Other Matters Raised in Submissions
Advocacy
Grey Power recommended an officially recognised and properly funded consumer advocacy organisation be established to ensure the interest of individuals and households and small business are properly considered.
Maori capacity for engagement was also limited and needs support. Suggest establishing a National Maori Forum to facilitate and coordinate strategic iwi engagement which would be the single point of coordination i.e. dispense with variety of mechanisms in use.
Partnership central/local government
Local Govt New Zealand, and many councils in there individual submissions, seek greater recognition of local government's role in implementation of the NZES. Identifying relationships between national goals and local authority roles will make the strategies more effective in practice and provide guidance for local government implementation, particularly as there are a number of areas within the NZES and NZEECS which are significantly controlled by local government. Consideration needs to be given to how this relationship between central agencies and local government might operate in practice.
Some councils noted that they have or are in the process of developing Sustainable Energy Strategies and regional energy strategies for their districts. These contain action plans for the local communities. Christchurch City Council, for example, notes that national energy strategies could succeed if they relate to and collaborate with local/regional strategies. The national strategy has failed to take the potential of local strategies into account.
Capability building & skills
Councils are looking for tangible support from Government in regard to implementation of energy issues, including support for training, direction, guidance and funding.
Other submitters noted skill shortages and lack of expertise in the area of energy efficiency services, in constructing new technologies, in the technical and engineering skill-base, in the building, architectural and engineering trades on solar and other energy efficient devices. Work needs to commence now to develop skills where shortages exist or are likely. Some suggested the strategy should explicitly support the growth of the technical/engineering skill base, perhaps by direct support to education and training providers.
On workforce issues it was also suggested that the Labour Department analyse and monitor the effects of the strategy on employment.
A tertiary institution recommended that Government consider the best way of fostering tertiary institution leadership in sustainability issues. Tertiary institutions can provide leadership on sustainability issues through:
- educational programmes and curricula
- research capabilities
- their own sustainability initiatives.
Role of Lines Companies
The Electricity Networks Association believe that the potential role of electricity networks in terms of security of supply, demand side response, the RMA, distributed generation and, critically, delivered energy prices has been overlooked in the NZES and broad government policy frameworks. They can reduce supply interruptions as part of the supply chain through efficient network operation, price signals to consumers, reducing consumption within a network area and reducing national generation needs. Line companies are specifically required to engage with the consumer on cost/reliability trade-offs and hold information on this, in contrast to retailers who are one step removed from the consumer. Lines companies through effective management of networks in real time can ensure dynamic adaptation to changing energy requirements e.g. electrification of Auckland rail.
Consultation process
Process to date
Views were mixed on the NZES consultation process to date. Some submitters were positive about consultation to date and request an ongoing dialogue and engagement as policy development progresses.
Many submitters were less positive about the process – there were too many discussion papers at one time (the five climate change documents), the consultation period was not long enough and considerable prior knowledge was required to tackle the information. The general public was alienated by these factors and a lack of information as to how they would be affected. Submitters commented the format of the NZES was intimidating for many. Another criticised the way the questions were phrased and noted that they did not identify problems involved in implementing various government policies or provide submitters with a way of adequately expressing views.
Maori seek a better process for the consultation and sufficient time to participate. They suggest it is prudent to have tangata whenua involved from start of the policy development process and also engaged in implementation. More Maori staff at a senior management level within agencies are needed as they tend to prioritise working with Maori, are more accessible, more responsive to the obstacles to Maori involvement and able to ensure that research with a Maori component is carried out. It was suggested a Maori endorsement protocol be introduced prior to any papers going to Ministers/Cabinet.
Others thought more industry engagement in policy making is required and the basis for policy recommendations should be more clearly set out. Further advice on regulatory options was needed including net benefit analysis and a regulatory impact assessment. Another complaint was that it is not clear from the strategy document how submissions are to be taken into account and how the detailed implementation of the strategy is to be agreed and finalised.
Structure of the energy and climate change discussion documents
Some submitters questioned the need for two documents – the NZES and NZEECS and suggested they be merged and the Energy Efficiency and Conservation Act be amended to enable the statutory process of developing a replacement NZEECS to apply to a final New Zealand Energy plan.
Suggestions for improvements to the final strategy included stronger language, more specific actions, a prioritisation schedule for the short, medium and long term, a summary table of what might be achieved and by when.
It was suggested Government should provide a summary document explaining the whole of Government approach to climate change and energy issues.
Some submitters viewed the integration of strategies for stationary and non-stationary energy as problematic. The issues for these sectors differ significantly with energy being sufficiently important for a strategy in its own right and transport issues covered by the New Zealand Transport Strategy or another document.
Another round of consultation
Absence of specifics and analysis and the significance of some of the decisions to industry and the economy as a whole prompted some to suggest there should be another round of consultation, particularly once the cost benefit analysis, assessment of trade-offs and the government's final preferred package have been agreed.
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