National Allocation Plan saga

It has been reported that Malta is among the 15 EU member states which missed the June 30 deadline for the submission of their second greenhouse gas National Allocation Plans. It is understood that, shortly, the EU may be taking legal action against these states, which are effectively rendering the successful implementation of Directive 2003/87/EC (the Emissions Trading Scheme Directive) no less than impossible.

Article 9 of this directive binds each EU state to prepare a National Allocation Plan (NAP) providing details about envisaged greenhouse gas emissions for a set period. Nevertheless, Malta's draft second NAP (NAP2) had already been published by MEPA in April. The plan covers the 2008-2012 timeframe, purposely coinciding with the Kyoto Protocol emissions reduction commitment period.

Malta and Cyprus currently enjoy a privileged status within the EU as far as greenhouse gas emissions reduction commitments are concerned. Although both are signatories to the Kyoto Protocol, these two EU member states are the only ones within the bloc which are not bound by any emissions reduction commitments whatsoever.

The other 23 are obliged to reduce their greenhouse gas emissions to some extent as detailed in Annex B of the protocol, the latter imposing an overall eight per cent reduction target compared to 1990 levels covering the entire EU bloc. These reductions obligations are expected to be fulfilled throughout 2008-2012.

Yet, Malta and Cyprus' special emissions status does not exonerate them from implementing Directive 2003/87/EC, including the periodic submission of NAPs. As an EU member state, Malta is expected to support all initiatives - particularly those enshrined within definite legal frameworks - intended to maximise the bloc's collective efforts directed to curb the negative impacts of climate change.

That Malta is not alone in failing to meet deadlines for the purposes of the Emissions Trading Scheme Directive should be no consolation whatsoever, given the ever-increasing regional and global concern with climate change issues. Perhaps it is not merely a case where Malta may not be taking climate change matters seriously enough, after all. Rather than being a question of transposing EU Directives, our already over-stretched human and financial resources may not be coping effectively enough as far as the successful implementation of these complex legislative tools is concerned. But perhaps, that is a purely administrative matter.

A more involving issue for Malta as far as climate change matters are concerned is the question of how long shall we keep on enjoying our relatively soft non-Annex B party commitments. Climate change analysts are already contemplating a significantly more stringent revised post-2012 Kyoto Protocol regime. As a consequence, countries such as Malta and Cyprus would easily have to deal with an emissions reduction commitments scenario with resultant socio-economic implications that cannot be underestimated.

A close look at Malta's draft NAP2 is quite revealing. Perhaps it is one of the first official documents providing an insight into Malta's way forward as far as power generation is concerned. In our case, only the Marsa and Delimara power stations fall within the parameters of Directive 2003/87/EC and hence their greenhouse gas emissions status needs to be regulated by a NAP.

Even before Malta's National Energy Policy Proposal or Enemalta's Electricity Generation Plan had been published, the draft NAP2 document already states that, by the end of 2012, a series of major power generation-linked projects may be underway. These include the establishment of a direct link with Sicily via an undersea cable or gas pipeline, the conversion of Malta's power plants to gas firing and also the construction of an energy-from-waste facility. The latter is meant to include both incineration (specifically mentioned in the draft NAP2) and the recovery of biogas or landfill gas for conversion to electrical power.

The implementation of any of these alternatives may already be a must for Malta, given the likely need to conform to a more stringent greenhouse gas emissions control regime even in the nearer future. Though maybe quite controversial in some aspects, energy-from-waste, for one, may very rapidly evolve into the most practical first-hand option not just in terms of using the significant calorific value of waste but also given Malta's overall waste management considerations; and this irrespective of all renewable energy considerations currently being scrutinised. Malta's ultimate answer to a more stringent greenhouse gas emissions reduction regime may however be dominated by conversion to more expensive gas-firing technology.

As expected, Malta's draft NAP2 has been formulated on the same guidelines as the previous NAP. The sufficiently strong correlation between electricity demand trends and both time and Malta's GDP was used to estimate carbon dioxide emissions projections throughout the 2008-2012 period, also taking into account, however, that Malta's realistic renewable energy source potential for 2010 may lie in the region of 1.37%.

The draft NAP2 reflects an expected power shift towards the Delimara plant, so that only 41.1% of the 11 million tonnes of Enemalta-allocated CO2 throughout the five-year period covered by the plan, are assigned to the Marsa Power Station, with the rest (i.e. circa 58.9%) allocated to Delimara. This is understandable given the age of the Marsa plant, which may warrant partial if not complete decommissioning in the very short term. However, according to Enemalta's Electricity Generation Plan, it may be more a case of replacing about 200 MW of Marsa power by the Malta-Sicily electric cable link. Clearly, such a scenario does not exonerate Malta from its greenhouse gas allocation commitments under Directive 2003/87/EC.

Malta's power generation industry now faces a major challenge. Whereas the need to modernise both the Marsa and Delimara plants has long been felt, this needs to be done in the context of the dynamic EU regulatory framework which invariably entails more stringent environmental standards. Greenhouse gas emission limits constitute only one aspect in this regard. Is Malta's recent transgression with respect to Directive 2003/87/EC just the tip of the iceberg? Despite recent successes in lowering SO2 emissions from our power plants, concern still exists about NOx and particulate emission levels, particularly in the context of a host of costly EU Directives to which Malta is expected to comply. How are we dealing with these?