Taituarā has made a submission to the Environment Committee on the Natural Environment Bill and Planning Bill, supporting the intent of reform while raising significant concerns about design, sequencing, and implementation.
Drawing on sector-wide expertise, the submission focuses on ensuring the new resource management system is practical, integrated, and deliverable for local government and communities.
Along with the written submission, Taituarā representatives also gave a verbal submission at the Environment Committee (Select Committee) earlier this week. The verbal submission focused on the implementation of the reforms, the system architecture, the need for recognition of Te Tiriti and Māori interests, and regulatory relief.
The written submission is thorough and detailed, coming in at over 100 pages, for a quick snapshot of what it contains read the short summary below.
You can read the full submission here.
Key messages
System design must be integrated and workable
Taituarā raises concerns about the proposed split between the natural environment and land use regimes, noting this could create gaps, duplication, and inconsistent decision-making. The submission recommends a more integrated approach to ensure all environmental effects can be properly considered.
Implementation timeframes are unrealistic
The proposed rollout, and associated timeframes, is unworkable, with critical national direction and environmental limits scheduled too late to inform planning. Taituarā recommends re-sequencing the system so national direction is in place first, and extending timeframes, particularly allowing at least 24 months to prepare Regional Spatial Plans.
Transition arrangements risk complexity and confusion
The transition from the current system to the new framework is expected to be highly complex, with overlapping rules and unclear processes. The submission calls for simplified transitional provisions, clear guidance, and strong communication to support councils and system users.
Funding and capacity challenges must be addressed
Implementation costs for local government are estimated at more than $860 million, with additional pressures from other reforms. Taituarā stresses the need for clarity on funding responsibilities and direct central government support to ensure successful delivery.
Alignment across reforms is critical
The Bills are being introduced alongside multiple other major reforms, including water services, emergency management, and local government restructuring. Taituarā highlights the cumulative impact on councils and recommends a coordinated, system-wide approach to implementation.
Te Tiriti obligations must be strengthened
The submission raises concerns that the Bills weaken existing provisions relating to Te Tiriti o Waitangi. It calls for clearer, stronger obligations and for the Crown to retain responsibility for Treaty settlement arrangements.
Key recommendations
The submission includes a comprehensive set of recommendations, with a focus on:
- Re-sequencing implementation so national direction is established before regional and local planning
- Extending timeframes and enabling flexibility through Order in Council
- Simplifying transition arrangements and minimising interim regulatory changes
- Removing or redesigning the proposed regulatory relief regime
- Strengthening Te Tiriti provisions and Māori engagement requirements
- Providing clear funding pathways and implementation support for local government
- Ensuring alignment with other major reform programmes
Looking ahead
Getting the foundations right is critical. While reform presents an opportunity to improve the system, the Taituarā submission cautions against prioritising speed over quality.
A well-sequenced, adequately funded, and integrated approach will be essential to delivering a planning system that works for communities, the environment, and future generations.
Next Steps
Taituarā is working alongside the Ministry for the Environment (MfE), New Zealand Planning Institute (NZPI), and Te Ura Kahika to support the sector through these reforms, with work currently underway on further pre-enactment activities.
We have shared with all council CE’s high-level details of MfE’s plans to engage directly with all councils to create a ‘readiness snapshot’. This will involve face-to-face interviews with chief executive and relevant managers focused on the operational side of things to build a picture of each council’s readiness. This will start with a small pilot group before expanding to all remaining councils.
