The Parliamentary Commissioner for the Environment (PCE) Simon Upton has reviewed our environmental reporting system and
found it wanting.
In his latest report
, the Commissioner says we don't collect the right data to know how our environment is faring, undermining efforts to
The report reviews the first full cycle of reports under the Environmental Reporting Act 2015 as well as the data that
feeds into these reports.
The Commissioner says New Zealand has a 'passive system' that makes use of whatever data is available, rather than
targeting indicators that would give a clear picture of the state of our environment. In particular, we lack measures
that would provide information about how ecosystems change over longer time periods - which would help us spot tipping
points and guide when intervention is needed.
The SMC asked experts to comment on the PCE's report
. Feel free to use these comments in your reporting.
Dr Roger Young, Coastal-Freshwater Group Manager, Cawthron Institute, comments:
"It’s fantastic to see such a thorough review of New Zealand’s environmental reporting system with strong
recommendations that, if implemented, will make a big difference.
"The report emphasises how our current environmental reporting system is largely reliant on ‘cobbling together what
information we have at hand’. This has resulted in many data and knowledge gaps. Clearly a much better approach is to
systematically decide what information is needed on what topics, how it should be measured and then provide resources
and systems so that valuable long-term datasets can be built over time.
"Despite the challenges identified, it’s good to see that the PCE acknowledges improvements that have been made such as
the recent Environment Aotearoa 2019 report, and efforts like the Environmental Monitoring and Reporting initiative, National Environmental Monitoring Standards
, and Land Air Water Aotearoa
. These initiatives have improved consistency in monitoring practice, stimulated the development of automated data
transfer processes for national reporting, and provided the public with easy access to some environmental data. However,
as the report states, these efforts have largely been reliant on committed individuals contributing when their day jobs
allow. Further progress would be much faster with stronger national direction and resourcing.
Conflict of interest statement: Roger regularly works with MFE, regional councils and other agencies with an interest in
water management. He is on the Steering group of the Environmental Monitoring and Reporting Initiative and involved with
the development and operation of LAWA.
Dr Andrea Byrom, Co-Director, Biological Heritage National Science Challenge, comments:
"I have been eagerly awaiting this report for some months, and I had high expectations of it. I was hoping that the
Commissioner would comment on a raft of issues we know need to be addressed:
• the massive data and knowledge gaps in our current evidence base for environmental decision-making;
• rigidity in the current reporting format and associated expectations around data quality;
• the lack of a cohesive set of environmental indicators in Aotearoa along with a lack of consistent methodologies
for collecting such indicators;
• the critical role of Mātauranga Māori yet minimal recognition of its importance in our environmental monitoring
and reporting system;
• poor understanding of the link between human and environmental health in our current reporting frameworks;
• our inability to aggregate local and regional data spatially into a national framework (including a recognition
of the importance of local or place-based knowledge such as Mātauranga Māori);
• and last but not least for me – the need to monitor with a purpose in mind: to focus effort on critical threats,
rates of environmental change, and on indicators that will tell us something about ecosystem function and ecological
processes (not just static patterns).
"I was not disappointed. This report is comprehensive. It covers all the things I wanted to see and much more. Amongst
the many excellent comments and recommendations made, there is a clear call for a set of core environmental indicators,
and for a more flexible and adaptive reporting structure that focuses on emerging issues.
"I am sure that this will empower the Ministry for the Environment (MfE) to move away from the current treadmill,
providing some much-needed breathing space for their staff and other national experts to better interpret environmental
"The recommendation for an independent science panel – with a focus on interpretation and synthesis – is welcome and
long overdue, as is the call for a coherent basis for national investment in environmental science.
"Mātauranga Māori is also recognised and acknowledged as a critical and unique aspect of Aotearoa’s environmental
monitoring and reporting system.
"I was pleased to see a call for long-term monitoring and good time series data: countries that have put such systems in
place have much better knowledge of the state of their environments than Aotearoa does. Time series are also much more
useful when comparing trends in one indicator against another – enabling better interpretation of the potential drivers
of change, and better understanding of underlying ecosystem processes.
"The Commissioner also provides commentary on the current lack of emphasis on ‘impact’ indicators (as opposed to
‘pressure’ or ‘state and trend’ indicators). This is important because again it sets the foundation for Aotearoa to
become proactive in the way we manage our environmental health.
"Finally, I was pleased to see the Commissioner's deliberations about environmental data: undoubtedly issues with
storage, accessibility, and curation, have hampered New Zealand’s ability to re-use, integrate across domains and land
use types, and interpret our environmental data. There are several comments and recommendations around how we fund and
curate data collection and storage for the benefit of the country.
"Overall I hope this report is a watershed moment for the way we monitor (and manage) the health of our environment in
Aotearoa. Equally importantly, I hope the report provides a catalyst for a much-needed shift towards a future-focused
environmental monitoring and reporting system that is not about reactively monitoring trends, but rather enables us to
act swiftly and put in place interventions when we get environmental signals that things are starting to go pear-shaped
– before it’s too late."
No conflict of interest.
Dr Scott Larned, Chief scientist freshwater, NIWA, comments:
"NIWA has contributed to all components of national environmental monitoring, analysis and reporting in the freshwater,
marine, atmosphere and climate domains for several decades. We recognise the need for consistent and rigorous monitoring
and data analysis to provide the evidence base for planning and policy making. And we recognise that the evidence base
has many short-comings.
"The PCE report addresses some of the short-comings and we generally agree with the recommendations in the report. The
following comments are intended to add emphasis to some of the recommendations, and suggest alterations in other
"First, we agree that there are persistent shortages of environmental data. In one sense, this is a truism – there are
never enough data to alleviate all uncertainty in plans and policies. However, in New Zealand we have a fairly clear
picture about environmental data shortages from repeated state-of-environment assessments, and some shortages are quite
"For example, approximately 150 of the thousands of lakes in New Zealand are currently monitored, and less than half of
the 150 lakes had sufficient water-quality data for state and trend analysis in the 2019 NIWA report. Extrapolating from
such a small number of lakes to several thousand is fraught with uncertainty.
"The draft National Policy Statement for Freshwater Management
released by MfE last month provides many cases of pending data shortages. It proposed ‘attributes’ that are to be
monitored in rivers and lakes. For many of these attributes (e.g., ecosystem metabolism, lake-bottom oxygen), monitoring
has been very limited in terms of spatial extent, duration and frequency. The data limitations will make it difficult to
assess current state or trends in these attributes. The draft strategy also requires councils to identify pressures that
affect the attributes and control those pressures through limit setting or action plans. There are limited data that
characterise those pressures and limited knowledge of the links between pressures and attributes. We reiterate the PCE’s
statement that generating accurate data for numerous variables over long durations requires stable and reliable funding.
"The PCE notes that data availability is partly limited by the number of monitoring sites in operation. But adding
monitoring sites is not the only way to reduce data shortages. Models are routinely used to predict environmental
conditions at unmonitored sites. Model predictions are sometimes viewed as poor, inaccurate substitutes for direct
measurements, but that is unwarranted. Models and direct measurements both have multiple sources of error and both can
be improved. More importantly, modelling is the only feasible way to estimate conditions in some inaccessible locations
like deep lakes and aquifers. Other alternatives to establishing new monitoring sites are remote sensing by satellites,
drones, aeroplanes and fixed cameras, autonomous sensors, and crowdsourcing. These are not just speculative ideas; they
are in use or development now and their use is certain to expand rapidly.
"The PCE also notes that council-operated monitoring networks are not always ‘representative’, which can affect our
perception of environmental conditions, particularly at the national scale. In part, this situation reflects the fact
that none of the council networks were originally intended for national reporting. Most council sites were established
for consent monitoring or for small-scale investigations. Aggregating these sites for national reporting is a recent
"It is also worth noting that representativeness is not the only requirement of monitoring networks. Replication of
sites to enable comparisons (e.g., forest streams versus urban streams) may be needed, reference sites may be needed; no
network will meet all needs equally. New, fit-for-purpose monitoring networks would probably be prohibitively expensive
to operate, so we need to get the best information possible from existing networks. Some of the new technologies listed
above will alleviate problems associated with fixed-site networks.
"The PCE calls for an expansion of the pressure-state-impact framework to the driver-pressure-state-impact framework.
Briefly, pressures are human activities that generate environmental stressors, state is the bio-physical condition of an
environment, impacts are the consequences of changes in state for humans, and drivers are socio-economic forces that
control pressures. In my view, the need to add high-level drivers to environmental reporting is less urgent than the
need for more and better pressure data. Applying the pressure-state-impact framework basically means linking causes and
effects. Pressures are presumed to be the causes of degraded environment state, which are the effects. If the pressures
causing degradation are known, then reducing those pressures should lead to improvements in state.
"Environmental monitoring and reporting in New Zealand has traditionally focused on characterising current state and
temporal changes in state (i.e., trends), with little focus on pressures and even less effort to identify causal
relationships between pressures and state. There are some impediments to compiling pressure data – they may be
proprietary, confidential, or simply difficult to measure. However, cause-and-effect relationships that link human
activities to environmental conditions are fundamental tools for planning, policymaking, limit setting and designing
management actions. Despite the challenges, more effort is needed to compile pressure data and develop reliable
"The PCE recommends a standing science advisory panel for environmental reporting. We agree. NIWA scientists have
participated on these panels since their inception and can be of great service as science translators and critical
No conflict of interest.
Professor Richard McDowell, Chief scientist, Our Land and Water National Science Challenge comments:
"I support the recommendations made by the Parliamentary Commissioner for the Environment on Aotearoa New Zealand’s
environmental reporting system - especially concerning the need to fill data gaps and increase the number of monitoring
sites. In locations where data is not being collected frequently enough or in the right places, we might have an
unrepresentative picture of environmental health and may not be picking up change.
"Expanding the scope of environmental reports to include the drivers of change will add context and better inform the
public. Current reports have highlighted issues but left people wondering what could be done or is being done to fix
them, so I welcome the suggestion that the Minister for the Environment be required to respond to report findings.
"With the proposed changes to environmental policy for freshwater, a robust monitoring system will be key to guiding
where we need to act. I support the Commissioner’s recommendation for the development of a nationally consistent
environmental monitoring system, informed by science."
No conflict of interest.
Professor Troy Baisden, Professor of Lake and Freshwater Science, University of Waikato, comments:
"We often take free access to good information for granted. The Parliamentary Commissioner for the Environment (PCE), Rt
Hon Simon Upton, has just analysed New Zealand’s Environmental Reporting System, and tells us that we simply can’t
depend on it as it stands.
"On net, the PCE says we don’t have a reliable information system to measure or manage our environment. He uses the
haphazard system for monitoring our iconic lakes and rivers as a prime example of the need for improvement.
"As a useful analogy, imagine a world without free local libraries.
Fascinatingly, free libraries were once far from assured, and their worldwide spread over a century ago depended on
billionaire steel tycoon Andrew Carnegie far more than anyone likes to admit. I recommend viewing this report as a story
about how information, which the future of our society depends on, was at risk.
"Anyone who cares deeply about the environment may well find the PCE’s report to be a surprisingly gripping read. It’s
like a chapter in a mystery where all the surprises unfold and the suspense reaches a climax.
"I’ll highlight two of the big surprises. First, our system of environmental reporting has been designed to avoid paying
to create the information it needs to report on the environment. Instead, it only harvests and tries to make sense of
information that’s already collected for other reasons.
"The PCE has had the perfect career to be the author of this story, as the Minister overseeing many critical reforms of
the environment and science in the 1990s and most recently as a director in the OECD think tank overseeing environmental
analysis. Yet, the report does not tell us how this ends, leaving us with recommendations that create further unresolved
"Second, the environmental reporting system completely lacks an internationally standardised cycle of policy responses
to evidence of environmental impacts. In other words, the purpose of environmental reporting begins and ends with
reporting, lacking expectations of using the reports for action.
"It makes perfect sense to suggest that environmental reporting should fund fit-for-purpose information collection, and
a cycle of responding to the findings. Yet there is a disconnect.
"A 2003 OECD report
on the indicator reporting framework the PCE recommends stated, 'Indicators are not designed to provide a full picture
of environmental issues, but rather to help reveal trends and draw attention to phenomena or changes that require
further analyses and possible action.'
"Thus, we should expect the indicator framework, or the cycle of policy review the PCE recommends, to supplement rather
than replace robust information systems like the accounting framework for greenhouse gas emissions. This framework is
specified by, and its funding linked, to international treaties.
"By comparison to greenhouse gas emissions, the current process of assessing freshwater trends is not yet a comparable
accounting framework linking sources of contaminants to loads and impacts in rivers and lakes. We will need both a true
accounting system, and an indicator framework for states and trends.
"There needs to be consideration of whether the ongoing development of whether freshwater accounting and indicator
systems should be run by regional councils rather than central government. A balance is needed between regional councils
setting effective local policy, and the need for central government to fund the accounting framework in sparsely
populated regions where we often care most about water.
"Unthoughtful implementation of the PCE’s recommendations risks undermining the progress that regional councils have
made on monitoring freshwater. Well-structured freshwater monitoring and policy will require both support and thought.
"Monitoring of lakes represents a huge challenge, largely because the only coherent national program for this purpose
was cancelled in the 1990s.
Successful monitoring and resulting action plans in the Rotorua Lakes demonstrate the potential value of good
"The report is timely given the deep consideration of freshwater as part of the framework. We can all look forward to
seeing the story unfold further."
Conflict of interest statement: Funded as the Bay of Plenty Regional Council Chair in Lake and Freshwater Science at the
University of Waikato.
Dr Clive Howard-Williams, NIWA emeritus scientist, comments:
"This is a very welcome report, and after one round of domain reporting and the Environment Aotearoa 2019 synthesis, it
is also very timely. The suggestion for a six-year interval between domain synthesis reports is prudent as five years is
generally considered a minimum time period (in the case of freshwater monitoring) for trend detection. It is also very
important that reports on state and trends in the environment link back to past reports so that assessments of change
(positive or negative) can be made. The recommendation by the PCE on the consistency of reporting along theme lines
(such as those used in Environment Aotearoa 2019) will allow for this.
"A key point made by the Commissioner is that only with 'consistent and authoritative time series coupled with improved
spatial coverage' may we understand 'whether costly interventions are having an effect.' The importance of this point
cannot be overstated. Very significant financial and community resources are being applied for instance to freshwater
restoration activities across New Zealand. Very few of these have adequate reporting to test their effectiveness either
at local or regional scales.
"I do have some concerns over the practicality (rather than the concept) of the single-theme, or cross-theme,
commentaries of ‘variable geometry’ that will appear in the intervals between the synthesis reports. The PCE report
states that in those intervals: 'MfE staff will need to produce at least five commentaries, drawing on the advice of a
standing science advisory panel' and that the timing of the commentaries 'should be determined by the complexity of the
task at hand'. It may be easy for these commentaries to fall between the cracks given pressures on staff time and I
suggest a more robust schedule regarding their production is needed to ensure that the commentaries are written in a
timely manner to keep the public informed on our state of the environment between the synthesis reports.
"The recommendation of a standing science advisory panel is very welcome and from my experience, I believe such a panel
will strengthen the environmental reporting process.
"The Commissioner has emphasised in several places in the report the need for linking of research funding to nationally
identified data gaps. The table of data and knowledge gaps in the report that have been linked to the priority issues is
both instructive and concerning given the Commissioner’s three main points regarding problems relating to the way data
collection is, has been, and is currently funded: (i) a preference for funding exciting, novel research ahead of the
collection of essential underpinning data; (ii) the stagnation of datasets due to a lack of proper maintenance and (iii)
a lack of secure, ongoing funding for important new datasets. Attention to these problems will certainly improve the
data and knowledge collection needed to meet the requirements of national environmental reporting.
"In my view, if implemented, the seven principle recommendations in this report will greatly improve New Zealand’s
environmental reporting and hence the evidence base for allocation of resources to the environment sector and
development of environmental policies."
Conflict of interest statement: Dr Clive Howard-Williams was a member of the Senior Science Team for Environment
Aotearoa 2019. His comments attached therefore are of a general nature based on his experience and avoid mention of any
specific content in the Environment Aotearoa 2019 report.
Dr Murray Petrie, Senior Research Associate, Institute of Governance and Policy Studies, Victoria University of
"This is an excellent report from the PCE. It addresses a number of critically important and under-appreciated
constraints on the ability of governments to manage our natural environment and to be held accountable for it.
"Of particular importance are the recommendations to:
• Expand the coverage of State of Environment reports to include the drivers of environmental pressures (bringing
New Zealand closer into line with the internationally recognised DPSIR reporting framework) as well as forward-looking
environmental outlooks that are critical to better stewardship.
• Invest in significantly expanded environmental data collection and monitoring – which needs to be recognised as
part of New Zealand’s core national infrastructure.
• Require a synthesis report every six years (from 2025), retaining alignment with the electoral cycle, and a
government response to each report - thereby increasing direct public accountability and ensuring the reports are not
"Environmental reporting and stewardship could be further strengthened, beyond the recommendations in the report, by:
• Generating and using better evidence on the intended and unintended environmental impacts of current policies (a
knowledge gap not referred to in the report).
• Stipulating that the government response to each synthesis report must include goals for its priority
environmental outcomes with measurable targets, milestones and progress reports – similar to the mandated accountability
arrangements for fiscal and monetary policy.
• Specifying that environmental outlooks should include data and discussion on resilience, risks, and tipping
points - to promote earlier mitigation and provide detail on environmental risks that can be brought to bear alongside
the wealth of information on fiscal risks. This would enable explicit consideration of policy priorities and trade-offs
across domains in the setting of medium-term fiscal strategy."
No conflict of interest.