Before the Christchurch Replacement District Plan Independent Hearings Panel

CCC - Rebuttal evidence Jenny Moore Page 1 of 19

BEFORE THE CHRISTCHURCH REPLACEMENT DISTRICT PLAN INDEPENDENT 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 Proposal (Stage 3) Topic 9.4 – Significant Trees

REBUTTAL EVIDENCE OF JENNIFER FLORENCE MOORE ON BEHALF OF CHRISTCHURCH CITY COUNCIL

LANDSCAPE ARCHITECTURE

5 AUGUST 2016

Barristers & Solicitors M G Conway / C G Coyle Telephone: +64-4-924 3511 Facsimile: +64-4-472 6986 Email: [email protected] PO Box 2402 SOLICITORS WELLINGTON

28225607_2.docx

CCC - Rebuttal evidence Jenny Moore Page 2 of 19

TABLE OF CONTENTS

1. INTRODUCTION ...... 1 2. SCOPE ...... 1 3. Westall Trust, Mr Robert Watson (#68) ...... 2 4. Medbury School Board of Trustees, Mr Tony Milne (#22) ...... 2 5. Science Alive Investments Limited, Mr Tony Milne (#34) ...... 3 6. Civic Trust and others, Ms Di Lucas (#3700)...... 3 7. Trees identified by commenters as having exceptional values (Lowe (#3700), Cadwallader (#3700), Ostash (#3661)) ...... 3

28225607_2.docx

CCC - Rebuttal evidence Jenny Moore Page 3 of 19

1. INTRODUCTION

1.1 My full name is Jennifer Florence Moore. My qualifications and expertise are set out in my evidence in chief for the Natural and Cultural Heritage proposal dated 3 December 2015.

1.2 I confirm that I have read the Code of Conduct for Expert Witnesses contained in the Environment Court Practice Note 2014 and that I agree to comply with it. I confirm that I have considered all the material facts that I am aware of that might alter or detract from the opinions that I express, and that this evidence is within my area of expertise except where I state that I am relying on the evidence of another person. The Council has agreed to me giving expert evidence on its behalf in accordance with my duties under the Code of Conduct.

2. SCOPE

2.1 I have read the submitter evidence in chief dated 29 July 2016 and 3 August 2016 relevant to my area of expertise. My rebuttal evidence is provided in response to the evidence in chief filed by the following submitters:

(a) Mr Robert Watson for the Westall Trust (NCHT- 68); (b) Mr Tony Milne for Medbury School (NCHT – 22); (c) Mr Tony Milne for Science Alive Investments Limited (NCHT – 34); (d) Ms Di Lucas for the Christchurch Civic Trust and others (#3700); (e) Ms Helen Lowe for the Christchurch Civic Trust and others (#3700); (f) Mr Bradley Cadwallader for the Christchurch Civic Trust and others (#3700); and (g) Mr Michael Ostash (#3661).

2.2 My evidence has the following attachment:

(a) Attachment A: Trees identified by commenters as having exceptional values.

28225607_2.docx 1

CCC - Rebuttal evidence Jenny Moore Page 4 of 19

2.3 My evidence in chief1 focused on the assessment of trees with exceptional values using the methodology outlined in paragraph 9.5 (a-e).2

3. Westall Trust, Mr Robert Watson (#68)

3.1 A landscape assessment of three Category II Notable trees at 104 Glandovey Road was carried out by Mr Robert Watson for the Westall Trust. Mr Watson outlines his approach to his assessment in paragraphs 4.1-4.6.

3.2 I concur with the methodology of landscape assessment undertaken by Mr Watson as outlined in paragraphs 5.1 to 7.13 and agree with his conclusions.

4. Medbury School Board of Trustees, Mr Tony Milne (#22)

4.1 Mr Milne along with Lancewood Urban Forestry Ltd has undertaken an assessment of all the trees at the Medbury School site on behalf of Medbury School Board of Trustees.

4.2 In paragraph 6, Mr Milne advises the School Board to oppose the recommendation to list a Cedar of Lebanon (T549), and in paragraph 7 to support the retention of three listed trees (T546, T548 and T558) in the proposed significant tree schedule.

4.3 In paragraph 15 Mr Milne concludes that “the removal of the Cedar of Lebanon will not result in a significant loss of amenity and landscape value within the Medbury School site.” I concur with Mr Milne’s approach to assessing the amenity and landscape value of significant trees as outlined in paragraphs 15 and 16 and agree with his conclusions.

4.4 I concur with Mr Milne’s comment in paragraph 17 regarding the changes to the provision for pruning and felling of significant trees (Appendix A, 9.4.3.2.1 Permitted Activities – Trees P1-P6) and agree with his conclusions that this allows landowners greater flexibility in managing and maintaining significant trees.

1 dated 3 December 2015 and 29 August 2016. 2 Evidence in chief, dated 3 December 2015.

28225607_2.docx 2

CCC - Rebuttal evidence Jenny Moore Page 5 of 19

5. Science Alive Investments Limited, Mr Tony Milne (#34)

5.1 I concur with Mr Milne’s comments in paragraph 12 regarding the changes to the provision for the pruning and felling of significant trees where the landowner has greater flexibility to manage, maintain and provide successional replanting.

6. Civic Trust and others, Ms Di Lucas (#3700)

6.1 Ms Lucas in paragraph 6 identifies the Hadfield Elm (Tree ID 4595) at 300 Stanmore Road as contributing landscape and amenity values. I note that this tree is included on the proposed schedule.

6.2 In paragraph 7 Ms Lucas identifies the Eliza Manor Elm (Tree ID 3451, T431) at 83 Bealey Avenue as having stature and character, where the tree contributes very importantly to landscape and amenity. I am not familiar with this tree and have not undertaken an assessment.

6.3 In paragraph 8 Ms Lucas identifies the London Plane (Tree ID 1514, T820) at 39 Kahu Road as providing important landscape and amenity due to its elegant shape and important location at the entrance to Christchurch Boys High School. I am not familiar with this tree and have not undertaken an assessment.

6.4 In her evidence Ms Lucas has provided her own landscape and amenity assessment of the Hadfield Elm, Eliza Manor Elm and 39 Kahu Road London Plane which is consistent with assessments carried out by Mr Watson and Mr Milne for Significant Trees. I concur with the methodology of assessment for significant trees and on the basis of Ms Lucas's assessment I agree that these three trees should be scheduled on the basis of exceptional landscape values.

7. Trees identified by commenters as having exceptional values (Lowe (#3700), Cadwallader (#3700), Ostash (#3661))

7.1 Ms Lowe has identified the following trees as having exceptional values: T1017, T1022, T1025, T1026, T1035, T1103, T1128-T1130, T400- T404, T482-T483, T485-T486, T488, T492, T493, T496, T498-T500,T547, T550 – T561, T563-T566, T606, T622-T628, T635 – T637, T694, T705-T718 T852- T853, T944, T970, TG7.

28225607_2.docx 3

CCC - Rebuttal evidence Jenny Moore Page 6 of 19

7.2 I am unaware of a landscape and amenity assessment having been carried out by Ms Lowe to determine the exceptional values of these trees. I am not familiar with all these trees and have not undertaken an assessment of them, therefore I cannot comment on their exceptional values.

7.3 Mr Cadwallader has identified the following trees as having exceptional values: T482, T483, T485, T486, T488, T492, T493, T496, T498 T499, T500, T622 – T628, T705 – T718.

7.4 I am unaware of a landscape and amenity assessment having been carried out by Mr Cadwallader to determine the exceptional values of these trees. I am not familiar with all these trees and have not undertaken an assessment of them, therefore I cannot comment of the exceptional values.

7.5 Mr Ostash has identified the following trees as having exceptional values: T1103, T464, T483, T485, T486, T488, T492, T493, T496, T498- T500, T575, T622 – T628, T680, T705 – T718, T852 T853.

7.6 I am unaware of a landscape and amenity assessment having been carried out by Mr Ostash to determine the exceptional values of these trees. I am not familiar with all these trees and have not undertaken an assessment of them, therefore I cannot comment on the exceptional values.

7.7 To determine whether a tree has exceptional landscape characteristics, a landscape and amenity assessment needs to be undertaken by a landscape architect detailing these characteristics.3 Further, a tree is required to be in good health as assessed by a qualified arborist. In absence of these reports and assessments, I would be reluctant to schedule any tree on the basis of it having exceptional landscape characteristics.

Jennifer Florence Moore 5 August 2016

3 Outlined in 9.5 (a) – (e) in my evidence in chief dated 3 December 2015.

28225607_2.docx 4

CCC - Rebuttal evidence Jenny Moore Appendix A - Trees identified by commenters as having exceptional values Page 7 of 19

Bupa Care (97) Oppose listing; possible association Does not meet new criteria Papanui Sequoiadendron Services NZ; (3661) Supports with Mrs Pope's and no identified 429 Road T1017 giganteum Wellingtonia Y 97; 3661 Michael Ostash listing Both Y Landscape * prominent tree Lowe p29 property Remove exceptional values

*Located in the 'Park Terrace Historical Area' Heritage New Zealand register number 7058. * 100+ years old Catherine (27) Do not list this * A prominent landscape specimen - Possible association Does not meet new criteria Park Drayton; Michael tree; (3661) Heritage; should have exceptional landscape with George and no identified 90 Terrace T1022 Quercus robur English Oak Y 27; 3661 Ostash Supports listing Both Y Landscape assessment Lowe p29 Moore's property Remove exceptional values

Does have some historic heritage value - association with expensive rural * Part of a heritage setting -- Cat 2 homestead and Historic Place, yet no exceptional Studholme family. evaluation done - HPT 3109 Reflects rural past of Does not meet new criteria Peartree Penny Wenlock Oppose listing of Heritage; * Exceptional landscape probably the more recent and no identified 6 Lane T1025 Eucalyptus globulus Tasmanian Blue Gum Y FS5090 and Bill Packard tree N Y Landscape also appropriate Lowe p29 subdivision. Remove exceptional values

Does have some historic heritage value - association with expensive rural * Part of a heritage setting -- Cat 2 homestead and Historic Place, yet no exceptional Studholme family. evaluation done - HPT 3109 Reflects rural past of Does not meet new criteria Peartree Penny Wenlock Oppose listing of Heritage; * Exceptional landscape probably the more recent and no identified 6 Lane T1026 Eucalyptus globulus Tasmanian Blue Gum Y FS5090 and Bill Packard tree N Y Landscape also appropriate Lowe p29 subdivision. Remove exceptional values

Herbert Lawrence (40) Oppose listing; Does not meet new criteria Puriri John Govan; (3661) Supports and no identified 118 Street T1035 Ulmus procera English Elm Y 40; 3661 Michael Ostash listing Both Y Landscape * high visibility Lowe p30 no info Remove exceptional values * Very prominent specimen on the James Robin streetscape. Musgrave (57) Oppose listing; *Associated with 'Long Cottage' possible association Does not meet new criteria Rugby Davidson; Michael (3661) Supports Landscape; Historic Place Category 2, Heritage Lowe p30; Ostash with previous and no identified 1/140 Street T1103 Quercus robur English Oak Y 57; 3661 Ostash listing Both Y Heritage NZ reg # 1900 p9 homestead Fassifern Remove exceptional values (71) Expresses some concerns Beckenham about listings School and relating to future If located near the Ministry of development; heritage listed Does not meet new criteria Sandwich Cryptomeria Education; (3661) Supports library - may be and no identified 71 Road T1107 japonica Japanese Cedar Y 71; 3661 Michael Ostash listing Y Botanical * Relatively rare species Lowe p30 associated with it. Remove exceptional values

* This tree is 1 of only 15 Heritage trees listed under the OCDP Susan and Garry (56) Oppose listing; * pre-European Stanleys Minnell; Michael (3661) Supports * reputedly a traditional landmark no info in heritage Reassessment found not 69 Road T1117 Cordyline australis Cabbage Tree Y 56; 3661 Ostash listing Both Y Y Y Heritage feature used as a waymarker Lowe p30 team Remove significant

1 CCC - Rebuttal evidence Jenny Moore Appendix A - Trees identified by commenters as having exceptional values Page 8 of 19

* 1 of a group of 4 trees that should probably be reassessed as a GROUP * 2 of 4 have been assessed as having exceptional cultural value; 1 of 4 has been assessed as > 100 years old -- likelihood that all are? * large / old natives in a group rare Helen and Chris (25) Do not list in Christchurch potential association Does not meet new criteria Thorringt Pfahlert; Michael these trees; (3661) Heritage; * exceptional heritage with a previous and no identified 14 on Road T1129 Nothofagus solandri Black Beech Y 25; 3661 Ostash Supports listing Both Y Y Landscape * exceptional landscape Lowe p31 homstead Remove exceptional values * 1 of a group of 4 trees that should probably be reassessed as a GROUP * 2 of 4 have been assessed as having exceptional cultural value; 1 of 4 has been assessed as > 100 years old -- likelihood that all are? * large / old natives in a group rare Helen and Chris (25) Do not list in Christchurch potential association Does not meet new criteria Thorringt Pfahlert; Michael these trees; (3661) Heritage; * exceptional heritage with a previous and no identified 14 on Road T1130 Nothofagus solandri Black Beech Y 25; 3661 Ostash Supports listing Both Y Y Landscape * exceptional landscape Lowe p31 homstead Remove exceptional values * historic association with former Middleton Grange homestead: HPT 1824 Cat 2. The Christian * number & significance of trees on Association with Schools Trust Does not oppose site that indicate potential for Middleton former Does not meet new criteria Acacia Pseudotsuga (Middleton listing. No reasons Heritage; contribution to wider landscape dwelling and Charles and no identified 50 Avenue T400 menziesii Douglas Fir Y 46 Grange School) provided. Y Landscape and amenity Lowe 3700 (p19) Bowen Remove exceptional values

(46) Oppose listing; (3661) Support * historic association with former listing of two oak Middleton Grange homestead: HPT The Christian trees on this 1824 Cat 2. Schools Trust property but the * number & significance of trees on Association with (Middleton tree reference site that indicate potential for Middleton former Does not meet new criteria Acacia Grange School); numbers are Heritage; contribution to wider landscape dwelling and Charles and no identified 50 Avenue T401 Quercus robur English Oak Y 46; 3661 Michael Ostash unclear. N Y Landscape and amenity Lowe 3700 (p19) Bowen Remove exceptional values * historic association with former Middleton Grange homestead: HPT 1824 Cat 2. The Christian * number & significance of trees on Association with Schools Trust Does not oppose site that indicate potential for Middleton former Does not meet new criteria Acacia (Middleton listing. No reasons Heritage; contribution to wider landscape dwelling and Charles and no identified 50 Avenue T402 Ulmus procera English Elm Y 46 Grange School) provided. Y Landscape and amenity Lowe 3700 (p19) Bowen Remove exceptional values * historic association with former Middleton Grange homestead: HPT 1824 Cat 2. The Christian * number & significance of trees on Association with Schools Trust Does not oppose site that indicate potential for Middleton former Does not meet new criteria Acacia (Middleton listing. No reasons Heritage; contribution to wider landscape dwelling and Charles and no identified 50 Avenue T403 Quercus robur English Oak Y 46 Grange School) provided. Y Landscape and amenity Lowe 3700 (p19) Bowen Remove exceptional values * historic association with former Middleton Grange homestead: HPT 1824 Cat 2. The Christian * number & significance of trees on Association with Schools Trust site that indicate potential for Middleton former Does not meet new criteria Acacia (Middleton Heritage; contribution to wider landscape dwelling and Charles and no identified 50 Avenue T404 Quercus robur English Oak Y 46 Grange School) Oppose listing N Y Landscape and amenity Lowe 3700 (p19) Bowen Remove exceptional values Ministry of (6) No relief Does not meet new criteria Albert Education; disclosed; (3661) * a good example no information in and no identified 22 Terrace T407 Quercus robur English Oak Y 6; 3661 Michael Ostash Supports listing Y Heritage * could exceed 100 years Lowe p19 heritage team Remove exceptional values Ministry of (6) No relief Does not meet new criteria Brougham Education; disclosed; (3661) Heritage; Exceptionally large tree- 32m wide; no information in and no identified 22 Street T464 Quercus cerris Turkey Oak Y 6; 3661 Michael Ostash Supports listing Y Landscape and over 100 years old Ostash p20 heritage team Remove exceptional values

2 CCC - Rebuttal evidence Jenny Moore Appendix A - Trees identified by commenters as having exceptional values Page 9 of 19

* Very important site for botanical plantings associated with founding settler John Cracroft-Wilson, so botanical and heritage significance as a site and grouping * Heritage association with Cracroft- Wilson & "Cracroft House" ; HPT 3104 * Given size of site, the number of trees, as well as their heritage Association with significance, trees should be Cracroft Wilson assessed for contribution to (prominent Chch The Girl Guides landscape and wider amenity; figure) and his Association of (4) Do not include Probably at least 150 years old; Lowe p21-22; family. Possible that Does not meet new criteria Cashmere Sequoiadendron New Zealand Inc.; listed tree; (3661) Heritage; currently protected as a heritage Ostash p13; he planted some of and no identified 151 Road T482 giganteum Wellingtonia Y 4; 3661 Michael Ostash Supports listing Both Y Landscape tree Cadwallader p5 the trees. Remove exceptional values

3 CCC - Rebuttal evidence Jenny Moore Appendix A - Trees identified by commenters as having exceptional values Page 10 of 19

4 CCC - Rebuttal evidence Jenny Moore Appendix A - Trees identified by commenters as having exceptional values Page 11 of 19

* Very important site for botanical plantings associated with founding settler John Cracroft-Wilson, so botanical and heritage significance as a site and grouping * Heritage association with Cracroft- Wilson & "Cracroft House" ; HPT Association with 3104 Cracroft Wilson * Given size of site, the number of (prominent Chch The Girl Guides trees, as well as their heritage figure) and his Association of (4) Do not include significance, trees Lowe p21-22; family. Possible that Does not meet new criteria Cashmere New Zealand Inc.; listed tree; (3661) Heritage; should be assessed for contribution Ostash p10-13; he planted some of and no identified 151 Road T500 Ulmus procera English Elm Y 4; 3661 Michael Ostash Supports listing Both Y Landscape to landscape and wider amenity Cadwallader p5 the trees. Remove exceptional values * Given number of trees on site should be considered as a potential group & for contribution to landscape and Association with amenity ballantyne Family or (22) Oppose listing *Historical association with former the School. School of tree; (3661) "Ripsford" homestead that conversion not long Does not meet new criteria Clyde Medbury School; Supports listing of Heritage; predated school (ca. (15? Years) after the and no identified 109 Road T547 Juglans regia Common Walnut Y 22; 3661 Michael Ostash tree Both Y Landscape 1900) Lowe p23 house was built. Remove exceptional values * Given number of trees on site should be considered as a potential group & for contribution to landscape and Association with amenity ballantyne Family or (22) Oppose listing *Historical association with former the School. School of tree; (3661) "Ripsford" homestead that conversion not long Does not meet new criteria Clyde Medbury School; Supports listing of Heritage; predated school (ca. (15? Years) after the and no identified 109 Road T550 Cedrus deodara Deodar Cedar Y 22; 3661 Michael Ostash tree Both Y Landscape 1900) Lowe p23 house was built. Remove exceptional values

5 CCC - Rebuttal evidence Jenny Moore Appendix A - Trees identified by commenters as having exceptional values Page 12 of 19

Commenter says potentially Which values Which values exceptional suggested actually F/G/F Can come off or (Landscape/H Actually exceptional? Tree ID Supports Exceptional Preferred as a result of exceptional eritage/Botan exceptional? (Landscape/Heritag Other (See # Address Number Name Sub? # Name Relief Sought Listing? values? Option reassessment (Y/N) ical) Specific comment Reference (Y/N) e/Botanical) Notes) Recommend Reason * Given number of trees on site should be considered as a potential group & for contribution to landscape and Association with amenity ballantyne Family or (22) Oppose listing *Historical association with former the School. School of tree; (3661) "Ripsford" homestead that conversion not long Does not meet new criteria Clyde Medbury School; Supports listing of Heritage; predated school (ca. (15? Years) after the and no identified 109 Road T551 Ulmus procera English Elm Y 22; 3661 Michael Ostash tree Both Y Landscape 1900) Lowe p23 house was built. Remove exceptional values * Given number of trees on site should be considered as a potential group & for contribution to landscape and Association with amenity ballantyne Family or (22) Oppose listing *Historical association with former the School. School of tree; (3661) "Ripsford" homestead that conversion not long Does not meet new criteria Clyde Medbury School; Supports listing of Heritage; predated school (ca. (15? Years) after the and no identified 109 Road T552 Tilia x europaea Common Lime Y 22; 3661 Michael Ostash tree Both Y Landscape 1900) Lowe p23 house was built. Remove exceptional values * Given number of trees on site should be considered as a potential group & for contribution to landscape and Association with amenity ballantyne Family or (22) Oppose listing *Historical association with former the School. School of tree; (3661) "Ripsford" homestead that conversion not long Does not meet new criteria Clyde Aesculus Medbury School; Supports listing of Heritage; predated school (ca. (15? Years) after the and no identified 109 Road T553 hippocastanum Horse Chestnut Y 22; 3661 Michael Ostash tree Both Y Landscape 1900) Lowe p23 house was built. Remove exceptional values * Given number of trees on site should be considered as a potential group & for contribution to landscape and Association with amenity ballantyne Family or (22) Oppose listing *Historical association with former the School. School of tree; (3661) "Ripsford" homestead that conversion not long Does not meet new criteria Clyde Medbury School; Supports listing of Heritage; predated school (ca. (15? Years) after the and no identified 109 Road T554 Ulmus procera English Elm Y 22; 3661 Michael Ostash tree Both Y Landscape 1900) Lowe p23 house was built. Remove exceptional values * Given number of trees on site should be considered as a potential group & for contribution to landscape and Association with amenity ballantyne Family or (22) Oppose listing *Historical association with former the School. School of tree; (3661) "Ripsford" homestead that conversion not long Does not meet new criteria Clyde Medbury School; Supports listing of Heritage; predated school (ca. (15? Years) after the and no identified 109 Road T555 Tilia x europaea Common Lime Y 22; 3661 Michael Ostash tree Both Y Landscape 1900) Lowe p23 house was built. Remove exceptional values * Given number of trees on site should be considered as a potential group & for contribution to landscape and Association with amenity ballantyne Family or (22) Oppose listing *Historical association with former the School. School of tree; (3661) "Ripsford" homestead that conversion not long Does not meet new criteria Clyde Medbury School; Supports listing of Heritage; predated school (ca. (15? Years) after the and no identified 109 Road T556 Platanus x acerifolia London Plane Y 22; 3661 Michael Ostash tree Both Y Landscape 1900) Lowe p23 house was built. Remove exceptional values * Given number of trees on site should be considered as a potential group & for contribution to landscape and Association with amenity ballantyne Family or (22) Oppose listing *Historical association with former the School. School of tree; (3661) "Ripsford" homestead that conversion not long Does not meet new criteria Clyde Cedrus atlantica Medbury School; Supports listing of Heritage; predated school (ca. (15? Years) after the and no identified 109 Road T557 Glauca Blue Atlas Cedar Y 22; 3661 Michael Ostash tree Both Y Landscape 1900) Lowe p23 house was built. Remove exceptional values

6 CCC - Rebuttal evidence Jenny Moore Appendix A - Trees identified by commenters as having exceptional values Page 13 of 19

Commenter says potentially Which values Which values exceptional suggested actually F/G/F Can come off or (Landscape/H Actually exceptional? Tree ID Supports Exceptional Preferred as a result of exceptional eritage/Botan exceptional? (Landscape/Heritag Other (See # Address Number Name Sub? # Name Relief Sought Listing? values? Option reassessment (Y/N) ical) Specific comment Reference (Y/N) e/Botanical) Notes) Recommend Reason * Given number of trees on site should be considered as a potential group & for contribution to landscape and Association with amenity ballantyne Family or (22) Oppose listing *Historical association with former the School. School of tree; (3661) "Ripsford" homestead that conversion not long Does not meet new criteria Clyde Cedrus atlantica Medbury School; Supports listing of Heritage; predated school (ca. (15? Years) after the and no identified 109 Road T559 Glauca Blue Atlas Cedar Y 22; 3661 Michael Ostash tree Both Y Landscape 1900) Lowe p23 house was built. Remove exceptional values (6; 31) No specific relief sought.Expresses concern about ability to trim or * Given number of trees on site remove trees when and generally good specimens Ministry of school site is should be considered Education; redeveloped in as a potential group & for Possible historical Does not meet new criteria Clyde 6; 31; Fendalton School; 2020; (3661) contribution to landscape and association with the and no identified 168 Road T560 Quercus robur English Oak Y 3661 Michael Ostash Supports listing Y Landscape amenity Lowe p24 school Remove exceptional values (6; 31) No specific relief sought.Expresses concern about Heritage and cultural significance ability to trim or * Given number of trees on site remove trees when and generally good specimens Ministry of school site is should be considered Education; redeveloped in as a potential group & for Possible historical Clyde 6; 31; Fendalton School; 2020; (3661) Heritage; contribution to landscape and association with the 168 Road T561 Nothofagus fusca Red Beech Y 3661 Michael Ostash Supports listing Y Y Landscape amenity Lowe p24 school Remove Does not meet new criteria (6; 31) No specific relief sought.Expresses concern about ability to trim or * Given number of trees on site remove trees when and generally good specimens Ministry of school site is should be considered Education; redeveloped in as a potential group & for Possible historical Does not meet new criteria Clyde 6; 31; Fendalton School; 2020; (3661) contribution to landscape and association with the and no identified 168 Road T563 Quercus robur English Oak Y 3661 Michael Ostash Supports listing Y Landscape amenity Lowe p24 school Remove exceptional values (6; 31) No specific relief sought.Expresses concern about ability to trim or * Given number of trees on site remove trees when and generally good specimens Ministry of school site is should be considered Education; redeveloped in as a potential group & for Possible historical Does not meet new criteria Clyde 6; 31; Fendalton School; 2020; (3661) contribution to landscape and association with the and no identified 168 Road T564 Quercus robur English Oak Y 3661 Michael Ostash Supports listing Y Landscape amenity Lowe p24 school Remove exceptional values (6; 31) No specific relief sought.Expresses concern about ability to trim or * Given number of trees on site remove trees when and generally good specimens Ministry of school site is should be considered Education; redeveloped in as a potential group & for Possible historical Does not meet new criteria Clyde 6; 31; Fendalton School; 2020; (3661) contribution to landscape and association with the and no identified 168 Road T565 Tilia x europaea Common Lime Y 3661 Michael Ostash Supports listing Y Landscape amenity Lowe p24 school Remove exceptional values (6; 31) No specific relief sought.Expresses concern about ability to trim or * Given number of trees on site remove trees when and generally good specimens Ministry of school site is should be considered Education; redeveloped in as a potential group & for Possible historical Does not meet new criteria Clyde 6; 31; Fendalton School; 2020; (3661) contribution to landscape and association with the and no identified 168 Road T566 Juglans regia Common Walnut Y 3661 Michael Ostash Supports listing Y Landscape amenity Lowe p24 school Remove exceptional values

7 CCC - Rebuttal evidence Jenny Moore Appendix A - Trees identified by commenters as having exceptional values Page 14 of 19

possible association (37) Oppose listing; with a historical Does not meet new criteria Colombo Terry O'Rawe; (3661) Supports Heritage; Very large historic tree about 100 homestead in the and no identified 876 Street T575 Quercus robur English Oak Y 37; 3661 Michael Ostash listing Both Y Landscape years old Ostash p8 area Remove exceptional values

Denise Mary (44) Oppose listing; Garnier; Therle (82) Oppose listing; * Very prominent specimen in the Does not meet new criteria Fendalton 44; 82; Schumacher; (3661) Supports streetscape no information in and no identified 1/165 Road T606 Quercus palustris Pin Oak Y 3661 Michael Ostash listing Both Y Landscape Lowe p24 Plantedheritage when team the Remove exceptional values house was built and directly relates to the house - the avenue frames the driveway entrance, relates to the house spatially and in terms of the style of the house in terms of it being centered on the front door, and formal in character. The avenuemakes an important contribution to the heritage significance of the house, and it * A significant avenue & should be is desirable that it assessed as a GROUP - not as be protected, individual trees beyond the * Also significant landscape protection that the considerations y - potentially heritage setting (45) Oppose listing * Heritage: Heritage NZ Historic a case could provides. Based on Edward John of trees; (3661) Place Category 2 site. Reg # 3805; Lowe p25; Ostash be made with visual analysis and Does not meet new criteria Glandove Cook; Michael Supports listing of Heritage; Heritage associated with historic p7; Cadwallader more research historical aerial and no identified 27 y Road T622 Platanus x acerifolia London Plane Y 45; 3661 Ostash trees Both Y Landscape dwelling and landscape values p5 and expertise photographs. Needs Remove exceptional values

* A significant avenue & should be assessed as a GROUP - not as individual trees * Also significant landscape considerations y - potentially (45) Oppose listing * Heritage: Heritage NZ Historic a case could Edward John of trees; (3661) Place Category 2 site. Reg # 3805; Lowe p25; Ostash be made with Does not meet new criteria Glandove Cook; Michael Supports listing of Heritage; Heritage associated with historic p7; Cadwallader more research and no identified 27 y Road T623 Platanus x acerifolia London Plane Y 45; 3661 Ostash trees Both Y Landscape dwelling and landscape values p5 and expertise as above Remove exceptional values

* A significant avenue & should be assessed as a GROUP - not as individual trees * Also significant landscape considerations y - potentially (45) Oppose listing * Heritage: Heritage NZ Historic a case could Edward John of trees; (3661) Place Category 2 site. Reg # 3805; Lowe p25; Ostash be made with Does not meet new criteria Glandove Cook; Michael Supports listing of Heritage; Heritage associated with historic p7; Cadwallader more research and no identified 27 y Road T624 Platanus x acerifolia London Plane Y 45; 3661 Ostash trees Both Y Landscape dwelling and landscape values p5 and expertise as above Remove exceptional values

* A significant avenue & should be assessed as a GROUP - not as individual trees * Also significant landscape considerations y - potentially (45) Oppose listing * Heritage: Heritage NZ Historic a case could Edward John of trees; (3661) Place Category 2 site. Reg # 3805; Lowe p25; Ostash be made with Does not meet new criteria Glandove Cook; Michael Supports listing of Heritage; Heritage associated with historic p7; Cadwallader more research and no identified 27 y Road T625 Platanus x acerifolia London Plane Y 45; 3661 Ostash trees Both Y Landscape dwelling and landscape values p5 and expertise as above Remove exceptional values

8 CCC - Rebuttal evidence Jenny Moore Appendix A - Trees identified by commenters as having exceptional values Page 15 of 19

* A significant avenue & should be assessed as a GROUP - not as individual trees * Also significant landscape considerations y - potentially (45) Oppose listing * Heritage: Heritage NZ Historic a case could Edward John of trees; (3661) Place Category 2 site. Reg # 3805; Lowe p25; Ostash be made with Does not meet new criteria Glandove Cook; Michael Supports listing of Heritage; Heritage associated with historic p7; Cadwallader more research and no identified 27 y Road T626 Platanus x acerifolia London Plane Y 45; 3661 Ostash trees Both Y Landscape dwelling and landscape values p5 and expertise as above Remove exceptional values

* A significant avenue & should be assessed as a GROUP - not as individual trees * Also significant landscape considerations y - potentially (45) Oppose listing * Heritage: Heritage NZ Historic a case could Edward John of trees; (3661) Place Category 2 site. Reg # 3805; Lowe p25; Ostash be made with Does not meet new criteria Glandove Cook; Michael Supports listing of Heritage; Heritage associated with historic p7; Cadwallader more research and no identified 27 y Road T627 Platanus x acerifolia London Plane Y 45; 3661 Ostash trees Both Y Landscape dwelling and landscape values p5 and expertise as above Remove exceptional values

* A significant avenue & should be assessed as a GROUP - not as individual trees * Also significant landscape considerations y - potentially (45) Oppose listing * Heritage: Heritage NZ Historic a case could Edward John of trees; (3661) Place Category 2 site. Reg # 3805; Lowe p25; Ostash be made with Does not meet new criteria Glandove Cook; Michael Supports listing of Heritage; Heritage associated with historic p7; Cadwallader more research and no identified 27 y Road T628 Platanus x acerifolia London Plane Y 45; 3661 Ostash trees Both Y Landscape dwelling and landscape values p5 and expertise as above Remove exceptional values

* Heritage NZ Historic Place (68/FS5094) Category 2: No. 3802: Greystones. 68 and Oppose listing; * Trees are associated planting and Association with Does not meet new criteria Glandove Ulmus glabra FS5094; The Westall Trust; (3661) Supports the elm is likely 100+ years old Paynter, and no identified 104 y Road T632 Camperdownii Camperdown Elm Y 3661 Michael Ostash listing Both Y Heritage * Exceptional heritage? Lowe p25 businessman Remove exceptional values no information in heritage team. Ministry of (6) No relief * part of site with a number of Possible historical Does not meet new criteria Glouceste Education; disclosed; (3661) trees; consideration of contribution association with and no identified 311 r Street T635 Quercus robur English Oak Y 6; 3661 Michael Ostash Supports listing Y Landscape to wider landscape and amenity Lowe p25 school. Remove exceptional values

* native tree & understood to be a no information in good size for Christchurch heritage team. Ministry of (6) No relief * part of site with a number of Possible historical Does not meet new criteria Glouceste Education; disclosed; (3661) trees; consideration of contribution association with and no identified 311 r Street T636 Agathis australis Kauri Y 6; 3661 Michael Ostash Supports listing Y Landscape to wider landscape and amenity Lowe p25 school. Remove exceptional values no information in heritage team. Ministry of (6) No relief * part of site with a number of Possible historical Does not meet new criteria Glouceste Education; disclosed; (3661) trees; consideration of contribution association with and no identified 311 r Street T637 Juglans regia Common Walnut Y 6; 3661 Michael Ostash Supports listing Y Landscape to wider landscape and amenity Lowe p25 school. Remove exceptional values

Historical association with Ministry of (6) No relief school and possibly Does not meet new criteria Hagley Education; disclosed. (3661) former pleasure and no identified 510 Avenue T672 Fraxinus excelsior English Ash Y 6; 3661 Michael Ostash Supports listing Y Heritage Associated with a historic building Ostash p20-21 gardens on site Remove exceptional values

9 CCC - Rebuttal evidence Jenny Moore Appendix A - Trees identified by commenters as having exceptional values Page 16 of 19

Historical association with Ministry of (6) No relief school and possibly Does not meet new criteria Hagley Education; disclosed. (3661) former pleasure and no identified 510 Avenue T673 Quercus robur English Oak Y 6; 3661 Michael Ostash Supports listing Y Heritage Associated with a historic building Ostash p20-21 gardens on site Remove exceptional values

Historical association with Ministry of (6) No relief school and possibly Does not meet new criteria Hagley Aesculus Education; disclosed. (3661) former pleasure and no identified 510 Avenue T674 hippocastanum Horse Chestnut Y 6; 3661 Michael Ostash Supports listing Y Heritage Associated with a historic building Ostash p20-21 gardens on site Remove exceptional values

Historical association with Ministry of (6) No relief school and possibly Does not meet new criteria Hagley Education; disclosed. (3661) former pleasure and no identified 510 Avenue T675 Quercus robur English Oak Y 6; 3661 Michael Ostash Supports listing Y Heritage Associated with a historic building Ostash p20-21 gardens on site Remove exceptional values

Historical association with Ministry of (6) No relief school and possibly Does not meet new criteria Hagley Education; disclosed. (3661) former pleasure and no identified 510 Avenue T676 Quercus robur English Oak Y 6; 3661 Michael Ostash Supports listing Y Heritage Associated with a historic building Ostash p20-21 gardens on site Remove exceptional values

Historical association with Ministry of (6) No relief school and possibly Does not meet new criteria Hagley Education; disclosed. (3661) former pleasure and no identified 510 Avenue T677 Quercus robur English Oak Y 6; 3661 Michael Ostash Supports listing Y Heritage Associated with a historic building Ostash p20-21 gardens on site Remove exceptional values

Historical association with Ministry of (6) No relief school and possibly Does not meet new criteria Hagley Education; disclosed. (3661) former pleasure and no identified 510 Avenue T678 Fraxinus excelsior English Ash Y 6; 3661 Michael Ostash Supports listing Y Heritage Associated with a historic building Ostash p20-21 gardens on site Remove exceptional values

Historical association with Ministry of (6) No relief One of the largest in Christchurch; school and possibly Does not meet new criteria Hagley Ulmus glabra Education; disclosed. (3661) 19m across; high landscape former pleasure and no identified 510 Avenue T680 Horizontalis Horizontal Elm Y 6; 3661 Michael Ostash Supports listing Y Landscape amenity value Ostash p20-21 gardens on site Remove exceptional values * this tree is highly significant for James Baines and (59) Oppose listing; height, the third largest recorded Does not meet new criteria Harakeke Ulmus glabra Brigid Buckenham; (3661) Supports of this cultivar in no information held and no identified 53 Street T694 Horizontalis Horizontal Elm Y 59; 3661 Michael Ostash listing Both Y Landscape the world Lowe p25 in heritage team Remove exceptional values

* Botanically unique avenue of elms associated with historic 'Fifefield' two storey (33) Opposes wooden residence c1870 Lowe p26; Ostash Association with Does not meet new criteria Hawford Fifield Estate; listing; (3661) Heritage; * exceptional landscape evaluation p10; Cadwallader homestead and and no identified 14 Road T705 Magnolia grandiflora Southern Magnolia Y 33; 3661 Michael Ostash Supports listing Both Y Landscape * exceptional heritage evaluation p5 William Bray Remove exceptional values

* Botanically unique avenue of elms associated with historic 'Fifefield' two storey (33) Opposes wooden residence c1870 Lowe p26; Ostash Association with Does not meet new criteria Hawford Fifield Estate; listing; (3661) Heritage; * exceptional landscape evaluation p10; Cadwallader homestead and and no identified 14 Road T706 Thuja plicata Western Red Cedar Y 33; 3661 Michael Ostash Supports listing Both Y Landscape * exceptional heritage evaluation p5 William Bray Remove exceptional values

* Botanically unique avenue of elms associated with historic 'Fifefield' two storey (33) Opposes wooden residence c1870 Lowe p26; Ostash Association with Does not meet new criteria Hawford Fifield Estate; listing; (3661) Heritage; * exceptional landscape evaluation p10; Cadwallader homestead and and no identified 14 Road T707 Thuja plicata Western Red Cedar Y 33; 3661 Michael Ostash Supports listing Both Y Landscape * exceptional heritage evaluation p5 William Bray Remove exceptional values

10 CCC - Rebuttal evidence Jenny Moore Appendix A - Trees identified by commenters as having exceptional values Page 17 of 19

* Botanically unique avenue of elms associated with historic 'Fifefield' two storey (33) Opposes wooden residence c1870 Lowe p26; Ostash Association with Does not meet new criteria Hawford Fifield Estate; listing; (3661) Heritage; * exceptional landscape evaluation p10; Cadwallader homestead and and no identified 14 Road T708 Quercus robur English Oak Y 33; 3661 Michael Ostash Supports listing Both Y Landscape * exceptional heritage evaluation p5 William Bray Remove exceptional values

* Botanically unique avenue of elms associated with historic 'Fifefield' two storey (33) Opposes wooden residence c1870 Lowe p26; Ostash Association with Does not meet new criteria Hawford Fifield Estate; listing; (3661) Heritage; * exceptional landscape evaluation p10; Cadwallader homestead and and no identified 14 Road T709 Quercus robur English Oak Y 33; 3661 Michael Ostash Supports listing Both Y Landscape * exceptional heritage evaluation p5 William Bray Remove exceptional values

Association with homestead and William Bray. This avenue was planted by Walter Fielding Cotterell when he was a youth (pers comm with Mrs Adams approx 10 * Botanically unique avenue of years ago - Amanda elms associated with historic Ohs). Fielding 'Fifefield' two storey Cottrell was City (33) Opposes wooden residence c1870 Lowe p26; Ostash Arborist and would Does not meet new criteria Hawford Ulmus glabra Fifield Estate; listing; (3661) Heritage; * exceptional landscape evaluation p10; Cadwallader have retired around and no identified 14 Road T710 Horizontalis Horizontal Elm Y 33; 3661 Michael Ostash Supports listing Both Y Landscape * exceptional heritage evaluation p5 10 years ago? Remove exceptional values

* Botanically unique avenue of elms associated with historic 'Fifefield' two storey (33) Opposes wooden residence c1870 Lowe p26; Ostash Does not meet new criteria Hawford Ulmus glabra Fifield Estate; listing; (3661) Heritage; * exceptional landscape evaluation p10; Cadwallader and no identified 14 Road T711 Horizontalis Horizontal Elm Y 33; 3661 Michael Ostash Supports listing Both Y Landscape * exceptional heritage evaluation p5 See above Remove exceptional values

* Botanically unique avenue of elms associated with historic 'Fifefield' two storey (33) Opposes wooden residence c1870 Lowe p26; Ostash Does not meet new criteria Hawford Ulmus glabra Fifield Estate; listing; (3661) Heritage; * exceptional landscape evaluation p10; Cadwallader and no identified 14 Road T712 Horizontalis Horizontal Elm Y 33; 3661 Michael Ostash Supports listing Both Y Landscape * exceptional heritage evaluation p5 See above Remove exceptional values

* Botanically unique avenue of elms associated with historic 'Fifefield' two storey (33) Opposes wooden residence c1870 Lowe p26; Ostash Does not meet new criteria Hawford Ulmus glabra Fifield Estate; listing; (3661) Heritage; * exceptional landscape evaluation p10; Cadwallader and no identified 14 Road T713 Horizontalis Horizontal Elm Y 33; 3661 Michael Ostash Supports listing Both Y Landscape * exceptional heritage evaluation p5 See above Remove exceptional values

* Botanically unique avenue of elms associated with historic 'Fifefield' two storey (33) Opposes wooden residence c1870 Lowe p26; Ostash Does not meet new criteria Hawford Ulmus glabra Fifield Estate; listing; (3661) Heritage; * exceptional landscape evaluation p10; Cadwallader and no identified 14 Road T714 Horizontalis Horizontal Elm Y 33; 3661 Michael Ostash Supports listing Both Y Landscape * exceptional heritage evaluation p5 See above Remove exceptional values

11 CCC - Rebuttal evidence Jenny Moore Appendix A - Trees identified by commenters as having exceptional values Page 18 of 19

* Botanically unique avenue of elms associated with historic 'Fifefield' two storey (33) Opposes wooden residence c1870 Lowe p26; Ostash Does not meet new criteria Hawford Ulmus glabra Fifield Estate; listing; (3661) Heritage; * exceptional landscape evaluation p10; Cadwallader and no identified 14 Road T715 Horizontalis Horizontal Elm Y 33; 3661 Michael Ostash Supports listing Both Y Landscape * exceptional heritage evaluation p5 See above Remove exceptional values

* Botanically unique avenue of elms associated with historic 'Fifefield' two storey (33) Opposes wooden residence c1870 Lowe p26; Ostash Does not meet new criteria Hawford Ulmus glabra Fifield Estate; listing; (3661) Heritage; * exceptional landscape evaluation p10; Cadwallader and no identified 14 Road T716 Horizontalis Horizontal Elm Y 33; 3661 Michael Ostash Supports listing Both Y Landscape * exceptional heritage evaluation p5 See above Remove exceptional values

* Botanically unique avenue of elms associated with historic 'Fifefield' two storey (33) Opposes wooden residence c1870 Lowe p26; Ostash Does not meet new criteria Hawford Ulmus glabra Fifield Estate; listing; (3661) Heritage; * exceptional landscape evaluation p10; Cadwallader and no identified 14 Road T717 Horizontalis Horizontal Elm Y 33; 3661 Michael Ostash Supports listing Both Y Landscape * exceptional heritage evaluation p5 See above Remove exceptional values

* Botanically unique avenue of elms associated with historic 'Fifefield' two storey (33) Opposes wooden residence c1870 Lowe p26; Ostash Does not meet new criteria Hawford Fifield Estate; listing; (3661) Heritage; * exceptional landscape evaluation p10; Cadwallader and no identified 14 Road T718 Quercus palustris Pin Oak Y 33; 3661 Michael Ostash Supports listing Both Y Landscape * exceptional heritage evaluation p5 See above Remove exceptional values * trees associated with Heritage NZ Historic Place Category 2; HPT 3075 ca. 1868 - Church Property (21) Oppose 1874 historical Does not meet new criteria Trustees; Michael relisting; (3661) Heritage; * Exceptional heritage? Lowe p 27; association with and no identified 50 Kirk Road T852 Cedrus atlantica Atlas Cedar Y 21; 3661 Ostash Supports listing Both Y Landscape * Exceptional landscape? Ostash p15 church Remove exceptional values * trees associated with Heritage NZ Historic Place Category 2; HPT 3075 ca. 1868 - Church Property (21) Oppose 1874 historical Does not meet new criteria Cupressus Trustees; Michael relisting; (3661) Heritage; * Exceptional heritage? Lowe p 27; association with and no identified 50 Kirk Road T853 sempervirens Italian Cypress Y 21; 3661 Ostash Supports listing Both Y Landscape * Exceptional landscape? Ostash p15 church Remove exceptional values

historical association with demolished heritage (14) Do not list tree; house and William Does not meet new criteria Linwood Paddy Snowdon; (3661) Supports * On site of Linwood House, Rolleston and the and no identified 32 Avenue T891 Ulmus glabra Wych Elm Y 14; 3661 Michael Ostash listing Both Y Heritage established 1857 Lowe p27 Brittan family. Remove exceptional values

historical association with demolished heritage (14) Do not list tree; house and William Does not meet new criteria Linwood Paddy Snowdon; (3661) Supports * On site of Linwood House, Rolleston and the and no identified 32 Avenue T892 Juglans regia Common Walnut Y 14; 3661 Michael Ostash listing Both Y Heritage established 1857 Lowe p27 Brittan family. Remove exceptional values

Important historical Association - suburb of "Redwood" conection for this Main The Redwood Hub (50) Oppose listing; named for the tree at request of Christchurch suburb. Does not meet new criteria North Sequoiadendron Ltd; Michael (3661) Supports citizens / No info on historical and no identified 340 Road T908 giganteum Wellingtonia Y 50; 3661 Ostash listing Both Y Heritage community? Lowe p27 origins of the trees. Remove exceptional values

12 CCC - Rebuttal evidence Jenny Moore Appendix A - Trees identified by commenters as having exceptional values Page 19 of 19

Refer to agreement to protection, but unhappy with cost associated with Matai this. Want relaxing Does not meet new criteria Street Liane and Kenneth of controls and and no identified 63 West T944 Quercus palustris Pin Oak Y 87 Shields associated cost. Y Landscape A landmark tree Lowe p28 no information Remove exceptional values

* significant specimen Merivale Mall/TEL * contributes landscape amenity in Property (26) Do not list this context of supermarket and Does not meet new criteria Office Fagus sylvatica Nominees Ltd; tree; (3661) adjoining residential and no identified 135 Road T970 Purpurea Copper Beech Y 26; 3661 Michael Ostash Supports listing Both Y Landscape amenity Lowe p29 no information Remove exceptional values (32) Seek that groups of trees be not included as protected unless they have at least one of the ratings Derek Garard for structure, Goring and Clair health, and shape, Heritage; Cultural significance Margaret better than fair; Unusually large, healthy examples Does not meet new criteria Brockwort Pittosporum Mulcock; Michael (3661) Supports Heritage; of the species with public amenity and no identified 87 h Place TG7 eugenioides Lemonwood Y 32; 3661 Ostash listing Both Y Landscape in the location Lowe p19 no information Remove exceptional values (32) Seek that groups of trees be not included as protected unless they have at least one of the ratings Derek Garard for structure, Goring and Clair health, and shape, Heritage; Cultural significance Margaret better than fair; Unusually large, healthy examples Does not meet new criteria Brockwort Pittosporum Mulcock; Michael (3661) Supports Heritage; of the species with public amenity and no identified 87 h Place TG7 eugenioides Lemonwood Y 32; 3661 Ostash listing Both Y Landscape in the location Lowe p19 no information Remove exceptional values (32) Seek that groups of trees be not included as protected unless they have at least one of the ratings Derek Garard for structure, Goring and Clair health, and shape, Heritage; Cultural significance Margaret better than fair; Unusually large, healthy examples Does not meet new criteria Brockwort Pittosporum Mulcock; Michael (3661) Supports Heritage; of the species with public amenity and no identified 87 h Place TG7 eugenioides Lemonwood Y 32; 3661 Ostash listing Both Y Landscape in the location Lowe p19 no information Remove exceptional values