Before a Special Tribunal
Under the Resource Management Act 1991
In the matter of an application for a Water Conservation Order for the Ngaruroro River and Clive River
Statement of Evidence of Dr Douglas Alexander Rankin on behalf of New Zealand Fish and Game Council, Hawke's Bay Fish and Game Council, Royal Forest and Bird Protection Society of New Zealand, Jet Boating New Zealand, Whitewater NZ Incorporated and Ngāti Hori ki Kohupatiki
17 October 2017
Introduction
1 My name is Douglas Alexander Rankin.
2 I have been engaged by Whitewater NZ to assist with their application for a WCO on the Ngaruroro River by characterising the kayaking/rafting values of the Ngaruroro River in a regional and national context.
Qualifications and experience
3 I am 64 years old and reside in Christchurch. I hold BSc (Hons) and PhD degrees in Chemistry from the University of Canterbury and have worked all my professional life until 2010 as a research chemist and scientist in wool science1 at the Wool Research Organisation of New Zealand (Inc) and its successors.
4 In the last five years I have been working virtually full time in a voluntary capacity as Conservation Officer for Whitewater NZ, on various issues concerning river and water conservation in New Zealand.
5 Since being introduced to sailing boats as a youngster, and then joining the University of Canterbury Canoe Club (UCCC) in 1971, and building my first canvas white water kayak, I have developed a life-long interest in white water paddling. This has involved me making journeys over the last forty six years to various well-known white water rivers throughout New Zealand and also in the United Kingdom, France, Austria, Germany, Switzerland, Australia and the USA. In addition to kayaking I have in the last 20 years also enjoyed using other white water craft such as rafts, catarafts2 and river bugs3 to make white water journeys both in New Zealand and overseas. In 2012 I was fortunate enough to cataraft the Grand Canyon of the Colorado River (I had kayaked it twice previously in 1985 and 1997) and a number of other classic wild and scenic river runs in Oregon and Washington in the USA. I have just recently returned from my fourth trip down the Grand Canyon, this time rowing an 18 foot gear and passenger raft (and doing a little kayaking and river bugging) as lead qualified boating operator on a 16-day private trip of various New Zealand and overseas friends.
1 Except for two years as a post-doctoral research fellow at the Unit of Nitrogen Fixation at the University of Sussex in Brighton, UK, from 1978-1980.
2 Two inflatable pontoon rafts with a metal frame between the pontoons, often fitted with oars for rowing and controlling the craft.
3 A river bug is a single person inflatable craft (a little like a single person raft) designed for river running in which the river ‘bugger’ sits facing downstream. The bugger uses fins on their feet and webbed hand gloves for propulsion and control, a full wetsuit, helmet and lifejacket, and descends the river feet first drifting down at the speed of the current (see http://bugsports.org/river-bugging/, accessed 2 October 2017).
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6 My white water paddling has also taken me into administrative, instruction and advocacy roles in the sport. I have held various positions from gear officer to treasurer and club captain and president within the UCCC, and the BugSports Club (Inc) and the Whitewater Canoe Club (Inc) both here in Christchurch. I have also been actively involved in the national body representing kayakers and white water paddlers interests in New Zealand, namely Whitewater NZ (Inc) (and its predecessors the New Zealand Recreational Canoeing Association (NZRCA) and the New Zealand Canoeing Association (NZCA)), primarily as Conservation Officer and supporting and leading conservation cases. I am a life member of the UCCC, and an awardee of the Canard Cup from the New Zealand Canoeing Federation, the latter for services to river conservation in New Zealand and particularly for my role on behalf of the NZCA in the Buller Water Conservation Order (WCO) application.
7 Since my earliest days paddling I have appreciated the value and conservation of the best white water recreation resources both here and abroad. This interest was heightened for me during my two years as a post-doctoral research fellow at the University of Sussex in the UK in 1978-1980. There I was also able to travel and kayak a little in the UK and Europe on some of the classic white water runs (and others that I have since done including the Dee, Isel, Inn, Möll, Loisach, Sanna, and Leiser, and the Olympic white water course at Augsburg) and also witness first-hand the demise of many of its waterways through damming.
8 Since then I have been actively involved in advocacy for kayakers and rivers in New Zealand, in activities ranging from submitting and producing evidence for Regional Water Boards, Special Tribunals and the Environment Court, to leading kayaking cases for Whitewater NZ for Water Conservation Orders (Buller, Rangitata and Hurunui) on some of New Zealand’s outstanding white water rivers. I have submitted and presented evidence to Regional Councils and Department of Conservation (DOC) Hearings (the most recent being the Westpower concessions on the Waitaha River in December 2016) and the Environment Court on resource consents and/or concessions impacting on kayakers values. I have also been involved in assisting with NZCA surveys to quantify river values throughout New Zealand and more recently involved in regional planning processes on behalf of Whitewater NZ and writing on kayaking values in the Canterbury region [1].
9 I have developed a strong interest in river and groundwater hydrology and water quality, and flow and other requirements needed to provide for kayaking and white water values. I have done this to support effective engagement in advocacy, and I have submitted to various parties and presented to Hearings on such matters. This has involved me using my expertise as a scientist, and also as an expert kayaker and river runner. This kayaking and technical expertise has been ground-truthed by numerous conversations with other expert paddlers here
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and overseas and other experts in their own fields over the years. I have done this to ensure my views reflect those of the wider paddling community, and that I have the right understanding concerning other technical matters.
10 I have been fortunate to have kayaked and/or rafted and bugged4 many of the classic outstanding white water runs on rivers in New Zealand at up to a Class IV- IV+ level of technical difficulty, including many runs on more remote rivers accessible essentially only by helicopter. This has included normally repeat visits to nationally outstanding runs such as on the Landsborough, Waiatoto, Mokihinui, Karamea, Whataroa, Rangitikei, Mohaka, Motu, Ngaruroro, Tongariro, Kawarau, Grey, Buller, Maruia, Matakitaki, Clarence, Hurunui, Rangitata, Waiau and Glenroy as well as regionally outstanding runs on other rivers primarily in the South Island such as the Waimakariri Gorge, Ashley Gorge, Taipo, Okuku, Takaka, Wairoa (Nelson), Opihi, Grebe and others. A number of these river runs are recognised for their outstanding white water and kayaking and rafting values by inclusion in Water Conservation Orders (WCOs), but for various reasons many are not.
11 In addition, I have run a number of outstanding wild and scenic rivers overseas including the Franklin in Tasmania (in a world heritage area), a number in Western Europe, and the Grand Canyon of the Colorado River (one of the seven natural wonders of the world) and the Clackamas, Klickitat, Tutle, Wind, White Salmon, Rogue and Klamath in the USA. This river running experience and my scientific expertise has put me in a very good position to be able to comment knowledgably and comprehensively on the different features, values and aspects that make many white water runs so valuable to the New Zealand and wider white water recreation community.
12 My involvement in this Water Conservation Order application and process to date has been as Conservation Officer of Whitewater NZ. I have primarily assisted with the gathering, coordination and provision of sufficient information to support the application to date with regards to kayaking and rafting values. This has involved a degree of analysis of relevant literature known to me, and which in some cases I have co-authored, as well as gathering contributions from (and discussion with) various other paddlers.
13 While this is not a hearing before the Environment Court, I confirm that I have read the code of conduct for expert witnesses contained in the Environment Court Consolidated Practice Note (2014). I have complied with it when preparing my written statement of evidence and I agree to comply with it when presenting evidence. I confirm that the evidence and the opinions I have expressed in my
4 Making river journeys using river bugs.
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evidence are within my area of expertise. I have not omitted to consider material facts known to me that might alter or detract from the opinions that I express.
Scope of evidence
14 My evidence will address:
(a) Personal experience of the Ngaruroro River;
(b) Activities carried out by kayakers and canoeists on rivers;
(c) Kayaking runs and flow requirements on the Ngaruroro River;
(d) Analysis of previous kayaking value assessments of the Ngaruroro River and comparison with other rivers nationally;
(e) The threat posed to kayaking values by irrigation or hydroelectricity power development in the Ngaruroro catchment;
(f) The kayaking values which warrant protection; and
(g) Concluding comments.
Personal experience of the river
15 I made my first visit to the Ngaruroro River in November 2011 when I made a descent from Kuripapango to Whanawhana as part of an overnight trip along with fellow catarafters and rafters from Christchurch, Blenheim, Nelson, Wellington and Taihape. Although I have paddled extensively in rivers in the South Island of New Zealand, I had up until then paddled little in the North Island, having been time constrained by my professional work as a research scientist and in bringing up a family.
16 Subsequently I have made two further trips from Kuripapango to Whanawhana both by cataraft.
(a) Labour weekend of 2012, another overnight trip with a contingent of over thirty kayakers, rafters and catarafters, including members of the Whitewater NZ Executive, kayakers from various kayak clubs from throughout New Zealand, and participants from other organisations such as River Valley, Fish and Game and the Catalyst Group; and
(b) Labour Weekend of 2016, another overnight trip facilitated by rafting support from River Valley and Mohaka Rafting, with various representatives from the WCO co-applicants.
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17 I have made one descent of the river from Boyd’s airstrip to Kuripapango (including through the Oxbow) by cataraft, just after Labour Weekend in 2012, accompanying a commercial rafting trip on a three day run by Hidden Valleys Ltd.
18 My overall impression from both these runs is that the Ngaruroro River contains outstanding wilderness, scenic and white water values. This impression has been subsequently affirmed on many occasions by other experienced white water kayakers I have talked to.
Activities carried out by kayakers and canoeists on rivers5
Introduction
19 Kayakers and canoeists6 use hard shell or inflatable craft called kayaks or canoes for travelling down rivers, and also on lakes and in the sea. Kayakers are attracted to paddling rivers for a variety of reasons including the excitement and challenge of negotiating or playing on rapids containing a variety of white water features; training and competing in multisport, downriver racing and white water slalom events; reading and using the water to enjoy the thrill and exhilaration of surfing on standing waves, playing in holes (looping the boat end over end, cartwheeling, doing flat spins, blunts, tail and nose stands), and executing numerous other free-style moves; executing underwater mystery moves while squirt boating; running drops or waterfalls, or particularly scenic white water rivers or spectacular gorges; or just surviving a run down through a miasma of crashing white water.
20 All facets of the sport except flat water kayaking or racing rely on moving water producing hydraulic features and rapids, which provide exciting features or a challenging pathway down a river. Each branch of the sport requires its own specialised and appropriately designed craft. For example, flat water and downriver racing paddlers use very long narrow fast craft often constructed of glass fibre, Kevlar and/or carbon fibre composites, whereas most other white water paddlers use polyethylene plastic craft that are much shorter, more stable,
5 This section of my evidence is largely taken (and modified) from a report I helped prepare for Environment Canterbury, and of which I was the lead author [1]. It summarises the essence of what constitutes river kayaking and canoeing.
6 The term kayaker and canoeist are often used interchangeably. Strictly speaking a canoeist kneels and uses a single bladed paddle in a canoe that may or may not have an enclosed deck. A canoe is of native-American origin. In a kayak a kayaker sits and uses a double bladed paddle and the boat normally has an enclosed deck. However, ‘sit-on top’ hard skin plastic kayaks and inflatable kayaks with no enclosed deck are now widely available and used, although not normally in more difficult white water. Kayaks are of Inuit origin. Despite this difference the term ‘canoe’ is often used to include kayaks but not generally vice versa. A ‘canoe club’, for example, often has more kayakers than canoeists as members and most paddlers in New Zealand are kayakers rather than canoeists. ‘Canoe polo’ is usually played in short purpose built kayaks. In this report the term kayaker and paddler covers both kayakers and canoeists.
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highly manoeuvrable and extremely robust and durable. The use of polyethylene plastic boats, which started about 30 years ago in New Zealand, has revolutionised the sport and the average standard of paddling has also increased significantly in recent years.
White water
21 White water hydraulic features that paddlers seek out are formed by the interaction of water flow or volume of discharge and the river bed morphology, and particularly the bed gradient and structural features, such as large rocks, ledges, and bank features. The hydraulic features include:
(a) Standing waves like ocean swells;
(b) Breaking waves or haystacks;
(c) Boils; upwellings from below the river surface;
(d) Holes or stoppers; recirculations formed behind submerged rocks or bed features which tend to stop and hold kayakers;
(e) Eddies; pockets of water behind bank and bed features where the water moves in a different direction to the main current;
(f) Eddy lines; boundary lines between eddies and the main current;
(g) Big water; large size hydraulic waves, holes and other features typically found in high flow and flooded rivers; and
(h) Drops, slides or waterfalls.
22 The size and power of such hydraulics depend on the flow down the river, the gradient or steepness of the bed and the roughness and features in the bed (gravel, rocks, bedrock). In smaller rivers with lower flows the size of features and power of the white water is normally smaller, whereas in rivers with larger flows more powerful hydraulics are produced including highly valued ‘big water’. This water is typified by very large waves and hydraulic features and is a sought after challenge by many more experienced kayakers. The hydraulic features are found in various combinations on rivers and produce rapids, sometimes only in small numbers where gradients are lower and in much higher numbers where gradients are steeper.
Technical difficulty of white water
23 The difficulty of negotiating these features is described by river Classes or Grades given to different reaches of water or rapids, with six Classes ranging
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from I to VI in order of increasing difficulty (Appendix I). Henceforth, I use the word Class, when capitalised, to refer to level of difficulty on this scale.
Kayaking activities
24 White water or touring kayakers generally make river journeys down reaches or parts of rivers, sometimes carrying gear in their boats for camping on overnight or longer trips. Such kayakers normally prefer rivers with many rapids and will often stop to inspect rapids to work out pathways down them or stop to play on suitable hydraulic features during a trip. Steep creek paddlers specialise in running hard (Class IV-V+) high gradient white water, often in steep creeks or rivers with waterfalls or rock slides, using specialised high volume boats designed to exit holes or recirculations at the bottom of waterfalls easily. Such kayakers normally wear protective arm and elbow pads.
Repairing canvas canoes in a Christchurch backyard in 1972. Trips down rivers in New Zealand in early days were in canvas boats until fiberglass boats arrived on the scene. The arrival of stronger fibreglass boats revolutionised kayaking and opened up the possibility of running much more difficult white water than was previously possible. Photo: Doug Rankin.
25 Squirt boaters use low volume kayaks designed to be easily submerged on hydraulic features such as eddy lines and spend much of their time executing moves below the water surface. Squirt kayakers primarily use larger volume rivers. Downriver and multisport racers mostly use multisport kayaks, specialised narrow fast purpose built craft made in New Zealand, on Class I-III white water. They normally focus on developing paddling fitness on river runs for competing in race events, rather than playing on hydraulic features. Wild water racers race Olympic class white water race kayaks that are 4.5 metres long down white water
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rivers or courses up to Class III or IV, and which are normally less than 10 km in length. Multisport or long distance racers will often use much longer kayaks (over 6 metres in length) and race longer distances, such as about 65 km down the gorge on the Waimakariri River in the Coast to Coast multisport race.
Ian Fox paddling a low volume plastic play boat, which is ideal and designed for playing on water features. Location: Grandstand Eddy (the pocket of water tucked in behind the rock on the bottom left of the picture) and running over the ledge and into Cheesegrater at 14 cumecs in Māori Gully on the Hurunui River. Photo: Graeme Wilson.
26 Rodeo7 and park and play kayakers use small short play boats and specialise in executing skilled technical, and sometimes aerial, acrobatics on well suited and structured hydraulic features. These include holes and waves on short sections of river or at single features that are sometimes artificially built in water parks (such as the two play waves recently constructed by Contact Energy on the Hawea River in Central Otago).
27 Paddling is predicated on having sufficient water available to produce water features and courses of value. For example, on a flat water or white water river for downriver race training, enough water will be needed to create sufficient depth (typically two metres) so boats don’t drag or squat. For a white water river, enough flow has to be present to create valued white water.
7 Now more commonly referred to as ‘free-style’ kayakers, will often compete in organised free-style events.
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Running white water
28 Paddlers read the water they are about to descend and choose a route or line down the river, which will give them the most fun and satisfaction. This might mean the fastest route of descent for competitive wild (white) water and slalom racers (the latter through an ordered course of gates suspended above the river) or that offering the greatest technical challenge, enjoyment or safest route for a white water, steep creek or touring paddler. Beginners may prefer white water small enough in size to give a certain level of excitement without being too frightening, whereas experienced paddlers may get their satisfaction from running bigger water and hydraulic features or big drops.
29 Paddlers negotiate their way down through hydraulic features, playing on them or sometimes avoiding them at all cost. Some of the features can form a serious hazard to kayakers, e.g., big holes that don’t release paddlers, waterfalls, or steep strainer rapids - where water flows between rocks often beneath the water surface but which doesn’t permit a boat or paddler to do so. Sometimes features are too hazardous or risky to run, except by the most skilled, and so are walked around or portaged. Thus, white water paddling can offer a serious technical and physical challenge to a boater.
The sport of kayaking
30 Kayaking is a sport and recreation that is growing in New Zealand with increased instruction through school, polytechnic, and private instruction organisations such as the New Zealand Kayak School. This, and registration of professional kayak instructors through the New Zealand Outdoor Instructors Association (NZOIA), and canoe club programmes has grown significantly the technical skills and uptake of the sport. School and polytechnic programmes often focus on personal and social development and risk assessment and management for young people, and also for training and educating them for future careers in teaching, kayak instruction, raft guiding and the tourism sector.
31 Most river kayaking is done in spring, summer and autumn. However, with the advent of dry suits8 and other purpose built paddling gear, kayaking can be carried out all year round. Thus, kayakers will sometimes run some rivers in winter when they have sufficient flows in them, especially if they do not have reliable flows in them at other times of the year. Kayakers also spend time honing their skills in the surf and by playing canoe polo in the winter off-season and
8 Dry suits are complete body suits normally made out of a breathable but waterproof fabric such as Goretex, and fitted with water tight zippers and latex wrist and neck seals. They are completely water tight and allow a paddler to stay dry and warm even in a wet and cold environment.
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learning, or practising, Eskimo rolling (self-righting a capsized kayak whilst remaining in the boat) skills in indoor pools.
32 It takes expert tuition, training and a lot of experience to make a good paddler of any discipline. Technique and skill are generally more useful than physical strength. Kayakers learn basic skills on flat water and easy moving water initially, and then progress to more difficult water. Basic skills like the ability to Eskimo roll are essential for tackling more difficult white water. Paddling takes you to hidden places amongst beautiful scenery and wilderness that many people never see. On a river you are the master of your own destiny – it is your knowledge, experience and skill that allows you to safely negotiate white water at any level of difficulty. Each kayaker is responsible for their own navigation, decision making and performance.
33 While kayaking is an individual sport it is almost always done in groups, because if you accidentally get caught on a rock or pinned on a log or in a rapid, or take a bad swim, your only chance of rescue is normally by the team of people you are with. This breeds a strong camaraderie amongst paddlers, who rely on self- knowledge, experience and skill, both in terms of looking after themselves and their paddling companions on a river. Rescue in some situations can only be accomplished by highly skilled and trained paddlers using tools such as rope and pulley systems and saws, adding another dimension to the sport. Paddlers on any river trip should always carry rescue and safety gear. Although there are risks, kayaking is one of the safest adventure sports.
Kayaking runs and flow requirements on the Ngaruroro River
Kayaking runs
34 The Ngaruroro River offers kayakers a range of kayaking runs and paddling experiences. They include two outstanding multiday wilderness kayaking trips, both of which are of a moderate Class and a reach of river valued as a nursery run for beginner kayakers. Landscape, vegetation, wilderness, scenery and class of rapids vary over the length of the river. The sections that are kayaked include:
(a) The upper river multi-day trip from Boyd Hut or Ngaawapurua Hut down to the Cameron carpark at Kuripapango or down to the Kuripapango bridge;
(b) The Oxbow, which is a short section from the Cameron car park down to the Kuripapango bridge;
(c) The lower river gorge (normally a two-day trip) from Kuripapango bridge to the next road access at Whanawhana; and
(d) The braided river below Whanawhana to the coast.
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35 The Taruarau River, a tributary of the Ngaruroro River, offers a remote two-day (or long one-day) Class IV kayaking run from the Napier-Taihape Road Bridge down to the Ngaruroro confluence.
36 The Ngaruroro River (and Taruarau River), like many of its North Island river counterparts, is typically a smaller river, with white water and rapids of a more technical nature (typically ‘tighter’ with less river room and a little more difficult to navigate) and generally smaller in size than many of its larger volume or higher flow South Island counterparts. The runs contain many of the white water features and/or hydraulic elements valued by kayakers and rafters and described in the previous section, except there are no waterfalls in any of the main river reaches (there are in side streams entering the river in a number of locations). The Oxbow provides an ideal place for introducing beginner kayakers to white water and a taste of what the Ngaruroro catchment has to offer.
37 I have provided a selection of photographs that illustrate some of the sights, values and experiences to be had on the Ngaruroro River. They follow this text.
Having landed at the Boyd airstrip after a successful flight from Taupo, team adrenaline and excitement levels build at the beginning of a three day adventure with over 100km of paddling on the Ngaruroro River. Part of the adventure is flying into remote wilderness areas to access rivers. Auckland University Canoe Club (AUCC) trip October 2012. Photo: Ross Whittome.
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Upper Ngaruroro River tussock flats. Photo: Eric Martinot.
Exceptionally clear blue, cold crisp drinking water with an abundance of trout in the upper tussock clad reaches of the Ngaruroro River. Photo: Ross Whittome.
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A section of the Upper Ngaruroro in the transition from high country tussock to pristine beech forest. Hidden Valley’s four day raft descent with about 20 people October 2012. Photo: Doug Rankin.
In the beech forest zone on the Upper Ngaruroro, crystal clear water, good white water and beautiful scenery. Typical tight rocky Class III rapid. Hidden Valley’s raft descent October 2012. Photo: Doug Rankin.
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Campsite at the old Forestry Service Omarukokere bivouac in the Upper Ngaruroro, with a bonfire at night beside the river. Part of the magic of a river journey. At this point the party had seen about three people all day so there are a few hunters and fisherman up in the upper river. AUCC trip October 2012. Photo: Ross Whittome.
Class II white water not far down below the Kuripapango get-in on the Lower Gorge on the Ngaruroro River. Note the vertical rock gorge walls. Whitewater NZ and North Island Canoe Clubs descent October 2012.
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An inflatable kayak and catarafts on the Lower Gorge on the Ngaruroro River. These craft are relatively stable and offer less experienced paddlers the opportunity to make the journey. Skill is still required to run the more difficult rapids or otherwise they need to be portaged. Whitewater NZ and North Island Canoe Clubs descent October 2012. Photo: Brian Megaw.
Challenging rapids in the Lower Gorge on the Ngaruroro River below Kuripapango on the last day of a three-day AUCC journey from Boyd airstrip in 2012. The flow in the river lifted overnight by about a foot and resulted in a fantastic Class III-IV white water run on the last day. A kayaker is visible in an eddy in the right bank background. Photo: Ross Whittome.
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Kayaker on Lower Gorge on the Ngaruroro Gorge. Note the bedrock lining the banks in this section of the river and the massive sloping large rock slabs exposed on the banks up to the vegetation line (near sky line in places). Photo: Gwyn Ashcroft.
Catarafters enjoying negotiating a rapid in the Lower Gorge. The rapid is formed by a constriction by bedrock and larger rocks in the river producing a gradient step and a hole that the nearer catarafter has just burst through. Such features are a delight to run and negotiate or play on for kayakers, rafters and catarafters alike. Photo: Hugh Canard.
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Looking back up to Barrier Falls in the Lower Gorge on the Ngaruroro.Whitewater NZ and North Island Canoe Clubs descent October 2012. This is a Class IV rapid with a route down the chute visible on river left or another chute (obscured) on river right. Photo: Doug Rankin.
Lunch stop on the Ngaruroro River about 10 km above Whanwhana, Whitewater NZ and North Island Canoe Clubs descent October 2012. Photo: Doug Rankin
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38 The Ngaruroro is widely used and valued by kayakers, rafters and white water adventurers both from the Hawke's Bay and nationally.
39 Further evidence on these values is provided by expert witnesses Mr Bernie Kelly, a past President of the Hawke's Bay Canoe Club, and Mr Mike Birch, a former President of the NZRCA, both of whom have much experience of the Ngaruroro River.
40 Additional supporting evidence for the rafting values and use of the Ngaruroro River and the Taruarau River is provided by Dr Gwyn Ashcroft, a canoeist, kayaker, rafter and member of the New Zealand Rivers Association.
Kayaker on an easy Class II drop on the Taruarau River. Photo: Gwyn Ashcroft
Flow requirements
41 Water flow is the key requirement to produce white water (paragraphs 20-29).
42 Flow needs for kayakers can be visualised using the conceptual flow evaluation model of Whittaker and Shelby [2] (Figure 1). The model assumes that there are marginal flows below which a reach is unnavigable and has little or no white water (marginal flow low) and above which the flows are too high and dangerous or white water features are lost (marginal flow high), and ranges of flows in between which are acceptable and optimal. The ranges of flows can be broad as a result of catering for different kayaking activities and kayaker skill levels and interests but also reflect the range of flows over which white water features can be present.
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Figure 1. Hypothetical flow evaluation curve with characteristics labelled (after Whittaker and Shelby [1, 2])
43 In general beginner kayakers prefer a range of flows lower than those preferred by more experienced kayakers9 on the same white water river reaches. In lower flows the white water will be easier to negotiate and less powerful and less intimidating. Intermediate, advanced and expert kayakers will often progressively prefer higher ranges of flows but this is not always the case, it depends on the quality of the white water sought, and what white water features exist at different flows, and the reason for the trip.
44 The Upper Ngaruroro River and Lower Gorge for kayakers are very slow and difficult to navigate below flows of about 5 cumecs (556 mm stage height at Kuripapango10), and between 5 and 10 cumecs (721 mm stage height) are rocky and not so good for beginners.
45 For flows of approximately 10 to 40 cumecs (1211 mm stage height) both runs are good for kayaking and for rafting the lower Ngaruroro gorge. However, higher
9 Kayaker abilities have been classified as: Beginner; kayakers early in their careers - comfortable on Class I or II white water; Intermediate; comfortable on Class III white water; Advanced; comfortable and competent on Class III+ or Class IV white water; Expert; competent on Class V white water [1].
10 The calculated stage height data are derived from a power fit (R2=0.9998) of appropriate high quality approved stage height and river flow data from the 2017 year, using the 9 September 2015 rating curve for site 23104 – Ngaruroro at Kuripapango, and data from the NIWA hydroweb portal. (https://hydrowebportal.niwa.co.nz/Data/DataSet/Chart/Location/23104/DataSet/QR/Master/Interval/Monthly/C alendar/CALENDARYEAR/2017/06; accessed 10 October 2017)
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minimum flows are needed for rafting the upper river depending on the launching site11.
46 Flows of between approximately 10 and 15 cumecs (839 mm stage height) are good for beginner kayakers, and between 12.5 cumecs (784 mm stage height) and 17.5 cumecs (889 mm stage height) for intermediate kayakers, with a flow of about 15 cumecs (839 mm stage height) being most suitable for intermediate kayakers. As flows increase above 20 cumecs (934 mm stage height) so does the size and the power in the hydraulic features of many of the rapids, increasing their technical difficulty and making group and incident management more challenging.
47 The approximate lower flow limit requirements for kayakers for different river reaches above are similar to those presented by Dr Ashcroft in his evidence.
48 As the river bed is relatively confined and often narrow, especially below the tussock flats in the upper river, and down to below Barrier Falls in the Lower Gorge, quality white water remains in these reaches over a range of river flows, which is particularly valued by white water boaters. It also permits river journeys to be made at lower end flows by slightly less experienced parties, albeit a little ‘scratchily’ (i.e., with a certain amount catching on the bottom of the river), as the power, size and speed in the white water is not as great and so can be less intimidating and difficult and less hazardous than higher flows.
49 Above flows of 40 cumecs the river is approaching a fresh or flood stage, where river users need to be highly skilled and aware of the risks of such higher flowing rivers. Flows in the river can rise very rapidly in intense rain events (and correspondingly fall relatively rapidly once the rain stops) and paddlers venturing on the river at such times need to be able to handle such conditions.
50 The flow in the Taruarau needs to be above 600mm on the stage height gauge under the Taruarau Bridge at the put in on the Napier-Taihape Road for a worthwhile trip.
51 In general river flows that best meet the needs for kayakers and rafters on wilderness rivers such as the Ngaruroro and Taruarau Rivers are those provided by natural flows. These provide flows that seem natural and which experienced paddlers recognise as being in keeping with the size and geomorphological structure of the rivers. Furthermore, flow recessions from freshes or floods are
11 For example, Dr Ashcroft in his evidence to this Hearing on behalf of Whitewater NZ suggests that a minimum stage height of about 900mm or flow of about 18 cumecs is needed to get a raft down if launching near Boyd Hut. If launching at Ngaawaparua Hut, about one third of the way down the upper river run, Dr Ashcroft suggests a minimum stage height of about 700 mm or a flow of about 9 cumecs at Kuripapango will be needed for a raft to get down the river.
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also in keeping with the size and scale of the river bed and corridor and surrounding landscape.
Analysis of previous kayaking value assessments of the Ngaruroro River and comparison with other rivers nationally
52 Two national surveys have been carried out examining the kayaking recreation values of rivers throughout New Zealand. They are the New Zealand Recreational River Survey (NZRRS) conducted by Graham and Jan Egarr [3, 4] and published in 1981 for the NZCA, and the 1991 River Use Survey (RUS) conducted by the NZCA [5]. The data from the RUS survey were analysed by Martin Unwin (who assisted in the design of the RUS), Jonathan Hunt and myself. The results were first presented to the Planning Tribunal/Environment Court Buller WCO Hearing [5], and subsequently in a number of other proceedings (e.g., see reference [6]). I provide a précis of the relevant results below.
1981 New Zealand Recreational River Survey
53 The NZRRS was started in 1978. Over about a two year period the authors visited and examined the established or potential value of over 1500 streams and rivers throughout New Zealand for river recreation. They assessed river water- based recreation opportunities for motor launches; jet boats; drift boats; kayaks and canoes; rafts; pack floating, cascading and Li-lo drifting; and swimming. It is a seminal and comprehensive study conducted by experienced insightful river recreation users.
54 The study is very thorough in its discussion on the methodology used. The authors consulted literature and experts in various disciplines, and clearly explain how the results have been analysed. The authors also describe the rationale and the lengths required to address concerns over subjectivity, and to ensure consistency of assessment of river values throughout the country, both of scenic and recreation values12.
55 The results are now a little dated in some areas, particularly for some recreation values. Some reaches of rivers were considered unnavigable and highly dangerous at the time (e.g., Nevis Bluff rapid on the Kawarau River, or the Huka Falls on the Waikato River), but now they are routinely run, albeit by very skilled
12 In both cases this has been done from the point of view of the experienced recreationalist using the resource, and therefore is river user based (“This survey was aimed at locating those areas of importance to the recreationalists themselves, not to locate areas of importance for recreation according to administrators or any other group” (pp 29 [4]). The scenic evaluations were also based on perceptions and experience from the river itself by river recreationalists, and therefore is river corridor focussed, and not reliant on land based assessments.
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expert kayakers. In addition, a number of river reaches had never been run and therefore their recreation potential was not fully appreciated.
56 Nevertheless many of the results of the study have stood the test of time and much of the data generated, and especially the comparative data, are as relevant today as when they were originally generated.
57 Recreational and scenic values of different reaches of the Ngaruroro and Taruarau Rivers [3] determined in the NZRRS are given in Table 1. Recreational values were ranked on a five point scale of insignificant, low, intermediate, high and exceptional. A low recreation rating reflects a valueless and mediocre rating based on user numbers whereas intermediate value reflects an average ranking, high value reflects a popular ranking, and exceptional reflects an extreme ranking. Scenic values were ranked on a six point scale of dull, uninspiring, moderate, picturesque, impressive, and exceptional.
Table 1. Values assessed in the 1981 New Zealand Recreational River Survey
River Recreational Value Scenic Value
Ngaruroro, Upper High Impressive
Ngaruroro, Lower Gorge Exceptional Impressive
Ngaruroro, Lower Intermediate Moderate
Taruarau Low Impressive
58 At the time of the survey a complete kayak descent of the Taruarau River had not been made and the low recreational value was largely ascribed on this basis. As such, the recreation score for this river is inaccurate. The high and exceptional recreational values ascribed to the Upper Ngaruroro and Lower Gorge, respectively, were primarily for the known kayaking and rafting values of the runs. The intermediate value for the lower Ngaruroro River (Whanawhana down) was largely given for the jet boating values.
59 In addition to the above assessments, reaches of rivers were ascribed recreation- preferred categories, which combined recreational and scenic values. This was done in an effort to rank the relative values of the nation’s best recreational rivers, as assessed at that time. Rivers were classified as:
(a) Category A: consisted of all rivers with both exceptional recreational and exceptional scenic values (six reaches of the Wanganui, Motu, Grey,
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Ahaura, Shotover and Clarence Rivers – the Motu, Ahaura and Shotover have WCOs13 on them);
(b) Category B: consisted of all rivers with exceptional recreational and impressive scenic values or high recreational and exceptional scenic values (seven reaches in the North Island including the lower gorge on the Ngaruroro River and thirteen reaches in the South Island – including reaches of the Buller, and Maruia and Motu that have WCOs on them);
(c) Category C: consisted of all rivers with exceptional recreational and picturesque scenic values, high recreational and impressive scenic values, high recreational and picturesque scenic values, and exceptional recreational and moderate scenic values (twenty five reaches in the North Island including the upper Ngaruroro and thirty nine reaches in the South Island – including reaches of the Rangitikei, Mohaka, Buller, Gowan, Ahaura, and Rangitata which have WCOs on them); and
(d) Category D: consisted of all rivers with high recreational and moderate scenic values, intermediate recreational and exceptional scenic values, intermediate recreational and impressive scenic values, and intermediate recreational and picturesque scenic values (thirty one reaches in the North Island and forty eight reaches in the South Island – including reaches of the Buller, Kawarau, and Rangitata which have WCOs on them. However, note that neither the lower Ngaruroro River (from Whanawhana to the sea) nor the Taruarau River featured in Categories A-D).
60 Thus, from as early as 1980, reaches of the Ngaruroro River were recognised as having outstanding white water recreation and scenic values, on a par with other outstanding rivers throughout the country.
1991 River Use Survey
61 The 1991 RUS was initiated by the NZCA in recognition of the need for up-to- date information on river usage by NZCA members and recreation values after the NZRRS had been published in 1981. The objectives of the RUS [5] were:
(a) To measure the relative importance of New Zealand rivers to NZCA members;
(b) To measure the usage of New Zealand rivers by NZCA members; and
(c) To develop a database for future advocacy of New Zealand rivers.
13 In part on the Motu and Shotover for outstanding kayaking, canoeing and rafting values, but not for the Ahaura River.
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62 The survey was implemented via a questionnaire distributed to NZCA members in affiliated clubs throughout the country. The key item of this questionnaire was a table listing 200 river sections, chosen after consultation with each club and grouped by geographical region, with a matrix of data columns against each river for respondents to complete as appropriate [5]. The Taruarau River was not included in the survey as it was not widely paddled at that time.
63 Respondents were asked to identify any river sections which they had paddled, and to provide: the total number of canoeing trips made to the river; the importance of the section to them as a canoeist on a scale of 1 (lowest) to 5 (highest); and the travel time, scenic beauty, wilderness feeling, and degree of canoeing challenge, also rated on a 1-5 scale.
64 To maximise consistency between respondents, guidelines detailing the characteristics associated with each 1 to 5 grade were included with the survey instructions, so as to establish a clearly delineated hierarchy of responses for each attribute’ [5] (see Appendix II). Scenic beauty attributes referred to the beauty of the river, riverbanks, and the surrounding countryside, and wilderness feeling referred to the feeling of wilderness at river level.
65 A total of 604 replies were received from whitewater paddlers, representing approximately 50% of the affiliated NZCA club members who participated in white water kayaking at the time. Collectively, these respondents provided 9,788 assessments of individual rivers, representing a total of over 35,000 paddling trips [5].
66 Mean attribute responses were calculated for respondents who had paddled different river sections. Data from a number of rivers where only a limited number of responses were received, and/or a limited number of trips had been recorded, such as the Whataroa, Landsborough and Waiatoto, were excluded so as to not unfairly bias the results. Thus some key rivers that had at the time of the survey not been run that much, but which nevertheless have outstanding values, were not included in the survey.
67 The results for the upper Ngaruroro River (Section 1613 in the Whitewater NZ RiverBase) are shown in Table 2.
Table 2. Mean attribute ratings (1=lowest, 5=highest) and ranks for the upper Ngaruroro River. Ranks in parentheses are for the subset of North Island rivers alone
Attribute Mean (1-5) Rank Description of relevant ratings "Important; canoeing this river provides an experience exceeded by few other rivers." (4) Importance 4.11 16 (8) or "Extremely important; this river offers a unique canoeing experience." (5)
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"Moderately close; suitable for a long day-trip, or an overnight trip from home." (3) or Travel time 3.63 - “Distant; involves a full weekend or long weekend trip from home.” (4) "Very attractive; river environs scenic and sometimes spectacular. Surrounding country provides striking views.” (4) or “Inspiring; Scenic 4.51 3 (2) scenery spectacular and varied. Large scale beauty vistas [e.g. rock formations, gorges, overhanging vegetation, deep and clear pools, rapids.” (5) "Strong wilderness feeling; largely unmodified environment, with very limited access to any form of roading. Walking out from the river Wilderness 4.74 3 (2) feasible, but could take up to a day.” (4) feeling "Exceptional wilderness feeling; pristine environment, extreme sense of remoteness, walkout long, arduous and difficult.” (5) "Rapids frequent and/or difficult enough to be enjoyable, but still well within my own Canoeing capabilities: essentially a “fun” trip, with plenty 3.37 23 (12) challenge of good play spots.” (3) "A challenging canoe trip which requires full use of my canoeing skills without actually extending them." (4)
68 The overall mean importance for the upper Ngaruroro River is 4.11 and the reach is ranked 16th (or 8th out of North Island rivers) out of the 200 river reaches in the 1991 survey (i.e. in the top 10%). The rating of 4.11 translates to "Important: this river provides an experience exceeded by few other rivers."
69 The mean ratings for scenic beauty and wilderness feeling for the upper Ngaruroro of 4.51 and 4.74 both rank very highly at 3rd (and both 2nd in the North Island), respectively, after the Motu and Karamea Rivers.
70 The mean canoeing challenge for the upper Ngaruroro is 3.37 (ranked 23rd), reflecting the Class of the white water on the run (Class II to III with a little Class III+-IV) and the challenge to and the ability of the respondents that have run the reach.
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71 There is a degree of correlation (R=0.866) between the mean canoeing challenge and mean overall importance for the ninety four most highly ranked river reaches in the country (Figure 2), where about 75% (R2=0.7495) of the mean overall importance is associated with the variation in the mean canoeing challenge [8]. Most points are scattered along a well-defined line, with two main outliers low on the right hand side that correspond to reaches of the Wanganui River – a river that is technically easy but highly valued. This is perhaps a logical result; white water kayakers will want to paddle white water, and for those that can handle it, the more difficult, or that with the greatest challenge, is likely to be the more highly valued. In some cases wild (wilderness) and scenic values (and possibly other values) might occur with some river reaches and add to the overall recreational or importance value, but this might not always be the case.
5
y = 1.0854x - 0.9705
4 R² = 0.7495
3 Canoeing challenge Canoeing
2
1 1 2 Overall Importance3 4 5 Figure 2. Degree of canoeing challenge versus overall importance 72 The mean travel time rating was a parameter that proved a little difficult to interpret. However, what was noticeable was that important rivers that required significant commitment to visit them and/or to travel between and within the North and South Islands to access them, or that required flights to access them, often
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had higher travel time ratings than those that could be readily accessed by roads or that were close to larger centres of population.
73 The results for the lower Ngaruroro gorge (Section 1614 in the Whitewater NZ RiverBase) are shown in Table 3.
Table 3. Mean attribute ratings (1=lowest, 5=highest) and ranks for the lower Ngaruroro gorge. Ranks in parentheses are for the subset of North Island rivers alone
Attribute Mean (1-5) Rank Description of relevant ratings "Moderately important; a river with some unique features, although comparable alternatives exist Importance 3.89 27 (13) elsewhere." (3) or "Important; canoeing this river provides an experience exceeded by few other rivers." (4) "Moderately close; suitable for a long day-trip, or an overnight trip from home." (3) or “Distant; Travel time 3.28 - involves a full weekend or long weekend trip from home.” (4) "Attractive; scenic appeal is significant, but generally derived from local features such as bankside vegetation and the nature of the river Scenic 3.81 22 (12) environs rather than large scale grandeur." (3) beauty or "Very attractive; river environs scenic and sometimes spectacular. Surrounding country provides striking views.” (4) "Strong wilderness feeling; largely unmodified environment, with very limited access to any form of roading. Walking out from the river Wilderness 4.14 8 (6) feasible, but could take up to a day.” (4) feeling "Exceptional wilderness feeling; pristine environment, extreme sense of remoteness, walkout long, arduous and difficult.” (5) "Rapids frequent and/or difficult enough to be enjoyable, but still well within my own Canoeing capabilities: essentially a “fun” trip, with plenty of 3.44 22 (11) challenge good play spots.” (3) "A challenging canoe trip which requires full use of my canoeing skills without actually extending them." (4)
74 The overall mean importance for the lower Ngaruroro gorge is 3.89 and the reach is ranked 27th (or 12th out of North Island rivers) out of the 200 river reaches in the 1991 survey (i.e., in the top 15%). Like the rating for the upper Ngaruroro River, the rating of 3.89 translates approximately to "Important: this river provides an experience exceeded by few other rivers." On average the view of the
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respondents is that the lower gorge is not overall as important as the upper Ngaruroro River, whose overall mean importance rating was 4.11.
75 The mean ratings for scenic beauty and wilderness feeling of 3.81 and 4.14 are ranked 22nd and 8th (12th and 6th in the North Island), respectively, reflecting the very attractive scenery and strong wilderness values of the reach.
76 The mean canoeing challenge for the reach of 3.44 (ranked 22nd) which is slightly higher than the upper river run. This no doubt, reflects the Class of the white water on the run (Class II-IV, and on average higher than that of the upper river), and the challenge to, and the ability of, the respondents that have run the reach.
77 The mean travel time rating of 3.28 for the lower gorge run compared with that of 3.63 for the upper river presumably in part reflects the greater commitment in terms of time and travel (and perhaps cost; air transport is needed as well) to reach the put-in for the upper river trip compared to the road access available for the lower gorge run.
78 Neither the lower Ngaruroro River (below Whanawhana down to the sea) nor Taruarau River feature in the assessments of the top 94 river reaches in the 1991 RUS.
79 Further analysis of the RUS data for Class III-III+ river reaches shows how the Ngaruroro runs rank in overall importance (or other parameters of interest) to similar Class runs throughout New Zealand.
80 Tables of data for these runs are not presented here for brevity. However, the upper Ngaruroro River and lower gorge ranked 5th and 12th, respectively, for importance out of thirty one Class III-III+ river reaches throughout the country. In contrast, the same reaches ranked 2nd and 4th, respectively, for importance out of eleven Class III-III+ river reaches in the North Island. The upper Ngaruroro River ranked 1st for both scenic beauty and wilderness feeling for the thirty one Class III-III+ river reaches throughout the country, and the lower Gorge 8th and 2nd for these same two values, respectively.
81 A summary of the mean attributes of importance, scenic value, wilderness value and canoeing challenge, and their ranks, for a selection of different river reaches surveyed in the RUS, is presented in Table 4 (see Appendix III). In addition reaches are flagged if they are recognised for their kayaking river values in a WCO.
82 Clearly the upper Ngaruroro River and the lower Ngaruroro gorge runs have ranks similar to a number of other highly ranked and important kayaking river reaches identified in 1991, and which are recognised by WCOs.
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83 Some river reaches of lower overall importance in the RUS rankings are also recognised in WCOs. These are typically highly valued kayaking reaches of lower Class or difficulty.
Other literature sources
84 In 1978 Graham and Jan Egarr published for the NZCA a comprehensive series of canoeists guides for New Zealand [7]. They were followed by two books drawing these compilations together [8] for both kayakers and rafters. A more recent literature source for kayakers wanting information on river runs throughout New Zealand is New Zealand Whitewater written and compiled by Graham Charles [9] (now in its 5th edition).
85 In general guidebooks do not rate or rank the relative values of different river runs.
86 However, in his North and South Island guidebooks [8] Graham Egarr did list the best and most popular and frequently run river trips, and in a smaller (subset) list the very best of the difficult white water trips. The upper Ngaruroro River, lower Ngaruroro Gorge and Taruarau Rivers featured in the list of the best and most popular and frequently run river trips in the North Island (out of a total of 42 runs in the North Island; there was a total of 59 rivers/runs in the South Island). The lower Ngaruroro gorge (but not the upper river nor Taruarau River) featured in the list of the very best of the difficult white water trips (for which there was a total of 10 runs in the North Island, and a total 19 runs in the South Island).
87 In his second edition guidebook Graham Charles rates the lower Ngaruroro gorge run amongst 120 great kayaking runs (1999 edition) as
wilderness and worth it
and in the lower gorge river description also mentions the upper river trip from Boyd’s Hut as
highly recommended …. a fabulous and rare beginner/intermediate self-support trip.
In his fifth edition of the guide published in 2013 [9] Graham Charles has expanded the list of rivers to 180 great runs, including the Taruarau River, where he states:
seldom-run …. needs a bit of rain or snowmelt to bring it into condition” and is “A long trip in the wilderness with a couple of great gorge sections”.
88 Over fifty new runs have been added to the 2013 edition of the guidebook, most of them harder Class IV and higher creek boating runs. Such runs only flow sufficiently after rain and are not generally suitable for rafting or for the majority of
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kayakers, being the domain of expert kayakers/canoeists. Most of the runs are in the North Island or West Coast of the South Island and are relatively inaccessible. These additions to the guidebook reflect the continuing growth and development of the sport of kayaking in New Zealand and particularly the identification and use of more challenging creek boating and wilderness runs.
89 To quote the author from his introduction to the 2013 edition [9]:
The information in this guide book STILL stands as a useful snapshot of the values and beliefs the whitewater community holds from the start of 2013. By virtue of being included, any of the runs are of exceptional value. The individual character of each is only a small part of the bigger picture that makes Aotearoa wai huka such a valuable resource. Remove any of these runs and the picture becomes fragmented and of less value. ….
Hence this information and reflection, and that from other guidebooks, gives further evidence as to the long recognised value of the Ngaruroro and Taruarau white water runs.
Hawke's Bay Regional Council River Values Assessment System (RiVAS) white water kayaking study
90 In 2010 a regional white water kayaking study was conducted by the Hawke's Bay Regional Council [10] using the River Values Assessment System (RiVAS) [11]. The RiVAS study identified the significant kayaking rivers and runs in the region using an expert panel of local kayakers, and ranked river reaches using a multi-criteria analysis approach. Total river ‘scores’ were determined by summing scores for a range of attributes of different rivers and/or river reaches and then ranking the scores from highest to lowest and ascribing high, medium or low values to groups of rivers with scores in particular ranges. Other RiVAS kayaking studies have also been done by the West Coast Regional Council [12], of which I was a co-author, and the Tasman District Council [13].
91 In the Hawke’s Bay RiVAS kayaking study [10], final overall scores were calculated giving equal weights to river reaches scored on a scale of 1 to 3 for seven attributes: scenic attractiveness, perception of wilderness, density of quality hydraulic features, flow reliability, number of users, user catchment and scarcity of kayaking opportunity14. The combined runs on the Ngaruroro River
14 Giving equal weighting to such parameters in the RiVAS model is not based on any rational basis, deductive reasoning, or model validation. The observation from the 1991 RUS study that 75% of the variance associated with the overall mean importance of different river reaches throughout the country could be explained by the mean degree of canoeing challenge for those reaches (see paragraph 71 and Figure 2), suggests that many of the attributes used in the RiVAS study have less relevance to the overall importance of river reaches than is assumed by the RiVAS model. If canoeing challenge is the dominant factor, then other factors will be less important, presumably contributing to 25% of the variance in river reach importance not
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featured high up in the overall scores, ranking overall 3rd equal and with the same high score (19; out of a possible total score of 21) as the combined runs on the Mohaka River (which has a WCO), and other reaches of the Ruakituri, Mohaka and Ngaruroro (Kuripapango to Whanawhana reach).
92 The upper Ngaruroro reach (Boyds airstrip to Kuripapango) scored 18 and was 4th equal with two other river reaches, and the Oxbow reach (DOC campground down to the Kuripapango Bridge) scored 16 and was 6th equal and the lower Ngaruroro gorge scored 19 and was ranked 3rd equal.
93 Thus, the ranking of the Ngaruroro River by the RiVAS study is not inconsistent with the relative ranking measured in earlier studies. That said, I have concerns regarding the accuracy of the rankings generated, given my previous experience with the RiVAS method [1, 10, 12, 14], and comments from participants in the Hawke's Bay study15. As such, I do not place great weight on the findings from this study.
Threat posed to canoeing values by irrigation or hydro electricity power development in the Ngaruroro catchment
94 Significant takes for irrigation or damming for hydroelectricity power (HEP) development on the Ngaruroro River would undermine the kayaking values of the upper Ngaruroro. At present HEP development in the Ngaruroro is not being mooted as an option but damming the river or side streams to create a water reservoir for irrigation purposes is apparently a possibility. Conflict arises because the river features valued by paddlers and HEP or irrigation developers often are the same, e.g., rivers of appreciable gradient and water flow. Impacts from such developments could be serious.
95 Harnessing waterways by damming or diverting them destroys the wild, natural and scenic characteristics of rivers. The presence of artificial structures such as
explained by canoeing challenge. Thus, summing the scores equally for seven factors, none of which incorporate canoeing/kayaking challenge, to produce a total score assumed in RiVAS to define the relative value of different river reaches is not likely to be valid or correct. This exemplifies concerns about the RiVAS methodology and highlights the need to validate the model, before it is widely adopted for use by Regional Councils and/or other parties in RMA or other processes.
15 The expert panel touched on various limitations of the assessment In the Hawke’s Bay kayaking study in the foreword to the report [10]. Amongst other matters it states “ … Additional work is needed to be confident that the assessment reflects the values of the wider kayaking community. The assessment is a best estimate only, given a lack of existing data and limitations to the Expert Panel’s knowledge; ….The assessment is primarily intended as an engagement tool to assist the Hawke’s Bay Regional Council in planning for more sustainable management of the region’s rivers. The Resource Management Act 1991 (RMA) makes it clear that its purpose includes enabling people and communities to provide for their social wellbeing, of which whitewater kayaking is a part (RMA Part 2, section 5). The assessment is neither intended, nor robust enough, to be used definitively in the RMA resource consenting process. …”.
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canals, dams, penstocks or power generation facilities in river valleys or the taking of large quantities of water contributes to the loss of these values.
96 HEP or water storage schemes, which impound significant quantities of water, destroy free flowing reaches of rivers. White water canoeists require free flowing rivers with natural flows, and these resources are diminishing rather than increasing in number.
97 Schemes that involve the taking of substantial flows out of the Ngaruroro River or its tributaries for irrigation, such as for storage of flood flows in side streams, could impact negatively and severely on the recreational values of the river downstream from such abstraction points.
98 Schemes which involve impoundment or control of water (e.g., of lake levels) in a catchment and the release of water back into that catchment for HEP or to the land for irrigation, could smooth the natural variation in flows and replace this by a uniform flow. This would normally mean that flood flows will no longer flow down the river as these peaks will be stored for electricity generation or irrigation purposes. Therefore rapids downstream will still have water flowing through them, but these flows may no longer be variable so the canoeing opportunities will be reduced. If the flows are not optimal, the canoeing value of the rapids downstream may also be reduced or destroyed. Various flows are needed for optimal boating and unless these are provided and of sufficient magnitude then canoeing values could be destroyed.
99 Controlled flows could also alter the natural river building and bed alteration processes downstream, which occur during major flood events. These natural events can be an important dimension to the canoeing value of a river. They can change rapids over time producing new features, which offer new challenges. They can also result in changes for the worse, for example, where valued rapids are filled in with debris and lost.
100 Degraded water quality can lead to unsightly and unnatural periphyton growths or blooms and/or toxic bacterial blooms (such as Phormidium) occurring in waterways, which can exclude river users from valued resources due to health risks to themselves or other animals or otherwise degrade the river recreation experience.
The kayaking values which warrant protection
101 The attributes that provide for and contribute to the outstanding kayaking values, which warrant protection, are those that contribute to make the upper river to Whanawhana outstanding in that respect. They include:
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(a) The nature of the rapids and bed and river channel features, including gorge wall and river bed bedrock features;
(b) The natural river flows that in combination with the river bed features and gradient produce the outstanding white water in the river runs;
(c) The scenery and wilderness values in the catchment;
(d) The water clarity and quality in the catchment and natural clean river beds free of unsightly and unnatural algal growths found in degraded or polluted water ways; and
(e) The length of the river containing the features above that provides for a variety of multi-day river trips of various durations, including a potentially 5 day or more multi-day trip.
102 The values are best protected by ensuring the river catchment is left in its current largely undeveloped state. This will mean no alteration of the river bed will be permitted or damming of the Ngaruroro or Taruarau Rivers or their tributaries. Leaving the river catchment in its natural state will ensure vegetative cover will maintain water quality and clarity and natural flows, and retain scenery and wilderness values.
Concluding comments
103 It is my expert opinion that both runs on the Ngaruroro River - the upper river down to Kuripapango (including the Oxbow reach) and the lower Ngaruroro gorge from Kuripapango down to Whanawhana – are clearly outstanding for their kayaking and rafting values and scenic and wilderness values when compared to other river reaches in the country. This view is supported by my reading and understanding of the literature on the subject, my personal experience rafting and kayaking many rivers in New Zealand and overseas, and conversation I have had with fellow paddlers over the years.
104 Although the Oxbow reach is described and identified as a separate run in the evidence of Mr Kelly for Whitewater NZ, I do not believe it should be considered a separate reach for the purposes of the WCO. The Oxbow reach has the same scenery and wilderness character and white water values as the upper Ngaruroro River, and is an integral part of the multi day trip experience that really makes this river stand out nationally.
105 Some submitters have suggested that the white water recreation value should not extend down to Whanawhana, but should stop where the white water stops, where the river emerges from between the Ruahine and Longfellow Ranges.
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Such a suggestion does not take into account the complete experience and journey that makes up this part of the run:
(a) The get out for the lower Ngaruroro gorge run is an access road off Whanawhana Road, approximately 7 km downstream of the Whanawhana cableway, therefore the actual river trip experience extends below Whanawhana. The WCO is seeking protection of the lower Ngaruroro gorge run down to the Whanawhana cableway.
(b) The transition in scenery and river character downstream from the Taruarau confluence to the Whanawhana cableway is an elemental part of the lower Ngaruroro gorge run and the eventual warm down and reflection post journey.
106 The kayaking value of the Taruarau River is clearly not as highly ranked in importance as the runs on the Ngaruroro River. Nevertheless, the white water experience is highly spoken of by those who have done it and adds to the overall outstanding white water experience offered by the Ngaruroro River.
107 Granting a Water Conservation Order that retained natural flows and water quality on as much of the Ngaruroro River system as is possible, would help protect the outstanding significance of the system, and not just for the kayaking and rafting values.
Dr Douglas Alexander Rankin 17 October 2017
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References
1. D A Rankin, N Earnshaw, I M G Fox and T Botterill, Kayaking on Canterbury Rivers: reaches, values, and flow requirements, Report No. R14/31, Environment Canterbury Regional Council, February 2014, 80 pages. 2. D Whittaker and B Shelby, B (2002), Evaluating instream flows for recreation: applying the structural norm approach to biophysical conditions. Leisure Sciences, 24, 363-374. 3. G D Egarr and J H Egarr, New Zealand Recreational River Survey Part II North Island Rivers, Water and Soil Miscellaneous Publication No 14, National Water and Soil Conservation Organisation, 1981; G D Egarr and J H Egarr, New Zealand Recreational River Survey Part III South Island Rivers, Water and Soil Miscellaneous Publication No 15, National Water and Soil Conservation Organisation, 1981 4. G D Egarr and J H Egarr, New Zealand Recreational River Survey Part I Methods and Conclusions, Water and Soil Miscellaneous Publication No 13, National Water and Soil Conservation Organisation, 1981. 5. M J Unwin, Brief of evidence of Martin John Unwin in the matter of an inquiry into the Draft National Water Conservation (Buller River) Order 1989; Hunt, J, Unwin, M and Rankin, D (1995), New Zealand River Use Survey, unpublished results, New Zealand Canoeing Association. 6. D A Rankin, Brief of evidence of Douglas Alexander Rankin in the matter of an Environment Court inquiry into the draft National Water Water Conservation (Rangitata River) Order 1991, Christchurch. 7. G D Egarr and J H Egarr, Northland; Waikato and Hauraki; Hawke Bay, East Cape, Bay of Plenty; Taranaki; Manawatu, Wellington, Wairarapa; Nelson Marlborough; Canterbury; Westland; Otago Southland Canoeists’ Guides, New Zealand Canoeing Association (Inc) by the Watermark Press, Auckland,1978. 8. Graham Egarr, New Zealand’s North Island Rivers: A Guide for Canoeists and Rafters, David Bateman Ltd, Auckland, 1989; Graham Egarr, New Zealand’s South Island Rivers: A Guide for canoeists, kayakers and rafters, Nikau Press, Nelson, 1995. 9. Graham Charles, New Zealand Whitewater, Craig Potton Publishing, Nelson, Editions 1996, 1999, 2002, 2006; New Zealand Whitewater 5: 180 Great Kayaking Runs, 5th edition, Graham Charles, Hokitika, 2013. 10. Booth, K, Bellamy, S, England, A, Hales, W, Kelly, B, Mahoney, M, Reed, C and Sevicke-Jones, G (2012), Whitewater Kayaking in Hawke's Bay: An Application of the River Values Assessment System (RiVAS). Land Environment and People Research Paper No. 12 HBRC Plan No: 4373, Lincoln University, Canterbury. 11. Hughey, K F D, Booth, K and Baker, M-A (2010), River Values Assessment System (RiVAS), The method. In: Hughey, K F D, Baker, M-A eds. The River Values Assessment System: Volume 1: Overview of the method, guidelines for use and application to recreational values. LEaP Report No. 24A, Lincoln University, Pp. 43-62. 12. Booth, K, England, A, Rankin, D, Unwin, M, Charles, G, England, K, Riley, K and Ritchie, D (2010a), Part A: Whitewater kayaking in the West Coast Region: Application of the River Values Assessment System (RiVAS). In: Hughey, K F D, Baker, M-A (eds) (2010). The River Values Assessment System: Volume 1: Overview of the method, guidelines for use and application to recreational values. LEaP Report No. 24A, Lincoln University, Pp. 95-117.
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13. Booth, K, England, A, James, T, McGowan, S, Miles and Price, M (2010b), Part B: Whitewater kayaking in the Tasman District: Application of the River Values Assessment System (RiVAS). In: Hughey, K F D, Baker, M-A (eds) (2010). The River Values Assessment System: Volume 1: Overview of the method, guidelines for use and application to recreational values. LEaP Report No. 24A, Lincoln University, Pp. 121-140. 14. Hughey, K F D (2012), RiVAS and RiVAS+: Insights and lessons from 5 years’ experience with the River Values Assessment System. Paper presented at the 2012 New Zealand Agricultural & Resource Economics Society (Inc.) Conference, Nelson.
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Appendix I - International Scale of River Difficulty (also referred to as Grade, especially outside the USA)
Class I Fast moving water with riffles and small waves. Few obstructions, all obvious and easily missed with little training. Risk to swimmers is slight; self-rescue is easy.
Class II Novice: Straightforward rapids with wide, clear channels which are evident without scouting. Occasional manoeuvring may be required, but rocks and medium-sized waves are easily missed by trained paddlers. Swimmers are seldom injured and group assistance, while helpful, is seldom needed. Rapids that are at the upper end of this difficulty range are designated “Class II+”.
Class III Intermediate: Rapids with moderate, irregular waves which may be difficult to avoid and which can swamp an open canoe. Complex manoeuvres in fast current and good boat control in tight passages or around ledges are often required; large waves or strainers may be present but are easily avoided. Strong eddies and powerful current effects can be found, particularly on large-volume rivers. Scouting is advisable for inexperienced parties. Injuries while swimming are rare; self-rescue is usually easy but group assistance may be required to avoid long swims. Rapids that are at the lower or upper end of this difficulty range are designated “Class III-” or “Class III+” respectively.
Class IV Advanced: Intense, powerful but predictable rapids requiring precise boat handling in turbulent water. Depending on the character of the river, it may feature large, unavoidable waves and holes or constricted passages demanding fast manoeuvres under pressure. A fast, reliable eddy turn may be needed to initiate manoeuvres, scout rapids, or rest. Rapids may require “must” moves above dangerous hazards. Scouting may be necessary the first time down. Risk of injury to swimmers is moderate to high, and water conditions may make self-rescue difficult. Group assistance for rescue is often essential but requires practiced skills. A strong Eskimo roll is highly recommended. Rapids that are at the lower or upper end of this difficulty range are designated “Class IV-” or “Class IV+” respectively.
Class V Expert: Extremely long, obstructed, or very violent rapids which expose a paddler to added risk. Drops may contain large, unavoidable waves and holes or steep, congested chutes with complex, demanding routes. Rapids may continue for long distances between pools, demanding a high level of fitness. What eddies exist may be small, turbulent, or difficult to reach. At the high end of the scale, several of these factors may be combined.
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Scouting is recommended but may be difficult. Swims are dangerous, and rescue is often difficult even for experts. A very reliable Eskimo roll, proper equipment, extensive experience, and practiced rescue skills are essential. Because of the large range of difficulty that exists beyond Class IV, Class 5 is an open-ended, multiple-level scale designated by class 5.0, 5.1, 5.2, etc… each of these levels is an order of magnitude more difficult than the last. Example: increasing difficulty from Class 5.0 to Class 5.1 is a similar order of magnitude as increasing from Class IV to Class 5.0.
Class VI Extreme and Exploratory Rapids: These runs have almost never been attempted and often exemplify the extremes of difficulty, unpredictability and danger. The consequences of errors are very severe and rescue may be impossible. For teams of experts only, at favourable water levels, after close personal inspection and taking all precautions. After a Class VI rapid has been run many times, its rating may be changed to an appropriate Class 5.x rating.
(From American Whitewater: http://www.americanwhitewater.org/content/Wiki/do- op/id/safety%3Astart/#vi._international_scale_of_river_difficulty; accessed 21 October 2013)
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Appendix II - Assessment scales from 1991 River Use Survey
From p3 of the NZCA River Survey questionnaire:
WHAT SECTIONS ARE APPLICABLE TO ME?
Section One [to be completed by all N.Z.C.A members]
Please answer all questions in this section, regardless of whether or not you paddle rivers.
Your answers will give us basic profile data on the membership of N Z C A.
Section Two (to be completed by all river paddlers)
In this section, we would like you to identify all the rivers you have paddled, and to think about how each river appeals to you as a canoeist. On the following pages, we have listed 200 rivers (or sections of rivers) used for river canoeing. For any of these rivers that you have canoed, please fill in the following information.
Column 1: Total number of canoeing trips on this river.
This is the total number of river trips you have done on this river since you started canoeing/kayaking. If you have difficulty remembering exactly how often you have used a river an approximation will do.
Column 2: Importance of the river to you as a canoeist/kayaker.
We would like you to give the river a rating, from 1 [least important) to 5 most important], depending on how you, as a canoeist, feel about this river. Base your rating on the following scale:
1. Little or no importance; plenty of other rivers provide similar canoeing canoeing opportunities.
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2. Minor importance: other rivers provide similar canoeing opportunities.
3: Moderately important; a river with some unique features, although comparable alternatives exist elsewhere.
4. Important; canoeing this river provides an experience exceeded by few other rivers.
5. Extremely important; this river offers a unique canoeing experience.
Column 3: Attributes of the rivers.
We would now like you to consider four attributes of each river in more detail. These are trave/ time; scenic beauty; wilderness feeling; and the degree of canoeing challenge. As with column 2, we want your personal assessment of each factor, expresses [sic] on a 1 to 5 scale. Base your rating for each factor on the following scales:
Column 3 [a] Travel Time (closeness to where you lived when you paddled the river)
1. Very close; suitable for a part-day trip from home
2. Close; a comfortable day-trip from home.
3 Moderately close; suitable for a long day-trip, or an overnight trip from home.
4. Distant; involves a full weekend or long weekend trip from home.
5. Very distant; would only be canoed during an extended trip involving four of more days away from home.
Column 3[b]:Scenic Beauty.
This refers to the beauty of the river, riverbanks, and the surrounding countryside. Score this according to your opinion of the scenic beauty on a scale of 1 to 5.
1. Not attractive; river environs and surrounding country generally uninspiring, river water may be dirty or discoloured.
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2. Moderately attractive; some local features of scenic interest, mixed with less attractive sections.
3. Attractive; scenic appeal is significant, but generally derived from local features such as bankside vegetation and the nature of the river environs rather than large scale grandeur.
4. Very attractive; river environs scenic and sometimes spectacular. Surrounding country provides striking views.
5. Inspiring; scenery spectacular and varied. Large scale vistas [e.g mountains/bush/open country), and/or unique and striking river environs (e.g. rock formations, gorges, overhanging vegetation, deep and clear pools, rapids.
Column 3 [c] Wilderness feeling
This refers to the feeling of wilderness for you at river level.
1. No wilderness feeling; road traffic or other human activity generally visible/audible from river. Highly modified river environment.
2. Little wilderness feeling; roads/human activity readily accessible from river, even if not directly visible. River environment shows obvious signs of modification.
3. Some wilderness feeling; river environment may be modified, but canoeist is essentially isolated from immediate human activity. Roads generally reachable from river, but may involve some rough scrambling.
4. Strong wilderness feeling; largely unmodified environment, with very limited access to any form of roading. Walking out from river feasible, but could take up to a day.
5. Exceptional wilderness feeling; pristine environment, extreme sense of remoteness, walkout long, arduous, and difficult.
Column 3[d] Degree of Canoeing Challenge.
1. Little or no canoeing challenge; play spots either very limited or non-existent. For me, a canoe trip on this river is mainly a social occasion/day in the fresh air.
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2. Rapids require little concentration to negotiate, but satisfying play spots can be found; mainly a social occasion, but always provides an enjoyable trip.
3. Rapids frequent and/or difficult enough to be enjoyable, but still well within my own capabilities; essentially a "fun" trip, with plenty of good play spots.
4. A challenging canoe trip, which requires full use of my canoeing skills without actually extending them.
5. A very challenging trip, which I would only attempt when confident of paddling at my best. The limit of what I feel to be within my canoeing ability.
Column 4: Rivers you have not paddled but have interest in.
There may be some rivers which you have NOT paddled, but for which simply knowing that the river exists is important to you as a paddler. For any such river(s), please use column to assign an importance grade, using the same criteria as for column 2. i.e. 1: little importance 2: Minor importance etc.
Column 5: Additional Comments
This is optional and is for any comments you may like to make concerning the river, its significance to you, or concerns you may have for the river. You may if you wish write further comments on a separate sheet of paper and return with survey.
Other Rivers:
We realise that some canoeists may have paddled rivers which are not on our list. If you have paddled any such rivers, please list these individually, one per line, in the spaces indicated on pages 5 onwards, and complete columns 1 to 3 as for the other rivers you have paddled.
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Appendix III – Table 4. Mean attributes of importance, scenic value, wilderness value and canoeing challenge and their ranks for a selection of different river reaches surveyed in the 1991 RUS (backgrounds for rows containing reaches recognised for their kayaking values in WCOs are highlighted in red, and those for the upper Ngaruroro and gorge in green)
Attributes Ranks River District River Reach Class Scenic Wilderness Canoeing Scenic Wilderness Canoeing WCO Importance value value challenge Importance value value challenge 1761 Gisborne/East Cape Motu all reaches IV 4.74 4.64 4.80 3.86 1 2 2 8 yes 2111 Nelson Karamea all reaches IV-V 4.58 4.80 4.93 4.43 2 1 1 1 no 1618 Hawke's Bay Mohaka Te Hoe to Willowflat IV 4.54 4.36 3.96 4.01 3 5 11 6 yes 2422 Otago Shotover Below Deep Ck IV 4.43 4.02 3.70 4.07 5 13 17 5 yes 2419 Otago Kawarau Roaring Meg III 4.43 3.40 2.59 3.76 4 41 65 12 yes 2116 Nelson Buller Murchison to Lyell III 4.41 3.66 3.04 3.89 6 27 38 7 yes 2418 Otago Kawarau Dogleg III+ 4.40 3.32 2.65 3.76 7 46 60 11 yes Matawhero Bridge to 1428 Central North Island Rangitikei Pukeokahu IV 4.30 3.95 3.83 4.36 8 17 14 2 yes 2612 Marlborough Clarence II+ 4.26 4.27 4.41 2.92 9 7 4 48 no 2429 Otago Taieri Sutton to Hindon IV 4.25 3.53 3.63 3.53 10 34 22 16 no 1415 Central North Island Whakapapa IV 4.24 4.17 4.16 3.71 11 8 6 13 no 2311 Fiordland/Southland Hollyford IV 4.21 4.46 3.81 3.79 12 4 15 9 no Rangipo to Potu 1435 Central North Island Tongariro Intake Dam III+ 4.18 3.96 3.71 3.53 13 16 16 15 no Bay of 1819 Plenty/Rotorua Wairoa V 4.17 3.09 2.61 4.11 14 55 64 4 no Bay of 1814 Plenty/Rotorua Rangitaiki Wheao to Murupara IV 4.15 3.46 3.30 3.77 15 39 30 10 no 1613 Hawke's Bay Ngaruroro to Kuripapango III+ 4.11 4.51 4.74 3.37 16 3 3 23 no 2211 West Coast Grey Gentle Annie Gorge III 4.09 4.30 3.98 3.20 17 6 10 33 noa 2519 South Canterbury Rangitata Gorge IV-IV+ 4.08 3.16 3.19 4.12 18 49 36 3 yes
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Attributes Ranks River District River Reach Class Scenic Wilderness Canoeing Scenic Wilderness Canoeing WCO Importance value value challenge Importance value value challenge 1212 Auckland/Waikato Waikato Nga Awapurua II+ 4.07 2.67 2.18 3.52 19 80 82 17 no 1434 Central North Island Tongariro Rangipo Dam IV 4.03 4.17 3.88 3.48 20 9 12 18 no 2421 Otago Shotover Upper II+ 4.03 4.07 3.56 3.16 21 12 24 34 yes 1617 Hawke's Bay Mohaka Pungahuru to Te Hoe III 4.00 3.87 3.65 3.23 23 21 19 28 yes 1616 Hawke's Bay Mohaka to Pungahuru II 4.00 3.95 4.16 2.98 22 18 7 46 no Maori Gully to 2528 North Canterbury Hurunui Hawarden Gap III 3.93 3.28 3.01 3.58 24 48 39 14 nob Lake Rotoiti to Owen 2114 Nelson Buller River III 3.91 3.54 2.80 3.29 25 33 51 26 yes 2121 Nelson Matakitaki Earthquake rapid III-IV 3.90 3.36 2.94 3.45 26 42 42 21 noc Kuripapango to 1614 Hawke's Bay Ngaruroro Whanawhana III+ 3.89 3.81 4.14 3.44 27 22 8 22 no 1413 Central North Island Wanganui Retaruke - Pipiriki II 3.88 4.16 4.21 1.73 28 10 5 88 no 2530 North Canterbury Waiau to Hope River IV+ 3.83 3.77 3.86 3.47 31 24 13 19 no Potu Intake Dam to 1436 Central North Island Tongariro Boulder Reach III+ 3.83 3.53 3.24 3.07 29 35 33 39 no 2430 Otago Taieri Taioma to Outram IV 3.83 3.14 3.29 3.05 30 52 31 41 no 2216 West Coast Taipo III 3.81 3.98 3.63 3.21 32 14 21 30 no Owen River to 2115 Nelson Buller Murchison II+ 3.80 3.35 2.65 3.07 33 44 59 40 yes Bay of 1818 Plenty/Rotorua Kaituna IV 3.76 3.5 2.85 3.47 34 38 46 20 no 1412 Central North Island Wanganui Taumarinui - Retaruke II 3.75 3.69 3.51 1.74 35 26 25 87 no 2319 Fiordland/Southland Mararoa III 3.72 3.79 3.23 3.21 36 23 34 31 no 2526 North Canterbury Ashley III+ 3.68 3.51 3.22 3.32 37 36 35 24 no Bay of 1816 Plenty/Rotorua Whirinaki III 3.67 3.98 4.08 3.15 38 15 9 35 no 2123 Nelson Maruia III-III+ 3.65 3.92 3.65 2.93 39 19 18 47 yes Upper (to Rainbow 2616 Marlborough Wairau Road) III 3.64 3.65 3.05 3.24 40 29 37 27 no Manganui-a- 1416 Central North Island te-ao III+ 3.63 3.74 3.47 3.12 41 25 26 37 no
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Attributes Ranks River District River Reach Class Scenic Wilderness Canoeing Scenic Wilderness Canoeing WCO Importance value value challenge Importance value value challenge 2527 North Canterbury Hurunui Upper II+ 3.61 3.15 2.81 2.72 42 50 49 52 no 1429 Central North Island Rangitikei Pukeokahu to Utiku II 3.36 3.66 3.33 2.39 57 28 29 68 yes 1430 Central North Island Rangitikei Utiku to Mangaweka II 3.36 3.36 2.82 2.31 58 43 48 71 no Waikari Station to Peel 2520 South Canterbury Rangitata Forest II-II+ 3.33 2.78 2.51 2.51 60 73 67 61 yes yes 2118 Nelson Gowan III 2.98 3.02 2.65 2.66 79 60 61 54 rafting Nevis Bridge to - Otago Nevis Kawarau IV-V ------yesd a Kayaking and rafting values presented at WCO Hearing but not accepted by Tribunal b WCO applied for and kayaking values recognised for part of run in draft WCO. However, applicants withdrew the application, and from the process, after legal tests for granting of WCOs in Canterbury were changed by the National government in the 2010 Environment Canterbury Temporary Commissioners Act, and to be judged equally in terms of outstanding values, economic and (farm) industry interests c WCO asked for in Buller River WCO Hearing process but declined as challenged by electricity interests d Note the Nevis River was included in an amendment to the Water Conservation (Kawarau) Order 1997 in the Water Conservation (Kawarau) Amendment Order 2013. This river reach was not assessed in the 1991 survey as it was not widely known or used at that time
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