DATA CENTRES

DPMC [OIA-2026/27-0175] Development of the Government's Data Centre Principles: Participants, Process and Industry Engagement

MCERT [26-OIAD-02576] Data Centres: Resource and Environmental Governance, Public Participation and the Makarewa Datagrid Development

MBIE [REQ-0038937 CRM:0257503] Data Centre Strategy: Scale, Costs, Environmental Limits and Public-Interest Evidence

Public Service Commission / GDDA [OIA 2026-0282] Digital Government Architecture: Cloud Infrastructure, Digital Identity, Citizen Data & Public/Private Control

SUMMARY FOR PSGR WEBSITE

New Zealand seems to be moving rapidly towards much larger data centres, expanded cloud computing, AI infrastructure and a more interconnected digital state. Yet these developments are being governed through different parts of government, each responsible for only part of the picture.

Over the past week PSGR lead researcher, Jodie Bruning, lodged four Official Information Act requests with the agencies sitting at critical points in this emerging system: MCERT, MBIE, the Department of the Prime Minister and Cabinet, and the Government Digital Delivery Agency/Public Service Commission.

The requests included questions that communities should be able to ask before thes infrastructures becomes embedded: How much electricity, water and land might it require? Who pays for the supporting infrastructure? Who benefits? Who controls the data and physical infrastructure? What happens to local decision-making? Who is helping Government write the rules? What risks arise as government information and services become increasingly interconnected and dependent upon private infrastructure?

Most importantly, is anyone in Government responsible for putting all of these questions together?

We do not yet know the answers. That is precisely why the questions need to be asked.

MCERT: Resource, Environmental and Planning Governance of Data Centres

The Ministry for Cities, Environment, Regions and Transport (MCERT) holds a central stewardship function in data-centre development. Many of the most significant consequences of large data centres extend beyond concerns relating to digital technology. They include questions of land, electricity, water, infrastructure, environmental limits, planning, consenting and the allocation of decision-making authority between central and local government.

MCERT was not established via an act of Parliament. It was established as a Public Service department through secondary legislation, Order in Council 2026/6 under the Public Service Act 2020. Schedule 2, Part 1 now lists MCERT as a department. Separate legislation was required to disestablish the statutory Ministry for the Environment and preserve its environmental functions. The underlying decision was taken by the Cabinet Economic Policy Committee, December 10 2025, ECO-25-MIN-0218, and subsequently confirmed by Cabinet through CAB-25-MIN-0476 on 15 December 2025. However, any underlying broader function and purpose of MCERT is difficult to identify.

Data centres are long-lived strategic infrastructure whose cumulative demands may extend well beyond their immediate sites. Large data centres potentially place substantial demands upon electricity generation and transmission, groundwater and surface water, land and supporting infrastructure. Multiple developments may also compete with households, industry, agriculture and other users for finite resources and infrastructure capacity.

MCERT is a new ministry and New Zealand's resource-management system is itself undergoing major reform. Much is yet to be defined, particularly the long-term stewardship of resources facing pressures from shrinking aquifers and increasing contaminant pollution. In the absence of publicly available analysis, communities cannot simply presume that this work is being undertaken. The Ministry's December 2025 Resource Management consent data report estimated that up to 46% (±6%) of existing resource consents might become unnecessary under the proposed system and recorded decisions to raise thresholds for identifying affected parties and requiring public notification. Yet the principal sample underpinning that work excluded publicly notified consents, non-complying activities and the highest-cost 25% of consents, which were considered more likely to include large or complex developments.

Unfortunately, a regulatory system designed to reduce consenting burdens for ordinary development may not necessarily provide an adequate framework for developments with unusually large, cumulative or nationally significant effects. Official Information Act request 26-OIAD-02576 therefore asks whether the new effects-management and notification thresholds have been tested specifically against large-scale developments; whether reduced notification could diminish meaningful public participation; and whether the system can identify cumulative pressures across electricity, water, land, infrastructure and environmental limits.

MCERT also occupies a key position between central direction and local democratic authority. National data-centre policy, national planning direction and Fast-track mechanisms may facilitate investment, while regional councils and territorial authorities remain responsible for assessing many of the resulting environmental and community effects. The extent of those effects, particularly without full disclosure, may be unknown. The request consequently asks what responsibilities are being centralised, what responsibilities and implementation burdens remain with councils, and whether councils possess the scientific expertise, staffing, information and financial resources necessary to assess complex developments and monitor them over time.

Stewardship extends beyond deciding whether an individual consent should be granted. Data centres may operate for decades. Sound governance therefore requires assessment of long-term resource constraints, infrastructure dependencies, cumulative development, drought and water availability, technological change and other material risks. These are issues that affect central government planning and regional communities. The OIA specifically asks whether government assessment frameworks consider horizons of 25 years or longer, rather than treating each development principally through the circumstances prevailing when consent is sought.

The proposed Makarewa Datagrid provides a practical test of this system. The request asks what MCERT knows about the development's approximately 280 MW anticipated electricity demand, groundwater abstraction, aquifer capacity and recharge, land-use opportunity costs, infrastructure requirements and effects on other resource users. It asks whether ownership and controlling interests, electricity-market implications and the overlapping roles of Mercury as generator, prospective electricity supplier and equity investor were considered in assessing public benefit.

Makarewa is particularly useful as a governance case because substantial information about the development exists across Overseas Investment Office decisions, council consent files, Fast-track processes and corporate announcements, yet the principal resource-consent applications were not publicly notified. The issue is therefore not simply whether individual agencies discharged their particular statutory functions. It is whether any institution is responsible for assembling the whole picture.

The OIA asks whether anyone has integrated Makarewa's electricity demand, water requirements, land use, infrastructure, ownership and control, environmental effects, economic costs and benefits, community consequences and public-participation implications into an assessment of its net public benefit to New Zealand. If MCERT does not hold such an assessment, the request asks it to say so explicitly.

The underlying stewardship question extends beyond thorough consenting: does New Zealand have an institution capable of determining whether major data-centre development is environmentally sustainable, infrastructurally prudent and in the long-term public interest, or are these questions being fragmented across agencies and individual consenting decisions without anyone being responsible for the whole?

MBIE: Economic, Infrastructure and Public-Interest Governance of Data Centres

The Ministry of Business, Innovation and Employment (MBIE) occupies a central position in the governance of data-centre development because it sits at the intersection of economic development, investment, energy policy, infrastructure and national productivity. While environmental and planning agencies are principally concerned with how developments are consented and their environmental effects managed, MBIE has an important responsibility for the larger economic question: why should New Zealand encourage data-centre development, at what scale, and under what conditions would doing so be in the national public interest?

The Government is developing principles or rules for data centres, and MBIE has already undertaken policy work concerning both “Data centre investment in New Zealand” and options to “capture benefits and manage risks”. The OIA seeks the underlying analysis supporting that work, rather than simply the resulting policy position.

Large data centres are unusual investments because their private commercial benefits may be accompanied by substantial demands upon publicly shared or regulated infrastructure. Electricity generation, transmission and distribution capacity, water, land and supporting infrastructure are finite resources. Decisions about facilitating data centres can therefore influence not merely individual investment projects, but how national infrastructure capacity is allocated between competing uses and who ultimately bears the resulting costs and risks.

MBIE is consequently an important agency for determining the anticipated scale of development. Before government creates a favourable policy environment, it is reasonable to know whether it anticipates several relatively modest facilities or a substantial hyperscale and AI-computing industry, and what that development might require over medium and long-term horizons.

OIA request [26-OIAD-02576] therefore asks for scenarios and modelling of electricity demand and additional generation, transmission and distribution requirements, water demand and availability, land requirements and associated infrastructure.

A second critical MBIE responsibility concerns who pays. Infrastructure required by data centres does not necessarily remain a private cost to their operators. New generation, transmission lines, network upgrades, water infrastructure or other supporting investment may ultimately affect electricity consumers, ratepayers or taxpayers. The request therefore seeks analysis of public expenditure and infrastructure investment associated with facilitating the sector, together with evidence identifying where those costs are expected to fall.

The corresponding question is whether the benefits justify those costs. Data centres may attract foreign investment, generate tax revenue and create employment, but these benefits need to be weighed against infrastructure and environmental costs, effects upon communities and the possibility that substantial economic returns accrue offshore. The OIA accordingly asks for cost-benefit analysis, economic modelling, value-for-money assessments and, importantly, distributional analysis: not simply whether economic activity occurs, but who receives the benefits and who carries the costs.

Electricity makes MBIE's stewardship role particularly significant. Large data centres can represent very substantial new loads. The request asks whether operators should provide or finance the additional generation, transmission or storage their operations require and whether allocating electricity-system capacity to data centres carries opportunity costs for households, existing businesses or other productive activities. It also asks whether major data-centre demand could affect electricity prices or security of supply.

The OIA also tests whether New Zealand policy is being developed with adequate international perspective. It seeks MBIE's analysis of experience in Ireland, the Netherlands, Australia, Japan, South Korea, the United States and Nordic countries, particularly where rapid data-centre growth has raised questions concerning electricity, water, infrastructure, planning and community impacts.

Finally, the request asks MBIE to identify uncertainty and evidence gaps before the policy framework is established, rather than allowing investment policy to outrun the evidence required to govern its consequences. It also asks how much resource Government itself has committed to developing the framework, including commissioned research and external expertise.

MBIE's stewardship role is therefore fundamental. It is not simply to facilitate investment. It should be capable of establishing whether the proposed industry represents a sound allocation of New Zealand's scarce electricity, infrastructure, water and land resources and whether the resulting economic gains justify the public and private costs.

The central governance question posed by this OIA is therefore: before New Zealand creates policy intended to attract and facilitate large-scale data-centre investment, has Government established what scale of development it wants, what resources it will require, who will pay for those resources, what alternative uses may be displaced, and whether the overall result will produce a demonstrable net public benefit for New Zealand?

DPMC: Whole-of-Government Coordination, Public Interest and the Integrity of Data-Centre Policymaking

The Department of the Prime Minister and Cabinet (DPMC) has been directly tasked by the Prime Minister with helping develop the Government's proposed data-centre principles or rules. The OIA records the Prime Minister's July 2026 direction involving DPMC, the Minister for Economic Growth and MBIE, alongside an intention to involve energy companies, data-centre operators and other interested parties in shaping the rules.

DPMC's importance is therefore different from that of an environmental regulator, consenting authority or economic-development agency. Its significance lies in whole-of-government coordination and the integrity of the policy-development process itself. At this formative stage, decisions about the purpose, scope and objectives of the framework can determine which questions government subsequently asks, which risks it examines, whose evidence it considers and ultimately what constitutes an acceptable data-centre development.

DPMC's stewardship responsibility is therefore fundamentally about the quality and legitimacy of the governing framework.

It is the agency in this set of OIAs most directly positioned to ensure that policy development is coordinated across government, that relevant but competing interests are represented, that commercial expertise does not become commercial dominance, and that constitutional and public-interest considerations are incorporated before consequential policy settings become embedded.

This OIA request [OIA-2026/27-0175] therefore begins upstream of individual policy decisions. It asks when the Prime Minister first directed the DPMC to participate and seeks the terms of reference, project brief, objectives, work programme, deliverables and milestones.

Governance begins with problem definition. A framework established principally to facilitate investment may develop very differently from one established to determine whether, where and under what conditions data-centre development serves New Zealand's long-term public interest.

DPMC also has an important role because data centres cut across conventional departmental boundaries. Their development potentially engages energy security, infrastructure, freshwater and environmental management, foreign investment, competition, privacy, digital governance, local government and community interests. No single sectoral agency necessarily sees all these dimensions.

A central coordinating agency is therefore well placed to ensure that the Government's framework is not constructed through one institutional lens while important consequences residing elsewhere in government remain outside consideration.

The central concern tested by this OIA is who participates in creating the rules. It asks DPMC to identify government agencies and Ministers but also consultants, energy companies, electricity-sector interests, data-centre operators, technology companies, investors, experts and other external organisations involved in developing the principles. It additionally seeks meeting records and documents showing the substance of engagement between DPMC and external organisations.

Industry knowledge is plainly relevant to workable policy. However, firms proposing to build, supply or finance data centres have strong commercial incentives concerning the resulting regulatory environment. The governance issue is therefore not whether industry should participate, but whether its access and influence are balanced by interests that may lack equivalent resources, organisation and direct financial incentives to engage.

For this reason, the OIA asks whether DPMC has developed a stakeholder map or consultation strategy and what processes exist to represent affected communities, local government, electricity consumers, environmental and freshwater interests, privacy and civil-liberties interests, Māori, independent scientists, competition and consumer interests, and public-law or constitutional expertise.

This is an important stewardship issue. Decisions about large infrastructure projects can distribute costs, benefits, risks and decision-making power across generations and communities. Public participation after the fundamental policy settings have already been determined is not equivalent to participation while the objectives and rules themselves are being formulated.

The request consequently asks DPMC for advice concerning conflicts of interest and, more broadly, whether officials have considered regulatory capture, policy capture, lobbying and unequal stakeholder influence, together with safeguards intended to ensure that the resulting framework reflects the wider public interest.

The central governance question posed by this OIA is therefore: before Government and commercially interested parties begin shaping the rules for data centres, has DPMC established a sufficiently broad and independent public-interest framework to determine what those rules should achieve, whose interests must be protected, which risks must be considered and who should have a meaningful voice in making them?

GDDA and the Public Service Commission: Digital Architecture, Sovereignty and Public Control of Data-Centre Infrastructure

The Government Digital Delivery Agency (GDDA), located within the Public Service Commission (PSC), occupies a critical position in data-centre governance because government is itself becoming a major user of interconnected cloud, computing and data-centre infrastructure. Following the transfer of Government Chief Digital Office functions from DIA to GDDA on 1 April 2026, the Government has pursued a more centralised and coordinated approach to digital investment, procurement and delivery.

GDDA's role therefore extends beyond purchasing information technology. Following the Hon Judith Collins digital government policy reforms the government's Digital Government Target State establishes a direction towards consolidation, common infrastructure and greater interoperability, progressively grouping agencies around shared ICT platforms and systems. The Digital Investment and Procurement Principles similarly encourage agencies to treat data as a strategic asset, enable connected data flows and support a ‘single view of the customer’. Meanwhile, Cloud First policy encourages public-cloud services and government services increasingly depend upon privately owned cloud and data-centre infrastructure.

This makes GDDA/PSC an important data-centre stewardship agency. Government information, AI-enabled computing, digital identity and essential public services ultimately require physical infrastructure through which information is stored, processed and transmitted.

GDDA/PSC is therefore important because Government is not merely regulating the emerging data-centre ecosystem: it is designing itself to become increasingly dependent upon it. Decisions about digital architecture can determine future dependence upon particular infrastructure, providers and jurisdictions, while simultaneously changing the practical boundaries between government agencies and citizen datasets.

The central governance question is therefore: as New Zealand centralises and connects government digital systems, has it established the structural safeguards needed to preserve sovereignty, resilience, institutional separation, public accountability and effective democratic limits upon both governmental and private power before that architecture becomes difficult to reverse?

This OIA request [OIA 2026-0282] therefore asks whether Government is assessing its digital architecture and its dependence upon cloud and data-centre infrastructure as one interconnected system, rather than treating procurement, digital services and physical infrastructure as separate policy questions.

One major issue is concentration and dependency. Reliance upon a small number of hyperscale cloud or data-centre providers can create technological and contractual lock-in, substantial switching costs and an imbalance of bargaining power between Government and major suppliers. The request therefore asks GDDA/PSC what it knows about provider concentration, ownership and control of infrastructure, dependency and the strategic risks created when essential public functions become reliant upon particular private providers.

A related stewardship responsibility concerns data sovereignty. Physically locating government information within New Zealand does not necessarily establish New Zealand control. Foreign ownership, corporate control, overseas legal jurisdiction and foreign-government access powers can remain relevant. The OIA consequently distinguishes between the physical location, legal control and effective control of government and citizen information.

The request also raises a deeper constitutional issue. Different government agencies possess different statutory powers and collect information for different purposes. Institutional and informational separation can itself provide a safeguard against excessive concentration of administrative power.

Yet interoperable digital identity, common platforms, cross-agency data exchange and a ‘single view of the customer’ approach advocated by the Hon Judith Collins can make previously separate information and functions increasingly capable of being connected.

The OIA therefore asks not merely what these systems are currently intended to do, but what the resulting infrastructure would technically or operationally be capable of doing if permissions, software, policies or legislation subsequently changed.

Digital infrastructure is long-lived and extensible. Architecture created for legitimate and limited purposes today may later enable additional data linkage, profiling, AI analysis, automated decision-making or access control.

Resilience provides another direct connection to data-centre stewardship. Concentrating government information, computing capability and essential services within common providers or interconnected infrastructure may create systemic dependencies and single points of failure. It is reasonable to expect that distributed-ledger or blockchain-type architectures may form part of some of this infrastructure, potentially protecting or distributing data across multiple points.

But this raises another important unknown: what architecture is actually envisaged, where will data and control reside, and what risks would decentralisation solve, or create? These questions are scarcely visible in the public discussion. GDDA/PSC therefore has an important role in determining whether consolidation intended to produce efficiency simultaneously increases vulnerability or threatens continuity of government and essential public services.

A key concern, articulated in the request is to understand whether Government has undertaken an integrated assessment combining the Target State, Cloud First policy, AI and data-centre infrastructure, digital identity, interoperability, citizen data, private-provider dependence and jurisdictional risk. It also asks what independent constitutional, public-law, civil-liberties, competition, sovereignty and systemic-risk expertise has challenged the developing architecture, and whether decentralised, federated, multiple-provider or publicly controlled alternatives were examined.

The question nobody should have to piece together

None of these questions means that data centres are inherently undesirable, that cloud computing should be rejected, or that government should not modernise its digital systems. The problem is more elementary.

Infrastructure of this scale can reshape electricity demand, water use, land use, investment, local planning and the physical architecture upon which government itself depends. At the same time, increasingly interconnected government systems may alter where information resides, who controls it, how easily datasets can be connected and what future governments or private providers are technically capable of doing with them.

Communities should not have to reconstruct this picture from council consent files, Cabinet papers, procurement policies, Overseas Investment Office decisions, corporate announcements and Official Information Act requests.

Nor should the important questions emerge only after billions of dollars have been invested and the infrastructure has become difficult to change.

These four OIA requests are therefore asking different agencies versions of the same question: who is looking after the whole?

Who is assessing the cumulative demand for electricity, water, land and infrastructure? Who is determining whether the economic benefits exceed the public costs? Who is ensuring that commercially interested parties do not write the rules in their own interests? Who is examining concentration, foreign control, digital sovereignty and systemic dependency? Who is protecting the ability of communities to participate in decisions that may materially affect them?

And if responsibility for all of this is divided between agencies, who is responsible for identifying what falls through the gaps?

Perhaps Government has undertaken this work and the OIA responses will demonstrate that it has.

If it has not, that is something New Zealanders should know before the architecture is built around us.

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Data Centre Governance: 2026 Official Information Act request series

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