Submission on A Liveable City on behalf of Historic Places Canterbury (HPC)
HPC generally supports the visions for a Liveable City as set out in the draft document. However we feel that there is a serious disconnect between the vision which has been articulated and the changes to the rules of the City Plan by which the vision is intended to be achieved.
HPC wishes to oppose the following aspects of the Liveable City plan Changes:
The imposition of a single uniform height
The removal of all Special Amenity Areas
The removal of all notified consents
The removal of urban design assessment
It is claimed that existing Living Zones in the District Plan result in “an unduly and unnecessarily complex planning environment” and hence the zone has been reduced to one overall height limit and set of controls. The existing plan was drawn up to recognise the character of a variety of distinctive neighbourhoods within the city. The outcome of the proposed changes may well suit developers but is likely to result in a bland monotony, a lack of diversity of neighbourhoods and a serious loss of character for some of Christchurch's distinctive early neighbourhoods. The proposed changes place touching faith in the market providing quality housing but even with the controls in place under the current city plan, the general quality of medium density developments within the city provides little evidence to suggest that the quality of the urban environment weighs heavily on the mind of developers. The market may well provide the size of dwellings people want and the sorts of conveniences people desire in their homes but all too often in the past multi-unit dwellings have ridden rough-shod over the amenity of existing inner city dwellers. It is notable that in the explanation for the changes, the reasons given are to balance the needs of developers for flexibility and to give certainty about amenity to the extent that potential residents will have the confidence to move into the area. Concern about the impact on the amenity of existing neighbourhoods does not rate a mention. The rules as drawn up may well be satisfactory for the blank slate area of the east frame but the one size fits all approach of the plan completely fails to take into account or provide any protection for the quality and character of existing neighbourhoods.
HPC supports some simplification of height limits and considers that the proposed height of 14 metres is generally satisfactory However, we are strongly opposed to raising the existing 8 metre height restrictions to 14 metres. These have been put in place in areas which contain strong heritage character ( for example the area from Worcester Boulevard to Kilmore Street which includes Cramner Square and faces onto key heritage sites: The Arts Centre, the Museum and Christ's College) Other existing 8 metre restricted areas have been defined around neighbourhoods which still retain many character buildings but also have narrow streets where a 14 metre height would be overwhelming and destroy the amenity of existing properties. Defining two sets of height limit clearly on a map does not create unnecessary complexity but would go a long way towards helping protect the amenity of those areas.
Special Amenity Areas
HPC feels strongly that the 6 Special Amenity Areas which were identified as still having value by the Council in consultation with local residents should be retained along with the streamlined and consolidated rules proposed for them. We do not believe that the special qualities that these areas were designed to protect can be dealt with adequately by a set back provision.
Removal of notified consents
HPC opposes this change. The removal of the rights of neighbouring owners to be notified when a development proposal breaches the standards set in the plan is a fundamental attack on the the philosophy of the Resource Management Act . As well as breaching the rights of existing inner city residents this provision is unlikely to give prospective urban dwellers “certainty about amenity to the extent that [they] will have the confidence to move into the area.”
Where breaches are minor or the developer has had regard to the amenity of the neighbours, their written consent should be easy enough to obtain. In the rare case of purely vexatious neighbours, the Council would still have the power to issue a consent.
It is noted that 4a 2.3 (building height), 4a 2.5 (Sunlight and outlook for neighbours, 4a 2.6 (Streetscene and accessways) and 4a 2.7 (Separation from neighbours) all recognise economic justifications for allowing a non-complying consent ( e.g.efficient, cost effective use of a site) While Historic Places Canterbury recognises that this could in some cases allow for an overall better design or arise from the need to protect listed trees, there is an equal likelihood that it could place pressure on the Council to grant a non-complying consent simply because it suits the economic needs of the developer. This danger makes it all the more important that neigbours should be notified.
Removal of the Urban Design Standards
This standard is proposed to be removed in order to increase the attractiveness of the central city for residential development. It is expected that the market will demand the high quality residential housing that will help make central Christchurch an attractive place to live. As noted above, there is little evidence from existing multi-unit developments that the market will reliably deliver attractive, high quality residential housing. Urban design assessment should be compulsory where any development is adjacent to or opposite listed heritage buildings. Urban design assessment should be discretionary whenever a developer proposes a non-complying development (unless the notification provisions are changed and neighbouring owners have given written consent). In the case of medium or high density developments (3 or more units) the Council should also have a discretion to require oversight by a design panel. If a development is indeed of high quality and has adequate regard for the amenity of the area it is located in then developers should have little to fear from such a provision but in other cases approval of an urban design panel has the potential to raise the level of amenity provided by developments. Poor urban design can have very long lasting effects. Short of the sort of catastrophic changes wrought by a disaster such as the earthquake, poor urban design can be very difficult to remedy once it has occurred. Although HPC favours greater flexibility for development to meet changing needs and to allow for creative design solutions which rigid planning controls can inhibit, we believe that allowing urban design overview needs to be a concomitant of allowing for greater flexibility in the rules.
We note also that removal of the urban design provisions of the existing plan is inconsistent with Chapter 6 of the Canterbury Regional Council Regional Policy Statement which was included in the Regional Plan by the direction of the Minister of Earthquake Recovery.
Issue 6.1.4 – Amenity and urban design
While the speed of recovery is important, so too is the quality of the built form. Poorly designed development can adversely affect urban amenity values, rural amenity values, historic heritage, health and safety, integration with community, educational, social and commercial facilities, and overall liveability. These matters are important for retaining population and attracting skilled workers and new business opportunities. They will affect the timing and the success of recovery.
Sometimes the desire to rebuild quickly competes with the desire to build well or build back better. Enabling timely and appropriate development during the recovery period in a manner that does not compromise the key values of either existing or future communities is a challenge that must be recognised at Greater Christchurch, city, district and neighbourhood levels. Rebuilding can also impact on issues of significance to Ngāi Tahu, affecting their relationship with ancestral lands, water, sites, wāhi tapu and other taonga. In particular, good urban design will contribute to vibrant and renewed centres and help support wider wellbeing objectives such as quality of life, economic vitality and crime reduction.
Furthermore, the City Council's Plan change 53, which was introduced following proper Resource Management processes and was developed as a consequence of the shortcomings of the City Plan in dealing with urban design issues, should not be set aside lightly because of fears that it might cause delays. The need for urban design assessment is widely recognised throughout the country. The benefits of good urban design well and truly outweigh any slight delay that such rules might cause and the existence of design review provision provides developers with an incentive to pay attention to good design from the outset. As previously noted, the failure to ensure good design will have lasting consequences long beyond the short term need to boost the population of the inner city.
It would be good to see provisions in the draft residential chapter which encourage green building practices. HPC understands that the Council, in its District Plan Review, is proposing to introduce environmental performance standards for new homes and to include the ability for homes to be adapted for different life stages. It may be that if such changes are introduced they will also apply to the central city living zone. If that is not the case there will be a significant discrepancy in standards between this area and other residential areas of the city. The draft should be amended to ensure that any such changes introduced by the Council will also apply to the central city living zone. It would be undesirable to have a lesser standard in the inner city and this would work against the goal of the Recovery Plan to deliver a more sustainable city.