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Submission details

Submission ID 9004
Name Imteaz Bhuiyan
Date 22 March 2026
1. Do you have any feedback on the IAWAI Water Services Strategy?
The proposed shift toward a “growth pays for growth” model is directionally sound and aligns with principles of fairness, transparency, and long-term financial sustainability.
While I support the principle of growth contributing to growth, experience from Canadian municipalities such as Regina shows that a pure “growth pays for growth” model can face challenges. These include infrastructure timing mismatches, impacts on housing affordability, and limitations in fully recovering long-term system costs, particularly in lower-density or moderate-growth contexts.
A balanced, hybrid funding model is therefore more practical, where growth contributes significantly, but broader community funding supports system resilience and long-term sustainability.
In implementing this approach, I encourage IAWAI to ensure:
- Clarity and predictability in the charging framework over the 10-year horizon
- Benchmarking against other regions to maintain competitiveness and support housing supply
- Recognition that water infrastructure underpins public health, environmental outcomes, and climate resilience, which extend beyond growth alone
Overall, I support the direction, with careful implementation to avoid unintended impacts on affordability and development.
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.
While I support the principle that growth should contribute to the cost of growth-related infrastructure, a fully “growth pays for growth” approach may not always be practical or optimal.
Experience from Canadian municipalities such as Regina shows that relying entirely on growth funding can create challenges, including infrastructure timing mismatches, affordability impacts, and incomplete recovery of long-term system costs—particularly in moderate-growth or lower-density environments.
A hybrid approach is therefore more appropriate, where:
- Growth contributes a fair and significant share of incremental infrastructure costs
- Broader ratepayer or community funding supports system-wide assets, resilience, and long-term capacity
This balance helps maintain housing affordability, supports continued development, and ensures the sustainability of core water services over time.
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.
Yes,
Please explain.
Treating secondary minor dwellings as ½ HUE is a reasonable and pragmatic approach, as these dwellings typically place a lower demand on water infrastructure compared to a full standalone dwelling.
This approach also supports:
- Housing intensification and efficient land use
- More diverse and affordable housing options
- Incremental growth without disproportionately increasing infrastructure burden
It would be beneficial for IAWAI to monitor actual usage patterns over time to validate the ½ HUE assumption and ensure it remains aligned with real-world demand, while retaining flexibility to adjust if needed.
3. How would you prefer IAWAI engage you?
Website, E-newsletter, Surveys, Events (online or in person), Antenno app
4. Do you support IAWAI’s Significance and Engagement Policy?
Partially support
5. Do you have any feedback on the Significance and Engagement Policy?
The Significance and Engagement Policy is a critical framework for guiding how IAWAI determines the importance of decisions and the appropriate level of community engagement. I support its intent to provide clarity, consistency, and transparency in how engagement is approached across different types of decisions.
I particularly support the principle of aligning the level of engagement with the scale, impact, and significance of decisions, ensuring that more consequential matters receive more meaningful community input.
To strengthen the policy, I recommend the following:
- Clear and consistently applied significance criteria: The thresholds and criteria used to determine what constitutes a “significant” decision should be clearly defined and applied consistently to avoid ambiguity and improve public confidence in the process.
- Transparency in classification decisions: Where a decision is determined not to be significant, it would be beneficial to clearly communicate the rationale behind that classification to support trust and understanding.
- Proportional and meaningful engagement: Engagement approaches should not only reflect the significance of a decision but also consider long-term impacts on infrastructure, affordability, service levels, and intergenerational outcomes.
- Early engagement on strategic decisions: For long-term infrastructure strategies and funding models, early-stage engagement is important to ensure community perspectives are incorporated before key decisions are finalised.
- Accessibility and inclusiveness: A range of engagement methods should continue to be used to ensure broad participation across different segments of the community, including those who may not typically engage through formal consultation channels.
Overall, I support the policy’s direction, with emphasis on clarity, transparency, and meaningful engagement that supports well-informed and durable decision-making.
6. Do you support IAWAI'S Waiver Policy?
Partially support
7. Do you have any feedback on the the Waiver Policy?
The Waiver Policy is a useful and necessary mechanism to ensure fairness and flexibility in situations where standard charges may not be appropriate. I support the intent of providing targeted relief in exceptional circumstances, such as financial hardship, genuine billing errors, undetected leaks, or other legitimate cases where applying full charges would be unreasonable.
The policy appears to provide a structured and consistent framework for considering waiver applications, which is important for maintaining transparency and equitable treatment across different users.
However, I recommend the following considerations to strengthen the policy:
- Clear and consistent criteria: The conditions under which waivers are granted should be clearly defined to ensure consistent decision-making and avoid ambiguity.
- Transparency in application outcomes: Where waiver requests are declined, it would be beneficial to clearly communicate the rationale to applicants to support trust in the process.
- Equity and fairness: The policy should ensure that waivers are applied in a way that is fair across different user groups, while avoiding unintended incentives that may discourage responsible maintenance of properties or water systems.
- Link to asset condition and risk management: Where waivers relate to issues such as leaks or infrastructure condition, there should be a strong emphasis on addressing root causes, not just short-term financial relief, to support long-term system performance.
- Consistency with broader policy objectives: Waivers should be applied in a way that aligns with overall goals of financial sustainability, cost recovery, and maintaining reliable water services.
Overall, I support the policy’s direction, with emphasis on clarity, consistency, and fairness in its application.
Are you giving feedback on behalf of an organisation?
No, these are my own personal views
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