THE CONCLUSIONS
The development of the draft has been done by ignoring key findings and recommendations from studies conducted and funded by KeTTHA and few versions draft NEEMP that have been develop and produced from 2009 to 2011.
The development of the draft has been done by ignoring key findings and recommendations from studies conducted and funded by KeTTHA and few versions draft NEEMP that have been develop and produced from 2009 to 2011.
- The so-called Malaysia EE Action Plan has never come across the same process in the development compare to the initial document from the same ministry and in the same time ignored some core or fundamentals elements in any strategic EE plan at national level as generally deliberated, discussed, argued and finally shared some common grounds with key stakeholders before.
- The draft is basically a cut and paste document from previous documents and just being simplified with some changes in some key figures and data with addition of some elements that have never been consulted with any of key stakeholders in government and private sectors compare to the previous draft that also owned by the same ministry.
- KeTTHA seems has never been consistent in pursuing EE but still giving one after another reasons to justify all delays of its actions to stakeholders, public and even to the parliament. I believe this is due to the incompetency and ignorance of some of its officers who have been responsible in EE since 2012 that resulted in inaccurate advice given to the top management of the ministry for deliberation and consideration about the proposed holistic plan needed for EE. Answers at the two parliament sessions in 2013, clearly showed that.
- Some of the highly recommended elements based on engagement and consultations also have been ignored with no rational given to those who have spent thousands of man hours in about 4 years.
- A comprehensive EE law covering significant energy uses by intensive energy users for electrical and thermal energy consumption from key sectors such as industrial and building must be enacted and enforced as proposed earlier.
- A permanent, dedicated, competent, accountable and empowered with legal powers under the EE law must be made available to be responsible on the overall implementation of the NEEMP in the 10 year plan and beyond.
- The recent draft also has never been shared with any of us out here at the development stage and suddenly and quietly it was uploaded with only one month to comment for a national level document.
- The draft is not fit to be considered as the national document. The draft NEEMP must be relooked and updated with current development with all core elements in sustainable and effective implementation of strategic energy efficiency plan at national level with the ready to be implemented key energy efficiency measures as outlined.
- Stakeholders’ engagement is crucial and their inputs must not be ignored by KeTTHA before finalising the plan.
- The ministry’s correct name is wrongly written in the footer at all pages of the drafT
- The name of the plan is National EE Action Plan (NEEAP) or Malaysia EE Action Plan (MEEAP) as written at the header of all pages and mixed in the document contents.
- These glaring errors do indicate how serious the document was really reviewed and prepared before publishing it online.
- Bear in mind that this document is officially prepared by KeTTHA and can be referred by anyone in the world online.
Public consultation awareness and duration given
- Why only one month for public comments for the so-called national document?
- Why did announce it to the mass especially to key stakeholders for greater awareness about the draft and to indicate how serious is KeTTHA to get external inputs to the plan.
Stakeholders engagement in the development
stage was ZERO
- Why no consultation such as seminar, workshop and dialogue with stakeholders in the development process like typically done by the ministry or other government agencies for other initiatives that require inputs from stakeholders?
- Who and which parties were involved in the development of the plan?
- Stakeholders from government and industry players?-EE experts-technical & economist(Professional bodies,industry representatives, financial institutions, NGOs,Consumer groups?
- If the plan is prepared by KeTTHA officers, what are their credentials and competencies in EE?
- The issue of credentials of who drafted this plan is valid since this is a national level document. If not, anyone can come up with something claim to be a national document and later impose it to Malaysians to obey while using the taxpayers’ money along the way.
In the drafting previously since 2009 NEEMP, the stakeholders participated in the
following sessions
- Technical Work Group Workshops in Peninsula Malaysia;
- Technical Work Group Workshop each in Sabah andSarawak; and
- Technical Review Committee Meetings from 2009 to 2010.
- Seminars and workshops on TORs and the drafting of the proposed EE Law in 2011.
- It is to be noted that the NEEMP was approved by the Steering Committee, the highest level of governance of NEEMP on 24th June 2010. It was chaired by the then Secretary General of KeTTHA with active participation of senior government officials and key industry experts.
Stake holders involved in NEEMP
studies and development process
- 1. Ministry Of Finance
- 2. Economic Planning Unit
- 3. Ministry Of International Trade & Industry
- 4. Ministry Of Domestic Trade, Cooperative And Consumerism
- 5. Ministry Of Science ,Technology & Innovation
- 6. Ministry Of Housing And Local Government
- 7. Department Of Local Government
- 8. Department Of Occupational Safety &Health
- 9. Malaysian Industry-Government Group For High Technology
- 10. Malaysia Investment Development Authority
- 11. Department Of Environment
- 12. Department Of Standards Malaysia
- 13. Jabatan Kerja Raya – Cawangan Alam Sekitar Dan Tenaga
- 14. Jabatan Kerja Raya – Cawangan Kejuruteraan Mekanikal
- 15. Jabatan Kerja Raya – Cawangan Senggara
- 16. Jabatan Kerja Raya –Cawangan Pengurusan Aset
- 17. Jabatan Kerja Raya – Cawangan Kejuruteraan Sivil
- 18. Jabatan Kerja Raya – Cawangan Kejuruteraan Elektrik
- 19. ST
- 20. CIDB
- 21. Malaysia Green Technology Corporation
- 22. SME Corp
- 23. BEM
- 24. IEM
- 25. PAM
- 26. Lembaga Arkitek Malaysia
- 27. TNB
- 28. Sarawak Energy Berhad
- 29. SESB
- 30. FMM
- 31. Malaysian Iron And Steel Industry Federation
- 32. Malaysian Gas Association
- 33. Malaysian Plastics Manufacturers Association
- 34. Malaysian Pulp And Paper Manufacturers Association
- 35. The Electrical And Electronics Association Of Malaysia
- 36. Malaysia Electrical Appliances Distributors Association
- 37. Malaysian Air-Conditioning & Refrigeration Association
- 38. Real Estate & Housing Developers’ Association Malaysia
- 39. Persatuan Pengurusan Kompleks Malaysia
- 40. Malaysia Association Of Energy Service Companies
- 41. Malaysia Association Of Hotel Owners
- 42. Malaysia Association Of Hotels
- 43. Malaysian Wood Industries Association
- 44. Real Estate & Housing Developers’ Association
- 45. Glass Manufacturers Association Of Malaysia
- 46. Malaysian Rubber Products Manufacturers’ Association
- 47. Pertubuhan Pengurusan Kompleks
- 48. Association Of Private Hospitals Malaysia
- 49. Malaysia Rubber Exporters And Promotional Council
- 50. Small Medium Enterprise Association
- 51. Malaysia Green Building Confederation
- 52. Sirim Bhd
- 53. UNITEN
- 54. MASHRAE
- 55. Association Of Consulting Engineers, Malaysia
- 56. FOMCA
- 57. UTM
- 58. Universiti Teknikal Malaysia Melaka
- 59. Fakulti Kejuruteraan Universiti Malaya – Jabatan Kejuruteraan Elektrik
- 60. MEPA
- 61. ISI Ventures Sdn Bhd
- 62. Akademi Sains Malaysia
- 63. Centre For Education, Training, And Research In Renewable Energy And Energy Efficiency(CETREEE)
- 64. Centre Of Environment And Technology Development Of Malaysia(CETDEM)
- 65. Research Management Institute
- 66. Institute Of Certified Engineers Malaysia
This has clearly shown that the
initial final draft developed by KeTTHA has more inputs from stakeholders that
have been taken into consideration after series of consultative and dialogue
sessions.
Inputs form IEA EE Governance Handbook.
Why is stakeholder
engagement important?
- Stakeholder engagement is a crucial component of an overall energy efficiency governance system.
- Stakeholder engagement helps build political consensus and ensures broad buy-in to policy implementation.
- That is not to say that stakeholder engagement is not without its risks, and it is a process which should be actively and carefully managed to ensure the benefits.
Stakeholders engagement in the development
stage of MEEAP/NEEAP was ZERO
- Why no consultation such as seminar, workshop and dialogue with stakeholders in the development process like typically done by the ministry or other government agencies for other initiatives that require inputs from stakeholders?
- Who and which parties were involved in the development of the plan?
- Stakeholders from government and industry players? EE experts-technical and economist(Professional bodies,industry representatives, financial institutions, NGOs,Consumer groups?
- If the plan is prepared by KeTTHA officers, what are their credentials and competencies in EE?
- The issue of credentials of who drafted this plan is valid since this is a national level document. If not, anyone can come up with something claim to be a national document and later impose it to Malaysians to obey while using the taxpayers’ money along the way.
- In the drafting previously since 2009 NEEMP, the stakeholders participated in the following sessions
- Technical Work Group Workshops in Peninsula Malaysia
- Technical Work Group Workshop each in Sabah andSarawak
- Technical Review Committee Meetings from 2009 to 2010.
- Seminars and workshops on TORs and the drafting of the proposed EE Law in 2011.
The NEEMP was approved by the Steering Committee, the highest level
of governance of NEEMP on 24th June 2010. It was chaired by the then
Secretary General of KeTTHA with active participation of senior government
officials and key industry experts.
This has clearly shown that the
initial final draft NEEMP developed by KeTTHA has more inputs from stakeholders that
have been taken into consideration after series of consultative and dialogue
sessions.
Inputs form IEA EE Governance Handbook.
Why is stakeholder
engagement important?
·
Stakeholder
engagement is a crucial component of an overall energy efficiency governance
system.
·
Stakeholder
engagement helps build political consensus and ensures broad buy-in to policy
implementation.
·
That
is not to say that stakeholder engagement is not without its risks, and it is a
process which should be actively and carefully managed to ensure the benefits .
Guidelines
for stakeholder engagement
Ensure engagement in energy
efficiency policy development should be open to all interested stakeholders.
The legislative framework
should make stakeholder engagement a mandatory requirement (see examples in Massachusetts and New Zealand)
Integrating
public participation into the legal framework has several benefits, among them
ensuring that the government engages stakeholders even when decisions need to
be made on potentially sensitive issues, and providing clarity to stakeholders
in terms of the timing and scope of the engagement process.
Stakeholder diversity should be a goal of engagement
As
stakeholders have different interests and concerns. Also, stakeholders excluded
from the decision process may work to disrupt it.
Mechanisms that provide for ongoing stakeholder engagement are particularly useful.
Engaging
stakeholders should be part of every policy process, rather than carried out
only in response to public outcry. Ensuring that stakeholder involvement is
part of all energy efficiency policy development will ultimately lead to improved
policy design and implementation.
There are a large number and variety of participation techniques ranging, for example, from opinion polls, to focus groups and consensus conferences.
No clear governance structure other than the
proposed project organizational setup.
The MEEAP/NEEAP has ignored one
of the enabling frameworks which are the absence of Laws for EE and not
committing the funding sources and mechanisms to implement the plan.
No proper institutional arrangement proposed and explained in the draft other than brief information on the formation of merely a project team with no specified competency and agency that will make them accountable to ensure targets to be achieved with funds allocated and actions to be implemented.
Inputs from IEA EE Governance Handbook.
The structure of common EE
governance as outlined by IEA based on studies among its member countries covering
i) Enabling Framework(Laws and decrees,
Strategies and action Plan,
Funding mechanism)
ii)Institutional arrangement(Implementing agency, resources
requirements,roles of energy providers,stakeholders engagement,public
private sector cooperation, international assistance)
iii)Coordinating mechanism(government coordination, targets, evaluation)
Funding mechanism)
ii)Institutional arrangement(Implementing agency, resources
requirements,roles of energy providers,stakeholders engagement,public
private sector cooperation, international assistance)
iii)Coordinating mechanism(government coordination, targets, evaluation)
The MEEAP/NEEAP prescribes a path towards
improving energy efficiency by pursuing the implementation of measures that are
considered as “harvesting the low hanging fruits”, as they are viable for the
nation as well as the end users.
- The overall key actions and key initiatives that outlined briefly in the plan contradict thus statement since low hanging fruits measures not suppose to require so much investments such as energy audit, energy efficient technologies and etc.
- Low hanging fruits or low-no cost measures would be able to be implemented from the adoption energy management system based on recognized standards such as ISO5001:2011 which should the initial approach in energy efficiency implementation and then followed by high cost measures.
- This clearly shows the incompetency of whoever who prepared this draft in understanding the basic concept of sustainable energy management system implementation which will lead to efficient use of energy in long term with continual improvement in the way forward beyond 10 years.
The barriers can be categorised in MEEAP/NEEAP
as:
i) Low energy prices;
ii) Lack of finance for energy efficiency;
ii) Lack of overall national plan for Energy Efficiency;
iv)Lack of champion to drive Energy Efficiency; and
v) Lack of consistency in embarking on energy efficiency.
i) Low energy prices;
ii) Lack of finance for energy efficiency;
ii) Lack of overall national plan for Energy Efficiency;
iv)Lack of champion to drive Energy Efficiency; and
v) Lack of consistency in embarking on energy efficiency.
- How the these barriers in the MEEAP/NEEAP identified?
- Was there any independent study done to confirm these findings for Malaysia.
- Why the stated barriers do not mention about having the dedicated comprehensive law for EE agency to be accountable for EE implementation although both have been highlighted and strongly recommended by findings of all studies done by KeTTHA's consultants and independently by other local and international experts.
- Why suddenly KeTTHA took out both since KeTTHA still could not decide who will be accountable for EE and have unilaterally cancelled the drafting of the EE act based on personal opinions and interests.
- The memo of 10 NGOs to the YB Minister sent last year elaborated at length on that and seeking explanation but still ZERO response from today. Then suddenly the ministry come with this downgraded document from good to” rubbish” draft after some officers rubbished all inputs from over 60 entities in 3-4 years.
- It would be a big shame should this document is labelled as national level draft document seen or referred by other countries online while Malaysia is busy telling the world through our PM that we are becoming more green and energy efficient.
Previous studies by the consultants appointed by KeTTHA highlighted the follows as presented and shared by KeTTHA in seminars and workshop with stakeholders:
- Low energy prices
- Lack of overall national plan for Energy Efficiency
- Lack of legal and regulatory framework for Energy Efficiency
- Lack of champion to drive Energy Efficiency initiatives
- Lack of funding and support to promote Energy Efficiency initiatives
- Lack of consistency in embarking on the energy efficiency efforts
Below are the findings by
International Energy Agency(IEA) EE Governance Handbook based on studies among its member countries.
The Draft MEEAP/NEEAP Only confine to electricity usage and does
not cover the other aspects of the energy sector
Why only electrical energy and not covering thermal energy as highly recommended
by all experts and stakeholders involved in the draft of NEEMP development?
The need to include thermal has been justified and agreed by key
stakeholders. The verbal reasons given so far by some officers in KeTTHA due to
their scopes is only electrical and existing laws enforced by ST only cover
electrical is totally unacceptable ( that should be the justification to expand
the scope of the existing laws by amending it or draft the new law)
· KeTTHA's Legal head has confirmed and informed all stakeholders in the
workshop organized by KeTTHA in March 2011 to finalize the TORs for drafting
the EE law that KeTTHA has responsibilities to develop the energy policy for
Malaysia and not only electrical energy.
The aim of the MEEAP/NEEAP is to promote energy efficiency in order to
meet the following
policy direction:
”Promote energy efficiency to ensure
productive use of energy and minimise waste in order to contribute to
sustainable development and increased welfare and Competitiveness.”
- Is this the energy policy statement for Malaysia or just a normal statement that not carry any commitment with dedicated accountability to ensure it will be achieved?
- If yes, it should be discussed for inputs and comments and made to be understood by stakeholders.
Draft MEEAP/NEEAP
Establish an overall long-term national plan for energy efficiency
Establish an overall long-term national plan for energy efficiency
- Preparing a plan is a thrust? This should be works on the ministry and not as a part of an action plan.
- KeTTHA claimed the document is the action plan document which means it is a document that basically ready to be implemented with specified and detailed measures and targets that can be quantified to monitor their performance.
- Is this the plan to prepare another plan because my understanding is the action plan is suppose to be something that is basically ready to be implemented.
- There is no indication on when exactly the targeted year the plan to be implemented and all details on the time frame with key milestones, periodical reviews within the 10 year period.
- It is also another proof that KeTTHA has not done the ground works needed before this plan published for public consultation.
- The progress of this action plan is totally contradict with official statements of the ministry in the media and answers to parliament sessions in 2013.
The statements related to draft NEEMP since 2011
has clearly showing that KeTTHA has been
inconsistent in pursuing EE but still giving one after another reasons to justify all delays of its actions
to stakeholders, public and even to the
parliament.
The development and enforcement of dedicated EE law - ignored in MEEAP/NEEAP
- KeTTHA has cancelled the drafting of the initially agreed EE Law with approved budget too using the open tender process in the end of 2012. Logically some money has to be paid to the consultant as well due to the cancellation for works that they have done at that stage because they have been appointed according the proper procedure.
- The drafting consultant was also carefully selected through a normal assessment procedure and followed by the formation on committees and sub-committees headed by KeTTHA and comprised of key stakeholders.
- The reasons of the cancellation was also not officially notified accordingly and found was decided by a meeting chaired by only a junior level officer. The letter of invitation to the meeting was also signed by the same officer.
Create a Legal and Regulatory Framework for Energy Efficiency - ignored again
We are aware that Malaysia has no
comprehensive law to govern the implementation of energy efficiency at national
level and why KeTTHA ignored the findings about the lack of regulatory
framework for energy efficiency.
Countries like Thailand, Japan and
recently Singapore and Indonesia have proven that the needs of law to ensure
energy efficiency implementation will achieve the national EE targets.
I was invited by IEA at the EE policy
recommendations for ASEAN countries in Jakarta on 11-12 December 2013 and all
countries presented papers showed all of them have dedicated EE law
too.Malaysia has been proven have not be able to show any significant energy
saving results since the last 20 years and to use the low energy price alone
that will hinder the EE implementaion is absolutely not totally correct and
need to supported by assessment by independent body and not the ministry.
ST has been entrusted to implement EE
regulations and that only cover electrical energy and still struggling
enforcing it with limited powers and resources to ensure EE is implemented.
Here is some brief information
from studies by IEA on the needs of laws to ensure effective implementation of
EE for countries.
Inputs from IEA EE Governance Handbook.
Why are laws and decrees
important?
Energy efficiency laws or decrees are important
because they can:
i)
give
direction to
energy efficiency policies, by stating the government’s overall objectives as
well as policies and strategies to achieve them;
ii)
provide
a statutory basis for
rules and regulations, such as building codes, appliance efficiency labelling
or minimum efficiency performance standards, and obligatory activities (e.g.
audits or investment);
iii)
assign
responsibility for
developing rules or implementing programmes, which in some cases involves
establishing new agencies or institutions;
iv)
Specify
funding required and funding mechanisms for energy efficiency activities.
In
many countries, an energy efficiency law or decree forms a critical part of EE
governance arrangements. In
Recent
years, there has been rapid growth in the number of countries that have enacted
energy efficiency legislation.
Over
two-thirds of responses to the IEA EE governance survey indicated that their
country had some form of legal basis in support of energy efficiency.
The importance of
energy efficiency laws is clear considering that the most successful energy
efficiency programmes around the world have a statutory basis.
Create a Centralized Agency for Energy Efficiency and Conservation Implementatio
None in Draft MEEAP/NEEAP. Just a project
team proposed.
- Why there is no agency to be accountable to implement the plan?
- The idea to have a project team for the plan is a proof that the ministry do not see the plan is comprehensive and concrete enough to have a long term commitment for the implementation and monitoring.
Draft MEEAP/NEEAP
Strengthen Implementation Capacity to Promote Energy Efficiency;
Strengthen Implementation Capacity to Promote Energy Efficiency;
- No clear definition on what is the capacity such quantity of resources, competencies and target groups.
Inputs from IEA EE
governance handbook
What is important about
energy efficiency resource allocations?
Governments need to allocate sufficient
financial and human resources to achieve the desired level of energy efficiency
improvement. Implementing agencies need to understand the resources required
for different energy efficiency policies in order to properly organise, staff
and budget their activities
What is the scale of energy
efficiency resourcing in selected countries?
Estimating and comparing energy efficiency
resource allocations across countries is challenging because resource requirements depend on:
i) the
policy being implemented;
ii) The
structure of the energy efficiency institutional organisation. For example,
energy efficiency functions are often distributed across many departments or
agencies. In this case, it can be difficult to isolate the part of the
resources in any one agency that is allocated to the work on energy efficiency.
Based on the current work and previous work by
the Protocol on Energy Efficiency and Related Environment Aspects (PEEREA), it
appears that no country spends more than 0.1% to 0.2% of GDP on energy
efficiency, and most countries spend between 0.01% and 0.05%.
What resources (staff and budget) are needed for
energy efficiency institutions for Malaysia? All this has been described in
more detailed in the NEEMP draft but surprisingly has been stated much more
briefly in the action plan draft.
Draft MEEAP/NEEAP
Create adequate and sustainable funding mechanism for energy efficiency
Create adequate and sustainable funding mechanism for energy efficiency
- There is no indication of any specific and sustained source of funds for the execution of the EE programme for a 10-year period under NEEAP.
- Is this a deliberate effort as a planned "scapegoat excuse" for inevitable failure to achieve the desired targets? I call it "inevitable" because it would be subject to "stop-&-go" decision making for funds allocation. Depending on Federal funds on a year-to-year basis would be like living in a "Walter Mitty World" (in other words, a dream world)-from fellow EE activist
- The recent increase in the electricity tariff levy for RE funds could be allocated to finance the EE programmes under the NEEMP and surely will require to amend the RE Act that govern the levy and RE fund-from fellow EE activist
Draft NEEMP
Funding and Financial Mechanism
Funding and Financial Mechanism
The proposed funding options and mechanisms in
the NEEMP after the series of consultation with stakeholders, Bank Negara, EPU
and then with YB Minister and the Secretary General of KeTTHA in 2011.
Some options were initially proposed before that also examined several options on the sources of money which could be used for the
establishment of the Energy Efficiency Fund (EE Fund) in
Malaysia.
Other financing and incentive
related support measures proposed were
as follows:
EE Revolving Fund
The main aim of a
revolving fund would be to provide low interest loans for EE strategies
to industrial and commercial users via EECAM and disburse through selected
financial institutions. The outcome of this would ultimately yield support for
a large amount of EE strategies, to increase investment and generate
significant energy savings. In addition this incentive would be able to
facilitate the role of financing institution in EE initiatives. This
incentive also allows for more co-financing to come from banks and in turn,
banking officers would need to be trained on EE.
Additional Fiscal Tax Incentives
It is proposed tax
incentives are to be made available to all applicants who are involved in all
relevant EE activities. Investment in control devices which save energy
and monitoring and verification system to log and trend energy consumption are
allowed to apply for this incentive apart from out-right purchase of energy
efficient equipments. Factories or buildings owners who acquire and install new
equipments can enjoy 150% of cost incurred to be exempted from income tax.
However, the tax exemption shall only apply to expenditures incurred within the
first five years. There is no direct disbursement of money compared to the
EE Revolving Fund mechanism.
ESCO Performance Contracting Fund
This incentive
scheme is only applicable to Energy Service Companies (ESCOs) approved by
EECAM. This fund as the name implies provide soft loans to ESCOs executing
energy performance contracting (EPC) to fund factories or buildings on capital
investment and interest costs of EE equipment, systems, costs on monitoring and
verification of saving results after testing and commissioning and assuming
those business risks. ESCOs are eligible to purchase all audit tools and
equipment from this Fund.
Inputs from IEA EE Governance Handbook.
Why are energy efficiency
funding mechanisms important?
A steady and reliable source of funding is
essential for energy efficiency institutions and programmes. The complex,
market transformational nature of energy efficiency programmes means that they
often require multi-year funding. If energy efficiency funding depends on
annual budget allocation then implementation may be compromised. “Stop-and-go”
programme funding is a big concern for energy efficiency managers.
Key
notes: Policy makers should
avoid funding volatility as a matter of good energy efficiency governance.
Draft MEEAP/NEEAP
Implement Energy Efficiency Programmes
Implement Energy Efficiency Programmes
Implementation of programs should not be a
thrust in a national plan. That is the works to done by the agencies
accountable in the implementation.
Capacity
Building and Training - no clear targets in draft
MEEAP/NEEAP
it was presented in the draft NEEMP
Strengthening the capacity building of Energy Managers, Energy
Auditors and ESCOs
Training of teachers, lecturers, financial experts, other relevant
professional such as engineers, architects, lawyers, semi-professional,
etc.
MEEAP/NEEAP
it was presented in the draft NEEMP
Strengthening the capacity building of Energy Managers, Energy
Auditors and ESCOs
Training of teachers, lecturers, financial experts, other relevant
professional such as engineers, architects, lawyers, semi-professional,
etc.
Draft MEEAP/NEEAP
Enable commercial finance institutions to support energy efficiency.
- How to enable when no clear mechanism of sourcing, distribution and monitoring of the fund specified in the plan
- Who will be empowered with legal authorities to source, distribute and manage the fund?
- How can a project team has the power to manage the fund as proposed in this draft?
STRATEGIC ACTION
Draft MEEAP/NEEAP Ignored two key elements
Draft MEEAP/NEEAP Ignored two key elements
- EE law development and enforcement;and
- Dedicated , competent and centralized agency for national plan implementation
Inputs from IEA EE Governance Handbook
Why are energy efficiency
strategies and action plans important?
Many countries use a strategy development or
action planning process as a means to engage stakeholders, build consensus and
galvanise action on energy efficiency. These strategies and action plans help
guide and
encourage energy efficiency policy development
and implementation by:
- placing energy efficiency policy within the broader policy context;
- allocating resources across the range of possible energy efficiency policies;
- capturing synergies between policies;
- engaging stakeholders and building political consensus; and
- Assigning responsibility for policy development, implementation and oversight.
Questions relating to
strategies and action plans
National energy efficiency strategies play an important role as they provide a high-level view of how a country can meet economy-wide goals. For example, the European Union’s 20-20 target aims for a 20% reduction in primary energy use compared with projected levels by 2020.
The EE strategy should also be comprehensive in describing the approach to and rationale for energy efficiency policies and programmes.
National energy efficiency strategies play an important role as they provide a high-level view of how a country can meet economy-wide goals. For example, the European Union’s 20-20 target aims for a 20% reduction in primary energy use compared with projected levels by 2020.
The EE strategy should also be comprehensive in describing the approach to and rationale for energy efficiency policies and programmes.
Draft MEEAP/NEEAP Action No.5: Research and Development
Very briefly
explained. No indication on the focused areas and who will be responsible or
strategic partners will be involved such as SIRIM or universities.
Education and Awareness – ignored in MEEAP/NEEAP
Public-private sector partnership – ignored in
draft MEEAP/NEEAP
- Compare to Draft NEEMP which developed with extensive involvement and participation of the private sector, the MEEAP/NEEAP was developed in isolation and suddenly there are significant portion of the investments to implement the plan.
- How could the ministry be so sure that the plan is workable when inputs from private sectors were not sought in the development?
Inputs from IEA EE Governance Handbook.
Public-private sector
co-operation
Why is public-private
sector co-operation important?
Co-operation with the private sector in policy
development:
· Ensures
that government policies take full advantage of the resources and commercial
energy of the private sector.
· Allows
public funding to be leveraged through private investment, as well as private
sector participation in programme delivery.
· Is
essential for market transformation strategies, as demand-creation for more
efficient products must be accompanied by supply-creation by appliance and
equipment manufacturers.
Public-private sector co-operation is a win-win
proposition, as government energy efficiency agencies and private firms benefit
from close co-operation in designing and implementing energy efficiency policy
and programmes.
Questions
relating to private sector engagement
Why is public-private sector co-operation
important in EE governance?
What are some good examples of public-private sector co-operation?
How can the private sector be mobilised in implementing energy efficiency policies?
What are some good examples of public-private sector co-operation?
How can the private sector be mobilised in implementing energy efficiency policies?
Draft MEEAP/NEEAP Initiative 1: Rating and labeling of appliances
- Only to target mainly domestic users which are not significant as clearly stated in the plan compare to industrial and building facilities.
- The initiative has already in place for implementation soon by ST and only requires effective enforcement by the regulator.
SAVE rebate programs implemented
for common appliances such as refrigerators and split unit air conditioners
have already prepared the market since 2011 and only need further enhancement
of the projects.
Draft MEEAP/NEEAPInitiative 2: Minimum Energy Performance
Standards (MEPS)
Only to target mainly domestic users which are not significant as clearly stated in the plan compare to industrial and building facilities.
The initiative has already in place for implementation soon by ST and only requires effective enforcement by the regulator.
Only to target mainly domestic users which are not significant as clearly stated in the plan compare to industrial and building facilities.
The initiative has already in place for implementation soon by ST and only requires effective enforcement by the regulator.
Even the implementation
of MEPS by ST for refrigerators has been "screwed up". After the SAVE
programme achieved a 40% market share for 5-Star refrigerators, ST set the MEPS
for them at a 2-Star grade last year, opening the way for Malaysia to become a
"Dumping Ground" for the low efficiency fridges.
Draft MEEAP/NEEAP Initiative 3: Energy Audits and Management
in Buildings and Industries
All initiatives proposed are not
low hanging fruits since require significant costs for investments to be
implemented.
Draft MEEAP/NEEAP Initiative 4: Targeted
“Kick Start Promotion Bonus” and support programmes. Energy efficiency
programmes will be designed and implemented to create a market transformation
towards more energy efficient technologies.
Rebate programmes will be made available to provide
support to cover the incremental capital costs for energy efficient technology
e.g. 5-star appliances as compared to average appliances.
Already implemented under SAVE
program in ETP from 2011
The SAVE Programme was created and is funded by
the Government under the Economic Transformation Programme to stimulate the
economy.
The SAVE Programme is under Entry Point Project
9 and improving energy efficiency has been identified as a key criteria to
boost the economy development in Malaysia.
Under the SAVE Programme, there are five key
pillars:
i)“Government Leading by example” on energy-efficient practices and philosophy;
ii) Stimulating the sales of energy efficient appliances;
iii) Making co-generation economically viable;
iv) Improved regulation on building insulation;
v) Stimulating the sales of energy-efficient vehicles
i)“Government Leading by example” on energy-efficient practices and philosophy;
ii) Stimulating the sales of energy efficient appliances;
iii) Making co-generation economically viable;
iv) Improved regulation on building insulation;
v) Stimulating the sales of energy-efficient vehicles
For 2011, the first initiative under SAVE is a
rebate Program for energy efficient air-conditioners, refrigerators and
commercial chillers. This initiative
addresses Pillar #2 of the SAVE Programme which is to stimulate the sale of
energy efficient appliances.
The initiative targets the final end user
through retailers of electronic appliances and will generate up to 7,300GWh of
energy saving by 2020. For the nation, this means a GNI of up to
RM5.1 billion by 2020.
In general, the 5 key initiatives for EE in EPP9
were designed for 3 year period in the first phase of the implementation which
requires some allocations from the government for a kick-off. When the budget
was proposed, it went through an evaluation process at outlined by PEMANDU, MoF
and EPU.
In short, every EPP has gone through rigorous
assessments from all angles such as practicality, implementable, economically
viable, acceptance by key stakeholders and industry players and etc. On top of
that, EPPs also were presented by PEMANDU to be vetted by the central agencies
such MoF, EPU and relevant ministries to gauge their feedback and inputs.
Then each EPP was presented again to these
agencies after actions taken based on feedback and input given and finally to
be tabled to the committee which was chaired by the PM for the consideration
and approval to be included in ETP.
When each initiative in EPP9 was designed and
proposed to PEMANDU the measures that would give quick impacts, proven to be
effective as implemented in successful countries in EE and also with reasonable
budget which would give less resistance to the decision makers to accept.
What was done is by looking into some existing
EE measures that being planned to be implemented but need some policy
directives to get the green light. The strategy was to use ETP as a platform to
put EE in the mainstream agenda of the country which would require parties
related to the implementation of EE measures to give their commitment.
2010 was the year that NEEMP planned to be finalized and both of us had that in-depth knowledge about the key findings and proposed key strategic initiatives in the initial draft NEEMP document. When looked at those initiatives, there were some of they could be implemented without the endorsement of the final NEEMP document and what needed were just some allocation of budget and commitment by certain parties to implement it.
That was the key considerations when the proposed initiatives such as rebate programs for energy efficient electrical appliances and equipment, implementing of energy management system and energy conservation measures at government buildings and energy efficient insulation for buildings as among the earlier initiatives to kick-start EPP9 implementation in 2011.
Based the development of EE at the time, it was believed that the proposed initiatives would be sufficient to enhance the awareness of EE among the public and prepare the market related industry players such as manufacturers and retailers before the introduction of NEEMP which was targeted in 2011.
All initiatives proposed in EPP9 were to be
implemented on voluntary basis and while some of them will become mandatory
gradually with the implementation of NEEMP at the later stage.
The achievement of market share in the period July 7
to August 31, 2012 for refrigerators and air conditioners:
·
5-Star rated
refrigerators: 242.3936 units (40.40%)
·
5-Star rated air
conditioners: 159.102 units (26.52%)
Total energy savings was 246.42 GWh. Carbon
savings of 167.5 million tons
Through achieving the market share, the rate of
reduction of carbon dioxide (CO2) emissions
·
5-Star rated
refrigerators: 41,646.06 tonnes
·
5-Star rated air
conditioners: 82,335.29
For Energy Efficient Chiller
Total capacity of market share for chillers with
performance in compliance with MS1525:2007 Standard at 39.2% or 80,611 RT
- So, why do not build from the success of this program? Bear in mind it is the program implemented by KeTTHA itself.
In Draft MEEAP/NEEAP Initiative 5: Energy Efficient Building Design
- Already in place such integrating MS1525 Standard in Uniform Building by Law (UBBL) and only need further efforts to ensure the implementation comprehensive by implementing agencies at federal level such as ministries, JKR and local authorities.
Draft MEEAP/NEEAP Action 1: Establishing
Malaysia Energy Efficiency Action Plan Project Team,
Just a project setup for national plan?
- It clearly shows the degree of commitment of the KeTTHA to commit in the implementation of the plan.
- No indication of total actual personnel and types of competencies required in the set up.
- Why there is no agency to be accountable to implement the plan?
- The idea to have a project team for the plan is a proof that the ministry do not see the plan is comprehensive and concrete enough to have a long term commitment for the implementation and monitoring.
- Bear in mind Thailand took more than 10 years and Japan took more than 30 years to be where there are today and both are still improving and there are permanents setups which are accountable in long term with powers given under the dedicated EE law.
- Lessons and experiences from the MIEEIP , Biogen and MBIPV projects jointly funded and implemented with UNDP should be noted by KeTTHA. Project set up will never able to sustain the program in long term.
- Out of the three projects on MBIPV project managed to be sustained with the formation of a permanent entity like SEDA with powers with SEDA and RE acts and supplied with sustainable funding source with specified sourcing and distribution mechanism.
The proposed
comprehensive and initial permanent set up in the 10 year plan and expandable
for future needs in the way forward is as outlined below.
Energy Efficiency Agency
Malaysia (EEAM)
- Empowered under the dedicated EE law.
- One Stop Center to implement the nation’s policy and measures on EE
- To be established as a Department under existing agencies such as Energy Commission to reduce Government operational cost.
- Relevant NGOs or professional bodies can also involve as strategic partners to implement certain initiatives.
The
functions of EEAM as empowered under the EE law shall be to:
(i) Effectively co-ordinate with designated factories and buildings; and
collaborate with government agencies and other relevant bodies to recognize and
utilize existing resources and infrastructure.
(ii) Perform such functions and exercise such powers as may be assigned to it
as itemized below;
Measures for Factories
a) Recommend to the Federal Government the norms for processes and energy
consumption standards required to benchmark approach on energy intensity.
b) Recommend to the Federal Government to notify prescribed users as
Designated Factories.
c) Take suitable steps to prescribe EE guidelines and/or codes of
practice for the industrial sector in achieving the set target to reduce 10%
energy accumulated over the first 5 years and 5% over subsequent 5 years.
d) Specify by regulations and certification procedures for Energy Managers
to be designated or appointed by Designated Factories
e) Maintain a register of certified Energy Managers.
f) Specify qualifications for the accredited Energy Auditors as may be
specified by regulations.
g) Specify by regulations, the manner and time intervals that energy audits
shall be conducted.
Measures for Buildings
a) Recommend to the Federal Government to notify prescribed users as
Designated Buildings.
b) Take suitable steps to prescribe guidelines and/or codes of practice for
the Energy Conservation Building Codes (ECBC) and to incorporate MS1525:2007
into ECBC.
c) Promote EE businesses.
Measures for Equipment
a) Recommend to the Federal Government the information required to be
displayed on labels for equipment and appliances and manner of their display.
b) Develop testing and certification procedure and promote testing
facilities for certification and testing of energy consumption of equipment and
appliances.
c) Specify Minimum Energy Performance Standard (MEPS) for equipment and
appliances as prescribed by regulations.
Measures for Consumers
a) Take all measures necessary to create awareness and disseminate
information on EE.
b) Promote use of energy efficient processes, equipment, devices and
systems.
Common Measures
a) Arrange and organize training of personnel and specialists in EE
techniques.
b) Strengthen consultancy services in the field of EE.
c) Promote research and development in the field of EE.
d) Formulate and facilitate implementation of pilot projects and
demonstration
projects for promotion of EE
projects for promotion of EE
e)
Promote innovative financing of EE projects.
f) Distribute financial assistance to institutions for promoting EE.
g) Prepare educational curriculum on EE from primary education to
Institutionsof Higher Learning (both public and private) and professional
bodies as part of their CPD (Continuing Professional Development) and
coordinate with them for inclusion of such curriculum in their syllabus.
h) Implement international co-operation programs relating to EE&C as
may be assigned to it by the Federal Government.
Data and Information Repository Centre
a) Collect,
analyse, compute, update, review and file data and information relating to
EE
b) Publish
handbooks on information relating to EE
From IEA EE Governance Handbaook
Structuring energy
efficiency agencies
What is the issue?
- Implementing energy efficiency policies and programmes is a complex enterprise. The implementing agency or agencies must co-ordinate policy analysis, project management, marketing, programme evaluation and
- Carry out other functions. As a result, governments often struggle to find the best organisational solution to delivering improved energy efficiency outcomes
·
The
key questions relating to structuring EE agencies
- What type of organisation should be created and where should it be housed?
- How will the agency and its programmes be funded? Who will provide oversight and accountability?
- What skill sets will be required to make the arrangement successful?
- How should an energy efficiency agency be organised internally?
- What factors are critical to agency effectiveness?
How to establish an
effective energy efficiency institutional structure
A statutory basis is
desirable, as it conveys status and permanency to an energy efficiency agency.
- Having a statutory basis confers a definite institutional advantage for an energy efficiency agency,
- Especially if the legal basis includes provisions for funding or other resources. Successful examples of this include: Brazil’s National Electrical Energy Conservation Program (PROCEL), Finland’s Motiva,France’s ADEME, India’s Bureau of Energy Efficiency (BEE), Japan’s ECCJ, Korea’s KEMCO,Mexico’s National Commission for Energy Efficiency (CONUEE) and New Zealand’s EECA.
There is no single
organisational answer. In
general, there are five different energy efficiency organisational types:
(i) generalised
government energy agencies
(ii) specialised
government EE/clean energy agencies
(iii) independent
EE/clean energy authorities or parastatal corporations,
(iv) EE/clean
energy NGO
v) EE/clean energy
public-private partnerships
Draft MEEAP/NEEAP
Funding for energy efficiency
Funding for energy efficiency
Inputs from IEA EE
Governance Handbook
Key
attributes to consider when selecting an EE funding mechanism
· Adequacy the
funding should be sufficient to finance policy implementation costs.
· Stability Funding
should be steady and predictable from year to year.
Autonomy The funding source needs to be under the control of the implementing agency.
Autonomy The funding source needs to be under the control of the implementing agency.
·
Origin The
funding source needs to be credible and contribute to overall EE policies.
·
Distortive Effects
The funding source
should not create market distortions or crowd-out other funding.
Draft MEEAP/NEEAP Action 3: Government led
initiatives
- Has already started from 2011 in EPP9, OGE, and ETP with aims to implement high cost EE measures through Energy Performance Contracting(EPC) model and adoption of energy management system.
- BSEEP program has been started and still in progress by JKR.
- The policy to set air conditioning system temperature to reach 24o C from 2011.
- Why not take it from there?
Draft MEEAP/NEEAP Action 4: Capacity Building
- MIEEIP with UNDP and on going the Industrial Energy Efficiency for Manufacturing Sector with UNIDO by SME CORP which also endorsed by KeTTHA have covered the capacity building.
- There are plenty of training and other capacity building are currently carried out by many parties such as universities, FMM, IEM, MGTC,MAESCO and etc.
- Why not integrating them in the plan?
- No indication on type of competencies and quantity of competent people within specified time frame in the plan
Draft MEEAP/NEEAP Key initiatives
Very brief with no clear methodology, approach strategies, targeted quantities for each initiative and amount fund allocated that has been estimated for each unit quantity.
· Details are
as attached. Why not include it in the
MEEAP/NEEAP Draft?
Draft MEEAP/NEEAP Economic impacts -Only highlighting the absolute savings in kWh
and RM values.
Some key data and information ECONOMIC
BENEFITS AND IMPACTS HAVE BEEN PRESENTED BY KeTTHA in
seminars, workshop in 2011
Why not
include similar impacts in the newly proposed draft?
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