Proposed District Plan


DATE: 12/05/2015

Submissions to the Proposed Kapiti Coast District Plan


Long View

For Perspective Only (possibilities for parking and landscaping are endless)

Longview2 2b

Typical Section b







Sand level accreted near to the top of the wall.


Recently finished timber seawall.


Root systems under stress through wind erosion.


Vegetation flourishes with protected root systems.


Centennial Highway concrete seawall complete with sea/road barrier


Still holding up after 76 years


Part 1


John Mills. Licenced Building Practitioner number BP114480

18 Beach Road Paekakariki since 1976. This property with the house spans the Urban Relocatable Build Coastal Management Area.

From the year 1999 I have owned the adjoining property number 4 The Parade. This property with the house is entirely within the Urban No Build Coastal Management Area. Both of these properties are currently now bordered and protected by the million dollar rock revetment.

I have been a carpenter and building contractor all of my 46 year working life from the age of 17.

I have been a contractor building seawalls and other varied construction around coastal, road, and river protection for 40 years. I have observed many changes to the beach levels brought about through weather events, tidal flows and built structures. I have also observed the re-establishment and flourishing of coastal trees and foliage with the protection to their root systems by timber sea walls I have constructed (see photo attachment page no 15) where previously they struggled to survive against wind and wave erosion of the sand dune.

The policies and rules contained in the District Plan have been a source of great frustration and hardship to both me and many of my clients in the “active discouragement” policy to the building of these “Hard protection structures”.

Therefore I object to

  • The draconian rules which have been applied across the whole district which do not take into account many of the circumstances which I as an individual land owner and builder have to face.
  • The District Plan policies and rules being based on provably dubious scientific data.

See e.g. Dutch Study: Unlike Arctic Region Antarctic sea ice has expanded at significant rate since 1985. (01/04/13)


I object because

  • There are many hugely negative and long term ramifications to the community and myself as an individual land owner if these plans are adopted without some consideration to the changes I have outlined later in part 1 of my submission.
  • The Managed retreat policy assumes that mankind can do nothing positive to defend our coastline from future promised inundation by the sea. I offer the example of the defence of Holland as a counter to this.


I seek relief

  • In either to delete or amend the policies, rules and standards I have identified, or
  • In asking that all of the Coastal Hazards section be re-written taking into account the options I have outlined and my wish to be further consulted about the outcome.


This submission addresses the following matters

  • Coastal Protection Structures
  • Area No Build Zones
  • Permitted Activities


Reasons for wanting change.


Coastal Protection Structures.


Policy 4.9 – Hard protection structures.

“the use of hard protection structures will be actively discouraged by”

This policy statement:

a)     Far too radically assumes sea level rise coupled with depletion of the sand reserves in a (fear mongering) worst case scenario and it gives no room for innovative solutions.

b)    Is pessimistic to the extreme, ignoring examples of sand accretion measured by various reliable observers over the past hundred years.

c)     Tramples the rights of both private seaside land owners and the coast enjoying populace whose rights must be upheld by the council regarding protection of the shore line at least to existing lines.

d)    Suppresses innovative development in favour of managed retreat as if there will be no will or ability to adequately hold the line sometime in the distant future.

e)     Ignores human progress armed with increasingly technologically advanced machinery to accomplish large projects with ever more efficiency and speed.

f)     Must have been written by “back to nature” coastal activists.



Restrictions to current height levels have had to be disregarded along The Parade Paekakariki and The Esplanade Raumati by the KCDC as fear of sea level rise and storm events has brought public assets under threat. This shows a contravention of the maintenance of height and locations explanation in the policy showing it to be too restrictive and thereby flawed.


So called “hard protection structures” are necessary in areas where there is insufficient room to cultivate healthy sand dunes. The right to protect a land owner’s property must always be maintained provided it is at their own expense whether through hard, soft or other means of protection. Timber or concrete walls and rock revetment are terms respectively “hard” and “soft or medium hard”. They are applied in an adopted pseudo engineering term referring to coastal erosion protection. Walls are safe to humans and animals but rocks involve risk and ought not to be used in areas where space is at a premium. (see photo attachment page no 14)


Specific planning strategies need to be developed for categorised coastal areas taking into account both where they are situated and any existing protection/management systems.

Planning strategies need to require adjoining land owners to adopt a combined and consistent approach in areas specifically where hard protection is adopted and/or necessary.

The burden of unplanned and unwanted negative effects arising from any development of coastline protection must to be on the developer.


Changes sought to the Proposed District Plan.

In my opinion hard protection structures because of their importance should not be subject to costly and lengthy resource consent application procedures under the PDP.


No 1:

That Policy 4.9 be changed to –

The use of hard protection structures –

a)     Will be permitted in designated areas.

b)     Which must be maintained by property owners will require compulsory replacement insurance to counter any event of catastrophic failure.

c)     May protect new development where specific planning strategy has been developed for areas and where there is existing adequate coastal protection.

d)    Will be increased in length and height as the need arises at the compulsory responsibility of the owner, similar to the earthquake strengthening obligations of building owners.

e)     Means owning a seaside property carries a greater burden of responsibility.


Council owned and maintained seawalls protecting private property need to be sold, gifted, or leased to the property owners whose properties they protect. This is to alleviate council responsibility for ongoing maintenance, increase in strength and height, and/or replacement costs.


No 2:

That Non Complying Activity Rule 4A.5 (3) on Coastal Protection Structures be deleted.


No 3:

That Prohibited Activity Rule 4A.6 (1) on Coastal Protection Structures be deleted.


No 4:

That a new Permitted Activity Rule be included, subject to appropriate standards, be included in the Coastal Environment Section of the District Plan allowing protection structures.


Area No Build Zones and Permitted Activities


Reasons for wanting change

Rule 4A.1 – Permitted Activities.

The range of Permitted Activities is too narrow and stifling to any improvement of the environment and for usage of coastal lands. They allow for no innovative new buildings and focus only on forcing development to be constricted to existing levels. I have found no forthright legislative statement whereby development of the coastal land resources is required to be inhibited and contained, to satisfy any particular political interest. But the effect of these limited Permitted Activities is to frustrate and trample the natural rights of many invested citizen/landowners.

Furthermore in areas where significant expenditure has already been committed to coastal protection it has become a glaring farce to continue to restrict reasonable progressive improvements. The phrase in the explanation stating increased protection “is considered to be unsustainable both in terms of cost and effects on the natural systems” breaches the rights of property owners and council to protect the coastline on the assumption that there will be no accumulated, and even planned ability to take action at the time such events may or may not become an issue.

The phrase “and gross floor area” which refers to a restriction of alteration size, of existing buildings in the No Build zones is indicative of an unnecessary dampener on innovation. And it halts the improvement of the building useability of the footprint unfairly reducing the value of the property.


Change sought to the Proposed District Plan.


No 1:

That a new Permitted Activity Rule 4A.1. be included to allow for new structures.


No 2:

That (2) in the Standards of this proposed new Permitted Activity the words be included to “The footprint of the building shall not increase as a result of the new building unless there is adequate coastal protection”.


No 3:

That (2) in the Standards of Permitted Activity number 3 the words “and gross floor area” be deleted, and the words be added to the end of the sentence “unless there is adequate coastal protection”.


No 4:

That Policy 4.15 – Adaption be changed to include at the end —

“— where over a set time no adequate effort or expenditure has been committed to protect the property”



Part 2


Example of a proposed “Hard Protection Structure”

(Dimensionally accurate drawings attached.)


Comments and proposal regarding the maintenance and protection of the remainder of the Paekakariki foreshore.

During this submission process I have learned that the only way to bring about a change to the district plan requires a thoughtful presentation which has arisen from problems experienced with the plan highlighted by ordinary people at the coal face.


Reasons for wanting change

The plan which prohibits hard protective structures at the coastal edge while may be reasonable in areas with sandy dunes between the built area and the high tide mark is taking much too broad an approach and is unrealistic for areas which have little or no space to accommodate the softer options. Such a rule is damaging to the coastal environment and infringes on property owner’s rights to protect their property. I believe it to be misleading that seawalls are labelled hard structures and rock revetment not hard, rocks are provably hard structures in any normal understanding of the English language.


The 400 meters of rock revetment to the Southern Parade section have been a dubiously successful fix to mostly the high bank area. The protection to the council road asset has been gained at the cost of $2,250 per meter (one million dollars) and loss of space to many thousands of recreational users. (See council options attachment page no 17)

At the same rate already outlaid it would take $3,000,000 more to complete The Parade as rock revetment. I submit that the money could go towards a more constructive and far more user friendly concrete option.


Paekakariki Beach is cramped between the rocky centennial highway and the hill and does not have the huge sand reserves and space of the beaches to the north. The road is protected by a similar sized concrete wall to that of this proposal. (See photo attachment page no 16)


In the public consultation process over the proposal of the Rock Revetment it was generally agreed to, provided it stayed within the confines of the existing rock protection which covered 4 meters of the high tide (dry sand) area out from the original seawall as per original design. This assurance was given together with options and costing’s. The meeting was told it made sense to use the existing resource consent to install the first 400 meters. It can be backed up with photographic evidence that these confines have been significantly exceeded.


It is my contention that a continuation along the remaining 1.2 kilometres of the same to the northern end of The Parade should not adopted because:


1/ A full parade length rock revetment will permanently change the culture and feel of Paekakariki as a destination for sun and surf bathers.

2/ The area where the rock revetment is installed has destroyed all dry sand beach. The only usable beach area for walking occurs twice in a 24 hour period when the tide is out.

3/ The rocks are slippery, not people friendly; and dangerous to climb over.

4/ The rock revetment requires on-going maintenance re-placing dislodged boulders after stormy events.

(See council options attachment page no 17)



  • At any given day over the 2012/2013 summer holidays and sunny weekends many hundreds of people including families with small children, body surfers and sunbathers could be seen enjoying the entire beach to the north of the Rock revetment and past the surf club along to Queen Elizabeth Park.
  • Conversely at the area of beach along the Rock revetment at low tide, only one or two persons settled between spilled random rocks thrown from the pile by the surf during a previous storm.
  • When the tide is beginning to flow around the rock toe, walkers are seen to pick their way between and over the slimy rocks risking injury as the tide washes round their ankles.
  • These observations provide a clear indication of the threatened complete destruction of recreation areas enjoyed by many.
  • The large access ramp opposite the Sand Track provided with the revetment has become unpassable at the beach level due to localised erosion which exposed strewn rocks similar to a rocky river bed.
  • The effect of the rock revetment to the sand movements is thought by many observant locals, to have significantly increased sand levels to the south. This can be observed through the use of photographs showing that the sand has accreted almost to the top of a timber seawall built more than 30 years ago (See attachment photo page no 14). This is an accretion of about 0.800 mm, a height not seen before.
  • Therefore then with the revetment having caused significant effect to the south as just stated, if extended gives an unknown and impossible to predict further possibility of negative consequences.
  • The people of Paekakariki greatly value the beach front store, Campbell Park, and Memorial Hall as gathering places worthy of significant adjacent beach entrances.



Because of the now proven radically negative changes to Paekakariki’s best, most used and enjoyed asset which will occur with a full length rock revetment I propose the following:


A concrete wall constructed immediately in front of the existing old timber wall to the same height as the rock revetment. A rough estimate of cost of this concrete option is $2,500 per meter.

This wall would consist of

  • A concrete or sheet piled toe founded deep enough to ensure that the supporting material is contained despite the wildest known fluctuations in beach sand levels.
  • A concrete footing/pad constructed just below the normal beach sand. This would be exposed only when needed during stormy weather events at which time the beach can drop below the normal levels without danger of undermining.
  • A vertical wall constructed directly in front of the existing timber poles to the full height of the rock revetment.
  • A concrete pad constructed on top of the wall and over imported backfill cantilevered out for wave deflection.
  • Concrete buttresses for sectioning recreation areas and providing strength to the retaining value of the wall. With some expert design these could also act in a wave control function.
  • Some significant and generously sized access points. Preferred examples are included in the dimensionally accurate computer generated drawings.


The benefits of this wall would be:


  • A beach saved for present and future generations to enjoy.
  • No ongoing maintenance problems with shifting boulders creating dangers.
  • Safe beach environment for users.
  • “Hard protection” is already in place as the existing seawall and therefore the effects to the overall coastal environment can be reliably guaranteed.
  • The saving for recreational use, 7,200 m² of publicly usable dry beach sand.
  • The creation of 12,000 square meters of additional prime sea side recreational space. This is a 1.2 kilometres long by 10 meters wide strip of usable flat space (shown in the dimensionally accurate computer drawings. This strip allows for a wide public walkway, long grassed picnic areas with tables, seats and rubbish receptacles, trees and smaller coastal plantings. Angle and parallel parking with plenty of room for overnight camper vans. Including the saved beach space, 15,000 square meters of recreation area can be created which would be impossible given the revetment option. This space equals more than two full sized rugby fields. And added to this is the space for the walk way. Altogether more than 19,000 m².
  • For this section see Typical Section and Areas 1,2,3,4 attachment pages nos 9,10,11,12,13.


Suggestions on how to construct:


  • The site could be prepared using a tracked machine to flatten and level.
  • Sheet piling driven to a depth of 2.5 meters below toe level  at 3 meters out from the existing wall – or:
  • The toe could be installed using a large chain digger of the type employed by Meridian Energy in the installation of the power feeds between the turbines of wind farms. These machines can quickly excavate a trench more than 2 meters in depth.
  • The concrete toe could be insitu poured reinforced concrete with the horizontal reinforcing fed into place by the excavator.
  • Or pre cast slabs placed immediately the machine has excavated prior to the sand washing back in.
  • The reinforcing would connect into the footing and run continuously up the wall ending in the walk way.
  • The wall could be built with either conventional concrete formwork or a combination of formwork and Shotcrete using local labour.
  • Much of the preparation for the concrete option can be done off site. And proposed beach entrance sites could be utilised ramping the existing rocks currently functioning as toe protection.
  • The walk way would offer an excellent strengthening opportunity in tying and bracing the top of the retaining wall helping to suppress wave vibration.
  • If during the process of building or waiting to build the concrete option a storm emergency eventuates, a stock or rocks could be kept to protect the toe of the existing wall as has been the case up until now. Upon completion of the work these rocks could be uplifted and used for construction of rock revetments perhaps to the northern beaches of the Kapiti Coast where space and effects is not an issue.
  • Any unlikely failure of supporting ground under any part of the structure can be corrected by simple chemical injection technology.



We the residents of Paekakariki if given a choice prefer to wait under a longer termed staged or incrementally programmed completion time period than see more of our beach destroyed by more rock revetment.


If it was deemed that the whole project was too large for a single build I propose a two stage construction period.

Stage 1

Construction of the footing.

Stage 2

Construction of the wall and landscaping.




The footing constructed just under beach level would act as a buttress to the existing timber seawall eliminating the need for tie back and maintenance of existing metal fixings if a staged construction plan was chosen.

2 thoughts on “Proposed District Plan

  1. A well presented, thorough and considered submission – looking at the cost benefits surely the community cannot sit idly by, simply accepting the “inevitable” when for a very tiny % of the property value, and dare I say % of the collected community rates, we can turn what is considered a community threat into a positive community outcome as outlined in your concept drawings?
    Whilst the financial return may be hard to quantify, even in the short/medium term this must be considered a public priority and a community investment rather than a cost. With modern day engineering design/materials/techniques, your submission is a far, far cry from King Canute’s ineffective command –
    “Very well. Sea,” cried Canute, “I command you to come no further! Waves, stop your rolling!. Surf, stop your pounding! Do not dare touch my feet!
    Your submission is a breath of fresh air amoungst what could be seen as a defeatist attitude to climate change and its effect on coastal erosion. Whilst we may have to accept rising sea levels, and design for them (at additional cost) this does not absolve us of the responsibility of protecting our foreshore from coastal erosion.

  2. A well thought out and presented proposal John and certainly worth serious consideration. I am against a rock revetment, and prefered a wooden wall if we have to have something – but your ideas seem quite acceptable 🙂

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