summary of submissions report final with appendix november 2021.pdf

Summary of local government feedback
on the three waters reform proposals

October 2021

About this report
1.
This report has been jointly prepared by the Department of Internal Affairs (the
Department), Local Government New Zealand (LGNZ), and Taituarā to summarise
feedback from the local government sector on the Government’s three waters
reform proposals that were released on 30 June 2021.
2.
This report collates and summarises written feedback submitted by individual
councils and groupings of councils into a comprehensive national picture.1 It has
also been informed by local government feedback gathered during engagements
undertaken by LGNZ, the Department and Taituarā during the eight-week
engagement period from 1 August 2021 to 1 October 2021.
3.
The report has also been informed by feedback received from individuals, iwi/hapū
and other community groups; however, this feedback has not been included in the
quantitative analysis.
4.
This report summarises and reflects formal submissions only. It does not include
responses to questions raised through the letters or submissions from councils, and
does not include any analysis of the suggested changes.
Purpose of the eight-week engagement period
5.
At the request of LGNZ, the Government set aside a period from 1 August 2021 to
1 October 2021 for local authorities to consider the impact of the reform proposals
on them and their communities, and to provide feedback on the proposed model.
6.
During this period, the Department also continued engaging with iwi/Māori and
industry stakeholder groups, as outlined in Appendix A.
7.
Local authorities were not asked to take any formal decisions regarding the reform
through this period. The purpose of this period was for all local authorities to:
(a)  “engage with and understand the large amount of information that has been
released on the nature of the challenges facing the sector, the case for change,
and the proposed package of reforms, including the recently announced support
package;


1 Individual council submissions are published on the Department of Internal Affairs’ Three Waters webpage.

Summary of local government feedback – October 2021  2

(b)  take advantage of the range of engagement opportunities to fully understand
the proposal and how it affects [your] local authority and [your] community; and
(c)
identify issues of local concern and provide feedback to LGNZ on what these are
and suggestions for how the proposal could be strengthened”.2


2 From LGNZ, DIA and Taituarā, Three Waters Guidance for Councils over the next eight weeks - 30 July 2021
Summary of local government feedback – October 2021  3

Executive summary
Overview of feedback
8.
Written feedback was received from all councils currently delivering three waters
services, except for the Chatham Islands Council and Waitomo District Council.
Written feedback was also received from the Greater Wellington Regional Council,
and the following groupings of councils: Entity B; Entity C; LGNZ Zone one; LGNZ
Zone six; the Canterbury Mayoral Forum; and Hawke’s Bay Mayors and Chair.
9.
Written feedback was received from a small number of individuals (including
elected members) and iwi representatives. This feedback has been welcomed and
considered by the Department, LGNZ and Taituarā, and has informed the content of
this report. However, given this report focuses on local government feedback, the
report does not include these submissions in the quantitative analysis.
10.  Many of the council submissions acknowledged there are challenges facing three
waters services across New Zealand. Twenty-seven submissions noted that the
status quo is unsustainable, and 39 submissions agreed that all New Zealanders
should have access to safe drinking water, and that three waters activities should
improve outcomes for the environment.
11.  While many acknowledged there is a case for change, about 75 per cent of the
submissions stated they did not support the proposed model put forward by the
Government.  A few councils noted their overall opposition to the reform.
12.  The engagement period and feedback process did not require councils to make a
decision on whether to opt in or opt out of the reforms. However, many councils
discussed this decision in their submission. While most councils noted they did not
convey a decision because they were not required to do so, or were silent on this
matter in their submissions, eight councils reported taking a decision to
provisionally opt out of the reforms.
13.  A small number of submissions noted that, based on current available information,
if they had to make a decision now, it would be to opt out of the reforms. This was
based on a view that neither councils nor the public were sufficiently informed
about the case for change, or because of questions or concerns about the
proposals.
Summary of local government feedback – October 2021  6

14.  While almost all submissions identified areas of concern and feedback on aspects of
the Government’s reform proposals, 47 submissions also welcomed the opportunity
to continue working with the Government on addressing these concerns and
feedback.
15.  Submissions contained a wide range of feedback, with key concerns and comments
including:
(a)  the governance model being complex, and not adequately providing for local
authority and mana whenua influence in decision making, on behalf of their
communities;
(b)  the loss of local voice in the system, especially given the large size of the
proposed entities;
(c)
how the water services entities will interact with, and be influenced by, local
government planning documents and decisions around growth and economic
development;
(d)  that more certainty is needed around the inclusion of stormwater in the reform
proposals, and how the entities will interact with, and work alongside, councils to
take an integrated approach to stormwater management, including how assets
with multiple uses will be treated;
(e)  that the limitations and assumptions used in the Water Industry Commission for
Scotland (WICS) modelling do not reflect the situations of individual councils
accurately enough;
(f)
that there has not been enough engagement and appropriate information to
date on the reforms, and there needs to be public consultation before decisions
on the next steps are made;
(g)
the three waters reforms should be better aligned with the resource
management reforms and the Future for Local Government review, to create the
best possible outcome for local government and communities.
16.  In addition to the above areas of feedback, a number of submissions stated support
for the establishment of Taumata Arowai, the new water services regulator, and for
stronger regulation in general of the water services sector.
Summary of local government feedback – October 2021  7

17.  Many councils also supported the proposal to create an economic regulator for the
water services sector, but considered there is not currently enough information on
the proposed form and functions of the regulator. Some submissions noted that the
economic regulator is a key part of the three water reforms, and therefore they do
not feel a decision to opt out should be made until more certainty on this element
of the system is provided to councils and the public.
18.  Given the above factors, many Entity D councils, and some other councils,
requested a pause in the reform programme.
Key themes raised in local government feedback
Case for change
19.  The majority of submissions supported the fundamental objectives of the proposed
reform, being to ensure all New Zealanders have affordable access to safe drinking
water and three waters services that improve environmental outcomes. Most
submissions also acknowledged there is a case for change, with three waters service
delivery reform needed across New Zealand. A few submissions remained silent on
this matter, and a small number of submissions were unconvinced by the case for
change and opposed the reform.
20.  While most submissions agreed on the need for change in general, many
submissions said the Government had not convincingly made the case for the
proposed solution. Most commonly, submissions cited concerns with the
assumptions and limitations of the WICS modelling, and felt the analysis was not
accurate enough to justify the model proposed. A few councils questioned whether
they would be better off under the reform scenario, as implied by the ‘council
dashboards’, and a small number of councils had commissioned their own review of
the modelling or undertaken their own analysis.
21.  Despite these concerns, the general consensus from the body of submissions was
that there are challenges with three waters service delivery that need to be
addressed, and change of some kind is needed. Forty-seven out of the 66
submissions from councils expressly stated they are willing to further discuss the
reform proposals, and will continue to work with central government to arrive at a
model that better addresses the concerns raised by the local government sector.
Summary of local government feedback – October 2021  8

Suggestions for alternative models
22.  Many council submissions expressed concern that the Government had not
sufficiently considered alternatives to the proposed model, and a few submissions
suggested alternatives and asked that these be considered and assessed further.
23.  For example, Auckland Council provided a detailed submission.  It requested that a
scenario be explored in which “the Crown provides some form of explicit financial
support to Watercare (either guaranteeing Watercare debt or providing a liquidity
facility) to help achieve greater levels of investment whilst maintaining a strong
credit rating and consequently a lower cost of borrowing.”
24.  The main suggestions in other submissions related to:
(a)  a regional entity model – particularly for Hawke’s Bay and for Taranaki;
(b)  a council-controlled organisation model;
(c)
a shared services model; and
(d)  consideration of the Tasmania Water or Scottish Water models.
25.  In addition to the above alternative reform models, some submissions suggested
alternatives to service delivery reform such as proceeding with regulatory reform
only, provision of further Government funding to help close the infrastructure
deficit without structural reform, or a funding model similar to that used for roading
(a ‘Waka Kotahi style model’).
Ownership, governance, and accountability
26.  Almost all submissions provided comments on this topic.  Many submitters
recognised that getting the governance structure right is a critical success factor,
but considered the current proposal needs further work. While there was support
for aspects of the proposed governance arrangements, there were also some
significant concerns about the approach and a number of submissions suggested
specific improvements.
Summary of local government feedback – October 2021  9

27.  A common theme across the submissions involved concern about the loss of
democratic accountability, and a loss of direct control and influence by councils
over infrastructure decision making and levels of service in their communities. The
proposed model was described by many submitters as overly complex and at risk of
not achieving the intended benefits and objectives. Many of the suggested
improvements related to reducing this complexity and/or providing strengthened
oversight mechanisms and opportunities for councils to hold the water services
entities to account.
28.  Statutory recognition of ownership was viewed as meaningless without associated
rights and accountabilities.  For example, Central Hawke’s Bay District Council
stated: “Council struggles to understand what benefit there is from ownership if
there is not a direct ability to influence the make-up of the Board of the entities and
the Statements of Strategic and Performance Expectations.”
29.  Concerns about the risk of future privatisation were highlighted in several
submissions, with the general view being that assets should remain in public
ownership, and that legislation should include strong protections against
privatisation.
30.  There was strong support for mana whenua involvement in the governance
arrangements, as well a few councils that expressed concerns about this aspect of
the reform proposals. These included equity-related concerns around iwi/hapū
participation across large geographical areas, and practical challenges associated
with identifying mana whenua representatives. Several areas for improvement
were suggested, particularly in submissions from iwi/Māori representatives.
Protecting and promoting community voice
31.  Many of the submissions expressed concern that the Government’s proposals do
not include adequate mechanisms for community voices to be heard – either
directly or via local authorities. There was a common view that local authorities are
best placed to engage with their communities and represent their views – meaning
there were close connections between this topic and submissions on the broader
theme of governance and accountability.
32.  Some submitters were sceptical that, given the scale of the entities, they will be
able to engage effectively with local communities. There were general concerns
that there will be less consultation and engagement than currently, less recourse if
services are poor, and a lack of accountability to communities.
Summary of local government feedback – October 2021  10

33.  There were particular concerns that community voices in districts will be lost, and
that the water services entities will not focus on or reflect local views when making
investment decisions or determining priorities and service standards. Submitters
noted a lack of clarity about how much ability communities would have to directly
influence entity decision making, and the process for engaging with entities.
34.  Submissions also made connections between community voice and the proposed
governance arrangements. Submitters suggested the ability to provide ‘local voice’
could be limited by the number seats available on the Regional Representative
Group and questioned how communities would have influence and ensure their
voices are heard if their council is not represented on this Group.
35.  Some submissions indicated that future legislation should recognise that local
government must have a role in community engagement and entity consultation
processes, to ensure community and consumer voices are heard and local priorities
are communicated to the water services entities.
Planning interface
36.  An area of critical interest to local government was the way the proposed entities
would interact with council planning and place-making. Many submissions noted
the strong links between planning for urban development and growth, and water
infrastructure provision, and the new water entities would have to work within the
resource management and local government planning frameworks. Others
discussed the uncertainties presented by the resource management reforms,
including a lack of clarity about what the future planning system would mean for
three waters service provision, and the role councils play in that system.
37.  Equitable distribution of resources for growth and urban development was a
concern raised in submissions. Many councils want assurance that the new entities
would give effect to current council long-term (and other associated) plans. Others
want assurance they would be able to direct the entities to deliver on the objectives
of future council plans, particularly where those plans relate to housing and
economic development.
Summary of local government feedback – October 2021  11

Resource management reform and Future for Local Government
38.  Submitters raised concerns about the pace and cumulative impact of several reform
programmes affecting councils, with three waters reform, resource management
reform, and the Future for Local Government Review happening concurrently. Some
suggested three waters reform should happen over a longer period, which would
give more time for communities to better understand the changes and allow the
impacts of other reforms to play out first.
39.  There was a strong desire among submitters for there to be better sequencing of,
and alignment between, the three major reform programmes currently underway,
and an expectation that central government agencies be better aligned in planning
and communicating the roadmap for these concurrent reforms.
40.  Many submitters requested that the Future for Local Government Review take
place ahead of the three waters reforms, while several other submitters suggested
the resource management reforms should take place first.
Charging and pricing
41.  Many submissions raised concerns about the uncertainty of the short-term pricing
and charging impacts following the reforms, noting the WICS analysis primarily
discussed average costs in 30 years’ time. Affordability and equity were two main
issues underpinning these concerns.
42.  Councils in areas with high deprivation were particularly concerned about
ratepayers’ ability to absorb higher costs, while acknowledging these would need to
rise with or without reform. Several submitters suggested households that receive
benefit payments should pay discounted charges, similar to rates relief offered by
councils or winter energy payments.
43.  Equity was another key issue. Some councils suggested there should be equal costs
for all households within an entity, while some larger councils expressed concerns
about cross-subsidisation of higher cost rural communities by urban ratepayers.
Some councils wanted clarity that areas could ringfence different charges for
communities that choose to receive a higher level of service.
44.  Several councils brought up the value of development contributions as a tool to
enable growth, and requested that this funding tool continue in use under the
proposed reforms.
Summary of local government feedback – October 2021  12

45.  Submitters also requested transparency around pricing and charging decisions
taken by the entities for their communities.
Number of water services entities and their boundaries
46.  Many submitters felt that the four entities were too large and compromised the
benefits of local voice and influence in the system. Thirteen councils signalled a
preference for regional models, stating that this level of aggregation strikes the
right balance between achieving some benefits from scale, while maintaining
community and council influence. Ten out of those 13 councils are located in the
Entity C grouping, in particular in Hawke’s Bay.
47.  A few councils located on or near the proposed entity boundaries also discussed
issues with the proposed divisions. Most commonly discussed was the Entity C/D
boundary, with mixed views about whether the whole of the South Island should be
included in one entity or not. A small number of submissions suggested that
conversations should continue with the councils and iwi in the affected areas, to
determine the best boundary line for those communities most affected.
48.  In addition, some practical questions were raised around the impact of the
boundary lines. For example, submitters in Entity A questioned whether they would
still be able to receive water from the Waikato River (which would be in Entity B),
and the potential impact on planning and resource management in Horizons
Regional Council was raised, given the proposed Entity B/C boundary splits the
region.
Regulatory environment
49.  Many submissions signalled support for the establishment of Taumata Arowai and
the new regulatory system introduced by the Water Services Act 2021. Some
councils noted that the establishment of Taumata Arowai by itself is expected to
result in a step change in performance across the sector, as drinking water and
wastewater standards are enforced. Submitters were generally supportive of this.
50.  Some submissions also supported the proposal for the establishment of an
economic regulator. However, a common concern was the lack of information
currently available regarding the form and function of the economic regulator,
given its importance in the new system. Some of the councils that requested a
pause in the reform programme stated that this would allow more time for further
clarity and certainty on the role of the two regulators.
Summary of local government feedback – October 2021  13

Rural supply arrangements
51.  Councils with large rural communities had specific concerns about how the reform
would affect rural areas. In particular, submitters noted reticulated water supply
was not appropriate in all areas of New Zealand, and this needed to be accounted
for in the reform.
52.  Submitters suggested communities should have the ability to buy-back council-
owned and operated rural schemes prior to the reforms being implemented, and
these schemes should be able to opt out of the reform.
53.  Rural councils also expressed concerns about the cost of the reform. Submitters
believed rural communities may not see the same benefits as urban communities,
and rural ratepayers were concerned they would bear the cost for services they
would not receive due to low connectivity to council networks.
Stormwater
54.  There were a wide range of responses on the proposal to transfer responsibility for
certain stormwater assets to the new water services entities.
55.  While only four submissions expressly signalled opposition to the proposed
approach, the majority of submissions that discussed stormwater noted a need for
further information and analysis. Common questions related to what specific assets
and functions would be transferred, and how the interface with other district and
regional council functions would be managed.
56.  Some submissions argued the decision on whether to transfer stormwater functions
and assets should sit with individual local authorities. Others drew attention to the
scale of the task associated with transferring drinking water and wastewater
services, suggesting stormwater could be dealt with in a subsequent phase instead
of transferring all three waters at once.
57.  There were also suggestions for how the transfer could work in practice, with many
submitters recommending that mechanisms and processes be introduced to clarify
roles and responsibilities, and enable effective and integrated working
arrangements between councils and entities.
Summary of local government feedback – October 2021  14

Transition considerations
58.  There was a wide range of feedback on transition-related matters that would need
to be addressed should the reforms proceed. These submissions reflected on the
scale and complexity of the reforms, and the associated transfer of three waters
assets, debts and liabilities.
59.  Common issues related to the mechanism for calculating and transferring debt
associated with three waters assets; the process for and approach to due diligence;
how local staff and contractors would be provided with certainty; and ensuring local
knowledge, expertise, systems and data are not lost through the transition.  Some
submissions raised questions around the feasibility of achieving the establishment
of the new water services entities by July 2024.
60.  A common challenge noted across multiple submissions was the need to find the
workforce, skills and technical capability required to support the transition period,
and fill governance and management positions for the new entities. Further detail
was also sought on the Government’s commitment to ensuring continued
employment of local staff, with some feedback commenting on the local
employment and career development opportunities created through reform,
including for iwi/Māori.
61.  Several submissions noted that a collaborative approach between the Government,
mana whenua and local authorities would be necessary to ensure a smooth
transition process and establishment of the new entities, and made suggestions for
how this could be undertaken.
Process and timeframes
62.  Concerns were raised across many submissions around the information and analysis
provided to date, including in relation to the public information campaign, the WICS
analysis and modelling, and the lack of information in relation to economic
regulation and outcomes for service levels and the environment.
63.  Several submissions sought clarity on the decision-making process, as well as the
ongoing engagement with the sector on the design and establishment of the water
services entities beyond the current period of engagement. Some local authorities
recommended that the Government should refine the modelling and analysis
further and provide councils with an opportunity to review the data.
Summary of local government feedback – October 2021  15

64.  A consistent theme in the submissions was concern about the pace and scale of the
reform programme. This included requests for more time for local authorities to
consider the three waters reform proposal alongside the other significant reform
programmes, and to consult their communities. Many submissions noted the
importance of community consultation prior to decisions being made, and sought
assurance about how and when this would occur.
65.  Concerns were also raised in relation to engagement with iwi/Māori, including the
need for more consistent engagement, and for iwi/Māori to be adequately
resourced to participate in the reform process.
Comments on other matters
66.  A common concern from a few councils was the need for the new system to take
more account of climate change, resilience and emergency management
considerations. A few councils provided specific suggestions for what the entities
should be required or encouraged to do, to ensure these considerations are
provided for within the policy design.
67.  Other concerns and suggestions included:
(a)  the risk of declining levels of service in communities that currently have relatively
high levels of service following transition, to match the average levels found
across the new entity;
(b)  the need for more information on how the reforms might impact certain
businesses (for example trade waste businesses);
(c)
the incorporation of the ‘four well-beings’ into the operational and decision-
making principles for the water services entities; and
(d)  the potential impact on current and future Treaty settlement arrangements.

Summary of local government feedback – October 2021  16

Introduction
Background
68.  The Three Waters Reform Programme began in mid-2020 following agreement at
the Prime Minister’s Central/Local Government Forum (between Cabinet Ministers
and LGNZ National Council) that council-owned three waters services were facing
urgent challenges, and central and local government should partner to progress
reforms. This agreement built on work undertaken as part of the Three Waters
Review from 2017-2020, led by the Minister of Local Government and Department
of Internal Affairs.
69.  This led to the establishment of the Joint Central and Local Government Steering
Committee to inform policy development and sector engagement in relation to the
Government’s reform proposals. The Government also committed $761 million to
stimulate investment in three waters infrastructure, as part of the COVID Response
and Recovery Fund.
70.  Following a series of sector workshops in July/August 2020, at which officials
provided an overview of the Reform Programme, policy direction and available
stimulus finding, all eligible councils across New Zealand entered into a
Memorandum of Understanding to engage on and further explore reform to service
delivery arrangements.
71.  The subsequent year saw extensive research, policy design, and sector and
iwi/Māori engagement, overseen by the Joint Steering Committee (supported by a
joint Department of Internal Affairs, LGNZ and Taituarā secretariat).
72.  During June 2021, the Department of Internal Affairs (the Department) published
the national evidence base on the case for change, and local dashboards pulling
information together (on a council-by-council basis) into one, nationally consistent
place.
Reform proposals
73.  On 30 June 2021, Cabinet released detailed decisions on the reform proposals.
These proposals are summarised here. They include the number and boundaries of
the entities, governance and accountability design features, and mechanisms to
protect and promote iwi/Māori rights and interests.
Summary of local government feedback – October 2021  17

74.  At the LGNZ National Conference in July 2021, the Government announced a $2.5
billion package to support local government transition through the reforms. This
package was provided for within the Heads of Agreement entered into between the
Government and LGNZ, under which both central and local government committed
to continuing to partner on three waters reform and related reforms.
Engagement period
75.  At the request of LGNZ, the Government agreed to an eight-week period from
1 August 2021 to 1 October 2021 for local authorities to consider the impact of the
reform proposals on them and their communities, and to provide feedback on the
proposed model, including suggestions for improvement.
76.  This report collates and summarises the feedback received from the local
government sector during this eight-week engagement period. This includes written
feedback submitted by individual councils and groups of councils. The individual
submissions are available on the Three Waters website alongside this report. Some
councils used standard submission templates, either by editing the exemplar report
provided by Taituarā, or through a shared submission with neighbouring councils.
77.  The report is also informed by local government feedback gathered during
engagement undertaken by LGNZ, the Department and Taituarā during the eight-
week period, as well as feedback received from individuals, iwi/hapū and
community groups.
78.  During this period, the Department continued to engage with iwi/Māori and
industry stakeholder groups. A full list of these engagements, including with local
government, is outlined in Appendix A.
Feedback on the case for change
Summary of feedback
79.  The majority of councils and submissions agreed that all New Zealanders should
have access to safe drinking water and that three waters activities should improve
environmental outcomes. Most submissions also acknowledged that reform of the
three waters sector is needed across New Zealand. A few submissions remained
silent on this matter, and a small number of submissions were unconvinced by the
case for change and therefore opposed the reform.
Summary of local government feedback – October 2021  18

80.  While many submissions agreed in general that there is a case for change, and
acknowledged that the status quo is not sustainable, they also noted that, in their
view, the Government had not successfully made the case for its proposed model.
For example, the Hawke’s Bay Mayors and Chair, in a letter to the Minister of Local
Government, noted that “…the status quo for the supply of three waters services is
not a viable model for our communities and there is a compelling case for change to
ensure ongoing safe, efficient and affordable drinking, waste and storm water
services. However, after comprehensive assessment of Government’s service
delivery proposal, a detailed comparison of the proposal against our own Hawke’s
Bay Three Waters Review and feedback from our communities, we have concluded
that our preference remains for a Hawke’s Bay regional option”.
81.  Similarly, a few councils considered that, while the case for change had been made
for many areas of New Zealand, it did not universally apply. Most notably, Auckland
Council said that Watercare had already achieved the size and scale benefits
proposed under the reform.
82.  Many submissions cited concerns with the assumptions and limitations in the Water
Industry Commission for Scotland (WICS) modelling, and believed the analysis was
not accurate enough to justify the proposed model. Councils considered the
analysis did not take into account their specific circumstances and were worried the
potential efficiency gains were overstated. A few councils questioned whether they
would be better off under the reform scenario, as the modelling presented in the
council dashboards suggested. For several councils, this was based on externally
commissioned reviews of the modelling, and for others this represented the
conclusion from their own analysis.
83.  A typical comment was along these lines: “When comparing our LTP to the
Department of Internal Affairs WICS data, we are concerned that the calculations
based on population, area and population density tested against experience and
observations in the United Kingdom are over-stated and unnecessarily inflate costs
at the local level.” (Ashburton District Council).
Summary of local government feedback – October 2021  19

84.  Another common concern was that the analysis relied too heavily on financial and
economic analysis when assessing the case for change and the viable options. For
example, Napier City Council stated: “The Central Government’s Three Waters
Reform bases its justification of scale on economic indicators and would be
enhanced by adopting a more holistic and contemporary view of efficient delivery.
Subsidiarity is essential for sustainable three waters service delivery and community
resilience”.
85.  A few of the submissions suggested that it was unclear why the Government, in
arriving at the current proposal, discounted other alternatives such as a Waka
Kotahi style funding model.
86.  Nearly all submissions expressly stated they were willing to further discuss the
reform proposals, and would like to continue to work with central government to
arrive at a model that better addresses the concerns raised by the local government
sector and iwi/Māori.
Sentiment by entity groupings
Entity A3
87.  Two out of the four councils in Entity A indicated they had provisionally opted out
of the reforms, with the remaining two not indicating a decision in their submission.
Two out of the four councils acknowledged that the status quo was unsustainable,
and all four councils expressed support for the core objectives of the reform.
88.  Common themes across the Entity A councils were concerns about prioritisation of
investment, due to the large differences in needs and environmental factors
between the councils, the need for further engagement by central government on
the reform, and the loss of democratic accountability in the proposed governance
model.


3 Entity A comprises the Auckland Council and territorial authority districts in the Northland region.
Summary of local government feedback – October 2021  20

Entity B4
89.  Twenty one out of the 22 councils in Entity B made a formal submission. Seven of
the Entity B councils who submitted acknowledged that the status quo is
unsustainable. Nine signalled support for the main objectives of the proposed
reform, while the remainder where silent on the matter. Only one council signalled
that they would opt out of the reforms when given the chance to do so. Fourteen
councils expressly signalled the desire for further engagement with central
government on these reforms.
90.  Key themes that emerged from the Entity B council submissions included: the
number of representatives in the Regional Representative Group being too few (six
seats for 21 councils); that council influence in the proposed model should be
strengthened; concerns about pricing differences between urban and rural areas;
and that many councils felt there has not been enough engagement from central
government.
Entity C5
91.  Out of the 22 councils in Entity C, one council (the Chatham Islands) did not send in
a formal submission. Nine councils acknowledged that the status quo is
unsustainable, and 13 councils supported the core objectives of the reform. Two
councils signalled their intention to opt out of the reforms, with the rest either not
mentioning this or stating that they have not taken a decision yet. Seventeen
councils signalled their willingness to engage further with central government on
the reforms, and the remaining councils did not mention this in their submission.
92.  Shared concerns mentioned in the submissions included that: the proposed
governance model is too complex; the engagement requirements are not strong
enough; there are risks of privatisation; and the pace of the reform is too fast.


4 Entity B comprises all districts from the Waikato, Bay of Plenty, and Taranaki regions, and the upper parts of
the Manawatū-Whanganui region (Ruapehu, Whanganui, and Rangitikei).
5 Entity C comprises the districts in the eastern and lower part of the North Island (Gisborne, Hawke’s Bay,
lower parts of the Manawatū-Whanganui, and Wellington regions); and the districts at the top of the South
Island (Tasman, Nelson, and Marlborough).

Summary of local government feedback – October 2021  21

Entity D6
93.  All 20 councils within the proposed Entity D made a formal submission. Nine
acknowledged the status quo is unsustainable and 13 supported the objectives of
the reform. Most of the councils either did not support the current proposed model
or stated they would like more information on it. Three councils signalled a
provisional decision to opt out of the reforms, and nine councils asked for the
reforms to be paused. Twelve councils stated they would like to further engage with
central government on these reforms.
94.  Some strong themes that were evident across the submissions from Entity D
included: concerns about the loss of democratic accountability and investment
prioritisation; the need for a better alignment between local government reforms;
and the need for further information for councils and the public. Mayors in Zone 6
and the Canterbury Mayoral Forum requested a pause in the reform programme, to
allow for more time to properly understand the reforms and the new regulatory
environment.
Changes suggested in feedback
95.  Feedback on the case for change primarily requested that alternative options to the
Government’s proposed model be considered. Some councils also requested a
review of the modelling and analysis on which the case for change was based. In
particular, councils would like to see further options analysis undertaken, including
considering alternative models suggested in the submitted feedback.
96.  The majority of councils suggested appropriate solutions could be found by
continuing and enhancing the Government’s approach to partnering with the local
government sector and iwi/Māori. Many councils would like to see further
engagement led by central government, and have signalled they would be
interested in working with government and iwi/Māori to create a better model.


6 Entity D comprises the districts in the remainder of the South Island, including those parts of the Marlborough
and Tasman Districts that comprise the Ngāi Tahu takiwā.
Summary of local government feedback – October 2021  22

97.  For example, Mackenzie District Council noted that it would like the Crown to “work
with local government to align its case for change regarding three waters delivery
and thoroughly examine a range of options from the status quo to the proposed four
entities, as well as several options between”.  Dunedin City Council stated that they
are “eager to work in partnership with the Government and iwi/Māori to achieve
these goals”.
Suggestions for alternative models
Summary of feedback
98.  Feedback on the Government’s proposals expressed a concern that the
Government had not sufficiently ruled out other alternatives to the current
proposals. The submissions included suggestions for other alternative models for
further consideration. The main suggestions are summarised below.
99.  In addition to other reform models, some submissions suggested alternatives to
aggregation of service delivery, such as proceeding with regulatory reform only; the
provision of further Government funding to help close the infrastructure deficit
without structural reform; or a funding model similar to that used for roading (a
‘Waka Kotahi style model’).
Changes suggested in feedback
100.  New Plymouth District Council suggested that the water services entities become
cooperatives, with non-transferable shareholding for each property connected to
drinking water or wastewater networks, and shareholders electing community
representatives on the Regional Representative Group (from a pool approved by
territorial authorities). This would be similar to the Fonterra model.
101.  South Taranaki District Council and Stratford District Council suggested a ‘Taranaki
Region Asset-Owning Entity’, which meets the outcomes of the three waters
reforms, but is focused on the Taranaki region. Their suggested model:
(a)  is a stand-alone asset-owning entity, with a separate identity and direct
relationship with customers (including direct billing for services);
(b)  has councils as shareholders (with proportions to be determined) and a
governance structure including council and non-council directors;
(c)
is able to borrow in its own right.
Summary of local government feedback – October 2021  23

102.  Auckland Council asked that a scenario be explored in which “the Crown provides
some form of explicit financial support to Watercare (either guaranteeing
Watercare debt or providing a liquidity facility) to help achieve greater levels of
investment whilst maintaining a strong credit rating and consequently a lower cost
of borrowing.”
103.  “This approach could see a model developed that includes potential shareholdings
for the Northland councils (proportionate to their asset value), and potentially a
shareholding or step-in rights for the Crown. The overall framework could then
retain the current council-controlled organisation arrangements and accountability
mechanisms, with appropriate modifications to reflect any additional shareholding
interests and mechanisms for iwi input. It would have sufficient scale to create
strategic capacity across the region and support the areas where that is currently
lacking. Importantly, the capacity and capability is shared across the region in an
ongoing and sustainable way.”
104.  “This option would also retain direct accountability to shareholders. Leaving to an
independent water services entity board the power to determine the price of water,
within the constraints set by the economic regulator, should provide comfort to the
credit rating agencies’ concern that there might be political interference in price
setting.”
105.  The other main suggestions, from across a range of submissions, were for:
(a)  a regional entity model for Hawke’s Bay;
(b)  a council-controlled organisation model;
(c)
a shared services model;
(d)  consideration of the Tasmania Water services model;
(e)  consideration of the Scottish Water model.
Ownership, governance, and accountability
Summary of feedback
106.  This topic was the most heavily discussed through submissions, with nearly every
submission providing comments on this topic in some form.
Summary of local government feedback – October 2021  24

107.  Many submitters recognised that getting the governance structure right is a critical
success factor, but felt that the current proposal needs further work. While there
was support for some aspects of the proposed governance arrangements, there
were also a range of concerns about the approach and a number of suggested
improvements.
108.  For example, Hamilton City council stated that “It is disappointing, and a missed
opportunity, that the proposals do not include alternative options on the key issues
of ownership and governance.”… “In the spirit of partnership, we have provided
feedback on improving the proposed governance structure as proposed”.
Ownership and protections against privatisation
109.  A common theme through this feedback was that it was difficult to see the benefits
of council ownership of the entities, if councils could not directly influence the
composition of the board nor the statement of strategic and performance
expectations.
110.  Some submissions viewed ownership by local authorities as meaningless without
associated rights and accountabilities. For example, Matamata-Piako District
Council noted that “the Council’s ownership is not demonstrated in any substantive
way in the proposed governance framework. Councils do not appear to have
influence or be able to hold to account the entity directors, as would be the case in a
traditional relationship of an owner or part owner of a company”.
111.  Concerns about privatisation were highlighted in a smaller number of submissions.
Common views were that assets should remain in public ownership, and any
legislation establishing the entities should include strong protections against
privatisation. Some submitters recognised that protections are already proposed,
but suggested further strengthening these – for example, by referring any
privatisation proposal back to the original asset owners (councils) for resolution.
Governance and accountability
112.  There were general concerns across many submissions about the perceived loss of
democratic accountability and loss of direct control and influence by councils, and
that the proposed model is overly complex and at risk of not achieving the intended
benefits and objectives. There were requests to explore other options that involve
fewer governance layers.
Summary of local government feedback – October 2021  25

113.  Specific concerns included:
(a)  the limited ability to hold the board to account for local decisions and actions;
(b)  that the Regional Governance Group would not provide effective oversight and
accountability, and that its ability to influence the board of the entities appeared
too far removed;
(c)
a loss of local representation to advocate for communities in the proposed
governance structure;
(d)  concerns from local boards in Auckland that there was not a role for them in the
proposed model;
(e)  that the proposed model will create confusion in communities regarding
councils’ roles, accountability, and ability to effect change;
(f)
that the entities will focus on financial performance, to the detriment of
environmental, social and cultural outcomes;
(g)
that the proposed model does not provide for strong connections between
infrastructure planning and spatial planning at regional and local levels.
114.  There were some contrasting viewpoints and concerns from metropolitan and rural
councils.  For example, larger, urban councils (such as Auckland and Christchurch)
suggested that the governance arrangements should reflect those councils’ relative
size and proportionate investment in assets. However, smaller, rural councils (such
as Far North, Kaikōura and Manawatū) were concerned that representation on the
Regional Representative Group has the potential to become urban-centric.
115.  Kaikōura District Council reflected a common concern of smaller councils, asking
“how can our small council have guaranteed influence over the direction of the
water services entity and how [can] our growth aspirations be considered within the
context of the wider entity?”  They commented that “we would be deluding
ourselves to imagine that a structure could be put in place to deliver services at a
multi-regional level that did not compromise localism”.
The role of mana whenua in governance arrangements
116.  There was strong support for mana whenua involvement in the governance
arrangements, as well as support for aspects of the proposals that relate to cultural
competency and expertise on entity boards, and the Te Mana o te Wai statement.
Summary of local government feedback – October 2021  26

117.  However, there were concerns, expressed by councils, about the mana whenua
forum approach, including:
(a)  equity-related concerns around iwi/hapū participation across large geographical
areas;
(b)  that the number of mana whenua representatives was not large enough;
(c)
challenges associated with finding a small number of representatives in areas
with a large number of hapū, iwi and Māori organisations;
(d)  that mana whenua and/or iwi/Māori will have limited influence and voice
through this model;
(e)  that some iwi/Māori may not feel properly represented by mana whenua; and
(f)
that entity responses to Te Mana o te Wai statements might not be meaningful.
118.  A very small number of submissions suggested that a ‘co-governance’ approach was
not appropriate, or that an equal number of council and mana whenua
representatives on the Regional Representative Group was not the right ratio.  For
example, Southland District Council noted that Entity D would cover 21 councils and
one iwi. Waipā District Council submitted that it does not agree that iwi/Māori
rights and interests should be achieved through “vesting 50 per cent control of
community assets, which have been funded by local communities over many
generations.”
119.  Several areas for improvement were suggested by submissions from iwi/Māori
representatives, including in relation to:
(a)  partnership arrangements;
(b)  the degree to which Iwi Mana Motuhake has been acknowledged;
(c)
the degree to which water is recognised as a taonga;
(d)  the degree to which the reforms protect Treaty settlements and initiatives;
(e)  ongoing provision for significant resourcing to help ensure the proposed model is
workable.
120.  The Auckland Council Independent Statutory Māori Board recommended that
timeframes for water services entities to respond to Te Mana o te Wai statements
should be agreed between mana whenua and the entity.

Summary of local government feedback – October 2021  27

Changes suggested in feedback
121.  Several submissions expressed support for a model that uses the same
accountability mechanisms as council-controlled organisations.  This would include,
for example, the ability to approve and modify statements of intent, and directly
appoint and remove directors.
122.  Auckland Council specifically expressed that water services entities should have the
same accountability mechanisms as provided under the Local Government Act
2002. They supported a water services entity model, like the CCO Watercare model,
where real ownership continues to reside with Councils and where the water
services entity is required as Watercare currently is, to give effect to the relevant
aspects of Councils’ long-term plans and growth strategies. Further, Auckland
Council expressed that Aucklanders should, through their elected representatives,
maintain majority control over their assets and service delivery.
123.  Kaipara District Council – which would be in the same proposed entity as Auckland –
requested an enduring seat on the Regional Representative Group for Entity A.
They proposed the Group be comprised of three seats for Auckland Council, and
one seat each for the Far North, Whangarei, and Kaipara Districts.
124.  Christchurch City Council suggested that, if the reforms proceed, the Regional
Representative Group should reflect the proportional investment and service
requirements of councils. This would include:
(a)  guaranteeing that the largest metropolitan council in each entity is a member of
the Regional Representative Group;
(b)  using a proportional voting system at Regional Representative Group meetings;
(c)
providing a clear process for rotating representatives.
125.  Hamilton City Council suggested including a schedule to the legislation that defines
the process by which councils would come together to make decisions about their
representatives on the Regional Representative Group, and subsequently hear from
those representatives. This process could include creating a permanent joint
committee, with a single representative for each council and voting based on
population.
Summary of local government feedback – October 2021  28

126.  On a similar theme, Hauraki District Council noted that it will be essential for
councils to have regular, effective communication with the local authority
representatives on the Regional Representative Group, and for people with sub-
regional knowledge to be members. They suggested setting up sub-regional areas
for each entity, from which these representatives would be chosen.
127.  Rotorua District Council suggested the early development of agreements (a ‘three
waters strategy’) between councils, mana whenua, and the entities setting out how
they will work together to ensure communities receive the outcomes they need.
This process would involve each entity working with the relevant councils on a
business plan that articulates the methodology by which the outcomes and
objectives of the agreed three waters strategy will be pursued, and then regular
reports on progress against the business plan. There would be a partnership-based
approach, recognising that the entity would hold the technical expertise, while
councils and iwi have greater knowledge of local needs and values.
128.  Other suggestions made in submissions included:
(a)  increase the size of the Regional Representative Group, so all territorial
authorities are represented – or, alternatively, introduce a ‘shareholder council’
model in which all councils have a seat (with a corresponding number of mana
whenua representatives);
(b)  remove the Independent Selection Panel from the proposed governance model,
so the Regional Representative Group establishes/appoints boards directly – or,
alternatively, enable that Group to approve appointments and remuneration
policies, and require the Independent Selection Panel to include members with
local government knowledge and experience;
(c)
make the Independent Selection Panel an advisory board to or sub-group of the
Regional Representative Group, not an additional layer between that Group and
the board;
(d)  include a requirement for direct negotiation between the entities and individual
councils or groups of councils over service delivery levels and infrastructure
investment plans in their respective areas;
(e)  that the entities should be required to provide funding to support the Regional
Representative Group, and meetings of councils and mana whenua (including
funding members of these groups);
Summary of local government feedback – October 2021  29

(f)
work with iwi and councils to develop a model that allows for strong local and
regional representation based around sub-boundary ‘clusters’ or catchments;
(g)
amend the governance structure to enable direct council involvement in board
performance, accountability, and appointments;
(h)  enable councils to approve and modify the statement of intent;
(i)
the approach to mana whenua participation in the Regional Representative
Group should be replicated across the governance structures, so there is also
equal representation in the entity board and Independent Selection Panel;
(j)
that people with local government experience should be eligible for
appointments;
(k)
water services entities should be subject to similar consultation requirements as
provided in the Local Government Act 2002;
(l)
that members of the Regional Representative Group should be elected;
(m)  provide a voice for rural water supplies in the governance structure, such as
through a sub-committee to the Regional Representative Group; and
(n)  require the entities to provide quarterly reports to councils.
Protecting and promoting community voice
Summary of feedback
129.  Many of the submissions expressed concern that the proposed approach does not
include adequate mechanisms for enabling community voices to be heard – either
directly, or via local authorities.
130.  There was a common view expressed through submissions that local authorities are
best placed to engage with their communities and represent their views, through
internal processes and requirements in the Local Government Act 2002. There
were, therefore, close connections between this topic, and the comments relating
to governance and accountability outlined above.
131.  Specific concerns in the feedback included:
(a)  scepticism that, given the scale of the entities, the entities will be able to engage
effectively with local communities;
Summary of local government feedback – October 2021  30

(b)  lack of clarity about how much ability communities will have to influence the
entities’ decision making, and the process for connecting with those entities;
(c)
the ability to provide ‘local voice’ is limited by the consolidation of seats available
on the Regional Representative Group – if some councils are not on this Group,
how will their communities have influence and ensure their voices are heard?
(d)  that entities will not focus on or reflect local voice when making investment
decisions, or determining priorities or service standards;
(e)  that voices in smaller districts will be lost;
(f)
that there will be less consultation and engagement than currently, less recourse
if services are poor, and a lack of accountability; and
(g)
that the needs of Tāmaki Makaurau mātāwaka (Māori who reside in Tāmaki
Makaurau who do not whakapapa to the area) have not been considered.
132.  Some submissions sought assurances relating to, or further clarity about, the future
system including:
(a)  seeking assurance that small and rural communities will receive the same level of
service as people living in large, metropolitan areas;
(b)  how the consumer forum will work in practice;
(c)
how local voices will be heard;
(d)  opportunities for local influence and the integration with the spatial planning
system; and
(e)  how people who are not currently receiving a council supply will have their
voices heard regarding future service provision.
Changes suggested in feedback
133.  Some submissions indicated that future legislation should recognise that local
government must have a role in community engagement and consultation
processes, to ensure community and consumer voices are heard, and local priorities
are communicated to the water services entities.
Summary of local government feedback – October 2021  31

134.  Hamilton City Council suggested a specific process that would provide each council
with the opportunity to participate in a ‘pre-engagement’ process and work with
the relevant water services entity on its strategic documents (funding and pricing
plans; asset management plans; and prioritisation methodology that informs the
asset management plan). Councils would do this as representatives of their
communities, and to ensure alignment with their own plans.
135.  The suggested process involves (in summary):
(a)  entities being required to develop an engagement policy, with local councils,
communities, and consumers;
(b)  entities including sufficient information in their key strategic documents that
councils can understand the proposed service levels for communities,
investment in assets, and fees and charges for consumers, within each council
district;
(c)
entities consulting with councils about these strategic documents prior to
consultation with communities and consumers; and
(d)  enabling councils to provide written statements expressing views on the entities’
proposed strategic documents, for inclusion in community/consumer
engagement relating to those documents.
136.  Other suggestions across the feedback included:
(a)  legislative requirements relating to reporting to communities;
(b)  enabling entities to have ‘sub-regional ring-fencing’ to ensure equitable spend in
smaller areas;
(c)
a ‘request for service’ system for consumers to use to deal with service
disruptions, complaints, and general queries;
(d)  an Ombudsman (or similar consumer protection body);
(e)  a community liaison group; and
(f)
that a ‘District Social Action Plan’ should be created that ensures a direct link to
the community wellbeing in the district.
Summary of local government feedback – October 2021  32

Planning interface
Summary of feedback
137.  Feedback on this theme highlighted the inextricable links between water
infrastructure provision and urban development/growth, and noted that water
services entities will have to operate within a larger planning framework.
138.  This planning framework includes responding to the long-term plans (and other
associated plans) for multiple councils within each entity. Many councils felt that
the current governance design does not provide strong enough connections to, or
influence over, growth infrastructure, integrated planning at a regional and local
level, and levels of service. Several councils suggested that, at a minimum, there
needed to be a guarantee the 2021-2031 long-term plans would be delivered.
139.  Hamilton City Council noted that “The entity must ensure that Council’s aspiration
for growth and spatial planning outcomes (including any Special Purpose Vehicle or
Infrastructure Funding and Financing solutions) has surety that any waters entity
will prioritise and give effect to our long term local, sub-regional and regional plan”.
140.  There was also a strong desire from councils to continue to have meaningful
knowledge of, and input on, the strategic direction of the entities, and to uphold
principles of localism by aligning the new entities with local government plans. For
example, Dunedin City Council was worried that “a water services entity with a
geographical footprint much larger than the local communities it services will exert
an investment power over councils’ ability to plan for future land use”. It further
noted that “Councils are best placed to balance the wide variety of considerations
that inform land use planning decisions, of which three waters service provision is
but one part.”
141.  Councils wanted the new entities to support growth and urban development, and
ensure equitable distribution of resources for this. Councils wanted assurance their
development priorities would not lose out to priorities in other areas. "There is the
possibility that in the medium-term the priorities of the new entity may not align
with council's growth priorities" (Palmerston North City Council).
Summary of local government feedback – October 2021  33

142.  In addition, a few councils were concerned about the impact of the reforms and
competing priorities within the entity on high growth areas. For example, Tauranga
City Council was concerned about the impact of timely decision making by the
entity. Queenstown Lakes District Council was worried about the impact of the
multiple reforms, as they felt in limbo until the proposed Spatial Planning Act is
passed and existing spatial plans are given legislative weight.
143.  Many of the submissions wanted more information and certainty around the role
for councils and their planning functions: "Water is a key tool for shaping how
communities develop and grow. So how do we ensure councils can continue to do
this if part of the reform? How would WSEs understand exactly what is happening
locally, and have the flexibility to respond to local needs and changes?" (Stratford
District Council).
Changes suggested in feedback
144.  Multiple submissions requested there be a requirement for councils to be involved
in decision making and planning of water services in their district, for the planning
instruments to be integrated, and for the entities to be required to ‘give effect’ to
local planning documents. There were also requests for the process of investment
prioritisation to be transparent, include community consultation, and contain an
independent review/regulatory process to manage conflicting planning priorities.
145.  Several councils requested that, at a minimum, the new entities should guarantee
the delivery of 2021-2031 long-term plan and any associated plans. Many councils
also asked for the entities to be able to charge for development contributions, or
similar, to ensure equitable funding across the entity area.
146.  Some specific suggestions from councils included:
(a)  Christchurch City Council suggested legislation should include a requirement for
the entities to align their work programmes with other infrastructure planning
organisations, such as councils. The Council also recommended a memorandum
of understanding/cost sharing agreements to ensure both the entity and
territorial authority had some flexibility of work programmes.
Summary of local government feedback – October 2021  34

(b)  Dunedin City Council requested “assurances, through legislation, that any new
water services entity will answer to councils in relation to the provision of three
waters infrastructure to support growth and increased housing capacity”. The
Council also requested the establishing legislation should require the “water
services entities to give effect to councils’ land use strategies, policies and plans”.
(c)
Clutha District Council stated that councils must retain the balance of power for
determining where and when growth occurs.
(d)  South Waikato District Council suggested that, to ensure local-level plans are
accommodated, each council should have a statement of intent with the entity.
(e)  Waitematā Local Board noted that decision making needs to be integrated with
urban planning, there should be a closer relationship between the water services
entities and the regional planning bodies, being either a regional council or a
council in co-governance with mana whenua.
(f)
Waitematā Local Board also suggested that the water services entities should be
consulted during the development of each region’s land use, spatial,
environmental and other planning documents to help ensure alignment and buy-
in.
(g)
Queenstown Lakes District Council recommended the Government “consider
requiring the new entities to commit to delivery on the Future Development
Strategies of high growth councils”.
(h)  Auckland Council recommended a council-controlled organisation model, which
would require the water services entities to give effect to long-term plans and
growth strategies.
(i)
Buller District Council requested a ‘lessons learned’ study from the
amalgamation of the councils that now constitute Auckland Council.
(j)
Waipā District Council suggested there should be a system to manage conflicts
that arose from competing priorities. It noted going through the High Court
would be inappropriate. It also suggested a Lisbon Charter model.7


7 The Lisbon Charter is an international framework of good practice for public policy and regulation in drinking
water supply, sanitation and wastewater management services: https://iwa-network.org/publications/the-
lisbon-charter/
Summary of local government feedback – October 2021  35

Resource management reform and Future for Local
Government
Summary of feedback
147.  Many submitters raised concerns about the number of changes councils were facing
in a short period of time, with three waters reform, resource management reform,
and the Future for Local Government review happening concurrently. One council
described the cumulative effect as "overwhelming".
148.  The predominant theme from councils was that these reform programmes need to
be better aligned, and for the Government to be better aligned in planning and
communicating the roadmap for these concurrent reforms.
149.  Several councils specifically requested that the Future for Local Government review
should take place first. This was seen as important to ensure an enduring and strong
local government following the other reforms.
150.  A smaller number of councils requested that the resource management reform
should take place first. Some also suggested three waters reform should happen
over a longer period, which would give communities time to better understand the
changes and allow the impacts of other reforms to play out first.
151.  “The Three Waters Reform Programme is effectively removing one third of MDC’s
business ahead of the future of local government review. This is not appropriate.”
(Manawatū District Council)
152.  “The Three Waters Reform continuing without appropriate consideration for, or
integration with, the Resource Management Act Reform or the Future for Local
Government Review, risks undermining the lasting success of all these reform
programmes. A whole of local government approach with aligned direction and
goals across all three reforms would undoubtedly be more beneficial for community
wellbeing outcomes." (Timaru District Council)
Changes suggested in feedback
153.  The most common suggestion was for better alignment between the three reform
programmes. As Auckland Council noted, the reforms “currently appear quite
siloed”.
Summary of local government feedback – October 2021  36

154.  Many councils requested further information on the cumulative impacts of the
three reform programmes on local government and their communities. Ashburton
District Council specifically suggested “that before the three waters reform process
proceeds, an issues analysis is completed and understood in relation to the impact
on the water reform of the Resource Management and the Future for Local
Government reforms as these are all inextricably linked”.
155.  As noted above, there were several suggestions for both the Future for Local
Government review and resource management reform to take place first.
Christchurch City Council suggested that the “Future for Local Government review
should occur first and cast its net wider and look at the future for local and central
government in terms of public benefit service delivery both national, regionally and
locally”.
156.  Other councils suggested that the reforms be coordinated differently and should
take place over a longer period, to allow the councils and communities time to
better understand the impacts and implications. “This Government is undertaking
many once in a generation reforms which are interlinked in terms of their impact on
local communities and Local and Regional Government…It is essential that these
reforms are undertaken in a coordinated manner and in a form which is possible for
local government and communities to absorb the information and participate
effectively.” (Invercargill City Council)
157.  Other specific suggestions from councils included:
(a)  Queenstown Lakes District Council suggested all three concurrent reforms should
be prioritised and managed by the same government entity.
(b)  Porirua City Council requested an explicit programme of reform alignment that
takes a community-centred and system approach.
(c)
Timaru District Council requested that the Government review the Productivity
Commission’s advice following the 2019 review of local government funding,
which recommended councils have control over how they structure their three
waters business.
Summary of local government feedback – October 2021  37

Pricing and charging
Summary of feedback
158.  Feedback about pricing and charging was largely about equity of charging, potential
cost increases, transparency, and affordability for ratepayers. Another key issue
raised was the potential for cross-subsidisation, including concerns about
communities that have heavily invested in water infrastructure paying for
communities that may not have invested ‘responsibly’.
159.  Councils raised concerns about the potential for inequitable pricing across different
areas within an entity, especially if consumers in one area end up paying for higher
levels of service in another. “Affordability is a broader issue than just the direct cost
of providing three water services. The issue of user-pay charges, currently
substantially different across proposed Entity A, will need more consideration to be
unified”. (Far North District Council)
160.  Many councils requested transparency about pricing and charging. Some councils
suggested volumetric charging (water metering) would be a way of ensuring equity
across the entity; however, this was not something supported by all submitters.
161.  Rates harmonisation was another tool some councils recommended be used to
ensure equity across the entity; however, others questioned whether that would be
fair, especially in districts that have lower rates. For example, Hauraki District
Council stated that they “have questions about whether rates harmonisation, should
this be implemented, will increase the Hauraki District's household three waters
cost, which is currently 20% lower than the Entity B average. As affordability is a key
issue in the district this uncertainty is a concern for us, especially when higher costs
may not necessarily deliver better services for our residents.”
162.  Affordability was another key issue raised. Invercargill City Council noted
“Affordability is one of the key financial benchmarks which Council legally must
utilise in setting its Long-term plan. As a result of the reform it will no longer be able
to control a large part of the bill for services which the community is receiving. It will
become very difficult to manage affordability in this context.”
163.  The issue of development contributions was also raised, with several councils noting
they wanted this funding model, or a similar funding model, to continue. Councils
requested more information on the development contributions framework, and
how existing agreements would transition.
Summary of local government feedback – October 2021  38

Changes suggested in feedback
164.  Various, often contrasting, suggestions were put forward by councils to address
their concerns about pricing and charging. For example, several councils requested
a user-pays model, whereas others requested equity across the entity. Some
councils noted the importance of cross-subsidisation as a key driver of ensuring
costs remain affordable for all; however, others were worried about their
community paying more to increase the levels of service elsewhere in their entity’s
region.
165.  Some of the main suggestions put forward by councils included:
(a)  Buller District Council suggested the water entities offer a discounted rate to
beneficiaries.
(b)  Horowhenua District Council suggested ratepayers offered rates relief are also
recognised by the water service entities.
(c)
Christchurch City Council recommended that “entities should be required to have
a robust and equitable a process in place to address ability to pay, in advance of
any new charging scheme being introduced”.
(d)  Central Otago District Council recommended a standardised base rate, with
higher levels of service paid for by the community that receives the benefit: “The
model should have standardised pricing for baseline services that is a level of
service that meets minimum compliance requirements irrespective of location.
The Council proposes that service levels higher than baseline could be paid for by
the specific community who receives that benefit. We recommend that this
requirement is written into legislation to protect the consumers”.
(e)  Western Bay of Plenty District Council recommended pricing principles be made
public as soon as possible, and consideration should be given to mandating
pricing changes in the lead up to 1 July 2024 to shorten any period of transition.
(f)
Central Hawke’s Bay District Council “expect there to be a consistent pricing
approach within an entity, and between entities, and for industry to pay for what
it uses”.
(g)
Manawatu District Council noted that uniform pricing may not be relevant, as it
does not take different costs related to water infrastructure into account
(topography, ground water, climate, etc.), and they believe these considerations
should be reflected in pricing.
Summary of local government feedback – October 2021  39

(h)  Waikato District Council would like certainty that price paths would be in line
with, or lower than, their long-term plan budgets, and would like more
assurances and detail around affordability and impacts on ratepayers under the
proposed model.
(i)
Whakatane District Council suggested that the waters services entities should be
required to consider total household costs when setting their charges to
communities.
Number of water services entities and their boundaries
Summary of feedback
166.  The feedback on the number and boundaries of entities was mostly specific to the
entity boundary relevant to the submitter. That said, many submissions raised
general concerns about entities being too large, and therefore risking loss of local
voice, influence and prioritisation for smaller communities.
Entity size and scale
167.  A few submissions raised questions around the size, scale and number of entities
that were decided by central government, and some did not see the rationale
behind the decision beyond scale benefits. There was a strong theme throughout
the submissions of concern for the loss of local voice and influence, and many cited
the size of the entities as one source for that concern.
168.  Many of the smaller councils were worried about competition for prioritisation of
investment, if placed in an entity with many larger cities. Mackenzie District Council
stated that the Crown has not made a sufficiently compelling case about why it is
not feasible for the new regime to be delivered successfully by smaller entities.
Matamata-Piako District Council believed that the changes will be more challenging
in large geographic areas with no historic relationships and competing interests.
169.  “Entity B is too large, with 22 councils, 78 iwi, large rural areas and remote isolated
communities. There will be competing demands between the rural areas, provincial
towns and metros across Entity B. Entity B has a significant amount of growth
identified, and the prioritisation of investment for delivery against this growth will
be challenging.” (Whakatāne District Council)
Summary of local government feedback – October 2021  40

170.  Waimakariri District Council noted some smaller models that may appear
suboptimal from an economies of scale perspective based on the Department’s
modelling would only lead to marginal differences for entities, while improving
other factors of value to communities such as local voice. They also noted that the
justifications for a “sweet spot” of approximately one million in population for each
entity (based on the Departmental modelling) seems to ignore the fact that Entity A
has 1.7 million people, suggesting that there is some acceptance of a loss of
efficiency due to diseconomies of scale.
Specific boundary issues
171.  There were mixed views from the Local Boards in Auckland Council’s submission on
whether Entity A should include both Auckland and Northland, with many noting
concerns around cross-subsidisation. Auckland Council’s submission also touched
on the boundary between Entities A and B. There were concerns around the
utilisation of water from the Waikato River to support Auckland’s water supplies
and how assets that are shared across the boundary (such as the Pukekohe
Wastewater plant) would be dealt with. The Mana Whenua Kaitiaki Forum raised
concerns with how Entity A’s southern boundary has been established; in particular,
the splitting of the rohe of Ngāti Whanaunga, and disconnecting Auckland from the
Waikato River.
172.  A few iwi submissions also noted similar boundary issues between Tāmaki
Makaurau and Te Tai Tokerau, and the need to consider water supply.
173.  Manawatū District Council and Palmerston North City Council questioned why
Entity B and Entity C are split across the Horizons region. Manawatū District Council
stated that this could cause an issue for Manawatū ratepayers, as they provide
three waters infrastructure for Rangitīkei, which falls into a different entity under
the current proposals. Palmerston North City Council noted that this could also
cause issues for integrated land-use and infrastructure planning.
174.  The boundary line between Entities C and D attracted views from councils in the
surrounding areas. Some councils believed that the whole South Island should be
one entity, while others signalled a preference for Entities C and D to be split along
the existing unitary authority boundaries. Tasman District Council noted its
preference was to remain undivided and, while there was a strong case for them to
join Entity C, there was also community interest in them joining Entity D.  Ngāi Tahu
emphatically supported the alignment to the takiwā boundary.
Summary of local government feedback – October 2021  41

Changes suggested in feedback
175.  There were many specific suggestions and requests based on the proposed
boundaries of the four entities:
(a)  Ashburton District Council stated that it would like further work done on
whether the Chatham Islands should be part of Entity C or D, citing the strong
links between Canterbury and the Chatham Islands. (The Chatham Islands
Council did not submit any written feedback.)
(b)  The boundary at the top of Entity D and bottom of Entity C was signalled in a few
submissions as a complex issue, and in need of further discussions with the mana
whenua and councils in those areas.
(c)
Hauraki District Council has signalled an intention to meet with the Department
to discuss the option of being in Entity A, instead of Entity B, whereas Ngāti
Whātua Ōrākei supported Hauraki’s inclusion in Entity B.
(d)  Thames Coromandel District Council requested ongoing dialogue and meetings
between Thames Coromandel District Council, the Department, LGNZ, Pare
Hauraki Collective, Waihou Piako Catchment Committee, neighbouring local
authorities, and any other invited parties to consider the issues and
opportunities of joining with Entity A and implications for Entity B.
(e)  Marlborough District Council signalled a preference to be in Entity C if the
reforms proceed, as future cost projections are more favourable compared with
Entity D.
(f)
Nelson City Council stated a preference for Entity D to cover the whole of the
South Island, and for Marlborough and Tasman to not be split between different
entities.
(g)
Stratford District Council noted their preference is for the regional alternative, as
proposed in their feedback. However, if the reforms proceed they noted support
for placement in Entity B.
176.  In response to the size of the entities proposed, many councils signalled a
preference for smaller, more regionalised entities or models. For example:
(a)  Central Hawke’s Bay District Council proposed a regional council-controlled
organisation model comprising all the councils in the Hawke’s Bay Region
(Hawke’s Bay Regional Council; Hastings District Council; Wairoa District Council;
Napier City Council; and Central Hawke’s Bay District Council).
Summary of local government feedback – October 2021  42

(b)  Waimakariri District Council suggested that the alternative models being
prepared by councils and regions should be considered and compared against
the WICS modelling, to show the differences in benefits between scales.
177.  In contrast, Gore District Council questioned why central government had not
seriously considered having just one entity, as they noted it would reduce
bureaucracy and costs.
Regulatory environment
Summary of feedback
178.  Many submissions supported the Water Services Act 2021, the establishment of
Taumata Arowai, and the proposed establishment of an economic regulator should
the reforms proceed. Some councils noted that, with the establishment of Taumata
Arowai alone, they expect to see a step change in performance across the sector as
drinking water and wastewater standards are enforced, and were very supportive of
this. South Taranaki District Council acknowledged that “better regulation of the
water sector is needed and the introduction of Taumata Arowai is a welcomed
addition”.
179.  The majority of the submissions that mentioned the role of the economic regulator
noted concern about the current lack of detail and information available about this
regime. A few councils requested a pause in the reform programme to allow time to
better understand the role of the economic regulator, and to assess how Taumata
Arowai will have an impact on the system.
180.  A few submitters noted the need to take into account and align with various
national policy statements, such as the National Policy Statement – Urban
Development, and the National Policy Statement – Freshwater.
181.  Ōtorohanga District Council mentioned the impact that the Water Services Act
might have on councils. It was concerned that councils might have to inherit the
many small and rural schemes that have not been subject to any regulation in the
past, noting the large additional compliance and maintenance costs this might
create for councils.
182.  Waimakariri District Council stated that the current proposal was counter to an
integrated regulatory system, and the separation of three waters regulation would
lead to less integration and introduce a number of transactional complexities.
Summary of local government feedback – October 2021  43

Changes suggested in feedback
183.  Many councils signalled the need for further information about the economic
regulator, including requesting clarity on:
(a)  who would be regulated by the economic regulator, including whether councils
who opt out or private supplies would be captured;
(b)  whether councils could be confident that regulation would lead to standardised
pricing across the entity overtime;
(c)
how the economic regulator would sit alongside the governance model; and
(d)  how prices would be set, especially for different activities such as stock water.
184.  Many councils in Entity D requested a pause in the reform programme until further
clarity is provided on the role of the two regulators in the system.
185.  Noting the wide range of environmental consents for infrastructure upgrades and
work from day one, Napier City Council suggested that the consenting and planning
connections would be better dealt with under a regional model.
186.  Whakatanē District Council recommended the reform package should include
funding to support private and rural schemes to meet new regulatory standards.
Ōtorahanga District Council supported the provision of funding for marae to enable
compliance.
Rural supply arrangements
Summary of feedback
187.  Councils with large rural populations raised specific concerns about the impact of
reform on these communities. In particular, councils requested that rural schemes
be given the option to make their own decisions about opting out of the reform,
and that there be a streamlined process for returning council-owned rural supplies
to community ownership. There was also concern rural communities would end up
contributing to water costs when they did not receive any service.
188.  “Significant further work is required to understand the impacts on rural water
schemes and assets including floodwater management, regulation and when and
how water standards can be practically applied to local schemes.” (South Wairarapa
District Council)
Summary of local government feedback – October 2021  44

189.  Many councils with rural communities noted water is critical to land productivity,
and often supplied through a rural scheme. Rural councils also noted that
reticulated water supply is not practical or appropriate for some areas in the New
Zealand context.
190.  Clutha District Council noted rural communities were unlikely to see the same
benefit as urban customers over the next 10 years, and benefits over the next 30
years were unclear. The cost for rural customers was a key issue raised by rural
councils, with many noting their rural ratepayers were concerned they would pay
for services they did not receive.
Changes suggested in feedback
191.  Suggestions included that:
(a)  rural supplies be further defined;
(b)  a streamlined process be implemented to transfer council-owned rural supplies
back to community ownership; and
(c)
the Government work with councils to tackle the complex issue of rural supplies.
Stormwater
Summary of feedback
192.  Fewer submissions reflected on this aspect of the reforms than some of the earlier
themes. The section below reflects a summary of those submissions that did discuss
this matter.
193.  There was some support in submissions for the transfer of stormwater services to
the new water services entities:
(a)  Greater Wellington Regional Council noted it supported this proposal in-
principle.
(b)  Entity C councils noted the plan to keep stormwater within scope of the reforms,
but that this required further work as there were mixed views among member
councils.
Summary of local government feedback – October 2021  45

(c)
Hutt City Council noted it was encouraged by the “approach to the transfer of
stormwater functions outlined in the [Stormwater] Working Group's report and
the report's recommendations”.
(d)  South Taranaki District Council noted that, should drinking water and
wastewater services be transferred, it would make it more difficult for the
Council to retain suitably qualified staff to manage the stormwater function on
its own.
194.  Many councils commented that there is a need for further information and analysis
on the case for transferring stormwater. These submissions sought further work
and clarification around this, in particular raising questions around:
(a)  which assets will be transferred;
(b)  whether water services entities would honour current consent conditions on
council infrastructure;
(c)
the scope of the stormwater management role that the water services entities
would play, including growth and development planning, asset management and
maintenance (particularly of green and water sensitive assets);
(d)  how to ensure integration between stormwater management and local planning
of other assets such as roading, parks and wider environmental management
needs; noting it is likely that a large number of stakeholders would need to be
involved;
(e)  how these services would be charged for, given it was not as easy to identify
users or beneficiaries of stormwater services in a similar way to those for
drinking water and wastewater services;
(f)
how this would impact on the management of flood control (the ‘fourth water’
as noted by Gisborne District Council), with Greater Wellington Regional Council
and Nelson City Council noting the need to clarify the boundaries between
stormwater and flood control and resilience; and
(g)
what the proposed pathway for transfer would be.
195.  Kaipara District Council sought clarity about land drainage parts of the stormwater
network, which in Kaipara are managed by the district council rather than the
regional council.
Summary of local government feedback – October 2021  46

196.  Some submissions requested that the decision on whether to transfer stormwater
functions and assets should sit with individual local authorities. Others drew
attention to the scale of the task associated with transferring drinking water and
wastewater services, and suggested stormwater could be dealt with in a
subsequent phase of the reforms instead of transferring all three waters at once.
197.  Auckland Council listed the key risks to transferring stormwater to the water
services entities as:
(a)  Auckland’s ability to drive an integrated land and water response to big
challenges, such as climate change and growth;
(b)  the Council’s ability to carry out regional council functions – transfer could
require duplication of resources and break connections between freshwater
planning, monitoring and implementation;
(c)
an optimised response to natural hazards; and
(d)  connected and consistent stormwater regulation.
198.  Christchurch City Council, and New Plymouth, Selwyn and Stratford District
Councils, did not support the transfer of stormwater to the new water services
entities, for the following reasons:
(a)  it could risk undermining the existing integrated and holistic approach to
managing stormwater and its interfaces with other assets like parks and roads;
(b)  the complexities of integrating land use and infrastructure planning in relation to
stormwater were best managed at a local authority level;
(c)
the new water services entities “would need to collaborate with multiple local
authorities to reduce contaminants at source, from building site runoff to roof
material approval to industrial site audits, amongst many others. This will
introduce inefficiencies and gaps in the response” (cited from Christchurch City
Council’s submission); and
(d)  it would be complex to unbundle water assets, liabilities, associated contracts.
199.  New Plymouth District Council recommended that regulatory improvements and
co-funding arrangements be explored as alternatives to transferring stormwater.
Summary of local government feedback – October 2021  47

Changes suggested in feedback
200.  Notwithstanding its preference that responsibility for stormwater should remain
with councils, Auckland Council proposed that, should this be transferred,
mechanisms and processes should be introduced to:
(a)  agree working arrangements between councils and the water services entities,
such as memoranda of understanding or service level agreements. This should
include establishment of key stormwater roles and boundaries prior to transfer
of assets and functions;
(b)  ensure that entity data and models will be freely available to the council;
(c)
strengthen the council’s remaining regulatory tools;
(d)  ensure the funding streams required to support the assets and functions that will
remain with council are maintained; and
(e)  ensure an integrated view of land and water directs coordinated decision making
across the council and water services entity.
201.  Greater Wellington Regional Council suggested that regional councils could take
responsibility for all stormwater and flood water management functions that are
not transferred to the water services entities. This includes emergency
management, integrated catchment management, managed retreat, land use, and
river and stream work restoration. It also requested that the Government
contribute funding to flood risk management work, whether undertaken through
the water services entities or the regional council. (This was the only regional
council to submit written feedback, as Greater Wellington delivers some services as
part of Wellington Water).
202.  New Plymouth District Council recommended that, if stormwater is included within
scope of the reform, there should be work to standardise asset classifications and
introduce agreements between water services entities and local authorities. It also
noted that there will need to be a process for territorial authorities to divest any
flood protection schemes they manage to relevant regional councils.
203.  Palmerston North City Council noted that, if there was greater alignment between
the entity boundaries and catchment areas, there would be more flexibility
regarding the ability to take on catchment-based management and river
management functions.
Summary of local government feedback – October 2021  48

204.  Palmerston North City Council also suggested that “stormwater in the context of
land use planning, development and growth, remains with local authorities, and
that the stormwater roles of the new entities are more clearly defined as network
provision and maintenance to comply with regional plans. This includes water
entities working with flood-protected floor levels and the like set by councils”.
205.  Waitematā Local Board suggested that a logical division of responsibility could be
for “the initial collection of stormwater off roads, other public areas and private
property to be the responsibility of councils and for the eventual release of
stormwater into the receiving environment to be the responsibility of the water
entities”.
Transition considerations
Summary of feedback
206.  Submissions noted a significant number of issues that will need to be addressed
through the transition, reflecting the complexity and scale associated with the
transfer of three waters assets, debts and liabilities. Noting some matters raised
earlier in this report could also be considered matters to resolve during any future
transition, other transitional issues included:
(a)  the mechanism for transferring debt associated with three waters assets, and
how this will be calculated;
(b)  the process, timeframes and funding to enable due diligence;
(c)
how local contracts, contractors and their staff will be protected through the
transition, including situations where councils may be liable for legal action and
compensation;
(d)  addressing community resistance to change;
(e)  ensuring the pace of change does not result in mistakes or unforeseen issues;
(f)
ensuring service delivery and efficiency to local users is not disrupted;
(g)
ensuring communities are well informed of the changes from a practical
perspective (for instance, knowing who to call in the event of a fault or delay);
(h)  understanding development / financial contribution charges linked to debt
(including the possibility of refunds);
Summary of local government feedback – October 2021  49

(i)
the transfer of asset management systems and data will need to be clearly
established, as the loss of data or failure of systems will affect the continuity of
service delivery;
(j)
stranded overheads within local authorities will need to be well understood and
plans established to mitigate impacts;
(k)
the continued employment, and creation of employment and procurement
opportunities in local areas, not only the metropolitan areas;
(l)
novation of contracts and tenders in progress, including communication to the
market of any changes in the procurement rules and processes they will be
expected to follow;
(m)  transferring consents, including where these relate to more than one land parcel;
(n)  greater transparency and community engagement on the likely pricing and
charging model for the water services entities; and
(o)  recognising different approaches to managing and maintaining three waters
networks. For instance, Waimakariri District Council noted it had built up
renewals funding from depreciation funding surpluses and ring-fenced this
funding for future renewals expenditure – funding that would be transferred to
the new entity without necessarily recognising that ratepayers had already
contributed to future renewals. This could lead to inequitable outcomes relative
to other local authority areas.
207.  Some submissions raised questions about the feasibility of achieving the proposed
reforms and establishment of the new water services entities by 2024.
208.  Submissions also noted some of the challenges and risks associated with the
transition period. In particular, a common challenge noted across multiple
submissions was the need to find the workforce, skills and technical capability
required to support the transition, and fill governance and management positions
for the new entities. The workforce challenge would likely be exacerbated given
current constraints in the labour market and the likelihood of increased investment
by the four water services entities once established.
209.  It was recognised that the Government had committed to ensuring continued
employment of local staff, but further detail was sought on this commitment and
how staff would transfer to the new water services entities, including what change
management processes would be put in place.
Summary of local government feedback – October 2021  50

210.  Some submissions commented on the positive opportunities created through
reform for employment and career development pathways, including for iwi/Māori.
Kāpiti Coast District Council noted that the new entities “would have deeper
resources, and yet can still be expected to ensure local suppliers are involved in
water services”.
Changes suggested in feedback
211.  Several submissions noted that a collaborative approach between government,
mana whenua and local authorities would be necessary to ensure a smooth
transition process and establishment of the new entities.
212.  Ashburton District Council recommended that the Government form a transition
team with representation from local authorities. However, it acknowledged this
would require a balance of ensuring local authority staff have the opportunity to
contribute to the transition process, while also ensuring that local authorities can
continue to deliver business as usual services.
213.  Many local authority submissions noted the importance of local staff and suppliers
with expertise and experience continuing to design, maintain and manage
networks. Central Hawke’s Bay sought assurances that local knowledge, local staff
and local network management will be the starting point should reform proceed,
and that “any possible arrangements for local staff will ensure an environment of
local ownership and empowerment so that staff continue to remain engaged and
responsive to local issues and are not ever hindered by burdensome process and
reporting back via any centralised control points”.
214.  Some local authorities noted they had begun work to establish their existing
positions and support discussions around the ‘no worse off’ support package, and
recommended this would need to consider broader impacts. For instance:
(a)  Christchurch City Council sought assurances that, should the support package
payments exceed the amount the Government had allocated, local authorities
would still be compensated appropriately.
(b)  Some local authorities sought assurance that appropriate compensation could be
agreed for any stranded overheads with an impact extending beyond two years.
Summary of local government feedback – October 2021  51

(c)
Other local authorities noted that reform would have an impact on other
activities within their organisation that three waters staff have responsibility for,
and that when staff are transferred to the new entities there should be
appropriate compensation to fill these roles. Ōpōtiki District Council used the
example of its Harbour Development programme that it had committed to with
the Government on the understanding it would be overseen by its asset
managers.
(d)  Hamilton City Council requested that the Government guarantee it would fund
all reasonable costs of council participation in the reform programme and
transition process between now and 2027, including the costs of any formal
consultation with their communities.
(e)  Hamilton City Council also requested that the Government guarantee funding for
all reasonable costs of the Regional Representative Group during the
establishment phase until Entity B can fund its activities.
(f)
Some councils called for the Government to increase funding for the support
package and/or to fully fund the support package as opposed to these being
funded through the water services entities.
215.  Christchurch City Council recommended that statutory provisions be enacted in
respect of three waters assets, similar to those that exist for electricity,
telecommunications and gas infrastructure situated in legal roads. This would avoid
the complications associated with creating and transferring property rights to the
new entities, and would make use of a model that is already in use by other utility
service providers and is well understood.
216.  Dunedin City Council recommended that a nationwide three waters workforce
development initiative be established to support the reform programme, and which
would require increased funding and training of new staff by the Government. This
was also signalled in Waikato District Council’s submission.
217.  Queenstown-Lakes District Council noted that the ‘better off’ and ‘worse off’
funding had been calculated on the basis of population-based modelling, which
would be insufficient to meet its needs given its high visitor numbers and the need
to provide three waters services for peak day populations. It recommended
apportioning funding on a demand basis, rather than a resident population basis.
Summary of local government feedback – October 2021  52

218.  South Waikato District Council recommended that the Government establish a
central body to oversee training and workforce development, and that it seeks to
harmonise terms and conditions of employment. A similar suggestion was made by
New Plymouth District Council, for the Government to consider the possibility of
entering into multiple-employer collective agreements now for water functions
within each water services entity area.
Process and timeframes
219.  A number of submissions, particularly from Entity D councils, called for a pause to
the reform process. These submissions raised concerns over the scale and pace of
the reform programme, noting insufficient time had been allowed for engagement
with local government and their communities. Some councils also commented the
eight-week period for engagement was not sufficient for councils to undertake a
meaningful analysis of the proposal and/or to engage with their communities.
220.  Submissions that requested a pause in the reform programme indicated this would
provide more time for local authorities and their communities to consider the three
waters reform proposal alongside other significant programmes of work, like the
resource management reform and the Future for Local Government review. Other
councils saw a pause as enabling a ‘reset’ to occur, providing an opportunity to
revisit the parameters of the reform programme and to consider alternative
options.
221.  There was some support for the engagement approach with iwi/Māori. However,
the Auckland Council Independent Statutory Māori Board, as well as a number of
submissions from iwi, noted that the current engagement approach had not
provided easily understood information for/to Māori, and called for Māori to be
adequately resourced to participate in reform discussions. Other submissions noted
that Government engagement with mana whenua had not necessarily met local
government requirements for engagement.
222.  Some submissions raised concerns over the public information campaign that had
been undertaken, commenting that it should have focused on providing detailed
information to the public on the reform proposal.
Summary of local government feedback – October 2021  53

Concerns over the information and analysis
223.  Some submissions raised the need for more information and clarity about aspects
of the proposals to be provided to councils, including in relation to economic
regulation, and outcomes for service levels and the environment.
224.  There were questions raised by some submitters on the accuracy of the information
and assumptions that underpinned the Government’s modelling and analysis. This
included some noting the limitations of the WICS analysis and modelling, with
councils including Ashburton, Kaikōura and Kāpiti Coast commenting that they
disagreed with the WICS analysis.
225.  Some councils, including Christchurch City and Mackenzie, noted they had
undertaken their own analysis that suggested they could be better off without
reform, which led them to question the projected economic benefits in the
Government’s modelling.
Clarity on the process for decision making and next steps
226.  Several submissions sought clarity on the decision-making process, as well as the
ongoing engagement with the sector on the design and establishment of the new
entities, beyond the current period of engagement.
227.  Horowhenua District Council noted that “the Government has not appropriately
publicly messaged the stage at which the reforms are at, nor explained at what
point communities will be able to properly consider the case for change and
meaningfully contribute to the reform development”.
Changes suggested in feedback
228.  Several submissions raised concerns that the Government might make the reforms
mandatory, recommending that the decision should be left to councils to make on a
voluntary basis.
229.  Many submissions noted the importance of community consultation prior to
decisions being made, with some pointing to the wide range of responses triggered
by the reform proposals. It was noted that community consultation should occur
irrespective of whether reform is pursued on a voluntary or mandatory basis. Some
submitters noted that a referendum might be appropriate.
Summary of local government feedback – October 2021  54

230.  Auckland Council recommended the Government seek further engagement on the
following aspects of the proposals:
(a)  representation from and on behalf of mana whenua;
(b)  integration with other local government reform processes;
(c)
integration with spatial and local planning processes, and growth;
(d)  the nature, role and timing of economic regulation;
(e)  process for decision making regarding prioritisation of investment;
(f)
the transfer of stormwater assets and functions;
(g)
process for local authority decision making on ‘opting in or out’ of the three
waters reform;
(h)  conditions associated with the Government’s package of funding for local
government; and
(i)
transition arrangements, including for the council group workforce, information
sharing, and due diligence for asset transfers.
231.  Howick Local Board suggested trialling the reforms in the South Island and, if
successful after five years, to roll it out to the rest of the country. Other councils
suggested trialling the reforms in Entity B.
232.  Some local authorities recommended that, in relation to the concerns around the
modelling, the Government should refine this analysis further and provide councils
with an opportunity to review the data.
Comments on other matters
Summary of feedback and changes suggested
233.  A few submitters raised concerns about how the entities will be involved in the
emergency management system, and how having three waters services managed by
a different entity could create further complexities, especially for areas that already
have small emergency operations at a local level. Many wanted further information
about how the water services entities would incorporate resilience and climate
change considerations into their decision making.
234.  Hamilton City Council suggested that climate change mitigation principles be added
into the operating principles of the water services entities.
Summary of local government feedback – October 2021  55

235.  Dunedin City Council would like the legislation to require the entities to engage in
emergency management and event response: “The council urges the Government to
ensure legislation that establishes any new water services entities requires the
entities to actively work with Civil Defence and local communities on response
planning and emergency event response”.
236.  Kaipara District Council would like confirmation that the entities will align with, and
support the outcomes of, the climate change adaptation work being done by their
communities.
237.  Masterton District Council would like more clarity on how the proposed entities will
deliver on local strategies that are already in place, for example the Wairarapa
Water Resilience Strategy.
238.  Queenstown-Lakes District Council reflected that, because the three waters system
has an important role to play in the management of climate change, it was
concerning the reforms were progressing ahead of the National Adaptation Plan
(anticipated in 2022). The Council also suggested a carbon accounting exercise
should be done to fully assess the benefits of the different models, and this should
be displayed publicly on the dashboards.
239.  Gore District Council was concerned that once the reforms are implemented, “all
bets are off” in regard to capital investments. Gore District Council asked for a
minimum guarantee on future capital investment before it can support the reform
proposals.
240.  A few councils mentioned the process for the development of the Government
Policy Statement was currently unclear and requested to be consulted meaningfully
during the development of the statement.
241.  Southland District Council suggested that the 'four well-beings’ (cultural, social,
environmental and economic) provided for in the Local Government Act should be
integrated into the operational and decision-making principles for the entities and
the reform.
242.  Waitematā Local Board stated “Climate change resilience, ensuring food security,
biodiversity, the health of harbours and water courses should all be important
considerations of water entities as well as the provision of quality potable water,
and the management of waste water and storm water. We recommend a holistic
approach.”
Summary of local government feedback – October 2021  56

243.  Whanganui District Council noted that there is not any information currently
available from the Department on the impact these reforms will have on large
businesses, especially trade waste businesses.
244.  Whangarei District Council raised concerns around decreasing levels of service post
reform, noting “Service levels is also a significant issue. Currently, Whangarei enjoys
generally better three waters outcomes than Auckland. We rarely (if ever) need to
close beaches because of wastewater contamination, we rarely have water use
restrictions, and our response time for faults are generally quicker. If WDC joined
with Entity A there is a reasonable chance that service levels would decrease to
match those found in Auckland.”
245.  Ashburton District Council was worried about the impact of removing the three
waters services on local body elections, as they were concerned the loss of this role
from councils might affect the pool of candidates wanting to stand for election.

Summary of local government feedback – October 2021  57

Appendix A: List of engagements with local government,
iwi/Māori, and industry stakeholders
The table below provides an overview of formal engagements and discussions held with the
local government sector, iwi/Māori, and industry experts on the case for change and the
reform proposals. This table begins with the Government’s national evidence base released
(1 June 2021) and runs through to the end of the August/September 2021 period of
engagement (1 October 2021).
Key:  Iwi /Maori
Local Government
Joint Local Government and iwi  Other/Industry
Date (2021)
Engagement
Engagement with
Where
Webinar with for Mayors, Chairs and
DIA
Chief Executives to explain the national
1 June
evidence base release
Online
Meeting with LGNZ Executive Leadership  MoLG and LGNZ
3 June
team
Wellington
4 June
Meeting with Te Tau Ihu iwi
MoLG
Online
Detailed question and answer webinar
DIA
8 June
for council technical leads
Online
10 June
Meeting with Ngai Tahu representatives
DIA
Online
Presentation to industry hosted by
MoLG
14 June
Russell McVeagh
Wellington

Discussion at Zone Five (upper South
MoLG, LGNZ
15 June
Island Councils) meeting
and DIA
Christchurch
15 June
Hui with Waikato Tainui
DIA
Hopuhopu
Trade and Industrial Waters Forum
MoLG
16 June
Conference
Wellington
Institute of Finance Professionals New
DIA
16 June
Zealand, Infrastructure panel
Wellington
Presentation to industry hosted by
MoLG
17 June
Russell McVeagh
Auckland
Hui with Hawkes Bay Regional Council
DIA
17 June
and Ngāti Kahungunu representatives
Napier
Meeting with Auckland Council
MoLG and DIA
18 June
Governing Body
Auckland
21 June
LGNZ Chief Executives Forum
LGNZ and DIA
Wellington
Construction Sector Accord Workshop on  DIA and MBIE
23 June
interface with Water Reform
Wellington
25 June
Meeting with Otago Regional Council
DIA
Otago
Joint Central/Local Government Steering
LGNZ, Taituarā
28 June
Committee meeting
and LGNZ
Wellington
Webinar for all council elected members
DIA
and Chief Executives on Cabinet
decisions on entity size, shape and
29 June
design features
Online
Webinar for all iwi on Cabinet decisions
DIA
30 June
on entity size, shape and design features
Online
1 July
Hui with Waikato River iwi
DIA
Rotorua
Summary of local government feedback – October 2021  58

Date (2021)
Engagement
Engagement with
Where
MoLG, MoF and
1 July
Meeting with LGNZ
LGNZ
Wellington
Discussion at Zone Six (lower South
MoLG, LGNZ
2 July
Island councils) meeting
and DIA
Dunedin
2 July
Hui with Maniapoto Māori Trust Board
DIA
Te Kuiti
Discussion with Institute of Public Works
DIA
Engineering Australasia (IPWEA)
2 July
Canterbury members
Christchurch
5 July
Hui with Wellington iwi
DIA
Porirua
Question and answer webinar for all
DIA
council elected members and Chief
8 July
Executives
Online
9 July
Meeting with Auckland Council
MoLG and DIA
Auckland
MoLG, MoF and
11 July
Meeting with LGNZ
LGNZ
Online
Webinar for council Chief Executives and
DIA
nominated staff on early transition
12 July
planning
Online
Discussion with Central North Island
DIA
12 July
council Chief Executives
Wellington
Meeting with Māori Council officers on
DIA
working with mana whenua through
12 July
reform
Wellington
Meeting with Environmental Defence
DIA
12 July
Society
Wellington
Hui with Te Maruata (LGNZ Māori
MoLG, LGNZ
Committee – a sub-group of National
and DIA
14 July
Council)
Blenheim
14 July
Hui with ngā iwi o Te Tau Ihu
MoLG and DIA
Blenheim
Meeting with councils from the top of
MoLG and DIA
14 July
the South Island
Blenheim
Waikato District Council stormwater
DIA
15 July
regulation hui
Online
Prime Minister,
Minister of
Finance, MoLG,
Minister of
Housing,
Steering
LGNZ National Conference including
Committee
announcement of financial support
Chair, LGNZ,
15-16 July
package
and DIA
Blenheim
19 July
Discussion with E Tu Union
DIA
Online
Discussion with Public Service
DIA
20 July
Association
Auckland
Meeting with Auckland Council Planning
DIA
21 July
Officers
Auckland
Discussion with Zone Two (Upper North
LGNZ and DIA
22 and 23 July
Island councils below Auckland)
Taupō
Summary of local government feedback – October 2021  59

Date (2021)
Engagement
Engagement with
Where
Meeting with representative from
MoLG
22 July
Waikato-Tainui
Hamilton
Webinar for all Mayors and Chief
LGNZ
22 July
Executives
Online
Presentation at Local Government
DIA
22 July
Funding Agency Shareholders event
Wellington
22 July
Infrastructure NZ policy event
MoLG and DIA
Auckland
Transformation hui with Christchurch
DIA
23 July
City Council
Christchurch
23 July
Transformation hui with WSP
DIA
Christchurch
Joint Central/Local Government Steering
LGNZ, Taituarā
26 July
Committee meeting
and LGNZ
Wellington
28 July
Discussion with Amalgamated Workers
DIA
Union NZ
Auckland
Meeting with Greater Wellington
MoLG and DIA
28 July
Regional Council Chair
Wellington
DIA and
Steering
Committee
28 July
Meeting with Gisborne District Council
Chair
Gisborne
28 July
Meeting with Waikato-Tainui
DIA
Ngaruawahia
29 July
Transformation hui with AECOM
DIA
Auckland
2 August
Meeting with Dame Karen Poutasi,
MoLG
Online
Taumata Arowai Chair
2 August
Waikato District Council/ Transitional
DIA
Online
Industry Training Organisation Steering
Group Meeting
2 August
Webinar for council Chief Executives and
DIA
Online
nominated staff on transition planning
3 August
Question and answer session with
DIA
Online
Waimakariri District Council
4 August
Discussion with Tasman District Council
DIA
Online
on the transition approach
5 August
Hui with all council’s collectively from
LGNZ and DIA
Taupō
across Entity B
5-6 August
Iwi Chairs Forum
MoLG
Online
5 August
Webinar for Mayors and Chief Executives  LGNZ
Online
with guest speakers form Beca and
FarrierSwier
6 August
Meeting with senior waters staff from
DIA
Whangarei
councils across all of Entity A
6 August
Discussion at Zone Four meeting (greater  LGNZ and DIA
Hutt City
wellington region)
6 August
Meeting with Wairoa Mayor Craig Little
MoLG and DIA
Online
9 Aug-21
Local Authority Protection Programme
DIA
Wellington
Disaster Fund (LAPP) Board meeting
Summary of local government feedback – October 2021  60

Date (2021)
Engagement
Engagement with
Where
9 August
Question and Answer session with
DIA
Online
Canterbury Engineering Managers Forum
(collective of council staff across the
Canterbury region)
9 August
Wellington Council working group
LGNZ
Wellington
9 August
Grey District Council workshop
LGNZ
Online
9 August
Webinar for council elected members
LGNZ
Online
10 August
Discussion with Engineering Leaders
DIA
Wellington
Forum (includes IPWEA, Water NZ,
Association of Consulting Engineers, Civil
Contractors NZ, Cement NZ, University of
Canterbury, Electricity Engineers
Association, IT Professionals NZ)
10 August
Kapiti Coast councillor workshop
LGNZ
Kapiti
10 August
Te Ao Māori Technical Working Group
DIA
Auckland
10 Aug-21
Overview of reform proposals and
DIA
Online
question and answer webinar hosted by
Water NZ for their members
11 August
Meeting with West Coast council Mayors   LGNZ
Online
11 August
Technical call to discuss indicative
DIA/LGNZ
Online
financial modelling and ‘no worse off’
funding support with Chatham Islands
Council
11 August
Technical call to discuss indicative
DIA/LGNZ
Online
financial modelling and ‘no worse off’
funding support with Manawatu District
Council
12 August
Technical call to discuss indicative
DIA/LGNZ
Online
financial modelling and ‘no worse off’
funding support with South Waikato
District Council
12 August
Technical call to discuss indicative
DIA/LGNZ
Online
financial modelling and ‘no worse off’
funding support with Hutt City Council
12 August
Technical call to discuss indicative
DIA/LGNZ
Online
financial modelling and ‘no worse off’
funding support with Dunedin City
Council
12 August
Technical call to discuss indicative
DIA/LGNZ
Online
financial modelling and ‘no worse off’
funding support with Wellington City
Council
12 August
Technical call to discuss indicative
DIA/LGNZ
Online
financial modelling and ‘no worse off’
funding support with Whangarei District
Council
Summary of local government feedback – October 2021  61

Date (2021)
Engagement
Engagement with
Where
12 August
Technical call to discuss indicative
DIA/LGNZ
Online
financial modelling and ‘no worse off’
funding support with Christchurch City
Council
12 August
Discussion with Amalgamated Workers
DIA
Union NZ
Auckland
12 August
Discussion with Aviation and Marine
DIA
Auckland
Engineer Association
13 August
Overview of reform proposals and
DIA
Online
question and answer webinar hosted by
IPWEA for their members
13 August
Deloitte – extending Wellington Water
DIA
Online
study to meet objectives of Waikato
District Council/ Transitional Industry
Training Organisation three Waters
Workforce Strategy project
13 August
LGNZ metro sector meeting
LGNZ and DIA
Wellington
14 August
Meeting with Waitomo District Council
MoLG
Te Kuiti
Mayor John Robertson
16 August
Meeting with Forest and Bird Chief
MoLG
Online
Executive Karen Hague
16 August
Central Hawkes Bay Regional
LGNZ and DIA
Hawkes Bay
Collaboration forum
16 August
Technical briefing with Whangarei CEO
LGNZ
Whangarei
and water general manager
16 August
Meeting with Local Government Funding
DIA
Online
Agency Executive
16 August
Discussion with Amalgamated Workers
DIA
Union NZ
Auckland
17 August
Speech at Bay of Plenty Regional Council
MoLG
Rotorua
Komiti Māori meeting
17 August
Meeting with Bay of Plenty Regional
MoLG
Rotorua
Council Chief Executive and Chair
17 August
Technical briefing with Otorohanga
LGNZ
Online
District Council
18 August
Technical briefing with Wellington City
LGNZ
Wellington
Council
18 August
Technical Briefing with Manawatu
LGNZ
Online
District Council
16 August
Technical briefing with Matamata-Piako
LGNZ
Online
District Council
18 August
Hui with Ngāti Whātua representatives
DIA
Auckland
19 August
Local Government Funding Agency
DIA
Online /Auckland
investors meeting
19 August
Question and answer webinar with
LGNZ
Online
Mayors and Chief Executives
19 August
Technical workshop with Manawatu
LGNZ
Online
Council
Summary of local government feedback – October 2021  62

Date (2021)
Engagement
Engagement with
Where
19 August
Question and answer webinar for council  Taituarā and
Online
Chief Financial Officers
DIA
20 August
Technical workshop with Central Otago
LGNZ
Online
councils
20 August
Attended Entity A councils’ people and
DIA
Online
workforce hui
23 August
Wellington Councils working group
LGNZ
Online
24 August
Greater Wellington Region Wananga
LGNZ
Online
24 August
Hui of all iwi across Entity B
(no Government  Online
or LGNZ
attendee, but
content support
provided in
advance)
24 August
Technical briefing with Christchurch City
LGNZ
Online
Council
25 August
Meeting with New Zealand Utilities
DIA
Online
Advisory Group
26 August
Meeting with Central Otago District
LGNZ and DIA
Online
Council
26 August
Meeting with Minister and LGNZ
MoLG and LGNZ  Online
leadership
26 August
Porirua workshop
LGNZ
Porirua
26 August
Hui with Te Uri o Hau representatives
DIA
Online
30 August
Hui with Whakatane District Council and
DIA
Whakatane
Bay of Plenty iwi
30 August
Technical briefing with Waimakariri
LGNZ
Online
District Council
30 August
Meeting with Christchurch City Council
DIA
Online
Chief Executive
30 August
Webinar for council Chief Executives and
DIA
Online
nominated staff on transition planning
31 August
Question and answer session with
DIA
Online
Ashburton District Council
31 August
Detailed workshop on Governance
LGNZ
Online
proposals
31 August
Meeting with Clutha District Council
DIA
Online
31 August
Meeting with Federated Farmers
MoLG and DIA
Online
(primarily to discuss the drinking water
regulatory environment)
31 August
Meeting with a variety of council Mayors  LGNZ and DIA
Online
and Chief Executives on the funding
allocations
31 August
Technical briefing with Selwyn District
LGNZ
Online
Council
31 August
Technical briefing with Upper Hutt City
LGNZ
Online
Council
Summary of local government feedback – October 2021  63

Date (2021)
Engagement
Engagement with
Where
31 August
Technical briefing with Nelson City
LGNZ
Online
Council
31 August
Technical briefing with Ashburton District  LGNZ
Online
Council
31 August
Data and Digital hui with Watercare
DIA
Online
31 August
Attended Entity A councils people and
DIA
Online
workforce hui
1 Sept
Technical briefing with Palmerston North  LGNZ
Online
City Council
1 Sept
Technical briefing with South Taranaki
LGNZ
Online
District Council
1 Sept
Technical briefing with Ruapehu District
LGNZ
Online
Council
1 Sept
Technical briefing with Masterton
LGNZ
Online
District Council
2 Sept
Workforce Development Strategy Project  DIA and
Online
Working Group (includes members from
Taituarā
Hamilton City Council, Connexis,
Taituarā, Wellington Water, Citycare
Water, Water NZ, and Taumata Arowai)
2 Sept
Hui with Te Uri o Hau representatives
DIA
Online
2 Sept
Detailed workshop on maintaining
LGNZ
Online
community voice
2 Sept
Webinar with Mayors and Chief
LGNZ
Online
Executives including guest speakers from
TasWater and Tasmanian councils
2 Sept
Technical briefing with Greater
LGNZ
Online
Wellington Regional Council
3 Sept
Webinar will all council elected members  LGNZ
Online
on the reforms with guests from Victoria
Water in Australia
3 Sept
Discussion with Public Service
DIA
Association
Online
6 Sept
Detailed workshop on integration with
LGNZ
Online
council planning
6 Sept
Hui with Young Elected Members
LGNZ
Online
6 Sept
Technical briefing with Tararua District
LGNZ
Online
Council
6 Sept
Technical briefing with Dunedin City
LGNZ
Online
Council
6 Sept
Hui with Ngāti Kahungungu
MoLG and DIA
Online
Representatives
6 Sept
Stormwater asset transfer implications
DIA
Online
discussion group establishment with
Queenstown Lakes District Council,
Waimakariri District Council, Dunedin
City Council
Summary of local government feedback – October 2021  64

Date (2021)
Engagement
Engagement with
Where
6 Sept
Waikato District Council/ Transitional
DIA
Online
Industry Training Organisation Connexis
Workforce Strategy project discovery
Session 1
7 Sept
Hui with all council’s collectively from
LGNZ and DIA
Online
across Entity B
7 Sept
Public Service Association discussion
DIA
Auckland
7 Sept
Discussion with Citycare Water
DIA
Online
7 Sept
Discussion with Energy Academy about
DIA
Online
their Training model for Orion Energy
7 Sept
Te Ao Māori Technical Working Group
DIA
Online
8 Sept
Detailed workshop on Rural Schemes
LGNZ and
Online
Steering
Committee
Chair
8 Sept
Technical briefing with South Wairarapa
LGNZ
Online
District Council
8 Sept
Hui with New Plymouth District Council
DIA and
Online
and Taranaki iwi
Taumata Arowai
8 Sept
Pre meet Hui with Hauraki, Thames-
DIA
Online
Coromandel and Matamata-Piako
District Councils and local iwi
8 Sept
Question and answer session with
DIA
Online
Wellington City Council
8 Sept
Systems of Record scoping meeting with
DIA
Online
Watercare
9 Sept
Stormwater asset transfer implications
DIA
Online
discussion group with Queenstown Lakes
District Council, Waimakariri District
Council, Dunedin City Council
9 Sept
Watercare hui about the Waikato District  DIA
Online
Council/ Transitional Industry Training
Organisation 3Water Workforce Strategy
project
9 Sept
Waikato District Council/ Transitional
DIA
Online
Industry Training Organisation Connexis
Workforce Strategy project discovery
session 2
9 Sept
Technical briefing with Tasman District
LGNZ
Online
Council
9 Sept
Technical briefing with Central Hawke’s
LGNZ
Online
Bay District Council
10 Sept
Technical briefing with Auckland City
LGNZ
Online
Council
10 Sept
Presentation from Waikato District
DIA
Zoom
Council on interface and transfer of
stormwater assets
10 Sept
Ngāi Tahu management hui
DIA
Online
Summary of local government feedback – October 2021  65

Date (2021)
Engagement
Engagement with
Where
10 Sept
Discussion with Kaipara District Council
DIA
Online
General Manager People + Capability
13 Sept
Webinar for council Chief Executives and
DIA
Online
nominated staff on transition planning
13 Sept
Question and answer session with
DIA
Online
Selwyn District Council
13 Sept
Technical briefing with Horowhenua
LGNZ
Online
District Council
13 Sept
Meeting with Amalgamated Workers
DIA
Online
Union NZ about their training volumes in
Three Waters workforce
13 Sept
Meeting with Whakatane District Council  DIA
Online
and local iwi
13 Sept
Hui with Hauraki, Thames- Coromandel
DIA
Online
and Matamata-Piako District Councils
and local iwi
14 Sept
Meeting with Queenstown Lakes District
DIA
Online
Council
14 Sept
Technical briefing with Waimate District
LGNZ
Online
Council
14 Sept
Waikato District Council/ Transitional
DIA
Online
Industry Training Organisation 3Water
Workforce Strategy project proposal
14 Sept
Refresher webinar and question and
DIA
Online
answer session for all iwi/Māori contacts
15 Sept
Employers and Manufacturers
MoLG and DIA
Online
Association Members Forum
15 Sept
Hui with representatives from ngā iwi o
MoLG and DIA
Online
Te Tau Ihu
15 Sept
Hui with Ngāti Kahungungu
DIA
Online
representatives
15 Sept
Technical briefing with Kaipara District
LGNZ
Online
Council
15 Sept
Charging and pricing hui with Waikato
DIA
Online
District Council
16 Sept
Hui with Ngāti Wai representatives
DIA
Online
16 Sept
Webinar for Mayors and Chief Executives  LGNZ
Online
to discuss key areas of feedback on
reform proposals
16 Sept
Technical briefing with South Waikato
LGNZ
Online
District Council
16 Sept
Data and Digital hui with Wellington
DIA
Online
Water
16 Sept
Discussion with Public Service
DIA
Association
Online
16 Sept
Discussion with First Union
DIA
Online
Summary of local government feedback – October 2021  66

Date (2021)
Engagement
Engagement with
Where
16 Sept
Meeting with Healthy Waters, Auckland
DIA
Online
Council – regarding the Waikato District
Council/ Transitional Industry Training
Organisation Three Waters Workforce
Strategy project
17 Sept
Hui with Rotorua Lakes Council and iwi
MoLG and DIA
Online
representatives
17 Sept
Meeting of sub-group of Entity C Chief
LGNZ
Online
Executives (made up of 6 representative
CEs)
17 Sept
Meeting with Watercare – Chief
DIA
Online
Executive and General Manager Healthy
Waters
17 Sept
Wellington Water - seeking interest in
DIA
Online
participating in Waikato District Council/
Transitional Industry Training
Organisation 3Water Workforce Strategy
project
20 Sept
Charging and pricing hui with Watercare
DIA
Online
20 Sept
Water Services Managers Group (Water
DIA
Online
NZ) Committee meeting
20 Sept
Waikato District Council/ Transitional
DIA
Online
Industry Training Organisation 3Water
Workforce Strategy project proposal
20 Sept
Technical meeting with Wellington
LGNZ
Online
Councils
20 Sept
Hui with Ōpōtiki District Council and iwi
DIA
Online
representatives
21 Sept
Meeting of all Mayors and Chief
LGNZ
Online
Executives from across Entity C
21 Sept
Attend New Plymouth District Council
DIA
Online
meeting as technical support
22 Sept
Meeting with Waikato District Council
MoLG and DIA
Online
Waters Governance Board
22 Sept
Meeting with Ruapehu District Council
DIA
Online
22 Sept
All of entity B councils collective meeting  LGNZ and DIA
Taupō
22 Sept
Discussion with E Tu Union
DIA
Online
22 September
Hui with Ngai Tahu and working party of
MoLG and DIA
Online
South Island Mayors
23 Sept
Pre-meeting with Rangitāne Tū Mai Rā
DIA
Online
Trust
23 Sept
Meeting with Gisborne District Council
MoLG and DIA
Online
23-24 Sept
Visit to Clutha District rural water
DIA
Clutha
scheme
27 Sept
Discussion at Canterbury Mayoral Forum
MoLG, LGNZ
Online
and DIA
Summary of local government feedback – October 2021  67

Date (2021)
Engagement
Engagement with
Where
27 Sept
Virtual roadshow of Australian water
LGNZ, Taituarā
Online
services hosted by SPICAE
and DIA
27 Sept
Hui with Te Rūnanganui-o-Ngāti Hikairo
DIA
Online
30 Sept
Discussion at Zone Six (lower South
MoLG, LGNZ
Island councils) meeting
and DIA
Online
30 Sept
Webinar for Mayors and Chief Executives  LGNZ
Online
to discuss key areas of feedback on
reform proposals

Summary of local government feedback – October 2021  68