INPUTS AND FEEBACK TO THE KeTTHA’S DRAFT MEEAP/NEEAP

INPUTS AND FEEDBACK TO THE MINISTRY OF ENERGY, GREEN TECHNOLOGY AND WATER ON THE DRAFT NATIONAL EE ACTION PLAN/MALAYSIA EE ACTION PLAN

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.

1. 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. 
2. 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. 
3. 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. 
4. 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. 
5. 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. 
6. 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. 
7. 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. 
8. 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. 
9. Stakeholders’ engagement is crucial and their inputs must not be ignored by KeTTHA before finalising the plan.

 

SUMMARY OF COMMENTS, INPUTS,COMPARISON, SUGGESTIONS AND REFERENCES

• 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 24^th 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 24^th 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)

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.

• 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

• 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;

• 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

• 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

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

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. 

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

• 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.

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?

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.

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

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

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

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.

·         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 24^o 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?