Navigating the Resource Management Reforms in Consent Processes
- Foss Shanahan
- 5 days ago
- 6 min read
The upcoming Resource Management (RM) reforms are front of mind for New Zealand planning teams.
This deep dive explores the practical impact of these shifts on the preparation and processing of resource consent applications.
Change is Inherently Challenging
Historically, major planning framework changes have created challenges for consent processing. As new policies hit the ground, high-level provisions are stress-tested on real-world projects, often needing to be interpreted and turned into actionable processes.
The result is predictable. Major regulatory shifts typically lead to:
Increased processing timeframes as implementation details are refined in action.
A higher volume of RFIs and rejected applications due to misinterpretation of new policies on the applicant side.
Significant delays and additional costs for those seeking consent.
Most planners will have experienced these frictions, whether from central government, or locally initiated, changes to the planning framework
This is not an indictment on the current reforms. It is simply to say that whether or not the system is better, there is a "cost of change" at a mechanical level as planning teams need to hash out the details of applying new policies in practice, and that needs to be acknowledged and accepted coming into this period of reform.
The New Reform Roadmap
While the full details are not yet finalised, the roadmap includes a transitional system starting in late 2026, followed by a full system launch post-2029.
Key indicative details can be found in following central government communications:
The transitional system will operate under the existing RMA with several critical adjustments:
National rules for specific activities.
Reduced scope for effects considered in decision-making.
Removal of "special circumstances" from notification assessments.
Mandatory regard for new spatial plans (once decisions on these plans are made).
Procedural updates aligned with new efficiency principles.
Concurrently, local authorities must draft new combined regional plans to replace existing ones, consolidating city, district, and regional plans into a unified framework.
Existing (Separate unless unitary authority) | New (Combined in Regional Plan) |
City and district plans | Land use plans |
Regional plans | Natural environment plans |
Regional policy statements | Spatial plans |
Existing Governing Legislation | New Governing Legislation |
Resource Management Act | Planning Bill |
Natural Environment Bill |
Once all these new plans have been notified, the transition period will end and the new consenting regime will be turned on.
What Past Change Can Teach Us About The Reforms
Our most concrete guide for what's to come is what's already been.
The transition period will be an adjustment to the existing process, before the new bills, and new system, fully come into effect.
Generally, changes to the existing framework either adjust the decision-making process (set out in the RMA) directly, or introduce new planning instruments within that process which add a layer to consent processing. The friction sits in working out how that new layer interacts with what's already there. A more detailed picture of how this looks can be seen in past examples of central government initiated changes:
RMA Amendment (directing councils to make plan changes)
Example: Resource Management (Enabling Housing Supply and Other Matters) Amendment Act 2021, a.k.a Medium Density Residential Standards.
Effect on Plans and Consent Processes
Change | Challenges in Practice |
Directed certain territorial authorities to incorporate specific rules into their district plans within a certain timeframe. Once notified, new rules had immediate legal effect and superseded existing plan rules in certain circumstances (e.g. where there were no qualifying matters). | Plan-making teams struggled to make changes to existing plans in a specified timeframe, and some pushed back. At a consent processing level, though the new rules came into legal effect, qualifying matters meant that they were not always applicable. This created an additional layer of assessment to determine how the new rules interacted with existing rules which varied across proposals. |
New National Environmental Standards
Example: National Environmental Standards for Detached Minor Residential Units 2025.
Effect on Plans and Consent Processes
Change | Challenges in Practice |
Introduced new rules that could override district and regional plan rules, making detached minor residential units permitted in more cases. | The consent process must now consider both the NES and the relevant District / Regional plan, as some local rules still apply while others are explicitly excluded. This creates two layers of provisions that need to be considered in determining what rules do and don't apply. |
New National Policy Statement
Example: National Policy Statement for Natural Hazards 2025.
Effect on Plans and Consent Processes
Change | Challenges in Practice |
Introduced a national risk matrix framework for managing natural hazard risks, adding a new layer of national direction on top of existing local plan provisions addressing natural hazards. | The NPS applies to proposals requiring consent only and does not trigger plan changes directly. Consent processing must consider both the NPS risk matrix and the local plan's natural hazard framework, creating two layers of guidance for managing similar risks. |
RMA Amendment (to consent decision-making processes)
Example: Resource Management (Simplifying and Streamlining) Amendment Act 2009.
Effect on Plans and Consent Processes
Change | Challenges in Practice |
Restructured the notification rules with a more prescriptive step-by-step framework across new sections (s95A to s95F), separately covering public notification, limited notification, and affected persons. | The shift from a discretionary approach to a multi-step framework means planners must formally address each step, including ruling out steps that are irrelevant in many cases (e.g. Step 4 Special Circumstances, which is now set to be removed in the transition). |
The Key Bottlenecks
It is important to identify specifically where the cost of change will create bottlenecks operationally, so planning teams can be best positioned to prepare for these.
Based on the examples above, we can expect three specific bottlenecks to surface as reforms take effect:
Interpreting new rules and provisions as changes to existing plans come into force.
Assessing an additional layer of national rules and provisions on top of local plans.
Adjusting decision-making processes, particularly for Notification (s95) and Substantive (s104) decisions.
These challenges ring true overseas too. In my experience speaking with planning teams in NSW, where the state government is pursuing its own reform agenda, planning teams report the same bottlenecks.
How This Transition Can Be Different
First, it is important to be realistic in that there will be a cost of change, so you expect it. Then it is important to know where bottlenecks are likely to surface, so you know where to target. This positions you with a realistic read on the situation.
Both skills and processes will need to improve to address these bottlenecks.
At Rico, we are not legal or planning experts - we are planning process experts and focus on the process level specifically. From our perspective, the key gap we see is consistent process, or in some cases, any process, in these areas identified as bottlenecks.
Picture a team of ten planners dealing with a new plan change. Without a documented process for analysing its effects on a given proposal:
Each planner is left to develop their own ad-hoc approach.
Less experienced planners are left to take a stab in the dark or recycle logic from existing projects that may or may not be correct.
With multiple approaches in play across the team, outcomes naturally vary and time is wasted interpreting each different approach slowing down reviews and communication between planners.
All of this adds to the cognitive load and creates more work.
This process gap exacerbates the "cost of change." The resulting friction (longer timeframes, higher RFI volumes, project delays) is a direct consequence of teams hashing out new standards individually and then managing all the variations that emerge.
Individual skill matters, but when it comes to teams and scale, so does consistency. Without it, we revert to the disorganised approach of the past (and the same results).
What This Looks Like in Practice
The content of the new legislation is out of our control. Each team's capacity to adapt effectively isn't.
Teams that proactively standardise and document their core assessment processes will be in a fundamentally different position.
This doesn't mean ignoring nuances, or removing the thinking, it means implementing processes that adapt to your team's unique approach and nuances, while keeping everyone working off the same page.
The areas that matter most:
Determining applicable rules and provisions for a given project when multiple instruments are in play.
Understanding the effect of plan changes at a fundamental level, so the analysis is repeatable across different applications.
Incorporating national planning instruments (NES, NPS, national rules) into assessments alongside local plan provisions.
Getting these right can be hard, but teams that do can dramatically reduce ad-hoc decision-making, cut down complexity, and navigate the transition successfully without unnecessary.
A Word on Rico
At Rico, we help planning teams build consistent processes that handle the nuances of planning, support planners in their thinking, and respond to change with confidence. We do this by:
Freeing up the mechanical work of creating, updating, and distributing templates
Giving planning experts more time to develop guidance and processes that cover a wider range of circumstances
Get everyone working in the same workflow, avoiding outdated or incorrect approach
Helping teams implement a full plan assessment process, which we keep up to date with local and national planning instruments, and tracked across versions/changes
We're committed to helping our clients navigate the implementation challenges that come with the reforms. We'd love to talk to anyone working through the same thing and share mutual learnings.
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