ATSE appreciates Infrastructure NSW has offered and welcomes the opportunity to respond to the consultation on Decarbonising Infrastructure Delivery. NSW is one of the largest investors in infrastructure in Australia with $88.4 billion being spent on infrastructure in NSW over the next four years.
By embedding embodied carbon reduction as a key principle for infrastructure in NSW, greater reductions in emissions nationwide can be achieved. This approach will also encourage further industry investment in technologies that reduce carbon in the construction sector, leveraging the strengths of universities in NSW, home to research centres like the Sustainable Materials Research & Technology Centre at UNSW.
The proposed framework has the potential to lead the way nationally as a gold standard approach to decarbonising infrastructure and the construction sector, however some additional actions are needed. There are many matters addressed in the Discussion Paper which ATSE is supportive and ATSE has only chosen to comment on those, where we think ATSE has something to add to the discussion. ATSE recommends the inclusion of the following actions to strengthen the proposed framework:
Recommendation 1: Under Principle 1 – Use consistent methods and data to measure embodied carbon include actions to “use carbon balance sheets through all project phases, establish an open-source database for embodied carbon, include emissions from power generation for electric vehicles, and include emissions from land use changes”.
Recommendation 2: Under Principle 1 – Use consistent methods and data to measure embodied carbon, include an action for Infrastructure NSW to “support research and development projects to fill gaps in knowledge and datasets for measuring embodied carbon”.
Recommendation 3: Under Principle 2 – Reduce embodied carbon from options analysis and early design stages, include an action to “create a comprehensive, whole-of-life strategy to be used for carbon budget planning”.
Recommendation 4: Under Principle 2 – Reduce embodied carbon from options analysis and early design stages, include an action to “use a circular economy approach to planning infrastructure projects”.
Recommendation 5: Under Principle 2 – Reduce embodied carbon from options analysis and early design stages, include an action to “establish carbon balances sheets for: no changes to land proposed for infrastructure development projects, all project options, and preferred project options (to be updated at all critical phases of a project)”.
Recommendation 6: Under Principle 2 – Reduce embodied carbon from options analysis and early design stages, include an action to “utilise digital technologies, including digital twinning, to develop a standard approach to carbon modelling”.
Recommendation 7: Under Principle 2 – Reduce embodied carbon from options analysis and early design stages, account for any loss of carbon absorption capability of the natural environment and its maturity due to infrastructure development and the degree to which proposed nature-based solutions mitigate any loss in the scoping, options analysis and design phases.
Recommendation 8: Under Principle 4 – Establish minimum expectations for embodied emissions reduction in tenders, include an action to “set a total carbon budget for infrastructure projects and determining the minimum requirements accordingly”.