Submission on Measures for Transition to an Expanded and Highly Renewable Electricity System

About this Submission

In November 2023, the Ministry of Business, Innovation & Employment (MBIE) sought consultation comments on Measures for Transition to an Expanded and Highly Renewable Electricity System.  This included responses to 63 questions raised by MBIE, under the following headings:

  • Growing renewable generation
  • Competitive Markets
  • Networks for the Future
  • Responsive Demand and Smarter Systems
  • Whole-of-system Considerations

Our opening comments are provided below.

Full responses to the submission questions can be read by clicking on the "Open in PDF Viewer" button above.


Growing Renewable Generation

ESR recommends commencing work on a vision of how New Zealand will look without fossil fuels and then to develop a pathway how to get there. This consultation
document assumes a great manufacturing effort over the next decades of power lines, power pylons, windmills, PV panels, electric cars, rail tracks and other
infrastructure. This will all be done predominantly by using fossil fuels with associated emissions. It will also be done on the backdrop of diminishing resources of raw
materials including crude oil. In terms of energy we are also dealing with a reduction of the ratio of Energy Returned On Energy Invested (EROI) while aiming to produce
new infrastructure and trying to maintain or replace existing infrastructure all built with fossil fuels at a high EROI ratio. It is very likely that globally and nationally the current underlying assumptions of resource availability and emissions future are overoptimistic, but the proposed workstream should clarify that.

We also recommend to face up to the reality that growth, even green growth, is associated with increased emissions, because economic growth and emissions are
not uncoupled. We should therefore consider an economy of “enough” or even well managed degrowth. This could lead to a demand side response of not engaging in
wasteful economic activities of overconsumption but still providing the necessities of life for everyone.


Meeting The Net-Zero Challenge
Submission to Draft Advice of Climate Change Commission on 2nd Emissions Reduction Plan