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BEFORE THE ENVIRONMENT COURT AT CHRISTCHURCH ENV-2013-CHC-019 IN THE MATTER of of the Resource Management Act 1991 AND IN THE MATTER of a direct referral under section 87G of the Act BETWEEN CANTERBURY CRICKET ASSOCIATION INCORPORATED Applicant AND CHRISTCHURCH CITY COUNCIL Respondent BRIEF OF EVIDENCE OF DIANE JEAN LUCAS ON BEHALF OF HANDS OFF HAGLEY INCORPORATED ______________________________________________________________ ______________________________________________________________ WYNN WILLIAMS LAWYERS CHRISTCHURCH Solicitor: M Perpick ([email protected]) Homebase, Unit B, 195 Marshland Road, P O Box 4341, CHRISTCHURCH Tel 0064 3 3797622 Fax 0064 3 3530247
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Page 1: Hagley Oval Evidence Di Lucas

BEFORE THE ENVIRONMENT COURT AT CHRISTCHURCH

ENV-2013-CHC-019 IN THE MATTER of of the Resource Management

Act 1991 AND IN THE MATTER of a direct referral under section

87G of the Act BETWEEN CANTERBURY CRICKET

ASSOCIATION INCORPORATED

Applicant

AND CHRISTCHURCH CITY

COUNCIL

Respondent

BRIEF OF EVIDENCE OF DIANE JEAN LUCAS ON BEHALF OF HANDS OFF HAGLEY INCORPORATED

______________________________________________________________

______________________________________________________________ WYNN WILLIAMS LAWYERS CHRISTCHURCH Solicitor: M Perpick ([email protected])

Homebase, Unit B, 195 Marshland Road, P O Box 4341, CHRISTCHURCH Tel 0064 3 3797622 Fax 0064 3 3530247

Page 2: Hagley Oval Evidence Di Lucas

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Introduction

1. My full name is Diane Jean Lucas. I am a landscape architect and

landscape planner with more than 35 years' experience. I am a

Director of Lucas Associates Limited, a landscape planning, design

and management practice I established in Canterbury in 1979 and

have worked throughout New Zealand.

2. I have read the Code of Conduct for Expert Witnesses contained in

the Environment Court's Consolidated Practice Note dated 1

November 2011. I have complied with the Code when preparing my

evidence.

Qualifications and Experience

3. My qualifications include a Bachelor of Science Degree (Otago

University), a post-graduate Diploma and a Masters Degree in

Landscape Architecture (Lincoln University). I was elected a Fellow of

the New Zealand Institute of Landscape Architects (NZILA) in 1987

and am a Registered NZILA Landscape Architect. I am a certified

Resource Management Hearings Commissioner.

4. I have attached my curriculum vitae as Appendix 1.

5. At the request of 10 groups - professional, business and residential -

in October 1995 I was contracted by the Christchurch City Council to

facilitate the Inner City Charrette, a community workshop-based

planning process. The process was instigated by the Civic Trust;

professional groups including Institute of Architects (NZIA), Institute of

Landscape Architects (NZILA), Historic Places Trust (HPT), and the

Inner City Promotion Team (ICPT), along with residents' groups.

6. The charrette process and resultant document, “The Shape of

Christchurch within the frame of the 4 avenues”, showed an

overwhelming vision for a low-rise, lively, aesthetic inner city character

with strong historic qualities and identity, amenity, and plains city

character. The tree canopy height for major tree belts such as the

avenues, park and river corridor, was identified as a desired height

threshold for structures to enable the low rise character to prevail. The

project received a premier NZILA planning award.

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7. I have authored several tree planting design publications1 and of

heritage management2. I have been an advisor on waterway

restoration in Christchurch and received a premier award for waterway

work. I am familiar with park requirements and was an appointed

member of the Garden City Committee, a sub-committee of the

Council’s Parks and Recreation Committee. I have developed park

plans in Christchurch and assessed proposals in and around Hagley

Park, including an amphitheatre assessment. I have developed

heritage assessment criteria and am a judge of heritage awards. I am

currently a member of the council’s Urban Design Panel and have an

advisory role in several anchor projects.

8. I am very familiar with Hagley Park having lived and worked nearby,

and moved around and through the park, for more than 25 years and

have undertaken professional assessments within and around Hagley

Park.

Scene Setting

9. Central Christchurch is admired by many from afar. It is essentially a

low-rise city of the plainscape. In contrast, trees being essentially

taller than nearby built masses, form frameworks to green spaces and

corridors have been able to form, creating a strong framework and

thus an identity for the city.

10. Many cities of admired character have a strong identity formed by a

coherence created by strong topographic form and pattern. The

isthmus of Auckland, whilst often criticised for its lack of built cohesion

and spatial coherence, intricate land-sea relationships as well as the

dramatic series of volcanoes provide such a strong framework that

Auckland is able to achieve some pattern in response, thus some

definition and distinctiveness. The vast built environment is broken

1 “Planting Design” Chapter 1 in Trees for the New Zealand Countryside. Pp. 19 – 39. 1984.

“Woodlots in our Landscape” 1987. Landscape Publications Limited. Wellington.

2 Vegetation Management in the Archaeological Landscape. Research report for Department of

Conservation Science and Research. 1993.

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and somewhat subordinate to the natural pattern provided by the

coastal edge, the open water spaces, and the volcanoes as "islands"

dotted through, giving a degree of aesthetic coherence and thus

identity to greater Auckland.

11. Wellington, sited on the faultline, wrapping around the harbour hills,

but usually not extending onto the upper slopes, giving these the job of

forming enveloping green space. The tallest built form steps up the

city slopes, enabling Wellington to have a very coherent pattern and

identity.

12. Dunedin, too, wraps the harbour basin, with the tallest buildings

confined to the base of the slope, with hill backdrop and green belts

encircling on and above the slopes. Together with the coherent built

character, this provides an overall exceptionally high aesthetic

coherence for that city. The strong coherence and enhanced human

scale mean that Dunedin has a distinctive identity and a very high

amenity value. This coherence is increasingly recognised, from both

resident and visitor appeal, as a valuable city resource.

13. For Auckland, Wellington and Dunedin, the location on slopes allows

for diverse outlooks and spaces and quite different opportunities in

relation to building heights and spacings than occur if located on the

flat.

14. As a plains city, Christchurch, being mostly of the subtle plains

landscape, lacks the strong topographic frameworks that form the

basis for the identity of Auckland, Wellington and Dunedin. Lacking

anything to relate to, some cities surrounded by plains create their

identity through tall buildings - to create an exclamation mark, a focus,

a statement, out on the plains. Some, e.g. Brasilia, recognise the

expansive plains scale through having substantial buildings of similar

scale and of blocky form, but surrounded by extensive open space.

15. Christchurch, however, is backed by the Port Hills. Traditionally a low

rise city with a vast majority of residential buildings being single storey,

the Port Hills provide a backdrop enjoyed across the city. The low-rise

flats spreading out from the foot of the volcano have enabled the city

to have a strong aesthetic coherence, a high amenity, because the

urban form has been evident. The taller built node of the central city

and the major natural, green and open space features and corridors of

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the flats are legible. They provide the fundamental pattern that makes

sense of the city form.

16. The major corridors and spaces of the flat central city are those of

Hagley Park, the river, squares and surrounding avenues. It is their

tree pattern, the scale and continuity of trees forming a logical pattern

defining the spaces and corridors and establishing a setting for the

built matrix between. The tree pattern is an essential contributor to the

amenity of central Christchurch. The tree pattern, along with the open

spaces and river, are highly valued resources for city amenity, both in

themselves and in what they contribute to city coherence, character

and identity.

17. The importance of the tree pattern and the open spaces, and their

contribution to the appeal of Christchurch. If the city is to retain the

character and amenity, the appeal of the city, it is essential that

structures are designed to respect the tree setting and the open

spaces. The central Christchurch tree framework suggests both a

vertical and a horizontal scale of reference in the city.

18. Past planning here and elsewhere has sought to maximise the value

of the open spaces and river through allowing/encouraging taller

buildings nearby so that a maximum number of occupants of these

buildings can enjoy views over the trees space, and river. The

aesthetic underpinning this approach gave minimal recognition to

potential effects on other users of these spaces.

19. The taller buildings changed the experience of the spaces through

overtopping the tree surrounds and thus reducing the significance of

the trees, reducing the naturalistic qualities of the space, and

increasing the built character of spaces.

Disaster Landscape Context

20. I have resided and worked in the Central City throughout our quaking

era, earlier being within the Red Zone. It has been clearly evident that

unbuilt, tree-framed green open spaces formed refuges during the

major quake times. In this (hopefully) post-disaster city landscape, the

tree-framed green spaces of the central city – Latimer Square,

Cranmer Square, the Ōtākaro Avon corridor and Hagley Park - provide

on-going refuge qualities.

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21. With the continued flattening of the predominance of built sites in the

central city, the tree-framed green spaces have become the major

surviving heritage, the symbols of what Christchurch was renowned

for, prior to the quakes.

22. Care is needed in any change to what remains of our historic heritage,

particularly the intact and highly valued heritage park, Hagley Park.

Hagley Park

23. The tree framework is an important contributor to enabling the amenity

values to be sustained. The cohesive, large-scale, deciduous exotic

tree band characterises Hagley Park. The large tree mass, with high

aesthetic value and seasonal variety, is important in setting the scale

for the adjoining built city.

24. The tree cover, clearly overtopping the built fabric within Hagley Park,

enables coherence so that various areas are experienced as a single

comprehensive unit.

25. Hagley Park forms the heart of the Garden City. I quote from the

website NZ.com:

" The Garden City

Christchurch City easily wins the heart of visitors with its reputation as

New Zealand's Garden City. The Avon River and gently undulating

topography of the central city and its surrounds encouraged the city's

leaders to recreate 'the best of botanical British'.

Hagley Park and the Botanic Gardens

The Garden City’s crowning glory is Hagley Park, which offers 165

hectares (407 acres) of mature introduced tree plantings, beautifully

thought-out walkways meandering past the river, permanent and

evolving garden features and installations, extensive sports grounds,

and a small golf-course.

There are many cycle tracks and pathways around the perimeter and

throughout the park, making it accessible for everyone. In wintertime

you’ll find the park packed with people playing sport, especially on

Saturday mornings, and in summer the park literally buzzes with

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activity – people meeting after work for a run or perhaps a game of

ultimate frisbee.

Although much of the central city has been ravaged by earthquakes

and in varying stages of demolition and rebuild, Hagley Park remains

a steadfast symbol of the city of Christchurch. Despite a small number

of closures of buildings and structures within the Park, the grounds are

largely unscathed and are a wonderful reminder of what Christchurch

will always be – the Garden City.

Hagley Park is a glorious place to wander or exercise all year round,

but is especially lovely in springtime. This time of year the park is

brimming with daffodils and bluebells – Little Hagley Park along

Harper Ave is covered in a carpet of spring flowers, making the area

particularly pretty.

Christchurch’s Botanic Gardens, located in South Hagley Park, are

another magical place to explore, featuring 21 hectares of horticultural

displays, conservatories, memorials, walking tracks and unique flora

from New Zealand and other parts of the world. The Botanic Gardens

are open every day of the year from 7am. Highlights include the

Central Rose Garden and the Daffodil Woodlands. Although the Band

Rotunda is currently closed due to the recent earthquakes, this area is

still cheerfully spring-like – a perfect spot for a picnic.

The Peacock Fountain, located in the gardens beside Canterbury

Museum, has recently be repainted and restored in its original vibrant

Edwardian style. Hire a paddleboat or kayak at the nearby Antigua

Boatsheds and peacefully meander through the Park along the Avon

River. The water is a great way to see the sights!

With towering trees, some as old as 120 years, the park is

characterised by woodlands and wide open spaces. Hagley Park has

a number of sporting grounds and is home to Hagley Golf Club,

Hagley Park Tennis Club, the Christchurch Petanque Club and United

Croquet Club and Canterbury Netball.

As well as being a recreation centre, the Park is a venue for a number

of concerts and festivals, such as the biannual Ellerslie Flower Show,

when North Hagley Park becomes awash with landscape-designed

gardens of a world class standard. The North Hagley Park Events

Village is a temporary entertainment and performance events village

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which was built in time for the 2011 Rugby World Cup. Since then the

Village has hosted events for festivals such as the Body Festival, the

Christchurch Arts Festival and the World Buskers Festival. During the

summer months as part of the Christchurch City Council’s Garden City

SummerTimes initiative there are a number of free concerts and

events held in different spots around the Park – check out the

SummerTimes website for more information.

Two events not to miss are the Anthony Harper Summer Theatre

season of Wind and the Willows, which will feature Mark Hadlow from

The Hobbit as Toad and The Breeze Lazy Sundays, which will feature

an assortment of Christchurch musicians performing on the Archery

Lawn every Sunday from January through to early March.

Another good reference point for events in and around Hagley Park is

the BeThere website. The Christchurch City Council (CCC) website

provides you with a map of Hagley Park, as well as a map and

information for your tour of the Botanic Gardens.

If you’re visiting the city and would like a uniquely Christchurch

experience, head to Hagley Park to enjoy the beautiful open spaces,

cultivated gardens and vibrancy of this established and much-loved

Christchurch landmark."

(NZ.com)

Hagley Park South

26. Whilst records of the original design intent for Hagley Park are scarce,

the planting layout and species selection was well-recorded and the

management intent is clear. Hagley Park South plantings were

recorded as a challenge to establish, due to hare damage, and were

thus replaced several times, with varying attempts through species

choice to increase resistance to that damage.

27. A series of historical plans show the planting patterns. The layout was

of the English Landscape School tradition, with multi-row long, straight

avenues widened to form woodland blocks in several locations. Whilst

the land surface involved various undulations and several waterways,

the planting layout did not follow these, but involved formal rows, from

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single to many wide. That is, it was not laid out in naturalistic or

picturesque clumps and groves.

28. The planting layout involved establishment of the single rows and

avenues in large-growing deciduous broadleaf species, primarily of

European origin. However, within the rows, the deciduous trees were

deliberately inter-planted with fast-growing conifer species, particularly

pines, to force the deciduous trees into a single, clean-trunked upright

form. The infill conifers were removed once the deciduous trees had

adequately formed. The purpose of the dense nurse planting to

encourage clean trunks was to provide for high visual permeability

through the tree rows. A "gothic canopy" was sought.

29. The dominant characteristic of clean-trunked tree rows has enabled

the key heritage landscape attribute of visual permeability through the

tree rows and across intervening spaces.

30. Whilst an aerial photo might suggest limited visual access from space

to space, the "gothic canopy" enables exceptional visual permeability

from one side of Hagley Park South to another. The grassed ground

plane continues through almost entirely undisrupted. There are few

paths. Most is accessible grass, which is well-used, formally and

informally by many people, by a great diversity of people in daytime

plus at dawn and dusk.

31. The tree spacing has also established an intact canopy that

intermittently roofs the park. The canopy above, spaced trunks below

and uncluttered space between are crucial landscape attributes with

very high intactness through South Hagley and for the Oval.

32. The character from the upper canopy surface continuity around park

spaces sets the scene and the experiential scale.

33. This character of ground level permeability results in a lack of visual

and physical barriers around and across large tree-framed open

spaces.

Historic Heritage

34. There is an important simplicity about Hagley Park. This contrasts

sharply with the character of the Botanical Gardens. The simplicity

experienced from the large open spaces bound by tree rows and

woodlands which you can see under, from space to space. The large

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tree rows and woodlands with dominant trees of similar size that have

been specifically managed to display clear single trunks so that the

resulting visual and physical permeability of South Hagley is a major

heritage and amenity attribute.

35. Designed in the style of the English Landscape School, the name

‘Hagley Park’ references the founders of the English Landscape

Garden (“Changes in the Canterbury Landscape” S.Challenger.

Lincoln College. 1974).

36. The flatness of the grassed surfaces extending from space to space,

with the rows and groves of clear trunks enable visual continuity that is

highly valued. It is a heritage and an amenity attribute.

37. Hagley Park and some adjoining areas to the east, particularly

Worcester Boulevard to Montreal Street, including the Museum and

Arts Centre, provide a strong cohesive heritage landscape character.

38. As has been well-recognised by colleagues internationally, historically

Hagley Park is of high significance. The first funding approval for

plantings in Hagley Park occurred in 1858, the year the design for

New York’s Central Park was approved, just prior to the statute in

England that provided for public recreational land to be set aside.

Large tree-lined open spaces, long vistas, avenues and woodlands

were key ingredients. Simplicity and grandeur are essential

components.

39. Egalitarianism was a fundamental intent for Hagley Park. It was to be

a common or people’s park. Not a place for segregated interests.

40. South Hagley was leased out for grazing from 1852; lessees had to

fence their stock but were not allowed to impede the public’s access

for recreation or amusement “or to interfere with the right of way

across it in any direction”.

41. From 1859, Enoch Barker guided the overall design and layout of the

park, undertaking substantial tree plantings. This work was reportedly

‘One of the first attempts at “landscape gardening” in the Colony.’

(Lyttelton Times 1866).

42. That year, the United Canterbury Cricket Club located its pavilion and

club to the South Hagley site, followed by other cricket grounds

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established across Addington Brook toward Hagley Avenue

(Attachment 4).

43. Designed on traditional English lines, the pavilion reinforced Barker’s

English planting aesthetic (Beaumont, 2012). Barker resigned the

following year, and by then the surrounding tree belts were all

established. (Challenger, 1979).

44. John Armstrong was responsible from 1867 – 1889. He completed the

tree belts, increasing the depth of some, and established permanent

footpaths. Around South Hagley, additional avenues were planted in

1875 along Riccarton Road, Hagley and Moorhouse Avenues, plus a

woodland on the south-west corner of the park. Particular broad-

leaved deciduous trees were favoured by Armstrong for their carbon

absorption properties, as they were understood to correlate with

environmental health (Armstrong, J.B. “Planting in Towns”. New

Zealand Country Journal. 1 January 1880, 4:50).

45. Nurse trees of various pine species were established between the

deciduous broad-leaved specimens. The pines typically formed every

second row and every second plant, and were removed when they

were 5, 10 or 15 years old. (Armstrong, J. B. The Forming and

Management of Plantations. New Zealand Country Journal, Vol 3, No

2, 1879, page 101).

46. The effect of the nurse trees continues to be enjoyed today, with the

single clear trunk formation, side branches discouraged, and high

branches forming a canopy. The clear trunks and high canopy allow

views through Park spaces and beyond. English grasses were

cultivated in the spaces between tree plantings.

47. The large-scale planting across the park between 1862 and 1889

determined the landscape aesthetic for the park. The walk around

Hagley Park was soon recorded as “one that for sylvan beauty cannot

be surpassed” (The Star 3 November 1887).

48. By 1889 there was considerable criticism that the development of

clubhouses and barriers was alienating areas and was contrary to the

requirement that the Park be a place of recreation for all. Hedging of

playing fields was not allowed initially, as they were considered to

adversely affect the character that was being worked toward. However

Page 12: Hagley Oval Evidence Di Lucas

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with a clutter of buildings appearing, hedging was allowed to mitigate

their visual effects where possible.

49. The eastern corner of South Hagley, between Riccarton and Hagley

Avenues, was the venue for the International Industrial Exhibition. The

building was more than 200 metres long and 85 metres wide.

Construction began in January 1882 and was all removed by

September 1882 (Attachment 7).3

50. Taking control in 1889, Ambrose Taylor thinned, pruned and removed

trees including the remaining nurse pines, to open and manage

viewshafts through the Park and to the Port Hills. He worked on the

avenues and woodlands to “lift up the trees to form a Gothic arched-

shaped canopy” and sought to clear space between each avenue tree

of around 15 metres (The Star, 11 February 1899). Taylor managed

the trees to achieve “outlook” to and through the spaces beyond.

51. The hectare behind the Netball Centre was planted in 1893.

52. James Young, in command from 1908 to 1932, continued the pruning

and thinning, and new plantings continued the established aesthetic of

large-growing, broad-leaved deciduous trees.

53. The Cricket Club caretaker’s house was built south of the Umpires

Pavilion, where the Council caretaker's house is today (Attachment 8,

lower).

54. Post-war, with an increased demand for sporting facilities, small

buildings became dotted across the Park and sports grounds were

enclosed with planted hedges or fences. There was major public

concern expressed at potential conflict between the Park’s active

amenity role, its aesthetic values and a loss of the landscape’s

spaciousness.

55. The fundamental planted structure of Hagley Park is the oldest

surviving aggregation of planted trees in the city. The layout and

3 This exhibition should not be confused with that of 1905, when 116 acres of North

Hagley Park was fenced off for the New Zealand International Exhibition in 1906-07.

Special buildings were constructed just for the Exhibition. As an indication of the

scale, 37,000 people attended the opening. All structures were removed afterwards.

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management has followed an English parkland aesthetic with broad-

leaved deciduous species planted in orderly lines, avenues, perimeter

belts and woodlands demonstrating visual and physical permeability.

The simplicity created by the spatial layout, species selection and tree

management is a very important attribute of the historic heritage of the

Garden City. It is a major landscape and amenity value of the city.

South Hagley, including the plantings and spaces associated with the

Hagley Oval, exemplifies this landscape and heritage character

56. The heritage significance is associated with the first government

gardeners and their decisions on English Landscape Design through

the spatial layout, species selection and ongoing management toward

achieving spatial enclosure, shelter, shade, and, visual and physical

permeability.

57. In several woodland blocks, long term conifer species were also

incorporated. Up until the 1940s, much of the park was leased for

grazing.

58. The stature and maturity of the trees, their venerable broadleaved

character, their individual legibility as well as their massing as a simple

high canopy, means the tree cover has very high landscape value.

They are crucial in defining South Hagley’s sense of place, heritage

and amenity value. The continuity of the near-level ground surface

beneath and visual and physical permeability between the tree trunks,

allowing views through the trees, across and between spaces and

beyond, providing the desired ‘ample uninterrupted promenade’.

59. The tree belts define Hagley Park in total. For the simpler landscape of

South Hagley, which generally has greater landscape integrity in total,

the simple uncluttered land surface and permeable spatial divisions

with grand over-arching canopy forms, form very important historic

heritage in the city. They display a depth of time, and a clarity of

purpose at a surprisingly large scale for a central city, and this is

internationally valued. (eg Attachments 6, 29, 31, 32, 36, 38, 41, and

43).

60. Various more recent introductions detract from the integrity, including

several utilitarian structures, including the large Horticultural Centre,

the caretaker’s house beside the Umpires Pavilion, and the soccer

light standards alongside the grounds to the south.

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61. The tree rows, belts and woodlands created spaces and spaces were

also created within the grand belts. As identified by heritage landscape

architect Louise Beaumont (Conservation Plan: Hagley Park and

Christchurch Botanic Gardens. Draft May 2012. Vol 2, S. 1, page 19)

“The spatial organisation of Hagley Park reflects some of the common

maxims of design for Victorian-era public parks with the formation of

the planted perimeter, limited use of tree massing (clump planting or

the formation of groves) in the internal spaces of the park, and an

early design emphasis on pedestrian and equine promenade and

other public sporting amenity.”4

62. As was identified in 1926, the space of the Park as a whole has a high

value to the community. Encroachment by buildings and vehicles has

been strongly resisted. That the needs of sports groups have been

considered contrary to the highly valued parkland aesthetic was

identified to illustrate the community’s deep sense of attachment to the

Park and its various spaces.

63. The Umpires Pavilion is not only a heritage asset to the Oval, it is a

heritage asset enjoyed from across Hagley Park South, and from

lengths of the surrounding Avenues, specifically Deans Avenue and

Riccarton Avenue. Located in the Oval in 1866, this heritage building

contributes importantly to the heritage landscape of Hagley Park.

64. Either side of the Oval are two houses, with a small amount of

associated private space for these caretakers' homes. This is the only

private space in Hagley Park South.

65. The crucial attribute of visual and physical permeability through

Hagley Park, within and through tree masses and between tree trunks,

makes the Oval a core feature in South Hagley. Highly visible from

near and far, the Umpires Pavilion makes it a landmark in the Oval.

The near-level grassed surface allows for the full view of the Umpires

Pavilion. The 13 m long, two-level Umpires Pavilion sets the scale for

the space. It is the focus. Excepting the Horticultural Centre set back

from the edge, the other buildings are not of overly larger scale. It is

the visual and heritage appeal of the Umpires Pavilion and the small

4 Note: All content in this plan is the property of the Christchurch City Council unless

otherwise acknowledged.

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built scale around the oval that enables this space to have a village

green character. The trees and space dominate. It is an

overwhelmingly green space, not a dominantly built space. It is a

space that is so inextricably visually and physically linked to spaces

beyond, with the level ground surface extending out between the trees

to the west and south. The smaller Oval space is appreciated as part

of the greater South Hagley. As a continuous part. A special part.

66. As recorded by R. T Brittenden in “Great Days in New Zealand

Cricket” (1958, page 34), “In September, 1864, the Canterbury

Provincial Council granted the Christchurch Cricket Club the lease of

30 acres of Hagley Park,…. The council wisely stipulated that the

public must always have the right of access to the area, and it was

thus saved from becoming an arena.” The current proposal would now

convert that ground to an arena.

67. Brittenden recalled that “Hagley matured and the legends were born

beneath the sturdy elms and oaks.” “At day’s end the stumps cast long

shadows across the soft grass to the mellowing timbers of the ancient

pavilion. The “serenity of the surroundings” was appreciated, being

identified as “The loveliest ground in the world.” (pp. 33-4).

68. He recorded further that: "The pavilion from the original ground was

also brought down, long lines of trees were planted, live fences

established, wells sunk, and the first club match was played in

November, 1866…."The pavilion is still there, nearly 100 years of age,

… From it some of the world's greatest cricketers … have gone out to

play.” “… the only bowler in the world to take all ten wickets in an

innings in his first-class debut – and he did it at Hagley.”

69. The grand tree lines of the surrounding park have, for more than a

century, been part of the experience of the Oval. The undisrupted

grass surface between pavilion, Oval and surrounding park has long

been appreciated.

70. South Hagley and the Oval are not enjoyed merely from fixed

viewpoints. They are part of people’s experience moving around and

through the Park. Many people do this daily. The nuances are well-

known and appreciated. The experience, the vistas and spaces vary

as you move, whether on cycle or foot within or around, or by car. The

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experience changes markedly with the seasons, with greater visual

permeability in winter.

71. In 2003, Dr Janet Stephenson (Patina. 20105) described heritage

landscapes as ‘those landscapes, or networks of sites, which deserve

special recognition or protection because of their heritage significance

to communities, tangata whenua or the nation.” Hagley Park is

undisputedly a heritage park of high significance. The Oval within

South Hagley is within a Christchurch Central heritage landscape that

embraces the whole of Hagley Park and the adjoining heritage

complexes including Christ’s College, Canterbury Museum and the

Arts Centre on Worcester Boulevard. It is a network of sites that is of

very high heritage significance to the Christchurch, Canterbury and

wider communities. The integrity of this heritage landscape, of the

relationship between sites within it, requires particular consideration in

terms of the proposed development.

72. The Regional Policy Statement, Chapter 13, Objective 13.2.1, requires

the identification and protection of significant historic heritage.

Objective 13.2.2 requires recognition that such values are often

expressed in a landscape setting which requires protection from

inappropriate development. The Christchurch City Plan and the

Hagley Park Management Plan address these aspects, and Ms Briggs

outlines those measures.

73. Under Policy 13.3.3 of the RPS, significant historic cultural and historic

heritage landscapes are to be protected from inappropriate

development. That policy states:

Significant historic cultural and historic heritage landscapes are

to be protected from inappropriate subdivision, use and

development. When determining the significance of values of

historic cultural or historic heritage landscapes, the following

matters will be considered:

(1) Heritage fabric

(2) Time depth

5 Beyond the Scene. Landscape and identity in Aotearoa New Zealand. Ed. Janet

Stephenson, Mick Abbott, Jacinta Ruru. Otago University Press. Page 165.

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(3) Natural science value

(4) Tāngata whenua value

(5) Cultural diversity

(6) Legibility and evidential value

(7) Shared and recognised value

(8) Aesthetic value

(9) Historic or cultural importance

74. The significance of Hagley Park South in total is largely due to the

integrity of assessment matter (1) heritage fabric. The layout around

150 years ago of the grand tree framework spread out around and

across generally level grassed space, and the management of those

trees and the grass beneath to maximise the spatial qualities,

maximise the visual and physical permeability and allow for maximum

all-purpose public usage and enjoyment, has been commendable.

75. The spatial integrity of South Hagley overall has high intactness. The

Hagley Oval is a key feature within this, as a continuity of the smooth

grassed open space framed by clear-trunked trees. The grand stature

of the tree trunks and canopy, the treed continuousness, the evident

age and intactness demonstrate highly significant heritage fabric.

76. These characteristics also demonstrate significant time depth (2). The

English Landscape Garden style remains very highly legible (6). The

heritage values of the tree-framed grass spaces that form South

Hagley have very high shared and recognised value as can be shown

through the public responses to various proposals and planning

processes over the last century.

77. Within the Hagley Oval, the Umpires Pavilion is a heritage feature that

has been present and enjoyed there for almost 150 years. The scale

of the structure, the elevated viewing balcony and detail of the

construction contribute importantly to the village green character that

exists within the Oval.

78. The elevated viewing balcony is an important characteristic of the

series of cricket buildings, excepting the former cricket building, the

Horticultural Centre. The other buildings are of small footprint, typically

more enclosed below, with balconies and windows for over-viewing

the Oval above. The two-storied built form with the upstairs over-view

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focus is an important characteristic of the surrounding cricket

structures. The Umpires Pavilion is the most elegant in this regard. It

forms a distinctive landmark when viewed from near or far, including

from along Deans Avenue. The distinctive heritage building relates to

the tree-framed Oval space but is also a key feature in the vistas from

beyond.

79. The Umpires Pavilion has buildings of a similar scale either side. The

St Albans Cricket Club pavilion to the north, and the caretaker's house

to the south. Some decades ago, this house replaced the original

caretaker's house on that site (attachments 15, 26). Whilst low profile

and with a hedge around, the current house does not assist the

heritage and aesthetic values of the Oval. To respect the restoration of

the Umpires Pavilion, any upgrade project for the Oval would

preferably revamp the caretaker's house. Whilst an acknowledged

negative in this space in the management plan, the current proposal is

as yet silent in addressing this issue.

80. I understand that the Horticultural Centre was built by Canterbury

Cricket. The adverse visual effects of that building are referred to in

the application documents. Whilst within the "site", it is disappointing

that no effort is made in the proposal to improve the aesthetic of that

building and its environs. The facility is unbecoming to Hagley Park

South and highly visible from many directions. The only effort by the

Applicant is stated to be to place the Pavilion to (somewhat) block out

the view of it from the Oval. This is a very narrow approach to the

issue.

81. The aesthetic value (8) enjoyed around and within the Hagley Oval,

and from adjoining spaces and routes, the vistas through, to, and from

the Oval are of very high significance. The regular tree placement in

single and multiple rows, all open beneath and canopies enmeshed

above, form a major aesthetic attribute. The grass surface that is

clearly visible linking between trees, surfacing across spaces and

providing the continuity and base ingredient that links the Park

together. It is the tree, grass space combination and their absolute

visual clarity that is a valued aesthetic.

82. The flatness of the grass surface through South Hagley enables full

visual continuity. The mounds at the Netball Centre, whilst of

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naturalistic form, are obvious as works associated with the Courts, and

not part of the broad park surface. Whilst barely 2 metres in height, the

larger one blocks the visual continuity from alongside Hagley Avenue

across the Park. It provides a visual separation that is contrary to the

overall Park heritage character. Landform separation is not a Park

characteristic.

83. Hagley Park, South Hagley and the Hagley Oval are a series of nested

heritage sites of high historic importance in Christchurch and

Canterbury. The historic heritage requires consideration in terms of

section 6(f) of the RMA and Policy 13.3.3 of the RPS.

The Site

84. 'The Site' has been defined by Mr Nixon (para 1.7) and is shown at

Attachment 2, along with the 'Polo Grounds' which are to

accommodate event parking. As mentioned earlier, the eastern

boundary to The Site is along the Addington Brook, a spring-fed

waterway that is an important Central City Ōtākaro / Avon tributary.

Existing access and car parks intrude into this degraded natural

feature. The proposal involves no landscape analysis or plans to

address remedying this or other existing adverse effects within the

site. Nor is there any proposal to address appropriate access to

service the major new venue proposed.

85. The site involves a central space within South Hagley. The space is

blocked off to the east with a series of buildings and some vegetation.

To the south and west, it is open to adjoining spaces.

Assessment of Effects

86. I have analysed the attributes of Hagley Park and the proposed

development of cricket facilities in Hagley Park South to international

level requirements as proposed by Canterbury Cricket, as Papa

Kirikiti. In summary, I assess that the pavilion, embankment and

lighting as proposed would have significant adverse effects on the

park's valued heritage landscape character and the amenity attributes

enjoyed. In addition, the temporary structures and concentration of

activity associated with large and multiday events have the potential to

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have further adverse effects on the public's everyday experience of

the Park landscape and amenity.

87. From my analysis I assess that the proposal does not remedy existing

adverse effects, instead exacerbating a number of them.

88. The application involved no landscape analysis to underpin the

proposal, no identification of issues needing to be addressed. The

assessments by landscape architects have merely assessed three

proposed features, the pavilion building, the embankment mounding

and the lighting structures. The landscape has not as yet been

comprehensively assessed by the applicant or the partner agencies.

Yet, as has previously been identified (Heremaia, 2003)6 the

Horticultural Hall and associated car park are inconsistent with the

overall English parkland character of South Hagley. These were

developed by Canterbury Cricket and are within the application site.

Yet there has been no analysis and no attempt to address the existing

landscape issues in the site redevelopment.

89. The application is to provide a “replacement pavilion”. The former

Canterbury Cricket building, now the Horticultural Centre, was a

former cricket pavilion. Replacement or redevelopment of this intrusive

structure is desirable. Whilst it is currently owned by the Horticultural

Society and included within the application site, it is disappointing for

an anchor project to be contemplated without a comprehensive

approach to “the site” being undertaken.

90. Considering the site as involving significant historic heritage, in terms

of Policy 13.3.3 of the RPS, I note that the Policy goes on to state:

In relation to [the management of significant historic cultural and

historic heritage landscapes] and determining the appropriateness of

scale, form and location of development in these areas, the following

matters will be considered:

(a) Cultural sensitivity of the proposal

(b) Integrity or intactness of the landscape, items, features or

linkages

6 Heremaia, Christine "Case Study: Hagley Park Management Plan (1991)", Lincoln

University.

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(d) Vulnerability to change or modification

(e) Recognition of boundaries

(f) Opportunities for maintaining values

91. For more than a century there has been considerable cultural

sensitivity regarding the intent of the park being for the enjoyment of

all, and the pressure for more exclusive activities. The proposal is one

such activity involving a corralling of a core area with an embankment,

introducing a building of a scale that would dwarf the heritage spatial

qualities and heritage features of that space, introducing very hefty

lighting standards of a height that would dwarf the tree canopy that is

the crucial scene-setter of Hagley Park.

92. The landscape integrity of South Hagley, within which the Hagley Oval

is a subset, is very vulnerable to intrusion through built structures and

landform change. The spatial qualities are vulnerable to intrusion by

buildings.

The Pavilion

93. The large, white pavilion structure would introduce a much greater

scale and presence of structure to the Oval and to Hagley Park South

in total. Even with burial into the embankment, the pavilion would be

somewhat visible across much of Hagley Park South. It would jostle

to form a landmark, but be segregated by the embankment. Given the

unbuilt character and long open vistas which are major attributes of

Hagley Park, the pavilion corralled in the Oval would appear out of

scale and out of context.

94. The visual effects of the Pavilion would not be confined to the Oval.

The proposed pavilion is of a very large scale that will command

control of the Oval and of the vistas and spatial relationships beyond.

The size and whiteness proposed mean that it will be highly visible.

95. The Pavilion will adversely affect the historic heritage through the

dominating scale and character of the building. The Umpires Pavilion

would no longer command this space. Instead the Pavilion would

dominate it. The Umpire’s Pavilion would become a minor curiosity, a

little heritage left-over, and no longer the visual and heritage core of

this place and space.

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96. The essential park character of domination by trees and grass would

be significantly adversely affected by the introduction of the Pavilion.

The integrity and intactness that are important historic heritage

attributes would be significantly adversely affected by the introduction

of the Pavilion.

97. Considering the raft of Objectives and Policies and the direction they

provide, I assess the Pavilion to be inappropriate. As outlined by Ms

Briggs, it is contrary to the relevant objectives and policies, and it

would result in highly significant adverse landscape, amenity and

heritage effects.

The Embankment

98. The park as part of the plainscape is a place of gentle terrain, of

flatness, excepting for the waterways. Except where obstructed by

structures or dense vegetation at least 1.5 m high, the flatness

enables high visual permeability. The introduction of the embankment

over 2 m high would separate the Oval space from the Hagley South

landscape context.

99. Enjoyment of the vistas, such as more distant through from Deans

Avenue or nearby from the Lime Walk, Christ's College Grounds and

the Polo grounds, would be intercepted by the embankment. Walking

by, the embankment extending above head height, would provide a

separation from the Oval. (attachments 26 - 38).

100. The sudden embankment slope would be a disruption to the visual

and physical permeability of South Hagley and of the Oval specifically,

that is in contradiction to the historic heritage attributes long valued

and recognised.

101. When walking by, the height is such that it would appear as a

deliberate screen to the space beyond. A segregation of spaces.

102. The embankment would screen out the lower storey of the existing

pavilion structures, removing their relationship with the surrounding

spaces.

103. Whilst a slot through the embankment is proposed to the Umpires

Pavilion, this does not allow retention of the relationship of that

building to the breadth of the Oval. Most certainly it does not allow

retention of the relationship to the wider South Hagley.

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104. The relationship between heritage attributes of the Oval and its

heritage building would be very significantly adversely affected by the

construction of the embankment.

105. From within the Oval space, the enclosure by the embankment would

create a very different landscape experience that is contrary to the

integrity and intactness of South Hagley as a heritage park.

106. With the geometric form of the embankment extending to above eye-

level, with just 2 narrow slots cut through, with the large embedded

Pavilion building, and with the 4 very large embedded lighting masts

towering above, the Oval would be transformed into an arena. Whilst

utilising the surrounding tree canopy as backdrop, the Oval would no

longer relate to South Hagley as in the heritage character defined.

From within, the corralled and built Oval would be experienced as

separated and apart.

107. Whilst the embankment structure would be grassed, and therefore

have some visual continuity with the adjoining spaces and their

surfaces, that does not mitigate the effects. The elevation forms a wall,

and whilst a green wall, it would significantly disrupt the visual

relationship from one side to the other. It would be too high to see

over. It would disrupt the ground surface permeability to and through

the space.

108. From outside, and from beyond, the Oval would be considerably

separated from South Hagley, visually, physically and psychologically.

109. I assess the corralling embankment proposed to be inappropriate.

110. Due to the fundamental heritage landscape characteristic of high

visual and physical permeability through and across Hagley Park, the

large embankment encircling the Oval would permanently 'wall out' the

public, making the Oval a seemingly exclusive place and foreclosing

viewshafts. The continuity of the levelled and grassed plains surface

across the various Hagley Park South spaces, continuing through the

deliberately managed tree rows, would abruptly change to a rather

steep circular and obviously very artificial grassed landform.

111. The embankment would be an inappropriate landform feature in South

Hagley Park.

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112. The corralling embankment would seek to selectively display and

screen structures to Oval users. In doing so, it would disrupt important

views across Hagley Park South, for the small scale and upstairs

overview character of several of the existing cricket buildings

contribute to amenity, heritage and landscape character. From within

and around the Oval and South Hagley, the embankment would

visually “knee-cap” them.

The Lighting Structures

113. The lighting structures, both the substantial masts and the large light

heads mounted on them, would introduce modern and out-sized

structures to a small "village character" site. Even whilst retracted, the

structures would breach the tree canopy. Being almost the width of a

full grown tree, the hefty-looking structures would belittle the trees that

are the context and setting for the Oval. The lights would visually

disrupt the heritage landscape character created by tree canopy that

forms the highly valued spatial framework to South Hagley and the

Oval.

114. The 1.5m x 1.5m octagonal lighting masts would form substantial

structures extending out of the embankment. Extending up 30 metres

or more, they would extend above the tree canopy. The mast head

structures some 10 m wide and elevated would appear almost the

width of the Umpires Pavilion. Their modern character would be in

stark contrast to the heritage character of the existing Oval.

115. The integrity of the tree canopy around South Hagley and around the

Oval is a very important heritage attribute. The masts would be visible

from various places within and around the Park. When walking by,

their bases would be evident, and the scale and height of the mast

heads.

116. Variously visible intruding through the tree canopy, the very

substantial lighting structures would introduce modern and out-size

structures aloft that would diminish the integrity of the tree canopy.

Whilst only visible at intervals, their presence would intrude into the

grandeur that the tree canopy provides across the Park space.

117. The lighting structures would be intrusive and clumsy introductions to

a place valued for its fine-grained attributes.

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118. I assess the lighting structures would have significant adverse effects

and to be inappropriate at the Hagley Oval.

Overall Landscape Character and Amenity

119. The proposal to establish a venue capable of hosting international

cricket was stated by the applicant to be founded on a number of key

design influences, including:

• The over-arching desire of all stakeholders to preserve the long-

standing quality and accessibility of Hagley Park for all users, as a

shared recreational heart to the city;

• The retention of the park setting with an established grouping of

mature trees around the presently established natural oval grassed

clearing, with the loss of no trees or historic buildings;

• A commitment to establish a village-green atmosphere utilising the

present treed oval enclosure, rather than to develop a ‘stadium’ type

venue.

120. From my analysis of the site and its context landscape including its

heritage, I assess that the proposal fails to adequately address these

provisions. The long-standing quality and accessibility of South Hagley

would be disrupted by the structures and embankment that disrupt

perceived accessibility. The Oval would no longer read as a shared

space in south Hagley, but as a space owned by a large Pavilion and

defined by an embankment.

121. The proposal would not retain the relationship with the surrounding

trees, the grassed space or the historic buildings. The large scale

building, lighting and embankment would significantly disrupt the

valued relationship between trees, space and historic buildings.

122. The existing Oval already has a village green atmosphere and the

proposed development would convert that to instead an enclosed

arena.

"Temporary" Effects

123. The additional structures such as the TV towers, grandstands

extending metres above the embankment, the car parking in and

around Hagley Park, fencing, entrances structures and portaloos,

which would occur on an ongoing but intermittent basis, would

exacerbate the effects of the activity occurring.

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124. A picket fence is proposed to encircle the pitch inside the

embankment. It is able to have advertising attached to it and will be

present for the length of the season (September – April).

125. I assess that the presence of the picket fence would further segregate

the cricket Oval from surrounding Park enjoyment. In addition to the

embankment barrier, the fence would impede casual access by

runners, and would impede the visual continuity of the green space.

The fence with any advertising would make a strongly commercial

presence which is alien to the Hagley Park character outside of

specific events. The picket fence scale would be somewhat more in

keeping with the Umpires Pavilion. However being physically

separated from it by the embankment, with the Umpire’s Pavilion

largely hidden behind, the picket fence will not have any legible

heritage connection. Located in front of the large modern Pavilion, the

little picket fence may appear rather incongruous. Around events a

mesh fence would be installed around the outside of the embankment.

The triple barriers, of picket, bank and mesh, would create visual

clutter that is inappropriate, resulting in significant adverse effects. In

my assessment, the design is inadequate to avoid, remedy or mitigate

these adverse effects.

Access

126. As is appropriate for such a park, I understand there are currently no

allocated access route or car parks for cricket activities. With the large

development proposed, which would inevitably have substantial

regular servicing and other access requirements, no specific access or

parking is proposed. This will result in the significant parking

requirements being placed in an ad hoc and likely inappropriate

manner, creating significant adverse effects on the existing landscape,

character and amenities of the park.

Avon Catchment – Addington Brook

127. The Hagley Park Management Plan is one of several council

documents where the intent to reduce the degraded state and

naturalise Addington Brook is recorded. Disappointingly the applicant

ignores this need. The waters of the Addington Brook are very

contaminated. Drainage from the Oval is all piped into Addington

Brook. The car park intrudes on the waterway space. Yet the conflicts

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in sustainable management of this resource are ignored in the

application and in the experts’ reports and evidence. Mr Field states

there is no need for any landscape works. Whilst part of the “site”, the

degraded state of the areas shared with the Horticultural Centre is

entirely ignored in the application.

128. Investigations into Hagley Park have for some time been critical of the

management of the Avon tributaries as utilities, and the need for

naturalistic restoration works along Addington Brook (C. Heremaia

2003). Bank re-grading and riparian restoration are very obviously

needed for the Addington Brook length that is part of the application

site. Because of the excessive degradation of the stream corridor, the

undercut and eroding banks, and the very contaminated waters, a

comprehensive approach is necessary to ensure the stream is

adequately addressed to support the aspirations for the health and life

of the Ōtākaro Avon.

129. My site analysis endorses the concerns previously identified. That to

enable the naturalisation of the stream banks and natural stream

movement, some facilities such as car parking and access routes may

need to be removed or relocated. The anchor project involves several

partners that should appropriately take responsibility for the Addington

Brook enhancement as part of the proposal. The Canterbury Cricket

application has ignored this need. Disappointingly, the assessments

by my colleagues Mr Field and Mr Brown have also ignored this issue.

130. Water quality studies undertaken by the Christchurch City Council

(CCC) between 1992 and 2006 identified Addington Brook as a

significant source of pollution for the Avon River/Ōtakāro. Golders'

study for Environment Canterbury, published January 2012, notes that

Addington Brook is part of the stormwater network with waters

channelled through stormwater pipes and road gutters before

becoming an above ground stream as it passes through Hagley Park,

to then be discharged untreated into the Avon River/Ōtakāro. Golders

(2012) identify that Addington Brook waters smell anoxic and is the

most contaminated waterway tested in Canterbury: “In the biofilm

survey results reported in this document, Addington Brook had the

highest number of ISQG exceedances across the range of parameters

analysed – three exceedances of the ISQG-High guideline (arsenic,

nickel and zinc) and four exceedances of the ISQG-Low guideline

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(cadmium, copper, lead and mercury). It seems highly likely that the

ecological values in this stream are being compromised as a result.”

(Golders 2012 page 80) (see also summary data at Attachments 44 -

46).

131. Waterway restoration in Christchurch has been led by landscape

architects. Whilst neither Mr Field nor Mr Brown may have been

actively involved in such projects, it is not acceptable to ignore the

degraded waterway within the site as a landscape issue requiring

remediation.

Heritage

132. My assessment of the proposal overall is that it would have significant

adverse effects on the environment, in relation to the historic heritage

values of Hagley Park. I assess that, even when not in use, the

pavilion, embankment and lighting structures would not protect the

historic heritage of Hagley Park South. The proposal is thus assessed

as inappropriate development in terms of section 6(f) of the RMA, a

matter of national importance.

133. The importance of such a historic heritage landscape, composed of

various heritage items, places and areas, provides a crucial sense of

identity to Christchurch and Canterbury. The City Plan and the Hagley

Park Management Plan recognise the important English Heritage

Landscape character of South Hagley. As is recognised in the

Canterbury Regional Policy Statement, Policy 13.3.3, adverse effects

on such significant historic heritage are to be avoided in the

consideration of any development proposal.

Amenity

134. The proposed structures and activities, both when not in use and

when hosting events, would not maintain or enhance the amenity

values of Hagley Park South, or of the Oval specifically, in terms of

section 7(c) of the RMA. The proposal would not maintain or enhance

the pleasantness, the aesthetic coherence, the cultural or the

recreational attributes of the Oval and its context landscape, which are

all highly valued dimensions.

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135. I assess that this historic landscape requires protection from

inappropriate development, and that the Oval development proposal is

inappropriate development.

136. I note that the proposal is to be assessed as a non-complying activity,

and therefore must either be not contrary to the relevant objectives

and policies, or not have any adverse effects on the environment

which are more than minor. I have reviewed Ms Briggs' analysis in

relation to the relevant objectives and policies, and agree with that

analysis. In my view, the proposal fails on both limbs of section 104D

of the RMA.

Remediation Required

137. The caretakers house and Horticultural Centre within The Site have

been recognised in Hagley Park planning documents as landscape

issues. No effort has been applied in the application to remedy these

issues, nor to address the degraded Addington Brook along the east

of the site.

138. The adverse visual effects of what is now the Horticultural Centre are

referred to in the application documents. The lack of visual appeal of

this large building, which was originally built by Canterbury Cricket for

cricket activities, has not been adequately addressed to achieve

mitigation through management of this site.

139. Whilst within the “site”, it is disappointing that no effort is made in the

proposal to improve the aesthetic of that building and its environs. The

facility is unbecoming to Hagley Park South and highly visible from

many directions. The only effort by the applicant is stated to be to

place the Pavilion to (somewhat) block out the view of it from the Oval.

This is a very narrow approach to the issue.

140. Whilst maligning the use of camouflage colours on buildings –

presumably such as The Atrium building owned by Netball interests,

and the Tennis Pavilion in North Hagley (see attachments 39 and 44)

- the proposal is for a structure around twice their size and white and

therefore of considerably greater visual presence. Yet the park

planning documents seek a lessened built presence.

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141. As has been recorded in various council documents, with changing

community requirements, the Netball Association and Horticultural

Society have both sought alternative uses for their buildings. I

understand they unsuccessfully sought to realise the equity in their

buildings.

142. As is appropriate for such a park, I understand there are currently no

allocated access route or car parks for cricket activities. With the large

development proposed which would inevitably have substantial regular

servicing and other access requirements, no specific access or

parking is proposed. The application provides no landscape analysis

of site access. Disappointingly, no landscape analysis has been

provided of the site or proposal.

Christchurch Central City Recovery Plan

143. The Recovery Plan states the underpinnings as including the

“greening of the city, embracing and improving the health of the water

and the river, and a strong sustainability focus to the redevelopment of

public and commercial spaces” recognised as of importance for all

communities of greater Christchurch. (CCRP page 11).

144. As stated on page 17, “A city’s identity is made up of its collective

memories which create a sense of place. After a natural disaster this

becomes even more important.” The “Green City” aspiration (page 23)

was for a “revitalised Ōtākaro/Avon River corridor, and improved

surface stormwater treatment”. Papa o Otakaro / Avon River Precinct

is shown (page 37) to extend from the Carlton Bridge on the Bealey

Avenue – Park Terrace corner, down to Armagh Street, and also from

Rolleston Avenue through to Fitzgerald Avenue. That is, it does not

include the meander around the Botanic Gardens, but lengths

upstream and downstream of this.

145. Addressing heritage, the plan identifies (page 39) that existing

heritage “will continue to define the identity of central Christchurch and

provide a point of difference for visitors and residents alike.”

146. Addressing sustainability, the plan seeks “Greening the city,

embracing and improving the health of the water and the river, and

focusing strongly on sustainable redevelopment” (page 41). It is stated

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(page 45) that the aspirations for a “green” city are reflected in the

Blueprint Plan and the anchor projects.

147. The Avon River Precinct anchor project (pages 53 – 56) seeks to bring

life and health to the waters, to improve water quality, to protect and

enhance springs and waterways and to better treat and manage

stormwater. “Specific measures will be taken to improve the water

quality of the Otakaro/Avon River. Rain gardens, planted swales and

other treatment measures are references as tools for the cleanup.

Addington Brook is shown flowing into the river upstream of the

Hospital.

148. On The Blueprint Plan (page 33), stating that the Hagley Cricket Oval

will be “enhanced”, the proposed pavilion and the encircling

embankment with two gaps, are shown.

149. Listed in the Blueprint (page 87) for the Cricket Oval anchor project is

the addition of a grass embankment, lighting and a “replacement

pavilion”. The Pavilion is to have “lounge and media facilities” Training

and coaching facilities with indoor and outdoor nets are proposed. It is

stated that the project will stimulate activity in the area. Identified

partners in the project include CERA, CCC, New Zealand Cricket,

private sector and other government agencies as necessary.

Canterbury Cricket is not referenced

150. The CCRP seeks comprehensive development to enhance urban

design opportunities. It is mentioned on page 107 that fragmented

underlying landholdings can be a barrier to a comprehensive

approach. With council ownership of the lands of and around The Site

the lack of a comprehensive approach is questionable, particularly in

regard to access and waterway management.

……………………………….

D J Lucas

14 May 2013

Page 32: Hagley Oval Evidence Di Lucas

attachmentsto the evidence of Di Lucas, Registered NZILA Landscape Architect

Hagley Oval, April 2013print A3, landscape, double sided, bind left

photo taken: April 2013

Page 33: Hagley Oval Evidence Di Lucas

Hagley Oval in Central Christchurch, post-quake source: Google Earth, 26th April 2012

Hagley Park North

BEALEY AVE

MOORHOUSE AVE

WORCHESTER STRET LATIMER SQUARE

CRANMER SQUARE

VICTORIA

BOTANIC GARDENS

AVON RIVER

MON

TREA

L STR

EET

DEAN

S AVE

FITZ

GERA

LD AV

E

Hagley Park South

Riccarton Ave

Hagley Ave

Hagley Oval

attachment 1

Page 34: Hagley Oval Evidence Di Lucas

Hagley Oval

Riccarton Ave

Polo Grounds

Netball

Hockey Ground

Hagley Oval

Christs College Grounds

Addington BrookHagley Park South

Hagley Oval - “the site” as per application

attachment 2

Page 35: Hagley Oval Evidence Di Lucas

Hagley Park Plan 1850

source: DRAFT Maps in Conservation Plan for Hagley Park and the Christchurch Botanic Gardens, Volume One: History, Christchurch City Council 2013attachment 3

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Hagley Park Plan 1867

source: DRAFT Maps in Conservation Plan for Hagley Park and the Christchurch Botanic Gardens, Volume One: History, Christchurch City Council 2013 attachment 4

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Hagley Park 1955

source: DRAFT Maps in Conservation Plan for Hagley Park and the Christchurch Botanic Gardens, Volume One: History, Christchurch City Council 2013attachment 5

Page 38: Hagley Oval Evidence Di Lucas

source: http://en.wikipedia.org/wiki/File:HagleyParkAerialPhoto.jpgHagley Park aerial, 24th October 2007

attachment 6

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New Zealand International Exhibition, Hagley Park, Christchurch 1882Photograph of the Cricket Pavilion, 1869 showing saw tooth detailing

source: http://christchurchcitylibraries.com/Heritage/Photos/Disc2/IMG0008.asp

                                                                                                                                                                                                                       VOLUME 2. SECTION 5: PAGE 94

performed in a way that cannot fail to afford satisfaction to every member of the club. Ahawthorne (sic) hedge has been planted, and a small ditch dug round the ground. The old fencehas been strengthened by the addition of two more wires, and has been properly strained andstayed. An iron gate has been put up at the corner of the fence nearest town, and by the erectionof a stile, the members are enabled to get to the ground.”108

Soon after this meeting and once the new Club's finances had been determined the pavilion fromthe Canterbury Club's former grounds was divided into sections, relocated to its present site atthe Oval and reassembled by George Blockley for the sum of £28 and 10 shillings.109 

Over the following years the pavilion became the home of various cricket clubs, the last beingMarist in the 1980s.  

108 The Press, 24 September 1866, p. 2109  Lowrie, G. publication quoted in NZHPT File 12009‐086            

CONSERVATION PLAN: HAGLEY PARK AND CHRISTCHURCH BOTANIC GARDENS                                                                           VOLUME TWO: HAGLEY PARK

                       Figure 1.83 Photograph taken in 1910 showing chimney in the background.                                                                     Source: NZHPT File 12009‐086

                       Figure 1.82 Photograph of the Cricket Pavilion,1869 showing saw tooth detailing.                                                                      Source: NZHPT File 12009‐086

source: NZHPT File 12009-086

                                                                                                                                                                                                                        VOLUME 1. SECTION 3: PAGE 78

Two main entrances were formed for carriage drive access, each half a chain in width. The first wasdescribed as being on Riccarton Road about a chain from the Riccarton Road/ Lincoln Road corner,and the second entrance was formed on Hagley Avenue opposite St Asaph Street and necessitatedthe construction of a bridge across a drain. Following the exhibition, this bridge was purchased bythe promoters of the horse ride for use on the Rotten Row. Other earthworks associated with theexhibition involved the cutting of drains and the laying of permanent drainage pipes.287

Newspaper reports documenting the development of the exhibition site describe the ceremoniallaying of a foundation stone by the Christchurch Mayor and note that “copies of the localnewspapers were placed in a sealed jar and deposited in the receptacle, together with the followinginscription on parchment:‐New Zealand International Exhibition. Promoters‐ Jules Joubert, Esq.Richard E. N. Twopeny. Esq. W. R. Mitchell, agent for New Zealand. This foundation stone was laid byJ. G. Ruddenklau, Esq., Mayor of the City of Christchurch, on the 30th day of January, 1882. T. S. Lam‐bert, Esq., architect. H. Carmichael and Son, contractors.”288 Attempts to trace both the foundationstone and the time capsule have been unsuccessful.

Calls to retain the exhibition building as a “Palace of Delight” did not find favour with the DomainsBoard and, following the exhibition's closure in July 1882, all construction materials, parts of themain structure, fixtures, fittings and artworks were auctioned. By September 1882 the last vestige ofthe buildings had been removed and five of its six ornamental fountains had been razed from thesite, using charges of blasting powder. However, one fountain was left intact on the site where themain building had been located.289 This was variously described by The Star as a “memento” and“memorial” of the exhibition and was said to serve the purpose that Mr Joubert intended to befulfilled by the foundation stone.290 No information concerning the fountain's removal or relocationhas been located to date. 

287 New Zealand Tablet, 3 February 1882, p. 11; The Star, 24 August 1882, p. 3288  The Star, 31 January 1882, p. 3; Exhibition Sports Committee Scrapbook 1882, CH343/75b,CCCA289 The Star, 20 September 1882, p. 3290 Ibid; The Star, 27 September 1882, p. 2          

CONSERVATION PLAN: HAGLEY PARK AND CHRISTCHURCH BOTANIC GARDENS                                                                                      VOLUME ONE: HISTORY

Figure 3.19 Postcard view of themain exhibition building fromLincoln Road ( Hagley Avenue).Source: PhotoCD 1, IMG00013, CCL

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                                                                                                                                                                                                                        VOLUME 1. SECTION 3: PAGE 96

As in previous years, sports groups were required to prepare the grounds at their own expense and pay a licence fee to the Domains Board to occupy a fixed part of the Park. This was a nominal fee,with football and hockey paying 30 shillings a year for three acres, and the Ground Committeerepresenting cricket, paying £15 pounds for the use of ten acres.358 Designs for all proposedstructures were reviewed by the Board, and the cost of erecting buildings was met by the sportsclubs who, although frequently permitted to fence off their grounds, greens and lawns, were notpermitted to debar the public from entering. It was stressed by the Domains Board that Hagley Parkbelonged to the public, and was absolutely open to everyone, without charge for admission.

New licences and structures agreed by the Board during this period are summarised as follows;• 1886. Canterbury Rugby Union Footballer's Memorial pavilion erected on North Hagley Park • 1889. Cricket Club caretaker's house built on South Park • 1891. Linwood Football Club granted a ground on North Hagley Park• 1891. The re‐formed Christchurch Golf Club held its first match on North Hagley links in September• 1892. Christchurch Polo Club granted 15 acres in South Park behind Christ's College Cricket Ground   in the north‐west corner of the Park. By 1900 this had grown to 25 acres 2 roods and 25 perches      

• 1892. The Christchurch Ladies’ Golf Club began to share the 18 hole layout of the Christchurch   Golf Club's course 

• 1893. Christchurch Polo Club pavilion erected to a design approved by the Board• 1893. Christchurch Golf Club erected a hut (on wheels) on North Park to hold their equipment• 1896. Hockey Club granted ground between the polo ground and the College Cricket club• 1899. Model Yacht Club pavilion erected near Victoria Lake• 1901. Golf Course reduced to nine holes in 1901• 1902/ 1903. Christchurch Golf club surrendered its lease and removed its hut on wheels• 1904. Hagley Golf Club formed and took over the nine‐hole course • 1905. United Bowling, Tennis and Croquet Club took up a lease of 3 acres, 3 roods and 27.2    perches in North Hagley Park in an area “bounded by the Plane Avenue Riccarton Road and the   Wellingtonias.” Their two‐storey pavilion was erected in December 1905

358  The Star, 25 September 1900, p. 1          

CONSERVATION PLAN: HAGLEY PARK AND CHRISTCHURCH BOTANIC GARDENS                                                                                      VOLUME ONE: HISTORY

                         Figure 3.37 Cricket Pavilion and caretaker's house, South Hagley Park, ca. 1908.                                                                 Source: Part of G‐004102‐1/1, ATL

                                                                                                                                                                                                                        VOLUME 1. SECTION 3: PAGE 50

Hagley Oval, taking the turf from their Dilloway's pitch with them.138 (Refer Volume 2:1.9.4 for a fullaccount of the history of the pavilion). Soon after this the Albion and a newly re‐formedChristchurch Cricket Club were given permission to develop pitches near Hospital Corner.139

Challenger (1979) has noted that, by the time Barker tended his resignation in late 1867, theperimeter belts of Hagley Park were wholly in existence except for the belt adjacent to what is nowknown as Harper Avenue and a small portion in the north‐east corner of North Hagley Park oppositePark Terrace. It is possible that these areas were left unplanted to facilitate access to a workingshingle pit which operated in North Park until 1870, “when it was abolished owing to the greatinjury done to the Park by carting the gravel away.”140 In addition, tree belts had been formed onthe north side of the Avon River, opposite Christ's College and thorn hedges edged the RiccartonAvenue boundary of both North and South Hagley Parks.

Access into Hagley Park had been improved by the construction of the College Bridge at the westernend of Armagh Street in 1859.141 In addition, as part of the subdivision of his property to the northof North Hagley Park, Joseph Helmore had erected what came to be known as Helmore's Bridge in1865.142 Access through the Park had also been addressed with a system of utilitarian footwalks thatlinked the College Bridge with stiles which had been constructed to allow access to Park Road,Fendal Town (Fendalton), Riccarton and Great South Roads (figure 3.7).  

 

                    

138  'Dilloway's Ground and Hagley Oval', Unsourced publication held on New Zealand Historic Places Trust        Christchurch Branch File: 12009‐086  139  Reese, T. W. (1945) A short history of Hagley Park, pp. 4‐7          140 The Press, 21 November 1906, p. 12141  Lamb, R.C. (1981) From the Banks of the Avon, p. 125142  Hagley Park bridges including Carlton Mill and Helmore's. CAAR 19946 CH287/ICPW 2525/1876, ANZ          

CONSERVATION PLAN: HAGLEY PARK AND CHRISTCHURCH BOTANIC GARDENS                                                                                      VOLUME ONE: HISTORY

Figure 3.6 Photograph of a lithograph depicting the England vs. Canterbury cricket match held at 'Dilloway's'North Hagley Park, in February 1864. Enoch Barker's perimeter plantings are depicted as a running belt to therear of the stands and tent. The pavilion (right background) was constructed for this event.  Source: Exploded detail from “All England II. V 22 of  Canterbury. N. Zealand 8th, 9th, 10th of Feb. 1864”                                                                                1/2‐028957‐G, ATL

Cricket Pavilion and caretaker’s house, South Hagley Park, circa 1908

Exploded detail from “All England II. V 22 of Canterbury, N. Zealand 8th, 9th, 10th Feb. 1864 source: 1/2-028957-G, ATL

source: Part of G-004102-1/1, ATL

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Sheep grazing in Hagley Park, 1910 Hagley Park

`In the past, animals grazing on urban green spaces like Hagley Park, Christchurch, would have been a common sight. Farm animals were kept in urban areas well into the 20th century and parks were a con-venient place to house and feed them, particularly if saleyards were nearby. Owners had to get permission from the local council – but not all did, particularly in the early days of settlement when local govern-ment structures were still emerging.`

source: www.teara.govt.nz, 1910 source: Brian Brake, Te Papa online collection

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Hagley Oval Addington Brook

embankment proposal

Christchurch EcosystemsDry Plains

Houherepiwakawaka - kohuhu, mid-age plains ecosystem

Kahikateakereru - manatu, older plains ecosystem

Totarabellbird - matai, older plains ecosystem

Pukiopukeko - karamu, peat plains ecosystem

Wet Plainssource: Lucas Associates & Ian Lynn, Landcare Research 1995

1850 Landcover of Christchurch source: Lucas Associates 2011, based on Waterways, wetlands, and vegetation cover of the Christchurch Region, as at 1856. Modified by J. Walter based on a compilation in Wilson (1989), which was based on the Black Rural Section cadastral maps of 1856.

Addington Brook

HagleyOval

Underlying Ecosystems of ‘the site’

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Hagley Oval

Hagley Oval

LiDAR image (DRAFT March 2011) LiDAR image (DRAFT March 2011) with embankment proposal

Addington Brook Addington Brook

Riccarton AveRiccarton Ave

Avon RiverAvon River

attachment 11

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HAGLEY PARK MANAGEMENT PLAN 2007

27

Hagley Park Landscape Zones

source: Hagley Park Management Plan 2007, Christchurch City Council attachment 12

Page 45: Hagley Oval Evidence Di Lucas

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Convention Centre

Papa o Ōtākaro Avon River Precinct

Te Puna AhureaCultural Centre (indicative)

Cricket Oval

Metro Sports Facility

Justice & Emergency Services Precinct

Health Precinct

The Frame

Retail Precinct

Botanic Gardens New Visitor CentreNew Visitor Centre including inter pretation and information facilities, a new café and greenhouses

Christchurch Hospital

Antigua Boatsheds and FootbridgeHistoric riverside recreation since 1882

Cambridge TerraceLocal tra�c and buses only along part of Cambridge Terrace to provide widened river corridor

Bridge of RemembranceWar memorial and gathering space at the end of City Mall. Design improved to remove visual barriers and improve access

Addington Brook

Riccarton Stream

Canterbury Provincial Council BuildingsHeritage buildings that housed the early provincial government

Additional islands provide habitat for birds

Deciduous canopy trees to provide shade in summer

Commuter cyclists on true left bank

Christchurch Central Blueprint Summary (pp 5-6) overlain with Avon River Precinct Te Papa o Ōtākaro (pp 55-56)

source: Christchurch Central Recovery Plan, 2012

attachment 13

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Hagley Park on a winters day without the maintenance fence Cricket in Hagley Parksource: Save Hagley Park’s Facebook page source: Save Hagley Park’s Facebook page

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St Albans Pavilion and Umpires Pavilion source: Athfield Architects Ltd Hagley Cricket Oval Perspectives, View 4 Existing p.10

10-22Hagley Oval 23.01.13

P.10

hagley cricket oval / perspective images

View Four: Existing

attachment 15

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Photo Locations

DEAN

S AVE

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source: Google Earth, 26th April 2013

view 7

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view 2

view 4

view 5

view 6

view 1view 8

view 11

view 9view 10

view 12view 13

view 20

view 22

view 23

view 21

view 14view 16

view 17 view 18 & 19

view 15Hagley

Oval

temporary carpark

MOORHOUSE AVE

attachment 16

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VIEW 1: Existing entry into the Horticultural Hall carpark from Riccarton Ave. Photo taken: 29th April 2013

attachment 17

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VIEW 2: Looking south along Addington Brook toward Horticultural Hall Photo taken: 29th April 2013

attachment 18

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VIEW 2: Looking north along Addington Brook to Riccarton Ave. Photo taken: 29th April 2013

attachment 19

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VIEW 3: Looking north along Addington Brook, Horticultural Hall access on left Photo taken: 29th April 2013

attachment 20

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VIEW 4: Looking north along Addington Brook, Old Boys Collegians Pavilion on right to be demolished Photo taken: 29th April 2013

attachment 21

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VIEW 5: Addington Brook (Old Boys Collegians Pavilion on left to be demolished) VIEW 6 : Addington Brook by Horticultural HallPhoto taken: 29th April 2013 Photo taken: 29th April 2013

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VIEW 7a: Looking south over Hagley Oval from second floor of Umpires Building

VIEW 7b: Looking south over Hagley Oval from second floor of Umpires Building (panorama stitched)

Photo taken: 23rd April 2013

Photo taken: 5th May 2013

Horticultural Hall

Old Boys Collegians Pavilion (to be demolished) Store Shed (to be demolished)

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VIEW 8: Looking south over Hagley Oval from beside Umpires Pavilion Photo taken: 23rd April 2013

Horticultural Hall

Old Boys Collegians Pavilion (to be demolished)Umpires Pavilion Store Shed (to be demolished)

attachment 24

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VIEW 9: Looking south over Hagley Oval from carpark on Riccarton Ave. Photo taken: 23rd April 2013

Horticultural Hall

Old Boys Collegians Pavilion (to be demolished)Umpires Pavilion

St Albans Pavilion

Groundsmans House

attachment 25

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VIEW 10: Looking south over Hagley Oval from Line Walk Photo taken: 29th April 2013Old Boys Collegians Pavilion (to be demolished)

Groundsmans House

Umpires’ PavilionSt Albans PavilionRiccarton Pavilion

attachment 26

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VIEW 11: Looking south-east over Hagley Oval to the Port Hills

Old Boys Collegians Pavilion (to be demolished) Horticultural Hall

Photo taken: 23rd April 2013

attachment 27

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VIEW 12: Looking south through Line Walk and over Hagley Oval Photo taken: 29th April 2013

Umpires’ PavilionSt Albans Pavilion Groundsmans House Old Boys Collegians Pavilion (to be demolished)

attachment 28

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VIEW 13a: Looking south through the line walk and over Hagley Oval

VIEW 13b: Looking south through the line walk over Hagley Oval with dashed green line as indicative embankment height

Photo taken: 29th April 2013

Horticultural HallOld Boys Collegians Pavilion (to be demolished)

Groundsmans HouseUmpires PavilionSt Albans Pavilion

attachment 29

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Photo taken: 23rd April 2013VIEW 14: Looking north-east over Hagley Oval from Line Walk

Photo taken: 23rd April 2013VIEW 15: Looking north-west over Hagley Park South over Christs College grounds

Umpires’ PavilionSt Albans PavilionRiccarton Pavilion

Groundsmans House

Old Boys Collegians Pavilion (to be demolished)

Horticultural Hall

attachment 30

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Photo taken: 29th April 2013VIEW 16: The Line Walk entrance from Riccarton Avenue and carpark

attachment 31

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Photo taken: 29th April 2013VIEW 17a: Looking north-east over Hagley Oval from near Christs College facilities

Old Boys Collegians Pavilion (to be demolished)Groundsmans HouseUmpires PavilionSt Albans Pavilion

attachment 32

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Photo taken: 29th April 2013VIEW 17b: Looking north-east over Hagley Oval with dashed green line as indicative embankment height

attachment 33

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Photo taken: 29th April 2013VIEW 18: Looking north-east over Hagley Oval with dashed green line as indicative embankment height

Old Boys Collegians Pavilion (to be demolished)Groundsmans HouseUmpires PavilionUmpires Pavilion

attachment 34

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Photo taken: 29th April 2013

Photo taken: 29th April 2013

VIEW 19b: Looking north-east over Hagley Oval with dashed green line as indicative embankment height

VIEW 19a: Looking north-east over Hagley Oval

Old Boys Collegians Pavilion (to be demolished)Groundsmans HouseUmpires PavilionSt Albans Pavilion

attachment 35

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Photo taken: 23rd April 2013VIEW 20a: Looking east from Deans Ave over Hagley Park South to Hagley Oval & Umpire´s Pavilion

Store shed (to be demolished)Umpires Pavilion Groundsmans House, grandstand & sheds

attachment 36

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Photo taken: 23rd April 2013

Umpires Pavilion

Groundsmans House Groundsmans House, grandstand & shedsSt Albans Pavilion

VIEW 20b: Looking east from Deans Ave over Hagley Park South to Hagley Oval & Umpire´s Pavilion

attachment 37

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VIEW 21: Hagley Avenue and Netball Association building (Atrium in the Park) Photo taken: 5th May 2013

attachment 38

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VIEW 22a: From Hagley Ave over Netball court mound Photo taken: 5th May 2013

attachment 39

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VIEW 22b: From Hagley Ave over Netball courts, across temporary carpark to Hagley Oval Photo taken: 5th May 2013

attachment 40

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VIEW 23: Hagley Avenue’s Avenue Photo taken: 5th May 2013

attachment 41

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Photo taken: 29th April 2013Looking east from Riccarton Ave over Hagley Park North

attachment 42

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Photo taken: 29th April 2013Hagley Park North from Riccarton Ave looking over Rugby Fields through to Tennis Club

attachment 43

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source: Canterbury regional urban stream sediment and biofilm quality survey p 67, report prepared for ECAN by Golder Associates, January 2012

source: clipped from Canterbury regional urban stream sediment and biofilm quality survey p 27, report prepared for ECAN by Golder Associates, January 2012

CANTERBURY REGIONAL URBAN STREAM SEDIMENT AND BIOFILM QUALITY SURVEY

January 2012Report No. 1078105525 65

6.6 Implications of Changes in Metal Concentrations in Sediments The ANZECC (2000) sediment quality guidelines are used in this section to assess the potential effects that sediment quality may have on biological communities inhabiting the stream. Increased concentrations of metals in stream sediments have the potential to adversely affect stream biota that inhabit these sediments. Toxicity arises through the exposure of organisms to pore water within the sediments. Metals adsorbed to sediment particles are in equilibrium with the metals in the pore water. The concentration in the pore water is a function of many factors including the redox state of the sediment (how much oxygen is present) and the rate of diffusion between the pore water and the overlying stream waters. Concentrations can in some situations become high enough to exert toxic effects on biota. It should be noted however, that toxicity may arise from constituents other than metals. Ammoniacal nitrogen is common in stream-bed sediments especially if organic matter builds up and the sediments become anaerobic. A number of studies have shown that ammoniacal nitrogen in sediments is often implicated as the prime causal agent of toxicity.

In Figure 25 and Figure 26 the concentration of copper, lead and zinc has been presented graphically in a traffic light system, where green denotes sediment metal concentrations were below the ISQG-Low, yellow denotes concentrations above the ISQG-Low, but below the ISQG-High, and red denotes concentrations above the ISQG-High. Table 9 provides a summary of the ANZECC (2000) ISQG exceedences.

Only two ISQG-High trigger values were exceeded across the entire survey:

Zinc in Addington Brook at Riccarton Ave (Christchurch)

Lead in Taitarakihi Creek at SH1 (Timaru)

All sites recorded cadmium, chromium and nickel concentrations below the ISQG-Low trigger value. This indicates that concentrations of these parameters would be unlikely to cause adverse effects on aquatic biota.

Arsenic concentrations were below the ISQG-Low trigger value at all sites except for Addington Brook at Riccarton Ave (Christchurch). Copper concentrations exceeded the ISQG-Low trigger value at one site (Heathcote River/Ōpāwaho at Annex Road).

Lead and mercury concentrations were below the ISQG-Low trigger value at the majority of sites. Dock Creek at Chamberlains Park (Amberley) and Avon River/Ōtakāro at Fitzgerald Ave (Christchurch) reported lead and mercury concentrations above the ISQG-Low trigger but as noted above, lead exceeded the ISQG-High trigger in Taitarakihi Creek at SH1 (Timaru).

Zinc concentrations exceeded the ISQG-Low trigger value at 10 sites and as noted above, zinc exceeded the ISQG-High trigger value in Addington Brook.

Table 9: Summary of sites where exceedences of ANZECC (2000) sediment quality guidelines were found in this study. Site No. Location Arsenic Copper Lead Mercury Zinc

3 Dock Creek4 Dock Creek10 Avon River/Ōtakāro13 Avon River/Ōtakāro15 Addington Brook

16 Heathcote River/Ōpāwaho

18 Heathcote River/Ōpāwaho

19 Heathcote River/Ōpāwaho

source: Canterbury regional urban stream sediment and biofilm quality survey p 65, report prepared for ECAN by Golder Associates, January 2012

Hagley Oval

Addington Brook sampling site 15

attachment 44

Page 77: Hagley Oval Evidence Di Lucas

CANTERBURY REGIONAL URBAN STREAM SEDIMENT AND BIOFILM QUALITY SURVEY

January 2012Report No. 1078105525 49

Table 8: Metal/metalloid concentrations in sediment samples collected from Canterbury streams. Site Number Waterway Arsenic Cadmium Chromium Copper Lead Mercury Nickel Zinc

1 Lyell Creek 6.4 0.32 17 27 27 0.094 16 160

2 Lyell Creek 5.4 0.12 14 14 17 0.065 13 81

3 Dock Creek 4.8 0.45 20 32 150 0.17 10 260

4 Dock Creek 2.8 0.21 12 11 17 0.078 9.1 220

5 South Brook 2.4 0.056 11 7.6 14 0.044 7.5 57

6 Middle Brook 3.4 0.12 12 27 48 0.071 8.6 140

7 North Brook 2.0 0.062 11 8.2 19 0.080 8.7 79

8 Avon River/Ōtakāro 7.7 0.15 30 20 32 0.11 15 150

9 Avon River/Ōtakāro 3.7 0.11 17 14 25 0.060 14 110

10 Avon River/Ōtakāro 4.4 0.52 19 40 110 0.17 14 380

11 Avon River/Ōtakāro 1.9 0.074 12 10 20 0.051 11 81

12 Avon River/Ōtakāro 1.0 0.12 11 8.9 27 0.047 8.9 120

13a1 Avon River/Ōtakāro 3.6 0.28 15 35 70 0.083 9.4 250

13b Avon River/Ōtakāro 4.0 0.30 15 38 70 0.077 9.4 250

13c Avon River/Ōtakāro 4.0 0.29 16 41 72 0.086 10 270

14 Dudley Creek 2.1 0.052 10 4.6 14 0.038 8.4 61

15 Addington Brook 21 0.24 16 16 39 0.047 14 500

16 Heathcote River/Ōpāwaho

4.6 0.30 28 25 36 0.078 13 250

17 Heathcote River/Ōpāwaho

2.1 0.040 11 6.0 10 0.043 8.6 71

18 Heathcote 7.3 0.45 21 54 50 0.087 14 410

CANTERBURY REGIONAL URBAN STREAM SEDIMENT AND BIOFILM QUALITY SURVEY

January 2012Report No. 1078105525 75

Table 15: Trace element concentrations in biofilms from urban streams in Canterbury. Site Number Waterway Arsenic Cadmium Chromium Copper Lead Mercury Nickel Zinc

1 Lyell Creek – Information Centre 9.2 0.2 35 85 16.5 0.21 27 115

2 Lyell Creek – u/s SH1 11.4 0.25 29 92 10.9 0.26 27 92

3 Dock Creek – Chamberlains Park 9 0.42 53 124 121 0.23 48 450

4 Dock Creek – d/s Lawcocks Rd 6 0.32 68 73 21 0.29 35 200

5 South Brook - u/s Railway Rd 7 0.25 68 96 23 0.34 35 2406 Middle Brook- Denchs Rd 12.5 0.27 42 74 108 0.19 28 390

7 North Brook – d/s stormwater pond 8.8 0.31 46 90 55 0.32 47 174

8 Avon River/Ōtakāro – Pages Rd 18 0.19 40 28 49 0.2 20 157

9 Avon River/Ōtakāro – Kerrs Reach 15.9 0.23 35 54 57 0.21 32 320

11 Avon Rivew – Antigua Boatsheds 10.3 0.41 38 92 79 0.33 30 460

12 Avon River/Ōtakāro – Carlton Corner 16.4 0.43 33 98 93 0.36 34 410

13 Avon River/Ōtakāro – Mona Vale 10 0.36 67 128 130 0.3 49 260

14 Dudley Creek – Banks Ave 24 0.61 41 62 129 0.21 29 780

15 Addington Brook – Riccarton Ave 90 6.0 39 121 80 0.23 91 7,100

16 Heathcote River/Ōpāwaho –d/s the cut 10.6 0.32 56 43 59 0.16 21 300

source: Canterbury regional urban stream sediment and biofilm quality survey p 49, report prepared for ECAN by Golder Associates, January 2012

source: Canterbury regional urban stream sediment and biofilm quality survey p 75, report prepared for ECAN by Golder Associates, January 2012

Addington Brook sampling site 15

Addington Brook sampling site 15attachment 45

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CANTERBURY REGIONAL URBAN STREAM SEDIMENT AND BIOFILM QUALITY SURVEY

January 2012Report No. 1078105525 77

a) Arsenic b) Cadmium

c) Chromium d) Copper

Figure 27: Concentrations (mg/kg) of (a) arsenic, (b) cadmium, (c) chromium and (d) copper recorded in biofilms and sediments at stream sites sampled in 2011. ANZECC recommended sediment quality trigger values for ISQG "high" and "low" are shown. Site names and corresponding site number are listed in Table 2.

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ISQG - High 270 mg/kg

CANTERBURY REGIONAL URBAN STREAM SEDIMENT AND BIOFILM QUALITY SURVEY

January 2012Report No. 1078105525 78

a) Lead b) Mercury

c) Nickel d) Zinc

Figure 28: Concentrations (mg/kg) of lead (a), mercury (b), nickel (c) and zinc (d) recorded in biofilms and sediments at stream sites sampled in 2011. ANZECC recommended sediment quality trigger values for ISQG "high" and "low" are shown. Site names and corresponding site number are listed in Table 2.

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ISQG - High 220 mg/kg

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ISQG - High 410 mg/kg

ISQG - Low 200 mg/kg

*Biofilm Zinc Concentration at Site 15 continues to 7100 mg/kg

source: Canterbury regional urban stream sediment and biofilm quality survey p 77, report prepared for ECAN by Golder Associates, January 2012

source: Canterbury regional urban stream sediment and biofilm quality survey p 78, report prepared for ECAN by Golder Associates, January 2012

Addington Brook sampling site 15

attachment 46

Page 79: Hagley Oval Evidence Di Lucas

attachment P39

View from Titirangi Road over Melville Cove

Gannet Point

Sanford Pool Head mussel farm

Port Gore Saddle

Mt FurneauxMelville Cove

Tinui

Hagley Park South sign on Deans Ave. Photo taken: 29th April 2013

attachment 47

Page 80: Hagley Oval Evidence Di Lucas

Appendix 1 - DI LUCAS, LANDSCAPE ARCHITECT, CV

Director of Lucas Associates Limited, Christchurch, a Registered NZILA Landscape Architect and Fellow member of NZILA (1987), Di works in community -friendly planning and design processes for creative and sustainable solutions. Having skills in landscape assessment, landscape ecology and restoration, natural character analysis, community consultation, heritage values, sustainable resource management, creative problem solving and documentation, Di works on a range of projects around Aotearoa New Zealand. Projects vary in scale from broad frameworks for regions, districts and towns to planning development or restoration for specif ic sites, working for community, industry, landowners, iwi and government agencies.

Di has undertaken landscape assessments for a wide diversity of projects and locales, uti lis ing an holistic approach. She has undertaken assessments and prepared plans and proposals under various conservation statutes as well as the RMA.

The Lucas Associates team has twice been awarded New Zealand’s premier landscape planning award, the NZILA Charlie Challenger Award, the only recipient of this award in the decade to 2005. Di received a NZILA landscape planning 2008 Gold Award for evidence to the Environment Court.

Assessment and Planning Di Lucas is a qualif ied Resource Management Act decision maker .

Landscape assessment, reporting and preparation of evidence, including to council and Environment Court hearings, regarding landscape, natural and amenity value s of rural and urban areas, and sites, working variously for individuals, landowners, community groups, iwi, councils and government departments.

Community Plans Facil itation of rapid community-based workshops ranging nationwide, town and/or country, with on-site immediate follow up preparation of community plans and documentation - typically a week or a month from “go to whoa”.

Biodiversity and Land Collation and communication of complex scientif ic data through the interpretation of land, geomorphology and biodiversity, enabling restoration via easy to understand field booklets, brochures and plans.

Sustainability Sustainable management plans recognising natural and cultural values, land use practices and alternative markets, through enhanced landscape mana gement.