Response 179156519

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3. Are you submitting as an individual, or on behalf of an organisation/group?

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Name of your organisation (if applicable):
Metals New Zealand
Type of group/organisation (if applicable)
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Metals New Zealand was established in 2011 to advocate for the New Zealand metals-related industry. It is committed to working with partners to deliver sustainable products for use in residential, commercial and infrastructure build projects and supporting the sector's transition to a low emissions and circular economy future. It represents a diverse range of large and medium-sized manufacturers, distributors and recyclers who combined employ c. 25,000 people across New Zealand. The sector contributes c. $3 billion annually to gross domestic product.

Chapter 2: The proposed level of the fourth emissions budget

7. Do you agree with our assessment of the considerations that have informed our proposed budget level, including key judgements?

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Chapter 3: Developing the proposed path to the fourth emissions budget

10. Do you agree with the approach we have taken to developing our EB4 demonstration path?

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Chapter 4: Sector contributions to meeting the fourth emissions budget

13. Do you agree the changes we assume for each sector are plausible and achievable?

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Chapter 5: The impacts of meeting the fourth emissions budget on New Zealanders

16. Do you agree with our assessment of the impacts?

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Why or why not?
We need to ensure the cost of any inaction across sectors (ie agriculture) do not burden future generations.

17. Are there other impacts the Commission should consider, or give more prominence to?

Your answer:
If we want the New Zealand building and construction sector to do better in reducing its emissions, then when need to focus on and measure the carbon impacts of the entire produce life cycle i.e. cradle to cradle.

Chapter 6: Proposed changes to the first, second, and third emissions budgets

20. Do you agree with the Commission’s approach to assessing changes to emissions budgets which have already been set?

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Why or why not?
Metals NZ expect that budgets 2 and 3 calculations accurately reflect New Zealand Steel’s May 2023 announcement that it will partner with the Government to build a new $300 million Electric Arc Furnace (EAF) at its steelworks at Glenbrook within the next three years, as part of the country’s largest-ever emissions reduction project. This significant investment will reduce Glenbrook’s carbon footprint by at least 800,000 tonnes from day one – the same as taking approximately 300,000 cars off the road permanently. That represents a reduction of over 45% in New Zealand Steel’s emissions – or a total of 1% of New Zealand’s total annual emissions.

21. Do you agree that all set budgets should be revised to account for methodological changes?

Why or why not?
If we want the New Zealand building and construction industry to do better in reducing its emissions, then when need to focus on and measure the carbon impacts of the entire produce life cycle i.e. cradle to cradle.

Chapter 7: Measuring progress towards emissions budgets and the 2050 target

24. Do you agree with our assessment that the Government should continue with the existing accounting approach?

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26. Do you agree with our assessment of what the Government should be considering when it sets a reference level for forest management?

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Your answer:
Only in so much as the sector requires clarity of rules going forward.

27. Do you agree with our assessment of what the Government should be considering as it develops accounting methodologies for inclusion of additional sources and sinks in budgets and target accounting?

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