WHATEVER HAPPENED TO OUR BESPOKE PLAN?

Kia ora koutou,

Combined Residents’ Associations, Christchurch is calling on all city councillors to resist pressure to accept entirely the recommendations of the Independent Hearings Panel (IHP) on Plan Change 14 (Housing Intensification), to help ensure this controversial plan change is the best it can be for our city.

While we support much of what is proposed in PC14 plan, the IHP has rejected most of the social and environmental enhancements put forward to make the plan bespoke for Christchurch.

Remember how we all fought for those changes when the city council voted down the original PC14, almost two years ago?

Elements of PC14 rejected by the IHP (for various reasons) include Sunlight Access Protection; Financial Contributions for Tree Canopy Cover; Riccarton Bush Interface; New Heritage items; Residential Heritage Areas and Heritage Interfaces; New Residential Character Areas; Significant Trees Protection; the Low Public Transport Accessibility Area and the City Spine Transport Corridor. All of these had merit and, to some extent the IHP agreed, but still rejected them.

On top of that, there are other issues that need to be addressed, like fair and reasonable walkable catchment sizes, and the need to ensure infrastructure is sufficient to support new intensive developments.

The deadline for your decision-making is September 4th which seems too little time to adequately consider what to accept and reject. We in the process of seeking clarifications and analysing the potential impacts of the recommendations and views may change but at this stage here are our suggestions.

We know, from questions you have asked council staff already, many of these are already being considered.

1. Sunlight Access Protection
   You proposed sunlight access protection to ensure residents living in densified areas would not be deprived of sunlight because of our climate or geographical location. The IHP rejected that proposal, not in principle, but seemingly as a result of process, not acknowledging the obvious impacts of latitude across New Zealand. We urge you, for the health of all residents, to do whatever you can to ensure sunlight is preserved in areas earmarked for intensification, on at least equitable terms with what Aucklanders enjoy.
2. Walkable Catchments
   The IHP has defined so-called walkable catchments outside the centres of commercial areas, where high-density (4-storey and taller) development will be permitted as of right. These walkable catchments are supposed to be small enough to enable residents to walk easily to and from the closest shops and other facilities. This is not the case. The IHP has recommended 800 metres as a baseline distance around larger town centres, but actual walking distances of twice that and more (Riccarton is one example) have been mapped. That’s a 30 minute walk each way, a totally unreasonable task with small children or carrying shopping bags. 
   The catchment in the central city is also well outside walkable distances to amenities. All this information was provided to the IHP by various submitters but appears to have been ignored. We ask you to review the baseline distances and reject the extended catchment areas to ensure actual walking distances and walking times are reasonable and manageable for the majority of residents living in these areas.
3. Financial Contributions (from Developers) for Tree Canopy Cover
   Surely this is a no-brainer. It received widespread community support when the city council consulted on this prior to IHP process, but the panel appears to have totally bought into developers’ and Kainga Ora's opposition to it. Again, please review the evidence. Huge areas of our city are almost devoid of tree canopy cover and, compared to other large cities around the motu our overall level of tree cover is abysmal. This needs to be addressed.
4. The City Spine
   You wanted increased setbacks along major transport routes but this Qualifying Matter was rejected by the IHP. It made sense, providing space for future mass transit should that ever be planned for and funded in the future. We suggest you reject the recommendation and take time to look at ways the proposal might be re-introduced, as a strong signal that we are committed to supporting our future focus on a vibrant and growing city.
5. Infrastructure Funding
   It is clear, in some areas, our city cannot support increased density without considerable added infrastructure investment and subsequent increased costs for ratepayers. We need you to support the proposed IHP advice notice to prevent intensification in areas where there is insufficient infrastructure to support it; or alternatively, ensure developers pay for infrastructure upgrades to support their proposals before the developments are approved and completed.
6. Riccarton Bush
   The residential area around the perimeter of Riccarton Bush / Pūtaringamotu is proposed for 3 and 4 storey buildings, twice the current heights. Riccarton Bush is the oldest protected natural ngahere in the country with 600-year-old kahikatea, the latest generation of a forest that established itself on the plains during the bronze age, more than 3000 years ago. You proposed a simple protective zone around the bush where heights and density would be limited. This was rejected by the IHP. Look back at the evidence and ensure this interface zone is reinstated to preserve everyone's views, vistas and aspects of Riccarton Bush.
7. Medium Density Standards
   The IHP recommends widespread introduction of medium density (3-storey) housing intensification (MDRS) across most of our city and suburbs. The new government’s written policy is to make this optional provided overall housing capacity targets are met, which they have been already. Therefore, you can (and should) reject the IHP recommendation, giving time to properly consider if and where medium density development is needed.

Finally, it is worth noting the PC14 IHP aligned all its recommendations to 2021 intensification legislation, as it was required to do, but the current government has produced and adopted a new Going for Housing Growth Policy. This will remove the need for increased intensification, given Christchurch already has adequate capacity for housing growth and no plans for rapid transit for decades. Christchurch residents, developers, and land owners need to be made aware new policy might mean yet another plan change (Plan Change XX) in 2025 or 2026.

All the groups below support this letter, and more may join as the people of Christchurch slowly come to realise how much better this plan change could and should be.

Nāku iti noa nā

Addington Neighbourhood Association

Central Riccarton Residents’ Association

Central Riccarton Residents’ Association

Charleston Neighbourhood Association

Chester St East & Surrounds Residents Group

Christchurch Civic Trust

Deans Avenue Precinct Society

Englefield Residents Association

Greater Hornby Residents’ Association

Gwynfa Avenue Residents’ Association

Halswell Residents Association Secretary

Inner City West Neighbourhood Association (ICON)

Moa Neighbourhood Group

Redcliffs Residents' Association

Riccarton Bush-Kilmarnock Residents’ Association

Somerfield Residents Association

Spreydon Neighbourhood Network

Victoria Neighbourhood Association

Westmorland Residents’ Association

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