Recommendations
WRSAG has had a frustrating time during the workshops and general engagement. To move forward we propose council adopt the following recommendations.
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Formal note: Whilst the recommendations below have evolved from the the stormwater improvement project many apply to all engagement with council.
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1. Recall all flood letters immediately
The purpose of modelling is to run various solutions so infrastructure can be tailored to meet future development and correct current shortfalls in stormwater infrastructure. Dragging 3500 property owners into disputes with council about ‘maybe’ flooding is a poor use of councils authority and abuse of power. Governance has put employees in Whangamata under stress and been subject to abuse. Property owners are powerless to query the ‘maybe’ flooding and cannot stop trespass run-off from roads and poorly maintained stormwater assets. By councils’ own admission modelling is not accurate or reliable so councils’ actions are in breach of s44A of LGOIMA by placing ‘maybe’ flooding on property files and LIM’s. Until the NIWA:MfE best practice guide claims modelling is accurate and reliable it cannot be part of property records.
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The letters are a blanket decision so unlawful.
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Council already has flood warnings on over 400 properties (Opus survey 2003) and the 71 properties identified by HAL. Staff can pull these property records and survey these sites with floor levels to ‘maybe’ flood levels as first cut. These are the ‘proof’ required to validate modelling. If neighbouring properties have similar low-lying land these should also be surveyed. These are the properties council must consult and considered for warnings.
2. Council staff attend training session on engagement with community
WRSAG main beef is staff are not engaging as per councils Significance and Engagement Policy. We see it as a privilege to debate, assist and provide dialogue to prepare solutions and options for council decisions. Councils’ policy to date is ‘only release information under an official LGOIMA’, place restrictions on LGOIMA requests on the basis we are asking too many questions and making decisions that have not been part of the discussions. In several decisions staff claim we have been ‘outnumbered’. None of this complies with IAP2 the foundation document of our Significance and Engagement Policy.
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Once staff are correctly trained they will not accept this culture and become engaged in an open and transparent way. This will make a substantial change in gaining trust from the community.
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When councillors and Community Board members are included in the engagements., as elected members they are part of council so are to be included in this training.
3. Council staff purposed with engagement prepare induction packs for stakeholders.
It is standard practice every employee joining an organisation must have an induction pack. This includes things like employment contracts, confidentiality, code of conduct, departmental training and policy they are to operate under. Staff are paid so this is just part of the overhead organisations carry.
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Stakeholders are not paid. We are volunteers. It is therefore even more important those chosen to represent the community get at the beginning of engagement a good knowledge base of what is being engaged so they can contribute. Our experience is one of pure frustration. We have wasted hundreds if not a thousand hours on needless research and over 30 LGOIMA. This ties up staff not part of the workshops to prepare information they know nothing about to respond. Invariably these requests go back to the very staff we are engaged with. We cannot comprehend the reason council has to frustrate us in this way and to waste needless hours of staff time.
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Our only presumption is council does not want stakeholders to know sensitive things. The only reason documents and discussions are sensitive is council has made or omitted critical decisions that have come back on them and are the very reason why the engagement is required. This is a direct conflict of interest that cannot be managed by withholding information and misdirecting discussions. It means council is failing to honour its commitment to serve the community. Withholding important information leads to distrust and resentment.
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Councillors and Community Board members must also have induction packs. In this way stakeholders will know they have the same information as its elected members so they can have open discussion on the same playing field at any time to progress community’s needs.
Our experience is council staff have provided incorrect information to our councillors which has led to tensions between us and elected members.
4. Council staff undertake cross departmental training
The stormwater project cuts across many departments within council. The staff council appointed to run our workshops have not had authority to discuss the District Plan, RMA s31, Building Act s72, the building code E1/AS1 floor heights, roading management or Parks and Reserves.
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This puts major limitations on the outcomes of workshops. It becomes ‘impossible’ to discuss all matters stormwater. It is also unacceptable stormwater workshop discussions and outcomes can be vetoed by other departments within council.
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A classic is Kiwi Rd. Councils water services team claim this was a roading matter so not part of discussions. WRSAG findings are clear about what went wrong and what must be done. Despite this roading has this week laid another seal. This demonstrates council has no cohesion or discussion between departmental heads.
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It is imperative staff are cross trained so they can come to workshops knowing what impact will have to all departments and that they can follow up option selections.
5. Elected members attend the Ombudsman members training program
A particular frustration is our elected members do not or have not familiarized themselves with the Ombudsman’s reports. One is called ‘Open for Business’. It is incomprehensible elected members are not aware of how local government works. In one instance LGNZ was asked to trump the Ombudsman. Councillors even voted to ignore the ombudsman’s transparency report.
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Community is not being honoured or empowered when councillors do not understand why they have been elected. Stakeholders only way to get heard is through our elected members. Without this support leads to mistrust of our own members.
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This leads to community not coming forward to have there say as they are being ignored. This is not acceptable for the future of our community.
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Whilst this may be a contentious recommendation we would not have had to include this if we had support when we requested it. This failure impacts all of community.
6. Modelling to be run at 50%, 20%, 10% and 2%AEP to validate outputs.
The modelling has been presented. WRSAG does not know how complete the model is or whether it is at a stage to model future development and increased rain intensity events. We do not know if it complies with the NIWA/MfE best practice guide. The Auckland Council guide is a useful start. Logically it would have been better to engage consultants familiar with the best practice guide. If the model is suitable for different AEP events this should be done to validate it and form shortlists of current deficiencies. These will become the urgent works.
7. Modelling at 1%AEP to then have runs with various stormwater options
Once the modelling of existing infrastructure is complete based on the 2%AEP and the required work scopes have been planned and execution the model should be run for the 1%AEP future scenario.
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To run the 1%AEP we need our spatial plan completed so development of land use can be inputted into the model. Then improvements can be inputted to see the cost benefit of each option to meet future development. In this way stormwater improvements can be kept in tune with land development. That way council will not have to stop all development. Instead, council will plan and implement infrastructure to allow that development to proceed.
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It is possible some flood areas may require a ‘do nothing’ approach because solutions are in the too hard basket, relate to retreat areas or funding cannot be justified.
8. Council to immediately adopt TCC ‘no secrets policy’ and release all information
Release everything. It’s too late to withhold information now. It is disappointing this recommendation is even required.
9. Reserves and Development Contributions be increased.
Whangamata has a significant under-investment in stormwater infrastructure. This needs correcting to reflect the improvements required to mitigate flooding and adverse effects of Natural Hazards.
10. Holocene sands not to be removed.
Long term plans to prevent or minimize retreat, requires land in general to be raised as and if sea levels and water tables rise. Excavations for building platforms and hard surface preparation must be used as fill on low lying land and to raise at threat land subject to inundation. This is a standard District Policy in many coastal towns around the world.
11. Restrict concrete construction.
Long term plans must factor the possibility of dune erosion and low lying houses subject to flooding or inundation to be lifted or retreat. The unresolved issue is who will clean up metal fill, concrete floors and wall panels if retreat is required. WBOPC already has restrictions on concrete within proximity of sand dunes.