The ARA appreciates the NSW Environmental Protection Authority’s request for feedback on the draft Sustainable Construction Protection of the Environment Policy (PEP). The PEP aims to establish a reporting and monitoring framework for embodied emissions and recycled materials use in the construction of public infrastructure in NSW. The development of this policy is a key step in acknowledging and addressing the emissions generated and raw materials consumed by the infrastructure sector.

Embodied carbon in infrastructure and buildings is estimated to account for up to seven per cent of Australia’s national carbon emissions. Reducing embodied emissions at the design stage of a construction project presents an opportunity for significant and permanent reduction in the overall emissions from any given infrastructure project.

In addition to encouraging consideration of embodied emissions, the PEP aims to provide a reporting and monitoring framework for preferencing the use of recycled and reused materials in infrastructure
construction. While the policy doesn’t mandate specific volumes or amounts of recycled materials for a given project, it requires agencies to preference the use of recycled materials on an “if not, why not”
basis that will require justification for the use of non-recycled materials.

This submission was prepared in consultation with the ARA’s Sustainability Committee, Rail Infrastructure Contractors Executive Committee, and Circular Economy Working Group

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