Tag: Text of Submission

Ministry for the Environment Manatū Mō Te Taiao

“Comprehensive review of the resource management system – preliminary questions for initial stakeholder engagement” HPA Submission

The following is the text of the Historic Places Submission:

Dear Review Panel

This submission is made by Historic Places Aotearoa (HPA) which welcomes the opportunity to comment on the issues and options paper relating to the RMA review.
The reasons for making this submission are that HPA promotes the preservation of historic places in Aotearoa New Zealand. HPA also has an interest in promoting the education of the public in the appreciation of heritage values. HPA is a key stakeholder in 
the consultation process and answerable to its affiliated regional societies and affiliated membership.

HPA makes the following two main points. Firstly, we do not wish to see the existing (fairly weak) support for built and other heritage in the RMA further weakened. While heritage is identified as a matter of national significance, in practice the general provision often falls short for actual protection in specific cases. In the last three years, for example, 3 Category 1 Heritage New Zealand listed buildings either have already been demolished or are in the process of being demolished. These are Aniwaniwa (Visitors Center Lake Waikaremoana), Erskin College main block Wellington, and the former teachers college at Karori Wellington.

Countless category 2 buildings have been demolished all around Aotearoa. Councils are generally under resourced to support property owners who are willing to repair substandard heritage buildings. In other cases, owners target heritage buildings as a cheap option for demolition and development. 

HPA supports efforts to make good use of urban space for much needed additional housing etc, but not at the further expense of retaining heritage buildings. 

Secondly, HPA supports the idea to introduce a mechanism for Councils to use spacial planning as a way of directing development into suitable specified areas, and thus provide clearer signals about where development and intensification would be welcome while identifying heritage areas where that is not suitable. 

Yours sincerely

President Historic Places Aotearoa              

HPA “Submission on NATIONAL POLICY STATEMENT – URBAN DEVELOPMENT” ( Ministry for the Environment Manatū Mō Te Taiao


The following is the text of the Historic Places Aotearoa Submission:

Submission on


This submission is made by Historic Places Aotearoa Inc. (HPA) which welcomes the opportunity to comment on the proposed National Policy Statement on Urban Development (NPS-UD).

The reasons for making this submission are that HPA promotes the preservation of historic places in Aotearoa New Zealand. HPA also has an interest to promote the education of the public in the appreciation of heritage values. HPA is a key stakeholder in the consultation process and answerable to its affiliated regional societies and associated membership.

HPA has reviewed the NPS-UD and considered the impact the proposed statement will make with respect to this countries heritage buildings.

HPA has a particular interest in the subject of this NPS-UD, as it has the potential to dramatically change the distinctive heritage character of sections of New Zealand cities and towns.


“Heritage Buildings and Sites Reference Group” Historic Places Canterbury Public Forum Submission to The Social, Community Development and Housing Committee Christchurch City Council

Historic Places Canterbury Public Forum Submission to

The Social, Community Development and Housing Committee 

Christchurch City Council

31 July 2019


Thank You for hearing our Public Forum Submission

Historic Places Canterbury (HPC) wishes to request that the CCC set up what we are provisionally calling a "Heritage Buildings and Sites Reference Group”.

HPC considers a Reference group with appropriately qualified individuals would be useful for the CCC Staff and Councillors wishing to seek advice from those with heritage expertise.

It could be useful for a number of roles such as:

  1. Advising on the Provincial Council Buildings (replacing its defunct(?) Advisory Group), 
  2. Review of Policies for District Plan Statements of Significance etc.
  3. Peer reviewing the work done for the District Plan,  
  4. Heritage Buildings under EOI. The Reference Group would be useful for providing feedback/comment on the development plans where seeking public comment is precluded under the Tendering Process.
  5. Provide independent advice to the Councillors
  6. Provide commentary where a full Engagement or Consultation is not practical or where expert advice is sought.

HPC wishes to nominate Dr Ian Lochhead,  Dr Anna Crighton,  Dr Lynne Lochhead, Katharine Watson and a Ngai Tahu representative as members of the Heritage Buildings and Sites Reference Group.

Forming such a Group would be an implementation of the much lauded CCC Heritage Strategy where there is recognition of the importance of the heritage expertise held in the community.

HPC notes the success of the Victoria Square Reference Group where the Plan was refined after Consultation and the feedback/comment was sought on the Design decisions etc in the restoration / construction. 

(The CCC you will recall recommended the Group be kept so it could have a role in the restoration work.)

Mark Gerrard
Chair Historic Places Canterbury

Christchurch City Council Draft Annual Plan 2019-2020- Submission From Historic Places Canterbury

Christchurch City Council Draft Annual Plan 2019-2020

Submission from Historic Places Canterbury

Mayors and Councillors;

Thank You for the opportunity to make this Submission.

Historic Places Canterbury (HPC) requests the Councillors pass on our appreciation of the efforts and application of the Council Heritage Team. 

They have worked hard ensuring the Stakeholders and Residents were kept informed and HPC considers the recently adopted Heritage Strategy to be a credit to them and the Council as a whole.

In addition, we request the Councillors pass on our appreciation of Richie Moyle and his team in their ongoing efforts in restoring and repairing the Councils Heritage Buildings. Highlights in the past year include the reopening of the Nurse’s Memorial Chapel and Historic Rose Chapel.

Historic Places Canterbury wishes to acknowledge the passing of the heritage stalwart Pam Wilson. Her passing is a loss to us all.

HPC in addition wishes to acknowledge the efforts and achievements of the recently retired Dave Hinman who served this Council for 50 years.


Historic Places Aotearoa : Submission On Building Amendment Bill (2018)

The following is the text of the Historic Places Aotearoa Submission to the Building Amendment Bill:

Patron: Dame Anne Salmond, DBR, FRSNZ, FBA
2013 New Zealander of the Year

25th October 2018

Ministry of Building, Innovation and the Employment
PO Box 1473,
Wellington 6140

Submission on


This submission is made by Historic Places Aotearoa Inc. (HPA) which welcomes the opportunity to comment on the Building Amendment Bill.

The reasons for making this submission are that HPA promotes the preservation of historic places in Aotearoa New Zealand. HPA also has an interest to promote the education of the public in the appreciation of heritage values. HPA is a key stakeholder in the consultation process and answerable to its affiliated regional societies and associated membership.

HPA has reviewed the Building Amendment Bill and considered the impact the proposed amendments will make on heritage buildings.

HPA has a particular interest in the subject of this Bill, for the merits of the sustainable urban quality and distinctive character of New Zealand cities and towns.

Too often demolition of heritage building post disaster is seen as the only solution to public protection. Other countries deal with heritage buildings in a more considered manner. Italy for example have teams of trained experts that will shore up damaged heritage buildings post natural disasters. This enables heritage and structural assessments to be made on a more considered basis.

It will be important that New Zealand trains people who are competent to make decisions with respect to heritage buildings and structures following an emergency situation and can either be, or assist the “responsible person” who is exercising their powers in the designated area under the proposed revisions to the Building Act.

HPA is generally supportive of the proposals in the consultation document as they try to strike a balance between the risk to life, the built historical environment and public / private rights during the difficult periods associated with managing buildings after an emergency and to provide for investigating building failures.

General comments:

In New Zealand under the current heritage management and protection systems, not all heritage is listed with Heritage New Zealand Pouhere Taonga (HNZPT). Much of the country’s heritage is scheduled under each of the various district plans.

For the purposes of this amendment, consideration needs to be given to acknowledging the significance of heritage listed buildings in the heritage lists of district plans, as required under the RMA, as well as those on the HNZPT National Historic Landmarks list and the HNZPT category one list.

In most cities there are examples of significant heritage buildings scheduled in the local territorial authority (TA) plans that are not listed by HNZPT or have been listed as Category II items. This may be due to HNZPT budget constraints, lack of information when buildings were initially assessed. (more…)

Christchurch City Council Draft Heritage Strategy 2019-2029 : Submission from Historic Places Canterbury.






Christchurch City Council Draft Heritage Strategy 2019-2029

Submission from Historic Places Canterbury.

The Process of Consultation and Formulation of the Draft Heritage Strategy:

Historic Places Canterbury (HPC) wishes to commend the Christchurch City Council Heritage Team for its efforts in Community Consultation, developing and delivering this Draft Heritage Strategy (Strategy). The Heritage Teams leadership has benefitted the process thus far and HPC considers it essential that they continue to lead in all subsequent work related and resulting from the Strategy.

Secondly Historic Places Canterbury formally knowledges the actions of the Christchurch City Councillors who adopted the Heritage Team’s recommendation of starting this process by right at the beginning asking the residents, groups and Communities of Christchurch what they wanted in the Christchurch City Council Heritage Strategy and then developing the draft strategy driven by the Residents, groups and Communities responses. In addition, the CCC Heritage Team sought feedback in the process of formulating the Draft Heritage Strategy.

Historic Places Canterbury was pleased to learn that the Mayor and Councillors individually involved themselves in the workshops and events that were used to develop this Draft Heritage Strategy.

Historic Places Canterbury considers the process and philosophy used for the Draft Heritage Heritage Strategy adopted by the Heritage Team and the Christchurch City Council (CCC) as one that should be used as a Council Template for future Consultations especially concerning Heritage.


Historic Places Canterbury requests the Christchurch City Council share these processes and experiences with other Territorial Authorities as we consider they and heritage will benefit from this approach of consultation and this process of strategy formulation becoming more widespread.

General Overall Comment on Draft Heritage Strategy:

Historic Places Canterbury is in agreement with the Strategy and our comments are mainly suggestions of refinement. HPC considers it is an important to consolidate and recognise the many informal relationships as well as establish new ones with the Communities that make up Christchurch and the Banks Peninsula. HPC fully endorses this approach.

Historic Places Canterbury considers the partnership, participation, role and acknowledgement of the Papatipu Rūnanga as being essential and long overdue.

Historic Place Canterbury is supportive of the Draft Heritage Strategy’s recognition and inclusion of the heritage of those who are not part of the traditional European heritage and again we consider this long overdue.

Historic Places Canterbury notes the extensive use of the work “community” in the text of the Strategy.  HPC requests “community” should be substituted with the word “Communities” or something similar in meaning.  HPC notes the phrase “communities of Christchurch and Banks Peninsula” (p16 of the Draft Heritage Strategy) sums up the intention of the documents.

The Strategy uses the phrase “partnership with six papatipu rūnanga” to define its relationship.

For the Community/Communities it uses the word “collaboration” and “together with the community” within the Strategy.

HPC requests the CCC reconsider the relationships (as defined in the Strategy) with the Communities and change it to one of Partnership or Collaboration as appropriate?

The Strategy mentions a “Charter” which effectively quantifies the CCC heritage relationship with the Communities.

(HPC notes the terms and conditions for those who take part in Heritage Week could be described as partnership agreements.) Defining relationships clearly also means there is less chance of a misunderstanding.

Historic Places Canterbury considers the Draft Heritage Strategy needs more development in dealing with our digital heritage future which is already here and will continue to exert a growing and significant presence. The CCC has put online the Scheduled Heritage Building’s own Statements of Significance but what is its Strategy when it comes to its own history and the social history of the buildings it has within its custody?(At one stage an oral history project recording the experiences of those who worked in the Canterbury Provincial Chambers was being discussed.)


Historic Places Canterbury would like the Strategy to give an indication of the variety of roles CCC envisages it will be providing in supporting the Communities of Christchurch and Banks Peninsula in their attempts to record and promote their heritage.

HPC notes the Library has a digital archive along with the Canterbury Museum’s collection and similar organisations such as Wigram and Akaroa, the Hall of Flame at Ferrymead etc and the University of Canterbury and the Strategy needs to look at the relationships the CCC has with these. What are the Community Board’s role within their local area? How is their local history and objects to be recorded or kept?

The Strategy correctly identifies the importance of intangible heritage as it relates to the stories of a heritage building. Questions will then be asked, for example, will the Library have a role in facilitating or storing those oral histories?

Historic Places Canterbury notes that a workshop participant commented the Strategy has the potential to be a part of the core of the CCC in its functions. HPC submits the Strategy provides an opportunity for the CCC to lead by example in demonstrating the importance of our City’s and Banks Peninsula’s heritage.

The Strategy commits the Christchurch City Council to be an active Heritage participant as evidenced by the word’s “collaboration” and “partnership”.

Historic Places Canterbury fully endorses this approach.

Such an approach will necessitate a cultural change within sections of the Bureaucracy especially as it will require a change to the traditional bureaucratic top down decision making management style which will at minimum have to be more open and communicative. HPC considers the Councillors will have to lead by example as they have thus far in this process.


Historic Places Canterbury is aware of the work published, such as by Building Economist Donovan Rypkema which conclusively provides evidence of the positive economic contribution of Heritage Buildings (and their retention). (These economic benefits are not just confined to Tourism.)

The Strategy, HPC requests should have additional text that states that the CCC understands and accepts the Economic Value of Heritage Buildings, the value of their active retention and the positive economic effects i.e. revitalization, restoration benefits etc they have on the local economy.

Specific Strategy Comments:


Whāinga  Goals (p34)

Historic Places Canterbury requests an additional Whāinga be added, that the CCC will commit to updating and regularly add heritage buildings and sites to its District Plan Heritage Schedule.

HPC understands that between 1996 and recent Independent Hearing Panel there were little or no Christchurch Heritage Buildings Scheduled. It is important to acknowledge the importance of heritage however the CCC needs to actually commit itself to fulfilling its RMA Duties in its own Heritage Strategy.

Historic Places Canterbury requests the Strategy state that it will be adopted as binding by the Council as a whole. 

HPC understands that the Urban Design Panel approved plans for the proposed demolition of the Harley Chambers, a scheduled heritage building. Whilst HPC does not wish to curb the independence of the Urban Design Panel it is not unreasonable that the Strategy be respected and acknowledged by such organisations and only in exceptional circumstances should the Strategy be ignored.

Mahinga Actions

Whāinga Goal 1. (page 35) …

“4. Celebrate and promote the Council’s role as heritage champion…

  1. Celebrate how the Council models best practice asset management ..”

Historic Places Canterbury requests that an addition be made to this section that the CCC will commit to share its knowledge and experience of heritage management best practice.

The Council has extensive experience knowledge in all aspects of heritage building management i.e. procurement, project management, budget, engaging professionals and HPC considers a practical Strategy is to commit to sharing its knowledge and experience with Heritage Building Owners and other Territorial Authorities.

Historic Places Canterbury requests that Whāinga Goal 1 contain a paraphrase of Whāinga Goal 2 section 4.

HPC proposes that  “The Council …” add the following;

Raise awareness of Our Heritage, Our Taonga across all Council Departments.

Whāinga Goal 2

Historic Places Canterbury fully endorses Whāinga Goal 2.

Whāinga Goal 3

Historic Places Canterbury fully endorses Whāinga Goal 3.

Historic Places Canterbury requests further consideration be given to this goal and the responsibility that will need to taken on by the Community Boards.

For example HPC notes that Crown Glass used to be a prominent industry in Hornby with artisans living close by. HPC considers the Strategy should enable the local Community Board to participate in celebrating and preserving its own unique community heritage.

Whāinga Goal 4

Historic Places Canterbury requests that under

(Section) “4 Support owners of heritage building through; …. ”

Historic Places Canterbury request that an addition be made to this section of the Strategy. The CCC work on a standard or accredited list of approved suppliers of Heritage Plaques for owners of Heritage Buildings. These plaques would publicly identify that the building is a historic building.


Historic Places Canterbury’s federated national body Historic Places Aotearoa has recently launched a nationally available Heritage “Blue” Plaque project (inspired by the UK Blue Plaque) which allows a building to be identified as heritage. Such a project is an ideal candidate for accreditation as well as being part of an emerging national standard.

Whakatinanatanga Implementation (p42)

“Implementation of this strategy depends upon partnership and collaboration.”

Historic Places Canterbury fully endorses this approach.

As noted above HPC requests the CCC reconsider and describe the relationships in the Strategy with its Communities as one of Partnership and or Collaboration.

HPC considers the Heritage Charter to be an excellent initiative and is looking forward to hearing the Communities heritage voices.


HPC requests as part of the Whakatinanatanga that consideration be given to setting up a Forum and or Reference Group that would meet on a regular basis.

As well as enabling the CCC to receive feedback it will have the additional advantage of allowing the sharing and exchanging of views.  The CCC could use this to facilitate the sharing and understanding of views from the Papatipu Rūnanga and the wider Communities.

We wish to heard by the Hearing Panel.

Mark Gerrard
Chair Historic Places Canterbury
021157 5043

Historic Places Canterbury: Submission on Building Amendment Bill (2018)

Submission of Historic Places Canterbury on the Building Amendment Bill 2018

1. Our comments

Historic Places Canterbury supports the policy objectives of the Building Amendment Bill. The experience of the Canterbury Earthquakes illustrated the shortcomings of the exisiting legislation both in regards to managing buildings after an emergency event and in relation to investigating serious failures.

2. Sections 207C - 207S

We believe the power to investigate major building failures is vital if lessons are to be learned which could help avoid future building failures and potential loss of life. We believe that the measures proposed in this Bill strike an appropriate balance between the need for investigation and the rights of property owners and other affected individuals.

3. Subpart 6B Special Provisions for buildings affected by emergency

We recognise that the Bill proposes significant improvements over the current situation in relation to managing buildings after an emergency and it will avoid the need for special empowering legislation to deal with those shortcomings as was required following the Canterbury earthquakes.

It is pleasing to see that these proposed amendments to the Building Act directly address the serious shortcomings that occurred in relation to heritage buildings following the Canterbury earthquakes but we have some reservations as to whether that protection goes far enough. We accept that protection of life safety must have primacy over heritage issues (and that this can include risk to critical infrastructure). Hence we accept a need to draw a distinction between the rules set out in 133BU ( Urgent works to remove or reduce risks) and 133BV (Works to remove or reduce other risks). However we are concerned that the requirement for the responsible person to obtain Ministerial approval for demolition of a heritage building is limited to Category 1 and Landmark buildings on the Heritage New Zealand Register. This involves the false assumption that all the most significant heritage buildings will be listed by Heritage New Zealand,(HNZ) but this is not the case. If a significant building is already protected by a Territorial Local Authority (TLA) then HNZ may have opted to apply its scarce resources to registering another building, given that district plan listing is the key listing for protection under the Resource Management Act. A good example of a key building not listed by HNZ is the Christchurch Town Hall but which is listed as Highly Significant by the Christchurch City Council. The problem identified here could be overcome by extending coverage of the section to Highly Significant heritage buildings listed by TLAs (however they may be described in the relevant district plan). However the reality of the situation for many small towns and rural areas in New Zealand is that most of their heritage buildings will be Category 2 or simply listed as protected in the district plan. If the provisions of this proposed section are limited to Category 1 buildings then smaller towns could potentially lose most or all of their heritage buildings following a major earthquake, especially as these will typically be on the major thoroughfare through the town, so for this reason may well pose a risk to critical infrastructure. Significant loss of heritage from small towns or rural areas would constitute a major loss for the cultural heritage of the country. We understand that extending the requirements of this provision to all listed heritage buildings would place a more onerous responsibility on the the 'responsible person' and the Minister than confining the section to Category 1 and landmark buildings, but if heritage listing is to be meaningful, then all listed buildings should be worthy of consideration. A national register of all listed heritage buildings would be helpful in the case of emergencies to ensure that the responsible authorities are aware of which buildings are heritage buildings. The suggested extension to the section would also require notification to the TLA (if it is not already the responsible authority).

S. 133BV(3)

We fully support the application of this section to all heritage buildings. We have a minor reservation relating to the wording. S. 133BV (3) (a) states that the responsible person must consult with various persons listed in 133BV(3) (a) (i) - (vii) " if it is reasonably practicable to do so". While one can readily see that it may not always be practicable, for example, to locate the owner or occupiers of the building or persons with a mortgage interest etc, it is difficult to conceive of a situation in which it would not be reasonably practicable to consult with HNZ or the territorial authority. We would feel happier with a less discretionary provision in relation to HNZ and the TLA and a stronger directive than merely to consider their views. With the current wording the 'responsible person' seems to be granted greater discretion to deal with a Category 1 building in the less urgent situation envisaged by S. 133BV than in the previous section where Ministerial approval is needed before carrying out demolition. It is clear that demolition may be an outcome of S. 133BV even though there is a requirement to consider alternatives to demolishing the building [S.133BV(3)(b)] but there is no comparable requirement to seek Ministerial approval. It seems an anomaly of the proposed changes that a building which might have been protected by the Minister withholding approval for demolition in the more serious situation dealt with in S.133BU, might be lost through the exercise of the discretion in S. 133BV if the situation is deemed to be one where S.133BU does not apply.

It should also be noted that at the time of an emergency there may be a number of buildings which are presently going through the process of listing either by HNZ or the TLA. It would be beneficial if these could be included, at the very least, in the provisions of S133BV. This would be difficult under the current law relating to heritage protection but it may be that as a result of the review of the heritage protection system being undertaken at present by the Ministry of Culture and Heritage there could in future be a provisional listing category to provide protection against pre-emptive destruction of buildings in the process of being formally listed. If such a change were to be introduced As in the case of listed buildings, a national register of provisional listings would assist those involved in emergency responses.

S .133 BP

We commend the inclusion of S. 133BP (4) (b) which requires those entering or inspecting a building to take all reasonable steps to ensure that minimal damage is caused to the buildings. This was a significant problem following the Canterbury earthquakes where, for example, doors were forced open and wrecked rather than applying the simple expedient of testing the door handle first. It is doubtful whether this legislative requirement will have much impact in reality unless it is backed up by a penalty for failure or at the very least a change in the culture of search and rescue personnel through training.

In conclusion, we welcome these proposed changes to the Building Act and believe, apart from the reservations that we have expressed here, that they will make a substantial contribution to dealing with future emergencies in a much more satisfactory way.

4. Our recommendations

We recommend the following changes:
That the requirement be extended to all heritage buildings by removing (a) and (b) from S133 BU (2)/
If this recommendation is accepted then consequential changes will be required to S 133BU (3) (4) and (5) to include reference to the TLA

S.133BV Insert a requirement that the Minister must approve demolition of a Category 1 listed building or landmark building (or if the recommendations in relation to S. 133BU are accepted, then the Minister must approve demolition of any listed heritage building.

Historic Places Canterbury Submission on the Christchurch City Council Proposed Grant of $10million for the Christ Church Cathedral (Hearing Held 14th December 2017)

Historic Places Canterbury Submission on the Christchurch City Council Proposed Grant of $10million for the Christ Church Cathedral

Mayor and Councillors,

Thank You for the opportunity to make a Submission on the Proposed Grant of $10 million for the Christ Church Cathedral.


  1. Historic Places Canterbury (HPC) fully supports and endorses the Christchurch City Council (CCC) Proposed Grant of $10 million Grant for the Christ Church Cathedral.


Historic Places Canterbury Submission to Regenerate Christchurch Re: “Draft concept and key moves for the Square and surrounding area”






Historic Places Canterbury Submission to:

Regenerate Christchurch:
“Draft concept and key moves for the Square and surrounding area”


Heritage buildings and sites often change through generations and in the way they are used and function that often differs from their original intention.

Heritage organisations and individuals acknowledge these changes occur and that heritage building and sites can accommodate change by using appropriate “Adaptive reuse principles,” to keep them vibrant and relevant to their time and circumstance.

Historic Places Canterbury is encouraging of designs that seek to make the Cathedral Square vibrant and relevant to a post “quake” Christchurch.  Any re-design of Cathedral Square however must be respectful of its heritage status under the District Plan (Scheduled as “Highly Significant”) and acknowledge in its layout and new additions its past functions and shape that made it a premier civic space and transport hub.

Historic Places Canterbury cannot support the Draft Concept as proposed by Regenerate  Christchurch as we deem it to be deeply un-sympathetic with an inappropriateness that borders on being  disrespectful of Cathedral Square’s heritage. Indeed Regenerate Christchurch ignores and fails to mention the protected status of Cathedral Square and its history.  (more…)



To: The Local Government & Environment Committee
Parliament Buildings



This Submission is made by Historic Places Canterbury (HPC) , an independent regional society affiliated to Historic Places Aotearoa (HPA). HPC is the NZHPT approved body which the Canterbury Branch Committee has transitioned to. Our objectives are the protection of heritage and providing local advocacy on heritage.

HPC supports the general purpose of the Bill to set out the objects and powers of the trust in legislation; to update, revise, and consolidate the governance arrangements of the trust; and to revise the winding up provision of the trust. (more…)