Submission details
| Submission ID | 10466 |
|---|---|
| Name | Simon Brough |
| Date | 12 April 2026 |
| 1. Do you have any feedback on the IAWAI Water Services Strategy? |
The need for resilient water infrastructure is obvious, but the current IAWAI Water Services Strategy does not show how this will be delivered in a transparent, responsible, or community-aligned way. The strategy relies on outdated growth assumptions—only 237 CBD units built in a decade versus forecasts of 4,000—yet still proposes multi-billion-dollar investments. This risks locking ratepayers into oversized assets and unnecessary debt.
Public health and environmental risks are also downplayed. Discharging treated wastewater just 4 km upstream of drinking water intakes, despite treatment systems that cannot remove pharmaceuticals and other micro-contaminants, is not a precautionary approach. Financially, the strategy leans heavily on debt and inconsistent development contributions, creating a real risk that costs will fall on existing ratepayers. At the same time, it prioritises major capital projects over fixing leaks, reducing waste, and improving efficiency—despite 14% water loss and minimal focus on demand management. The wider economic and supply-chain risks are barely acknowledged, and the engagement process has not met the standard expected for decisions of this scale. Communities were brought in too late, after key directions were already set. Conclusion The strategy needs substantial revision. Growth assumptions must be reassessed, financial modelling made transparent, environmental and public health protections strengthened, existing infrastructure optimised first, and community engagement brought in early and meaningfully. Communities deserve a credible, future-ready plan—not one that shifts unnecessary risk onto them. |
| 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 fund the infrastructure it requires, but this only works when the system is transparent, evidence-based, and genuinely fair. At the moment, it’s not clear that the money collected will actually be directed to growth-related infrastructure rather than absorbed into wider organisational costs.
There is also no strong evidence that past growth hasn’t paid its way. Without reliable modelling and clear justification, introducing new charges risks being unfair and based on outdated assumptions—especially given how significantly growth forecasts have been overstated in the past. A credible growth-funding model needs to reflect real demand, remain affordable, and use modern, efficient planning approaches. Without this, the financial burden is likely to fall back on existing ratepayers or future generations, undermining the very idea 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
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| 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 support genuine early engagement. The community is often brought in only after key decisions have already been shaped, leaving little real opportunity to influence outcomes. This makes consultation feel more like confirmation of predetermined decisions than meaningful participation.
This approach weakens transparency, limits community input, and erodes trust. A credible policy must require engagement to happen early—when options are still open, information is honest, and different pathways can genuinely be considered. To rebuild confidence, the policy needs clearer expectations for early involvement, transparent presentation of options, and a genuine commitment to listening before decisions are effectively locked in. |
| 6. Do you support IAWAI'S Waiver Policy? |
No
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| 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, consistent decisions. Without a clear process or explanation of how waived contributions will be funded, the cost is likely to fall back on existing ratepayers and future communities. This undermines the core principle that growth should fund the infrastructure it requires. Stronger limits, clearer rules, and genuine public accountability are essential to prevent misuse and protect ratepayers.
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| Are you giving feedback on behalf of an organisation? |
No, these are my own personal views
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