To the Wellington City Council
This is our submission on the Town Belt Guiding Principles (public consultation closing 9 September 2011). It is of enduring interest to us, and we wish to be heard in any oral submissions process on this consultation.
Overriding paramount principles
- Firstly, the Wellington Civic Trust (the Trust) recommends to Council that there be overriding paramount principles. The foremost of these would be that the Town Belt is to be accorded a mana and a sanctity that place it supremely above all other public reserve and recreation areas. The other overriding principle would be that each generation of Wellington Councillors and citizens honour the responsibility of protecting and enhancing the Town Belt as open recreational space for future generations in perpetuity. This is not just another park.
Legislative review
- Curiously, the explanatory booklet lacks any context or commentary for the legislative part of the proposed review.
- The Trust believes that it would be more enlightening for the public of Wellington to have from Council an outline of the legislative changes that will be sought. Preferably timing for such disclosure would be before the guiding principles are adopted and before the review of the management plan. This will enable all participants to comprehend the end game before detailed consultations commence.
- Of primary importance is for the amending legislation to establish a legal process for returning original Town Belt land back to Town Belt status enjoying statutory protection as well as the protections bestowed by the 1873 Trust Deed. Rather than requiring amending legislation as at present, provision could be made for returning land to be mandated by an Order in Council on the joint recommendation of the Mayor and City Councillors as Trustees and of the Minister of Conservation. Removal of Town Belt land on the other hand should require amending legislation.
- The broad intent of the 1873 Trust Deed needs to be upheld: that it is a public recreation ground available as open space to all, at all times, in perpetuity. The legislation should make reference to the original ideals enunciated when the Town Belt was established in 1839.
- The temptation to expand the definition of ‘recreation’ needs to be resisted. Instead, consideration could be given to spelling out those activities that are not compatible with the ideal of universal accessibility. For example, these could include educational institutions, commercial ventures, and allotment gardens. It is the Trust’s view that any widening of the interpretation of ‘recreation’ has the potential to seriously and perhaps permanently undermine the integrity of the Town Belt.
- Another feature that the Trust would like to see in the amending legislation is formal status being accorded to the position of Town Belt Curator. The statute could require the Mayor and Councillors as Trustees to appoint a senior officer with experience in the management of parks and reserves. This would help ensure that the Town Belt is perceived by Council officers and by the public as having a status unique from other reserve lands. It would also assist in establishing clear lines of responsibility.
- Submissions for improvements to the wording of the proposed Principles, plus some explanatory comment, follow.
Principle 1
Proposed wording in Council’s brochure
There will always be a Town Belt in Wellington
Suggested changes
The Trust recommends that the wording of this guiding principle be changed to read as follows:
There will always be the Town Belt in Wellington, held in trust for the citizens of Wellington in perpetuity.
It needs to be emphasised that there will always be the Town Belt, not ‘a Town Belt’ and that the boundaries be defined as those established in 1840 by William Mein-Smith. Confining the term ‘Town Belt’ to the original intention gives that part of the city an historic and legal identity that sets it apart from all else and gives it a unique status. It also acknowledges that over time areas have been alienated and that every opportunity should be taken to restore those areas to the Town Belt.
Principle 2
Proposed wording in Council’s brochure
The Council will work in partnership with mana whenua to manage the Town Belt
Suggested changes
The Trust recommends that the following wording be adopted for this principle:
The Council will work in partnership with mana whenua and will acknowledge the value of the Town Belt to Wellington by actively consulting with other guardian groups in the community that have maintained a long-lasting commitment to protecting and managing the Town Belt.
Principle 3
Proposed wording in Council’s brochure
The Town Belt’s natural character will be protected and enhanced
Suggested changes
We suggest that the wording be changed to read:
The Town Belt’s natural character of open space and visual beauty will be protected and enhanced.
Principle 4
Proposed wording in Council’s brochure
The Town Belt is for all to enjoy
Suggested changes
The Trust suggests that this principle be more comprehensively defined, and read as follows:
The Town Belt is for all to enjoy and is to be freely accessible at all times. To this end buildings and carparks will be kept to a minimum and over time be Council owned and operated as multi-purpose facilities available to a wide variety of recreational groups.
The Civic Trust favours a gradual change in the ownership and control of buildings on the Town Belt. Exclusive use by individual clubs should over time be set aside and succeeded by multipurpose facilities that can be pre-booked by a wide variety of recreational groups. The Council would then have more freedom to influence higher standards of building design and of maintenance.
Principle 5
Proposed wording in Council’s brochure
The Town Belt will be used for a wide range of recreational activities
Suggested changes
It is suggested that this principle be changed to read as follows:
The Town Belt will be primarily used for casual and organised outdoor recreation activities, without compromising its natural character.
The definition of ‘recreation activities’ is the linchpin to this whole exercise. It is recommended that a very constrictive approach be taken to defining what constitutes recreation.
Definitely to be excluded are any educational facilities. These invariably involve either Government funding or commercial interests, and would inevitably lead to Town Belt land being sequestered by specific interests.
Another concern is the idea of creating recreational hubs. There is the risk of these being regarded as areas for more buildings with sporting codes pressing for exclusive use.
Principle 6
Proposed wording in Council’s brochure
Management of the Town Belt will acknowledge historical and cultural links to the land
Suggested changes
We suggest the wording be as follows:
The Town Belt is to be celebrated for its longstanding historical cultural importance to Maori and to Pakeha alike.
The Civic Trust is wholly supportive of greater emphasis being given to pre- and post-European history and settlement and is keen to see greater balance in relating the history of both cultures.
The use of the word ‘open’ in Overriding Paramount Principles would normally be interpreted as meaning no buildings. Is this what you mean?
Denny – I will ask the Convenor of our Town Belts issues group and post a reply.
Yes, open space does imply no buildings. It is an ideal that underpins
the concept of the Town Belt being accessible to all at all times.
Presently many of the buildings on the Town Belt are occupied by one
sporting code alone. This exclusivity of use is contrary to the ideal of
universal accessibility. This is why the Civic Trust is suggesting that
the City Councillors as trustees could have a very long-term objective of
the Council owning and controlling buildings for multiple use.
Finally, the Civic Trust regards the guiding principles as long-term
ideals rather than emphatic statements of immediate policy. They are seen
as compass points for making decisions, and inevitably there will at times
be exceptions.