About the Author
Grant Eccles | Technical Director – Planning, Legislation and Reform | Tonkin + Taylor
Grant leads as Technical Director – Planning, Legislation and Reform at Tonkin + Taylor in Hamilton. With 31 years in resource management, including 29 as a consultant planner in Hamilton, he delivers deep, practical expertise to navigate complex consenting and designation challenges across New Zealand.
Grant has led planning on some of the country’s most significant infrastructure projects, including Ōtaki to North of Levin, Hamilton Southern Links, the Additional Waitematā Harbour Crossing study, and new electricity distribution infrastructure for Powerco across the Coromandel and Bay of Plenty. He navigates large, complicated projects through the designation and consenting process and keeps them on track when challenges arise, ensuring conditions remain focused and relevant.
More recently, Grant has led Tonkin + Taylor’s response to the RMA (Resource Management Act) reforms, including preparing key submissions and presenting before the Select Committee on the Planning Bill and the Natural Environment Bill. There, he advocated specific improvements to the designation provisions, emphasising their importance for project delivery and efficient resource management.
Having recently had the opportunity to speak to the Select Committee on aspects of the RMA reform package, I’ve been thinking about what the Planning Bill’s proposed designation framework could mean in practice for infrastructure providers.
There’s a lot to like – let’s begin with the positives.
For requiring authorities, one of the more useful shifts is the move away from the current alternatives assessment toward an Assessment of Strategic Need. In practical terms, that feels more aligned with how major infrastructure projects actually come about.
By the time a project reaches the designation stage, the question of need has already been rigorously tested through business cases, funding approval, investment scrutiny, options work, and potential inclusion in long-term infrastructure plans. Strategic need has already been addressed as part of the investment conversation.
If the new system recognises that more clearly, that could be a genuine efficiency gain.
The Planning Bill also creates an important opportunity through Spatial Plans. If an indicative infrastructure corridor/location is identified in a Spatial Plan, and a later designation sits within that footprint, there will be less need to re-litigate strategic need and alternatives under RMA section 171(1)(b)-type arguments. For infrastructure providers and local authorities/CCO’s, that could save time, cost, and duplication. It should also reward those who have done good early strategic planning.
There is also an opportunity to achieve a designation through the Spatial Plan process.
This brings me to a crucial uncertainty: how does this actually work on the ground?
Designations are inherently site-specific. They affect particular land, particular owners, and particular communities. Spatial Plans, by contrast, are broader strategic tools. They are meant to look across regions, growth areas, infrastructure needs, environmental limits, and long-term development patterns.
So how do we bridge that gap?
An indicative infrastructure corridor in a Spatial Plan may be exactly the right tool for signalling long-term intent. It can help councils, infrastructure providers, developers, and communities understand where future infrastructure may be needed. For developers, this matters because indicative corridors can shape land values, acquisition strategies, staging, and confidence in growth areas.
But an indicative corridor is not the same thing as a designation.
At some point, the line on the map becomes real. It starts to affect expectations, investment decisions, property values, and relationships with landowners. That is where the detail matters.
My sense is that Spatial Plans may be best used to identify indicative corridors or areas, with the more detailed designation work confirmed later through a more granular planning instrument, such as Land Use Plans. That would better match the difference between strategic planning and site-specific route protection.
A similar transition is underway for Construction Project Plans, which are set to replace Outline Plans. If these new instruments are clear, robust, and well understood, they could reduce duplication and help keep designation conditions focused on the key decisions. If not, we may simply push difficult effects-management questions further down the track.
And route protection through designation is sometimes the easy part of a project. I’ve seen numerous examples where the really hard issues don’t arise until resource consents are sought further down the track.
One issue likely to emerge first – property blight.
If land is identified within an indicative corridor, owners may face a long period of uncertainty. Yet they may not have access to remedies such as the existing section 185 of the RMA, because those protections are generally triggered only once a formal Notice of Requirement for designation is in play. If the new system creates long-lived “quasi-designation” effects without equivalent protections, I would expect disputes — and probably litigation — to follow.
Of course, the Bill may change through the Select Committee process, so these comments are based on the version currently in front of us.
Stepping back, there is a real opportunity here.
The proposed framework could make route protection and designations faster, clearer, and better aligned with how infrastructure investment decisions are actually made.
Yet caution is needed here. If the interface between spatial plans and designations isn’t clearly defined, we may not be able to remove complexity from the system. We may simply create confusion and litigation.
To make the most of the proposed framework, I’d recommend that infrastructure providers, councils, developers, and project teams:
- Identify which future corridors or locations need to be protected.
- Assess where existing designations may need review, and
- Determine at what level of detail a Spatial Plan’s infrastructure corridor should begin to influence landowners, investment decisions, and project confidence.
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Contact Grant Eccles to discuss how the RMA reforms could impact your project and get expert guidance.
To hear more about the RMA Reforms, stay tuned for the next piece on Environmental Limits.
