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
Subject: LGOIMA Request – Riparian Fencing and Planting Grants, Gifts, and Contributions
Dear Mr. McCartney,
Thank you for your letter dated 15 September 2025.
However, I must respectfully dispute several key assertions. I have responded to Horizons Regional Council (HRC) on numerous occasions regarding these matters. This is clearly evident to any objective reader reviewing my prior correspondence via FYI.org.nz — particularly if they read both the content of my requests and the full substance of HRC’s replies.
It is increasingly apparent that HRC’s attempts to summarise or reframe my LGOIMA requests omit key queries and ignore critical context. I have no issue with genuine requests for clarification, but I ask that all communications reference the FYI request ID and directly address the relevant bullet points. When HRC does reply it is invariably on the last statutory date and usually without substantive response, this and transparency are the main reasons for raising separate LGOIMA to keep focus on the context and avoid extensive delays.
Below I summarise several concerns with HRC’s position and reiterate my request for full disclosure of the information sought — in unredacted form — as required under LGOIMA and consistent with guidance from the Ombudsman, Department of Internal Affairs (DIA), and Auditor-General.
1. Background and Prior LGOIMA Correspondence
1. I have repeatedly requested full details of communication and documents relating to the EFP, all grants, gifts, and contributions issued by HRC, especially through the Manawatū River Leaders’ Accord and related riparian fencing and planting initiatives. In 2018 Grant Cooper reaffirmed there was no grants or funding related to my Farm and expressed ignorance on the origins of the ERP, it now appears he was an author in the quarterly environmental reports on progress of the programme initiatives and EFP’s.
2. On 19 October 2022 (via FYI.org.nz), I explicitly requested this grant funding information for each year.
In November 2022, Logan Brown responded with only a partial list of community grants for the 2022 year only.
3. On 2 July 2025, I submitted a LGOIMA re:-HRC’s Derek Ryan apparent signing a landowner agreement for our farm without the knowledge of the actual elderly landowners, effectively depriving the elderly owners of the service and associated fencing grants despite the owners paying the worker for fencing which was clearly eligible for grants.
4. On 29 July 2025, HRC responded that all records had been deleted under the Public Records Act 2007 after 7 years. The actual legislation is the Public Records Act 2005 (PRA) which contains no reference to seven year periods. It is concerning that this response was based on non-existent statutory provisions. It is also concerning that, as set out below, this forms part of a pattern of mis-citation of statute and regulations.
HRC did provided a copy of the 65-page EFP document, which reinforced that significant public monies had been spent some of which contracted to third parties.
5. Between 30 July to 8 August 2025, I responded, highlighting that the requested records related to grants, meetings with landowners, and signed agreements — all of which should be considered protected records under the PRA due to their connection to the disbursement of public funds (including from MfE), and to an earlier concern of possible fraud which I raised in 2019 directly with HRC’s CEO and Chair.
2. Recordkeeping and Deletion Concerns
2.1. On 29 August 2025, HRC now advised:
1. All the Records were deleted after only 3 years under ALGIM 2021 Disposal Authority Z23.5.5.
2. Files were bulk deleted by folder and no record or log of deleted files is kept.
3. HRC does not record who authorised the disposal of files.
4. In response to Ms. Agnes M.'s query about protected records related to concerns of fraud , HRC claimed deletion was in accordance with ALGIM 2021 and stated that it would consider developing policies in the future….
2.2. I must stress that:
1. Z23.5.5 relates to internal administrative meetings — not external meetings or agreements that underpin public funding and contractual obligations.
2. Such records fall under protected classes (e.g. Z8.14) and should have been preserved — especially where public money is involved or concerns of financial irregularities are raised.
3. HRC’s mass deletion of information/records without any record of what was deleted or when deleted or on whose authority appears to encompass meetings, agreements, and communications associated with approximately 87 farms visited by and signed up by Derek Ryan, impacting up to $5.2 million in MfE funding — part of a broader $30 million public programme.
3. HRC’s 15 September 2025 Response – Summary of Concerns
1. A grant panel was only established in 2024.
2. Prior to that, Team Leaders or Managers made grant decisions.
3. HRC refused to disclose the total funding pool, claiming it is published in the Annual Report (without granularity).
4. HRC refused to disclose names of grant recipients or HRC officials involved in approving grants, citing privacy.
4. Privacy and Transparency
4.1. HRC has previously disclosed names of grant recipients — including partial response from Logan Brown to my 2022 FYI request.
4.2. On 16 August 2024, Dr. Jon Roygard claimed that all relevant information had been provided; this was demonstrably untrue. Only partial records were released.
4.3. HRC has published names in public forums — e.g., the Bush Telegraph on 14 March 2022 refers to a $15,000 grant/gift and mentions the recipient receiving multiple grants. These grants/gifts were not apparent in disclosed recipients.
Thus, HRC’s current invocation of privacy appears inconsistent and selective. Earlier responses offered the information either in full or in part, or offered to release it subject to payment — not privacy concerns. Further, any privacy concerns are outweighed by the public interest in transparency and accountability.
5. Grant Totals and Traceability
5.1. While HRC claims total funding is disclosed in Annual Reports, there is:
1. No traceability to individual grants, recipients, or purposes.
2. No reconciliation with internal approvals or external disbursements.
6. Authority and Governance
6.1. Please provide:
• The authorisation limits for Team Leaders and Managers who approved grants 2101 to 2024.
• The names of HRC officials who authorised each grant or gift.
6.2. I reiterate that I have raised concerns about potential misuse of funds, and the mass deletion of underpinning records raises significant questions about financial probity and public accountability.
7. Risk of "Salami Slicing" and Circumvention of Controls
7.1. I understand that a panel is now required for grants over $20,000.
7.2. There is a public interest in identifying whether previous disbursements were structured to fall below scrutiny thresholds — a common risk referred to as “salami slicing.”
8. Ombudsman Precedent – Case 446391
The Ombudsman has clearly ruled (Case Ref. 446391) that where public money is involved, the low privacy interest in names of individuals is outweighed by the public interest in transparency and accountability. This ruling was in relation to guest lists for council-funded events — a far less significant use of public money than grant disbursement under a $30 million programme.
9. Conclusion and Request
Given the above, I respectfully request HRC respond to my previous LGOIMA in full including:
1. Full and unredacted disclosure of all grant recipients, with name amounts, dates, and approving officials.
2. Disclosure of the funding pools used and criteria applied.
3. Confirmation that all decisions were consistent with proper delegation and public sector financial controls.
Failure to provide this information undermines public confidence and is inconsistent with LGOIMA, the Public Records Act, and best practice guidelines issued by the Ombudsman, DIA, and the Auditor-General.

4. Please also Provide the Names and positions of the HRC Officials who have responded to my LGOIMA requests.

Yours faithfully,

Gerard Paver

I acknowledge a typo on
6. Authority and Governance
6.1. Please provide:
• The authorisation limits for Team Leaders and Managers who approved grants 2101 to 2024.

the dates should be 2010 to 2024

Yours sincerely,

Gerard Paver