Part 2: Our observations on the 2018-28 consultation documents
2.1
In this Part, we discuss:
- our observations on the previous long-term plan consultation documents;
- what we saw in the 2018-28 long-term plan consultation documents; and
- examples of effective consultation documents.
A recap of our observations on the previous consultation documents
2.2
In our view, the more effective 2015-25 consultation documents:
- provided a useful summary of the council's financial and infrastructure strategies' main elements as context for long-term plans;
- highlighted the significant issues, options, and implications and how these would affect the public and communities; and
- contained specific questions on options facing the public.
2.3
However, in our view, many councils missed an opportunity to engage effectively with their communities about the significant issues facing them. This is because their consultation documents often:
- included too much background or other unnecessary information, leading to a loss of focus;
- contained poor discussion of the infrastructure and financial strategies, so it was difficult to understand what the strategies were and how they related to the significant issues;
- were unclear about which issues the council had already consulted on and which were new issues for consultation; and
- had poorly drafted consultation questions, making it difficult for the community to understand what the council was seeking a response on.
2.4
The presence of these characteristics (often in combination) lessened the effectiveness of the consultation documents.
What we saw in the 2018-28 consultation documents
2.5
During our most recent audits, we saw councils taking several different approaches to meet the Act's requirements.
2.6
Most of the consultation documents that we audited had one or more of the positive features we saw in 2015. Overall, the 2018-28 consultation documents gave effect to their purpose.
2.7
However, in 2018 many councils still missed the opportunity to engage effectively with their communities, with some consultation documents sharing many of the same shortcomings as the 2015-25 consultation documents. The improvements we were hoping to see in the 2018-28 consultation documents did not transpire.
2.8
In our view, there is still room for improvement overall in how consultation documents are presented. Just as councillors cannot make deliberate and informed decisions without the right information, the public also need the right information on issues and the consequences of councils' proposals to be able to properly consider and give their views on key matters affecting their communities.
Accessibility
2.9
The main challenge for councils preparing consultation documents is to present their information in a concise, readable, and understandable way. Council staff told us that they put a lot of work into making their consultation documents easy to read.
2.10
The purpose of the consultation document is to provide the community with a short and accessible document. However, the consultation document does need enough background information to provide context for the issues being consulted on.
2.11
We noted that the 2018-28 consultation documents included an increasing amount of information about progress on past decisions and about future decisions that were not ready to be consulted on. Council staff often told us that they wanted to take the opportunity to update people on progress with decisions and issues that had already been consulted on.
2.12
Increasingly, councils have taken the view that providing contextual information is important to allow a community to participate effectively in the consultation process. Achieving a balance between contextual information and the issues being consulted on is one of the challenges councils face when preparing consultation documents. There is also a challenge for the auditor, who must evaluate whether the contextual information a council considers relevant to the community's understanding actually detracts from the specific issues being consulted on.
2.13
As well as the observations we made in 2015 about the readability of consultation documents, we also encourage councils to be clear about what is being consulted on and what is not. The consultation document is not intended to be an annual plan update or a summary of the long-term plan.
Funding and financial strategies
2.14
Information about rates is always of high public interest. In the consultation documents, rates were discussed in several ways. Councils often gave specific dollar amounts for specific proposals. However, it was sometimes difficult to find, or understand, the total and proposed rates for an individual ratepayer. We recognise that this can be challenging, particularly where councils have many different rates.
2.15
As well as presenting rates increases, consultation documents need to describe the council's approach to debt. However, it was sometimes hard to find simple, plain English explanations in one place about councils' approaches to rating, debt, spending, and then paying back debt. This could make it difficult for people to understand the council's approach.
2.16
In our view, clear and unambiguous explanations on why proposed rate and debt increases, and significant changes in plans or intentions, were considered "affordable" or "equitable" would have made the consultation documents more effective.
Grouping issues and options by theme
2.17
Several councils presented issues, and options to address them, in groups or themes. This made the proposed projects and initiatives under each group or theme appear like a "package deal". In our view, this limited some people's ability to understand what level of priority or need, costs, or benefits could result from each project in the group or theme.
2.18
The approach of grouping matters into themes was often used by councils that were experiencing growth. Hamilton City Council's consultation document was one example of this approach used effectively. For example, Hamilton City Council asked one consultation question about investing in its community infrastructure. The Council proposed nine projects as a package to provide community facilities where these are required to support the city as it grows and changes. The Council, in taking this approach, still provided sufficient and clear details about the nine projects so that a reader could understand the document and provide feedback on each proposal.
Clear "signposting" to underlying information
2.19
It is important that the information underlying the consultation document is not only clearly signposted in the consultation document but also presented in a reasonable way so it can be accessed. This information is essential for people who want to understand the issues presented in the consultation document at a more detailed level.
2.20
We continue to reinforce that it is important that councils clearly state what underlying information is available and how members of the community can review it.
Grouping issues by area or township
2.21
Some councils grouped issues in their consultation documents by area or township. The risk with this approach is that the consultation document becomes too detailed and loses focus. However, with appropriate consideration of the issues that the whole district, city, or region is facing, this approach can be effective.
2.22
In our view, the way that Ruapehu District Council applied this approach was effective. The Council has jurisdiction over a large rural district with a relatively large number of townships. Its consultation document went into detail to explain the proposed plans and their implications in a way that residents from the different townships could understand.
Consultation questions
2.23
Feedback forms and the way that consultation questions are presented are critical to the success of the consultation process. We noted in our 2015 report that the better consultation documents asked specific open questions.
2.24
Some councils presented three choices of response to its key issues: "support", "don't support", and "other". Although the "other" option provides for open responses, the challenge remains for councils to effectively present issues to encourage engagement and demonstrate a genuine desire to receive feedback from the community. Designing good consultation questions is challenging.
The length of a consultation document
2.25
Consultation documents ranged from 16 pages (Chatham Islands Council, Otorohanga District Council, and South Wairarapa District Council) to 90 pages (Rotorua Lakes Council).10 The average page length of the consultation documents was 37 pages. For the 2015-25 consultation documents, the average page length was 32 pages and the page range was 11 to 100 pages.
2.26
Councils have discretion to design a document that meets the needs of their community. A logical argument would suggest that a shorter document would be easier to read and understand, but that was not always the case.
2.27
Rotorua Lakes Council's consultation document was the longest at 90 pages. Much of this length was because the Council used an innovative presentation style. The consultation document included sketch illustrations, pull-out quotes in speech bubbles, large graphs, two-page black-and-white stylised section breaks and heading pages, and specific spaces allocated for the community to record their responses to the content. The pages were well set out and mostly uncluttered.
2.28
As well as the nine specific consultation matters included in Rotorua Lakes Council's consultation document, there were a number of issues included only for the reader's information. These matters had previously been consulted on and decisions had been made. Although the consultation document looks quite long, it is a relatively easy read. Rotorua Lakes Council also provided a consultation document in te reo Māori.
2.29
Tauranga City Council's 68-page consultation document, although long, is clearly formatted. It has minimal use of graphics but effectively uses a bold colour scheme to differentiate sections of the document and has plenty of white space to improve readability. The boxed presentation of the option costs, effect on debt, and rates organised by relevant parts of the community, are particularly helpful for the reader.
2.30
Although shorter consultation documents might be easier for the community to read, we noted that these documents often used small fonts and dense formatting. We also saw less use of "signposting" to help readers find their way through the document. In the shorter consultation documents, there was also less background information. These shorter documents lacked the narrative that can, arguably, help a reader to more fully understand the context of the issues being presented for consideration. The story-telling style was more prominent in some of the longer consultation documents.
2.31
In our view, the success of the consultation document does not depend on its length. The clarity of the messages and the ability of the community to engage with it is more important.
Some effective consultation documents
2.32
We saw four consultation documents that were written in plain English and had an effective presentation style. That is not to conclude that these councils' consultation documents were perfect. We have focused on overall impact and effectiveness in this section, not legislative compliance.
Hauraki District Council
2.33
The Hauraki District Council consultation document used white space effectively and had a balanced mix of narrative, tables, diagrams, and infographics. The structure of the document is logical and easy to follow, with a clear hierarchy of headings. The colour scheme is applied consistently throughout the document.
2.34
The most striking element of the Hauraki District Council consultation document is the road-trip analogy that is used throughout the document (see Figure 1). The analogy makes technical subjects relatable without over-simplifying the issues.
Figure 1
Examples from Hauraki District Council's consultation document for 2018-28
Note: An example page from Hauraki District Council's consultation document for 2018-28 and selected quotes show how the road-trip theme was used throughout the consultation document.
Waimate District Council
2.35
Waimate District Council's consultation document uses clear and conversational language, such as "[t]he Long Term Plan affects you, your family, your neighbours and even your dog!"11 and "[t]o meet the Drinking Water Standards, water suppliers (that's us) must meet certain compliance criteria."12
Gisborne District Council
2.36
Gisborne District Council used the deliberately provocative branding "WTF What's the future Tairāwhiti?" for its consultation document. The consultation document uses questions focused around the word "what", such as "What's our plan for income?", "What are the big decisions to weigh up?", and "What does it mean for you and your rates?". These questions are to guide the reader through the issues and what they need to consider to be able to respond.
2.37
Although the document has 62 pages, the logical presentation and graphs, pictograms, photos, and consistent use of icons and colour makes it reasonably easy to read.
Horowhenua District Council
2.38
Horowhenua District Council's consultation document uses two primary school children, Maia and Xander, who are pitched as the "champions of the Long Term Plan 2018-2038".13 In 32 pages, the consultation document includes:
- a te reo Māori translation of the Mayor's message;
- details of pre-consultation activities and consultation to be carried out;
- a presentation of community outcomes that are also being reviewed; and
- a two-page spread setting out what the Council has done, is doing, and plans to do.
2.39
One of the strengths of this consultation document is the frequent use of tips about how to read the information presented and clear indications of where to find the underlying information. Sketch-style graphics are effectively combined with photos from the district and input from the "champions" (see Figure 2). For most of the document, the language used is clear and avoids unnecessary jargon and technical terms.
Figure 2
Examples from Horowhenua District Council's consultation document for 2018-2038
Note: Pages and images selected from Horowhenua District Council's consultation document for 2018-2038 show how the Council applied a graphic style throughout its consultation document.
10: All numbers in this section exclude data from Westland District Council and West Coast Regional Council. Their consultation documents were not completed when the analysis was done.
11: Waimate District Council (2018), Our future today – Waimate District Long Term Plan 2018-28 Consultation Document, page 5.
12: Waimate District Council (2018), Our future today – Waimate District Long Term Plan 2018-28 Consultation Document, page 18.
13: Horowhenua District Council produced a 20 year long-term plan.