On 16 October 2026, Property Council submitted to the Ministry for Cities, Environment, Regions and Transport (“MCERT”) on New Zealand’s New Planning System: Testing the approach to National Policy Direction (the illustrative NPD)
Why this matters to our members
The new Planning Act 2026 and Natural Environment Act 2026 require councils to develop planning instruments, including regional spatial plans and land use and environment plans. The illustrative NPD provides an early indication of Government’s planning system priorities and high-level directives to ensure planning instruments enable development and consistently manage conflicts between incompatible land uses.
Our view
Property Council supports the overall direction of the illustrative NPD. We support its emphasis on ensuring that planning instruments enable housing and development, new and existing infrastructure, economic growth, investment, competitive land markets and the protection of existing lawful activities. However, the success of the final NPD will depend on its quality as a practical decision-making instrument. It must provide sufficient clarity and direction to prevent strategic policy questions being reopened at the regional, local or consenting level.
At a high level, we recommend the following:
- recognise mitigation measures rather than defaulting to separation to manage reverse sensitivity effects in urban areas;
- recognise changing housing needs, and define key building height, density and intensification terms;
- establish tiers for categorising outstanding natural features (especially wetlands);
- define key terms relating to significant historic heritage to avoid unnecessary development constraints;
- align the NPD with the National Infrastructure Plan and expand the definition of infrastructure to include digital and natural hazard resilience infrastructure;
- enable development where natural hazard risks can be appropriately managed, unless residual risk is ‘very high’;
- recognise the role of natural features and ecosystems in hazard mitigation; and
- provide clear implementation guidance and monitor implementation of the NPD.