11 min read

Our letter to the Minister of RMA Reform on upcoming Plan Change 14 decisions

20 December 2024

Dear Minister,

We are writing to you to provide our position on the councillor-proposed alternative recommendations to the Independent Hearings Panel report adopted by Christchurch City Council at their recent Plan Change 14 vote on December 2nd, 2024. We feel many of the adopted alternatives go against the intent of the National Policy Statement on Urban Development, while there are some others that we strongly support. 

Hopefully, our views as a local YIMBY housing advocacy group will be useful to you in your decision-making over the coming months. Our appraisal of the alternatives is attached at the end of this letter.

If you would like further clarity on our position, we’re keen to meet with you and your staff to discuss this and urban development in Christchurch more widely.

We hope you and your staff have an enjoyable summer break, and we look forward to working with you in the new year.

Yours,

David Palmer

Jono de Wit

Harrison McEvoy

Jack Gibbons

Cody Cooper

Peter Galbraith


M Grace-Stent


Greater Ōtautahi is a non-partisan urbanist collective consisting of people who are passionate about making Ōtautahi Christchurch a more sustainable, vibrant, and equitable city. We focus mainly on urban issues of housing, transport, and other facets of sustainable urban living.

Christchurch City Council Plan Change 14 Councillor Alternative Recommendations Appraisal

When compiling this appraisal, we have worked against the alternative recommendations documented in the minutes for the council meeting on 2 December 2024, where the final Plan Change 14 adjustments were approved. The full meeting minutes can be found here: https://christchurch.infocouncil.biz/Open/2024/12/CNCL_20241202_MIN_10336_AT_WEB.htm

Please take into account that there may be discrepancies between these meeting minutes and the final plan as it reaches your office. We have been working with the information available to us at the time of appraisal.

The councillor alternative recommendations begin at section 5.10 and go through to section 5.25 of the meeting minutes. Some alternatives we do not have a position on, and are not included in this appraisal.

Alternative #51 (Riccarton Bush Interface Qualifying Matter)

This recommendation would reinstate the Riccarton Bush Interface Qualifying Matter, limiting the scope of development in the area of Riccarton close to Riccarton Bush.

We recommend you reject this alternative.

We believe this alternative recommendation goes against the intent of the NPS-UD by restricting intensification, and does not provide alternative zoned capacity to offset.

Riccarton Bush, showing the location to Hagley Park, Riccarton Road, Christchurch Boys' High School, and the University of Canterbury

In our view, there is nothing about the proximity of Riccarton Bush that should prevent housing intensification in the area. On the contrary, the area is perfect for greater intensification, as it is close to a major urban centre around Westfield Riccarton Mall and Christchurch Boys’ High School. It is also adjacent to the existing busy public transport corridor and the planned mass rapid transport project on Riccarton Road. There is no reason to believe that housing intensification within the existing urban area, next to the bush, would have a negative impact on the bush itself. Indeed, allowing more people to live in a high amenity area, and being able to experience  an ancient native forest is highly valuable.

Alternative #52 (Papanui War Memorial Avenues)

This alternative would instate special consideration of the Papanui War Memorial Avenues in the high-density residential zone (HRZ) around Papanui.

We recommend you reject this alternative.

There is nothing about these war memorial streets that should restrict housing development on them. In practice, these war memorial streets consist of tree-lined residential avenues with a memorial plaque attached to the street signs. Our view is that this is an attempt to designate the streets as “special character areas”, which goes against the spirit of the NPS-UD by potentially restricting development in these areas. Special character areas have been largely rejected by the IHP.

These areas have been zoned as high-density due to their close proximity to the Papanui Road public transport corridor and the major urban centre at Northlands shopping mall. Approving this alternative would essentially create “islands” of low-density character areas within this high-density zone, which will negatively impact the ability of the area to be intensified. This would enormously undermine the effort to upzone this area to high density.

We have constructed an approximate overlay demonstrating how much of the Papanui HRZ this would effectively downzone, marked in blue:

We feel this is an unacceptably large area to effectively downzone from the IHP recommendation.

We further recommend reading about the history of the War Memorial Avenues, as it makes clear that there is nothing about them that should restrict housing development on those streets. The memorial character of the avenues is embodied by the presence of avenue tree lining and the memorial street signs. Nothing about the character of the housing on those streets is relevant to the memorial. You can read more on their history here:

https://canterburystories.nz/collections/community/papanui-heritage/publications-papanui-heritage-group/ccl-cs-98771 

Alternative #53 (with amendment)

This alternative does two things:

  1. Upzones the currently derelict former Stockyard Site at 25 Deans Avenue to be a Mixed-Use Zone.
  2. Downzones the Riccarton Bush Interface area from high-density (HRZ) to medium-density (MRZ).

We recommend you reject this alternative.

As explained in our response to Alternative #51, the Riccarton Bush Interface area is an ideal place for housing intensification due to its location. We feel that downzoning this area to MRZ goes against the intent of the NPS-UD, especially when it is so closely connected to the Riccarton urban centre.

The provision regarding upzoning of the 25 Deans Ave site is effectively duplicated in Alternative #54. Therefore, there is no value in accepting this alternative recommendation.

Alternative #54 (25 Deans Avenue)

This alternative increases the effective building height limit on the 25 Deans Avenue former stockyards site, and rezones to mixed-use.

We recommend you accept this alternative.

25 Deans Avenue highlighted in red, showing proximity to Hagley Park and central city

The upzoning of the stockyard site is an excellent outcome from this process. This is a large site that is perfectly situated for a large mixed-use development; for example, a hotel and serviced apartments with attached restaurant and convenience stores. It is opposite Hagley Park and therefore well-connected to the central city and major cycle routes. The site has remained vacant for around 30 years, and it is long overdue for development.

Alternative #55 (Peer Street local centre)

This alternative would remove the Peer Street local centre designation.

We recommend you reject this alternative.

Peer Street in relation to the University of Canterbury Ilam campus

The Peer Street locality has been described by the Mayor as “just a New World supermarket and a car park” but we feel this is disingenuous at best. This locality is just south of and partly between the University of Canterbury Ilam campus and the UC Dovedale campus. There is already high-density development in the area in the form of a retirement village. This is an excellent area to bring in more housing density to support the growing student population close to the university. Students have expressed a desire for more and better quality rental accommodation, and this is an ideal place for that to be provided.

Alternative #56 (City Spine Qualifying Matter)

The alternative keeps in place the City Spine Qualifying Matter. The city spine imposes slightly more restrictive setbacks than the IHP recommendation along planned public transport corridors in Papanui and Riccarton. 

We recommend you accept this alternative.

Preventing development of frontages along this corridor is critical to the future enablement of mass rapid transit in the city. If development is allowed close to the boundary along this corridor, it will hugely increase the cost for the council—or the government—to acquire those frontages if they choose to widen the corridor in the future. Adoption of high frequency public transport is a critical part of the NPS-UD. We would prefer to see this moderate restriction on housing developments imposed to ensure success with future public transport initiatives in the city.

Alternative #57 (Sunlight Access Qualifying Matter)

This alternative would reinstate the Sunlight Access Qualifying Matter, which would create restrictive height in relation to boundary rules across the city. It is more restrictive than the minimum rule outlined in the MDRS, and would apply in NPS-UD areas, including the high-density zones in the city center walking catchment. While there are exemptions to the HiRTB rules for the front 20 meters of the plot in HRZ areas, in this old part of the city, plots are often very deep and narrow so the HiRTB rule will still bind.

We recommend you reject this alternative.

This QM was explicitly rejected by the IHP as too restrictive. It will limit housing choice in perhaps the most suitable place for more housing in the South Island. It does not align with the intent of the NPS-UD.

Alternatives #58, #59 and #60 (Hornby)

Collectively, these alternatives seek to restrict development around the Hornby urban centre, by reducing walking catchments and imposing more restrictive height limits than those recommended by the IHP.

We recommend you reject these alternatives.

We feel there is nothing special that differentiates this major urban centre from other urban centres at Papanui and Linwood. These alternatives go against the spirit of the NPS-UD and do nothing to enable intensification. We see no justification for limiting development in this area.

Alternatives #61, #62 and #63 (Linwood)

Similar to the previous alternatives, these seek to restrict development around the Linwood major urban centre by reducing height limits and imposing more restrictive height limits than those recommended by the IHP.

For the same reasons as outlined above, we recommend you reject these alternatives.

Alternative #64 (Airport Noise Corridor Qualifying Matter)

This alternative adjusts the Airport Noise Corridor Qualifying Matter. It firstly reduces the threshold at which developments in the corridor become a Restricted Discretionary Activity from four units to three, and secondly removes the requirement for the Christchurch International Airport to be notified of developments in the corridor.

We recommend you accept this alternative, though we have mixed feelings on it.

Generally, we see the Airport Noise Corridor QM as needlessly restrictive and would have preferred to see it struck down by the IHP. 

The first part of this amendment would have a negative effect on intensification in our view, as it would make “3-over-3” infill townhouse developments a discretionary activity within large parts of northern and western Christchurch. This would undermine the benefits sought through the plan change.

The second provision would mean that the airport does not have the power to give evidence against developments in this area. Our feeling is that the airport’s approach to housing consents in these corridors has been an impediment to housing intensification in the city, and we are pleased to see this power removed from them.

If it is possible to strike the first part of the alternative (reducing the discretionary activity threshold), while keeping the second part (removing the need to notify the airport), you should take that approach.

Alternative #65

This alternative may not come before you as it was not adopted by the council. During voting, there was a tie vote on an enabling provision for this alternative, and it was therefore not adopted. However, we think it has significant value for the city, and you should use any tool within your power to have the council reconsider it.

This alternative would do two things:

  1. Increase the central-city zone HRZ walking catchment north up Papanui Road to connect with the HRZ around Merivale.
  2. Rezone the large light industrial area in Sydenham, directly south of the central city, to mixed-use.

Central City Walking Catchment

We think this proposal to extend the central-city HRZ north up Papanui Road to Merivale would have been an excellent outcome for the city and strongly in-line with the goals of the NPS-UD. Papanui Road is planned to be a high-frequency public transport corridor and is only a short walk from the many businesses in the northern part of the central city.

We think the IHP made an error in not including the Victoria Street Commercial Central City Business zone as part of the CCZ for the purpose of determining the surrounding HRZ walking catchment. This has essentially resulted in a zero-metre HRZ walking catchment north of this area. Our feeling is that the high-density commercial area on Victoria Street should be surrounded by a suitably large HRZ zone, given the high amenity of having housing close to employment.

The proposed alternative would have solved this discrepancy in the IHP determination. We urge you to send this determination back to the council and the IHP. Our view is that the best outcome would be for the IHP to recalculate the HRZ walking catchment, taking into account the Commercial Business Zone area on Victoria Street that they incorrectly excluded from the CCZ. The next best outcome would be for the council to adopt the proposed alternative to extend the walking catchment to be 1.2 kilometres north of the IHP-recommended CCZ, effectively solving the problem through another route. Either way, we trust that you will do what you can to resolve this huge error in the decision-making so far.

Sydenham Mixed-Use Rezoning

This part of the alternative would have rezoned the large industrial area directly south of the central city to be mixed-use zoning with no height limit. 

Currently, this area is poorly utilised. It is a sprawl of car mechanics and sale yards, with many industrial storage warehouses. We perceive this as an exceptionally poor use of space so close to the central city. Rezoning this area to mixed-use would allow the city to begin transforming the area into a residential and commercial hub, smoothly adjoining the CCZ to the southern suburbs. 

It additionally would have taken pressure off infill intensification in the outer suburbs, by enabling intensive housing development immediately adjacent to the central city. 

We think the failure to adopt this alternative recommendation represents a failure of decision-making by the council. Most of the councillors expressed support for this rezoning, but were not given an opportunity to vote on it due to a tied vote at a previous enabling provision on the day. There was some confusion around the table about the process. If this alternative had been put to a standalone vote, we are certain it would have passed.

Given the extremely high value of this proposed change, we urge you to send this decision back to council for proper reconsideration.

Alternative #66 (Sydenham)

This alternative rezones a small parcel of council-owned land in Sydenham.

We regard this alternative as being of very low impact, so we have no position on it.

Alternative #67 (Perimeter block)

This alternative enables greater density through perimeter block controls around local centres throughout the city. This would relax setback and recession plane rules to enable larger-scale perimeter block developments.

We recommend you accept this alternative.

Perimeter block controls present an excellent alternative to the current trend of “sausage flats” for infill housing developments. These developments make use of the street-facing front portion of a section, creating an area of shared green space behind the building. This is a tried-and-true strategy for designing attractive cities internationally and represents best-practice urban design.

We are attaching two examples of perimeter block housing: the first is from Brno in the Czech Republic (a city of similar size to Christchurch), showing street-facing apartment buildings with a shared green space park behind them; the second is a proposed development in Mt Albert, Auckland, designed by Tom Robertson, a Masters of Architecture student at the University of Auckland.

Alternatives #68, #69 and #70 (Remove heritage protections)

These alternatives remove heritage protection from some derelict buildings and character areas. We recommend you accept these alternatives.