DOIA REQ 0026023 Response Letter.pdf

13 February 2026

Ref: DOIA-REQ-0026023

Hayden
Email: [FYI request #33481 email]

Tēnā koe Hayden

Thank you for your email of 10 January 2026 to the Ministry of Business, Innovation and Employment
(MBIE) requesting, under the Oﬃcial Information Act 1982 (the Act), the fol owing information:

1.  The net energy analysis for increasing electricity demand from 39.6 TWh to 71.7 TWh by 2050
(MBIE EDGS July 2024) while transitioning to 96.3% renewable and closing thermal baseload.
Specifically:
•  Energy return on energy invested (EROEI) for the transition
•  Embodied emissions in required infrastructure (wind, solar, transmission, storage)
•  Material throughput requirements (steel, copper, concrete, rare earths)
If no net energy analysis exists, confirm this and identify who approved the 81% demand
projection without one.

2.  The funding mechanism for "many tens of bil ions" in generation and network investment under
structural deficit (Treasury, continuous since 2019). Three options exist:
•  Electricity price increases (contradicts demand growth assumption)
•  Crown investment (contradicts deficit reduction)
•  Private capital (requires ROI assumptions—provide them)
If no integrated funding analysis exists, confirm this and identify who approved the targets
without one.

3.  The allocation framework when demand exceeds supply. Data centres, households, hospitals,
industry—who gets cut first? Provide the framework or confirm none exists. MBIE's projections
assume we build massive infrastructure without accounting for the energy cost of building it.
That's not planning—that's wishful accounting.

Question 1 – net energy analysis
MBIE is refusing this question under section 18(e) of the Act, as the information requested does not exist.

MBIE prepares an independent set of scenarios, cal ed the Electricity Demand and Generation Scenarios
(EDGS), that explore potential future electricity demand and required generation capacity. These are used
by the Commerce Commission to assess Transpower’s planning proposals for future capital investment in
the electricity transmission grid. As part of this, MBIE does not analyse the energy return on energy
invested (EROEI), embodied emissions in required infrastructure, or material throughput requirements

Question 2 – funding analysis
While MBIE does estimate projected costs based oﬀ the EDGS this is not an investment plan. Actual
costings, and the working out thereof, are made by those who make the investments, namely Transpower
and the private investors who build generation plants and infrastructure.

Question 3 – energy al ocation framework
MBIE is refusing this question under section 18(e) of the Act, as the information requested does not exist.

An allocation framework is not required as part of EDGS.

If you wish to discuss any aspect of your request or this response, or if you require any further assistance,
please contact [email address].

You have the right to seek an investigation and review by the Ombudsman of this decision. Information
about how to make a complaint is available at www.ombudsman.parliament.nz or freephone 0800 802
602.

Nāku noa, nā

Karlene Tipler
Head of Data Service Delivery
Data Service Delivery