30 September 2021
Nanaia Mahuta
Minister
Email: [Nanaia Mahuta request email]
Copy to: Allan.Prangnel
Email: [email address]
Copy to: Stuart Crosby, President LGNZ
Email: [email address]
Tēnā koe Nanaia,
Re: Preliminary Feedback on the Three Waters Reform
Thank you for the opportunity to provide preliminary feedback on the Three Waters Reform.
We understand the Department of Internal Affairs is currently seeking preliminary feedback
on the Three Waters Reform Package.
Our Understanding of Key Drivers and Core Objectives
We  understand  the Government  launched  a  programme  to reform  local government  three
waters service delivery arrangements in July 2020. Currently, 67 dif erent councils own and
operate the majority of the drinking water, wastewater, and stormwater services on behalf of
their communities; and that the Government proposed to establish four new publicly owned
multi-regional entities (four) to deliver these services.
Reviews into the delivery of three waters services in New Zealand have identified significant
ongoing challenges and a considerable level of underinvestment in three waters infrastructure
under the Official Information Act 1982
We  also  understand  that  the  reform  programme  is  being  progressed  through  a  voluntary
partnership-based approach with the local government sector, alongside iwi/Maori as the
Crowns Treaty Partner. The Three Waters Reform Programme is a major intergenerational
project.
The over-arching aim is to ensure that New Zealand’s three waters –  our  drinking  water,
wastewater, and stormwater –  infrastructure  and  services  are  planned, maintained, and
Released
delivered in a way that improves the health and wel being outcomes to benefit all communities
in New Zealand and to ensure that these networks are affordable and fit for purpose
Specifically, to:
1. Improve the safety, quality, and environmental performance of water services
2. Ensure all New Zealanders have access to affordable three waters services
3. Move the supply of three waters services to a more financially sustainable footing, and
address the af ordability and capability challenges that currently exist in the sector
Ngā Maunga Whakahi  o Kaipara Development Trust
16 Commercial Road, PO Box 41, Helensville, Auckland | www.kaiparamoana.com | +64 9 420 8410

4.  Improve transparency about, and accountability for, the delivery and costs of three
waters services
5.  Improve  the  coordination  of  resources  and  unlock  opportunities  to  consider  New
Zealand’s  water  infrastructure  needs at a larger scale and alongside wider
infrastructure and development needs
6.  Increase the resilience of three waters service provision to both short and long-term
risks and events, particularly climate change and natural hazards
7.  Provide mechanisms for enabling iwi/Maori rights and interests

Following extensive work since July 2020, we understand the Government has decided to
pursue an integrated and extensive package of reform to the current system for delivering
three  waters  services  and  infrastructure.  The  package  comprises  the  following  core
components:
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1.  Establish four statutory, publicly owned water services entities to provide safe, reliable,
and efficient water services
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2.  Enable the water services entities to own and operate three waters infrastructure on
behalf of local authorities, including transferring ownership of three waters assets and
access to cost-effective  borrowing  from  capital  markets  to  make  the  required
investments
3.  Establish independent, competency-based boards to govern each water service entity
4.  Set a clear national policy direction for the three waters sector, including expectations
relating  to  the  contribution  of  water  services  entities  to  any  new  spatial  /  resource
management planning processes
Information
5.  Establish an economic regulation regime to ensure efficient service delivery and to
drive the achievement of efficiency gains, and consumer protection mechanisms
6.  Develop  an  industry transformation  strategy  to support  and  enable the wider  three
waters industry to gear up for the new water services delivery system

Official
We also understand the Government has committed to working closely with local government
and treaty partners to help increase chances for success and ensure the new water service
entities are operational by 1 July 2024. Further to the initiatives (above), we also understand
the
that in  mid-July  2021, the  Prime  Minister  and Minister  of  Local Government  announced  a
comprehensive $2.5 bil ion three waters support package. The package has three financial
components.
1)  Support  for  local  government  to  invest  in  communities  wellbeing.  This  part  of  the
under
investment totals $2bil ion, with $500 mil ion being available from 1 July 2022. It wil  be
allocated  between  councils  according  to  a  nationally  consistent  formula,  reflecting
population (75%), deprivation (20%), and land area (5%).
2)  Targeted support to ensure that no councils are financially worse off as a result of
transferring their three waters assets. This is designed to protect councils from any
negative financial consequences of the asset transfer.
3)  Cover of reasonable transition costs. This is intended to make sure council service
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delivery (including water services) during the transition isn’t compromised by the work
needed to make the transition happen.

We  understand  that  no  formal  decisions  are  required  at  this  stage.  However,  that  the
Department of Internal Affair is seeking preliminary feedback on the: 1) potential impacts of
the proposed reform; and 2) how it could be improved.
2

Our Approach and Methods
To evaluate requirements, we are currently undertaking a comprehensive package of works
that  includes  undertaking  a  detailed  literature  review  of  local  government  legislation  and
requirements  relating  to  the  management  of  water  and  wastewater  (Watercare  Services
Limited) and stormwater in the Auckland Region; and review the efficacy of water, wastewater,
and stormwater delivery in Northland ie areas pertaining to the proposed “Entity A.” We are
currently working closely with all Mana Whenua Entities in the Auckland Region (19), and
Auckland  Council.  Our  intention  is  to  broaden  our  discussions  with  Te  Tai  Tokerau  and
Waikato over the coming weeks.
Our Preliminary Feedback
Given the breadth of the Three Waters Reform Programme, we are currently focusing our
feedback  on  four  Potential  Impacts  and associated Areas  for  Improvement  (see  Table 1
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below).
Important Note: These  Potential  Impacts  and  Areas  for  Improvement  (also see Table 1
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below) are based on our preliminary work; and we anticipate identifying additional feedback
areas as we work through the proposal.
Table 1: Identified Potential Impacts and Areas for Improvement
Potential  Topic
Areas for Improvement
Impacts
1
Governance
•  Partnership arrangements
and Entity
•  The degree to which Iwi Mana Motuhak
Information  e has been
Boundaries
acknowledged
•  The degree to which water is recognised as a taonga
•  The  degree  to  which  the  reforms  protect  Treaty
Settlements and initiatives
•  Rectifying  inherent  flaws  in the broader Strategic
Official
Management Framework
•  Boundary issues and rationale relating to Entity A –
the Tāmaki Makaurau and Te Tai Tokerau
•  Boundary issues need to consider water supply
•  Assumptions underlying development of the Entities
are fundamentally flawed
under  •  Engagement to date has been poor, the expectation
is that the Crown will work closely with Mana Whenua
entities
•  Wil  need to make provision for significant resourcing
to help ensure the proposed model is workable
2
Te Mana o te
•  Statutory, regulatory, and policy definition of Te Mauri
Wai
/ Te Mana o te Wai
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•  Engagement with mana whenua relating to the
National Policy Statement - Freshwater
3
Proposed
•  The degree to which proposed reforms work together
Reform
to achieve desired outcomes
Alignment
•  Scoping  Key  Drivers  (and related constraints and
and Intent
opportunities)
3

4
Operational
•  Three Waters servicing outcomes
Preparedness
•  Management of constraints and opportunities
•  Lack of engagement with mana whenua to help
manage change
Feasibility  of  achieving  proposed  reforms  and  their
associated requirements by 2024

Key Messages
Please note our key messages:
1.  Water as a taonga needs to be central to all decision-making
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2.  The Three Waters Reform need to be founded on a holistic framework that captures
social, economic, cultural and environmental aspirations of both partners and it needs
to be founded on a robust framework for success
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3.  We are keen to work closely with the Department of Internal Af airs as Treaty Partners
to achieve mutually beneficial outcomes, please contact us directly
4.  We expect to be adequately re-imbursed for our time and resources to work with you
on developing mutually beneficial outcomes.
Next Steps
It is our intent that we form a highly collaborative working partnership with the Department of
Internal Affairs for the benefit of people and the environment. We expect your staff to make
direct contact with us.
Information

To this end, please contact us anytime to discuss how we can move forwards. Please feel
very welcome to contact me if you have any queries.  The best way to contact me is via mobile
9(2)(a)
or email 9(2)(a)
.

Official
Ngā mihi,

the

Sarah Ihaia-Chapman
under
Chief Executive
Ngā Maunga Whakahii o Kaipara Development Trust
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Hon Nanaia Mahuta
Minister of Local Government
By email only to:
[Nanaia Mahuta request email]
[email address]
15th November 2021
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Tēnā koe e te rangatira,
Three Waters Reform Programme
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As the collective iwi of Te Tauihu, we are writing to express our concern that as your Te Tiriti
partners and as iwi entities with which you have signiﬁcant post-settlement obligations, we
have not been adequately consulted nor listened to regarding the Three Waters Reform
programme.
As mentioned in previous discussions with you and your ofﬁcials, we do not agree with Te
Tauihu being included in the entity as currently proposed, and our expectation is that we
remain within an entity that includes the whole of Te Waipounamu.
Information
As you will be aware the Crown has important duties, including the responsibility of full and
adequate consultation with Iwi. Our expectation is that we are consulted about these matters
in detail, prior to any decisions being made about our region. We are concerned that the
decision to split Te Tauihu away from the rest of Te Waipounamu has been made without
adequate consultation and disregards our collective position as manawhenua iwi.
Official
Of equal concern to us is that the current proposal is based on boundary line assumptions that
do not consider, nor reﬂect, Te Tauihu interests. This approach is extremely disappointing and
the
unacceptable from our Te Tiriti partner who has legal obligations which are reﬂected in our
deeds of settlement as well as in Te Tiriti itself.
We welcome an open discussion directly with you on this matter.
under
Nā mātou noa, ngā iwi o Te Tauihu
____________________________________________________
Nā Anthony Little
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Chair, Ngāti Tama ki Te Waipounamu Trust
______________________________________________
Nā Rachel Hāte
Chair, Te Ātiawa o Te Waka-a-Māui

________________________________________________
Nā Olivia Hall
Chair, Te Rūnanga o Ngāti Rārua
____________________________________________________
Nā Melanie McGregor
Chair, Ngāti Koata Trust
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____________________________________________________
Nā Callum Katene
Chair, Ngāti Toa Rangatira
___________________________________________________
Information
Nā Waihaere Mason
Chair, Te Rūnanga o Ngāti Kuia
Official
____________________________________________________
Nā Hinemoa Connor
the
Chair, Ngāti Apa ki Te Rā Tō
under
____________________________________________________
Nā Calvin Hart
Co-Chair, Rangitāne o Wairau
____________________________________________________
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Nā Janis de Thierry
Co-Chair, Rangitāne o Wairau

31 January 2021

Sarah Jones
Secretariat
Te Tauihu Iwi Chairs Forum
[email address]
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Tēnā koutou ngā rangatira
Ānei e whai ake nei ko taku whakautu ki tō reta i tukuna mai i te (15 Maramamātahi 2021) e
Act
hāngai ana ki ōu nā whakaaro take Three Waters Reforms.
Thank  you  for  your  email  of  15  November  2021  regarding  the  Three Waters  Reforms  (the
Reforms).  I also want to thank you for sharing the concerns of ngā iwi o Te Tauihu with me
and  detailing  your  preference  regarding  the  boundary  of  the  proposed  the  Water  Service
Entities (WSEs).  The obligations of the Crown when it comes to the Treaty of Waitangi and
Treaty  settlements  has  been  a  driving  force  in  the  progress  of  the  Reforms  and  the
development of several of the proposed mechanisms.  Information
I recall from our earlier Zoom  and in person discussions that you have raised these issues
with me and my officials.  The boundaries of all the proposed WSEs are of interest to several
parties,  both  Councils  and  iwi.    I  felt  that  our  most  recent  discussions  of  the  proposed
boundaries had developed from the earlier hui, noting that the later discussions focused on
developing an understand of the practical components of how working across the boundaries
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would occur.
I have considered a range of factors to determine the number of proposed WSEs and their
the
boundaries. The key considerations have been to establish entities that:
  have a sufficient asset and customer base to be financially sustainable, operate at an
economically efficient scale, and deliver water services at an affordable price;

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  operate effectively in relation to water catchments and achieve desired environmental
outcomes, which is dependent on containing entire catchments within the boundaries of
entities. This will enable effective catchment planning and management of associated
infrastructure;
  understanding of rohe/takiwā boundaries and the importance of considering a Te Ao
Māori expression of kaitiakitanga through ki uta ki tai – the passage of water from the
mountains and great inland lakes, down the rivers to hāpua/lagoons, wahapū/estuaries,
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and to the sea;
  understand  and  reflect  relevant  community  interests,  particularly  where  there  are
existing economic or functional relationships or a shared identity between neighbouring
communities; and
  have access to a skilled local workforce.

As  you  are  aware  I  recently  announced  the  establishment  of  a  Working  Group  on
Representation, Governance and Accountability of new Water Services Entities, with Olivia
Hall, Chair of Te Rūnanga o Ngāti Rārua as one of the iwi representatives.  The role of this
Working  Group  is  to  examine  the  proposed  representation,  governance  and  accountability
arrangements for the new entities.  The Working Group will help develop solutions to concerns
relating to representation and accountability, and other critical issues.  It will report back in
March 2022, which ensures there is time for the advice and recommendations to inform the
final entity design.
Thank  you  for  extending  me  the  opportunity  to  have  an  open  discussion  on  this  matter.  I
happily  accept  your  offer  to  engage  and  discuss  the  Reform  and  other  aspects  of  your
feedback.  I will direct my office to work with the Secretariat to organise a date in the new year
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for this to occur.
I do see a path forward to address your concerns and finding a solution that is practical and
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effective.  I hope our continued engagement and the Working Group can provide direction for
these solutions, that are informed by your perspective.
Thank you again for writing.

Nāku noa
Information
Hon Nanaia Mahuta
Minister of Local Government
Official
the
under
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Statement of Support: Iwi/Māori Members of Three Waters Working
Group
9 March 2022
The Working Group on Representation, Governance and Accountability of the Proposed New
Water Services Entities (Working Group) has provided its report and recommendations (Report)
to the Minister of Local Government (Minister). This supporting paper is issued by the iwi/Māori
members of the Working Group (Iwi/Māori members).
The Iwi/Māori members wish to reconfirm their support of the Working Group’s Report and its
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recommendations. We believe that the recommendations in the Report will support the
provision of equitable, affordable, and high-quality water services for everyone while protecting
human health and ensuring the health and wellbeing of the environment.
Act
It is disappointing that much of the public commentary regarding Three Waters has been focused
on misunderstanding and misinformation regarding the issue of ownership. Contrary to some
views that have been expressed, the proposed reforms do not involve the seizure of assets or
disenfranchisement of communities.  Iwi/Māori know all too well what that looks like.  Like the
wider community, iwi/Māori are concerned about any suggestion of the privatisation of water
services, and this was a bottom line of our position as part of the Working Group. These are
Information
legacy assets that must remain publicly owned for the benefit of both current and future
generations.  To this end, we have supported the recommendation of the Working Group that
such public ownership is reflected by councils being the shareholding owners on behalf of their
communities of the water service entities and their assets.
Official
The issue of the ownership of water was also an area of focused concern for iwi/Māori and again
inaccurate statements have been made in some quarters. It is correct that there are unresolved
issues of iwi/hapū rights and interests in freshwater, however, those are separate matters to be
the
addressed between the Crown and iwi/Māori and are unconnected to these reforms. We
therefore made it clear to the Working Group, and this is reflected in the Group’s
recommendations, that the legislation should be explicit that nothing in the reforms creates or
transfers a proprietary interest in water or adversely affects iwi/hapū rights and interests in
under
water.
As part of the Working Group, we have also actively promoted the addition of mechanisms that
will further enable and ensure the participation and input of our communities, both Māori and
Pākehā, in the governance of our water services.  Co-governance by councils and iwi/hapū is
enabled through the establishment of regional representative groups for each water services
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entity, with the recommendation of sub-regional advisory groups that will enable an increased
input by councils, communities and iwi/hapū to issues at place.
These co-governance mechanisms are not only consistent with the principle of partnership under
Te Tiriti o Waitangi, but they will enable the skills, governance experience and local knowledge of
councils and iwi/hapū to contribute to the improved delivery of water services.  Iwi/Māori
members held a shared many other Working Group members that current and past problems in
1

relation to water services, which have adversely affected the environment and human health in
several regions, could have been avoided by making better use of the knowledge, skills and
mātauranga available within communities.
Consistent with the objective of working together with the common goal of improved water
services, we also strongly advocated for a governance model based on consensus decision-
making, and we are pleased that this recommendation was adopted by the Working Group in its
Report.
The central importance of Te Mana o te Wai is another matter on which the universal agreement
within the Working Group. Te Mana o te Wai is the fundamental principle that the health and 1982
wellbeing of our communities (including the provision of safe drinking water and the social,
cultural, and economic needs of our regions) are dependent on the future health and wellbeing of
our waterways.  To this end, the Working Group has recommended Te Mana o te Wai as the
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overarching korowai (cloak) for the delivery of water services under the new regime.
The application of Te Mana o Te Wai at all levels of the new framework, and input from iwi/hapū
through Te Mana o te Wai statements, will ensure that water services will be planned and
delivered with a new focus on the health and wellbeing of our regional waterways and their
interconnected ecosystems which demands improved efficiency and resilience in our Three
Waters infrastructure.  This is a key consideration for iwi/Māori, but is also an expectation and
Information
necessity for contemporary Aotearoa New Zealand as a whole as we rise together to meet the
challenges of the 21st Century. It represents a significant step-change towards ensuring
community wellbeing, environmental protection, and sustainable regional development for both
present and future generations.
Official
While we endorse the recommendations in the Working Group’s Report, there were three areas
where the Iwi/Maori members considered further measures were required, although consensus
the
could not be achieved around the table on these matters. Those three additional elements are:
1.  that the 50/50 representation between councils and mana whenua on the regional
representative groups should also extend to the appointment of board members to each
water service entity;
under
2.  that the boards of water service entities should operate on the basis of consensus
decision-making (with provision for a supermajority, if consensus cannot be reached); and
3.  that all persons exercising powers and functions under the Water Services Entities
legislation (including regional representative groups and water service entities) should be
required to give effect to Te Tiriti o Waitangi and its principles.
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We maintain these additional measures would result in better outcomes for all communities and
for Aotearoa New Zealand.  We therefore commend the Minister, when considering the Report
and recommendations of the Working Group, to also give careful consideration to the three
additional elements that we have identified above.
2

Finally, we wish to acknowledge that this process has been difficult, but rewarding.  The
discussions within the Working Group were frank and robust and we all benefited from the
information and perspectives that were shared.  Many voices were heard and options considered
and, while we did not agree on every issue, there was a clear agreement from everyone, including
council representatives, that the status quo is not working and that things must change to ensure
the long-term, safe and sustainable maintenance and delivery of water services throughout the
country.  We firmly believe the adoption of the Working Group’s recommendations will be a
significant step towards achieving this goal for the benefit of waterways, our communities,
iwi/Māori, and Aotearoa New Zealand as a whole.  As a nation, iwi/Māori and Pākehā, we simply
cannot afford to miss the opportunity for transformative change provided through these reforms.
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Kotahi te kōwhao o te ngira e kuhuna ai te miro mā,
te miro pango me te miro whero
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There is only one eye of the needle through which the white,
black and red threads must pass
Pōtatau Te Wherowhero, 1858
Nā mātou katoa
Iwi/Māori Members of the Working Group on Representation, Governance and Accountability
of new Water Services Entities
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Official
Ngarimu Blair
Huhana Lyndon
the

Tukoroirangi Morgan
Jamie Tuuta
under

Karen Vercoe
Ngahiwi Tomoana
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Olivia Hall
Barry Bragg

Gabrielle Huria

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Ngāti Manuhiri Settlement Trust

P.O Box 117. Warkworth 0910
2-4 Elizabeth Street, Warkworth, Auckland 0910
0508 MANUHIRI
[email address]
https://ngatimanuhiri.iwi.nz

30 September 2021,

Nanaia Mahuta
Minister
Email: [Nanaia Mahuta request email]
Copy to: Allan.Prangnel
1982
Email: [email address]
Copy to: Stuart Crosby, President LGNZ
Email: [email address]
Act

Tēnā koe Nanaia,

Re: Preliminary Feedback on the Three Waters Reform

Thank  you  for  the  opportunity  to  provide  preliminary  feedback  on  the  Three  Waters  Reform.  We
understand the Department of Internal Affairs is currently seeking preliminary feedback on the Three
Waters Reform Package.
Information

Our Understanding of Key Drivers and Core Objectives
We understand the Government launched a programme to reform local government three waters service
delivery arrangements in July 2020. Currently, 67 different councils own and operate the majority of
the drinking water, wastewater, and stormwater services on behalf of their communities; and that the
Official
Government  proposed  to  establish  four  new  publicly  owned  multi-regional  entities  (four)  to  deliver
these services.
the
Reviews into the delivery of three waters services in New Zealand have identified significant ongoing
challenges and a considerable level of underinvestment in three waters infrastructure
We also understand that the reform programme is being progressed through a voluntary partnership-
based approach with the local government sector, alongside iwi/Maori as the Crowns Treaty Partner.
The Three Waters Reform Programme is a major intergenerational project.
under
The over-arching aim is to ensure that New Zealand’s three waters – our drinking water, wastewater,
and  stormwater  –  infrastructure  and  services  are  planned,  maintained,  and  delivered  in  a  way  that
improves the health and wellbeing outcomes to benefit all communities in New Zealand and to ensure
that these networks are affordable and fit for purpose
Specifically, to:
Released
1.  Improve the safety, quality, and environmental performance of water services
2.  Ensure all New Zealanders have access to affordable three waters services
3.  Move the supply of three waters services to a more financially sustainable footing, and address
the affordability and capability challenges that currently exist in the sector
4.  Improve  transparency  about,  and  accountability  for,  the  delivery  and  costs  of  three  waters
services
1

5.  Improve  the  coordination  of  resources and  unlock  opportunities  to  consider  New  Zealand’s
water infrastructure needs at a larger scale and alongside wider infrastructure and development
needs
6.  Increase the resilience of three waters service provision to both short and long-term risks and
events, particularly climate change and natural hazards
7.  Provide mechanisms for enabling iwi/Maori rights and interests

Following extensive work since July 2020, we understand the Government has decided to pursue an
integrated and extensive package of reform to the current system for delivering three waters services
and infrastructure. The package comprises the following core components:
1.  Establish four  statutory,  publicly  owned  water  services entities to  provide  safe,  reliable, and
efficient water services
2.  Enable the water services entities to own and operate three waters infrastructure on behalf of
1982
local  authorities,  including  transferring  ownership  of  three  waters  assets  and  access  to  cost-
effective borrowing from capital markets to make the required investments
Act
3.  Establish independent, competency-based boards to govern each water service entity
4.  Set a clear national policy direction for the three waters sector, including expectations relating
to the contribution of water services entities to any new spatial / resource management planning
processes
5.  Establish an economic regulation regime to ensure efficient service delivery and to drive the
achievement of efficiency gains, and consumer protection mechanisms
6.  Develop  an  industry  transformation  strategy  to  support  and  enable  the  wider  three  waters
industry to gear up for the new water services delivery system

Information
We also understand the Government has committed to working closely with local government and treaty
partners to help increase chances for success and ensure the new water service entities are operational
by 1 July 2024. Further to the initiatives (above), we also understand that in mid-July 2021, the Prime
Minister  and  Minister  of  Local  Government  announced  a  comprehensive  $2.5  billion  three  waters
support package. The package has three financial components.
Official
1)  Support for local government to invest in communities wellbeing. This part of the investment
totals $2billion, with $500 million being available from 1 July 2022. It will be allocated between
the
councils according to a nationally consistent formula, reflecting population (75%), deprivation
(20%), and land area (5%).
2)  Targeted support to ensure that no councils are financially worse off as a result of transferring
their  three  waters  assets.  This  is  designed  to  protect  councils  from  any  negative  financial
under
consequences of the asset transfer.
3)  Cover  of  reasonable  transition  costs.  This  is  intended  to  make  sure  council  service  delivery
(including water services) during the transition isn’t compromised by the work needed to make
the transition happen.

We understand  that  no  formal  decisions are required  at this stage.  However,  that  the  Department  of
Internal Affair is seeking preliminary feedback on the: 1) potential impacts of the proposed reform; and
Released
2) how it could be improved.
Our Approach and Methods
To evaluate requirements, we are currently undertaking a comprehensive package of works that includes
undertaking a detailed literature review of local government legislation and requirements relating to the
management of water and wastewater (Watercare Services Limited) and stormwater in the Auckland
Region; and review the efficacy of water, wastewater, and stormwater delivery in Northland ie areas
pertaining to the proposed “Entity A.” We are currently working closely with all Mana Whenua Entities
2

in the Auckland Region (19), and Auckland Council. Our intention is to broaden our discussions with
Te Tai Tokerau and Waikato over the coming weeks.
Our Preliminary Feedback
Given the breadth of the Three Waters Reform Programme, we are currently focusing our feedback on
four Potential Impacts and associated Areas for Improvement (see Table 1 below).
Important Note:  These  Potential  Impacts and  Areas for  Improvement  (also see  Table  1  below)  are
based on  our  preliminary  work;  and we anticipate  identifying  additional  feedback areas as we  work
through the proposal.
Table 1: Identified Potential Impacts and Areas for Improvement
Potential
Topic
Areas for Improvement
Impacts
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1
Governance
•  Partnership arrangements
and Entity
•  The  degree  to  which  Iwi  Mana  Motuhake  has  been
Boundaries
acknowledged
Act
•  The degree to which water is recognised as a taonga
•  The  degree  to  which  the  reforms  protect  Treaty
Settlements and initiatives
•  Rectifying  inherent  flaws  in  the  broader  Strategic
Management Framework
•  Boundary  issues  and  rationale  relating  to  Entity  A  –
Tāmaki Makaurau and Te Tai Tokerau
•  Boundary issues need to consider water supply
Information
•  Assumptions underlying development of the Entities  are
fundamentally flawed
•  Engagement to date has been poor, the expectation is that
the Crown will work closely with Mana Whenua entities
•  Will need to make provision for significant resourcing to
Official
help ensure the proposed model is workable
2
Te Mana o te
•  Statutory, regulatory, and policy definition of Te Mauri /
the
Wai
Te Mana o te Wai
•  Engagement with  mana  whenua  relating  to  the  National
Policy Statement - Freshwater
3
Proposed
•  The degree to which proposed reforms work together to
under
Reform
achieve desired outcomes
Alignment and
•  Scoping  Key  Drivers  (and  related  constraints  and
Intent
opportunities)
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Operational
•  Three Waters servicing outcomes
Preparedness
•  Management of constraints and opportunities
•  Lack of engagement with mana whenua to help manage
Released
change
•  Feasibility of achieving proposed reforms and their
associated requirements by 2024

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Key Messages
Please note our key messages:
1.  Water as a taonga needs to be central to all decision-making
2.  The  Three  Waters Reform  need  to  be  founded  on  a  holistic  framework  that  captures social,
economic, cultural and environmental aspirations of both partners and it needs to be founded
on a robust framework for success
3.  We  are  keen  to  work  closely  with  the  Department  of  Internal  Affairs  as  Treaty  Partners  to
achieve mutually beneficial outcomes, please contact us directly
4.  We  expect  to  be  adequately  re-imbursed  for  our  time  and  resources  to  work  with  you  on
developing mutually beneficial outcomes.
Next Steps
It is our intent that we form a highly collaborative working partnership with the Department of Internal
Affairs for the benefit of people and the environment. We expect your staff to make direct contact with
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us.

Act
To this end, please contact us anytime to discuss how we can move forwards. Please feel very welcome
to contact me if you have any queries. The best way to contact me is via mobile 9(2)(a)
or email
9(2)(a)


Ngaa mihi,

Information
Terrence (Mook) Hohneck
Chairman
Ngāti Manuhiri Settlement Trust
Official
the
under
Released
4

22 February 2021
Hon Nanaia Mahuta
Minister of Local Government
Parliament Buildings
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Wellington
[Nanaia Mahuta request email]
Act
Tēnā koe e te Minita
Three Waters Reform - Consultation
The Canterbury Mayoral Forum and Ngāi Tahu are partnering in a review of the Three Waters
service delivery arrangements across Canterbury in response to the Governments Three Waters
Information
Reform agenda. The review has been commissioned to provide councils and mana whenua with a
clear understanding of the Three Waters assets within the region, and the options available to
them for Three Waters service delivery and funding arrangements.
Simultaneously all Canterbury councils have opted in for the first tranche of the Three Waters
Official
Services Reform Programme and are engaging proactively in this first phase of reforms. Five of the
ten Canterbury councils have responded to DIA’s detailed request for information.
the
The Canterbury Mayoral Forum and Ngāi Tahu are very concerned about the lack of true
engagement with both local government and iwi in the reform programme, and in particular the
news that the next round of consultation, scheduled for March, is unlikely to include the detailed
analysis that is being prepared, and that there is unlikely to be further consultation before advice is
under
provided to Ministers in mid-2021.
The agenda for the engagement scheduled for March, clearly shows a significant level of detail for
attendees to absorb, and then comment on. There needs to be time for attendees to take this
information away and discuss with their councils and/or iwi before being able to comment in a
meaningful way. We are also aware that the dates proposed for engagement do not suit a number
of critical attendees as they clash with council meetings and other commitments.
Released

The Canterbury Mayoral Forum and Ngāi Tahu request that there is an opportunity for further
engagement following the March dates, which provides for councils and Ngāi Tahu to respond to
the information provided and also engage on options for Three Waters that come from the review
being undertaken by The Canterbury Mayoral Forum and Ngāi Tahu.
We would welcome a meeting with you to further discuss our concerns.

Ngā mihi
1982

Act

Sam Broughton (Mayor Selwyn District)
Dr Te Maire Tau
Chair, Canterbury Mayoral Forum
Ūpoko Information
Ngāi Tūāhuriri

Official

the
under
Released
Page 2 of 3

Document Outline

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