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Submission: Response to Climate Change Commission's advice on Second Emissions Reduction Plan

11 Jul 2023


CCNZ made a submission to He Pou a Rangi Climate Change Commission on its “2023 draft advice to the Government to inform the strategic direction of the Government’s second Emissions Reduction Plan”. 

The submission called for the second Emissions Reduction Plan to better acknowledge the needs of the civil contracting industry, and work with industry to develop a plan that acknowledges practical opportunities and better supports horizontal construction companies to do what’s required.

Key points

  • The draft advice needs to explore achievable opportunities and proven technologies that can be applied within the timeframe available. It’s essential there is discussion with industry to identify appropriate opportunities. 
  • The Emissions Reduction Plan currently puts the onus on a range of client groups to independently produce emissions reduction guidance for transport and water construction. This creates uncertainty for all involved.
  • Civil construction provides essential services to New Zealand, such as resilience to natural hazards and the effects of climate change.
  • Civil contractors have to balance obligations between reducing CO2 emissions and delivering resilience infrastructure such as transport networks, seawalls, stopbanks and wetlands.
  • A holistic approach to infrastructure emissions - to consider whole of life emissions and account for construction, operational and decommission (demolition and recycling)  emissions at the same time - will help solve the above problem.
  • The draft advice needs to include horizontal construction material supply chains: e.g. asphalt, aggregate, and concrete, to ensure proximate sources of materials to reduce transport “carbon miles” and remedial wear and tear on the transport network.
  • The heavy machinery sector is decarbonising in many ways, but to achieve this at scale will take longer than 2030 due to unavailable, unworkable or transitional technologies.
  • Avenues for heavy machinery include electricity, hydrogen, biofuels, and new fuel efficiency measures.
  • Government support of innovation in decarbonising heavy vehicle fleets would help speed the lower-emissions transition. 
  • A particular barrier to overcome is charging and refuelling infrastructure for hydrogen and charging stations, which needs to be accessible to the fleet for change to be affordable and successful.
  • Civil contractors are already recycling concrete, asphalt, aggregate, steel, and the mud/rock produced from tunnelling, from construction and demolition waste. However, this is isolated to areas within the country where there are facilities – we need widespread depots/facilities across the country to make this feasible.
  • Better guidance, more investigation and more flexibility is needed around specifications for re-use of these materials (i.e. with transport or foundation engineering specifications).
  • Closer positioning of recycling, reuse and repurposing of waste to funded sites of use, e.g. new material recycling infrastructure and cleanfill sites, will reduce “carbon miles” in terms of material transport.
  • The Government should specify the use of the ISO 14064 framework of greenhouse gas accounting and verification to calculate embodied carbon in infrastructure so emissions are consistently measured.

 

 

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