Ryan's submission on the Water Services Entities Bill was among 100,000 received by the government.
The government wants to take drinking water, wastewater and stormwater functions away from 67 councils and create four co-governed giant inter-regional water services entities (WSEs).
For Northland, this would see the Three Waters functions of Whangārei, Far North and Kaipara District Councils combined with Auckland Council in New Zealand's northern-most entity, Entity A.
Hannah said he shared Ryan's concerns that under the Water Services Entities Bill, the WSEs could not be held to account by ratepayers.
"Nor can they be held accountable by Parliament because they are not Crown entities. This makes direct accountability to their respective communities more important," Ryan said in his submission.
"I am concerned about whether these mechanisms will be sufficient individually or collectively, to enable comprehensive and effective accountability."
Deputy Prime Minister and Minister of Infrastructure Grant Robertson said the government's goal was community accountability for the water service entities.
"Obviously, when we're moving from a situation where you have up to 70 local authorities involved in the provision of water services and you're bringing it down into four entities, that will mean significant change in the kind of accountability arrangements, but our goal is still that those entities are accountable to their communities," Robertson said.
Acting Minister for Local Government Kieran McAnulty said the Government always took the Auditor-General's comments seriously and was prepared to consider all constructive improvement suggestions.
Hannah said Northlanders' democratic participation in Three Waters provision would be lost under the new Entity A.
It would be controlled by Auckland and run through Watercare, Auckland's water provider, he said.
He said Northlanders were currently able to, via the local government election process, vote out councillors who weren't effectively governing council functions such as Three Waters.
That democratic right would be lost as those helming WSEs would be appointed.
"Democracy is so important. You've only got to look at the French Revolution," Hannah said.
"It is a key part of being a Kiwi. It's about us having a say in what goes on around us."
Hannah said Northlanders voting in the October 8 local government elections should question candidates to make sure they fully understood Three Waters' implications for Northland.
"The Northland candidates need to really be thinking about Three Waters if they are thinking about their future and their children's future," Hannah said.
Ryan's submission said moving water services from local authorities to WSEs brought a significant reduction in audit scrutiny.
Local government's audited 10-year council Long Term Plans provided assurance to Parliament and the public that councils were working as required.
There was no WSE auditing equivalent, he said.
Whangārei District Council (WDC) chief executive Simon Weston said his organisation would be interested in the Government's response to the issues raised by Ryan.
WDC was also keen to see the Government's response to Three Waters issues that WDC had raised in its submission on the same bill.
WDC is part of the Three Waters councils breakaway group Communities 4 Local Democracy, formed in opposition to the sector's restructure.
Weston said WDC, as part of that group, had made its position on the bill clear.
WDC is one of three New Zealand councils which have challenged the Government in the High Court over ownership and property rights in relation to Three Waters.
■ Local Democracy Reporting is Public Interest Journalism funded through NZ On Air
