Issues and options paper for coastal hazards plan change

We are at the start of this plan change process and we want to hear from you. We have a preferred option that we believe would best manage coastal hazards in the District Plan. However, before we go any further we want to hear what you think.

Project status: Closed
Consultation open: 8th October 2021 - 6th December 2021

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The Christchurch City Council needs to make changes to its District Plan to avoid new developments being exposed to coastal hazards such as flooding (including tsunami) and erosion, and also to ensure Council meets its legal obligations under the Resource Management Act.

Coastal hazards have the potential to affect a large number of people and communities along the coastline and in low-lying parts of our district. The risks associated with these hazards for property, people and the wider community are likely to intensify as the impacts of climate change increase.

We've developed an Issues and Options Discussion Paper as a first step in the Plan Change process. It identifies how coastal hazards might affect communities across Christchurch and Banks Peninsula, discusses the issues that we are facing and why we need to change the District Plan, and sets out a range of options for how the District Plan could manage the risks associated with these hazards.

No decisions have been made yet, and nothing will change until we've been through the full plan change process. Feedback on the Discussion Paper will to help shape the draft Plan Change. 

Read the Coastal Hazard Plan Change Issues and Options Discussion Paper [PDF, 1.1 MB]

The objectives we are seeking to achieve from this Plan Change reflect those from the Resource Management Act, New Zealand Coastal Policy Statement and Regional Policy Statement:

  • Ensuring that coastal hazard risks are addressed by managing activities in areas prone to coastal hazards, having regard to the level of risk. This aligns with our responsibilities to implement national and regional direction that seeks the following:
    • Management of significant risks of natural hazards, (section 6(h) of the Resource Management Act), and controlling potential effects of the use of land including for the purpose of avoiding or mitigating natural hazards (section 31(1)(b) of the Resource Management Act).
    • New subdivision, use and development is to be avoided where it increases risks associated with coastal hazards (Objective 11.2.1 of the Canterbury Regional Policy Statement).
  • Enabling people and communities to provide for their social, economic and cultural well-being and their health and safety through subdivision, use and development (Objective 6 of the New Zealand Coastal Policy Statement).

Risk-based approach to coastal hazards

This is our preferred option. It involves managing activities according to the level of risk in that location, acknowledging the uncertainty (of when land may be affected by rising sea levels) and the vulnerability of the activity to risk.

It reflects the approach taken to other hazards in the District Plan (areas identified at a higher risk of river flooding that could cause harm are classified as High Hazard Management Areas. Similarly on the Port Hills, a graduated approach is taken with a more restrictive set of rules applying to properties subject to a higher risk of rock fall, cliff collapse and mass movement compared with other areas where there is a lower risk.). It is also consistent with international risk management best practice(external link).

It recognises that the level of risk is not the same in every location and that a range of restrictions should therefore apply to reflect the circumstances in different areas.

The risk-based approach to coastal hazards would limit land use, development and subdivision in areas at High risk, and would remove or reduce the opportunities for further investment and development in some of these areas. 

In areas of Lower to Medium risk, there would continue to be development opportunities with people still able to extend their house, subdivide their property, and change the use of a building. However, there would be conditions on land use and development to improve the adaptability and resilience of any future development.

Maps showing areas of Very Low, Low, Medium and High risk, along with information about how we have determined these risk classifications can be found here.

Read the full detail on this option in the Issues and Options Discussion Document. 

 

Minimal changes (do minimum)

This option bolsters existing District Plan policies and rules with practical methods that would better manage risk, for example, requirements to raise floor levels and identifying areas of high risk where subdivision, land use and development would be restricted.

This option involves relying on the existing objective of the District Plan below, which is generic to all hazards.

New subdivision, use and development (other than new critical infrastructure or strategic infrastructure)… is to be avoided in areas where the risks from natural hazards to people, property and infrastructure are assessed as being unacceptable’, while ensuring that the ‘risks of natural hazards to people, property and infrastructure are appropriately mitigated’ in other areas (Objective 3.3.6 of the Christchurch District Plan).

The existing objective aligns with direction in the New Zealand Coastal Policy Statement and Regional Policy Statement and is therefore included as part of this option. However, the methods of achieving this objective, described below, would not give effect to either document to the extent that Option 1 would.

The change to the existing District Plan would be in the methods to achieve the existing objective including:

  • Definition of coastal hazards on the planning maps
  • Requirements for higher floor levels
  • Inclusion of additional matters of discretion to enable assessment of the risks to subdivision, land use and development from coastal hazards
  • Reliance would otherwise be on existing rules, where resource consent is already required for other reasons, to assess the risks of coastal hazards.

Methods of implementation in District Plan:

  • Application of Objectives and Policies to the assessment of resources consents
  • District Plan Rules & standards for flood hazard areas, which include coastal as well as inland areas.

This option is not preferred because land use, development and subdivision would likely continue to occur in areas at risk of coastal hazards, where resource consent is obtained, including on sites subject to coastal flooding and erosion over the next 100 years and beyond. This means there is a high likelihood that people and communities are exposed to harm/adverse effects at some time in the future. The lack of specific provisions also creates uncertainty for those living in and developing the area, and there is a risk of ad hoc and inconsistent decisions.

Avoiding activities that increase risk across the District.

This option would seek to avoid all land use, development, and subdivision that increases any level of risk of harm or adverse effects from coastal hazards – within and outside of the existing urban areas.

Development, subdivision and land use activities would only be allowed where it can be demonstrated that there is no increase in ‘adverse effects’ – which means everything from physical effects on people and property, to environmental, economic, financial, social or other effects.

Opportunities for development, changes in land use, and improvements to existing developments would therefore be limited in affected areas. ‘Non-complying’ activity status would apply to subdivision and development, being activities that are not generally consistent with objectives of the District Plan and subject to additional requirements.

Methods of implementation in District Plan:

  • Objectives and policies that seek to avoid new development in identified coastal hazard areas.
  • Restrictive activity status requiring resource consent for most development, land use and subdivision.
  • Non habitable buildings and recreational activities would continue to be enabled subject to meeting standards.

While this option provides the greatest resilience to future events, it is not preferred because it does not differentiate between relative levels of risk, and would therefore not reflect that the risk in one location could be quite different to another. We have a much better understanding of the different levels of risk and can respond accordingly.

Limitations on new development and increased costs are unlikely to be justified across the existing urban area, and outside of it. Option 3 would therefore be unduly restrictive.

Avoiding activities that increase risk outside the existing urban area while enabling a risk-based approach within the existing urban area

This option is a two-pronged approach, comprising elements of options 1 (risk-based approach) and 3 (avoiding activities):

  • It would seek to avoid land use, development, and subdivision that increase the risk of harm or adverse effects from coastal hazards, outside of the urban area.

The opportunities for development and land use would be limited under this option unless it could be demonstrated that there is not an increased risk of harm or adverse effect. This would preclude further urban growth in areas where there is increased risk beyond the existing urban area.

  • In the existing urban area, it would take an approach of managing the risk to new development and changes in land use.
    Within urban areas, a managed approach would enable development and land use activities to occur in areas of lower risk while limiting development and land use activities in areas at high risk, removing or reducing the opportunities for further investment and development.

Urban areas includes those areas that are zoned for residential, commercial or industrial activities in the District Plan, are already built up and are serviced by infrastructure. The Canterbury Regional Policy Statement defines existing and future urban areas in Map A.

Methods of implementation in District Plan:

  • A combination of Options 1 & 3 above.

This option is not preferred because it does not reflect the differences in the nature of the hazard which has a strong influence on the level of risk. As a result, there could be unnecessary restrictions on people’s ability to develop outside the urban area. Conversely, within urban areas, it may not adequately manage development in areas at higher risk where avoidance may be more appropriate.

We will consider the feedback received on the Issues and Options Discussion Paper, and then prepare a draft change to the District Plan. This will include objectives, policies and rules. Currently we are planning to have a draft Plan Change completed in the first half of 2022.

We're then proposing to formally notify the Plan Change under the Resource Management Act in the third quarter of 2022. After this, further submissions can be made, supporting or opposing what others have said. This will be followed by a hearing before an panel of independent commissioners who will make recommendations to Council on whether the Plan Change is approved or rejected. By appointing an independent panel, we want to ensure there is thorough testing of the Plan Change and supporting documents. 


Come and talk to us

Drop in any time to discuss the Issues and Options Discussion Paper with the Project Team, and ask any questions you might have. We'll also have staff at these sessions to answer your questions on the Coastal Hazards Assessment, and the Coastal Adaptation Planning Programme

  • Monday 18 October 2021 — any time between 2.30pm and 6.30pm. Governors Bay Community Centre, 1 Cresswell Avenue, Governors Bay
  • Thursday 21 October 2021 — any time between 2.30pm and 6.30pm. North New Brighton Community Centre, 93 Marine Parade, New Brighton
  • Friday 22 October — any time between 2.30pm and 6.30pm. South New Brighton Community Hall, 74 Beatty Street, South New Brighton
  • Tuesday 26 October 2021 — any time between 2.30pm and 6.30pm. Parklands Recreation Centre, 75 Queenspark Drive, Parklands
  • Monday 1 November 2021 — any time between 2.30pm and 6.30pm. Matuku Takotako: Sumner Centre, 14 Wakefield Ave, Sumner
  • Tuesday 2 November — any time between 2.30pm and 6.30pm. Woolston Community Library, 689 Ferry Road, Woolston
  • Wednesday 3 November — any time between 2.30pm and 6.00pm. Gaiety Hall, 104 Rue Jolie, Akaroa

Please note, these sessions may need to be postponed or cancelled if COVID alert levels change. 

Can't make these drop-in sessions? If there is a community meeting you would like us to attend, please let us know

The Coastal Hazards Plan Change is about managing new development, changes of use and subdivision proposed in the future. Reducing risks to existing land use activities and development will be considered through the Coastal Hazards Adaptation Planning programme.

Find out more information about the Coastal Hazards Adaptation Planning programme

You can also have your say on the Coastal Hazard Adaptation Planning Programme's Coastal Adaptation Framework(external link) - a proposed approach for how we will work with communities to develop adaptation pathways that respond to natural hazards.

 

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Who to contact

Mark Rushworth,
Senior Planner

How the decision is made

  • Closed