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ARTICLE · Small Concession

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

An analysis of the Small Concession case involving the former Kamiya residence (registered tangible cultural property) within the nationally designated historic site of Honshoji Temple in Anjo City, Aichi. This article examines the scheme design structure under dual legal constraints — historic site designation and cultural property registration — with Deloitte Tohmatsu serving as the expert advisor.

The points of this article

  • Anjo City has designated the former Kamiya residence (registered tangible cultural property) within the nationally designated historic site of Honshoji Temple as the target facility for the Small Concession Formation Promotion Project
  • The dual legal constraints of historic site designation (Cultural Properties Protection Act) and registered tangible cultural property (same act) fundamentally limit the degree of freedom in activation — a high-difficulty case
  • Deloitte Tohmatsu was selected as the expert advisor due to their legal and institutional risk management capability at the intersection of cultural property activation and public-private partnerships
Who this is for, and what to know first

Who this is for

  • Cultural properties and planning division officials considering activation of designated cultural property facilities
  • Private operators considering business entry using historic sites and cultural properties
  • PPP/PFI consultants interested in high-difficulty Small Concession cases

What to know first

  • Basic understanding of Small Concession ([What Is Small Concession?](/en/small-concession-what-is))
  • Small Concession case studies ([7 Case Studies](/en/small-concession-cases))
In this article

Overview of Honshoji Temple and Former Kamiya Residence

Historical value of the nationally designated historic site and architectural features of the registered tangible cultural property

Unit costs and amounts in financial examples without a cited source are illustrative assumptions, not statistically established market rates. Use estimates and comparable records appropriate to the target facility, location and business when preparing a project plan. Distinguish these assumptions from cited statistics and case expenditure.

Honshoji Temple precinct historic site designation

2015

Nationally designated

Former Kamiya residence main building cultural property registration

2024

Registered tangible

Population of Anjo City (2025 Census preliminary figure, as of 1 October 2025)

186,353

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 main house of the former Kamiya residence, registered as a national Registered Tangible Cultural Property (structure) on August 15, 2024. Built in 1920, single storey with a partial second floor, 203 square metres of floor area. Anjo City has acquired the building and plans to open it to the public after seismic reinforcement.

Five phases to commercialization and where the barriers stand: momentum, site selection, feasibility, planning, solicitation.
Main challenges and actions across five stages of project developmentSource: MLIT Policy Bureau, Draft Promotion Measures for Small Concessions (2024)

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.


Legal structure of current-state change regulations in historic sites and the notification system for registered tangible cultural properties

Constraint 1: Current-State Change Regulations in Historic Sites

The Honshoji Temple precinct is a nationally designated historic site, and the 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:

ActivityPermission Required?
New construction or extensionsAgency for Cultural Affairs permission required
Exterior changes (roof, walls, openings)Agency for Cultural Affairs permission required
Ground excavation (piping, foundation work)Agency for Cultural Affairs permission required
Tree felling or plantingPermission required depending on scale
Temporary structure installationDetermined by scale and duration

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

Role of Deloitte Tohmatsu

Reasons for the selection of a major consulting firm and expert functions in cultural property cases

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.


Market Sounding Survey

Design, process, and results of the sounding survey conducted by Anjo City

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 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.


Design Patterns for Cultural Property × Small Concession

Methodology for scheme design premised on legal constraints

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.


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

What to do next

When considering reuse of idle facilities, examine their condition, local demand and operator interest.

#What to check or considerResponsible team or contact
1Review idle facilities and local demand. Compare building condition and location with uses needed in the areaAsset management team
2Check seismic assessment and asbestos survey results for candidate facilities. If surveys are missing, determine their scope and how to commission themFacilities team
3Use MLIT's platform to gather information. Membership is free and provides case studies and notices about grants and expert dispatch callsOfficial platform website
4Ask operators about their interest and requirements. If a standalone project is difficult, consider cooperation with neighbouring municipalitiesMarket sounding and neighbouring municipalities
5Compare operating rights, leasing and designated management in light of operator feedback. Choose a method suited to the facility's use, finances and public-private responsibilitiesResponsible department and asset management team

Platform membership provides access to information about expert dispatch and grant calls. Before applying, check eligibility, available support and deadlines in the call documents.


References

Notice: Beginning Public Solicitation of Experts for Small Concession — Ministry of Land, Infrastructure, Transport and Tourism (2026)

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

Historic Site: Honshoji Temple Precinct — Anjo City (2024)

Small Concession Promotion Strategy — MLIT General Policy Bureau (2024)

Statistics cited in this article

  1. 1Anjo City Historic Site Honshoji Temple Precinct(2024) Open source
  2. 2Anjo City, Main House of the Former Kamiya Residence(2024) Open source
  3. 3Aichi Prefecture, 2025 Census Preliminary Results: Population and Households by Municipality (as of 1 October 2025)(Published 29 May 2026) Open source
  4. 4MLIT Small Concession Formation Promotion Project(2025) Open source
  5. 5Anjo City Market Sounding Survey(2025) Open source

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What was corrected

  1. — The number card gave Anjo's population as about 190,000 with no source.

    Before
    ~190K (no source)
    After
    186,353 (Aichi Prefecture, 2025 Census Preliminary Results: Population and Households by Municipality, as of 1 October 2025)

    Reason The card now carries the census figure and its source.

  2. — The sources for the temple and the residence moved from Wikipedia to Anjo City pages.

    Before
    The temple and the registration of the former Kamiya residence were both sourced to Wikipedia
    After
    The temple now cites Anjo City's page on the historic Honshoji precinct, and the residence cites Anjo City's page on the main house of the former Kamiya residence

    Reason The registration date of August 15, 2024 is unchanged. The Anjo City page also gives the construction details, which we have added: a single storey with a partial second floor, 203 square metres of floor area, built in 1920.

Key Terms in This Article

Sounding (Market Survey)
A dialogue-based market survey conducted before public tender to gather private sector opinions and ideas on utilizing public assets. Used to pre-validate feasibility and appropriate conditions.
Small Concession
A small-scale PPP/PFI initiative (typically under 1 billion yen) for revitalizing underused public properties such as vacant houses and abandoned schools. MLIT established a dedicated platform in 2024.

What to check on your own case

  • Does your municipality have facilities with historic site or cultural property designation that could be considered for activation?
  • How would you design the balance between cultural property 'preservation' and 'activation'? Where are the risks that activation undermines preservation?
  • What criteria distinguish cases requiring major consulting firms' legal risk management from those manageable by locally-embedded experts?

YOUR PROJECT

From the general to your own case.

For your building and your tender terms, you can ask us about studies, policy groundwork, dialogue and proposal preparation. The first conversation covers where things stand and what we can cover; work on your case is quoted in advance.

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