3.4 Summaries of LTCCPs, annual plans, and annual reports

Accessibility and readability

3.401
A long-standing concern with the statutory requirements for public consultation on annual plans (and now LTCCPs too), and for the presentation of annual reports, has been the size of the documents concerned, which inhibits accessibility for many members of the public.

3.402
The 2002 Act seeks to address this concern by providing for certain summaries to be prepared by local authorities. For example:

• Section 83(1)(a) requires that, where the special consultative procedure is to be used, the local authority must prepare a statement of proposal (SOP) and also a summary of the information contained in the SOP. Since the special consultative procedure is required by sections 93(2) and 95(2) to be used in adopting, respectively, an LTCCP and an annual plan, it means that an SOP and a summary of the SOP must be prepared for all LTCCPs and annual plans.
• In respect of annual reports, section 98(4) requires, in a more direct manner, that a local authority must make publicly available its annual report, and a summary of the information in its annual report, within 1 month after adoption of its annual report.

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The 2002 Act also describes the extent of public availability for these summaries, although the wording varies.

• For summaries of SOPs, section 89(c) requires them to be distributed as widely as reasonably practicable (in such manner as is determined by the local authority, having regard to the matter to which the proposal relates) as a basis for general consultation.
• For summaries of annual reports, section 98(4) simply requires them to be made publicly available.¹⁹

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There are similar provisions to promote accessibility by the public to the more lengthy SOPs and the underlying plans.

• Section 83(1)(c) requires SOPs to be made available for public inspection at the principal public office of the local authority, and such other places as the local authority considers necessary in order to provide all ratepayers and residents of the district with reasonable access.
• For LTCCPs and annual plans, sections 93(10)(a) and 95(7)(a) respectively contain the same requirement as for annual reports, i.e. simply to make them publicly available within one month after adoption.

3.405
In our view:

• The main readers of summaries are likely to be lay readers. Summaries should therefore be capable of being readily understood by such readers. Informed readers, such as interested community groups, analysts, professionals or specialists, are more likely to seek the more detailed information contained in the full plan or report.
• In many instances, the summaries will be the full extent of the information that most of the community will have about the council. Each summary must therefore be able to stand alone, without the need to refer to the base document, unless more detailed information is sought.

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Guidance developed by the Society of Local Government Managers contains suggestions for good practice in preparing summaries that achieve these principles, as well as including:

• suggestions about communicating and distributing the summary; and
• thoughts about the different content and considerations that might feature in the various SOP summaries required and the annual report summary.

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This is a useful initiative that should be helpful to the sector in preparing summaries.

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In particular, the summaries of the LTCCP, annual plan and annual report should be seen as a coherent and discrete set of accountability information. The annual report summary should therefore provide information linking back to the LTCCP and annual plan summaries.

3.409
Several councils contacted us to ask about the material that a summary of the SOP for the annual plan is to cover. With the exception of the annual report summary, a summary is of the SOP rather than the LTCCP or annual plan document to which the SOP relates. This is relevant because the SOP includes the proposed plan to be adopted as well as setting out additional information requirements. For example:

• The SOP for the LTCCP is required to include the details, reasons and options for a proposal to which section 97 applies. This information is not required by Part 1 of Schedule 10 – Information to be included in LTCCPs.
• The SOP for the annual plan is required to include the Schedule 10, clause 2(2) information for the year about groups of activities, whereas the full annual plan document is required to contain only the annual budget and Funding Impact Statement.

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Councils should be aware of this, and ensure that LTCCP and Annual Plan summaries are a fair representation of the major matters of both the content requirements set out in Schedule 10 for each document and the SOP requirements under sections 84 and 85.

Timing of annual report summaries

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We also dealt with enquiries about one of the councils that had adopted an LTCCP in 2003 and was therefore required to prepare its annual report including the new requirement for a summary under the 2002 Act.²⁰

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This council had published its annual report summary – as required by the Act within one month of adopting its annual report. Unfortunately, this timing coincided with the run-up to local authority general elections, and led to community concern that the summary was being used as a council-funded advertising opportunity for sitting councillors who were standing for re-election.

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Such concern and such timing may not be entirely avoidable. However, a council should always ensure that a summary is a fair representation of the major matters, and is therefore set out impartially without providing a platform for political promotion. Councils should be particularly sensitive to this type of risk in pre-election periods.

2004 LTCCP SOP summaries

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We also reviewed the 2004 LTCCP SOP summaries to assess the extent to which these summaries had addressed their statutory purpose under section 89(c).

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Overall, councils had made good efforts to use the summaries for their intended purpose. We assessed the extent to which these summaries covered the major matters in the LTCCP SOPs, and concluded that:

• over 50% of councils’ summaries had covered all the major matters;
• 36% had omitted a small number of major matters; and
• just over 10% had not covered a number of major matters.

3.416
In general, the matters omitted related to major projects proposed, but we were surprised that hardly any councils included financial information in their summaries. While we understand the view of councils that the public find financial information difficult to understand, we believe that it has a valid place in the consultation and accountability processes between a council and its community. We have suggested that financial information be kept brief, and should provide:

• a financial overview of the council, using 5 major lines from the statements of financial performance and financial position; and
• information about financial impacts that the community is likely to be interested in, such as rating information and information about the financial impact of specific proposals that the community is being consulted on.

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Given the use of the summary as a vehicle for general consultation, we also asked our auditors to consider whether the LTCCP SOP summaries would be accessible to a general readership. We concluded overall that:

• 23% were well written and presented;
• 36% were adequately written and presented; and
• 41% had areas in which presentation and writing could be improved.

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We encourage councils to refer to the SOLGM publication Good Practice for Summaries to assist in summary preparation.

19: See section 5(3) for the definition of “publicly available”.

20: All other councils will be required to prepare annual report summaries along with their annual reports once they begin reporting under the 2002 Act, which occurs in the first year of their 2004 LTCCPs.