2023 DoC & LINZ consultation on information & emerging technologies

The Physicians and Scientists for Global Responsibility welcome the opportunity to submit to the public consultation on the use of emerging technologies to help biodiversity thrive.

Submission to: The Department of Conservation and Toitū Te Whenua Land Information New Zealand (LINZ).

This response concerns feedback relating to the November 2022 draft Long Term Insight Briefing.[1][2]

[PDF COPY OF THE SUBMISSION HERE]

The deadline for this submission was January 16, 2023

[A] THE PSGR SUBMIT THAT:

The questions in the Long Term Insight Briefing document reflect the fact that this consultation is not primarily concerned with the application of highly relevant scientific and technological processes to understand key drivers of biodiversity decline, but rather, illustrate that this document is primarily concerned with securing social, political and cultural licence for the funding and policy integration of a narrow set of technologies named in (3) below.
A strategic approach that can more adequately establish a robust and comprehensive approach to environmental science and environmental protection, as suggested by the Parliamentary Commissioner for the Environment (see part [B]), has been ignored.
Document authors did not review the relevant scholarly and regulatory literature available that would (a) identify established and new pathways of biological risk to the ecosystems that support biodiversity; (b) identify new knowledges of how harm is plausibly occurring (including through combinatory effects of stressors); and (c) explore appropriate scientific and technological approaches that can address the leading variables identified in (a) and (b).
This work could then prioritise what work was most urgent for the purposes of policy formulation and investment in science and technology.
The question ‘How can we help biodiversity thrive through the innovative use of information and emerging technologies?’ is configured to promote discussion revolving around a narrow set of technologies:
- Satellite imagery and remote sensing (for much greater environmental monitoring and surveillance).
- AI and data-driven technologies (for collecting and analysing vast quantities of data).
- Genetic technologies (for new realms of environmental monitoring and management).
These expensive technologies are not first order technologies suitable for the identification of many scientifically established primary drivers of biodiversity decline.
By the selection of the technologies, scientific and analytical research on air, water and soil pollution, a primary driver of biodiversity decline remains out of scope (see part [C] and [E]). e. monitoring and analysis of complex chemicals and heavy metals cannot be realistically and meaningfully undertaken ‘remotely’ or by ‘satellite’.
Due to absence of reflection of the findings of the Parliamentary Commissioner for the Environment, and the ignorance regarding what drivers actually constitutes hazard and risk (and as such is most appropriate for directing policy), and the seemingly arbitrary selection of a narrow range of technologies, the PSGR recommend that this Long Term Insight Briefing is inadequately informed, inappropriate and premature.
The PSGR recommend that a broader consultation across the science and research community, and that analysis by public sector scientists, are instead undertaken to identify priorities for research, consistent with the Parliamentary Commissioner’s recommendations.
The word ‘thrive’ directs consideration away from a broad range of possible anthropogenic (industrial, agricultural and urban) drivers which stress ecosystems, including the mauri of the ecosystem. A failure to thrive as a consequence of overlapping environmental stressors which require much more informed and strategic research trajectories, appear outside the scope of the officials who drafted this document.
The questions (part [D]) are awkward to answer as complex, highly specialist and interdisciplinary expertise and technologies, involving a broad range of science and technologies are required to properly assess the drivers of biodiversity decline, and analyse potential policy mechanisms that would ameliorate or halt decline. In addition, the questions appear focussed on techniques to secure social and cultural licence for the specific technologies that appear that officials are focussed on.
There can be no doubt that the scope for consideration has been predetermined. This is evident from the background research (see part [F]) which has a narrow remit. The background information has been curated for the purpose of directing research funding to a small range of defined technologies.
The Long Term Insight Briefing reflects an historic, political reluctance to strategically address dominant environmental drivers of biodiversity decline and adopt a comprehensive approach to environmental science research that is guided by principles of stewardship and kaitiakitanga, and purposefully dedicated to preventing further environmental harm, rather than principles of technology application.
The PSGR request that the government, including elected representatives and officials develop a political will to allocate budgetary funding for environmental science and research funding so that officials and civil society may understand the complex drivers of environmental degradation.
Such research must be conducted independently from the powerful ministries and managers which currently predominantly funnel science and research funding to projects with commercialisation or income-related benefit. As scientists that identify the social, industrial and agricultural drivers which threaten biodiversity can come under political pressure, there must be a safe place for this to be done, if the mauri – water, land, flora and fauna – of Aotearoa New Zealand is to be actively protected, and the principles of the Treaty of Waitangi is to be honoured.

To read further and access the complete submission, click HERE

REFERENCES

[1] Have your say on how we innovate and shape the future for thriving biodiversity. https://www.doc.govt.nz/ltib-consult

[2] Long Term Insight Briefing https://www.doc.govt.nz/contentassets/8bb2214f37aa47ffbbba17af76fd5e46/ltib-draft-2022.pdf

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