Hamilton City Council has been imposing heritage designations on properties as part of Plan Change 9.

Jean Dorrell supplies CityWatch NZ with her detailed analysis of the “PC 9” problems in a document sent to Hamilton City Councillors.

The document’s Executive Summary is copied below and the full open letter can be downloaded using this link.

Jean Dorrell HeritageGate

 

Executive Summary

  1. The imposition of a heritage designation on a property results in increased costs[1], it generally decreases the property value[2] and places restrictions on the home owner[3]. These are serious impositions and should not be placed on a property without strong evidence.
  2. Hamilton City Council (HCC) was required to identify and review qualitifying matters, including heritage, under the NPS-UD and the usual ten-yearly review of the District Plan.
  3. HCC engaged a heritage expert, Richard Knott (Richard Knott Limited) , who identified 32 Historic Heritage Areas (HHAs). He later stated that he was not given the time or resources to carry out research on individual HHAs. Mr Knott revised his reports and methodology multiple times, being paid for rework each time. Mr Knott was paid $200k in total.
  4. Prior to public notification, HCC engaged Adam Wild (Archifact Consultants Limited) to complete a desktop peer review[4] of the original Knott report. The report was critical of Mr Knott’s methodology (noting that it was more about character (not a qualifying matter) than heritage values) and recommended that 17/32 (53%) of the Knott HHAs either required further work before public notification or should be removed.
  5. The 32 HHAs were publicly notified in July 2022 with no amendments. Mr Wild’s peer review was not made public.[5]
  6. By the end of 2023 (prior to the third and final hearing), HCC had decided not to pursue 14 of the 32 original HHAs. This is 44% of Mr Knott’s original recommendations.
  7. HCC engaged WSP to identify individual built heritage items (mainly residences). WSP recommended 181 new built heritage items. The WSP report was not peer reviewed prior to public notification. WSP were paid $366k for their work on built heritage.
  8. In 2023, HCC employed Elise Caddigan. Over the next year Ms Caddigan reviewed all the publicly notified built heritage items. Based on her recommendations and other work, HCC chose not to pursue 123 (68%) of the publicly notified items.
  9. The muliple changes in the HHA methodology and reports resulted in HHA submissions being heard at three hearings, instead of one as originally planned.

Footnotes

[1] House insurance is either higher or heritage features are excluded from coverage. [Confirmed by AA, AMI, NZI and Vero]. Consents are required for things which non-heritage properties do not require consents for. Heritage expert reports are required to accompany consent applications.

[2] The price premium of heritage in the housing market; evidence from Auckland, NZ (2020, Bade, Castillo, Fernandez and Aguilar-Bohorquez) states a 9.6% reduction.

[3] For example, no solid fences over 1.2m and no fences whatsoever over 1.5m.

[4] A brief peer review with no research or site visits.

[5] I obtained it via a LGOIMA.

 

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Further reading on this issue

 

Plan Change 9: Kāinga Ora appeals against large blocks of Hamilton becoming Historic Heritage Areas