Timetable and process for the introduction of the Coastal Hazards Plan Change PC12

CCRU Submission re: Plan Change May 13/22

After consultation with our group, CCRU ﬁnd that they are not in a position to support the CCC draft proposed plan change as it has currently been drafted.

General

Firstly there are good aspects in this draft and we appreciate the time staﬀ have taken to engage with us on this.

Overall we feel there is a conﬂict in the objectives between wanting to avoid increased risk and enabling development. The former we think will become the blanket result if the policies and rules are not changed or clariﬁed. We are concerned that development that would reduce risk might even be blocked under the current rules.

Issues like this happened with the last plan change leading to diﬃculties for both CCC staﬀ and property owners alike, we would not like to see this happen again.

There have been times where additional restrictions, not intended at the time of drafting, have been read into rules. We are concerned this disconnect is about to be repeated in the current draft plan.

a- In our view we think the enabling rules are orphaned by the objectives and higher level rules. It seems any application would have a predetermined outcome based on the overriding Risk Avoidance statements.

5.2.2.5.2. Avoid increasing risk from Coastal Hazards
5.2.2.5.3. Managing subdivision, development and land use in Coastal Hazards areas

i. Subject to policy 5.2.2.5.2, any subdivision, development and land use within coastal hazards areas

b- We believe the objective as it stands has divergent goals that will be diﬃcult to balance

c- We are not conﬁdent that the rules will function in a fair and reasonable manner when weighed against policy 5.2.2.5.2 which is about ‘avoidance’

d- A clear deﬁnition/understanding of what avoidance means is required. Past experience in Christchurch has shown it to be read as prohibition.

e- We believe the policies and rules are overly complex and should be simpliﬁed. An improved and clariﬁed 5.2.2.5.2 might mean subsequent policies are not necessary.

f- The RUO should not be disposed of and instead should be extended. It was arrived at through a rigorous process and is working well.

g- The concept that risk is not increased until the hazard itself has reached a certain trigger point needs to be integrated into the rules.

h- The plan change does not seem to address area-wide mitigation to enable works that will protect communities from coastal hazards.

Objectives

Objective 5.2.1.2 shows an internal inconsistency in the sense that "not increased" and "managed to an acceptable level" can be interpreted as pointing to diﬀerent outcomes. It is not clear to CCRU how the CCC will manage this dichotomy fairly and consistently

Objective 5.2.1.2 – Coastal Hazards.

a- Development, subdivision and land use does not increase the risk of coastal inundation, coastal erosion, rising groundwater or tsunami causing physical, social, economic or environmental harm.

b- Existing communities potentially aﬀected by coastal hazards are able to continue to develop and use land, natural and physical resources where the risk of adverse eﬀects from coastal hazards is not increased and the level of risk can be managed to an acceptable level.

Policies

We feel the policies are too complex, there are over two pages of policies and we believe these could be simpliﬁed

5.2.2.5.2 Avoid increasing risk from Coastal Hazards Within areas of coastal hazards avoid development, subdivision and land use that would increase the risk of social, environmental and economic harm from coastal hazards unless:

it is dependent on a coastal location, and
there are no other reasonable alternatives available, and
the beneﬁts of the proposed development out-weigh the potential harm, and
the adverse eﬀects from coastal hazards and the development on people, property, infrastructure, the environment and cultural values are mitigated to the fullest extent practicable

We see policy 5.2.2.5.2 above as being particularly problematic due to the following

“Avoid increasing risk from Coastal Hazards” does not reﬂect the balance displayed in objective 5.2.1.2
As policy 5.2.2.5.2 informs all subsequent rules, we are not conﬁdent that the policy in this format supports the perceived intent or outcome of the rules.
We are concerned any application will have a predetermined outcome based on the overriding Risk Avoidance statements.
We ﬁnd “i) it is dependent on a coastal location, and ii) there are no other reasonable alternatives available” are vastly open to interpretation and could serve as a catch-all clause. A planner assessing and application under this clause could say that there are many other sections to build on in CHC so we will not allow any development, at all in these areas. It could consequently lead to an application to build in a coastal area being rejected in favour of building anywhere else simply because it is possible.
5.2.2.5.2 iv “ the adverse eﬀects ….. are mitigated to the fullest extent possible. Is up in the air.. Someone could read into this that the only way to achieve the “fullest extent possible ” is to not allow any development.

Rules

This includes restricted discretionary RD1-RD21. That has over 17 matters of discretion. We see this is needlessly excessive.

We are unsure how Adaptation will be applied as an assessment matter. Many communities do not have an adaptation plan, have not engaged in this conversation, and will not do so for a number of years. How will the lack of a plan or the inclusion of a plan be used in the assessment?

RUO

The draft plan change appears to propose removing the current RUO. CCRU does not support the removal of the RUO.

At present the RUO is functioning well. It has allowed residents to build safe and site appropriate houses, within a set of fair and reasonable rules. It has restored vitality to the community. We believe the RUO works eﬃciently and fairly and should be extended to other high management areas.

We are concerned the current draft plan will not function in such a fair and eﬃcient manner. As an example, a replacement residential unit in the high inundation zone (which at present equates to the RUO) is a RD activity. This plan indicates two aspects will be considered. (a)The very speciﬁc matters of discretion for RD and (b) that it must align with the policies and objectives which indicate avoiding an increase in risk.

We are concerned that avoidance policy 5.2.2.5.2 of which the rules are subordinate to, will inform rules in such a way that development may appear possible on the face of it but will be stalled by avoiding risk. This is what occurred pre RUO. Staﬀ were provided legal advice at the time that instructed an avoidance policy.

The issues impacting on the properties and communities in residentially zoned land which may be aﬀected by sea level rise were clearly identiﬁed and addressed by the IHP.

The IHP considered there was nothing in the CRPS which warranted non-complying activity status and accordingly introduced the restricted discretionary activity status to limited activities in the RUO (204). “In our view, the risk here is one to property, not to people. We accept that wellbeing can be aﬀected by ﬂooding, even if safety is not.” (205)

The IHP said, “Relevant to these two issues is another matter: the source of the risk. Where the risk is one which could occur suddenly, such as a breach of a river or similar, clearly the risk to life and people is greater. Conversely, where the source is more gradual, as is the case here, the risk is primarily to property.

In our view the draft is in eﬀect a role back to the pre-RUO time, where risk and avoidance was used to stall any level of development.

If you want to see what an ineﬀective policy looks like and its eﬀect on a community, look no further than Southshore. The Southshore experience is one that should be considered and learning followed. This led to an erosion of the well-being levels, so concerning that it was raised at council level. Several residents were ﬁnancially aﬀected, and their health was of concern to their friends and families. This is what happens when communities are over regulated, and a district plan fails to function fairly and reasonably. Communities were smothered.

A return to this type of policy application is in our view not acceptable and is most likely to have similar results.

We do not want a repeat performance of the pre RUO ﬁasco and we see nothing in the policy that would prevent such a repeat.

Risk

We ﬁnd there is no clear deﬁnition of risk. What does avoid risk mean? There is a time element to risk. Is this policy concerned about avoiding current risk or future risk? This is not clearly speciﬁed, and it appears this policy supports applying future risk prematurely

We see no opportunity or provision to acknowledge a reduction of risk in the plan. What if a remodel of a property reduces risk?

For example, an old house that is ground level (high risk/ less resilient) should be encouraged to build new. The new build should be viewed as reducing risk (higher, safer, eco). Residents need to be able to adapt to family needs and improve the housing stock.

Avoidance

Avoidance is a central term in this plan change but its meaning is not clear. To date it seems to have been read as prohibited. It needs to be clariﬁed along with how it will be applied in this circumstance.

Foundational Data

The CCC have indicated in submission feedback that comments and feedback on the Jacobs report are welcome during the process for the plan change. This is appreciated as all aspects should be open to questions and feedback in a good process.

CCRU make the following comments

An independent comprehensive review would be valuable and help to build community trust.

We are unsure how the High hazard erosion line has come about.

Mapped ﬂood levels appear not to correlate with actual ﬂooding that is currently happening in the example 100 and 200 year events.

The new policy should be road tested

We have stated that we are concerned and do not have conﬁdence that the policies and rules will be able to be applied in a manner the planners are portraying or perhaps expecting.

For this reason, we believe it is important that the CCC either via internal or external sources undertake work on applying the rules to real life examples.

CCRU believe it is the council's obligation to test a policy thoroughly before it is implemented. CCRU request suggest that the CCC road test the plan using 15 real-life examples across the areas of control and discretion and in the diﬀerent zones. We would like to see how the plan works and what outcomes can be expected.

This road-testing would best occur before the plan change is formally notiﬁed.

It is CCRUs view that this would be of beneﬁt to both the public and the planners to see how the rules work in practice.

We see that it can only be a win win. If the outcome shows the plan does not respond as expected, then modiﬁcation can occur before further hearings. If the plan does function fairly and consistently it will give residents a transparent pathway to better understand how the plan functions and the conﬁdence to better support the plan change in the processes moving forward.

Additionally, we see that publicly available road tested examples support the intent of the rules into the future by keeping a consistent and transparent pathway. We believe this will assist both planners and homeowners alike.

Adaptive vs Risk based approach

The plan change has taken a ‘risk based’ approach based on models. We think a better and safer approach would be adaptive management.

Policy Clause 5.2.2.5.3 states that subdivision development and land use within coastal hazard areas shall be located in the lowest risk category possible. If this clause remains, we will not be allowed to subdivide, develop or even live in any area outside of the lowest risk areas. Is this what is intended? We hope not.

Clause E in the same policy relies on risk-based trigger points. What is the deﬁnition of this?

Who makes this call and based on what information? It seems very arbitrary and open to the particular bias of individual council oﬃcers.

Clause F in the same policy sounds as though the council has already made its decision that there will be "removal relocation or sensation of activity" perhaps the words if deemed required could be added here and softened so that it reads to be less of a requirement and endgame policy

5.2.2.5.5. Innovative forms of development and design within Coastal Hazards areas

We very much support solutions that enable people to safely build in areas that are ‘likely’ to be aﬀected by natural hazards however as the Plan is currently drafted, it would appear these would still be subject to the restrictions noted in 5.2.2.5.3.

5.2.2.5.4 would also be subject to such restrictions as it is clearly noted in the policy.

Area wide Mitigation

The plan change does not seem to address area-wide mitigation to enable works that will protect communities from natural hazards. The ability to be able to build ﬂood and erosion protection is an important part of adaptive planning but to have these options they need to be enabled in the plan.

CCRU feedback on the Issues and options paper for coastal hazards plan change and the Coastal Adaptation Framework Dec 6-2021

Introduction

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.

Guiding principles

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.

Summary

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
engagement.

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.

Background:

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.

Submission:

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.

Simon Watts

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.

http://councillive.ccc.govt.nz/video/7549

Simon watts CCRU LTP submission

http://councillive.ccc.govt.nz/video/7550

Simon Brown SSRA LTP Submission

http://councillive.ccc.govt.nz/video/7650

Megan Roulston

http://councillive.ccc.govt.nz/video/7619

New Brighton Business and Land Owners

http://councillive.ccc.govt.nz/video/7493

Community Board

These are very good presentations re the appalling engagement of the East – Evan is on the 'How' team.

http://councillive.ccc.govt.nz/video/7521

Peter Beck - Eastern Vision

http://councillive.ccc.govt.nz/video/7523

Evan Smith