Aotearoa New Zealand Policy Proposals on healthy waterways

posted in: Submissions

Are they fit for purpose?

Excellent water quality is of paramount importance for our Treaty obligations, agriculture, tourism industry, health and sense of national identity. 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 document outlines possible ways of ‘reducing soil loss, reducing nutrient run-off, and/or investing in upgrading wastewater and stormwater infrastructure’, there is one glaring omission – it does not address the need to monitor synthetic chemicals in our waterways.

Diffuse emissions must be urgently addressed.

Chemical production is predicted to increase exponentially, constituting a present and growing threat to human and environmental health, and risking the wellbeing of future generations. Chemical contaminants include pesticides, household products, resins, plastics, petroleum products, pharmaceuticals and personal care products. Currently, routine national monitoring for chemical contaminants in New Zealand freshwater that is publicly accessible, is confined to groundwater. While laudable, this is not sufficiently protective of public or environmental health.

Polluting synthetic chemical contaminants create intersecting social, cultural and economic harms. Without a mandate to monitor chemical contaminants in waterways as well as aquifers, territorial and national authorities will not have the capacity to safeguard:

Photo: iStock/KiraVolkov
  • The quality of our drinking water;
  • Māori customary fishing and traditional riverside food gathering;
  • Favourite Kiwi swimming areas;
  • Key tourist destinations as safe and ecologically healthy;
  • Food production and processing, and organic systems from contamination.

Excluding diffuse chemical contaminants from monitoring and regulation additionally leaves Māori without appropriate scientific resourcing to assert rangatiratanga and kaitiakitanga. We will be unable to protect biodiversity and our food chains, reverse declining fish populations and ensure that our agricultural exports are not inadvertently contaminated. And the possibility of endocrine disruption puts at risk our most vulnerable citizens – our babies.

The solution is not to stick our heads in the sand, because it is not politically comfortable, nor convenient. Nor is it acceptable to wait for certainty – until scientific endpoints are established. It is evident, for many endocrine disruptors, that it may not be possible to establish endpoints because of the miniscule levels at which these chemicals cause harm, and because of the varying vulnerability at different life stages.

In such an environment, there remain many opportunities to ensure policy and regulation concerning freshwater are fit for purpose and can reasonably meet the foreseeable needs of future generations.

  1. Where degraded areas are identified, scientists can utilise a suite of nationally regulated testing screens for diffuse chemical contaminants and publish this information for public debate.
  2. New Zealand can resource scientist experts in chemical toxicology, endocrinology and environmental chemistry and build on international research to innovatively evaluate the risk to both aquatic food chains and human health – at arms-length from industry.
  3. Our chemical risk assessment can adopt best practice alongside Europe, sending a firm message to trading partners and tourist operators that freshwater and food in Aotearoa is clean and safe.
  4. We can update regulations to recognise additional risk from chemical mixtures; and the risk from exposures at low levels that impacts the hormone system and can set the stage for disease and dysfunction.
  5. New Zealand can appropriately engage the precautionary principle as the key policy instrument that over-arches risk evaluation, rather than retaining it where it currently sits in legislation and policy, alongside social, cultural and economic considerations where it is
    rarely called upon, and frequently ignored.

We recommend that the monitoring of diffuse chemical pollutants in our fresh water is required as a national environment standard and that the recommendations for reform in this paper are included in any policy on protecting the quality of our fresh water.

For more information on the freshwater proposals to: https://www.mfe.govt.nz/consultation/action-for-healthy-waterways

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This paper is jointly published by the Soil and Health Association and Physicians and Scientists for Global Responsibility and has been supported by a wide range of public and private sector organisations throughout Aotearoa New Zealand.