The question of who is included, or who is excluded, from environmental governance arrangements is at the heart of debates of institutional legitimacy. The recent redefinition of representation as a claim to ?speak for? another provides an opportunity to re-examine the inclusiveness of environmental governance arrangements. This article builds on these developments by empirically evaluating the inclusiveness of three representative claims embedded in freshwater governance in Canterbury since 2002. The contribution argues that accounts of environmental governance must consider implicit forms of representation that can exclude or marginalise and raises some caveats relating to expansion of network governance.