The Planning Bill: What Infrastructure Providers Need to Know

The Government’s reforms reset the resource management framework for infrastructure: what matters most now happens at the top of the system.

This article provides a high‑level overview of the Planning Bill through an infrastructure lens, highlighting the key changes and how they compare with the framework under the Resource Management Act 1991 (RMA). The aim is to help infrastructure providers understand where the most important pressure points now sit, and where the real opportunities to influence the system arise.

1. “Goals” at the top of the funnel: get them right, or live with them

The Planning Bill sets out several “goals” for the new regime that drive downstream decisions. Two goals are especially pivotal for infrastructure:

• To ensure that land use does not unreasonably affect others, including by separating incompatible land uses; and
• To plan and provide for infrastructure to meet current and expected demand.

Because national instruments (see point 3 below) are required to particularise these goals, direct how they are to be achieved and resolve conflicts between the goals of the Planning Bill and Natural Environment Bill, the precise wording of the goals will directly influence how well existing and future infrastructure is both protected and enabled. Once national instruments are finalised, councils must comply with their directions and implement them, often with very limited discretion. Those instruments then drive the content of regional spatial plans and land use plans, locking the goals into the system’s architecture.

Action for infrastructure providers: Prioritise submissions on the wording of the goals.

2. “National instruments”: the new power tools

National instruments (national policy direction and national standards) sit at the top of the new system’s hierarchy. They are created and issued by central government. Their purpose is to particularise the goals and to help resolve conflicts between the goals in the Planning Bill and the Natural Environment Bill. Once made, councils will be required to implement them, and in many cases must insert their provisions directly into regional spatial plans and land use plans, often with limited discretion.

The Planning Bill allows national instruments to direct how land use is managed, how councils make decisions, which methodologies they apply, and even the structure and form of regional spatial and land use plans. Critically, they can require standardised provisions to be inserted directly into plans, with limited or no local ability to amend or tailor them. It is possible that these standardised provisions will include buffers, mapping conventions, conditions, and enforcement settings etc relevant to infrastructure providers.

This brings both opportunity and risk. Favourable national provisions can significantly streamline infrastructure delivery. But highly standardised provisions, if not carefully considered, could unintentionally weaken protections for infrastructure (for example, if generic development‑enabling provisions override local operational needs/protection).

Action for infrastructure providers: Push for strong, targeted provisions in the national instruments that:

• Embed fit‑for‑purpose protections for existing and future infrastructure;
• Enable the continued operation, upgrade, and expansion of critical assets through clear, policy settings; and
• Resolve conflicts between the goals in infrastructure’s favour where necessary and appropriate.

3. A narrower effects lens: why it matters for infrastructure

The Planning Bill deliberately narrows the scope of effects that decision‑makers may consider. Certain effects are expressly out of scope or must not be taken into account, including precedent effects and “less than minor” adverse effects. This is intended to streamline consenting and reduce complexity, which may assist for the development and upgrade of infrastructure. However, it may limit the ability to respond to incremental pressures on existing infrastructure, particularly reverse‑sensitivity risks, unless robust protections are embedded in national instruments and reflected in plan provisions.

Action for infrastructure providers: Focus submissions on the Planning Bill to ensure the narrowed effects framework does not unintentionally compromise the protection of infrastructure.

4. Spatial planning & land use plans: where you show up and how

Three plan layers will sit in one combined regional plan:

• Regional spatial plan: a 30‑year blueprint for growth, infrastructure and separations. These must implement national direction in a way that provides for use and development within environmental limits and promote integration of development planning with infrastructure planning and investment. They are also intended to integrate decision-making under the Planning Bill and Natural Environment Bill.
• Land use plan: district‑level rules enabling and regulating the use and development of land within a district and implementing the national instruments and regional spatial plan. Notably, submission rights are tighter (for example, they are limited to qualifying resident / greater than general public interest tests).
• Natural environment plan: these are provided for under the Natural Environment Bill and set environmental allocations/limits prescribed under that Bill and the resulting national direction.

Action for infrastructure providers: Engage early in regional spatial plan processes to lock in safeguards and enablement. There may be limited follow-on participation in the development of land use plans which must implement regional spatial plans, often through standardised provisions.

5. Designations: a modernised and more accessible regime

The Planning Bill recasts the designation regime in a way that feels familiar but modernises how designations are secured, maintained, and integrated into the new planning documents.

• Updated terminology: the terminology and eligibility framework have evolved. For example, the Planning Bill replaces the RMA’s “requiring authority” with the updated term “designating authority”, and “notice of requirement” is replaced with “proposed designation”.
• Existing designations remain intact: RMA designations are carried forward into the new system, and existing requiring authorities automatically become designating authorities. Existing designations will be incorporated into the new land use plans. The plan‑making process also provides opportunities to include new or future designations. Councils may also incorporate designations into regional spatial plans.
• Eligibility to become a designating authority: the Planning Bill introduces a mechanism for a Minister to approve an infrastructure operator who would not ordinarily be a designating authority to become a designating authority for a one-off project where the Minister is satisfied that the project or operation will deliver significant public benefit and a designation approach is appropriate for the purposes of the project. This could open the door for operators who previously could not access designation powers under the RMA, to secure long‑term protection for operational land and assets.

Actions for infrastructure providers: Consider how the new regime could support your organisation’s long‑term operational needs, future growth areas, and protection of critical infrastructure.

6. Timelines & choreography: when the dominoes fall

The new system is designed to roll out in a tight, top‑down sequence: national instruments → regional spatial plans → land use and natural environment plans.

Because every downstream document must “implement” national direction, the early milestones will lock in the architecture of the entire system.

Where we are now: the legislative clock is already ticking. Public submissions on the Planning Bill and Natural Environment Bill close on 13 February 2026, following the Environment Committee’s joint call for feedback.

The Government has signalled its intention for both Bills to receive Royal assent by mid‑2026, setting the stage for a cascade of implementation steps.

What happens after Royal assent: once the Planning and Natural Environment Bills are passed, Schedule 1 triggers an ambitious rollout (see our article on the transition here):

• Within nine months of Royal assent, the first national policy direction must be issued. Nine months later the first set of national standards setting the evidence base supporting combined plans must be issued.
• Within 18 months of Royal assent, any national standard on standardised provisions must be issued.
• For regional spatial plans, councils must notify these within 15 months of Royal assent or six months after the first national policy direction is issued and finalise them within six months of notification.
• For land use plans and natural environment plans, councils must notify these within nine months of regional spatial plan decisions.

This creates a system where national instruments define the content, and regional/local planning processes implement them with limited ability to deviate.

The key influence points occur early:

• Submissions on the Planning Bill (due 13 February 2026) are the first and most important opportunity to ensure the primary legislation provides for and protects infrastructure.
• National instruments will follow quickly, and these will particularise the goals, resolve conflicts between the goals (to the extent practicable), and set the standardised provisions and rules that regional spatial plans and land use plans must adopt.

For infrastructure providers, this means:

• Prepare now for the 13 February 2026 submission deadline.
• Expect an intense period of consultation on national instruments soon after the Planning Bill receives Royal assent.
• Treat national direction as a critical consultation because this is where conflicts are intended to be resolved and, accordingly, where protections for existing and future infrastructure will be won or lost.

Want to know more?

For further detail on other aspects of the reforms that may be relevant to your business, please refer to our related articles.

If you have any questions about the new Planning Bill or the Natural Environment Bill, please contact our specialist environment, planning and natural resources team.

Related articles:

The Planning Bill: What Infrastructure Providers Need to Know
Growth on the coast – a more enabling consenting pathway for the coastal environment
Resource management reform: what does it mean for the primary sector?
Resource Management Reforms: Push play on projects or sit tight for now?