Part 3: Case studies on consultation

Consulting the community about local authorities' 10-year plans.

In this Part, we look at:

  • case studies of how five local authorities engaged with their communities during the consultation period; and
  • Federated Farmers' views on the effectiveness of the new consultation approach.

The case studies present some of the innovative ways that local authorities used to engage their communities, the challenges they faced, and their views on how the new consultation documents and the increased flexibility introduced to the consultation process requirements in the Act affected the quality of the feedback they received.

We approached several local authorities. We considered it useful to get an early indication of what local authorities thought about the new statutory requirements and whether they consider that the new requirements have enhanced consultation and helped them finalise their LTPs.

We also asked Federated Farmers for its views. Federated Farmers is a regular participant in local authority consultation processes, and it has discussed the quality of planning and accountability documents with us since we began auditing LTPs in 2006. We were interested to hear its views on how the new consultation requirements have affected its participation in considering and submitting on local authorities' LTPs.

Auckland Council

Seeking innovation in engagement

Auckland Council had an unprecedented response during the consultation period for its 2015-25 LTP. It received 27,383 submissions, with 262,503 individual pieces of written feedback. This was a 171% increase on the 2012-22 LTP consultation response.15

The Council extended the consultation period from the minimum one month to seven-and-a-half weeks. This was to ensure that it had time to raise awareness and understanding of the issues and for the community to get involved. The Council considered that having an awareness-raising phase before holding public events that sought community views was important to the overall quality of the process.

The Council also had logistical issues to consider. Because the Auckland Council LTP must contain the plans for each local board area, the timetable for holding consultation events needed to be long enough for each local board to seek feedback on both local and regional issues. For 21 local boards to hold a meeting in each area within the minimum consultation period is a huge challenge.

The Council wanted to engage the people of Auckland more effectively than in previous years. After the 2012-22 LTP consultation process, the Council planned to take a more innovative approach for its 2015-25 LTP. It considered that its intentions were supported by the 2014 amendments to the Act.

The Council aimed to use approaches that research suggested would suit people better than traditional methods. People could make verbal or written submissions and use social media. The Council also held events in the evenings and weekends rather than during the working day.

The Council also carried out a significant media campaign. This included ensuring extensive national and Auckland media coverage at important points, such as the launch and close of the consultation period.

The Council advertised in print-based media (including in university student magazines and ethnic, regional, and local newspapers), on the radio, and on bus shelter advertising panels.

Digital promotion included banners on websites such as MetService, TradeMe, The New Zealand Herald, and Stuff. The Council also used Facebook and Twitter to request and receive consultation.

The Council held stalls at all major events around Auckland during the consultation period. The Council distributed flyers and promotional material at train and bus stations and the ferry building.

Council staff attribute the increase in the level of engagement to the improved engagement processes as well as public interest in the transport issues being consulted on.

The formal hearing process was largely replaced by "Have your say" events that enabled the Council to discuss issues with the community in a less formal and more interactive way. These events provided an opportunity to educate the community about, clarify, and "de-myth" many issues that were raised in discussion.

The Council received very positive feedback from attendees and elected members about the format of these events. Those involved told the Council that they generally felt that they had a good opportunity to speak directly to decision-makers and to have their views heard. However, there were varying levels of attendance at these events. The Council considered that there was a lot of benefit gained from sharing views between participants that is not gained through the normal hearing process.

The "Have your say" events were held in different ways to meet the needs of the attendees. Events were held in each local board area, and other events focused on special interest groups, such as Aucklanders with disabilities and ethnic communities.

Two "Have your say" events were co-hosted by non-council groups. This helped Auckland Council to engage with groups it might not otherwise have easily reached.

The "Have your say" events were attended by 1412 people, who named 8638 issues for Auckland Council to consider in addition to those received through the written submission process.

Feedback was also sought from all Auckland Council advisory panels and two reserve boards.

Because of the amount of feedback received, council staff compiled an overall report on the consultation responses and a series of summary reports on specific themes and for each local board area. Staff briefed elected members on the feedback. These reports were made publicly available. The individual submissions, the submission points gathered from each of the "Have your say" events, and the social media feedback were also made available online.

Information available to the community

Auckland Council's consultation document was 63 pages. It had two parts: one focused on providing context, and the other set out the four main consultation issues. In our view, it contained some very effective infographics:

  • a budget overview by area of spending;
  • rates issues, such as the average value increase from the 2014 revaluation;
  • how general rates are calculated overall and divided between ratepayers;
  • expected rates based on various property values and the options of different levels of Uniform Annual General Charge being consulted on; and
  • the range of general rates increases for various property types.

The clear use of the phrase "average general rate increase" was an improvement on previous Auckland Council publications, including the 2012-22 LTP, where there had been a lack of clarity about what was included in the "rate increase" that was publicised.16

To supplement the audited consultation document, Auckland Council also produced a summary document, the Household Summary. This was 16 pages and focused on the main elements of the four consultation issues. It was distributed to 540,000 households throughout Auckland.

The Household Summary directed the reader to the consultation document. It noted that the consultation document had been audited and that the audit opinion highlighted the choices for Auckland's transport programme.

The Household Summary was translated into six languages, and an accessible version for the visually impaired was also available. A sign language video was also produced. The consultation document and the Household Summary were available online and in hard copy at all libraries, service centres, and local board offices.

Auckland Council also adopted a comprehensive package of information to meet the requirements in section 93G of the Act (see paragraphs 2.48-2.59 for details of these requirements). This information was not in the form of a draft LTP. It was collated and presented in an indexed volume. This material was also available online.

Auckland Council uses a dedicated website called Shape Auckland for all major consultation processes. The Auckland Council website linked to Shape Auckland.

Shape Auckland provided the consultation document and a significant amount of additional information and tools to help the community to understand the consultation issues, including a frequently asked questions document, fact sheets on important projects such as the City Rail Link, and a 60-second video on transport issues.

The website also provided two tools we considered to be particularly useful. These were a budget calculator and a rates calculator.

The budget calculator allowed users to experiment with different funding levels for Council activities, reflecting the options proposed in the consultation document. It calculated the effect of the options on total Council debt levels, total Council spending, and average household rates.

The rates calculator allowed users to enter a specific address and get details of the rates applicable to that property based on the proposals in the consultation document. It was also possible to enter the different levels of Uniform Annual General Charge that were provided as options in the consultation document to understand the effect on household rates.

Challenges faced

We are aware of two challenges for Auckland Council during the consultation period because of direct correspondence with us. The first was about people not receiving the Household Summary. Delivery agents were given clear instructions that the Household Summary should be delivered to letterboxes with "no circulars" signs and in areas with bylaws about unaddressed mail.17 It remains difficult to ascertain whether this is the reason for people not receiving the Household Summary or whether people might have inadvertently disposed of it with other unwanted mail. Some libraries also ran out of the Household Summary on some days.

Several correspondents raised the second issue with us. Several readers of the Household Summary did not understand the hierarchy of information that was available to them and missed the pointers to the full consultation document and to the underlying information package.

Because the overall campaign and the documents were titled "Auckland's 10 year budget", some members of the community were particularly concerned about the lack of detailed financial information provided in the consultation document and the Household Summary.

Moving the detailed and technical information, which is often difficult for the general public to understand, out of the main consultation document while still making it available in the underlying information is a challenge for all local authorities.

In our view, both of these issues were made more complex because Auckland Council produced the Household summary. Because the Household summary was itself a sizeable document, many in the community did not understand that it was a summary of the even larger main document that Auckland Council was required to produce.

If the widely distributed document had been a flyer, or something very clearly less than the full consultation document, the Council might have reduced some of this confusion. We also consider that Auckland Council, and most other local authorities, could more clearly point the interested reader to the detailed underlying information.

The use of a summary was not unique to Auckland Council. Auckland Council is undertaking a review of the consultation process to assess the experience of Aucklanders. This will provide useful information for the Council and others interested in the process and documents used for the future.

New Plymouth District Council

We asked New Plymouth District Council to be a case study because we were aware that it had used several methods to reach out to its community as part of its 2015-25 LTP consultation process. The Council reported that this had been very effective in terms of the quality of the feedback it received.

Approach to engagement

New Plymouth District Council has a focus on finding new and interesting ways of engaging with the community. In 2009, it ran a comprehensive pre-plan consultation that included a roadshow, a series of hui, a web forum, and a telephone survey. It won the SOLGM Communications Award in 2009 for "Best Communication for the Draft LTCCP".18

The Council's overriding approach to consultation and engaging with its community is to "be where the people are". This means being present in a range of places, both physical and virtual, where the public gather.

The Council reports that, over time, it has got better at doing this. It has broadened its reach, gathering more feedback from ratepayers who rarely engage in consultation processes.

Before developing its consultation document, the Council held a series of meetings around the district, referred to as "Shaping Our Future Together". The Council deliberately went to outlying towns in the district to give all communities a fair opportunity to provide feedback.

Once the consultation period began, the Council continued the meetings. Ninety-seven people attended nine meetings. The Council also hosted webchats with the Mayor for people who were unable to attend any of the meetings.

The Council launched an interactive website called MyRates. This website provided ratepayers with an innovative way to see the effect of including or excluding the main proposals on their rates. Users could then submit their preferences to elected members. The tool was designed to help demonstrate the direct relationship between levels of service and costs to the ratepayers.19

Also, the Council produced a video, "What has the Council ever done for us?", featuring retired television personality Jim Hickey, Mayor Andrew Judd, the Council's Chief Executive, and various council staff members. This was a novel and light-hearted approach to highlighting the various services that the Council provides with ratepayer funds. At the time of writing, the video had received more than 3300 views.

The Council promoted these engagement methods in its weekly community newsletter "7 days", as well as on its website. The Council used social media extensively to raise public awareness of the consultation process and to encourage members of the community to have their say.

The Council told us that it had more than 5000 combined "likes" and followers on Facebook and Twitter.

During the consultation phase, the Council circulated the consultation document inside the local weekly paper, which reaches 30,000 homes.

Community submissions

The Council received considerably fewer submissions in 2015 than in 2012 and 2006, but about the same number as in 2009 (see Figure 2).

Figure 2
New Plymouth District Council – Number of submissions received, 2006-15

YearType of documentNumber of written submissionsNumber of submissions requesting a hearing
2015-25 Consultation Document 526 79
2012-22 Draft LTP 1831 147
2009-19 Draft LTCCP 565 91
2006-16 Draft LTCCP 1037 125

The Council commented that the nature of the issues it seeks feedback on often determines the number of submissions it receives. High-profile issues that are of significant public interest usually generate a higher number of submissions than "business as usual" proposals. This means that it is not easy to identify any trends or attribute the response rate to the nature and content of consultation mechanisms.

In 2012, the Council consulted on the development of a multi-sports facility and also on providing new recycling services. There was a lot of interest from the community. The Council also made it easier for the community to provide feedback by including a cut-out form in the community newspapers.

This year, the Council's proposal was a "business as usual" approach, with few new projects and a greater emphasis on keeping rates increases down. Arguably, the lower number of submissions compared to 2012 could indicate that the community was generally happy with this proposal.

Of the submissions the Council received, many were specifically about the main proposals in the consultation document and clearly indicated which option the submitter preferred. This was possibly helped by MyRates, which focused attention on the Council's main proposals.

Submitters told the Council that they found it much easier to engage with the consultation document than with previous draft LTPs. Previously, the community received a summary of the LTP that was much shorter but less informative than the consultation document. This had led most submitters to focus their feedback on the information in the summary, with only a minority responding to the full draft LTP.

Council staff told us that the feedback seemed more informed than previously. This was possibly because the consultation document provided more detail than previous summary documents.

Councillors said that the consultation document was a much better mechanism for engaging the community in the LTP discussion than previous summary documents and draft LTPs.

Information available to the community

The Council did not produce a draft LTP. Instead, residents were able to view a collation of additional supporting information on the Council's website, including draft policies and strategies, activity information, performance measures, and financial information. Hard copies of that information were made available in libraries, service centres, and the civic centre. The Council reported that demand for hard copies was limited.

Challenges faced

Council officers told us that their main issue was the requirement in section 93C of the Act for proposals to include principal options. The Council commented that some of the proposals it was consulting on were either "do it" or "don't do it", and it felt challenged to present a range of options to meet what it considered the legislative requirements to be.

Council observations

The Council thought that the new requirement to produce a consultation document meant it was able to clearly focus on its LTP proposals and the effect of these for the average ratepayer. The format of the document made it easier to communicate in a clearer and more engaging manner. It allowed the Council to more clearly describe the issues it wanted feedback on and focused it on telling the story as simply as possible.

The Council felt that the consultation document was successful in getting targeted, useful feedback to help the councillors with their final deliberations before adopting the LTP.

Dunedin City Council

Approach to engagement

Dunedin City Council adopted a similar approach to engagement as for previous LTPs but used some new techniques. The Council developed a consultation plan that included the traditional approach to submissions – that is, giving readers the option of providing a formal written submission and attending scheduled hearings – as well as using social media channels, such as Twitter and Facebook.

Readers were made aware that they could provide feedback through social media, which would be provided to councillors for consideration. This was a change from the Council's previous approach of using social media to tell the community how to provide feedback, but not actually to receive and collate feedback.

The Council also used its "People's Panel" to provide feedback. This email-based panel includes members of the public from a range of backgrounds who provide views on topical issues that are before the Council.

Also, the Council recorded the main themes residents raised at engagement events and gave this feedback to councillors. The meetings had an informal focus to enable more face-to-face discussions with councillors. The Council said it hoped to "do less talking, and more listening" at these events.

Previously, feedback from these events was available to councillors attending them but was not formally recorded. The Council considers that changes to the Act provided it with more freedom to engage with the community and consider feedback than had previously been the case.

The Mayor hosted two online chats during the consultation period. Interested residents were able to lodge questions or provide comments, and the Mayor then responded online. Transcripts of the chats were made available on the Council's website.

The Council's website also included an online rates calculator, which enabled residents to enter their property valuation and calculate their estimated rates for the coming year.

The Council did not circulate the consultation document to all households. Rather, it distributed a small information flyer alerting the community to the consultation process, outlining the major issues, and telling readers where they could obtain a copy of the consultation document and supporting documentation. The flyer also explained how people could provide feedback.

Community submissions

The Council received twice as many submissions in 2015 than in 2012 but heard 25% fewer verbal submissions than in 2012. Figure 3 summarises the number of submissions received between 2010 and 2015.

Figure 3
Dunedin City Council – Number of submissions received, 2010-15

ConsultationNumber of submissionsNumber of submissions requesting a hearing
2015-25 Consultation Document 2178 147
2014/15 Draft Annual Plan 1119 176
2013/14 Draft Annual Plan 262 108
2012-22 Draft LTP 1024 200
2011/12 Draft Annual Plan 985 156
2010/11 Draft Annual Plan 746 189

Submitters made 3074 comments on 158 topics. The Council received only 34 hard-copy submission forms that had been included in the consultation document. The Council received 57% of submissions electronically, a reduction from 85% of submissions on its 2014/15 Annual Plan. It received about 1430 "form" submissions.20

Fifty-five people made comments about the consultation document on social media. A survey of registered members of the People's Panel received 177 responses from a pool of 1289 registered members.

The Council reported that the total number of contacts with ratepayers was considerably higher this year, which could have contributed to the higher submission rate. However, the higher submission rate is largely attributed to the high level of public interest in the issues presented. Figure 4 summarises community engagement numbers.

Figure 4
Dunedin City Council – Community engagement numbers, 2010-15

2015-25 LTP2014/15 Annual Plan2013/14 Annual Plan2012-22 LTP2011/12 Annual Plan2010/11 Annual Plan
Number of contacts at events 849 295 83 530 99 220
Number of events* 9 8 4 8 6 9

* Events are either public meetings, pop-up road show stalls at public events, or in shopping centres or supermarkets.

The Council told us that the overall quality of the submissions it received was about the same as for previous years. That said, the Council considers that the consultation document enabled readers to better focus on the major issues.

However, not all submitters appeared to appreciate that they were submitting on the LTP. The Council received just under 1400 form submissions on two issues – a cycleway/road safety improvement project and an unfunded aquatic centre project. These submission forms were created by interest groups, were focused on a single option for the project, and were provided by those groups to the community.

The consultation document included a fairly comprehensive feedback form that included questions on 16 main issues and asked the community to select which option they preferred for each issue. Submitters were able to add additional comments at the end of the feedback form and additional pages if required. Readers were also encouraged to complete the feedback form online if they preferred.

Information available to the community

The Council did not prepare a full draft LTP when it issued its consultation document. Instead, it provided a range of supporting documents, including its financial and infrastructure strategies. This information was available on the Council's website, and the consultation document included a link to the webpage.

The Council's website statistics showed that the supporting documentation was viewed 357 times during the submission period. This represented 3.21% of pages viewed on the Council's website during the consultation period, and the average time spent on the page was just over five minutes.

During the submission period, eight people requested a hard copy of the infrastructure strategy and six people requested the financial strategy.

Challenges faced

One issue that the Council told us about was about a change to library funding that did not meet a level of significance to include in the consultation document. However, an interest group drew the matter to the attention of the media and the community. The Council was subsequently accused of hiding this information, even though it was available in the supporting documentation.

The Council said that some concerns were expressed about the lack of a draft LTP. However, once it was explained that the same information was available in the supporting information, those concerns seemed to be allayed.

The Council told us that, in hindsight, it could have included a full list of supporting documentation in the consultation document as well as on its website.

Council observations

The Council told us that feedback seemed more focused than in previous years, with fewer "scatter gun" submissions. The Council explained that it previously received a lot of submissions with comment on every item in the summary document, but this time people appeared to have submitted on issues of the greatest interest to them.

Otago Regional Council

Approach to consultation

Otago Regional Council tried a different approach to consultation as part of its 2015-25 LTP process. It:

  • used a consultant to design the consultation document and to present it in a user-friendly format; and
  • developed a dedicated webpage for the LTP process, which included the consultation document, a "frequently asked questions" section, and a list of all the supporting documents with a brief explanation of each.

The Council launched the consultation process at two public meetings, to which about 450 people were invited.

Also, the Council wrote to more than 3600 ratepayers likely to be affected by a proposal in the consultation document for a new targeted rate related to rural water quality.

Council staff were available to answer queries or to meet with individuals and groups to discuss the consultation document and the Council's proposed activities.

Community submissions

The submission form included in the consultation document contained two parts. The first part sought comment on proposed activities, but left it for the submitter to determine what they wanted to write. The second part sought comments on proposed changes to the Council's revenue policy, which included the new targeted rates.

The Council received 160 written submissions, which was a similar number to previous years. However, the Council noted that it is difficult to assess whether the number of submissions is significant because some high-interest issues had previously generated multiple photocopied responses from interest groups.

The Council told us that it received fewer submissions than it expected, particularly given the 3600 targeted letters drawing attention to an important proposal in the consultation document.

The Council heard from 80 submitters at hearings.

Information available to the community

The Council included links to the supporting information in the consultation document, including the draft financial and infrastructure strategies, the rates calculator, bus fare schedule and new zones, supporting information for a proposed new targeted dairy rate, and a list of frequently asked questions.

Because of the proposed new targeted rates affecting dairy farmers, the Council met with Federated Farmers before publishing the consultation document to discuss the issues to be included.

Challenges faced

Many submitters told the Council that the consultation document did not have as much detail as they were used to.

Council observations

The Council does not believe that the new process has achieved better engagement with the community. The Council feels that it has hindered rather than assisted meaningful consultation, with important stakeholders and regular submitters looking for the same level of detail they have received in the past and having to search for that information separately from the consultation document.

The Council was unsure how much of its detailed supporting information it could make publicly available, including whether it could make its draft LTP available when consulting on its consultation document. Although the Council was able to answer questions by sending out detailed information from the draft LTP, it will make its full draft LTP available when consulting on its consultation document next time.21

The Council said that the rates calculator was a well-used innovation.

Canterbury Regional Council

We selected the Canterbury Regional Council (Environment Canterbury) to be a case study because it received submissions on its 2015-25 consultation document from individuals who have not previously submitted on Environment Canterbury's planning documents. In Environment Canterbury's view, it received these submissions because of the style of the document and because the document was directly delivered to households.

Approach to engagement

Environment Canterbury has embarked on an ongoing collaborative approach to engaging with its community, largely in response to managing the region's water resources.

Environment Canterbury delivered its consultation document to every household and organisation in the region. This was a new approach. Previous planning documents were not distributed in this way. Previously, Environment Canterbury provided public access to the full LTP and the summary LTP through the principal office, service centres, district councils, and libraries. Environment Canterbury advertised the availability of the LTP in local media and through a quarterly publication.

Environment Canterbury believed that the new requirement for a consultation document enabled it to reach new audiences willing to submit on the plan. It linked readers to supporting information on its website. The intention was to separate the detail from the high-level messaging, enabling the community to identify points of interest and provide feedback if desired. Several submitters indicated that they found this approach very helpful and clear.

Environment Canterbury's website presented supporting information, such as the relevant draft policies and strategies, financial information, and rates proposals. It also included a video of Commissioner David Bedford explaining Environment Canterbury's proposed rates increases. As it had with previous consultation processes, Environment Canterbury also made hard copies of this information available at many locations throughout the region.

The consultation document posed specific questions under each topic area and included a hard-copy submission form and the option of submitting online. The form asked one overarching question: What do you want Environment Canterbury to do? Environment Canterbury noted an improvement in the structure of submissions, which assisted greatly in reporting to the Commissioners.

Community submissions

Environment Canterbury received 375 submissions on its consultation document, which was considerably more than the 205 submissions it received on its draft 2012-22 LTP.

About 10% of submissions were received after the closing date for the consultation period, despite Environment Canterbury allowing for the statutory one-month consultation time frame. Improvements in administrative processes enabled Environment Canterbury to consider all but seven of the late submissions – these were received more than one week after the closing date.

Council observations

A lot of the work done by regional councils is long term. The work is also often significant and subject to separate consultation processes. Environment Canterbury has worked to align the results of these consultations with decision-making in the LTP process.

A lot of Environment Canterbury's consultation document outlined work that carried on the direction and momentum of work already under way. Most of the projects outlined in the consultation document had already been through a separate consultation process. Environment Canterbury ensured that community feedback on matters to do with specific policy, as opposed to LTP funding priorities, were fed into the appropriate policy processes.

Having reflected on the consultation document process, Environment Canterbury will be more explicit to readers in future about its service intentions and related funding rather than existing strategies or approaches. It also received feedback about the lack of service performance information in the consultation document, which is not required for the consultation document. However, some members of the community thought that service performance information should be included. Environment Canterbury sees value in reviewing the relationships between planning, reporting, and future LTP consultation processes.

An external view – Federated Farmers

Opinion about the importance of effective consultation

Federated Farmers was not entirely comfortable with the 2014 amendments to the Act. It told us that its main concern was that the amendments could lead to a reduced opportunity to assess the effects and value of local authority spending.

Federated Farmers makes submissions on about 65-70 draft annual plans and draft LTPs each year. Federated Farmers considers that an important aspect of its advocacy on behalf of its constituents is to make sure that the rates burden is equitable. It seeks to hold local authorities to account not only for their spending but also for how that spending is funded and who pays.

Because Federated Farmers is a regular submitter to local authority consultation processes, it has developed considerable knowledge and experience of local authority expenditure and revenue policies and practices, both at a national and local level. Federated Farmers considers that making submissions on annual plans and LTPs is an essential part of its advocacy role.

Federated Farmers considers that it needs transparent and logical information to make constructive submissions to local authorities.

Federated Farmers told us that it was not opposed to high-level consultation documents. However, it wanted the consultation documents of all local authorities to consistently identify the main issues for ratepayers, including the effects of proposals on a representative range of properties. Federated Farmers also told us that it supports local authorities making the detailed supporting information available on their websites.

Opinion on consultation process for the 2015-25 LTPs

Federated Farmers acknowledged to us that, because of the new LTP process this year, the quality and transparency of consultation documents and their underlying information would vary.

Overall, Federated Farmers considers that the consultation document approach, when implemented as intended, has improved public interest and engagement in the LTP process.

In Federated Farmers' view, good consultation documents highlighted the "big picture" changes in a way that explained, for each main issue, the options the local authority had considered and their effects on ratepayers, the local authority's preferred option, and why it preferred that option. Federated Farmers considers that consultation documents that took this approach were clear what effect the options would have on funding and helped readers assess the factors influencing the costs and who pays.

However, Federated Farmers considers that a focus on the "big picture" and on specific things the local authority wants to know about (for example, should a local authority build a new swimming pool?) means that the consultation documents are not enough for those submitters who want to examine the policy detail.

Federated Farmers noted that, regardless of the quality of the consultation documents, in every case it had to review the supporting information to provide an informed response to local authorities on the broader issues that interested it.

In terms of the quality and quantity (length) of consultation documents, Federated Farmers noted that quantity did not always equate to quality.

Federated Farmers considered that some consultation documents were weak, particularly those that presented limited options, posed leading questions, or had many "feel-good" pictures. In its view, these documents did not contain information on rating revenue, alternative options, and expenditure that Federated Farmers considered vital.

Federated Farmers understood that one of the main goals of the changes to the Act was to rationalise the material local authorities have to produce and so reduce costs. Based on what Federated Farmers observed, it is not sure that this goal has been achieved. It observed that a large amount of supporting information was placed on local authority's websites, including in many cases either the full draft LTP or the various components that would make up an LTP.

Federated Farmers described the information provided this year as "haphazard" compared to previous years.

In Federated Farmers' view, the consultation process was not improved by the need to consider multiple documents and to search for information that had previously been contained in a consistent and coherent order in one (albeit large) document – that is, the LTP. It considered that the additional search time significantly affected submitters. Federated Farmers is concerned that consultation about important policies could become the domain of experts and exclude the interested ratepayer.

Federated Farmers was concerned about some of the proposed changes to rating policies that it found in the supporting information but that was not highlighted in the consultation document, such as a proposal to separate a roading rate from the general rate.

Federated Farmers was also concerned that it needed to closely consult each local authority's supporting information to discover the dollar amounts of specific rates, the usage and amounts raised by targeted rates and uniform annual charges, as well as how activities are funded, including the mix of property value rates, uniform charges, and fees and charges.

Federated Farmers noted that one consultation document was 26 pages. However, after reviewing the consultation document and the supporting information, Federated Farmers had so many issues to raise that its submission was longer than the local authority's consultation document.

Federated Farmers considered that supporting information that was largely presented in the same format as the old LTP requirements was relatively more easily accessed and navigated.

Federated Farmers believes that more consistency and uniformity in the consultation document and the supporting information is required. Federated Farmers would like to see a best practice model provided to guide local authorities in the future. This might include preparing and placing on the council website a draft LTP as "supporting information", but with the focus remaining on the consultation document as the key method of engaging with the community.

Our observations

We acknowledge Federated Farmers' concerns. In our view, they highlight the challenges caused by users of consultation documents having different needs. The amendments to the Act were particularly focused on the needs of most of the community, who are unlikely to want to engage with the details of the planning that local authorities do.

The main purpose of introducing the consultation document was to more effectively engage this part of the community. For the more in-depth reviewers, such as Federated Farmers, the high-level consultation document was less useful than the previously required full draft LTP.

The flexibility the Act allows in the presentation of the underlying information appears to have heightened the frustration for regular submitters. We also acknowledge that some local authorities were uncertain about what underlying information to present and how they should present it.

Our view is that the Act deliberately allowed discretion so that local authorities could tailor their materials in a way that they believed would best suit the needs of their communities. We acknowledge Federated Farmers' views about the benefits of consistency. SOLGM also recommended that the underlying supporting information be "put together in a coherent way".22

15: In 2012, Auckland Council received 10,084 submissions, with 55,606 individual pieces of feedback.

16: The phrase "average rate increase" in previous Council material was meant to refer to just the increase in the general rate. However, various groups interpreted it to mean average total rates increase, which did not align with the actual rates increase. Using more clear language linking the increase to just the general rates component of the total rates should address some of these previous concerns.

17: Some correspondents did not believe that these instructions were followed.

18: Up to 2009, the LTP was called a long-term council community plan or LTCCP.

19: This interactive tool has remained available since the consultation period closed and can be viewed at

20: Form submissions are standard submissions prepared by an interest group and completed by people who support that group's submission.

21: The consultation document must state where people can access the information the local authority has adopted under section 93G before adopting the consultation document itself (section 93C(3)(c)). If a local authority has adopted a draft LTP before it adopts the consultation document, it can include a link to the full draft LTP.

22: New Zealand Society of Local Government Managers (2014), Telling our Stories 2015, Wellington, page 7.