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Submission details

Submission ID 9915
Name Gus Tissink
Date 5 April 2026
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.
It is appropriate that new residential and commercial developments contribute to the cost of the additional infrastructure and services they create. Existing households should not be burdened with the capital costs associated with population growth.
However, this approach must be applied rigorously and transparently. In particular:
Growth charges should fully reflect the marginal cost of growth, including network capacity, treatment, and long-term infrastructure requirements
There should be clear separation between growth-driven investment and renewal/maintenance of existing assets
Existing ratepayers should be protected from cross-subsidising new development, particularly where infrastructure is delivered ahead of growth
The methodology for calculating growth charges should be publicly available and regularly reviewed
Consideration should also be given to one-off connection or installation fees for new developments to ensure that access to the network is appropriately priced at the point of entry.
Overall, I support the approach, provided it is implemented in a way that ensures fairness, transparency, and full cost recovery from 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.
I support the intent of treating secondary minor dwellings differently, but a flat ½ HUE approach is too simplistic.
Secondary dwellings (such as granny flats) generally have lower occupancy and therefore lower demand on water and wastewater infrastructure. Recognising this through a reduced charge is appropriate.
However, a fixed ½ HUE does not accurately reflect actual usage and risks being either under- or over-representative depending on occupancy and use.
Preferred approach:
In the short term, a reduced HUE (such as ½ HUE) is a reasonable proxy where better data is not available
Over time, this should transition toward a usage-based model enabled by metering, where charges more accurately reflect actual demand
Consideration could also be given to size-based or occupancy-based thresholds as an interim step
Key principle:
Charges should reflect actual demand on infrastructure, not just dwelling type.
So while I support the direction, I would encourage Council to view ½ HUE as an interim measure rather than a long-term solution, with a clear pathway toward more accurate, usage-based charging.
3. How would you prefer IAWAI engage you?
Website, Social media, Public signage, E-newsletter, Surveys, Hui, Marae forum, Events (online or in person)
4. Do you support IAWAI’s Significance and Engagement Policy?
No
5. Do you have any feedback on the Significance and Engagement Policy?
I do not support the policy in its current form.
A clear and structured engagement framework is important, particularly for an entity that will manage essential services and significant long-term investment. However, the Policy as drafted risks under-defining what is “significant,” which may limit meaningful public input on decisions with major financial and social consequences.
Key concerns and recommendations:
Definition of significance:
The criteria should be strengthened to ensure that decisions involving:
Long-term debt and capital programmes
Changes to pricing structures
Governance or service delivery models
Essential services (such as water)
are automatically treated as high significance, requiring enhanced consultation.
Essential services threshold:
Water is a critical public service. Decisions affecting water supply, pricing, or delivery should always trigger the highest level of engagement.
Transparency around non-consulted decisions:
The Policy should clearly state what types of decisions may not require consultation (e.g. procurement, partnerships, financial structuring), and require proactive public disclosure of those decisions.
Timing of engagement:
Engagement must occur early, when options are still open and public input can influence outcomes — not after key decisions are effectively locked in.
Demonstrating impact of submissions:
The Policy should require clear reporting on how feedback has influenced final decisions, including where feedback has not been adopted and why.
Overall position:
I support the intent of the Policy, but it should be strengthened to ensure that public engagement is meaningful, transparent, and proportionate to the scale of decisions being made.
6. Do you support IAWAI'S Waiver Policy?
Partially support
7. Do you have any feedback on the the Waiver Policy?
A waiver policy can play an important role in supporting hardship cases and enabling practical outcomes where strict application of charges may be unreasonable. However, any waivers ultimately shift cost elsewhere, so strong guardrails are required.
Key points and recommendations:
Targeted use only:
Waivers should be limited to clearly defined circumstances (e.g. genuine financial hardship, technical anomalies, or cases where charges are demonstrably inappropriate).
Avoid cost shifting to other users:
Any waived charges are effectively redistributed to other ratepayers or users. The Policy should ensure that waivers do not result in systematic cross-subsidisation.
Transparency and reporting:
There should be regular public reporting on:
Number of waivers granted
Total value of waived charges
Categories/reasons for waivers
Consistency and fairness:
Clear criteria should be applied consistently to avoid discretionary or uneven decision-making.
Alignment with pricing principles:
Waivers should not undermine the broader direction of user-pays and growth-pays-for-growth, except in clearly justified cases.
Overall position:
I support the use of waivers as a targeted and controlled tool, provided there is strong transparency, clear criteria, and safeguards to ensure fairness across all users.
Are you giving feedback on behalf of an organisation?
No, these are my own personal views
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