Heritage Church Hall, Coastal Erosion, and Relocation Cost
A Category 1 heritage building, a 1905 wooden church hall, sits on a coastal reserve edge. It is owned by a trust and used as a community hall. A storm in 2023 caused a landslip that removed 4 m of the reserve, leaving the hall 6 m from the cliff edge. Geotechnical advice says the cliff could retreat another 3–5 m in the next 10 years. The trust applies for resource consent to demolish the hall and build a new hall 30 m inland. The district plan lists the hall as a heritage item and requires resource consent for demolition as a discretionary activity. Heritage New Zealand has lodged a submission opposing demolition and says the hall can be relocated. The trust says relocation costs $600,000 and it has only $150,000. Iwi has cultural associations with the hall. The council planner must make a recommendation.
1. Outline the matters the planner must consider under s104 and the relevant s6 matters, and explain how the financial cost of relocation should be weighed against heritage values.
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Under s104(1)(a), the planner must assess the effects of demolition. The loss of a Category 1 heritage building is an irreversible adverse effect. Under s104(1)(b), the planner must consider the plan's heritage objectives, policies, and assessment criteria, including whether demolition is a last resort and whether relocation or adaptive reuse has been explored. Under s104(1)(c), the planner may consider the trust's financial position, the geotechnical risk, iwi cultural values, and the future use of the site.
Section 6 matters are central. Section 6(f) requires the council to recognise and provide for the protection of historic heritage. Section 6(h) requires recognition of the management of natural hazards. Section 6(e) requires recognition of the relationship of Maori and their culture and traditions with ancestral lands, water, sites, waahi tapu, and other taonga. These are not merely relevant considerations; they are matters of national importance. The planner must weigh the risk to life from coastal erosion against the loss of heritage, but s6(f) does not permit demolition simply because the building is in a hazardous location. Relocation may be the better option if it is feasible.
Cost is relevant but not decisive. The trust's inability to fund the full $600,000 does not, by itself, justify destroying a Category 1 item. The planner should test the cost estimates, consider staged relocation, grant funding, insurance, and whether the building can be temporarily propped or partially relocated. If relocation is genuinely impractical, the planner must explain why and consider conditions requiring documentation, salvage of heritage fabric, and interpretation. The recommendation should be an integrated weighing of s6 matters, s104 factors, and the alternatives.
2. What additional statutory approvals or processes may be required, and how should the council address iwi interests?
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Demolition may require an archaeological authority under the Heritage New Zealand Pouhere Taonga Act 2014 if the hall or its site is an archaeological site, which is likely for a 1905 building. The planner should confirm whether the site is recorded and advise the applicant to apply to Heritage New Zealand before demolition. A building consent will also be needed for demolition and for the new hall. If any works are in or near the coastal marine area, a regional coastal permit may be required under the regional plan and the New Zealand Coastal Policy Statement. The district plan may also require earthworks or vegetation clearance consent.
Iwi interests should be addressed early and substantively. The planner should identify the relevant iwi or hapu, provide the application and technical reports, and invite a cultural impact assessment. The council should consider whether the hall or site has waahi tapu or other cultural values, and whether the iwi supports relocation, demolition, or retention. Section 6(e) and s104(1)(c) require those values to be weighed. If there is a relevant iwi planning document, the council must have regard to it under s81. The planner should not treat consultation as a box-ticking exercise; if the iwi opposes demolition, the planner must explain how that opposition has been weighed.
Conditions could require a cultural protocol for any disturbance, salvage and return of heritage fabric, and interpretation of the hall's history at the new site. The planner should also consider whether the trust has legal authority to demolish and whether the reserve status affects the proposal.