Kiwi Property Group Limited ("Kiwi Property")

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Kiwi Property Group Limited ( SUBMISSION ON HAMILTON CITY COUNCIL'S LONG TERM PLAN 2021-2031 To: Hamilton City Council ("Council") Submission on: The Draft Long Term Plan 2021-2031 ("Draft LTP") Name: Kiwi Property Group Limited ("Kiwi Property") Address: C/- Russell McVeagh, at the address for service specified below. 1. SUMMARY 1.1 Kiwi Property opposes two aspects of the Draft LTP: (a) the introduction of the Government Compliance targeted rate for 2021/22; and (b) the general rates increase to existing ratepayers of 4.4% for 2021/22 and 4.9% for 2022 onwards. 1.2 Kiwi Property owns and operates The Base and Centre Place in Hamilton. Under the increases proposed in the Draft LTP, The Base's rates bill will increase by 9.4% ($308,000) to $3.6 million. 1.3 Centre Place's rates bill will increase by 9% ($103,000) to $1.25 million. 1.4 Kiwi Property already makes a significant contribution to the Hamilton economy. Over the last 13 years, it has invested in excess of $400 million in the development of The Base, and in excess of $50 million in the development of Centre Place. Together, the Base and Centre Place are home to nearly 300 businesses. 1.5 These centres provide employment for Hamilton locals, including in a range of trainee and apprenticeship roles. Together, Centre Place and The Base generate approximately 2,700 retail / service full-time and part-time jobs, which is a significant proportion of the retail, service and management employment opportunities in Hamilton. 1.6 The proposed rates increases are of significant concern for Kiwi Property. In the event they are approved, these changes will place a direct burden on Kiwi Property and its many tenants, who have already been significantly impacted by COVID-19. 1.7 Kiwi Property is strongly opposed to the introduction of the "Government Compliance" targeted rate for the following reasons: (a) The proposed rate is disproportionately targeted at Commercial and BID Commercial rate payers. 4294785 1 (b) It is inappropriate to have a "targeted" rate which applies to all ratepayers across the board. (c) The Government is still yet to fully announce the details of the Three Waters reform package, how any reforms will be funded, and when the changes will need to be implemented by. The Council cannot possibly be in a position to quantify these costs or indeed require ratepayers to fund them now. (d) There are a range of alternative funding methods available to the Council for these initiatives. (e) The costs of District Plan reviews and other similar local government processes are better suited to other funding mechanisms. 1.8 Local government must conduct its business in an open, transparent and democratically accountable manner that is efficient and effective.1 Simply put, a targeted rate for "Government Compliance" rate is unreasonable, lacks transparency, and is out of step and premature. The impact on ratepayers like Kiwi Property (and by extension all its tenants) has not been properly assessed. The proposed targeted rate should not proceed. 1.9 Kiwi Property is also opposed to the increase to the general rate and seeks that the increase remain at 3.8% as outlined in the 2018-2028 ten-year plan to reflect the reality for many businesses already struggling with the economic impacts of the pandemic. 2. BACKGROUND 2.1 Kiwi Property owns and manages some of New Zealand's best and largest shopping centres, large format retail and office buildings. 2.2 In Hamilton, Kiwi Property has major interests at Centre Place, located at 501 Victoria Street. Centre Place is jointly owned with Tainui Group Holdings Limited through Centre Place Limited. Kiwi Property manages Centre Place South on behalf of TEA Custodians (Silverfin) Limited. The Base is jointly owned by Kiwi Property and Tainui Group Holdings through The Base Te Awa Limited. This submission also covers the commercial office owned by Kiwi Property and Tainui Group Holdings Limited through Centre Place Limited at 67 Bryce St that is on the same rating valuation number as Centre Place. 2.3 Kiwi Property makes this submission on behalf of all of the owners of Centre Place and The Base. 1 Local Government Act 2002, section 14. 4294785 2 2.4 Shopping centres form an important part of the commercial infrastructure of a modern society and are important to the success and vitality of wider city centres. Beyond commercial opportunities, shopping centres are also a community space for local residents, families and youth alike to meet. 2.5 Kiwi Property's shopping malls in Hamilton provide a number of services to the community and there has been considerable investment - in excess of $400m for The Base and $50m in recent development of Centre Place respectively to ensure that these shopping centres are attractive places to work and visit. Centre Place 2.6 Centre Place has 102 speciality retail stores, with 30% of businesses owned and operated locally. The shopping centre aims to make shopping convenient and enjoyable for the whole of the Hamilton community, and as part of this provides: (a) 554 spaces in the Bryce Street car park which also has free parking every weekend and after 5pm on Thursdays; (b) undercover and accessible parking; (c) two parents' room spaces; (d) accessible facilities; (e) community bookings that allow registered charities to create awareness for their cause and fundraise; and (f) city-wide information and direction service for customers and tourists. 2.7 Centre Place also supports a variety of community groups throughout the year by facilitating: (a) Volunteer Waikato which provides gold coin donation gift wrapping; (b) The Sensory Santa event for sensory-challenged children; (c) support of Dress for Success, Hamilton RSA, Hamilton City Council community events; (d) a free space for H3 events promotions (Lions Tour, Rugby 7s); and (e) a performance space for community theatre and musical groups. 4294785 3 The Base 2.8 The Base has a considerable retail offering with 164 specialty retail stores including 36 food outlets. In addition, The Base provides: (a) over 3,300 free car parks; (b) a free shuttle service to assist customers around the site; (c) a well-resourced parent's room; (d) community bookings to enable registered charities to create awareness of their cause and fund raise; and (e) Justice of the Peace services. 2.9 Kiwi Property has provided significant investment into the refurbishment and redevelopment for both The Base and Centre Place to ensure these are vibrant, safe and secure shopping environments for the communities of Hamilton. The shopping centres contain a variety of tenancies and provide an opportunity for Hamilton owned and operated businesses to operate alongside major retail businesses such as the James Pascoe Group (including Farmers), Hoyts cinemas, The Warehouse, Rebel Briscoes and Mitre 10. 2.10 These shopping centres provide good employment options for Hamilton locals, including in a range of trainee and apprenticeship roles. Together, Centre Place and The Base generate approximately 2,700 retail / service full-time and part-time jobs, which is a significant proportion of the retail, service and management employment opportunities in Hamilton. 2.11 Kiwi Property invests into The Base and Centre Place every year by way of continual reconfiguration and refurbishment of the premises, vital to ensuring high quality, attractive shopping centres. Continual annual capital expenditure ensures the revitalisation of the assets and common areas including amenities such as children’s outdoor play area, toilet facilities, customer car parking and health and safety improvements that ensure amenity and safety for employees and visitors. The impacts of COVID-19 2.12 The retail sector has been severely affected by the impacts of COVID-19 and the associated lockdowns and continues to struggle.2 COVID-19 has resulted in reductions in retail spending. 2 Retail sales plummet in lockdown, Statistics New Zealand, dated 24 August 2020, available at https://www.stats.govt.nz/news/retail-sales-plummet-in-lockdown. 4294785 4 4.10 The Revenue and Financing Policy says that targeted rates could be used to fund the Council's proportion of new projects where costs and beneficiaries of these activities can be easily identified.10 4.11 The Policy also sets out that the Council may establish targeted rates to fund specific capital projects and explains that targeted rates are more likely to be considered where a benefit can be linked to an identifiable individual or group.11 4.12 The Government Compliance targeted rate will apply to all ratepayers in Hamilton. Funding for water services reform and changing the District Plan are both activities that benefit the whole community, and it is difficult to identify specific beneficiaries in the way the Council's own policy intends. It is unclear why these activities are being funded by a targeted rate. 4.13 The rate per dollar of capital value is also significantly higher for Commercial and BID commercial rate payers, compared to the rate per dollar of capital value for residential ratepayers. This means Commercial ratepayers will pay disproportionately more per dollar value of their property than residential ratepayers. It is unclear why Commercial ratepayers should pay proportionally more than residential ratepayers for this targeted rate, when the funding is going towards water services and changing the District Plan, something all rate payers will benefit from. 4.14 Under its own "affordability" principle, the Council has said that it will explore external funding options for new agreed discretionary projects wherever possible.12 There is nothing to demonstrate that the Council has properly considered any external funding options for this projects, particularly in light of the clear alternative funding methods available. Alternative funding methods are available 4.15 There are a number of alternative methods available to the Council to fund the water and District Plan changes that the Government Compliance rate is supposedly addressing, including: (a) the Infrastructure Funding and Financing Act 2020 ("IFFA"); (b) Three Waters stimulus and reform funding from central Government; (c) Local Government Funding Agency; and (d) general rates.
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