Submission to the EPA on the Tukituki Catchment
Proposal 2nd August 2013
The New Zealand Federation of Freshwater Anglers (inc) is an affiliation of
anglers and angling clubs throughout NZ and overseas. Operating
independently since 1974 it represents the collective interests of the near
100,000 licence holding anglers who participate in freshwater sports fishing
throughout New Zealand. The Federation's strength lies in its independence
and the number of anglers it represents.

As fishermen we are fortunate in that we see and get to know more of the
rivers and streams than many do. In so doing we get to understand it’s
infrastructure, it’s environment and it’s aquatic life. Our members value this
river (the Tukituki) for what it is and what it once was. That is an intrinsic
aesthetic value that is very important to us. It includes the very physical nature
of the river and the ecosystems it supports (of which the sports fishery is part).
We see that value as not just being threatened by this proposal; we see it
being degraded forever. We are losing a public asset for private gain. We see
no attempt to mitigate or compensate that loss, therefore we can only oppose
it. (Refer point 5 below.)

New Zealand is one of the richest countries in the world as far as our
abundant supply of freshwater is concerned. It is the lifeblood of our country,
our streams, rivers and lakes are its very arteries and veins. Our freshwater is
our most valuable renewable resource and we must manage it appropriately
for the benefit of all New Zealanders now, and for future generations. We are
the envy of many countries in this regard. Further, we are not at the mercy of
other countries ‘upstream’ who could take water and contaminate our
freshwater before it gets to us. (We are very clean and green in this regard.)

Further, within our extensive membership we have seen many of the massive
changes that have been wrought within our freshwater system with works
such as you are proposing now. We have seen devastation to unique
environments (and fisheries) and to some degree we have accepted the
necessity for this. (The need for power generation/water storage). However we
look at every project on a case by case basis and this very very large project
encompassing not one but many river catchment systems, concerns us
greatly.

It is very public knowledge that already the available water in many of the
Hawkes Bay (like Canterbury) rivers and aquifers is well over allocated and
this is of concern to many – especially in the long term.

For this reason we accept the need for water storage. Water being managed
in the same way as seasonal crops, hay and silage being carried forward from
good growing periods to be used at times of shortages. We also note current
overseas experiences where, due to changing climatic patterns (as expected
in the North Island’s east coast), large water storage schemes have failed due
to a lack of replenishment.

However in so saying we have no assurances that a water storage project that
you are proposing would in fact be used to reduce the seasonal allocation for
water in your rivers and aquifers in times of dry conditions allowing the
aquifers and rivers to be re-charged and the resulting flow rates to be
acceptable. In fact to the contrary. We see the water so stored being used to
increase both stock numbers and crop areas with the downstream
contamination that will result. While we well accept that we are a primary
producing country and our exports of dairy and other agricultural produce is
important for our economic well-being, there is a breakeven point above which
the very land and water cannot sustain the demands being placed upon it to
the detriment of future generations.

It is well accepted by many that trout and salmon are very good barometers of
water quality. Using the Tukituki as an example we have seen remarkable
reduction in water levels, trout numbers and fish size. Again we consider this
is due to the well known and accepted fact that there is already drastic overallocation of the freshwater resource.

We accept that you see that the proposal will result in:
o Addressing specific water allocation and water quality issues in the
Tukituki River Catchment.
o Reducing the amount of phosphorus in waterways (reducing slime and
algae)
o Enable you to set limits for nitrate levels in the waterways (protecting
fish and invertebrates)
o To set groundwater quality limits
o To propose new water allocation limits
o And, very importantly, to increase current minimum flows.

However feel that insufficient assurances have not been made
allowing us to support the proposal as it stands. We say this with
some regret as the status quo is also unacceptable and action is
needed.
Taking into account the points made above, the NZ Federation of Freshwater
Anglers (Inc.) strenuously opposes this proposal for the following reasons:
1. The proposed dam will be built on the active Mohaka fault line. We
reject the assumption that this can somehow be designed into the
structure and therefore consider that the integrity of the dam cannot be
guaranteed. Any failure of the dams integrity would be catastrophic to
the downstream fisheries, not to mention communities.
2. The proposed dam is said to be modelled on the Opihi dam. The
building of that dam has had a devastating effect on the river and the
fishery downstream of it. The dams design has meant that this
ecological disaster cannot be mitigated or remedied. We have seen
nothing proposed that would suggest that this won’t be repeated on the
Tukituki.
3. The Tukituki already suffers from over extraction and gross pollution as
a result of nitrification by intensive agriculture. This has had a
detrimental effect on the sports fishery. Increasing the scale and
intensity of such activities will, in our view, inevitably increase the
resulting pollution and decline of recreational opportunities within the
river system.
4. The NZFFA opposes in the strongest possible terms, any suggestion to
increase the level of allowable nitrogen in the river as a result of
external activities. The suggestion that algal growth can be controlled
by controlling phosphate levels alone is not supported by science or
rational thought. The implied suggestion that nitrogen is not a
significant pollutant that affects the river ecology and fishery in its own
right is bizarre.
5. Our members value this river for what it is and what it once was. That is
an intrinsic aesthetic value that is very important to us. It includes the
very physical nature of the river and the ecosystems it supports (of
which the sports fishery is part). We see that value as not just being
threatened by this proposal; we see it being degraded forever. We are
losing a public asset for private gain. We see no attempt to mitigate or
compensate that loss, therefore we can only oppose it.
6. Dams are internationally recognised as having the greatest detrimental
effect on rivers, their ecosystems and fisheries of any single influencer.
Indeed in other countries dams are currently being removed from river
systems to restore river health and ecosystems. We can find nothing in
this proposal that addresses or attempts or mitigate such detrimental
effects, and therefore oppose it.
7. Further, the Hawke’s Bay Regional Council’s Proposed Plan Change
proposes the setting of nutrient levels in the river water which are far
too high. So high as to adversely affect not only the health of the river
but the aquatic life therein.
Ian Rodger
On Behalf of the NZ Federation of Freshwater Anglers (inc)
PO Box 338-777, Howick, Auckland
Ph 09 534 7104 and 0274 996 000