The study by the Institute for Climate Change and Sustainable Development (ICCSD – ‘Cost of road transport in Malta’) has been taken aboard, lock, stock and barrel by Transport Malta. Some remarks on this study need to be made.

Fifty-two hours are lost annually while motorists are stuck in traffic. Equating time loss to lack of doing business by commercial vehicles is acceptable.

It is, however, groundless to quantify idle time as a cost regardless of what is in the guidance manual for cost benefit appraisal in Malta. Idle time waiting at bus stops could also be similarly considered.

Commercial vehicles lose the equivalent of €35.3 million because of congestion (45,000 x 52 hours x €15.07).

Loss of fuel due to idling. The study calculates a loss based on 2-litre engines. Seventy per cent of passenger cars are under 1.5 litres, 25 per cent have engines between 1500cc and 2000cc.

More realistically (petrol @ €1.44/litre and diesel @ €1.38/litre 70 per cent of passenger cars @ 0.9 litres/hour - €11.8 million; 30 per cent @ 1.2 litres/hour - €6.7 million; 29,000 light duty vehicles (LDVs) @ 2.4 litres per hour – €5 million; 16,000 heavy duty vehicles (HDVs) @ 3.8 litres per hour – €4.4 million. That is a total of €27.9 million.

With the loss of business put at €35.3 million, the revised congestion costs amount to €63.2 million, substantially below the authors’ €117.9 million.

With regard to health effects due to air pollution, the ICCSD study mentions the sum of €14.3 million.

The study uses the estimated average annual emissions by passenger cars and LDVs. It considered all commercial vehicles to be LDVs and ignores the pollutant contributions by different vehicle categories (petrol and diesel passenger cars, HDVs and LDVs).

It claims that the average annual mileage of all vehicles is 7,800 kilometres. This masks the higher mileage covered by commercial vehicles and, therefore, the share costs by different polluters.

There are significant differences between the derivations (in the tables) and those from the ICCSD study: NMVOC – study 162 tons vs 585 tons; NOx –1,100 tons vs 2,300 tons and PM2.5 – 65 tons vs 84 tons.

Using the study’s cost factors for the reviewed quantities, the total cost of pollutants is higher at €19.3 million. The cost share due to cars is €5.8 million while that due to commercial vehicles is €13.5 million.

The ICCSD study puts the cost of Co2 emissions at €46.8 million.

The study indicates that road transport in this country generates 533,000 tons of CO2. A total of 70,000 tons of petrol and 80,000 tons of diesel is consumed annually. A small portion of that is used in the maritime sector.

The bulk emission factor for CO2 in kg/kg fuel is 3.18 for petrol and 3.14 for diesel. The total amount of fuel used annually should generate 475,000 tons of CO2, that is, 302,000 from cars and 173,000 from commercial vehicles.The revised cost for climate change is €42.8 million, or €27.2 million from cars and €15.6 million from commercial vehicles.

The study does not attempt to equate the positive externalities of increased personal mobility with the positive effect on the economy

The cost (€83.9 million) quantification for accidents as described in the study is a complex affair. There are some aspects on the way costs have been calculated that need to be challenged.

The value of statistical life (VSL) is used to determine costs by applying its standards to fatalities, grievous and slight injuries. A fatality being quantified at €1.2 million is acceptable. However, the study’s quantification of the costs of serious and slight injury are based on unrealistic durations, one year for grievous and two months for slight injuries.

Grievous injuries would include rare prolonged cases, however, to ‘assume’ – as the study does – that all grievous injuries require a year of disability is unrealistic. Even injuries involving a slow-healing leg fracture requires at most 16 weeks to heal (classical plaster repair without internal fixation) and eight weeks rehabilitation. A realistic average duration for grievous injuries is six months.

Slight injuries require less than 30 days to resolve by definition. Giving two months for slight injuries is another erroneous assumption. Two weeks is a more realistic maximum average.

The revised costs should be €1.2 million for fatalities, €77,000 in the case of grievous injury and €3,000 if there are slight injuries.

The authors of the study took it upon themselves to determine the rate of injuries and accidents by only considering the period 2011 to 2013. This period showed a spike in the number of total accidents. The authors explain this spike to be due to “better injury reporting”.

This is a totally false assumption because the real cause is the closure of major roads during their rebuilding, which forced traffic into the rest of the roads.

The data considered should have included periods before 2011 and not just the last few years.

Given these several ‘assumptions’, the authors introduce bias into the study which inflates costs. The 1999 - 2012 averages out as: fatalities – 17, grievous – 253 and slight – 970 and, applying the revised costing, the costs would amount to €42.9 million not €71.8 million.

Human capital costs based on the revised costing would drop to €3.6 million from €11.2 million.

The revised total cost of road accidents is €46.5 million.

Commercial vehicles account for 10 per cent of injuries, excluding those caused by motorcycles and buses.

The study says noise costs €11 million.

Mepa uses computer models which give predicted noise levels from known traffic flows and vehicle categories on main roads. Does not the dB rating reflect all road transport in the computer model?

Let us accept the noise costings at €11 million. The effect of noise on health must surely be biased towards the more noisy larger vehicles, including buses, so a share of €4 million for cars and €7 million for all other vehicles is plausible.

The revised cost of road traffic is €183 million and not €274 million, as purported by the study.

The cost share due to passenger cars is €123 million and €60 million due to commercial vehicles. These costs are amply covered by the hefty taxes imposed in Malta on passenger cars.

The ICCSD study does not attempt to equate the positive externalities of increased personal mobility with the positive effect to the economy. This is like equating the costs on climate change from jet fuel in bringing 1.5 million tourists without considering the benefits to our economy. Climate change costs due to the tourism industry are €68 million annually when considering only jet fuel!

The following is based on 2007 data (updated in 2013) for standard vehicle fuel consumption and emissions (EEA – emissions guide book) and fuel imports in Malta:

  Consumption Fuel: g/km Annual mileage: kilometres Number of vehicles Fuel: tons Annual total kilometres Bulk emission factors (g/kg fuel)
            Nox NMVOC PM2.5
Petrol cars 70 5709 175,286 70,000 1,000,707,774 5.97 6.13 0.04
Diesel cars 60 5709 73,946 25,300 422,157,714 13.1 0.6 0.8
LDVs (diesel) 80 6834 29,000 15,800 198,186,000 15.3 1.44 1.1
HDVs (diesel) 250 9800 16,000 39,200 156,885,000 34 3 1.11

Total emissions in tons:

  NOx NMVOC PM2.5 Fuels
Petrol cars 417.9 429 2.8 70,000
Diesel cars 331.4 15.18 20.24 25,300
LDVs (diesel) 241.7 22.8 17.4 15,800
HDVs (diesel) 1333 117.6 43.5 39,200
Tons 2324 584.58 83.94  

Albert Bezzina is a medical practitioner with an interest in road traffic impact, safety and maintaining a perspective on its effects.

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