STEWARDING: FRESHWATER

In 2019 the Soil & Health Association and PSGRNZ released the joint paper Aotearoa New Zealand Policy Proposals on healthy waterways: Are they fit for Purpose? Our white paper highlighted a critical gap in the Government’s Action for Healthy Waterways proposals.

We sent submissions into the related consultations, and sent out press releases to all media. The concerns expressed in that 2019 paper were not covered by the media, despite the fact that a major government consultation was underway.

Seven years ago, we discussed at length that a freshwater policy cannot credibly protect waterways for future generations if it did not have a systematic way to identify and investigate significant chemical contaminants.

The Government was prepared to discuss sediment, bacteria and nutrients. There were measures (called attributes) for nitrogen, phosphorus, dissolved oxygen, E. coli, sediment, periphyton, cyanobacteria, macroinvertebrates and fish communities which were subsequently incorporated into the National Environment Standards for Freshwater framework - the NES-FW.

What the proposed new standards did not build in, was an equivalent national architecture for anthropogenic chemical contaminants from urban, industrial and agricultural sources.

Despite our best efforts (and we were aware that a wider public were also sending their chemical pollutant concerns into the committee) the issue ‘was disappeared’. The Ministry’s Summary of submissions, published in May 2020, responsible for summarising 17,500 submissions, only mentioned chemical pollution fleetingly. The document noted calls to investigate ‘emerging contaminants’ because of their implications for human and ecosystem health, and elsewhere records concerns about chemicals and emerging contaminants in stormwater and drinking water.

It isn’t just us. Over this same period, Parliamentary Commissioner for the Environment Simon Upton has repeatedly raised these concerns - including at the highest levels. His reports and papers in 2019 2020 2021 2022 2026 are testament to a sustained effort to improve New Zealand’s environmental knowledge and reporting systems. Yet remarkably little seems to change.

The problem, seven years later in late 2026, is that several parliamentary Bills which claim to improve environmental stewardship, continue to fail to address the problem - the gap - that we identified so many years ago. If a government agency does not specifically require that a process is followed, and then also fund the work so that it can be done - it will not be done.

Environmental Reporting Amendment Bill 321-1 - 20/8/2026 PSGR Submission to Select committee.
Natural Environment Bill 234-2 - 13/2/2026 PSGR Submission to Select committee.
Hazardous Substances and New Organisms Amendment Bill (304-1) – 3/6/2026 PSGR Submission to Select committee.

At every opportunity, we have highlighted the risks. When we cannot know what is happening, we cannot stop it! We have highlighted the problems that arise when higher-level legislation fails to establish adequate frameworks requiring officials to detect, monitor and investigate chemical contamination. Without those frameworks, agencies may have no systematic process for determining whether industrial chemicals, agrichemicals, wastewater contaminants or other human-made substances are contributing to the degradation of a groundwater source, lake or river, and then feeding that knowledge back into regulatory decisions.

The government had commenced a work programme in 2022 in response to the PCE’s eight recommendations, outlined in his 2022 paper: Environmental reporting, research and investment. Do we know if we’re making a difference? But, even though it was a National Party 2023 election manifesto, by 2024, the programme was to all appearances, discarded:

‘I am refusing your request in full under section 18(e) of the Act as the information requested does not exist or, despite reasonable efforts to locate it, cannot be found. … there is currently no work to establish a nationally consistent monitoring framework for anthropogenic synthetic chemical contaminants in freshwater.’

Currently, government monitoring is largely organised around the national environment standards for freshwater (NES-F) a relatively narrow set of established indicators and contaminants, including nutrients such as nitrogen and phosphorus, microbial indicators such as E. coli, sediment, and selected metals and other known contaminants. What is largely missing is a systematic framework for detecting and investigating the much wider range of synthetic chemicals entering the environment, including pesticides and their metabolites, PFAS, pharmaceuticals, plastic-associated chemicals, industrial chemicals and complex mixtures.

If we do not routinely look for these substances, it becomes very difficult to establish where they are occurring, at what concentrations, whether they are contributing to ecological degradation, or whether regulation needs to change.

This becomes particularly important at the level of the local receiving environment. Existing freshwater monitoring and national standards may tell council staff that a river, lake or groundwater body is degraded, but that does not necessarily provide them with the investigative framework needed to determine why.

Where the familiar indicators do not adequately explain the observed degradation, there is no sufficiently developed framework that guides officials towards a progressively broader suite of chemical testing based on plausible local sources and pathways.

That might mean looking beyond nutrients, E. coli, sediment and selected metals to pesticides and their metabolites, PFAS, pharmaceuticals, plastic-associated chemicals, industrial chemicals, wastewater contaminants and, ultimately, relevant mixtures.

We raised this issue in 2019, when the government had $221 for freshwater improvement, and we (and all the groups that supported our paper) were ignored.

The critical missing step is therefore the bridge between detecting degradation and investigating causation. A functioning environmental-health system should enable an unexplained signal of harm to trigger progressively more sophisticated investigation, identify plausible contaminants and sources, and feed those findings back into monitoring, regulation and pollution prevention. Without that capability, we can know that a receiving environment is degraded while remaining remarkably poorly equipped to discover what is degrading it.

As of 2026 we have no Ministry for the Environment. We have a Secretary for the Environment (see Environment Act 1986, part 2). It is unclear whether that Secretary has the authority and resources to undertake the important work that is required to bring attention to the challenge from anthropogenic, manmade synthetic chemical pollutants.

Keep an eye out for ta response to this Official Information Act request NGOIA162 / 26-OIAD-02614. Hopefully we might find out a little more on this issue.

More information is available on a related Op Ed: Labour & National had $221 million for Freshwater Improvement. They didn’t ask about the Chemicals. New Zealand keeps rewriting environmental law without building the science frameworks to detect chemical harm. (September 2, 2026)

These fantastic organisations supported our 2019 white paper: Aotearoa New Zealand Policy Proposals on healthy waterways: Are they fit for Purpose? (2019) Published by: The Soil and Health Association of New Zealand and Physicians and Scientists for Global Responsibility Charitable Trust New Zealand Wellington, New Zealand Cover Image: N.Thamm ISBN (digital) 978-0-473-50130-3

WE CAN DETECT DEGRADATION, BUT NOT WHAT IS CAUSING IT

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