To: Michael McCartney, Chief Executive Officer, Horizons Regional Council
Cc: Rachel Keedwell, Chair, Horizons Regional Council
Cc: Bruce Gordon, Former Chair and Current Audit Committee Member

It is with considerable concern that I read HRC’s response to Mr. Paver’s recent LGOIMA request, where the Council indicated that key legal and grant-related documents were deleted under the Public Records Act (PRA) 2005. Of particular concern is that the LGOIMA was addressed To: Michael McCartney, Chief Executive Officer, Rachel Keedwell, Chair and Bruce Gordon, Former Chair and Current Audit Committee Member and presumably they have reviewed the response.

For this reason i also address this LGOIMA to the same parties that they may address my concerns
From my understanding of the PRA 2005 and other relevant New Zealand legislation, this response raises serious legal and procedural issues. Specifically, it appears that HRC may have breached legislation and guidelines from Archives New Zealand, the Department of Internal Affairs (DIA), and the Office of the Auditor-General, particularly in relation to the transparency and accountability required in grant management.
1. Legal and Recordkeeping Concerns
1.1 Retention Period Misapplied
• Under Archives NZ and PRA 2005, grant-related records must be retained for 7 years after the last action, not from the creation date.
• “Last action” includes final payment, audit of a programme of work, or reporting.
• Grant monies for an EFP completed in 2016 would require records to be retained at least until 2023.
• Where Grants are associated with land use and environmental considerations I understand the retention is longer >10 years after last use or permanent retention.
1.2 Complaint Triggers Record Protection
• Per Section 18(1)(a) of the PRA 2005:
“Public offices must maintain full and accurate records, especially where matters are subject to review, complaint, audit, or legal inquiry.”
• When Mr. Paver raised a complaint with the HRC CEO in 2019, all related documents — including the signed EFP agreement, funding approvals, Derek Ryan’s notes, and internal evaluations — became protected. These records should not have been deleted.
1.3 Protected Records – Class 2.13
• Under Archives NZ guidance, Class 2.13 includes:
• Grant applications
• Signed authorisations
• Final grant documentation
• These records are protected and cannot be destroyed without formal notice to the Chief Archivist.
2. Broader Governance and Audit Obligations
2.1 Financial Recordkeeping and Audit Requirements
Under the Public Records Act and guidance from the Auditor-General:
• Councils must keep a register of all grants awarded.
• Supporting documentation must be retained and available for audit. (ie: Derek Ryans visit and signed up documentation)
• Grant processes must be open and transparent.
2.2 DIA and OAG Grant Management Standards
• DIA and Auditor-General policies emphasize public accountability, integrity in grant approvals, and full transparency of public funds.
2.3 Transparency Failures in HRC’s Published Data
• A review of HRC’s published grant data indicates gaps in disclosure, undermining transparency obligations.
• The purpose of such legislation is to protect public trust and ensure governance is free from bias or mismanagement.

3. Formal Requests Under LGOIMA
I request the following under the Local Government Official Information and Meetings Act 1987 (LGOIMA):
3.1 Recordkeeping and Retention Policies
1. A copy of HRC’s retention and disposal policy including grant and contract records and were complaints have arisen.
2. HRC’s internal procedures for safeguarding records after a formal complaint has been received.
3. Confirmation of whether it is standard HRC practice to delete grant application and supporting documents after 7 years, regardless of complaint, audit, or land-related relevance.
3.2 List of Grant Recipients (2010–2024)
Please provide a list of all recipients (individuals or organisations) who received grant(or gifts) funding from Horizons Regional Council or the Manawatū River Leaders Accord between 2010 and 2024 for:
• Fencing
• Planting
• Whole of Farm Plan-related works
For each grant, please include:
• Name of recipient (individual
• Name of farm or organisation
• General location (
• Date approved and/or paid
• Amount of grantor gift (public monies /rates contribution)
• Purpose (e.g., hill fencing, riparian planting)
3.3 Withholding Justification
If any portion of this information is withheld, please:
• Specify the clause under Section 7 of LGOIMA being relied upon
• Explain how the harm from disclosure outweighs the public interest in transparency
3.4 Existing Lists
I note reference to pre-existing lists of grants and recipients, which should make this request straightforward to fulfil.
Ngā mihi

Agnes M