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The fight over the Three Waters reforms is about to reignite in earnest in 2022 amid claims of administrative bullying, broken promises, and dodgy numbers. But all agree we need to rise higher than our global top ten drinking water quality ranking

Rural News / analysis
The fight over the Three Waters reforms is about to reignite in earnest in 2022 amid claims of administrative bullying, broken promises, and dodgy numbers. But all agree we need to rise higher than our global top ten drinking water quality ranking
Water infrastructure
Image sourced from Adobe Stock 396693449

The “Three Waters” programme being introduced by the Government has become a major cause of contention with Councils, with one talley showing 61 of New Zealand’s 67 councils not in favour of it in its current form, and with 24 Councils forming an action group “to bring fresh ideas to the debate’.

At the moment, no doubt as a result of public and Councils' criticism, the Government has paused the legislative process and is awaiting the return of a Working Group's recommendations. This is due on February 28, 2022 with the legislation process to re-begin by the end of March. The tight timeframe makes it look like Government is still determined to go ahead, with at least the bulk of its initial plan.

The Three Waters reform programme is being set up to provide safer and reliable drinking water, wastewater and storm water services. The Government view is that approximately $5 billion per year over the next 30-40 years is required to get water services up to the standards required and this is beyond the capacity of many local councils to afford. They also expect 6,000-9,000 new jobs to be created in the process.

When the Government first mooted the idea of revamping regulations and oversight around water it ‘promised’ that there would be a full consultation process with the implication that Councils input and concerns would be listened to. Councils would argue that this has not occurred. There are several issues which have concerned Councils:

A major one is the reduction from 67 entities down to four with most councils questioning the ability of these new entities to be able to efficiently and effectively keep the water systems operating.

Entity C which goes from East Cape into the South Island and Entity D the bulk of the South Island have drawn the most criticism due the large and in Entity C’s case the broken nature of the territory.

Some Councils have suggested that 12 entity’s would be a more manageable. Councils have accepted that reform around water does need to take place but the disagree with the government over the current proposed model.

The handing over of Council-owned assets to Central Government is another issue Councils are concerned about. While assets will still be publicly owned, control will be passed over to the four entities and elected Councils’ representation will be diminished. For instance, in D. (South Island) under the current proposal only 6 Council representatives will be on its board from a total of 21 Councils.

The proposed set-up as provided by the Department of Internal Affairs is shown below.

Some Councils who have bitten the bullet over time and kept their water supply and infrastructure systems up to a reasonable standard question whether there will be compensation for them when other Councils have failed to do so. The issue of equity also spreads to larger populated urban centres which effectively will be subsidising smaller (rural) centres where much of future upgrading work needs to be carried out, (Wellington aside).

Earlier last year Government had said that $2.5 bln was budgeted to allow inequities to be smoothed out. Some Councils believe this will not be adequate compensation. The graph below shows what the government believes needs to be spent ($120-$185 billion versus $45 -$85 budgeted by councils) in the short to medium term.

How this translates to annual user costs is shown below. Independent analysts believe some of the gains are overstated, with the Department of Internal Affairs getting some base numbers wrong.

Government believes they will be able to secure benefits by their greater ability to borrow and create a multi-generational system and they examined 30 different models, with the proposed one being the best.

The Government also says the problem is urgent with 20% of New Zealand populations receiving drinking water that does not met full compliance. Despite this, one Council highlights that New Zealand features in top 10 of 195 countries for drinking water quality.

The original incentive that this was meant to be voluntary, and that is now twisted subsequently into mandatory council involvement, a move which has also irked Councils. And the Government's high profile and expensive TV advertisements campaigning for these changes have further fuelled the impression that the Government is being disingenuous.

Federated Farmers have also held their support back mainly around issues of governance and accountability. They also question the figures the Government has put forward. President, Andrew Hoggard has said "How will the new entities ensure the needs of smaller and rural communities are not crowded out when setting investment priorities and plans?" And "The proposed arms-length governance arrangements with directors appointed by panel, which are in turn appointed by yet another panel, weaken the accountability of water service entities to communities."

Concerns over the needs of smaller communities being met is a major concern for rural water users. For instance, Gisborne District Council has 4% of the Entity C district population while Wellington has 23% but with a large Maori population Gisborne may have different tolerance of the waste water going into their harbour (history would indicate this). However, as a small centre getting their needs met may be difficult.

While things have quietened down at the moment over the annual summer break, with the Working Group providing its feedback in 5 or 6 weeks, the fuse is soon to be reignited.

Saleyard Prime Steer

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85 Comments

This article fails to mention that Iwi will be handed 50% control of our water infrastructure.

Old cousin botherer has stitched this up remarkably well for her stakeholders.

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It doesn't mention it because it's not true.

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Hi Labourthide.

How are you going to spin this one?

https://www.newsroom.co.nz/maori-co-governance-of-three-waters-a-histor…

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Fifty (50) percent of each entities board will be iwi appointed. With 6 board members being proposed, 3 of them will be selected on the basis of race.

Sounds like apartheid.

With the value of each entity being in the billions (?) I'd like to see appointments based on merit.

Government overreach has nothing to do with improving water quality. The asset will appear on their balance sheet and allows borrowing against the increase in equity. It's a rort. 

You're naive if you don't think this will pave the way for more race based representation.

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Board members =/= ownership.  But I agree, appointment based on merit is needed.  

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This is a deceptive sleight of hand.  The Iwi are in control, the "owners" are sidelined.

They have even carved up the boundaries along tribal lines.

It is not a huge mystery why the general public don't want these "reforms" railroaded through.

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Who decides what is meritorious?

Studies often show that "merit" means lack of diversity as it is based on what the person sees in the mirror. That lack of diversity is then detrimental to good decision making.

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Please point out these 'studies'. A good percentage of studies within the social sciences lack appropriate design which provides any poof, and are generally a brain fart to keep academics in a job.

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Handing 50% of decision-making power on such a critical resource to a demographic that represents a-sixth of our population is undemocratic.

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It's much worse than that.  Most of that one sixth are just normal people that have no affiliation with the tribal aristocracy.

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Even for you Brock, that is an grossly ignorant generalisation and not worthy of this platform.

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Hardly.  If you are so enlightened, why don't you tell us what percentage of ancestral Maori are actively involved in Iwi matters?

I found this on wikipedia:

In the 2006 census, 16 per cent of the 643,977 people who claimed Māori ancestry did not know their iwi. Another 11 per cent did not state their iwi, or stated only a general geographic region, or merely a waka name.

So... 27% of Maori don't even know the name of their Iwi.

It seems that some Maori are more equal than others.  The rest of us are just New Zealanders.

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You said "Most of that one sixth are just normal people that have no affiliation with the tribal aristocracy"

27% isn't most is it Brock... I do not know a single person who identifies as Maori that isn't aware of their tribe, hapu and waka. Citing wikipedia is  embarassing. And you consider those Maori that do not know their whapapa as normal?? WTF???

You're an embarrassment Brock, bitter, negative and bigoted. 

 

 

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27% don't even know the name of their Iwi and plenty more are quite happy having nothing to do with it.

There are a lot of people out there with Maori ancestry that aren't big on racial priviledge and would prefer to identify as New Zealanders and there is nothing wrong with that despite how embarrassed you might be.

I cited Wikipedia which cited the 2006 census.  You failed to cite anything and decided to resort to bluster and name calling.

Thank you for your robust, respectful and insightful debate.  We don't welcome abusive or defamatory comments.

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I have stated this on here before, but will try again. My wife's grandparents and my grandparents were typical Anglo- Irish immigrants. Of their approximately one hundred direct and indirect descendants about sixty acknowledge some Maori connection, but none of them identify as Maori. The word is miscegenation, and its progress is inevitable. When the whole population has a portion of Maori ancestry what will be the point of any special treatment for Maori?

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If someone has 1/3rd Maori and 2/3rds English in their blood, then has their family technically screwed themselves over???

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An ( aspiring ) member of that aristocracy milking it for all it is worth would say that of course. 

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To say that "50% of decision-making power is being handed over to Maoris" understates it. Maoris also  get a sixth of the votes for the government. The percentage of the voting power they get is 50 +50/6. They get over 58% of the votes.

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Yes, Labour failed to hand 'control/right of return' of water to Maori under Helen Clark (even though she was content to take just little steps) but this is a whole new "being answerable is irrelevant" government we have under Ardern.  Anyway, if we judge how ineffectual this government has been on a whole myriad of critical issues then why should we for a minute believe they have a central answer on water services.  This just has to be a backdoor transfer of another national resource to tangata whenua.

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Lanthanide,

I often agree with your posts, but not this time. I cannot see the rationale for Iwi having a 50% stake in governance. I agree that maori should be represented, but why 50%?

The actual proposal leaves me unimpressed. It is clear that the government lied when they promised full consultation and the model is a recipe for inefficient and very expensive centralised control. They should go back to the drawing board and have a proper consultation with all councils. Any legislation should be contingent on labour winning the next election.

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Mate, you might want to speak with somebody who has been on the board before. Because having the control over the board is much more important than percentage of ownership. You can do things like issuing new billion shares just for you to devalue everyone else’s stake. Or start paying 10x more for people based on their race, etc.

Of course there is a diff between 50 and 51% plus there should be a system of checks and balances in entity’s constitution. However historically our gov isn’t good in planning for “what if” scenarios, think Kiwibuild or Transmission Gully.

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Anything involving iwi or Tiriti alway seems to attract the ignorant, like moths to a flame.

A board does none of the idiotic statements you made, it is there to act in the shareholders interests and select and manage the CEO. It is far better to be an owner than board member.

It is against the law in NZ to pay someone based on their ethnicity.

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Mainzeal?

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A board that operates lawfully.

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Don’t disagree TK but far too often the unlawful activities are discovered far  too late and the whole outfit has by then been white anted. 

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Agreed. The penalties are harsh but rarely enforced.

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If anyone 'owns' the water, then a cursory reading of Te Tiriti would indicate that iwi own 100%.

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A cursory reading certainly doesn't take very long Battinz as the document is notable for both its brevity and generality. However, Article 2 of Te Tiriti is the section relating to the preservation of Maori ownership rights and that has no mention of water at all so I'm not sure where you are coming from with your comment. 

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The Three Waters reform programme is being set up to provide safer and reliable drinking water

It's being set up to centralise control over water assets, let's not pretend it's about anything else.

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Why is centralising assets inherently a bad thing? In what world is a system of 44 local bodies managing three waters for just over 5 million people (43 bodies for 3.4 million Kiwis ex-Auckland) a better idea?

Not saying I am onboard with the new structure but the current system isn't without inefficiencies.

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I didn't pass any value judgements, I just pointed out why it was being done. I'll leave it as an exercise for the reader to determine whether central government control over local resources is a "bad thing" or not.

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In what world? Perhaps in the current world, where those 44 local bodies manage to have us ranked in the top ten nations worldwide for quality of drinking water.

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Reform is not being proposed because they've all done a great job. It's being proposed because of massive deferred maintenance and underinvestment, the likes of which has resulted in unswimmable beaches and feces in Wellington streets. It's reminiscent of Rodney Hide pushing for the Super City Auckland to achieve "economies of scale"...though arguably the best thing to come out of that was the separation of Watercare out of the financial reach of the council. 

Watercare probably provides a good model for this regional approach, and I'd suggest Watercare expanding to encompass Northland would be a good start. And ideally replicate the template, where it's run by technical experts and financially separated from politicians. Watercare has had a massive legacy of deferred maintenance and small councils' misappropriation of waters funding to catch up on.

It's tough to know exactly what to think re the board constitution as there's been so much hyperbole. I would question what real power the boards will have, and use that to inform thinking. But would agree that part needs scrutiny. 

I also have some disagreement with this statement:

President, Andrew Hoggard has said "How will the new entities ensure the needs of smaller and rural communities are not crowded out when setting investment priorities and plans?" And "The proposed arms-length governance arrangements with directors appointed by panel, which are in turn appointed by yet another panel, weaken the accountability of water service entities to communities."

As people I have spoken to who worked for many years in waters management say, much of the infrastructure at the regional level has always been funded - and thus vetted and approved - at a national level. Because small towns have never been able to pay their own way. Thus they don't see this being as big a change as Andrew Hoggard suggests. It's more you might be dealing with expert technical leadership rather than mired in the politics of local councils. 

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I really struggle with the argument from councils. It's not that they are nessacarily wrong it's just that many have made such a pigs eat of water and have such a vested interest in retaining the assets and control that their views require excessive grains of salt.

One interesting comment was the one regarding the comparison between  the tolerance for sewage discharge.i don't think most ratepayers have any idea at all where their sewage goes or what standard of treatment it gets and would be horrified if they actually knew. Dairy farmers would be looked at in a different light, but I'm guessing councils consider ignorance of the populace is bliss.

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100% agree  - whats so great about what we have in so many areas now and would you want to give them money to fix it based upon the track record?

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I think many younger Aucklanders (for example) that I've heard from are pretty sick of the fact the councils undermaintained and underinvested in waters infrastructure, and glad to see the greater investment under Watercare, e.g. the Central Interceptor. They think pollution of city waterways is as bad as pollution of rural waterways and its fair that polluters work to stop polluting and bear (at least a good chunk) of the cost of cleaning up their pollution.

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I'd be concerned if Mahuta has any influence on the possibility of 3 Waters ..

She's struggling to develop a sentence let alone representation of NZ in her warrant as foreign minister  ??

 

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I wonder what Jacinda saw in her?

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Deleted

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Interest team, I'm all for free speech but this sort of bigoted crap is a stain on your platform should not be tolerated. 

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That’s right… the play the bigoted card to cancel free speech… it’s what any fascist would do

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Rate payers to local governments will rightly expect their respective councils to protect ownership of the assets that they, the ratepayers have paid for, owned since day one. On the other hand some, but far from all, councils have not been diligent in either respecting the basic vitalness, or maintaining those very same assets. Instead vainglorious & more sexy agendas have been preferred. The government though has inflamed suspicion and resentment by an approach that has been revealed as being pre-determined, covert and arrogant. A one size fits all scheme unjustly & abruptly dismisses both councils & ratepayers in locations where infrastructure has been well invested & maintained, dragging them into the swamp with all of the opposite. In this regard the government has only themselves to blame and now the legal challenges are well afoot, hard to see any nationwide finalisation in the near future.

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Re paid for and owned, in fairness many smaller places have benefited significantly from central taxpayer funding of local waters infrastructure as it's been beyond their budget. This heard from people who worked in the field. So there's that.

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Let us recall how successful the centralizing of rabbit control was.

Once upon a time we had rabbit boards which were largely controlled by local farmers.  No great over head there.  If a rabbit showed it's nose the local grapevine quickly spread the word and the small group of professionals aided by the locals were quickly on to it.  No problems for a long time. 

Then the idiots in Wellington thought that they could do a better job, so they captured that portfolio to bolster their inefficient empires.  From their desks in Wellington they did not have a clue what was actually going on but came up with wondrous control programs.  We can see the results now of their incompetence.  Desperate farmers now taking matters into their own hands with Calici etc.

10 th in the world for water standards.  Is that so bad and warrant such an enormous response. I would have thought that we have far higher priorities that require far more urgent attention.  Housing, Child poverty, general deprivation, a collapsing health system.  As far as I can see we only have a few examples of poor water systems that could relatively easily addressed without such draconian measures.  The only sense that this makes is an asset grab to solve the Maori/water issue.  In terms of the average Maori it is also a cruel con and they will along with every body else loose control of public assets in favor of a small Maori elite and like the rest of us be paying through the nose for anything to do with water.  Remember that Mahuta comes from an elite Maori family with strong links to the Maori king movement.

https://en.wikipedia.org/wiki/Nanaia_Mahuta

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Chris-M , one of the best comments this year .

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Chris, when did the rabbit issue change? I recall back in the 1980s television footage of masses of rabbits on South Island hills. May have been the whole myxamitosis debate around the same time...? 

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Totally agree. Government cannot begin to charge for water without asserting ownership, thereby buying a fight with iwi. But giving iwi a 50% controlling interest is a way of buying them off.

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If there is an issue with investment in water infrastructure for a given council, then mandate a percentage of revenue generated through water is being reinvested into the asset. I suspect many councils have viewed water as a cash cow for many years.

Some councils objections are real. Namely there are no issues with their infrastructure and delivery of water but they will be dragged into a entity where they are having to financially prop up other councils.

 

Cost saving? So they need an extra 6'000 staff. Sounds just like Labour. 

 

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In Auckland's small councils, a portion of rates was set aside for that. But councils spent it instead.

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ECONOMICALLY SPEAKING: SWISS SUCCESS: SMALL IS BEAUTIFUL

Apart from the nonsense of the proposed management structure i.e Iwi etc  Labours proposal to centralise everything doesn't work, its typical socialist thinking.

www.nzinitiative.org.nz/reports-and-media/opinion/economically-speaking…

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Coming from a Swiss background the problem is people in NZ are not Swiss and you may as well be comparing life on another planet.

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It's typical right-wing thinking too. Recall Rodney Hide's Super City. In fact, it's probably just typical thinking past a certain age when one decides one knows best and just needs to have the power to do it.

Some mix of Participatory Budgeting (actually executed properly) and regional Watercares might be a useful mix that would defy the natural tendencies of the Natbour cohort. 

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I work in the 3 waters industry.  If the reform does go ahead, hopefully it brings some conformity around material supply standards and a fairer procurement model.  

 

We have 67 water authorities in New Zealand, many of whom have their own standards for materials.  Example:  Napier & Hastings use different cast iron service boxes, different size consumer property feeds (see page 20 of -> HyndsStreetwareProductCatalogue.pdf).  We have 67 little empires.   

 

When a watermain upgrade is released for tender, depending on the water authority, the pipe could be anything from:

Steel, Ductile Iron to NZS2280, Ductile Iron to ISO16134, Polyethylene, uPVC Series 1, uPVC Series 2, oPVC, mPVC Series 1, mPVC Series 2, GRP.  Decisions are often "feels" and based on cost over long term benefit.

 

Then you have councils setting up contractor panels, with many of these contractors having preferred supply agreements with suppliers who reward business through rebates and tickets to rugby matches.  These are all jobs funded by the ratepayer or taxpayer.  

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I've also worked in one water and exposed to the other (potable water  and waste water). Your reference to standards and procurement is correct but you don't need three waters in its current proposed form to achieve that. Some other form of legislation can achieve that.

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The centralisation and control of local body assets is just part of an overall Govt campaign to centralise everything in NZ:  Polytechnics, Training, Health Boards, etc, 

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Did anyone give John Key any socialist jibes when he amalgamated Auckland Councils or was that just good business practice? cost savings of scale? retrenching duplicated roles? conformity of systems?

Not big on completely centralized management of water resources but I do recognize the need for a centralized framework for quality and standards, and centralized oversight of best use practices and systems to prevent council fiefdoms and nepotism, over-commitment and/or under performance -   Hawkes Bay at Ruataniwha, Kaipara in Mangawhai and Hastings in Havelock North are recent examples.

As usual the answer lies in the middle and on merits - pity we have this adversarial party system where we lurch from ideal to ideal every 6 or 9 years. A plague on both your houses.

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Hear, hear. Too much Facebook-talkback nonsense on here re socialism and ignoring exactly such moves as Key's above. Probably would've been lauded as sensible and borne out of good solid "business experience" by the same commenters back then.

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Thank you dollar bill. If Key or Luxon put this forward it would be hailed as innovative and sensible by white middle class kiwis. But a brown lady with moko kauae brings the bigot out in many.

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I am 100 % against the 3 waters current proposal for the very real fact that 50% control will be given to unelected IWI, THIS IS OUTRAGEOUS, Jacinta's being controlled by her Maori MPs.

Sorry if that sounds racist but it currently is racist to non Maori !

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Or she sets this agenda herself ;)

In a country where 25% of population are Asian or Pacific descent one might suggest they should get a chuck too!

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And having Stormwater in the mix brings up boundary issues with regional councils which incorporate the old catchment and Drainage boards.  Stormwater in all but highly urbanized environments is inextricably tied in to rivers, streams, creeks, drains, swamps, retention ponds, swales, levees, dams, barriers, stop banks, groynes and other non piped assets.  Oh, what fun lies ahead....

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Wonder about that too. In Christchurch the old CDB across from the Avon gave wonderful independent specialised  service to trade & residents alike. Machines ploughed up & down the rivers & channels, keeping weed free & flowing. Flooding seemed much more under control than now. Recall an ex engineer from there writing to the Press with complete accuracy of the history where it had all been allowed to go wrong subsequently. Ditto from a contemporary, explaining that there was no need for water restrictions, all that was needed was a redeployment of volumes vs heads etc, but that was too difficult to have to think about whereas water restrictions weren’t.

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I agree Waymad. I think adding stormwater (which is about management of whole water catchments with multiple competing vested interests) in with fresh and sewer (which is about a technocratic process of volumetric charging for access to safe pipes) will lead to very messy outcomes. I wrote about it here.

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And your very perceptive article is exactly what set my tired old three brain cells along this path.  Cheers.

 

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Less democracy, more centralization and theft from the most transparent govt ever

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I just want clean, safe water at the best cost possible. I don’t care if people from Mars run the system as they can’t do any worse than a lot of councils, not all, there now - they have done a P Poor job to date. All the councils there now want is someone to give them money and trust us – yeah right!!.

A large number of the different hobbit shires ain’t working and in reality are broke or going broke.

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Astonishing the race based control issue is not mentioned in the article.

It's a fundamental disgrace and must be stopped.

It's time we ditched the Treaty.  Abolished gone.

It might have been relevant for the first 20 years, but now after 180 years it's outmoded.

Maori are not the maori of 1840.  Nor am I the Irishman of 1861.  We are a very diverse nation, there can be no special ones.   Democracy rules. 

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Maybe we should withdraw your citizenship and any certificates of title you have on property while we're cancelling legally binding documents.

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They've already withdrawn the citizenship of a million kiwis abroad.

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Haha.  Typical aggro reply.  Not going to get you anywhere.

Ditch the Treaty.  Lets get real about our nation as it actually exists. 

Or go for one system of government which is what the Treaty actually describes. But we don't really need the Treaty. 

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Who's version of real are you wanting and what system of government? Or is your version and system the one version?

 

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Democracy redcows.  Imperfect as it is.  One man one vote.  (and we recently let woman in.  Very sensible)  Secret vote.   (very important, whoever is leaning on you, you can vote as you choose.  Doesn't go down well in maoridom)

Anti gerrymandering.  (where some votes become more important than others) (we do have a rort currently with that with maori seats and the low voter numbers. But can be fixed with reducing the number of those seats. 

I am against race based governance, pro  democracy. 

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But the implication of what you're suggesting is also that democracy should outweigh contract law and land ownership. That is, if voters say so, they should be able to take your land or void all contracts and that's fine. It's an interesting viewpoint to take: Majority rules and stuff common law.

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I would recommend reading the actual treaty text.  It's the founding document of our nation.

https://nzhistory.govt.nz/politics/treaty/read-the-treaty/english-text

It's very different to the so-called "principles of the treaty" which have been concocted in modern times.

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You reading the one we signed or the one you concoted after? The old switcheroo as Chow would say.

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You are now suggesting a conspiracy theory where a different Treaty of Waitangi was created and switched in and the signatures were forged?

I don't know what this "you" and "we" thing means.  I wasn't personally there in 1840 and with our mixed ancestry it makes zero sense.

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Nothing was concocted afterwards.  Both the texts were present at the signing.  I recommend reading them both and understanding the translation contentions.

Why does Wikipedia upset you so much?

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.

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Thats an old potato Te  Kooti.  Don't believe everything they taught you at some crap Wananga.

The versions are closely aligned.  Examination of the background discussion (one example theBritish foreign office papers) confirm that. 

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If a minority has the power to turn off the tap for the majority, democracy ceases.

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Does anyone know how many people are employed by their council to manage water?. It seems to be hard to find out. It seem these guys operate in secret , and leave all the question taking and answering to the mayor , and councillers. Undoubtedly , they are earning more than the mayor ,  In the bigger councils , they media may occasionally have access to the upper echelons. 

We had a sewer break out front, and there must have been 20 -30 suits turn up , biggest task seem to be finding somewhere for them all to park , so they didn't get in the way of the 3 to 5 workers. A couple waved clipboards around, a few were on their phones , most seemed to just mill around hopelessly. no doubt the effiicency of the workers was put under the spotlight.  I suspect the tail wags the dog in most councils.

I would think the claim of 6000 new jobs is not taking into account the greater number of council staff no longer needed. 

 

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'Taumata Arowai

Drinking Water Acceptable Solution For Roof Water Supplies

This Acceptable Solution may only be used where a networked community supply is not available to the buildings'

 

So it starts, the neoliberal privatisation of water that falls from the sky onto your own roof.

 

'Taumata Arowai is not part of the Three Waters Reform programme looking to create new publicly owned water entities. Our role is to regulate rather than determine future changes to the delivery of water services.'

 

So Taumata Arowai's role will be the enforcer for the 3 waters entities.

 

I will never vote Labour again. I will never vote for the Greens.

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But those couple of 10,000 litre water tanks, tucked under the deck, are just for watering the garden,  officer......

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Their website says the new Act they administer only applies to entities that supply drinking water to more than one household. Are you sure you're on the right track with this?

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