There has for many years been interest in finding necessary conditions for dynamo action. These are usually expressed in terms of bounds on integrated properties of the flow. The bounds can clearly be improved when the flow structure can be taken into account. Recent research presents techniques for finding optimised dynamos (that is with the lowest dynamo threshold) subject to constraints, (e.g. with fixed mean square vorticity). It is natural to ask if such an optimum solution can exist when the mean square velocity is fixed. The aim of this note is to show that this is not the case and in fact that a steady or periodic dynamo can exist in a bounded conductor with an arbitrarily small value of the kinetic energy.