E McGruddy, Senior Policy Adviser, FFNZ
The Government’s aspiration to deliver demonstrable environmental improvements in short order just hit a road block. Or did it?
The Overseer model has been found wanting by an independent panel – unfit for purpose in regulation. It may or may not be resurrected in a more limited domain, more suited to the original purpose for which it was designed.
But Overseer always operated in a limited domain, focusing just on nutrients and just the rootzone, and just at farm-scale. The Independent Panel presented a litany of all the things that Overseer doesn’t do, but Overseer was always just one tool in the toolbox, albeit it was stretched beyond its original purpose.
Perhaps the most trenchant criticism in the Panel’s report is this section: “From a Māori perspective, the reduction of environmental impact down to just one or two contaminants is problematic. The use of models – with their necessarily reductionist limitations – should also be done in the context of a more holistic analysis of te Taiao. The desire to simplify the natural world for ease of administration by using models and ignoring the inconvenient complexities of agricultural and environmental context should be strongly resisted.”
Strong words. Another who has used strong words to castigate the uncritical reliance on models in environmental policy is the Parliamentary Commissioner for the Environment (PCE). The PCE instigated the review of Overseer in 2018, but his recommendation to Government was wider than just Overseer: “I have concluded that the Minister for Science and Innovation, in consultation with the Minister for the Environment, should take a look at the ownership, use and development of the many models and databases that inform our understanding of catchments.”
Alongside challenging the uncertainties and lack of transparency of these many models, the PCE has not been afraid to expose weaknesses in the underlying data and evidence. In 2019, his review of national environmental reporting systems concluded that “significant data and knowledge gaps bedevil our understanding”.
In 2020, the PCE reviewed the funding and prioritization of environmental research, finding that “current public investment is fragmented and inadequate”, and that it too often elevates “novelty” in funding criteria. Instead, the PCE emphasized that much environmental research “involves the patient interpretation and understanding of environmental changes that unfold over decades”.
Federated Farmers NZ endorses these concerns. Too often, proposals for foundation research in critical areas – including and especially catchment transport and attenuation pathways and processes – do not make the cut for funding. A notable exception is the “Smarter Targetting for Erosion Control” project which was supported by Federated Farmers and which secured funding in 2018.
Earlier this year the PCE wrote to incoming parliamentarians, re-emphasising these themes: “Today’s environmental challenges did not arise overnight, and any course corrections involve playing a long game. In my view, high quality information is a priority. It is a false economy to box ahead without good quality information.”
In a recent Radio NZ interview probing “where now without Overseer”, the PCE expanded again on his thinking. Interestingly, he used the “reductionist’ word again: “The idea you can manage things at farm level is very reductionist…we keep focusing on the farm, but the farm is next to another farm, and farms are part of the landscape with water moving through.”
Instead of this “reductionist” approach, the PCE returned to the theme he developed in his 2019 report “Farms, Forests and Fossil Fuels”, emphasizing the need for research and action at catchment scale: “Getting beyond laudable vision statements will require engagement with real communities on the ground…integrate all that we know about environmental processes at landscape scale with bottom-up grass-roots knowledge. It would focus on giving those who live there the incentives and the means to address environmental and socio-economic concerns in parallel.”
This is not a new theme. Manaaki Whenua Landcare Research have a long history with integrated catchment management (ICM) projects, and a recent report similarly questioned this reductionist approach (MW-LCR Contract Report LC3859): “Current approaches to the implementation of resource management policy in New Zealand are dominated by an individual approach to limit-setting policy, which embodies the assumption that the actions of individuals will, ultimately, accumulate to a required limit, target or outcome.
“While the sustained actions of individuals can be cumulative, there are often constraints on what farmers can do individually. For example, environmental problems often arise from issues, land features or critical source areas that cross multiple boundaries. Viewed from this perspective, we are concerned that the individual-based policy structure is limited in its capacity to foster the collective responsibility, accountability and actions that are increasingly recognized as needed to effectively address the social-ecological issues we face.”
The PCE notes that some may look to “input’ controls in lieu of Overseer estimates, but as set out in his 2018 report: “Farmers have consistently resisted input controls on the basis that these sorts of regulation would be inflexible and stifle innovation. These concerns have and should continue to be taken seriously. Trying to make an effects-based regime work is, in my view, worth the effort – it focusses everyone on the issue we are trying to address.”
The PCE is currently test-driving his thinking with real communities in two catchments – one in Northland, one in Southland – drawing on multiple layers of data and local knowledge “to help focus attention on areas where we can really make a difference”.
In part this work builds on work by his predecessor, Jan Wright, who wrote in 2015: “A weakness of the NPS is that it does not direct Councils to take a strategic approach to the water quality challenges in their regions. Waterbodies that are very vulnerable or subject to particular pressures should be considered first. And where water quality is under pressure, not every attribute is important. Comprehensiveness should not trump effectiveness.”
In turn, that recommendation echoed recommendations made in the Third Report of the Land and Water Forum in 2012, including that regional councils should prioritise catchments for planning on the basis of the state of the waterbody, and risks posed by resource use (recommendation 2); that councils should create catchment strategies for achieving objectives and limits, and agree plans for sharing responsibilities and costs among stakeholders (recommendation 5); and that councils should provide for the resource requirements of catchment management processes in their financial plans (recommendation 7).
In 2020, MfE published Our Freshwater 2020: a key message was that most catchments are a mosaic of land uses, and that challenges and opportunities are best addressed and progressed in the catchment-specific context. Work commissioned by MfE in support of that report presents box-and-whisker plots showing state and trends across a range of water quality attributes, graphically illustrating that the “whiskers” and “outliers” could and should be prioritised for attention and action.
In 2019, Federated Farmers submission on the Essential Freshwater discussion document commended work underway within MfE to identify and prioritise “at risk” and “exemplar” catchments for coordinated action and investment; within a wider context of a burgeoning growth in catchment communities developing action plans to address the multiple drivers of ecosystem health. On any given week in rural New Zealand, there will be a line-up of utes at a local hall for a meeting of the local catchment committee; and both MfE and MPI are coming to the party to support these groups.
In the wake of the Overseer peer review report, Ministers are now keen to progress the next solutions-oriented phase. The PCE has already anticipated this phase with a coherent strategy for beefing up foundation science, and engaging with catchment communities on the ground to ‘give ourselves the best chance of realizing the goal of protecting the life supporting capacity of air, water, soil and ecosystems”.
The PCE describes this as “the long game”. Could the long game also be the short road to delivering the runs on the board that the Ministers want?