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Spark submits on Climate Change Commission's draft advice

This morning the Sustainable Business Council (SBC) and the Climate Leaders Coalition (CLC) published their joint submission on the Climate Change Commission’s draft advice to the Government on climate action in Aotearoa.


This submission was made by the SBC and CLC in partnership, and so represents the views of around 150 businesses, which contribute more than a third of GDP. Together, we are committed to a zero-carbon future and believe the Climate Change Commission’s proposals represent an achievable transition pathway that New Zealand can get behind. The joint submission has some headline recommendations focussed on the transport, agriculture and energy sectors, and identifies aspects of the CCC advice we would like to see reframed or strengthened.


Spark has also made our own submission copied below, in which we make clear our individual support for the CCC’s draft advice. We recommend the Commission takes a system-wide view when considering the role of technology and innovation in enabling climate change adaptation, given its applications and benefits transcend individual industries. We believe that digital technology should be a particular focus, as it offers the opportunity to drive efficiencies and de-carbonise our existing industries and sectors.


As New Zealand’s largest digital services company, we are ready to step up and play our part in addressing these challenges. 





Thank you for the opportunity to submit on the draft advice to Government. Spark supports the overall direction of the Commission’s advice. We believe this work is an important step towards New Zealand’s zero-carbon future. 


As members of the Sustainable Business Council (SBC) and the Climate Leaders Coalition (CLC) we have participated in their processes to shape a collective submission representative of their broad memberships. We support their submissions and feedback on the detailed policy questions raised by the Commission, which identify areas of the draft advice that could be strengthened or given further consideration. 


The purpose of this stand-alone submission is to make clear our individual support and our readiness as New Zealand’s largest digital services company to step up and play our part.


Technology will play a critical enabling rolein the transition to a zero-carbon future,as New Zealanders and New Zealand businesses adapt and transform to reduce emissions. 


Global research shows a significant opportunity for the ICT sector to support climate change mitigation, with emissions reductions opportunities enabled by digital technology estimated at 20% in the period to 2030. We recognise that many of these opportunities are already captured in the Commission’s  existing assumptions and have been built into the modelling and projected savings that formed the recommendations. However, we are not aware of any New Zealand specific modelling or identification of emissions reduction opportunities enabled by digital technology, and in particular, emerging technology.


To ensure New Zealand can capitalise on the full potential ofboth existing andemerging technologies,it will be critical for Government and industry to work alongside each other. Together we mustensure we are buildingthe rightskills and innovation capabilitiesfor our future,and that we continue to rollout at pace the supporting infrastructure to enable innovation. Beyond specific R&D investments we recommend that the Commission takes a system-wide view when consideringthe role of technology and innovation in enabling climate change adaptation,given its applications and benefits transcend individual industries. 


We believe that digital technology should be a particular focus, as it offers the opportunity to drive efficiencies and de-carbonise our existing industries and sectors. It also paves the way to create new market opportunities and to promote growth in areas of the economy without environmental constraints.  Emerging technologies, such as IoT (Internet of Things), Artificial Intelligence (AI), and the rollout of 5G mobile technology will drive business innovation and enable more transformative change, delivering emissions reductions and broader sustainable development benefits.


As an example, Spark’s deployment of low powered Cat M1 and LoWaRANIoT networks allows for lower cost, longer life sensors to be deployed to provide real-time data, with uses including monitoring water, soil, and weather to support informed environmental decisions. These applications have direct benefits to supporting New Zealand’s emissions reduction ambitions, and also support broader environmental work to addresswater quality, biodiversity and species protection. 


Continued investment inconnectivity through telecommunications infrastructureis also critical, as noted in the Commission’s draftreport: “Improved rural connectivity via broadband will make it easier to access the information and data farmers need to measure and monitor emissions and will support precision agriculture approaches.”


Spark will continue to invest in building rural capacity by upgrading existing cell towers and investing in new ones through ourjoint venture, the Rural Connectivity Group–which has just delivered its 200th tower to rural communities. Sustained investment by Government in connectivity for rural areas that would otherwise be uneconomic to deliver services to will remain critical, and Spark will continue to support the rollout of such investments through Crown Infrastructure Partners. Spark’s rollout of a national 5G network, while predominantly focussed in urban areas, will also have flow through benefits for rural communities. As we move customers in urban areas from 4G to 5G this will create capacity on the 4G network that can be repurposed to rural communities, with the ultimate objectiveof removing constraints such as data caps.  


Our 5G rollout plan will deliver nationwide coverage by 2023. However, for the 5G rolloutand its associated benefits to continue at pace, the industry will need the Government to proceed with the long-term 5G spectrum auction within proposed timeframes(end 2022). 


Beyond rural connectivity, all aspects of digital equity and inclusion are important to ensurea just and equitable transition to a low-carbon economy. Covid-19 highlighted the unacceptable levels of digital inequality we have in New Zealand. According to 2018 census data 211,000 homes around the country still don’t have access to broadband,significantly limiting many people’sability to work, learn and connect. 


Spark is committed to championing digital equity, and we will continue to work in partnership with Government and others to address this issue,which we know hassignificant spill-over effects into thewider economy. 


We also recognise that preparing New Zealand’s workforce for new ways of working is important to address potential political and economic barriers to bold moves to decarbonise our regional economies. We believe industry and Government need to work together to better align our education sector to the career opportunities available, to build digital skills locally, expand representation in the sector, and ensure that New Zealanders benefit from the significant growth in digital careers that will be experienced globally in the years to come. 


We believe both digital equity and digital skillsshould be a key component of an Equitable Transitions Strategy.  


As the Commission builds on its initial advice, we are ready and willing to play a supporting role bysharing our digital services and technology expertise and helping to define the role emerging technologies will playas we move towards a zero-carbon future. 


We support the SBC and CLC recommendation thatthe Climate Change Commission consider a formal process to engage enabling industries and sectors to work together, share evidence, data, and insights to support the Commission’s future advice to Government.


Once again, we thank the Commission for the opportunity to submit on its draft advice to Government.


We welcome any further correspondence with the Commission on the matters raised in our submission.


Yours sincerely,


Jolie Hodson


Chief Executive Officer


Leela Gantman

Corporate Relations Director
+64 275 416 338 |

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