The RMA Quality Planning Resource

  • The system for receiving, processing and evaluating electronic and paper submissions should be set up well in advance of receiving the first submission. The system should be designed with the end in view – i.e. it should facilitate the decision-making process. Ideally, therefore, there should be a strong relationship between the structure of the proposed plan and that used in processing submissions. A well-numbered and structured proposed plan greatly assists in the referencing process
  • The system should also be able to deal with potential problems, such as submissions arriving at different places (service centres, libraries etc).  One way of dealing with this is to ensure each service centre or library date stamps or records the date the submission arrived and have them forward submissions received to a central point (such as council records, or the planner overseeing the plan) at the end of each day.
  • Implement a good referencing system: number submissions, code submission points, and file them correctly. Note: the submission referencing system will need to be considered from the outset - however, coding of submission points should occur after all submissions have been received, when the structure of the issues' analysis is able to be confirmed.
  • It is often helpful to use distinct codes to differentiate between submissions and further submissions to avoid confusion (such as when a submitter had also lodged a further submission that cross references their original submission).
  • The submission process can be improved if people are given some guidance in writing them - for example, if there is a logical structure to the submission, and if the relief sought is quite specific and clearly differentiated from discussion points or reasons. The process is hindered by submissions that are difficult to read, express the relief sought in very general or unclear terms (or do not specify any at all), seek relief outside the ambit of the RMA, or the relief sought is not able to be easily identified within a vast rambling text. Submitters could be directed to the RMA Everyday Guide Making a Submission about a Proposed Plan or Plan Change for assistance in preparing a submission.
  • There is varying practice about dealing with late submissions. It is good practice to waive the time limit for submissions received only a day or two out of time. Accepting submissions beyond that period will depend upon whether such waivers would unduly prejudice anyone (see s37) - the principles of participation must be balanced with the principles of natural justice.
  • It is good practice to ensure that all submitters have provided full and current contact details, and to follow up as early as possible if there are gaps - standardised submission forms should also give explicit direction to provide full details.
  • Submissions may be in written or electronic form. When submissions on proposed plans and policy statements are lodged electronically, they do not require a signature. Ideally systems should be designed so that an electronic submission lodged through a submission form      on a council website goes directly into the appropriate database. Receiving submissions electronically can have time-saving benefits for RMA practitioners such as:
    • automatic date stamping and the ability to receive submissions at any time without staff necessarily having to be on duty at that time
    • being able to cut and paste when summarising submissions;
    • mandatory fields on the submission forms would ensure that all boxes are filled in
    • less copying and sending out of paper submission forms
    • easier entry of submission points into a database
    • never losing submissions in the mail.

Quality control

  • Set up a quality control system to check that submissions have been coded, copied, acknowledged and filed. Use at least a simple quality assurance checklist.
  • While preferably one person should manage the submission handling process (to provide an overview of quality control and consistency), there should be a strong formalised audit procedure in place so the departure of that person does not jeopardize the entire process.
  • In processing submissions, quality is always better than speed.

Accessible database

  • Using computer software, local authorities can now index and code submissions. They can also use databases for correspondence, submission analysis and report preparation, and decision-making. Many local authorities have successfully developed and used databases using Microsoft Access© software throughout the entire process (from notification through to Environment Court references). However, a database is only as good as:
    • the analysis, coding and data entry of submissions;
    • the software support; and
    • the people using it.
  • The tracking and analysis process should be kept relatively simple (for example, analyse submissions according to all of the rules say on waahi tapu or setback requirements, not according to each individual rule that may apply throughout the Plan). Tracking submissions according to Plan page numbers is also a good technique.
  • Using a computer database requires the assistance of a technical support person throughout the process. Technical support staff should understand the present and future requirements for the database; be able to think laterally; and be involved in defining the coding process. For example, the system should be able to deal with changes in addresses for service, names of contacts, or submitters' names (such as company name changes), preferably avoiding the need for multiple data entry. A method for tracking submissions that have been withdrawn or not pursued needs to be considered.
  • Database users - planners and administration support - should be familiar with the database, rather than learning by experience. Prepare a manual to support use of the database over time by different people, and to ensure consistency in input and output over time.