Consent -- Options and Evidence Documentation

Status

BLOCKED

Planning consultant not yet engaged. Options analysis cannot be finalised until the consultant confirms the activity classification and the realistic notification risk.

---

Consent Pathway Options

There are two realistic pathways for the resource consent application. A third option (continuing without consent indefinitely) is not a viable long-term position and is not presented here.

---

Option A: Non-Notified Discretionary Application (Target)

What it is: A resource consent application that is processed on the papers without public submissions. Neighbours are not notified. Only the applicant and council are involved.

Why it is the target: Non-notification is faster (statutory 20 working days from lodgement), cheaper (no hearing costs), and eliminates the risk of neighbour objections derailing the application. It requires demonstrating that adverse effects on the environment will be minor or less, and that no neighbouring landowner is an affected person under s95E RMA.

What it needs:

• 5--6 months of documented operational evidence before lodgement
• Pin pad access log showing 3--5 vehicle movements per day on average
• Monthly photographs demonstrating no visibility from Te Waerenga Road and no commercial signage
• Farm diary and other records demonstrating 40%+ agricultural use
• Neighbour support letters from adjacent landowners (the strongest single factor)
• A strong AEE from a licensed planning consultant arguing minor effects
• No prior enforcement action from Rotorua Lakes Council

Likelihood: Moderate to good, subject to carefully managing the pre-application period. Requires the physical address to remain out of public advertising until after lodgement.

---

Option B: Limited Notification Application (Fallback)

What it is: A resource consent application where council notifies only specific affected landowners (typically one or two adjacent neighbours) rather than the general public.

When it applies: If the planning consultant's affected persons assessment identifies one or two neighbouring landowners who may be affected (e.g., they can see the shed or have a driveway close to the access route), council may require limited notification to those specific parties even if the general public is not notified.

What it means in practice:

• Those neighbours receive a copy of the application and have 20 working days to submit
• A hearing may or may not be held depending on whether submissions are received
• Timeline extends by 2--3 months over Option A
• Cost increases by $2,000--$5,000 (hearing preparation, possible specialist appearances)
• A neighbour who is already supportive (support letter obtained) is much less likely to submit against the application

Mitigation: Pre-application outreach to immediately adjacent neighbours -- ideally obtaining written support letters before lodgement -- reduces the practical risk of a limited notification turning into contested hearings.

---

Evidence Documentation Requirements

This section records what evidence must be collected, in what format, and by when. The application target is October/November 2026. Evidence collection must start now and cannot be backfilled.

---

Evidence Summary

---

Monthly Site Photographs

Must begin at the Easter 2026 site visit. Record from five fixed reference points. For each point: note GPS coordinates and compass bearing in a reference file so the same angle is reproduced every month.

File naming: YYYY-MM-DD_point-[letter]-[brief-label].jpg

Example: 2026-04-15_point-a_road-toward-shed.jpg

EXIF date/time must be accurate. Do not apply filters or crop heavily. Store in a shared folder accessible to Ed and Tom, organised by year and month.

Note: autumn and winter photographs (April--August 2026) are valuable because they show the site without summer vegetation masking any gaps in screening. Start in April.

---

Access Control Log (CSV)

This is the single most important ongoing evidence item. It provides the quantitative basis for the traffic assessment -- the primary argument for non-notification.

Required CSV format:

Date,Time,Bay_Number,Vehicle_Type,Customer_Reference
2026-06-01,08:32,B04,Boat_on_trailer,C-017
2026-06-01,14:15,B11,Caravan,C-004

Field specifications:

• Date: YYYY-MM-DD
• Time: HH:MM (24-hour)
• Bay_Number: alphanumeric consistent with site plan bay numbering (e.g. B01, B02)
• Vehicle_Type: one of Car, Car_with_trailer, Boat_on_trailer, Caravan, Motorhome, Unknown
• Customer_Reference: internal customer ID only -- never a customer name in the exported log

The export must cover the entire period from the first access event to the application lodgement date. Confirm with Tom at the Easter 2026 visit that the pin pad system logs access events with timestamps and can export in CSV format. If it cannot, a logging-capable system must be sourced before Phase 1 launch.

---

Farm Diary / Agricultural Use Records

Begin the first entry at the Easter 2026 site visit. Monthly entries recording: paddock condition, mowing or grazing activity, livestock movements if any, fencing or pasture work. If the land is under a grazing lease to a neighbouring farmer, retain the lease and records of activity. One page per month is sufficient.

The planning consultant must be asked at engagement: what does Rotorua Lakes Council consider sufficient "agricultural use" for Rural Zone purposes? Does a grazing lease to a third party qualify?

---

Customer Occupancy Month-End Snapshot

At the last day of each month from Phase 1 launch: number of bays occupied, bay number, lease start date, and vehicle type per bay. No customer names in this record. Retained in a spreadsheet or within the management platform when available.

---

Easter 2026 Site Visit Priority Checklist

The Easter 2026 visit (April 2026) is the first opportunity to start evidence collection. These tasks cannot be done remotely or backfilled.

• Take first monthly reference-point photographs at all five points
• Record GPS coordinates and compass bearing for each reference point
• Write the first farm diary entry (paddock condition, agricultural use estimate, fencing)
• Confirm pin pad make and model (photograph the unit label)
• Confirm whether the pin pad logs access events with timestamps
• Confirm whether logs can be exported and in what format
• Take site measurements for the future surveyor brief (shed dimensions, pad extent, driveway width, distance to road and nearest neighbouring structure)
• Note whether the shed or stored vehicles are visible from Te Waerenga Road
• Note whether any neighbouring dwellings are visible from the storage area
• Note condition of any screening vegetation between the shed and the road or neighbours

---

Documentation Timeline

---

Document Format Requirements

---

Blocked By

Consent plan blocked by planning consultant not yet engaged (open item, target engagement August 2026). Evidence collection activities listed above do not depend on the consultant and must proceed now.

Consent -- Legal and Compliance Interactions

Status

BLOCKED

Planning consultant not yet engaged. Compound requirements from this document are known and actionable, but the consent plan itself cannot be finalised until the consultant confirms the activity classification.

---

Purpose of This Page

This page records how planning and environmental requirements interact with other regulatory domains that affect the Max Storage operation. These are not planning requirements in isolation -- they are the compound effects that arise when planning overlaps with health and safety, privacy, the customer contract, and environmental obligations.

---

Key Compound Requirements Affecting Consent

CCTV and Privacy -- Retention for Consent Evidence

Privacy law (Privacy Act 2020, IPP 9) requires that personal information -- including CCTV footage -- is not retained longer than necessary for the purpose collected. General security surveillance does not justify indefinite retention; 31 days is a commonly cited benchmark.

However, CCTV footage that shows the pattern of operations (vehicle types, access frequency, absence of commercial signage) is useful evidence for the resource consent application. The planning requirements support 90-day retention to capture activity patterns over time.

Compound position: 90-day retention is adopted. It exceeds the insurer minimum (28--31 days), serves the consent evidence purpose, and is defensible under IPP 9 because the consent evidence purpose is stated in the privacy notice.

Action required before cameras go live: The customer privacy notice must explicitly state "resource consent compliance" as a purpose for which access logs and CCTV footage may be retained and used. Without this, relying on footage for consent evidence after the standard security window closes is harder to justify. This must be drafted before the first customer signs up.

---

Access Logs -- Shared with Council

Access control log data (pin pad records) will form part of the traffic assessment submitted with the resource consent application. Sharing this data with Rotorua Lakes Council is permissible under the Privacy Act only if the purpose was disclosed to customers at sign-up.

Action required: The customer privacy notice must list "Rotorua Lakes Council, for the purpose of a resource consent application" as a permitted recipient of access log data.

---

Customer Contract -- Consent Strategy Alignment

The customer contract must describe the storage activity in terms consistent with the consent strategy during Phase 1. The resource consent strategy frames the activity as incidental to agricultural use of a rural property. If the contract uses the language of commercial self-storage (storage units, mini storage, commercial facility) this creates a tension with the agricultural framing in the AEE.

The planning consultant should be given a copy of the customer contract draft before the AEE is finalised to confirm the activity description is consistent. After consent is granted, the contract can be updated to reference the resource consent number and conditions.

---

Physical Address -- Marketing Constraint

The physical address Te Waerenga Road, Hamurana must not appear in any public advertisement, directory listing, Google My Business profile, website, or social media until resource consent is granted. This is the most direct planning constraint on operations before consent.

The enforcement risk is that the address appearing publicly could alert neighbours or Rotorua Lakes Council to the commercial activity before the consent application is lodged. The realistic risk chain is: online listing identified by neighbour, complaint to council, abatement notice requiring cessation, consent application undermined by enforcement record.

What is permitted before consent:

• Word-of-mouth referrals to trusted contacts
• Direct-approach marketing to specific individuals
• An online presence that does not identify the location by address or suburb

What is not permitted before consent:

• Any public listing identifying Te Waerenga Road or Hamurana as the location
• Commercial signage at the property visible from Te Waerenga Road or neighbouring properties
• Claims about security features that are not yet installed and operational (FTA s12A requires reasonable grounds for representations)

---

Fire Access Path -- Contract Obligation

The 4.0m FENZ fire access path from the gate to the shed must remain clear of stored vehicles and items at all times. This is a Building Code requirement (C/AS5) and an HSWA s37 obligation. It must also be written into the customer storage agreement so that customers are contractually prohibited from obstructing the access route.

For the resource consent application, the operational controls statement within the AEE should reference the fire access path as a managed constraint -- demonstrating that the unattended facility has physical and contractual controls in place.

---

Spill Response -- Three Domains, One Obligation

Environmental law (RMA s15, s17), health and safety law (HSWA s36), and HSNO obligations all converge on a single spill response requirement. The operator must have:

1. A hydrocarbon spill kit on-site before Phase 1 launch (minimum content: absorbent granules, pads, containment booms, disposal bags, cones, laminated instruction card).
2. A written spill response procedure covering petrol and LPG incidents.
3. A spill register recording incidents, responses, and notifications.

Reporting: Any spill reaching a drain or water body must be reported to BOPRC (0800 884 880). Any incident creating a serious risk to persons must be reported to WorkSafe (0800 030 040).

The resource consent application AEE should reference the spill response procedure and kit as an existing operational control. Proactively having these in place before lodgement demonstrates responsible management and reduces the risk of onerous environmental conditions being imposed.

---

Prohibited Items -- Contract, Fire, and HSNO

The prohibited items list that must appear in the customer contract is simultaneously:

• A PCBU risk control under HSWA (reasonably practicable hazard elimination)
• An HSNO compliance measure for hazardous substances
• A fire risk mitigation for the building
• An exclusion clause in the contract

For the resource consent application, the AEE's operational controls statement should reference the prohibited items policy as a management measure that reduces the risk of hazardous goods on-site. This is relevant to the stormwater and contamination conditions that council is likely to impose.

Core prohibitions relevant to consent and environmental obligations:

• Portable petrol containers stored separately from a vehicle's built-in tank
• Agricultural chemicals, pesticides, herbicides (Class 6.1/9 HSNO -- severe risk in Lake Rotorua catchment)
• Pool chemicals and oxidisers (react with fuel; fire escalation risk)
• Unlabelled chemicals or substances in non-original containers

These prohibitions are relevant to both the HSNO compliance framework and to the environmental conditions that BOPRC may require in any resource consent for commercial outdoor storage.

---

Location Compliance Certificate -- Pre-Opening Requirement

Before Phase 1 launch, Max Storage must commission a one-time assessment by a WorkSafe-registered compliance certifier to confirm whether the aggregate petrol likely to be on-site from boats stored with fuel in their tanks exceeds the 50-litre Location Compliance Certificate threshold under the HSNO/HSW(HS) Regulations 2017.

If the threshold is exceeded, the certificate must be obtained before customers store boats. This is a pre-opening legal requirement, not a Phase 2 matter.

For the resource consent application, evidence that a Location Compliance Certificate has been obtained (if required) demonstrates responsible HSNO management and supports the operational controls narrative in the AEE.

Cost estimate: $300--$600 for the compliance certifier assessment.

---

What This Leaves Open for Ed

The following judgement calls affect both the consent strategy and related compliance areas. Tier 3 agents and the planning consultant need these decisions before they can complete their work.

1. Location Compliance Certificate -- act now or wait?

Commissioning the assessment before Phase 1 launch is the conservative position. Proceeding without it when petrol quantities from stored boats may be at or near the threshold is a WorkSafe enforcement risk. Decision needed before first customers go live.

2. Marketing approach for Phase 1 -- pure word-of-mouth or website without address?

Pure word-of-mouth (safest from a planning perspective) or a website / online listing that describes the facility without identifying the location? The research-market agent cannot recommend a Phase 1 marketing approach without this decision.

3. Direct debit or manual invoicing?

This determines whether the minimum fee-increase notice period in the customer contract is 14 days or 30 days (BECS scheme rules require 30 days if direct debit is used). The contract must get this right from the outset.

4. Solicitor review of contract -- before or after draft agent produces the draft?

Four areas require professional legal review: minimum notice period before lien sale; entry without consent on suspected prohibited goods; CGA-compliant liability clause for consumer customers; PPSR registration. Engaging a solicitor before the draft is produced is more efficient.

---

Consultant Questions (Consent-Specific)

The following must be asked at the first meeting with the planning consultant in August 2026:

1. Is commercial vehicle/boat/caravan storage in the Rotorua Rural Zone a discretionary or non-complying activity under the current operative District Plan? Identify the specific rule reference.
2. Is non-notification realistic given the traffic profile and agricultural use evidence assembled? Which neighbouring landowners are likely affected persons under s95E RMA?
3. Is a standalone traffic engineering report required, or can traffic be addressed within the AEE?
4. Is a standalone acoustic report required, or can noise be addressed briefly within the AEE?
5. What does Rotorua Lakes Council consider sufficient evidence for 40% agricultural use in a Rural Zone application?
6. Is a pre-application meeting with Rotorua Lakes Council advisable before lodgement?
7. Confirm scale and content requirements for the site plan before commissioning the surveyor.
8. Are there any current or proposed plan changes that could affect Rural Zone rules before October/November 2026?
9. What is the typical consent duration for rural commercial storage in the Bay of Plenty / Rotorua region?
10. Does the activity description in the Phase 1 customer contracts create any planning law complications?

---

Blocked By

Consent plan blocked by planning consultant not yet engaged (open item, target August 2026). The actions listed above that do not require the consultant -- evidence collection, certificate of title retrieval, BOPRC enquiries, spill kit, privacy notice drafting -- should proceed on their own timelines independently of the consultant engagement.

Consent -- Planning and Environmental Requirements

Status

BLOCKED

Planning consultant not yet engaged. The consent plan cannot be finalised until the consultant confirms the activity classification, scale thresholds, and affected persons assessment from the operative Rotorua District Plan.

---

Planning Framework

Governing legislation

The Resource Management Act 1991 (RMA) governs the consent application. The Natural and Built Environment Act 2023 and Spatial Planning Act 2023 were repealed and the RMA reinstated (with amendments) in late 2023/early 2024. The Fast-track Approvals Act 2024 is not relevant to this site -- it applies only to nationally significant projects.

Rotorua District Plan status

The operative Rotorua District Plan continues in force under the RMA. No new combined plan is being prepared following the repeal of the NBA/SPA. A plan change or review may be underway -- the planning consultant must confirm whether any proposed changes affect Rural Zone commercial storage activity provisions before the application is lodged in October/November 2026.

---

Activity Classification

The site at Te Waerenga Road, Hamurana sits in the Rural Zone under the Rotorua District Plan. Commercial vehicle, boat, and caravan storage operated for paying customers is not a primary production activity and is not listed as a permitted use in the Rural Zone.

Working assessment: Commercial storage is most likely a discretionary activity under the Rotorua Rural Zone. This is the standard classification in Bay of Plenty district plans for commercial activities not specifically anticipated by rural zone provisions. A discretionary classification means council has full discretion to grant or decline consent, and conditions will be attached.

It could also be non-complying if the District Plan contains a specific trigger for commercial activities conflicting with rural character objectives. Non-complying carries a higher statutory test under s104D(1) RMA.

The specific rule reference must be confirmed by the planning consultant against the operative District Plan. The District Plan portal was not accessible during desk research (403 errors), so the exact rule number is not confirmed.

Scale factors that influence classification:

---

What the Consent Application Must Include

Assessment of Environmental Effects (AEE)

The core document, prepared by a licensed planning consultant. Must address: description of the activity; description of the environment; assessment of effects on traffic, noise, visual amenity, stormwater, and rural character; proposed methods to avoid or mitigate adverse effects; and an affected persons assessment. Must argue against notification.

Site plan (to scale)

A surveyed site plan showing: legal boundaries, shed footprint and bay layout, vehicle circulation, driveway connection to Te Waerenga Road, gate location, vegetation and screening, and the area in agricultural use (dimensioned). Must be prepared by a licensed cadastral surveyor or drafter. Commission August 2026 -- this is the longest-lead item and gates the AEE.

Certificate of title

Current LINZ computer register for the property. Obtainable online -- retrieve now (April 2026). No reason to delay.

Landowner authorisation

Letter from Douglas Enterprises Ltd (landowner) authorising Max Storage Ltd (operator/applicant) to apply for consent over the land. One page. Prepare October 2026 when the AEE is near-final.

Traffic assessment

Evidence of actual vehicle movements from the access control log export: daily totals, vehicle types, time-of-day distribution, Te Waerenga Road access conditions. Confirm at the pre-application meeting whether a standalone traffic engineering report is required -- for a low-traffic rural operation it is likely not.

Visual and landscape effects assessment

Assessment of visual impact from Te Waerenga Road and neighbouring properties, supported by the monthly photograph archive. Existing vegetation screening, absence of commercial signage, rural character of the site.

Photographs

Date-stamped monthly photographs from five fixed reference points. Cannot be backfilled -- the archive must start at the Easter 2026 site visit (April 2026).

Agricultural use evidence

Farm diary and stock or grazing records demonstrating that 40% or more of the total site area remains in active agricultural use throughout the evidence period.

Operational controls statement

Formal description of unattended operation, pin pad access, CCTV, no commercial signage, hours of access, and how after-hours restrictions would be enforced. Planning consultant drafts this as part of the AEE.

Neighbour consultation evidence

Record of any pre-lodgement consultation and responses. If not undertaken, the AEE must explain why no neighbouring landowners are affected persons under s95E RMA.

---

Non-Notification Assessment

Factors supporting non-notification:

• Low daily traffic volumes -- a 15--20 bay facility at this access frequency generates 5--15 movements per day at most
• No new buildings or structural changes
• Rural lifestyle block with low-density neighbouring properties
• Existing pin pad gate controlling access (managed, not open, facility)
• Screening by existing vegetation between the shed and road/neighbours
• No commercial signage visible from Te Waerenga Road
• Agricultural use maintained at 40%+
• No complaints or enforcement notices in the evidence period
• Neighbour support letters from adjacent landowners

Factors working against non-notification:

• Operating without consent before application: if enforcement action has been taken, council may be less sympathetic
• Commercial signage at the property: would undermine rural character arguments
• Online advertising identifying the physical address before consent
• High traffic generation or visible activity from the road

Likelihood: Moderate to good, dependent on managing the pre-application period carefully. A pre-application meeting with Rotorua Lakes Council (August/September 2026) is essential.

---

Likely Consent Conditions

Based on standard conditions imposed by New Zealand councils on rural commercial storage consents:

• Hours of operation: Expected 7:00 am -- 9:00 pm or similar. The pin pad system must be configured to enforce consented hours.
• Vehicle movements: A daily maximum movement count may be imposed. Access logs must be retained and available for council inspection.
• Screening: Maintenance of existing vegetation; possible requirement to plant additional screening.
• Signage: Commercial signage visible from Te Waerenga Road almost certainly prohibited or restricted to one small identification sign at the gate.
• Storage type: May be restricted to private vehicles, boats on trailers, and caravans (no commercial vehicles, no hazardous materials).
• Agricultural use: A minimum proportion of the property (e.g. 40%) may be required to remain in agricultural use as a binding condition.
• Reporting and monitoring: Access logs available to council on request; annual monitoring fee applies.
• Review condition: Council may include a s128 RMA review clause for conditions if effects differ from those anticipated.
• Consent duration: A first grant may be limited in duration (e.g. 5 years). Confirm typical duration with the planning consultant.

---

Operating Before Consent -- Enforcement Risk

Enforcement tools available to council (Part 12 RMA 1991):

• Abatement notice (ss322--325A RMA) -- most immediate tool; can require cessation within 5--15 working days
• Enforcement order (ss314--321 RMA) -- Environment Court; slower but stronger
• Infringement notice (ss343A--343D RMA) -- fixed penalty; creates formal compliance record
• Criminal prosecution (s338/s339 RMA) -- maximum $900,000 fine for a company; reserved for deliberate, large-scale, or repeated non-compliance

In practice: For a new, low-scale activity where the operator cooperates, the likely first response is an informal request to regularise the situation, followed by an abatement notice if no application is lodged. An abatement notice requiring immediate cessation before consent is granted would be a serious operational disruption.

What triggers enforcement:

• A complaint from a neighbour or member of the public
• Commercial signage or activity visible from Te Waerenga Road
• The physical address appearing in public online advertising or directories
• Council rates reassessment identifying a changed land use

Operational constraints during the pre-application period:

1. Do not advertise the physical address publicly. Word-of-mouth and direct referrals only.
2. Maintain at least 40% of the total site area in active, documented agricultural use.
3. Keep no commercial signage at the property.
4. Restrict customer numbers to a low-volume, low-frequency profile (access monthly or less per customer is ideal).
5. Log all access from the first day of customer use.
6. Do not construct any new structures without building consent.
7. Lodge the resource consent application by October/November 2026 without fail.

---

Environmental Obligations

Stormwater

Stormwater runoff from the concrete pad that drains to land (not a water body) is generally a permitted activity under the Bay of Plenty Regional Natural Resources Plan, provided it does not cause contamination of groundwater or surface water. Ed must confirm with Bay of Plenty Regional Council (BOPRC) whether drainage from the pad reaches a drain or water body. A resource consent for the storage activity is likely to include stormwater management conditions: grading or bunding to contain runoff, and an oil/water separator or interceptor sump at the pad drainage point. Installing a basic interceptor proactively is recommended given the water quality sensitivity of the Lake Rotorua catchment.

Relevant provisions: RMA 1991 s15 (discharge of contaminants); Bay of Plenty Regional Natural Resources Plan (specific rule numbers require BOPRC confirmation); National Policy Statement for Freshwater Management 2020.

Contamination and spill response

Max Storage Ltd, as the site occupier, has practical responsibility for remediation of any contamination on-site under RMA s17, even if the spill was caused by a customer. Before Phase 1 launch, the following must be in place:

• Hydrocarbon spill kit on-site: absorbent granules and pads, containment booms, disposal bags, warning cones, laminated spill instruction card. Location: near the main shed entrance, accessible without entering a contaminated area.
• Written spill response procedure covering petrol and LPG incidents, posted beside the spill kit.
• Spill register recording date, description, response, disposal, and whether BOPRC or WorkSafe were notified. Retain permanently.

Reporting thresholds: Any spill reaching a drain or water body must be reported to BOPRC (0800 884 880) as soon as practicable. Incidents involving a serious risk to persons must also be notified to WorkSafe (0800 030 040).

Customer contract: Must require customers to report spills immediately and make customers liable for all remediation costs. Must prohibit refuelling and oil changes on-site.

Lake Rotorua Nitrogen Scheme

The Lake Rotorua Incentives Scheme (BOPRC) targets pastoral farming operations with significant nitrogen discharge. A concrete-pad vehicle storage facility produces negligible nitrogen loss and is unlikely to fall within the scheme. However, Ed should confirm with BOPRC whether the property has a nitrogen allocation recorded against it (it may have been farmed previously). If a nitrogen allocation exists, understand its implications before the resource consent application.

Noise

New Zealand district plans for rural zones typically adopt noise limits based on NZS 6802:2008. Typical indicative limits for commercial activity are: 50 dB LAeq daytime (approximately 7:00 am -- 10:00 pm) and 40 dB LAeq nighttime, measured at the nearest noise-sensitive receiver. These values are indicative -- the actual Rotorua District Plan rural zone noise limits must be confirmed with Rotorua Lakes Council. For a low-traffic unattended facility, routine vehicle movements are unlikely to create a sustained noise issue. Voluntarily restricting customer access to 7:00 am -- 9:00 pm is sensible practice regardless.

A professional acoustic assessment is not expected to be required for this facility. The planning consultant will advise at the pre-application meeting. Relevant provisions: RMA 1991 s16; NZS 6802:2008.

Future contamination assessment

Selling or subdividing the property does not automatically trigger a mandatory contamination assessment under current NZ law, provided no HAIL (Hazardous Activities and Industries List) activity has occurred on the land. A vehicle storage facility for boats and caravans with no refuelling infrastructure does not clearly fall within the HAIL categories. However, if any fuel spill has reached the soil beneath the concrete pad, a prudent purchaser will commission a Phase 1 Environmental Site Assessment on sale. Maintaining the spill register is the primary protection against this risk.

---

Outstanding Actions

---

Blocked By

The consent plan is blocked by the planning consultant not yet being engaged (open item since 2026-03-31, target engagement August 2026). The following matters cannot be resolved without the consultant:

• Activity classification and specific rule reference in the operative Rotorua District Plan
• Scale thresholds affecting activity class
• Affected persons assessment under s95E RMA
• Whether a standalone traffic engineering or acoustic report is required
• Typical consent duration for this type of activity in the Bay of Plenty / Rotorua region

The evidence collection strategy (photographs, access logs, farm diary) does not depend on the consultant and must proceed now.