Local GovernmentFuture
Insights/Skills

The RMA's 46 percent estimate is not a council workforce forecast

Officials estimate that up to 46 percent of consent and permit applications could no longer be required under the RMA's replacement. It is a national estimate of applications, made before the settings are final. No council should change its consenting establishment on the strength of that figure alone.

DMDrew McGuireDirector, LG Future
September 20266 minute read
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The Planning Bill and the Natural Environment Bill were introduced on 9 December 2025, reported back by the select committee on 20 July 2026, and the Government aims to pass them this year. Officials estimate that up to 46 percent of consent and permit applications required under the current Act could be removed under the new system, between 15,000 and 22,000 a year on 2023/24 volumes. More than 100 plans are to become 17 regional combined plans. A Planning Tribunal is expected in mid 2027. National direction is expected within nine months of enactment, with further standards through 2027. Applications lodged before the transition remain under the current Act.

The 46 percent figure is likely to appear in council budget and workforce discussions over the next year, so a decision rule is worth stating at the start: do not use it to set local staffing. The estimate covers applications across the country that might no longer be required, and it was produced before the legislation was final and before national direction had been issued. It does not say which applications, in which councils, or how much staff effort those applications take today. A local result will depend on the council's current application mix, the enacted legislation, national direction, the regional combined plan and the functions the council performs. Local mapping will give a council a better estimate than the national figure. It will not remove the uncertainty while the settings and demand remain unsettled.

What the count leaves out

Consenting effort does not move in proportion to application numbers. A share of a planning team's time goes into work that is not an application at all: pre-application advice, duty planner enquiries, requests for further information, hearings and appeals, engineering and specialist referrals, site visits, legal review, quality assurance and the handling of incomplete applications. Changes in application numbers may reduce some of that work while leaving other parts unchanged. Whether the new system changes monitoring and compliance obligations for activities that no longer need consent is a question for the final legislation and national direction, and it should not be assumed in either direction.

The applications that remain are not a random sample either. Complex applications could represent a larger share of effort than of volume, and the specialist input they need does not scale down with the count. Capacity in a consenting team is often limited by a small number of specialists and by peaks in demand rather than by the total number of files. During the transition, a council may be administering applications lodged under the current Act alongside applications made under the replacement legislation, for a period the transition provisions will set. Plan-making work on the regional combined plan arrives on its own timetable, and each council's contribution to it will be settled region by region.

Estimate the local work first

Start by estimating the council's own work without applying the national percentage. The first question is whether existing consent data can identify the application types the bills and draft national direction propose to remove or change. Where it can, set those types against two or three years of the council's own volumes. Where it cannot, clean or sample the records before modelling anything. Use the 46 percent figure only to check the order of magnitude of the result.

The same mapping covers the work that stays and the work that changes: the complex applications that remain consentable, the transition caseload, the council's expected role in the combined plan, and any new obligations the final settings create. Scenarios are then built around changes in the work, with volume as one variable among several: activity type, complexity, specialist requirements, transition timing, plan-making responsibilities and demand peaks. Each scenario carries its assumptions and a confidence range, and each is updated as the legislation and national direction are confirmed.

Effort data that can bear weight

Consent systems record what the statute requires. Whether yours also records staff effort per application, rework, specialist input and the work outside applications is an audit question, and the answer is often partly. Elapsed time does not show how much time staff spent on an application. Start with the data already available. Where it is weak, sample enough files to estimate effort by major application type and complexity, and include contractor and specialist work. Use staff workshops to identify the work the systems miss, such as informal advice, interruptions and workarounds, and to test the interpretation. Do not build a data exercise larger than the decision requires.

What a published consents case shows

LSI Consulting's published redesign of consent processing for a rapidly growing urban council reports an 87 percent increase in applications processed on time, a 50 percent reduction in processing sent to outside contractors, and 10 percent more technical staff time available for specialist work, following changes to stage mapping, time standards, front end vetting, prioritisation, workload management and service level agreements. The case provides no evidence about what RMA reform will do. It does show timeliness, outsourcing and specialist capacity in a consenting team changing substantially after a workflow redesign, which is why councils should test workflow performance and the use of specialist time before treating application volume as a staffing ratio.

Use the national figure to check the order of magnitude. Calculate the local number by mapping the proposed changes against your own register and your own effort data.

Drew McGuire, Director

Fewer applications, not necessarily less capability

Resource consenting, policy planning, environmental monitoring, and compliance and enforcement share some knowledge, but the roles and delegations are not interchangeable, and experience in one area does not by itself show that someone can perform another role. Fewer applications do not automatically reduce demand for planning, monitoring, compliance or specialist capability. Once the settings are clearer, councils will need to assess the skills required to interpret national standards and know where local provisions are allowed, to contribute to a combined regional plan across council boundaries, to design any monitoring the new standards require, and to manage a transition caseload under two regimes. Any proposed change to roles then follows the council's employment agreements, change process and good faith obligations, with the scenarios there to inform it.

What to do now, and what to do later

Now: check the quality of your consent data, establish a baseline of effort by major work type, including the work outside applications, and identify the specialist skills each scenario shows as scarce. Prepare options for retraining, redeployment, shared arrangements with neighbouring councils and contractor use, with costs and lead times.

Once the legislation and initial national direction are confirmed: map the affected activities against your register and update the workforce scenarios. Do not make a permanent establishment change solely from the 46 percent estimate. If a decision cannot wait, separate the evidence already known from the assumptions that depend on the final settings, and make the decision on the first.

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