CCRU feedback on the Issues and options paper for coastal hazards plan change and the Coastal Adaptation Framework Dec 6-2021
Following is the CCRU feedback on the Issues and options paper for coastal hazards plan change and the Coastal Adaptation Framework.
While they are separate documents they are intertwined projects and so we feel it is more efficient and cohesive to respond to both in one document. The question boxes on the feedback webforms are also too narrow so feedback in a document is necessary.
Our read is that the plan change is about regulating/restricting new development while adaptive planning is about adapting existing properties to mapped hazards. More clarity over what constitutes new development would be useful.
The foundation report relied on to inform the plan change, LIM notifications and coastal adaptation framework is the Tonkin & Taylor Coastal Hazard Assessment for Christchurch District 2021.
We do not think the process should proceed in its current state
1. Community has not had enough time or been allowed close enough involvement.
The community has not had an adequate opportunity to question the technical reports. A large amount of technical information has been released at once with little time for communities to digest and respond. There has not been enough time or connection with council experts for the public to fully understand the council position, to communicate this to the community and for the community to give an informed response. While the small extension given is appreciated we have been unable to get effective collaboration with council experts during this time.
More time is needed along with real consultation as many important questions remain unanswered.
There appears to be an expectation that the public take the results in these reports (T&T Tonkin & Taylor Coastal Hazard Assessment 2021 and GHDs Multi-Hazard Baseline Modelling etc) as a given and without question. This is not reasonable given the costs
that will be shouldered by private property owners and the community. Given a history of problems with reports, it is a reasonable expectation that the experts be prepared to explain their science to the people affected by it. Pg 14 in the adaptation framework
document has the following sentence, it is exactly what is required and has not happened.
○ Develop a shared understanding of coastal hazards and risk, and local knowledge and issues.
There has been a regrettable lack of community involvement during the preparation of the technical reports. There was a perfect opportunity to include the community by allowing one place on the working group for a community representative but this was
refused along with efforts to get minutes from the working group meetings.
2. The reports have outstanding issues, questions that need answers and are not suitable for the purpose of a plan change or LIM notification.
The intended purpose of the Tonkin and Taylor report is to assist adaptation planning. It is thus not fit for the purpose of a plan change or LIM notations.
○ Section 1.2 reads:
○ The primary intended purpose of the updated coastal hazard and groundwater information is to help inform coastal hazards adaptation planning for Christchurch District. The results of the assessment could also inform a range of other purposes, provided the uncertainties and limitations are understood and appropriately managed. These other uses might include review of the coastal hazards provisions in the Christchurch District Plan, infrastructure planning decisions, consenting applications and Civil Defence Emergency Management. In many cases, the results of this assessment may provide an initial hazard screening for these other purposes, with more detailed analysis then undertaken for specific locations and scenarios of interest.
○ It is important to note this assessment is not intended to map out a hazard overlay for inclusion in the District Plan, but provides information about hazards (and the uncertainty in our understanding of those hazards), which may be subject to further analysis and consultation to eventually determine if and where a hazard overlay should apply.
Even for the purposes of assisting with adaptive planning the T&T report has a number of shortcomings that should be addressed and questions that need answered.
Broadly, the T&T report and frameworks embed too much precaution, do not clearly communicate ranges high and low and at points authors step beyond being honest brokers. This is not the place to critique the report but some examples are;
● Pg6 Coastal adaptation framework. “Under current conditions, it is predicted that New Zealand will experience around 30cm of sea level rise by 2050, 50cm of rise by 2075 and 1m of rise by 2115”
○ This kind of statement misleads the general public, council staff and elected members. It reads as a statement of fact but relies on the most extreme IPCC scenario that is now viewed as unlikely by the IPCC itself. Something like this should not be front and center and out of context like it is. The authors should know better, it is a red flag that undermines confidence in the rest of the report. We note that there was no questioning of this in the peer review.
● We are concerned that the models used in the T&T and GDH reports have not been back validated. The models are showing extensive flooding at current sea level. This does not seem to match with actual and observed flooding in recent 1/100 year events or correlate with previous modeling done by CCC.
● Pg9 of the adaptation planning framework - How the risk-based approach could be applied to activities.
○ It is not clear where the red zones are here and how they have been applied. Proposed restrictions in them are very severe, even infrastructure is non complying. Maps with where these zones are, are needed.
● Adaptive planning is about thresholds and trigger points; how this fits with areas being mapped as high risk using modeled RCP scenarios is unclear. Are we doing risk based planning or adaptive planning?
● Pg10 of the adaptation planning framework - Developing policy direction that is responsive to the decisions made through adaptation planning and enables subsequent implementation without necessitating a plan change in all circumstances.
○ Soothing words, but what does this actually mean and how will this be achieved given the modeled ‘risk based’ approach?
While we do not think this process can proceed with the technical reports and the framework in the state they are now, not all is bad and it can be rescued.
Community and council need to work together to answer unanswered questions, make necessary corrections and clarifications to produce a balanced technical basis and framework that everyone can support.
This will require council experts being prepared to sit down with community experts to go through the reports and framework to address issues and concerns. It is a shame that this did not happen from the beginning.
A better process and a way forward
1. Which option do you think is the most appropriate way forward and why?
2. Are there other options we should be considering?
Nobody (communities or council) want homes falling into the sea or communities destroyed 100’s of years ahead of when they will actually be affected.
None of the options presented are ideal in our opinion. An ideal approach would be an adaptive approach. A genuine partnership between affected communities and council is required that starts with developing an agreed technical foundation.
We understand the council's concern about liability and needing to keep people out of harm's way but the cost of restricting investment in communities also needs to be recognised. A balance needs to be struck and for this to happen, we need reports that give likely outcomes with ranges to properly communicate uncertainty. Highly precautionary reports and frameworks are not helpful in this context.
A round table is needed with community experts engaging with council experts and report authors. Ideally the council would assist with funding to support a community expert group. The proposed STAG would be an ideal forum for this.
Models and an adaptive approach vs risk based approach
The biggest thing missing from this framework is a genuinely adaptive approach.
‘Adaptive’ is on the label and what the community and CCRU have been advocating for but is not what has emerged from the black box. What we have is a risk based approach but it is flawed because risk is being assessed on precautionary analysis.
A truly adaptive approach does not rely on models and in fact adds protection against a ‘worse than we thought’ scenario unfolding. Under an adaptive approach you extrapolate based on recurrent trends and reassess regularly. Communities agree to stop building or
build in adaptable ways in areas that will be uninhabitable in [30, 50, 100] years based on current sea level rise trends. This is reassessed every 10 years as part of the district planning process and zones extended or contracted as appropriate.
This approach shares a lot with the current framework but avoids the problem of having to rely on models that will be wrong. Issues with inappropriate developments around the margins can happen in both approaches. CCC needs to consider that avoiding issues at the margins will require such precaution that the cost outweighs the benefit.
Policy setting should also be decided in collaboration with the community.
Like the technical documents, policy settings should also be discussed and set in collaboration with the affected community at an expert level. For example:
○ The place of Extreme RPC scenarios (RCP 8.5 and 8.5+)
○ The appropriateness of the 100 year timeframe. Very few houses last this long and especially now where materials are less permanent and technology improvements mean rebuilding is more attractive that renovation.
○ The place of precaution etc.
1. Uphold te Tiriti o Waitangi
a. It would be good to know what this means in practice, and how it differs from protecting the interests of other affected parties. Is appointing a Ngāi Tahu representative to each community panel that extent of it? Do Ngai Tahu have interests in all areas? Who will appoint this representative?
2. Develop local plans for local communities and environments
a. This is supported but there also needs to be consistency of approach and investment. There also needs to be a forum where all communities can talk to each other to avoid divided communities and inconsistent results.
3. Focus on public assets that contribute to the health, safety and wellbeing of communities
a. Can we take this to mean that the council will focus on protecting (sea walls and the like) public assets but will avoid putting these in for private assets like peoples homes. If that is the case we think the people in those communities providing those public funds will have a problem with this principle. It also does not indicate a will by the CCC to consider all options in a truly transparent adaptive approach.
i. ‘ Council’s resources (including public funds) will primarily be used to manage risks to public assets that contribute to the health, safety and wellbeing of communities.’
4. Be flexible and responsive
a. Agree with this but to be accurate responses need to be based on actual empirical trends and trigger points not computer models.
5. Recognise inter-generational equity issues
a. The subtext here reads restrict development and move people back now so that it does not need to be done in the future. There is however a double edged sword, if you limit development and move people along too early you destroy the next generations inheritance. Destroying assets today has a compounding effect into the future. The equity and wellbeing of people living today cannot be overlooked, having this in its current form risks doing this.
6. Prioritise natural and nature-based options
a. We support this with the provision that they are not the only option and that other ‘non-natural options’ (whatever that might mean) are used when natural defenses do not work.
7. Keep managed retreat on the table
a. Managed retreat as a guiding principle? This is completely out of place in this list and should be removed. Putting it here sends all the wrong signals. There is no information on when and how managed retreat would be implemented or compensation mechanisms. Until these and many other questions are resolved, managed retreat should not be on the table and certainly not a guiding principle.
Guiding principles that should be on the list
b. People first - Affected people and community wellbeing should be at the centre of the process. The following is from pg16 in the adaptation planning framework - highlights council centric thinking.
i. Land use restrictions ($: Low)
Land use restrictions are low cost for council, very high cost for private landowners who get no compensation.
c. Good science that is clearly communicated, focuses on likely outcomes, is open to question and is authored by honest brokers.
d. A genuine community partnership that recognises the costs borne by private property owners alongside councils need to reduce risk and comply with regulations.
e. A recognition that adapting too early and too late are both costly.
Community panel and the STAG
Community panel members should largely consist of affected property owners and be appointed by local residents associations. Currently it appears that only half the panel will be local and appointed by council. Affected communities should be able to appoint all members to community panels.
As well as a community panel there needs to be an umbrella group comprising a member from each panel. This is to make it easy for communities to talk to each other about the process. Avoid the perception of divide and concur, ensure consistency and equity between communities.
Affected communities should have equal rights with CCC when it comes to appointing members to the STAG. The STAG should be 50% community appointed. The STAG will highly influence community panels. This recognises the costs borne by communities and the partnership needed to resolve this.
Specific rules for flooding and groundwater
● Should we have specific policies and rules on groundwater, or rely on policies and
rules for managing coastal flooding?
A single rule for both would only work if the areas covered in all scenarios are the
same and the planning or adaptive response would be the same. This seems
unlikely and more likely to lead to a development halt type response to cover all
bases but further discussion would be required to fully understand this. The
authors of the recent groundwater study state,
○ “The purpose of the groundwater assessment was not to accurately
define the shallow groundwater hazard at a local scale, but to provide
a high-level assessment at the citywide scale. It is not sufficiently
detailed to identify individual property risks therefore will have no
impact on LIM wording. Any future consideration of a groundwater
response would be part of long-term planning, require additional
investigation and policy direction from Council”.
Tsunami - Should the District Plan manage areas at risk of a tsunami?
Our opinion is that using the district plan to deal with natural disasters such as Tsunami is a bridge too far. The DP is too blunt an instrument that would lead to depopulation in very large areas if the same level of precaution was applied to tsunami that is being
applied to sea level rise. If tsunamis were modeled on top of sea level rise then an even greater area will be affected. At some point we have to live with the possibility that disaster can strike and that emergency services and civil defence can adequately deal
with it. The cost of completely avoiding all possible disasters is simply too high or more precisely is not an efficient use of resources.
Tsunami is however mentioned explicitly in ‘the guidance’. The fact that you are asking if tsunami should be in or out raises the prospect that the guidance is in fact guidance and not a bible. The guidance (MtE, NZPS, Regional policy statement etc) are not perfect
documents, they are confusing, often conflicting and tend to be highly precautionary and in places misleading. Guidance documents are written far from the coal face and so wiggle room is given to enable sensible planning regulations on the ground. Climate
change guidance needs to be treated in the same way.
There is a lot that is good in the updated ccc commissioned consultant reports and the new framework but both suffer from a lack of transparency and engagement with affected communities during their development.
There was the opportunity to involve the community from an early stage by allowing a community representative to join the working group and making the working group process an open and transparent one. This was regrettably refused despite widespread
support and numerous approaches.
Had these requests not been refused we might not be in the position we are in now. Communities have not had the opportunity to question staff thoroughly enough.
This leaves us in the position that we are now and that is gaps in the framework and technical reports that are not fit for purpose. However all is not lost and this important process can be rescued with some additional time combined with better community
What is needed next
Next community and council experts need to work together to plug the gaps in the framework and technical reports to get to an agreed base that both can work from to adapt. We think the STAG is the ideal forum for this provided STAG experts are 50/50 council community appointed.
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