NPS-FM Clause 3.11: Setting target attribute states

  1. In order to achieve the environmental outcomes included as objectives under clause 3.9, every regional council must:
    1. set a target attribute state for every attribute identified for a value; and
    2. identify the site or sites to which the target attribute state applies.
  2. The target attribute state for every value with attributes (except the value human contact) must be set at or above the baseline state of that attribute.
  3. The target attribute state for the value human contact must be set above the baseline state of that attribute, unless the baseline state is already within the A band of Tables 9 or 10 in Appendix 2A, as applicable.
  4. If the baseline state of an attribute is below any national bottom line for that attribute, the target attribute state must be set at or above the national bottom line (see clauses 3.31, 3.32, and 3.33 for exceptions to this).
  5. Every target attribute state must:
    1. specify a timeframe for achieving the target attribute state or, if the target attribute state has already been achieved, state that it will be maintained as from a specified date; and
    2. for attributes identified in Appendix 2A or 2B, be set in the terms specified in the relevant Appendix; and
    3. for any other attribute, be set in any way appropriate to the attribute.
  6. Timeframes for achieving target attribute states may be of any length or period but, if timeframes are long term:
    1. they must include interim target attribute states (set for intervals of not more than 10 years) to be used to assess progress towards achieving the target attribute state in the long term; and
    2. if interim target attribute states are set, references in this National Policy Statement to achieving a target attribute state can be taken as referring to achieving the next interim target attribute state.
  7. Every regional council must ensure that target attribute states are set in such a way that they will achieve the environmental outcomes for the relevant values, and the relevant long-term vision.
  8. When setting target attribute states, every regional council must:
    1. have regard to the following:
      1. the environmental outcomes and target attribute states of any receiving environments
      2. the connections between water bodies
      3. the connection of water bodies to receiving environments; and
    2. take into account results or information from freshwater accounting systems (see clause 3.29).

Policy intent

What is a target attribute state?

A target attribute state (TAS) is the state of the attribute that needs to be achieved in order to fulfil the associated objectives, outcomes, values and vision. For most values, regional councils will need to establish one or more attributes and set a TAS.

A TAS must only be set once appropriate attributes have been identified for assessing values. A TAS sets out a council’s end goal for an attribute in a specified location and when that will be achieved by.

Where do they apply?

A TAS may be different at different locations, and councils must set out the location that each applies to. Together, the bundle of TASs for a location should achieve the environmental outcomes for the values at that location, and the long-term vision, and consider all connected and receiving water bodies.

What are the requirements?

A TAS must be set for every attribute identified for a value, including those in appendix 2A and appendix 2B of the NPS-FM. The attribute tables in these appendices list attributes for four of the five biophysical components of ‘ecosystem health’ (not flows) and for the value ‘human contact’, for rivers and lakes.

TASs for attributes in these appendices must be expressed by the appropriate unit in the relevant table. In the case of periphyton, TASs are required for all FMUs, along with instream nutrient concentrations.

A TAS must be set at or above the relevant baseline state (clause 3.10 and definitions in clause 1.4) for all or part of the FMU or catchment where it has been set. It should always be set at or above the national bottom line (unless exceptions apply, see clause 3.11). This helps to achieve the direction in Policy 5 of the NPS-FM, to at least maintain the health and well-being of water bodies and, where they are degraded, improve them. (For a definition of degraded, see the section Clause 3.20: Responding to degradation.)

The compulsory attributes for the value of human contact do not have a national bottom line. For these attributes, councils must, however, set a TAS higher than the baseline (ie, improvement must be required) unless the baseline state is already within the ‘A’ band of table 9 or table 10 in appendix 2A of the NPS-FM.

Timeframes

A TAS must link to a timeframe for achievement. For timeframes longer than 10 years, councils must set interim target states, at intervals of no longer than 10 years, as stepping stones.

Councils are restricted in setting their TASs by the requirement to maintain or improve: maintain at baseline, or improve to the national bottom line if the baseline state is worse than the national bottom line, or improve to a more ambitious target. However, the timeframes can be more flexible. Councils can set these to make their TAS achievable, and to spread the task of improvement over the current or future generation of resource users.

Best practice

If a TAS is achievable in 10 years (eg, because the water body is not degraded), or the improvement is achievable within 10 years, there is no requirement to set interim target states.

For degraded water bodies, the pathway through interim TASs does not have to be a straight line. Councils should take into account lag times and the local circumstances of their ecosystems and water bodies.

Frontloading improvements

In most cases, it is best to frontload any improvements rather than leaving the largest amount of change till later. The state of water bodies improves sooner if this is done, which will have immediate benefits for ecosystem health and help give effect to Te Mana o te Wai.

Frontloading improvements also takes into account the needs of future generations, because it does not leave the bulk of the work to them. In addition, if monitoring shows that a water body is not on track, changes can happen sooner (and it may still be possible to meet the timeframe) than if a big change is set close to the end goal. In a ‘frontload’ scenario, the improvements pathway would look more logarithmic (taking the largest leaps first) rather than exponential (leaving the largest improvements to last).

Table 1 shows an example for interim TASs for dissolved oxygen for a water body that is degraded. The baseline state of this example is 5.0 milligrams per litre (mg/L) as a seven-day minimum over the summer period. The current state in 2024 is 3.0 mg/L. The TAS is to achieve ≥ 8.0 mg/L as a seven-day minimum over the summer period by 2050. The interim TASs are set up so that the largest improvements are made in the first years, because the council has determined there is some low hanging fruit in the form of improvements that can be made. The council acknowledges it may be hard to make the final improvements required to achieve the TAS, so it has stretched out the timeframe to allow for the final improvements to be made in smaller increments.

Table 1: Lookup table with interim target attribute states (TASs) for dissolved oxygen milligrams per litre (mg/L)

Timeframe Interim TASs (mg/L) Required improvement over five years (mg/L)
Summer period ending in 2030 ≥5.0 2
Summer period ending in 2035 ≥6.6 1.6
Summer period ending in 2040 ≥7.4 0.8
Summer period ending in 2045 ≥7.8 0.4
Summer period ending in 2050 ≥8.0 0.2

For each TAS, it is advisable to have a lookup table, similar to table 1, with the timeframe and pathway to reach the final target. Use these tables to provide transparency to resource users on the size and timeframe of improvements required, and to compare findings from regular monitoring, to assess whether the water body is on track to achieve its TAS or further action is required.

Even though TASs are location specific, councils can group them together for simplicity (eg, setting a TAS for a specific attribute at the same level for each lake within an FMU).