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Submission details

Submission ID 10465
Name Andrea Brough
Date 12 April 2026
1. Do you have any feedback on the IAWAI Water Services Strategy?
The need to invest in resilient water infrastructure is clear. What is not clear is how the current IAWAI Water Services Strategy delivers on that need in a way that is responsible, transparent, or aligned with the realities facing our communities. As it stands, the strategy raises significant concerns about accuracy, affordability, environmental protection, and democratic accountability.
A fundamental issue is that the strategy appears to rely on outdated assumptions rather than a fresh, evidence-driven assessment of what the city actually needs. Growth projections have repeatedly failed to materialise—only around 237 CBD residential units have been delivered in the past decade, compared with forecasts of roughly 4,000. Continuing to plan multi-billion-dollar infrastructure on the basis of projections that have proven unreliable is not responsible governance. It risks locking ratepayers into oversized assets, unnecessary debt, and long-term financial commitments that could have been avoided with more rigorous analysis.
Public health and environmental protection must also be treated as non-negotiable. The continued discharge of treated wastewater into the Waikato River—just 4 km upstream of drinking water intake points—poses a level of risk that cannot be brushed aside. Current treatment systems are not capable of reliably removing pharmaceuticals, hormones, and other micro-contaminants. Without clear evidence on cumulative impacts, it is difficult to accept assurances that the river will remain safe for recreation, food gathering, or long-term ecological health. Communities deserve a strategy that prioritises precaution, not one that minimises risk.
Financially, the strategy leans heavily on debt while introducing new growth charges without demonstrating that past growth has failed to pay its way. Inconsistencies in development contribution policies, and the ability for discretionary waivers, create a real risk that costs will be shifted onto existing ratepayers. Ratepayers should not be expected to subsidise growth or absorb the consequences of poor forecasting.
Equally concerning is the strategy’s emphasis on large capital projects over smarter, more efficient use of existing infrastructure. Less than 1% of treated water is used for drinking, significant volumes are used for non-essential purposes, and around 14% is lost through leakage. These figures show that demand management, maintenance, and alternative supply options—such as rainwater harvesting—have not been meaningfully prioritised. Before committing to major new builds, the community should see a clear plan for reducing waste, improving efficiency, and maximising the value of what we already have.
The broader risk environment also appears to be under-acknowledged. Economic pressures, interest rate volatility, and global supply chain constraints all have direct implications for affordability and deliverability. A credible long-term strategy must confront these realities head-on, not treat them as peripheral.
Finally, the process itself has not met the standard of transparency or community partnership that a strategy of this scale demands. Key decisions appear to have been shaped before public engagement began, leaving communities feeling sidelined rather than included. Genuine engagement requires early involvement, open information, and a willingness to adapt based on community input—not consultation after the fact.
Conclusion
For these reasons, the strategy requires substantial revision before it can be considered fit for adoption. A responsible path forward must include a full reassessment of growth assumptions, transparent financial modelling, stronger safeguards for public health and the environment, a clear commitment to optimising existing infrastructure, and meaningful community involvement from the outset. Communities deserve a strategy that is credible, future-ready, and grounded in evidence—not one that asks them to shoulder unnecessary risk.
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 idea that growth should fund the infrastructure it requires, but this must be done transparently and based on solid evidence. The current approach does not clearly show that the money collected will be dedicated to genuine growth-related projects rather than absorbed into wider organisational costs.
There is also no convincing evidence that past growth has failed to pay its way. Without reliable modelling and clear justification, introducing additional charges risks being unfair and based on outdated assumptions—especially given that previous growth forecasts have been significantly overstated.
A credible growth-funding model must reflect real demand, remain affordable, and use modern, efficient planning methods. Without this, the financial burden is likely to fall back on existing ratepayers or future generations, undermining the very principle that growth should pay for growth.
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 needs to be applied in a fair and consistent way, recognising the important contribution these types of dwellings make to supporting older relatives, multigenerational households, and more efficient use of existing homes. It is essential that any charging framework does not unintentionally discourage these living arrangements or create barriers for families who rely on them.
More broadly, any charging system should be grounded in actual patterns of use and demand, be transparent in how costs are determined, and remain affordable for households. A blanket, one-size-fits-all model risks inequity and does not reflect the diverse ways people live or the varied impacts different households have on infrastructure.
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 current Significance and Engagement Policy does not appear to support genuine early engagement. Too often, the community is approached only after key directions have already been set, leaving little room to influence the outcome in any meaningful way. This creates the impression that consultation is being used to validate decisions rather than shape them.
Such an approach weakens transparency, limits the community’s ability to contribute, and erodes public trust. A credible engagement policy must require decision-makers to involve the community at the point where options are still open, information is shared honestly, and alternative pathways can be considered. Without this, engagement becomes a procedural formality rather than a genuine partnership.
To restore confidence, the policy needs to mandate earlier involvement, clearer presentation of options, and a commitment to listening before decisions are effectively locked in.
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 the transparency and clear criteria needed to ensure fair and consistent decisions. Without a defined process or explanation of how waived contributions will be funded, the financial burden is effectively shifted onto existing ratepayers and future communities. This directly weakens the principle that growth should fund the infrastructure it requires. Stronger limits, clearer rules, and full public accountability are essential to prevent misuse and protect ratepayers.
Are you giving feedback on behalf of an organisation?
No, these are my own personal views
I live:
Waipa District
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