SUBMISSION ON S71 CHANGES TO THE DISTRICT PLAN - HAGLEY OVAL. My name iss9(2)(a I was part of a group that took part in the Environment Court EC and attended each day for 5 weeks. I learned during that case and subseq uently, to be wary of anything Canterbury Cricket Trust CCT says and even more so what they don't say. I have put in a submission on behalf of HO H, concentrating on amenity. This is my personal submission dealing with the proposed changes requested by CCT and their impact on Hagley Park and its other users. I believe that the use of S71 in this instance is wrong. The ability to question expert evidence and present opposing expert evidence is essential in this sensitive proposal. The RMA is the vehicle t hat can provide this. The minister is no doubt aware of the section in the letter of expectation that advises her regarding the use of S71, where the RMA could be used instead. Also the amendment to the Regenerate act proposed by the current minister Megan Wood and passed unanimously by Parliament protecting Hagley Park from the Regen Act. https://www.parliament.nz/en/pb/hansard This states: "But what we are saying is that when it comes to Hagley Park and the protections that have been built up over that piece of land, it actually is time to return to business as usual. When it comes to that particular taonga in the centre of our city, we do need to be able to say, it is if the earthquakes never happened and it is as if the bespoke legislation that is put in place to aid our recovery and our regeneration does not exist...." And... "There are a number of instruments that are used in this legislation and what my amendmentsProactively do ensure that the managementreleased plan of by Hagley the Park is the primary instrument and that it cannot be overridden by anything else that mighr be in this legislation." The use of the Regen act to affect the district plan and therefore the Hagley Park Management Plan HPMP, seems to fly in t he face of what Parliament intended or was in the mind of Parliament when they voted on the amendment. I dispute the need for urgency in this matter. CCT have known about the Womens' World Cup since 2013 and have had permission for retractable lights since 2013 and have chosen not to proceed with Associateconstruction. The issueMinister I believe, is thatfor both Greater initial cost and ongoingChristchurch costs of the consented Regeneration retractable lights exceed the cost of 6 f ixed lights. In finding what CCT and their legal team think is a loophole, they 1 are using it to try to obtain all that the EC denied them plus some. CCT see this as their last best chance to get all they want. The EC was forced to grant them permission to use the oval because the CER act was deemed to overrule the HPMP. Now we are back again CCT using emergency legislation, urgency and our old friend, fear of missing out. The whole thing gives one a sense of deja vu. Why would CCT need 6 permanent lights when Seddon Park Hamilton have just installed 4 lighting towers which meet international broadcasting standards? The consented 4 retractable towers with LED lights should be able to provide the same results. The impact of 6 lighting heads of 14.Sm x 10m on the vista of South Hagley Park will be huge. Taken together they would be like a 10m tall 85m long, visual scar S0m up in the skyline. PARKING The increase in the number of games will result in increased demand for parking around the hospital. Hospital staff, out patients and visitors will be further inconvenienced and frustrated by the lack of parking. This was acknowledged by the EC and was one factor in their decision to restrict the number of games at the oval. The increase in the time allowed for pack in and out will also increase the length of time heavy vehicles are in and around the oval. When games are televised, the car park inside Hagley Park next to the oval is closed and used by television outside broadcast vehicles. For a one day game plus pack in and out this is three days that the public lose the use of that car park. The hours that CCT want for the oval 7am to 12am effectively impact on the ability of hospital staff on the afternoon and night shifts to find nearby safe parking. Out patients with specialist or ongoing treatment appointments could miss those appointmentProactively times due to parking released issues. They would by have the to reschedule, wasting valuable doctor's time and delaying their ongoing treatment. Is the inconvenience caused to hospital staff, visitors and patients a price worth paying so that NZ Cricket can sell games to an overseas audience in prime time? STRUCTURES The structures (temporary as per S71) shall be limited to: AssociateBroadcasting and mediaMinister production facilitiesfor Greater Christchurch Regeneration Broadcasting and media technical services and facilities 2 Broadcasting camera towers and media transmission equipment Temporary power generators Event directional wayfinding and or sponsor signage Event administration or operational facilities There is no mention of how many camera towers and transmission units will be used . This is important as the camera towers are proposed to remain in place for the season and are not part of any pack out. The broadcasters call the tune as to how many cameras they want at a game so as time goes by we may see more structures albeit temporary, cluttering up Hagley Park. It's proposed that the camera towers be allowed to carry advertising. This is an area the EC was quite specific on both in location and time limits. {Inside the boundary fence only and for the match day only.) The extending of advertising signage to temporary structures and the pavilion is another step in the commercialisation of the oval and would not be allowed in any other part of Hagley Park. Overturning the EC conditions moves us ever closer to KFC Stadium Hagley Oval or similar. PACK IN PACK OUT In the EC my evidence showed that Crickets timetable of games plus pack in and out would add up to 80 days per season. This was clearly unacceptable to the court, so cricket came back with what we now have, after assuring the court that the timetable was reasonable and doable. I disputed this, especially their claim to be able toProactively pack in and out in a day. released They now claim theby EC conditionsthe are not fit for purpose. Conditions they proposed in order to get access to the oval in the first place. They now want up to 75 days excluding 6 public holidays and unknown allowances for inclement weather. This takes us past the original 80 days they couldn't get in the EC. I believe it is known as planning by stealth. As my grandmother would say, "You made your bed, now lie in it." Associate Minister for Greater Christchurch Regeneration 3 SPORTING EVENTS AND THE USE OF EXISTING FACILITIES Re Chapter 18 open space p24: Events for 2000 or more spectators shall not occur on days where the cumulative attendance at events in SOUTH HAGLEY park exceeds 20,000 people. The EC condition was for Hagley Park not just South Hagley. This was an attempt to mitigate any parking problems, especially around the hospital caused by events. To my knowledge there are no large events in South Hagley. The slight change in the condition by adding the word south to Hagley and hope nobody would notice, could lead to major traffic problems around the hospital area when cricket clashes with a large event in North Hagley Park. This is especially so when these events continue into the late evening. PUBLIC ACCESS Public access to the oval is restricted during match days and pack in and out days. Otherwise, signs on the fences will be used, to indicate where the access gaps in the fence are. This is not satisfactory. Legally, I believe a fence is still a fence even if it has gaps in it. On non match days one should be free to traverse the oval without hindrance or having to detour along fence lines to enter and exit. To this end, every second section of fence should be removed to enable public access to their park while still giving CCT a speedy set up of their fencing. The extended playing days asked for, risk excluding the public from what are "The public commons" for almost all of the summer. Proactively released by the TEMPORARY SEATING CCT want no restriction on the amount of temporary seating within the oval. The EC restricted temporary seating to 8,000 to try to minimise the amount of temporary structures within the oval and maintain where possible the village green feel. The increasing amount of temporary structures in the oval restricts the space available for lying on the grass embankment to watch a game. Grandstands, temporary or permanent, are a way to pack more spectators into a smaller place. How many scaffolding temporary grandstands and camera towers do CCT want? If CCT wanted unrestricted use Associatethey should have gone Minister elsewhere. The for idea soldGreater to us of a village Christchurch green is slowly morphing Regeneration into a stadium by default. All of Hagley Parks protections mean nothing unless the guardians of those 4 protections do their job.