Commenting on Draft Municipal Documents – Are Residents Wasting Their Time?

OVAC Articles
Commenting on Draft Municipal Documents – Are Residents Wasting Their Time?
Holding Power to Account

Residents who have taken the time to work through thousands of pages of draft municipal documents and submit detailed comments have probably asked themselves the same question: does any of it actually make a difference?

In an attempt to explore this question, OVAC recently conducted an AI-assisted comparison of draft municipal documents against final adopted versions over the past three years and found very few substantive differences between them.

Documents analysed included:

  • Integrated Development Plans (IDPs)
  • Annual Budgets and MTREF documentation
  • Spatial planning and related policy documents
  • Tariff-related documentation

The changes identified were largely administrative, technical, formatting, or minor project-level adjustments. OVAC could find no clear indication in the documents reviewed that public comments materially influenced final strategic decisions.

Of further concern was the apparent absence of any consolidated record showing where public participation processes resulted in substantive amendments to final municipal documents. While

this may not be a specific legal requirement, record-keeping of this nature is widely regarded as good governance practice.

OVAC subsequently submitted a formal request to the Municipal Manager, Dr Dean O’Neill, seeking records demonstrating where written public submissions resulted in substantive amendments to municipal strategic, planning, financial, and policy documents over the past five years.

Dr O’Neill responded that the Municipality does not have the time to compile such information and advised OVAC to consult comments attached to council reports and agendas.

OVAC could not help but note the irony of this response. When OVAC previously raised concerns regarding the limited time afforded to residents to review and comment on thousands of pages of draft municipal documents, Dr O’Neill advised residents to stop complaining and rather use the available time to read the documents.

Meaningful public participation is a central principle of the Municipal Systems Act and forms part of the broader constitutional requirement for accountable and responsive local government.

OVAC again invites the Overstrand Municipality to provide clear examples where written comments have resulted in significant changes to final adopted documents. In the absence of such evidence, OVAC could find no indication that written public comments materially influence final outcomes.

Yours in Accountability
Anton Kruger
OVAC