Despite local government reforms in Western Australia aimed at reducing reactionary complaints, a mixed picture remains evident around effective complaints causation (dysfunction) management. For example, while some specific types of complaints of substandard conduct had decreased, broader administrative complaints to the Ombudsman have reached record highs. This suggests dysfunction where current complaint management appears to be simplistically treating symptoms rather than root causes. This creates a chain reaction where issues resurface elsewhere, bypassing the systemic analysis needed to prevent repetitive or repercussive failures.

Complaint management in the West Australian local government industry is best described as symptomatic management. Essentially “playing Whac-A-Mole” with issues. By shutting down the voiced complaint without addressing the root cause, the systemic friction can be seen to simply migrate elsewhere. In systems thinking, this is often called a “Shifting the Burden” archetype. The short-term fix (the “band-aid”) relieves the pressure, which reduces the urgency to find a permanent solution, allowing the underlying dysfunction to persist and manifest as new problems later.

It would make a good deal more sense if the WA Local Government Inspector’s efforts were dedicated to moving toward permanent resolution, shifting focus from reactive management to proactive structural or functional analysis including the development of root cause analysis frameworks and feedback loops to capture and remove reappearing dysfunction patterns.

Trends in Complaint Data

Recent annual reports show diverging trends across different oversight bodies: (AI generated)

• Standards Panel (Minor Breaches): There was a 12% decrease in new minor breach complaints lodged with the Local Government Standards Panel in 2024–25 (118 complaints) compared to the previous year (134 complaints).
• Ombudsman WA (Administrative Actions): Conversely, the Ombudsman Western Australia reported that the greatest increase in complaints across the public sector was about local governments, rising nearly 39% from 326 in 2023–24 to 453 in 2024–25.

Impact of Specific Reform Measures

Newly introduced in the 2024–2026 reforms, authority to designate individuals as ‘Unreasonable Complainants’ represents a reactive ‘reform’ that masks systemic failures. Under such a policy, local government CEOs can terminate engagement with complainants who continue to pursue compliance on unresolved legal matters. This administrative silence ignores the underlying causal factors, ultimately compounding the organization’s dysfunction by allowing identified problems to persist and spread.

The Ombudsman’s office also faces a clear conflict: they cannot impartially address complaints against a local government using an ‘Unreasonable Complainant’ policy that the Ombudsman’s office itself encouraged.

The high number of complaint failures is a factor of inadequate formal defining of substandard or non-compliant conduct.

The high rate of complaint “failures” (where issues recur or remain unresolved) is often linked to vague or inadequate formal definitions of what constitutes “substandard” or “non-compliant” conduct. Without clear, measurable benchmarks, the process becomes subjective, making it easier for administrations to dismiss valid concerns.

1. The “Standard” Problem

“Substandard performance” is broadly defined as failing to “attain or sustain a standard that a person may reasonably be expected to attain”. This reliance on “reasonableness” creates several issues:

• Subjectivity: What a complainant considers a “reasonable” expectation of legal compliance may differ significantly from what a CEO or manager deems “reasonable” for their staff.
• Lack of Specificity: Unlike technical fields, administrative “conduct” often lacks a granular, “pass/fail” checklist.
• The “Handled” Loophole: If a standard isn’t strictly defined, an agency can claim a matter is “handled” simply because they followed a process, even if the causal factor (the actual error) was never fixed.

1. Regulatory Gaps

The current framework often focuses on who is complaining rather than what they are complaining about.

• Focus on Behaviour: Policies like the [Ombudsman’s Unreasonable Complainant Conduct) provide very clear definitions for “unreasonable persistence” or “unreasonable demands” even where those definitions are themselves ‘unreasonable’ with respect to causal remediation.
• Absence of Inverse Standards: There is no equivalent, equally rigorous “Unreasonable Administrative Conduct” policy that defines the point at which a manager’s refusal to acknowledge an error becomes “substandard.”
• Systemic Neglect: The City of Melville complaint systems are designed to handle individual grievances rather than perform the root cause analysis required for “permanent system resolution”.

1. Impact on Recurrence

When “non-compliance” is not strictly defined:

• Escalation Fails: Oversight bodies like the Local Government Inspector struggle to intervene because there is no “bright-line” breach to enforce against a senior manager.
• Whac-A-Mole Effect: Without a formal definition of the “correct” standard, a “fix” in one department may just shift the non-compliant practice to another, as the underlying logic remains unchallenged.