There is a basic requirement to periodically review consent charges to ensure statutory compliance and to only recover actual and reasonable costs more properly met by consent applicants or holders, as opposed to the community as a whole. This is particularly the case for fixed application charges, fixed compliance monitoring charges, and fixed initial deposit charges for the compliance monitoring of complex consents.
Such reviews should be aimed at utilising actual records of consent processing and monitoring costs to ascertain whether or not the fixed fees or fixed initial deposit charges are representative of actual costs.
Fixed application charges, fixed monitoring charges, and fixed initial deposit monitoring charges for complex consents should be reviewed annually as part of the annual plan development process. In this way actual historical recorded costs can be used to validate existing charges and there would be no need to apply inflation adjustments.
In the absence of the recommended annual reviews, reviews should occur no less frequently than every three years. In that case the review period should be aligned with the three yearly LTP review cycle. In the intervening years it would be acceptable practice to simply increase the charges by the same percentage rate that staff salary costs have increased by in the preceding year. This recognises that staff costs will largely underpin actual charges.
However, if a council uses a system of nominal ($100 to $500) fixed initial deposit charges with actual and reasonable additional charges in arrears for processing consent applications, then there is no need to review the application charges so frequently. In fact such a charging system should have a relatively long shelf life and might only need reviewing every six years or so.
