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Council
19 February 2026
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Reports
Simplifying Local Government Submission
Department: Corporate Policy
EXECUTIVE SUMMARY
1 The
purpose of this report is to seek Council’s approval of a draft Dunedin
City Council (DCC) submission to the Department of Internal Affairs (DIA) on
the Simplifying Local Government consultation (the consultation).
2 For
the purposes of the consultation analysis, as requested by the DIA, the draft
DCC submission is attached as answers to set questions (Attachment A) and a
supplementary attachment in the form of a covering letter (Attachment B), which
will both be submitted via an online form.
3 The
Government is proposing to simplify local government in two steps:
· Step 1: Instead of
electing separate regional councillors, elected mayors in the region will
collectively form a Combined Territories Board (CTB). The CTB will lead
regional issues and govern the regional council, taking over all of the current
regional council’s roles and obligations.
· Step 2: The CTB
will develop a Regional Reorganisation Plan (RRP) for how the councils in the
region can work together more effectively and efficiently. The RRP will be
developed in consultation with the public, examined independently, and be
approved by the Minister for Local Government.
4 The
consultation also seeks feedback on alternative options of appointing one or
more Crown Commissioners, appointed by the Government, to lead or join the CTB.
5 The
consultation closes on 20 February 2026.
RECOMMENDATIONS
That the Council:
a) Approves the draft
Dunedin City Council submission, with any amendments, to the Department of
Internal Affairs on the Simplifying Local Government consultation.
b) Authorises the Chief
Executive to make any minor editorial amendments to the draft submission.
c) Notes that there are
no hearings for this consultation.
BACKGROUND
6 Currently,
there are 11 regional councils across New Zealand that govern services such as
environmental management, regional transport planning, and civil defence.
7 There
are 67 city or district councils that govern services such as roads, water
infrastructure, rubbish collection, libraries, parks, and land use planning.
There are six unitary authorities’ that combine the two roles.
Draft
Proposal – Simplifying Local Government
8 The
proposed changes in the consultation seeks to simplify governance by consolidating
decision making with mayors, to reduce duplication and ensure regional decision
making is more aligned across councils. It also seeks to ensure there is clear
accountability to the public for delivery of regional services.
9 A combined territories
board (CTB) will manage regional issues and govern regional councils. CTBs will
be funded through current rates.
10 CTBs
will take
over the governance for the roles and functions of regional councils,
including:
· managing rivers,
lakes, the coastal marine area, and air quality
· implementing any
Treaty settlement commitments that are administered by regional councils
· managing assets
· regional transport
planning
· civil defence and
emergency management
· environmental
regulation and resource management.
The
CTB decision-making approach
11 CTBs
will meet regularly, as city and district councils do currently.
12 When making decisions,
each mayor would have a set number of votes. This number would be based on
population and adjusted to ensure smaller communities receive effective
representation. The independent Local Government Commission would make these
adjustments.
13 CTB decisions must
comply with the same laws regional councils have to comply with now, including
consulting with communities and considering environmental impacts.
Alternative
Options
14 A CTB comprised of
mayors is the Government’s preferred approach outlined in the proposal
document.
15 The consultation is
considering alternative options for structuring regional decision-making in the
short term.
16 The
proposal document presents three options for a Crown Commissioner on the CTB:
· Observer
only: Crown Commissioner has no vote
· Veto
power: Crown Commissioner can override CTB decisions
· Majority
vote: Crown Commissioner has more than half the votes on the CTB, with the
remaining votes distributed among the mayors.
17 Another alternative
option mooted in the proposal document is to have no CTB, and to appoint Crown
Commissioners (Government appointees rather than elected representatives) to
lead regional councils
18 If
Crown Commissioners are appointed, they would have the same responsibilities as
regional councillors currently have.
Regional
Reorganisation Plans
19 The consultation
proposes that each CTB would develop a regional reorganisation plan (RRP)
within two years of being established. As outlined in the consultation document:
· the
purpose of the RRPs is to reduce duplication, improve efficiency, and be
responsive to local needs.
· to
support this, the consultation proposes a Government review of regional council
roles and functions will provide clarity on which responsibilities remain local
and which may be either centralised or discontinued.
· this
review will be completed before CTBs are established and CTBs will need to
consider the outcomes from this review when developing their RRPs.
20 If Crown Commissioners are
appointed, the appointments would run until a RRP is agreed.
21 RRPs
will need to reflect and incorporate local context and community feedback. RRPs
will:
· map
all council functions in the region
· recommend
the best delivery model for each of the functions across the region (e.g.,
shared services, joint council-controlled companies, or amalgamations)
· require
mandatory consultation with communities, iwi, hapū, Māori, and
stakeholders in the region be approved by the Minister of Local Government if
they meet statutory criteria (not by referendum).
22 Depending
on the region, the CTB might be kept, dissolved, or repurposed via RRPs.
DISCUSSION
The DCC
submission
23 The DCC
submission was workshopped by the Mayor and Councillors during early February
2026.
24 The
submission notes that the DCC’s priority in making this submission is the
consideration of the impact local government reform will have on our city and
communities.
25 The
DCC submission is structured as responses to the 11 questions posed in the
consultation.
26 The DCC is
consistent throughout its responses to the consultation questions that it
supports local government reform and believes that the representation review
process is the best mechanism to undertake structural reform in local
government.
27 The DCC
submission also raises concerns regarding asset ownership and resource
mismatches, stemming from lessons learnt during the last major local government
reform of 1989. DCC staff are preparing to research background information on
this which will inform the submission to Select Committee, if requested.
Representation
Review
28 Local authorities are required by the Local Electoral Act
2001 to review their representation arrangements at least once every six years.
In the context of the timing of this consultation, the DCC is due to
undertake its own representation review in 2026 and the DCC believes this
provides the opportunity for DCC to work with neighbouring councils to consider
representation arrangements.
29 DCC staff
are preparing for the representation review by developing research and insights
material which will also inform the DCC’s submission on proposed
legislation noting Select Committee consultation on any Bill is expected to
open mid-year.
30 A
representation review addresses the total number of councillors and community
board members there should be for the district or region. In the case of
territorial authorities, representation review also determines whether councillors
are elected from wards or 'at large' across the whole district, or by a mix of
both wards and 'at large'.
31 A
representation review also covers the boundaries of wards and constituencies
(including community board areas.
Need to simplify local
government (Question 1)
32 The
DCC seeks clarity on the goal of the proposed reform. The draft proposal uses
the following justification for reform, but does provide an evidence base to
support:
· that
having both regional councils and territorial authorities operating in the same
geographic areas is seen as “complex,” “confusing,” and
“costly”
· that wider system
reforms either underway or upcoming —including resource management, water
services, and climate adaption — will change the future role and workload
of councils, making this a timely moment to reconsider institutional
arrangements.
33 Noting that
a “rapid review” by central government is underway at the same time
as this consultation, the DCC submits that a detailed analysis should be
undertaken prior to the establishment of the Combined Territories Boards (CTBs)
for a clearer view on the role that mayors and/or commissioners have within the
short term of reform.
Response to the Overall Proposed
Approach (Question 2)
34 The
DCC supports a regional planning approach in principle, but not at the cost of fair
representation. It recommends use of the next local election cycle to allow for
a representative and planned transition.
35 The
DCC submits the case for replacing regional councils has not been clearly
proven in the proposal document, and questions remain on the criteria for
reform including the absence of an outcome-focused approach to simplifying
local government. It is supportive of improving efficiency where it delivers
real value to its communities, but not at the cost of reduced services without
detailed analysis of function.
36 If
the government commits to CTBs and the associated regional reorganisation plans
included in the proposal, the DCC notes that developing and consulting on the
regional reorganisation plans will involve significant work for both CTB
members and those staff or contractors supporting them.
Replacing regional councillors
with CTBs (Questions 3 and 4)
37 The
DCC submits there are too many unknowns to assess risks confidently on the
structure and function of CTBs in an interim governance role.
38 The
DCC is concerned about the loss of institutional knowledge if regional
councillors are replaced with a CTB. If reform proceeds with this element, then
DCC submits that existing governance knowledge of regional functions should be
represented within the interim arrangements.
39 The
DCC notes that the replacing regional councillors with CTBs risks:
· potential for the
loss of local voice
· established
representation and partnership arrangements
· extra workload for
mayors and, by extension, councillors
40 The
DCC requests further
consideration of how the regional reorganisation would be resourced is
needed. In its current form, the proposal risks a substantial unfunded
mandate falling on ratepayers, with interim transition governance arrangements using existing
regional council revenue. The DCC is of the view that the Local Government
Commission is not adequately resourced to support the structural change
proposed, additionally the DCC asks that role the new Ministry of Cities,
Environment, Regions and Transport (MCERT) will have within the wider Local
Government reform.
Level of
Crown participation in regional decision-making (Question 5)
41 The
DCC is of the view that appointing Crown commissioners signals a breakdown in
governance and should be avoided. If they are to be appointed, then
commissioners should serve as advisors not as voting members.
42 The
DCC submits that representation must remain with the locally elected members
who understand their communities needs and priorities.
Proportional vote adjustment for mayors on the CTB and
Effective Representation ( Questions 6 and 7)
43 The
DCC is of the view that geographical extent of each council area and local
voice needs to be represented regardless of population size. Based on the 2023
Census, there is an asymmetric population distribution with Dunedin likely to
dominate decision making relevant to other councils. The DCC maintains that
representation reviews provide an existing pathway for local government reform.
44 If
the government commits to CTBs and mayoral membership, then DCC supports the
proposal of the Local Government Commission determining voting power of each
mayor, based on population, and adjusted to ensure smaller communities receive
effective representation.
45 The
DCC supports the principle of effective representation. However it seeks
further information and clarity on the Local Government Commission’s
specific role and functions, which remain poorly defined in the draft proposal.
Communities
Crossing Regional Boundaries (Question 8)
46 The
DCC recognises that this situation does not apply to Ōtepoti Dunedin and
submits that this should be worked through with the territorial authorities
where it does apply.
Requirement that CTBs to develop regional reorganisation
plans (RRPs) (Questions 9 and 10)
47 The DCC submits
that:
· the proposal lacks
adequate consultation with mana whenua and partners and has not clearly
articulated the specific problems the reform is intended to solve at a unique
local level.
· the issues the
proposed changes are meant to resolve have not been clearly articulated in the
consultation.
· if the government
proceeds to establish CTBs with the responsibility of developing RRPs, then the
assessment criteria should be expanded to include the current criteria that the
Local Government Commission considers in a reorganisation investigation (clause
10, Schedule 3 of the Local Government Act 2002).
Provision for iwi/Māori interests and Treaty
arrangements (Question 11)
48 The
DCC is of the view that the proposal does not provide for Iwi / Māori
interests, despite the intent that existing mechanisms for Māori
participation that does not depend on regional councillor seats will continue
under the new arrangements. It does not have confidence that, as proposed, enduring
Māori representation will be committed to in practise.
49 The
DCC submits that it is unable to provide further feedback on this element of
the proposal without meaningful engagement with mana whenua in Ōtepoti
Dunedin.
OPTIONS
Option One – Approves the draft Dunedin City Council
submission to the Department of Internal Affairs on the Simplifying Local
Government consultation
50 Council
approves the draft DCC submission to the DIA on the consultation:
Advantages
· Opportunity
to advocate to central government decision-making that will impact at a local
level on Ōtepoti Dunedin and its residents
· Opportunity
to participate in discussions on proposed changes that will impact on Dunedin
City Council and other local authorities in the Otago region
· Opportunity
to contribute to discussions on proposed changes that will impact on the
governance and operational functions of the Dunedin City Council.
Disadvantages
· There
are no identified disadvantages to this option.
Option Two – Does not approve the draft Dunedin City
Council submission to the Department of Internal Affairs on the Simplifying
Local Government consultation
51 Council
does not approve the draft DCC submission to the DIA on the consultation.
Disadvantages
· Missed
opportunity to advocate to central government decision-making that will impact
at a local level on Ōtepoti Dunedin and its residents
· Missed
opportunity to participate in discussions on proposed changes that will
impact on Dunedin City Council and other local authorities in the Otago region
· Missed
opportunity to contribute to discussions on proposed changes that will impact
on the governance and operational functions of the Dunedin City Council.
Advantages
· There
are no identified advantages to this option.
NEXT STEPS
52 If
Council approves the draft submission, DCC staff will submit it to the DIA by
20 February 2026.
Signatories
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Author:
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Danielle Tolson - Policy Analyst
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Authoriser:
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Nadia Wesley-Smith - Corporate Policy Manager
Nicola Morand - Manahautū (General Manager Community
and Strategy)
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Attachments
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Title
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Page
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⇩a
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Attachment A: DCC
submission- Simplifying Local Government consultation
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25
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⇩b
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Attachment B:
Simplifying Local Government cover letter from the Mayor
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30
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SUMMARY OF CONSIDERATIONS
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Fit with purpose of Local Government
This decision enables democratic local
decision making and action by, and on behalf of communities.
This decision promotes the social,
economic, and environmental well-being of communities in the present and for
the future.
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Fit with strategic framework
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Contributes
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Detracts
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Not applicable
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Social Wellbeing Strategy
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✔
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☐
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☐
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Economic Development Strategy
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✔
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☐
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☐
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Environment Strategy
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✔
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☐
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☐
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Arts and Culture Strategy
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☐
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☐
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✔
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3 Waters Strategy
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✔
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☐
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☐
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Future Development Strategy
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✔
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☐
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☐
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Integrated Transport Strategy
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✔
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☐
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☐
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Parks and Recreation Strategy
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☐
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☐
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✔
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Other strategic projects/policies/plans
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✔
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☐
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☐
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Te Taki Haruru, the DCC’s Māori Strategic
Framework.
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Māori Impact Statement
Te Taki Haruru, the DCC’s Māori Strategic
Framework, contains the principle of Te Taki Haruru, the DCC’s Māori
Strategic Framework, includes the principle of Autūroa, whereby Māori
will participate and demonstrate leadership in the community.
In its submission, the DCC posits the view that the
proposal does not provide for Iwi/ Māori interest and the DCC lacks confidence
that existing mechanisms for Māori participation will continue under the
new arrangements. The DCC also submits that it is unable to provide further
feedback on this aspect of the proposal without meaningful engagement with
mana whenua in Ōtepoti Dunedin.
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Sustainability
There are no implications for sustainability in making
this submission.
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LTP/Annual Plan / Financial Strategy /Infrastructure
Strategy
There are no implications by making this submission.
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Financial considerations
There are no financial implications.
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Significance
This decision is considered low in terms of the
Council’s Significance and Engagement Policy.
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Engagement – external
The DCC’s submission has been informed by the Otago
Regional Council’s workshop on this topic, held on 14 January 2026.
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Engagement - internal
The submission has been prepared by the Corporate Policy
team with input from the Mana Ruruku team, and informed by workshops with
Councillors held in 2026.
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Risks: Legal / Health and Safety etc.
There are no identified risks.
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Conflict of Interest
There is no conflict of interest
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Community Boards
There are potential future implications for Community
Boards as regional councils functions currently occur in Community Board
areas.
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