Public Comment on Draft Contributions Policy

I support the City establishing a clear framework for the requesting and acceptance of contributions. The Policy appropriately seeks to promote good governance, due diligence, transparency and accountability.

However, I recommend that the following matters be strengthened before the Policy is adopted:

1. Public transparency (NB)

The Policy should require a publicly accessible register of accepted contributions, including the contributor, value/nature of the contribution, purpose, conditions attached, receiving department and approving authority. Internal recording alone does not provide sufficient public accountability.

2. Transparency of implementation

The Policy relies substantially on separate SOPs, guidelines and delegated authorities. These documents should be publicly available so that residents and potential contributors can understand how contributions will actually be assessed, approved or rejected.

3. Consistent decision-making

The City should establish clear and objective criteria for accepting or rejecting contributions. Where a contribution is rejected, written reasons should be provided, together with an appropriate mechanism for reconsideration. This would reduce the risk of inconsistent or arbitrary decisions.

4. Equity between communities

The Policy should expressly ensure that private contributions do not result in preferential service delivery or create greater disparities between communities based on their ability to raise private funds. Contributions should supplement, rather than replace, the City's responsibility for equitable service delivery.

5. Long-term costs and donor conditions

Before accepting significant contributions, the City should consider the full lifecycle costs and future municipal obligations created by the contribution. Conditions attached to contributions should also be clearly regulated to ensure that contributors cannot improperly influence municipal priorities, procurement, land-use or other municipal decisions.

Conclusion

I support the objectives of the Draft Contributions Policy, but recommend that it be strengthened to ensure that contributions are managed in a manner that is transparent, equitable, proportionate and consistently accountable to the public.