Muddied waters: reframing modern freshwater pollution

In response to the NZ government’s 2017 national policy on freshwater, which was unduly narrow and unscientific, and would by default, favour polluting industry and keep New Zealand monitoring in the dark ages; a group of organisations established the Freshwater Rescue Plan.

Freshwater that is safe to drink is shrinking by the day. Drinkeable water is possibly the most precious resource in the world, and is known as ‘Blue Gold’ for a reason. It’s worth listening to long time campaigner Maude Barlow discussing how water is a human right; but with the increasing commodification of water including that it is frequently poorer communities of colour that suffer most.

New Zealanders are passionate about water- but there isn’t enough cross-communication - ‘participatory democracy’ and policies do not interconnect sufficiently. Framing this lack of complexity is an inadequate knowledge base because there is little funding to undertake the science on chemical pollution in freshwater. Science funding in New Zealand tends to be ‘market’ oriented to product/patent/process development, rather than to understand and deal with rapidly increasing pollution that will impact the wellbeing of future generations.

In March 2018 we put together a Freshwater Forum in the Bay of Plenty - speakers included farmers, scientists, fishermen and experts on fertiliser. It can be viewed on Youtube here. There are many answers to protecting freshwater, however policy decisions are frequently narrowly framed (to protect vested interests and not be unduly onerous), while the issues are far more complex and have a lot to do with knowledge production, short-termism, transparency and vested interests.

If we aren’t doing the monitoring, how do we know there is a problem? It’s called ‘undone science’.

What is its value? And why is this becoming more important? More ‘acute’?

It’s a creeping, challenging issue. Traditionally New Zealand regions depended on pollutants ‘assimilating’ into the environment and wetlands, as kidneys of aquatic ecosystems, filtering and degrading the man-made chemicals that pollute. Chemical pollution is now recognised as a threat to ‘planetary boundaries.’ [1] Yet despite legislation demanding pollution is prevented [2], and water protected [3], chemical pollution in freshwater remains largely unaddressed in New Zealand. This incorporates nutrient excess, but extends beyond that. Our eyes appear wide shut to this complex modern threat.

Bay of Plenty, New Zealand

Bay of Plenty, New Zealand

Current debate on freshwater remains restricted to discussion of nutrients and sediments, with ‘sediments’ remaining undefined, and the creeping problem of industrial, agrichemical and urban chemical runoff, largely ignored. Our Resource Management Act barely only touches on nutrients and sediments - here lies the legislative schism. Future generations depend on us to pivot and address chemical contamination.

A recent landmark Lancet report described pollution as the ‘largest environmental cause of disease and premature death in the world today.’ [4] Forty international researchers produced the paper, and concluded that disease caused by pollution was responsible for an estimated 9 million deaths in 2015.

In addition to dying earlier, welfare losses due to pollution were calculated at 4.6 trillion, or 6.2% of global economic output. New Zealand has a heavy dependence on primary production – as such agrichemical use is significant. It’s not just nitrogen.

Our primary producers are dependent on intangibles to maintain product value and our farmers are just as devastated when their local rivers die. It’s up to government to keep an eye on this, and if government doesn’t we all loose out. It’s not just tourism, it’s not just protection of drinking water. As such, we all require the clarity and science, to unravel this story.

The Lancet report considers modern pollution, including chemical pollution, ‘a great and growing global problem’. It discussed the emerging problem of new synthetic chemicals including ‘developmental neurotoxicants, endocrine disruptors, chemical herbicides, novel insecticides, pharmaceutical wastes, and nanomaterials.’

Lead author Dr Philip Landrigan stated in The Guardian ‘I worry we have created a situation where people are exposed to chemicals that are eroding intelligence or impairing reproduction or weakening their immune system, but we have not yet been smart enough to make the connection between the exposure and the outcome, because it is subtle.’ [5]

The 2017 New Zealand National Policy Statement for Freshwater Management (NPS-FW) [6] did not provide parameters nor direction concerning environmental synthetic chemicals. Its list of 9 attributes to test for, severely restrictive, and the safe levels, was inadequate to address twenty-first century system stress.

While discussion on urban and industrial waste deserves much more public attention than is currently produced in the media, agriculture is a big part of the problem. As Professor Russell Death has clearly stated ‘intensified agriculture is driving the decline in freshwater.’[7]

My paper ‘Chemical Drains’ investigated the current policy gaps, the risk from ‘undone science.’ It called for a greater scientific commitment to understand the wider chemical synergies in our freshwater systems, especially at low levels that can harm children and ecosystems. I argue this is necessary to enable public decision-makers to more aptly and transparently evaluate emerging (particularly non-linear) risks, improve our strategic foresight in the public interest, and protect future generations. [8]

Safeguarding the future – embedding the future into day-to-day policymaking

A 2017 book ‘Safeguarding the Future’ by Professor Jonathan Boston, describes ‘creeping problems’ which emerge gradually, sometimes imperceptibly. He considers long-term environmental interests are ‘particularly vulnerable’ to short-termist decision-making, and that ‘relevant causal pathways, path dependencies, cumulative effects and tipping points may be poorly understood.’ [9]

Boston’s book is full of recommendations to help governments and decision-makers strengthen anticipatory governance and embed concern for the future in day-to day policy-making. and produce, as Professor Boston has said, ‘strong enough voices for the future.’

The issues evident around environmental chemical pollution reflect many of the governance challenges discussed in ‘Safeguarding the Future.’ Emerging chemical pollution is arguably an issue extremely vulnerable to what Professor Boston describes as ‘a presentist bias.’

Chemical pollution, as a ‘creeping’ problem, poses ‘particularly unattractive intertemporal trade-offs.’ As Professor Boston explains more simply, ‘long term pain may depend on short term pain.’

Yet if we do not seek to address chemical pollution, regulators and authorities, enable, by default, these chemical ‘by-products’, (produced by special interests) leach into our environment. New Zealand inevitably absorbs these ‘negative externalities’ – which include intangibles such as trust and goodwill.

This produces a culture of governance, as economist Professor Joseph Stiglitz has noted, that by design naturally privatises the profits, and socialises the costs. It is not a particularly democratic way to deal with pollution (nor any other externality that causes adverse harm).

Testing for contaminants (but not chemicals) in freshwater.

New Zealanders believe that their freshwater is tested for chemicals – for ‘contaminants’. Perhaps this belief needs a little ‘fleshing out.’

Drinking water suppliers are obligated to test for a range of chemicals, including agrichemicals, in drinking water. [10] if local councils wait until chemicals are detected in drinking water, it is arguably, too late. It costs much more to remove chemical contaminants than bacteriological contaminants from drinking water, and local councils have extremely limited budgets. Moreover, councils are only obliged to test for chemicals with established Maximum Acceptable Values (MAVs) listed in our 2018 Drinking Water Standards. However MAVs don’t necessarily reflect the ubiquity and risk from harmful chemicals. For example drinking water suppliers aren’t required to test for glyphosate nor metsulfuron-methyl as there are no MAVs for these. Glyphosate is commonly sprayed on farmland and (unlike most OECD countries) along roadsides and mixed with metsulfuron-methyl. The organosilicon pollutant frequently applied with it is ignored; and the mysterious ingredients in pesticides that are not declared in the patented formulation approved by the Ministry of Primary Industries ignored. Drinking water standards don’t include neonicotinoids. If the acceptable dose for imidacloprid is derived from a 28 year old unpublished Bayer study - the WHO won’t set maximum acceptable value (MAV) and neither will our Ministry of Health (as drinking water standards). Imidacloprid has been detected in New Zealand food and honey, so we know it is out there.

We do have the National Environmental Standard for Sources of Human Drinking Water (NES). A regulation made under the Resource Management Act (1991) that sets requirements for protecting sources of human drinking water (whether lakes, rivers or groundwater) from becoming contaminated. However there appears no requirement in law for regional councils to test water before treatment.

(If glyphosate is regarded as controversial, and considered by New Zealand’s own authority on cancer, the International Agency for Research on Cancer to be a probable carcinogen, [11] perhaps we should, at least, be testing for it in our drinking water.)

At least (sort of, most of) our groundwater is tested.

The only regular testing of agrichemicals in our freshwater landscape is via the National Survey of Pesticides in Groundwater (NSPGW). [12] The NSPGW tests every four years, but it is restricted.

The problem is, regional councils can elect not to participate, or may elect to only test a small number of wells. Bay of Plenty Regional Council (BOPRC), for example, was one of only two regions that did not participate in the previous 2014 survey, and in the previous 2010 survey BOPRC appeared to only test in 6 wells [13] - less than 10% of available sources. [14] Decisions to test or not appear to be made by staff, rather than councillors. Deficits in data such as this makes it more difficult to recognise creeping toxicity, and restricts future focused analysis.

Further, the groundwater survey (an excellent initiative and a critical policy instrument) is limited by the pesticides selected for testing, and may not screen for all the metabolites (breakdown products) of a chemical. It’s funded by regions, who struggle with funding. Europe is moving more swiftly to understand this situation. [8] It should be nationally led and nationally funded.

In 2018, the burden is left to Regional Councils to test freshwater and sediment for agrichemicals. Sir Geoffrey Palmer and Andrew Butler have written in their latest book ‘Towards Democratic Renewal’ of the propensity for National governments to create legislation that is unaffordable for the regions. The book makes suggestions to address this.

Our current freshwater data for agrichemical toxicity is at best patchy, at worst, non-existent. For example, the Rotorua Te Arawa Lakes Programme, a partnership between Te Arawa Lakes Trust, Rotorua Lakes Council and Bay of Plenty Regional Council has a $230 million budget to clean up the 12 Rotorua lakes. [15] To date, not one test for pesticides in freshwater or sediment in the lakes appears to have been carried out.

Despite Canterbury being the centre of New Zealand cereal cropping, and cereal crops having, on average 5-7 pesticide sprays a season, there has been limited or no testing of agrichemicals in Canterbury’s most polluted waterways. It is not just dairying that we must track. Good science would be to monitor sediment and surface water annually - for the agrichemicals used in cropping and horticulture in the region. This would create the evidence base for further decision-making. Non-knowledge privileges the agrichemical industry.

Moreover, if we simply label sediment, as sediment, (see the RMA for no description of wet dirt) it can be difficult to consider ‘wet dirt’ as a future pollution issue. Yet sediment can capture persistent and harmful chemicals in its dark environment for a long time. If we label nitrogen and phosphorous as nutrients, we are less able to consider them as agrichemicals. This ‘muddies the water’ - delaying us, making us clumsier in recognising and researching the cumulative impacts on our waterways, and the low dose synergies that could very well be contributing to our waters’ chronic ill-health.

Nitrogen is a major problem, but it isn’t the only issue. Commissioner for the Environment Simon Upton has made some great inroads – testing the MCI is a clever and scientific way to assess aquatic health – but then we need to step into a suite of testing for local agricultural, urban and industrial chemicals. Just like Europe does. The October 2018 NZ Freshwater Agenda continues to ignore agricultural, industrial and urban agrichemicals.

How we frame pollution in our waterways – the language we use - has a direct effect on the challenges and threats we seek to address, and, our capacity to protect future New Zealanders.

Moving forward – a freshwater rescue plan and a national approach to environmental chemicals

A Freshwater Rescue Plan (FRP), released to counter this extensively criticised 2017 National Policy Statement, included expert input from experts from New Zealand’s leading universities. The FRP maintains ‘The Government’s current policy has limits to these major pollutants that are either so weak that they offer little protection, or they have been left out entirely.’ The Freshwater Rescue Plan outlines seven steps necessary for protecting New Zealand’s waterways, and deserves greater media and public attention than so far granted. [16]

In addition to the FRP seven steps, New Zealanders deserve a greater commitment to transparently monitoring environmental synthetic chemical pollution and the toxic mixtures that can lead to polluted, sterile and dysregulated water systems, if we are to scientifically and strategically protect our environment from a very real pollution threat.

New Zealand citizens and public servants depend on data collection to be consistent, transparent and timely. We require the language to be plain and clear. As a community, we deserve the intelligence to understand long term risk to our water supplies, basing risk analysis on the latest science in the published literature. We deserve a moral dialogue that recognises the intangible nature of this resource, the goodwill embedded in it, and the risk we face when international trust is eroded.

This cannot be achieved without greater national leadership, dedicated scientific integrity and national funding. This is essential so that we may, in the national interest, safeguard our water and protect future generations.

I have attempted to submit this article for publication in NZ media but have been unsuccessful.


[1] Steffen, W.; Richardson, K.; Rockström, J.; Cornell, S.E.; Fetzer, I.; Bennett, E.M.; Biggs, R.; Carpenter, S.R.; de Vries, W.; de Wit, C.A.; Folke, C.; Gerten, D.; Heinke, J.; Mace, G.M.; Persson, L.M.; Ramanathan, V.; Reyers, B.; Sörlin, S. Planetary boundaries: Guiding human development on a changing planet. Science (2015) 347 (6223) 1259855-1259855. [DOI: 10.1126/science.1259855]

[2] Hazardous Substances and New Organisms Act. Part 2. Purpose of Act. Sn 4.

[3] Resource Management (National Environmental Standards for Sources of Human Drinking Water) Regulations 2007

[4] Landrigan et al 2017. The Lancet Commission on pollution and health.

[5] Global pollution kills 9m a year and threatens 'survival of human societies' D. Carrington The Guardian Oct 20, 2017.

[6] New Zealand National Policy Statement for Freshwater Management 2014, which was updated August 2017 to incorporate amendments from the National Policy Statement for Freshwater Amendment Order 2017.

[7] J.Morton 50 questions about the environment: Our rivers NZH Jan 15, 2017

[8] Chemical Drains: New Zealand’s new NPS-FW freshwater policy is not watertight. J. Bruning 2017.

[9] Safeguarding the Future: Governing in an Uncertain World. Jonathan Boston. BWB Texts 2017. ISBN 9780947518257. DOI 10.7810/9780947518257

[10] Drinking water Standards for New Zealand 2005 (Revised 2008)

[11] Guyton KZ, Loomis D, Grosse Y, et al, for the International Agency for Research on Cancer Monograph Working Group. Carcinogenicity of tetrachlorvinphos, parathion, malathion, diazinon, and glyphosate. Lancet Oncol 2015; 16: 490–91.

[12] National Survey of Pesticides in Groundwater 2014 ESR. B.Humphries and M.Close.

[13] Sixth national survey of pesticides in groundwater in New Zealand. 2012 ESR. ME Close & A Skinner.

[14] Environment Bay of Plenty State of the Environment Groundwater Level and Quality. G.Zemansky. GNS Science Consultancy Report 2006/116 June 2006. (Data for wells 0001 1393 2707 3301 indicated significant trends).