From time to time ESR makes submissions to Local Bodies or to Government, on issues of concern. These submissions are listed here and can be accessed for perusal.

Papers are presented in .PDF format and require Adobe Acrobat Reader .


Submission in response to:

Inquiry into the future of inter-regional passenger rail in New Zealand

Given the urgency of the issue, for some time now the organization has been particularly focused on how to respond to the climate crisis by reducing emissions and concentrations of greenhouse gases in the atmosphere.

The New Zealand rail network is a vital part of our transport services and must also play a large part in how we react to the urgency of the climate changes being thrust upon us. Increased use of the rail network can is essential.

Today, there is a list of very valid reasons to re-establish a well running rail network in New Zealand, as it is also hinted by the terms of reference of this inquiry:

• In 2020 the New Zealand parliament declared a climate emergency, acknowledging the need to reduce CO2 emissions. The superiority of rail solutions and especially electric rail transport in having the smallest carbon footprint has been demonstrated in many studies.

Submission on the Auckland Land Transport Plan 2021-2031

Engineers for Social Responsibility Inc. is of the firm view that the Draft Auckland Regional Land Transport Plan 2021 - 2031 (Draft ARLTP 2021) should be put on hold and revised when the Central Government has developed clear climate change policies and interim targets following finalisation of the Climate Change Commission’s Draft Advice for Consultation. In the interim, a decision is needed on implementing congestion pricing instead of yet more studies, and much higher priority must be given to developing and implementing actions which start to make the major reductions in Auckland’s emissions required. Climate change is one of, if not the most important issue facing the world today. ESR's submission is here. PDF 141 kB

Submission on the Climate Change Commission's Recommendations

Although the need for action to limit climate change has been well understood since at least 1990, global CO2 e emissions have continued to increase strongly over the past 30 years. It has become clear that we need to limit global warming to 1.5 degrees C aove pre-industrial levels. To have some hope of maintaining a reasonably habitable planet for ourselves and for many other living species, we need to take urgent and decisive action. The latest scientific advice from the IPCC clearly indicates that the CCC's recomentaations are not nearly storng enough. ESR's submission to the CCC draft recomendation is here. PDF 57k.

Submission to Ministry of Business, Innovation & Employment

As a group of professional engineers, Engineers for Social Resonsibility Inc (ESR) strongly endorses MBIE's commitment to meet the government's Carbon Zero targets by 2050, and the implementation of changes to our Building Consent regulations that will improve operational efficiencies and reduce livecycle carbon emissions from New Zealand's building stock.

We endorse most of the propsals made in MBIE's consultation documents titles "Whole-of-Life Embodied Carbon Emissions Reduction Framework" and "Transforming Operational Efficiency".

More importantly, we would like to draw attention to several insights from the emerging field of Transition Engineering which highlight three improvement oporortunities associated with the 'Building for Climate Change' framework as currently proposed. More... PDF 271 KB

Submission in reponse to:

Climate Change Response (Zero Carbon) Amendment Bill

We strongly support the Bill’s objective of limiting global heating to 1.5ºC, legislating targets projected to make this possible, creating a framework of five-yearly emissions budgets to make meeting the targets achievable, and establishing an independent Climate Change Commission to assist with the above. More ... pdf 134kB

Submission in response to: Process Heat in New Zealand: Opportunities and barriers to lowering emissions (Technical paper January 2019)

While the Process Heat in NZ report covers a lot of useful points, and while a few organisations have already achieved significant recudtions in their emissions, for many others fossil fuels remain the simplest, lease expensive and best understood option to provide heat. Moving away from them would require capital funding, installation of new equipment and processes, and the expertise to achieve this. If the carbon price were sufficient to drive change, then this change would happen. More ... (pdf 411kB)

Submission on the CPTPP Amendment Bill

We oppose ratification of the TPP in its present form (TPP-11), because its remaining investor-state dispute settlement (ISDS) provisions endanger our efforts to deal with climate change.

The TPP is strongly aligned to protecting relatively short-term corporate business interests rather than addressing more important and wider environmental issues. In particular, there is no reference to climate change, even though this is the most urgent and critical issue currently facing us. However, the TPP provisions directly affect our ability to take necessary climate protection measures. More ... (pdf 115kB)

Submission on the proposed Zero Carbon Bill

The Zero Carbon Bill is a critically important piece of legislation for New Zealand. Even though the importance of controlling global warming has become increasingly clear and more widely understood over the past 30 years, to date we have not set meaningful targets to significantly reduce emissions and we have not had any mechanisms in place that seem to have had any significant effect on driving reductions in emissions. Hence our net emissions have just continued to increase through most of this period. More ...

Submission on the Draft 2018 GPS on Land Transport

ESR is pleased to see a move away from excessive reliance on road construction towards an

approach which places more emphasis on investment in public transport, walking and cycling and supports more efficient land use development less reliant on travel by car. ESR also supports a greater emphasis on travel demand management, and on measures to reduce environmental effects including greenhouse gas emissions. More ...

National Energy Efficiency and Conservation Strategy Submission February 2017

Our colleagues over at the Sustainable Energy Forum Inc have prepared this submission and comment on the new National Energy Efficiency and Conservation Strategy and have forwarded it to Government.

In brief, NZ is falling woefully behind other countries in efforts to raise energy efficiency and energy productivity. NZ is very slow in taking actions to reduce greenhouse gases (GHG). NZ is not aggressively working to implement or adapt to the use of new technologies.

These factors are impacting negatively on NZ’s potential economic growth, whilst they also reveal planning to fail to meet NZ’s climate change obligations.

SEF believes New Zealand must do better. To achieve better results the actions and targets included in the strategy must change. More...

ESR Submission to the Government, on the TPPA

March 2016

The TPPA in its current form is strongly aligned to protecting relatively short-term corporate business interests rather than addressing more important and wider environmental and other issues. In particular, there is no reference to climate change, even though this is the most urgent and critical issue currently facing mankind (1).

In earlier drafts of the TPPA there were references to working together to combat climate change, but these were removed at US insistence. Now the agreement does not mention climate change a single time. More...


ESR Submission to the Government, on the ETS

February 2016

Moving to a charging system for emissions that is simpler, fairer, more transparent, more effective and involves lower administration costs, for example a standard carbon charge payable to the government that applies to all New Zealand-based emissions. More...


ESR Letter to Engineering Insight Magazine

The Featured Letter on page 3 of Engineering Insight September/October 2015 Volume 16/5 published by IPENZ follows.


Engineers for Social Responsibility Inc. (ESR) is an independent group of engineers with interest in the role of engineering in achieving sustainable and equitable energy, environmental, and social systems.

Climate change is one of the biggest challenges facing humanity. The negative effects particularly affect developing countries and are only beginning to be felt. They will increase greatly over coming decades unless we all accept our responsibilities and substantially reduce our greenhouse gas emissions.

We urge all professional engineers to take leadership in transitioning New Zealand to a low-carbon future.

Engineers have a vital role in raising energy efficiency standards, and in planning, designing and building stormwater, communications and transport systems. Every man-made chemical with greenhouse potential, every mine, every earth-mover, highway, aeroplane and factory farm is an engineered system.

There are renewable electricity generation plants consented but not built with a combined capacity of 3000MW. That additional capacity could be used to achieve emission reductions through the transition of transport energy demand from liquid fuels to electricity. The electricity market should be reorganised to encourage demand side management. A predictable and rising carbon price should be introduced, and all fossil fuel subsidies discontinued. Urban transport policies should prioritise reducing vehicle travel demands.

It is time for engineers to recognise their responsibilities; to change things so that they contribute to ensuring an equitable, more sustainable and more resilient future. All IPENZ members will ultimately be responsible for this transition to a low-carbon engineered system, or for their failure to act.

Ross Rutherford MIPENZ,

ESR President


ESR Submission on "New Zealand's Climate Change Target Discussion Document", Ministry for the Environment, May 2015

The Discussion Document sets out the issues relatively clearly and succinctly. However, the discussion reads like a series of excuses for avoiding or delaying action. Continuing to delay action is not a way forward. The following sets out a number of the issues raised in the discussion document and our responses. More ... PDF 135kB


Otago Regional Council Policy Statement Review Consultation Draft 26 November 2014

ESR’s submission focuses on responding to the potential impacts of climate change and on measures to reduce greenhouse gas emissions. It proposes some changes to the section headed Objective 2.3, including the addition of proposed Methods. More (PDF 70k)


Submission to the Prime Minister on the required reduction of New Zealand's CO2 emissions

We urge the New Zealand Government to set an ambitious target for reduction of our gross greenhouse gas emissions by 2020, and beyond, in advance of the UN Climate Change Conference to be held in Paris in late 2015. In our view this should take the form of a commitment to a minimum 10% reduction in our 2012 gross emissions total by 2020 and 30% by 2030 (equivalent to 2% a year from 2016). More (PDF 56 KB)


Submission to Government

on the draft Government Policy Statement

on land transport 2015/16 to 2024/25

Parts of the Engagement Draft read like a document that sets out policies for the coming 10 years while looking in the rear view mirror. Road investment is promoted. The primary response to severe congestion is to manage roads more efficiently, and to invest in removing bottlenecks and building new roads - very reflective of the 20th century. More (PDF 60.5 KB)


Submission to Auckland Council

on "Low Carbon Auckland"

ESR strongly supports the aim of changing Auckland to a low carbon city by 2040. We are extremely concerned at the potential impacts of climate change on ecosystems and humanity and see it essential that early, ongoing, and effective action is taken to reduce greenhouse gas emissions (GHG). More ... (PDF 72kB)


Climate Change and Kyoto

Letter to the Prime Minister 6 Dec 2012:

We are very concerned at the Government’s decision to pull out of the Kyoto protocol and instead to enter into “talks about talks” to quote 1 December 2012 Economist article headed “Theatre of the absurd”. These talks are supposed to negotiate a new climate change regime by 2015 and have one in force by 2020! More ... (PDF 12kB)


“Realising our Hidden Treasure…”

This is a response from Engineers for Social Responsibility (ESR) to the IPENZ report Realising Our Hidden Treasure: Responsible Mineral and Petroleum Extraction [1]. ESR disagrees with the core principles that underpin the report, specifically that:

· Economic growth is required to achieve the living standards that New Zealanders aspire to.

· A “global decision” has been taken that the responsibility for minimising greenhouse discharges lies with fossil fuel users, not producers [and, as such] it is not immoral or inappropriate to derive economic benefit from [New Zealand’s mineral and petroleum] resources. More ... (PDF 60kB)


Submission on the Local Government Act 2002 Amendment Bill

to the Parliamentary Select Committee for Local Government and Environment (22 July 2012)

We are concerned about some of the proposed changes outlined in the Local Government Act 2002 Amendment Bill, particularly the deletion of “social, economic, environmental, or cultural wellbeing” in Clauses 19, 20 and 25.

While we do understand the need for financial constraint in both Government and Local Government, we do not agree that social, economic, environmental and cultural well being is the sole responsibility of Central Government. Local government is charged with the responsibility of looking after the citizens in their regions and they must be able to undertake a range of activities that benefit their citizens. This is what our communities expect. More ...


Submission to Auckland Council on the draft Auckland Long Term Plan 2012 - 2022.

(22 March 2012)

Engineers for Social Responsibility Incorporated supports the general direction being taken by the Auckland Council in the Draft Long Term Plan 2012-2022. In particular ESR supports the emphasis on improving public transport, facilitating and encouraging more walking and cycling, and on achieving higher density, mixed use, quality urban development in selected centres and corridors. More ...


Submission to Auckland Council's Draft Waste Management and Minimisation Plan.

(25 January 2012)

This is ESR's response to the November 2011 Draft Waste Management and Minimisation Plan prepared by Auckland Council which can be found at The central points are that the present waste collection and disposal arrangements must be improved to minimise the amount of material going to wasteful landfill, to improve the value and utilisation of recycled materials as well as to maintain a healthy and safe environment for Auckland residents. More ...pdf


ESR Submission on the Auckland Plan

(28 October 2011)

Chapter 6 of the Draft Auckland Plan states the Auckland Council intends to develop energy and greenhouse gas emissions reduction strategies and action plans for adoption in 2012. ESR strongly supports this and would welcome the opportunity of being involved in the process.

ESR considers that the following improvements are required to the Auckland Plan’s energy policies:

1. It needs to be made much clearer that giving priority to the movement of people and freight rather than cars will mean that a lower priority will be given to the movement of cars, particularly single occupant cars. Among other things, achieving this will mean allocating more road space to buses, high occupancy vehicles, and cyclists. More...


Government Policy Statement on Land Transport Funding

(24 May 2011)

ESR is concerned at Government intervention in the process of objective decision making on national land transport funding in favour of state highway construction. Several of the Roads of National Significance will deliver a very poor economic return on investment. If the Government is really determined to drive efficiencies in the transport sector, this should be applied consistently to all projects and activities. Anything else implies a selective bias.

Instead of relying on short term fixes we need to think seriously about ensuring New Zealand is a successful and desirable place to live for future generations. That is likely to require differing short term priorities. Above all it requires clear, measurable long term objectives for the transport sector, the achievement of which is monitored and regularly reported on. More…


To Auckland Council on Transport

(12 April 2011)

In ESR’s opinion, the Auckland Plan discussion document does not provide a clear or convincing description of the city’s transport options, and it does not adequately address the linkage between the nature and location of future land use development and the transport option selected.

ESR also considers that the Auckland Plan should take into account the potential implications of a sustained increase in fuel prices beyond that assumed in developing the RLTS 2010-2040, and the increased risk of future disruptions to supply. These would impact on the city’s economy and would particularly impact on the more vulnerable members of society. More


To Auckland Council on Waste Management

(25 March 2011)

We live in a finite world with finite resources that should not be disposed of in landfills. The ultimate objective should be to do away with conventional landfills. ESR commends the Council’s objectives in reducing waste, especially that going to landfill, encouraging the recycling of material. ESR supports the Council’s ownership and operation of landfills, the establishment of Resource Recovery Centres, the imposition of container deposits on all beverage containers, and of a strong public education campaign in support of these moves. More…