2.1 Review of resource and building consent processing, compliance and complaints – Manukau City Council

Local government: Results of the 2003-04 audits.

In June 2004, members of the public and elected representatives of Manukau City Council (MCC) raised concerns about a number of building and resource consent issues. As a result, MCC asked Audit New Zealand to review its systems for:

  • processing resource and building consents;
  • monitoring compliance with their conditions; and
  • dealing with complaints.

We reviewed MCC’s documentation for those 3 areas, along with a sample of consent files relating to 25 separate properties throughout Manukau City. We interviewed a wide range of staff within the environmental services division of MCC to gain an understanding of how the relevant policies and procedures were applied in practice. We also interviewed senior staff within MCC, elected members of the Council, and members of the public who had raised specific concerns.

We found that MCC’s resource and building consent and compliance units were operating in an environment of increasing pressure, characterised by a number of problems that we believe are common to the local government sector:

  • a shortage of appropriately qualified and experienced staff;
  • high staff turnover and staff in acting positions for long periods;
  • performance assessment that focuses on the quantity of consents processed or compliance visits undertaken;
  • statutory timeframes that have not been amended since 1992;
  • significant growth in the numbers of consents to be processed; and
  • increasing complexity of the issues being highlighted (particularly in the building consent area).

We made 55 recommendations to improve MCC’s procedures across the 3 areas reviewed. Our recommendations broadly covered:

  • improved documentation of the procedures for processing consents, to provide evidence that the work performed and the conclusions reached are of an acceptable standard;
  • further guidance to staff in exercising their decision-making roles, and the provision of appropriate training;
  • appropriate quality assurance processes, to provide assurance over the quality of decision-making;
  • processes to enhance the quality of the information received, to reduce the amount of rework required to fully process consents (including possible increased use of the council’s right to reject incomplete applications);
  • formalised risk management processes, to better align the work effort to the risks faced;
  • improved monitoring processes, to ensure that a more holistic view of the property is taken, and that resource and building consents monitoring is further integrated;
  • providing more clarity around the processes for reporting and actioning breaches of consents in a timely manner; and
  • processes to significantly strengthen the complaints system.

Given the factors identified, these recommendations may well apply to other local authorities operating in the same environment.

In addition, a number of higher-level issues arose from our review that are likely to be common across the local government sector:

  • Linkages between the planning policy and consent processing and monitoring areas. We believe that analysing consent activity and feeding the results back into planning policy will produce significant benefits. The area includes consents regularly granted for infringements of District Plan rules, non-compliance or unconsented work, and complaints arising from development activity.
  • Linkages between consents, compliance, and enforcement. It appears that organisational structures may be encouraging a “silo” nature that does not support effective, integrated decision-making.
  • Linkages between building and resource consents. Again, organisational structures do not necessarily support the overlapping skill sets needed to ensure integrated decision-making.
  • Risk management. Although risk management may be undertaken informally, there is no formalised risk framework to guide staff in identifying and dealing with risk issues. Many risks that councils face are “managed” without a full understanding of the implications of the “management action”.

The results of our review were reported to MCC in early-September 2004. The Council accepted them and took immediate steps to address the issues raised. A task force was established to implement the changes required, guided by a specialist project manager.

MCC staff were empowered to identify and implement the changes themselves, although, where specialised skills were required (e.g. in developing the risk management framework), outside assistance was called in. An independent peer reviewer was engaged to provide assurance that the programme of action was appropriate and being carried out.

MCC has invited Audit New Zealand to review progress one year from the beginning of the original review.

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