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Not enough time, too little information, and no sign of any plans for rigorous public consultation. Those are some of the failings of the Three Waters Reforms the Government is proposing, according to a submission by the Horowhenua District Council.
Its response to the proposal from Wellington will be debated in Wednesday's council meeting, from 2pm.
Horowhenua believes there are better and more workable models that need exploring.
Given that several other reforms are in progress, on the Resource Management Act and local government, Horowhenua's submission said all these reforms will have a bearing on the three waters and it considers "the sequencing of three waters reform ahead of the finalisation of the future of local government review is ill-considered and inappropriate".
Its submission expresses concern about the "current lack of democratic accountability and the fact that local government may have limited ability to influence the make-up of the board and the performance expectations".
Locally major decisions require councils to consult with communities, and iwi and Horowhenua's council believes the proposed three waters new entity must consult iwi and local communities as well as local government.
Horowhenua believes it is on top of infrastructure despite its fast growth in population, having earmarked $231.7 million (including $191m for three waters) across housing development areas. It said it has achieved close to full irrigation of wastewater to land and has safe water supplies.
While Horowhenua has planned for this growth, it fears this planning may in danger if it has to compete with others as a result of reforms.
....sequencing of three waters reform ahead of the finalisation of the future of local government review is ill-considered and inappropriate...
A major concern is the lack of information and the absence of plans for public consultation.
"We want our community to be engaged with significant decision making regarding three waters infrastructure, at a minimum at the level council currently conducts community consultation."
The proposed structure for each of the four three waters entities allows for only 12 board members each and this would leave many councils and iwi not represented, Horowhenua observes.
"We believe there are other credible and workable models and approaches that should be explored as an alternative."
Three waters, drinking water, stormwater and sewage, are intertwined with many aspects of life and council's services. Housing affordability is impacted by any three waters' reform, Horowhenua warns.
Its list of recommendations is extensive and includes: any new three waters entity must promote community resilience, must be able to meet reasonable response times, must consider affordability when setting charges, must collaborate with local councils and offer rates relief, but local government reforms must occur first, and any three waters entity plans must support existing and future local plans,and must follow consultation requirements similar to those of councils, development contributions collected must benefit the region where they are collected and the new entity must have an investment prioritisation framework.
Horowhenua is urging the Government to investigate Tasmania's water model. Government's current proposals are based on water reforms from Scotland.
Horowhenua would like the new entity to be required to develop an infrastructure strategy/financial strategy as well as detailed 30-year plans in line with the Local Government Act and have minimum underpinned quantity investment per annum in water infrastructure.
Government should consider alternatives to the funding of infrastructure and said the new entity must be a centre of subject matter excellence rather than focus just on infrastructure planning and delivery, Horowhenua suggested.
"It is imperative that the Government consults with the public before a decision is made. Our community has concerns around issues such as additional charges and future privatisation."
Alternative options for delivery HDC has identified include taking a regional approach, such as collaboration between smaller councils. Horowhenua already has a structure in place for its three water management and that could be extended into neighboring councils. A council-controlled organisation dealing with multiple councils could be looked at.
Horowhenua's alternative funding proposal suggests keeping the three waters at councils but provide alternative funding, so council can afford them and does not need rely on ratepayers.
Increasing the debt ceiling, or providing direct central government funding are among the options suggested.
Horowhenua would like further engagement on opportunities and practicalities of a targeted reform programme and delivery model for our region.
Horowhenua already has multiple projects under way and for the next 10 years is planning to spend $44m on water supply, $119m on wastewater and $27m on stormwater.
"The process of unbundling water assets, liabilities and associated contracts and staff will technically and legally complex and as three waters touch on many other aspects of council services and the boundaries are not always clear."
While equity seems key to the reforms proposed there is little information on how this will be achieved. Horowhenua's submission also expresses concerns about what impact the change in charging for water services will have on local businesses.
Currently Horowhenua has 70 staff involved here and it expresses concern that a larger entity could bypass local contractors or may lead to smaller margins for them, as well as loss of sustainability. Most of all it pleads for giving the community "a simple and clear way of contacting water service providers".
Horowhenua District Council said the current single proposed solution has not enabled "council or the community to consider the appetite for change".
