Dr Ian Lochhead has generously supplied us with the text of the IConIC submission.

"While it is so self evident that it scarcely deserves comment, the release for consultation of a draft Heritage Building and Places Recovery Programme for Greater Christchurch (HBPRP) over three years after the September 2010 earthquake and nearly three years after the February 2011 quake, is woefully inadequate."

The text of the submission is as follows:

Submission from IConIC on
Draft Heritage Building and Places Recovery Programme for Greater Christchurch

1. Introduction:
IConIC (Interests in Conserving the Identity of Christchurch) represents a diverse group of building owners, developers, inner city tenants as well as a range of heritage interests who recognise the essential role of the recovery of the inner city and its restoration as a vibrant place of economic, social, cultural and public life to the overall recovery of Christchurch.

2. While it is so self evident that it scarcely deserves comment, the release for consultation of a draft Heritage Building and Places Recovery Programme for Greater Christchurch (HBPRP) over three years after the September 2010 earthquake and nearly three years after the February 2011 quake, is woefully inadequate. The CERA Draft Recovery Plan indicated that a Scope of the Heritage Recovery Plan would be delivered to the Minister for Earthquake Recovery during October 2011. This target does not appear to have been met and a draft document was only released for limited consultation in mid 2012. In spite of the Minister of Culture and Heritage announcing on national television that the document would be released for consultation in September 2013, it did not appear for another three months.

3. In the face of the greatest destruction of heritage from a single event in New Zealand’s history, this delay is utterly inexcusable and calls into question the commitment of Government to the protection of the nation’s built heritage. Had an effective Heritage Recovery Plan, incorporating a much more rigorous process and clear criteria for decision making with the regard to heritage demolitions, been implemented in a more timely fashion it is likely that many more heritage buildings in greater Christchurch would already be making a significant contribution the recovery as a whole. (See paragraph 12 below)

4. For a nation that aspires to first world status and which consistently benchmarks its performance against the upper echelon of OECD nations such a failure to meet reasonable, publicly-signaled, performance outcomes is a matter for embarrassment if not shame.

5. It is also a matter of concern that immediately following the disaster of 22 February 2011 offers of assistance from international organisations and consultancies, including Blue Shield, Donald Insall and Associates, a leading UK-based heritage consultancy and Miyamoto International, a multinational seismic engineering consultancy with expertise in heritage recovery, were either rejected or simply ignored. Such behavior also suggests a government that does not value the nation’s built heritage.

6. This impression is further signaled by the downgrading of the initially proposed

Recovery Plan for Heritage Buildings and Cultural Heritage Places (‘Heritage Recovery Plan’) and a Heritage Recovery Programme to the current Heritage Building and Places Recovery Programme, a programme furthermore, that is not binding on any of the listed parties.

7. It is also a matter for concern that there is no frank acknowledgement of the magnitude of the heritage destruction that has occurred in greater Christchurch. The HBPRP under- represents the number of heritage sites that have been destroyed, providing a total loss of 200 across the region. The Historic Places Canterbury website http://canterburyearthquakedemolist.weebly.com/ currently lists 235 demolitions to date, only a small number of which have occurred since the release of the HBPRP. The document should not only correctly report demolitions, but also should include a comprehensive demolition list as an appendix, and list those sites subject to CCDU plan designation that will potentially lead to their demolition.

8. These concerns are particularly troubling when placed against New Zealand’s legislative record in heritage protection. The Canterbury Provincial Buildings Protection Act 1928 was the first legislation to protect built heritage in this country. (It is worth noting that full statutory protection was only accorded to Stonehenge in the United Kingdom when it was acquired by the Crown in 1918.) The Historic Places Act, 1953 introduced the registration of heritage sites, and this process was extended to territorial authorities through the Resource Management Act, 1991, under which local authorities were required to introduce mechanisms for the protection of heritage in district plans. A further degree of protection was introduced with the 2003 amendment to the RMA that made ‘the protection of historic heritage from inappropriate subdivision, use, and development’ a matter of national importance under s.6.

9. Given the legislative provision for and protection associated with the listing of historic heritage, and the resources devoted to registration at national level and listing at local level, it seems incomprehensible that the protection of heritage was effectively set aside by the CER Act, 2011. If heritage listings are not given weight when heritage is at greatest risk of destruction as the result of natural disasters, what is the value of devoting resources to such listings in the first place?

10. Government funding for heritage recovery is incompletely addressed in the HBPRP. While the Government contribution of $10 million assistance for heritage recovery is correctly stated, it is not recorded that this funding was conditional upon the Government contribution being met on a dollar-for-dollar by private donations. While such an approach might be appropriate for a specific project in normal circumstances in order to gauge the level of public support, such a policy is totally inappropriate in a post-disaster recovery environment, where destruction is spread across multiple sites and where many of those who would normally contribute to a specific appeal are facing widespread disruption and uncertainty in their personal lives, loss of income through changing employment opportunities, threats to their assets and disruption to their business operations. In comparison with the generous and unconditional grants made to other sectors, such as sport, the Government contribution to built heritage seems parsimonious at best and verges on being discriminatory. It should also be noted in the HBPRP that central and local government heritage properties do not qualify for assistance from this fund. Given that the Christchurch City Council is a major owner of heritage properties, including a former Crown asset, the Canterbury Provincial Government Buildings, the HBPRP represents the Crown’s funding of heritage recovery in a misleadingly positive light. It should be further recorded that the Government’s contribution of $10 million was made following the September 2010 earthquake and was not increased following the much more widespread destruction of heritage in February 2011.

11. Consideration should be given to providing the Canterbury Earthquake Heritage Conservation Trust with the resources it needs to perform its function effectively. Had the Trust been provided with a core professional staff from the outset, including an executive director and fundraiser, it could have generated additional income and been more proactive in providing assistance. There have been too many instances of building owners proceeding to demolish because of cost concerns without any knowledge of the potential funding

available from the Trust.

12. There is an implicit assumption throughout the HBPRP document that heritage preservation constitutes a potential impediment to the wider recovery (‘a roadblock to recovery’). Both the CER Act and the HBPRP make heritage recovery subservient to the interests of the recovery as a whole. Final decision making on heritage demolitions rests with the CEO of CERA and s.38 of the CER Act allows for heritage demolitions to occur ‘to assist recovery’ even when buildings do not present a danger to the public. There is no appeal or review process for such decisions. While such a process may have been appropriate in the immediate post-disaster phase of the recovery such provisions are no linger credible given the extent of building demolitions generally in the Christchurch CBD. While there has, in recent weeks been a more considered approach to heritage demolitions apparent from CERA it is our view that the current process has long since outlived its usefulness and it is recommended that future decision making on heritage buildings should revert to the relevant territorial authority and be conducted through the existing RMA process.

13. It needs to be recognised in the HBPRP that heritage buildings, far from being a roadblock to recovery, have led economic recovery in many areas of the Christchurch CBD. Heritage buildings have been at the forefront of the revival of commercial activity in the CBD through the provision of permanent accommodation for on-going business activity. These buildings include the former High Street Post Office, the New Regent Street precinct, the Heritage Hotel, Bonnington’s building in High Street and the former Registry of the Arts Centre. The reconstructed Theatre Royal will open towards the end of 2014. With a different recovery model in place other heritage buildings, including the former Majestic Theatre and Duncan’s buildings in lower High Street could equally be contributing to the recovery. The owners of these buildings were planning to strengthen and restore their buildings, but compulsory purchase by CERA in the case of the Majestic and indecision over the Innovation Precinct have prevented this from occurring. Outcomes in Section 3 of the HBPRP should also include the fact that restored heritage buildings provide appropriate accommodation for business at a lower rental cost than can be provided by new buildings, thereby adding to the economic vitality and commercial variety of the city. They also add to the range of accommodation options available to visitors.

14. Far from presenting a roadblock to recovery it is becoming apparent that the

indiscriminate destruction of heritage and character buildings, including seismically strengthened heritage buildings, will itself present a roadblock to recovery. By removing building stock that could have been repaired and strengthened and brought back to use much more quickly and at a lower cost than new buildings, the city has lost the capacity to develop a diversity of tenancies for small business in the CBD at lower rentals than in new buildings. It is already apparent that the rental structures for new buildings in the CBD will be at a level that only ‘high end’ retail and businesses can afford. This will restrict the range of business operations within the CBD and exclude the small businesses (start-ups, small boutiques, hairdressers, shoe repairs, independent bookshops and so on) that give variety and vitality and provide essential services in central city environments. Greater attention to retention of heritage would have avoided such a rental monoculture in the Christchurch CBD.

15. It is important that the programme includes as an appendix a list of all registered and listed heritage buildings whose future remains in doubt, including those currently under designation in the CCDU ‘Blueprint’. These include the Majestic Theatre, the former St James (Odeon) Theatre, the Lawrie and Wilson building and the Longden and Le Cren store (Pegasus Arms). It is essential that the plan recognises the threat posed to these buildings and identifies strategies that will mitigate these threats.

16. Section 3 Outcome 5 advocates the reuse of heritage fragments in new structures. Such a programme is fraught with difficulties and the HBPRP provides no policies or guidance as to how successful outcomes can be achieved. While the retention of complete facades and their reconnection to new structures is supported as a means of retaining memory and creating diverse and interesting streetscapes, the incorporation of heritage fragments into new structures that are dissimilar in scale, form and materials to the original building from which the heritage fragment is derived runs the risk of creating heritage ‘bling’ at best and at worst, architectural kitsch. At the very least the HBPRP should provide examples of both good and bad practice in the reuse of heritage fragments. Note should also be taken of repetition and redundancy of information between Project 3 (pp. 20-21) and Project 8 (p.29).

17. Canterbury churches collectively contained the most extensive collection of Victorian stained glass in New Zealand, much of it of exceptional quality. Following both the 2010 and 2011 earthquakes much of this stained glass was recovered from churches and some secular buildings. While stained glass may fall under the category of recovered heritage

elements in terms of the programme it constitutes such a large and specialised category of recovered heritage that it deserves specific identification and attention. Many of the churches from which glass was recovered have been demolished and reinstallation of stained glass made for one location into another structure, even if it is of a similar era, will present challenges of adaptation. This will potentially involve adaptation of the glass forming a window or modifications to the window openings in the building that is to receive the recovered glass. There is a need for policy to be developed to guide this process, as well as policies that reflect the commemorative nature of much of this stained glass heritage. In particular protocols need to be developed to ensure consultation occurs with the descendants of those who are commemorated as well as with the donors of windows.

18. Because of the extensive destruction of architectural heritage in Christchurch an additional project should be adopted in the programme, (or incorporated into Project 8) specifically the creation of a Museum of Canterbury Architecture. This would allow the story of Christchurch architecture to be told through photographs, architectural drawings and models but also, and uniquely in New Zealand, through the incorporation of recovered architectural fragments into museum displays. This would allow the history of traditional building crafts, which have been almost completely erased from the CBD, to be recovered and interpreted in the context of displays organised around recovered examples. Such a museum could also house displays of artefacts recovered through archaeological investigations.

19. Mothballing of heritage buildings is a recovery strategy that should be identified within the document. Making buildings both safe and weather tight to allow them to remain in an unrestored condition until such time that technical or economic solutions can be found to allow for their recovery is a well-tried strategy and has been adopted for the Provincial Council Buildings and, to a less comprehensive degree, with the Cathedral of the Blessed Sacrament. This process should be identified as a strategy that can be adopted by other building owners to ensure that hasty demolitions do not occur and to prevent on-going deterioration of the fabric of damaged buildings due to exposure to the elements.

20. The absence of all mention to Christ Church Anglican Cathedral in the HBPRP, except for references in the historical overview in Appendix Two, seems inexplicable. This is the city’s most recognised heritage structure, both nationally and internationally and has been the focus of extensive attention in the media, as well as contention in the courts. The

building has stood with its west end exposed to the elements for over three years. This is manifestly a building that would benefit from protective measures to minimise deterioration to its fabric as well as its contents while its future is resolved. Failure to discuss the city’s most prominent heritage building is a manifest failure of the document in its current form.

21. It is a matter of concern that the HBPRP contains no mention of the principles guiding heritage conservation practice, notably the New Zealand ICOMOS Charter 2010. This omission should be rectified and the charter should be included as an appendix.

22. The HBPRP recognises the potential of the unparalleled opportunities of new building producing heritage of the future. This assumption is presumably based upon the experience of Napier, where reconstruction occurred in a period of little more than three years in a fashionable but ephemeral architectural style and the subsequent promotion of Napier as a tourist destination based on its ‘Art Deco’ heritage. It should equally be recognised that the rebuild of Christchurch has the potential to follow the example of the reconstruction of the City of London and other British towns following destruction during World War II. Much of this reconstruction proved disastrous in urban design terms and has been subsequently replaced. It also needs to be recognised that in the time it has taken for the HBPRP to be produced, Napier had been rebuilt. Further, the reconstruction of the CBD of New Zealand’s second largest city is more complex and demanding, and will be a much more protracted task than the rebuilding of a provincial town in the 1930s. The probability of a unified aesthetic, which is the principal attraction of the rebuilt Napier, is much less likely in Christchurch. While it is undeniable that some buildings resulting from the Christchurch rebuild will be regarded by future generations as heritage, this will be the result of values ascribed to those buildings by the society of that time, and should not be a concern of the HBPRP .

23. It is a matter of concern that the HBPRP will become a template for the management of heritage following future natural disasters New Zealand. Given that much of this document is reportage of what has occurred following the Christchurch earthquakes, rather than a robust process for (a) identifying heritage at risk (b) mitigating those risks wherever possible and (c) identifying the value of heritage to the community, this would be most regrettable. Post earthquake management of heritage following the Christchurch earthquakes has manifestly fallen well short of international best practice and it should not be seen in any way as a precedent for managing heritage in any future natural disaster. MCH needs to

analyse the failure to adequately manage heritage following the Christchurch earthquakes, including the absence of a recovery plan template for built heritage, in order to develop such a template that can be implemented in the immediate aftermath of any future natural disaster.

24. One of the fundamental shortcomings of heritage recovery in Christchurch has been the total failure to recognize the distinctive and unique architectural character of the Victorian city as a whole. The bland historical overview provided as Appendix 2 makes only passing mention of the city’s Gothic Revival buildings, and fails to recognise Christchurch’s status as probably the most complete Gothic Revival city in the world prior to February 2011. Almost all the city’s major 19th- century public and ecclesiastical buildings were in the Gothic Revival style and, with the notable exception of the Law Courts, all the city’s founding educational, cultural and governmental buildings had survived into the 21st century. A credible nomination for the inclusion of the city’s Gothic Revival heritage buildings on New Zealand’s World Heritage Tentative List was made by the Canterbury Branch Committee of the New Zealand Historic Places Trust in 2006 and this document is provided as Appendix A. In the context of this unique collection of buildings the loss of even one exemplary heritage structure diminishes the whole.

25. Passing mention is also made in Appendix 2 of the post World War II architecture of the Christchurch School, an aspect of the New Zealand manifestation of architectural modernism that was recognised both nationally and internationally as significant regional development of 20th century architecture. A very high proportion of this architecture in the CBD has now been destroyed with no consideration of its possible heritage value because only the most prominent examples of this era had been registered or listed. At the time of the earthquakes listing of modern heritage was under review and this should have been taken into account in decision making over demolitions. The HBPRP fails to address the problem of buildings not currently registered or listed but which will almost certainly be listed in future reviews of heritage. It is a matter of urgency to identify surviving examples of Christchurch School architecture within the CBD as well as elsewhere, including the campus of Canterbury University, to ensure that these now scarce examples are strengthened and restored to a standard commensurate with their heritage value, rather than having their value as future heritage compromised through unsympathetic modification.

26. Project 4, Ensuring that District Plan Regulation assists recovery, is supported but

should be broadened to facilitate new heritage listings that result from the comprehensive revaluation of heritage that now needs to occur. District plan heritage lists need to be reviewed in the light of heritage losses. Buildings that might not have been considered for listing prior to the earthquakes have now become rare or unique examples of particular building types. Other listed buildings with comparatively low rankings may now be worthy of higher listing status. The CCC had also initiated a process for new heritage listings prior to the earthquakes but this had to be suspended. In order to ensure that buildings worthy of heritage listing are not demolished or unsympathetically modified in the period preceding implementation of new district plans, a mechanism of interim heritage listing should be investigated, potentially utilising the powers of the CER Act.

27. The CCC was moving towards a review of District Plan heritage provisions prior to the earthquakes and these had strong support within the heritage community. It is important that heritage provision in the new district plan are not watered down on the pretext that heritage retention represents a roadblock to recovery. As pointed out in paragraphs 13 and 14 above, heritage buildings make an economic as well as a cultural contribution to the vitality of cities that new buildings will not provide.

28. While we do not wish to undervalue the excellent work being carried out by CEISMIC in documenting the Canterbury earthquakes and collating digital records of lost buildings, neither this programme nor the High Street Stories programme of the NZHPT can be considered a substitute for the loss of built heritage. The particular value of built heritage is its physical presence and materiality, offering an experience of scale, texture, form and space that cannot be replicated by any other means.

29. Since the HBPRP mentions CEISMIC and similar resources it should also include mention of the University of Canterbury’s Architectural Archives that incorporates over 100,000 architectural drawings, the great majority of which relate to Christchurch and Canterbury buildings. As a repository of records of the built memory of the city this collection is un-paralleled.

30. IConIC applauds the outstanding contributions to heritage recovery being made by public and private bodies such as the Arts Centre of Christchurch Trust Board, the Christchurch City Council, through its programme of restoring its heritage assets, and those businesses and individual building owners who have restored or are restoring their heritage

buildings. It also recognises the contributions made by the staff of the New Zealand Historic Places Trust Southern Regional office and the heritage team of the CCC to the recovery. However we are disappointed that the HBPRP does not go further in offering greater support to all those who have made such tremendous efforts to ensure that as much of Christchurch’s built heritage as possible survives to enrich the lives of the region’s inhabitants and support the economic vitality of Canterbury. The draft document adopts a stance of complacency that assumes that what has been achieved in terms of heritage recovery is as much as could have been expected. IConIC is of the view that not only could much more have been done, but had the recovery of heritage been handled differently the recovery as a whole would be much further advanced.

Contact person:

Dr Ian Lochhead
Associate Professor of Architectural History University of Canterbury
Chairperson, IConIC