Our questions for the government

The 22 councils that comprise Entity B provided feedback to the government on 29 September 2021. View the letter to the Minister of Local Government(PDF, 132KB) and the accompanying survey report(PDF, 1MB).

Whanganui District Council's feedback and questions for the government were as follows:

  1. Whanganui fully supports the issue that has already been raised, i.e. that councils’ plans for growth, as reflected in spatial plans, district plans or LTPs, are appropriately integrated with water services planning (we understand this has been addressed in the latest documentation release).
  2. Whanganui also supports the position of many councils that these reforms, which are the most significant in the past thirty years, are progressing too fast to enable all stakeholders to fully engage in the process and understand the impact on local communities. The three waters reforms are happening alongside other major reforms, such as the Future of Local Government and the Resource Management Act. It seems more appropriate to work through the Future of Local Government and then, in that context, to consider the impact of three water reforms.
  3. If the reforms remain voluntary for local authorities there will need to be sufficient time for councils to fully engage and consult with their communities. The public advertising being undertaken by central government is woefully inadequate to meet any form of local community engagement and consultation.

Financial modelling

  1. Whanganui accepts the case for the need for reform at a national level and that the amount of investment that is needed at a macro level. The issue for Whanganui (and many councils) is that the macro model has been applied at a micro level, i.e. based on population and density as opposed to actual requirements of individual councils based on asset condition etc.  The model for Whanganui has a yearly enhancement amount of $35M, which we have difficulty accepting given the significant investment Whanganui has made in its three water networks over the past 20 years. In addition this amount suggests that Whanganui will, at least in the short to medium term, be subsidising those councils that have not invested in their three waters.
  2. Further to Q.4 – during this eight-week period councils are being asked to fully understand the proposal and how it affects them and their communities. The difficulty we have in understanding the future impact for Whanganui is that there has been no detailed information released on what the new regulations for all three waters, including those of an economic regulator, will look like.  The WICS financial numbers showing costs to ratepayers for those councils that opt out of the reforms are difficult to understand in the absence of this critical information.


  1. There needs to be some equity between those councils that have been diligent and invested in their water assets to those that have not. Whanganui has sold community assets to pay for the significant investment it has made in its water networks, whereas some of our neighbours have underinvested in their water networks. How is this going to be recognised in the transfer of assets?


  1. Most of the material that is available from the Department of Internal Affairs on the assessment of the investment that is needed in New Zealand ($120-$185B) has been around potable water and wastewater. We also understand WICS is involved in only these two waters and not stormwater.
    The questions we have on stormwater are:
    • Approximately what portion of the estimated $120 - $185B relates to stormwater and how was this quantum determined? 
    • What mechanisms will there be for communities to influence stormwater policies of the entities and regulators?
    • Is there an overall goal to have all New Zealand conform to one universal standard (LOS is part of this and noting that both potable and wastewater will have to meet national standards).  This question seeks an answer to whether, or not, the entities will eventually all have to discharge stormwater to a single prescribed standard or will they even have to meet a single standard within their entity?
    • Councils may use road reserve, recreational and undeveloped land as storm event flooding/bund areas and/or develop wetlands to attenuate storm water flows. What incentives and funding will be provided to incentivise councils to continue this (ecologically and economically sound) approach rather than utilising council assets solely to deliver purely recreational amenity or fiscal return to our communities? 
    • In relation to the above, what social/wellbeing outcomes may councils expect/require of water entities in delivering their services? 

Commercial businesses

  1. For a community such as Whanganui, our large businesses, including our trade waste businesses are a vital part of our economy. We have worked hard with these businesses, including offering competitive rates, to ensure they remain in Whanganui. We do not want to lose these businesses due to a new water entity not appreciating the importance of them and charging non-competitive prices. Currently there is little information on the impact and proposed charges for businesses and trade waste customers in the reforms.
    Questions we have in relation to this are:
    • What certainty and protection is proposed to ensure these businesses are not disadvantaged by the reforms?
    • Will there be any mechanism to prevent the water entities from trying to attract larger users of three waters away from one entity to another i.e. poaching?
    • Whanganui uses a marginal cost approach to charging major trade waste businesses for waste water services. Will these locally agreed charging methodologies be continued by the new water entities?

Development Contributions

  1. We have just updated our development contributions policy with a number of three water growth projects to be funded via development contributions over the next 10 years. This means, for sections developed in the next three years, development contributions will be charged by the council, however there could be some inequities for sections developed after 1 July 2024 as the council will presumably no longer be charging development contributions for these.
    • Will the new entities charge development contributions or something similar?
    • Should councils continue to charge development contributions for three water projects for the next three years?
    • Will the new entities take over the legal responsibilities to deliver on projects that development contributions have been charged for?


  1. Within Entity B there are 22 councils.  These councils will appoint six representatives to the Regional Representative Group. There is no mention of how this process will work.
    • Has consideration been given to how this process will work, and if so please elaborate?
    • How will Whanganui ensure it has a local voice within this group?
  1. In the same manner as above, what is the process for the appointment of the remaining six representatives appointed by Mana Whenua?
  2. What is the process or mechanism for removing group appointments where it is perceived the Regional Representative Group is not functioning properly?