SUBMISSION TO ROTORUA LAKES COUNCIL
RE DRAFT DEVELOPMENT CONTRIBUTIONS POLICY 2022 – 2031
BY ROTORUA DISTRICT RESIDENTS AND RATEPAYERS
Submitted Thursday 16 June
RDRR’s members, associates and friends are ambivalent about the Development Contributions Policy (DCP) for several reasons. The forced choice offered by Council between either developers or ratepayers paying for Three Waters infrastructure is simplistic. It is needlessly divisive. It shrouds (a) Council’s objective of embedding a revenue-raising mechanism to assist Three Waters implementation, and (b) the costs of its current contributions policy and structures.
RDRR’s members reject the claim that reintroducing Development Contributions (DCs) in Rotorua to fund Three Waters infrastructure is justified by an ‘exponential growth in needs’ generated by population and economic growth. It is shown to be far more likely that national and international monetary policy is impacting the economics of Rotorua and house building. The DCP is interpreted as a policy narrative intended to justify the collection of DCs to fund a historical and current deficit in Three Waters infrastructure in Rotorua created by successive councils’ investment policies.
RDRR members support reasonable DCs being collected by Council specific to each development project and its unique and actual infrastructure costs. At the same time, they insist that neither public nor private sector providers should be given concessions. Council should aim to eliminate all subsidies by ratepayers and be seen to provide a ‘level playing field’ to all potential investors.
To achieve such ends, RDRR recommends that Council take expert advice on the impact of RLC’s financial management strategy on ratepayers and developers since 2013, and update its vision, priorities, and practices – to improve prudence and transparency in a turbulent environment. This process will need to cohere with major organisational rationalisation that should be anticipated with the implementation of the Minister’s Three Waters legislation.
In the interim, RDRR members argue that the current Council must not undermine the viability of private sector development projects with DCs adding unreasonably to the burden of increasing Financial Contributions under the RMA. Council must avoid creating the impression of favouring public sector developers with secret sales of Council land at ‘agreed prices’ and transferring wealth from ratepayers at a pace indicated by the 50% increase in the rates take by Council since 2013.
The proposed implementation plans appear to follow logically from the strategy proposed in the DCP, although why the Producer Price Index Outputs Construction index should be used is not clear.
This submission to the Rotorua Lakes Council (Council) is on behalf of the 1,093 members, associates and friends of the Rotorua District Residents and Ratepayers (RDRR). It was initiated by an email offering advocacy through RDRR regarding the RLC’s Draft Development Contributions Policy 2022 – 2031.
While it was noted that individual submissions had a deadline of 16 June, those who wished to have their views aggregated into a RDRR submission were invited to provide feedback by 10 June.
A second draft summary was emailed to all members, associates, and friends on 12 June for a final round of feedback and editing prior to final submission.
THE PROPOSED DEVELOPMENT CONTRIBUTION POLICY
The proposed DCP is prefaced by a Statement of Proposal (Statement). This Statement provides the basic reason for the reintroduction of DCs:
Over the last 5 years or so, due to a wide range of factors, Rotorua has become a destination city. Many people have decided to move out of major centres and raise families in a smaller community or choose a better work/ life balance.
Rotorua has been one of those smaller destinations of choice. This has led to exponential growth needs across our city as referenced in the graph below. With this demand for growth, the infrastructure that caters for this growth needs to be created. This infrastructure needs to be timely and comes at a cost. (p.2)
All respondents regard this statement as fiction. With the mass and managed influx of homeless and associated crime, and middle-class flight, RDRR members see Rotorua as having a ruined reputation.
It is most unfortunate that the graph referred to in the Statement does not show ‘exponential growth needs across the city’. It shows that the number of new dwellings every four months peaked at about 300 in December 1997, again in December 2007, and again in December 2021, suggesting a need to develop a more sophisticated understanding of the dynamics and causal context of Rotorua’s housing market.
The graph shows that the number of new dwellings oscillated between just over 200 in December 1991 to 300 by December 1991 and then fell below 200 about December 2009. It recovered for four months to about 225 in December 2009 and them fell dramatically to 60 new dwellings in December 2013, but then climbed steadily to just over 300 in December 2021.
It would be a mistake to conclude or even imply that the building of new dwellings since December 1991 in Rotorua is substantially a reflection of local and/ or central government housing policies in New Zealand or the financial strategy of the RLC since the October 2013 local elections.
A more convincing causal explanation by FRED/WALCL of the oscillations since 2007 suggests the impact of three factors
- the Federal Reserve’s response to the Global Financial Crisis (GFC) with ‘Quantitative Easing (QE)’,
- its adoption of Modern Monetary Theory (MMT) early in 2020, and
- the broadly matching monetary policies of the New Zealand Government over the same period that responded to the GFC with QEs and MMT, and then to the Covid pandemic.
The other foundational and increasingly questionable assumption in the proposed DCP is Rotorua’s ‘exponential growth’ in population and economic terms. Census data from StasNZ summarised in Table 1 indicates modest annual average population growth overall with slightly higher growth in the Asian ethnic group (the 10.7% count in 2006 is a typo, probably 1.7%).
Table 1: Population Growth in Rotorua District, 2006–18 Censuses
|Population Category||2006 (count)||2013 (count)||2018 (count)||Average Annual Growth (count)|
|· Pacific peoples||4.5||5.0||5.4||0.075|
|· Middle Eastern/Latin American/African||0.4||0.6||0.5||0.008|
|· Other ethnicity||10.7||1.7||1.0||N/A|
Table 2 from Infometrics overleaf confirms that economic growth over the last year to March 2022 has also been modest, compared to the Bay of Plenty and New Zealand, despite a dramatic surge in residential consents caused by Council’s encouragement of a new homeless industry.
Table 2: Economic Growth Indicators to Year End March 2022
|Indicator||Rotorua District||Bay of Plenty Region||New Zealand|
|Annual Average % change|
|Gross domestic product (provisional)||5.0 %||6.6 %||5.2 %|
|Traffic flow||2.7 %||4.6 %||1.8 %|
|Consumer spending||3.8 %||8.3 %||6.1 %|
|Employment (place of residence)||2.7 %||4.0 %||2.7 %|
|Jobseeker Support recipients||-2.7 %||-5.7 %||-7.3 %|
|Tourism expenditure||-1.7 %||6.5 %||7.1 %|
|Health enrolments||0.7 %||1.6 %||0.7 %|
|Residential consents||101.0 %||12.2 %||24.0 %|
|Non-residential consents||11.7 %||-9.8 %||13.6 %|
|House values *||15.0 %||25.2 %||17.7 %|
|House sales||-13.9 %||-12.0 %||-9.3 %|
|Car registrations||17.1 %||13.0 %||24.7 %|
|Commercial vehicle registrations||32.1 %||25.2 %||35.3 %|
|Unemployment rate||5.6 %||4.2 %||3.4 %|
* Annual percentage change (latest quarter compared to a year earlier)
It appears that the primary reason for reintroducing DCs in Rotorua is more likely to be a consequence of how national and international monetary policy has been impacting the economics of Rotorua rather than being caused by local population or economic growth. This also means that Council’s DCP should be interpreted as a policy narrative intended to justify the collection of DCs to fund a historical and current deficit in Three Waters infrastructure prior to, and to enable, the implementation of the Minister’s Three waters policy.
There is one exception: marae development. Consistent with Section 102(3A)(a) of the Local Government Act 2002, Council’s DCP had to comply the principles set out in the Preamble to the the Ture Whenua Maori Act 1993, and was cited and applied as follows (p. 5):
Whereas the Treaty of Waitangi established the special relationship between the Maori people and the Crown: And whereas it is desirable that the spirit of the exchange of kawanatanga for the protection of rangatiratanga embodied in the Treaty of Waitangi be reaffirmed: And whereas it is desirable to recognise that land is a taonga tuku iho of special significance to Maori people and, for that reason, to promote the retention of that land in the hands of its owners, their whanau, and their hapu, and to protect wahi tapu: and to facilitate the occupation, development, and utilisation of that land for the benefit of its owners, their whanau, and their hapu: And whereas it is desirable to maintain a court and to establish mechanisms to assist the Maori people to achieve the implementation of these principles.
The Policy recognises that land is a taonga tuku iho of special significance and the importance of retaining that land and facilitating its occupation, development and use for the benefit of its Maori owners, their whanau and hapu. To this end it specifically excludes from the requirement for development contributions any applications made by iwi for resource or building consents, service connections authorisations or certificates of acceptances that apply to Marae development.
This exception aside, the Council’s proposed DCP is to apply to all developers in the private and public sectors.
QUESTIONING THE COUNCIL’S DCP
Many developers and residents consulted or who responded believe that Council cancelled DCs in 2014 in the naïve belief that this would help attract more investment to Rotorua. They regard the proposed reintroduction of DCs as based on another mistaken assumption – that Rotorua’s population and economy are growing exponentially – and that the proposal is about clearing the pathway for revenue raising prior to the Three Waters functions being transferred to a new supra-regional entity.
This impression was reinforced by what appeared to be a policy ‘kite-flying’ discussion at the Strategy, Policy and Finance Committee meeting on Thursday 9 June 2022. Council’s Deputy Chief Executive, Organisational Enablement (actually the CFO) said emergency housing providers were the “exacerbators” of “an escalation of costs” in the Council due to emergency housing “challenges.” However, he added, a targeted rate would require an amendment to the Long-Term Plan and to the Council’s funding and revenue policies. RDRR members were quick to point out that such costs levied on emergency housing providers would soon become institutionalised and eventually fall on residents and ratepayers as maintenance and capacity shortfalls.
Rotorua Mayor Steve Chadwick said that a targeted rate may be worthwhile, but it will be “something for the next Council to consider”. This was an unusual stance by the mayor, given all the other policies she has been trying to ram through before the end of her term prior to the coming election on 8 October 2022. In effect, the absence of a targeted rate would constitute an unfair subsidy to emergency housing providers by ratepayers.
Hence, RDRR respondents interpret the situation assumed by the DCP very differently. After nearly nine years of what they see as inflexible and unresponsive financial management – that has paid little heed to the affordability of rates to ratepayers – they reject the basic premise of the DCP; that it is ‘exponential growth’ alone that has created significantly additional demands on our water, sewerage, and storm water services.
Many developers and residents also reject the simplistic generalisation that the costs of such additional services should be contributed to mainly by those that in large part ‘create the demand’ without considering Council’s own contributions and costs. They consider it knowingly deceptive for Council’s consultation with the community to aim solely at identifying who else should pay for this ‘growth-related’ infrastructure, when its own system policies and practices are significant contributors to Three Waters costs and to infrastructural development.
Council claims that the cost of Three Waters infrastructure is currently borne primarily by the ratepayers of our district. Under their proposal a DC would levy developers seeking support and consents from Council to fund the expansion of water, sewerage, and storm water networks. In the absence of this policy, it is argued, Council will have to borrow to invest in the additional growth needed, unless ratepayers or developers meet the cost of Three Waters infrastructure.
RDRR’s consultations suggest the need for a very different and much more complex housing policy. The forced choice offered by Council, to have either developers or ratepayers pay for new Three Waters infrastructure, or have Council borrow more, is considered simplistic and divisive. It pits two parties living in our community, developers and ratepayers, against each other while distracting attention from the Council’s revenue raising objectives and its role, responsibilities and cost structures as system managers.
To introduce the need for a more sophisticated policy narrative, an RDRR member with over three decades of service as an elected member on a district council argued as follows:
I totally support the collection of DCs in the same way that I support some recreational organisations, such as Golf Clubs, requiring a ‘Joining Fee’ and an annual subscription from its members.
The reason is that ratepayers have contributed over time to the capital cost of current assets and maintenance, just as past members of recreational organisations have. Like club members, developers should contribute a reasonable amount in the form of DCs.
DCs are needed to pay for essential services that must be extended to cater for additional infrastructure and many other forms of residential and commercial support, such as footpaths, playgrounds, mowing verges, passive areas, sports facilities, cemeteries, public services and libraries, etc.
However, his support for DCs was not unconditional. He went on to argue that
Realistically, developers, and that includes all developers such as Kainga Ora and other social housing providers, should not be given concessions by Council. Private sector developers have a primary aspiration – to make a profit. Public sector developers have a primary aspiration – to provide forms of social housing to the needy. Both capitalise on existing facilities in the locality of their investment.
Both purposes are legitimate and essential for communities living in a mixed economy to survive and thrive. However, any concessions to either sector will distort the market signals and conditions needed to sustain development and rising productivity in all parts of the housing continuum, including the residential and accommodation sectors, housing-for-rent and AirBnBs. Council needs to provide a ‘level playing field’.
This means that consenting costs should be applied uniformly to be fair and cover the real costs of compliance, such as inspections. It also means that ratepayers should not be expected to fund costs resulting from a developer’s business investments or from Central Government investments in social housing.
His conclusion was that
RDRR should recommend a complete review and overhaul of RLC expenditure priorities, its borrowing history and massively increased debt, the impact of its rating charges since 2013 on ratepayers and developers and their affordability.
This review may result in stopping or delaying some planned works, particularly those projects with massive costs where budgets have blown out, with no obvious consequences to RLC management. There must be strict controls applied to expenditure and the Covid excuse cannot continue to be accepted.
John Citizen could not operate with such flexibility. Councils must cut their coat according to the cloth they have. There is no such thing as ‘champagne living on a beer income’. The reality is that people, businesses, and governments must continue to ‘break eggs to bake a cake’ in the current very difficult circumstances.
Council should therefore strive for financial prudence and transparency in its collection and expenditure of DCs from private and public sector developers and avoid the temptation to play favourites with the public sector in the belief that it will achieve greater equity in housing outcomes.
APPRECIATING THE REAL SITUATION
Instead of exponential growth, developers and residents consulted reported a significant slowdown in economic activity in recent years and an upsurge in emigration caused by many causes; Covid, damage to Rotorua’s reputation (due to law and order and public safety issues related to the new homeless industry), supply chain problems, staff shortages, and growing inflation in the cost of living. They also consider Council’s under investment in water, sewerage and storm water services as due in part to wasteful spending on vanity, legacy and iwi partnership projects since 2013.
One member spoke for many when she wrote:
I find it very worrying that giving favourable terms to Kainga Ora to develop and build will simply encourage more ‘homeless,’ who are not necessarily from the town, to arrive and stay here. Rotorua is already suffering greatly from actions and problems of some of this group. I think local people feel that the Ministry of Social Development need to look again at its policy for dealing with this group. People are fearful that ‘infill’ sites in already established areas will create problems, with their policy of ‘no eviction’, no matter what persistent ill-effects are being inflicted on local residents.
In this context, many consulted consider the assumptions reiterated in the DCP as obsolete and implausible. For example, they flatly reject the statement in the DCP:
Created in 2013, Vision 2030 created an enduring pathway for Council. A key goal is to build 6,000 new homes by 2030. This goal is part of the assumptions that underpin the LTP and this Policy. (p. 27)
Many residents and ratepayers are also of the opinion that the mayor and her majority on Council were wrong to support Minister Mahuta’s Three Waters proposals and to empower a local co-governance ‘joint committee’ and two senior officials to negotiate with Central Government, without any local consultations or debate at Council. Nevertheless, they recognize the political reality that the legislation just introduced to Parliament will probably move the management of investment for Three Waters from Council to a new supra-regional ‘co-governed’ entity.
This is not to say that the Three Waters proposals are accepted. The converse is more likely to be the case, as one respondent clarified:
The Government’s plan to nationalise the nation’s water infrastructure in the face of ratepayer opposition is far more than “co-governance”, it is feudal and amounts to theft. The many layers of bureaucracy to be introduced, people put in power because they have the right ancestors, the loss of local power over water infrastructure has been vehemently opposed throughout the country. Convening an anonymous “co-governance” joint committee and two unknown senior officials to negotiate with central Government with NO input from the people of Rotorua was typical behaviour of Rotorua Mayor and Council and is WRONG!
Members also recognize that Council’s proposed reintroduction of DCs will be overtaken by the policies and practices of a new entity, and that Council will presumably be down scaled when Three Waters functions, services and income and expenditure depart, with water rates remaining and increasing with even less transparency and public accountability in the new entity.
In the interim, developers consulted by RDRR report that Council has steadily increased charges for a range of consents and related services since 2013, so much so that they are undermining the viability of possible private sector developments. At the same time Council has been boosting the homeless industry and now proposes to sell Kainga Ora reserves or part reserves secretly at ‘agreed prices’ to build social housing. Conversely, residents and ratepayers note the 50% increase in rates paid to Council since 2013. The point here is that Council has been ‘playing favourites’.
This common view was summarised by one respondent:
Council should ALWAYS provide a level playing field – certainly not favouring public-sector development with secret sales of Council land at ‘agreed prices’ that have not been discussed with ratepayers, and which remain unknown until the ‘deed is done!’ Private/Business Developers and those buying land for public housing should ALL be treated equally. The current situation is definitely a case of transferring wealth from Ratepayers, which has been happening for some time in Rotorua, and cannot be supported.
Another respondent insisted:
I think a complete review and overhaul of ALL Rotorua Lakes Council spending priorities and borrowing history, massively increased debt and the impact of its rating charges since 2013 is desperately needed. Surely it is the job of the Council CEO to review and rein in Council proposals that have not been properly costed nor thought through.
In sum, instead of additional DCs being paid solely by private and public sector developers, most consulted wanted a complete overhaul of Council’s spending priorities, rates and charges related to development to eliminate subsidies and to provide equitable and reasonable conditions for developers operating at all parts of the housing continuum and at all levels of the housing market.
Currently, however, there is a crisis of confidence in Council’s financial and development strategies. As one respondent put it,
In today’s Post, even Bryce Heard, who I have thought of as one of the Mayor’s ‘team’, says ‘In my view our local body elections in October give us the chance to start with new brooms, new philosophies and a new spirit of togetherness.’ SO BE IT!
The following summary, derived from the Council’s Factsheet, outlines the practical detail of how the DCP will be implemented.
As indicated in the Long-Term Plan 2021-2031, if approved, the DCP will be applied from 1 September 2022 for the rest of the 2022/23 year. Initially, DCs will only be collected for additional Three Waters network infrastructure activities in the Rotorua Urban Area, with the wastewater levy excluded in Ngongotaha. The scope of the DCP could be expanded in next Long-Term Plan review process and include investments for Transport, Community Facilities and Reserves.
It is claimed that residential development in the Rotorua Urban Area is creating significant demand for Council infrastructure. “While the extra housing is needed, as costs rise it has placed considerable pressure on rates affordability. Council has increased debt and rates, and sourced grants from central government, but is facing the need to invest further in expensive infrastructure.” (p. 1) The absence of any sense of responsibility for having diverted tens of millions into legacy, vanity and iwi partnership projects is bizarre.
It is stated that “The key purpose of DCs is to ensure the person/business doing the development pays a fair share of the capital cost for new or expanded infrastructure. DCs will not be used to fund the maintenance or improvement of infrastructure for existing users. This cost will be met from other sources such as rates and debt.” (p. 1) This is an entirely self-serving declaration of purpose.
It is conceded that “house prices are determined by the market balance of supply and demand” and that “DCs will add to the cost of development and developers may seek to recover the DCs with increased prices” (p. 1) although Council expects that DCs will not have a major effect on house prices. This rare concession suggests that officials intent on intervention normally disregard the dynamics of the market.
Another rarer admission is that “Central government is responsible for affordable and social housing. The council supports affordable and social housing through the investments it makes in infrastructure. Affordable and social housing are charged DCs as they place the same demand on the need for the council to invest in infrastructure as other developments.” (p. 1) RDRR members are of the view that Council has chosen to be subordinate to central government Ministers and their departments.
In addition to DCs, Financial Contributions are also being charged for reserves/community purposes under the RMA. Under the provisions in the District Plan, Council may also charge Financial Contributions for other infrastructure on a case-by-case basis. “Developments that require a subdivision consent, land use consent, building consent or service connection will be assessed for DCs. These include:
- new subdivisions (which may be fee simple, cross lease, or unit title);
- new house builds;
- minor dwellings (granny flats and small units);
- new retail and commercial space;
- new tourist accommodation;
- extensions to commercial buildings;
- change the use of a property that causes additional demand on services.” (p. 2)
The Factsheet goes on to state that additions or alterations to an existing house, such as a new deck, living area, or garage, will not attract DCs, unless it adds a kitchen and creates an additional residential unit.
“DCs are calculated by dividing the council’s capital expenditure for growth by the estimated number of new growth units (both residential and non-residential) over the next nine years to 2031. The calculation is based on the number of Household Unit Equivalents or HUEs (one HUE = the average demand of a residential household unit). Each development is assessed based on the impact on infrastructure services in the location (catchment) where the development is located.” (p. 2)
Small dwellings (less than 73 m2) will be levied at 50% HUE. The proposed (2022/23) schedule of charges per HUE are listed in Table 3 below.
The full details of how to calculate the charges for residential and non-residential activities and the catchments are in the DCP.
Table 3: Proposed Charges per HUE (p. 3)
|Activity||Rotorua Urban Area||Development Contribution|
|Eastern, Western and Central||Ngongotaha|
|Total DCs (including GST)||$10,856||$3,654|
The Factsheet points out that different types of development will require different DCs. DC charges will be set at different levels for the same size of development depending on the demand they place on the need for the Council to invest in infrastructure. Most of the differences will relate to non-residential developments and will allegedly be kept to a minimum. Developers openly doubt this likelihood.
It is also stated that credits may be given as a way of acknowledging that the lot or activity may already be lawfully established, or a development contribution has been paid previously. No further DCs will normally be payable when a single house is built on a vacant section because either a contribution will have already been paid at subdivision or a credit will be applied for lots existing prior to this policy.
Past practices will continue. DCs will be “assessed in association with the following applications, normally at the first opportunity:
- Subdivision Consent
- Land Use Consent
- Building Consent
- Service connection.
Advice of the DC charge payable will be included in the decision letter you receive as a result of lodging the application.” (p. 4)
DCs will normally be “collected:
- Those assessed with subdivision consents: before issue of 224(c) Certificate.
- Those assessed with land use consent: on issuing of the consent and prior to commencement of the activity.
- Those assessed with building consents:
- within 180 days of issuance of Building Consent; or
- prior to issuance of Code of Compliance certificate (whichever is the earlier).
- Those assessed with service connections: before issue of authority to make service connection.” (p. 4)
If payment of the DC is not received, “Council will use the powers outlined in Section 208 in the Local Government Act 2002 (LGA) that allow a territorial authority to:
- Withhold a certificate under Section 224(c) of the RMA 1991 – land use consent.
- Prevent the commencement of a resource consent under the RMA 1991 – land use consent.
- Withhold a code compliance certificate under Section 95 of the Building Act 2004 – building consent.
- Withhold a service connection to the development, and
- Register the development contribution under the Statutory Land Charges Registration Act 1928, as a charge on the title of the land in respect of which the development contribution was required.
The Factsheet seeks to assure developers that they will have the right to appeal Council assessments and to seek external reviews if they do not agree with the final assessment of charges. A DC can be refunded in a few circumstances. There was skepticism expressed by some developrs.
Finally, the Factsheet claims that “The Council will annually review the DC charges and can adjust them in line with the Producer Price Index Outputs Construction index. The Policy itself will be fully reviewed at least every three years as part of the Long-Term Plan process.” (p. 5) The use of this index was not justified.
RDRR’s members, associates and friends are ambivalent about the DCP because they recognise that the forced choice offered by Council between either developers or ratepayers paying for Three Waters infrastructure is simplistic, crudely divisive and cloaks Council’s revenue raising objectives that will facilitate Three Waters implementation and its role, responsibilities, and cost structures as system managers.
Respondents take the view that the primary reason for reintroducing DCs in Rotorua is more likely to be driven by how national and international monetary policy is impacting the economics of Rotorua than by local population or economic growth. Council’s DCP should therefore be interpreted as a policy narrative intended to justify the collection of DCs to fund a historical and current deficit in Three Waters infrastructure.
While RDRR members support reasonable DCs being collected by Council specific to each development project and its unique and actual infrastructure costs, they insist that neither public nor private sector providers should be given concessions. Council needs to be seen to provide a ‘level playing field’ to investors and eliminate all subsidies by ratepayers.
To achieve such ends, RDRR recommends that Council take expert advice on the impact of RLC’s financial management strategy on ratepayers and developers since 2013, and update its broader vision, priorities, and practices – to improve prudence, transparency, and legitimacy in a turbulent environment. This process will need to cohere with major organisational rationalisation anticipated given the application of the Minister’s Three Waters legislation.
In the interim, the current Council must not undermine the viability of private sector development projects with DCs adding unreasonably to the burden of Financial Contributions under the RMA. Conversely, Council must avoid creating the impression of favouring public sector developers with secret sales of Council land at ‘agreed prices’ and transferring wealth from ratepayers at a pace indicated by the 50% increase in rates paid to Council since 2013.
The proposed implementation plans appear to follow logically from the strategy proposed in the DCP, although why the Producer Price Index Outputs Construction index should be used was not clear.
Thank you for considering our views. Please advise when a spokesperson from RDRR will be heard. Kia ora tatau.
Inquiries should be directed to Reynold Macpherson, Chairman of RDRR, 484 Pukehangi Road, Rotorua 3015, 07 346 8553, 021 725 708, firstname.lastname@example.org