IAWAI Water Services Strategy

Bridge Housing Charitable Trust supports the overall intent of the Strategy, particularly the focus on long-term infrastructure planning, financial sustainability, and ensuring that growth is funded in a fairer way.
We acknowledge the significant investment required to address growth, ageing infrastructure, and environmental standards, and we agree that relying solely on existing ratepayers is not sustainable.
However, we have a key concern regarding the application of proposed growth charges to Community Housing Providers (CHPs) and charitable trusts delivering affordable housing.
The Strategy does not adequately distinguish between commercial or speculative development, and not-for-profit affordable housing delivery responding to existing community need.
Without this distinction, the proposed approach risks unintentionally reducing the supply of affordable housing, which is inconsistent with local and national housing objectives.
We recommend that the Strategy explicitly recognise the role of CHPs and include provisions to waive or significantly reduce growth charges for affordable housing developments held long-term by registered CHPs or charitable trusts.

Partially support

Bridge Housing supports the principle of “growth pays for growth” in general, particularly for market-led residential development and commercial and industrial development.
However, we do not support applying this approach uniformly to affordable housing delivered by CHPs and charitable housing trusts.
Community housing differs fundamentally from private development. It is not-for-profit and reinvests surpluses into housing supply. It addresses existing unmet demand, not discretionary growth and it is often delivered in partnership with government funding and policy objectives
The proposed charge of $500 per dwelling per year for 25 years creates a material financial burden on affordable developments, given that rents are generally capped or set below market levels and projects are often marginal in feasibility.
This cost could directly result in fewer homes being delivered, or reduced affordability outcomes.
There is also a policy misalignment, where government and councils are investing to increase affordable housing supply, while the proposed charges introduce new long-term costs on the same developments.
We note the Strategy already contemplates waivers or adjustments for papakainga housing, and we submit that affordable housing delivered by CHPs and charitable trusts warrants equivalent consideration.
Our submission is that IAWAI should fully waive growth charges for registered CHPs and charitable trusts providing long-term affordable rental or leasehold housing.

Partially support

We support recognising that smaller dwellings generate lower infrastructure demand, and therefore support the principle of reduced charging (½ HUE) for minor dwellings.
However, this does not go far enough for affordable housing.
For CHPs and charitable providers, minor dwellings are often used as affordable housing solutions, including for older persons, smaller households and transitional or supported housing.
Even at ½ HUE, applying ongoing annual charges creates a cumulative cost burden that can undermine delivery.
Recommendation:
Retain the ½ HUE approach as a baseline, but introduce a full waiver for minor dwellings delivered as part of CHP-led affordable housing developments and developments that meet defined affordability criteria.
This would better align pricing with actual demand on infrastructure, and the broader social benefit of affordable housing provision.

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Bridge Housing Charitable Trust