Enough is enough: Consenting and monitoring challenges

Environmental monitoring sits at the heart of responsible aquaculture. It helps us understand environmental effects, demonstrate compliance and give regulators, operators and communities confidence that environmental safeguards are doing what they are intended to do.

It is a question we are encountering more often in our work across New Zealand’s aquaculture industry.

Consenting inevitably requires decisions to be made with a degree of uncertainty. Proposed developments vary in scale, duration, and intensity, while assessments need to consider everything from environmental sensitivity and natural variability to potential cumulative effects. Operators, regulators and stakeholders all bring different information and perspectives into that process, and decision-makers ultimately have to turn a complicated body of evidence into controls, conditions and monitoring requirements.

For new activities, new regions or environments where there is limited existing information, it makes sense for those requirements to be precautionary. The challenge comes later, when the evidence has developed but the monitoring framework has not necessarily developed with it.

What happens when we know more?

A consent reflects what was known, and what could reasonably be anticipated, at the time it was granted. It should not follow that our understanding of environmental risk remains fixed at that same point.

Some aquaculture sites now have extensive monitoring records behind them, and those long-term datasets are increasingly being complemented by new research, guidance and monitoring technologies. Together, they can give us a much richer understanding of environmental effects than we had when conditions were originally established.

We have seen this play out with high-flow finfish farms in the Marlborough Sounds. Over time, similar farms had developed complex and variable consent conditions, intensive monitoring requirements and differing interpretations around compliance. Long-term datasets, new research, new guidance and technology provided an opportunity to revisit those requirements and remove assumptions that were no longer appropriate.

The important point is that environmental protection was maintained. What changed was the way it was demonstrated, with more standardised conditions, reduced monitoring requirements where appropriate and clearer compliance assessment processes.

That is where we think the distinction between less monitoring and better monitoring becomes important.

Proportionality needs to be part of the conversation

Scale is another part of the equation.

One of the examples we speak to in our Aquaculture New Zealand Conference presentation involves a pilot-scale operation with two pens at the Blue Endeavour offshore salmon farm, 600-tonnes of feed input per year, but with monitoring requirements assuming a20 pens and 20,000 tonnes of feed input.

There are good reasons to consider what an operation may look like at full scale, but it also raises a practical question: at what point do monitoring requirements become disproportionate to the activity actually taking place, and how should this be captured in consent conditions?

Monitoring needs to provide the information required to understand environmental effects, but greater monitoring effort does not automatically produce greater environmental protection. If requirements are considerably out of step with the scale, duration or intensity of an activity, we need to be able to ask whether that additional effort is generating useful environmental information.

For us, proportionality is not about lowering the bar. It is about making sure the bar is in the right place, supported by the evidence available.

Monitoring should help us test our assumptions

Perhaps one of the clearest demonstrations of this comes from the monitoring of high-value reef environments close to finfish farms.

The presentation considers reefs within 80 metres of farms where annual monitoring requirements were established. More than 15 years of monitoring found no farm-related detrimental effects on the reef, while eDNA tools identified little or no detectable farm-related deposition.

Sometimes that evidence will reinforce the need for close scrutiny. At other times, it may demonstrate that an anticipated effect is not occurring in the way initially expected. A strong environmental management framework should be capable of responding to both.

If we expect monitoring requirements to increase when evidence identifies a new or greater risk, it is reasonable that they should also be reconsidered when a strong body of evidence points in the other direction.

The same approach will not work everywhere

There is also value in consistency, particularly when it gives operators and regulators greater clarity around how environmental performance will be assessed. However, consistency should not become a substitute for considering the environment in front of us.

Receptors, environmental sensitivity, background variability and cumulative effects can differ considerably between locations. A monitoring methodology that makes sense in one environment may not necessarily provide an accurate picture somewhere else.

This matters because conditions that are not well aligned with the receiving environment can lead to inaccurate compliance limits, unnecessary complexity and additional cost without delivering a better environmental outcome.

Rather than simply asking whether we are monitoring enough, we should be asking whether we are monitoring the right things, in the right way, for the environment and level of risk in front of us.

Using better evidence to make better decisions

None of this is an argument for stepping back from robust consenting or environmental monitoring. If anything, it is an argument for getting more value from both.

The information accumulated through long-term monitoring should help improve the decisions we make next. As scientific understanding develops, technology improves and datasets grow, we have an opportunity to make consent conditions and compliance measures more precise, relevant and effective.

The examples presented at the conference show that environmental protection can be maintained while conditions become more realistic, monitoring becomes more proportionate and compliance processes become clearer. They also show that financial savings can follow, although that should be an outcome of better environmental management rather than the reason for it.

Ultimately, the measure of a good monitoring programme should not simply be how much data we collect. It should be whether that information is continuing to tell us something useful about the environment we are trying to understand and protect.