Richard Rudman Submission on the Draft Proposal

This submission is a hard-hitting analysis of the LGC's draft proposal.

Note: emphasis (bold text) has been added to the original text.



  1. This submission is made by Richard Rudman, a resident of Martinborough and former member of the Martinborough Community Board.
  2. In brief, I oppose the proposal. For the reasons outlined in this submission, the proposal is so fundamentally flawed that it should not be allowed to proceed.
  3. The first issue is the assumption that amalgamation of the existing councils into a single territorial authority is needed, appropriate, and justified. The proposal scarcely addresses these questions. Instead, it assumes that a Wairarapa District Council would be a positive change, without any real discussion of the reasons for this, or of the options.
  4. In other words, the proposal fails on these three counts:
    • If there is a need for restructuring and reorganisation, it is not adequately described and discussed in this proposal.  
    • If there is a case for the replacement of the three existing councils, it is not made out in the proposal.
    • The proposal is long on assertion and short on argument backed by objective evidence or facts. It contains insufficient information to support the recommendations it makes.
  5. It is possible that the existing councils could operate more effectively and collaborate more extensively, but that possibility is not addressed in the proposal. Instead, it is assumed that organisation change is the only way to achieve such objectives. There are alternatives.
  6. Even if restructuring and reorganisation were the best way to achieve more effective operations and collaboration, the proposal fails to establish how or why a single council would achieve those objectives. It fails to establish the need to move away from the organisational status quo, and appears to be proposing change for the sake of change.
  7. The proposal seems to be based on an assumption that local government amalgamation is desirable. This is an ideological stance, which is not supported by international experience, or by evidence from the relatively new Auckland Council. The international evidence is that local government amalgamation does not achieve its stated objectives, or produce more effective or efficient administration or delivery of services, or lead to lower operating costs, or improve consultation and communication. Moreover, the evidence is that the amalgamated local authority becomes more and more remote from the communities it is meant to represent and serve.
  8. The Commission appears to have been influenced by what it perceives as widespread support for change. Its evidence for this support is based largely on self-generated responses to polls and surveys. The results of such surveys are notoriously unrepresentative.
  9. I doubt that many of the people who express support for change have read the Commission’s proposal. Instead, they assume that a single local authority would be more efficient and have lower operating expenses. Intuitively, that seems reasonable. But it is not supported by the evidence, either in this proposal or in the experience of local government amalgamation around the world.
  10. The Commission also assumes there is a significant degree of common interest in the Wairarapa. That is highly debatable.  It is more likely that people identify less with the Wairarapa than with the local communities in which they live, have businesses, and work. My personal decision was to shift residence from Wellington to Martinborough, not to the Wairarapa, or even the South Wairarapa.
  11. The Wairarapa is a collection of different communities which happen to be located within a geographical area. If there are linkages, they result from geographical proximity rather than any  sense of a single community.
  12. There appears to be significant and justified concern outside Masterton that the interests of the smaller centres, and the rural population, would be overwhelmed by Masterton if there were to be a single authority. That concern is further justified by the proposed membership of the Wairarapa District Council, where the interests of Masterton would clearly dominate the agenda, the discussion, and its decisions.
  13. The proposal acknowledges (para 19) that the existing councils work together and collaborate to provide some council services. However, it does not consider how that co-operation and collaboration could be extended as an alternative to organisational restructuring, with the inevitable consequent loss of local identity and participation. The Wairarapa Combined District Plan and the Wairarapa Library Service are possible models for extending the ways in which the existing councils could work together, but such alternatives are ignored in this proposal.
  14. The proposal asserts, but provides no evidence, that local government in the Wairarapa faces difficulty recruiting and retaining specialist council staff, that an increasing proportion of the population is on fixed incomes, and that infrastructure will need to be upgraded to meet changing requirements (para 19). It offers no backing for these assertions, or any assessment of the risks involved, and provides no explanation of how a single council would be better able than the three existing councils to address such challenges.
  15. The proposal concludes that a single district council could best promote good local government in the area (para 20). However, it does not say how or why this would happen, and the assertion is no more than an article of faith.
  16. Again, the advantages of a single council are listed as a series of assertions (para 21), but are not supported by evidence. It is arguable whether a single council is the only, or best, way to secure the benefits claimed.
  17. For example, the proposal asserts (para 21) that a single council would be able to advocate “more strongly for the Wairarapa community as a whole”. This assumes there are whole-of-Wairarapa interests which need stronger advocacy — yet the proposal gives no examples. It also ignores the quite effective advocacy that already exists. Here are just two examples. Destination Wairarapa combines the existing councils, tourism operators and other interests in effective promotion of the region, and the councils showed they work together as effective advocates for the district when major work was done on the Rimutaka Hill road a few years back.
  18. The proposal further asserts (para 21) that a single council would make it “easier and cheaper for companies, and sporting and community groups that work across the Wairarapa to do business”. However, it does not describe any current difficulties in this regard, nor does it say how a single council would achieve this outcome. Is it more than wishful thinking?
  19. Similarly, the proposal promises “potential productivity improvements” for businesses and community groups if they only had to work with a single council (Annex 2). It asserts, with certainty but no guarantees, that “[I]t would be easier and cheaper for them to obtain consents and permits, understand council fees and engage in council processes”. Even if this were true, there is no reason why harmonisation of this kind could not be achieved by the existing councils (as they have with the combined district plan).
  20. The proposal also makes claims (para 21) for the capabilities of a combined council. Again, it does not say how or why these claimed advantages would be available to a single organisation, but could not be available to the existing councils. The proposal should set out why a change in organisation and structure would achieve these results — and why they could not be achieved in other ways.
  21. The proposal also claims that a single council would provide simplified decision-making (para 21). The problem here is that local government is concerned with democracy, representation, participation, and effectiveness — as much as with efficient or simple decision-making processes. Doing away with elected representatives altogether would also simplify decision-making, but would not be acceptable.
  22. The proposal claims (para 21) there would be “modest financial savings from amalgamation”. The estimated net savings — $1 million a year for 10 years — are so modest that they serve as an argument against change, rather than for it. The amounts are hardly material, and are indeed mainly speculative.
  23. In addition, the changes which are offered as the possible basis for these savings could occur without any organisational change. The existing councils have already demonstrated that they can work together on policy and administration issues; there is no need for structural change to achieve those objectives.
  24. It is a matter of concern that two-thirds of the estimated savings come from the sale of surplus property. This raises two issues:
    • Should the proceeds of the sale of capital assets be applied to the reduction of operating expenses? Good accounting practice would stop that.
    • The proposal assumes that the surplus properties (which are not identified) could be sold at 105% of their current value. On the surface, that seems unlikely. One wonders, for example, what market demand there would be for a two-story office building in Martinborough, the current offices of the South Wairarapa District Council.
  25. On the matter of possible savings and asset sales, the proposal needs much more information and analysis. Estimates are not good enough without supporting evidence. Otherwise, if enacted, this proposal would be likely to join the long list of local government amalgamations which have failed to meet their financial targets.
  26. It is worth noting that the proposal concedes (para 22) that transition costs would outweigh cost savings for the first two years. Add this to the speculative income from the sale of capital assets, and the overall savings imagined for the first ten years are shown to be illusory.
  27. The possible disadvantages of amalgamation (para 22) significantly understate the risks to democratic representation and participation, and to the efficiency and effectiveness of local government in the Wairarapa.
  28. The proposal also makes a series of statements about advantages and disadvantages (Annex 2) which, at least, require further explanation. For example, it claims that a single council would reduce the “staff time required to support political decision-making within the Wairarapa”.  What does that mean? What is “political decision-making”? What support do staff currently give? How much time is involved? If it is a problem, why have the existing councils taken action?
  29. The proposal recommends the establishment of five community boards. However, it does not insist that these boards should be given real powers, with financial allocations and staff to support the exercise of those powers. These matters are left for discussion with the proposed transition authority and the new council — which means there is no assurance that the boards would have real powers. As anyone who has served on a community board would say, they are totally dependent on the largesse of the governing council, and otherwise can have little effect.
  30. In the proposed structure of the Wairarapa District Council, the community boards would be totally dependent on the elected council, with its membership heavily weighted in favour of Masterton interests.
  31. The proposal sets out the number of people to be represented by each elected member. This ratio is, of course, irrelevant because each elected member will have only one vote on the council. It would be relevant if their votes were weighted to reflect the population they represented.
  32. The Commission seems to believe that a smaller council would, inevitably, be a more efficient council — whatever they might mean. But that is to misunderstand both government and decision-making. Research shows that the highest quality and most efficient decisions are made by a group of not more than five well-informed and expert individuals. In local government, it is more important that councils make decisions which are effective for their communities and acceptable to ratepayers. That is an argument for more elected members, not fewer.
  33. The proposal (para 24) acknowledges a continuing role for the Greater Wellington Regional Council and includes the establishment by that council of a Wairarapa Committee. It is, of course, not that long since the Wairarapa’s representation on the regional council was reduced from two to one. However, the regional council has a significant involvement in the Wairarapa and its views on working with a single council should have been included in the proposal.
  34. The proposal’s section on offices and service centres seems to be little more than a reorganisation of the existing structure, albeit with a degree of centralisation (in the proposed Masterton head office) which seems contrary to any notion of decentralisation in local government. It is difficult to understand how better local government will be achieved by this proposed rearrangement of the furniture.
  35. It is regrettable that the Commission — having persuaded itself that Wairarapa people are in favour of a change in the local government structure — is unwilling to trust those people to implement the proposed changes. Why should the proposed Transition Body be “set up” by the Commission (para 71)? Why would it report to the Commission and not to the existing councils? Would it not be better for the people of the Wairarapa to “do this to (and for) themselves” rather than have decisions imposed by central government?
  36. In conclusion, the Commission’s proposal is an ill-informed and inadequately argued solution looking for a problem. It should be abandoned.

Richard Rudman

3 May 2017 your social media marketing partner