Earlier on i wrote on my personal opinion on the recent released of NEEAP Draft, here I will not mind sharing with my email feedback to the team behind the draft, as well as CC-ed to some key people in Pemandu, ETP, KETTHA, as well as the minister himself.. Feel free to comment on anything and kindly correct me if there is any misinformation spotted. Thanks.
Dear Sir/Madam and to whom it may concern,
I am a member of the public who shares some interest on the latest NEEAP National Energy Efficiency Action Plan draft that was posted on MEGTW’s website for the sake of our country’s future in socio-economy, energy security and environmental obligations. I would like to submit my comment as below on the mentioned draft.
1) Only 1 Month of Feedback Allowance
It shocked me to find that such draft of the national plan that will impact for the following 10 years development on Energy Efficiency is only given 1 month of response time. The public is not even fully aware of such draft before the feedback time is done. Even other government official documents feedback processes have more than 2 months timeline. Furthermore, there is no public media coverage to announce on such arrival of the draft, except Berita Harian, but the daily did not post on the dateline of such public feedback too. I will recommend MEGTW to allow longer feedback period and more effective public announcement for a justifiable respond from the public.
2) Lack of Stakeholder Engagement
This draft did not state if there was any engagement with related stakeholders to discuss on the implication of the NEEAP on them. Any effective government plan/policy shall engage relevant stakeholders and discuss intensively to set an understanding in order for the policy/plan to work. As a result, the NEEAP draft does not state anything about the commitment needed from various stakeholders especially the government, industries and end users towards this Action Plan.
3) No details of Implementation Arm
I refer to your detail on establishing Malaysia’s ten years EE action team 4.1. As a member of public, I acknowledge that MEGTW is a policy maker, however not an implementation arm to execute such NEEAP. EC Energy Commission, however, is a regulatory enforcement arm focuses solely on gas/electricity issue. I will recommend SEDA to absorb the capacity for NEEAP as they have shown success in implementing SAVE Program and MBIPV project. In fact, the intention of SEDA was created with Energy Efficiency being part of its role. The NEEAP needs concrete details on the task force such as jurisdiction power over matters of electricity efficiency. There shall be a dedicated agency but not project team, handling this implementation.
4) No detail on Funding
I refer to your detail on funding 4.2. I believe there is a lack of details in how are you going to source the funding for NEEAP effectively. I acknowledge that NEEAP will be funded by Federal Government and MESITA, however, the public needs to know, based on what interest, this fund will be sustainable for the next 10 years? Details are needed. The recent additional impose to RE Fund to 1.6% has enabled SEDA RM625mil annually, I refer to the annual budget needed for NEEAP is RM104mil stated at section 4.2. This can be the 0.3% out of 1.6%. In fact, to a personal opinion, RE fund has been unfair to 3 million consumers who needs to pay the additional of 1.6% for the benefit of only 20,000 end users.
5) No Legislative Power for the Task Force
A task force needs legislative power, acts/policy to enable them to complete their tasks. For example, in section 4.1, the draft mentioned that the task force needs to monitor and evaluate the NEEAP by keeping track with all the data on energy use. If there is no law to enforce the need of end consumer to report on their EE effort, then the task force is powerless to act upon. This is similar to the example of how EMEER 2008 regulation that has enabled EC to keep in view with Energy Management who has >3mil kWh. I hope MEGTW has learnt the experience from our Renewable Energy targets ever since the 8th and 9th Malaysian plan (total of 10 years) that have failed to meet the objective and only to slowly catching up with the 5% target for RE during this period of 10th Malaysia Plan, and this only possibly done with the formation of SEDA and RE Act 2011.
6) No Clear Timeline and Action Plan Checkpoint Feedback System
Having a 10 years plan without breaking down the necessary programs of the action plans into 2 or 5 years plan is a vague plan. What is the details of each action plan in terms of details and funding? What is the feedback mechanism? Is there a checkpoint every 2 or 5 years? How are we sure that NEEAP is heading to the right trend we expect it to be? No details of specific time frame and action plan are mentioned.
7) 6% reduction in Electricity (NOT Energy) is Not Ambitious
I refer to Annex 1 MEEAP summary table, the savings of 6% reduction in electricity is deemed not ambitious, as oppose to benchmark from our northern neighbor, Thailand is aiming to reduce energy intensity (which includes transportation) by 25% by 2030 with their 20 years EE plan. In actual fact, the NEEAP draft is still projecting for an increased of 59% of electricity usage for the next 10 years of the plan. The true energy savings are only 1.3% over 10 periods, if the plan has included transportation sector. How possibly is that ambitious?
The previous NEEMP has targeted 9%, it went through stringent quality control through 16 project meetings, 5 progress meetings, 3 technical work group workshops, 4 technical review committee meetings and 2 steering committee meetings. It has also been peer reviewed by APEC and it was facilitated by Japanese Energy Economist when CPC Cofreth-Primetech-Consortium undertook the earlier stage of NEEMP studies, and I believe a significant amount of taxpayers’ money is paid for this. And why 9% is deemed impossible for NEEAP?
8) Why is no significant amendment to capture input from other reviewers?
A search on NEEAP has also shown that NEEMP was reviewed and suggested by the committee of APEC during 2011. There are ample of valid constructive recommendations here given by the professionals, why are not many of those consider? NEEMP has been delayed for as much as 4 years and spent various human resources on the draft of it. Why does it end up a thin 47-page draft instead that looks like merely a university student cut and paste assignment?
9) A National Document that does not appreciate International Efforts.
Over the years we have seen various projects from the private sector and international funds that aim to be the catalyst of displaying the potential of energy efficiency. This includes DANIDA projects, UNDP’s latest BSEEP project, as well as professionals from Japan that involved in reviewing the NEEMP. The current NEEAP draft ignores the inputs from various international country and organization being said. I suggest that this NEEAP draft shall be sent to IEA International Energy Agency as well as ASE Alliance to Save Energy for review to see if the draft earns well to the respect of international level if we aim to be the pride of energy efficiency on a regional level.
10) This Document does not fit to be a National Document
As a simple fact, a lot of important elements are missing. As from the point of view of an ordinary citizen, professionalism is not displayed in this draft of NEEAP, where it does not address the mentioned barriers in the draft itself, such as Capacity Building and Research and Development. It is ridiculous to see a result of intensified and fruitful development of NEEMP since 4 years ago ended up today with a thin 47 page of disappointment. This is a public embarrassment.
Kindly keep me and other public members who have given feedback an update of the current draft. I will strongly suggest a stakeholder meeting before this draft proceeds, with the presence of relevant and crucial parties.
Thank You.
Lim Gene-Harn
