Possible changes to the draft proposal that have been widely raised include increasing the size of the proposed nine-member council, and establishing a local board structure rather than having less powerful community boards.
"DAD believes that until there is genuine and region wide community based consensus on reform, the present proposal should be withdrawn," the group said in its submission.
Napier City Council's submission opposing amalgamation is expected to be the most substantial at about 600 pages.
Napier Mayor Bill Dalton said yesterday the council wanted to give the commission access to all relevant material.
"We've given them every opportunity to hear what we've got to say. We see it as a total rebuttal of their proposal which in our opinion is poorly researched, lacks evidence, lacks data and is an incredibly lightweight, pathetic document," he said.
"I'm delighted that we've got this stage over."
Hastings District Council last week delegated the preparation of its submission to Mayor Lawrence Yule and Deputy Mayor Cynthia Bowers.
The council is supportive of amalgamation but will be proposing several changes to the draft proposal including an increase in the number of councillors to 18, perpetual ring-fencing of existing debt, and a change to local boards.
"Our council has given it a lot of thought and while we are broadly supportive of what the commission says, we've tried to tweak a few things."
Wairoa District Council, which opposes amalgamation, will also lodge its submission today.
Interim chief executive James Baty said the council's submission was all but complete but lodging it had been left to the final day so that councillors had the opportunity to make any last-minute additions.
The commission has said it expects to hold consultative meetings with submitters in Hawke's Bay in mid-April.
A public debate will be held in Napier at 5.30pm today between Labour candidate and amalgamation opponent Stuart Nash and pro-amalgamation regional councillor Rick Barker.
The "town hall style" event, with time for questions and answers, is being held at the Photographers' Gallery, 138 Tennyson St (previously the Red Cross Hall) at 5.30pm. There is a $5 door charge.