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Our Ref T Whitmarsh/jc:DOC14/18621

4 July 2014

Regulation Review — Local Government Independent Pricing and Regulatory Tribunal PO Box Q290 QVB POST OFFICE NSW 1230

City of Botany Bay

General Manager's Office

Administration Centre 141 Coward Street Mascot NSW 2020

PO Box 331 Mascot

Telephone: (02) 9366 3666 Facsimile: (02) 9667 1793

DX 4108 Maroubra Junction

Dear Sir/Madam

Re: IPART Draft Report on Local Government Compliance and Enforcement

Thank you for the opportunity to review and comment on this report. Botany Bay City Council supports the general thrust of the recommendations contained in it. We are especially keen to see improved partnering between State Government agencies and Local Government authorities. We look forward to more detailed proposals that will emerge as a result of the IPART analysis and work from concurrent local government reform reviews. In this context we have confined the balance of our current feedback for IPART to a handful of areas of special concern as follows.

Shared Inspection Regimes Particular care needs to be taken where inspection regime responsibilities are to be shared. There are dangers of work 'falling into cracks' where it may be incorrectly assumed that one or the other is taking up the slack on coverage, for example, of food shop inspections under the "A B C" inspection programming options. [Note background to Draft Recommendations 1, 2, 24 and 25 of the IPART draft report]

Regional Sharing of Human Resources There are significant limits to flexibility with human resource sharing across regions when deploying regulatory enforcement specialists who do not possess (or cannot quickly acquire) local area knowledge needed to effectively patrol and monitor otherwise unfamiliar territory. We would like to see accreditation of competencies to understand roles and perform critical tasks. We note that role definitions can be confusing and will have to be addressed — for example, one cannot assume that the role of a "ranger" is the same in every authority although regulatory reforms may well help stakeholders move closer to defining common standards around occupational definitions and likely job roles. [Note background to Draft Recommendation 10 of the IPART draft report]

Regular Review of Core Documents Underpinning Policy and Service Delivery Frameworks We note Principle 7 of the 2009 "Guide to Better Regulation" published by the former NSW Better Regulation Office, and the importance of keeping core documents that define and drive delivery frameworks fresh and relevant. We would like to see more mandatory requirements for regular review of critical public policy documents, MOUs and other key instruments. We appreciate that the nature and frequency of review may need to vary according to the type of instrument and strategic imperatives associated with it. However, there appears to be a strong case to 'better regulate the regulators' to ensure that due attention is paid in at least the same way that black letter law is subject to review every 5 years under provisions of the NSW Subordinate Legislation Act 1989. [Note background to Draft Recommendations 3, 4, 6 and 7 in the IPART draft report]

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Improved Accessibility of Strategic and Operational Information We would like to highlight the importance of making strategic and operational information more readily discoverable through mechanisms such as State Government agency websites, extranets and web based collaborative tools. We note that the Office of Local Government needs to set a better example in this regard as far as comprehensive, current and user friendly provision of information that is relatively easy to search and navigate on its website. [Note background to Draft Recommendation 1 of the IPART draft report]

If you have any queries about this submission you are welcome to contact Tanya Whitmarsh by emailing Whitmarsht@botanybay.nsw.gov.au or phoning 9366 3638.

Yours sincerely

Lara Kirchner GENERAL MANAGER

GAGM's Office \Utters \ 2014 \ Submission to !PART - Draft Report on Local Government Compliance and Enforcement - Out 14.docx

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