The first question every Fast-track applicant has to answer is which pathway they are on. Schedule 2, referral, or neither.
Schedule 2
If your project is named in Schedule 2 of the Act, you have a guaranteed pass to the Fast-track substantive application process. That is not consent. It is a pathway. The expert panel still has to grant the consent and the substantive package still has to meet the statutory tests.
The benefit is certainty on the pathway. The downside is that being on Schedule 2 does not change the technical bar. A weak ecology assessment fails on Schedule 2 just as it would on referral.
Referral
If your project is not on Schedule 2, you can apply via referral. The Minister decides whether the project meets the regional or national benefit test. Successful referrals join the substantive lodgement queue.
The referral application itself is a significant piece of work — it has to argue, with evidence, that your project clears the significance test. This is where many applicants underestimate the effort. The referral is not paperwork; it is the first formal articulation of your project’s case for being treated as nationally significant.
Neither — and what to do instead
For some projects, Fast-track is the wrong answer. The EPA cost recovery is high. The submitter regime narrows political legitimacy. And the 2026 RMA replacement (Natural Environment Bill + Planning Bill) is going to change the underlying landscape again.
If your project is not time-critical, has soft cultural and environmental groundwork, and could plausibly be re-pitched under the replacement regime, sitting Fast-track out is sometimes the strategically correct call.
The decision matrix
A clean way to decide:
- Project is Schedule 2 + FID-blocking + tight grid window → lodge Fast-track now
- Project is not Schedule 2 + clear national benefit + good cultural groundwork → referral
- Project is not Schedule 2 + weak cultural or environmental groundwork → fix the groundwork first
- Project is plausible but not time-critical + complex opposition risk → wait for replacement regime
Picking the right pathway is worth more, in expected value, than any other decision you make on the application.