By that token the amount of energy for neural networks will be bound to some extent by the development of the biosphere and the creators of neural networks.
Not really? The point is that most artificial neural networks are started from basically zero (random noisy weights), where as a human neural network is jump-started with an overall neural structure that has been shaped by millions of years of evolution. Sure, it's not fair to compare the overall energy required to get there, but the point is just that a biological neural network starts with a huge headstart that is frequently forgotten when talking about efficiency.