NZMSS Measuring Up: Environmental Reporting-a discussion document

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Submission on proposed Environment Reporting Bill

Ministry for the Environment

PO Box 10362

Wellington 6143

environmental.reporting@mfe.govt.nz


1
8 October

2011



Dear Sir/Madam,


NZMSS
Submission on “
Measuring Up: Environmental Reporting
-
a discussion document



Please find
attached
a submission regarding the Environmental Reporting
D
iscussion
D
ocument

on
behalf of the New Zealand Marine Sciences Society

(NZMSS)
1
, a professional society o
f New
Zealand’s marine scientists

(representing over 250 members)
, affiliated to the Royal Society of New
Zealand
.

In general,
NZMSS
welcom
es the proposal by Hon Dr Nick Smith for a

new Environmental Reporting
Act requiring publicly accessible and meaning
ful national scale information on our water air and
land

.
However, we believe that that the proposal is too narrowly focused

and

potentially under
-
resourced

to achieve its purpose
.

This opportunity to
develop

meaningful
reporting

about

the marine environment
at a national scale
will
require

rigorous time series of data that extend beyond the coast and the RMA
’s jurisdiction to
be effective.

We would like to see a whole systems approach

to reporting

on
the
full
marine
environment
, with a
ttention given to

connectivity

issues such as the downstream effects of land
-
based activities on marine habitats and species, and the broader
context
of climate change impacts
on the ocean, including ocean acidification.

Interpretation of highly variable c
oastal data will
need to
take place in

the context of long
-
term trends in the oceanic domain beyond the Territorial Sea
,

to
the EEZ and Continental Shelf waters.

We
provide more detailed comment on

the discussion document
page by page in the attached
submi
ssion.

Please do not hesitate to contact me should you need further c
l
arification on our
submission.




1

Letter approved for release by the NZ Marine Sciences Society
Council,
7

October
2011




Yours faithfully



Associate Professor Colin McLay

President

New Zealand Marine Sciences Society

Biological Sciences, Canterbury University

Christchurch
PB4800.

Email Address:
colin.mclay@canterbury.ac.nz





Submission from the New Zealand Marine Sciences Society on

“Measuring Up: Environmental Reporting
-
a discussion document”

October 2011


Executive Summ
ary Page 2

Para 1.

“Environmental information should underpin all environmental and economic
decisions….”.We consider that environmental information will be used to inform socio
-
economic
decisions, not just economic decisions.

Para 2.

It would be helpful to see what the other components of MfE’s initiatives are so that we can
better evaluate how comprehensive this
B
ill needs to be
. Please advise of these?

The Issues Page 3

Issue 1.

We agree that the lack of statutory obligation in New
Zealand needs to be rectified. The
weakness of the second SoE report in 2008 was not
so much in

its
apparent
lack of independence

as
we suspect that some sort of peer review process was followed
.
Our concern was more that the SoE
report
was particularly we
ak in the ocean domain and land/marine interface and did not incorporate
information readily available about the marine environment. For example, data on changes to sea
temperatures, ocean acidification, sea level, significantly the status and trends of ma
rine
biodiversity, river pollution and sedimentation out flows and so on.

Issue 2.
We believe that there are two issues here. The first is that MfE appears to be unaware of
existing data sources and indicators collected by other agencies in the ocean domai
n, or that these
data are not collected in a co
-
ordinated way that is managed and accessible.
MfE has co
-
ordinated
several attempts to derive national marine indicators and stats and data information sources during
the 1990’s


2000’s, but lack of success
was due to the non
-
national coverage, inconstant data
collection, non
-
management of data and inaccessibility of data, and the affordability to get anything
more than the status quo.

The second
is the

lack of
legal requirement

for
Regional Councils, but als
o
for
CRIs and
government

agencies to collect national
-
scale data unless they are required to report on
Tier 1 Statistics. The current review of the environmental Tier 1 statistics should somehow link to the
proposed Bill.

The Objectives Page 4

We believe
that it is essential for the proposal to consider environmental information collected by
other agencies, particularly CRIs. By limiting it to RMAs, you will only get monitoring in the highly
variable coastal environment. This needs to be placed in the cont
ext of the broader signals from the
ocean on an exclusive economic zone (EEZ)
-
scale from remote sensing data and other monitoring
datasets that validate satellite data. If this is not specified, then who will volunteer to improve this
information?

The prop
osed approach Page 4

The approach needs to explicitly include the ocean domain, covering New Zealand’s total sovereign
marine environment
, ie territorial sea, Exclusive Economic Zone and the Continental Shelf.

Costs and Benefits Page 5



The “informal” analy
sis should be available for stakeholders to see. We suspect that “informal” is
code for “back of the envelope”. We find this sort of approach unacceptable given the software and
methodologies available to formally assess such things.

Introduction
P
age 6/7

It is not just about New Zealand’s environmental performance, but our achievements in meeting the
blue
-
green growth agenda, and our ability to demonstrate that new developments are undertaken
and are remain within environmental limits. There is a need for
scientifically rigorous indicators as
well as measures of long
-
term environmental change.

CRIs
P
age 9

In the absence of an Oceans Policy, there needs to be better coordination between RMAs,
government agencies,

universities and CRIs. I.e. a true whole of g
overnment

and New Zealand Inc

approach.

National

State of the Environment reporting Pages 10/11

We observe that biodiversity, the economic evaluation of biodiversity
, biosecurity

and ecosystem
services and the review of environmental statistics by Stats NZ are missing from this discussion. This
needs to be rectified
.

Inconsistent regional SOE monitoring programmes

We agree that this situation needs to be urgently rectified. We
think that the “devolved” nature of
NZ’s environmental management system is an understatement, particularly for marine. It is
fragmented, under resourced and almost non
-
existent.

Questions Page 14

1.

Do you agree with the issues identified above?

Have the mai
n issues been defined
accurately?

Agree with the two issues identified but consider that the proposal is too narrowly focussed on
RMAs. That’s a good first step, but for the legislation to produce meaningful results, it needs to
ensure that a whole of Govt

approach is taken, good indicators, standardised monitoring methods
are developed, data and information is managed and accessible and that monitoring includes the
ocean at an EEZ scale.

2.

Are there any other issues that have not been

considered?

Yes we thin
k there are a few other issues that could be addressed by this Bill.

A)

National level environmental reporting



Currently this discussion document only mentions amendment of the RMA….there is an
opportunity to get his right with the new EEZ legislation also by

including responsibilities for
SOE reporting in that.



National
-
scale information on the marine environment is identified as an issue (pg 4) but is
not addressed by this legislation.





The
OECD’s 2007 environmental performance review

also recommended
establi
shment of a
national policy statement on coastal waters.


B)

12nm reporting



Who will report on state and trend of the marine environment within the 12 nm mile e.g.
state of species and habitats (
Local
Authorities

or DOC )?

Some but not all Local Authorities
a
re doing this e.g. Environment Southland

SoE Report
, Nelson Marlborough just put out
report on significant habitats for species.



Much information is held by central agencies e.g. DOC, MFish.



Decide which marine indicators will be collected by regional coun
cils versus national
agencies and ensure that the programmes are integrated for national reporting.



Marine reserves (
present in a
range of habitat types e.g. estuarine, rocky shore) can act as
control sites for regional monitoring programmes.


C)

Integration

of national and local reporting



If L
ocal
A
uthorities

continue to produce their own regional SoE reports there is potential for
duplication of effort

between regional reporting and national reporting
.
Would all reporting
be aligned into one
year

e.g.
regio
nal

reporting

with more details
,

and information of local
interest
,

plus a national summary report


with data being maintained and
in
accessible
form
s at

local and national levels.



There needs to be a
process and timing to maximise efficiencies across the

regional and local
scales.



Coordinate databases


e.g. spatial mapping of
s
pecies distributions and habitats is carried
out by RCs, DOC and MFish.
There is much d
uplication of GIS. C
ould

one agency be tasked to
house, manage and co
-
ordinate the updates of

this data?


D)

Integration across organisations at local level and at national level.

A coordinated network
that integrates existing marine research
and monitoring
efforts will greatly improve
understanding of the status

and trends in biodiversity of New Zealand

waters at relatively
modest cost.



This can be achieved using interagency collaboration via meeting structures. For instance in
Southland they had an interagency approach to report on the coastal/marine environmen
t.
This involved Regional Council leading an interagency process with iwi, Maritime NZ, MFish,
DOC.



This collaboration should be ongoing to
encourage
regular dialogue on information
management and issues, roles and efficiencies.



At a national level coordin
ation could be driven by the Natural Resource Sector (NRS) Forum.


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 e
nvironment monitoring?



Inconsistent and uncoordinated monitoring, and, gross underfunding for an issue which is so
fundamental to the government’s green growth strategy
.

4.

Do
you
agree with these objectives?

Yes but
we
don’t

think this proposal will lead to

achieving them because of gaps identified above.



It
need
s

to be
clear who is responsible for regular state of the

environment reporting.



The role of state of the environment reporting
may need to be

independent

of
Government,
but what is role of CRIs
?

The

PCE

still needs to get

data from other
organisations. They can act more as a facilitator to bring information together.



High quality environmental statistics are
required

to underpin

state of the environment
reporting and environmental

policy
-
making

but n
ot all issues are addressed for this to
occur
.

5.

Do you agree with the assessment criteria?

A.

We do not see how the proposal will lead to criterion A being met.

B.

The government is giving very mixed messages about its commitment to independence.
For example, fis
heries science is struggling to be seen as independent from industry,
particularly whe
n industry conduct the research;
w
hy has the Food safety authority been
merged with MAF? Why has Archives NZ been merged with Internal Affairs?

C.

If the proposal is to be a

natural fit with legislated responsibilities, those interfaces need
to be spelled out, and if independence is required, an indication of how that will be
achieved (given other agency mandates).


6.

Do you agree with the preferred options?

We suggest that
provisions under the Sta
t
istics Act should be dove
-
tailed with regulation
powers under the RMA.
i.e. options 2 and 3 in the Summary Table page 19.


7.

Is there an alternative option that has not been considered?

To extend to the full ocean domain, it may be n
ecessary to amend legislation for CRIs, DOC
Maritime New Zealand and MFish (MAF).


8.

To what extent do the options address the identified problems?

It will not address the problem of lack of reporting in the wider ocean domain
.


9.

Are you aware of any other c
osts and benefits of the options?

No…the costs and benefits have not been provided
.


10.

Do you have any comment about which option would deliver the highest level of net
benefit?

Of the options provided the p
referred
one is that

proposed in the Bill:



“Give th
e Parliamentary Commissioner for the Environment (PCE) an explicit role under
the Environment Act 1986 by requiring five
-
yearly reports on the state of the
environment





Expand regulation
-
making powers under section 360 of the RMA to improve the
consistency
of state of the environment monitoring statistics at the local level.”

11.
What are the pros and cons of the proposed Environment Act amendment?

Pros



O
ne clear lead

Cons



N
o
clear
roles

for

other agencies
or the process for
engagement and efficiency of effo
rt
,
or data management
.

12 Is five
-
yearly reporting an appropriate reporting timeframe? If not, what time period would you
recommend?

Yes, h
owever, some reporting could be undertaken on a more regular basis (e.g. MPAs/protected
sp
ecies



area of legal biodiversity protection by habitat type, no. of protected species)
.

13. What do you think about the proposed environmental domains that the PCE should report on in
the state of the environment report? What topic areas or requirements (if a
ny) would you suggest?

We agree with the domains. Biodiversity should be explicitly stated as including all 4 environmental
domains
;
Issues with
in

each
domain are
not addressed by this discussion document
.

Suggested amendments to table 3:



Include other
agency functions and responsibilities to contribute to the reporting e.g. EPA,
MFish, DOC.



Add more detail so it is clear e.g. MfE will still carry ou
t

functions outline
d

in
the
current
functions columns. Add these to proposed column or are some of these c
urrent functions
now undertaken by EPA?



We need clarify of roles where there is uncertainly not just the lead agency.

14. Outline any problems you perceive with the proposed RMA amendment?

Comments



Good coverage of i
nconsistencies
in

regional

environmental

monitoring programmes
identified (pg 13) but these do not need to be detailed in legislation.
This is far to
o
prescripti
ve and will be difficult if not impossible to achieve.



Instead
we suggest that the
legislation
has
that monitoring will be based on env
ironmental
standards and protocols e.g.
National E
stuary
M
onitoring
P
rotocol. Where national
standardised methods can be used


they should be.



Suggest requirement for PCE to develop national documents standards and prot
o
cols.

These
need

to be based on pre
ssure,
state and response information.





Currently the focus of the Bill appears to be primarily reporting of “state” indicators.
Pressure and response data is important to link the findings to targeted and improved
management.



The reporting re
quire
s

peer re
viewing.



Databases data management and data sharing also an issue at a both local, regional and
national level.



Suggest more of a
focus on
setting up a good
process
for achieving reporting requirements



Need to identify gaps in National Environmental Stand
ards and
m
onitoring protocols.
Dev
elop these at a national level.

1
5. Which environmental domains (e
.g.

fresh water, land, oceans) do you think should be prioritised
for improvements in consistency?

Freshwater has well developed monitoring protocols…..mari
ne has very little.

16. Have we accurately reflected the high
-
level costs and benefits arising from the proposals for an

Environmental Reporting Bill? Please give reasons.

No, the cost benefit analysis has not been provided in any detail,
so the costs of
implementing the
bill are not explicit.

17. Can you identify any other high
-
level costs and benefits?

A benefit is that environmental reporting should also be scanning for emerging problems in the
environment
.

A
more

co
-
ordinated approach will improve i
nve
st
ment and innovation in
developing new
approaches for automated sample processing
.

Better coordination between agencies
on reporting also
imp
roves

the wider
communication and

can
lead to
improved management i.e. acting on what the data tell
s us.

Data ret
urned and analysed from a co
-
ordinated approach
will support the environmentally
sustainable

development of new resources and uses derived from the marine environment.

There are many advantages
in
develop
ing
open access data
sharing
and promoting the rescue and
reuse of
publicly

generated or funded data:



Promotes interdisciplinary,
inter
-
sector,
inter
-
institutional, and national and
international research;



Facilitates entirely new forms of distributed research collaboration and inform
ation
production;



Supports freedom of inquiry and collaborative research
;



Supports the development of a national marine information networks
;



Promotes discovery of unfamiliar data (contemporary or legacy)
;



Enables automated knowledge discovery;



Avoids inefficiencies, including
duplication of research and promotes new research
and new types of research;





Increases the intrinsic value of data;



Promotes new research and new types of research;



Reinforces open scientific inquiry and encourages diversi
ty of analysis and opinion;



Allows for the verification of previous results;



Makes possible the testing of new or alternative hypotheses and methods of
analysis;



Enables the exploration of topics not envisioned by the initial investigators
;



Supports stud
ies on data collection methods and measurement;



Facilitates the education of new researchers;



Promotes the creation of new data sets when data from multiple sources are
combined;



Promotes citizen scientists and serendipitous results,
enabling the explorati
on of
topics not envisioned by the initial investigators and t
he primary research
community;



Permits the creation of new data sets when data from multiple sources are
combined;



Promotes capacity building and global research;



Supports economic growth and

social welfare; and



Generally provides greater returns from public investments in
monitoring and
research.


18. Do you have any information you would like to see included in the final cost
-
benefit analysis
which will be carried out after the submissions a
re received and analysed?

Horizon scanning;
market and non
-
market value,
ecosystem services
, future benefits.