Freshwater : Current policy excludes synthetic chemical pollutants

PDF: Aotearoa New Zealand Policy Proposals on healthy waterways: Are they fit for Purpose? (2019).

This document is jointly published by the Soil and Health Association of New Zealand and PSGR is a response to a long term Ministry for the Environment consultation process that has narrowly framed the problems we face in freshwater, resulting in an approach that regretfully cannot address freshwater pollution in New Zealand to ensure freshwater is safe and life-supporting for our grandchildren and future generations. We know that creating legislation to protect future generations is extremely hard, because it is political - it involves a trade-off between the long term and the short term. Over twenty organisations supported us. Despite the significant support base, and multi-organisation approach, this critical paper was not reported in the media.

In September 2019 the Ministry for the Environment released its proposals for dealing with the crisis in our waterways: ‘Action for healthy waterways – A discussion document on national direction for our essential freshwater’. While the Ministry for the Environment document outlines possible ways of ‘reducing soil loss, reducing nutrient run-off, and/or investing in upgrading wastewater and stormwater infrastructure’, there are glaring omissions – National Environment Standards do not address the need to monitor synthetic chemicals and trace elements in our waterways. Urban, industrial and agrichemical pollution has been left outside consultation. Further, linear one chemical at a time approaches to national environment standards are clumsy and cannot address the problem of accumulation and synergistic effects.

We agree with the OECD, if we are to protect freshwater, diffuse emissions must be urgently addressed.

We, and a wide range of supporting organisations consider the way to scientifically understand our water status is to undertake a broad spectrum synthetic chemical monitoring program, engage experts in endocrinology, chemical toxicology and predictive analytics to build a picture of the chemicals, the pathways they target, the presence of chemical families and to pull this back to the evidence in the published scientific literature. Then we regulate

New Zealand can undertake a necessarily broader basic science and systems-based analytical data approach to our water quality problem that uses a high tech approach to understanding diffuse emissions and and discuss the pressure from synthetic chemicals and trace elements - and the mixture 'cocktail'effects and the capacity for these chemicals to disrupt all vertebrate life at hormonally relevant levels (ppm ppb and ppt).

As we state in the report we believe ' Advances in predictive analytics and statistical techniques, including data mining, machine learning and predictive modelling should not be limited to the commercial sphere and social media'.

Our document has many recommendations for Reform because of the complexity of this issue. This includes requiring diffuse emissions are monitored and transparently published, we additionally consider that in order to act as effectively as Europe so that tourists and Kiwi's alike are not swimming in chemicals banned in Europe, nor consuming chemicals banned in Europe, New Zealand must (as with Europe) urgently elevate the Precautionary Principle to a high level in legislation so that it is an overarching mechanism in law that guides decision-making (we believe in environmental and human health respects), rather than a minor consideration that is easily dismissed by policy-makers.

The science will always be uncertain, but it is our approach, and who we act to protect, and the degree of resourcing (financial, technical, scientific, monitoring based) we engage to ensure a process will be effective - that reveals a nations priorities.

Monitoring has, for good reason, been called the Cinderella Science.

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Aotearoa New Zealand Policy Proposals on healthy waterways: Are they fit for Purpose? (2019) ISBN 978-0-473-50130-3

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