Our Submission to Christchurch City Council Draft Long Term Plan 2018–2028
Christchurch City Council asked the city for feedback on the draft Long Term Plan 2018-28.
Submissions closed on Friday 13 April 2018. CCRU requested to present our submission in person at the hearing so that the following submission to be fully considered.
CCRU was established in response to the District Plan which was being fast tracked using CERA Legislation with minimal engagement with communities. Whilst the Coastal Hazard provisions were removed from that District Plan the High Flood Management Zones were not and a 1m sea level rise was used in planning for these zones. The overly restrictive planning rules that have resulted, as well
as contradictory and apparently inconsistent planning advice from planners, are causing concern, frustration and having a social impact on our coastal communities. CCRUs objective is to promote openness, fairness and communication with council on important decisions that affect our lives.
Meaningful community involvement in discussions and decisions around these matters continues to be a focus and concern of coastal communities and CCRU, particularly as CCC, ECan and Regenerate Christchurch look to begin consultation on Coastal Hazard related issues. This submission focuses on the Long Term Plan 2018 (LTP). The LTP is cumbersome and inaccessible to most individuals. It
contains numerous accompanying documents that need to be read in order to obtain the full picture.
CCRU strongly believe CCC have not got the balance right in the LTP and are concerned that the Eastern suburbs and coastal communities are not being treated with fairness and equity compared to funding, projects and policies elsewhere in the city. Each suburb/area is different. Post earthquake damage and impacts of the design of the city drainage system are not evenly/equally
distributed geographically. So achieving city-wide fairness may mean that budget allocation must be interpreted beyond simplistic equal geographic splits.
The LTP has mixed messaging, particularly around current CCC policy. On the one hand the LTP seems to be saying, investment is business as usual according to need irrespective of considerations of long-term futures of neighbourhoods ie “..infrastructure renewals will continue to be undertaken across the city as the Council is yet to decide which, if any, areas to retreat from“, but at the same
time says that current “…design guidance is applied to projects, with increased capacity being provided where possible and careful consideration being given to construction of new infrastructure in areas affected by climate change”.
CCRU seeks clarification around which is it? In areas potentially significantly impacted by climate change are we in the next 3 years investing to meet any needs, interim needs or long-term needs?
CCRU contends that in line with their responsibilities, CCC should be addressing long term needs. Southshore was granted emergency temporary flood protection, for which they are grateful. However, beyond stabilisation of the temporary bund there is nothing further budgeted for Southshore/South Brighton, which is unacceptable and sends a negative message to the community.
CCC has committed to permanent flood protection for some estuary suburbs. Just in terms of fairness, we demand equity in treatment as other areas are afforded flood protection.
CCRU draws CCC attention to inadequate stormwater discharge system and seeks funding to improve this, in particular the Heron St/Godwit St/Ebbtide St end of Southshore water is clearly not discharging out through stormwater pipes. This needs to be addressed.
Coastal residents have through their rates helped pay the six-figure sum to defend The City against flooding via the Waimakariri stopbanks. We note plans for more rates to protect The City against a 1 in 1000 year (a very unusual and high flood) event. We also note on the basis of flood modelling of a 1 in 50 year (a very common and low flood) event, planned works to protect Southshore and South New Brighton were very recently cancelled. Although we struggle to see how these two decisions taken together are consistent or fair, nonetheless with regard to a possible rate increase we think it is reasonable to expect a rates increase to ensure the needs of the community / city are met, provided coastal communities get what they desperately need.
CCRU also challenge CCC on some of the statements made in the LTP as we strongly believe you are not delivering on many of these messages:
1. Enabling active citizenship and connected communities.
CCRU understands the Southshore Residents Association (SSRA) delivered to Regenerate an Ocel Report on building a permanent bund and have not been replied since March/ April 2017. We understand that SSRA handed in 1000 submissions in 2016 that called for flood protection. They asked for action years ago, before Heathcote. Heathcote are mentioned in the LTP – why is Southshore not mentioned?
There is no talk of people on the subject of flooding. Coastal communities value their environment and have lived on the coast, beside the estuary and the Pacific Ocean, for many generations. Many of the flood risk reduction related programs to reduce risk of flooding to
property and dwellings during extreme rain events have been removed from the LTP due to being “focused on more on technical process detail and data acquisition than on community outcome”. What is the rationale behind leaving out community outcomes? Why is CCC turning their backs on coastal communities. What about the councils responsibilities of listening to people's concerns when it affects properties that they pay rates on and insurance.
2. Maximising opportunities to develop a vibrant prosperous and sustainable 21st century city.
CCRU are concerned at the inadequate level of CCC spend in the East. Hence we struggle to understand how the East is going to be included in this statement?
3. Climate change leadership and Informed and proactive approaches to natural hazard risks.
Why are locally sourced international engineering reports not being considered e.g. SSRA Ocel Report for flood protection? What was the outcome since the OCEL report was submitted. The Council has not been proactive in engaging with the community to find a solution. It is also not clear whether in the Land Drainage Recovery Programme, the “restoration of community resilience and wellbeing by reducing the risk of flooding” includes areas adjacent to the Avon river, that include New Brighton, South Brighton and Southshore.
4. Increasing active, public and shared transport opportunities and use
Why is it that four out of six bus services that are closing, are all in the East? How does this promote active public and shared transport opportunities?
The Status of the Regeneration Strategy for Southshore/SouthBrighton (SS/SB).
This is of great concern to CCRU and it impacts directly on the value of the engagement process and the real level of community engagement in decisions of Council that significantly impact people’s future. Firstly there is no acknowledgement of the Regeneration Strategy for SS/SB in the Infrastructure Strategy.
The LTP does however acknowledge that “A multi hazards study is underway and will include options, costs and risks and development of adaptation pathways.” and that “This will include identifying which areas may be defended, and from which areas the city may need to retreat. This will be incorporated into the 2021 Infrastructure Strategy.”. CCRU seeks clarification that a. The Multi-Hazards Study with regard to SS/SNB will be undertaken with the community as part of creating the Regeneration Strategy, and that b. The Regeneration Strategy for SS/SNB will be embedded within the Infrastructure Strategy 2021 such that the latter can not be inconsistent with the former.
CCRU wants assurance that SS/SB will not be treated unfairly or differently than other coastal communities, especially given they will be ‘the first cab of the rank’ in having coastal hazard planning engagement.
CCRU objects to the tone and language around 'retreat' in the document. Rather, in line with government guidance on the matter we expect the CCC to be thinking, planning and writing in terms of adaptive management. Under that thinking/planning, retreat should not be initially considered to be the inevitable option. Instead retreat is only the result of a series of events triggering agreed responses. There are many options and pathways to be considered before retreat should be on the table.
CCRU wants CCC to show faith and a commitment to its coastal communities.
acting CCRU Chair - Friday 13 April 2018
These are links to the LIVE presentations- most often when presenting LIVE more information is given and more meaning is understood.
Simon watts CCRU LTP submission
Simon Brown SSRA LTP Submission
New Brighton Business and Land Owners
These are very good presentations re the appalling engagement of the East – Evan is on the 'How' team.
Peter Beck - Eastern Vision