Thursday, July 28, 2022

Hidden Cost of Three Water Reform

After 12 years Auckland Councillor; Watercare Shareholder Representative; Three Water specialist; and Mangawhai Ratepayer Representative, and other stuff - I wrote an OpEd for NZ Herald on 3 Waters.....


Here's the draft OpEd which wasn't published:


Government’s Three Water proposals risk costing the country more in the long run, hide from the public the true cost of traditional engineered systems, resist innovation which benefits ecosystems, and perpetuate century old flush and forget wastewater management.

For most of my last thirty years in New Zealand I have immersed myself in the economics, governance and politics of its sewage, stormwater and water supply issues, and I cannot understand or accept Government proposals to centralise our whole country’s dispersed and different three water systems into entities modelled on Auckland’s Watercare and hoping for the best.

Watercare was mainly formed from amalgamating the assets of Auckland’s four city councils, thus removing the comparative bench-marking which enabled ratepayers to compare the relative water and wastewater costs and benefits of the region’s service providers - thereby encouraging efficiencies, and instead creating a relatively unregulated entity with dozens of managers each earning salaries of hundreds of thousands of public dollars. Watercare’s focus on discharging treated wastewater to the Manukau Harbour and Rangitoto Channel has led to the development of an extremely expensive sewage collection network which leaks in freshwater when it rains (necessitating bigger pipes with a billion dollar price tag), which routinely overflow raw sewage when it rains anyway, and  whose demand for pumps and electricity makes Watercare Auckland’s biggest electricity user.  

Watercare is not a paragon of virtue or exemplar upon which to base New Zealand’s future. Barely a drop of Auckland’s treated wastewater gets returned to land, despite the environmental benefits and savings when there’s a drought, and despite international best practice. When Watercare sought consent to draw Waikato River water for town supply, it was only concerted court action that forced Watercare to treat the Cryptosporidium microbes and agricultural organochlorines that raw contained. And local Tainui cultural concerns that Waikato water should not be mixed with Auckland catchments was dealt with by the “gift” from Watercare to Tainui of a piece of prime land on the banks of the Waikato where a significant battle had been fought.

New Zealand’s governance experience with Watercare is much the same as is experienced with very large public water infrastructure entities the world over. They become laws unto themselves, their internal processes largely invisible, impervious to public opinion, and stuck in the past. This is unlike New Zealand’s smaller community-focussed three water entities whose performance is very much on display, where costs and processes are much more transparent, and which depend on the advice of New Zealand’s nimble, innovative and competitive engineering consultancies such as AECOM, BECA, WSP and Tonkin & Taylor.

These smaller local providers are all on the same learning curve and mistakes are made. Mangawhai’s Ecocare system – an innovative pocket treatment plant designed to replace leaky septic tanks and discharge highly treated wastewater to farmland – is an example. The urbanisation of developing parts of New Zealand does require local communities to incorporate appropriate three water systems into their planning and budgeting, but big doesn’t mean better.

Recent discussion about the costs of computerisation of the proposed four new three-water entities is just the tip of the iceberg of the eye-watering transition costs that can be expected – just look at Watercare setup costs, along with the wasted costs of investment in existing community systems. But the greatest concern is the loss of innovation opportunity that centralisation of three water services will bring, concretely exemplified in Watercare, at a time when advances in membrane technologies, local reuse and collection systems, along with climate change, point in the direction of community level governance, operation and ownership. 

Friday, June 17, 2022

Why is Central Government Reducing Local Government and Democracy?

 This is an OpEd piece sent to NZ Herald a couple of weeks ago. Unpublished. So here it is:

While it is concerning that all of Auckland’s and Northland’s mayors are resigning ahead of  upcoming Council elections, it is not particularly surprising given the unprecedented and unrelenting attacks that have been aimed at Local Government by the present Central Government and which threaten local democracy and community planning in particular.

Kaipara District Council’s Mayor Jason Smith has given the Three Water Reform which forces all Councils to divest public water assets to entities established by new legislation as his main reason for resignation.

That reform is the latest in a salvo of change striking at the very heart of what local governments in Western countries around the world are for, with New Zealand already near the bottom list for functions and responsibilities delegated to local government, lagging significantly behind Japan, Switzerland, Australia and the USA for example.

The previous National Government was the foundry for much of Central Government’s appetite and ammunition for local government reform. The Hon Nick Smith, past Minister of Local Government and Environment, championed the argument that Local Government development planning and infrastructure construction activities were the principle cause of the steep rise in house prices, and that reform was needed.

He argued that Councils were slow to release land for development, making it scarce and thus forcing up land prices needlessly, and inept at building necessary supporting infrastructure such as roading and water and wastewater networks, thereby driving up the development contributions fees payable on each new lot.

The reforms he led included several Resource Management Act changes requiring large councils to review District Plan documents and make property development less restrictive and quicker.

For the past few years Auckland Council has routinely published data showing that despite its new Unitary Plan releasing huge tracts of land for development, and the consequent yearly construction of thousands more homes than have ever been built before, house prices have persistently shown strong upward growth well before COVID supply line restrictions on construction materials.

The present Government has adopted this argument wholeheartedly, and it continues to underpin its plan of attack on Local Government, despite growing recognition and acceptance of the counter argument that the main driver for house price increases since the Global Finance Crisis is the combination of near zero interest rates, cheap loans and mortgages, poor returns on traditional term deposit savings unlocking that money and further increasing demand for housing investment assets, and few meaningful taxes on capital gains. 

In the last two years economists and policy advisers in Australia have accepted this counter argument, and, interestingly, recent and anticipated reserve bank base rate increases here in New Zealand are cited by economists as the main cause of reductions in house price increases now.  

But still Central Government’s local government reform machine grinds on with consequences for local democracy and communities.

Decades of careful community planning have gone into the District Plans that shape the way towns and urban areas develop, change and grow.  These have been tossed aside by Central Government’s Resource Management Housing Enabling Act which permits three homes, three stories high to be built on most urban lots without need for resource consent.

While this reform should produce more homes, some of which might be “affordable”, the impact of additional housing on infrastructure has been ignored. There will be more pressure on water and transport infrastructure which will require upgrading. This needs to be planned and budget provided. Increased density means more people using community facilities such as halls, libraries, schools, sports facilities, parks and reserves. These community concerns are built into local government plans, and are why local government exists, but they are ignored by Central Government’s edict.

While there is room for improvement in local government three water infrastructure provision, there are many informed reasons not to proceed with the current Three Water Reform proposals which very much risk throwing the baby out with the bathwater.

Key among these are international trends away from centralisation of wastewater systems to de-centralised systems where wastewater is treated as close as possible to its source of generation. Considering the three basic components of a wastewater management system - collection, treatment and disposal – collection infrastructure costs account for about 60% of the total budget for a centralised system. Whereas in decentralised or more local systems, this component is reduced and focused mainly on wastewater treatment and disposal.

Local Government is ideally placed to be incentivised to work with its local communities, invest in new technologies, work hand-in-hand with local iwi, and build and operate efficient and sustainable three water systems that fit the local environment. 

Central Government needs to work in partnership with strong and motivated Local Government attracting the best staff and local representation to get the best outcomes, and deliver democracy.


Wednesday, June 17, 2020

COVID kills DOLPHINS

As a s.274 party I have just received a joint memorandum of the Environment Court recording that Panuku wishes to surrender resource consent CST60323353 authorising the construction of the Queens Wharf mooring dolphins and the parties request that the Court close its files.....



Such a good outcome for Queens Wharf and for Auckland - in my opinion.

Friday, June 12, 2020

Commercial Bay in a COVID context

A few days before official opening it was all go in the covered laneway that runs between Lower Queen Street and Lower Albert Street, and is where Queen Elizabeth Square used to be.
The public space is coming together - and those of us who walk through there each day to and from work will breath a sigh of relief. And look forward to other parts of this massive project to come to a conclusion.

But so much has changed in downtown Auckland. Years ago when all this was being planned, there was no COVID scenario. There was no "black swan" event that needed to be planned around.

So many assumptions made around the presence of wealthy cruise ship passengers drawn to Dior, Prada, Gucci and the rest, offices bursting with workers to such an extent there were projections of office space shortages, and thriving cafe and bar life providing opportunities for investment and more urban construction.

Even in lockdown level 1 Lower Queen Street and Queen Street itself is a ghost town. You could fire a cannon up Queen Street at 9:00 in the morning and hit nobody. Almost the same on the footpaths...

It will change. We're social animals and enjoy being out and about. But it will not be the same for a while. Social distanced behaviour has become a norm for now. NZ may be able to sustain this amazing COVID-free bubble it has become, but we all look at the news and we all know that tourists can't easily come, and we are infected by that, and find other ways to live and to occupy ourselves.

Thursday, June 11, 2020

Auckland Water Shortages and Watercare

It seems like yesterday to me, but 1994 was a while ago. Auckland had a much bigger water crisis than we're experiencing now, and it was part of my political education. At the time Watercare was owned by the Auckland Regional Services Trust (ARST), having been put there after a hefty dose of central government driven local government restructuring. Parts of Auckland local government services were privatised - including its landfills. This was in the hey days of neo-liberalism. Regionally owned bulk water services and bulk waste water services were removed from Auckland's regional government (at the time a fresh Auckland Regional Council itself a cut down version of the celebrated Auckland Regional Authority), and placed in ARST, a sort of waiting room for privatisation. That was the birthplace and birth process of Watercare, and much of its institutional behaviour was designed then.

The water shortage came as big surprise to its owners and privatisation strategies took second place to addressing the water crisis. In 1994 due to an unusual roll of the political dice, Alliance candidates were the majority elected to the ARST, and as an active Green Party guy at the time, I was able to get, through my contacts, some Watercare information about what was happening...

This Watercare graph shows how the storage levels changed 1991, 1992, 1993 and 1994. The "normal demand management" curve 1991- end of 1993 shows the typical oscillation of dam storage levels from full to 75% of full. This is normal and to be expected when rainfall is normal. The dam levels get drawn down in summer and fill up in winter. But when there's a drought and the expected winter rains of 1993 didn't eventuate, followed by normal summer consumption, then, by May 1994 things were looking problematic. The graph projects water levels from June 1994, based on different levels of "savings" - up to 30%, and how many days before the dams would be empty.
 
A very well funded conservation campaign was run. (NB: As shown in the graph, Watercare had already run various media campaigns starting at when levels were at 60%, and then hose bans etc)

The main "customers" of Watercare - which then was a bulk water wholesaler - were the four city councils, North Shore City, Waitakere City, Auckland City and Manukau City. (This is before amalgamation). As the drought evolved, some Councils were more supportive of conservation than others. At the time, it was the Councils that metered water use, and charged users for their water. Not Watercare. Watercare charged each of those four councils in bulk. Councils used their water revenues to maintain local water network infrastructure. There was quite a competition between councils as to whose networks were the least leaky - water leaking from pipe networks is a problem the world over. One of the things that got lost when Watercare took over the retailing of water, not just the wholesaling, this bench-marking process has gone. It is not in Watercare's interest to check how much water is leaking from its network. It concentrates on metering what comes out of the pipes and charging customers accordingly.

At the time, Aucklanders were served by a robust NZ Herald with reporters who delved into the detail and understood much of the politics of what went on beyond the media statements.

As the crisis unfolded, about 10 options were canvassed for additional supply. At the time, taking water from the Waikato was at the bottom of the list prepared by senior planners within Watercare, but it quickly jumped to the top of the list when the corporate types who moved into Watercare at the time of the crisis, looked at it. Especially when the possibility of building an Emergency Pipeline got floated, complete with fast-tracking and RMA avoidance.
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Cartoonists had a field-day with this. Some Councils were all for the emergency pipeline, others were not so sure. And meanwhile it started raining...

Sometimes the pipe was up, and sometimes it was down. It was certainly an idea that appealed to the newly floated Watercare, for all sorts of reasons but the main one was that as a business it would be much more viable with a continuous run of river source to complement its lake storage. At the time I did accept that Auckland needed an insurance policy - a source that could be used when there was a serious crisis. But that preference should always be for raw water sources that were clean. And the Waitakere and the Hunua dams - being in bush catchments without agriculture or urban activity certainly delivered that.

I prepared this graph at the time of the drought (September 1994), which was after rain had been falling reasonably regularly - but not particularly heavily - for 10 weeks or so. It was designed to reveal just how negative Watercare's projections were (3 are shown). And at the time Watercare had got its teeth firmly into the emergency pipeline project. Watercare really wanted that project.
 
NZ Herald reporters - notably Philip English - followed the issue and developments extremely closely, and stuck hard to the facts. It was a matter of huge public interest.

This story is an excellent example of the reporting at the time. The Mr Cook quoted here is an example of the public relations investment that Watercare specialised in at the time. Since then Auckland Council and all Auckland CCO's have invested heavily in public relations experts and concentrated on spin-doctoring and managing and influencing public opinion. One of my major pieces of education through this whole period was that information asymmetry is a thing - that large CCO's and councils hold onto information that is not in their interests to make public. Anyone questioning local government - and especially CCOs is at an enormous disadvantage because of the lack of transparency around key pieces of information. Reports are routinely with-held etc.

I note the mention in this article of Ashton Wylie. He and I met after I ran some OpEd pieces in NZ Herald. He was a wealthy importer of Pansonic equipment - and passionate about Auckland's water resource. We got on like a house on fire and he funded me to seek expert advice outside New Zealand for expert evidence. He help me financially when it came to the Environment Court - see later...
 
This report is dated 28th September. I remember at the time phones running hot - people wanting to know "how much rain fell out your way?" It was knife-edge. Watercare was leaving no stone unturned and had mobilised a significant lobbying campaign in Wellington to keep MPs on side. And all funded with public money.

In fact the Emergency Pipeline project never happened. It rained enough and at the right time so that the Emergency legislation did not get a majority in Parliament. So 1994 ended well. But just as rust never sleeps, neither does a good project inside Watercare. considerable sums had been invested - of public money - in getting that project off the ground. Much of that effort was then directed at developing a proper Waikato based bulk water source, and sometime in 1997 Watercare notified resource consent applications to build a pipeline, a new treatment plant, and to take water from the  Waikato River and treat it and augment Auckland's water supply. Which is where the next part of this story goes....

One of the experts I found - and he came out to New Zealand - was Professor Dan Okun. From South Carolina, USA. He was profoundly expert and enthusiastic about the reuse of treated wastewater for non-potable purposes. I learned so much from him. His expert evidence was a big part of my evidence in the Environment Court. He knew a lot about cities in the USA that routinely reticulated highly treated wastewater for industrial washing, and golf course irrigation and suchlike. It gets reticulated in purple pipe networks. It's a whole network industry across big parts of the USA. Turns out also to be common in arid parts of Australia, and also in Japan. The diagram above is one I prepared based on Prof Okun's advice - mainly to show how 250,000 cubic metres drawn from a dam daily (equivalent to 250 million litres) - can be equivalent to a total supply of 750,000 cubic metres per day if you use the water three times before discharging it. It's simplistic - and doesn't talk about golf course and park irrigation (where water evaporates). 

Remember this all happened 25 years ago. And the discussion you get from Watercare today is just as ignorant and uninformed as it was then. Its business model, with a single network of supply of freshwater, top quality, used for everything, from drinking to washing out concrete trucks, all using premium piping, and all charged for at the same rate, used once, then wastewater treated to a "you can swim in it" standard, which is then all dumped. 
  
A key issue with taking water for drinking from the Waikato is the fact - at the time - there were almost 3,000 separately consented discharges into it. Farms, factories, geothermal, and sewage treatment plants. Contaminants that were most significant included organochlorines from horticulture, and cryptosporidium bugs from dairy farm sewage. These contaminants are not treated by the water treatment carried out on raw waters from the Waitakere and the Hunua dams. If raw water did come from the Waikato, it would need additional treatment.

I haven't published the full page advertisment that Watercare ran at the time. It showed a glass of water. The message was that the water would be the same. I challenged them at the Advertising Standards Complaints. Watercare - like Ports of Auckland - retain the best and brightest lawyers from Russel McVeagh. It isn't just about information asymmetry. Watercare has a culture of winning. Not just sustainable reporting awards (which are a travesty), but anything. Particularly where its reputation might be challenged. It's only public money after all.
 
Nevertheless the cartoons kept coming,and public concerns were real.

Watercare's resource consent applications were granted by the relevant TLAs - of course it was Environment Waikato that heard the application to take water from the Waikato, and due to the vagaries of the RMA, once water is in a pipe, the RMA is no longer interested in it. Many of us joked about it being "discharged" from taps and pipes into cups and glasses - but those arguments didn't hold much water....

You get a flavour from the above report as to how Watercare (and Ports of Auckland, and Auckland Council), can all throw piles of public money at public interest issues to ensure they win. But there was information and concern in the public arena about what was in the Waikato water.

This NZ Herald editorial summed up some of those concerns. Just a week or so before the Environment Court hearing, Waitakere City Council withdrew its appeal, and then so did Tainui (the Sunday before - it was gifted a chunk of land I think the site of a maori battle, by Watercare, which bought them off). That left Mr Hamilton and me as appellants. Not good.

But then I discovered that Manukau City Council had become a s274 party to my appeal. I was approached by someone and encouraged to keep my hat in the ring as they tried to work something though with Watercare. Manukau City is closest to where Waikato water would come out the tap, and had concern about water treatment. I learned afterward that Watercare was pressured by Manukau City council to sign the "Manukau Agreement" - this committed Watercare to including two additional treatment processes for Waikato water. One was a carbon bed filter - for organochlorines, and the second was nano-filtration - for cryptospordium.

This was a huge result. But went totally under the radar. If I had withdrawn my appeal, under pressure, Manukau City Council would no longer have had any standing in the appeal....
   
My second expert, funded thanks to Ashton Wylie, was Dr Perri Standish-Lee from California (I think). She uncovered the work of NZ's Dr Gillian Lewis and submitted her own arguments as an expert witness for my appeal. You will see reported in this article that I stood for North Shore City Council at the time.
 
Again, another positive NZ Herald report of how Watercare sued me (and Mr Hamilton) for costs after the Environment Court appeal. The gains won from the action were all in the Manukau Agreement already. We gained nothing more in the Environment Court.

So. What does all this mean now? Well - Watercare is bigger and stronger now than it was in 1994. There are no sizeable city councils to challenge it. Auckland Council has as much control over it, as it has over Ports of Auckland or Auckland Transport - ie little control. Watercare is very well resourced, and it's no surprise it is so impervious to challenge. It was designed and built by a chief executive for whom winning and the appearance of winning was everything. He was appointed in 2010 on the strength of this reputation to design the newly amalgamated Auckland Council. This is just as robust in the face of public concern and any internal dissent.

A major factor in Auckland's water shortage in 2020 is the monopoly structure of the responsible organisations, their focus on revenues, and their interest in delivering and funding a steady stream of large engineering projects to keep expensive and highly qualified project teams in employment.

Until those things change, and until there is a fundamental commitment to sustainability, including the reuse of recycled water for example, the widespread use of locally owned rainwater storage, and appropriately encouraged and systematic water conservation systems Auckland will continue to be vulnerable to weather and to opportunistic behaviours from its publicly owned water utilities.

Tuesday, June 9, 2020

When does Tiny House need Building Permit?

A two storey Tiny House was towed to this residential site in Mangawhai a couple of weeks ago, and since then the owner has been systematically preparing it so he and his partner can live in it part-time.

The planning question this sort of activity poses is when does such a development require a Building permit?

I'm interested in your views please. Use the comment facility of the blog to provide your suggestions - anonymously or otherwise.
This image shows the corner support used. A car jack on a concrete tile. The chain is wrapped around the trailer chassis beam, and U-bolted to a wooden post which appears to be set in concrete into the ground. The chain is likely to prevent the structure tipping in a strong wind. The site is elevated and exposed (see picture at end of this post). The elevation shown in picture 1 is to the north, and is about 8 metres long by about 4.5 metres high.
The same chain/post combination is deployed at the opposite end. Timber lengths are used to support the structure.
The wheels have been removed from the trailer supporting the structure, and axles protected with plastic covers from water and suchlike.
Electric power is provided to the Tiny House from this mains switch and electric metre board which has been built into one corner of the site.

The floor area adjacent to the elevation shown (to the south) contains the greywater drainage pipes from kitchen and bathroom which have yet to be connected to any disposal or collection system. I understand a waste pipe will be installed directing greywater into a storage tank located next to the retaining wall visible in the first pic (above). This will be pumped out from time to time. Unclear so far.
A freshwater tank about 2500 litres capacity has been set into the ground and collects runoff from the roof. It has no overflow discharge system as yet.
Kitchen and bathroom water gets heated here and reticulated into the Tiny House.

I understand there is a composting toilet in the bathroom part of the Tiny House. It is unclear whether urine can be passed into the composting toilet system.

Grey water discharge systems are not fitted as yet.
The locked cabinet shown by the trailer draw bar contains the gas bottle. The water pump is mounted on the timber platform at the left.
This view is to the East. The Eastern end houses a bathroom utility area at the ground floor, and a mezzanine level above for the bedroom which is accessed by means of an internal staircase.

So. All you experts and practitioners out there, what's the regulatory position on a Tiny House like this in a residential area? It complies with District Plan provisions. Fixture to piles, or connection to the local wastewater network, triggers the need for Building Consent in Kaipara District. But as it stands, would it comply in your neck of the woods?

Friday, May 29, 2020

Submission Kaipara District Council Plan Change 78 Mangawhai Central

According to Kaipara District Council website information:
Private Plan Change 78 (PPC78) was lodged on 3 December 2019 by Mangawhai Central Limited. PPC78 seeks to rezone 130ha of land contained within the Estuary Estates Structure Plan of the operative Kaipara District Plan 2013 (the District Plan), PPC78 area comprises of 83 Molesworth Drive, and Lots 1 and 4 DP 314200 Old Waipu Road, Mangawhai.
This blog posting contains some information about this plan change, public concerns, and my submission. This image is taken from latest issue of Mangawhai Focus.....

Preamble

There's a lot of history to this story. Very briefly, about ten years ago, Chapter 16 which provides for Mangawhai Central development was written into the Kaipara District Plan. Thus the proposed development had its own zoning controls built into the District Plan. Those provisions would have enabled the development of a new piece of town located on about 130 hectares of rural land situated on Molesworth Drive between the towns of Mangawhai Heads and Mangawhai Village. The development proposed then included about 500 residential lots (up to about 1000 square metres), 17,000 square metres of commercial development including a supermarket, and a retirement village. Various resource consents would be needed for earthworks and suchlike. Simmering concerns within the community related to the impact on the road network, the wastewater system, surrounding estuary environment, and the aquifer because of proposals to take bore water.

Fast forward to 2019, when the development company (Virandah Partners) lodged a private plan change whose purpose was basically to double the development potential of the site - to provide for 1000 residential sites and 34,000 square metres of commercial development. The application is accompanied by substantial technical documentation. On the face of it, careful urban design, green space, walking networks, on site streetscape plans, will provide for a well functioning new town with a population of around 5,000 where previously there were paddocks. (5,000 is more than the current population of Mangawhai Heads and Mangawhai Village combined.)

The concerns of existing communities and residents relate to what effects this new town will have on surrounding environment - particularly the transport and wastewater infrastructure and freshwater. 
  
Mangawhai communities are mobilising again in the face of growth pressures and planning processes that persist in rocking the boat. You can get a feel for these concerns at the campaign website run by Clive Boonham.  

I have written a submission which is here....

Twenty Years Ago
Twenty years ago I was invited to help the Mangawhai Residents and Ratepayers Association (MRRA) make submissions on a pro-development plan change (Plan Change 9) that was notified by Kaipara District Council.  MRRA approached me because of my experience working with North Shore City Council on its wastewater network and system, and because of research I'd done abroad on alternative community wastewater systems. At that time Kaipara District Council came under pressure from the Regional Council to clean up the Mangawhai Estuary, and from developers keen to follow the Cooks Beach example and get intensive subdivision development underway. KDC pushed ahead with a proposed $16 million sewage scheme. Kaipara District Council decided they could not fund the project and instructed Beca’s to put the whole project out to private tender. Quoting from my submissions at the time:

"MRRA are particularly concerned that Mangawhai residents themselves have been insufficiently consulted over the implications and consequences of PC9. The consultation with the community over the infrastructure study, what should be done, what options to pursue, how a possible community sewage scheme should be funded, how it should be built and owned, are all severely deficient – given the huge issues for the community....

"We have even more of an issue with what is proposed for wastewater, and how that has been shared with the community. The MRRA recognise that how we tackle wastewater is fundamental to the proposed zonings in PC9. Many of the proposed changes cannot go ahead – or at least cannot be made to happen in real life - without the proposed community waste water system. The huge increase in urban intensification envisaged by PC9 for Mangawhai can only occur with a reticulated sanitation system. We believe there is a gap in the council's communication over this. It is hugely controversial, building something as expensive as a community sewage scheme, and involving the private sector in the manner proposed. It represents a major political shift in service provision. I am not aware that the community has really much of an inkling as to the possible impact of what is proposed - in terms of costs, changes in accountability, what their options are - and indeed whether they have been asked whether this is what they want for their community....

"We are of course aware that PC9 does not explicitly mention any costs for the proposed Community Sewage System. PC9 is explicit about financial contributions required for stormwater and roads, but is silent when it comes to wastewater. Documents we have sighted suggest the capital cost of the sort of system which seems to be preferred by Kaipara District Council and its consultants – Beca – is $16,000,000. There are 1200 affected lots in Mangawhai Township now, and PC9 envisages a further 535 – giving a total of 1735. If we all paid equally for this sewage system, it would cost each ratepayer $9221. But PC9 is silent about this huge sum of money….

There are many parallels between this plan change (twenty years ago) and the way Private Plan Change 78 is being mishandled and miscommunicated by Kaipara District Council. The quoted figure of $16 million for the EcoCare wastewater system is of course woefully short of the actual cost which was in the vicinity of $80 million. Unless we learn from this history, we are doomed to repeat it.

Auditor General Enquiry into Mangawhai Community Wastewater Scheme

In November 2013, after an immense and drawn out public campaign, and much anxiety and cost distributed throughout the Mangawhai Community, the Office of the Auditor General published its 400 page report into what had happened. Of critical importance to the present plan change proposal, are the OAG findings. And here I quote from the report’s overview:

"After 20 months of carefully collecting and analysing evidence, this inquiry has made some clear findings about what happened. The positive findings are that:
• the decision that Mangawhai needed a reticulated wastewater scheme was well founded; and
• the wastewater scheme that has been built works effectively and has appropriate capacity for population growth.  (NB: The OAG report was prepared in 2013 – when population growth forecasts would have included at max a half sized Mangawhai Central proposal.)

"The other findings are more sobering. Overall, KDC has ended up with a wastewater scheme that works, but it has come at a significant cost. The fact that we cannot put a precise figure on that cost is indicative of KDC’s poor management. KDC’s records did not contain good or systematic information on the total amount spent. However, our best estimate is that the total cost was about $63.3 million. The overall costs are not just financial. They include a failed council, councillors who have been replaced with commissioners, the departure of a chief executive, a severely damaged relationship between the council and community, an organisation that has needed to be rebuilt, and much more….

"KDC’s decision-making processes were also poor throughout the entire 16 years of the wastewater project. KDC relied too heavily on its professional advisers and had a practice of receiving briefings and effectively making decisions in informal workshops. The governance and management arrangements put in place specifically for the project were also inadequate. In our view, these underlying problems made it harder for KDC to deal with the problems that emerged as the project progressed.

"KDC decided that it wanted to explore a public private partnership (PPP) approach, to keep the debt “off the balance sheet” and to put as much risk as possible on to the private sector provider. In my view, this decision took KDC out of its depth. It followed all the right basic steps when it initially went to the market for advisers and put the project to tender, but it did not fully understand the complexity of what it was doing. The early decision to use a PPP approach put too much emphasis on achieving a certain accounting outcome and the transfer of risk, and not enough on value for money and affordability. KDC’s decision-making about the PPP was not consistent with the good practice guidance that was available at the time….

"I am also concerned that KDC does not appear to have regarded the disciplines and checks in the contract about the construction and handover process as particularly important. In my view, the relatively relaxed approach that was taken to some of these protections, such as the approval processes involved in commercial acceptance and handover of the asset, exposed KDC to unnecessary risk…..

"For these and other reasons, the costs of the project increased steadily. KDC assessed affordability by considering the annual cost to ratepayers. It decided to increase the number of estimated ratepayers that would be covered by the scheme and contribute to funding it. KDC increased the scope of the project to cover more properties and adopted new growth projections that assumed more properties would be developed. We have criticised these decisions on the grounds that they were not based on good information and did not take adequate account of the risk of slower growth. KDC’s focus on the annual cost to the ratepayer as a measure of affordability was unfortunate: it meant that it did not fully appreciate the significant increase in capital costs and the effect on the project’s overall affordability…..

I have quoted selectively here, but not taken any of the matters out of context. It appears that much of this criticism is at risk of being laid at the feet of the Kaipara District Council again.  

While not strictly a PPP, the current plan change arrangement will clearly be of direct benefit to the developer (because of the increased development potential of the land) and to the Kaipara District Council (not least because of increased rate revenues).

The way the costs and capacities of roading, wastewater and the receiving natural environment are being handled in the plan change application has forced existing residents and property owners to defend themselves, their interests, and the surrounding environment in much the same way as they had to twenty years ago.    

National Policy Statement on Urban Development Capacity 2016

This NPS was enacted in 2016. Its objectives apply to all decision-makers when making planning decisions that affect an urban environment. The objectives relate to outcomes; evidence & monitoring; responsiveness and coordination. In particular there are objectives requiring coordinated planning evidence and decision-making in “Urban environments where land use, development, development infrastructure and other infrastructure are integrated with each other.”

In terms of outcomes for planning decisions, the NPS imposes duties on the relevant local authority:


The preamble to the NPS gives direction on how infrastructure planning is a critical part of the provision of development capacity:

Development capacity must be provided for in plans and also supported by infrastructure. Urban development is dependent on infrastructure, and decisions about infrastructure can shape urban development. This national policy statement requires development capacity to be serviced with development infrastructure, with different expectations from this infrastructure in the short, medium and long-term. It encourages integration and coordination of land use and infrastructure planning. This will require a sustained effort from local authorities, council controlled organisations, and infrastructure providers (including central government) to align their intentions and resources.

It is my submission that KDC has not given effect to all of the relevant objectives of the NPS UDC in the way it has approached the community consultation on PPC78 because it has separated from the consultation facts and figures about infrastructure capacity, costs and who and how those matters will be provided for.  

There is no evidence that the planning for Mangawhai Central development is coordinated with infrastructure planning.

The plan change technical documentation is particularly deficient in the way it deals with traffic matters and their effects on Molesworth Drive, and almost silent on the way it deals with the community owned wastewater scheme and how the wastewater needs of the proposed development will be met and paid for.

In my opinion the infrastructure aspects of the plan change need to be reviewed.

Deficiencies in Private Plan Change 78 Process

The development and institutional context for this plan change inevitably influences perceptions and issues that arise for both the developer, the existing population, and the planners and other experts engaged to process the application.

To start with, the proposed development, when complete, will be a small town with a population of between 4000 and 4500 (assuming 1000 homes with 4 people each and a retirement complex), situated midway between two existing small towns: Mangawhai Heads whose population is about 2,500 (estimating from 2018 figures) and Mangawhai Village whose population is about 1,000, and adjacent to a moderate capacity arterial roadway (Molesworth Drive), drawing water from a common aquifer (at the proposed rate of about 100 cubic metres/day), and discharging its wastewater to the community owned and privately operated EcoCare wastewater system.    

The institutional context is a small District Council – Kaipara District Council – whose recent history includes the Ecocare fiasco (described above) and associated debt. This private plan change, any public consequences, management of the public interest and any public infrastructure and amenity effects, and the implementation, evaluation and monitoring of the development plan and any conditions falls to this small council to manage.

It is of critical importance to all concerned =- not least the existing residential population - that all of these processes are managed and resourced properly.

To date the public has every reason to be concerned. Council media (eg Peter Wethey in Mangawhai Focus) have stated that due process provides that the plan change be notified, submissions received, and hearings about the Plan Change held. This has been the process with many growth-related plan changes across New Zealand, which have generally focused on environmental effects, and not included as part of the plan change consideration, the costs and budgets related to supporting infrastructure. Development levies have gone some way to meeting this concern, but they are often not coordinated with plan changes, and often out of synch with infrastructure needs.

While the main thrust of the NPS UDC was to ensure that local authorities provided land capacity for residential and business growth, the national direction also recognised the need to plan and provide for growth outcomes in an integrated, coordinated and spatial way. The NPS UDC includes guidance which is available on MfE’s website for all Councils, including KDC, particularly where rapid growth is being experienced. Quoting from the NPS UDC:

Future development strategies:
·         provide certainty to the community and stakeholders about where and when future urban development is likely to occur
·         are responsive to changing circumstances
·         inform decision-making by local authorities and infrastructure providers
·         demonstrate that there will be sufficient development capacity opportunities enabled through local authorities’ district plans, Long Term Plans and infrastructure strategies.
Development and content of future development strategies
Future development strategies should be developed:
·         collaboratively by all local authorities that share jurisdiction over the geographical area of focus
·         in consultation with infrastructure providers, other stakeholders, and the community.
The content of a future development strategy includes descriptions of:
·         minimum targets for sufficient, feasible development capacity for housing
·         evidence underpinning the strategy
·         the location, timing and sequence of development capacity, using maps and tables
·         the infrastructure and implementation actions required to support development capacity
·         how the strategy will respond to changes in demand or land owners’ intentions
·         how consultation was carried out.

There is no evidence that this has occurred in accordance with this guidance in Mangawhai to date, despite the growth pressures that are being experienced, and despite the fact that Mangawhai Central has been foreshadowed for more than ten years.

No future development strategy for Mangawhai has “been developed in consultation with infrastructure providers, other stakeholders, and the community”.  And of critical importance to PPC78, this means that there has been no community consultation worth its salt about:

·         the location, timing and sequence of development capacity, using maps and tables
·         the infrastructure and implementation actions required to support development capacity
·         how consultation was carried out

The absence of the properly resourced coordinated planning, and future development planning, required by the NPS UDC lies behind the amount of public concern that is being expressed throughout the community, and the volume of submissions in opposition.

In my opinion PPC78 requires supporting infrastructure and financing plans organised in accordance with the NPS UDC and prepared with community and stakeholder participation. These should also provide for triggers and staging of development implementation, linked with the staged provision of infrastructure and resources including bore water, to avoid the risks and adverse effects of uncontrolled growth.  

I wish to be heard in support of my submission. 




Monday, May 4, 2020

NZ's Covid-19 Truth is Hiding Behind Numbers

Science and Sensibility

Long ago, in my post graduate studies and my London based operations research working career I did a lot of computer modelling of scientific systems, and built computer models. The study of Pandemics relies heavily on computer modelling. I've done some reading and produced this piece which is a contribution to New Zealand's Covid-19 public policy debate....



Each day since the start of our Covid-19 pandemic New Zealanders are given the day’s numbers at the top of the news – how many new cases, and how many deaths and recoveries. We’re also advised how many cases are in hospital and how many are critically ill. Increasingly we get information about how much has been spent subsidising workers wages, supporting businesses, and what’s needed to support the economy.

Counting and numbers is comforting science. It can be a way of confronting an onslaught as we gradually get our heads around what’s happening, and at the same time bundling it away as if it’s all under control. But what exactly are we being told each time the latest figures are announced, rising consistently, dropping slightly, increasing again? As we do what we’re told, and we wait.

Scientific analysis of an epidemic typically divides the population into three groups of people: Susceptible, Infectious and Recovered. It’s a useful way for us all to understand what’s happening. Computer models of how a pandemic progresses through a population calculate, one day at a time, how many to subtract from the Susceptible and add to the Infectious, and how many to add to the Recovered. How many die each day is also predicted. Assumptions include the average number of contacts each person has per day, the probability contact with an infected person results in infection, what proportion of the Infectious population recover, and what proportion die.

Significantly, the model shows how the Susceptible population reduces over time as the pandemic works its way through the population because people who have Recovered are assumed to be immune (the jury is still out on that assumption with Covid-19). The chance of someone getting infected after social contact drops over time because fewer people are susceptible. Most models assume that as more of the population become immune through having been infected and recovered, major outbreaks happen less and less frequently then stop, and the pandemic is said to have run its course.

Modelling is an essential tool in forming policy to guide national and global responses to a threat like Covid-19. Fine tuning of pandemic model assumptions has been enabled by data from the direct experience of frontline health workers in Wuhan, Italy and New York.

The teams that have been advising the UK government have published descriptions of their models. These are typically structured as above, but provide for more stages in the progression of an infection, divide the population into age groups and geographic areas, and model the capacity of the health system to cope – including the number of intensive care units available (ICU).

Such models have played a critical role in shaping the UK government’s response which has shifted from mitigation to suppression since the pandemic started. The London School of Hygiene and Tropical Medicine (LSHTM) model predicted that, if nothing was done to mitigate the effects of the epidemic in the UK, 85 per cent of the population would be infected, there would be 24 million clinical cases and 370,000 deaths. At its peak, 220,000 ICU beds would be required whereas only 4122 were available.

All of the UK models examined options for mitigation including case isolation, voluntary home quarantine, social distancing of the over-seventies, social distancing for everyone, and school and university closures. But modelling indicated mitigation would still lead to more than 200,000 deaths. UK researchers generally argued the only alternative options to mitigation were suppression strategies, partly because China showed they were possible, and as a reaction against the huge death toll in Italy.

The LSHTM group modelled the use of repeated lockdowns, each triggered when the number of ICU beds occupied by Covid-19 patients reached a particular number. If the threshold was set at a thousand ICU beds, the number of infections could be kept to four million and the number of deaths to 51,000. The downside of the strategy would be that 73 per cent of the time between now and December 2021 would be spent in lockdown, by which time only 11 million people would have been infected and, unless a vaccine had been found, the epidemic would still be far from over.

So far in New Zealand the number that we are not talking about is the size of our Susceptible population. That’s because it’s just about all of us, and instead we talk about elimination or eradication of the virus. However, the Covid-19 virus is alive and well all round the world and despite the best disinfection and sanitising under the sun, it is certainly present in New Zealand. Those of us who haven’t been infected yet are susceptible to infection at any moment – though those moments are minimised while we are in lockdown – and it is assumed that testing and tracing will deal with the Covid-19 viruses already in our environment.

There has been some discussion in New Zealand of second and third waves of infections (as happened in the Spanish Flu epidemic 100 years ago) which are generally though to have been caused by mutants versions of the original virus. That is not the same as recognising that modelled suppression strategies being implemented in the UK and elsewhere show the need to provide for repeated lockdowns for the rest of this year and 2021 at least. Way before then in New Zealand, based on the present rate of Government subsidy spending and the effects of lockdowns on economic activity, the treasury cupboards will be well and truly bare. Before then very difficult public policy decisions will need to be made, which go well beyond the simplistic and comforting numbers we currently see on TV.

We need to have conversations about the cost of a death, and about social inequality.

More than 32,000 people died in New Zealand last year. Of these 353 were due to motor vehicle accidents and 685 were suicides. The largest cause of death - about 30% - were cancer deaths, 15% were from heart disease, and 7% due to brain conditions like stroke.

Of the 3,912 people in the UK who died of COVID-19 in March, 91% had at least one pre-existing condition (most common was heart disease), and on average they had 2.7. Many of those who died would likely have died from pre-existing conditions. This isn’t to say those deaths don’t matter, or to forget that although significantly fewer young people have died, they too have died in numbers that in normal times would be shocking.

We can always live in hope for a vaccine, but we also need to be prepared as a country to expect a very long wait. It is easy to say that “we” are all in this together, but already the gap between the have’s and the have not’s is a chasm. It is relatively easy to ride out long lockdown periods in a pandemic with a big back garden, protected income, and substantial retirement savings. Much harder if you’re unskilled, got a young family, aged parents in care, and a mortgage.

Deaths attributable to the economic consequences of lockdowns must also be anticipated. People will vary enormously in their reactions to being confined in their homes, without regular work. Domestic violence incidents are on the rise here, and US news reports of kilometre long queues for food parcels and people openly carrying guns are frequent.

Our Government says it has “provisioned $52 billion, if necessary, to use for cushioning New Zealanders against the impacts of the virus, positioning New Zealand for recovery, and helping us to reset and rebuild our economy to support long-term recovery.” This would be an enormous debt for the country to carry.

Our death-count due to Covid-19 is now 20. How many deaths have been avoided so far is difficult to know, but we are beginning to understand what the costs of the Government’s suppression strategy are and will be, to us and for the country.

The cost of a life is routinely used in justifying the cost of a new road in New Zealand. It’s set at somewhere between $1,000,000 and $2,000,000. If a new road can avoid enough fatal motor vehicle accidents public money gets invested in the road. The benefit in lives saved exceeds the cost of the new road. Who knows what investment might reduce youth suicide, or prolong the lives of those suffering from cancer?

Part of our preparation for the rest of 2020 and 2021 will require public conversations about how the suffering caused by the pandemic should be allocated and shared, and about the very future of our society.

** I have drawn from an article by Paul Taylor, titled "Susceptible, Infectious, Recovered" contained in the 7th May issue of London Review of Books.

Thursday, July 28, 2022

Hidden Cost of Three Water Reform

After 12 years Auckland Councillor; Watercare Shareholder Representative; Three Water specialist; and Mangawhai Ratepayer Representative, and other stuff - I wrote an OpEd for NZ Herald on 3 Waters.....


Here's the draft OpEd which wasn't published:


Government’s Three Water proposals risk costing the country more in the long run, hide from the public the true cost of traditional engineered systems, resist innovation which benefits ecosystems, and perpetuate century old flush and forget wastewater management.

For most of my last thirty years in New Zealand I have immersed myself in the economics, governance and politics of its sewage, stormwater and water supply issues, and I cannot understand or accept Government proposals to centralise our whole country’s dispersed and different three water systems into entities modelled on Auckland’s Watercare and hoping for the best.

Watercare was mainly formed from amalgamating the assets of Auckland’s four city councils, thus removing the comparative bench-marking which enabled ratepayers to compare the relative water and wastewater costs and benefits of the region’s service providers - thereby encouraging efficiencies, and instead creating a relatively unregulated entity with dozens of managers each earning salaries of hundreds of thousands of public dollars. Watercare’s focus on discharging treated wastewater to the Manukau Harbour and Rangitoto Channel has led to the development of an extremely expensive sewage collection network which leaks in freshwater when it rains (necessitating bigger pipes with a billion dollar price tag), which routinely overflow raw sewage when it rains anyway, and  whose demand for pumps and electricity makes Watercare Auckland’s biggest electricity user.  

Watercare is not a paragon of virtue or exemplar upon which to base New Zealand’s future. Barely a drop of Auckland’s treated wastewater gets returned to land, despite the environmental benefits and savings when there’s a drought, and despite international best practice. When Watercare sought consent to draw Waikato River water for town supply, it was only concerted court action that forced Watercare to treat the Cryptosporidium microbes and agricultural organochlorines that raw contained. And local Tainui cultural concerns that Waikato water should not be mixed with Auckland catchments was dealt with by the “gift” from Watercare to Tainui of a piece of prime land on the banks of the Waikato where a significant battle had been fought.

New Zealand’s governance experience with Watercare is much the same as is experienced with very large public water infrastructure entities the world over. They become laws unto themselves, their internal processes largely invisible, impervious to public opinion, and stuck in the past. This is unlike New Zealand’s smaller community-focussed three water entities whose performance is very much on display, where costs and processes are much more transparent, and which depend on the advice of New Zealand’s nimble, innovative and competitive engineering consultancies such as AECOM, BECA, WSP and Tonkin & Taylor.

These smaller local providers are all on the same learning curve and mistakes are made. Mangawhai’s Ecocare system – an innovative pocket treatment plant designed to replace leaky septic tanks and discharge highly treated wastewater to farmland – is an example. The urbanisation of developing parts of New Zealand does require local communities to incorporate appropriate three water systems into their planning and budgeting, but big doesn’t mean better.

Recent discussion about the costs of computerisation of the proposed four new three-water entities is just the tip of the iceberg of the eye-watering transition costs that can be expected – just look at Watercare setup costs, along with the wasted costs of investment in existing community systems. But the greatest concern is the loss of innovation opportunity that centralisation of three water services will bring, concretely exemplified in Watercare, at a time when advances in membrane technologies, local reuse and collection systems, along with climate change, point in the direction of community level governance, operation and ownership. 

Friday, June 17, 2022

Why is Central Government Reducing Local Government and Democracy?

 This is an OpEd piece sent to NZ Herald a couple of weeks ago. Unpublished. So here it is:

While it is concerning that all of Auckland’s and Northland’s mayors are resigning ahead of  upcoming Council elections, it is not particularly surprising given the unprecedented and unrelenting attacks that have been aimed at Local Government by the present Central Government and which threaten local democracy and community planning in particular.

Kaipara District Council’s Mayor Jason Smith has given the Three Water Reform which forces all Councils to divest public water assets to entities established by new legislation as his main reason for resignation.

That reform is the latest in a salvo of change striking at the very heart of what local governments in Western countries around the world are for, with New Zealand already near the bottom list for functions and responsibilities delegated to local government, lagging significantly behind Japan, Switzerland, Australia and the USA for example.

The previous National Government was the foundry for much of Central Government’s appetite and ammunition for local government reform. The Hon Nick Smith, past Minister of Local Government and Environment, championed the argument that Local Government development planning and infrastructure construction activities were the principle cause of the steep rise in house prices, and that reform was needed.

He argued that Councils were slow to release land for development, making it scarce and thus forcing up land prices needlessly, and inept at building necessary supporting infrastructure such as roading and water and wastewater networks, thereby driving up the development contributions fees payable on each new lot.

The reforms he led included several Resource Management Act changes requiring large councils to review District Plan documents and make property development less restrictive and quicker.

For the past few years Auckland Council has routinely published data showing that despite its new Unitary Plan releasing huge tracts of land for development, and the consequent yearly construction of thousands more homes than have ever been built before, house prices have persistently shown strong upward growth well before COVID supply line restrictions on construction materials.

The present Government has adopted this argument wholeheartedly, and it continues to underpin its plan of attack on Local Government, despite growing recognition and acceptance of the counter argument that the main driver for house price increases since the Global Finance Crisis is the combination of near zero interest rates, cheap loans and mortgages, poor returns on traditional term deposit savings unlocking that money and further increasing demand for housing investment assets, and few meaningful taxes on capital gains. 

In the last two years economists and policy advisers in Australia have accepted this counter argument, and, interestingly, recent and anticipated reserve bank base rate increases here in New Zealand are cited by economists as the main cause of reductions in house price increases now.  

But still Central Government’s local government reform machine grinds on with consequences for local democracy and communities.

Decades of careful community planning have gone into the District Plans that shape the way towns and urban areas develop, change and grow.  These have been tossed aside by Central Government’s Resource Management Housing Enabling Act which permits three homes, three stories high to be built on most urban lots without need for resource consent.

While this reform should produce more homes, some of which might be “affordable”, the impact of additional housing on infrastructure has been ignored. There will be more pressure on water and transport infrastructure which will require upgrading. This needs to be planned and budget provided. Increased density means more people using community facilities such as halls, libraries, schools, sports facilities, parks and reserves. These community concerns are built into local government plans, and are why local government exists, but they are ignored by Central Government’s edict.

While there is room for improvement in local government three water infrastructure provision, there are many informed reasons not to proceed with the current Three Water Reform proposals which very much risk throwing the baby out with the bathwater.

Key among these are international trends away from centralisation of wastewater systems to de-centralised systems where wastewater is treated as close as possible to its source of generation. Considering the three basic components of a wastewater management system - collection, treatment and disposal – collection infrastructure costs account for about 60% of the total budget for a centralised system. Whereas in decentralised or more local systems, this component is reduced and focused mainly on wastewater treatment and disposal.

Local Government is ideally placed to be incentivised to work with its local communities, invest in new technologies, work hand-in-hand with local iwi, and build and operate efficient and sustainable three water systems that fit the local environment. 

Central Government needs to work in partnership with strong and motivated Local Government attracting the best staff and local representation to get the best outcomes, and deliver democracy.


Wednesday, June 17, 2020

COVID kills DOLPHINS

As a s.274 party I have just received a joint memorandum of the Environment Court recording that Panuku wishes to surrender resource consent CST60323353 authorising the construction of the Queens Wharf mooring dolphins and the parties request that the Court close its files.....



Such a good outcome for Queens Wharf and for Auckland - in my opinion.

Friday, June 12, 2020

Commercial Bay in a COVID context

A few days before official opening it was all go in the covered laneway that runs between Lower Queen Street and Lower Albert Street, and is where Queen Elizabeth Square used to be.
The public space is coming together - and those of us who walk through there each day to and from work will breath a sigh of relief. And look forward to other parts of this massive project to come to a conclusion.

But so much has changed in downtown Auckland. Years ago when all this was being planned, there was no COVID scenario. There was no "black swan" event that needed to be planned around.

So many assumptions made around the presence of wealthy cruise ship passengers drawn to Dior, Prada, Gucci and the rest, offices bursting with workers to such an extent there were projections of office space shortages, and thriving cafe and bar life providing opportunities for investment and more urban construction.

Even in lockdown level 1 Lower Queen Street and Queen Street itself is a ghost town. You could fire a cannon up Queen Street at 9:00 in the morning and hit nobody. Almost the same on the footpaths...

It will change. We're social animals and enjoy being out and about. But it will not be the same for a while. Social distanced behaviour has become a norm for now. NZ may be able to sustain this amazing COVID-free bubble it has become, but we all look at the news and we all know that tourists can't easily come, and we are infected by that, and find other ways to live and to occupy ourselves.

Thursday, June 11, 2020

Auckland Water Shortages and Watercare

It seems like yesterday to me, but 1994 was a while ago. Auckland had a much bigger water crisis than we're experiencing now, and it was part of my political education. At the time Watercare was owned by the Auckland Regional Services Trust (ARST), having been put there after a hefty dose of central government driven local government restructuring. Parts of Auckland local government services were privatised - including its landfills. This was in the hey days of neo-liberalism. Regionally owned bulk water services and bulk waste water services were removed from Auckland's regional government (at the time a fresh Auckland Regional Council itself a cut down version of the celebrated Auckland Regional Authority), and placed in ARST, a sort of waiting room for privatisation. That was the birthplace and birth process of Watercare, and much of its institutional behaviour was designed then.

The water shortage came as big surprise to its owners and privatisation strategies took second place to addressing the water crisis. In 1994 due to an unusual roll of the political dice, Alliance candidates were the majority elected to the ARST, and as an active Green Party guy at the time, I was able to get, through my contacts, some Watercare information about what was happening...

This Watercare graph shows how the storage levels changed 1991, 1992, 1993 and 1994. The "normal demand management" curve 1991- end of 1993 shows the typical oscillation of dam storage levels from full to 75% of full. This is normal and to be expected when rainfall is normal. The dam levels get drawn down in summer and fill up in winter. But when there's a drought and the expected winter rains of 1993 didn't eventuate, followed by normal summer consumption, then, by May 1994 things were looking problematic. The graph projects water levels from June 1994, based on different levels of "savings" - up to 30%, and how many days before the dams would be empty.
 
A very well funded conservation campaign was run. (NB: As shown in the graph, Watercare had already run various media campaigns starting at when levels were at 60%, and then hose bans etc)

The main "customers" of Watercare - which then was a bulk water wholesaler - were the four city councils, North Shore City, Waitakere City, Auckland City and Manukau City. (This is before amalgamation). As the drought evolved, some Councils were more supportive of conservation than others. At the time, it was the Councils that metered water use, and charged users for their water. Not Watercare. Watercare charged each of those four councils in bulk. Councils used their water revenues to maintain local water network infrastructure. There was quite a competition between councils as to whose networks were the least leaky - water leaking from pipe networks is a problem the world over. One of the things that got lost when Watercare took over the retailing of water, not just the wholesaling, this bench-marking process has gone. It is not in Watercare's interest to check how much water is leaking from its network. It concentrates on metering what comes out of the pipes and charging customers accordingly.

At the time, Aucklanders were served by a robust NZ Herald with reporters who delved into the detail and understood much of the politics of what went on beyond the media statements.

As the crisis unfolded, about 10 options were canvassed for additional supply. At the time, taking water from the Waikato was at the bottom of the list prepared by senior planners within Watercare, but it quickly jumped to the top of the list when the corporate types who moved into Watercare at the time of the crisis, looked at it. Especially when the possibility of building an Emergency Pipeline got floated, complete with fast-tracking and RMA avoidance.
.
Cartoonists had a field-day with this. Some Councils were all for the emergency pipeline, others were not so sure. And meanwhile it started raining...

Sometimes the pipe was up, and sometimes it was down. It was certainly an idea that appealed to the newly floated Watercare, for all sorts of reasons but the main one was that as a business it would be much more viable with a continuous run of river source to complement its lake storage. At the time I did accept that Auckland needed an insurance policy - a source that could be used when there was a serious crisis. But that preference should always be for raw water sources that were clean. And the Waitakere and the Hunua dams - being in bush catchments without agriculture or urban activity certainly delivered that.

I prepared this graph at the time of the drought (September 1994), which was after rain had been falling reasonably regularly - but not particularly heavily - for 10 weeks or so. It was designed to reveal just how negative Watercare's projections were (3 are shown). And at the time Watercare had got its teeth firmly into the emergency pipeline project. Watercare really wanted that project.
 
NZ Herald reporters - notably Philip English - followed the issue and developments extremely closely, and stuck hard to the facts. It was a matter of huge public interest.

This story is an excellent example of the reporting at the time. The Mr Cook quoted here is an example of the public relations investment that Watercare specialised in at the time. Since then Auckland Council and all Auckland CCO's have invested heavily in public relations experts and concentrated on spin-doctoring and managing and influencing public opinion. One of my major pieces of education through this whole period was that information asymmetry is a thing - that large CCO's and councils hold onto information that is not in their interests to make public. Anyone questioning local government - and especially CCOs is at an enormous disadvantage because of the lack of transparency around key pieces of information. Reports are routinely with-held etc.

I note the mention in this article of Ashton Wylie. He and I met after I ran some OpEd pieces in NZ Herald. He was a wealthy importer of Pansonic equipment - and passionate about Auckland's water resource. We got on like a house on fire and he funded me to seek expert advice outside New Zealand for expert evidence. He help me financially when it came to the Environment Court - see later...
 
This report is dated 28th September. I remember at the time phones running hot - people wanting to know "how much rain fell out your way?" It was knife-edge. Watercare was leaving no stone unturned and had mobilised a significant lobbying campaign in Wellington to keep MPs on side. And all funded with public money.

In fact the Emergency Pipeline project never happened. It rained enough and at the right time so that the Emergency legislation did not get a majority in Parliament. So 1994 ended well. But just as rust never sleeps, neither does a good project inside Watercare. considerable sums had been invested - of public money - in getting that project off the ground. Much of that effort was then directed at developing a proper Waikato based bulk water source, and sometime in 1997 Watercare notified resource consent applications to build a pipeline, a new treatment plant, and to take water from the  Waikato River and treat it and augment Auckland's water supply. Which is where the next part of this story goes....

One of the experts I found - and he came out to New Zealand - was Professor Dan Okun. From South Carolina, USA. He was profoundly expert and enthusiastic about the reuse of treated wastewater for non-potable purposes. I learned so much from him. His expert evidence was a big part of my evidence in the Environment Court. He knew a lot about cities in the USA that routinely reticulated highly treated wastewater for industrial washing, and golf course irrigation and suchlike. It gets reticulated in purple pipe networks. It's a whole network industry across big parts of the USA. Turns out also to be common in arid parts of Australia, and also in Japan. The diagram above is one I prepared based on Prof Okun's advice - mainly to show how 250,000 cubic metres drawn from a dam daily (equivalent to 250 million litres) - can be equivalent to a total supply of 750,000 cubic metres per day if you use the water three times before discharging it. It's simplistic - and doesn't talk about golf course and park irrigation (where water evaporates). 

Remember this all happened 25 years ago. And the discussion you get from Watercare today is just as ignorant and uninformed as it was then. Its business model, with a single network of supply of freshwater, top quality, used for everything, from drinking to washing out concrete trucks, all using premium piping, and all charged for at the same rate, used once, then wastewater treated to a "you can swim in it" standard, which is then all dumped. 
  
A key issue with taking water for drinking from the Waikato is the fact - at the time - there were almost 3,000 separately consented discharges into it. Farms, factories, geothermal, and sewage treatment plants. Contaminants that were most significant included organochlorines from horticulture, and cryptosporidium bugs from dairy farm sewage. These contaminants are not treated by the water treatment carried out on raw waters from the Waitakere and the Hunua dams. If raw water did come from the Waikato, it would need additional treatment.

I haven't published the full page advertisment that Watercare ran at the time. It showed a glass of water. The message was that the water would be the same. I challenged them at the Advertising Standards Complaints. Watercare - like Ports of Auckland - retain the best and brightest lawyers from Russel McVeagh. It isn't just about information asymmetry. Watercare has a culture of winning. Not just sustainable reporting awards (which are a travesty), but anything. Particularly where its reputation might be challenged. It's only public money after all.
 
Nevertheless the cartoons kept coming,and public concerns were real.

Watercare's resource consent applications were granted by the relevant TLAs - of course it was Environment Waikato that heard the application to take water from the Waikato, and due to the vagaries of the RMA, once water is in a pipe, the RMA is no longer interested in it. Many of us joked about it being "discharged" from taps and pipes into cups and glasses - but those arguments didn't hold much water....

You get a flavour from the above report as to how Watercare (and Ports of Auckland, and Auckland Council), can all throw piles of public money at public interest issues to ensure they win. But there was information and concern in the public arena about what was in the Waikato water.

This NZ Herald editorial summed up some of those concerns. Just a week or so before the Environment Court hearing, Waitakere City Council withdrew its appeal, and then so did Tainui (the Sunday before - it was gifted a chunk of land I think the site of a maori battle, by Watercare, which bought them off). That left Mr Hamilton and me as appellants. Not good.

But then I discovered that Manukau City Council had become a s274 party to my appeal. I was approached by someone and encouraged to keep my hat in the ring as they tried to work something though with Watercare. Manukau City is closest to where Waikato water would come out the tap, and had concern about water treatment. I learned afterward that Watercare was pressured by Manukau City council to sign the "Manukau Agreement" - this committed Watercare to including two additional treatment processes for Waikato water. One was a carbon bed filter - for organochlorines, and the second was nano-filtration - for cryptospordium.

This was a huge result. But went totally under the radar. If I had withdrawn my appeal, under pressure, Manukau City Council would no longer have had any standing in the appeal....
   
My second expert, funded thanks to Ashton Wylie, was Dr Perri Standish-Lee from California (I think). She uncovered the work of NZ's Dr Gillian Lewis and submitted her own arguments as an expert witness for my appeal. You will see reported in this article that I stood for North Shore City Council at the time.
 
Again, another positive NZ Herald report of how Watercare sued me (and Mr Hamilton) for costs after the Environment Court appeal. The gains won from the action were all in the Manukau Agreement already. We gained nothing more in the Environment Court.

So. What does all this mean now? Well - Watercare is bigger and stronger now than it was in 1994. There are no sizeable city councils to challenge it. Auckland Council has as much control over it, as it has over Ports of Auckland or Auckland Transport - ie little control. Watercare is very well resourced, and it's no surprise it is so impervious to challenge. It was designed and built by a chief executive for whom winning and the appearance of winning was everything. He was appointed in 2010 on the strength of this reputation to design the newly amalgamated Auckland Council. This is just as robust in the face of public concern and any internal dissent.

A major factor in Auckland's water shortage in 2020 is the monopoly structure of the responsible organisations, their focus on revenues, and their interest in delivering and funding a steady stream of large engineering projects to keep expensive and highly qualified project teams in employment.

Until those things change, and until there is a fundamental commitment to sustainability, including the reuse of recycled water for example, the widespread use of locally owned rainwater storage, and appropriately encouraged and systematic water conservation systems Auckland will continue to be vulnerable to weather and to opportunistic behaviours from its publicly owned water utilities.

Tuesday, June 9, 2020

When does Tiny House need Building Permit?

A two storey Tiny House was towed to this residential site in Mangawhai a couple of weeks ago, and since then the owner has been systematically preparing it so he and his partner can live in it part-time.

The planning question this sort of activity poses is when does such a development require a Building permit?

I'm interested in your views please. Use the comment facility of the blog to provide your suggestions - anonymously or otherwise.
This image shows the corner support used. A car jack on a concrete tile. The chain is wrapped around the trailer chassis beam, and U-bolted to a wooden post which appears to be set in concrete into the ground. The chain is likely to prevent the structure tipping in a strong wind. The site is elevated and exposed (see picture at end of this post). The elevation shown in picture 1 is to the north, and is about 8 metres long by about 4.5 metres high.
The same chain/post combination is deployed at the opposite end. Timber lengths are used to support the structure.
The wheels have been removed from the trailer supporting the structure, and axles protected with plastic covers from water and suchlike.
Electric power is provided to the Tiny House from this mains switch and electric metre board which has been built into one corner of the site.

The floor area adjacent to the elevation shown (to the south) contains the greywater drainage pipes from kitchen and bathroom which have yet to be connected to any disposal or collection system. I understand a waste pipe will be installed directing greywater into a storage tank located next to the retaining wall visible in the first pic (above). This will be pumped out from time to time. Unclear so far.
A freshwater tank about 2500 litres capacity has been set into the ground and collects runoff from the roof. It has no overflow discharge system as yet.
Kitchen and bathroom water gets heated here and reticulated into the Tiny House.

I understand there is a composting toilet in the bathroom part of the Tiny House. It is unclear whether urine can be passed into the composting toilet system.

Grey water discharge systems are not fitted as yet.
The locked cabinet shown by the trailer draw bar contains the gas bottle. The water pump is mounted on the timber platform at the left.
This view is to the East. The Eastern end houses a bathroom utility area at the ground floor, and a mezzanine level above for the bedroom which is accessed by means of an internal staircase.

So. All you experts and practitioners out there, what's the regulatory position on a Tiny House like this in a residential area? It complies with District Plan provisions. Fixture to piles, or connection to the local wastewater network, triggers the need for Building Consent in Kaipara District. But as it stands, would it comply in your neck of the woods?

Friday, May 29, 2020

Submission Kaipara District Council Plan Change 78 Mangawhai Central

According to Kaipara District Council website information:
Private Plan Change 78 (PPC78) was lodged on 3 December 2019 by Mangawhai Central Limited. PPC78 seeks to rezone 130ha of land contained within the Estuary Estates Structure Plan of the operative Kaipara District Plan 2013 (the District Plan), PPC78 area comprises of 83 Molesworth Drive, and Lots 1 and 4 DP 314200 Old Waipu Road, Mangawhai.
This blog posting contains some information about this plan change, public concerns, and my submission. This image is taken from latest issue of Mangawhai Focus.....

Preamble

There's a lot of history to this story. Very briefly, about ten years ago, Chapter 16 which provides for Mangawhai Central development was written into the Kaipara District Plan. Thus the proposed development had its own zoning controls built into the District Plan. Those provisions would have enabled the development of a new piece of town located on about 130 hectares of rural land situated on Molesworth Drive between the towns of Mangawhai Heads and Mangawhai Village. The development proposed then included about 500 residential lots (up to about 1000 square metres), 17,000 square metres of commercial development including a supermarket, and a retirement village. Various resource consents would be needed for earthworks and suchlike. Simmering concerns within the community related to the impact on the road network, the wastewater system, surrounding estuary environment, and the aquifer because of proposals to take bore water.

Fast forward to 2019, when the development company (Virandah Partners) lodged a private plan change whose purpose was basically to double the development potential of the site - to provide for 1000 residential sites and 34,000 square metres of commercial development. The application is accompanied by substantial technical documentation. On the face of it, careful urban design, green space, walking networks, on site streetscape plans, will provide for a well functioning new town with a population of around 5,000 where previously there were paddocks. (5,000 is more than the current population of Mangawhai Heads and Mangawhai Village combined.)

The concerns of existing communities and residents relate to what effects this new town will have on surrounding environment - particularly the transport and wastewater infrastructure and freshwater. 
  
Mangawhai communities are mobilising again in the face of growth pressures and planning processes that persist in rocking the boat. You can get a feel for these concerns at the campaign website run by Clive Boonham.  

I have written a submission which is here....

Twenty Years Ago
Twenty years ago I was invited to help the Mangawhai Residents and Ratepayers Association (MRRA) make submissions on a pro-development plan change (Plan Change 9) that was notified by Kaipara District Council.  MRRA approached me because of my experience working with North Shore City Council on its wastewater network and system, and because of research I'd done abroad on alternative community wastewater systems. At that time Kaipara District Council came under pressure from the Regional Council to clean up the Mangawhai Estuary, and from developers keen to follow the Cooks Beach example and get intensive subdivision development underway. KDC pushed ahead with a proposed $16 million sewage scheme. Kaipara District Council decided they could not fund the project and instructed Beca’s to put the whole project out to private tender. Quoting from my submissions at the time:

"MRRA are particularly concerned that Mangawhai residents themselves have been insufficiently consulted over the implications and consequences of PC9. The consultation with the community over the infrastructure study, what should be done, what options to pursue, how a possible community sewage scheme should be funded, how it should be built and owned, are all severely deficient – given the huge issues for the community....

"We have even more of an issue with what is proposed for wastewater, and how that has been shared with the community. The MRRA recognise that how we tackle wastewater is fundamental to the proposed zonings in PC9. Many of the proposed changes cannot go ahead – or at least cannot be made to happen in real life - without the proposed community waste water system. The huge increase in urban intensification envisaged by PC9 for Mangawhai can only occur with a reticulated sanitation system. We believe there is a gap in the council's communication over this. It is hugely controversial, building something as expensive as a community sewage scheme, and involving the private sector in the manner proposed. It represents a major political shift in service provision. I am not aware that the community has really much of an inkling as to the possible impact of what is proposed - in terms of costs, changes in accountability, what their options are - and indeed whether they have been asked whether this is what they want for their community....

"We are of course aware that PC9 does not explicitly mention any costs for the proposed Community Sewage System. PC9 is explicit about financial contributions required for stormwater and roads, but is silent when it comes to wastewater. Documents we have sighted suggest the capital cost of the sort of system which seems to be preferred by Kaipara District Council and its consultants – Beca – is $16,000,000. There are 1200 affected lots in Mangawhai Township now, and PC9 envisages a further 535 – giving a total of 1735. If we all paid equally for this sewage system, it would cost each ratepayer $9221. But PC9 is silent about this huge sum of money….

There are many parallels between this plan change (twenty years ago) and the way Private Plan Change 78 is being mishandled and miscommunicated by Kaipara District Council. The quoted figure of $16 million for the EcoCare wastewater system is of course woefully short of the actual cost which was in the vicinity of $80 million. Unless we learn from this history, we are doomed to repeat it.

Auditor General Enquiry into Mangawhai Community Wastewater Scheme

In November 2013, after an immense and drawn out public campaign, and much anxiety and cost distributed throughout the Mangawhai Community, the Office of the Auditor General published its 400 page report into what had happened. Of critical importance to the present plan change proposal, are the OAG findings. And here I quote from the report’s overview:

"After 20 months of carefully collecting and analysing evidence, this inquiry has made some clear findings about what happened. The positive findings are that:
• the decision that Mangawhai needed a reticulated wastewater scheme was well founded; and
• the wastewater scheme that has been built works effectively and has appropriate capacity for population growth.  (NB: The OAG report was prepared in 2013 – when population growth forecasts would have included at max a half sized Mangawhai Central proposal.)

"The other findings are more sobering. Overall, KDC has ended up with a wastewater scheme that works, but it has come at a significant cost. The fact that we cannot put a precise figure on that cost is indicative of KDC’s poor management. KDC’s records did not contain good or systematic information on the total amount spent. However, our best estimate is that the total cost was about $63.3 million. The overall costs are not just financial. They include a failed council, councillors who have been replaced with commissioners, the departure of a chief executive, a severely damaged relationship between the council and community, an organisation that has needed to be rebuilt, and much more….

"KDC’s decision-making processes were also poor throughout the entire 16 years of the wastewater project. KDC relied too heavily on its professional advisers and had a practice of receiving briefings and effectively making decisions in informal workshops. The governance and management arrangements put in place specifically for the project were also inadequate. In our view, these underlying problems made it harder for KDC to deal with the problems that emerged as the project progressed.

"KDC decided that it wanted to explore a public private partnership (PPP) approach, to keep the debt “off the balance sheet” and to put as much risk as possible on to the private sector provider. In my view, this decision took KDC out of its depth. It followed all the right basic steps when it initially went to the market for advisers and put the project to tender, but it did not fully understand the complexity of what it was doing. The early decision to use a PPP approach put too much emphasis on achieving a certain accounting outcome and the transfer of risk, and not enough on value for money and affordability. KDC’s decision-making about the PPP was not consistent with the good practice guidance that was available at the time….

"I am also concerned that KDC does not appear to have regarded the disciplines and checks in the contract about the construction and handover process as particularly important. In my view, the relatively relaxed approach that was taken to some of these protections, such as the approval processes involved in commercial acceptance and handover of the asset, exposed KDC to unnecessary risk…..

"For these and other reasons, the costs of the project increased steadily. KDC assessed affordability by considering the annual cost to ratepayers. It decided to increase the number of estimated ratepayers that would be covered by the scheme and contribute to funding it. KDC increased the scope of the project to cover more properties and adopted new growth projections that assumed more properties would be developed. We have criticised these decisions on the grounds that they were not based on good information and did not take adequate account of the risk of slower growth. KDC’s focus on the annual cost to the ratepayer as a measure of affordability was unfortunate: it meant that it did not fully appreciate the significant increase in capital costs and the effect on the project’s overall affordability…..

I have quoted selectively here, but not taken any of the matters out of context. It appears that much of this criticism is at risk of being laid at the feet of the Kaipara District Council again.  

While not strictly a PPP, the current plan change arrangement will clearly be of direct benefit to the developer (because of the increased development potential of the land) and to the Kaipara District Council (not least because of increased rate revenues).

The way the costs and capacities of roading, wastewater and the receiving natural environment are being handled in the plan change application has forced existing residents and property owners to defend themselves, their interests, and the surrounding environment in much the same way as they had to twenty years ago.    

National Policy Statement on Urban Development Capacity 2016

This NPS was enacted in 2016. Its objectives apply to all decision-makers when making planning decisions that affect an urban environment. The objectives relate to outcomes; evidence & monitoring; responsiveness and coordination. In particular there are objectives requiring coordinated planning evidence and decision-making in “Urban environments where land use, development, development infrastructure and other infrastructure are integrated with each other.”

In terms of outcomes for planning decisions, the NPS imposes duties on the relevant local authority:


The preamble to the NPS gives direction on how infrastructure planning is a critical part of the provision of development capacity:

Development capacity must be provided for in plans and also supported by infrastructure. Urban development is dependent on infrastructure, and decisions about infrastructure can shape urban development. This national policy statement requires development capacity to be serviced with development infrastructure, with different expectations from this infrastructure in the short, medium and long-term. It encourages integration and coordination of land use and infrastructure planning. This will require a sustained effort from local authorities, council controlled organisations, and infrastructure providers (including central government) to align their intentions and resources.

It is my submission that KDC has not given effect to all of the relevant objectives of the NPS UDC in the way it has approached the community consultation on PPC78 because it has separated from the consultation facts and figures about infrastructure capacity, costs and who and how those matters will be provided for.  

There is no evidence that the planning for Mangawhai Central development is coordinated with infrastructure planning.

The plan change technical documentation is particularly deficient in the way it deals with traffic matters and their effects on Molesworth Drive, and almost silent on the way it deals with the community owned wastewater scheme and how the wastewater needs of the proposed development will be met and paid for.

In my opinion the infrastructure aspects of the plan change need to be reviewed.

Deficiencies in Private Plan Change 78 Process

The development and institutional context for this plan change inevitably influences perceptions and issues that arise for both the developer, the existing population, and the planners and other experts engaged to process the application.

To start with, the proposed development, when complete, will be a small town with a population of between 4000 and 4500 (assuming 1000 homes with 4 people each and a retirement complex), situated midway between two existing small towns: Mangawhai Heads whose population is about 2,500 (estimating from 2018 figures) and Mangawhai Village whose population is about 1,000, and adjacent to a moderate capacity arterial roadway (Molesworth Drive), drawing water from a common aquifer (at the proposed rate of about 100 cubic metres/day), and discharging its wastewater to the community owned and privately operated EcoCare wastewater system.    

The institutional context is a small District Council – Kaipara District Council – whose recent history includes the Ecocare fiasco (described above) and associated debt. This private plan change, any public consequences, management of the public interest and any public infrastructure and amenity effects, and the implementation, evaluation and monitoring of the development plan and any conditions falls to this small council to manage.

It is of critical importance to all concerned =- not least the existing residential population - that all of these processes are managed and resourced properly.

To date the public has every reason to be concerned. Council media (eg Peter Wethey in Mangawhai Focus) have stated that due process provides that the plan change be notified, submissions received, and hearings about the Plan Change held. This has been the process with many growth-related plan changes across New Zealand, which have generally focused on environmental effects, and not included as part of the plan change consideration, the costs and budgets related to supporting infrastructure. Development levies have gone some way to meeting this concern, but they are often not coordinated with plan changes, and often out of synch with infrastructure needs.

While the main thrust of the NPS UDC was to ensure that local authorities provided land capacity for residential and business growth, the national direction also recognised the need to plan and provide for growth outcomes in an integrated, coordinated and spatial way. The NPS UDC includes guidance which is available on MfE’s website for all Councils, including KDC, particularly where rapid growth is being experienced. Quoting from the NPS UDC:

Future development strategies:
·         provide certainty to the community and stakeholders about where and when future urban development is likely to occur
·         are responsive to changing circumstances
·         inform decision-making by local authorities and infrastructure providers
·         demonstrate that there will be sufficient development capacity opportunities enabled through local authorities’ district plans, Long Term Plans and infrastructure strategies.
Development and content of future development strategies
Future development strategies should be developed:
·         collaboratively by all local authorities that share jurisdiction over the geographical area of focus
·         in consultation with infrastructure providers, other stakeholders, and the community.
The content of a future development strategy includes descriptions of:
·         minimum targets for sufficient, feasible development capacity for housing
·         evidence underpinning the strategy
·         the location, timing and sequence of development capacity, using maps and tables
·         the infrastructure and implementation actions required to support development capacity
·         how the strategy will respond to changes in demand or land owners’ intentions
·         how consultation was carried out.

There is no evidence that this has occurred in accordance with this guidance in Mangawhai to date, despite the growth pressures that are being experienced, and despite the fact that Mangawhai Central has been foreshadowed for more than ten years.

No future development strategy for Mangawhai has “been developed in consultation with infrastructure providers, other stakeholders, and the community”.  And of critical importance to PPC78, this means that there has been no community consultation worth its salt about:

·         the location, timing and sequence of development capacity, using maps and tables
·         the infrastructure and implementation actions required to support development capacity
·         how consultation was carried out

The absence of the properly resourced coordinated planning, and future development planning, required by the NPS UDC lies behind the amount of public concern that is being expressed throughout the community, and the volume of submissions in opposition.

In my opinion PPC78 requires supporting infrastructure and financing plans organised in accordance with the NPS UDC and prepared with community and stakeholder participation. These should also provide for triggers and staging of development implementation, linked with the staged provision of infrastructure and resources including bore water, to avoid the risks and adverse effects of uncontrolled growth.  

I wish to be heard in support of my submission. 




Monday, May 4, 2020

NZ's Covid-19 Truth is Hiding Behind Numbers

Science and Sensibility

Long ago, in my post graduate studies and my London based operations research working career I did a lot of computer modelling of scientific systems, and built computer models. The study of Pandemics relies heavily on computer modelling. I've done some reading and produced this piece which is a contribution to New Zealand's Covid-19 public policy debate....



Each day since the start of our Covid-19 pandemic New Zealanders are given the day’s numbers at the top of the news – how many new cases, and how many deaths and recoveries. We’re also advised how many cases are in hospital and how many are critically ill. Increasingly we get information about how much has been spent subsidising workers wages, supporting businesses, and what’s needed to support the economy.

Counting and numbers is comforting science. It can be a way of confronting an onslaught as we gradually get our heads around what’s happening, and at the same time bundling it away as if it’s all under control. But what exactly are we being told each time the latest figures are announced, rising consistently, dropping slightly, increasing again? As we do what we’re told, and we wait.

Scientific analysis of an epidemic typically divides the population into three groups of people: Susceptible, Infectious and Recovered. It’s a useful way for us all to understand what’s happening. Computer models of how a pandemic progresses through a population calculate, one day at a time, how many to subtract from the Susceptible and add to the Infectious, and how many to add to the Recovered. How many die each day is also predicted. Assumptions include the average number of contacts each person has per day, the probability contact with an infected person results in infection, what proportion of the Infectious population recover, and what proportion die.

Significantly, the model shows how the Susceptible population reduces over time as the pandemic works its way through the population because people who have Recovered are assumed to be immune (the jury is still out on that assumption with Covid-19). The chance of someone getting infected after social contact drops over time because fewer people are susceptible. Most models assume that as more of the population become immune through having been infected and recovered, major outbreaks happen less and less frequently then stop, and the pandemic is said to have run its course.

Modelling is an essential tool in forming policy to guide national and global responses to a threat like Covid-19. Fine tuning of pandemic model assumptions has been enabled by data from the direct experience of frontline health workers in Wuhan, Italy and New York.

The teams that have been advising the UK government have published descriptions of their models. These are typically structured as above, but provide for more stages in the progression of an infection, divide the population into age groups and geographic areas, and model the capacity of the health system to cope – including the number of intensive care units available (ICU).

Such models have played a critical role in shaping the UK government’s response which has shifted from mitigation to suppression since the pandemic started. The London School of Hygiene and Tropical Medicine (LSHTM) model predicted that, if nothing was done to mitigate the effects of the epidemic in the UK, 85 per cent of the population would be infected, there would be 24 million clinical cases and 370,000 deaths. At its peak, 220,000 ICU beds would be required whereas only 4122 were available.

All of the UK models examined options for mitigation including case isolation, voluntary home quarantine, social distancing of the over-seventies, social distancing for everyone, and school and university closures. But modelling indicated mitigation would still lead to more than 200,000 deaths. UK researchers generally argued the only alternative options to mitigation were suppression strategies, partly because China showed they were possible, and as a reaction against the huge death toll in Italy.

The LSHTM group modelled the use of repeated lockdowns, each triggered when the number of ICU beds occupied by Covid-19 patients reached a particular number. If the threshold was set at a thousand ICU beds, the number of infections could be kept to four million and the number of deaths to 51,000. The downside of the strategy would be that 73 per cent of the time between now and December 2021 would be spent in lockdown, by which time only 11 million people would have been infected and, unless a vaccine had been found, the epidemic would still be far from over.

So far in New Zealand the number that we are not talking about is the size of our Susceptible population. That’s because it’s just about all of us, and instead we talk about elimination or eradication of the virus. However, the Covid-19 virus is alive and well all round the world and despite the best disinfection and sanitising under the sun, it is certainly present in New Zealand. Those of us who haven’t been infected yet are susceptible to infection at any moment – though those moments are minimised while we are in lockdown – and it is assumed that testing and tracing will deal with the Covid-19 viruses already in our environment.

There has been some discussion in New Zealand of second and third waves of infections (as happened in the Spanish Flu epidemic 100 years ago) which are generally though to have been caused by mutants versions of the original virus. That is not the same as recognising that modelled suppression strategies being implemented in the UK and elsewhere show the need to provide for repeated lockdowns for the rest of this year and 2021 at least. Way before then in New Zealand, based on the present rate of Government subsidy spending and the effects of lockdowns on economic activity, the treasury cupboards will be well and truly bare. Before then very difficult public policy decisions will need to be made, which go well beyond the simplistic and comforting numbers we currently see on TV.

We need to have conversations about the cost of a death, and about social inequality.

More than 32,000 people died in New Zealand last year. Of these 353 were due to motor vehicle accidents and 685 were suicides. The largest cause of death - about 30% - were cancer deaths, 15% were from heart disease, and 7% due to brain conditions like stroke.

Of the 3,912 people in the UK who died of COVID-19 in March, 91% had at least one pre-existing condition (most common was heart disease), and on average they had 2.7. Many of those who died would likely have died from pre-existing conditions. This isn’t to say those deaths don’t matter, or to forget that although significantly fewer young people have died, they too have died in numbers that in normal times would be shocking.

We can always live in hope for a vaccine, but we also need to be prepared as a country to expect a very long wait. It is easy to say that “we” are all in this together, but already the gap between the have’s and the have not’s is a chasm. It is relatively easy to ride out long lockdown periods in a pandemic with a big back garden, protected income, and substantial retirement savings. Much harder if you’re unskilled, got a young family, aged parents in care, and a mortgage.

Deaths attributable to the economic consequences of lockdowns must also be anticipated. People will vary enormously in their reactions to being confined in their homes, without regular work. Domestic violence incidents are on the rise here, and US news reports of kilometre long queues for food parcels and people openly carrying guns are frequent.

Our Government says it has “provisioned $52 billion, if necessary, to use for cushioning New Zealanders against the impacts of the virus, positioning New Zealand for recovery, and helping us to reset and rebuild our economy to support long-term recovery.” This would be an enormous debt for the country to carry.

Our death-count due to Covid-19 is now 20. How many deaths have been avoided so far is difficult to know, but we are beginning to understand what the costs of the Government’s suppression strategy are and will be, to us and for the country.

The cost of a life is routinely used in justifying the cost of a new road in New Zealand. It’s set at somewhere between $1,000,000 and $2,000,000. If a new road can avoid enough fatal motor vehicle accidents public money gets invested in the road. The benefit in lives saved exceeds the cost of the new road. Who knows what investment might reduce youth suicide, or prolong the lives of those suffering from cancer?

Part of our preparation for the rest of 2020 and 2021 will require public conversations about how the suffering caused by the pandemic should be allocated and shared, and about the very future of our society.

** I have drawn from an article by Paul Taylor, titled "Susceptible, Infectious, Recovered" contained in the 7th May issue of London Review of Books.