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Submission details

Submission ID 10217
Name Dianne Mulhern
Date 9 April 2026
1. Do you have any feedback on the IAWAI Water Services Strategy?
While I support the need for long-term investment in water infrastructure, I have significant concerns that the IAWAI Water Services Strategy is not sufficiently evidence-based, transparent, or future-fit.
A key concern is that the strategy appears to be largely a continuation of previous approaches rather than being developed from first principles. This is particularly problematic given clear evidence that growth projections have been significantly overstated (for example, approximately 237 CBD residential units delivered over 10 years compared with projections of around 4,000). Continuing to plan major infrastructure investment based on these assumptions risks substantial overbuilding and unnecessary long-term debt.
There are also serious concerns regarding public health and environmental outcomes. The proposed or continued discharge of treated wastewater into the Waikato River, in close proximity (approximately 4km) to drinking water intake points, creates a level of risk that does not appear to be adequately addressed. This is compounded by the well-documented limitations of current treatment systems to remove pharmaceuticals, hormones, and other micro-contaminants, which raises questions about long-term cumulative impacts and the credibility of claims regarding river health and safe food gathering.
From a financial perspective, the strategy relies heavily on debt funding while introducing additional growth charges without clear evidence that historical growth has failed to pay its way. At the same time, inconsistencies in development contribution policies and the potential for discretionary waivers create a real risk that costs will be unevenly distributed and ultimately shifted onto existing ratepayers.
There is also concern that the strategy prioritises large-scale capital investment over optimisation of existing infrastructure. Evidence indicates that less than 1% of treated water is used for drinking, with significant volumes used for non-essential purposes and approximately 14% lost through leaks and inefficiencies. This suggests that demand management, maintenance, and alternative approaches (such as rainwater harvesting) have not been fully explored before committing to major new infrastructure.
More broadly, the strategy does not appear to adequately reflect the current risk environment, including economic pressures, interest rate uncertainty, and global supply chain risks. These factors materially affect affordability and project delivery and should be central to decision-making.
Finally, there are concerns about governance, transparency, and engagement. The community has not been meaningfully involved early in the process, and key decisions appear to have been shaped prior to engagement. This undermines trust and limits the ability for genuine community input.
Conclusion
Overall, I consider that the strategy requires further review before implementation. In particular, I recommend reassessment of growth assumptions, greater transparency of financial modelling, stronger consideration of public health and environmental risks, prioritisation of maintenance and efficiency, and earlier, more meaningful community engagement.
2a. Do you support a growth pays for growth approach for new residential and commercial developments, including the use of growth charges to help fund growth-related infrastructure and services?
Partially support
Please provide comment.
I support the principle that growth should pay for growth, provided it is applied fairly, transparently, and based on sound evidence. However, I have concerns that the current approach does not clearly demonstrate that funds raised will be directly used for growth-related infrastructure, rather than contributing to broader costs such as corporate structures, consultants, or inefficiencies.
There is also insufficient evidence that past growth has failed to pay its way, and without consistent modelling and clear justification, the introduction of additional growth charges risks being arbitrary and inequitable. Furthermore, given that growth projections have been significantly overstated in the past, there is a real risk of over-investment in infrastructure based on outdated assumptions.
Any growth funding approach must be affordable, accurately reflect actual demand, and incorporate modern, efficient solutions rather than relying on outdated methodologies. Without this, there is a risk that costs will ultimately be passed on to ratepayers or future generations, undermining the intent of a “growth pays for growth” framework.
2b. In the current residential growth charges proposal secondary minor dwellings (i.e. granny flats) may be treated as ½ HUE. Do you support treating secondary minor dwellings as ½ HUE? If you have an alternative proposal, please explain.
Partially support
Please explain.
This approach should be applied consistently and fairly, recognising the important role these dwellings play in supporting elderly family members, extended families, and more efficient use of existing housing. Care should be taken to ensure that charging structures do not unintentionally discourage these living arrangements.
More broadly, any charging model should be based on actual usage and demand, be transparent, and ensure affordability for households, rather than applying a one-size-fits-all approach.
3. How would you prefer IAWAI engage you?
Letter / Flyer, E-newsletter, Focus groups
4. Do you support IAWAI’s Significance and Engagement Policy?
No
5. Do you have any feedback on the Significance and Engagement Policy?
The Significance and Engagement Policy does not appear to deliver genuine early engagement, as the community is often informed after key decisions have already been made. In practice, this feels more like consultation on pre-determined outcomes rather than meaningful participation in shaping decisions. This approach reduces transparency, limits community influence, and undermines trust. The policy should require earlier, more open engagement with clear options presented so the community can genuinely contribute to decision-making.
6. Do you support IAWAI'S Waiver Policy?
No
7. Do you have any feedback on the the Waiver Policy?
The proposed waiver policy lacks transparency and clear criteria, creating a risk that decisions will be made inconsistently and without public accountability. Without identifying how waived costs will be funded, the policy effectively shifts the financial burden onto existing ratepayers and future generations. This undermines the principle that growth should pay for growth and requires stronger safeguards, transparency, and clear limits.
Are you giving feedback on behalf of an organisation?
No, these are my own personal views
I live:
Elsewhere in New Zealand
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