Your details
6. If on behalf of an organisation, what is its name?
Name of organisation
Lynker Analytics Ltd
Part 2: Opportunities and objectives
1. Would you add any issues to this list?
Please select one item
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Yes
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No
2. Which of these issues are the most important to fix? Why?
Please explain your answer here
Issues 3 - Inconsistent and deficient data and knowledge is the most important one to fix because understanding the complex connected environmental system requires a well put together and coordinated measurement and data gathering system. This requires councils, NGOs, academia/CRI's (researchers) and government (and all of their contractors) and the private sector to be working in a coherent way using consistent and proven tools. This issue can be designed to include (4) be enabled by (2) and deliver (1) - the latter two are easier and more policy than evidence.
3. Are these objectives the most effective for improving environmental reporting?
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Yes
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No
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Unsure
Part 3: Proposals for environmental reporting
4. Do you agree with the proposal to expand the purpose of the ERA to include the reasons why we need environmental reporting?
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Yes
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No
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Please explain your answer here
In itself the existing purpose statement is not fit for purpose and does not achieve effective stewardship of the environment. The proposed expansion achieves this.
5. The initial preferred option for this proposal sets out four points. Are these a suitable basis for a purpose statement? What changes, if any, do you consider are needed to focus, expand or improve them?
Please explain your answer here
In the first point I would add "standardised where possible" state of the environment reporting with a goal to get higher quality national thematic data. The goal of the 4 points should be to gather high quality longitudinal indicator data suitable for all of system and domain e.g. marine specific analysis, investment and decision making.
6. What should the purpose include, to reflect te ao Māori values and perspectives?
Please explain your answer here
Environmental well being from a te ao Maori perspective needs to be enshrined in the purpose statement. This includes using the concept of mauri as the measure of sustainability.
8. Do you agree with the proposal to require the Minister for the Environment and other relevant Ministers to release a staged response to synthesis reports?
Please select one item
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Yes
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No
Please give your reasons
The threat to society, economy and overall well being from compounding environmental pressures is such that this is the only option. Using the OECD definition of the environment, which includes all of the external conditions affecting life, the cross sector/portfolio implications of a synthesis report need to be understood in the context of a complete wellbeing framework.
10. Should the ERA specify the layout and style of a government response?
Please select one item
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Yes
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No
11. If the Government is required by the ERA to respond to a synthesis report’s findings, is anything more needed? If so, what?
Please explain your answer here
Policy steps to address specific risks and headwinds for example waste management, carbonised energy regulations, transport programmes. A synthesis report needs to make specific recommendations based on robust data and science from which policy decisions can be weighed in the context of impact on society.
12. In what way could a formal response adequately address the needs of te ao Māori?
Please explain your answer here
The Maori world view should be considered in a synthesis report recommendations. Environmental risks or the interpretation of risk in both western and te ao Maori may differ so these should be presented separately where required. Ministers however mist respond to the report findings appropriately.
13. Do you consider a response is necessary for all environmental reports or commentaries specified in the ERA (that is, not just synthesis reports)?
Please select one item
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Yes
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No
If yes, why? Please explain your answer here
Having said that, occasionally a domain or in-cycle report may also warrant government response or an intervention. For example if an indicator moves to a heightened level of risk we cannot wait for a synthesis report to act. One would assume the relevant ministry will retian this focus year on year but some facility to initiate a government or minister level review would be advisable in this scenario.
15. Do you agree with the proposal to add drivers and/or outlooks to the reporting framework?
Please select one item
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Yes
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No
Please give reasons here
Adding drivers and outlooks better reflects the complexity and inter-connectedness of the systems. Outlooks will enable new scientific understanding to be considered and projected onto issues and indicator reporting.
16. What benefits or drawbacks do you see in including drivers or outlooks?
Please explain your answer here
Not all drivers may be clear or identifiable. The system is complex with multiple feedbacks which may mask drivers which may lead to inappropriate decision making. This comes back to investment in data, standards and coordination ensuring robust data for holistic system assessments. On balance we should trust the science and be prepared to make decisions even if some of the projections are not clear.
20. Do you agree with the proposal to adjust the roles and responsibilities of the Secretary for the Environment and the Government Statistician?
Please select one item
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Yes
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No
Why? Please explain your answer here
A joint role is unclear and may lead to confusion as well as difficulties in measuring outcomes and holding any one group to account.
21. Should the ERA state that the Secretary for the Environment and the Government Statistician may/must invite Māori to take part in preparing environmental reports? Why?
Please select one item
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Yes
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No
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Unsure
Please explain your answer here
Maori along with other key groups e.g. local government and other experts should be invited to take part in preparing reports
22. Do you consider there are broader roles and responsibilities for Māori under the ERA?
Please select one item
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Yes
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No
If yes, please explain your answer here
I think a consistent Maori world view needs to be presented and articulated in the reporting. It cant be only in the synthesis report nor should it be uneven in terms of coverage in domain reports. Treaty issues and te ao Maori should be considered as an ongoing perspective for decision making.
23. Do other agencies have roles and responsibilities related to environmental reporting that in future should be specified in the ERA?
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Yes
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No
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Unsure
Please explain your answer here
I wonder whether regional councils should have a specified role. They generally have the most intimate understanding and data series on environmental issues, indicators and investment plans at a local level. A joining up of thinking and roll up of regional council data and knowledge to the national level would be helpful. Perhaps some sort of legislative reporting system for regional councils to report data in a standardised way might work.
25. Do you foresee any problems with the proposal to make it a statutory requirement to establish a standing advisory panel under the ERA?
Please select one item
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Yes
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No
26. What range of perspectives do you think the standing advisory panel needs to include?
Please explain your answer here
A range of perspectives. te ao Maori is important but equally skills in specific areas like climate change adaptation, marine spatial planning, invasive species and ecosystem services will be essential. Also important will be links to groups like NZ Tech who can advise on advances in technology like AI and IOT technologies to scale up the data, measurement and analytics systems.
27. What responsibilities should the standing advisory panel have?
Please explain your answer here
Advise on data problems, inconsistencies, analytics, comparability to other jurisdictions, technology opportunities, research and development and risk profile of specific indicators. This group is critical and a panel approach should be used to maintain and refresh expertise in New Zealand to ensure our reporting system remains fit for purpose and innovative.
29. What are some pros and cons of a theme-based approach for both synthesis reports and in-between commentaries? Should another approach be used? If yes, why?
Please explain your answer here
A theme based approach will be restrictive at times and constrain reporting to a subset of the connected system. Generally speaking a science based approach should be taken for in between commentaries for example wetland ecosystem reporting will consider land use, water quality, invasive species, waste and consider a changing climate. Attempting to just report on land use would not provide the focus needed when reviewing the value of these services. I advocate the thematic reports be focused on indicator areas and consider the environmental forcings in totality. The synthesis reports need a more formulaic approach based on robust data and statistical parameters allowing longitudinal studies.
30. Do you think the themes in Environment Aotearoa 2019 (table 2), or those proposed by the PCE, or some other themes are the right ones to use? Are they broad enough to give certainty for future environmental reporting?
Please explain your answer here
Generally the themes are good and represent the major areas of focus and investment however the crossover between themes will need to be considered. Somewhere in between cycles there should be room for assessment of indicator or critical areas for example: freshwater fish stocks, indigenous forest, wetlands, soil health and condition, wilding pines, mammalian predators etc. Each of these are issues impacted by all themes.
31. What themes are appropriate for te ao Māori? Should te ao Māori be considered as a theme?
Please explain your answer here
No I dont believe so. This again separates te al Maori as independent of the challenge instead of being implicitly part of the reporting system.
33. Is six-yearly reporting an appropriate interval for synthesis reports? Which timeframe do you prefer, and why?
Please explain your answer here
No 6 years is too long. This seems to have been suggested due to the burden of acquiring sufficient new data for new analysis. If the data gathering system is more streamlined, standardised and powered up with AI and IOT sensors plus better integrated cross sector research then more frequent change detection and analysis of policy will be possible. A 6 year cycle will mean a 9 year decision cycle given ministerial reviews, consultations and budget cycles. A 3 year synthesis report should be the target supporting regular scrutiny and budget review by incoming and returning governments. The data and reporting system will then fall into line and issues identified can be considered more quickly and effectively.
34. In your view, have we overlooked any costs, benefits, risks or opportunities?
Please describe these and any mitigations
Opportunities exist with AI and other advanced technologies to better surveil, analyse and project impacts of stressors. NZ has an opportunity to unite our research and science and engineering industry to tackle these threats and find solutions. The SFFF has for example been used effectively to develop new methods to mitigate environmental problems, identify new products or accelerate measurement of data or fill gaps in our data system. These programmes could be aligned and focused through an invigorated reporting system that is more agile and responsive to the data and best science.
35. What are some pros and cons of changing the frequency of in-between commentaries to a priority basis, with no mandatory coverage of all themes in a reporting cycle?
Please explain your answer here
A expert panel based assessment year on year is a better approach. The three-yearly synthesis will build a clear picture of the state of the environment and indicator data series. In between targeted reports (which might also be theme based) will be required and be more focused on a topic that will add value to the next synthesis report. There should be space for critical indicator reports that might arise due to measurement data crossing thresholds, or international reporting or other trend analysis that the expert panel will monitor.
38. Do you foresee any problems with the proposal to establish a set of core environmental indicators?
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Yes
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No
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Unsure
39. What are some pros and cons of publishing updates to environmental indicators outside the reporting cycle?
Please explain your answer here
I dont think there are many cons aside from any misinterpretation of data out of context but this can be handled with a standardised statistical reporting framework for all data. The environment doesnt operate on a 3 or 6 year cycle so if data are captured on key indicators these should be open and available for researchers and policymakers to use. The reports are an opportunity to provide an analytical overlay for decision makers considering other data series and context.
40. Should the indicators include topics based on te ao Māori and mātauranga Māori?
Please select one item
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Yes
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No
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Unsure
Please explain your answer here
A broad cross section of experts should be put together to define which topics.
42. Do you foresee any problems with the proposal to include provisions in the ERA to require the supply of data for national environmental reporting?
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Yes
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No
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If yes, please describe
This is critical to ensure the whole system works effectively. Commercial imperatives by CRI's or other commercial data providers are unhelpful and counter-productive. Critical indicator data must be open and free to serve the best interests of New Zealand and enable investment to occur not just from the Crown.
Part 4: A summary of estimated additional funding, benefits and risks
45. Have we correctly noted all the high-level costs and benefits of these proposals?
Please select one item
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Yes
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No
Are there any others? Please explain your answer here
Testing and developing new technologies, for example remote sensing, machine learning and IOT or edge computing based measurement may require additional r&d budget. It is likely that some of these new technologies will deliver new modes for improved national scale reporting but an experimentation phase may be required. This might also be covered through research programmes or elsewhere in ministry budgets.
46. What costs and benefits, if any, would any or all these proposed changes have for you or your organisation?
Please explain your answer here
As a consultancy and research organisation we would be supportive of a more robust measurement and data gathering system. We would be willing to participate in an enhanced data and measurement system, on an advisory panel and in report development if helpful. For the most part businesses like Lynker are more equipped to take on and operationalise novel research for example national land cover mapping than academia as our natural work environment is task and outcome based rather than publication oriented. Solutions in the private sector tend to be fit for purpose not fit for publication.
47. We are planning a full benefit-cost analysis after assessing all submissions. What, if any, information should we include in that analysis?
Please explain your answer here
An analysis of the cost/benefit of standardised gathering of indicator data by regional councils should be considered. It is important that data are comparable region to region and councils and their contractors adopting a standard method will be critical to this working well. Some sort of central register of methods, sensors, standard operating procedures, ML models etc should be considered. A coordinated dev ops or MLOps group may also be needed to if models and sensor based data gathering is to be applied correctly. Perhaps some programmes will be better to be run nationally but which ones? And how to Maori groups participate. Overall this analysis should weigh up these options to find a suitable starting point with ongoing review and refinement.
Integrating te ao Māori and mātauranga Māori in environmental reporting
1. How could Te Tiriti o Waitangi be reflected in the ERA?
Please explain your answer here
The ERA needs to centre tikanga and mātauranga Māori in the future reporting system — including data collection and labelling methodologies, clear indicators of success, impacts, and governance frameworks. In Aotearoa New Zealand, Whanganui awa and Te Uruwera have both been granted legal person status — that is, it has the same rights and responsibilities of a person. To bestow a river or land area with personhood rights is to give it the strongest possible protections within the legal system we have, and to come as close as is currently possible to legally honouring the centrality of te taiao to our lives and wellbeing. Our reporting system therefore needs to fundamentally address the Maori world view in its reporting alongside western science based analysis.
2. Should the principles of Rights and Interests, Partnership, Participation and Protection be stated or referred to in the ERA?
Please select one item
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Yes
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No
Please explain your answer here
These should be implicit in the reporting and governance frameworks put in place. Our indicators and the outcomes of these need to be measured in both a western and a te ao Māori worldview.
3. Manaaki Whenua’s report Reporting Environmental Impacts on Te Ao Māori: A Strategic Scoping Document proposes a Te Tiriti-based framework with five key principles: mana whakahaere, tūrangawaewae, whanaungatanga, taonga tuku iho and te ao tūroa. Do you agree with these principles?
Please select one item
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Yes
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No
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Unsure
4. How can the work of active kaitiaki contribute to environmental reporting?
Please explain your answer here
Projects like the Wellington region Mana Whenua whaitua plan to return mana to freshwater bodies and mauriOmeter are positive examples of work that can contribute to environmental reporting. More groups working in this mode coordinated and enabled by the revise ERA will be necessary.
5. If a Standing Advisory Panel was established: How should it be organised to ensure that te ao Māori voices are represented? What roles and responsibilities should representatives have to ensure te ao Māori is meaningfully represented in environmental reporting?
Please explain your answer here
I would include representatives from all key groups including Māori, local government, MfE, StatsNZ, CRI's, NGO's and business plus groups like NZ Tech and other relevant industry bodies. No specific structure is needed but a committee of thought leaders and positive collaborators will be required with annual refresh and rotation of roles.
6. Is participation in a Standing Advisory Panel preferred, or is a dedicated committee or panel needed?
What other options should be considered? Please explain your answer here
I would recommend a committee with tenure so there is rotation and refresh ongoing. There should probably be seats for various representatives so all voices are heard with a democratic process used. This works well in industry bodies and ensures a committee is connected in to its constituents and the key issues of the day. There will need to be checks on areas of conflict but in the end we want good minds debating the reporting system with varied perspectives to ensure the best advice is developed.
10. Do you support the integration of the measures and indicators proposed in Manaaki Whenua’s report Reporting Environmental Impacts on Te Ao Māori: A Strategic Scoping Document?
Please select one item
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Yes
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No
Why or why not?
Generally speaking these measures and indicators align well with the broader goals of this update. It makes very good sense to align the work.
12. How should information that is important to Māori be collected and protected to ensure Māori data sovereignty is upheld?
Please explain your answer here
A key part of Māori data sovereignty includes ensuring Māori communities benefit from the use of their knowledge and genetic resources, which are often harnessed by others for commercial gain. The use of data labels will help by offering Indigenous communities the tools to add cultural and historical context to environmental data in non-Indigenous digital archives. The labels can include information about what iwi or group are the primary cultural authority for the material, or what activities the community has approved as generally acceptable use of the material.
The jurisdiction in which data is stored is also a key consideration for Māori data sovereignty. In its Māori Data Sovereignty Principles, Te Mana Raraunga notes “where possible, Māori data should be stored in Aotearoa, reflecting the need to make decisions about storing Māori data in ways that enhance control for current and future generations”.
The jurisdiction in which data is stored is also a key consideration for Māori data sovereignty. In its Māori Data Sovereignty Principles, Te Mana Raraunga notes “where possible, Māori data should be stored in Aotearoa, reflecting the need to make decisions about storing Māori data in ways that enhance control for current and future generations”.