science panel round 3 - myriver

8/12/2019 Science Panel Round 3 - Myriver

http://slidepdf.com/reader/full/science-panel-round-3-myriver 1/28

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Science Panel Round 3

Our ultimate aim with this project is to identify what a representative group of

NZ’s scientists agree on with respect to freshwater management and to identifythe issues where there is significant disagreement. That, indeed, is the purpose of

Round 3.

13/15 panel members answered the 6 questions of Round 2. On the basis of

these responses we have identified three issues we think it is useful to explore

further. These are:

Issue 1: Are the NOF bottom lines adequate as they stand?

Issue 2: Implementation of NOF/NPS

Issue 3: What protection does the NPS offer to water bodies that are above

bottom lines?

To this end under each of these issues we have developed, for Round 3, a

statement that we expect to have widespread agreement among the panel. This

is termed the “Statement of Agreement”.

Under each of the issues we have also identified a key area where there seems to

be significant disagreement among the panel. This is termed the ‘Statement of

Disagreement’.

We ask panel members if they would, for each of the three issues:

1.indicate whether or not they agree with the Statement of

Agreement (comments and adjustments are also welcome).

2. tell us their position on the disputed matter outlined in the

Statement of Disagreement and (if possible) direct us to evidence

that supports their position.

You will note that for each Issue we have also provided a series of unattributed

quotes from the panel that we believe are reflected in the Statements of

Agreement and Disagreement. We are not expecting you to comment on these.We have included these for illustrative purposes. They are indicative only, as

often comments were duplicated amongst the responses. A comprehensive set of

quotes from Round 2 is included in the Appendix.

Once we have responses to Round 3 we will circulate and seek feedback on a list

of statements (reflecting all three rounds) that we believe have consensus

support, majority support or over which there is disagreement. This will mark

the end of your valuable input.



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and the rivers which feed into them and ultimately estuaries, wetlands and

groundwater.

Statement of Disagreement

Accepting that the set of NOF attributes is still incomplete, there is disagreement

over whether the existing NOF bottom line attribute values are sufficient to allow

for the recovery of the water body.

Question: Do the NOF bottom line attribute values allow for the recovery of a

water body?

Quotes

“Nitrogen for example set at toxicity for rivers is an example of why this will not

afford water bodies the protection they require – it is based on the notion that P

can be managed (and therefore periphyton) while N is allowed to run to

toxicity… For the NOF just set realistic bottom lines such as N 0.8, P 0.1, and MCI

100… contact recreation not allowed to deteriorate to secondary contact as a

bottom line through averaging of regional river/lake data.”

“get rid of the “single nutrient management” scam.”

“The NOF treats most variables as independent of each other and yet in the real

world systems are subjected to multiple stressors which may act in additive

ways…”

“... if the two NOF bottom lines (ie water quality levels that will (i) deliver

ecosystem health for the protection of indigenous species and (ii) allow

secondary human contact) are implemented properly and in a timely fashion in

conjunction with NPS objective A2a then they will deliver an overall national

bottom line level of water quality to future generations that will not limit their

choices greatly…no (or few) waters will be in a state that completely reduces

options for the future, ie, their ecosystems have “flipped” permanently toanother, less desirable, equilibrium state…

“Do the proposed environmental bottom-lines reflect science-based breakpoints

below which aquatic ecosystem health is considered ‘poor’? To that question I

would say ‘Yes’.

“The NOF “bottom lines” simply delimit unacceptable from acceptableconditions. They have nothing to do with good …ecosystem health. They are the

lowest acceptable grade before emergency management measures or restoration

efforts are needed to stabilize ecologically “sick” or unstable lakes/rivers.”

“Many of our urban waterways may not breach NOF bottom lines, however, they

are highly ecologically degraded. The bottom lines are generally extremelydegraded.”



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Issue 2: Implementation of NOF/NPS

Statement of Agreement

In principle using adaptive management is the best way to manage freshwater.

Adaptive management implies having policy tools that can be fine-tuned as new

information and knowledge comes to hand, acknowledging there is a need for

certainty in policy too. To be effective, adaptive management requires

comprehensive and timely monitoring of water quality, land use, off-takes and

discharges and a reliable understanding of the ecological processes at work

within catchments.


There is disagreement over whether the bottom lines (as defined by the values

for Bands C and D) are sufficiently precautionary given the imperfect knowledge

about water quality states across NZ, an imperfect understanding of ecological

processes and the response lags that are an inevitable part of adaptive

management.

Question: Should NOF have more cautious attribute limits for bands C and D to

ensure that adaptive management practices do not result in more irrecoverable

waterways?

Quotes

“Need robust and representative monitoring regimes of both pressures (eg landuse) and state (ie indicators relating to NOF values) and objectives, policies and

tools in regional plans that trigger responses when trends emerge (adaptive

management).”

“Ideally this would involve a process of staging development changes at a pace

that allows for monitoring regimes…to monitor the effect of the changes, andenable adjustments to be made before unacceptable effects occur. However,

sometimes the scale of investment requires some certainty to proceed, in which

case staging development and monitoring impacts will be limited in its

effectiveness and other strategies and value judgements of the risks need to be

considered carefully.”

“Apply an adaptive management approach in which all water quality objectives

and management actions for each water body are regularly (i.e. every 5 years)

reviewed and updated based on measurable water quality trends and outcomes.

This approach requires the development of an integrated catchment

management plan for each water body in New Zealand.”



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“This is a complex question. Ideally the precautionary approach is one of

adaptive management and robust monitoring of status and trends…Howeverstakeholders are averse to uncertainty and so there is great pressure on

governments/councils to provide certainty/stability around environmental

regulations/targets….Yet in a situation of imperfect knowledge about

environmental impacts on freshwater systems (especially when dealing withindividual lakes and rivers), adaptive management is the only prudent way

forward…Thus we have a serious regulatory dilemma.”

“A precautionary approach would do exactly that – be cautious of any changes in

activities that could lead to deterioration. It also points to the need to improve

monitoring and modelling so that trends can be more readily identified and

acted upon. In some cases we already know systems that are strongly influenced

by groundwater inputs and therefore have long response times. These should be

heightened sensitivity, ie a higher precautionary approach, adopted for these

systems.”

“Attribute values at the bottom of the C band need to provide sufficient buffer

between minimum acceptable state and ecological tipping points so

that….appropriate interventions [can be] undertaken, before irreversible effects

occur. Set limits that are sufficiently conservative to provide for under-

estimation of effects, and, most importantly, ensure that communities setting

water quality outcomes for their freshwater resources understand the

uncertainties…provide a policy framework that allows for rapid responses to

both measured and modelled changes in water quality…”

“It may be possible to consider “interim numeric bands” by including some ofthose attributes listed but currently not included in the NOF, on a trial and

review basis….However I suspect the legal ramifications, of interim numeric

bands ends up in the Environment Court, will make this impractical.”

“Greater use could be made of overseas approaches to setting water quality

criteria as interim NOF limits…”

“I am extremely concerned about the “reliance” on modelling approaches. Many

models of freshwater systems perform poorly but are being “sold” as providing

accurate predictions…”

“This question raises an interesting point. It assumes that the “lags and

uncertainties” in the science and modelling are so large that we cannot use or

trust our science and our models for guidance in making reasonable

management decisions and enforcing management regulations. For sure, there

are issues with the breadth and depth of our knowledge and science and there

are uncertainties associated with our modelling. However, these are often

overstated and often used as an excuse to delay taking action.”



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Issue 3: What protection does the NPS offer to water bodies that are above

bottom lines?

Statement of Agreement

Given the current wording of the NOF/NPS, with the exception of ‘outstandingwater bodies’, ‘significant values of wetlands’ and ‘degraded’ water bodies that

have been ‘over-allocated’, it is unclear what protection the NPS provides for

water bodies with water quality above the bottom line. As it currently stands

NPS Objective A2 (“t he overall quality of fresh water within a region is

maintained or improved”) could be seen as allowing deterioration in some

attributes within a waterway , or deterioration in water quality within a

catchment (providing on average there is no deterioration within the region).


There appears to be some disagreement among the panellists with the

proposition that: NOF should state unequivocally that all water bodies are

maintained or improved – i.e. that there should be no room for trade-offs

between attributes within a water body, or water bodies within a region.

Question: Do you think the intention of the NOF/NPS should be to prevent any

water body from deteriorating, irrespective of its current water quality?

Quotes

“One proviso here is that those water bodies with water quality better than theNOF bottom lines must be identified formally and protected from degradation….I

am not sure if NPS objective A2a…will achieve this since those water bodiesbetter than the NOF bottom lines, but not considered “outstanding”, could be

allowed to degrade…I think…the definition of “outstanding” [needs to] bereasonably broad to just not capture “iconic” water bodies.”

“…the NOF should not be considered as simply addressing bottom lines. It has a

system of bandings so that ‘maintain and improve’ [water quality] can beapplied…if there are regulations and enforceable penalties then opportunities for

future generations will not be compromised. Much will depend on councils,

enforcement and tools available to penalize polluters.

“…I think the NPS/NOF legislation is basically sound and innovative legislationand will produce results (with… provisos…)… One proviso is that those water

bodies with water quality better than the NOF bottom lines must be identified

formally and protected from degradation up to the NOF bottom lines.”

“Most lowland rivers and streams in New Zealand in agriculturally developed

catchments have high DIN and DRP concentrations that are not currently

addressed by the NOF. The smaller streams are particularly at risk because they

are not monitored as frequently as large rivers.”



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“I am concerned about sites where trends indicate statistically significant degradation of water quality, although current levels are not violating the NOF

bottom lines. It is possible to predict how long it might be before sites drop into

another band or drop below bottom lines. It will undoubtedly be easier to avoid

breaching the relevant limits or bottom lines rather than try to rehabilitate the

system. Examples of this are the lower Motueka River and lower Hurunui Riverwhere nitrate concentrations have been increasing over the last 20 years, but are

still relatively low.”



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Appendix

Question 1: Is the minimum level of water quality implied by the

combination of NOF bottom lines and NPS objective A2 sufficient to ensurefuture generations will inherit waterways that have a level of ecosystem

health that provides the same choices/options we have today?

(The following is based on a non-scientist’s interpretation of panel responses):

There is agreement among the panel:

1. NOF is a labelling system, created to help communicate the state of water

quality (especially to the public). All the Bands help with this.

2. NOF is also more than this because MfE states no region is allowed to designits water plans so as to deliberately deliver water quality in Band D. The NOF is

therefore a national management tool to provide consistency to councils in water

quality management.

3. Within the proposals the mechanisms that will guarantee poor quality rivers

will not deteriorate to a non-recoverable state are:

- no region is allowed to design water management plans so as to

deliberately deliver water quality in Band D.

- in a practical sense, the regulations and penalties set by councils andcommunities will bear the burden of this guarantee. A lot of responsibility

rests here.

4. NOF is a ‘work in progress’. There seems to be agreement that estuaries need a

NOF, and biological indices should be included as a matter of urgency in the NOF

for freshwater. There are various other suggestions about what more should be

included in the NOF as it develops (see Question 2 for these).

5. There is no guarantee in the current proposals that rivers in Band C or above

will be managed so as to have improving water quality in time.

6. The NPS and NOF are an improvement on past policy.

Disagreement among the Panel:

1. There seems to be disagreement among the panel about whether Band D

attributes and values are sufficient (accepting that the set is currently

incomplete) to ensure future generations have the option of restoring the life-

supporting capacity of poor quality rivers, lakes and wetlands.



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2. There is disagreement/uncertainty about how NWPS Objective A2 (“The

overall quality of fresh water within a region is maintained or improved”) is to

be interpreted.

Illustrative take out quotes from panel responses:

“Do the proposed environmental bottom-lines reflect science-based breakpoints

below which aquatic ecosystem health is considered ‘poor’? To that question I

would say ‘Yes’.

“The NOF “bottom lines” simply delimit unacceptable f rom acceptable

conditions. They have nothing to do with good …ecosystem health. They are the

lowest acceptable grade before emergency management measures or restoration

efforts are needed to stabilize ecologically “sick” or unstable lakes/rivers.”

“The bottom lines alone will not ensure that future generations will inherit asimilar level of ecosystem health.…”

“No, that is not their intention. The NOF and NPS objective set what the limits toacceptable/unacceptable water quality are. They do not actively encourage

improvement of currently impaired water quality.”

“…the NOF should not be considered as simply addressing bottom lines. It has asystem of bandings so that ‘maintain and improve’ [water quality] can be

applied…if there are regulations and enforceable penalties then opportunities for

future generations will not be compromised. Much will depend on councils,

enforcement and tools available to penalize polluters.

“The NOF bottom lines and NPS A2 objectives are not the only methods drivingstrategies for managing water quality, they are part of a package of expectations

and methods…”

“I struggle with this question because it seems to confuse the relationshipbetween Objective A2 and the NOF “bottom lines”…it’s critical to know the wayA2 is to be applied…the suite of proposals announced in November, including theNOF, is intended to provide greater clarity to and guidance on the NPS-FWM –

that should include the way the “maintain or improve” concept is to be applied.Sadly the connections between A2, the objectives framework, and the freshwater

management units within which objectives and limits are to be set are not well

made.”

“..if the two NOF bottom lines (ie water quality levels that will (i) deliverecosystem health for the protection of indigenous species and (ii) allow

secondary human contact) are implemented properly and in a timely fashion in

conjunction with NPS objective A2a then they will deliver an overall national

bottom line level of water quality to future generations that will not limit their

choices greatly…no (or few) waters will be in a state that completely reduces

options for the future, ie, their ecosystems have “flipped” permanently toanother, less desirable, equilibrium state…One proviso here is that those water



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formally and protected from degradation….I am not sure if NPS objectiveA2a…will achieve this since those water bodies better than the NOF bottom lines,

but not considered “outstanding”, could be allowed to degrade…I think…thedefinition of “outstanding” [needs to] be reasonably broad to just not capture

“iconic” water bodies.”

“The proposed NPS amendments, including NOF, are a significant step forward,

they are incomplete and could be improved, but this is a good step forward.”

“..the proposed bottom lines provide a significant step towards safe-guarding

future ecosystem health.”



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Question 2: What needs to be changed or included in the NPS-FW/NOF?

There was consensus on the need to keep developing NOF, no obvious

disputes among the panel and a variety of suggestions about what needs to

change.

The panel agrees:

1. the NOF is incomplete at present and adding new attributes would be a good

idea. Biological indicators in particular would be welcome (eg MCI, invasive

species), as would dissolved oxygen in all waters (currently this attribute is set

below point source discharges) and sedimentation (among others). Safe for

primary use, not secondary use, should be the standard set for some rivers.

2. Estuaries (especially), wetlands and groundwater need to be captured in

policy somehow so that associated bottom lines and other Bands can be defined(for estuaries this may be within the fresh water strategy or a revised New

Zealand Coastal Policy statement.

Other suggested changes:

1. Rather than wait until the science is exact, add useful attributes to the NOF

now on a trial or interim basis (eg macroinvertebrates).

2. As well as medians and means, there are benefits in some cases in measuring

and setting standards for variability around the mean values ie maxima and/or

minima as has been done for Dissolved Oxygen.

3. There should be central leadership, guidance and support for the NOF to work

well. This must give some standards for the timeframes for implementation as

well as clarifying the interpretation of NWPS objective A2.


“The NOF bottom lines are based on current scientific knowledge. We havesignificant gaps in our knowledge that are not being funded or researched.”

“The NPS needs to include…a clear articulation of the interaction between A2,

the NOF grades, including the bottom lines, and freshwater management units.

This should address the circumstances in which water quality in particular

management units should be allowed to decline below the band within which it

currently lies, and the way in which concomitant improvements are to be

provided for…”

“The NOF treats most variables as independent of each other and yet in the real

world systems are subjected to multiple stressors which may act in additive

ways…”



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“The NOF is not coherent because it did not adopt a catchment -scale approach.

Indicators for rivers and lakes have not been aligned (eg no TN and TP indicators

for rivers, but TP and TN indicators for lakes)….even within the specific

categories of rivers and lakes, the proposed indicators are confusing. For

example, nitrate and ammonia limits are set by toxicity (not their ecological

impacts) and have been set much higher than TN limits.”

“There has been no consideration of downstream impacts on estuaries and

coastal systems which receive the freshwater flows…”

“Groundwater and estuaries need to be added.”

“Wetlands – attributes for wetlands have been considered in draft form and

these need to be further developed in stages. Suspended sediment and dissolved

oxygen may be primary attributes together with macroalgae (periphyton)

biomass and extent of invasive species. Estuaries–

there needs to be further

discussion on estuaries as receiving waters and the extent to which these are

applicable to the NOF or whether they fall under the National Coastal Policy

Statement and therefore that policy needs to include a NOF.”

“…many more attributes need to be included. There are many protocols already

available and measures that can and are being used in New Zealand. This list

includes: sediment…, the fish index of biotic integrity,…MCI, nitrogen,temperature and dissolved oxygen (must be continuous not snap-shot), contact

recreation standards…, periphyton visual assessment of cover…”

“The NOF will benefit greatly from inclusion of more water quality variables - viz.dissolved reactive phosphorous, dissolved inorganic nitrogen and integrative

ecosystem indicators, such as the macroinvertebrate community index especially

for rivers and streams. The emphasis on secondary contact recreation for

microbial guidelines is unnecessarily permissive and should be changed to

primary contact to give greater protection to human health…”

“Suspended sediment is probably the largest single pollutant in New Zealandrivers, wetlands and estuaries. This will need to be incorporated in the

NOF…This may require separate bands within specific river classes…Given the

importance of this attribute to life, numeric bands for DO should be developed

for wider applications in rivers.”

“MCI included, N set at ecosystem health (rather than toxic levels), contactrecreation…”

“If this (MCI) is not included in 2013 (it should be) then it needs to be in by

2015.”

“The NOF should include more ecological (biological) indicators of ecosystem

health…The NOF doesn’t deal with biodiversity or the loss of ecological health

due to invasive species.”



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“Invasive species (exotic pest fish and aquatic weeds)…These have a verysignificant impact on ecosystem health, they can be managed and as yet have not

been included in the NOF. Indices of invasive species are available as part of the

NEMAR process so could be included in the NOF at a future stage.”

“There are other values that are not necessarily protected by the limits proposedfor compulsory objectives. For example, ecosystem health may be maintained

according to the list of indicators, but the abundance of eels or trout at a site may

not be sufficient to support valued fisheries.”

“In the NOF there is a strong emphasis on water chemistry variables and

relatively weak emphasis on what is actually effected i.e. the flora and fauna.”

“The NOF and NPS focus on medians, means and percentiles and ignore temporal

ecological variability/stability, which can be an important indicator.”

“The NPS/NOF framework doesn’t have a clear implementation pathway (this isdistributed to councils) nor does it have legal “teeth” (eg the RMA) to safeguard

freshwaters.”

“…I’m comfortable to some extent with decisions on waterbodies being made at alocal/regional level, but I think there needs to be strong central guidance on how

the NOF framework should be applied at a regional level….There is alsouncertainty about the time-scale required to reach targets in situations where

water quality is degraded. In some cases, it may take decades/centuries to reach

the targets…Again some strong central guidance on the time-scales for meeting

objectives would be helpful…There is considerable uncertainty at present in theproposed amendments to the NPS around what scale should be used for ‘water

management units’. Some more central direction on this would be helpful.”

“…I think the NPS/NOF legislation is basically sound and innovative legislation

and will produce results (with …provisos…)…One proviso is that those water


formally and protected from degradation up to the NOF bottom lines.”



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Question 3: Can you give examples of water bodies that you believe need

improvement but could be left untouched by management agencies because

they are not currently violating the NOF bottom lines?

There was disagreement among the panel on whether this was a meaningful

question.

However where a waterway is not currently in the NOF (eg estuaries) or is not

currently monitored at all, it would seem reasonable to say these waterways are

at risk of being omitted from active management and deteriorating as a result.

Other examples were given by panel members.


“This question suggests all water bodies should be restored to conditions priorto land use change. Desired water quality end points (values) should be

determined by the community not scientists. More relevant is whether some

existing (eutrophic) systems can ever meet the proposed guidelines for

ecosystem health and if so, at what restoration cost (for example, shallow

eutrophic lakes in highly modified catchments.”

“..The answers to this question can only be taken as individual opinions. They

carry no more weight than any other community member’s opinion.”

“…another leading question.”

“Most lakes that are approaching the NOF bottom lines probably need immediate

attention from management agencies because the bottom line is defined as the

acceptability boundary….”

“Many of our urban waterways may not breach NOF bottom lines, however, they

are highly ecologically degraded. The bottom lines are generally extremely

degraded.”

“Estuaries are a prime example…They are currently not in the NOF but in effect

are receiving water bodies for almost every catchment and aredeteriorating….Wetlands continue to degrade and disappear in spite of theRMA.”

“Most lowland rivers and streams in New Zealand in agriculturally developed

catchments have high DIN and DRP concentrations that are not currently

addressed by the NOF. The smaller streams are particularly at risk because they

are not monitored as frequently as large rivers.”

“I am concerned about sites where trends indicate statistically significant

degradation of water quality, although current levels are not violating the NOF

bottom lines. It is possible to predict how long it might be before sites drop intoanother band or drop below bottom lines. It will undoubtedly be easier to avoid



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breaching the relevant limits or bottom lines rather than try to rehabilitate the

system. Examples of this are the lower Motueka River and lower Hurunui River

where nitrate concentrations have been increasing over the last 20 years, but ae

still relatively low.”

“Hurunui and other Canterbury water bodies will slide to being some of theworst in the OECD for N – as the bottom line in the PCLWP is based on a N limit

of 3.8 mg/l (acceptable in the proposed NOF standard).”

“Manawatu River, Waikato River, Ruamahanga River.”

“..The concern should not relate to whether there is a trigger for action butwhether there is too much movement within a band so that by the time a decline

is identified (ie a change of band), the ‘wheels are already in motion’ and thetrend my be difficult to reverse or take substantial time to do so.”



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Question 4. Given lags and uncertainties in the science and modelling, how

would you apply the precautionary approach (wherein we act in a way that

doesn’t see waterways deteriorate to an unacceptable level) to the NOF

process?

The panel agrees:

1. The best approach is to have tools that can be responsive to new information

(adaptive management) acknowledging that there is also a need to provide some

certainty too as this underpins investment in new technologies (an economic

analogy would be use interest rates to manage the business cycle, not

government spending which has long lags). (notes from SG: this would imply a

cross-party accord is needed on fresh water management goals, the allocation of

authority, and accountability but tools that can be fine tuned should be used to

deliver on the goals).

2. The most important risk is the loss of waterways to irrecoverable states. This

is an asymetric risk (under-achieving the goal is far worse than over-achieving).

3. This asymmetric risk can be managed through:

- including margins for error in Band C and D definitions (ie err on the side

of caution when setting Band C and D values and attributes). This is

especially the case when the nutrient in question may not impact on

water quality for decades.

- adopting adaptive management

4. We need to know more about historical and contemporary land use in NZ and

the relationship between changing land use and water quality.

5. While there was disagreement about how much reliance should be placed on

ecosystem modelling in its current state, no-one seemed to suggest that action

should be avoided until such time as the modelling is perfected.


“Need robust and representative monitoring regimes of both pressures (eg landuse) and state (ie indicators relating to NOF values) and objectives, policies and

tools in regional plans that trigger responses when trends emerge (adaptive

management).”

“Ideally this would involve a process of staging development changes at a pace

that allows for monitoring regimes…to monitor the effect of the changes, and

enable adjustments to be made before unacceptable effects occur. However,

sometimes the scale of investment requires some certainty to proceed, in which

case staging development and monitoring impacts will be limited in its

effectiveness and other strategies and value judgements of the risks need to be

considered carefully.”



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“Apply an adaptive management approach in which all water quality objectivesand management actions for each water body are regularly (i.e. every 5 years)

reviewed and updated based on measurable water quality trends and outcomes.

This approach requires the development of an integrated catchment

management plan for each water body in New Zealand.”

“This is a complex question. Ideally the precautionary approach is one of

adaptive management and robust monitoring of status and trends…Howeverstakeholders are averse to uncertainty and so there is great pressure on

governments/councils to provide certainty/stability around environmental

regulations/targets….Yet in a situation of imperfect knowledge about

environmental impacts on freshwater systems (especially when dealing with

individual lakes and rivers), adaptive management is the only prudent way

forward…Thus we have a serious regulatory dilemma.”

“The best approach will be situation specific and relate risks and benefits given

the undoubted uncertainty in both. Further development of approaches for

comparing short-term benefits with long-term costs would be helpful.”

“A precautionary approach would do exactly that – be cautious of any changes in

activities that could lead to deterioration. It also points to the need to improve

monitoring and modelling so that trends can be more readily identified and

acted upon. In some cases we already know systems that are strongly influenced

by groundwater inputs and therefore have long response times. These should be

heightened sensitivity, ie a higher precautionary approach, adopted for these

systems.”

“Attribute values at the bottom of the C band need to provide sufficient buffer

between minimum acceptable state and ecological tipping points so

that….appropriate interventions [can be] undertaken, before irreversible effects

occur. Set limits that are sufficiently conservative to provide for under-

estimation of effects, and, most importantly, ensure that communities setting

water quality outcomes for their freshwater resources understand the

uncertainties…provide a policy framework that allows for rapid responses to

both measured and modelled changes in water quality…”

“For the NOF just set realistic bottom lines ….and make sure all rivers are

brought above that in the net 20-30 years.”

“It may be possible to consider “interim numeric bands” by including some ofthose attributes listed but currently not included in the NOF, on a trial and

review basis….However I suspect the legal ramifications, if interim numeric

bands ends up in the Environment Court, will make this impractical.”

“Greater use could be made of overseas approaches to setting water quality

criteria as interim NOF limits…”



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“I accept this is a tough one. I think the challenge here is less about current

waterways deteriorating further and more about the difficulties Councils will

have in fixing waterways that exceed the bottom lines.”

“I am extremely concerned about the “reliance” on modelling approaches. Many

models of freshwater systems perform poorly but are being “sold” as providingaccurate predictions…”

“This question raises an interesting point. It assumes that the “lags anduncertainties” in the science and modelling are so large that we cannot use or

trust our science and our models for guidance in making reasonable

management decisions and enforcing management regulations. For sure, there

are issues with the breadth and depth of our knowledge and science and there

are uncertainties associated with our modelling. However, these are often

overstated and often used as an excuse to delay taking action.”



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Question 5: Water quality is a complex issue, and we are devolving

important decisions to lay people in a large number of community

processes. Meanwhile we have a small pool of qualified experts to assist

these processes. How can we ensure the proposed processes will be based

on the best possible scientific understanding of fresh water management?

The panel agrees:

1. It is beneficial for scientists to be involved in central government policy

setting. Their role is to ensure scientific knowledge is reflected in national water

management policy. Scientists have a clear role in local water management too.

2. The relationship between communities and scientists is not very clear. While

communities are clearly having more involvement in local water management

(and thus there is growing demand for science input from communities) the

ultimate water managing authority remains with councils, not communities.Communities may be given responsibility for expressing community values but

they need scientific knowledge to be able to make value choices, so scientists will

impact on these choices too.

3. It is important to identify and actively develop the skills and knowledge

needed among scientists to fulfil their function in community processes, and

resource this development adequately. These skills are currently in short supply.

4. Scientific objectivity is vitally important and a concern for some on the panel.

Scientists must stick to science when asked to help in the design of policy (ateither central or local government). The scientists can be drawn from all sectors

but a scientist’s involvement must be dependent on their advice not being

coloured by their sector’s interests or their own private gain.

For example, if scientists employed by the horticultural sector are asked to

assess a policy they must base their assessment only on the policy’s likely impact

on water quality, not the impact of the policy on profits within the horticultural

sector (or the probability of on-going consulting work if the scientists are

consultants).

Some panel suggestions:

1. If objectivity is not possible then scientists giving input into central

government policy and local decision-making could be brought together into an

independent body and funded appropriately (in such a way that they are not

reliant on one sector).

2. Use the scarce supply of scientists where it has most effect (for example,

early on in the planning) and pool this resource where possible (eg one national

group could provide timely advice to regional councils on specific issues).



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“MfE, MPI and DOC…are to be acknowledged for the extent to which they have

included the science community in the development of the NOF to date. It

obviously needs further development but a very few years ago this involvement

of the science community on policy formulation would have been unthinkable.We need to ensure the science community is kept as involved as

possible….researchers from across the spectrum of academia, CRIs, industry and

government agencies.”

“The Land and Water Forum was a model of how that can be done. I would like to

see that continue with further input to legislation and making use of the pool of

expertise to provide necessary advice.”

“National coordination of some efforts may be possible, although many queries

arising from community processes will be site-specific.”

“The current system does not use our national expertise efficiently or wisely.

Processes like this panel are rare, where multiple scientists from multiple

agencies share views. Too often 1-2 scientists are consulted rather than groups

of scientists.”

“This is a real challenge, although we need to appreciate that in communityprocesses decision-making itself is not devolved, but still lies with the

authorising agencies like regional councils – indeed such decisions have always

been made by lay people, usually elected councillors.”

“Decisions on water quality policies ultimately sit in the RMA process with

council appointed commissioners or… judges…I don’t agree that we aredevolving important decisions to lay people.”

“..limit-setting processes are inherently valued-laden – only communities of

interest, both national and local, are well-placed to make those judgements, but

in doing so need to be informed by the best-science available.”

“The process should conceptually and practically provide for community input

regarding community fresh-water values. However lay people sometimes have

limited understanding of ecosystem functioning and ecological values…scientistswill have a clearer understanding of these environmental obligations and

therefore the process should also ensure that scientists provide input into the

prioritisation of ecological values….scientists should play a bigger role in

educating the public specifically on why certain ecological values, which may be

hard to grasp by lay people, are so important to safeguard.”

“This is probably my primary concern. The community-based decision-making

process relies strongly on expert knowledge to help with scenario

development…I have concerns that this need might simply overwhelm the

available scientific expertise, tax communities or councils who may not be ableto afford the detailed work required, and there may be difficulties with



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replicating complicated techniques and methods (eg modelling) for all water

catchments.”

“The role of scientists as translators and communicators, well-equipped to

participate in cross-disciplinary community engagement processes, needs to be

recognised and promoted. The science community has a responsibility toencourage and develop the skills needed to undertake this new type of dialogue.

At the same time, investment in the science fundamentals critical to defining

bottom lines and breakpoints, and in limit-setting – catchment modelling,

scenario building, community envisioning and deliberating, integrating

biophysical, economic and social systems – must be accorded the right priorities

and adequately resourced.”

“Research is underway on how best for science to engage with these communityprocesses. The relatively large number of regional council freshwater scientists

can potentially have an important role to play in this, although some

stakeholders will prefer to have access to scientific advice that is seen as more

independent. Some councils are setting up science advisory panels now.”

“We also need to bring the best people together into a team to develop guidelines

centrally for freshwater management to be used by regional authorities and the

local people working within collaborative processes. This group needs to act as a

central resource to provide timely assistance ‘on tap’ and to provide analyticalcapability…This team needs to be run efficiently and…with the independence

and support needed to get the job done….at arm’s length…from central

government.”

“My strong view is that we do indeed have a very small pool of qualified people

who are professionally competent and experienced in the areas of freshwater

ecology, freshwater management, farm and catchment modelling….and also

people who can create good and workable policies for freshwater management.

This is at a critical stage and needs to be addressed promptly.”

“..get scientists around the table early in the planning process and agree on

issues and potential solutions…”

“These experts need to be truly independent of industry, and also not in receipt

of “funds from industry”. A …panel of scientists funded by a truly independentorganisation who consider current water health and future water health for all of

NZ is the only way to ensure they present unbiased approaches to protection of

water quality, health, and amenity for current and future generations…”

“Ensure scientists used are totally independent”.

“The role of qualified experts should be to provide scientifically robust and

unbiased understanding to support the value-setting process by the

community…”



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“Often councils rely on consultants for their advice. This system has significant

drawbacks as the quality of consultants knowledge and ethics can be highly

variable. Many consultants are driven by money rather than the best advice.”



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Question 6: what do you consider to be a realistic long-term (30 year) water

quality goal?

The panel agrees:

1. A suitable long term goal relates to:

i) ecological conditions or states which must be met or bettered (eg fewer

waterways breaching ecological bottom lines);

ii) water quality trends (eg water quality must be maintained or improving); and

iii) processes (community values must be underpinning water management, the

scale and timeliness of monitoring and interventions must be appropriate).


“Groundwater and surface water quality leaving every property meetsacceptable limits so that water quality is no longer the most important

environmental issue identified by the public. Maintain and improve water qualityin every region of New Zealand so that less than 10% of our lakes are eutrophic,

less than 10% of our rivers have unacceptable periphyton blooms, toxic

cyanobacteria blooms are rare, wetland areas have increased and, in every

region, E coli levels in 4th order and higher rivers are suitable for swimming and

kayaking.”

“Make sure all rivers are brought above realistic bottom lines in the next 20-30

years.”

“All major water bodies meeting attribute state B o better. That includes rivers

with mean flows of 25 cumecs or more and medium sized lakes. Within 50 yearsall lowland streams and small lakes should aim to be at that level.”

“..in 20 years NZ has succeeded in maintaining and further expanding thenumber and coverage of a significant and representative ‘portfolio’ of

‘outstanding’ freshwater bodies that are in a pristine, or more realistically, a near

pristine, natural state of ecosystem health. This will represent NZ’s repository of‘natural’ freshwater resources that we leave in perpetuity to future generations.

…Alongside this…we will inevitably have a system of ‘developed’ waterwaysthat…will, however, all be at the de minimus level of the NOF bottom lines for

water quality or better. The range of water quality values achieved within thiscategory….and the extent of such waterways….will be the result of the balancestruck between the national bottom lines and the outcomes of regional processes

and the aspirations of local communities.”

“..our high value freshwater systems remain as such and that in the highly

modified environments (both urban and rural) we have successfully

implemented the means of maintaining and improving our freshwater systems

within our working/living landscapes.”

“…the long term goal should be to prevent further degradation of water quality

and ecological conditions through effective management and to improve orenhance water quality and ecological condition where desirable and



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feasible….These goals are laudable because they place restrictions on the ability

of our present society to ‘steal’ resources and development potential from futuregenerations…We should make sure that NZs natural capital remains intact for

future generations…while we try to maximise the current productivity that wecan get out of the natural capital. This is the basis of the concept of sustainable

development…”

“The goal for the next 30 years must be to try to halt the decline in health of allfreshwaters (lakes, rivers, groundwater and estuaries). All waterways must be

swimmable, fishable and support naturally functioning ecosystems suitable for

gathering food, and groundwater safe to drink.”

“Water quality should meet the goals and aspirations of most New Zealanders,allowing a balanced range of ecosystem services to be optimised without

compromise to opportunities for future generations, excessive costs imposed

from restoration and biodiversity to be improved…The quality of waterdistinguishes New Zealand from much of the rest of the world.”

“Community (including iwi) aspirations for water quality are clearly articulated,

and water quality management decisions give effect to those aspirations. Water

is of sufficient quality to provide for community needs and values in all but a

handful of localised situations. Trends of declining water quality have been

stabilised and in many cases reversed. In general, water bodies support healthy

and resilient aquatic ecosystems and, where anthropogenic influences are

discernible, sensitive species are still present.”

“Maintain and improve the quality of our freshwater ecosystems so they support

the range of values and ecosystem services sought by our community.”

“An integrated catchment management plan for every water catchment in NewZealand. Each plan should be based on community-agreed values and set clear

management objectives, actions and measurable end-points. Plans should be

regularly reviewed and updated…”

“Every catchment in New Zealand will have an integrated catchment

management plan in place that identifies specific, measurable, achievable and

time-bound objectives that give effect to a suite of community-agreed

values…Within the plan there is clarity over acceptable water quality…and [a]representative monitoring network that allows resource managers to track

achievement of objectives and identify emerging issues. Resource allocation

limits are in place to provide certainty to resource users and community alike.”



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Question 6a: What actions should be a priority to achieve the 30 year goal?

There was agreement on high level issues and a variety of detailed suggestions

about what should be done. One suggestion for example, is to identify waterways

that need urgent/special treatment and consider moratoriums on land use

changes and/or stocking levels to protect these.

The panel agrees:

1. NZ needs to invest more in research and innovation so that we have a greater

understanding of freshwater processes and have more effective tools with which

to intervene/influence outcomes.

2. More comprehensive, timely and relevant monitoring and reporting is needed.

3. We need to know more about historical and contemporary land use in NZ andthe relationship between changing land use and water quality.

4. Policy needs to support communities to adopt changed practices if that is

required to meet water quality goals.

5. Keep developing the NOF as a matter of urgency, and clarify (and develop

further if necessary) what ‘maintain and improve’ means.


“Transparent and regular reporting of freshwater ecosystem health at asufficiently fine scale to be meaningful…building on the LAWA initiative.”

“Improve state of the environment monitoring and reporting (include moreecological indicators in addition to the current water quality indicators). Identify

and articulate environmental values for lakes, rivers, wetlands, aquifers and

estuaries. These values must come from communities as well as

scientists/experts… Develop catchment plans…Freshwater management andmonitoring approaches should be catchment based, not piecemeal (ie not lakes

considered in isolation from rivers…)…”

Develop “integrated catchment management” plans “as quickly as possible.”

“Implementation of objectives and limits for all waterbodies with reasonable

timelines to meet targets in situations where ecosystem health is currently

degraded.”

“Get cracking with the limit -setting process set out in the NPS”.

“Adopt the NPS and NOF and ensure that councils adopt its principles.”

“Investment in further understanding of options for critical improvements.”



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“Sufficient funding available to develop and implement freshwater ecosystem

rehabilitation tools to speed up improvement efforts.”

“Increase scientific research and availability of scientists to assist with providing

science to communities for the purpose of the NOF.”

“Grow the human resource including water quality scientists, modellers,

software developers, ecologists, trained and certified nutrient management

advisers, economists, policy makers…”

“Improved knowledge of water resources, including systematic approaches to

water management units, groundwater-surface water interactions, system lags

and inter-dependencies,…the characterisation of multiple stressors on aquaticecosystems, and the ongoing development and refinement of bottom lines for

key drivers of water quality….better tools for deriving water quality

limits….Improved knowledge of current and historical land uses at catchment,farm and paddock scale and tools to link that knowledge to water resource

models…”

“Strengthened recognition of the effects of land use and associated poor

freshwater ecosystem health on downstream coastal and marine ecosystems.”

“Develop efficient and effective ways of managing anthropogenic impacts (eg capand trade, limit setting). Invest in R and D for improved mitigation…”

“Provide assistance to and open innovation pathways to science agencies to

develop new technologies for farming to reduce contamination in waterways.Develop new technologies that allow real-time decision making on the farm and

by regulatory agencies that influence farm environmental impacts and provide

early warning….to allow rapid mitigation.”

“Establish robust monitoring, reporting and verification systems for nutrient

discharges and water quality parameters… All farms above an agreed thresholdof size and nutrient inputs to have an auditable nutrient budget. Systems will

need to be put in place to facilitate the return and auditing of these budgets,

similar to income tax returns…”

“Support the implementation of catchment processes that engage the community

to understand the issues and identify and own the solutions. Support

community/relevant industries to implement the solutions effectively.”

“Reward NZ primary producers for their investments in developing and

implementing successful farming practices that build and vibrant and profitable

agricultural sector…through developing an internationally recognised ecolabel

that demonstrates the credentials of NZ primary producers….”

“Recognition by the science community that collaborative community processes

reflect the democratisation of science and require new ways of engagingcommunities in debates that require significant scientific underpinning. The



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development of new skills is necessary…translation of large amounts of complex

technical information is a central responsibility.”

“Establish as soon as possible a National Technical Advisory Group to act as a

central resource to provide timely technical assistance, guidance and analytical

ability “on tap” to regional authorities….This Group needs to be adequatelyresourced and run efficiently and pragmatically with.. independence. The Group

should be drawn from various organisations and include scientists, economists,

policy makers and a senior government off icial….”

“make community participation in the development of regional land and water

plans mandatory in all regions.”

“Further develop the NOF attributes to ensure the values of Ecosystem Healthand Human Health are considered acceptable by the community at large.”

“Produce ‘Version 1’ of the NOF values as soon as possible using the 80/20 ruleand promulage these values to the regional councils with guidance notes….When

in doubt conservative or precautionary NOF bottom line values are to be used for

some waterways until better data are available. The NOF Version 1 is then

updated annually with input from a standing Technical Advisory Group.”

“Alter the NPS-FM to ensure that the “maintain and improve water quality”requirement in the NPS applies to every Water Management Unit in every

region.”

“Greater government intervention eg redirecting the EPA [towards] investigatingand enforcing national water quality standards.”

“…central and regional government must make greater use of rules (less reliance

on voluntary actions) with suitable inducements and punitive measures to both

reward and encourage those who comply and punish those who do not. We have

a legacy of reliance on voluntary actions that simply has not worked.”

“…strong bottom lines need to be made clear and rigorously enforced in the

interim. Reduced N leaching and P/sediment and pathogen loss through careful

farm system configuration to profitable and low risk systems.”

“Stop subsidising externalities…Implement user pays.”

“Stop indirect subsidies that perpetuate practices of diffuse pollution and

develop economic models that account for all costs in agricultural development,

including social, cultural and environmental.”

“Detailed scrutiny of any plans for land use intensification and the onus on

developers to prove that any development can be done sustainably.”

“National moratorium on wetland drainage, with enough legal grunt andspecificity to avoid drainage of even small ephemeral wetlands.”



“No new intensification of agriculture on highly erodible or if on porous or

erodible soils unless it has advanced mitigations and proof that deleterious

effects are being intercepted.”

“Define sensitive water bodies in every region, develop management plans forthese individually (eg as has been done for the Rotorua lakes) and restrict

activities in their catchments to ensure their values are maintained.”

“Enshrine in legislation a list of ‘outstanding’ freshwater bodies to be protectedin perpetuity in a natural state. Any such designated water bodies not already in

a natural state to be managed to achieve this in a reasonable time. Private

landowners should be encouraged and incentivised to gift land the associated

freshwater assets….”

“Reduce stocking rates to a level that will protect waterways (Lake Taupo is agood example), enforce existing regulations, take a catchment approach, remove

grand-parenting of nutrient allowances, get rid of “single nutrient

management”…”

science panel round 3 - myriver

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