BEFORE THE SPECIAL TRIBUNAL FOR THE NGARURORO AND CLIVE RIVERS WATER CONSERVATION ORDER AT NAPIER

Transcription

1 BEFORE THE SPECIAL TRIBUNAL FOR THE NGARURORO AND CLIVE RIVERS WATER CONSERVATION ORDER AT NAPIER IN THE MATTER AND of the Resource Management Act (the Act) 991 IN THE MATTER The Special Tribunal of a Special Tribunal appointed under s202 of the Act to consider an application for a Water Conservation Order made by New Zealand Fish and Game Council, the Hawke's Bay Fish and Game Council, Ngati Hori ki Kohupatiki, Whitewater New Zealand, Jet Boating New Zealand, and the Royal Forest and Bird Protection Society of New Zealand (the Applicants) in relation to the Water Conservation Order Richard Fowler Q'C (Chair) Alec Neill Dr Roger Maaka Dr Ngaire Phillips John McCliskie AFFIDAVIT AND STATEMENT OF EVIDENCE OF ROBERT JAMES GREENAWAY FOR HORTICULTURE NEW ZEALAND AFFIRMED/^JANUARY 2019 ATKINS HOLM MAJUREY Helen Atkins/Nicole Buxeda PO Box 1585 Shortland Street AUCKLAND 1140 Solicitor on the record Contact solicitor Helen Atkins Nicole Buxeda Helen.Atkins@ahmlaw.nz Nicole. Buxeda@ahmlaw.nz (09) (09)

2 I, Robert James Greenaway of Nelson, Consultant Recreation and Tourism Planner, solemnly and sincerely affirm: INTRODUCTION 1. My full name is Robert James Greenaway. 2. I have personal knowledge of the matters set out in this affidavit and confirm that the maters dealt with in my attached Report are true and correct to the best of my knowledge and belief. Qualifications and experience 3. I am an independent consultant recreation and tourism researcher and planner. 4. I graduated from Lincoln University in 1987 with a three-year Diploma in Parks and Recreation Management with Distinction and completed 18 months of postgraduate study in conservation management. 5. I hold the status of an Accredited Recreation Professional with the NZ Recreation Association (NZRA) and am a member and past Chair of the NZRA Board of Accreditation for member accreditation to professional status. 6. I am also a 'core group' member of the New Zealand Association for Impact Assessment. 7. In 2011 I was appointed as an inaugural Board member of the Sir Edmund Hillary Outdoor Recreation Council, to assist Sport New Zealand with the implementation of the National Outdoor Recreation Strategy, amongst other things. 8. I was awarded the Ian Galloway Memorial Cup in 2004 by the NZRA (of which I am a past Executive member) to recognise 'excellence and outstanding personal contribution to the wider parks industry'. In 2013 I was awarded the status of Fellow with the NZRA. 9. I was employed in the fields of recreation and tourism at Tourism Resource Consultants ( ) and at Boffa Miskell Limited ( ) before beginning to work independently in I have completed more than 350 consultancy projects nationally since 1997 and have presented evidence at more than 80 resource management hearings. I have completed

3 recreation assessments on the following 34 rivers (amongst others): Ahuriri (ECan), Arnold (Trustpower), Arrow (Otago Regional Council), Ashburton (ECan), Clutha (Contact Energy, Otago Regional Council), Hurunui (ECan, Fish & Game, Hurunui Community Water), Kaituna (BOP Energy), Kawarau (Queenstown Airport Corp, Otago Regional Council), Maitai (Nelson City Council), Mangorie (Trustpower), Mokau (King Country Energy), Mokihinui (Meridian Energy), Motukawa (Trustpower), Nevis (Pioneer Energy), Opihi (ECan), Oreti (Southland District Council), Pukaki (Meridian Energy), Rakaia (Trustpower), Rangitata (Rangitata Diversion Race Management Ltd, Trustpower), Rangitaiki (Trustpower), Roding (Nelson City Council), Shotover (Queenstown Airport Corp), Tarawera (Norse Skogg), Waiau (Trustpower), Waihao (ECan), Waimakariri (ECan, Central Plains Water), Waimea (Tasman District Council), Wairau - Marlborough (Meridian Energy), Wairau - Southland (Meridian Energy), Waitaha (Westpower), Waitaki (Meridian Energy), Whangaehu (Mighty River Power), Whitestone (Glen Echo) and Wilkin (Lakes Environmental). 11. Most recently I have completed a resource review and assessment of significance on much of the Clutha catchment for the Otago Regional Council, a review of jet boating opportunities and significance in Canterbury for Environment Canterbury, a review of how to assess recreation significance for the Outstanding Freshwater Bodies Project for the Hawke's Bay Regional Council, and a review of esplanade reserve requirements for all Nelson City Council waterbodies to support the City Plan review. 12. I am familiar with the site that is the subject of the application and the surrounding locality and have jet boated the Ngaruroro River from 2km upstream of the Omahaki Stream confluence to Maraekakaho. 13. I was asked to prepare the Report (attached as Annexure A to this affidavit) for Horticulture New Zealand and the Hawke's Bay Regional Council. Code of Conduct 14. I confirm that I have read the Code of Conduct for Expert Witnesses contained in the Environment Court Practice Note (2014) and I agree to comply with it. In that regard, I confirm that this evidence is written within my expertise, except where

4 I state that I am relying on the evidence of another person. I have not omitted to consider material facts known to me that might alter or detract from the opinions expressed. SCOPE OF EVIDENCE 15. In my Report (attached as Annexure A to this affidavit) I: (a) Assess what is'outstanding'; (b) Consider what criteria have been applied to identifying the significance of recreation values in Water Conservation Orders (WCOs), (c) Assess whether historic national reviews of the significance of waterbodies have identified the Ngaruroro River as significant for recreation; and (d) Whether the Ngaruroro River between Whanawhana and Fernhill can be described as outstanding for trout fishing, kayaking, rafting, swimming, jet boating or whitebaiting. 16. The assessment contained within the Report relies on literature review, and a site visit by myself to the lower Ngaruroro River, including a jet boat trip from near Maraekakaho to the cableway upstream of Whanawhana. 17. In the Report I arrive at the following conclusions: (a) Being outstanding is a high test. The term 'outstanding' distinguishes something from others based on its exceptional qualities and is typically used to describe the 'best of the best'. (b) (c) Water Conservation Order decisions are clear that where sufficient data about a particular value of a water body are not available, then the value is not outstanding until the appropriate evidence is provided. While the Ngaruroro River has been identified in some historic reviews as having some significant recreation values at the national level, these have all been based on descriptions of the upper River, above Whanawhana, in its more remote and scenic setting.

5 (d) (e) (f) (g) (h) (i) The Ngaruroro River below Whanawhana is located in a common rural recreation opportunity setting and is not unusual for its recreation scenic values. The Ngaruroro River below Whanawhana is not an outstanding or nationally significant angling resource, in line with the documentation provided as part of the WCO application. The Ngaruroro River below Whanawhana is not an outstanding or nationally significant kayaking or rafting resource, also in line with the documentation provided as part of the WCO application. The Ngaruroro River below Whanawhana is not an outstanding or nationally significant swimming resource. In my opinion, the Ngaruroro River from Whanawhana to Fernhill could be considered outstanding for jet boating if the level of use exceeds 2000 individuals annually, but not otherwise. This figure is the cut-off in the Canterbury River Values Assessment System (RiVAS) assessment for a top score (3) for 'level of use'. Currently there are no quantitative data available to establish the level of jet boating activity, and estimates provided for my assessment were all below 900. The River below Fernhill has no nationally significant or outstanding recreation values. ATTENDANCE AT HEARING 18. I am aware that in Tribunal Minute and Direction 16 (dated 10 October 2018) Stage 2 of the hearing will commence on Tuesday 26 February 2019, for which up to four weeks have been set aside for the hearing. 19. I am also aware of the direction at paragraph [39] in Tribunal Minute and Direction 16 that parties notify the Tribunal as soon as possible where witnesses are unavailable. 20. As such, I wish to notify the Tribunal that I am unable to attend the hearing over the entirety of the dates that it is currently proposed to run.

6 21. The reason I am unavailable for the entirety of this time is that I am on a two-month solo sailing expedition which has taken extensive preparation and is time/weather dependent. 22. I am available for caucusing between Friday 25 January 2019 and Friday 1 February AFFIRMED at Nelson this / / day o &,"** before me: 2019 rt James Greenaway A solicitor of the Hign Courrof Anthony Gilbert Solicitor Nelson aland /

7 ANNEXURE A - LOWER NGARURORO RIVER ASSESSMENT OF RECREATION SIGNIFICANCE BY ROBERT GREENAWAY

8 Dec 2018 Lower Ngaruroro River Assessment of recreation significance This is the annexure marked "A" referred to in the affidavit of ROBERT JAMES GREENAWAY affixed at NELSON before rr/q: I A L\\ SolicitoXtof/thWH Anthony Gilbert Stallard Solicitor Nelson \J

9 Lower Ngaruroro River Assessment of recreation significance December 2018 Prepared for: Hawke s Bay Regional Council and Horticulture NZ By: Rob Greenaway & Associates Version status: Final Lower Ngaruroro River Assessment of recreation significance 2

10 Contents 1 Executive Summary What is outstanding The Ngaruroro recreation resource and its management Recreation opportunity setting Land tenure and public access Department of Conservation Conservation Management Strategy Kaweka Forest Park Conservation Management Plan Hawke s Bay Regional Council Hastings District Council Recreation significance: literature review New Zealand Recreational River Use Study: specialisation, motivation and site preference River Values Assessment System (RiVAS) Water Bodies of National Importance New Zealand recreational river survey National Inventory of Wild and Scenic Rivers A list of rivers and lakes deserving inclusion in a Schedule of Protected Waters Activity data and significance assessments Trout fishing Kayaking Rafting Swimming Jet boating Whitebaiting Conclusion References Appendix 1: Recreation Opportunity Spectrum definitions (Taylor 1993) Appendix 2: North Island jet boating rivers comparison Figures Figure 1: Ngaruroro River sections... 7 Figure 2: Public lands accessible to Ngaruroro River, upper lower section Figure 3: Public lands accessible to Ngaruroro River, lower lower section Figure 4: Hawke s Bay s favourite rivers by order of preference (HBRC 2010) Figure 5: HBRC Clive/Ngaruroro Rivers Reserved Areas Figure 6: 163 national braided river reaches in Duncan & Harding (2007) Figure 7: Upper Rakaia River. Photo: author Figure 8: Ngaruroro River near Whanawhana. Photo: author Figure 9: Ngaruroro River whitebait stands upstream of SH2. Photo: author Tables Table 1. What river setting respondents preferred (Galloway 2008) Table 2: Ngaruroro River compared with RiVAS assessment for Canterbury (Hughey et al 2015) Table 3: Ngaruroro jet boat flow availability 1990 to 2017 by month Table 4: Tom Lowry, estimate of jet boater days, lower Ngaruroro River Table 5: Mike Connor, estimate of jet boater days, lower Ngaruroro River Table 6: Phil Tither, estimate of jet boater days, lower Ngaruroro River Table 7: Kilometres of North Island river class by type Table 8: Percent of North Island river class by type Table 9: Existing and expired whitebait stand permits by river HBRC data Table 10: North Island rivers by section, class and key descriptive Lower Ngaruroro River Assessment of recreation significance 3

11 1 Executive Summary This report reviews, from a recreation perspective and for the Ngaruroro River: What outstanding means, What criteria have been applied to identifying the significance of recreation values in Water Conservation Orders (WCOs), Whether historic national reviews of the significance of waterbodies have identified the Ngaruroro River as significant for recreation, and Whether the Ngaruroro River between Whanawhana and Fernhill can be described as outstanding for trout fishing, kayaking, rafting, swimming, jet boating or whitebaiting. This assessment relies on literature review and a site visit by the author to the lower Ngaruroro River, including a jet boat trip from near Maraekakaho to the cableway upstream of Whanawhana. This review finds: Being outstanding is a high test. The term outstanding distinguishes something from others based on its exceptional qualities and is typically used to describe the best of the best. Water Conservation Order decisions are clear that where sufficient data about a particular value of a water body are not available, then the value is not outstanding until the appropriate evidence is provided. While the Ngaruroro River has been identified in some historic reviews as having some significant recreation values at the national level, these have all been based on descriptions of the upper River, above Whanawhana, in its more remote and scenic setting. The Ngaruroro River below Whanawhana is located in a common rural recreation opportunity setting and is not unusual for recreation scenic values. The Ngaruroro River below Whanawhana is not an outstanding or nationally significant angling resource, in line with the documentation provided as part of the WCO application. The Ngaruroro River below Whanawhana is not an outstanding or nationally significant kayaking or rafting resource, also in line with the documentation provided as part of the WCO application. The Ngaruroro River below Whanawhana is not an outstanding or nationally significant swimming resource. In the opinion of the author of this report, the Ngaruroro River from Whanawhana to Fernhill could be considered outstanding for jet boating if the level of use exceeds 2000 individuals annually, but not otherwise. This figure is the cut-off in the Canterbury River Values Assessment System (RiVAS) assessment for a top score (3) for level of use. Currently there are no quantitative data available to establish the level of jet boating activity, and estimates provided for this report were all below 900. The River below Fernhill has no nationally significant or outstanding recreation values. Lower Ngaruroro River Assessment of recreation significance 4

12 2 What is outstanding A review of literature relating to Water Conservation Orders (WCOs) and comparative recreation assessments of freshwater bodies illustrates 35 years of struggle with identifying the significance of rivers and lakes for recreation; and identifying their use and value for recreation at national and regional levels (Greenaway 2016). Research began well, with an exceptional national review of river recreation by the Egarr brothers (Egarr and Egarr 1981). This, and the National Angler Surveys (NAS) carried out for Fish and Game NZ (the Unwin, and Unwin et al, reports from 1998 to 2013, and other reports based on those data) appear to be the only relevant comprehensive and methodologically sound pieces of work completed at the national level since Egarr and Egarr (1981) is now out-of-date, and the NAS apply only to angling. Several studies have reviewed specific recreation activities, and the significance of rivers for those activities. Examples at the regional or sub-national level include whitebaiting in the South Island (Kelly 1988), kayaking on the West Coast (England 2011) and river and lake recreation at the regional level (Daly 2004). These rely on unique methodologies, apply to single activities, or are desktop studies relying on anecdotal data and, in some cases, weak methodologies. National surveys of recreation used to advise assessments of significance of lakes and rivers besides the NAS all have significant biases or methodological issues, and are ever only indicative and open to debate. National reviews of significance for recreation dating from A national inventory of wild and scenic rivers (Grindell 1984) to the MfE Sustainable Water Programme of Action: Potential water bodies of national importance (MfE 2004b), gained little traction in resource management processes. Most recently, and most relevantly, the Community Environment Fund: Outstanding Freshwater Bodies Project (Harper 2017) summarised the findings of multiple specialist reviews of the history and methods of assessing significance of in-river values and summarised these for definitions of outstanding and approaches to identifying recreation significance in WCOs. The author of this report was a member of the technical advisory group for the Project and contributed the specialist report on recreation. The full recreation review (Greenaway 2016) is appended to Harper (2017). The Project did not set out to identify outstanding rivers, but to consider methods and definitions. Harper made the following very useful summary points based on legal opinion and review of existing WCO decisions: Being outstanding is a high test. The term outstanding distinguishes something from others based on its exceptional qualities and is typically used to describe the best of the best. An outstanding value has a higher threshold than a significant value. An outstanding value will always be significant, but a significant value will not necessary be outstanding. A water body needs to have at least one outstanding value before qualifying as an Outstanding Fresh Water Body under the Policy Statement for Freshwater Management 2014 (NZPSFM). A sum of significant values is not enough to qualify the water body as outstanding, based on legal opinion. There will be exceptions and a water body with a sum of significant values (none alone individually outstanding) could potentially be incorporated this way. A water body can only be reviewed in the context of its present condition. It cannot be assessed on its past condition or its potential under the NZPSFM. Water Conservation Order decisions are clear that where sufficient data about a particular value of a water body are not available, then the value is not outstanding until the appropriate evidence is provided. Lower Ngaruroro River Assessment of recreation significance 5

13 Individual recreation values have contributed to WCO protection decisions and include for recreation: whitebaiting, eeling, angling amenity, jet boating, caving, canoeing, kayaking and rafting. There is no clear method for identifying outstanding whitebaiting settings. There is no one obvious set of characteristics and associated thresholds which can be applied to determine whether angling amenity is outstanding. The combinations of the characteristics assessed depend on the type of fishing experience being sought e.g. large trophy fish, high numbers of fish, salmon or trout, wilderness, and/or scenic natural characteristics. However, it is implicit in WCO decisions that to be outstanding as a recreational fishery or angling amenity, the waterbody must contain an exceptional biological feature such as an abundance of fish, exceptionally large fish, high salmon run numbers, or high numbers of large fish, and have an exceptional angling amenity to justify a finding that it contains an outstanding recreational fishery. There is no conclusive evidence in literature which suggests that any of: bird watching, tramping, walking, biking, camping and picnicking, can be outstanding in their own right. Jet boating, caving, canoeing, kayaking and rafting have been specifically recognised as outstanding and subsequently protected under a number of WCOs. As such, all are identified as key sub-values which have the ability to be outstanding in their own right. The preliminary findings from the WCO review on this value set show that in order to qualify as outstanding for boating, the waterbody must be reliable/predictable for the activity under normal flows, and meet at least one of the following criteria: - have participation rates which are significantly higher than anywhere else in the country, - non-local usage of 20% or more, - contain a unique/rare characteristic shared by few other rivers in New Zealand, - additionally, waterbodies identified in WCO decisions as being outstanding for boating activities also typically provide a highly scenic and/or wilderness experience. There is no conclusive evidence in literature which suggests that any other boating activities such as rowing, sailing, wind surfing, kite surfing, river boarding, water skiing and wakeboarding can be outstanding in their own right. While it is clear that swimming is a national value that needs to be accounted for in management decisions, it is unclear whether alone it would make a water body outstanding for the purposes of the NPSFM. Swimming has not been identified in any of the WCO decisions as being outstanding in its own right. Lower Ngaruroro River Assessment of recreation significance 6

14 3 The Ngaruroro recreation resource and its management This section considers regional recreation planning material in relation to recreation values on the Ngaruroro River, and includes an assessment of the River as a setting on the Recreation Opportunity Spectrum. 3.1 Recreation opportunity setting The study area can be divided into the following recreation opportunity settings (Figure 1): Upper and gorge sections above Whanawhana (not assessed in this report), The lower Ngaruroro River between Whanawhana and Fernhill, and The lower Ngaruroro River between Fernhill and the sea. Figure 1: Ngaruroro River sections 10 km The latter section (Fernhill to the sea) is only considered as a division in the lower River for jet boating. For all other activities, the lower Ngaruroro River from Whanawhana to the sea is considered as one complete section. Appendix 1 contains the Recreation Opportunity Spectrum (ROS) definitions used nationally (in different formats) to define outdoor recreation settings. The purpose of the ROS model is to assist in integrating the management of open space with visitor expectations. The system uses specific terminology to define the experiences a visitor might expect in different settings, ranging from an urban experience at the most developed end of the scale to wilderness at the least developed end. The model does not require all types of recreation settings to be provided in all situations, but encourages open space managers to consider the capabilities, values, uses and characteristics of the settings they look after, as well as the expectations of the recreational users, and to create an optimal match between these. With that in mind, an open space manager may seek to increase levels of service in some locations to facilitate, for example, easy family recreation, or ensure a setting has no development to enable Lower Ngaruroro River Assessment of recreation significance 7

15 an independent wilderness experience. The ROS is specifically recommended as an assessment tool when changes to a setting are possible. Currently, the ROS system is most closely applied by the Department of Conservation, with territorial authorities often adopting a more varied terminology. Appendix 1 presents the recreation setting and experience definitions originally developed by the Department of Conservation for land settings (Taylor, 1993). ROS definitions appear frequently in DOC publications, but not in the Hawke s Bay Conservation Management Strategy (see section 3.3.1). In this case, the Ngaruroro River below Whanawhana passes through a Rural setting according to the ROS definition: Predominantly a cultural landscape with mixed land uses, mainly primary production, farming, horticulture and forestry with some tourist/visitor attractions. Will have a network of services and facilities, roads, power lines, buildings, small population centres, rural communities, villages. This is a common setting description for braided rivers beyond their source foothills passing as they generally do through productive and easily-developed alluvial plains and does not set the Ngaruroro River apart in any way. This setting description is similar to that used by Galloway (2008 see section 4.1) for river recreation settings: Rural Developed Setting: A rural developed area is beyond a metropolitan area and the suburban ring of development. Development will be prevalent and common, yet the setting has a pastoral sense because of an interspersing of forests, water resources, hills, valleys, etc. Natural appearing shoreline edges are common, although various water controls or other structures are also common. This setting type was one of the least preferred for river recreation in Galloway s research. 3.2 Land tenure and public access Figure 1 shows the Walking Access Commission's description of public access along the Ngaruroro River from the Kaweka Forest Park to the coast, according to the Commission s online walking access mapping system (WAMS). This mapping system is consistently incomplete for public lands and, in this case does, not show the Hawke s Bay Regional Council lands extensively developed for public access downstream of Fernhill. Access upstream of Fernhill is limited on the true left to where legal road abuts the riverbed and Crown land at Ohiti Road (although many sections of what appears to be public land is separated by narrow strips of private parcels), and an access off Matapiro Road which is formed across private land but is near an unformed legal road leading to the River. There is no legal public access upstream on the true left until Kaweka Forest Park, where there is no vehicle access to the River from the east. On the true right above Fernhill, access is restricted to that at Maraekakaho (a legal road and reserve), via Mangatahi Stream, Caron Stream and Poporangi Stream. Most of these are identified as fishing access points in on the nzfishing.com, which is currently providing a more comprehensive set of angling access recommendations than the Fish & Game website. 1 The recommended jet boating launch site in the Jet Boating NZ Safety and Year Book (2013) for the section above Whanawhana is, Whanawhana with four wheel drive. This access is across private land and is used by casual agreement. Recommended jet boat access for the remainder of the River is via Ohiti Road, Fernhill or Clive, although access is also possible off Matapiro Road near Cloverdale via a private road to the River located near an unformed legal road. 1 at 10 October 2017 Lower Ngaruroro River Assessment of recreation significance 8

16 Figure 2: Public lands accessible to Ngaruroro River, upper lower section. Source Walking Access Commission Key Lower Ngaruroro River Assessment of recreation significance 9

17 Figure 3: Public lands accessible to Ngaruroro River, lower lower section. Source Walking Access Commission Key Lower Ngaruroro River Assessment of recreation significance 10

18 3.3 Department of Conservation Conservation Management Strategy The Hawke s Bay Conservancy Conservation Management Strategy (CMS) is well past its review date, but remains operative. The CMS identifies the Ngaruroro River within its chapters on Mountainlands, Lowlands and Coastal. In the Mountainlands, the CMS includes as a management objective (2.1.10): v. To advocate by statutory and non-statutory processes the protection of rivers, streams and wetlands which have high natural, historic or recreation values. The headwaters of several major North Island Rivers (Rangitikei, Mohaka, Ngaruroro, Tutaekuri, Manawatu) cross the mountainlands and have high natural, historic and recreation values, as do numerous smaller streams and rivers in the area. In the Lowlands, the CMS notes (p40): The two major plains (Heretaunga and Ruataniwha) were formed by extensive deposition of alluvial gravels by the major rivers which cross them - the Tutaekuri, Ngaruroro and Tukituki rivers. The plains contain some of the best agricultural and horticultural land in Hawke's Bay and are therefore highly developed for these purposes with very few large natural areas now remaining. And (p44): The braided river sections of the Ngaruroro and to a lesser extent the Tukituki rivers have high landscape values and are significant because such features are rare in North Island rivers. Otherwise, there are no management objectives for recreation or references to recreation values for the River in the Lowlands and Coastal chapters although references to important natural values are made. The generic management objective quoted above for the protection of rivers, streams and wetlands is also made in the Lowlands chapter, but without reference to any specific location. Volume 2 of the CMS includes land inventory records for DOC-administered conservation land in the region, including several blocks adjacent to the Ngaruroro River. In the upper River, reference is made to the Kaweka Forest Park Management Plan for site-specific management information. For the reserves in the lower River above the river mouth, visitor use is described as either low ( occasional angler ) or nil, with no visitor facilities. 2 River mouth reserves are described as having high recreational use for fishers (kahawai) and whitebaiters Kaweka Forest Park Conservation Management Plan 1991 The Kaweka Forest Park Conservation Management Plan (CMP) is also past its review period, but again remains operative. While it does not specify that its references to the Ngaruroro River apply only to the upper section, such an assumption is safely made considering the plan only covers the Forest Park area, and such statements as (p11): 2 Ngaruroro 80036, Brookfield 80105, Omahu 80106, Ngaruroro Upoko Block 80100, Ngaruroro Rivermouth Wildlife Refuge 7 Lower Ngaruroro River Assessment of recreation significance 11

19 The Ngaruroro and Mohaka rivers are renowned trout rivers with high wild and scenic qualities. They attract anglers from throughout New Zealand, and increasingly, from overseas. 3.4 Hawke s Bay Regional Council The Hawke s Bay Regional Park Network Plan (no date but operative) describes the lower Ngaruroro River below Fernhill as part of a relevant river corridor but offers no information about recreation use or significance. The River is identified as a regional river but not a regional park in Hawke s Bay Regional Parks 4 (2016). The Hawke's Bay Regional Resource Management Plan (2015) defines the Ngaruroro River upstream of Fernhill as having the lowest equal regional guideline for faecal coliforms (50 cfu/100ml) with the Mohaka River, Taharua Stream and Tutaekuri River upstream of Redclyffe Bridge and the lowest equal suspended solids target (10 mg/l) with those same rivers plus the Clive River and its tributaries (at section 5.4.2). The Plan notes ( ): The major river systems are the Wairoa, Mohaka, Esk, Tutaekuri, Ngaruroro, Tukituki and Porangahau Rivers. These are mostly fast flowing, clean, gravel rivers, with extensive braided reaches. They support a rich and diverse wildlife, and are well known for the recreational opportunities they offer, including fishing, jet boating, canoeing, rafting and swimming. They are used for water supply and irrigation purposes, but do not receive a large number of point source waste discharges. River flows and temperatures fluctuate markedly due to droughts, causing problems for instream biota and for water supply. There is no significance assessment for the Ngaruroro River (or any other) for recreation. In 2010 the Regional Council completed a recreational usage survey for Hawke s Bay rivers (HBRC 2010). The survey method was self-selection via on-line and hard copy response options, and 102 responses were gained. While the HBRC report authors were comfortable with this response level, in the opinion of the author of this report it is at the low end (a good target is around 400), and a self-selected sample is open to significant bias. The results should be read with some caution and are unlikely to be representative of the regional recreation population. Activities identified on the Ngaruroro River were kayaking, swimming, walking, fishing, shooting, camping, picnicking, biking and kite surfing. Bird watching, four-wheel driving and dog walking were not identified. Use was not subdivided by river section. Figure 4 shows the results for favourite rivers. The Ngaruroro River appeared in fifth place behind the Mohaka, Tukituki, Clive and Tutaekuri Rivers. For those respondents who rated the Mohaka as their favourite river (n=34), second and third place went to the Ngaruroro (14) and Tukituki Rivers (7) respectively. For those respondents who rated Tukituki as their favourite, second place equal went to the Tutaekuri and Ngaruroro (2) rivers, and for those respondents who rated Clive as their favourite, second place went to the Esk River (3) and third place equal went to Wairoa and Ngaruroro Rivers (2). No other data in the survey report are cross tabulated by river; and, considering the low response rate on a per-river basis (11 or 12 for the Ngaruroro River), this is advisable. 4 Lower Ngaruroro River Assessment of recreation significance 12

20 Figure 4: Hawke s Bay s favourite rivers by order of preference (HBRC 2010) To support the Regional Council s TANK planning process (an acronym from the Tūtaekuri, Ahuriri, Ngaruroro and Karamū catchments), an Inventory of Values in the Tank Catchments of Hawke's Bay was commissioned (Sinner & Newton 2016). This included the data presented in this report from the RiVAS assessments (see section 4.2 of this report), HBRC regional parks network plans and access data and the national angler surveys. No significance assessment was completed besides describing the findings of the RiVAS assessments for salmonid angling, swimming and kayaking (discussed in section 5 of this report). 3.5 Hastings District Council The District Council identifies several reserves adjacent to the Ngaruroro River in its District Wide Reserve Management Plan (no date, but operative), but offers no information relevant to this assessment. The Operative Hastings District Plan (February 2003) identifies in section 13.9 Appendix , Riparian areas in the rural and plains zones identified as being of natural, recreational or cultural significance. The Ngaruroro River is identified as having high values for fishing, swimming, water fowl & upland game hunting. This is a common assessment for 11 of the 13 waterbodies included in the appendix. This same assessment is included in the Proposed District Plan (September 2015) at Appendix 54, but 16 waterbodies are listed and 12 have high ratings for recreation and access. Lower Ngaruroro River Assessment of recreation significance 13

21 4 Recreation significance: literature review This section reviews academic and popular literature to provide a description of the recreational activities carried out on the Ngaruroro River, and the values ascribed to them. Activity-specific literature is reviewed in section New Zealand Recreational River Use Study: specialisation, motivation and site preference Galloway (2008) reported on the findings of a survey of individuals who recreate on and around rivers in New Zealand (New Zealand Recreational River Use Study). Individuals were invited to participate in an internet survey via direct contact at river recreation-related events and electronically via a range of related web sites, group membership, internet bulletin boards, magazines and newspapers. Just over 1300 respondents completed the survey which ran from October 2007 to March Although the survey results cannot be considered representative of the recreation population, as the sample was self-selected and not randomly generated, they give a useful impression of the opinions and preferences of what is probably the more active and aware end of the recreation participation spectrum. Twenty-three activities were represented in the data. The dominant respondents were white water kayakers, anglers and multisport participants. Respondents were grouped into four broad activity groups: boating (non-motorised) (55.4%), fishing (21%), boating (motorised) (2.4%), and shore-based (21.2%). The survey was designed to evaluate respondents' motivations and site preferences about their level of specialisation in their activity. It was not designed to ascribe values to defined reaches of rivers throughout New Zealand so, in that sense, its results must be treated conservatively. A list of 1043 rivers was compiled and respondents were asked to indicate up to ten rivers that they had last visited, and the next ten that they wished to visit. This provides a snapshot, rather than a complete picture of the respondents' experiences and views. A total of 4921 rankings were provided for 513 rivers. Rivers ranked more than 100 times included the Waimakariri (227), Tongariro (191), Buller (154), Hurunui (128), Kaituna (118), Mohaka (116), and Clutha (113) Rivers. The Ngaruroro was rated by 27 respondents out of 1300 (Galloway 2008: Table B1). Table B2 (Galloway 2008) identifies the recreation group of those respondents and, for the Ngaruroro, shows: 11 were 'boating (non-motorised)', 4 were 'fishing', none was 'boating (motorised) and 2 were 'shore-based'. There appears to be data missing in this analysis. The Ngaruroro River was not subdivided by reach, and so no comparison can be made between the upper and lower reaches. Respondents were asked to rate their preferences for river grade. 5 The majority of boaters preferred river sections graded 2 to 4 (67.8%) as opposed to the harder grades 5 to 6 (4.5%), 5 Charles (2006) defines the river grades: 1 moving water with a few riffles and small waves. Few or no obstructions. 2 easy rapids with waves up to one metre. Clear channels obvious without scouting. The ability to move your craft across the current is not necessary. 3 rapids with high, irregular waves and narrow passages. The ability to spin and manoeuvre is necessary. 4 difficult rapids requiring a series of controlled moves, cross-current and spinning in confused water. Scouting often necessary and a reliable roll is mandatory. 5 very difficult, long and violent rapids. Nearly always must be scouted. Definite risks in the event of a mishap. Requires a series of controlled, precise, must make moves to navigate successfully. 6 extreme, very dangerous and only for experts. Close inspection is mandatory and all possible safety precautions should be taken. Make my day the top end of the grading scale to date. Rather like staring down the barrel of a gun as Clint Eastwood sneers you have to ask yourself punk do you feel lucky? Lower Ngaruroro River Assessment of recreation significance 14

22 or ungraded rivers 6 (3.0%). Just over 50% selected grades 2 to 3. Grade 1 was preferred by 6.1%, grade 2 by 27.3%, grade 3 by 23.6%, grade 4 by 16.9%, grade 5 by 4.2% and grade 6 by 0.3%. The grade definitions are sufficiently similar to those used by Egarr (1995) and Charles (2006). Respondents were also asked to rate their ability according to what grade of river they could paddle. For each visited river, respondents were asked to rate its scenic beauty, wilderness feeling, degree of challenge, and opportunity to develop Whanaungatanga / companionship, on a 9- point Likert scale (a scale of response options ranging from full (9) to no (0) agreement, with 5 a neutral response). The question was phrased generally, and therefore is not able to take into account the different values supported by different reaches of each river. At best, it provides a general, broad brush impression of the values ascribed to the whole river, compared to the general values ascribed to other rivers. Of 71 rivers nationally the Ngaruroro River was ranked: 22nd for scenic beauty (a mean of 7.12 within a range of 3.05 for the Avon River to 8.6 for the Arahura River), 19th for wilderness feeling (a mean of 6.71 within a range of 2.0 for the Avon River to 8.38 for the Whataroa River), 42nd for challenge (a mean of 5.47 with a range of 2.1 for the Avon River to 7.8 for the Ruakituri River), 48th for companionship (a mean of 4.76 with a range from 3.25 for the Hinemaiaia River to 6.82 for the Waitaha River), and 30th overall (the grand mean) (a mean of 6.01 with a range of 3.22 for the Avon River to 7.69 for the Arahura River). Respondents were asked for their preference for the level of human development on or around rivers. A six point scale for development was described. Table 1 defines the development scales and shows the levels of preference. These data can only be applied in a general sense, as they are not specific to any named river. However, the development scales can be useful in describing the potential effect of introducing new structures into relatively undeveloped areas. In the analysis, the last three most-remote setting definitions, and certainly the last two, have fine shades of difference which are not helpful considering the subjectivity inevitably applied by respondents. The lower Ngaruroro River suits the ' Rural Natural Setting' and ' Rural Developed Setting definitions. Table 1. What river setting respondents preferred (Galloway 2008) Setting definition Urban Setting: An urban area may be found in extensively developed and populated cities and metropolitan spaces where virtually the entire landscape contains human-built structures. The water resources tend to be highly channelized, manipulated, or altered to contain large fluctuations in water flow and for the protection of public safety and property. Percent of respondents preferred This term is not defined in the report (Galloway 2008) and it does not appear as a response option in the questionnaire. Galloway (pers comm.) advises: "An ungraded river, in the sense I use the term, is one that hasn't been graded. I would interpret this as rivers that are very remote and/or difficult, rare at this point in time. 'Make my day' [Charles 2006] would fit too. Lower Ngaruroro River Assessment of recreation significance 15

23 Table 1. What river setting respondents preferred (Galloway 2008) Setting definition Suburban Setting: A suburban area is on the fringe of the urban area. The sights, sounds, and smells of development and built structures are widespread. The water resources tend to be highly channelized, manipulated, or altered to contain large fluctuations in water flow and for the protection of public safety and property. Rural Developed Setting: A rural developed area is beyond a metropolitan area and the suburban ring of development. Development will be prevalent and common, yet the setting has a pastoral sense because of an interspersing of forests, water resources, hills, valleys, etc. Natural appearing shoreline edges are common, although various water controls or other structures are also common. Rural Natural Setting: A rural natural area is a considerable distance from metropolitan areas and communities. Natural features are predominant on the landscape and the presence of development is occasional or infrequent. The water resources are bordered by natural appearing settings. Water controls or other structures are occasional along the shoreline. Semi Primitive Setting: A semi primitive area is a large expanse of natural resources that is far from any city or metropolitan area and a considerable distance from small communities, subdivisions or developments. Natural resources dominate the landscape. These water resources are often within large expanses of public lands and waters. Primitive Setting: A primitive area is a large expanse of natural resources far from development and settlement. Any sights, sounds, or smells of human activity are rare and very minor. The water resources and shorelines appear natural and show very little, if any, evidence of past human use such as historic homesteads and roadways. Percent of respondents preferred Respondents were asked to indicate the importance of selected site values in general terms (not specific to any river). The highest rated items were 'clean and unpolluted river water', and 'wilderness character' and 'scenic beauty'. The lowest rated items were the availability of a car shuttle service, and the presence of bathrooms, changing rooms, showers, etc. Large differences were reported for how important the four groups rated the importance of preferred site values. Wilderness values were highest rated among all activity use groups, and facility values lowest. The 'fishing' group placed significantly greater importance on wilderness values than the other three groups. The 'boating (non-motorised)' group placed greater importance on social-skill values than the other groups. 4.2 River Values Assessment System (RiVAS) Hughey et al (2010) carried out a research programme funded by the Foundation for Research Science and Technology to develop a 'useable' system for regional councils to assess the significance of in and out of stream river values in New Zealand. An assessment method called the River Values Assessment System (RiVAS) was developed and has been applied to several suites of recreation and natural river values within several regions. The RIVAS method has been applied to kayaking, swimming and salmonid fishing in the Hawke s Bay. The RIVAS method relies on a panel of experts from a specific recreation activity to identify the regional resources able to be used for their activity, the resource attributes which indicate Lower Ngaruroro River Assessment of recreation significance 16

24 their importance for recreation, including the level of use, and to score various indicators of value to give a relative assessment of significance. RiVAS provides the most complete description and analysis of white water settings on Hawke s Bay Rivers. The reductionist approach enables identification of the basis for each assessment, and while there may be disagreement about site-specific conclusions, RiVAS remains a significant resource for identifying the scale of alternative regional recreation options and the level of resource substitutability. Debate about absolute and relative values of river settings should not result in the RiVAS data being ignored. Reviews of each relevant RiVAS assessment is provided in section Water Bodies of National Importance As part of the Government's assessment of Water Bodies of National Importance, work has been undertaken to identify water bodies of value for recreation and tourism. The recreation report, titled Potential Water Bodies of National Importance for Recreation Value (MfE, 2004), lists 105 freshwater bodies including lakes, river and wetlands that are potentially important for recreation. Seven water bodies are identified in the Hawke s Bay including the Ngaruroro River. The list was derived from an internet survey of recreationists, a telephone survey of the public, a literature review and discussion with selected representatives of recreational groups. The report has many inconsistencies and the base research has significant weaknesses. The internet survey which was based on a self-selected sample with an apparent bias to kayakers and canoeists had the following count of activity respondents for the Ngaruroro River: 15: Canoeing or kayaking 11: Fishing 2: Jet boating 14: Tramping 2: Water skiing, wake boarding It was also identified as a whitebaiting river with more than 100 users. The equivalent report for tourism (TMT, 2004) used activity data from the International Visitor Survey and Domestic Travel Study to identify trips associated with freshwater bodies and included the following 'activities': scenic cruises, beaches, jet boating, glow worm caves, swimming, caving, white water rafting, black water rafting, lake fishing, river fishing, sailing, river kayaking, water skiing and punting. The dataset identified the top eight freshwater destinations (which did not include any destinations in the Hawke s Bay) and the top ten freshwater activities. To refine the analysis to individual water bodies, tourism organisations were contacted for their input. Since the Hawke s Bay did not contain a nationally significant tourism freshwater destination, no further analysis was undertaken for regional water bodies. A separate listing is given of freshwater bodies important for their scenic appeal rather than use value. None were in Hawke s Bay. Lower Ngaruroro River Assessment of recreation significance 17

25 4.4 New Zealand recreational river survey The only comprehensive assessment of recreation potential of inland waterways was undertaken over three decades ago (Egarr & Egarr 1981). The Ngaruroro was described in three sections: The Upper Ngaruroro Catchment above the Napier-Taihape Road (with High recreation value); Ngaruroro Gorge to the Otamauri Stream confluence (with Exceptional recreation value); and the Lower Ngaruroro to the sea (with Intermediate recreation value) LOWER NGARURORO Location: From the Otamauri Stream confluence the Ngaruroro meanders in a very braided fashion down to the sea at Clive. Length: 58km Average gradient: 1:250 4m/km. RECREATIONAL USE: Motor launches: At the river mouth only. Jet boats: Excellent boating up to the gorge. Requires above normal water flows for the best boating. Drift boats, rafts, canoes/kayaks: Seldom used as the river is devoid of good rapids, has a low current flow and the scenery is far inferior o the upper area. Easy Grade 1 canoeing and rafting. The larger boats find the river too shallow. Pack floating: Unused. Swimming: Isolated quiet pools only. Scenic description: The river meanders over a wide shingle bed down to Fernhill and thence to a straightened out channel which is flanked by stopbanks. The upper end of this river section contains numerous willows on the banks but they are not as thick, nor as numerous as on the other rivers in the south. Farmland lies on either side of the river with old river terraces further back from the river bed area. Scenic value: Moderate. Recreational value: Intermediate. The Egarrs' report provides rankings of rivers/reaches for recreational and scenic value and goes on to select the most important that deserve protection for their recreational value. The Ngaruroro River Gorge was identified as a Category B river section due to its Exceptional recreation value (one of seven in the North Island in Category B there were two North Island rivers in Category A). The Upper Catchment of the River was identified as a Category C section (one of 25 in the North Island). The Lower Ngaruroro was not identified. 4.5 National Inventory of Wild and Scenic Rivers In 1982 the National Water and Soil Conservation Authority released a draft inventory of wild and scenic rivers and sought submissions. A resulting document was published in 1984 (Grindel 1984), which provides a list of what were considered to be nationally important wild and scenic rivers. The final list excluded lakes because the Committee responsible for compiling the list decided that its terms of reference did not include them. Thirteen rivers were identified in the North Island and 40 in the South. The Ngaruroro River was not amongst them. Lower Ngaruroro River Assessment of recreation significance 18

26 The Ministry of Agriculture and Fisheries made a substantial submission to the draft inventory in relation to freshwater angling values (Tierney et al 1982). The authors recommended that the Ngaruroro River headwaters (source to Whanawhana, p65) be considered as nationally important due to the value as a wilderness fishery for fishing (p38): For the purposes of this discussion, the Ngaruroro headwaters extend from the source of the river to downstream of the gorge, where the river emerges onto the plains. Importance ratings assigned to this river reach by anglers from the Hawke s Bay,. Wellington, Wanganui and CNIWC acclimatisation districts indicated that there Ngaruroro headwaters are worthy of inclusion in the list of national important river fisheries. Access to this remote river reach was considered to be very difficult, despite the Napier-Taihape road which crosses the river at Kuripapango. However, anglers whim de the effort were rewarded by the peace and solitude associated with fishing this exceptional scenic stretch of water. Angers reported a relatively high catch rate of large trout, a feature of such headwater fisheries. Nymph and wet fly were the preferred methods used by anglers, over 60% of whim combined fishing with shooting. More than half of the respondents recorded tramping and camping as other recreational activities associated with angling. According to our criteria, therefore, the Ngaruroro headwaters qualify as a nationally important wilderness river fishery. Teirney et al (1982) recommended only two rivers in the North Island as potentially nationally important for non-salmonid reasons the Wanganui and Waikato. 4.6 A list of rivers and lakes deserving inclusion in a Schedule of Protected Waters In 1986 the Protected Waters Assessment Committee released its recommendations for a, list of those lakes and rivers which the committee commends as suitable for inclusion in a Schedule of Protected Waters (Grindell and Guest 1986). The intention of the study was to advise the then Ministers of Works and Development and Conservation of, those waters deserving inclusion in a schedule of Protected Waters that can be attached to the Water and Soil Conservation Bill. The committee s analysis built on the National Inventory of Wild and Scenic Rivers (Grindell 1984), but expanded the scope of assessment from that study s limit of wild, scenic, recreational and scientific values to include, in addition: fisheries, wildlife habitat, flora, tourism and cultural values. In terms of recreational values, the relevant assessment procedure for identifying an outstanding waterbody was well outlined (p7). This process was drawn, in the main, from the approach used in the National Inventory of Wild and Scenic Rivers: This category includes those rivers where the existing water regime plays an essential and dominant role in providing an outstanding recreational experience or range of experiences. An area which has an unrealised potential for providing an outstanding amenity may be considered. While the surrounding landscape may contribute significantly to those experiences the water, the river or lake bed and possibly a narrow riparian strip are the crucial elements for the recreational value. The recreations are mainly instream use (angling, jet boating, canoeing, packfloating, etc) but this committee recognised that picnickers, etc, also went there because of the water, not in spite of the water. An area may be considered outstanding because of one or more of a number of characteristics. It may provide a wide variety of recreational experiences and be used often by people within and, to an extent, Lower Ngaruroro River Assessment of recreation significance 19

27 outside its region. Or its present level of use may be low but provide an exceptional type of recreational experience, possibly requiring advanced skills so that people from other regions or overseas travel to the area to use it. Summary of characteristics a The characteristics vary and largely reflect the recreational uses for which the river is outstanding. b The river satisfies the recreational needs of a large number of people, or constitutes an amenity for a wide variety of recreational activities, or provides an outstanding recreational experience. c A river in this category may be under-utilised at present but have potential for varied, intensive or specialised use. d The area may be readily accessible, frequently by road. The surrounding land may show signs of human activity and settlement. e The water may be subject to some minor diversions and there may be some development such as bank protection works, but not to the extent that the river regime is controlled. f While there may be some waste discharges, the water will usually be of a quality compatible with the recreation activities. Rivers are the focus of a great variety of recreational activities. A range of recreational facilities for present and future recreationists must be protected throughout the country. a Wilderness and expedition type facilities : generally wild and scenic rivers of sufficient size to permit a range of recreational values. b White water : essential for whitewater rafting, canoeing, jet boating. c Placid water : essential for boating activities where coastal waters unsuited to boating. d Small urban streams : close to populated areas for general recreation and picnicking. e Routes as access and as a form of recreation. The committee developed a three tier classification (groups one, two and three) to define an order of importance for the waters identified as outstanding. In terms of including the waters in a schedule of protection (p12), anything less than the first group would provide an inadequate representation. If the Schedule should be bigger, then the second group should be used for making a selection. If the two together are insufficient then the third group should be used for making a selection. The Ngaruroro River (including the Taruarau River) was listed as a group two water body (second priority in a list of 35 such waterbodies in the North Island), with the narrative: Wild, scenic, high recreation use (canoeing, rafting, tramping, hunting, jet boating). Important trout fisheries in upper reaches. Headwaters are in tussock grasslands in the Kaimanawa Range. A highly valued river - excluded from Group 1 only because of its proximity to the Mohaka River. (Hawke s Bay Catchment Board). Lower Ngaruroro River Assessment of recreation significance 20

28 5 Activity data and significance assessments 5.1 Trout fishing Booth et al (2012a) in the RiVAS assessment for trout fishing in Hawke s Bay rated the Ngaruroro River downstream of the Taruarau confluence as of medium significance (24 th equal in the region noting that some double-counting was included with both reaches and entire lengths of some rivers assessed separately), and the River above this point as of high significance (4 th equal in the region). The River in total from source to sea was rated of medium significance (12 th equal in the region). Unwin (2013a) summarises the results of the national angler surveys, and reports (p5): Estimated annual angler usage of the Ngaruroro River was 3,760 angler-days in 1994/95, 6,240 angler-days in 2001/02, and 2,810 angler-days in 2007/08 [and 4,440 ± 550 in 2013/14 (Unwin 2016)]. This is well below usage levels for highly used North Island rivers such as the Tutaekuri, Tukituki, and Rangitikei, but comparable to wellknown South Island back country fisheries such as the Buller, Tekapo, and Ahuriri, and ahead of other high profile central North Island rivers such as the Ruakituri, Manganui-o-te-ao, and Whakapapa. The upper reaches of the Ngaruroro River sustain a fishery comparable in stature to back country and headwater fisheries elsewhere in New Zealand, including the Ahuriri, upper Oreti, Sabine, Travers, Caples, and Greenstone, all of which are recognised as nationally important. For this reason, the upper Ngaruroro should be regarded as nationally important. The lower reaches of the Ngaruroro River also sustain a significant recreational fishery, but its value is regional or local rather than national. This differs from the assessment recorded in the 2005 Sports Fish & Game Bird Management Plan for the Hawkes Bay Region (Fish & Game 2005): The [Ngaruroro] River is a nationally important angling resource. The main values placed on the Ngaruroro River angling experience include ease of access, the river morphology, the use of the surrounding land and intrinsic aesthetic values. In recent times, guides and air charter operators have repeatedly expressed concerns relating to the state of the fishery that is being affected by the increase in visitor pressure. Unwin (2013a) reviews the key base data which supports his analysis and notes (p15): In terms of the lowland / back country / headwater fishery spectrum, the upper Ngaruroro River has essentially all the attributes of a highly valued headwater fishery. Its level of use, apparently between about 500 and 1,500 visits annually, is consistent with figures for highly valued headwater fisheries elsewhere in New Zealand, such as the Ruakituri, Sabine, Travers, Nevis, Caples, and Greenstone. Indeed, few such rivers attract more than 1,000 visits annually, given that high scores for wilderness value and solitude are invariably associated with low levels of usage. For this reason, I believe the Ngaruroro headwaters support a fishery of national importance. The lower reaches of the Ngaruroro River also sustain a significant recreational fishery, but its value is regional or local rather than national. In a regional context, anglers who might otherwise choose to fish the lower Ngaruroro have at least two viable alternatives in close proximity, i.e., the Tutaekuri and the Tukituki. The Lower Ngaruroro River Assessment of recreation significance 21

29 relatively low usage of the lower Ngaruroro relative to its two neighbours is consistent with this interpretation. Kent (2006) reports in his comprehensive angling guide to the North Island (p184): Below Kuripapango on the Taihape-Napier Road, the river enters a very difficult gorge and only becomes fishable again in the vicinity of Whanawhana. Here the character of the river changes with open shingle banks, long glides, shallow runs and willows. There are some stable pools, especially where the river runs up against a bank, but the river can alter considerably during a flood. Favoured spots include the Ohara and Otamauri stream mouths at Whanawhana, and the Ohiti Stream mouth past Fernhill. Rainbows average 1kg and respond to all types of fly fishing and spinning The river becomes larger in the lower reaches with long glides and short runs. Fish are difficult to spot and weed becomes a problem in summer. However, there is some entertaining smelt fly fishing in October and November when the whitebait are running. Most trout are taken on spinners in these lower reaches. Without doubt, the inaccessible upper reaches upstream from Kuripapango offer the most exciting fishing in this large river. Kent & Madsen (2003) include the Ngaruroro River in their book New Zealand s Top Trout Fishing Waters, but state, Only the upper reaches of this large river, upstream from the Taihape-Napier road, will be described. Conclusion as to significance for angling As per Unwin s (2013) finding the Ngaruroro River below Whanawhana is not an outstanding or nationally significant angling resource. 5.2 Kayaking Booth et al (2012b) in the RiVAS assessment for kayaking in Hawke s Bay rated the Ngaruroro River downstream of Whanawhana in the bottom list of regional kayakable rivers, and provided no data about levels of use and values. In the 5 th edition of New Zealand Whitewater: 180 Great Kayaking Runs - the only current popular guide for kayaking - the Ngaruroro River is reviewed only for its Lower Gorge section, which begins at the Ngaruroro Bridge in Kuripapango and ends at the confluence of the Otaumuri River (Charles 2013). There is no description of kayaking in the River below Whanawhana. Graham Egarr s New Zealand's North Island Rivers: A Guide for Canoeists, Kayakers and Rafters guide (Egarr 1989) was prepared by the co-author of the original New Zealand Recreational River Survey (Egarr & Egarr 1981). In the author s opinion, the upper and gorge sections of the Ngaruroro River provided one of the best river trips in the North Island and the gorge was one of the best whitewater trips. In introducing the River, Egarr states (p160): The Ngaruroro River is a small backcountry river which offers excellent white water when a little above its average flow. It is a remarkable wilderness trip that has become popular over the last decade, although prior to this the river was little known. It can be run in two sections; these are the upper river down to the Napier-Taihape Road at Kuripapango, and the river from this point down through what is known as the Lower Gorge. The Taruarau, which is the largest tributary of the Ngaruroro, is also Lower Ngaruroro River Assessment of recreation significance 22

30 runnable, but requires high spring flows to be so. It has a difficult gorge of steep rocky rapids. Of the Lower Ngaruroro Egarr states (p163): The Lower Ngaruroro can be paddled from the Whanawhana Road access mentioned above as the take-out for the gorge trip down to the Fernhill Bridge. This is a flatwater paddle over a shingle bed, which is often very braided and has some willow problems. It should be considered grade I. An alternative access is to put in onto the very small and shallow Poporangi Stream at the bridge and picnic on Big Hill Road near Kereru. High flows will be needed for this access. At these times the current in the main river will give the best paddling conditions anyway. Very high flows will provide long, rolling pressure waves in the upper section of this run. The 64 New Zealand Rivers study (Egarr et al 1979) was an evaluation of the scenic values of the top river nationally. It was an adjunct to the New Zealand Recreational River Survey (Egarr & Egarr 1981) and was intended to provide additional detail about the rivers scenic qualities. As it was completed by renowned kayakers, it is often associated with kayaking amenity, although this was not its focus. Nevertheless, the assessment relied on scoring seven attributes of river sections, including water movement, water quality and wilderness quality. The Ngaruroro River gorge scored 15 from a maximum possible score of 24 (6 th equal in the North Island with the same score as six other river sections), and the lower River from Whanawhana to sea scored 6 (42 nd equal). The Whitewater NZ supporting documentation for the WCO on the River provides little data about the Ngaruroro River below Whanawhana (Whitewater NZ 2015). Their application states in summary: To maintain this outstanding kayaking resource, Whitewater NZ advocates the preservation of the wilderness, landscape, and flora values and flow and rapids of both the Ngaruroro and Taruarau Rivers from their headwaters down to Whanawhana. The surrounding land, river bed and flows should be allowed to remain in their natural state as much as possible down to Whanawhana. Conclusion as to significance for kayaking The Ngaruroro River below Whanawhana is not an outstanding or nationally significant kayaking resource. 5.3 Rafting There is little information available regarding rafting on the Ngaruroro River below Whanawhana. The Whitewater NZ supporting documentation for the WCO provides a summary of rafting activity in the River above Whanawhana only. There are no commercial operators offering guided trips below Whanawhana. Egarr & Egarr (1981b) reported that the River below the Otamauri Stream confluence is seldom used by drift boats, rafts and canoes or kayaks (p75): as the river is devoid of good rapids, has a low current flow and the scenery is far inferior to the upper area. Easy Grade 1 canoeing and rafting. The larger rafts and boats find the river too shallow. Much of the data discussed in relation to kayaking in the section above is relevant to rafting. In Re Application under section 20A of the Act for a water conservation order in respect of the Mohaka River (No W20/92) the panel noted, in comparing the Mohaka River which was Lower Ngaruroro River Assessment of recreation significance 23

31 found to provide outstanding recreational white-water rafting from the State Highway 5 bridge to Willowflat with other regional rafting rivers (p64): The Mohaka River and the Motu River offer the only available multi-day rafting tours on white-water in the North Island. The Mohaka has a full range of rapids from grade 1 to grade 5, with two full days of white-water with rapids of grades 3 to 5, where most other rivers only have a few hours of white-water. The Tongariro River has controlled flows and provides only short trips; The Rangitaiki River has similar restrictions; there are some difficulties in gaining access to the Rangitikei River; and the Motu River has less continuous whitewater and is more a scenic, than an excitement rafting trip. The Ngaruroro River has only grades 1 to 3 rapids, and suffers from low flows at times. The evidence established that the Mohaka River is often still raftable when other rivers such as the Motu and the Ngaruroro are not. The Whitewater NZ supporting documentation for the WCO indicates that two-day rafting trips are now undertaken on the Ngaruroro River above Whanawhana. Conclusion as to significance for rafting The Ngaruroro River below Whanawhana is not an outstanding or nationally significant rafting resource. 5.4 Swimming Booth et al (2012c) identified four swimming sites on the Ngaruroro River, and assigned the following scales of relative significance (all local in the River below Whanawhana): Kuripapango (associated with camping): Regional Chesterhope Bridge: Local Fernhill Bridge: Local Carrick Road entrance: Local The Hawke s Bay Regional Navigation Safety Bylaws set aside a section of the lower Ngaruroro River for passive water activity including swimming (E in Figure 5). This is in the coastal marine area and has poor swimming amenity with muddy banks and poor access to the water. Conclusion as to significance for swimming The Ngaruroro River below Whanawhana is not an outstanding or nationally significant swimming resource. Lower Ngaruroro River Assessment of recreation significance 24

32 Figure 5: HBRC Clive/Ngaruroro Rivers Reserved Areas 5.5 Jet boating There is little data available nationally to define the significance of jet boating on the river-byriver basis. The only RiVAS assessment for jet boating has been completed for Canterbury (Hughey et al 2015). The Jet boating NZ supporting documentation for the WCO indicates that the lower Ngaruroro River affords a rare for the North Island braided river experience suitable for a wide range of skill levels, with a challenging shallow-water theme. More than 2000 annual users are estimated. There are no commercial jet boat services on the Ngaruroro River for tourists. By comparison, the Waimakariri River is estimated to support 20,000 recreational jet boat users per annum and 8500 commercial jet boat passengers over two reaches (gorge and lower); and the Rakaia 15,000 recreational users and 7500 commercial (also over two Lower Ngaruroro River Assessment of recreation significance 25

33 reaches) (Hughey et al 2015). Both of these South Island rivers present outstanding jet boating experiences. The Waiau River from the Hope confluence to Leslie Hills (including the gorge near Hanmer Springs) featured 2500 recreational and 5000 commercial users and was considered nationally significant. Lower use, but still considered nationally significant in Hughey et al (2015) were the lower Wairau River with 700 recreational users, the upper half of the lower Waitaki River with 3000 recreational users, the upper Waitaki with 300 recreational users and the upper braided section of the Rangitata River with 1000 recreational users. In the Rangitata River Water Conservation Order Application Report by the Special Tribunal October 2002 the panel stated (p66): New Zealand Jet Boat Association (NZJBA) described how the Upper Rangitata River is the most extensive and unspoilt area of braided shallow water boating in New Zealand. Jet-boaters from the North and South Islands view this as a "must do". It provides conditions that that are suitable for both experts and beginners. "This unspoilt section above the gorge is singular and outstanding, with its combination of natural and recreational values, its backdrop of alpine splendour and its history." The upper Rangitata River was found to be outstanding for jet boating, canoeing and rafting. In the 1993 Report of the Special Tribunal to hear the Water Conservation Order Application on the Kawarau River and Tributaries, the lower Shotover was found to be outstanding for jet boating relying on such data as: 55 operators were involved in a wide variety of activities including rafting, jet boating, cruising and boating, paraflying, commercial kayaking, commercial guided fishing, and river surfing. Adventure tourism in the Kawarau catchment was at the leading edge of adventure tourism in Australasia based on the wide variety of natural features such as rivers, lakes and snow slopes. The Shotover River downstream of Deep Creek was particularly important for water based commercial recreation with an estimated 179, 000 visitors participating in jet boating and rafting operations in This was well in excess of any other river in the country. The Kawarau River had an estimated 100,000 visitors for jet boating and rafting for the same period. This was contrasted with rivers in other parts of the country with an estimated 10,000 visitors per annum (Rangataiki, Waikato and Wairoa Rivers). And for the Kawarau (in the application): The Kawarau River is the principal element of landscape along this road. It has an intrinsic recreational value as a scenic landscape and as the basis for a range of leisure pursuits such as rafting, kayaking, jet boating, trout fishing, walking and bungy jumping. Commercial rafting and jet boating operations on the river carried 37-45,000 passengers in The 1986 Rangitikei River Water Conservation Order Application Report and Recommendations of the National Authority Rangitikei Committee was not specific about the jet boating values being protected. The 1984 Rakaia River National Water Conservation Order Application Report of a National Water and Soil Conservation Authority Committee noted (p22): In terms of numbers participating, the most significant recreational pursuit after angling is jet boating. This is often associated with fishing, or part of a commercial Lower Ngaruroro River Assessment of recreation significance 26

34 operation, but is also pursued in its own right and is a competitive sport. The majority of use occurs downstream of the Lake Coleridge power station. The river system above the Wilberforce confluence is rarely used. Egarr and Egarr developed a five point scale to describe the value of rivers for swimming and boating : insignificant, low, intermediate, high and exceptional value. The Rakaia was assessed as follows: Lower Rakaia Low. Rakaia Gorge High. Upper Rakaia Intermediate. The only comparative jet boater data relates to regional use and boater preference. On both counts the Rakaia is behind the Waimakariri. This is consistent with Egarr's assessment that certain reaches of the Waimakariri are of exceptional value. It is appreciated that loss of jet boating opportunities on the Rakaia could lead to overcrowding on the Waimakariri River. However it was not established that in itself the Rakaia constituted an outstanding jet boating amenity. The Committee noted the value of jet boating to salmon angling, and recorded (p23): Anglers, particularly when standing in the river, do not appreciate jet boats passing close to them. Nonetheless the Rakaia River sustains a high level of recreational use. Except near the river mouth, it is able to do this without loss of satisfaction for its users, primarily because of the river's braided nature. The presence of many braids, and particularly of several major braids on a cross-section, reduces conflict by permitting separation of the recreational activities. This means higher levels of use can be sustained per river length compared with a single channel river. Abstraction during low flows, reduction in river width through say channelisation, or interference with freshes and floods, could reduce the degree of braiding, and hence recreational enjoyment. If the current degree of user satisfaction is to be retained, then loss of braiding may mean lower levels of recreation could be sustained by the river. Applying the RiVAS scoring for the Ngaruroro River in a Canterbury context in Hughey et al (2015) would result in the following output (compared with the top and bottom nationally, regionally and locally significant rivers in Canterbury). The River from Whanawhana to Fernhill rates as nationally significant, largely due to its flow reliability which is weighted by 100%, and is regionally significant from Fernhill to the sea. Lower Ngaruroro River Assessment of recreation significance 27

35 Table 2: Ngaruroro River compared with RiVAS assessment for Canterbury (Hughey et al 2015) Threshold applications (Steps 0, 1-3) Level of use Origin of users Organised Events Quality of experience Flow reliability in peak boating times (e.g., Oct-Mar) Diversity of uses Scenic attractiveness Regulatory considerations Access Weighting River Waimakariri Ngaruroro Reach Poulter to Woodstock (Gorge) Whanawhana to Fernhill High: >2000 jet boater days per annum (score: 3); Medium: jet boater days per annum (score: 2); Low: <500 jet boater days per annum (score: 1) 3= (Internation al), National, Regional and Local; 2 = Regional and Local; 1=Local 3 = International, National, Region. Local and family; 2 = regional, local and family; 1 = local and family; 0= no events 3 = rare, challenging, remote, bucket list, one of a kind; 2 = something a bit special; 1= everyday boating river High: >66% (score: 3); Medium: 33-66% (score: 2); Low: <33% (score: 1) 3= >5; 2= 3-5; 1=<3 High: Very or highly inspiring (score: 3); Medium inspiring (score: 2); Low: Low or little inspiration (score: 1) 3 = no restrictions; 2 = less than 4 months of seasonal limits; 1 = greater than 4<absolute; 0 = no boating allowed Reliable = 3; Unreliable = 1; None = 0 (1 (L=1 or 0); (P=1 or 0); (N=?) Flow*2; Regulation /2 Significance National National Rangitata Upper braided National Rakaia Above Wilberforce confluence Regional Ngaruroro Fernhill to sea Regional Upper Waitaki Rangitata Pukaki - Pukaki dam to Tekapo Junction Clyde & Havelock confluence to top Regional Local Makikihi Local Lower Ngaruroro River Assessment of recreation significance 28

36 The scenic attractiveness scores reflect the assessment of Egarr & Egarr (1981), Egarr et al (1979) and the opinion of the author. Other scores for regulatory controls, flow reliability, events, access, and origin of users are data-based, but have been assessed by the author. Flow reliability for the Ngaruroro River from Whanawhana to Fernhill is based on a suitable flow band of 5 to 50 m 3 /s measured at Fernhill; as identified by the three regular jet boaters discussed below in relation to estimates for levels of jet boating activity. Table 3 shows the data for the period January 1990 to September No account is taken for rapidly rising flows which may prove unusable, or days of bad weather and coincidence with weekends. The high level of apparent flow reliability for all months makes such analysis unnecessary. Flow reliability is weighted 100% in the RiVAS assessment (a score of 3 adds 6 to the total). Table 3: Ngaruroro jet boat flow availability 1990 to 2017 by month Days of data Days <5 cumecs <5 as % Days >50 cumecs Month January % 15 2% 36 4% 1.29 February % 15 2% 37 5% 1.31 March % 22 3% 36 4% 1.29 April % 20 2% 38 5% 1.36 May % 28 3% 35 4% 1.25 June % 29 3% 35 4% 1.25 July 868 0% 47 5% 47 5% 1.68 August 868 0% 44 5% 44 5% 1.57 September % 26 3% 32 4% 1.18 October 837 0% 21 3% 21 3% 0.78 November 810 0% 17 2% 17 2% 0.63 December % 23 3% 27 3% 1.00 Total % 307 3% 405 4% / year >50 as % Total unboatable Total unboatable as % Number of days per month/year unboatable Three local jet boaters have provided independent estimates of use of the River to support this assessment, as well as the boatable flows discussed above: Tom Lowry, Mike Connor and Phil Tither. The former two boaters are self-described as among the most regular jet boaters on the River, while Phil Tither is an occasional user. Their Individual assessments are shown in Tables 4, 5 and 6; ranging between 498 person days to 890. Jet boater days in the RiVAS assessment above are taken from the Jet Boating NZ WCO submission for the Ngaruroro River (>2000 people per annum). If the total count is between 500 and 2000, the total score for the Whanawhana to Fernhill section would drop to 24 (and 23 for a count below 500), but still remains in the nationally significant band (22+). However, with counts below 2000, it is unlikely to be outstanding. Lower Ngaruroro River Assessment of recreation significance 29

37 Period Table 4: Tom Lowry, estimate of jet boater days, lower Ngaruroro River Weeks Boatable weeks Boats/week People / boat People Jan - Mar Apr - Jun Shortest Day event Jul - Sept Oct - Dec Labour Weekend Other Club Days Totals Period Table 5: Mike Connor, estimate of jet boater days, lower Ngaruroro River Weeks Boatable weeks Boats/week People / boat People Jan - Mar Apr - Jun Shortest Day event Jul - Sept Oct - Dec Labour Weekend Other Club Days Totals Period Table 6: Phil Tither, estimate of jet boater days, lower Ngaruroro River Weeks Boatable weeks Boats/week People / boat People Jan - Mar Apr - Jun Shortest Day event Jul - Sept Oct - Dec Labour Weekend Other Club Days Totals Lower Ngaruroro River Assessment of recreation significance 30

38 5.5.1 Rarity of river type Appendix 2 shows an analysis of national river sections by type, giving the total kilometre distance for each type of jet-boatable river setting. All data are taken from the Jet Boating NZ Safety Year Book The results are summarised in Table 7 and Table 8. River classes for jet boating are: Class 1: Easy boating / suitable for beginners / family boating Class 2: More advanced boating / comfortable after one season Class 3: Difficult / adventure / skill required / families not recommended Class 4: Unlikely to be boated / lack of flow / obstructions Data are for only those rivers with an uplift of the 5 knot rule to permit jet boating. Most river sections have multiple descriptives for their particular type in the Jet Boating NZ Year Book, and the one most relevant to defining the class of the relevant river section has been used. For example, the Ngaruroro River from Whanawhana to Fernhill is described as shingle / shallows / braided / trees ; and braided has been used as the key descriptive. This means that the Awakino, Waiohine and Mokau have not been included as having braided sections, although this is one of the terms used to describe them in the Year Book. Shingle sections are similar to braided but generally have only one channel. No allowance is made for the reliability of flow in each river section. The Ngaruroro River from Whanawhana to Fernhill is Class 1 with the descriptive shingle / shallows / braided / trees typecast as braided in this analysis. The River from Fernhill to the sea is Class 1 shingle/ shallows / trees typecast as shingle. The Tukituki River has no uplift for jet boating, and although classed as a braided river by Duncan & Harding (2007) see Figure 6 on page 33 is not described as such in the Year Book, which uses the term shingle. Either way, the Tukituki River is not included in this analysis. The Whanganui River in its lower reaches is also classed by Duncan & Harding (2007) as braided, but is described here as wide to match the Year Book (which also appears to be more accurate). The Tutaekuri River with a similar braided patterns to the Ngaruroro has no uplift for jet boating and is also not included in the assessment (and is described as shingle in the Year Book). Class 1 rivers make up 39% of boatable distance in the North Island (Table 7). Class 1 braided rivers make up 15% of all Class 1 boatable distance in the North Island (115 of 755 km). Braided distances make up 9% of the North Island total (172 of 1944 km). The Ngaruroro River from Whanawhana to Fernhill makes up 32% of all braided Class 1 river in the North Island (37 of 115 km) and 22% of all braided river (37 of 172 km). Analysing any of the river classes by section and type will offer similar results (that is, most class and type subsections are similarly small), although braided river distance is the least represented in the North Island (9%, albeit not dissimilar to meandering at 13% and narrow / gorgy at 15%; and if the latter was subdivided, with gorgy as its own type, gorgy would be the least represented. Rocks / boulders / rapids could similarly be subdivided into smaller subsets). Lower Ngaruroro River Assessment of recreation significance 31

39 Table 7: Kilometres of North Island river class by type Type Class Total Braided Meandering Narrow / gorgy Wide Shingle Rocks / boulders / rapids Total Percent of Classes 39% 38% 20% 3% 100% Table 8: Percent of North Island river class by type Type Class Total Braided 15% 8% 0% 0% 9% Meandering 22% 4% 13% 0% 13% Narrow / gorgy 11% 29% 0% 0% 15% Wide 32% 9% 0% 0% 16% Shingle 20% 19% 6% 0% 16% Rocks / boulders / rapids 0% 31% 81% 100% 31% Total 100% 100% 100% 100% 100% Braided rivers are common nationally, but are largely confined to the South Island as shown in Figure 6. The accompanying text for Figure 6 in Duncan & Harding (2007, p11) reads: The braided reaches of the 163 braided rivers in New Zealand (New Zealand Land Resource Inventory). The locations of the larger rivers from each region have been labelled. Lower Ngaruroro River Assessment of recreation significance 32

40 Figure 6: 163 national braided river reaches in Duncan & Harding (2007) Lower Ngaruroro River Assessment of recreation significance 33

41 Conclusion as to significance for jet boating The Ngaruroro River from Whanawhana to Fernhill is nationally significant for jet boating, considering its popularity, formation, accessibility and reliability. The River from Whanawhana to the sea is regionally significant. It is difficult to clearly describe the Ngaruroro River from Whanawhana to the sea as outstanding since it compares easily to many of the braided river jet boating options in the South Island, many of Figure 7: Upper Rakaia River. Photo: author Figure 8: Ngaruroro River near Whanawhana. Photo: author Lower Ngaruroro River Assessment of recreation significance 34

42 which have more complex braiding patterns and distances and far superior scenery (compare Figure 7 and Figure 8). The Ngaruroro River has no commercial jet boat tourism operators, which would be a useful benchmark. Previous WCO orders such as for the Grey River have relied on features which are rare on an island-basis to suggest outstanding status. However, the braided nature of the Ngaruroro River is not significantly more rare than any other jet boating opportunity in the North Island (and is more common than narrow / gorgy Class 1 rivers). If shingle and braided rivers in the North Island are considered comparable and both can offer the shallow, shingle-bottomed experience described as of value in the Jet Boating NZ submission to the WCO, then 35% of the Class 1 river distance in the North Island offers the same opportunity, and is one of the most common jet boating options. The Ngaruroro River from Whanawhana to the sea is described by Jet Boating NZ in its submission as being used by more than 2000 jet boaters annually, including passengers; which although low by outstanding standards (compared, for example, with the Rakaia at 15,000 recreational users and 7500 commercial), is most likely high by North Island standards for which we have no comparable data. The figure of more than 2000 annual users is challenged by the three very regular jet boaters consulted for this report, who estimate a range of 498 to 890 jet boater days. As stated in section 2 of this report, Harper (2017) concluded that: And Jet boating, caving, canoeing, kayaking and rafting have been specifically recognised as outstanding and subsequently protected under a number of WCOs. As such, all are identified as key sub-values which have the ability to be outstanding in their own right. The preliminary findings from the WCO review on this value set show that in order to qualify as outstanding for boating, the waterbody must be reliable/predictable for the activity under normal flows, and meet at least one of the following criteria: have participation rates which are significantly higher than anywhere else in the country, non local usage of 20% or more, contains a unique/rare characteristic shared by few other rivers in New Zealand, additionally, waterbodies identified in WCO decisions as being outstanding for boating activities also typically provide a highly scenic and/or wilderness experience. Water Conservation Order decisions are clear that where sufficient data about a particular value of a water body is not available, then the value is not outstanding until the appropriate evidence is provided. There are no patronage data beyond the estimate in the Jet Boating NZ WCO application, and this cannot be considered robust. The Ngaruroro River below Whanawhana is neither highly scenic (on a comparative basis) nor a wilderness setting. The braided river characteristic is shared by many other rivers nationally. The River between Whanawhana and Fernhill is likely to have more than 20% of its patronage from outside the Hawke s Bay due to its accessibility, reliability and formation. Its level of patronage if at 2000 would not be significantly higher than anywhere else in the country, but would most likely be very high for the North Island. In the opinion of the author, the Ngaruroro River from Whanawhana to Fernhill could be considered outstanding for jet boating if the level of use exceeds 2000 annually, but not otherwise. This figure is the cut-off in the Canterbury RiVAS assessment (Hughey et al 2015) for a top score (3) for level of use. Currently there are no reliable data to establish this. Lower Ngaruroro River Assessment of recreation significance 35

43 5.6 Whitebaiting The HBRC has provided whitebait stand permit data for all rivers in the Hawke s Bay with registered stands. There is no stand-specific locational data. There is also no data on scoop netting at river mouths, although it occurs in the coastal marine area (CMA) and would not subject to WCO consideration as a recreation activity. Table 9 provides a summary of existing permits at 2017 and those which have expired since Most whitebaiting activity on the Ngaruroro River occurs in the CMA, but stands extend up to 500 metres downstream of the Chesterhope Bridge (Vincent Byrne, HBRC, pers comm). There has been no application to protect whitebaiting via the WCO proposal. The Ngaruroro River has the second-most number of existing permits for stands in the regional after the Tukituki River, and a higher level of churn with more expired stands. While this assessment is quite a blunt instrument: if the Ngaruroro River is not the most popular whitebaiting river in the region, it is highly unlikely to be outstanding at the national level. The Ngaruroro River below Chesterhope Bridge is also highly modified and has very poor natural character for whitebaiting (Figure 9). Table 9: Existing and expired whitebait stand permits by river HBRC data River Existing permits Expired permits Clive Ngaruroro Tukituki Tutaekuri Total Figure 9: Ngaruroro River whitebait stands upstream of SH2. Photo: author Lower Ngaruroro River Assessment of recreation significance 36