Creating Effective Submissions

A general guide for Cyclists on submissions

  Creating Effective Submissions

• Submissions are an important part of getting cycling needs heard
• You don't have to be technical expert or brilliant word smith to be effective (but it helps for some specialist consultations)
• It is more important to follow a few common rules and add your personal touch

Types of submissions

1 Written "Numbers Game" Submissions
-adding additional votes of support/dissent to assist decision-makers deliberate

2 Written Technical/Detailed submissions
- help agencies produce the best solution
Ideas for submissions - cheap things to ask your council for

3 Submissions in Person
-sometimes strategically useful (often additional to a written submission, i.e. "speaking to a written submission")

What can be submitted on

• It is important to be aware of all possible issues that may come up and be relevant to walking/cycling
• Limited time/resources may mean choosing (a) which issues to submit on (b) how much effort to put in

(a)    Obvious submissions

• Cycle/Walking Facility Projects
• General Roading Projects
• NZTA's 10 year State Highway Plan and Forecast (and Annual Work Programmes)
• Relevant Council Strategies e.g. Cycling, Pedestrian, Active Transport, Transport, Road Safety
• Local/Regional Council Annual Plans
• Parks/Reserve Development Proposals

(b)   Less obvious submissions to watch for

• Local/Regional Council Long Term Council Community Plans (LTCCPs)
• Regional Land Transport Strategy (RLTS) (5-10 year strategies with 3 yearly reviews)
• Council Policies/Strategies on:
• Central Business District Redevelopment
• Traffic or Public Space Bylaws
• Speed Limit Changes

(c)    Not-so-obvious submissions to watch for

• Other Council Policies Strategies on: Parking, Visitors, Public Transport, Sport and Recreation (e.g. SPARC, Physical Activity Plans-Regional and City/District Council)
• District Health Board Strategies (e.g. HEHA Regional Plan)
• Land Use Changes (District Plan)
• Regional Policy Statements (RPS)
• Major development Resource Consents

It is important to know about submissions
A group Submissions Co-ordinator's can:

• be the contact point for external notifications
• identify/watch out for issues to submit on (see above for examples of submissions)
• inform group members
• liaise with other Groups (swap notes, gain their views, consider joint submissions)
• delegate/co-ordinate submission preparation (i.e. s/he does not have to do the submissions)
• control timeliness (critical issue)

Tips on hearing about consultations

• Get onto any Stakeholder distribution lists (post and email)
• Some only go to immediate neighbours (e.g. people living in a street under consultation may be informed whereas walkers/cyclists passing through may not)
• Try to get early feedback opportunities (before a proposal/strategy is drafted) as its harder to change a draft strategy
• Having regular meetings with key agencies/contacts can help get a heads up
• Ensure representation on local committees
• Scan Council advance agendas on-line for items of interest. Often there has to be Council/Board approval for public consultation
• Keep on eye on Public Notices in the classified section of major papers (often midweek or important ones in Weekend edition)
• Scan websites
• All Councils should have a "Get Involved"/"Have your Say"/What's new" consultation web page http://www.govt.nz/record?recordid=4299

Timing of regular consultations

• Know approximate time of regular consultations e.g.
  • Annual Plans/Long Term Council Community Plan (LTCCP) usually March-May
  • Transit NZ's 10 year State Highway Plan and Forecast usually March-April
  • RLTS/LTCCP typically reviewed every 3 years
• Again, it is better to get into Draft Plans earlier via Staff contact

Don't rely on submissions alone

• Submissions are by their nature reactive. It can be hard to have major influence if a lot of work is already done, as thinking becomes more solidified
• Maintain ongoing links with key people e.g. Staff (NZTA, Council esp. Transport Planners & Engineers); Elected people (Councillors and Community Board members); and Resident Groups. You may get a heads up on potentially contentious consultations where some support on the other side would be appreciated

Group organisation for submissions

• Maintain a submission template
• Have a process in place for developing a submission that suits the organisation size e.g. for a small organisation:

(a) circulate draft to membership/subsection of membership
(b) receive feedback and comments
(c) work in feedback and if necessary recirculate for further feedback
(d) finalise submission
(e) may need committee to ratify
(f) chairperson signs
(g) submit and publish to membership

Resolving divergent views from your group

• Agree on a process (e.g. as in above bullet point a-g) before it is needed
• Strive for consensus of issues rather than consensus of views (what is important even if can not agree on the solution)
• If consensus is not possible provide the case for both opinions e.g. "Generally the group feels option A is the best because of... However a number of our members would suggest that option A is not the best solution as it... and option B is better as it will....
  We feel you should consider and address these aspects in your decision."

What is consultation?

• Important to understand what consultation is being sought
• Consultation may range from: totally open ended to all ideas and suggestions, no fixed proposals; comments on broad plans/policies; feedback on detailed proposals; information on pending activities-only minor opportunity to influence implementation
• Remember while genuine consultation must take account of your submission,they do not have to agree with your requests/proposals
• If you think they have missed the point you might follow up

But don't persist if they obviously don't agree

More detailed information on writing effective submissions

"Numbers Game" Submissions
Technical"/Detailed Submissions
Submissions in Person

Here's submissions from
CAN
Cycle Aware Wellington
Spokes Canterbury

Source: Glen Koorey's Cycling Advocates' Network (CAN) Workshop - "Creating Effective Submissions", 2007; with a few additions from Axel Wilke's "Effective Submissions" presented to ChCh City Council, 2003, CAN User Group Handbook, & Living Streets Aotearoa User Group Handbook.