ENVIRONMENT AND CONSERVATION ORGANISATIONS OF NZ INC.

Level 2, 126 Vivian St, Wellington, New Zealand; PO Box 11-057, WellingtonEmail: Website:
Phone/Fax 64-4-385-7545

As for 5 September 2016

ECO NZ’s SubmissionsPART TWO- re Conservation and Environmental Science Roadmap to inform development of the roadmap

Dear Team,

You gave us an extension for this submission because of our commitments for and at the IUCN Congress in Hawai’i for which we thank you.

This is Part TWO of the ECO submission and is to be read in conjunction with our Part ONE, which took us to p15, sorry, not p47 as earlier stated.

Name: Environment and Conservation Organsiations of NZ Inc

Address: P O Box 11-057, Wellington

Submitter type: Environmental NGO – umbrella group.

We are fine about you releasing ECO’s details but not those of particular individuals.

Things to note about our submission.

  • It is in two parts – this is part 2 but We reproduce part ONE of our submisisons at the end of this Part TWO submission.
  • We have ommited the yes/no answers that you asked for since it is rare that we can answer in such a binary fashion. We felt it best to go to the substance not an all-or-nothing judgement
  • It would make it much easier on submitters and on submission analysts if you used numbers instead of bullet points in your discussion documents please.
  • We have been pressed for time on this and apologise both for the delay and for the typos and inelegant language that are inevietably in this submission.
  • We wish to follow the progress of the work here. We thank you for much in the paper that is wise and well framed. For the sake of brevity we have largely left out commenting where we agree with you – so please do not think that we are wholly negative about this work – we are not. We have simply highlighted those areas where we have suggestions and disagreements, for brevity’s sake.

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Re p16 – Roadmap Phase 1 – the Discussion Paper.

P17 The Themes and Questions

  • In this and many other sections of the paper, we support reference to “ecosystems” but consider that this should also include “biodiversity” so that all of the levels of biodiversity are included.
  • Inclusion of research relating to New Zealand’s international obligations.
  • We would like to see reference here to reserch to fulfill’s New Zealand’s international obligations.

The “social and economic dimensions” research needs to be “unpacked”. This should include theories and evidence of:

  • changes of behviour;
  • the changing of social norms and their significance in influencing pro-social and pro-environmental behaviour;
  • the social and individual paychology of behaviour;
  • the role of norms, incentives and disincentives in shaping behaviour;
  • internalisation of externalities; inducing instrinsic motivation and impacts of extrinsic motivators;
  • the recognition of the value of non-rival and non-excluable (ie public) services and goods, and the funding there-off;
  • the ethical and other framing of choices;
  • framing choices as citizens rather than as those of consumers and producers in the market.
  • The evidence about the strengths and the limitations of self-governance, collaborative processes, of markets and of government and hybrids of these.

The Question of Priorities:

P18

We consider the priority advice useful but inadequate.

In our view:

In 1, the irreversibility of environmental harm is more compelling than a lost opportunity, since the latter tend to be more substituable than environmental harms are.

In 2, rearrange so that it says: the impact on nature’s welfare and subject to that, human welbeing.

To 3 ADD, after “probability”, “the severity, duration, scope and range of” damage.

To 4 insert after “risk and impact can be”, the words “avoided, remedied or”, since this idea is embedded in both the RMA and the EEZ&CSActs. Avoidance of damage is higher up the mitigation heirarchy than simply “minimisation” which could imply the toleration of the damage with no attempt to avoid it.

P 16, re your Questions about feedback on the questions:

We would like to ADD:

  • Research on what the evidence and literature says about the sources and measures of human well being– and the variables that contribute to or detract from this. [This will involve a critique of GDP and other macroeconomic indicators as well as drawing on the literature of evidence and self assessment of wellbeing – as for instance covered in the Spirit Level.
  • Research on the drivers of human behaviour (social, psychological, economic, etc) and the barriers to pro-environmental and pro-social behaviour change.
  • Re other comments, we suggest the addition of what IUCN calls “Nature-based solutions” – to climate change, to mental and physical health problems, to social delinquency, and other such.
  • Decision making and rules in information-short environmentals.
  • Research to comply with international obligations.

Related Roadmaps:

ECO requests that we be added to the list of those consulted about the Primary Sector Science Direction roadmap.

Theme 1 – Climate Change

These visions and goals are too weak.

1)While understanding the mitigation potential is an essential component, we need to move beyond getting New Zealand to “understand” the pathways that can lead to a low-carbon economy. We need this goal to emphasise that we must introduce a programme of actions, that will ensure we are on a learning curve that allows the results to be increased rapidly as the damaging impacts of climate change become more and more evident.

2)Yes we need a planned adaptation and risk reduction strategy. But an essential element of this strategy has to be to strengthen the public understanding through actions which can be increased as the situation gets worse.

3)ECO’s understanding of the science is that we need to move faster and further in reducing our GHG emissions and in particular, we need to srip carbon out of the atmosphere. New Zealand needs to achieve net zero carbon emissions by 2050, a more ambitious target than the feeble 30% reduction by 2050 and that the baseline must be 1990, not 2005.

Emerging ideas:

  • In our view we need to increase our understanding of the implications and methods of increasing the capacity of soil as a carbon sink, and not expect to do so until the impacts of that are unerstood.
  • Needs to be far greater focus on the impacts of greater precipitation events, and stronger droughts.
  • Carbon Capture and Storage seems to be the refuge of those who want BAU and to avoid substantial emissions reductions.
  • CC&S in the marine enviornment is opposed by ECO since the impacts of this are not likely to be well understood and this strategy is likely to be used as an excuse for not de-carbonising the economy.
  • Re your 7th bullet point under this heading, the emphaisis need not necessarily be the use of “novel” land use practices but rathe to develop those land use practices that are adapted to climate changes AND are low carbon emissions.
  • We suggest that you ADD here, research on spreading the acceptability and adoption of low enviornmental damage, low-input and low carbon emission land uses especially.
  • Methods for encouraging native bioidiversity provision and ecosystem services on privately held land.
  • 8th bullet point – changes of plants and land uses, not just plant breeding and not biotech where this means genetic engineering where adverse ecosystem or health impacts may result.
  • Innovative techniques? Well mahbe, but much is already known about this – as Alison Dewes’s work shows – and the real question is to research how to spread the uptake of the known methods.
  • Methods to induce switching from ruminant animal production to other animal and to plant-based farming is needed. This could include economic and other instrucments, social norms, peer-group influence and so on. One particularly important bit of work is to examine, using the natural experiement of changing dairy prices, the price elasticity of supply of dairy products v alternative land uses.
  • Last bullet point – this needs to be done for all invasive alien species, not solely those that will flourish with climate change. We need a further research point, which is how to improve our border and our internal biosecurity controls.

Research Questions:

1.1Add: and avoiding “non-economic growth”, ie that economic growth which does more damage than benefit, or does irreversible damage to the environment.

1.3We suggest the insertion of “species” after “organisms”

  • The research questions do not capture the need for research and analysis of existing data which demonstrates that stocks of fish and wild life are becoming critically endangered and are likely to be worsened by climate change.
  • Long term weather change impacts – ever increasing large rainfall events (and droughts) need further elaboration.

New or Expanding capability Needs

Bullet point 3: After “Maintaining” insert “and publishing for public access in a timely manner”;

  • ADD: Health impacts of climate change
  • Health impacts of increased access to native biodiversity and “nature”.
  • Drivers of human behavior and of behavior change.
  • Understandign our current carbon budget and how to achieve progressive and ambitious milestones
  • Sources of government and of market failures.
  • Impacts of sea level rise.
  • We need open data so that mass resources of scientists can analyse and suggest further remedies.
  • Learning from adaptation and mitigation measures instituted in other countries is essential – but we must take very fast follower actions – and lead in areas where we have unique conditions, qualifications and experience.

Continued over page.

Theme 2 Integrated ecosystems and processes.

We support the reference to ecosystems and processes, but also consider the other aspects of biogeophysical process and to biodiversity needs to be incorporated into the and similar sections. We suggest that this be incorporated through out.

Context

  • Add reference to the RMA’s integrated approach.
  • Note that the EEZ&CSA is a “gap filler” and that we still await integrated oceans policy and law.
  • Need to reduce silo fisheries management.
  • Key interface environments should also refer to atmosphere-ocean-land-freshwater interfaces.
  • Add the gradations and interfaces from coast to deepsea, seamounts, thermally active areas, deep seeps etc.

Vision /goals

  • Refer to “nature-based solutions – cf. IUCN’s work on this at iucn.org
  • Add biogeophysical systems

Emerging ideas

Re second bullet point – this should not be framed as “balanced”, but rather that the environmental should constrain the economic , and social and cultural conditions may, constrain the economic activity (eg the taboo on trading babies) and may need to change to protect the environment. The “needs” of society are not necessarily equally ranked, and thus should not be regarded as equally tradable. Environmental constraints are just that – and not all “needs” have equal standards, so “balance” is a misleading and inappropriate term to use. Some may have to change or be abandoned as no longer sustainable in an environmentally constrained world.

Re bullet point 3

It is not only “land use” but activities and impacts that need to be considered, including activities at sea.

Bullet 4 – agreed.

  • The non-linear effects of fresh water systems need to start well before the coastal-marine and estuary areas.
  • The impacts of glacier melt and the permanent impacts on the local environment are also missing from the questions.

Research questions

2.3 It is not only environmental policy but also transport, industrial and primary production and marine policy.

  • It is essential that the data collected is made available openly for analysis.
  • There is a huge amount of data collected that already has very little (often zero) resources for analysis and interpretation.

(continued below)

Theme 3 – Freshwater ecosystems and processes

Enduring Question:

We suggest that this be rephrased to say “What tools, novel and existing,… to ensure freshwater ecosystems are healthy and resilient, adverse human health impacts are avoided, and cultural needs are recognised, while, to the extent consistent with these, identifying tools, sysstems and uses that can allow human uses of water.

  • “Minimisation of human health impacts” lacks ambition, Avoidance is the first goal.
  • Identify economic, social, political and governmental barrieers to improved water quality and better functioning fresh water ecosystems
  • Improved institutional and legal requirements for monitoring, reporting, publishign and inducing compliance with better rules for freshwater and freshwater ecosystems.
  • YES we need many new and novel tools, however we also need higher base level standards and regulatory actions to ensure the base level standards are achieved – so we need research into why this hasn’t happened so far.
  • There is too strong an emphasis on research into new or novel tools, systems and processes to improve water quality. Conversely there is not enough research into the reasons such as agency capture by industry, the Ministry’s own caving in to political pressure to change the standards and distort reporting, council unwillingness to prosecute, and so on.

Context:

  • NOTE the potential for growing human well being while lowering private impacts on freshwater and freshwater systems.
  • ADD references to the benefits to be gained from aesthetics, recreation, tourism and ecosystem services and the need to capture these benefits in decision making and to recognise the non-rival and non-excudable benefits.
  • The reference to the “quality of water in New Zealand;s lakes” etc as “variable” is quite inadequate. This should be clear in its acknowledgement of the downwards trajectory of water quality and be very clear that this is more than “some negative trends”.

Vision/Goals

  • There is no need to requite “novel tools” – the application of any tools is needed and there must be work to analyse the socio-political and economic pressures that inhibit better outcomes.
  • The vision / goals needs to be rewritten to place the appropriate standards limits and targets as the first element of the vision – with the development of tools etc as the second element to improve the standards over time.

Emerging Ideas

  • We do not agree that collaborative approaches have been shown to be appropriate for setting limits and implementation. We consider that is a matter for research, not assumption. There is evidence of failures of these approaches, and there is evidence of community based management failures, government and market failures. What is needed is further literature reviews and research on the relative strengths and weaknesses of the various approaches, and how methods can be best implemented in different circumstances.
  • We need more analysis of the science of behaviour changes, individual and social, the barriers to change and how to overcome these, and unflinching politico-economic research into government failures, market failures and community decisionmakeinfailures.

Research questions

  • ADD the above also to the Research questions – and modify 3.1 to EXAMINE the extent toi which communities and iwi can set and implement limits etc.
  • ADD text to reference whether government failures can be avoided and remedied, not simply to see a wholesale retreat from government as implied by 3.1.

3.2 – Refer to “full cost accounting” not “economic costs” and ethics.

ADD

3.6Changing norms, attitudes, values and behaviours to be more pro-environmental.

3.7The strenths and limitations of the institutional arrangements for research, for management and reporting

  • Policy measures and their efficacy and weak points.
  • NOTE: the Immediate establishment of higher water standards is the essential pre-cursor to allow research to have a higher baseline for research to start from.

Theme 4 - Land Ecosystems and Processes

Context:

  • Include references to increased intensity of land use, esepcailly farming and include irrigation
  • We support and recommend inclusion elsewhere throughout the document to plant, animal, fungal and microbial life, and this should apply throughout the document, instead of simply plants and animals. Microbial life is vital and prolific in the marine environment also.
  • Some conservaiton land is private, as well as the much larger areas of public conservation land.In para three, add in references to mineral and fossil fuel mining and production forestry as having impacts.
  • Make clear that natural capital is biogeophysical systems, not “stocks” and flows of “resources” and that the conditions for maintenance and repair pf such natural capital systems must be attained and preserved.
  • Replace references in para 3 and 5 to “resource base” and “resource” with the term “environment base” and “environment”.

Vision/Goals

We reject this formulation since it reeks of “reverse sensitivity” – ie allowing harmful land uses and controlling other land uses that are affected by such harms.

Instead, we suggest a vision and goal of land uses that do not stress ecosystems and their processes or the biogeohysical systems; that we do not reach overcapacity and environmental limits, that human quality of benefit from land ecosystems and processes are maintained and enhanced from non-damaging and non-extractive uses.

Emerging Ideas

It is a matter for research whether OVERSEER is adequate, and whether community based management systems are adequate. Ostrom and FikretBirkes’ work shows clearly that these only work in certain – and often limited- circumstances. We suggest you examine Fiorino’s surveys of this literature.

We agree with your para re soils, but we consider this section should also include the values of conservation-based and ecosystem based management and the many health benefits from access to nature.

Include in the research questions references to:

  • Methods to induce the uptake of low-impact, low input farming;
  • Reductions in irrigation
  • How the uptake of already known low impact practices can be accelerated
  • The price elasticity of supply of dairy farming compared otherland uses
  • Methods for changing social norms
  • Methods for internalising enviornmental externalities.
  • Methods for improving the uptake of internal biosecurity controls.

Theme 5 0 - Coastal and Marine Ecosystems and Processes