Improving Aotearoa New Zealand's environmental reporting system

Yes – we would find benefit in clearer direction being provided. This is not just in regards to why reporting is needed, but also:
• what needs to be collected, and where (noting the value of continuing to be able to monitor trends at existing locations, and opportunities to expand to provide a better national picture),
• how it will be collected (and from whom),
• how is it contributing to Treaty responsibilities, and
• what is intended to be achieved (including opportunities for the environmental reporting to serve multiple purposes).

Yes - a requirement for a Government response would increase accountability. We agree this response should be required to include:
• what policies and initiatives currently exist,
• what new policies and initiatives are proposed or planned, and
• what policy analysis the Government proposes to undertake to identify any other policies and initiatives that are needed.
It should also outline what improvements are expected as a result of the above. We see the benefits of integrating a whole of Government response across agencies, coordinated by the Minister for the Environment.

Yes – understanding the drivers that cause pressures on the environment plays a key role in determining how to respond to issues. However, meaningful drivers rely on access to reliable data sets, so a greater understanding of how drivers will be identified is required. If adding drivers to the framework will involve collecting data off local authorities then further consultation will be required. While this remains uncertain it is not possible to provide a robust response regarding resourcing and cost implications.

In addition, Regional Councils would benefit from having access to the datasets of other organisations that are used to determine drivers. Open data can assist in achieving the improvements being sought by MfE.

We question how climate will be incorporated into drivers. Work we have done on attributing state and trends to drivers has shown climate (including the Southern Oscillation Index) to be a large factor. It would be useful to have robust methods to be able to separate human induced drivers from natural factors. This is to to assist with tracking human impact, and the information can then be used to drive action for change.

We have no comments to provide.

We support the establishment of a standing advisory panel that includes a representative who can provide expert advice on behalf of regional councils. The Regional Sector Science Advisor would be well suited for this role. We also see a need for appropriate representation to ensure expert advice is provided in relation to mātauranga Māori. Value may be able to be added to the advisory panel by considering grounded perspectives from citizen science and community action groups.

We agree that reporting in the confines of an individual domain can result in an incomplete picture of the environment. We support a theme-based approach to achieve a more holistic understanding of key issues. However, we don’t believe the proposed themes are correct. We suggest that ‘land and water’ should be combined as one of the themes due to the effects of land on water. Other themes could include ‘climate and air’, ‘biodiversity’ and ‘pollution and waste’.

Yes – we agree with six yearly synthesis reports. This frequency of reporting will be better suited for identifying trends, including whether responses to changes are making a difference. A reduced frequency of reporting should free up MfE resourcing to achieve more robust data monitoring and more comprehensive reporting.

In principle, we support a move to less frequent but better quality reporting, for the reasons provided in response to Proposal 7. We raise a question regarding how the annual commentaries for Year One to Year Five will feed into the synthesis report: Will the Year Six synthesis reports be solely reliant on the data contained in the five theme-based reports prepared over the five year in the lead up? If so, we are concerned that more up-to-date data will be excluded, and data that is four or five years old will be relied on in some instances. If trends are available from subset years it is important to make them available for governance direction.

Opportunities to incorporate automated reporting should be investigated as part of the conversation on reporting frequency.

We do not agree with MfEs preferred option. We are not convinced that Option 1 would have a greater benefit than Option 3. Option 3 (to specify the core indicators in regulation, as opposed to allowing flexibility) provides the most clarity. Local authorities require assurance as to what core indicators will be because changes to monitoring requirements can have significant resourcing and cost implications (and possibly LTP budgeting implications). Local governance will use this information to assist with setting directions and making decisions on investment.

It is also essential that local authorities are consulted when core indicators are being chosen, and that existing data being collected (including consistencies across local authorities) is fully understood. There are benefits in allowing for the continuity of existing monitoring. Additionally, standards-based indicators with published methodologies should be given weighting when identifying indicators.

It is uncertain what level of involvement and additional data collection will be required from local authorities; therefore it is not possible at this stage to provide a robust response regarding the costs to local government and ratepayers. It may be appropriate for a funding model to be developed by MfE, to include resourcing for the regional sector to support additional information reporting requests.

We agree with MfEs preferred option to request information from outside sources, such as local authorities, as opposed to requiring it. This is due to the ability for the data to be used for additional purposes under this approach (as opposed to the embargo that would otherwise apply). Incentives to encourage participation should be considered.

We support the intent to strengthen mātauranga Māori environmental monitoring through a robust engagement process between the Ministry and Māori. We don’t presume to have mātauranga Māori knowledge and expect that MfE will engage with all iwi in our region (and resource iwi to participate).

Engagement with Māori in regards to Proposal 10 and data sovereignty will also need to occur, acknowledging that for many people their information is a taonga to them.