1 April 2026
File Ref: OIAPR-1274023063-48983
Miss M Quicken
By email:
[email address]
[email address]
[email address]
[FYI request #34174 email]
Tēnā koe Miss Quicken
Request for information 2026-117
I refer to your four requests for information dated 20 March 2026, which were received by
Greater Wellington Regional Council (Greater Wellington) on 20 March 2026. You have
requested the following:
“
Please provide
A) the report / other document council has relating to SuperGold scheme funding gap from the
previous financial year.
B) Projections from revenue loss due to SuperGold funding gap for current or next FY
C) Risk register identifying the shortfall on SuperGold funding gap as well as the inability to
identify the shortfall in question acting as causation for revenue loss”
And
“
A) Current training materials provided to the bus drivers on how to deal with SuperGold
B) Policy / strategy document that outlined why council chose the option of not requiring
SuperGold users to register through snapper which then can be used to authenticate and verify
the user
C) Briefing and any other material that formed the basis of treating SuperGold holders differently
from the rest of the population, who both need a registered snapper and go through the process
of tagging on and off.”
Wellington office
Upper Hutt
Masterton office
0800 496 734
PO Box 11646
PO Box 40847
PO Box 41
www.gw.govt.nz
Manners St, Wel ington
1056 Fergusson Drive
Masterton 5840
[Wellington Regional Council request email]
6142
And
“
A) The options document provided to council - on which basis the council made the decision
was made to delay SuperGold registration requirement until the National Ticketing Solution
(NTS) is deployed
B) The minutes or such document which documented both the decisionmaker/s and the
decision itself to delay it for at least a year
C) Impact assessment of the decision adopted”
And
“
Please provide the strategy document that outlined the revenue recovery options provided for
the council to maintain the ticketing system in the bus network.
Also please provide the risk register & impact assessment documents which includes the item
of not using transport officers in the bus networks and the financial risks associated of not
applying fare enforcement.”
Greater Wellington’s response follows:
Your request has been assessed under the Local Government Official Information and Meetings
Act 1987 (the Act).
The report / other document council has relating to SuperGold scheme funding gap from
the previous financial year.
And;
Projections from revenue loss due to SuperGold funding gap for current or next FY
And;
Risk register identifying the shortfall on SuperGold funding gap as well as the inability to
identify the shortfall in question acting as causation for revenue loss
Greater Wellington emailed you on 23 March 2026, requesting clarification on your phrase of
“SuperGold Scheme Funding Gap”. As we received no response to our request for clarification
we have interpreted these requests to the best of our ability.
As noted in our response to your information request 2026-056, the SuperGold concession is
funded by central government and so therefore no revenue is lost by Greater Wellington through
providing this concession.
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As noted by yourself in your email titled “Official Information request - SuperGold bulk funding
gap revenue loss from last FY & projection next FY” SuperGold funding switched to a bulk
funding scheme, which occurred in 2016. Funding is provided by central government based on
patronage projections and adjusted in the following year based on the difference between
funding provided and recorded patronage. While we are aware of the possibility of some
SuperGold passengers not being recorded properly in the Snapper system occasionally due to
operators not manually recording every SuperGold passenger as required, we do not believe
this is a significant amount and is unlikely to meaningfully affect funding received.
Additionally, the SuperGold concession is only available on off-peak travel, which is when
services traditionally have available seating.
Greater Wellington does not consider that there is a SuperGold scheme funding gap, and as
such the documents you have requested (report, other document, projections, and risk
register) do not exist. Therefore, we are refusing these parts of your request under section 17(e)
of the Act on the basis that the document alleged to contain the information requested does
not exist or, despite reasonable efforts to locate it, cannot be found.
In refusing these parts of your request under section 17(e) of the Act we have considered if
consulting would assist you to make the request in a form that would remove the reason for the
refusal. In attempting to consult with you on this request we have fulfilled our obligations under
this section of the Act.
Current training materials provided to the bus drivers on how to deal with SuperGold
All bus drivers on the Metlink network are directly employed by the operators, who are
contracted by Greater Wellington to provide public transport services across the network.
From an employment perspective, bus drivers are not considered employees of Greater
Wellington. All training responsibilities and documentation for bus drivers is therefore owned
and held by the operators.
Copies of training documentation for bus drivers is not held by Greater Wellington. As a result,
we are refusing this part of your request under section 17(g) of the Act on the basis that the
information requested is not held by Greater Wellington and we have no grounds for believing
that the information is either—
(i)
held by another local authority or a department or Minister of the Crown or
organisation; or
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(ii)
connected more closely with the functions of another local authority, or a
department or Minister of the Crown or organisation
Greater Wellington is aware of instructions provided to Operators by Snapper on how to enter a
SuperGold passenger into the system. We have provided this as
Attachment 1. Please note,
this document was created by Snapper and includes some incorrect information regarding
SuperGold free travel periods being set by Greater Wellington. The periods where SuperGold
funding is provided is set by central government. Councils can choose to fund any extension to
those periods themselves, however, at this time Greater Wellington does not fund beyond the
period set by central government.
Any other direction to operators on this matter is included in the contract between them and
Greater Wellington. Greater Wellington has published our contracts with bus and rail operators
on our website;
you can access them through the following link:
www.gw.govt.nz/transport/metlink-bus-train-and-ferry/public-transport-contracts/
Policy / strategy document that outlined why council chose the option of not requiring
SuperGold users to register through snapper which then can be used to authenticate and
verify the user
And;
Briefing and any other material that formed the basis of treating SuperGold holders
differently from the rest of the population, who both need a registered snapper and go
through the process of tagging on and off.
And;
The options document provided to council - on which basis the council made the decision
was made to delay SuperGold registration requirement until the National Ticketing
Solution (NTS) is deployed
The SuperGold concession predates the implementation of Snapper on the Metlink Network.
SuperGold card was introduced in August 2007 while Snapper was introduced commercially by
New Zealand Bus to its services in July 2008, and by Greater Wellington to the whole Metlink
bus network in 2018.
Due to limitations from the Snapper system, dating back to its implementation, it is not possible
for integration of SuperGold cards. While this limitation could now be remedied, the
reprogramming necessary would be obsolete once the National Ticketing System (NTS) rollout
is complete. Additionally, this would require passengers using SuperGold cards to register
twice, once with Snapper and then again with NTS. To mitigate the effort and confusion for these
customers, we have opted to wait until the rollout of NTS is complete.
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The rollout of the NTS system across New Zealand is being led by NZ Transport Agency Waka
Kotahi (NZTA). As a part of the NTS initiative, there is clear intention to permit for the cross
registration between SuperGold card holders and NTS card holders, and the new system will be
designed to accommodate this.
As the concession is funded by central government based on the quantity of concessions
issued, it is a requirement that Greater Wellington track the number of concessions. As the
integration with Snapper is not currently available this necessitates the current process of bus
drivers manually entering SuperGold passengers.
Greater Wellington considers that the documents you have requested (strategy / policy
document, briefing and other material, options document) do not exist. Therefore, we are
refusing these parts of your request under section 17(e) of the Act on the basis that the
document alleged to contain the information requested does not exist or, despite reasonable
efforts to locate it, cannot be found.
In refusing these parts of your request under section 17(e) of the Act, we have considered if
consulting would assist you to make the request in a form that would remove the reason for the
refusal. We have considered this and do not believe consulting with you would assist in relation
to the material you have requested.
The minutes or such document which documented both the decisionmaker/s and the
decision itself to delay it for at least a year
And;
Impact assessment of the decision adopted
The rollout of the NTS system across New Zealand is being led by NZTA. Greater Wellington
considers that information on delays to the rollout of the NTS is held by, and is more closely
connected to the functions of, NZTA.
As such pursuant to section 12 of the Act, Greater Wellington transferred these parts of your
request to NZTA on 24 March 2026. A letter advising you of the transfer was provided to you on
that same day.
The strategy document that outlined the revenue recovery options provided for the council
to maintain the ticketing system in the bus network
And;
The risk register & impact assessment documents which includes the item of not using
transport officers in the bus networks and the financial risks associated of not applying
fare enforcement
Page 5 of 6
Greater Wellington considers that the documents you have requested (strategy document, risk
register and impact assessment documents including items outlined) do not exist. Therefore,
we are refusing this part of your request under section 17(e) of the Act on the basis that the
document alleged to contain the information requested does not exist or, despite reasonable
efforts to locate it, cannot be found.
In refusing these parts of your request under section 17(e) of the Act we have considered if
consulting would assist you to make the request in a form that would remove the reason for the
refusal. We have considered this and do not believe consulting with you would assist in relation
to the material you have requested.
If you have any concerns with the decision(s) referred to in this letter, you have the right to
request an investigation and review by the Ombudsman under section 27(3) of the Act.
Please note that it is our policy to proactively release our responses to official information
requests where appropriate. Our response to your request will be published shortly on Greater
Wellington’s website with your personal information removed.
Nāku iti noa, nā
Paul Tawharu
Kaiwhakahaere Matua Waka-ā-atea | Acting Group Manager Metlink
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