BEFORE THE CHRISTCHURCH REPLACEMENT
DISTRICT PLAN INDEPENDENT HEARINGS PANEL
IN THE MATTER
of the Resource
Management Act 1991 and
the Canterbury Earthquake
(Christchurch Replacement
District Plan) Order 2014
AND
IN THE MATTER
of the Definitions Proposal
(Stages 2 and 3)
STATEMENT OF REBUTTAL EVIDENCE OF JANINE ELIZABETH SOWERBY
ON BEHALF OF CHRISTCHURCH CITY COUNCIL
DEFINITIONS GENERAL OVERVIEW
10 MARCH 2016
Barristers & Solicitors
S J Scott / A O J Sinclair
Telephone: +64-3-968 4023
Facsimile: +64-3-379 5023
Email: [email protected]
PO Box 874
SOLICITORS
CHRISTCHURCH 8140
1.
INTRODUCTION
1.1
My full name is Janine Elizabeth Sowerby. My qualifications and experience
are set out in my evidence in chief for the Stage 2/3 Definitions Hearing.
1.2
I confirm that I have read the Code of Conduct for Expert Witnesses
contained in the Environment Court Practice Note 2014 and that I agree to
comply with it. I confirm that I have considered all the material facts that I
am aware of that might alter or detract from the opinions that I express,
and that this evidence is within my area of expertise except where I state
that I am relying on the evidence of another person. The Council, as my
employer, has agreed to me giving expert evidence on its behalf in
accordance with my duties under the Code of Conduct.
2.
SCOPE
2.1
I confirm that I have read the submitter evidence filed on 3 March 2016.
The relevant chapter leads have addressed evidence on specific
definitions where required.
The scope of my evidence is limited to
responding to the evidence of Ms Barker for the Crown (#2387 and #3721).
2.2
Since filing of Council and submitter evidence in chief for this hearing, the
Panel has issued Decision 16 Chapter 1 Introduction (part) and Chapter 2
Definitions (part) Stage 1, dated 7 March 2016 (Definitions Decision).
2.3
At Attachment A are the definitions that have been recommended to be
amended through Council's rebuttal evidence (this is not a full Revised
Proposal). I note that the Council has lodged a memorandum dated 9 March
2016 outlining its intention to file an updated Revised Proposal on 16 March
2016.
That updated Revised Proposal will incorporate the Stage 2 and 3
definitions into the text in the Definitions Decision, will include changes made
through Council's rebuttal evidence and address any other anomalies
identified in the 24 February Revised Proposal (e.g. identify consequential
amendments).
2.4
At Attachment B I list definitions that are relevant to the on-going mediations
for Chapter 9.
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3.
MS BARKER FOR THE CROWN
Duplication
3.1
Ms Barker has recognised that the Revised Proposal attached to my evidence
in chief contained some residual duplication.
I agree with Ms Barker's
recommendation that duplication be avoided where possible. I confirm that
through Council's rebuttal evidence, the following duplication has now been
reduced1:
(a)
Accessory building (non-residential activity) - Scott Blair rebuttal;
(b)
Accessory building (residential activity) Scott Blair rebuttal;
(c)
Earthworks - Andrew Long rebuttal;
(d)
Education activity - Glenda Dixon rebuttal;
(e)
Sensitive activities – Glenda Dixon rebuttal;
(f)
Surface water management structure – Glenda Dixon rebuttal.
Care facility and care facilities
3.2
In the Revised Proposal of 24 February 2016 there was potential duplication of
definitions for Care facility and Care facilities. The definition of Care facility
has been the subject of the Panel's Definitions Decision. Care facilities was
notified in Stage 2 and was slightly amended in the 24 February Revised
Proposal, to correct the title of the standards referred to therein.
Clean
versions of the latest forms of the definitions are as follows:
Care facility
means a facility providing rest home care within the meaning of the
Health and Disability Services (Safety) Act 2001, or a home for the
residential care of people with special needs, and/or any land or
buildings used for the care during the day of elderly persons or
people with special needs.
1
In the 24 February 2016 Revised Proposal there was also duplication of height, places of assembly, and pre-school /
pre-school activity. This duplication will be dealt with through the Council's response to the Panel's Definitions
Decision (and shown in the Revised Proposal for this hearing which is to be filed on Wednesday 16 March 2016).
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Care facilities
means land or buildings certified under the Health and Disability
Services (Safety) Act 2001, compliant with the Health and Disability
Services Standards 2008 and used for the provision of full-time
accommodation and care for people with special needs, including:
(a)
rest homes defined in Section 58(4) of the Health and
Disability Services (Safety) Act 2001;
3.3
(b)
palliative facilities;
(c)
accessory nursing and medical care;
(d)
care homes for aged or disabled people; and
(e)
care homes for children.
Care facility and/or Care facilities are used in the Commercial and Transport
Proposals.
Mark Stevenson in his evidence in chief for Stage 2 and 3
Definitions Proposal considered the Stage 2 definition.2 He recommended that
the reference to the Health and Disability Services Standards 2008 be
updated. All other amendments sought by submitters to the definition in that
proposal were rejected. At the time of evidence in chief for the definitions
hearing, the duplication of the Care facility and Care facilities definitions was
not addressed.
3.4
Except for Ms Barker's evidence that duplication be removed from the
Definitions Proposal, no submitter evidence on the Stage 2 definition of Care
facilities has been provided.
Mr Stevenson and Mr Falconer have since
confirmed that, as the two definitions are substantially the same, there is no
need for the Stage 2 definition of Care facilities. Mr Stevenson has noted that
the updated reference to the Standards does not need to be made to the
Decision 16 definition.
Site
3.5
In the 24 February 2016 Revised Proposal there were two definitions for Site
(the Stage 1 final version of Council and a Stage 2 version). The Definitions
Decision has included a definition for Site. I consider duplication can be
reduced by the differences provided by the Stage 2 version being incorporated
into the Decision Version. This is best done by carrying over the additional
text shown in the 24 February 2016 Revised Proposal at clause (g) relating to
2
Evidence in chief of Mark Stevenson in relation to the Stage 2 and 3 Definitions dated 24 February 2016 at
paragraphs 5.3 to 5.6.
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parking at the University of Canterbury. This combined change is set out at
Attachment A.
4.
CHAPTER 9 DEFINITIONS
4.1
As recognised by Ms Barker in section 7 of her evidence, a number of
definitions are part of the ongoing mediations for the Natural and Cultural
Heritage hearing. I agree with Ms Barker that it would be most appropriate for
the discussions on those definitions to continue through that mediation
process, with updates provided for the definitions hearing as and when
required.
For completeness, I record that the 24 February 2016 Revised
Proposal includes the Council's recommended changes to those definitions up
until that point in time.
4.2
The Council's rebuttal evidence has not responded to the submitter evidence
on definitions that are the subject of the Chapter 9 hearing, leaving those
discussions to continue in the Natural and Cultural Heritage mediation. For
completeness, I set out at Attachment B the definitions specific to Natural and
Cultural Heritage that are still open for consideration.
Janine Elizabeth Sowerby
10 March 2016
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ATTACHMENT A
Extracts of the Revised Proposal showing changes as a result of Council rebuttal
evidence
Key:
Grey text
Stage 1 definitions (where they were not decided through Decision 16, ie
deferred definitions)
Green text
Stage 1 definitions as a result of Decision 16
Black text
Stage 2 definitions
Shaded text
Stage 3 definitions
Red underline and strikethough
Changes made to the revised proposal in the Council's evidence in chief for
the definitions hearing.
Purple underline and
Changes made to the definitions in the Council's rebuttal evidence for the
strikethough
definitions hearing.
The rebuttal evidence supporting the change is shown in square brackets after
the change.
Note that reliant definitions have not been included below but will be included in the 16 March 2016 version of the
Revised Proposal.
Accessory building
[Scott Blair rebuttal evidence dated 10-3-16 – Recommended as a result of combining the definitions of
"accessory building (residential)" and "accessory building (non-residential)"]
means a building which is incidental to the principal building or buildings on the site. In respect of land used for
residential activity, accessory building includes a sleep-out, garage or carport, shed, glasshouse, fence, solar
panels and solar water-heating devices not attached to a building and an indoor swimming pool, but not a family
flat, balcony or similar structure (whether free-standing or attached to any building). An accessory building is not
a residential unit. On a vacant site, accessory building is a building that is ancillary of accessory to any activity
that may be permitted on a site regardless of whether the principal building or buildings have yet to be
constructed.
Accessory building (non-residential activity)
means a building which is incidental to the principal building or buildings on the site. An accessory building is not
a residential unit. On a vacant site, accessory building is a building that is ancillary or accessory to any
activity that may be permitted on a site regardless of whether the principal building or buildings have yet to be
constructed.
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Accessory building (residential activity)
means a building which is incidental to the principal building or buildings on the site. In respect of land used for
residential activity, accessory building includes a sleep-out, garage or carport, shed, glasshouse, fence, solar
panels and solar water-heating devices not detached from a building and an indoor swimming pool. Accessory
building does not include a balcony or similar structure (whether free-standing or attached to any building). An
accessory building is not a residential unit. On a vacant site, accessory building is a building that is ancillary or
accessory to any activity that may be permitted on a site regardless of whether the principal building or buildings
have yet to be constructed.
Aircraft operations
means:
a.
the landing and take off of aircraft; and
b.
aircraft flying along any flight path associated with a landing or take off.
For the purposes of Rules 6.1.4.2.7 and 6.7 [Glenda Dixon rebuttal evidence dated 10-3-16], aircraft operations
exclude:
c.
aircraft operating in an emergency for medical or national/civil defence reasons;
d.
air shows;
e.
military operations not associated with the Antarctic programme;
f.
aircraft using the airport as an alternative to a scheduled airport elsewhere;
g.
aircraft taxiing; and
h.
aircraft engine testing.
Air noise boundary
means a composite line formed by the outer extremity of the 65 dBA Ldn noise contour and the SEL Lae 95 dBA
noise contour. It defines an area around Christchurch International Airport within which the future daily aircraft
noise exposure is sufficiently high as to require restrictions on land use prohibition on new noise sensitive
activities [Glenda Dixon rebuttal evidence dated 10-3-16], to avoid adverse noise effects.
BOD5
[has the same meaning as s18.6 of the Thresholds and Classifications under the Hazardous Substances and
New Organisms Act 1996, January 2012]
means the five-day biochemical oxygen demand, being the mass of oxygen consumed by micro-organisms
during oxidation of the substance in water over five days, expressed in milligrams of oxygen consumed per
milligrams of the substance. [Scott Blair rebuttal evidence dated 10-3-16]
Care facility
means a facility providing rest home care within the meaning of the Health and Disability Services (Safety) Act
2001, or a home for the residential care of people with special needs, and/or any land or buildings used for the
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care during the day of elderly persons or people with special needs.
Care facilities
means land and/or buildings certified under the Health and Disability Services (Safety) Act 2001, compliant with
the Health and Disability Sector Services Standards 20018 [Chapter 2 Definitions Evidence in Chief Mark
Stevenson dated 24-02-16, #2123.4 CCC] and used for the provision of full-time accommodation and care for
people with special needs, including:
a.
rest homes defined in Section 58(4) of the Health and Disability Services
(Safety) Act 2001;
b.
palliative facilities;
c.
accessory nursing and medical care;
d.
care homes for aged or disabled people; and
care homes for children.
[Janine Sowerby rebuttal evidence dated 10-3-16]
Corrosive substance
means a substance that has the capability of breaking down metal or human tissue on contact. [Scott Blair
rebuttal evidence dated 10-3-16]
Earthworks
means any filling, excavation, deposition of or other disturbance of earth, rock or soil on a site, including:
a.
raising of the ground level or changes the profile of the landform; or
b.
earthworks including or inserting other materials into the ground for the purposes of repairing a site
damaged by earthquakes or strengthening a site in preparation for the construction of a building; or
c.
earthworks in relation to the installation of services or utilities; or
d.
the construction of tracks, firebreaks and landings; or
e.
root raking and blading.
Earthworks do not include the disposal of earthquake waste on a site within the Specific Purpose (Burwood
Landfill and Resource Recovery Park) Zone. [Incorporated through Andrew Long rebuttal evidence dated 10-316]
Earthworks
means any excavation, depositing or other disturbance of earth, rock, sand or soil on a site, including that which
raises ground level or changes the profile of the landform, and that which involves the inclusion or insertion of
other materials into the ground for the purposes of repairing a site damaged by earthquakes or strengthening a
site in preparation for the construction of a building, or the installation of services or utilities. Earthworks include
the construction of tracks, firebreaks and landings, and ground shaping (recontouring), root raking and blading.
[Andrew Long rebuttal evidence dated 10-3-16]
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Earthworks
means any excavation, depositing or other disturbance of earth, rock, sand or soil on a site, including that which
raises ground level or changes the profile of the landform, and that which involves the inclusion or insertion of
other materials into the ground for the purposes of repairing a site damaged by earthquakes or strengthening a
site in preparation for the construction of a building, or the installation of services or utilities. Earthworks include
the construction of tracks, firebreaks and landings, and ground shaping (recontouring), root raking and blading.
Earthworks do not include the disposal of earthquake waste on a site within the Specific Purpose (Burwood
Landfill and Resource Recovery Park) Zone. [Andrew Long rebuttal evidence dated 10-3-16]
Eco-toxic
[has the same meaning as s2(1) of the Hazardous Substances and Natural New Organisms Act 1996]
means capable of causing ill health, injury, or death to any living organism. [Scott Blair rebuttal evidence dated
10-3-16]
Explosive substance
means a substance that has the capability of sudden expansion due to a release of internal energy. [Scott Blair
rebuttal evidence dated 10-3-16]
Flammable/Flammability
[has the same meaning as s3.2 of the Thresholds and Classifications under the Hazardous Substances and New
Organisms Act 1996, January 2012]
means the ability of a substance to be ignited and to support combustion in air at 20°C and 101.3 kPa absolute
pressure. [Scott Blair rebuttal evidence dated 10-3-16]
Hazardous substance
means:
a.
any substance or mixture or formulation of substances which has one or more of the following intrinsic
properties, and exceeds any of the minimum degrees of hazard for the following hazards prescribed in
the Hazardous Substances (Minimum Degrees of Hazard) Regulations 2001:
b.
i.
explosiveness (excluding dust explosions);
ii.
flammability;
iii.
a capacity to oxidise;
iv.
corrosiveness;
v.
acute and chronic toxicity; and
vi.
eco-toxicity, with or without bio-accumulation;
substances which, in contact with air or water (other than air or water where the temperature or pressure
has been artificially increased or decreased), generate a substance or reaction with any one or more of
the properties specified in a. above;
c.
substances that, when discharged to surface or groundwaters, have the potential to deplete oxygen as a
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result of the microbial decomposition of organic materials (for example, milk or other foodstuffs); and
d.
radioactive substances, except smoke detectors.
But for the purposes of Rule 12.1.2.2.2 (NC1) excludes substances in the following activities or facilities and/or
quantities:
e.
storage of substances in or on vehicles being used in transit on public roads;
f.
installations where the combined transformer oil capacity of the electricity transformers is less than
1,000l;
g.
fuel in mobile plant, motor vehicles, boats and small engines;
h.
gas and oil pipelines and associated equipment that are part of a utility;
i.
retail outlets selling domestic scale usage of hazardous substances, such as supermarkets, trade
suppliers, and pharmacies.
j.
the accessory use and storage of hazardous substances in minimal domestic scale quantities;
k.
fire-fighting substances, and substances required for emergency response purposes on emergency
service vehicles and at emergency service facilities
l.
activities involving substances of HSNO sub-classes 1.4, 1.5, 1.6, 6.1D, 6.1E, 6.3, 6.4, 9.1D and 9.2D
unless other hazard classification applies;
m.
the temporary storage, handling and distribution of national or international cargo containers;
n.
waste treatment and disposal facilities (not within High Flood Hazard areas and Flood Management
Areas), and waste in process in the Council's trade waste sewers, municipal liquid waste treatment and
disposal facilities (not within High Flood Hazard areas and Flood Management Areas) which may
contain hazardous substance residues;
o.
vehicles applying agrichemicals and fertilisers for their intended purpose.
[Scott Blair rebuttal evidence dated 10-3-16]
Major Sports Facility
means the use of land, buildings, and/or structures principally for public or private major sport activity,
whether a charge is made for admission or not. Includes has the same meaning as Minor Sports Facility
except that it additionally includes but is not limited to the following:
a.
Stadium (covered and open air);
b.
Indoor sports and recreation facility;
c.
Swimming pool complex / aquatic centre (covered and open air);
d.
Golf driving range and/or golf course;
e.
Equestrian raceway and showgrounds, including ancillary buildings, such as stables, and
servicing facilities;
f.
Athletics facilities and structures, including running tracks;
g.
Accessory club rooms / clubhouse;
h.
Accessory spectator grandstands;
i.
Boat ramp, jetty and recreational boat launching facility; and
j.
Boat storage, and sheds, and repair and maintenance facilities workshops.
Major sports facility excludes motorised sport facility. [Janice Carter rebuttal evidence dated 10-3-16]
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Minor Sports Facility
means the use of land, buildings, and/or structures principally for public or private minor sport activity, whether a
charge is made for admission or not. Includes but is not limited to the following:
a.Informal and formal playing fields, including ancillary structures such as goal posts;
b.Ball courts and artificial playing surfaces;
c. Golf driving range;
d.Skateboard park;
e.BMX tracks;
f. Mountain bike tracks;
h.Accessory lighting, including support structures; and
i. Accessory spectator seating.;and
j. Accessory club rooms/ clubhouse.
Minor sports activity excludes motorised sports facility.
[Janice Carter rebuttal evidence dated 10-3-16]
Primary explosive substance
[has the same meaning as s2.2 of the Thresholds and Classifications under the Hazardous Substances and New
Organisms Act 1996, January 2012]
means a substance that:
a.
has the necessary sensitivity to heat, friction, or shock to make it suitable for initiating secondary
detonating explosive substances and articles; and
b.
when incorporated into an explosive article, is known as a primer or detonator. [Scott Blair rebuttal
evidence dated 10-3-16]
Propellant explosive substance
[has the same meaning as s2.2 of the Thresholds and Classifications under the Hazardous Substances and New
Organisms Act 1996, January 2012]
means a substance that deflagrates (that is, capable of a steady high rate of production of gas sufficient to
generate a force capable of producing movement or physical change, the rate of gas production under
confinement is able to result in a detonation). [Scott Blair rebuttal evidence dated 10-3-16]
Recreation activity
means the use of land, water bodies, and/or buildings for the purpose of principally for the active or passive
enjoyment of sports, recreation or leisure, whether competitive or non-competitive, casual or organised, and
whether a charge is made for admission or not. Excludes Motorised Sports Activity.
[Janice Carter rebuttal evidence dated 10-3-16]
Sensitive activities
means:
a.
residential activities, including care facilities;
b.
education activities;
c.
guest accommodation; and
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d.
health care facilities which include accommodation for overnight care;
e.
custodial and/or supervised living accommodation where the residents are detained on the site;
but in relation to airport noise excludes:
f.
any residential activities in conjunction with rural activities that comply with the rules in the relevant
district plans as at 23 August 2008;
g.
flight training or other trade and industry training facilities located on land zoned or legally used for
commercial or industrial activities, including the Specific Purpose (Airport) Zone; and
h.
guest accommodation, which is designed, constructed and operated to a standard to mitigate the
effects of aircraft noise on occupants." and
i.
health care facilities with no accommodation for overnight care. [Glenda Dixon rebuttal evidence dated
10-3-16]
Site
means an area of land or volume of space shown on a plan with defined boundaries, whether legally or otherwise
defined boundaries, and includes:
a.
an area of land which is:
i.
comprised in a single allotment, or other legally defined parcel of land, and held in a single
certificate of title; or
ii.
comprised in a single allotment or legally defined parcel of land for which a separate certificate
of title could be issued without further consent of the Council;
being in any case the smaller land area of (i) or (ii); or
b.
an area of land which comprises two or more adjoining legally defined parcels of land held together in
one certificate of title in such a way that the lots cannot be dealt with separately without prior consent of
the Council; or
c.
an area of land which is comprised of two or more adjoining certificates of title where such titles are:
i.
subject to a condition imposed under Section 77 of the Building Act 2004 or;
ii.
held together in such a way that they cannot be dealt with separately without the prior consent
of the Council; or
d.
in the case of land subdivided under the cross lease or company lease systems (other than strata titles),
site shall mean an area of land containing:
i.
a building or buildings for residential or business purposes with any accessory building(s), plus
any land exclusively restricted to the users of that/those building(s); or
ii.
a remaining share or shares in the fee simple creating a vacant part(s) of the whole for future
cross lease or company lease purposes; or
e.
in the case of land subdivided under the Unit Titles Act 1972 and Unit Titles Act 2010 (other than strata
titles), site shall mean an area of land containing a principal unit or proposed unit on a unit plan together
with its accessory units; or
f.
in the case of strata titles, or where one or more residential unit is proposed to be erected above another
residential unit, site shall mean the underlying certificate of title of the entire land containing the strata
titles, immediately prior to subdivision; or
g.
for the purposes of the activity standards (but not the built form or general city-wide standards) in the
Specific Purposes (Schools) and Specific Purposes (Tertiary Education) Zones, site means all of the
land used by a particular education or tertiary education or research facility, whether or not those parcels
of land are contiguous with each other. For the purposes of car parking requirements at the
University of Canterbury Specific Purpose (Tertiary Education) Zone, Appendix 7.1 (9) applies.
Site also shall include the access to the site.
[Incorporated through Janine Sowerby rebuttal evidence dated 10-3-16]
Spring
means a spring is where the point where groundwater driven by artesian pressure emerges to the surface and
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forms a pool, the head of a water body, or discharges into within or to a water body either on a permanent or
intermittent basis on a permanent or intermittent basis.
[Alison McLaughlin rebuttal evidence dated 10 March 2016]
Temporary activities and buildings
for the purpose of Chapter 6, means activities and their ancillary buildings that are intended to have a limited
duration and incidence (one-off, infrequent, transitional or with a defined end date, as opposed to regular and
ongoing) and:
a.
where utilising a permanent facility, are not part of a the permanent activity that occurs on the site
therein; and [Alison McLaughlin rebuttal evidence dated 10-3-16]
b.
create no, or only negligible, lasting alteration or disturbance to any site, building or vegetation.
Temporary activities and buildings includes:
c.
temporary activities and buildings following, and to assist in recovery from, a natural disaster, such as
the temporary relocation of activities and buildings, storage yards, workers’ temporary accommodation,
the temporary raising of buildings for foundation repairs, public artworks and recreation and
entertainment activities; and
d.
public artworks and recreation and entertainment activities; and
e.
the provision of car parking ancillary to a temporary activity, whether sealed or unsealed, provided in
accordance with an approved Traffic Management Plan or a Reserve Management Plan, except as
otherwise specified in Section 6.4.
Temporary activities and buildings does not include:
f.
temporary utilities, which must comply with the relevant provisions in Chapter 11.
Note: Temporary buildings are required to comply with the provisions of the Building Act 2004.
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Attachment B
Definitions that are part of the on-going Natural and Cultural Heritage mediations
In the table below I have identified definitions that are primarily used in the Natural and Cultural
Heritage Proposal, as these definitions may still be the subject of further change through the
ongoing Natural and Cultural Heritage mediation. It is considered that the generic definitions
used in the Natural and Cultural Heritage Proposal are unlikely to be the subject of further
change through the Natural and Cultural Heritage mediation.
In the right-hand column of the table below I have listed where submitter evidence for the
definitions hearing has identified definitions that are the subject of the ongoing Natural and
Cultural Heritage mediation and further work programme. The purpose of this is to assist the
Panel by showing where definitions are likely to be the subject of further discussions in the
Natural and Cultural Heritage mediation (although discussions are not necessarily required to be
limited to the definitions identified).
For completeness, I note that Mr Andrew Long has addressed the definition of Environmental
compensation in his definitions rebuttal evidence for the Council. Mr Long is not party to the
ongoing Natural and Cultural Heritage mediation, therefore it was considered appropriate for him
to address the definition through rebuttal evidence.
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List of definitions within scope of Natural Cultural Heritage Hearing
Definition
(* = subject of submission)
Alternation of a heritage item*
Alteration of a heritage setting*
Christchurch City
Conservation activities*
Customary harvesting*
Demolition*
Dripline*
Farming*
Heritage fabric*
Heritage investigative and temporary
works*
Heritage item*
Heritage setting*
Heritage upgrade works*
Heritage values*
Historic heritage*
Historic heritage place*
Indigenous biodiversity*
Indigenous fauna*
Indigenous vegetation*
Raised in submitters' definitions evidence
Ms Barker (at page 20) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 20) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Legarth, para 5 to 7 – no remaining issue.
Ms Barker (at page 22) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 23) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 26) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Mackenzie paragraph 8 – identifies this definition
as part of ongoing Natural and Cultural Heritage
discussions.
Ms Barker (at page 28) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 29) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 29) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 29) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 29) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 30) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 30) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 30) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 30) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Legarth, paragraphs 8 and 9.
Indigenous vegetation clearance*
Maintenance*
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Ms Mackenzie paragraph 8 – identifies this definition
as part of ongoing Natural and Cultural Heritage
discussions.
Ms Barker (at page 31) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Mackenzie paragraph 8 – identifies this definition
as part of ongoing Natural and Cultural Heritage
discussions.
Ms Barker (at page 32) identifies definition as being
considered through ongoing Proposal 9 mediation.
Minor pruning
Naturalness
Ngāi Tahu/Manawhenua
Partial demolition
Plantation forestry*
Reconstruction*
Relocation of a heritage item*
Repairs*
Restoration*
Ms Barker (at page 34) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 35) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 36) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 36) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 36) identifies definition as being
considered through ongoing Proposal 9 mediation.
Significant indigenous vegetation
Silent files
Site of Ngāi Tahu cultural
significance*
Ms Legarth paragraphs 16 to 18.
Ms Legarth paragraphs 16 to 18.
Spring
Ms Mackenzie paragraph 8 – identifies this definition
as part of ongoing Natural and Cultural Heritage
discussions.
Ms Legarth 11 to 14 – addressed in Ms McLaughlin's
rebuttal evidence.
Ms Legarth paragraphs 16 to 18.
Ms Legarth paragraphs 16 to 18.
Wāhi tapu
Wāhi taonga
Submitter requested definitions:
Definition
Biodiversity offset, net loss, net gain
Conservation plan
Cultural heritage
Cultural heritage sites
Environmental compensation
Raised in submitters' definitions evidence
Ms Mackenzie paragraph 8 – identifies biodiversity
offset as part of ongoing Natural and Cultural Heritage
discussions.
Ms Barker (at page 22) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 22) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 25) identifies definition as being
considered through ongoing Proposal 9 mediation.
Note this has been addressed in Mr Long's rebuttal
evidence for the Council.
Environmental service
Heritage
Heritage area
Heritage conservation
Improved pasture
Ms Barker (at page 28) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 28) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 30) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Mackenzie paragraph 8 – identifies this definition as
part of ongoing Natural and Cultural Heritage
discussions.
27472300_1.doc
Intensive farming
Maintenance3
Partial demolition
Preservation
Preservation (Heritage)
Protective material
Regenerated indigenous vegetation
Reinstatement
Sites of ecological significance
Stabilisation
3
Ms Mackenzie paragraph 8 – identifies this definition as
part of ongoing Natural and Cultural Heritage
discussions.
Ms Barker (at page 33) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 35) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Barker (at page 35) identifies definition as being
considered through ongoing Proposal 9 mediation.
Ms Mackenzie paragraph 8 – identifies this definition as
part of ongoing Natural and Cultural Heritage
discussions.
Ms Barker (at page 39) identifies definition as being
considered through ongoing Proposal 9 mediation.
With respect to indigenous vegetation-related fencing, etc, as opposed to the existing Stage 3 Maintenance definition
specific to heritage items and settings.
27472300_1.doc