New Zealand Freshwater Sciences Society
Ministry for the Environment
PO Box 10362
Wellington 6143
New Zealand environmental.reporting@mfe.govt.nz
Re: Submission on proposed Environmental Reporting Bill
The New Zealand Freshwater Sciences Society (NZFSS) is the major society for individuals and organisations with interests in freshwater sciences, management and education in New
Zealand. Members include staff from Universities, Central and Local Government, private industry, crown entities, NGOs and private consultancies. Its objective is to establish effective liaison between all persons interested in any aspect of fresh and brackish water research in New
Zealand, and to encourage and promote these interests.
The NZFSS through its Executive Committee and wider membership wishes to provide feedback on the proposed Environmental Reporting Bill. As a society we strongly support the development of the Bill in seeking to develop an independent State of the Environment
Reporting and to provide greater uniformity of reporting from regional councils and unitary authorities. Further specific feedback is given below.
Consultation questions
1.
Do you agree with the issues identified above? Have the main issues been defined accurately?
The Society considers that the document provides valuable insight into the major issues associated with a national “State of the Environment” reporting requirement and the associated legislative requirements to achieve this reporting. The report has made mention of issues of duplication of effort at the national scale, with potential for some overlap in the roles of the Ministry for the Environment, Regional Councils and Unitary
Authorities, Statistics New Zealand, Ministry of Fisheries, and Parliamentary
Commissioner for the Environment. With proper planning and careful delineation of roles, the Society believes that duplication can be minimised and that it is possible to optimise environmental monitoring, data collation and reporting. At a regional level it is clear that there will be cost implications for some regional reporting programmes and that in some cases, where regional populations are small and resources are substantial, that some form of central support may be required.

2.
Are there any other issues that have not been considered?
One issue that may arise is the capacity of the Parliamentary Commissioner, in its current form, to be able to adequately resource State of the Environment reporting. This issue may be at least partially negated through centralised databases and reporting provided by the Ministry for the Environment (MfE). The Society considers that this role is a prerequisite for development of effective policies and legislation by MfE.
One other issue that is not reported on in any detail in the report is the interaction of
State of the Environment reporting with the goals of national policy statements. The
National Policy Statement in Freshwater Management, for example, provides guidance in monitoring and reporting that is relevant to the Environment Reporting Bill.
3.
What is the scale of the problem? Which is the bigger issue: the lack of statutory obligation requiring regular independent state of the environment reporting or inconsistent state of the environment monitoring?
The report has clearly identified some of the issues with current State of the
Environment (SoE) reporting including: disparities amongst regional councils and unitary authorities; lack of central guidance on SoE monitoring and reporting; and lack of independence of the reporting agency. The Society does not view any issue as being larger than any other, nor is one issue insurmountable, but an Environment Reporting
Bill is essential to address the present concerns which place New Zealand poorly in terms of SoE reporting amongst OECD countries.
4.
Do you agree with these objectives? Please give reasons.
Yes (see reasons given above). In addition there needs to be readily accessible, up-todate recognised databases that may be used for comparative reporting purposes internationally. The Society can identify the “Yale Environmental Reporting Index” as an example where inappropriate data from New Zealand (i.e., outdated and contextually incorrect data) have been used for international reporting purposes, resulting in assessments that are inaccurate for NZ.
5.
Do you agree with the assessment criteria? Please give reasons.
Yes (see reasons above).
6.
Do you agree with the preferred options? Please give reasons.
The Society strongly supports the use of the Parliamentary Commissioner for the
Environment for SoE reporting.
7.
Is there an alternative option that has not been considered?
See response to question 6. The Society does not consider it necessary to address this question.
8.
To what extent do the options address the identified problems?

The Society considers that the report has clearly identified many of the issues related to the current SoE reporting. The extent to which SoE reporting will provide capacity to make a real environmental difference in the case that issues are identified, however, remains uncertain. Such actions may include additional monitoring but more importantly, where negative trends are apparent, actions taken to address the source of the problem and to rectify it. In this case the issue becomes one of interactions with the
National Policy Statements. The fact that the NPS in Freshwater Management may allow some regional councils up until 2030 to put in place an adequate monitoring framework (let alone lead to an enforcement obligation), is cause for concern.
9.
Are you aware of any other costs and benefits of the options?
See response to questions 1 above and 16 below.
10.
Do you have any comment about which option would deliver the highest level of net benefit?
The Society supports the necessary legislative changes for independent SoE reporting through the Parliamentary Commissioner for the Environment.
11.
What are the pros and cons of the proposed Environment Act amendment?
See response to question 8. State of the Environmental reporting should be associated with plans, policies and regulations that will directly address any identified environmental problems as well as identifying where it is possible to increase the resilience and biodiversity of natural ecosystems to mitigate for the potential effects of a changing world (e.g., increasing human population, greater environmental variability and climate change).
12.
Is five ‐ yearly reporting an appropriate reporting timeframe? If not, what time period would you recommend?
The society considers that five years is a good time scale on which to balance rates of environmental change, resources required for reporting, and time scales required to effect improvements in monitoring.
13. What do you think about the proposed environmental domains that the Parliamentary
Commissioner for the Environment should report on in the state of the environment report? What topic areas or requirements (if any) would you suggest?
The NZ Freshwater Sciences Society is concerned with all aspects of freshwater ecosystems as well as other inland aquatic systems (e.g., salt lakes). The Society would welcome consultation on the ecosystems that should be included in the assessment as well as the interactions with regional councils and unitary authorities that are necessary to support the SoE reporting. Briefly the ecosystems relevant to the Society include surface waters (lakes, reservoirs rivers, wetlands, ephemeral or temporary systems) and groundwaters.

14. Outline any problems you perceive with the proposed RMA amendment?
The issue of most significance to the Society is the way in which SoE reporting is linked to actions undertaken by regional councils and unitary authorties. There needs to be clearly identified pathways taken to address problems and these should be embedded within the RMA legislation.
15.
Which environmental domains (eg, fresh water, land, oceans) do you think should be prioritised for improvements in consistency?
Freshwater. Whilst there has been some standardisation of reporting through the NIWA
National River Monitoring Network and reporting on trends in lakes, there are disturbing trends in these systems and many related ones (e.g., wetlands) that place increased emphasis on SoE reporting for freshwater systems.
16.
Have we accurately reflected the high level costs and benefits arising from the proposals for an Environmental Reporting Bill? Please give reasons.
Costs associated with management of national-level databases and statistical data sets are high. These should be carefully evaluated in the development of the Environmental
Reporting Bill. See also response to question 1, which identifies a possible issue with poorly resourced councils and/or those which have poorly developed monitoring programmes to support the SoE reporting requirements
17. Can you identify any other high level costs and benefits?
See response to question 16.
18. Do you have any information you would like to see included in the final cost ‐ benefit analysis that will be carried out after the submissions are received and analysed?
Not at this point in time.
Yours sincerely
David Hamilton
President, NZ Freshwater Sciences Society cc. Executive Committee, NZ Freshwater Sciences Society