The draft of National Energy Efficiency Action Plan (NEEAP) was posted on KETTHA’s web page on the 24/1/2014. It is a crucial draft plan that will present the instruments for a successful implementation of energy efficiency strategies in the country for a period of 10 years which is intended to address several barriers on energy efficiency. Personally i am disappointed with the draft, as it only aims for 6% reduction in energy demand for the next 10 years, and this excludes the energy for transportation sector which made up almost half of our total end energy usage.

A crucial benchmark comparison is Thailand’s 20 years Energy Efficiency Development Plan, where it aimed 20% reduction of its total energy demand by 2030. The NEEAP draft does not address crucial details on the agency/task force involved for the EE implementation and feedback mechanisms, the methods to fund more than RM 10 billion for EE in both private and public sectors, policy making, talent capacity building, and research on EE.  Several countries have shown the significant of emphasizing energy efficiency, as this leads to a reduction in peak demand and saved them billion of dollars by avoiding unnecessary power stations, and these funds are used for a better purpose.

The public, including YOU, needs to review this draft plan as it is crucial plan that will affect our economy progression, environmental obligations, and energy security. You do not really to question on the very technical demanding part, but by judging on the quality of a document for a national plan, there are some obvious comments to be made.

As subsidy for electricity will subsequently be removed, the energy efficiency market in Malaysia needs to be stimulated significantly by the NEEAP for the next 10 years as a mean to mitigate the impact of rising cost of living. The limited 1 month time allowance for feedback and the lack of NEEAP draft exposure to public are not deemed professionally done. I  hope citizens will practise their democracy in citizenship by questioning our countries’ policies by sending in their opinions to KETTHA by 24/2/2014.

The Juice of the Draft

In a nutshell, one could turn up in frustration and disappointment by looking on 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 to 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 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 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 on the 4 years wasted waiting for this plan.

Screendump showing the identification of barriers and statement of 10 years planning

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?

As shown on the first page of the report, “Harvesting Low Hanging Fruits”

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 driven 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

Screendump from Thailand MOE’s 20 years EE plan showing the details

% 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 reduction in energy demand for the draft NEEAP. As indicated in the last page of the draft.

Screen dump from Draft NEEAP Last Page

And to make matter worst, this 6% is excluding energy usage from 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

NEEAP only covers Electricity Usage.

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.

Final Energy Demand by Sector. Red boxes indicate Residential, Commercial and Industrial demand. Source: National Energy Balance 2011

3) No Details on Agency/Task Force In Control of the Implementation & Feedback of NEEAP

Various literature have 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 consider 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 to overview the nation’s energy efficiency development, as far as we know, there are so many ministries/agencies and as well as 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 for 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?

6) Lack of Elaborations of Consultation Processes and Editing Team behind NEEAP

There is no appendix nor attachment describing on the evolution of drafting NEEAP along 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 round 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 is 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 of 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 masterplan, 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 for next few rounds of outcome.

#While i am not a professional to judge things on the very surface, but as a Malaysian who are concern on the policy that will make the change in our environmental obligations, economic progression, and social welfare situation, i say that the public must be concern on such draft!