Anjo City × Deloitte Tohmatsu — Legal Constraints and Scheme Design for a Historic Park Kominka

Honshoji Temple in Anjo City, Aichi Prefecture, is a Shinshu Otani-ha (True Pure Land sect) temple known as the base of the Mikawa Ikko-ikki uprising (1563). On March 10, 2015, "Honshoji Temple Precinct" was designated as a nationally designated historic site, with Anjo City serving as the management body.

Located within this historic site precinct is the former Kamiya residence, whose main building was registered as a registered tangible cultural property on August 15, 2024. Anjo City has acquired the building and plans to open it to the public after seismic reinforcement.

Why This Case Merits Attention

What fundamentally distinguishes the activation of the former Kamiya residence from typical public facility activation is the existence of dual legal constraints: historic site designation (land) and registered tangible cultural property (building). These dual constraints drastically limit the degree of freedom in activation, creating legal issues that cannot be addressed through conventional renovation or commercial reuse.

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Constraint 1: Current-State Change Regulations in Historic Sites

The Honshoji Temple precinct is a nationally designated historic site, and the Small Concession target facility is located within this designated area. Under Article 125 of the Cultural Properties Protection Act, permission from the Commissioner of the Agency for Cultural Affairs is required for any act that would alter the current state of a historic site or affect its preservation.

Specifically, the following activities are regulated:

Constraint 2: Notification System for Registered Tangible Cultural Properties

The main building of the former Kamiya residence is a registered tangible cultural property. Under Article 64 of the Cultural Properties Protection Act, notification to the Commissioner of the Agency for Cultural Affairs is required when changing more than one-quarter of the exterior. While regulations are less restrictive than for designated cultural properties (Important Cultural Properties, etc.), "anything goes" is not the case.

At the Intersection of Dual Constraints

When the historic site's current-state change regulations overlap with the registered tangible cultural property's notification system, constraints such as the following emerge:

• Building renovation: The exterior cannot be significantly altered (cultural property constraint), and ground excavation and piping changes in the surrounding area also require permission (historic site constraint)
• Use change: When considering conversion to a restaurant, building modifications for drainage, ventilation, and kitchen equipment installation, along with ground excavation, may conflict with both historic site and cultural property constraints
• Project timeline: Permission applications → Agency for Cultural Affairs consultation → permission acquisition can take months to over a year, making standard business schedules impractical

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Why Deloitte Tohmatsu Was Selected

In the FY2025 Small Concession Formation Promotion Project, Deloitte Tohmatsu was selected as the expert for the Anjo City case.

The reason Deloitte Tohmatsu was chosen lies in their legal and institutional risk management capability at the intersection of cultural property activation and public-private partnerships. Specifically, three factors are considered:

① Practical knowledge of the Cultural Properties Protection Act: Practical understanding and process management capability for historic site current-state change permission applications and registered tangible cultural property notification procedures.

② PPP/PFI scheme design: The ability to design viable business schemes (project duration, financial structure, risk allocation) even for cases with extensive legal constraints — a core strength of major consulting firms.

③ Experience in inter-ministry coordination: Cases involving multiple government bodies — the Agency for Cultural Affairs, MLIT, prefecture, and city — require inter-ministry coordination experience. Deloitte Tohmatsu has track records in national-level public-private partnership projects.

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Anjo City's Sounding Design

Anjo City conducted a market sounding survey regarding the utilization of the (provisional) Honshoji Temple Historic Site Park and the kominka (former Kamiya residence main building) within the historic site.

This market sounding survey aimed to ascertain private-sector participation appetite, utilization ideas, and business viability conditions for a facility with legal constraints. Unlike standard sounding surveys, it characteristically requires sharing the premise of "what is legally possible" at the outset of the sounding process.

Key Design Considerations for Sounding

In cultural property case soundings, the following information must be provided to operators in advance:

• Building condition survey results: Current state of structure, seismic capacity, and building systems
• Inventory of legal constraints: Historic site current-state change regulations, cultural property notification system, Building Standards Act applicability
• Permission procedure outlook: Required timeline and procedures for Agency for Cultural Affairs consultation
• Municipal policy: The city's basic position on the balance between preservation and activation

Unless operators are presented with this information and asked "what can you do within these constraints," actionable proposals cannot be obtained.

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Design Methodology from the Anjo City Case

From the former Kamiya residence case, effective patterns for cultural property × Small Concession business design can be summarized.

Pattern 1: Non-renovation activation

Minimize building renovation and pursue activation possible with the current state. Tea ceremony rooms, exhibitions, galleries, and meeting rooms — uses requiring no building renovation — are candidates. This presents the lowest legal hurdle.

Pattern 2: Reversible renovation activation

Activation premised on "reversible renovation" (renovation that can be restored to original condition) that does not impair cultural property value. This includes temporary equipment installation and removable interior modifications. Prior consultation with the Agency for Cultural Affairs is necessary but permission is relatively obtainable.

Pattern 3: Combination with surrounding land activation

Avoid building renovation itself and install revenue-generating facilities (dining, retail) on surrounding land outside the historic site designation boundary. The building serves as "an exhibition and experience venue" while revenue is secured through "surrounding facilities" — a functional separation design.

→ For comparative analysis of all seven Small Concession municipalities, see 7 Small Concession Case Studies.

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Related

7 Small Concession Case Studies

Structural analysis of the seven municipalities selected in FY2026

Fundamentals

What Is Small Concession?

Basic mechanics, target facilities, and how to participate

Comprehensive Comparison of 7 PPP Methods

How to choose among Park-PFI, Small Concession, designated manager, and other approaches

References

Notice: Beginning Public Solicitation of Experts for Small Concession (2026)

Market Sounding Survey for Utilization of (Provisional) Honshoji Temple Historic Site Park and Former Kamiya Residence (2025)

Historic Site: Honshoji Temple Precinct (2024)

Small Concession Promotion Strategy (2024)