Submission Policy
1.1 PURPOSE
Submissions from the community are a vital part of Buller District Council’s decision-making processes. Formal submissions offer the Council structured feedback on proposals, plans, policies, and bylaws, helping elected members understand community views alongside other relevant information. This policy aims to provide a clear and consistent framework for receiving and managing submissions, supporting fair and transparent decision-making.
1.2 SCOPE
This policy applies to all formal submissions made to Buller District Council as part of consultation processes, including but not limited to Long Term Plan and Annual Plan consultations, policies, bylaws, and other statutory or non-statutory consultations where submissions are invited.
This policy does not apply to submissions made under the Resource Management Act 1991, which are subject to separate statutory processes, or to petitions, complaints, service requests, or other informal feedback.
1.3 BACKGROUND
Buller District Council undertakes consultation in accordance with the Local Government Act 2002, and other Acts including the Reserves Act 1977, Local Government Act 1974. The Significance and Engagement Policy sets out when consultation is required and the level of engagement to be undertaken. This policy complements that approach by outlining how formal submissions are received, managed, and presented to decision makers during consultation processes.
1.4 PRINCIPLES
Accessibility: Submission processes will be designed to be inclusive and easy for people to participate in.
Fairness: All submissions will be treated consistently and impartially.
Transparency: Submissions are treated as public documents and are made publicly available, with personal or sensitive information withheld only where permitted or required by legislation.
Integrity: Submissions will be recorded and presented accurately and without distortion.
Privacy: Personal information will be handled in accordance with privacy legislation and Council policy.
2 POLICY
2.1 What is a submission?
A submission is formal feedback given to Buller District Council by an individual or organisation in response to a consultation on a proposal, plan, policy, or bylaw where Council seeks community input to guide decision-making.
A submission forms part of the official consultation record and is considered by elected members alongside other relevant information. For clarity, a submission does not include informal or ad hoc feedback such as comments made on social media platforms, in the media, or through general correspondence, unless specifically identified by Council as a submission method for a particular consultation.
2.2 Methods
Submissions may be made by:
- Online through the Let’s Talk Buller engagement platform
- In writing and delivered to a Council office or location specified in the consultation material
- By post, to Buller District Council, P O Box 21, Westport 7866
- By email, to submissions@bdc.govt.nz
- Any other method identified by Council as a submission option for a specific consultation
Comments made on Council social media channels are not considered formal submissions.
During consultation periods, Council may also offer other ways for people to share their views, such as drop-in sessions, workshops, or information sessions. Feedback from these channels is not considered a formal submission but can be summarised and relayed to decision-makers.
2.3 Format
Submissions will be accepted in the following formats:
- Written or spoken English
- Written or spoken te reo Māori, subject to prior arrangement where a submission is presented in person
- New Zealand Sign Language, subject to prior arrangement where a submission is presented in person
- Audio or video recordings
Council staff may provide assistance to people who need help to make a submission but cannot provide guidance on the content of submissions.
Where submissions are illegible or unclear, Council will make reasonable efforts to interpret the submission but is not responsible for any misinterpretation
2.4 Submissions as public documents
Submissions are public documents and may be made publicly available in full.
Personal contact details, such as phone numbers, email addresses, and physical addresses, will be removed before publication. Submitter names will normally be published.
Requests to withhold a submitter’s name will only be considered in exceptional circumstances and must be made before the close for submissions.
Submissions are official records and will be retained in accordance with the Public Records Act 2005. Submissions may also be subject to release under the Local Government Official Information and Meetings Act 1987.
Privacy Considerations
Council collects personal information as part of the submission process for the purpose of receiving, validating, and managing submissions, and for contacting submitters where required, including to arrange hearings.
Personal contact details such as phone numbers, email addresses, and physical addresses will not be made publicly available. Other personal information included in the body of a submission will generally not be redacted unless Council considers that publication would breach privacy obligations or the submitter requests redaction before the close of the submission period.
Only authorised Council staff will have access to unredacted submissions. Personal information will be managed in accordance with the Privacy Act 2020 and Council’s Privacy Policy.
2.5 Who can make a submission?
Anyone can make a submission to Buller District Council. There are no requirements to make a submission to the Buller District Council. There are no requirements to be a ratepayer, resident, or of a particular age. Submissions may be made by individuals or on behalf of an organisation, group, or agency.
2.6 Submission standards
Council will apply the following standards when receiving and managing submissions to ensure a fair, respectful, and effective consultation process.
2.6.1 Minimum requirements
To be accepted as a formal submission, a submission must include:
- The submitter’s name
- An organisation name, where the submission is made on behalf of an organisation
- At least one form of contact information, could be an email address, phone number or postal address.
Anonymous submissions will not be accepted.
Submitters who wish to be heard must provide sufficient contact information to allow Council to arrange hearing participation.
2.6.2 Optional information
The submission form occasionally requests demographic information, such as age, gender, ethnicity, or disability. These questions are optional and are used solely to help the council ensure that a broad cross-section of the community is being represented on any issue.
2.6.3 Content
Council may reject or redact a submission, in full or in part, where it:
- Contains offensive, abusive, or threatening language
- Includes defamatory statements
- Harasses or threatens elected members or Council staff
- Is frivolous, vexatious, or would undermine the integrity of the submission or hearing process
Where possible, Council will seek to preserve as much of the submission content as is appropriate and will not deny the opportunity for genuine submissions to be made.
2.6.4 Supplementary information
Submitters may provide additional information to support their submission during the consultation period.
Any supplementary information received will be attached to the original submission and will not be regarded as a new submission.
Supplementary information provided after the close of the consultation period may be accepted at Council’s discretion.
2.6.5 Lengthy submissions
Submissions may be summarised for convenience when they are presented to Council. Council will additionally receive the full submission (subject to any reductions as detailed).
2.7 Pro forma and templated submissions
The Council recognises that some submitters may choose to use pro forma or templated submissions as a means of expressing their views. These submissions are a legitimate form of public participation and will be accepted and recorded in the same manner as individually drafted submissions.
Where multiple submissions are received using identical or substantially similar wording, Council may group or aggregate those submissions for reporting and analysis purposes. In such cases, the number of pro forma submissions received and the matters raised will be clearly identified and reported to elected members.
In considering submissions, Council will focus on the substance of the issues, views, and matters raised, rather than the number of times identical points are repeated. All issues raised through pro forma submissions will be considered alongside other submissions, having regard to statutory requirements, available evidence, council policy, and the overall public interest.
2.8 Withdrawing a submission
A submitter may withdraw their submission by notifying Council during the consultation period. Requests to withdraw a submission after the consultation period has closed may be considered at Council’s discretion, taking into account whether hearings or deliberations have occurred.
2.9 Out of scope submissions
Submissions that raise matters outside the scope of the consultation will still be recorded. Out-of-scope matters may be referred to the relevant Council teams where appropriate. Elected members will be advised that parts of a submission are not relevant to the decision being considered.
Out-of-scope content may be weighed differently from in-scope submissions at the discretion of decision makers.
2.10 Late submissions
Submissions received after the stated closing date and time are considered late submissions. Late submissions will only be accepted and considered under extraordinary circumstances. They may be accepted at Council’s discretion, having regard to fairness to other submitters, timing, and the integrity of the overall consultation process.
Where a late submission is not accepted, the submitter will be advised where practicable.
2.11 Hearings
Where a hearing is provided as part of a consultation process, submitters will be given the opportunity to speak to their submission.
Hearings allow submitters to highlight key points of their submission and provide elected members with the opportunity to ask questions.
Hearings may be held in person and/or via video, and may be livestreamed or recorded, where appropriate. Details about hearing formats, participation options, and any time limits will be outlined in the consultation material.
Submitters wishing to be heard must indicate this as part of their submission and provide contact details so arrangements can be made.
Council may, for efficiency and fairness, invite or accept a single representative or spokesperson to speak on behalf of multiple submitters who have made pro forma submissions raising the same or substantially similar matters. The speaking time allocated for pro forma representatives or spokespersons will be based on the provisions in Council’s Standing Orders. The use of representative speakers does not affect the validity of individual submissions or the Council’s obligation to consider the issues they raise.
The use of aggregation, summarisation, or representative speaking arrangements does not diminish the status of pro forma submissions, and is intended to support transparent, effective, and balanced decision making.
2.12 Council Decisions
Following the close of the submission period, and any subsequent hearing, council will consider all submissions on a particular matter. A summary of submissions will be presented to Council to give councillors an overview of all the submissions. Copies of all individual submissions in full will also be provided to Council. In making a final decision on any matter Council will take all submissions into account along with expert advice and relevant legislation.
Where appropriate, submitters will be provided with access to the decision and supporting information. As a minimum, decisions will be made publicly available through Council’s usual publication channels.
Council is not required to respond individually to each submission unless otherwise specified in the consultation material.