Christchurch City Council

Supplementary No 2 Agenda



Notice of Meeting:

An ordinary meeting of the Christchurch City Council will be held on:


Date:                                     Thursday 9 November 2017

Time:                                    9am

Venue:                                 Council Chambers, Civic Offices,
53 Hereford Street, Christchurch





Deputy Chairperson


Mayor Lianne Dalziel

Deputy Mayor Andrew Turner

Councillor Vicki Buck

Councillor Jimmy Chen

Councillor Phil Clearwater

Councillor Pauline Cotter

Councillor Mike Davidson

Councillor David East

Councillor Anne Galloway

Councillor Jamie Gough

Councillor Yani Johanson

Councillor Aaron Keown

Councillor Glenn Livingstone

Councillor Raf Manji

Councillor Tim Scandrett

Councillor Deon Swiggs

Councillor Sara Templeton



7 November 2017




Principal Advisor

Dr Karleen Edwards

Chief Executive

Tel: 941 8554


Christopher Turner-Bullock

Committee Advisor

941 8233

Note:  The reports contained within this agenda are for consideration and should not be construed as Council policy unless and until adopted.  If you require further information relating to any reports, please contact the person named on the report.
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09 November 2017




09 November 2017




26.     Resolution to Include Supplementary Reports...................................................................... 4


28.     Proposed Redcliffs School Relocation - Council Response on Proposal to Use s71 of the Greater Christchurch Regeneration Act.................................................................................. 5  


09 November 2017



26.  Resolution to Include Supplementary Reports

1.       Background

1.1          Approval is sought to submit the following report to the Council meeting on 09 November 2017:

 28.  Proposed Redcliffs School Relocation - Council Response on Proposal to Use s71 of the Greater Christchurch Regeneration Act

1.2          The reason, in terms of section 46A(7) of the Local Government Official Information and Meetings Act 1987, why the report was not included on the main agenda is that it was not available at the time the agenda was prepared.

1.3          It is appropriate that the Council receive the report at the current meeting.

2.       Recommendation

2.1          That the report be received and considered at the Council meeting on 09 November 2017.

 28.  Proposed Redcliffs School Relocation - Council Response on Proposal to Use s71 of the Greater Christchurch Regeneration Act




09 November 2017



28.    Proposed Redcliffs School Relocation - Council Response on Proposal to Use s71 of the Greater Christchurch Regeneration Act




Glenda Dixon

941 8999



1.   Purpose and Origin of Report

Purpose of Report

1.1       The purpose of this report is for the Council to decide whether to approve a response under section 66 of the Greater Christchurch Regeneration Act (GCRA), to Regenerate Christchurch’s draft Proposal that the Minister use section 71 of the GCRA to amend the District Plan by designating the new Redcliffs School site (current Redcliffs Park), and by rezoning the new park site (current Redcliffs School).

Origin of Report

1.2       Regenerate Christchurch has drafted a proposal under section 65 of the GCRA, and as required by section 66 of the GCRA, has sought the views of Council on the proposal as a strategic partner under the GCRA.

2.   Significance

2.1       The decision in this report is of medium significance in relation to the Christchurch City Council’s Significance and Engagement Policy.

2.1.1   The level of significance was determined by the high level of community interest and the possible environmental impacts of the proposal.

2.1.2   The community engagement and consultation outlined in this report reflect the assessment.


3.   Staff Recommendations 

That the Council:

1.         Approve the Council providing to Regenerate Christchurch the attached letter recording the views of the Council on the Proposal to amend the District Plan to designate the new Redcliffs School site and to rezone the new Redcliffs Park site, including amendments sought by Council to the Proposal and to the Designation Conditions.


4.   Key Points

4.1       This report supports the Council's Long Term Plan (2015 - 2025):

4.1.1   Activity: Strategic Planning and  Policy

·     Level of Service: 17.0.4 Advice is provided to Council on priority urban regeneration issues that affect the City

4.2       Advantages and Disadvantages of sending the letter recording the Council’s views:

4.2.1   The advantages of this option include:

·     The response includes an assessment of the most significant potential effects of the proposal, and suggests amendments to the proposal where appropriate.

·     The response considers effects on neighbours, and foreshadows matters which will be of interest to Council in the future outline plan process for the new school.

4.2.2   There are no obvious disadvantages to this option. It does not express any final Council view on the appropriateness of the designation. Once the Proposal has been finalised and notified for public comment, it will be further investigated and reported again to the Council.


5.   Context/Background

5.1       On 7 September 2017 the Council as landowner approved the Recommendations of its Hearings Panel that it support the swap of land at Redcliffs Park, owned and vested in the Council, for Crown land at the current Redcliffs School site, the latter to be controlled and managed by the Council for a new park. That decision by the Council as landowner could not, and did not, address the planning considerations relevant to the designation of the current Park site as a school in the District Plan, or the use by the Minister of section 71 of the GCRA to achieve that. Those are the matters addressed here.

5.2       A copy of the draft Council response forms attachment 1 of this report, a copy of the Draft Redcliffs School Section 71 Proposal  forms attachment 2 and the Section 71 process is outlined in Attachment C.

5.3       Changes to the District Plan that will enable a school and a park to be established are now being sought using the Minister’s powers under a Section 71 GCRA process. The proposed Council response to Regenerate Christchurch agrees that the Minister's use of the GCRA power to insert the designation in the District Plan is appropriate if the site is the right one for the school. The draft response to Regenerate Christchurch invites further analysis of the proposed development of the site having full regard to the Council's objectives and policies concerning the avoidance of development in high flood hazard areas.

5.4       It is considered that there are valid reasons to expedite the process of requiring a designation for the new school in the District Plan, including the considerable length of time over which the School has not been able to occupy its current site.  It is also considered that the section 71 process being proposed is an appropriate way to concurrently authorise the changes in land use at both sites.

5.5       Shortening timeframes by removing the usual submission, hearing and appeal process should not however come at the expense of meaningful community engagement, or result in any less than thorough consideration of how potential adverse effects can be avoided or mitigated.

5.6       Only key issues are covered in the sections following. The Council’s response itself covers some additional matters. 

Proposed Changes to the District Plan

5.7       The package of changes to the District Plan in the Proposal is as follows:

·   The uplifting of the designation of the current Redcliffs School site for “Primary School”.

·   The rezoning of the part of this land to be controlled and managed by Council, to Open Space Community Parks Zone.

·   The rezoning of the rear of the site to be retained by LINZ, to Open Space Natural Zone.

·   The designation of the new school site for “Education Purposes”.


5.8       Officers consider that a further element should be added to the package. This is the rezoning of the new school site to Specific Purpose (SP) School Zone (effectively an underlying zoning) rather than it being left as Open Space Community Parks Zone. Virtually all of the schools in Christchurch are zoned SP School Zone, including the current Redcliffs School site. This provides a consistent approach to environmental outcomes sought across all schools in the City, and a guide to what the community would expect to see on outline plans which show in more detail how sites would be developed.

Natural Hazard Risk

5.9       The most significant issue associated with the new school site is flood risk on the larger, lower portion of the site i.e. that area below the terrace adjoining Main Road, in the context of a District Plan policy that requires development to avoid that hazard.

5.10    While the school buildings are intended to be based on the “terrace”, which is above even extreme modelled flood levels, it appears that about half of the buildings would need to extend out over the lower level land, at raised floor levels. This lower land would also accommodate outdoor playing areas and sports fields, and all vehicular access to the school is proposed to be from Beachville Road.

5.11    Much of the lower portion of the site is within a High Hazard Area as defined in the Regional Policy Statement (RPS), where new development should be avoided because water depths would be greater than 1m in a 1 in 500 year flood (Policy 11.3.1), or land would be subject to sea water inundation over the next 100 years. Policy 11.3.1(6) in the RPS provides an exception in areas zoned for residential, industrial or commercial use but officers do not consider that this exception is met. Rather, it is considered that that the proposal represents an intensification of use of a hazard area. The attached proposed letter asks that Regenerate Christchurch more fully addresses this issue in the final Proposal.

5.12    The District Plan contains similar avoidance policies at Policy and Any new buildings in High Flood Hazard Management Areas, such as parts of the currently proposed school buildings, would be non-complying activities were it not for the designation. It is considered that the proposal should include more discussion of the implications of the High Flood Hazard classification, and mitigation options.

5.13    With regard to more frequent rainfall flooding, all of the lower portion of the site is included in a Flood Management Area. As the site is lower than the surrounding residential areas, it forms an informal stormwater detention basin from which stormwater is required to be pumped to the estuary.  In storms exceeding a 1 in 5 year flood event, water ponds on the low lying areas of the park.

5.14    There is also a risk of flooding from the estuary in extreme tides and storms, which will be exacerbated by future Sea Level Rise. The current crest of the rip rap coastal wall at 11.2m above CCC Datum will not be sufficient to protect the site from coastal inundation by overtopping of the coastal wall, with even 0.5m of Sea Level Rise and a 1 in 5 year extreme tide.  This means that in the future, the lower parts of the site could be subject to frequent coastal flooding.

5.15    While there are some possible defence measures which could be adopted, especially for the school buildings, there are operational risks for the school both within the 50 year period and beyond, because the use of some or all of the outside areas of the school would be precluded during a flood event. If all vehicular access is to be from Beachville Road, as proposed, there are likely to be safety issues for children if accessing the school from this direction during a flood event.

5.16    The MOE should give early and specific consideration in building, site and access design, to coastal hazards and access to and from school buildings in flood events.

5.17    The draft Council response does not support any filling of the lower area of the site even for school building platforms, without equivalent volumes of compensatory storage, as any net filling will divert floodwaters onto neighbouring properties. This matter also needs to be addressed at an early stage in consultation with Council’s engineers. 

Traffic and Access Issues – New School Site

5.18    Several transport reports have been produced for the new school site. Because all vehicular access for the new school is proposed to be from Beachville Road, the operation of the intersection of Beachville Road and Main Road has been reviewed by consultants for the MOE. It has been agreed with Council staff that signalisation is not justified, but Council transportation planners have concerns about the speed environment on Main Road, and the likely efficiency and safety of the current intersection if there are increased traffic movements. Some redesign of the intersection may still be needed and further analysis is required.

5.19    A School Speed Zone is currently proposed to improve the safety of children walking, cycling or scootering along Main Road to the school. There also needs to be a safe crossing facility, possibly a Kea Crossing, between the old and new school sites. The details of all these improvement measures need further investigation and analysis.

5.20    Some improvements are also required at the Celia Street boundary of the site, in regard to sealing and marking parking spaces and separating car and pedestrian and cycle movements. Improvements to the Celia Street/Beachville Road intersection would also improve safety in this area. 

5.21    In order to address these traffic and safety concerns, the proposed response letter seeks a condition of the designation that requires a traffic safety report to be completed and implemented before the school opens. An effect of that condition would be that if the Council does not fund implementation of the roading improvements then the Ministry of Education must do so before the school opens.

5.22    Critically, there is a need for safety audits of all mitigation measures at scheme design stage, and then later after implementation.

Effects on Neighbours

5.23    The draft response highlights some of the aspects of the proposed development that may affect neighbours.

5.24    Because of the configuration of the park site and the need to elevate buildings and site them as far as possible from the coastline, there is the potential for the school buildings to be visually prominent from both directions, and some of the buildings could be in close proximity to boundaries with neighbours. Buildings should be designed with careful and sensitive consideration of this interface.   

5.25    One of the possible issues is the potential for glare and light spill from security lighting. This can be addressed by a consent condition regarding the appropriate standards, and this is proposed in the response letter.

5.26    The acoustic report with the proposal indicates that there could be difficulty with the school meeting the Ministry of Education’s noise standards at specific residential boundaries.

5.27    Acoustic fences along the relevant boundaries would address noise issues. The proposal includes a condition on this matter, but makes the provision of such fences dependent on the specified noise limits not being able to be achieved.


5.28    It should be possible to predict this ahead of construction, so it is considered that a better approach would be to provide acoustic fences on those residential boundaries where noise issues can reasonably be anticipated. The response letter proposes amended wording of a   condition to achieve this. This would give greater design flexibility for the school, rather than noise issues causing the need for example, for consideration of measures such as non-openable windows on some facades of the building(s). A condition requiring compliance with District Plan night-time noise levels is also suggested, because of the probable lack of separation distance to residential boundaries.

6.   Amendments sought to proposal and designation conditions

6.1       The draft response letter seeks amendments to the proposal. These are:

·   To include rezoning of Redcliffs Park to the Specific Purpose School zone.

·   To add discussion on the implications of part of the school being in a High Flood Hazard Area, proposed access to and from the school during flood events, responses to Sea Level Rise over time, and further discussion of mitigation proposed.

·   Undertaking rockfall modelling of the rock island at 1 Main Road.

·   Providing additional traffic modelling information on the speed environment on Main Road and potential delays at the intersection of Main Road and Beachville Road.

6.2       Additional designation conditions are sought covering:

·   Location of school buildings as far as practicable from Mean High Water Springs.

·   No filling of the lower part of the site without equivalent compensatory storage.

·   Traffic improvement measures, to maintain safety for both pedestrians and vehicles around the new school, and also maintain the operational efficiency of Main Road.

·   Glare and light spill to adjoining residential properties to comply with District Plan standards.

·   External plant or equipment being designed and located to comply with the District Plan night-time noise limits.

6.3       Amendments are sought to two designation conditions in the proposal, to:

·   Correct the finished floor level required and

·   To require acoustic fencing on the boundaries of the school with three adjoining properties, rather than making it an option.

7.   Option Description

7.1       Approve the response letter as attached.


7.2       The level of significance of this option is medium, consistent with section 2 of this report.

7.3       Engagement requirements for this level of significance are medium, and the GCRA sets the process. Once finalised, the proposal will be submitted to the Minister for approval, and if the Minister decides to proceed, there will be an invitation for public comment.

Impact on Mana Whenua

7.4       This option does involve a significant decision in relation to ancestral land, therefore this decision does specifically impact Ngāi Tahu, their culture and traditions. The entire new Redcliffs School site is within a Nga Turanga Tupuna Area, and part of it adjoining Main Road is within a Wahi Tapu/Wahi Taonga area associated with the Moa Bone Cave. The same is true for the old  school site, with the Wahi Tapu/Wahi Taonga area covering a greater portion of that site.

7.5       Te Runanga o Ngai Tahu are being directly consulted by Regenerate Christchurch, as they are also a strategic partner under the GCRA. 

Community Views and Preferences

7.6       There was significant community consultation during the land swap process which preceded this planning process, with 853 submissions received and a Council Panel hearing held. There will be an opportunity for public comment on the proposal as set out in 7.3.

7.7       In addition, the MOE is working with the School’s Board of Trustees to provide a separate opportunity for the community to comment on proposed designs for the school.

Alignment with Council Plans and Policies

7.8       Subject to the comments made above and in the draft Council response on natural hazards, this option is consistent with Council’s Plans and Policies.

Financial Implications

7.9       Cost of Implementation – staff time.

7.10    Maintenance / Ongoing Costs –Nil.

7.11    Funding source –Funding of traffic network improvements will need to be further discussed between the Council and the Ministry of Education.

Risks and Mitigations

7.12    There is a risk that Council will be exposed to unbudgeted costs stemming from the relocation of the Redcliffs School, in particular traffic improvements required to mitigate safety concerns.     This would likely result in budget having to be diverted from planned improvements elsewhere.

7.12.1 Residual risk rating: The residual rating of the risk after the response below is implemented will be Low.

7.12.2 This risk can be minimised by negotiations with the Ministry of Education, and by a condition on the designation requiring traffic improvements to be safety audited and implemented before the use of the site for a school commences.


7.13    Implementation dependencies - Nil in regard to the provision of Council’s views on the draft Proposal to Regenerate Christchurch.

7.14    Implementation timeframe – Under Section 16 of the GCRA, Council has 30 working days to respond on the draft Proposal. This timeframe expires on 21 November.

Option Summary - Advantages and Disadvantages

7.15    The advantages of this option include:

·   See 4.3 above

7.16    The disadvantages of this option include:

·   None identified.








Draft Council Response on Redcliffs Section 71 Proposal



Draft Redcliffs School Section 71 Proposal



Process Diagram - Section 71 GCRA




Confirmation of Statutory Compliance

Compliance with Statutory Decision-making Requirements (ss 76 - 81 Local Government Act 2002).

(a) This report contains:

(i)  sufficient information about all reasonably practicable options identified and assessed in terms of their advantages and disadvantages; and

(ii) adequate consideration of the views and preferences of affected and interested persons bearing in mind any proposed or previous community engagement.

(b) The information reflects the level of significance of the matters covered by the report, as determined in accordance with the Council's significance and engagement policy.




Glenda Dixon - Senior Planner

Approved By

Richard Osborne - Head of Planning and Strategic Transport

Brendan Anstiss - General Manager Strategy and Transformation



09 November 2017


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