While obviously, I am not a professional, long enough in the energy/building industry to feed in constructive inputs for the recently announced National Energy Efficiency Action Plan, I am writing this as a concerned citizen to express my thoughts on the 47 pages draft plan. So please understand that if my views are not seen as appropriate as I do not understand how the various policies or situation is like for the energy industry, I will be glad if you can comment and correct me as a mean of constructive discussion.
The Anticipation for the Fate of Energy Efficiency
The hit on me that the the future of our energy security lies in energy efficiency started off upon reading IEA’s Energy Efficiency Market Report 2013, where the report took a look at the energy efficiency practices of 11 developed countries, which apparently EE became the ‘first fuel’, showing the massive savings that can be done by EE, by leading a reduction in peak demand as well as reducing the need for power stations, which translates into reduction of amount of energy needed to produce each unit of GDP, and of course, lesser carbon emission.
I wrote further on my humble opinion towards the lack in the recipe in Malaysia to induce such practices. The National Energy Efficiency Master Plan NEEMP was delayed for a few years, since the early of 2010. Various EE advocates have been eyeing on this very day, when KETTHA announced the arrival of NEEAP, on the 24/1/2014, and the first pathetic thing one will realize is, there are only 30 days to give feedback to the officer in charged in KETTHA, while I will try to send in my opinions as I think any citizen on the street should do so to question on common sense.
The Juice of the Draft
In a nutshell, one could turn up in frustration and disappointment by looking at the depth of information of the plan. It sounds more like a draft plan that can be done by post-graduate students honestly speaking, I say this as I cannot help but feel the entire draft report, which was delayed for years, are not professionally done taken for the fact that it is more of a ‘literature review’ of what is being done currently. which is known to many easily? I personally do not see this as a plan that will elevate the EE industry with the lack of details of implementation in the aspect of financial, human resource, agency job description etc.
I personally see this ‘action plan’ as more of a draft plan to draft on how do we produce an action plan. I do not doubt the significance of starting off the plan of identifying our barriers towards EE as well as stating the principles of the formation of this action plan. However, the lack of details is just a pain to realize that this action plan does not resemble any information but just like a collection of literature of what is done currently. I do not know the history of NEEMP/NEEAP specifically but I suppose there were several drafts before this being done by experts outside of KETTHA and somehow was flushed down the drain. Here are some of my opinions:
1) Not an Ambitious Plan At All
The NEEAP is a plan potentially to improvise the socio-economics situation of the nation, with more efficient of energy usage and lowering peak demand, thus taking off unnecessary power plants, this budget can be allocated for the better purpose. The NEEAP is to be the document that will chart Malaysia’s EE journey for the next 10 years. That is long, also considering the 4 years wasted waiting for this plan.
The next statement will put your hands down. The first page of the plan has already resembled the mood of the plan, to harvest ‘low hanging fruits’, which translates into, doing easy cheap practical things only lah.
Thailand’s 20 year Energy Efficiency Plan (2011-2030)
One will feel how such draft plan is down the drain upon compared with Thailand’s 20 years plan. If you will go through the 83 pages 20 year EE plan prepared by Thailand’s Ministry of Energy, you would realize how detailed the plans are, with specific timeline chart, both short-term (5 years) and long term, with specific plans laid out and scope of responsibilities by each ministry/agency. The best part of this energy efficiency plan is the inclusion of Transportation sector which has close to one-third of the total end energy usage, however with more emphasis on industry sector as it bears 41% of end energy usage, as Thailand is known for a product manufacturer drove economy country.
You can view and download the plan at HERE. I do not have much to critic on the plan, but as a benchmark to our current draft plan for NEEAP, the difference in both, ambitious level and execution details puts us to shame obviously.
2) ONLY a Pathetic 6% Reduction in Electricity (Not Energy!) Demand Growth
So as oppose to what we saw in Thailand’s 20 years EE plan with the ambition to reduce energy intensity by 25% in 2030 (which includes transportation sector), we see only 6% is the target of a reduction in energy demand for the draft NEEAP. As indicated on the last page of the draft.
And to make matter worst, this 6% is excluding energy usage from the transport sector, which is stated clearly that it only confines to electricity usage. It is fine to do a plan only for electricity usage if it is due to ministry/policy red tape factors, but the reduction of 6% is clearly not anywhere ambitious, does not sound anywhere near to our Malaysia’s so much pride for promising to reduce 40% of carbon intensity as per 2005 level announced in COP17. To make matters worst, how can we be proud of 6% energy savings compared to business-as-usual, while the electricity assumption is still increasing by 59% during the 10 years period of the plan.
The fact is that transport sector itself constitutes almost half of our total energy end usage. By watering down the ambitious target of NEEAP to only 6% reduction, this statistically only mean 3% for overall reduction energy usage.
3) No Details on Agency/Task Force In Control of the Implementation & Feedback of NEEAP
Various literature has shown the similar concern that the effectiveness of various policy and plans in Malaysia is often affected by the ineffective structure of ministries and agencies. It is expected that conflicts from relevant ministries and agencies would happen when they compete for land, energy, funding, legal and political support, and this often explains clash in job descriptions and explanations between agencies. There is no concrete information in the NEEAP stating on the details of the task force and job description, which is also needed to be elaborated across the timeline which considers in the implementation and feedback channel to the task force.
To make matters worst, there is no saying on how much authority this task force has, particularly across different levels of governments and ministries. There has to be a concrete plan solely on setting up the task force which is responsible for overviewing the nation’s energy efficiency development, as far as we know, there are so many ministries/agencies and as well as a layer of government pertaining to any issue. The establishment of SPAD (land public transport authority) came in place, as part of GTP effort to centralize coordination, information and regulation pertaining to any matters on public transport is an example NEEAP can take into account.
4) Lack of Discussion on Policy Levels
While it is acknowledged that there are various Acts to allow KETTHA to promote efficient use of electricity such as Electricity Supply Act (Amendment) 2001 and Efficient Management of Electrical Energy Regulation 2008, and the latest Electricity Regulations (Amendment) 2013 to implement MEPS Minimum Energy Performance Standards, I believe there are many more needed to address the barrier to the implementation of the 10 years duration of NEEAP.
However, on the other side, I see this NEEAP as rather a standalone evaluation of EE itself, there are so many items pertaining to the concern of EE such as Transportation Plan, National Physical Plan perhaps.. there are no signs of the report finding other existing practices to complement to NEEAP or to be amended to do so perhaps? More interestingly, there is mention of lowering carbon emission of the nation by the NEEAP, however, there is no detail on how this ties in with our Prime Minister’s pledge at COP15 that Malaysia will reduce its carbon intensity per GDP by 40% by 2020 as per 2005 level.
5) Lack of Details for Funding Strategy
While the NEEAP draft does mention on the crucial need for stable funding to ensure continuity of programs to ensure effectiveness in delivering the impacts, there is no further details on how is the government going to ‘induce’ the private sector to fund RM9.5bil and also where are they going to source for the RM988million public funds for the 10 years period. The recent electricity tariff may have done well in addressing the issue with cheap dirty electricity. So how is this going to be done?
There is no appendix nor attachment describing the evolution of drafting NEEAP over the years, and also there are no names involved in the draft mentioned in the document. The public has the rights to know the draft plan is planned sufficiently by credible experts and after several rounds of consultation to various agency/think tank/end users etc. As far as I have realized in APEC Peer Review on EE for Malaysia has been a useful document in reviewing the current status, challenges and constructive criticism on the aspect of EE here, there are not many recommendations out of the 41 options being taken into consideration.
7) No Key Initiative for Capacity Building
While the earlier part of the plan highlights that talent pipeline is an issue for the EE industry, there is no key initiative stated at the later part of the draft plan, even though it was identified as one of the 5 strategic actions. The lack of champion in Energy Efficiency poses a huge challenge as we have ambitious goals but the lack of experienced human capital to kick start the various programs for the next 10 years is something not being addressed by NEEAP. The strategic action did briefly mention that EE shall be a focus in tertiary education, workshops will be organized, which doesn’t mean much as there are no details on how to kick off this capacity building.
How do we address energy efficiency studies in our universities? Are we sure that the talent pool of lecturer at the academic level is sufficient to cater such curriculum? Which institutes are able to cater these EE workshops? Are there any rebates/CPD by attending these seminars? There shall be a section of the Draft Plan addressing all these crucial basic concerns of capacity building.
8) No Key Initiative for Research and Development
Again, the same as point 7. No further details on RnD specifically, while the draft is just as simple as “universities and private entities are encouraged to enhance research in the field of EE.” There is no single elaboration of how is this going to be done. What are the possible drivers to encourage quality research papers on EE in our universities? Can there be funds allocated for such RnD? Or perhaps will there be a new research center established solely for the purpose of centralizing NEEAP research efforts? The draft plan is seriously lacking basic details like this to even justify it’s intended actions.
And I believe some can add up more opinions upon comparing with other countries energy efficiency plans.. and thinking that this NEEAP, is the sole document we have for our 10 years Energy Efficiency master plan, we are in a serious matter as this draft plan is one of the many factors that determine our economic progression, environmental responsibility, and also energy security. I rest my case for now. Will look forward to next few rounds of the outcome.