attempt to estimate the scale of popularity of the Waimakariri and Rakaia rivers among the paddlesports community.

2.3. Races

2.3.1. Coast to Coast Race

The Coast to Coast is one of the most well known multisport events in the world. It is held in February and has been running annually since 1982. Approximately 1000 competitors, from all over the world, come to kayak 67km of the Waimakariri River. The kayak course begins at Mt White Bridge, passes through the Waimakariri Gorge, and exits at the Gorge Bridge.

The AEEs lodged by CPWL make no mention of the Coast to Coast Race.

2.3.2. Waimak Classic Race

The ‘Waimak Classic’, run by Arawa Canoe Club, is held in December and has been running annually since 1989. On average, it attracts approximately 150 competitors. The course route is the same as that taken by the kayak leg of the Coast to Coast Race.

The AEEs lodged by CPWL make no mention of the Waimak Classic Race.

2.3.3. Brass Monkey Race

The Whitewater Canoe Club Brass Monkey Race is an annual kayak race series held on the Waimakariri. Five races are held fortnightly throughout June to August of every year since 1989. Up to 150 and 200 competitors paddle a 12 km course from the western end of Coutts Island Road (approx. 2470005E, 5751000N NZMG) to the State Highway 1 Waimakariri road bridge at Bridgend.

The AEEs lodged by CPWL make no mention of the Brass Monkey Race.

2.4. Instruction Trips

Numerous coaching organisations introduce beginner kayakers and multisport athletes to swift water on the Waimakariri.

The AEEs lodged by CPWL make no mention of the use of the Rakaia and Waimakariri rivers for paddlesports instruction.

3. Environmental Impacts of Reduced Flows on Swiftwater Paddlesports

The proposed irrigation scheme aims to significantly reduce the flow of the Waimakariri and Rakaia rivers, reducing the median flow of the Waimakariri by 45% and the Rakaia by 12%. This is a dramatic reduction in the value paddlers place on the river, and completely unacceptable to our sport.

3.1. Reduced Variety of Experience

Paddlers value the variety of experience that a range of flows brings. A popular paddling maxim is ‘every paddling trip is on a new river’. Every trip, even on the same river, is a new experience. bringing new choices of routes or ‘lines’ through a rapid, new rapids in their entirety, and a different, valued experience.

Nowhere are these facts more starkly obvious than on braided gravel rivers such as the Waimakariri and the Rakaia.

The ‘hydrograph flatlining’ proposed by CPWL is a direct reduction in the variation of the natural flow regime of the Waimakariri and Rakaia rivers. This is also a direct reduction in the variety of experience valued by paddlesports, in terms of the river’s flow, the choice of routes through the various braided channels, and the ever-changing nature of the braids themselves.

3.2. Reduced Depth

The Assessments of Environmental Effects submitted on the Waimakariri and Rakaia intakes in 2001 state that a kayak requires a draft of 0.1m. We dispute this figure for the following reasons.

3.2.1. The figure does not account for the many designs of paddlesports boats, or the nature of their use.

Kayak and canoe designs come in many shapes and sizes, from multisport race designs in excess of 5 metres long, to whitewater ‘play boats’, many of which are less than 2 metres long.

Larger paddlers in smaller boats can still require drafts of over 200mm. When held on an edge (much like skis and surfboards, shorter kayaks and canoes are designed to be dynamically steered by ‘edging’), a paddlesports boat can attain even deeper drafts.

Touring and racing boats, although longer, are designed to cut through the water in order to sustain higher speeds. These boats are often much thinner than shorter designs and as such can require depths of up to 250mm merely to float.

3.2.2. The figure does not take into account the required depth for a rudder.

Many longer designs such as touring, sprint and multisport boats feature a rudder. which is required for safe and effective manoeuvrability.

In most cases, the rudder is hinged such that it will not break in shallow water. However, water that is shallow enough to cause the rudder to hinge up will result in impaired manoeuvrability for the kayak. This can result in:

· grounding, which can damage the hull,

· flipping, which in shallow water especially can force the paddler to exit, or ‘swim’

Rudders generally require depths of between 200 and 300mm.

3.2.3. The figure does not take into account the depth reached during a paddle stroke

Most ‘whitewater’ style paddles have blades approximately 450mm long. Racing wing-style paddle blades are longer still, up to 550 or 600mm. A correct forward stroke employs a near vertical blade, fully planted in the water. To effect maximum power and provide assurance feedback to the paddler, the power hand is often submerged.

A paddle can reach depths of up to 0.7m.

3.2.4. The figure does not take into account the depth required to safely roll, or self-rescue the boat.

Most downriver paddlers are capable of self-righting their boats in the event of a capsize, using the well know 'eskimo' roll procedure. During this manouvre the paddler reorients his or her body and paddle against the side of the boat and performs a combined sweeping stroke and body rotation to right the boat.

Were the paddler's freedom to move around underwater denied, the paddler could be forced to swim, incurring safety risks and generally lowering the paddlesports value of the river.

When upside down and attempting to reorient the paddle into a roll set-up, a paddle blade can reach depths of up to 2m.

3.2.5. The paddlesports value of a river cannot be so simply defined in terms of the depth required to keep a kayak or canoe afloat

Further to the points made above, downriver kayaking and canoeing is a sport in which the paddler moves the boats by harnessing the energy of the current, using the combined interaction of the paddle, boat and current. This is analogous to a sailor using the sail and keel of the vessel to harness the wind. Sailors, as a rule, prefer to sail where the breeze is brisk enough to provide a degree of excitement. Downriver paddlers view the current of the river in exactly the same way. Depths that prevent a fully submerged paddle are useless in these terms. As an example, multisport and downriver paddlers make little use of the Avon river, where the current velocity is far below the terms of reference of a downriver trip.

Furthermore, a phenomenon known as 'bottom drag' occurs in channels less than 2m deep. Bottom drag is caused by the subsurface interaction of a boat's bow and stern waves against the channel bottom. To prevent bottom drag occurring to racing paddlecraft, the International Canoe Federation recommends a minimum channel depth of 2m for kayak and canoe races.

3.3. Increased Risks posed by Bankside Vegetation and Structures

The banks of the Rakaia and Waimakariri are populated by willow trees and other types of overhanging vegetation. The banks of the Waimakariri also feature flood protection and erosion control works. These works include concrete blocks with protruding steel bars, as well as timber posts and other such objects.

Bankside vegetation and flood protection works can form what are known as 'sieves' or 'strainers'. These present a significant drowning risk to paddlers. Once caught up in a sieve, a paddler is generally flipped upside down, from which it is essentially impossible to perform a self rescue roll. The paddler is invariably forced to swim, whereupon the swimmer is forced further into the bank and under the trees, branches, steel bars, etc. by the current. From here, neither escape nor rescue is an easy undertaking and drowning is a very real possibility.

Lower flows in the river narrow the navigable channel width, especially at bends, where sieves and strainers are most often found. These channels become exponentially more difficult to navigate, especially in longer race and touring boats, with an exponential increase in the consequences of a failure to avoid the hazard.

3.4. River Morphology and Sediment Transport

An important function of medium to high river flows is to transport sediment from the mountains to the sea.

Reduced flows will result in a major effect on the sediment transport regime of the river. More sediment will be deposited on the bed and the bed will rise from its natural level. This will result in bank erosion and subsequent flooding. In kayaking terms, localised sediment deposition will directly affect the navigability of the river.

The argument that sediment transport is principally effected by large floods is incomplete. Smaller floods have an effect too. Were the ability of the small to medium floods to move sediment undone, then this would leave more work for the large floods to do. The large floods can only do so much work, and there is a risk that they will not be able to address the deficit.

Furthermore, the reduction of average flows and frequency of smaller floods or ‘freshes’ will enable greater encroachment of riparian vegetation, which will bind the bankside soils and make them less susceptible to movement. Once established on sediments that were once moved by the freshes, this vegetation will hinder the effect of the larger floods.

It is our contention that permanent alterations to the morphology of the river and subsequent increases in bankside vegetation would firstly enhance the risks presented by sieves or strainers as previously described, and secondly reduce the value of these rivers as a paddling experience.

4. Environmental Impacts of Abstraction Works and Distribution Canals on Swiftwater Paddlesports

4.1. Diversion Channels and River Training

River training, or the practise of diverting the river into one channel that will deliver water to the primary intake, is detrimental to the value of the river in terms of paddlesports. The natural river bed is essentially destroyed for the length of the trained section. The downstream outlet of the diversion channel can become shallow, since the trained section is usually designed to keep the water level high enough to allow irrigation takes to continue. These outlets may be difficult or even impossible to navigate.

Narrowing the river at these sites also poses safety risks. Passing paddlecraft are forced closer to the irrigation intakes, which as a rule are something that paddlers try to stay well away from. One of the proposed sites on the Waimakariri is used as a base of operations for a commercial jet boating company. Large passenger jet boats arrive and depart this site on a regular basis during the height of the paddling season. Forcing paddlesports and jet boats to share the same narrow stretch of water would constitute a significant safety risk to all parties.

Furthermore, large plant such as excavators would be required to operate in the same area to keep the diversion channel in order. This increases the risk to paddlers still further.

Siltation in the river is a common side effect of river training works. Silt is an eye irritant and causes damage to paddlesports clothing.

4.2. Primary Intake Structures

The drawings of the primary intake structures developed thus far indicate multiple submerged radial gates built into a headwall. There are six radial gates 2.5m wide by 1.0m high. We calculate that for a capacity of 20 cubic metres per second (half the take proposed from the Waimakariri), the average velocity through these submerged gates would be 1.33 metres per second, or nearly 5 kilometres per hour.

In reality due to friction and boundary effects the maximum velocity at the orifice is likely to be much higher. Furthermore, were these structures designed to draw more than half the total take (such that the capacity of the scheme would be less impacted by ‘shutdown’ maintenance at one intake site), the velocity will be greater still.

In short, such velocities will create suction effects that few kayakers or canoeists would have much hope of overcoming. The likelihood of entrapment and subsequent drowning, should a swimmer, or even a fully afloat and in control paddler, find him or herself in the vicinity of one of these structures, is terrifying.

These dire prospects are exponentially worsened by the fact that the river bed itself would be ‘trained’ to divert the maximum flow possible directly towards the intakes, and that the overflow spillways at the intake sites will be difficult, even impossible, to navigate.

4.3. Bar Screens and other Grating Structures

Kayaks, especially recreational river running designs, are among the slowest watercraft available. A small playboat design, when propelled on flat water by the most powerful paddler, is barely capable of maintaining a walking pace, even for short periods. An intake velocity that exceeds the maximum sustainable velocity of any kayak likely to be in the vicinity could result in entrapment.

Gratings present the following hazards to kayakers:

· Breaching – this is when a kayak is stuck broadside on the grating. Breaches can occur anywhere on the roll axis of the kayak – upright, upside down, or with the beam perpendicular to the water surface

· Pitoning – in the case of kayaks with thin bow or stern sections, the hull can become jammed between the bars of a typical bar grating.

· Wrapping – either a breach or a pin can result in what is termed a ‘wrap’, when the force of the water overcomes the structural strength of the boat and the boat crushes. Long multisport boats are particularly vulnerable to this.

· Forced exit – if a kayaker cannot free his or her boat from the obstacle from while remaining inside, he or she must exit the boat.

· Entrapment – worse still, if a kayaker wishes to exit but is prevented from doing so by the obstacle itself, then an entrapment situation is in effect. An entrapment, for obvious reasons, is widely recognised as a kayaker’s worst nightmare. Entrapment can occur when the cockpit is forced against the grating in a breach, or when a pin results in the legs trapped inside the hull, or simply when the force of water against the paddler’s body overcome the padller’s strength.

4.4. Hydraulic Jumps

An engineered hydraulic jump is one of the most dangerous hazards posed to downriver paddlesports enthusiasts. It is a smooth, vertically recirculating designed to reduce the energy of the current within a concrete lined channel, thereby lowering the scouring potential of the water in the downstream earth lined channel.

Naturally occurring hydraulic jumps almost always have a weak point somewhere that enables a skilled paddler to escape whilst remaining in his or her boat. Even an unskilled paddler, upon deciding to swim, will be flushed underneath most natural jumps and on downstream, none the worse for wear.

Engineered hydraulic jumps are constant across the cross section of the channel, without any ‘tongues’ of current breaking through the feature that an in-boat paddler might try to head for to effect an escape. Should an in-boat paddler become trapped in such a feature, they are held in the recirculation zone. In-boat escape is effectively impossible and the paddler is eventually forced to swim.

The swimmer is now caught in the recirculation zone, which usually reaches the bottom of the channel, pushed downstream for a few metres, then back up to the surface only to be drawn back upstream to the interface to repeat the whole disorienting process.

The only hope of a solo escape is to surface far enough downstream to be able to swim away from the interface. Unfortunately the swimmer is generally highly disoriented by the ordeal and does not know when, or which way, to swim.

Complete exhaustion could be expected to occur within a few cycles - within ten to thirty seconds, depending on the size and power of the jump - and death soon after.

The only hope of rescue from a ‘well engineered’ hydraulic jump is bankside assistance, generally in the form of a ‘throwrope’. Unfortunately in a throwrope rescue situation the rescuee needs to be as alert as the rescuer, an in such instances this is not usually the case, and more elaborate and time consuming methods become necessary.

Furthermore, most throw ropes are no more than 20m long, and the maximum practical distance a throwrope can reach beyond the bank, even in skilled hands, is half its length. Therefore, in paddlesports terms, any engineered hydraulic jump more than 10m long poses a significant safety risk to even the most well equipped paddler.

4.5. Sluice Discharges, Emergency Releases and Canal Failure

The frequent sluice discharges proposed by CPW will result in immediate and erratic increases in the flow of the river, known as 'pulse' floods. This will result in the navigational difficulty of the river increasing almost immediately and without warning. This presents an especially significant hazard to instruction groups and learning paddlers. Even experienced paddlers will be taken very much by surprise and put at risk by pulse floods.

Sluixing discharges will also release large volumes of sediment, up to 20,000 cubic metres per year per settling basin. Based on a weekly discharge this equates to 385 cubic metres of sediment per discharge. High sediment loads cause a great loss of paddling amenity and present a safety risk.

Worse still is the very real risk of a canal failure. Should the main canal fail close to the take site, a massive volume of water will be released into the river without warning, causing massive damage and possible loss of life.

Large pulse floods will alter the river bed as they happen, such that anyone on the river at the time will have to contend with large floods of muddy water and a shifting riverbed at the same time.

4.6. Access

There are no bridges proposed over the main irrigation canals in the vicinity of the river. This will prevent access along the bank at these sites. Therefore, should a paddler become separated from his or her boat and swim to the bank upstream of the irrigation take, then he or she will be unable to walk down the bank to retrieve equipment. The paddler will be forced to swim past the irrigation intake, in a narrow, trained channel that will be shared by jetboats and heavy earthmoving equipment.