The fuel we consume for road transport should be accurately audited. This is of relevance in terms of revenue from excise tax on fuel. Data is useful to monitor revenue, trends, economic activity and, more importantly, to gauge the magnitude of contraband fuel, recently so much in the news.

Malta’s inland fuel consumption is either unavailable or, at best, inaccurate

Accurate data is of relevance to national emissions and pollutant inventory reporting to the European Environment Agency and to interpret traffic injury and fatality rates.

In references 38 and 39 of The Environment Report – Indicators 2010-2011, it is disturbing to read that “...Fuel stocks, which are carried forward from one year to another, are not deducted” and that “Data for gross inland consumption of energy is not currently available for Malta”.

This is further compounded by inconsistent quantifications of successive Enemalta yearly reports.

Malta’s inland fuel consumption is, therefore, either unavailable or, at best, inaccurate. The most accurate inland fuel consumption figures should be obtained from deliveries to (and, therefore, sales from) petrol stations.

Pollutant emission inventories are calculated from several factors. These include data inputs from fuel consumption, combustion method (power generation or road transport) and, in the case of road transport, classified vehicle fleets, fuel type and average mileage for each vehicle type.

This data, combined with ‘bulk emission factors’ for different pollutants and ‘fuel consumption factors’ for the different vehicle classes, give the figures making up emission inventories.

Pollutant and greenhouse gas emissions calculations are carried out by the planning authority’s environment section. A sample input data sheet (for 2006) used to calculate road vehicle emissions was provided.

Glaring deficiencies were noted. The number of road vehicles used was the total registered and not the number licensed for use on roads (the ones that can pollute). The division of goods carrying vehicles (HGVs) into light and heavy duty vehicles was made at 2,000kg gross weight and not 3,500kg used by convention. The average mileage for each vehicle class was overstated. More credible annual mileage was deduced after cross referencing the average mileage for each vehicle class indicated in the sample with the reported Enemalta fuel imports (averaged from a three-year period).

The Malta Planning and Environment Authority’s ‘assumptions’ gave incredibly low fuel consumption figures, indicating a highly overstated annual mileage. According to the Mepa data worksheet, passenger cars would have averaged 5.6 l/100kms (50 mpg) and heavy duty vehicles (HDV) 12 l/100kms (23 mpg). These are unrealistic fuel efficiencies.

The worksheet points out that a survey at VRT stations of odometers from buses and HDVs (which, in the Mepa classification, included goods vehicles over 2,000kg) revealed that most were either broken or tempered with. This should be seriously looked into. A functioning odometer should possibly be made a requisite for passing a VRT.

From available information, the approximate recent annual amounts of fuel sold (rounding off on the high side) at petrol stations were 85,000 tons of diesel and 70,000 tons of petrol. From Malta’s 2011 vehicle fleet data (National Statistics Office) and the Emissions Inventory Guide Book’s fuel consumption figures, the following data emerged as tabulated in Table 1.

These figures are not irrefutable but they are definitely credible. They also suggest that a total review of past emissions inventories must be undertaken as has been promised in the 2013 Informative Inventory Report for Malta. To do this, accurate fuel consumption data and vehicle fleet numbers must be sought. The latter have been available for the more recent years thanks to the work at NSO.

The computations shown in Table 1 also reveal the number of kilometres driven by each vehicle class. These are necessary to calculate particulate emissions from vehicle tyre and brake wear and road surface wear.

These two emission report data appeared for the first time in the 2010 and 2011 reports. In 2011, due weight was given for the first time in 12 years to the LDV share of particulate emissions, rising from 1.16 per cent of all road transport particulate emissions in previous reports to a 58 per cent share in the 2011 report.

Recent headlines indicated Malta has the safest roads in the EU while fatalities were almost halved from 2011 to 2012.

Malta being a small nation with small numbers involved, statistics tend to have greater variations. The reported low fatality of nine road users last year can only be considered a chance variation. The usual rate is about 16 fatalities annually and this has changed little over the span of 13 years.

We have become over-complacent at Malta’s road fatality rate when expressed as a function of population number. Ignoring the fluke nine fatalities from 2012, the fatality rate in Malta is 37 per million population.

The number of vehicle-kilometres travelled in Malta is lower than in larger European countries.

Another way of expressing the fatality rate is the number per billion vehicle-kilometres.

From the reasonably accurate conclusions shown in Table 1, the usual rate of 16 fatalities from 1.812 billion vehicle-kilometres is 8.83 fatalities/billion vehicle-kilometres (in 2012 it would have been 4.97 fatalities/billion vehicle-kilometres).

In Table 2, from a series of countries monitored by the International Traffic Safety Data and Analysis Group, Malta’s data is added to those from European countries plus the USA.

This shows that Malta has the fifth lowest traffic fatality rate when considered as a function of the nations’ (per million) population. On the other hand, when fatalities are considered per billion vehicle-kilometres, Malta is fourth highest of those countries where such data is available.

Though 8.8 fatalities per billion vehicle-kilometres is by no means very high, it is higher than the mean of 5.54 for the counties in the list were data is available.

So, let us not be too complacent. There is still work to be done to lower fatality rates.

It is important to ensure accurate fuel consumption data with implications to government revenue from fuel smuggling and income tax deductions by offering a benchmark in consumption.

It offers a chance of greater accuracy in reporting Malta’s emissions and realistically compares our road safety standardswith the rest of Europe.

Table 1

* Mepa derived figures
LDV: light duty vehicles. Petrol LDVs not calculated
HDV: heavy duty vehicles

TWV: two wheeled vehicles

Table 2

Road users killed: per million population and per billion vehicle-kilometres