Turning the draft energy strategy upside down, to shake some ‘step change’ out of it
Dear Gerry. I keep writing to you. You keep ignoring me.
Your draft New Zealand Energy Strategy (NZES) gestures at New Zealand’s two big problems: the economy, and the environment. But it is not a strategy for the current climate.
Its priorities are wrong, fundamentally. It needs to be turned on its head, to shake the ‘step change’ out of its pockets. In the language of the submission guide, it doesn’t “promote and support the appropriate development and use of energy resources”.
I understand your drive for energy-fuelled economic growth. But growth, at any cost, will not enhance “the benefit and well being of all [or any] New Zealanders”. Who knew we were living in a climate change-challenged world? There’s not one mention of “climate change” in the draft. That is the deal breaker, that all else must be built around.
It says there are “challenges and opportunities” for New Zealand’s continued economic growth, in moving to a lower carbon economy. That is, with respect, trite public service talk. It sounds fine, and tells nothing. Whatever we gain on oil, we risk losing on export markets; whatever we have in the bank would soon be spent, on climate disaster mop-ups.
The NZES says it is about realising our potential for energy development in all areas. And we can see, already, this government pushing forward on all of them, with some pretence at even-handedness: oil, minerals, biofuels, renewables.
For example, under "new energy technologies" and "oil security and transport", biomass and coal-to-liquid fuel options are both noted. Carbon capture and storage is discussed in a few places as a “potential” emissions reduction option. But before Solid Energy invests many billions of dollars in lignite conversion, CCS technology has to be found, and its effectiveness guaranteed. That is a necessary precondition, not a desirable possibility.
I appreciate the government’s reluctance to pick winners. I don’t believe it is smart not to acknowledge what we already know: carbon is going to end up a loser, if not one way, then another.
You have asked for comments on your proposed goal, priorities, and 12 areas of focus. The goal implies growth first, plus some token recognition that the environment is important. The government’s goal ought to be for New Zealand to make the most of its abundant energy potential, subject always to the paramount goal of environmentally responsible development — development that is environmentally responsible globally, as well as locally. If we don't demand this of ourselves, one of these days, the world will.
The draft gives some priority to renewable energy, and energy efficiency. But logically, energy efficiency should be first. How much we can cost-effectively save tells us how much more we need to generate; it affects energy security, and affordability, some of your other aspirations.
The draft New Zealand Energy Efficiency and Conservation Strategy (NZEECS) acknowledges all of this, so I know that you agree. But it is not given effect in the wider NZES structure. The NZEECS should be presented at the front, not the back.
Even within the "environmental responsibility" priority, the strategy’s wider priorities are evident: first “best practice in environmental management for energy projects”, then emissions reduction. Best practice in environmental management for energy projects seems, perhaps, a different thing from assessing whether a project should proceed at all. There seems a built-in assumption here that more of them will proceed.
For example, in the context of developing renewables, the government expects greater investment, to a target of 90 percent of generation capacity, “providing this does not affect security of supply”. It will support this by resource management reforms, and removal of other unnecessary regulatory barriers.
But there is no equivalent caveat about threats to conservation and the sustainable management of scarce environmental resources. There needs to be; security of supply is not the only imminent threat. We’ve seen a number of examples of Meridian Energy’s predilection for places of conservation importance; and under the Resource Management Act, it is already a nail-biting ride.
This could be the government’s opportunity to signal a preference for small scale and local renewables. The more local the better: more likely to be optimally efficient; less likely to be damaging.
The sectors and targets in the draft NZEECS are okay. We might quibble about whether the targets are truly "ambitious". And there’s an odd dissonance between what the draft NZEECS says and what the government has demonstrated it’s prepared to actually do.
It says, for example, minimum energy performance standards will only be used on selected products with relatively large energy savings potential. And yet, we all know about the light bulbs, which did have such potential. It talks up transport and vehicle efficiency, and green government procurement. Yet your party voted down a Green government vehicle procurement Bill, and scrapped work on vehicle fuel efficiency standards.
Of course, cost-effectiveness should be a factor. I'm just less sure that this is the factor, than ignorance and ideology.
And finally, both draft strategies need more about what the government will do, medium-term, to deliver them. You’ve pre-empted the criticism. “In many cases the draft suggests the Government will ‘support’ or ‘encourage’ other parties to make changes. How do you consider this support or encouragement is best provided?” you’ve asked.
Writing your strategy isn’t my job. I’m sure you’re as glad about that as I am. But there needs to be more than vague talk about “support” and “encouragement”; more specifics about the mix of information and incentives, and work programmes to develop them.
It is of course “the actions of all New Zealanders” that will realise the strategy. But it’s also the government’s role to offer leadership and support. Implicit in the fact that this is a strategy — not an election manifesto — and one that has taken a year to write, it should set out how.
You’ve small armies of officials whose job it is to develop specific strategies to give effect to government policy. I imagine the quandary they’re in is that the government doesn’t have much of a policy, beyond the talk of support and encouragement.
Much weight is placed in your draft on the flimsy shoulders of the ETS, to price carbon, and reduce emissions. Apparently, the ETS “will be the primary means to reduce emissions”. But as your colleague Nick Smith has recognised, it won’t — won’t reduce them much, that is. We need complementary measures: that’s why they’re called "complementary".