TUA's submission on the Planning Bill and Natural Environment Bill

Here is The Urban Advisory’s submission on the Planning Bill and Natural Environment Bill.

Our response supports the intent to replace the RMA with a more consistent, data-driven system that reduces consenting friction while safeguarding environmental limits. However, we believe the success of this reform hinges on moving beyond "paper consistency" to true systems integration.

Key themes from our submission include:

- Cities-as-Systems, Not Silos: Moving away from fragmented planning by requiring plans to be integrated and "stress-tested" for resilience against market shocks and infrastructure outages.

- Digital Urban Intelligence: Mandating region-wide, "decision-ready" evidence bases using spatial models to support planning rules and transparent monitoring.

- Defining "Well-Functioning" Environments: Explicitly defining "well-functioning urban environments" to distinguish them from rural goals, ensuring high-density success through better public-private interface quality.

- Sequencing Before Development: Ensuring environmental limits and hazards are established before growth patterns are locked in, so development is genuinely constrained by physical realities.

- Protecting Public Realm Performance: Amending out-of-scope effects to allow for objective standards on street-level performance—like active frontages and safety—without re-introducing subjective aesthetic controls.

- Te Tiriti and Māori Interests: Providing certainty for Māori participation and data sovereignty, while enabling the development of identified Māori land through partnership models.

We’re committed to a high-performing planning system that de-risks decisions, lifts urban productivity, and protects te taiao.

Read our full submission here:

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The Urban Advisory (TUA) supports the intent to replace the RMA with a clearer, more consistent system that reduces consenting friction while safeguarding environmental limits and improving decision‑making with better use of data and technology.  However, we see an opportunity for the legislation to more clearly support integrated land‑use–transport systems, expanded market‑aligned delivery models for social and housing infrastructure, streamlined environmental performance monitoring that can be embedded without adding prohibitive cost, and long‑term housing affordability mechanisms.

We agree with the Committee’s framing that these Bills are foundational and should be treated as a single, interlocking regime (spatial planning + land‑use rules + environmental limits). We also support the interim briefing approach and the Committee’s publication of initial advice, given the compressed submission window; transparent early advice improves the quality of sector feedback.

At a system level, we recommend the following principles—grounded in our practice here at TUA of integrated urban strategy, evidence‑led modelling, and delivery stewardship—be explicitly enabled across national direction and plans:

1. Cities‑as‑systems, not silos. Embed the concept that urban, infrastructure, economic, environmental and policy settings operate as one system; require plans to be integrated‑tested for resilience under stress (e.g., infrastructure outages, market shocks, hazard events), not just consistency on paper. (Aligns with Planning Bill objectives on growth and infrastructure; Natural Environment Bill limits.)
2. Digital urban intelligence. Require region‑wide decision‑ready evidence bases using spatial models (e.g., housing capacity vs. infrastructure capacity; hazard scenarios; biodiversity networks) to support spatial planning and plan rules, with open data standards for reproducibility and monitoring. (Reflects the Bills’ intent to “make better use of data and technology.”)
3. Well‑functioning environments defined. Clarify “well‑functioning urban environments” and avoid conflating urban and rural so decision‑makers can consistently operationalise outcomes across typologies and densities.
4. Sequencing that holds under pressure. Calibrate spatial planning, environmental limits, and land‑use rules so that limits and hazards genuinely constrain where development can go; avoid sequencing that plans growth before limits are known. (Echoes concerns raised by environment sector guidance.) 
5. Te Tiriti and Māori interests in practice. Ensure the regime provides certainty for Māori participation, identification and protection of sites of significance, and enabling development of identified Māori land, with data sovereignty and co‑governance pathways reflected across instruments. (Consistent with stated goals in both Bills and sector expectations.)

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Part 2 — Shared provisions across both Bills

2.1 Purpose and Goals (both Bills)
We support concise purposes and goals but recommend expanding the operative outcomes to:

• Define “well‑functioning urban environments” (Planning Bill) and “well‑functioning environments” more broadly, drawing on sector language to reflect integrated systems and private/public interface quality. Urban Auckland highlights that urban and rural goals should be distinct; we concur and recommend a definitional clause for “well‑functioning urban environments” supported by national criteria.
• Require evidence‑ready, digital baselines for both Bills (shared data schemas; model transparency; versioning) to support monitoring, recalibration, and stewardship over time—explicitly anticipated in the Bills’ “better use of data and technology” objective.
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‍2.2 Spatial planning and one‑plan logic
We support a single regional plan integrating spatial, natural environment, and land‑use components, with national direction released on time to avoid gaps and rework—echoing local government concerns. The sequencing of instruments should be clarified to avoid planning growth that will later be constrained by limits.

‍2.3 Implementation capacity and funding
We endorse calls for implementation funding and capability uplift for councils and iwi partners (including digital tooling and data infrastructure), acknowledging the significant transition workload flagged by councils.

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Part 3 — Planning Bill–specific comments

3.1 Purpose (s 4)
The current purpose—“to establish a framework for planning and regulating the use, development and enjoyment of land”—is concise but managerial. We support Urban Auckland’s suggestion to strengthen the purpose to explicitly address improved urban outcomes and productivity, recognising Auckland’s national role and the link between urban form, infrastructure efficiency, and economic performance. ‍

‍TUA lens (Areas 1, 3, 7, 9):

Add a system outcome clause requiring plans to integrate housing, infrastructure, environment, and economics, and to test performance under stress. This will reduce the well‑known “looks good on paper” problem that undermines delivery.

‍3.2 Goals (s 11)
We support the goals to enable growth, plan for infrastructure, and provide for Māori interests, but recommend splitting urban and rural goals or adding distinct sub‑clauses and a definition of well‑functioning urban environments. Urban Auckland’s rationale—that high‑density success hinges on public/private interface quality and design—is sound and aligns with urban design practice.

‍TUA lens (Areas 1, 5, 10):

Under the “well‑functioning urban” goal, add expectations for fine‑grain urban design outcomes (active frontages, service yard location, blank wall minimisation) where these materially affect public realm performance, coupled with national design guidance to maintain objectivity. This addresses the performance gap without re‑introducing subjective “amenity” controls.

‍3.3 Effects “out of scope” (s 14(1))
We share Urban Auckland’s concern that excluding internal/external layout, visual amenity, near‑field privacy effects, and site landscaping removes tools needed to manage the public/private interface—critical at higher densities and in centres. We recommend narrowly‑tailored, objective performance standards for interface conditions that directly affect public space function, safety (CPTED), and accessibility, while avoiding broad subjective aesthetic controls.

‍TUA lens (Areas 2, 10):

Use spatial evidence (pedestrian flow, frontage activation, servicing conflicts) to support objective standards (e.g., max blank wall length on primary streets; entrance frequency; service access placement relative to pedestrian priority streets). This keeps the benefits of simplification while protecting street performance. ‍

‍3.4 Regional Spatial Plans – Purpose (s 67)
We support strengthened expectations for place‑specific, design‑led spatial planning that translates national policy to local delivery, and forges community agreement on future patterns—consistent with NZIA’s emphasis. Require integration testing: housing capacity ⇆ infrastructure capacity ⇆ hazard/limit constraints ⇆ transport mode shift ⇆ biodiversity networks.

‍TUA lens (Areas 2, 5, 6, 7):

Mandate a single, decision‑ready evidence base (e.g. through Strategic Spatial Modelling) for spatial plans, scenario‑tested for housing mix, affordability pathways, infrastructure staging, and hazard exposure, with delivery plans (capital stacks, value‑capture) for priority precincts.

‍3.5 Māori interests and partnerships
We support explicit provisions for Māori participation, sites of significance, and enabling development of identified Māori land. Add guidance enabling JV partnership models and data sovereignty protocols (Te Mana Raraunga aligned) in evidence bases and monitoring.

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Part 4 — Natural Environment Bill–specific comments

4.1 Purpose and limits framework
To operationalise a limits‑based framework to safeguard air, water, soil, ecosystems, and no net loss of indigenous biodiversity codify in the Bill that regional evidence bases must include biodiversity network mapping, ecosystem health baselines, and monitoring methods (with open data standards) to support adaptive management and transparent trade‑off decisions.

‍4.2 Hazards and climate adaptation
Strengthen requirements for proportionate, risk‑based planning to address sea‑level rise, flooding, and cascading hazards, prioritising nature‑based solutions and risk‑responsive zoning. 

Alignment with sector submissions (for the Committee’s context)

• Urban Auckland: We align on strengthening purpose (outcomes‑oriented), splitting urban/rural goals, support for spatial planning, and concerns with s 14(1) exclusions where they undermine public realm performance at higher densities. 
• Professional bodies: Multiple bodies call for integrated, place‑based evidence, clear definitions, and caution on removing landscape/visual tools without targeted objective standards. (UDF/NZILA commentary and submissions.)
• Local government: Endorsement of single‑plan approach but calls for stronger local voice, Te Tiriti protections, biodiversity safeguards, and attention to funding/compensation impacts; the implementation load and sequencing risks are also highlighted by councils.

Summary of Key Amendments Sought

• Planning Bill s 11 (Goals):
  Split urban and rural goals or include sub‑clauses; define “well‑functioning urban environments” with reference to public–private interface performance and design quality where it materially affects public space, supported by national guidance to ensure objectivity.
• Planning Bill s 14(1) (Out‑of‑scope effects):
  Amend to allow objective, performance‑based standards for building‑to‑street interface and servicing impacts on the public realm, while still excluding subjective aesthetic matters.
• Planning Bill s 67 (Regional Spatial Plans):
  Require a single, decision‑ready, shared evidence base with scenario testing for capacity, infrastructure, hazards, and biodiversity networks, alongside national data standards.
• Natural Environment Bill (Limits):
  Clarify that limits must be set before spatial development patterns are locked in; cap exceptions; and require transparent trade‑off reporting in spatial and land‑use plans.
• Both Bills (Māori interests):
  Add operational guidance for Māori participation, site identification, Māori land enablement, and data sovereignty expectations for evidence and monitoring systems.

Conclusion

TUA supports the passage of the Planning Bill and Natural Environment Bill with the targeted amendments outlined above. Their success depends on systems integration, digital intelligence, clear definitions, calibrated scope of effects, and delivery‑ready planning — enabling projects to gain consent faster, attract capital, get built, and perform within environmental limits. Strengthening these elements will de‑risk decisions, lift urban productivity, and protect te taiao, particularly in Tāmaki Makaurau, where national productivity and housing outcomes rely on a high‑performing planning system.

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Ngā mihi nui,

Dr Natalie Allen and Greer O'Donnell