One big thing: our response to the Climate Change Commission’s draft advice to government

If there’s one big thing we want the Climate Change Commission (CCC) to understand – it’s that whatever actions the New Zealand government takes, it’s vital that all New Zealand’s trading partners similarly commit to programmes of action to ensure global warming does not achieve 2 degrees.

This is the framing for Metals New Zealand member ALENZ’s (Aluminium Extruders Association of NZ) submission on the CCC’s first draft package of advice to Government  This provides advice on what actions government needs to take to reach net-zero by 2050, and ensure a transition to a low-emissions, climate resilient and thriving Aotearoa.

The fact is that ALENZ members are committed to reducing their carbon footprint and source their primary aluminium from low-carbon smelters, principally NZAS at Tiwai Point, whose carbon footprint is 3.8kgCO2/kgAL This compares to a footprint of more than 15kgCO2/kgAL generated by over 80% of the global aluminium production.

However New Zealand manufacturers continue to be placed at a disadvantage when competing internationally and our current free trade policies do not support fair trade for local manufacturers. New Zealand manufacturers are taking a lead doing the right thing. Where is the action to ensure our manufacturing base is not eroded by our negligent trading partners?

ALENZ’s submission is comprehensive and whilst generally supportive of the draft advice, there are some glaring  omissions. A big one is the failure to address emissions leakage with imported product substituted for locally manufactured goods, and the risk of production and investment moving out of New Zealand.

The CCC does identify the issue but provides no guidance to government to address it, instead focusing on production based GHG emissions. However New Zealand also needs to address consumption emissions, particularly with respect to emissions imported.

Failure to address emissions leakage will result in New Zealand importing emissions, which may be significantly greater than New Zealand sourced materials – e.g. residential aluminium windows from New Zealand produced extrusions or from Asian suppliers with significantly higher embodied emissions, lower environmental regulations and unknown health and safety regulations governing workforce.

To read the full submission, view and download here  ALENZ submission to CCC draft advice to government-final