Submissions

Te Waihanga regularly makes submissions on consultations that relate to infrastructure policy.

Submission on the Sharing the cost of Drury’s growth – Contributions Policy 2022 variation A

Te Waihanga has submitted on Auckland Council’s proposal Sharing the Cost of Drury’s Growth – Contributions Policy 2022 Variation A. Our submission is that the development contributions work for Drury is a significant step forward for understanding the infrastructure costs associated with urban growth. The use of development contributions as an instrument to reflect infrastructure costs across space is broadly consistent with Rautaki Hanganga o Aotearoa, the New Zealand Infrastructure Strategy, specifically, the need for cost reflective pricing (page 126). However, the proposed variation raises a number of issues which will be important to resolve to ensure the intended outcomes. Our submission sets out several suggestions for consideration, based on our review of the various consultation documents, and our findings and consultation during the development of the Strategy.

Submission on the National Direction for Plantation and Exotic Carbon Afforestation

Te Waihanga has submitted on the Ministry for the Environment and Ministry for Primary Industries discussion paper “National direction for plantation and exotic carbon afforestation”. Our submission is that, in specifying the location of afforested areas and ancillary activities regulated under the Resource Management (National Environmental Standards for Plantation Forestry) Regulations 2017 (NES-PF), a set back from existing or planned infrastructure should also be included as a condition or consideration.


This issue is not adequately addressed in the current NES-PF and it is not raised in the Discussion Paper. In our view, setbacks from infrastructure should be addressed in any amendments to the NES-PF as they raise difficulties for infrastructure now, and will do so even more in the future. If exotic carbon forests and transitional forests are regulated through the NES-PF2, increasing the total area of afforested land, this could exacerbate impacts on infrastructure.

Submission on Auckland Council's Plan Change 78: Intensification

Te Waihanga has submitted on Auckland Council's Plan Change 78: Intensification. Te Waihanga has significant concerns about the management of infrastructure constraints through regulatory instruments, including the potential for unintended consequences as well as the precedent this may set for others in the local government sector.

Submission on the application of NES-F to the coastal marine area (CMA)

Te Waihanga has sumitted on the Ministry for the Environment’s (MfE) discussion document on the application of the NES-F to the coastal marine area (CMA). Te Waihanga’s submission is that the NES-F should not apply to the CMA. In that respect, we agree with MfE’s preferred option 2: amend the NES-F so its wetland provisions do not apply to the CMA. This amendment will provide greater clarity to NES-F users that the NES-F does not apply to wetlands in the CMA.

Submission on the National Policy Statement for Indigenous Biodiversity

Te Waihanga has sumitted on the National Policy Statement for Indigenous Biodiversity ('NBS-IB'). Te Waihanga generally supports the development of the NBS-IB to protect New Zealand’s indigenous biodiversity insofar as it provides a consistent framework for identifying areas of significant indigenous biodiversity and requires councils to consistently apply that framework to protect, maintain and enhance biodiversity (subject to appropriate changes being made to recognise the importance of infrastructure). However, Te Waihanga strongly opposes both the timing and content of the NPS-IB for the reasons detailed in our submission.

Submission on Water Service Entities Bill

Te Waihanga has sumitted on the Water Services Entities Bill. Te Waihanga supports the purpose of the Bill to improve the safety, quality, resilience, accessibility, and performance of three waters services. However, there are some aspects of the government’s proposal we believe merit further consideration. These can be classed as General and Bill-specific issues and are detailed in our submission.

Submission on exposure drafts of NPS-Freshwater Management and NES-Freshwater amendments

Te Waihanga has sumitted on the Ministry for the Environment exposure drafts of NPS-Freshwater Management, and NES-Freshwater amendments as part of the ‘Managing our wetlands’ workstream. Te Waihanga is concerned that the 2020 freshwater package currently has the effect of prohibiting, or restricting (i.e. making a non-complying activity, in respect of earthworks that result in complete or partial drainage of a wetland) a number of activities in or near natural wetlands. Among other things, this has the potential to be inappropriately disenabling where it affects infrastructure that needs to be located in such environments for practical or operational reasons.

Submission on the Regulatory Systems (Transport) Amendment Bill

Te Waihanga has sumitted on the Ministry of Transport’s consultation on the Regulatory Systems (Transport) Amendment Bill. Our submission relates to Proposal 2.1: Remove Road Controlling Authorities’ restrictions on cost recovery for residents parking.

Submission on Te panoni i te hangarua Transforming recycling Consultation document

Te Waihanga has sumitted on the Ministry for the Environment’s consultation document Te panoni i te hangarua. The submission was made on 20 May 2022 and makes a range of comments and recommendations. Moving towards a more circular economy is important for achieving a low-emissions and climate resilient future for Aotearoa. The proposals outlined in Te panoni i te hangarua are well aligned with Rautaki Hanganga o Aotearoa, the New Zealand Infrastructure Strategy 2022 – 2052 and partially give effect to five of the nine waste-related recommendations in the Strategy. While we are supportive of the desired outcomes of the proposals, we believe that the proposed approaches to collecting a standard set of materials and separation of business food waste should be revised to be more effective and efficient.

Submission on three waters economic regulation and consumer protection discussion paper

Te Waihanga has made a submission to the Ministry of Business, Innovation & Employment on their Economic Regulation and Consumer Protection for Three Waters Services in New Zealand discussion paper. The submission was made on 20 December 2021 and makes a range of comments and recommendations. Te Waihanga supports economic and consumer protection regulation of the proposed Water Services Entities. The Water Services Entities will be natural monopolies. This creates a risk of excessive prices, restricted volumes, poor quality, and lack of innovation.

Submission on the Resource Management (Enabling Housing Supply and Other Matters) Amendment Bill

Te Waihanga made a submission to Parliament's Environment Select Committee on the Resource Management (Enabling Housing Supply and Other Matters) Amendment Bill on 16 November 2021. The submission supports the intent of the reform to increase housing development in places with good transport access to employment and makes recommendations around managing the infrastructure impacts arising from such growth in housing.

Submission to the Ministry for the Environment on 'Managing our wetlands' discussion document

Te Waihanga has made a submission to the Ministry for the Environment on their Managing our wetlands discussion document. The submission was made on 27 October 2021 and makes a range of comments and recommendations. These include allowing for a broader range of infrastructure to be included in the proposed infrastructure consenting pathway.

Submission to Otago Regional Council on Proposed Otago Regional Policy Statement

Te Waihanga has made a submission to Otago Regional Council on the Proposed Otago Regional Policy Statement. The submission was made on Friday 3 September 2021 and encourages the Council to consider the statement's impact on the provision of infrastructure and housing.

Submission to Commerce Commission on the Market study into the grocery sector

Te Waihanga has made submission on 26 August 2021 to the Commerce Commission on the draft Market study into the grocery sector. The Commerce Commission study sets out the preliminary findings about how competition is functioning in the sector. The submission focuses on aspects of the draft Market study that relate to our He Tūāpapa ki te Ora, Infrastructure for a Better Future consultation document, including the role of the planning system and the role of freight and supply chains.

Submission to Environment Select Committee on the Natural and Built Environments Bill

Te Waihanga has made a submission to the Environment Select Committee on the Natural and Built Environments Bill. The Bill is the proposed legislation that will replace the Resource Management Act 1991. The submission was made on 4 August 2021 and covers a wide range of consenting and planning matters, such as the Purpose section of the new Bill, the role of national direction that councils are required to follow, the form and function of spatial and district planning and other permissions like designations.

Submission to Ministry of Transport on Hīkina te Kohupara discussion document

Te Waihanga has made a submission on the Ministry of Transport's Hīkina te Kohupara discussion document, which sets out potential paths to net-zero carbon emissions in the transport sector. The submission was made on 25 June 2021 and acknowledges that achieving the required emissions reduction pathways will need large changes to how we travel, what vehicles we use, and how we move freight. All of these pathways have significant infrastructure implications.

Submission to Transport and Infrastructure Committee on Auckland Congestion Pricing

Te Waihanga provided a submission to the Transport and Infrastructure Committee on the inquiry into congestion pricing in Auckland. The submission was made on 20 May 2021 and is an important question for the future sustainability of Auckland’s and New Zealand’s transport system.

Submission on Climate Change Commission’s 2021 Draft Advice

Te Waihanga made a submission on He Pou a Rangi, the Climate Change Commission’s 2021 Draft Advice. We acknowledge the impacts climate change will have on infrastructure. We also acknowledge the role of infrastructure in meeting New Zealand’s carbon emission goals and discuss what the draft advice could mean for our infrastructure. This includes the potential for non-built mechanisms such as making better use of the infrastructure we have to reduce New Zealand’s emissions.

COVID-19 Recovery (Fast-track Consenting) Bill (19 June 2020)

Te Waihanga supports the COVID-19 Recovery (Fast-track Consenting) Bill moving to a second reading in the House of Representatives. We believe the measures in the legislation represent a reasonable trade-off between good process and speedy implementation of projects, which can assist in recovery and boost employment. 

Our submission suggests the Government consider introducing a more enduring solution to fast-track projects in future emergencies and ‘call-in’ large and complex projects of national significance. Te Waihanga also encourages a future focus on addressing the uncertainty created for the delivery of infrastructure projects by aspects of the Resource Management Act 1991.

Draft Government Policy Statement on Land Transport 2021 (11 May 2020)

Te Waihanga made a submission on the draft GPS 2021 as this represents a substantial investment by the Government in the planning and delivery of land transport infrastructure and services. We also made a submission on the draft NZ Rail Plan due to the significant changes proposed to how rail is planned, funded and delivered. Both instruments will have a considerable impact on how the land transport network improves wellbeing for New Zealanders.

Infrastructure Funding and Finance Bill (4 March 2020)

The Infrastructure Funding and Finance (IFF) Bill aims to support the provision of infrastructure for housing and urban development. The proposed IFF model involves creating special purpose vehicles to finance and construct infrastructure for urban growth. The finance is repaid from a levy on the beneficiaries of the infrastructure. As the guardian of the New Zealand PPP model(external link), Te Waihanga has specialist expertise in project finance. Our submission largely relates to the implementation of the IFF model, drawing from our experience and knowledge gained from working with the New Zealand PPP model and with the procurement and delivery of major infrastructure projects.

Urban Development Bill (14 February 2020)

Te Waihanga made a submission on the Urban Development Bill because urban development has a critical and long-term impact on the social, economic, environmental and cultural wellbeing of people living in New Zealand’s cities. While we support this bill as a positive step to work around problems with New Zealand’s governance, planning, funding and delivery system, we make some suggestions for wider reform.

Resource Management Reform Bill (7 February 2020)

Te Waihanga welcomes this review, which proposes amendments to the Resource Management Act, the Local Government Act, and to the Land Transport Management Act. The key themes we focus on in our submission are:

  • outcomes-focused environmental planning system
  • integrated decision-making
  • the case for institutional reform
  • coordination of various government initiatives.