Submission details
| Submission ID | 9962 |
|---|---|
| Name | Scott Alison |
| Date | 6 April 2026 |
| 1. Do you have any feedback on the IAWAI Water Services Strategy? |
Yes get rid of it for the following reasons:
• Creation of a new bureaucratic layer: The establishment of IAWAI as a Council-Controlled Organisation introduces an additional board, executive team, dedicated policies, and new staff roles (including a Maori Partnerships, Communications & Engagement Executive). This adds setup, integration, and governance costs that are not fully quantified, instead of streamlining delivery through existing council structures or competitive tendering. • High capital expenditure and reliance on debt: The strategy commits approximately $3 billion in capital investment over 10 years, funded in part by substantial new debt (projected to reach $3.5 billion by 2036). This spreads long-term liabilities across generations of ratepayers rather than requiring current users or developers to bear appropriate upfront costs for assets with extended lifespans. • Increased charges for residents and developers: Median residential water charges are forecast to rise significantly (for example, in Hamilton from approximately $940 in 2026 to higher levels by 2030). New annual growth charges of $200 per Household Unit Equivalent for water supply and $300 for wastewater will apply for 25 years on new connections from 1 July 2026, increasing costs passed on to homebuyers and businesses. • Compliance with central government mandates: The CCO structure, standardised charging regimes, and many upgrades are driven by national legislation and regulatory oversight from Taumata Arowai and the Commerce Commission. This limits local autonomy in prioritising and timing investments according to local needs. • Undemocratic prioritisation of Maori partnerships: The strategy repeatedly commits to “full partnership” with Waikato-Tainui, embedding Te Tiriti o Waitangi principles, Treaty settlements, and the Waikato River Vision and Strategy (Te Ture Whaimana o Te Awa o Waikato) as core objectives. This includes requirements to protect “mauri,” avoid impacts on kai moana, and incorporate tikanga Maori into planning and discharge decisions. Such provisions elevate the interests of one ethnic group through co-governance-style arrangements, diluting equal democratic accountability to all ratepayers and residents who fund the services. • Limited emphasis on genuine market efficiencies: Although modest operational savings (2.5% from 2028/29) and some private partnerships are referenced, the model retains full public ownership and monopoly delivery. There is no clear pathway to competitive tendering, asset sales, or broader private-sector involvement to drive down costs. • Transparency and accountability concerns: The documents provide incomplete disclosure of merger/setup costs, limited long-term charge forecasts beyond 2029 in places, and no comprehensive comparison against a baseline without the IAWAI entity. Performance metrics focus primarily on regulatory compliance rather than minimising burdens on ratepayers, with oversight distanced from direct electoral control. |
| 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? |
Yes
|
| Please provide comment. |
Yes, I support a growth-pays-for-growth approach for new residential and commercial developments, including the use of targeted growth charges to fund the additional infrastructure and services required by that growth.
This principle is sound because it ensures that those who create the additional demand on water services bear a fair share of the incremental costs, rather than subsidising new development through higher charges or debt imposed on existing ratepayers. It promotes more efficient land-use decisions and helps contain the overall financial burden on the community. However, this objective does not require the creation of the new IAWAI Council-Controlled Organisation. The existing building consent and resource consent processes already provide an effective and established mechanism for imposing development contributions or targeted growth charges on new subdivisions and developments. These processes operate under current council structures with direct accountability to elected representatives and ratepayers. Utilising them would achieve the same cost-recovery goal without the additional bureaucratic layer, governance overheads, and integration costs associated with establishing and operating a separate water entity. |
| 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. |
No
|
| Please explain. |
No, I do not support treating secondary minor dwellings (such as granny flats) as ½ Household Unit Equivalent (HUE) in the residential growth charges proposal.
Treating secondary dwellings as half a unit creates an arbitrary discount that subsidises additional development on the same property at the expense of other ratepayers and new standalone developments. This undermines the growth-pays-for-growth principle by shifting a portion of the incremental infrastructure costs (water supply and wastewater demand) onto the broader community through higher general charges or increased debt. A consistent and fair approach requires that each independent dwelling unit—whether a primary residence or a secondary minor dwelling—be charged as one full HUE. This ensures that all new residential capacity on a property pays its proportionate share of the growth-related infrastructure it necessitates, without cross-subsidisation. The existing building consent and resource consent processes already provide an effective mechanism to apply and collect such charges accurately and transparently on a per-dwelling basis. There is no need for the new IAWAI entity to administer differentiated or discounted rates; the current council structures can handle this efficiently with direct accountability to ratepayers. |
| 3. How would you prefer IAWAI engage you? |
Website, Social media, E-newsletter
|
| 4. Do you support IAWAI’s Significance and Engagement Policy? |
No
|
| 5. Do you have any feedback on the Significance and Engagement Policy? |
No, I do not support IAWAI’s Significance and Engagement Policy.
The policy mandates ongoing, dedicated consultation with iwi, hapu, and other Maori organisations, including marae forums, joint management agreement hui, and case-by-case engagement based on impacts to mana whenua and cultural values. This creates a permanent layer of additional administrative processes and costs that will ultimately be borne by all ratepayers through higher water charges and operational expenses. Such provisions are undemocratic. They embed differential treatment by prioritising the interests of one ethnic group through co-governance-style arrangements, diluting equal accountability to all residents and ratepayers who fund the services. These engagement functions can be managed efficiently under the existing Significance and Engagement Policies of Hamilton City Council and Waikato District Council, using established consent and decision-making processes. There is no need for this new bureaucratic policy or the intermediary IAWAI entity. |
| 6. Do you support IAWAI'S Waiver Policy? |
No
|
| 7. Do you have any feedback on the the Waiver Policy? |
No, I do not support IAWAI’s Waiver Policy.
This policy, required under central government legislation, establishes discretionary processes for waiving water charges and penalties. It allows selective relief in various situations, including potential discounts or waivers for papakainga housing through negotiation. Such provisions introduce subjective decision-making and differential treatment, increasing administrative costs for assessing and processing waiver applications. These ongoing costs will ultimately be passed on to all ratepayers through higher water charges. The policy is undemocratic. It enables preferential treatment for specific groups, particularly Maori developments, eroding equal accountability and fairness for all residents who fund the services. These waiver functions can be managed efficiently under the existing rates remission policies of Hamilton City Council and Waikato District Council, using established processes. There is no need for this additional bureaucratic policy or the new IAWAI entity. |
| Are you giving feedback on behalf of an organisation? |
No, these are my own personal views
|