Submission details
| Submission ID | 10451 |
|---|---|
| Name | Alison Porter |
| Date | 12 April 2026 |
| 1. Do you have any feedback on the IAWAI Water Services Strategy? |
While I acknowledge the importance of sustained investment in water infrastructure, I have significant concerns that the IAWAI Water Services Strategy does not adequately demonstrate a robust evidence based, transparent, future proof model.
I am concerned that the strategy appears to largely utilise previous planning approaches rather than being developed from first principles thinking. This is particularly concerning in light of clear evidence that population and growth projections have been materially overestimated. As an example, approximately 237 CBD residential units have been delivered over the past decade, compared with projections of around 4,000 units. If we continue to plan major infrastructure investment based on such assumptions we risk overbuilding capacity resulting in an unnecessary and enduring debt burden on the community. Potential public health and environmental implications are also of significant concern to me. The proposed or ongoing discharge of treated wastewater into the Waikato River, located approximately 4 km upstream of drinking water intake points, presents a level of risk that does not appear to have been adequately addressed. This concern is heightened by well-established limitations of current wastewater treatment technologies in removing pharmaceuticals, hormones, and other emerging micro-contaminants. These factors raise legitimate questions about cumulative long-term effects, as well as the credibility of assurances regarding river health and the safety of food gathering. The strategy relies heavily on debt financing and proposes additional growth-related charges without providing clear evidence that historical growth has failed to fund its associated infrastructure costs. There also seem to be inconsistencies in development contribution policies, along with the potential use of discretionary waivers. These factors create a risk that costs will be unevenly allocated and ultimately transferred to existing ratepayers. The strategy seems to prioritise large-scale capital investment ahead of optimising existing assets. Available evidence indicates that less than one percent of treated water is used for potable purposes, while significant volumes are consumed for non-essential uses and around 14 percent is lost through leakage and inefficiencies. There is a lack of evidence to indicate that alternative options have been fully explored prior to committing to major new infrastructure. These should include strategies to manage demand, improved maintenance, and alternative supply options including gathering of rainwater may not The strategy does not appear to fully have taken into account factors that will have direct implications on project affordability, and the ability to deliver an outcome that provides value for money. The current environment has multiple risk factors including economic pressures, interest rate volatility, and global supply chain uncertainty, these do not appear to have been considered and should be more explicitly identified and planned for within the strategy I also have concerns regarding governance, transparency, and community engagement. Public consultation appears not to have occurred early enough to be given meaningful consideration in key decisions, which seem largely settled prior to consultation. This approach risks undermining public trust and prevents the community from having genuine, informed input. It is my opinion that the strategy requires further review before implementation. I would specifically recommend reassessment of growth assumptions, greater transparency of financial modelling, stronger consideration of public health and environmental risks, prioritisation of maintenance and efficiency. |
| 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 generally support the principle that growth should pay for growth, including the use of charges on new residential and commercial developments to fund infrastructure and services that are directly required as a result of that growth. In principle, this is a fair and logical approach, provided it is applied transparently, consistently, and on the basis of robust evidence.
I do however have reservations about how this approach is currently proposed. It is not clear enough that growth charges will be for genuinely growth-related infrastructure, rather than contributing to broader organisational costs such as overheads, consultants, or inefficiencies within the system. This needs to be clearly noted so that confidence in the fairness of the approach is not undermined. I am also concerned that there is limited evidence demonstrating that historical growth has failed to fund the infrastructure it required. In the absence of clear, consistent modelling and justification, the introduction of additional growth charges risks appearing arbitrary and may result in inequitable outcomes. Given that growth projections have been overstated in the past, there is a risk that growth charges could be used to support over-investment in infrastructure that does not reflect actual demand. For a “growth pays for growth” framework to be credible, it must be affordable, match real growth pressures, and be supported by transparent financial modelling. It should also focus on modern, efficient solutions rather than relying on outdated options. Without these safeguards, there is a genuine risk that costs will ultimately be shifted to existing ratepayers or future generations. |
| 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. |
I partially support treating secondary minor dwellings (such as granny flats) as ½ HUE, provided this approach is applied consistently, fairly, and reflects the actual demand these dwellings place on infrastructure.
Minor dwellings play an important role in supporting older family members, extended families, and more efficient use of existing housing. They often accommodate fewer occupants and typically place lower demands on infrastructure than a full additional dwelling. Charging structures should recognise this and avoid unintentionally discouraging these types of housing arrangements, which can deliver broader social and housing benefits. I believe that any growth charging model should be based on actual usage and demand, it should be transparent and evidence-based, and be affordable for households. We risk creating inequitable outcomes and undermining sensible housing options if we have a one size fits all model. |
| 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? |
I feel the Significance and Engagement Policy lacks genuine early engagement, and that the community is often informed after key decisions have already been made. It is hard not to feel like this is consultation on pre-determined outcomes rather than a genuine attempt to get community participation in shaping decisions. I feel as thought there is a lack of transparency, and a reduced opportunity for genuine community influence. My trust in the process has been reduced. I believe the policy should require earlier, more open engagement with clear options presented so our community can genuinely contribute to decision-making.
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| 6. Do you support IAWAI'S Waiver Policy? |
No
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| 7. Do you have any feedback on the the Waiver Policy? |
As it stands the proposed waiver policy appears vague, lacks transparency and clear criteria, there is a risk that decisions will be made inconsistently and without public accountability. How will waived costs be funded? Such a policy has potential to shift the financial burden onto existing ratepayers and future generations. This threatens the notion that growth should pay for growth. I would like to see stronger safeguards, transparency, and clear limits.
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| Are you giving feedback on behalf of an organisation? |
No, these are my own personal views
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| I live: |
Waipa District
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