BEFORE THE CHRISTCHURCH REPLACEMENT DISTRICT PLAN HEARINGS PANEL IN THE MATTER of the Resource Management Act 1991 and the Canterbury Earthquake (Christchurch Replacement District Plan) Order 2014 AND IN THE MATTER of the Natural and Cultural Heritage Stage 3 Proposal MEMORANDUM OF COUNSEL ON BEHALF OF CHRISTCHURCH CITY COUNCIL 7 MARCH 2016 Barristers & Solicitors Simpson Grierson M G Conway / M J Jagusch Telephone: +64-4-499 4599 Facsimile: +64-4-472 6986 Email:
[email protected] /
[email protected] DX SX11174 PO Box 2402 WELLINGTON MAY IT PLEASE THE PANEL: 1. This memorandum is filed on behalf of the Christchurch City Council (Council) in response to the Minute of the Panel dated 3 March 2016 regarding the Natural and Cultural Heritage Proposal (Minute). This memorandum addresses matters relating to Topic 9.3: Historic Heritage and Topic 9.4: Significant Trees. TOPIC 9.4: SIGNIFICANT TREES 2. The Minute granted leave for the Council to file a memorandum by 7 March 2016 confirming any request for leave to file supplementary evidence. Mediation on Thursday 3 March was helpful, and the Council does not consider that supplementary evidence or further formal engagement with interested parties will be necessary in relation to Topic 9.4 except to the extent envisaged by the timetable proposed below. While not all matters have been resolved, the Council anticipates that, by the time closings are filed, the points of disagreement will be reduced and clearly defined. The proposed process set out below is similar to that which was sought for Topic 9.1: Indigenous Biodiversity.