% 1070 words % actual: ~1040 words % Explain how you would identify the significant effects. Discuss % any difficulties in determining the significance of effects in EIA \section{Significance} The process of impact assessment is conceptually open-ended. As one of its major goals is to aid a decision-making process, however, each step in the assessment must be completed within a given time frame. Hence, limits are imposed on the level of detail, the length of the time period for which impacts can be assessed at the expected level of detail, and the number of interactions that can reasonably be considered. To set these limits, judgments must be made on how significant each potential impact is, a decision on how much detail and how much effort in avoiding or mitigating the impact is appropriate, and whether the residual impact is insignificant enough to be acceptable. These judgments are crucially guided by the practitioners' own values and the values they consider in the evaluation process \parencite{lawrence}. As the determination of significance is inherently subjective, it should not be an activity performed only by experts and with a claim to objectivity, but should aim to be a collaborative procedure guided by reasoned discourse \parencite{lawrence-approach}. One of the goals of impact assessment is to weigh the desired positive impacts of a proposal against the expected negative impacts in order to evaluate whether the project plan should be pursued or discarded. The dairy factory could, for example, result in an increase in the number of employment opportunities, enlarge the economic basis of the region, increase the country's export volume, etc. While it is possible to quantify many of these positive effects (e.g. by estimating from experience with similar projects) it is not clear how to weigh these potential economic benefits against the expected negative impacts on the biophysical and social environment without imposing market norms on intrinsic ecosystem and community values. Just how much more valuable is the somewhat polluted river now compared to a somewhat \emph{more} polluted river if the project was implemented? Involving the public in a collaborative approach may not lead to satisfying results. As \textcite{lawrence-approach} writes, ``the collaborative approach is viewed as too quickly equating public concerns and issues with impact significance, at the expense of other sources of insight and knowledge.'' According to \textcite{lawrence-approach}, the approach to determining impact significance is usually ``limited to ad hoc and inconsistent judgments with reasons and/or to the staged application of thresholds and/or criteria.'' The Resource Management Act 1991 does not prescribe a process for the assessment of significant effects. As all major projects require resource consents, however, impact significance is, in practice, reflected by the management plans and established by resource consent decisions of regional and territorial councils. The Ministry for the Environment bemoans that a ``lack of clarity and certainty in some regional plans (eg, a lack of enforceable limits) has led to issues being decided consent by consent and often re-litigated'', resulting in ``decision-making processes [that] are litigious, resource-consuming and create uncertainty'' \parencite[p. 18][]{freshwater-reform}. Since the National Policy Statement for Freshwater Management (2011) the ``national values of fresh water'' have been made explicit, but their postulation does not give rise to a guideline by which the significance of activities affecting these values could be determined. For example, the statement made in the NPSFM that water is valued for ``cleaning, dilution and disposal of waste'' conflicts with the statement about respecting water's intrinsic values such as ``the natural conditions of fresh water, free from biological or chemical alterations resulting from human activity'' \parencite{npsfm-guide}. Resolving this ambiguity, the NPSFM intends a limits-based regime to be established where regional councils are expected to collaborate with the community to translate individual values and freshwater objectives into enforceable limits for individual water bodies \parencite[][p. 14]{npsfm-guide}. The implementation and enforcement of this National Policy Statement---and pending its implementation, decisions relating to the significance of project impacts on the environment---crucially depend on a sound information base derived from regular monitoring. The National River Water Quality Network enables the measurement of various water quality indicators (e.g. temperature, dissolved oxygen, turbidity, nutrients etc.) at 77 sites and has been used to measure nation-wide water quality trends. In total there are about 600 monitoring sites \parencite{nrwqn}. %According to the \emph{Environment New Zealand 2007} report ... % say something about water quality trends? Following a limits-based approach and with the help of monitoring networks, it would be practical to impose absolute limits for a variety of water health indicators. Whether a residual impact on the physical environment is significant or not then is a matter of evaluating the expected level of the impacts of a proposed activity in light of the measured quality trends. In the case of the planned dairy factory, the significance of the impact of discharging warm water into the river not only depends on the absolute value of the temperature difference between wastewater and river water, but also on the cumulative temperature increase due to human activity reflected in the mean temperature of the affected body of water. Case studies can be used to estimate the magnitude of the impact. If the limit on water temperature would be exceeded by the plant's wastewater discharge, the impact would be rated as significant and in need of mitigation to avoid significant effects on the aquatic ecosystem. The same approach is applicable for any impact that affects quantifiable environmental properties, such as the release of organic and inorganic compounds, or the contamination with residual antibiotics and pesticides. According to the description, the river is already used as a sink for the wastewater of another dairy factory; dairy farming is said to have expanded in this area, indicating that the inflow of organic and inorganic components from farm effluent and non-point sources has also increased. It is likely that under these circumstances, the cumulative impacts of wastewater discharge would be deemed significant. Other impacts cannot easily be quantified. This includes higher-order impacts such as the stress that an increased number of workers may exert on local community services. The likelihood of these impacts depends on the state of local facilities and the cumulative workload they are sustaining. As it is difficult to find appropriate indicators for the state of social values and impractical at best to set upper limits for such ill-defined concepts, a limit-based approach to significance estimation is unlikely to succeed. This is an area where there is probably no better way to assess significance than to ask for direct community involvement.