Form 7
Notice of appeal to Environment Court against decision on
proposed policy statement or plan
Clause 14(1) of Sche du le 1 , Resour ce Management Act 1991
To the Registrar Environment Court Wellington
1. Wellington Civic Trust appeals against a decision/part of a
decision of the Wellington Regional Council on the Proposed Natural
Resources Plan for the Wellington Region.
2. Wellington Civic Trust made a submission and further
submissions on the Proposed Natural Resources Plan for the
Wellington Region
3. Wellington Civic Trust is not a trade competit or for the
purposesof section 3080 of the Resou rce Management Act 1991.
4. Wellington Civic Trust received notice of the decision on
31st July 2019.
5. The decision was made by the Wellington Regional Council.
6. The decision/part of the decision that Wellington Civic Trust
is appealing is:
The part of Decision 16, Significant Historic Heritage Values,
that refers to the submission by Wellington Civic Trust seeking to
retain protected st at us for all heritage items (being part s of
wharves and harbour edge structures in the Lambton Harbour) which
are currently identified and protected under the Operative
Wellington Regio n al Coastal Plan.
7. The reasons for the appeal are as fo llows :
a) The decision errs in that it fails to recognise the historic,
social and cult ural significance of the already protected items
within the Lambton Harbour area;
b) The decision errs in that it based its assessment on the
advice of heritage architects only, and overlooked other import ant
socia l and cultural component s of the items sought to be included
which are recognised by the wider public;
c) In reaching its decision, Wellington Regional Council failed
to correct ly apply Method 20 of the Regional Pol i cy Statement
(RPS;)
d) In parts of its decision, Wellington Regional Council
appeared to require that protection of places and items in the
coast al marine area must meet a t est of " regiona lly sign ifi
cant" (see paragraph 5.10, 5.11 of the decision). This is
incorrect in terms of both stated RPS po licy and the Resource
Management Act it self.
e) The decision overlooks or misunderstands the wider role of a
regional council in the coastal marine area, and applied a higher
policy test in that area than applies in relation to protection of
heritage in relation to district plans, where items of
"district " significance only are regularly listed for prot
ection; and
f) The decision is wrong in fact and in law.
8. Wellington Civic Trust seeks the following relief:
That the parts of the wharf edges and reclamation edges which
are currently protected under the Regional Coastal Plan are also
recognised and incorporated as part of the sites of historic
heritage values for protection in the Proposed Natural Resources
Plan , within Schedules El and E2 and on the relevant maps.
Any alternative means by which the same outcome is achieved
.
9. The following documents are attached to this notice:
a) a copy of the original submission (Appendix A)
b) a copy of the relevant decision/part of the decision
(Appendix B)
c) a list of names and addresses of persons to be served wit h a
copy of this notice (Appendix C).
(Jim McMahon - Chair, Wellington Civic Trust) gnature of person
authorised to sign
on behalf of appellant
18t h September 2019
Address for service of appellant:
PO Box 10183, Wellington 6143 and c/ o 26 Patrick St, Pet one ,
Lower Hutt, 5012
Telephone: 021665155
Fax/email: sylvia jallan@out look .com
Contact person: Sylvia Allan
Advice to recipients
How to become party to proceedings
You may be a party to the appeal if you made a submission or a
further submission on the matter of this appeal.
To become a party to the appeal , you must, -
· within 15 working days after the period for lodging a notice
of appeal ends, lodge a notice of your wish to be a party to the
proceedings (in form 33) with the Environment Court and serve
copies of your notice on the relevant local authority and the
appellant; and
· within 20 working days after the period for lodging a notice
of appeal ends, serve copies of your notice on all other part
ies.
Your right to be a party to the proceedings in the court may be
limited by the trade competition provisions in section 274(1) and
Part llA of the Resource Management Act 1991.
You may apply to the Environment Court under section 281 of the
Resource Management Act 1991for a waiver of the above timing or
service requirements (see form 38).
How to obtain copies of documents relating to appeal
The copy of this notice served on you does not attach a copy of
the appellant's submission and (or or) the decision (or part of the
decision) appealed. These documents may be
obt ained , on request, from the appellant .
Advice
If you have any questions about this notice, contact the
Environment Court in Wellingt on.
APPENDIX A - Copy of the Appellant's submission to which the
appeal relates
,
greater WELLINGTON
· . . ... .. . u ..., . .. ..
Full name Organ,sahon name
WELLINGTON CIVIC TRUST
PO Box 10183 Wellington 6143
Telephone no s Contad person
Won<
Sylvia Allan
HomeCell021665155
Address and telephone no 111different from abO\el
Welhngton Regional Council has a preference foi providing
informalton about the Proposed Natural Resources Plan via email We
wlfl send you updates on tne process informauon and provide you
With dela11s of any meetings and tne heanng Please
hck here O if you do not agree to receive commun,cauon via
email
Ema,1addresssylv1a allan@1hug co nz
E) I/We c ould not gain an advantage ., trade competn1on
ttuough111,s sobrl'llss,on {Go s1ra,gn110 Your Subm i ss i on ]
O I/We c ou ld gain an advantage in trade compe11110n through
1h1s submission If you c ould ga,n an advantage please comp1e1e one
of the following
O I/we are directly affected by an effect of the subJect maner
of my subm1ss1on that adversely affects the environment and does
no1relale lo trade compet1110n or the effects of trade
compe1111on
O I/We are not directly affected by an effec1 of the subJed
maner of my subm1ss1on 1ha1 adversely affects the env,ronment and
does not re1a1e 10 trade compet ,on or the effects of irade
compe111,on
The Wellington Civic -rustHlle Trust appreciates the opportunity
to make a formal subm1ss1on on the Proposed Natural Resources Plan
NRP for the Wellington Region The -rust acknowledges that some of
itscomments on the draft have been addressed Howe1,1er some remain
and are outlined below
The Wellington Civi-c
rustwas founded in 1981 and has among ,ts objectives:
To promote a c,v,c environment whereby the City of 'Nell1ngton.
its surrounding, sand its adJacent countrys,de becomes a resource
fo• the use benefit and enJOyment of all wellington citizens
To stimulate public interest ,n and care for the beauty history
and character of the City of Wellington and its surroundings and
adjacent countryside and coastline an,d ts dignity as the Capital
City
-o create or improve features of beauty or interest ,n and about
the C,ty and ,ts conltguous countryside and coastline
While the -rust has a wider ,merest,n the ,eg,on and ,ts
sustainable management its key focus 1s I/le Wellington City urban
area aoo nearby surroundings inc1ud1ng the coast and coastal manne
area (CMA, The Trust supports a compact city with effectJve pubhc
transport .vhich conta,ns and as far as ,s pracucable mIrnm1ses
adverse effects on the wider natural environment
These submissionsare made on the basis of that focus
The Trust notes the ,mpcrtanl role of the Nha1tJa comminees in
the Management of water resources ,n the region The Trust has a
particular interest In the Wellington Harbour and Hutt Valley
Wha1tua and seeks that sufficient resources are made available for
11 to urgently advance ,ts ,mportant work of ensunng water quality
1s generally improved in accordance with the Nattonal Policy
Statement for Freshwater Management g,11en that Wellington C,ty and
the Hutt Valley contain the regions largest and most
intenselydeveloped urban areas .'Ve look forward to seeking these
national policies implemented more effectively both w1th1n and
beyond the confines of this Plan
.. .e s:e,:..f,c :tc., , ,:- •-e ='·')00: t:"e
o'..· e ..:..r( t;::io P d· · \ •· , s..t'"' ..,
reJa•E I .. C e c:)0: •Oil , , L l.,"W '::,
Sectton 2 - Definition of Lalq_bton Harbour
\4l ! ..C,,.,. "-'!' s
t'!t:;, - . ' +
01 support the prov,sIon
:J1 oppo se '"e prov,s,on
:::]1wish 10 nave the spec1f1c prov,s,on amended
Th,s definition 10 assooauon with Map 32 effecuvely extends the
Lambton Harbour area toinclude wharfs and CMA to the north This has
consequences in terms of planning for this area
Map32y--• l"'-e lQt lt !'IQ
'rot"' A":
The Civic Trust supports the extension as provided for 1n the
definlbon andmap In general terms subJect to the careful management
of development ,n the area
· ne-:r":"..!ccro. onc/ 'tie., j
,, , J "' .,
r 01
-
support the p1ovIst0n
\atura ;; ..Ot;_' '".!;5- ;:.ii" •·a, -n, iwt m,s or reia·c'-"
•c.,oe:.·, t"'-eprov c o,, 1!CC: on n.mcer
5ecL - :.i;.," t1Ct' · ,\ -,.aJ .,a
: 1 • S 5
0 1 opp o se the pro, v, s on
01 wish 10 have the spec,f1c pro11Is,on amended
----'"--
The reference to designated area m this defrmuon 1s
confusing as ·designaedt area has a specific meaning ,n the
_I This point was made inthe Trust s subm1ss1on on the
(,ec·,)• 1-, •":C-A "'
" IY" M=
_"l.,e i:,eose .:>eta ,-
d lanand 1t 1s d1sappomt1ng that we nave to make It again
Replace designated area w,th specified area or defined area
Tr De-:1 C OfO-, '-;On c• .,.E: ..or< ..j
•l dw• ra i::>CNrc = ; ., .., ,1 ""' r --Jt.m!t"
"eJ.;• '"' tS ;:i .3'-.,J, S: '" t, r.,.:. ?v ' ,,.
-.. .n"1.1moo•
ObJect,ves 010 019 023 034
053 toO56
,,,, !l...!)r"l .... r,n ,:n•n ,
S:f-..- I,... -+
Ii'-• '"> u, A ",;
.,,.- ,\rK
, ,fo •.;.• c;:; C:.'.:.',3:lc;
0 1 supp o rt the pr ,s,on
01 opp ose the prov,s,cn
C:1 wish10 have lhe spe¥c prov,s,on am ended
Tnese obJect1ves are particll\qrty pported
Retain the specified ob)ecttves with eir current wording
-,.E- sr•: ·..ctfC- " "'' •t-e =re:-,c i:-:::
".a'u:al ::13 :,v :;i: =.a..'"'al ,r • ., JCm:,, ,:y,
e1a'.t:S10 s t; ecb:= -,::e:·, •rie :-t'O-, !I or
Pol,lcesP7 3 toP79
'h ;wr rr. a 0f'1 on •"Is
tfC-• -, ; ...
(.\ c):ttt • tf'le' .:,..,n
-=...c.-
.. , r•f:C,..:1; Ct-•.a ..
'.]1support 1he prov1s10n CJI oppose lhe prov,s,on
'.]1wish 10 have the spec,f,c prov,s,on amended
The Trust recognises that a comprehens,ve approach to stormwater
manageme,t s nee
Retain poltc,es unchanged
-'le ._, , : :re--.;:r- C.'"'le P• :-(l-.e0
·•aiw•a ::.e_s:,u•--;:;s;: a,., '"'a·.,.f C._..Ot!" "'" O"'I
re"..3fes o 5 oiea 1-0€(..', 'nt!oro, on
Policy P142
·rw:- s :e:..'-t:r:. sy t· tt... t:ft:tSfO
(-).., at.ijra .;,e ource... :, J- 'U! 'Tl, Jt'."'1s, -
retatt:-::- 1; : ': :}!-t- ')pee', ,.,,t o,o,.. (.=-:_,:or, nt
IT'tPr
Schedule E1 and E2 - H,stonc Hentage Structures and HIstonc
Hentage Wha!'lles and Boatsheds
'•') 5_c.,or "'"_. ,. •r: "
:•u,Sil" s
r f l ,:W ...
- , ;, •
::,_._ tt ... 10:awlt ng
· -- ,-orri i/\:;i,:
.,, : C<;'JJ '?ta
•,, ..t: S'-
:'°,..•"..
; t.:C.. S ' J' :T!,
"J '!-!
I support the pro,v s10n
:Ji o pp o se lhe prov,s,on
01 w,sh 10 have lhe spec,r,cprov,s,o,i amend ed
This Is a detailed and comprehensive policy wh,ch the Trust
cangenerally suppon However there appears to be a policy gap
inrelat,onto the recognition of the Wellington Waterfront
Framewor'rt. 2001 In this Plan This has been reconf,rmed in recent
years by WCC and remains a core document for the harbour area south
of Bunny St as Wellington s acknowledged i ewel ,n the crown The
harbour area north of Bunny St may have different charactenstics
but have strong visual and functional relat1onsh1ps between each
other and across land and sea and any GWRC WCC divide as to
planning intent and urban design pnnc1ples nsks undermining the
opbmum development of both areas Omnting clear reference to the
aterfront Framewor'rt. risks further concern from cihzens who
reasonablyenough. see their harbour In a holishc ·character of the
clty" sense rather than ,n a technical adm1n,stra11ve sense split
bew een two different counclis While there Is a reference to des,gn
guides ,n Pohcy 14201 and there Is a design guide ,n Wellington Cny
D1stnctPlan for the Lambron Harbour Nonh area there Is oo des1gr
guide for the remainder of the L.ambton Harbour area Rathe1 there
,s reference to but not
,ncorporat10n of) the Framework In the O,stnct Plan ItIs
unlikely that that document would be regarded as·contained Within
the Olstnct Plan
includespecific mention ol the WelingtonWaterfront Framewofl(
2001 ,n Policy Pt42 01
:Ji support the prov,s,on
01oppose the prov1s,on
:J i w1sn 10 have 1ne specific prov1s1on ame,ided
The schedules have retained some of the items,n the Reg,ona'
Coastal Plan. but not all The Section 32 analysis relating to the
,terns ,n the Regional Coastal Plan. incul ding mapped items In
Lambton Harbour Is cnucal of the 1nformat10n on which they were
1dent1fied
Ho.vever 11nee
,see ''."It! ' ,. ,. "9
trlll" A'':;
, ,. ,- e :it :.i :;
.....,e..;:,e:i• ::1 ,. or, •• e= rip: ...\ 1 , !i err '"S
,.,,,..-,, '" I;
. 311:, a=i t:':-..v,ces= lflt..al m, suom-s) .lfl :rrc--, sc:,
-t
Schedules F1 and F4 -,.c- "
Ka1wharawhara Stream
(,=, :)£1;• t fo'J .\ '>;
Jet. ' onr
; , C': e::..se l e:
tiave their own,megnty and recognition which may not be
acknowledged by peop:e in the category of conservauon architect
h1stonan and archaeologist who have lately been brought ,n to
advise GW and who compnse one opinion only Miss,ng from the l,st ,s
Harbour Board Gates 1899 on Queens
,'Vnarf which may nave been shifted/ and pan of the WestpOn
Chambers facade Circa Theatre - wt11ch Is no longer listed on the
D1srncr Plan
Wharves and wharf edges and rec1ama11on edges which are still In
place are however m,ss,ng Pans of these areas are picked up by the
comprehensive hs1Ing of Queens Wharf Ferry Wharf Railway Wharf
Taranak1Street wnarf and Waterloo Quay Wharf However lhe wharf and
reclamation edge protectJOn which reflec1s the harbour edge at the
ume the Lambton Harbour wa1erfront was handed ove• to the c,1y
101pubhc use 11,s not ,ocluded
The Civic Trust seeks that the parts of the wharf edges and
reclamauon edges which are currently protected under the Regional
Coasta' Plan are also recognised and ,ncorporated as pan of the
sites of h1stonc hentage values in the Proposed Pian
::]1 support theprov1s10n
::Ji oppos e lhe orov,s,on
::Ji w,sti 10 nave ine spec1f1c prov,s,on amended
The Trust suppons the 1nclus10n of the Ka,wharawhara Stream and
estuary within these schedules The Trust has aparticular interest
,n the nonhem gateway approach to Wellington Cny
of which the Ka,wharawhara reclamation area and Ka,wharawhara
Stream Is a pan The Trust considers that th,s area should be the
subJect of a JOtnt planning exercise for its future between the
City and Regional Councils to ensure its Iong-term sustainable
management It ,s d1sappom11ng that sucna io•nt plannmg exercise
hasnot been undertaken pnor to
· the development of this Plar - espec,ally given the conunuing
and close wortung rela110nshIps that GWRC has with lhe transpon
enrnIes ICenrtePon K1w1Ra,I and NZTAt operating In this area
Someone has to take 1eadersh1p in this and GWRC with its harbour
andland transpon accountab1lrt1es Is weII pos1t10ned to do so on
the basis of clear and strong commitments to ,ntegrateits planning
regimes
Reta,n the listing as recognrt,on of this important area
Att •danddn
0I/We do wish to be heard in support of my/our submission
(Note This means that you wish to speak In support of your
subm1ssIon at the heanng(s) J
0 I/We do not wish to be heard In support of my/our
subm,ssIon
(Note This means that you cannot speak at the heanng l"lowever
you will sull retain your nght to appeal any deos1on made by the
Wellington Regional Counol to the Environment Court ]
0If others make a s1mIlar submission . t will consider
presenting a 10Int case wnh them at a hearing
"\i
Date2210912015
[Person making submission or person authonsed to sign on behalf
of person making subm1ss1on . NB Not required 1f making an
electronic subm1ss1on)
Wellington Regional CounCJI ,s legally required to noufy a
summary of submIss1ons including your name and address for service
as provided on this submission form Your name and address are
included so that a person making a further submission Is able to
serve you with a copy or 11
APPENDIX B - Copy of decision/part of decision to which the
appeal relates
Decision/Parts of Decision Appealed by Wellington Civic Trust
From P575 onwards, Decision Report Part 2
Schedule E1
5.5 On thegrounds that as an integral part of the coastal road
infrastructure subject to climate change and weather events they
would need to be upgraded or
replaced in future, WCC sought the deletion of the following
from Schedule El relating to historic heritage structures:
(a) Aberdeen Quay;
(b) Oriental Bay Seawall; and
(c) Evans Bay Seawall.26
5.6 Mr Lewandowski indicated that WCC would not be opposed to
the retention of these items in Schedule E1 if changes were made to
policies and rules to
provide greater certainty and flexibility as to their upgrading
and / or
replacement. However, and in the absence of any evidence to the
contrary, we accept Mr Kelly and Mr Cochran's evidence for the
Council that all three structures meet the criteria for listing,
and that they should therefore be retained.21
5.7 In addressing this man er, Ms Legarth noted that the listing
for Aberdeen Quay
contains an error - the listing relates to the seawall, not the
quay as a whole.2s Therefore we have altered the title of that
listing in Schedule E2, and acknowledge that its representation on
Map 8 can be corrected as a clause 16 matter. In doing so, we
accept WCC-s relief in part, to the extent that the above changes
will clarify that it is only the seawall and not the entire quay
that is significant in historic heritage terms.
5.8 In its submission, WRMFA29 sought the inclusion of three
additional structures
in Schedule E1, namely Fort Opau. Moa Point Look Out Post and
Barracks and Fort Balance. No heritage technical evidence was
provided to support their inclusion. Moreover, Ms Legarth drew our
attention to the fact that the inclusion of land-based sites is
beyond the scope of what are regional coastal provisions in the
PNRP.Jo We therefore reject the relief sought by WRMFA.
5.9 The Wellington Civic Trust sought the addition of the edges
of specific wharves and reclamations in Schedule E1; these being
interface features associated with the history of Lambton Harbour
that the Trust noted are protected under the operative Regional
Coastal Plan.Ji We received planning evidence from Ms Allan on this
matter at the hearing, relating to the value of these features as a
record of the Harbour's development over time; a value that. in her
opinion, continues to be appreciated by the public.J2 Howeve r, Mr
Kelly and Mr Cochran concluded that the edges of the reclamations
do not meet the tests in RPS Policy 21,JJ for inclusion in Schedule
E1 and again as this was uncontested evidence we accept this
technical assessment.
5.IO As an alternative to the inclusion of wharf edges and
reclamation edges on
Schedule El, Ms Legarth recommended the creation of a new
Schedule 'E6" and Policy ' 46A' that would incorporate such
structures in recognition of their collective maritime heritage
value of Lambton Harbour. This recommendation is dealt with more
directly in paragraphs 5.33 to 5.39 below. However, it is
sufficient to note here that Ms Legarth acknowledged that not
all the items she proposed be included in new Schedule ' E6' have
retained sufficient heritage value to be described as regionally
significa.nt.J.i1n terms of her
recommendation, she relied on the technical evidence of Messrs
Kelly and Cochran that items such as the reclamation edges (which
have played a part in
the history of the area) are of ' lesser heritage value'.Js
5.11 It is partly for this reason that she suggested the
addition of Policy ' 46A' , which while recognising that 'Schedule
E6. items contribute to the setting of significant historic
heritage, would not apply the same policy tests for managing the
heritage fabric of those items that do not meet RPS Policy 21
criteria for regional significance.36 The fact that Council
officers acknowledged that the edges of the wharves and
reclamations are not themselves regionally significant, is an
important point with respect to the relief sought by the Civic
Trust. Accordingly, we reject the relief sought i.e. the inclusion
of those items in Schedule E1.
5.12 Finally, in its submission,J7 Heritage NZ sought to extend
the Clyde Quay Boat Harbour listing in Schedule El to include the
foreshore at the northwest end of
the pool building (or alternatively to include it in Schedule
E2). Heritage NZ provided no heritage technical evidence to support
its request, and Messrs Kelly and Cochran did not specifically
assess the proposal. We therefore have no basis for extending the
listing and accordingly reject the relief sought.
Schedule E2
5.13 The submission made by Heritage NZ sought the inclusion of
both Glasgow Wharf and Kings Wharf to the list of historic heritage
wharves and boatsheds
in Schedule E2.
5.14 We have added Glasgow Wharf to Schedule E2. and in doing so
we accept the heritage technical evidence of Messrs Kelly and
Cochran. The Wharf appears
to have been left off the schedule as notified as the result of
a flawed
evaluat io n.JS Messrs Kelly and Cochran have confirmed their
own professional assessment. that Glasgow Wharf meets the criteria
in Policy 21 of the RPS to a sufficient extent for it to be
included in the schedule.39We have accepted the wording for the
entry as proposed by Ms Legarth.40
5.15 The request by Heritage NZ to include Kings Wharf in
Schedule £ 241 was opposed by CentrePort.42 We reject the request
for the inclusion of this wharf in the schedule, again basing our
decision on the technical evidence of Messrs Kelly and CochranAJ
They concluded that the wharfs subsuming into the modern
reclamation and modifications to its deck and sub-structure have
resulted in a loss of authenticity and therefore it does not meet
the criteria in Policy 21 of the RPS to a sufficient extent for it
to be included in the schedule. We agree and have not added this
listing to Schedule E2.
35
27
From P581 onwards, Decision Report Part 2New Schedule 'E6' and
Policy 'P46A
5.33 The proposed addition of new Schedule 'E6' , Policy ·P46A'
together with references to Schedule ' E6' in Rules Rl 49, Rl68,
R169, RI 71 and RI 72, constitutes a package of provisions relating
to a ·Lambton Harbour Heritage Area Framework· that was recommended
by Ms Legarth69 as an alternative to the relief sought by the Civic
Trust and Heritage NZ. Ms Legarth also recommended the notation of
various listings in the existing schedules (El to E3) with
asterisks to acknowledge their contribution to the character of
the
Lambton Harbour Heritage Area.
5.34 The relief sought by the parties involved the addition of
the edges of wharves and reclamations to Schedule E l, and the
addition of Kings Wharf, the Tug Wharf. the Customs Port Building
and the Overseas Passenger Terminal to Schedule E2. We agree with
Ms Legarth' s recommendation to reject these requests. on the
grounds that the items do not meet the criteria set out in RPS
Polic y 21.10
5.35 We now assess the scope and merits of Ms Legarth·s
alternative recommendation.
5.36 As to scope. we agree that it exists with respect to the
items included within Ms
Legarth' s proposal, as they have alJ been requested for
protection by submitters.
5.37 As to the merits of the proposal, we note that none of the
items have sufficient
heritage value to warrant inclusion in Schedules El to E3. Ms
Legarth acknowledged this in her right ofreply, although she
suggested that "not all" the items have retained sufficient
heritage value when, in fact none of them have.11 It stands to
reason, then, that the inclusion of a Schedule ' E6' is not
supported by higher order provisions. notably RPS Policy 21. and
PNRP Objective 034 and Policies P46 and P47, which refer only to
significant historic heritage values. not to other values that
'contribute to the setting· of significant heritage values.
5.38 With respect to the proposed Policy ' P46A·, which would
guide consideration
of proposals impacting on the items listed in Schedule 'E6', Ms
Legarth acknowledged that different (i.e. lesser) tests are
required to manage the heritage fabric of those items that do not
meet the criteria for regional significance in RPS Policy 21.72 In
our view, the underlying problem is the lack of any justification
in higher order documents for such a management thrust. Moreover.
we recall that both Messrs Kelly and Cochran agreed during
questioning at the right of reply hearing for this topic that it
seemed inequitable that items in any Schedule ·E6' which don' t
meet the tests of Policy 21 of the RPS would receive the same rule
and policy protection that items in Schedules El to E3 do. We agree
with those experts and therefore find that neither
proposed new Policy ' 46A' nor proposed new Schedule ·E6' are
necessary or appropriate to implement Objective 034 and Policies
P46 and P47 of the proposed Plan.
5.39 For these reasons, we reject the alternative relief
proposed by Ms Legarth. in other words. the recommended addition of
a Schedule ' E6' . Policy ' P46A' and associated references in
relevant rules. While we acknowledge that there seems to be scope
within submissions for this proposal, the heritage values that
these provisions would seek to recognise and manage do not meet the
tests set out in RPS Policy 21, and would not be an appropriate
means of achieving Objective
034. They would have the effect of escalating the status of the
items concerned above their recognised value.
APPENDIX C - Names and addresses of persons to be served with a
copy of this notice
Greater Wellington Regional Counci l RegionalPlanAppeal
[email protected]
PO Box 11646, Manners St, Wellington 6142
Minister of Conservation kanton@doc .govt .nz
PO Box 10420, Wellington 6143
Submitt er
Address
CentrePort Ltd
PO Box 794, Hinemoa Street, Wellington, 6140
CentrePort Properties Ltd
PO Box 794, Wellingt on, 6140
Heritage New Zealand
PO Box 2629, Wellington 6140
Rangitane o Wairarapa Inc
PO Box 9348, Hamilt on 3240
Royal Forest and Bird Protection Society
PO Box 631, Wellington 6140
Wellington City Council
PO Box 2199, Wellington 6140
Wellington Recreational Marine Fishers Association
3 Ruskin Road , Newlands, Wellington 6037
