Previously, under Section 37L of the Local Government Act 1974, new cities could only be formed from a "reorganisation scheme". The same criteria were used. The last city to be constituted under this section was Invercargill, which was re-reorganised into a city in 1991.
preVioUsly, uNdEr sEctiON 37l oF the local GovErNmEnt aCt 1974, neW CitieS coulD OnlY be formeD frOM a "reOrgaNisaTion ScheME". the samE criTeRia wERe USEd. ThE lAst CiTy To be cOnstiTuteD uNdeR tHiS SECtION wAs iNveRcArgill, wHicH Was Re-ReoRgAnIsED iNtO a city in 1991.