The Government recently announced a voluntary “Head Start” pathway for councils to start exploring their own regional reorganisation plans, rather than waiting for central government to step in from 2028. Tessa McGregor explains that catchment management is likely to be a particularly significant factor when the Government assesses councils’ Head Start proposals.
As councils begin to explore the Government’s Head Start reforms, early attention has focused on governance models, representation, and financial sustainability. But these questions sit on top of a more fundamental constraint – catchment management, which is likely to be a decisive factor shaping which combinations of councils are viable and which aren’t.
This isn’t how most mayors and district and city councillors tend to think about local government. Outside episodes of major flooding, or major upgrades to flood protection schemes or stopbanks, catchment management and other regional council functions tend to attract limited political attention at the territorial level. Yet under the Head Start framework, catchments may end up playing a bigger role in determining the shape of local government.
The Government has been clear that catchment management will be a factor in evaluating proposals under the Head Start pathway. This reflects a broader conclusion emerging across multiple reviews, that certain functions work best at a scale that’s aligned with natural systems rather than administrative boundaries. A catchment approach may also take councils further in meeting their Treaty settlement obligations given the significant overlap between catchments and settlement areas, rohe, and takiwā.
So while catchments are unlikely to be a simple pass–fail test for councils’ initial “outline proposals” under the Head Start pathway, the issue will clearly be significant in how the Government assesses them.
A catchment focus would make it harder for some councils to be left behind
That has two important implications. First, it makes it much harder for councils to not participate in the way some didn’t under Local Water Done Well. With any proposal that excludes part of an existing region, the impact on the residual councils will be a key part of the Government’s assessment. The proposal will need to show that the regional functions in the remaining part can operate on a big enough scale to be viable. It may also run the risk of not meeting the land area or population tests that the Government has included in the Head Start pathway.
Second, a focus on catchments places real limits on how far regions can be impacted given the criteria related to simplification. Catchment management is particularly exposed, given that flood risk, sediment, land use, and water allocation pressures are interconnected across whole river systems.
Alongside catchments, assessments will also weigh whether the outline proposal “demonstrates fair and effective representation for communities of interest”. This is likely to be most challenging in places where the boundaries of communities of interest aren’t aligned with catchment boundaries.
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Recent reviews reinforce that catchments should be central for structuring local government
In 2025, Castalia reviewed regional and unitary authority functions for Te Uru Kahika, the consortium of New Zealand’s regional and unitary authorities, and recommended that flood management should be kept at the regional level.
The Government’s subsequent rapid review of regional councils’ statutory functions also supported this. It confirmed that key regional functions, including flood protection, biosecurity, public transport, and environmental management, would remain with local government rather than transferring to central government.
The Parliamentary Commissioner for the Environment has gone further. Writing to the Minister, the Commissioner identified catchment management as one of four functions that should not be delivered at a level below that of the region or at least a catchment – along with biosecurity, environmental regulatory compliance, and environmental monitoring and reporting.
In a later letter, the Commissioner made clear that of those four functions, it was most important to avoid the fragmentation of catchment management:
“Handing the management of catchments to more than one local government entity would represent the biggest step backwards in New Zealand environmental management for more than half a century.”
The Commissioner argued that fragmentation here would not only be bad for environmental outcomes, it would also run counter to the simplification that the resource-management reforms are intended to deliver.
Experience here and overseas illustrates the fragmentation risk
Fragmented catchment governance has been associated with poor flood outcomes and over allocation of water, particularly in systems where existing extraction permits already exceed available flows.
The Murray–Darling Basin in Australia is a cautionary example of how divided authority can undermine long term environmental and economic outcomes.
Te Uru Kahika has estimated that regional and unitary authorities currently provide flood forecasting systems that help New Zealand avoid an average of $1.2 billion in damage each year. That benefit depends on coherent, catchment wide planning and responses. Fragmenting responsibility makes that harder, not easier.
Not every region can support several unitary authorities
Scale also matters. Our existing unitary authorities are Nelson, Tasman, Marlborough, and Gisborne, all areas with populations over 50,000.
Using that yardstick, not all existing regions would have the scale to support multiple, appropriately scaled unitary authorities without cutting across catchments or making the delivery of regional functions less efficient.
District and catchment boundaries don’t always match
The difficulties come into sharp focus where catchment boundaries (within an existing region) do not align with district boundaries. In these cases, there are realistically only two options: first is bringing the affected districts together within the same future unitary authority; second is redrawing district boundaries to better reflect catchment realities.
The current Head Start framework doesn’t seem to envisage any changes to territorial authority boundaries, and it’s unclear how receptive the Government would be to any proposals that would involve changing them.
However, it may be something some councils choose to investigate. The work needed would be more substantial than under the existing Head Start grouping model, but in some limited cases the greater complexity may be justified.
There’s an opportunity here to address some anomalies
A related issue arises where small parts of districts sit within different regional boundaries.
Some of these areas are remote and contribute little to the rating base, but other part-districts are in populated areas and form a moderately substantial part of the overall district. These currently add administrative and planning complexity, often with little direct benefit to ratepayers.
The Head Start reforms provide an opportunity to address these anomalies, rather than entrenching them for another generation.
It’s not a technical detail
For councils considering whether, and how, to engage with the Head Start process, catchments shouldn’t be seen as a technical detail to be dealt with late in the piece. They are a primary structuring constraint that from the outset will shape what is feasible.
