A case study of technical (energy) policy reform from outside government

Lessons from 1.5 years in energy consumer advocacy

Disclaimer: Views expressed are my own and do not represent Energy Consumers Australia.

This post has not been peer reviewed. I spent 11 hours on it and used AI heavily throughout the research and writing process. Most of the time was spent working on the spreadsheet and Guesstimate cost benefit analysis. You can see a copy of my initial Claude prompts here. If the topic is of interest, I can see myself revisiting this in the future and going deeper.

See the post on the Effective Altruism Forum to make or view any comments.

Who might this be relevant for?

  • People with technical backgrounds in regulated industries (energy, telecommunications, water, finance)
  • People interested in climate change as a cause area but who want to work outside traditional environmental advocacy
  • People looking for earning-to-give opportunities that also offer meaningful direct impact
  • Anyone considering how to have policy impact from outside government

Introduction

In mid-2024, I took a role as an Executive Manager of Advocacy and Policy at Energy Consumers Australia (ECA), the independent national advocate for residential and small business energy consumers in Australia. I recently left after 1.5 years.

This role was primarily about earning to give and career development (it’s for-purpose work, but didn’t seem anything like top recommended charity levels of impact) — specifically, leveraging my resources sector background to build expertise in energy policy given its relevance to data centres and therefore AI. But I also had opportunities for direct impact that I didn’t fully anticipate going in.

This post covers what I learned about a theory of change that may be impactful in other EA cause areas: technical policy reform through regulatory systems that are surprisingly accessible to outsiders. I’ll use a rule change request I wrote and lodged as a case study, attempt a rough impact estimate, and share lessons that might be useful for others considering similar work. You should skip over sections you’re not interested in.

What is Energy Consumers Australia?

Energy Consumers Australia is a small non-profit (~25 staff) funded through levies on energy consumers (~$1 AU per household per year). Its mandate is to advocate for the long-term interests of residential and small business energy consumers in Australia’s National Electricity Market.

ECA has a unique position: it has a “seat at the table” with key decision-makers, including the Energy and Climate Change Ministerial Council (state and federal climate change ministers), the Australian Energy Market Commission (AEMC), the Australian Energy Regulator (AER), and the Australian Energy Market Operator (AEMO). This gives its voice more weight than most advocacy organisations.

A quick primer on rule changes

Australia’s electricity system operates under the National Electricity Rules — a detailed regulatory framework that governs everything from how networks plan infrastructure to how wholesale energy markets operate. These rules have the force of law but are easier to change than legislation. Technically, they’re a form of “delegated legislation” — Australian Parliament has delegated rule-making authority to the AEMC, which can make and amend rules within the framework set by the National Electricity Law.

Any organisation or individual can lodge a rule change request, which the AEMC must consider and provide a formal response. With the right idea, analysis, and stakeholder engagement, a single organisation or person could theoretically change the rules.

This is unusual. In most policy domains, changing the rules requires either convincing legislators (hard), mobilising public pressure (slow), or working from inside government (limited access). The National Electricity Rules represent a relatively straightforward path to having impact that doesn’t exist in many other sectors.

Case study: The Integrated Distribution System Planning rule change

The problem (this is inside baseball, skip if you don’t want the detail)

Australia’s distribution planning rules date from an era when electricity flowed one way — from large power stations to passive consumers. The rules focus on annual maximum demand: ensuring there’s enough capacity to meet peak usage (usually, the hottest day of the year when air conditioners are working the hardest, and likely a cloudy day when rooftop solar is at its lowest output).

But the grid has changed dramatically. Over 4 million Australian households now have rooftop solar. Household batteries and electric vehicles are proliferating. The grid is no longer one-way; it’s a complex, bidirectional system where consumers are also producers.

The current Distribution Annual Planning Reports that networks must produce each year have several problems:

  1. Wrong focus: They’re centred on maximum demand, even though the grid is underutilised most of the year and increasingly constrained by minimum demand (when solar generation exceeds consumption).
  2. Poor visibility: Networks lack requirements to transparently share information about low-voltage network capacity, hosting capacity for solar, or where constraints exist.
  3. Misaligned planning horizons: Distribution planning uses a 5-year horizon, while the Integrated System Plan for transmission looks 20+ years ahead. An efficiently planned network should plan further in advance.

This results in inefficient investment decisions in EV chargers, mid-sized batteries and solar, underutilised consumer solar and batteries, and an inefficiently planned network resulting in consumers paying more than they should for network infrastructure.

This matters because distribution networks — the local poles and wires connecting homes and businesses to the grid — account for around 35% of household electricity bills. The total regulatory asset base of Australia’s electricity distribution networks is over $82 billion, which consumers effectively pay for. Getting the rules right for how this infrastructure is planned, built, and operated has enormous implications for consumer costs and for Australia’s ability to integrate the solar panels, batteries, and electric vehicles that are central to decarbonisation.

The intervention

I wrote a rule change request (supported by a team) proposing to replace the existing Distribution Annual Planning Report with an Integrated Distribution System Plan (IDSP). Key features included:

  • A longer planning horizon aligned with the national Integrated System Plan
  • Requirements for networks to publish hosting capacity maps and constraint information
  • Data sharing standards to improve visibility of the low-voltage network
  • Community and stakeholder engagement obligations
  • New utilisation metrics to track whether networks are using existing infrastructure efficiently

The process took about 4 months from initial concept to lodging in January 2025. This involved multiple rounds of collaboration with my colleagues at ECA, as well as extensive consultation with industry stakeholders including AEMO, AEMC, and AER.

Stakeholder engagement for subsequent phases — responding to consultation papers, meeting with stakeholders, and attending public forums — took ~2 additional months throughout 2025.

Reception and current status

The rule change received 30+ stakeholder submissions and substantial engagement. In October 2025, the AEMC published a directions paper with three policy options for consultation, all of which address most of the core problems identified in our proposal. The most important decision-maker, the AEMC, appears largely on board with the direction of reform.

I currently estimate 80% probability that the rule change is implemented in a form similar to the directions paper, given it’s late in the consultation process and we’ve heard from the decision maker. We’ll know for sure by around mid-2026.

Stakeholder engagement: Five principles

A rule change request is half technical analysis, half stakeholder engagement. These are five principles of stakeholder engagement that I think generalise beyond energy policy:

1. Map your stakeholders

Identify who has influence over the decision, who is affected by the outcome, and who can help or hinder your proposal. In our case, this meant networks, retailers, consumer groups, state governments, and the market bodies themselves.

2. Build your evidence base

Ask stakeholders what problems they face with current rules. Their stories strengthen your case. We spoke with community energy groups, installers, and aggregators who had direct experience with the inadequacies of current planning processes.

3. Test early and often

Get feedback on your proposal while drafting. Refine before you submit. We shared early versions with key stakeholders and incorporated their feedback, which both improved the proposal and built buy-in.

4. Understand the opposition

For those who disagree, ask: what would need to change for them to support you? Some networks were concerned about compliance costs. Understanding their constraints helped us design transitional arrangements. Some gave us ideas we hadn’t thought of.

5. Get out the vote

Supporters need to actually support. Many who would benefit from our rule change never made a submission. Formal submissions carry weight in regulatory processes, so actively encouraging supportive stakeholders to participate matters.

Attempting to measure impact

Why this is hard

Measuring the impact of policy advocacy is difficult (see Coefficient Giving’s write up on the challenges of evaluating policy work here):

  • Benefits can accrue over decades
  • Attribution is complex (would this have happened anyway?)
  • The counterfactual is unclear (I made a lot of judgement calls in this analysis)
  • Implementation details matter enormously, which advocates lose control of over time

I’ve tried to be transparent about the significant uncertainty while still attempting a rough estimate.

The internal costs of undertaking the work were relatively low (1.5 FTE for 6 months * overhead costs) so I’m hand waving them away.

A back of the envelope calculation for impact

I’ve created a spreadsheet version of this here. I also attempted a Guesstimate version here. Some numbers in Guesstimate are different because I’m more explicitly using a 90% confidence interval. I’m familiar with CBAs, but haven’t done one this complex myself before.

There are two primary sources of benefits and one primary source of costs I’m modelling here. The benefits of improved planning are enabling more benefits of distributed energy resources (DER — and therefore consumer savings) and reducing network costs (and therefore increasing consumer savings). The cost modelled is in the cost of compliance by networks (and therefore consumer costs).

Given the existing estimate for the benefits of DER was done through to 2040, 2026 to 2040 is the time period I’ve used for this analysis.

There would also be unquantified emissions reduction co-benefits from better integration/higher adoption of renewable energy resources (see Appendix A for how I would have done this if I had more information).

Enabling more benefits from DER

Several analyses have estimated the economic benefits of better integration of DER in Australia:

These figures represent cost savings (avoided network investment, reduced wholesale costs) which are ultimately consumer benefits given these costs are passed on. For this calculation, I’ll use the $10-19 billion range and attempt to estimate the fraction attributable to improved planning rules:

FactorEstimateRationale
Total potential benefits$11B-19B NPV by 2040Baringa/IEEFA
Fraction attributable to better planning rules1-5%Planning enables but doesn’t directly create savings
Probability of implementation80%Based on current progress
Value of 2-year acceleration~13.3% of totalWould likely have happened eventually (2 years / 15 years)
Benefits due to ECA$12M-101M$11B-$19B * 1-5% * 80% * 13.3%

Reduced network costs

Energy consumers (residential and business) pay for the cost of the distribution network through their energy bills. $23 billion of electricity was supplied to households by retailers in 2024-2025. ~35% of this was distribution costs. So household consumers paid $8.05 billion in distribution costs in 2024-2025.

FactorEstimateRationale
Reduction in costs due to better planning0.1% to 0.5%Best guess
Reduction in annual cost$8M to $40M
NPV over 2026-2040$84M-$417MAnnuity factor of 10.37 (see spreadsheet)
Reduction in costs due to ECA$9M to 45MMultiplied by probability of implementation and value of 2-year acceleration

Compliance costs

Complying with the requirements of this rule change has a non-zero cost for distribution networks, which is ultimately passed on to energy consumers. I’ll directly subtract these costs from the benefits.

I estimate approximately 1-2 additional full-time equivalent staff per distribution network service provider (DNSP), ($180-360k) plus modest IT and data costs (~$50k per DNSP), totalling roughly $3-5.3 million annually across the 13 DNSPs in the National Electricity Market.

Over 2026-2040, this represents ~$31-$55 million in NPV terms. Scaled by the probability of implementation (80%) and the value of acceleration of 13.33% (because I’ve assumed the costs would have eventually happened as well as the benefits), this gives ~$3.3-5.9 million in expected compliance costs. These costs are what seem most plausible given my experience, but I’m quite uncertain about them.

Combined estimate

CategoryLowerUpper
DER benefits$12M$101M
Network cost savings$9M$45M
Compliance costs-$6M-$3M
Net total$15M$143M

For my personal contribution (~25% attribution as primary author and project leader, with the rest to ECA colleagues and external collaborators):

  • Range: $4-$36 million in expected consumer savings

Note we should also assume that there’s a decent chance that the second-best candidate for the job would have done similarly as well.

Caveats

I want to be clear about what this calculation does and doesn’t show:

  • The actual impact depends heavily on implementation details still being determined
  • I may be motivated to overstate both my contribution and the total value of the project
  • The counterfactual is uncertain — industry had recognised the need for distribution-level planning and data reform for at least 5 years (for example)
  • I made some assumptions that I haven’t discussed, such as assuming that the benefits of the rule change are evenly distributed over 2026-2040 (they may be front-loaded, for example)
  • Be aware of survivorship bias — not all rule change requests are successful or even conclude fully in line with what was lodged
  • The upper end seems (surprisingly and suspiciously) high for ~6 months of focused work
  • This analysis also likely makes the precision seem higher than it is

I’m not sharing this as a confident impact claim but as an illustration of the potential leverage available through technical policy reform. It’s also an interesting exercise that I’d encourage others to explore for their own work — just don’t overcorrect based on a BOTEC.

Note also that these are benefits experienced by, in global terms, well-off Australians. $1 of benefits to an Australian is on average less valuable than $1 of benefits to someone in a developing nation, or even just more specifically targeted at Australians in hardship.

Discussion

Some of the numbers in this BOTEC are doing a lot of work without a lot of certainty. The fraction of DER benefits attributable to better planning rules (1-5%) seems safe based on my experience and intuition, but I have low confidence on it.

The probability of implementation being 80% implies that the political will already existed. It’s interesting to me that despite the need for the change being identified for at least 5 years, it did not seem like anyone else was going to start the process in the foreseeable future. This is tied to the next assumption — how much did our lodging of the rule change accelerate the process. AEMC can’t lodge their own rule change requests, but another stakeholder could have.

From my discussions with people in the sector longer than me, it does seem like this is just genuinely a reform that many people wanted but no one got around to prioritising. No one else was working on it, so we accelerated the reform by at least a year, and maybe much more. There is also likely some value in locking in a better version of this reform as a consumer advocate body, relative to perhaps if an industry interest group had lodged a similar rule change.

There is a challenge I’ve experienced in consumer advocacy where the costs of reform tend to be relatively known, while the benefits tend to be relatively unknown. Reform often creates benefits that were unexpected. We expect better planning and more availability of network data to have this potential, but it makes it more difficult to sell the story on a purely cost benefit analysis framework.

I stand behind the ‘qualitative cost benefit analysis’ we conducted as part of the rule change request (page 20 onwards of this), and for what it’s worth, the sector seemed broadly convinced. We didn’t attempt a quantitative cost benefit analysis when lodging the rule change request partly because even with more effort it would have been flimsy.

What surprised me: A different theory of change

Coming from animal advocacy, I expected impact to come through familiar channels: public campaigns, mobilising constituents, and convincing legislators. What I found in energy policy was different. Most of my impact came through relatively non-public, non-exciting work:

  • Rule change requests
  • Technical submissions to consultations
  • Advisory and working groups
  • Direct engagement with regulators

This isn’t because public pressure doesn’t matter in energy (climate change and cost of living have been top election issues here for years), but the specific architecture of Australia’s energy governance creates unusual opportunities for outsiders to have direct influence through technical channels.

The National Electricity Rules represent an opportunity for small, non-industry/non-government actors to create substantial change that doesn’t exist in many other sectors. Any organisation or even individual can lodge a rule change request which the Australian Energy Market Commission must consider. With the right idea, analysis, and stakeholder engagement, any one person could in theory change the rules and influence the Australian energy sector, but the power and influence that your organisation holds clearly matters a lot.

I looked for some statistics on how many rule change requests end up resulting in rule changes to get a sense of the success rate. 548 rule change requests have been initiated. It’s hard to say how many of them were successful without spending more time, because AEMC doesn’t publish statistics on this, and some of the requests get merged into others. Also, not all rule change requests survive the consultation process intact. It could end up being quite different to what was originally proposed. A little over half of rule changes that have been initiated have commenced (incorporated in the live rules). Overall, I’m reminded of a hits-based giving approach.

Why this might generalise

The broader lesson is: understanding the specific architecture of a policy domain matters enormously for theory of change.

Some questions worth asking about any policy area:

  • Are there formal mechanisms for outside input (like rule change requests)?
  • Who actually makes decisions, and what evidence do they rely on?
  • Is the domain more technocratic or more political?
  • Where are the leverage points that don’t require legislative change?

Regulatory systems vary widely in how accessible they are to outside influence. Some are essentially closed; others, like Australia’s energy rules, have built-in pathways for external proposals.

Is consumer advocacy neglected from an EA perspective?

Consumer advocacy generally is almost certainly not neglected from an EA perspective, in my view. Consumer protection, fair pricing, and market efficiency are important but not obviously underfunded relative to their importance.

However, consumer advocacy as a vehicle for other cause areas — especially climate change — might be underrated.

The consumer frame can align diverse stakeholders around reforms that also serve climate goals. When I argue that better distribution planning will reduce costs for households, I’m building a coalition that includes people who don’t necessarily prioritise climate but do care about electricity bills. The same reform that saves consumers money also enables faster, cheaper decarbonisation.

However, there are some situations where consumer advocacy may conflict with environmental goals. For example, transitioning away from coal to large and small-scale renewables happens to be cheaper for consumers, but what if it wasn’t? Switching to time-of-use pricing might help with grid decarbonisation, but it might increase bills for some.

Reflections and lessons

On the work itself

Understand institutional architecture before choosing interventions. I could have spent more time trying to influence energy policy through public campaigns. Instead, the rule change pathway offered a more direct route to systemic change.

Technical credibility matters. Rule change requests are evaluated on their merits. Having a PhD (even in an unrelated field) and developing genuine expertise in energy policy may have helped my proposals be taken seriously.

Relationships compound. The stakeholder engagement I did for this rule change built relationships ECA and I will carry into future work. Australian energy policy is a relatively small world; reputation and trust matter.

Patience is required. The rule change process takes 12-18+ months. The benefits, if they materialise at all, will accrue over decades.

On career

This role served multiple goals simultaneously:

  • Earning to give: Competitive salary in a mainstream policy role
  • Career capital: Developing expertise in energy policy and regulatory systems
  • Direct impact: Opportunities like this rule change

The combination feels compelling to me. Many EA career paths frame earning to give and direct impact as separate tracks. But roles in regulated industries can offer both — plus skills relevant to areas like AI governance.

Energy expertise and career capital specifically may become more valuable as AI scaling continues. Data centres are major electricity consumers, and questions about energy infrastructure, grid reliability, and sustainable power sources are increasingly relevant to AI development.

Conclusion

The key lessons I’d highlight:

  1. Technical policy reform from outside government can be a viable theory of change in certain regulatory contexts. Some regulatory systems are surprisingly accessible to outsiders with good ideas and stakeholder engagement skills.
  2. Understanding institutional architecture matters. The specific pathway to change varies enormously across policy domains. Invest in understanding how decisions actually get made.
  3. Stakeholder engagement is half the work. Technical quality is necessary but not sufficient. Building coalitions, understanding opposition, and ensuring supporters actually participate are equally important.
  4. Consumer advocacy can be a vehicle for other goals. Framing reforms around consumer benefit can build coalitions that advance climate and other objectives.
  5. Earning to give and direct impact aren’t mutually exclusive. Roles in regulated industries can offer both.

I’m grateful to my colleagues at ECA for the opportunity to do this work, and to the many external collaborators in the energy sector who engaged constructively with our proposals.

I’m happy to answer questions or discuss further in the comments, and also welcome feedback. I’m particularly interested to hear from people working in the policy space, and whether any of this does/doesn’t resonate. I can also write more deeply about what we specifically did during the project if it’s of interest and use to people.

For context on why I’m leaving ECA — a new opportunity came up that offers continued development as an energy policy expert, strong earning-to-give potential, and the chance to work directly on emissions reduction in Australia.


Appendix A: How to estimate the benefits of reducing emissions

Electricity generated from rooftop solar has a much lower carbon footprint than electricity generated from the grid (as a mix of coal, gas, wind, solar, hydro, and other), though this effect will decrease over time as wholesale generation decarbonises anyway.

The AEMC now formally values emissions reduction in its rule-making using the interim Value of Emissions Reduction (VER), as set out in their March 2025 guidance. The VER starts at $80/tonne CO2-e in 2026 and rises to $420/tonne by 2050 (in 2023 dollars). I could use this to estimate the benefits from this rule change in terms of emissions reduction by enabling more solar generation and battery storage (so solar energy can be used at more carbon intensive times like in the evenings).

I didn’t end up including this in the main analysis because I couldn’t get it to a point that I was comfortable with, but here’s how I would have done it. The main missing link is knowing how much CO2-e we’d expect to be reduced due to distribution-level DER and what percent of that could be attributed to better planning.

Better planning enables additional emissions reduction through:

  • Reduced curtailment: Rooftop solar output is being increasingly constrained due to minimum system load and voltage issues. Better visibility of the ability of the network to host DER enables more efficient siting and reduces wasted generation.
  • Faster deployment: Hosting capacity maps and clearer connection processes accelerate DER installation.
  • Optimised locations: Transparent constraint information enables community batteries and EV charging infrastructure to be placed where they deliver most value.

I estimate these improvements could increase DER effectiveness by 2-4% (actual analysis would be better, obviously), so I’d multiply the value by 0.02 – 0.04. I’d then multiply this by $80/tonne CO2-e (or maybe integrate it over time to reflect the decreasing emissions reduction value of rooftop solar over time), then multiply it by 80% (for probability of implementation from now) then by 13.33% (for the value of 2-year acceleration).

Note that in some cases the emissions reduction benefits could effectively be passed on to consumers negating the benefits for this analysis, but not necessarily, and not necessarily all of the benefits.

Thoughts about Yew-Kwang Ng

I really enjoyed this 80,000 Hours podcast interview with Yew-Kwang Ng. His views around utilitarianism and moral realism are very similar to mine. That is – suffering and wellbeing are the only two things that can intrinsically matter, everything else is instrumentally valuable as a means to achieving wellbeing or less suffering. He also is concerned about wild-animal suffering, which is how I first heard about him several years ago.

I did disagree with his views on how we can most effectively reduce farmed animal suffering. He believes that improving welfare standards would be better in the long run than reducing the number of animals farmed by various means. The best steelman for this would be that if we could get animals in farms net positive lives, then farming more animals would be good (utilitarianly speaking).

I find this view strange in the face of Kwang’s strong concern (strong even within the space of pro-climate policy, but in line with other existential risk researchers) of the risk of human extinction due to climate change. His view is that, even if extinction risk is very small, we must act far more than we are to reduce that risk. Given that the animal agriculture industry is such a major contributor to climate change (~15-50% depending on whether you arbitrarily use a 100 or 20 year timescale), why doesn’t he advocate for solving the farmed animal suffering problem and the climate change problem with the one solution? Surely this would be more efficient than improving farmed animal welfare and then working on energy policy separately? A strange oversight (in my opinion) in an otherwise enjoyable interview.

How can we best help animals?

I was part of a panel a few months ago called ‘How can we best help animals?’ in Sydney. We talked about effective animal advocacy and had speakers from three different perspectives – Kai McBeth on local grassroots advocacy, Alex Vince on non-profits, and Emma Hurst on political change for animals.

You can watch the recording here!

www.youtube.com/watch?v=38PUzCPd-V8

Weekly election campaign update #1

If you’re not yet aware, I will be running as a candidate in the 2019 New South Wales state election in the seat of Heffron.

I’ve decided to start recording regular weekly updates to keep my supporters (you!) up to date on what I’m getting up to. This video is the first for the week of 7 – 13 January.

Follow my candidate page on Facebook here.

Announcing my candidacy for the New South Wales 2019 election

I’ve decided to run in the New South Wales state election in 2019 in the electorate of Heffron for the Animal Justice Party.

Why? Like many people, I’ve become frustrated by the lack of attention and consideration our government has traditionally given to those without a vote – the animals, the environment, young people and future generations. I want to represent these groups, and to be a force for good in parliament.

If you agree with this, and the values of the Animal Justice Party of Kindness, Equality, Rationality and Non-violence, Vote 1 AJP at the New South Wales state election in 2019, and follow me on my journey by liking my candidate page. With your help, we can make a fairer, more just world a reality.

My main areas of interest are animal welfare, climate change and evidence-based policy, but they can be summarised by this – a better world for all.

Why people are still unlikely to act after IPCC warnings on climate change

The Intergovernmental Panel on Climate Change (IPCC) said last week that we have 12 years to limit climate change. I’m not a fan of such language (what does that even mean – if we cease emissions in 11 years we’ll be fine but if we do it in 13 years we all suffer?), but it’s certainly gotten a lot of attention. It has undoubtedly renewed the sense of urgency among those already concerned about climate change. Yet people don’t really seem to be doing anything different, besides getting angry at governments and companies on social media.

Just 100 companies responsible for 71% of global emissions

If you’re paying attention to the space, you likely will have seen something like this quote. I think it’s the worst thing to come out of this entire media cycle and may have actually increased emissions in expectation. Here is why:

For a short few days after the IPCC announcement, mainstream media was starting to talk about something that some of us have known for some time (ahem, the UN said it in 2006 but few cared) – one of the most impactful things you can do as an individual to limit greenhouse gas emissions is to not eat animal products (or eat less, as they worded it). Finally, this weirdly neglected topic was being taken seriously by the media and public (and who knows, maybe even governments at some point).

Then, the above quote began to circulate. This lead many people who don’t understand expected value and marginal individual impact to shift the blame entirely to these large companies, or to governments, or to capitalism. I predict this stopped a lot of people from actually taking effective action (e.g. avoiding animal products) and made them feel comfortable with just blaming others. I take serious issue with the use of the word ‘responsible’ in the quote. A more accurate word might be ‘take part in’.

Marginal impact is an important concept. It is all well and good to argue that companies and governments and the system should change, and that may well be true. However, we are individual actors, and when considering what we can do to maximise or even just increase our impact, we have to think about it in individual terms. What can I do that would have the biggest impact? One might argue that we could maximise our impact by working together, but we can just capture that under the above definition. For example: As an individual, by working with others I can maximise my impact. And the reality is – as an individual, probably the most impactful thing we can do to mitigate climate change is to just not buy animal products.

Let me pose a hypothetical. Suppose you discover that there is a product you buy which turns out to contribute to a lot of suffering. In fact, over the course of your life it turns out that purchasing this product will cause several thousand lives to suffer and be ended. Strictly speaking, the company providing these goods is ‘responsible’ (to use the above and incorrect definition of the word), but you have the choice to just buy an alternative product. In this scenario, you are equally responsible (maybe more so, since the company wouldn’t create the product without your demand). By not changing your purchasing habits, you are causing these deaths.

If you agreed with this hypothetical, then I’m afraid that in order to be logically consistent you should stop eating animal products. Thousands of animals suffer and die to feed an average person in a developed nation who eats animal products, but even if you discriminate against farmed non-humans due to their species, the environmental damage of animal agriculture remains – and I haven’t even touched on its role in global antibiotic resistance.

This is not to say that I don’t think governments and companies have a role to play as well, there are many things I’d love to see them do including government targets to reduce animal product consumption. But we can’t shirk the enormous opportunity and obligation we have to reduce suffering and environmental damage just because some other entity has a role to play.

As an additional note, if you are thinking to yourself right now I don’t eat many animal products anyway, here is something to consider. I’ve copied these tweets below because they are bloody brilliant and you need to see them (I hope Christopher will forgive me), but here is the link to the originals.

Insanity over plant-based food labeling in Australia

Here we go again…

Today, the Regional Services Minister Bridget McKenzie of the National Party willask a food regulation forum to back her bid to have Food Standards Australia New Zealand (FSANZ) review terminology and crack down on imitation and so-called fake foods“. Fake foods as opposed to, what, real foods?

Laws are taking hold in France and Missouri, USA, which restrict the use of labels such as ‘meat’ and ‘milk’ to describe plant-based foods, even when they are clearly labelled as plant-based. For example, no more ‘plant-based meat’ or ‘soy milk’.

I’ve written about this before, and I’m frustrated that I need to write about it again. Apparently Australian Federal Government ministers don’t read my blog, because if they did, they’d surely see how their argument doesn’t stand up to scrutiny. Let me go through a few key points in response.

[Senator McKenzie] said farmers feared their businesses were at risk because shoppers often did not realise they were buying plant-based products, rather than products from animals.

The products are very clearly labelled as plant-based. Below is a picture of the plant-based mince available in Australia that kicked up a fuss earlier in the year. For Senator McKenzie or farmers to suggest that a consumer might get confused and accidentally buy this instead of meat from an animal is an insult to their intelligence.

Senator McKenzie is also missing the point. People are buying these products not because they are confused, but because they are concerned about their health, the environment, and the suffering of innocent non-humans.

[Senator McKenzie] said as an increasing number of consumers were not eating animal products because of allergies or philosophical beliefs, “that’s their decision but we need to be careful [we] don’t confuse the marketplace and we still protect the reputation, hard earned by our clean, green farmers”.

Somewhere along the way we seem to have romanticised animal farmers – they can do no wrong. What exactly do you mean by clean and green, Senator McKenzie? Clean as in lack of disease and animal suffering? To dissuade you of this notion which I am sure you have zero risk of being biased in, please watch this recently released documentary which shows exactly how animals are being farmed in Australia.

Green, as in animal agriculture being one of the leading causes of anthropogenic global warming? This UN report is over a decade old but has gone largely unnoticed by governments and traditional environmental charities.

Federal National Party politicians have been vocal critics of plant-based protein products being labelled as mince.

This is the most ridiculous claim out of them all. The word ‘mince’ refers to the production process, not what the product is made from. To mince means ‘to cut up into very small pieces’. One can mince plants just as they can mince animal products. The fact that the National Party has been comfortable with the existence of fruit mince pies for years and have made no comment on them recently reveals their true motive.

Please sign the petition here to demand that such a law is never passed in Australia.

Would Australians starve if we stopped farming animals?

An objection to not farming non-human animals that is common in Australia is that most Australian farm animals are raised in pasture land or arid land that would otherwise not be suitable for growing crops. Therefore, if everyone in Australia was vegan, we would starve. Or something like that.

When people think of Australian farmed animals, they usually think of cattle, sheep and goats, which are more likely to be pasture raised (but not always). People rarely think about the chickens and pigs, which are much more commonly kept in factory farms and fed a diet of grain and other farmed plant food. Using the average from 1994-2016 from FAO, in Australia there are 27.4 million beef cattle, 95.3 million sheep, and 2.7 million goats. For animals mostly raised in factory farms and fed grain, there were 2.5 million pigs, 1.1 million turkeys, and 87 million chickens (although note 551 million chickens were slaughtered in 2012 – this dichotomy is due to their short lifespans). Once we examine the statistics, Australia doesn’t quite seem like the land of pasture farming anymore.

One might reasonably suppose that it is no mistake that the type of farmed animal Australians are most familiar with are cows and sheep. If Australians knew what happened in chicken/pig farms (even free range, which are usually as bad), and all slaughterhouses, they might not eat animals. The pasture raised animals are the ones we see in advertisements of struggling farmers, not the chickens stepping over the decaying bodies of their fellow species in ‘free range’ farms.

It takes many kg of plants to make 1 kg of animal flesh (often at a 7 to 1 or greater ratio). We should be able to assume that these plants could be consumed by humans as well, but even if that is not the case, if we didn’t grow whatever plant it was, we could grow crops for humans in their place. If we assume that most of the plants fed to non-humans in factory farms in Australia are sourced in Australia (I think this is reasonable), we should still have enough food to feed Australians even if we eliminated all animal farming in Australia. We wouldn’t even need to repurpose arid land to grow crops that are suited to those climates (e.g. almonds and hemp), although we may want to do this anyway.

To put this another way, we would have so much spare land for growing crops for people if we stopped farming chickens, pigs and turkeys that it would almost certainly make up for the lost ‘food’ from farming cows, sheep and goats, and then some.

Los Angeles banning fur is great, but why not leather too?

The city of Los Angeles has banned the sale of new fur products. This is a fantastic outcome – there is no justification for the harms caused to animals raised for their fur when so many perfectly fine alternatives exist. The state of California is relatively progressive on issues relating to animals (San Francisco also banned fur sales earlier in the year), but one must wonder how best to use this momentum to have fur banned in other cities in the US and globally.

I also wonder how this momentum might be used to gain traction on related issues, such as banning the sale of leather. I have always found it interesting that the wearing of fur has been so strongly disdained by the public for so long, while the wearing of leather is seen by most (besides probably just vegans) as being benign. I’m quite unsure why this is the case, both involve the killing of a non-human to turn their bodies into clothing.

The only meaningful perceived difference I can think of is that cows, the animal leather is most commonly taken from, are also exploited for their flesh and milk, while fur animals are generally not (although I doubt most people think about it this much). However, the production of leather isn’t really a by-product, according to the documentary Dominion. Leather production is an economic factor in its own right, and thus buying leather should be expected to result in more cows being farmed.

If you have celebrated the banning of the backward practice of selling animal fur as clothing, please also consider not buying animal skin for clothing. If you’re feeling really adventurous, you can even consider not engaging in the ultimate unnecessary use of animals – using their flesh and excretions for food.

Asteroids and comets as space weapons

A video version of this is available here.

Introduction

Approximately 66 million years ago, a 10 km sized body struck Earth, and was likely one of the main contributors to the extinction of many species at the time. Bodies the size of 5 km or larger impact Earth on average every 20 million years (one might say we are overdue for one, but then one wouldn’t understand statistics). Asteroids 1 km or larger impact Earth every 500,000 years on average. Smaller bodies which can still do considerable local damage occur much more frequently (10 m wide bodies impact Earth on average every 10 years). It seems reasonable to say that only the first category (>~5 km) pose an existential threat, however many others pose major catastrophic threats*.

Given the likelihood of an asteroid impact (I use the word asteroid instead of asteroid and/or comet from here for sake of brevity), some argue that further improving detection and deflection technology are critical. Matheny (2007) estimates that, even if asteroid extinction events are improbable, due to the loss of future human generations if one were to occur, asteroid detection/deflection research and development could save a human life-year for $2.50 (US). Asteroid impact mitigation is not thought to be the most pressing existential threat (e.g. artificial intelligence or global pandemics), and yet it already seems to have better return on investment than the best now-centric human charities (though not non-human charities – I am largely ignoring non-humans here for simplicity and sake of argument).

The purpose of this article is to explore a depressing cautionary note in the field of asteroid impact mitigation. As we improve our ability to detect and (especially) deflect asteroids with an Earth-intersecting orbit away from Earth, we also improve our ability to deflect asteroids without an Earth-intersecting orbit in to Earth. This idea was first explored by Steven Ostro and Carl Sagan, and I will summarise their argument below.

Asteroid deflection as a DURC

A dual use research of concern (DURC) refers to research in the life sciences that, while intended for public benefit, could also be repurposed to cause public harm. One prominent example is that of disease and contagion research (can improve disease control, but can also be used to spread disease more effectively, either accidentally or maliciously). I will argue here that DURC can and should be applicable to any technology that has a potential dual use such as this.

Ostro and Sagan (1998) proposed that asteroid impacts could act as a double edged explanation for the Fermi paradox (why don’t we see any evidence of extraterrestrial civilisations?). The argument goes as follows: Those species that don’t develop asteroid deflection technology eventually go extinct due to some large impact, while those that do eventually go extinct because they accidentally or maliciously deflect a large asteroid into their planet. This has since been termed the ‘deflection dilemma‘.

The question arises: does the likelihood of a large impact increase as asteroid deflection technology is developed, rather than decrease? The most pressing existential and catastrophic threats today seem to be those that were created by technology (artificial intelligence, nuclear weapons, global health pandemics, anthropogenic global warming) rather than natural events (asteroid impacts, supervolcanoes, gamma ray bursts). Humanity has survived for millions of years (depending on how you define humanity), yet in the last 70 years have seen the advent of nuclear weapons and other technology that could meaningfully cause a catastrophic at any time. It seems possible therefore that the bigger risk will be that caused by technology, not the natural risk.

Ostro and Sagan (1994) argue that development of asteroid deflection technology is at the time of writing (and presumably today) premature, given the track record of global politics.

Who would maliciously deflect an asteroid?

Ignoring accidental deflection, which might occur when an asteroid is moved to an Earth or Lunar orbit for research or mining purposes (see this now scrapped proposal to bring a small asteroid in to Lunar orbit), there are two categories of actors that might maliciously deflect such a body; state actors and terrorist groups.

A state actor might be incentivised to authorise an asteroid strike on an enemy or potential enemy in situations where they wouldn’t necessarily authorise a nuclear strike or conventional invasion. For example, let us consider an asteroid of around 20 m in diameter. Near Earth orbit asteroids of around this size are often only detected several hours or days before passing between Earth and the Moon. If a state actor is able to identify an asteroid that will pass near Earth in secret before the global community has, they can feasibly send a mission to alter its orbit to intersect with Earth in a way such that it would not be detected until it is much too late. Assuming the state actor did its job well enough, it would be impossible for anyone to lay blame on them, let alone even guess that it might have been caused by malicious intent.

An asteroid of this size would be expected to have enough energy to cause an explosion 30 times the strength of the nuclear bomb dropped over Hiroshima in WWII.

We can temper the likelihood of this scenario by speculating that it is unlikely for some state actor to covertly discover a new asteroid and track its orbit without any other actor discovering it, considering there are transparent organisations working on tracking them. However, is it possible that a government organisation (e.g. NASA) could be ordered to not share information about a new asteroid?

What to do about this problem

Even if we don’t directly develop asteroid deflection technology, as other technologies progress (e.g. launching payloads becomes cheaper, propulsion systems become more efficient), it will become easier over time anyway. Other space weapons, such as anti-satellite weapons (direct ascent kinetic kill projectiles or directed energy weapons), space stored nuclear weapons, and kinetic bombardment (rods from god) will all become easier with general improvements in relevant technology.

The question arises – even if a small group of people were to decide that developing asteroid deflection technology causes more harm than good, what can they meaningfully do about it? The idea that developing asteroid deflection technology is good is so entrenched in popular opinion that it seems like arguing for less or no spending in the area might be a bad idea. This seems like a similar situation to where AI safety researchers find themselves. Advocating for less funding and development of AI seems relatively intractable, so they instead work on solutions to make AI safer. Another similar example is that of pandemics research – it has obvious benefits in building resilience to natural pandemics, but may also enable a malicious or accidental outbreak of an engineered pathogen.

Final thoughts

I have not considered the possibility of altering the orbit of an extinction class body (~10 km diameter or greater) in to an Earth intersecting orbit. While the damage of this would obviously be much greater, even ignoring considerations about future generations that would be lost, it would be significantly harder to alter the orbit of such a body. Also, we believe we have discovered all of the bodies of this size in a near Earth orbit (Huebner et al 2009), and so it would be much harder to do this covertly and without risking retaliation (e.g. mutually assured destruction via nuclear weapons). The possibility of altering the orbit of such bodies should still be considered, as it poses an existential/catastrophic risk while smaller bodies do not.

I have also chosen to largely not focus on other types of space weapons (see this book for an overview of space weapons generally) for similar reasons – the potential for dual-use is less clear, thus in theory making it harder to set up such technologies in space. It would also be more difficult to make the utilisation of such weapons look like an accident.

Future work

A cost benefit analysis that examines the pros and cons of developing asteroid deflection technology in a rigorous and numerical way should be a high priority. Such an analysis would consider the expected value of damage of natural asteroid impacts in comparison with the increased risk from developing technology (and possibly examine the opportunity cost of what could otherwise be done with the R&D funding). An example of such an analysis exists in the space of global health pandemics research, which would be a good starting point. I believe it is unclear at this time whether the benefits outweigh the risks, or vice versa (though at this time I lean towards the risks outweighing the benefits – an unfortunate conclusion for a PhD candidate researching asteroid exploration and deflection to come to).

Research regarding the technical feasibility of deflecting an asteroid into a specific target (e.g. a city) should be examined, however this analysis comes with drawbacks (see section on information hazards).

We should also consider policy and international cooperation solutions that can be set in place today to reduce the likelihood of accidental and malicious asteroid deflection occurring.

Information hazard disclaimer

An information hazard is “a risk that arises from the dissemination or the potential dissemination of (true) information that may cause harm or enable some agent to cause harm.” Much of the research in to the risk side of DURCs could be considered an information hazard. For example, a paper that demonstrates how easy it might be to engineer and release an advanced pathogen with the intent of raising concern could make it easier for someone to do just that. It even seems plausible that publishing such a paper could cause more harm than good. Similar research into asteroids as a DURC would have the same issue (indeed, this post itself could be an information hazard).


* An ‘existential threat’ typically refers to an event that could kill either all human life, or all life in general. A ‘catastrophic threat’ refers to an event that would cause substantial damage and suffering, but wouldn’t be expected to kill all human life, which would eventually rebuild.