The Fast-track Approvals Act explicitly permits staging — lodging separate substantive applications for different phases of the same overall project. Most applicants do not realise this is available, and so default to one mega-application that takes longer, costs more, and concentrates risk.
Done well, staging is one of the single most powerful structural tools in the regime.
What staging is
Staging means:
- Project is conceived as a multi-phase masterplan (e.g. 3,000-home development with town centre, three retirement villages, retail, schools)
- Phase 1 (say, 800 homes plus enabling infrastructure) lodged as substantive application now
- Phase 2 and 3 follow as separate substantive applications, each tested against the benefit limbs and effects in their own right
- Each phase has its own expert panel decision, its own conditions, its own appeal window
Each phase still needs to clear the s.22 test on its own merits. You cannot lodge a sub-scale phase and rely on the full project's benefit case.
Why staging works
Three reasons it de-risks large projects.
1. Cash-flow alignment. A 3,000-home masterplan over 10 years does not need every consent on day one. Lodging in stages aligns EPA cost recovery and specialist fees with the actual build pipeline. We have seen project-management costs reduce 30–40% under staged approaches.
2. Iterative learning. Conditions imposed on phase 1 inform the design of phase 2. Lessons from panel scrutiny improve subsequent applications. The first stage becomes the template — every subsequent stage runs faster.
3. Risk concentration. A single mega-application puts every benefit limb, every workstream, every politically sensitive component into one decision. Staging spreads the risk. If phase 2 hits an opposition surge, phase 1 has already cleared and is under construction.
Where staging does not work
Three cases where one mega-application is better.
Critical-mass benefit cases. If the project's benefit case depends on total scale (e.g. a 200 MW wind farm where 50 MW would not clear the threshold), staging undercuts the benefit limb. Lodge whole.
Designation-dependent infrastructure. Roads of National Significance, three-waters mains, transmission — where the corridor must be approved as a single integrated package. Cannot be staged without compromising the engineering case.
Cumulative effects across phases. Where adverse effects of later phases compound effects of earlier phases (e.g. ecological corridor fragmentation), the panel will require a cumulative-effects assessment anyway. Staging adds work without saving risk.
How to structure a staged lodgement
In practice, we usually scope it like this.
Stage 1 strategy — typically the highest-confidence, lowest-opposition phase. Build the panel relationship and conditions framework. Use this stage to test ambiguous workstreams (cultural, ecology) where conditions can guide later stages.
Stage 2 strategy — drives the bulk of the masterplan delivery. References stage 1 outcomes explicitly. Often the largest in scale.
Stage 3 strategy — final completion phases. Frequently includes the most politically sensitive components (mixed-use, density variation, retirement). By this point, the panel relationship is mature.
Timeline-wise: stage 1 lodgement at month 9, stage 2 at month 18, stage 3 at month 30 is a realistic shape for a major masterplan. Total project duration 5–7 years from feasibility to last stage decision.
A note on the panel
A common worry: "won't a different panel for each stage cause inconsistency?" In practice, the EPA tries to maintain panel continuity across staged applications where possible. Not guaranteed, but a real consideration in panel composition.
What we do with this
For any large project we engage on, the second deliverable of our pre-engagement is a staging assessment. We map the masterplan against the s.22 limbs at each potential phase boundary and recommend a staging shape. Applicants who arrive having already decided to lodge as one application have often left value on the table.