Dear Ministry for the Environment,

Under the Official Information Act 1982, I request information concerning national policy, funding and monitoring arrangements for anthropogenic synthetic (i.e. manmade) chemical contaminants in freshwater including policy and work undertaken through, or associated with, the Freshwater Improvement Fund (approximately $221 million appropriated between July 2020 and June 2025).

NB. This request does not include any request for information relating to the ESR groundwater studies and the trace (heavy) metals that are recognised in policy.

BACKGROUND TO THE REQUEST
This request seeks to understand the extent to which this fund contributed to national policy and strategy to enable regional councils to monitor, interpret and report anthropogenic synthetic chemical contaminants in a nationally consistent manner.

The purpose of this request is to understand how New Zealand's freshwater governance framework is intended to address anthropogenic synthetic chemical contaminants at a national level. It is unclear how New Zealand expects anthropogenic synthetic contaminants to be monitored, interpreted and managed within its freshwater systems.

Unfortunately, this is not located in the National Policy Statement for Freshwater management.

The Ministry for the Environment is responsible for developing the National Policy Statement for Freshwater Management, National Environmental Standards and the broader policy framework within which regional councils operate. Where nationally consistent monitoring parameters and reporting standards are not established, councils are necessarily left to determine independently whether, what and how to monitor, reducing national consistency and making it difficult to identify emerging contaminant trends or compare environmental outcomes between regions.

While the Environmental Protection Authority has important regulatory functions under the Hazardous Substances and New Organisms Act 1996, it is not resourced to undertake nationwide freshwater monitoring or to establish a comprehensive national environmental monitoring system. It is therefore important to understand what national policy framework, guidance and investment the Ministry has developed to support consistent monitoring and assessment of anthropogenic synthetic chemical contaminants in freshwater.

I have been unable to identify nationally consistent freshwater monitoring parameters, environmental benchmarks or environmental exposure limits (EELs) for anthropogenic synthetic chemical contaminants (including classes of chemicals) that would enable regional councils to evaluate monitoring results consistently across New Zealand. Without exposure levels, the regions are faced with inconsistent expectations of stewarding water but not understanding how to steward it.

The Freshwater Improvement Fund received approximately $221 million in appropriations between July 2020 and June 2025.

New Zealand’s freshwater policy framework also establishes freshwater attributes and other measures addressing matters such as:
 dissolved oxygen;
 nitrate and ammoniacal nitrogen toxicity;
 dissolved reactive phosphorus;
 total nitrogen and total phosphorus;
 visual clarity and deposited fine sediment;
 periphyton and chlorophyll-a;
 macroinvertebrate and fish-community health;
 cyanobacteria;
 E. coli; and
 ecosystem metabolism.

These measures address nutrients, sediment, microbiological contamination and ecological condition. However, I cannot identify equivalent compulsory national attributes, monitoring standards or reporting requirements for concentrations of anthropogenic synthetic contaminants, including:
i. pesticides, herbicides, fungicides and insecticides;
ii. PFAS;
iii. human and veterinary pharmaceuticals;
iv. endocrine-disrupting chemicals;
v. industrial contaminants;
vi. household chemicals;
vii. urban chemical pollutant stormwater contaminants; and
viii. other synthetic organic chemicals.

Such contaminants may contribute to ecological degradation while remaining unidentified by monitoring programmes that assess only conventional nutrient, bacterial, physical and biological indicators.

There is sustained public interest in the problem of manmade chemicals in freshwater, yet this has not been reflected in policy papers that I can identify.

2017: Documents cited in the ‘History of the National Policy Statement for Freshwater’
https://environment.govt.nz/acts-and-reg...

2019: Action for healthy waterways discussion document on national direction for our essential freshwater (September 2019)
https://environment.govt.nz/assets/publi...

2020: National Policy Statement for Freshwater Management (August 2020, superseded).
https://environment.govt.nz/assets/publi...

2020: Regulatory Impact Analysis Action for healthy waterways Part I: Summary & Overall impacts
https://www.regulation.govt.nz/assets/RI...

2025: National Policy Statement for Freshwater Management 2020 (Amended Dec 2025).
https://environment.govt.nz/assets/publi...

In 2019, Physicians and Scientists for Global Responsibility New Zealand and the Soil & Health Association produced the paper Aotearoa New Zealand Policy Proposals on Healthy Waterways: Are They Fit for Purpose?
https://psgr.org.nz/component/jdownloads...

The paper raised concerns about the omission of synthetic chemical contaminants from the proposed freshwater framework and it was sent to the Action for Healthy Waterways consultation. Therefore, the government had received information that synthetic chemical contaminants were a likely relevant consideration for any future policy framework.

However, the May 2020 summary of submissions to the Action for Healthy Waterways consultation, which received some 17,500 submissions, contained no mention of any of the synthetic contaminants mentioned in i-viii above. It instead, reflected the national standards focus on the expressed attributes, nutrients, bacteria and sediments.

As of July 2026 it is difficult to identify how the challenge of chemical pollution in water has been addressed, and the $221 million Freshwater fund appears to be the most likely allocation under which such work could be undertaken.

OFFICIAL INFORMATION ACT REQUEST

Please provide the following information for the period 1 January 2018 to the date of this request for the following activities relating to and funded by the $221 million Freshwater Improvement Fund.

1. National Environment Standards – freshwater.
Please provide any advice considering whether ecological attributes (for example dissolved oxygen, periphyton, macroinvertebrates, fish indices and nutrient measures) were considered sufficient proxies for the presence or effects of anthropogenic synthetic chemical contaminants, and if so, the scientific basis for that conclusion.
Freshwater Policy development: anthropogenic synthetic chemical contaminants
Copies of all Cabinet papers, Cabinet minutes, policy papers, ministerial briefings, scientific advice, reports and research concerning the monitoring, assessment or management of anthropogenic synthetic chemical contaminants in freshwater, including but not limited to pesticides, herbicides, fungicides, insecticides, PFAS, pharmaceuticals, endocrine-disrupting chemicals, industrial chemicals and other emerging contaminants.
2. Freshwater attribute framework: anthropogenic synthetic chemical contaminants
Copies of all advice, briefings, reports, correspondence and decision papers prepared for, or provided to, Ministers, Deputy Secretaries, Directors, programme managers or governance groups considering or urging that synthetic chemical contaminants should be incorporated into the National Policy Statement for Freshwater Management or associated National Environmental Standards as:
a. compulsory freshwater attributes;
b. national bottom lines;
c. environmental limits;
d. compulsory monitoring requirements;
e. nationally consistent reporting requirements; or
f. indicators within national environmental reporting.
Please include any advice explaining why such contaminants were not incorporated into the national attribute framework.
3. National monitoring framework: anthropogenic synthetic chemical contaminants
Copies of any strategy, policy, guidance, reasoning, framework or work programme intended to support regional councils, territorial authorities or unitary authorities to undertake nationally consistent monitoring of synthetic chemical contaminants, including guidance concerning:
a. priority contaminants;
b. sampling design and frequency;
c. analytical methods and detection limits;
d. assessment of mixtures and cumulative exposure;
e. interpretation of monitoring results including trigger values or thresholds requiring management action;
f. environmental benchmarks; and
g. nationally consistent reporting.
If no such framework exists, please confirm this.

4. Funding: anthropogenic synthetic chemical contaminants
Details of all funding allocated since 1 January 2018 under the Freshwater Improvement Fund for monitoring, analysing, interpreting and reporting anthropogenic synthetic chemical contaminants as freshwater risks, including to evaluate exposures by region/waterway:
 pesticides, herbicides, fungicides and insecticides;
 PFAS;
 human and veterinary pharmaceuticals;
 endocrine-disrupting chemicals;
 industrial contaminants;
 urban stormwater contaminants; and
 other synthetic organic chemicals.
including for:
a. analysis of monitoring data supplied by territorial authorities.
b. laboratory analytical capability;
c. contaminant surveys;
d. development of environmental benchmarks or exposure limits;
e. national monitoring guidance; and
f. nationally consistent reporting systems.

5. Freshwater Improvement Fund
Please provide any advice evaluating whether the Freshwater Improvement Fund contributed to developing:
a. nationally consistent monitoring capability;
b. national analytical capability;
c. national reporting systems;
d. guidance for regional councils;
e. or regulatory capability;
relating to the synthetic chemical contaminants listed above.

6. Regulatory framework: Responsibility across government.
Copies of all advice considering how responsibility for monitoring synthetic chemical contaminants in freshwater and receiving environments for drinking water is divided between:
a. the Ministry for the Environment;
b. the Environmental Protection Authority;
c. regional councils;
d. Taumata Arowai;
e. the Ministry of Health;
f. and any other public agency.
This includes advice concerning any uncertainty, overlap or regulatory gaps.
Please indicate issues where responsibility remains undefined.

7. Future national monitoring strategy and resourcing for freshwater contaminant chemicals
Following the cessation of the Freshwater Improvement Fund please provide any current or proposed programme intended to establish nationally consistent monitoring, the development of nationally consistent contaminant datasets and reporting of synthetic chemical contaminants in freshwater, including:
 scope;
 governance;
 staffing;
 budget;
 timetable;
 priority contaminants;
 implementation status; and
 expected outputs.

8. Absence of policy
Where any strategy, framework, guidance, monitoring programme or policy referred to above does not exist, please confirm that this is the case.
Where information is withheld, please identify the relevant withholding ground and release the remainder in redacted form rather than withholding documents in full. Please transfer any part of this request to the appropriate agency under section 14 of the Official Information Act where necessary.

Thank you

Yours sincerely

J Bruning.