Water quality has been a point of contention for dairy farmers.
Dairy industry critics have made politics out of recent reports on water quality by the Parliamentary Commissioner for the Environment.
Dr Jan Wright has issued two reports, Managing Water Quality: examining the 2014 National Policy Statement and updated her 2013 Land Use and Nutrient Pollution report.
But nearly all commentators missed the real significance of Dr Wright's reports.
From chemicals to biology
The first report signals a major change. Previously she had taken a broad-brush generic interest in nutrient discharge in waterways. Now her approach is more targeted.
Dr Wright's report concentrates on what needs to be fixed. She advocates, "focused efforts on certain water bodies, especially those which are especially vulnerable, or under particular pressure".
"It is critically important that councils prioritise their efforts and expenditure, so that immediate problems and pressure points are tackled early."
"Not every waterway in the country is in need of management. And where water quality is under pressure, not every attribute is important. Comprehensiveness should not trump effectiveness."
In previous reports, Dr Wright used the volumes of sediment, nutrients and bacteria as measurements of water quality.
In her latest report, she recommends bio-indicators, such as populations of fish, insects and algae to assess the health of an ecosystem.
If the macro-invertebrates (i.e. big insects) are doing well, we can assume the sediment, nutrients and temperature are not a problem. Conversely, if the index of macro-invertebrates is low, then the health of the watercourse is poor and something needs to be done about it.
This is a welcome and fundamental shift. It moves attention from chemical decimal points along to the endgame of the actual life in the river.
Her update report reinforces this theme. The earlier 2013 report focused on just two attributes -- nitrogen and phosphorous -- pointing to their role in contributing to algal growth.
The 2015 update looks at macro-invertebrate health. For 2000-2010, data from more than 300 testing sites shows no change for 80 per cent of them. Stream health is generally stable.
Noticeable were improvements in Taranaki, and 'red dots" indicating decline in some parts of Southland.
Southland Regional Council data from the same period grades four of 71 sites as 'poor'. These statistics - broadly the 80/20 game -- are a strong endorsement of Dr Wright's emphasis on hotspots.
Wrong figure in - wrong figures out
The welcome change in Dr Wright's direction in measurement of stream health is yet to be balanced by any revision of assumptions by her Ministry on land use change.
The Ministry uses land use statistics to make assumptions on water quality and therefore regulations. There is more discharge from cow farming than running sheep, for instance.
The 2013 report assumed dairy prices would hold at $6 to $7 to drive 370,000ha into dairy conversions by 2020.
The 2015 update report shows - through to 2012 -- the area of land in dairy increased by 10 per cent from 2008.
More recently of course, dairy prices have crashed well below $7.
The 2015 report ignores this. It even questions whether it has underestimated the conversion rate. It highlights conversions to dairying in Waikato by 2012 having already exceeded its 2020 projection and so the Ministry claims "the 2013 report is likely to have underpredicted the nutrients that will be lost from land into water."
So, using one regional exception, the Ministry is sticking to its 2013 formula to get to 2020.
It still believes in the accelerated loss of more than 700,000ha of sheep and beef farms. Some 500,000ha of hill country farmland is supposed to be planted in pines or revert to scrub. On the lowlands the remaining 200,000 ha will become dairy land.
Still using the $7 payout, the Ministry imagines by 2020 in the Auckland region another 8000ha of dairy farming, 26,000ha more in Manawatu and another 37,000ha of dairy cow farming in Otago.
It would be great if the $7.09 per kilo model Dr Wright uses was still real. It is not. The model needs to accommodate new price realities.
To use Dr Wright's own words, there needs to be "transparency which is characteristic of good policy".