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MALTA’S NATIONAL AIR POLLUTION CONTROL PROGRAMME

MALTA’S NATIONAL AIR POLLUTION CONTROL PROGRAMME 2019 2019

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Bibliographical reference: Malta's National Air Pollution Control Programme - 2019 Environment & Resources Authority, Malta, 128pp.

First published 2020

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ISBN: 978-99957-1-753-7 (Paperback) 978-99957-1-754-4 (PDF) Malta’s National Air Pollution Control Programme - 2019 3

Contents

1 BACKGROUND...... 10 2 EXECUTIVE SUMMARY...... 11 3 POLICY PRIORITIES AND THEIR RELATIONSHIP WITH OTHER POLICY AREAS...... 13 3.1 Coherence In Inventories And Projections ...... 14 3.2 Coordination With Other Reporting Requirements...... 14 4 RESPONSIBILITIES ATTRIBUTED TO NATIONAL, REGIONAL AND LOCAL AUTHORITIES...... 15 5 PROGRESS MADE BY CURRENT POLICIES AND MEASURES IN REDUCING EMISSIONS AND IMPROVING AIR QUALITY...... 17 Power generation ...... 20 5.1 Shift To Ultra-Low Sulphur Fuel In Power Plants ...... 20 5.2 Reform In The Power Generation Sector ...... 21 5.3 Closure Of Marsa Power Station ...... 21 Transport ...... 23 5.4 The ban of leaded petrol...... 23 5.5 Public transport reform ...... 25 5.6 Vehicle tracking for Public Transport...... 26 5.7 Facilitate the development of a real time multi-modal journey planner...... 26 5.8 Increase roadside checks and road worthiness testing...... 26 5.9 The Kappara Junction ...... 27 5.10 Economic measures and incentives related to the road transport sector...... 27 5.10.1 The scrappage scheme...... 28 5.10.2 Gas conversion scheme...... 28 5.10.3 Grants and schemes to purchase new environmentally friendly vehicles and to encourage the use of two-wheeled vehicles...... 28 5.10.4 Incentives for the purchase of electric vehicles...... 29 5.10.5 Bike sharing schemes...... 29 5.10.6 Promoting multiple options not to travel during peak hours...... 30 Industry ...... 30 5.11 Environment Permitting Agriculture ...... 31 5.12 Fertiliser plan and application ...... 32 5.13 Manure storage facilities...... 33 5.14 Animal housing...... 33 5.15 Livestock feeding strategies...... 33 5.16 The Governance of Agricultural Bio-resources Agency...... 33 Energy Demand...... 34 5.17 Provision of professional advice to households...... 34 5.18 Replacement of Appliances in Vulnerable Households Scheme...... 34 4 Malta’s National Air Pollution Control Programme - 2019

5.19 Exploit all reasonable potential indigenous RES through PV technology deployment...... 35 5.20 Feed-in tariffs scheme (electricity generated from solar PV installation)...... 35 5.21 Competitive bidding process for PV systems equal or larger than 1MWp...... 35 5.22 PV grant schemes...... 35 5.23 Solar water heaters and collectors scheme...... 35 5.24 Biofuels Substitution Obligation (2011 – 2020)...... 35 5.25 Energy efficiency obligation...... 36 5.26 Financing schemes and fiscal incentives...... 36 5.27 Regulations and voluntary agreements...... 36 5.28 Public sector leading by example in the energy demand sector...... 36 6 DEGREE OF COMPLIANCE WITH NATIONAL AND UNION OBLIGATIONS...... 37 6.1 Degree of compliance with the emission reduction commitments as set in Annex II of the NEC Directive ...... 38

6.1.1 Nitrogen oxides (NOx) ...... 39 6.1.2 Non-methane volatile organic compounds (NMVOCs)...... 39

6.1.3 Sulphur oxides (SOx)...... 39

6.1.4 Ammonia (NH3)...... 41

6.1.5 Fine particulate matter (PM2.5)...... 41 6.2 Degree of compliance with Ambient Air Quality Legislation...... 42 7 PROJECTED FURTHER EVOLUTION ASSUMING NO CHANGE TO ALREADY ADOPTED POLICIES AND MEASURES ...... 43 7.1 Projections for the WM Scenario...... 44 8 POLICY OPTIONS CONSIDERED TO COMPLY WITH THE EMISSION REDUCTION COMMITMENTS FOR THE PERIOD BETWEEN 2020 AND 2029 AND FOR 2030 ONWARDS ...... 45 Transport...... 46 8.1 Free school transport ...... 46 8.2 Tallinja card incentives...... 46 8.2.1 Tallinja’s Capping System...... 47 8.2.2 IoScoot: An electric motorbike sharing service...... 47 8.2.3 Tallinja Ferry Service...... 47 8.2.4 TD Plus...... 47 8.3 Free Public Transport fares for youths, students and elderly persons...... 47 8.4 Develop and incentivise schemes to promote multiple occupancy...... 48 8.5 Review of Malta’s National Electro-mobility Action Plan (MNEAP)...... 48 8.6 Car sharing schemes...... 49 8.7 Study the introduction of Low Emission Zones...... 49 8.8 Develop a national bicycle strategy...... 50 8.9 Sustainable Urban Mobility Plan (SUMP) for Valletta...... 51 8.10 Last-mile delivery for Valletta...... 52 8.11 Smart parking system for Valletta ...... 52 8.12 Pilot cycling corridors...... 52 8.13 Develop a shore supply action plan for the TEN-T ports...... 53 8.14 Introduction of electric buses in Gozo...... 53 Malta’s National Air Pollution Control Programme - 2019 5

8.15 Infrastructure interventions...... 53 8.16 Public Transport Quality Corridors (PTQC)...... 54 8.17 Increase the use of Intelligent Transport Systems in traffic management...... 54 8.18 Improvement of Ferry Landing Places...... 54 8.19 Fast ferry link between Malta and Gozo...... 55 8.20 Initiatives related to electrification of the ...... fleet 55 8.20.1 Electric Vehicles (taxis and Government fleet)...... 55 8.21 Increase in financial grants for more efficient internal combustion engines (ICE)...... 55 8.22 Reform of Public Service Garages...... 55 Industry ...... 56 8.23 Environmental Authorisations Regulations ...... 56 8.24 A more sustainable construction industry...... 56 Agriculture ...... 57 8.25 The creation of sustainable alternative strategies related to livestock waste management including treatment of by-products...... 57 8.26 Amendment to S.L. 549.66 for the utilisation of spent mushroom substrate...... 57 8.27 Develop a Soil Action Plan ...... 57 Energy Demand...... 58 8.28 Projects in primary water network ...... 58 8.29 Biofuels Substitution Obligation (2021-2030)...... 58 8.30 Development of Research & Innovation Strategy for Energy and Water...... 58 8.31 Waste to Energy Facility ...... 59 8.32 Financial incentives to increase the use of Renewable ...... 59 Energy Sources and promote energy efficiency...... 59 8.32.1 Financial support schemes for Solar PVs...... 59 8.32.2 Solar Water Heaters Scheme...... 59 8.32.3 Energy efficiency: electricity tariffs...... 59 8.32.4 Support scheme for Services and Industry...... 60 8.32.5 Energy Efficient Street Lighting...... 60 9 STAKEHOLDER AND PUBLIC CONSULTATION...... 61 9.1 Stakeholder consultation...... 62 9.2 Public consultation ...... 62 10 POLICIES AND MEASURES SELECTED FOR ADOPTION IN THE ‘WAM’ SCENARIO...... 63 10.1 Assessment of road transport measures ...... 66 10.2 Projections for the WaM Scenario...... 68 11 ASSESSMENT OF HOW SELECTED POLICIES AND MEASURES ENSURE COHERENCE WITH PLANS AND PROGRAMMES SET UP IN OTHER RELEVANT POLICY AREAS ...... 69 Annex 1: 'WM' Scenario...... 73 Annex 2: 'WaM' Scenario...... 75 Annex 3: Public Consultation on Aims and Objectives - Submissions and Responses...... 81 Annex 4: Public Consultation on Draft NAPCP - Submissions and Responses...... 87 6 Malta’s National Air Pollution Control Programme - 2019

List of Figures

Figure 1 Siting of the real time monitoring network...... 18

Figure 2 Locations covered by the diffusion tube network for NO2 and VOCs...... 19

Figure 3 SO2 national annual average concentrations monitored using passive diffusion tubes...... 20

Figure 4 Time series of SOx and NOx emissions in kt and fuel burn in TJ from the public electricity and heat production sector (IIR, 2019)...... 21 Figure 5 Nitrogen Dioxide and Nickel concentrations in Kordin air monitoring station...... 22 3 Figure 6 SO2 Annual Mean Concentrations (µg/m ) 2014...... 22 3 Figure 7 SO2 Annual Mean Concentrations (µg/m ) 2017...... 23 Figure 8 Benzene concentrations monitored using passive diffusion tubes...... 24 Figure 9 Benzene concentrations in Malta in 2014...... 24 Figure 10 Benzene concentrations in Malta in 2017...... 25

Figure 11 Trends in NO2 and PM2.5 concentrations...... 26 Figure 12 Mode of transport in 2010 (NHTS, 2010)...... 28 Figure 13 Trend in the contribution of the agricultural sector to total ammonia emissions...... 31 Figure 14 Time series of national total emissions in kt...... 38

Figure 15 NOx Sources (2017)...... 39 Figure 16 NMVOC Sources (2017)...... 40

Figure 17 NOx Sources (2017)...... 40

Figure 18 NH3 Sources (2017)...... 41

Figure 19 PM2.5 Sources (2017)...... 41 Figure 20 The Malta agglomeration...... 42 Figure 21 Diurnal variation of CO concentrations during the Summer and Winter periods at Msida traffic site from 2014 to 2017 (Summer is June, July and August, while Winter is December, January and February)...... 46 Figure 22 Key congestion hub identified in the National Transport Model (TM, 2016)...... 49 Figure 23 Stock of licensed motor vehicles (NSO, 2019)...... 51 Figure 24 Possible Pilot Cycling Corridors to Valletta in red (TM, 2016)...... 52 Malta’s National Air Pollution Control Programme - 2019 7

List of Tables

Table 1 Overall percentage reduction of national total emissions...... 38 Table 2 Emission projections for NEC pollutants for 2020 and 2030 considering the "With Measures" scenario as compared to 2020 and 2030 ceilings of the NEC Directive...... 44 Table 3 Key Corridors to be developed into Public Transport Quality Corridors (TM, 2016)...... 54 Table 4 PAMs/Packages of PAMs selected for adoption in the 'WaM' Scenario...... 64 Table 5 Summary of analysis of costs and benefits for the Do-Something 1 and Do-Something 2 scenarios..67 Table 6 Emission projections for NEC pollutants for 2020 and 2030 considering the "With Additional Measures" scenario as compared to 2020 and 2030 ceilings of the NEC Directive...... 68 8 Malta’s National Air Pollution Control Programme - 2019

List of Abbreviations

AD Agriculture Directorate ARPA Agriculture and Rural Payments Agency BCR Benefit-Cost Ratio CO Carbon monoxide

CO2 Carbon dioxide CoGAP Code of Good Agricultural Practice DCD Diversification and Competitiveness Directorate DS Do-Something EEA European Environment Agency EIRR Economic Internal Rate of Return EMEP European Monitoring and Evaluation Programme ENPV Economic Net Present Value ERA Environment and Resources Authority EU European Union EWA Energy and Water Agency GAB Governance of Agricultural Bio-resources Agency GAINS The Greenhouse gas - Air pollution Interactions and Synergies model GHG Greenhouse Gases HFO Heavy Fuel Oil IED Industrial Emissions Directive ITS Intelligent Transport System kt kilotonnes LEZ Low Emission Zones LPG Liquefied Petroleum Gas LV Light vehicle MCP Medium Combustion Plant MEPA Malta Environment and Planning Authority MECP Ministry for the Environment, Climate Change and Planning MNEP Malta National Electro-mobility Platform MRA Malta Resources Authority MWth Megawatt thermal NAPCP National Air Pollution Control Programme NEC National Emission Ceilings NECP National Energy And Climate Plan NEEAP National Energy Efficiency Action Plan

NH3 Ammonia NMVOC Non-methane volatile organic compound

NO2 Nitrogen dioxide

NOX Nitrogen oxides NSO National Statistics Office

PM10 Particulate matter of less than 10µm aerodynamic diameter Malta’s National Air Pollution Control Programme - 2019 9

PM2.5 Particulate matter of less than 2.5µm aerodynamic diameter PT Public transport PTQC Public Transit Quality Corridors R&I Research and Innovation RES Renewable Energy Resources SL Subsidiary Legislation SME Small and Medium-sized Enterprises

SO2 Sulphur dioxide

SOX Sulphur oxides SOER State of the Environment Report SUMPs Sustainable Urban Mobility Plans TEN-T Trans-European Transport Networks TM Transport Malta VOC Volatile organic compounds WaM With Additional Measures WM With Measures 10 Malta’s National Air Pollution Control Programme - 2019

BACKGROUND

Directive (EU) 2016/2284 of the European Parliament and of the Council on the reduction of national emissions of certain atmospheric pollutants came into force on 14 December 2016. Malta, as a Member State of the European Union, is obliged to implement the provisions laid down in this Directive, and has therefore transposed the Directive into national legislation through S.L. 549.124.

The new National Emission Ceilings Directive, also referred to as the NEC Directive, is intended to guide Member States to further reduce air pollution and its associated risks to the environment and human health by establishing future anthropogenic emission every four years thereafter. The NAPCP supports reduction commitments for each Member State for the Member States in planning the national policies following pollutants: and measures with the aim of limiting the annual anthropogenic emissions of the five pollutants mentioned above, and which must reflect the • Nitrogen oxides (NOx); • Non-methane volatile organic compounds national emission reduction commitments for 2020 (NMVOC); and 2030. The NAPCP contributes in achieving air • Sulphur dioxide (SO ); quality objectives and ensures coherence with other 2 relevant plans and programmes including climate, • Ammonia (NH3); and • Fine particulate matter (PM ) emissions. energy, agriculture, industry and transport policy 2.5 areas. Synergies between the NAPCP and the National Pursuant to Article 6 of the NEC Directive, every Energy and Climate Plan (NECP) exist as they both rely, Member State must submit a National Air Pollution to a large extent, on the same measures and actions to Control Programme (NAPCP) by 1 April 2019 and reduce emissions.

01 Malta’s National Air Pollution Control Programme - 2019 11

EXECUTIVE SUMMARY

The NAPCP is the principal governance tool under Directive (EU) 2016/2284, supporting Member States to plan their national policies and measures with the aim of being compliant with the national emission reduction commitments, as laid down in Annex II of the same Directive for years 2020 and 2030.

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In order to complete the NAPCP, historical emissions The measures included in the “With Measures” (WM) inventory data, as reported in the re-submitted data of scenario consist of the use of cleaner fuels in the power 2019, were used to assess the progress made so far generation and transport sector, the public transport with the implementation of policies and measures to reform, sustainable mobility measures, roadside checks date. Ambient air quality data was also assessed in and roadworthiness testing, grants and schemes in the this respect. In addition, emission projections were road transport sector, energy efficiency grants and a produced for two policy scenarios for the years 2020 number of good practice measures in the agricultural and 2030: the “With Measures” or baseline scenario, sector. whereby emissions are projected based on adopted policies and measures as of end 2017, and the “With The measures included in the “With additional Additional Measures” scenario, which reflects new Measures” (WaM) scenario build on the WMs scenario, policies and measures planned to be implemented in with additional measures mostly focused on road future years. transport. These include free school transport, the study related to the introduction of a low emission zone These emission projections were largely developed in the hub, additional sustainable mobility measures, using the same models and activity drivers used by the electric buses in Gozo, road infrastructure measures, Energy and Water Agency (EWA) for the development public transport quality corridors and the improvement of Malta's draft NECP. This ensured synergies between of ferry landing places. The WaM scenario also includes the plans since they rely, to a large extent, on similar measures in other sectors such as a permitting regime measures and actions. In addition, expert assistance for emission sources not yet regulated by EU legislation, was also provided through the capacity-building project and a number of measures to control ammonia on emission projections, funded by the European emissions from agriculture. Commission. This capacity-building project specifically provided support in developing emission projections Notwithstanding the above mentioned measures, for the road transport and national navigation sectors. projected data for the WaM scenario shows that more effort needs to be employed for Malta to be able to

The power generation sector was one of the major reach its NOx ceiling for 2030. contributors to atmospheric emissions in Malta. Initially, Malta was dependent on heavy fuel oil (HFO) to generate electricity. The sulphur content of the fuel was gradually reduced, and eventually both power stations shifted to ultra-low sulphur fuels. In 2017, Malta shifted to natural gas to generate electricity, and closed the

Marsa Power Station. A decrease in SO2 annual mean concentrations in ambient air was observed between

2014 and 2017, and SOx total national emissions have decreased by about 94.7% between 2005 and 2017. Moreover, sourcing of electricity through the sub- marine interconnector also contributed to the decrease in emissions from power generation.

Although NOx emissions from power generation have decreased by 91% between 2005 and 2017, NOx emissions from the road transport sector have not reduced. While there are several sustainable measures Emission projections for SO2 and PM2.5 demonstrate that are being implemented in the road transport compliance with 2020 and 2030 ceilings, while emission sector, this effort is masked by the daily increase in projections for NH3 demonstrate compliance with 2020 newly registered vehicles on the road, making this ceiling, but not with 2030 ceiling. Emission projections sector a major contributor to NOx emissions. for NMVOC result in a non-compliance with the 2020 ceiling. A plausible reason for the non-compliance with The NAPCP also outlines a number of measures which the NMVOC 2020 ceiling is that emission calculations are planned to be implemented with the aim to reduce for the sector related to ‘Domestic Solvent Use emissions of NEC pollutants by 2020 and 2030. These including Fungicides’ are estimated using a very basic measures were selected following a thorough review methodology, possibly leading to an overestimation of of related national plans, programmes and strategies NMVOC emissions, including projections. Therefore, which can affect the NEC Directive, and following projections for this sector are subject to further studies consultations with all relevant stakeholders. and verification.

Malta’s National Air Pollution Control Programme - 2019 13

POLICY PRIORITIES AND THEIR RELATIONSHIP WITH OTHER POLICY AREAS

03 14 Malta’s National Air Pollution Control Programme - 2019

3.1 COHERENCE IN INVENTORIES models and activity drivers sourced from the Energy AND PROJECTIONS and Water Agency (EWA). Bilateral consultations were carried out with stakeholders that are currently Pursuant to Article 8 of the NEC Directive, every implementing measures which are likely conducive to Member State must report annually a national emissions emission reduction. The measures that are currently inventory for air pollutants, and must prepare national being implemented are selected for the “WM” scenario emission projections every two years. The national of this programme. Measures included under this emissions inventory and projections are prepared scenario are measures adopted and implemented as through various consultations with the relevant of end 2017. The “With additional Measures (WaM)” authorities. scenario features planned policies and measures post 2017, and represents Malta’s projected achievement The inventories and projections are the basis on which once planned policies and measures are implemented. such programmes are developed. This programme uses the historical emissions inventory data as reported in Further consultations were carried out with the relevant the re-submitted data of 2019. The emission projections stakeholders in order to discuss the measures that will used for this programme were reported in 2019. In the likely lead in achieving compliance with the national previous round of reporting of the emissions inventory, emission reduction commitments as set out in Annex II ERA recalculated the data for years 2005 to 2017, using of the NEC Directive. the latest guidebook, the ‘EMEP/EEA Air Pollutant Emission Inventory Guidebook 2016’ (EEA, 2016). Data sources and activity data used to calculate emissions 3.2 COORDINATION WITH OTHER for the inventory are consistent with those developed REPORTING REQUIREMENTS in related policy areas. Given that a strong synergy exists between the NAPCP and the NECP, the ERA worked in close cooperation with the EWA, the national entity entrusted with the reporting of the NECP. The aim of the NECP is to set climate and energy objectives, targets, policies and measures to ensure that the Union’s 2030 targets for greenhouse gas emission reductions, renewable energy, energy efficiency and electricity interconnection are met1. The main difference between the NAPCP and the NECP is that these programmes target different pollutants. The NAPCP deals with atmospheric pollutants while the NECP’s main focus is climate action.

In the past round of reporting emission projections, ERA used the GAINS model. In the light of the need to ensure coherence with reporting under other obligations, ERA made use of the same assumptions and activity drivers used for the first draft submission of the NECP, as a basis to generate emission projections for most of the sectors. Updates in activity data performed by the Energy and The activity data used to prepare the emissions Water Agency as a basis for the updated version of the inventory is acquired from the relevant authorities of NECP could not be considered in time for the reporting the inventory sector concerned; for example, Enemalta of this NAPCP, however the relevant updates will be provides activity data required to estimate emissions carried out by the next reporting rounds. In addition, produced by public electricity. Other major data following the opportunity available through a capacity providers are Transport Malta (TM), National Statistics building project (as described in Section 2), ERA Office (NSO), Malta Resources Authority (MRA), the considered this project to be an excellent opportunity Agriculture Directorate (AD) and the Regulator for to improve its emission projections on a sectoral level, Energy and Water Services (REWS). through the technical assistance of the relevant experts. This project provided support specifically in the national The same activity data was used to develop emission navigation and road transport sectors. projections for years 2020, 2025 and 2030, based on

1 https://ec.europa.eu/energy/en/topics/energy-strategy-and-energy-union/governance-energy-union/national-energy-climate-plans Malta’s National Air Pollution Control Programme - 2019 15

RESPONSIBILITIES ATTRIBUTED TO NATIONAL, REGIONAL AND LOCAL AUTHORITIES

The ERA is the national competent authority that takes the overall responsibility for the drafting of the NAPCP, in consultation with the relevant stakeholders. In terms of air quality, the ERA has the following responsibilities:

• The elaboration of and reporting of the NAPCP; • The air emissions legislation; • The ambient air quality legislation, which includes the assessment, monitoring, reporting on air quality and air pollution impacts, together with the reporting of the emissions inventory and projections; • Regulates the environmental impact of the industrial sector through permitting systems; • Enforces compliance with legislation; • Regulates emissions from the industrial sector.

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ERA falls under the responsibility of the Ministry for the in culture of the public’s perception on mobility and Environment, Climate Change and Planning (MECP). transportation in general. TM reports to the Ministry for Transport, Infrastructure and Capital Projects. Climate change policy falls under the responsibility of the MECP. The Malta Resources Authority (MRA) Since the NAPCP needs to include measures that are is designated as the national inventory agency for also reducing atmospheric pollutants resulting from the elaboration of annual national inventories of the agricultural sector, discussions were held with the greenhouse gas emissions and removals. The Energy Agriculture Directorate (AD), the Diversification and and Water Agency (EWA), within the portfolio of the Competitiveness Directorate (DCD), the Agriculture Ministry for Energy and Water Management (MEW) and Rural Payments Agency (ARPA) and the Governance is responsible for the preparation of National Energy of Agricultural Bio-resources Agency (GAB), to identify and Climate Plans pursuant to the Energy Union which measures have been implemented so far and Governance Regulation, under the auspices of an that are likely to reduce relevant pollutants (mainly Inter-Ministerial Steering Committee. In this context, ammonia). The ARPA manages a Cross-Compliance the EWA is also responsible for preparing projections Framework whereby farmers who are provided for the energy sector, which are then converted to with subsidies are expected to implement a series of greenhouse gas emissions. The MRA is responsible sustainable actions. The Cross-Compliance Framework for preparing projections of greenhouse gas emissions brings together obligations arising from a number (and removals) for Industrial Processes, Agriculture, of Directives, which are enforced by the relevant Land Use, Land-use Change and Forestry, and Waste. competent authorities. The measures identified are As already mentioned earlier, there is a close synergy considered in the baseline scenario (“WM” scenario). between inventories and projections for GHG’s and for air pollutants, including in respect of activities for which emission estimations and projections are required. Therefore, ERA collaborates closely with MRA and EWA, so as to maximise and ensure coherence between reporting obligations.

Responsibility for sector-specific policy-making and policy implementation lies largely within the Ministries and government bodies responsible for the respective sectors.

Transport Malta (TM) is the authority responsible for the promotion and development of the transport sector in Malta, by means of proper regulation. TM aims to achieve modal shifts and improve the public transport system, amongst other objectives. Since the road transport sector is the most important key source category for NOx emissions in Malta, as clearly illustrated in Figure 15, most of the measures included The Diversification and Competitiveness Directorate in the NAPCP focus on the road transport. To this effect, (DCD) was also consulted on the agricultural measures the measures included in the National Transport Master included in the NAPCP. Farmers are shifting from Plan for 2025 were given due importance with a view to traditional trends that are no longer relevant, and are gauge the extent to which these measures will result in seeking new opportunities. The DCD encourages emission reduction. This Master Plan is a planning and farmers to diversify their products and find alternative implementation document, with measures in the short ways to improve their income2. to medium term duration. It aims to achieve the goals set by the National Transport Strategy, which creates the A number of measures arising from the National strategic framework by 2050. Furthermore, measures Agricultural Policy for the Maltese Islands (NAP) from the Malta National Electro-Mobility Action Plan (2018-2028), prepared by the AD, could potentially (MNEAP) were also given due importance since the plan reduce ammonia emissions and have therefore been includes a number of measures targeting sustainable considered in the “WaM” scenario. The AD, the DCD, mobility. The MNEAP also seeks to promote a change the GAB and the ARPA report to the MECP.

2 https://agriculturecms.gov.mt/en/agric/Pages/DCD/dcd.aspx Malta’s National Air Pollution Control Programme - 2019 17

PROGRESS MADE BY CURRENT POLICIES AND MEASURES IN REDUCING EMISSIONS AND IMPROVING AIR QUALITY

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This Chapter outlines a list of policies and measures Gozo. In addition, work is ongoing to install a fixed already implemented, and which were aimed to reduce monitoring station in the North of Malta, to act as a emissions. Using ambient air quality and emissions data, traffic site in the zone. The aim of this additional site the reductions in ambient concentrations and national is to better understand the effect of traffic outside the emissions of related air pollutants are documented. agglomeration. The stations cover all pollutants that require monitoring and reporting under the Ambient The ERA currently operates a fixed station network Air Quality Directive (2008/50/EC). composed of four real-time air-monitoring stations: a traffic site in Msida, two urban background sites in Żejtun and Attard and a rural background site in Għarb,

Figure 1: Siting of the real time monitoring network Malta’s National Air Pollution Control Programme - 2019 19

Real time monitoring is also complemented by a Passive targeted at emissions reduction have been implemented Diffusion Tube network, which consists of 100 sites for in the past and recent years.

VOCs and NO2, and a smaller network for SO2 (SOER, 2018). The energy sector is one of the major contributors to atmospheric emissions in the Maltese Islands,

In addition, the ERA annually compiles an emissions contributing mostly tox NO , SO2, NMVOC and PM2.5 inventory as required by the NEC Directive and in emissions. The energy sector includes public electricity, accordance with the EMEP reporting guidelines and heat production, fuel combustion activities in industries Guidebook, as described in Chapter 3.1. and construction, transport and small-scale combustion. On the other hand, the agricultural sector contributes

As a result of the monitoring and inventorying of to NH3 emissions. concentrations and emissions of pollutants respectively around the Maltese Islands, the sources and sectors where attention is required are identified and measures

Figure 2: Locations covered by the diffusion tube network for NO2 and VOCs 20 Malta’s National Air Pollution Control Programme - 2019

POWER GENERATION content of 3.5%, while 12% of electricity was generated by gas turbines (in open and combined cycle modes), 5.1 SHIFT TO ULTRA-LOW SULPHUR operated on gas oil (MEPA, 2006). However, the two FUEL IN POWER PLANTS power stations were not equipped with technologies (e.g. flue gas desulphurisation equipment) that reduced

SO2 emissions from their chimneys (EPD, 2002). In Sulphur dioxide (SO2) derives from the combustion of fossil fuels containing sulphur and is a major air 2004, both power stations switched to low sulphur pollutant. When the fuels containing sulphur are burned fuels, with a sulphur content of 1%. As a result, a drastic reduction in SO concentrations was observed (MEPA, (the sources of this pollutant being mainly the power 2 generation and transport sectors), sulphur oxidises and 2006), especially downwind of the Marsa Power Station, at Luqa, Fgura, Żejtun, Gudja and Birżebbuġa (SOER, forms sulphur dioxide (SO2). SO2 is highly water soluble, and once it dissolves in rainwater, it becomes sulphuric 2005). Throughout the years, the sulphur-containing acid, which produces acid rain (SOER, 2005). Acid rain fuels have been further refined to contain even less damages the natural and the built environment as it sulphur. Both the local air-monitoring network (Figure corrodes limestone buildings, damages vegetation 3) and the NEC emission inventory (Figure 14) saw a considerable reduction in SO2 levels. and distresses aquatic ecosystems. Additionally, SO2 can cause several health problems when inhaled, such as aggravated asthma attacks, respiratory problems Figure 3 shows data for the annual national average concentrations of SO2, sourced from the passive and irritation to the respiratory tract. SO2 can also contribute to the formation of secondary pollutants diffusion tube network (2000-2017). An annual average such as particulate matter. Once particulate matter decrease of 0.92 µg/m³, ranging from 1.6 to 0.54 µg/m³ is inhaled, it can penetrate through the respiratory per year, can be noticed. This can be attributed to the switch to low sulphur fuel in both power stations and to system especially the ultra-fine particles (PM2.5), which can cause respiratory problems such as asthma, the reform in the power generation sector (as explained cardiovascular diseases and lung cancer (WHO, 2018). in Section 5.2). The annual average concentrations of SO2 remained well below the level for the protection of 3 In the past years, Malta has relied completely on vegetation (20 µg/m ) as from 2004. heavy fuel oil to generate electricity from the Marsa and Delimara Power Stations, operated by Enemalta Corporation. In 2004, about 88% of electricity in Malta was generated using heavy fuel oil having a sulphur

Figure 3: SO2 national annual average concentrations monitored using passive diffusion tubes Malta’s National Air Pollution Control Programme - 2019 21

5.2 REFORM IN THE POWER generation sector have contributed to such decrease in GENERATION SECTOR emissions.

Following a major reform of the energy system brought Nowadays, SO2 concentrations have reduced and are up by a government policy, Malta implemented the no longer a concern to the Maltese Islands. As a result, following measures in the power generation sector: the number of passive diffusion tubes monitoring SO2 was scaled down to 24 sites. • Sourcing of electricity through the sub-marine interconnector. The project comprised the laying and operation of a 95km long, 200MW sub-marine 5.3 CLOSURE OF MARSA interconnector cable between Malta and Sicily POWER STATION connecting Malta to the European-electricity network (OPM, Energy and Projects, 2017). In 2005, a monitoring station was installed in an • Closure of the Marsa Power Station in March 2015. industrial area in Kordin, downwind of the Marsa • Decommissioning of the old generating units at the power station to monitor the effect of the power Delimara Power Station. The recently added plant plant on the agglomeration. In March 2015, the Marsa in the Delimara Power Station was converted to Power Station, which used to operate on HFO was run on natural gas instead of heavy fuel oil. decommissioned, except for one generating unit which • As from 2017, Malta shifted to natural gas to operates on a stand-by basis. Figure 5 shows the

generate electricity nationwide. This change has trends in concentrations of NO2 and Nickel in PM10 led to improved air quality and reduction in power over a period of 10 years. The trends show a general generation costs. decrease which continues post closure of the power

plant. Other heavy metals were analysed in PM10, and As from 2015, the local fuel consumption decreased with the data is available however their concentration is the commissioning of the Malta-Sicily interconnector, very low and no conclusions can be reached from such with a simultaneous increase in electricity demand. data. Moreover, the heavy metal which is present in the This shift in fuel use has already shown a decrease in highest concentration in HFO is Nickel, therefore it is emissions from the power generation sector as from ideal to use this metal as an indicator of combustion of 2015. HFO.

Figure 4 shows the NOx and SOx emissions in kilotonnes Due to the closure of the Marsa Power Station, SO2 (kt) from the power stations and fuel combusted in TJ annual mean concentrations have decreased downwind from the public electricity and heat production sector. It of the power station from year 2014 to 2017 (Figures 6 is evident that emissions decreased substantially since and 7 below). SO2 concentrations in 2014 range from 3 2009, and this can be attributed to a number of efforts 4.5 to 6.0µg/m , while in 2017 SO2 concentrations range implemented in the history of the electricity generation from 3.0 to 4.5µg/m3. sector. Amongst such efforts, the decommissioning of both power stations and the reform in the power

Trends in NOx, SOx emissions (kt) & Fuel Combusted in TJ

Trends in NOx, SOx emissions (kt) & Fuel Combusted in TJ 2.00E+01 8.00E+06

1.80E+01 7.00E+06

1.60E+01 6.00E+06 1.40E+01

5.00E+06 1.20E+01

1.00E+01 4.00E+06

Emissions in kt in Emissions 8.00E+00 3.00E+06 Fue l combusted

6.00E+00 2.00E+06 4.00E+00

1.00E+06 2.00E+00

0.00E+00 0.00E+00 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 Axis Title

NOx SOx Fuel combusted in TJ

Figure 4: Time series of SOx and NOx emissions in kt and fuel burn in TJ from the public electricity and heat production sector (IIR, 2019) 22 Malta’s National Air Pollution Control Programme - 2019

Annual NO2 and Nickel concentrations (µg/m³) Annual NO₂ and Nickel concentrations (µg/m³) 35 0.021

30 0.018

25 0.015

20 0.012 NO₂

15 0.009 Nickel

10 0.006

5 0.003

0 0 2006 2007 2008 2009 2010 2012 2013 2014 2015 2016 2011

NO2 - KOR Nickel - KOR

Figure 5: Nitrogen Dioxide and Nickel concentrations in Kordin air monitoring station

3 Figure 6: SO2 Annual Mean Concentrations (µg/m ) 2014 Malta’s National Air Pollution Control Programme - 2019 23

3 Figure 7: SO2 Annual Mean Concentrations (µg/m ) 2017

TRANSPORT Benzene concentration levels have been decreasing since the switch to unleaded petrol, as shown in 5.4 THE BAN OF LEADED PETROL Figure 8. Since 2004, benzene concentrations have remained well below the EU limit value of 5µg/m3 and Benzene, a volatile organic compound known for its toxic has remained below the EU limit value since then. An effect, affects mainly the blood system of the human annual average decrease of 0.3 µg/m³, ranging from being when exposed for a long-term. This pollutant is 0.57 to 0.14 µg/m³ per year can be noticed in Figure considered carcinogenic and mutagenic, and can be 8 below. harmful at any dose. Benzene is mostly present in the urban atmosphere due to the incomplete combustion of Figures 9 and 10 show a 29.4% decrease in benzene fuel in road transport and the handling and distribution concentrations between the years 2014 to 2017. This of petrol (SOER, 2018). remarkable difference can be mainly noticed in the Northern and Southern Harbour regions, also known as Leaded petrol, when combusted, constitutes a risk the agglomeration. This decrease can be attributed to for human health and the environment due to the the use of cleaner fuel in road transport, namely a lower atmospheric pollution by lead. Given that benzene benzene content in imported petrol. content in the leaded petrol was between 6-8%, and the benzene content in the unleaded petrol was below 1%, leaded petrol was phased out in Malta in 2003 (SOER, 2005). Unleaded petrol, and later on lead replacement petrol (which due to amendments to the fuel quality directive limiting the content of certain metals in gasoline was suspended from the market), were introduced in Malta. 24 Malta’s National Air Pollution Control Programme - 2019

Figure 8: Benzene concentrations monitored using passive diffusion tubes

Figure 9: Benzene concentrations in Malta in 2014 Malta’s National Air Pollution Control Programme - 2019 25

Figure 10: Benzene concentrations in Malta in 2017

5.5 PUBLIC TRANSPORT REFORM newer vehicle fleet is being masked by the rising number of vehicles being registered on the road. In 2018, the The public transport service in Malta was reformed number of newly licensed motor vehicles (new and used in 2011, where the old and polluting buses were vehicles) increased at an average rate of 72 vehicles per substituted with a younger and cleaner fleet. day (NSO, 2019).

To attempt to see the effect of the reform on ambient Moreover, whilst the introduction of diesel particle air quality, data from two air-monitoring stations was filters in Euro 4 cars and better might have contributed to the reduction of PM , the oxidization of NO into NO analysed; namely PM2.5 from the traffic station in Msida 2.5 2 and the urban background station in Żejtun, together might be the reason why NO2 levels are not reducing any further. Additionally, the average age of the vehicle with NO2 in Msida (Figure 11). These pollutants were selected in view of their direct relevance to road fleet (passenger cars) was 14 years in 20153 (TM, 2016), corresponding to the Euro 4 emission standard. This transport emissions. PM2.5 concentrations demonstrate a clear decrease during the time period, which continues might explain the mismatch between the trend for PM2.5 post implementation of the public transport reform. and that for NO2 due to the introduction of the diesel particle filter (DPF) in Euro 4 vehicles, which is known to This decrease is not mirrored in the NO2 profile, and decrease emissions of PM but increase the emissions NO2 levels seem to have stabilised. This trend is also 2.5 confirmed by data from the diffusion tube network. A of primary NO2 (Grice et al., 2009). reason for this could be that any improvement in the reduction of PM2.5 both through the public transport reform, and the improvement in technology of the

3 The average age of a passenger car in Malta is significantly higher than the European Union average of 8.6 years. 26 Malta’s National Air Pollution Control Programme - 2019

Annual NO2 and PM2.5 concentrations (µg/m³)

NO₂ and PM2.5 concentrations (µg/m³) 25 75

20 60

15 45 2 2.5 NO PM 10 30

5 15

0 0 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

PM2.5 - MSD PM2.5 - ZTN NO2 - MSD

Figure 11: Trends in NO2 and PM2.5 concentrations

5.6 VEHICLE TRACKING FOR PUBLIC better and more sustainable modal choices to be made TRANSPORT in the future for passengers and freight (TM, 2016). It is planned that the implementation timeframe of this This measure is a real-time vehicle tracking and measure is extended to 2030. management system, which enables public transport operators to keep track of the vehicles’ movements within the network, and schedule the services 5.8 INCREASE ROADSIDE CHECKS AND according to the planned and current traffic conditions, ROAD WORTHINESS TESTING considering current passenger journey behaviour and optimising operations efficiency. Moreover, vehicle Two of the main responsibilities of the Enforcement tracking ensures that the public transport service Directorate of TM is to act as a regulator for all licensed is running in accordance with the schedule, and transport providers and ensure that all vehicles are enables operators to monitor problems, such as traffic within legal emission levels. In 2017, the Directorate congestion and breakdowns (TM, 2016). It is planned routinely conducted a number of roadside checks, that the implementation timeframe of this measure is also referred to as roadside technical inspections. extended to 2030. Enforcement Officers are assigned to different locations every morning to check for road worthiness of vehicles that are randomly selected. If the vehicles 5.7 FACILITATE THE DEVELOPMENT selected fail to pass the tests, a restriction is imposed OF A REAL TIME MULTI-MODAL on the vehicle licence and this restriction is lifted once JOURNEY PLANNER TM deems that the vehicle is found roadworthy again. In 2016, there were 3,590 roadside technical inspections, while in 2017 this decreased to 2,751. Of the 2,751 The multi-modal concept includes road networks, vehicles inspected in 2017, 1,368 passed the test while public transport network and internal maritime 1,383 vehicles failed the test (TM, 2018a). connections. There is the need to improve the current journey planner, to synchronise timetables, providing Inspections at VRT Stations, on the other hand, are travelling information and incorporate a multimodal carried out by the Technical Unit on a risk-based quality ticketing system to provide a better and smooth assurance approach. The Road Transport Licensing Unit intermodal experience. Such improvements would continued with its commitment to ensure safer and facilitate the development of journey planners and cleaner vehicles on Maltese roads. smartphone applications which in turn would allow for Malta’s National Air Pollution Control Programme - 2019 27

To this effect, a number of quality control measures 5.9 THE KAPPARA JUNCTION were carried out on VRT stations using a risk-based assessment. The following measures were also The TEN-T core network is a new infrastructure policy implemented: brought up by the European Commission that connects the whole of Europe by closing all gaps, removing • 1,247 post-VRT checks were conducted on high- bottlenecks and eliminating technical barriers that exist risk vehicles. These vehicles were called at the between the transport networks of the EU Member Technical Services Unit for further inspection; States. As a result of this new European transport policy, • 142 unannounced inspections were carried out at 22km of Malta’s road network are required to form part various VRT Stations to ensure that correct and full in the TEN-T core network, and further 90km of Malta’s test procedures were being observed; road network have been identified as falling under the TEN-T comprehensive network, with a total of 29 TEN-T • All VRT stations were required to photograph all sections. By 2015, 73% of the TEN-T Core Network vehicles undergoing a test for further checking. and 32% of the TEN-T Comprehensive Network were 8,844 photos were verified by the Unit for correct completed (TM, 2016). photo taking and reporting procedures, and checking of the date and time when the vehicle was One of the six top sections that required prioritisation tested (TM, 2018a). was the Kappara Junction, identified as a TEN-T comprehensive network. This TEN-T network required As a result of these measures, operators and testers the removal of bottlenecks and the upgrading of which are found in breach of the VRT regulations the regional road. This junction was the cause of a are penalized accordingly in line with national court bottleneck for traffic coming from Valletta, San Ġwann, procedures. Gżira and St Julians’s. Work on this project started in April 2016 and was completed in two years’ time, The Enforcement Directorate is also responsible of with an investment of over €23 million4. The Kappara the inspection of vehicles reported through the SMS Junction was inaugurated in January 2018, and itis Emissions Alert System. In 2017, 629 vehicles were estimated that 100,000 litres of fuel will be saved5. reported through this system and were called for a test, of which 428 turned up. Consequently, 365 vehicles passed their test, while 63 vehicles failed (TM, 2018a). 5.10 ECONOMIC MEASURES AND In addition, TM is also working on the upgrade of the SMS Emission Alert System through a smartphone INCENTIVES RELATED TO THE ROAD application, facilitating the reporting of polluting TRANSPORT SECTOR vehicles. Road transport is responsible for most of the NOx emissions in Malta and is therefore a concern in areas

with high traffic influx. NO2 is also a source of very fine

particles (PM2.5). According to the National Household Travel Survey (NHTS) of 2010, the most common mode of transport in Malta is driving one’s private car (See Figure 12). By the end of 2018, the stock of licensed motor vehicles increased by 3.6% over the previous year, 77.9% of the total were passenger cars. By December 2018, 60.1% of the total vehicles were petrol-powered engines, 38.9% were diesel-powered engines, and only 0.6% were electric and hybrid vehicles (NSO, 2019). The following schemes have been introduced in the latest years to encourage the use of lower emissions vehicles.

4 https://www.tvm.com.mt/en/news/kappara-project-inaugurated-evening/ 5 https://www.tvm.com.mt/en/news/kappara-project-inaugurated-evening/ 28 Malta’s National Air Pollution Control Programme - 2019

Mode of Transport in 2010 5.10.3 Grants and schemes to purchase new environmentally friendly vehicles and to encourage the use of two-wheeled vehicles

The following grants have been set up to encourage the purchase of cleaner vehicles. Each person was eligible for one grant under this scheme:

• A €900 grant when registering a new category M1

vehicle with CO2 emission levels up to 100g/km, while at the same time de-registering a vehicle in the same category. In 2018, 631 vehicles registered for this grant; • A €700 grant when registering a new category M1

vehicle with CO2 emission levels between 101 and 130g/km, while at the same time de-registering a vehicle in the same category. In 2018, 919 vehicles Figure 12: Mode of transport in 2010 (NHTS, 2010) registered for this grant; • A €3,000 grant when registering a new category

5.10.1 The scrappage scheme M1 plug-in hybrid vehicle with CO2 emission 1-50g/ km, while at the same time de-registering a vehicle The scrappage scheme is a fiscal incentive that uses in the same category. There were no applications an annual grant system to scrap the old, polluting for this grant; cars, which are at least 10 years old, and replacing it • A €2,000 grant when registering a new category by a newer M1 category motor vehicle having a Euro M1 hybrid vehicle with CO emissions between 50- Standard 6b or 6c6. The granted monetary value can 2 65g/km. In 2018, 126 vehicles registered for this vary according to the CO emission levels of the newly 2 grant. purchased Category M1 vehicle, varying from €800 to €2000 (details on the different grants available can be The grants above had a successful outcome with a total found in Section 5.10.3). This scheme was introduced of 1,676 beneficiaries, and it was extended twice during in 2010 and has been renewed on a yearly basis to 2018 (Malta NRP, 2019). These form part of the first incentivise the purchase of vehicles that pollute less. phase of the measure in Section 8.5 on the Continuation Although this scheme has become popular, it does of the EV Grants and Electro-mobility Action Plan. not address the problem of the increasing amount of vehicles on the road (TM, 2016). The use of bicycles should not be considered only as a leisure activity, but rather as an alternative mode of 5.10.2 Gas conversion scheme transport for daily commuting. Bicycles and pedelecs are zero emission vehicles and do not create traffic Autogas, also known as Liquefied Petroleum Gas (LPG) congestion. To encourage the use of bicycles and pedelec is a cleaner fuel when compared to petrol. A scheme bicycles as an alternative mode of transport and at the was launched in 2013 (which is still active to this same time encouraging physical activity, a scheme was date), granting €200 to vehicle owners who convert a launched whereby an individual can purchase a bicycle Category M1 vehicle (passenger car) or a Category N1 or pedelec and apply for a one-time grant of 15.25% of vehicle (commercial) to run on autogas. During 2018, the purchase price (Ministry for Finance, 2017). During 142 vehicles benefitted from this scheme. Since 2015, 2018, there were 1,768 applications, out of which there have been in total 861 LPG conversions. Out 1,766 applications were paid and two applications were of the 861 applications, five were for N1 commercial rejected because they did not meet the requirements vehicles (Malta NRP, 2019). The aim of this incentive stipulated in the Government Gazette. This scheme is to reduce emissions from petrol/diesel-run vehicles. was renewed for 2019. Until end of January 2019, However, the number of petrol and diesel vehicles has 209 applications were submitted, and all have been increased over the years and the share of alternative processed and paid (Malta NRP, 2019). In the case fuel vehicles (which includes electric, hybrid and LPG of bicycles, pedelecs and bicycle racks, the Maltese vehicles) is still low (NSO, 2018).

6 https://www.transport.gov.mt/include/filestreaming.asp?fileid=4937 Malta’s National Air Pollution Control Programme - 2019 29

Government will provide a VAT refund up to €400 as vehicles, a grant of €6,000 is given upon registering a announced in the 2020 budget (Ministry for Finance, new electric category M1/N1 vehicle, without scrapping 2019). another vehicle. In 2018, 77 vehicles registered for this grant, and is being extended to 2019. In 2018, the scheme above was extended to companies which purchase bicycles or pedelec bicycles and A grant of €7,000 is being offered when registering a offered such bicycles for hire. A grant of 15.25% is new category M1/N1 vehicle, and scrapping another provided on the purchase price of bicycles (subject to vehicle. In 2018, 51 vehicles registered for this grant, a maximum grant of €85 per non-mechanised bicycle and is being extended to 2019. and a maximum grant of €250 for a pedelec bicycle). This is up to a capping of €7,500 per applicant. Apart When registering an imported second hand electric from encouraging more companies to enter into the category M1/N1 vehicle, a grant of €4,000 is given. In bike-hiring business and assisting those already in this 2018, 73 vehicles registered for this grant. sector, this scheme promotes sustainable mobility other than the use of private cars and thus reducing Another grant of €2,500 is given upon registering a new traffic congestion. It has been renewed in 2019, with an or used electric quadricycle, without scrapping another indicative budget of €150,000 allocated for this grant vehicle. In 2018, 27 vehicles registered for this grant. scheme (Malta NRP, 2019). Moreover, a grant of €25,000 is being awarded to BEV Another incentive was introduced by the Government importers introducing a new BEV model on the national in 2016 to cover the expenditure incurred by local market or car leasing companies having 10 electric councils and enterprises to install bicycle racks and vehicles as part of their leasing fleet. ancillary facilities, with a fund of €150,000 (Ministry for Finance, 2015). Local Councils are also being funded Furthermore, all electric and plugin hybrid vehicles to promote the use of bicycles in their localities, with and any vehicle that is propelled solely by gas are being a fund of €30,000. This scheme has been renewed for exempted from the registration tax, and the owners 2019. In 2017, four applications were submitted: three will be exempt from the circulation licence for the first from local councils and one from a private company. In five years7. Additionally, the drivers of these cars are 2018, five applications were submitted: three from local allowed to use bus priority lanes, irrespective of the councils, one from a private company and one from a number of passengers being carried by the car. non-profit organisation (Malta NRP, 2019). These incentives emanate from the Malta National To further encourage the use of two-wheeled vehicles, Electro-mobility Action Plan (MNEAP) published in the government announced that as from January 2016, 2013. small motorcycles that do not exceed 125cc will have their licenses drastically reduced to a flat rate of €10 a year. This scheme has been created to reduce the 5.10.5 Bike sharing schemes number of cars on the road, which take up more space than motorcycles do. The purchase of electric motor Public bike sharing schemes are very popular systems in cycles is also exempted from VAT (Ministry for Finance, European towns and cities. Nowadays, there are various 2015). bike-sharing systems in Malta, the first one started to operate in 2016. These bike-sharing systems are suitable for everyone, ranging from business travellers, 5.10.4 Incentives for the purchase of electric vehicles tourists and students. The main aim of the bike sharing schemes is to achieve a modal shift to sustainable modes Another scheme was set up in 2018 whereby a grant of of transport, especially in the high traffic areas. Most of €400 is given when purchasing a new pedelec or upon these schemes work through a smartphone application registering of electric motorcycles, mopeds/tricycle to register, rent and return a bike. falling under categories L1e, L2e, L3e or L5e. A total of 39 motorcycles/mopeds registered with a grant of Malta Public Transport operates a bike-sharing system €400, while 185 pedelecs were given a €400 grant. The in Malta, called the ‘Tallinja Bike’, which facilitates travel purchasing of a new pedelec grant will be extended to within and around Valletta. ‘Tallinja Bike’ can be used 2019 (Malta NRP, 2019). by locals and tourists who would like to use alternative modes of transport in the Capital City, via a smartphone To further encourage the use of electric and hybrid application. The ‘Tallinja Bike’ sharing system forms part

7 https://electromobility.gov.mt/en/Pages/Government-Grants.aspx 30 Malta’s National Air Pollution Control Programme - 2019

of the Sustainable Urban Mobility Plan (SUMP) of the INDUSTRY Valletta Extended Region, which is further discussed in Section 8.9. 5.11 ENVIRONMENT PERMITTING

By increasing the use of bicycles and decreasing the use One of ERA`s functions is the processing and issue of vehicles, traffic congestion is reduced, therefore NO2 of operational permits for certain installations and/ and PM concentrations in the most congested areas are or operations which are identified as having an reduced. These bike sharing schemes are planned to environmental risk. Of direct concern in terms of remain active until 2030. emissions to air are those falling within the scope of the Industrial Emissions Directive (2010/75/EU) and The Medium Combustion Plant Directive (2015/2193/EU). 5.10.6 Promoting multiple options not to travel during Nonetheless, installations which do not fall within the peak hours scope of the aforementioned legislation are regulated through site specific permits which include either Recently, several initiatives have been implemented in emission limit values or operational conditions aimed at Malta (TM, 2016) with the aim of reducing the need to the mitigation of emissions to air. travel during the morning peak hour, between 07:30 and 8:30, which accounts for 11% of all traffic throughout The Industrial Emissions Directive (2010/75/EU), the day. These initiatives include: also known as the IED, was adopted on 24 November 2010 and is the main legislative instrument regulating • Online banking; reduces the need for bank users to pollutant emissions from industrial installations. The travel to their local bank branch for simple actions, IED entered into force on 6 January 2011, and was example a transfer of money; transposed into national legislation through S.L. 549.76 • Online government services; reduces the need to S.L. 549.81 that entered into force on 7 January 2013. for people to travel to public offices for a simple application or query; • Video conferencing and video-presentations; these can be easily affected nowadays since most employees are equipped with the proper equipment (laptops) to communicate via video conferences; • Tele-diagnosis and remote maintenance; this measure allows ICT service providers to remotely resolve any technical issues that may arise; • Flexi-working hours which lets employees travel to work during the non-peak hour; this allows employees to avoid the morning and evening peak hours; • ‘Tele-working’ policy in the public sector; since this measure calls for employees to stay working from home, it subsequently results in a reduced number of vehicles on the road during the morning and afternoon peak hours. The aim of the Industrial Emissions Directive is to control industrial emissions with the purpose of safeguarding the human health and the environment. The Directive lays down instructions to prevent and control pollution emitted into the air, water and land, and to avoid generation of waste from the large industrial installations. Emissions (including atmospheric emissions) from installations within the scope of the IED are subject to permit conditions which inter alia include the application of best available techniques and wherever applicable the achievement of the associated Malta’s National Air Pollution Control Programme - 2019 31

emission levels (AELs) in the respective best available same pollutants. By the end of 2018, there were 13 techniques reference documents (BREFs). MCP installations permitted to operate in Malta. The emission limit values as set in the MCP Regulations By the end of 2018, the number of installations falling started applying as from 20 December 2018 for the within the scope of the Industrial Emissions Regulations new plants, whilst for the existing plants, they will start permitted to operate in Malta is as follows: applying as from 2025 or 2030 (depending on their size)8 . The MCP Directive also requires monitoring of • 14 Integrated Pollution Prevention and Control carbon monoxide (CO) from such plants with the aim of (IPPC) installations; two of which are Large collecting data on CO emissions from these plants so as Combustion Plants (LCPs) installations; to assess whether such a parameter would need to be regulated through amendments in the MCP Directive. • 19 installations with limitation of emissions of VOCs. AGRICULTURE The Medium Combustion Plant Directive (2015/2193/ EU) of 25 November 2015 was transposed into national According to Malta’s national emission inventory, legislation through S.L. 549.122. This Directive was agricultural activity is the main source of ammonia based on a Commission’s proposal, which was part of the emissions in the Maltese Islands (Figure 18 indicates Clean Air Policy Package (published on 18 December the main categories responsible for ammonia emissions 2013). The MCP Directive regulates emissions of SO , 2 in Malta). Figure 13 shows how nearly all total ammonia NO and dust into the air from medium combustion x emissions derive from the agricultural sector and these plants, with a rated thermal input equal to or greater have decreased slightly throughout the last twelve than 1MWth and less than 50MWth. Moreover, the reporting years. This can be attributed to the decline in MCP Directive also ensures the implementation of the animal heads. obligations arising from the Gothenburg Protocol under the Convention on the Long Range Transboundary Air Pollution, which also sets emission limits for the

Trend in the contribution of the agricultural sector to total ammonia emissions NH₃ national total emissions vs NH₃ emissions from the agricultural sector 1.8

1.6

1.4 NH₃ emissions from 1.2 the agricultural sector 1

0.8

Emissions in kt in Emissions 0.6 NH₃ national total emissions 0.4

0.2

0 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

Figure 13: Trend in the contribution of the agricultural sector to total ammonia emissions

8 Directive (EU) 2015/2193 of the European Parliament and of the Council of 25 November 2015 on the limitation of emissions of certain pollutants into the air from medium combustion plants 32 Malta’s National Air Pollution Control Programme - 2019

In livestock buildings, ammonia can be a threat to • Nutrient demand of the crop in relation to the yield livestock and agricultural workers as it can cause, over level time, significant respiratory hazard to those exposed • Nutrient content in the soil to this gas on a daily basis. When reducing ammonia emissions indoors, the health of animals and workers • Nutrient content in the mineral and organic is improved. In addition, the proper management of fertilisers that will be applied livestock manure also reduces nitrogen losses in the • Nutrient content of other sources soils. • Regulations for fertiliser application • Best time for application (CoGAP, 2001) Horticulture activity in the Maltese Islands has shifted gradually from traditional practice towards intensive A fertiliser plan is to be issued by a qualified person production systems throughout the past seventy years. as approved by the competent authority, i.e. the Imported technologies are used to increase yields Agriculture Directorate within the Rural Development per area, by the intensive use of agro chemicals and Department. fertilisers. The Maltese Code for Good Agricultural Practice (2001), also referred to as the CoGAP, was In addition, farmers are required to keep records of developed with a view to create a compilation of good manure transport. Records must include the name of practices pertaining to the Nitrates Directive, the contractor, the amount and type of manure, the date of Malta Action Programme and other Directives. The delivery, destination, registration number of the truck development of the CoGAP was based on the provision delivering manure and contract number of contractor. of long-term sustainable directives addressed to Moreover, farmers should keep record of the purchase farmers, keeping in mind an environmentally friendly or sale of mineral and organic fertilisers (including the perspective and cost-effectiveness. type of fertiliser and nutrient content of fertiliser) (ARPA, 2015). The CoGAP focuses on several sectors, including the following: The InfoNitrates Life+ Project was an information and communications campaign aimed at the proper use and • Fertilisation practice management of nitrates in agriculture and livestock • Manure management husbandry, thus improving the implementation of the national Nitrates Action Plan. This project started on 1 • Animal husbandry September 2011, and ended on 30 June 20149.

The implementation of the InfoNitrates Life+ Project 5.12 FERTILISER PLAN AND consisted of several training sessions at farms, as well APPLICATION as twenty-nine public meetings around Malta and Gozo. Farmers were given an individual fertiliser plan The mismanagement of animal manure and chemical (which varies from one field to another, as explained fertilisers can cause nitrogen loss. Excess application above in this section). The implementation of a fertiliser of organic (or inorganic) fertiliser can cause nitrogen plan reduces the Gross Nitrogen Balance on the farms to be washed away by torrential rains, resulting in the where it has been applied, thus farmers are able to contamination of freshwater aquifers, drinking water meet their obligations under the Nitrates Action supplies and bathing water. In addition, excessive Plan, as well as increasing the efficiency in fertiliser nitrogen levels in a water body can cause eutrophication. practices. The project also helped farmers in changing their farming practices so that nitrogen levels in soil are Moreover, the over-application of organic and reduced through the correct application of nitrogenous chemical fertilisers can further increase ammonia fertilisers and to train livestock breeders in the proper volatilisation, thus increasing ammonia emissions into management of animal manure so that nitrogen levels in the atmosphere. To regulate this problem, the amount soil are reduced. In this way, farmers save on fertilisers of manure or fertiliser is controlled through a fertiliser by applying only the necessary amounts while at the plan (which varies from one field to another) as issued same time they protect the environment. by the Competent Authority or personnel (ARPA, 2015), and which must take into account:

9 http://ec.europa.eu/environment/life/project/Projects/index.cfm?fuseaction=search.dspPage&n_proj_id=4027 Malta’s National Air Pollution Control Programme - 2019 33

The Project offered information, which was made 5.15 LIVESTOCK FEEDING STRATEGIES available at the InfoNitrates Office, as well as a free phone service. The InfoNitrates Office received 622 The Agriculture Directorate manages a voluntary calls from local farmers, mainly enquiring on technical scheme entitled “Products of Quality National Scheme” issues such as storage requirements for manure and (PQNS) which is open to all interested actors who form fertiliser, as specified in the Nitrates Action Plan. part of a recognised agricultural value chain. The scheme develops standards of production which identify the production and farming methods and those elements 5.13 MANURE STORAGE FACILITIES that characterize the superior quality of the product10. The PQNS requires feeding practices to be guided by Given that in Malta the rainy season falls mostly qualified animal nutritionists or any other competent between 15th October and 15th March, application person in animal nutrition for feeding practices. When of manure on agricultural land during this period is animals are fed more than they require, excess nitrogen prohibited to prevent nutrient run-off and leaching is excreted in urine and faeces, resulting in increase in (CoGAP, 2001). To this effect, during this same period gases (ammonia) and odour. When feeding the animals livestock manure must be stored in a covered and leak- according to their nutritional requirements, nitrogen proof clamp, connected to a cesspit. excretion and consequently ammonia emissions are reduced without altering the animals’ productivity (A Manure clamps should be built with three rendered Primer on Livestock Air Quality, n.d.). high walls with the least possible surface to volume ratio. A reduction in the surface area implies a reduction in ammonia emissions.

The InfoNitrates Life+ Project also delivered training sessions on the proper storage and transport of manure, as well as to finding tailor-made technical solutions according to the number and type of livestock (dairy cows, cattle, sheep or goats). Training was provided to 2,032 operators, around 73% of those available.

5.14 ANIMAL HOUSING

In line with the Nitrates Regulations S.L. 549.25, animals must be housed to decrease the possibility of nitrates leaching. The manure handling systems within an animal housing envelope can be designed to reduce ammonia emissions by decreasing its volatilisation. The emissions can be reduced by keeping all areas in the animal house (inside and outside, including passageways) dry and clean (ARPA, 2015), by keeping manure surfaces in pits as small as possible, by separating faeces and urine immediately, and by making sure that the air flow and 5.16 THE GOVERNANCE OF air temperature over surfaces with excreta is kept as AGRICULTURAL BIO-RESOURCES low as possible, without reducing the overall ventilation AGENCY (United Nations Economic Commission for Europe, 2015). Moreover, appropriately designed animal The Governance of Agricultural Bio-resources Agency housing is beneficial to the farmer’s health since the (GAB) was established through SL 497.22 in May 2017. proper management of feed, bedding material, manure The Agency was set up to update, co-ordinate and and the animals can reduce dust, thus reducing the implement the Agricultural Waste Management Plan, possibility of bronchitis and occupational asthma. with the main aim to sustainably manage agricultural bio-resources in a manner that supports the Maltese agricultural sector. The Agricultural Waste Management Plan is further discussed in Section 8.25.

10 https://agriculture.gov.mt/en/ikeltakwalita/Pages/PQNS/pqns.aspx 34 Malta’s National Air Pollution Control Programme - 2019

ENERGY DEMAND 5.18 REPLACEMENT OF APPLIANCES IN VULNERABLE HOUSEHOLDS The energy sector in Malta has improved in the recent SCHEME years, providing Maltese society and businesses with affordable, sustainable and secure forms of energy. The Energy and Water Agency, in collaboration with Malta’s energy policy focuses on maximising effective the LEAP centres within the Foundation for Social renewable energy potential, and thus the Government Welfare Services have set up financial schemes aimed is increasing measures related to the deployment of to reduce energy and water consumption in low- renewable energy, especially photovoltaics and solar income households through the replacement of old and water heating systems (NECP, 2018). The following inefficient appliances with new energy-efficient models. measures are referred to in the draft NECP. At the same time, this scheme helps in generating savings which count towards Malta’s energy efficiency targets. In 2017, a total of 472 visits to vulnerable 5.17 PROVISION OF PROFESSIONAL households were carried out, of which 242 households ADVICE TO HOUSEHOLDS have had one of their appliances replaced during 2018. The appliances were distributed during September The Energy and Water Agency are offering professional 2018. Following the success of this scheme, a new advice (free of charge) to vulnerable and low-income tender has been published to assist other vulnerable households on energy efficient appliances and families during 2019 (Malta NRP, 2019). behaviour. This scheme helps to reduce consumption costs and helps in generating savings which count towards Malta’s energy efficiency targets. From its inception to the end of 2018, a total of 2,121 household visits have been carried out, and this scheme shall continue in 2019 (Malta NRP, 2019). Malta’s National Air Pollution Control Programme - 2019 35

5.19 EXPLOIT ALL REASONABLE 5.22 PV GRANT SCHEMES POTENTIAL INDIGENOUS RES THROUGH PV TECHNOLOGY To further encourage and promote the use of renewable DEPLOYMENT sources of energy for domestic use, several grant schemes were launched. A major part of uptake of PVs on residential premises took place as a direct result PV technology turned out to be the most robust of all of EU-funded grant schemes enabling households to indigenous sources of RES. Yield of PV systems in Malta benefit from up to 50% of the initial capital investment is amongst the highest in Europe. There was a sharp (NECP, 2018). increase in the uptake of PV between 2010 and 2017, with the total cumulative installed capacity at end of 2017 standing at approximately 110 MWp. This has happened largely thanks to incentives offered through 5.23 SOLAR WATER HEATERS AND various schemes, including ERDF co-financed grants, COLLECTORS SCHEME attractive feed-in tariffs and decreasing PV technology costs. Measures targeted exploiting of remaining Since 2005 a number of grant schemes to promote the rooftop potential on industrial, domestic and public use of SWH for households have been launched and buildings (NECP, 2018). completed. Previous schemes were restricted to specific households, mainly those that meet social assistance criteria. The current National Scheme provides a grant 5.20 FEED-IN TARIFFS SCHEME of 50% up to €700 and is not restricted by social criteria (ELECTRICITY GENERATED FROM (NECP, 2018). SOLAR PV INSTALLATION)

The purpose of Subsidiary Legislation 545.27 titled Feed-in Tariffs Scheme Regulations from 2010 is to establish a feed-in tariff for electricity generated from solar PV installations and hence promote and support the generation of electricity from renewable energy sources. The tariff included systems benefitting from a capital grant. The introduction of the feed-in tariff increased the exploitation of roof space, including that of premises with no consumption of electricity and hence no incentive for net metering. Feed-in tariffs are revised regularly to ensure a reasonable return on investment and avoid overcompensation (NECP, 2018). In the Budget Speech 2020, it was announced that as from 2020, a grant will be offered to cover 25% of the expenditure for the purchase of renewable energy batteries, capped at €1,000 (Ministry for Finance, 2019).

5.24 BIOFUELS SUBSTITUTION 5.21 COMPETITIVE BIDDING PROCESS OBLIGATION (2011 – 2020) FOR PV SYSTEMS EQUAL OR LARGER THAN 1MWP The substitution obligation on the imports and wholesales of fossil fuels was introduced in 2011 The scheme provides support for electricity generated through an amendment of S.L. 423.28, with the aim from renewable sources, restricted to that produced of promoting the use of biofuels. It is required by law by PVs with capacity above 1 MWp. Aid is provided for that a percentage of total energy content of petrol and 20 years in the form of a premium over and above the diesel placed on the market for use by road transport proxy for the market prices of electricity (NECP, 2018). is biofuel. During 2018, this share reached 8.5% (by energy content) (NRP, 2018). 36 Malta’s National Air Pollution Control Programme - 2019

5.25 ENERGY EFFICIENCY OBLIGATION for improved relations between Government and large enterprises with the aim of resulting in the uptake of The Energy Efficiency Obligation considered for Article energy efficiency practices. Voluntary agreements 7 target of the EED consists of the progressiveness of last for three years. This measure also includes energy the domestic residential household tariff system and savings resulting from excise duties on motor fuels the incentive towards energy efficiency in the tariff exceeding EU’s minimum levels (NECP, 2018). structure (eco-reduction). Savings are measured as a direct reduction of electricity consumption (NECP, 5.28 PUBLIC SECTOR LEADING BY 2018). EXAMPLE IN THE ENERGY DEMAND SECTOR

5.26 FINANCING SCHEMES AND FISCAL The Government and public entities undertake INCENTIVES measures and projects to increase energy efficiency in their spheres of activity, particularly in services and Includes various schemes to incentivize target sectors buildings. Measures include street lighting retrofitting, to adopt more energy efficient technologies. Financial public schools or the Tal-Qroqq National Pool Complex instruments address energy efficiency measures within Project (NECP, 2018). industrial processes, transport and buildings. These policy measures aim to target the residential, industrial, commercial and transport sectors (NECP, 2018).

5.27 REGULATIONS AND VOLUNTARY AGREEMENTS

These measures target heavy consumers of energy with the aim of encouraging the adoption of energy efficient techniques. The national voluntary agreement scheme, the Energy Efficiency Partnership Initiative (EEPI), has been set up to foster, improve and create a roundtable Malta’s National Air Pollution Control Programme - 2019 37

DEGREE OF COMPLIANCE WITH NATIONAL AND UNION OBLIGATIONS

06 38 Malta’s National Air Pollution Control Programme - 2019

6.1 DEGREE OF COMPLIANCE of the five main pollutants reported under the NEC WITH THE EMISSION REDUCTION Directive, from year 2005 to 2017. It can be noticed that the national total emissions (NO , NMVOC, SO , COMMITMENTS AS SET IN ANNEX II x x NH3 and PM2.5) in 2017 decreased by more than half OF THE NEC DIRECTIVE when compared to 2005, and this is mainly due to the considerable reduction in SO emissions (which The following chapter provides a summary of the x decreased by almost 95%). NOx emissions have also trends and sources of the five main pollutants reported reduced as a result of measures related to the reform in under the NEC Directive, and their compliance with the the power generation sector. Directive. The year of the projections presented in the NAPCP and the historical inventory year of the data which underpins them is 2017.

Figure 14 below shows the national total emissions

National Total Emissions

National total emissions 30

10 Emissions in kt in Emissions

0 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

NOx NMVOC SOx NH3 PM2.5

Figure 14: Time series of national total emissions in kt

Pollutants 2005 in kt 2017 in kt Overall % reduction

NOx 9.19 5.37 41.6

NMVOC 3.83 3.45 9.9

SOx 11.98 0.63 94.8

NH3 1.46 1.13 22.5

PM2.5 0.73 0.32 56.5

Table 1: Overall percentage reduction of national total emissions Malta’s National Air Pollution Control Programme - 2019 39

6.1.1 Nitrogen oxides (NOx) heavy duty vehicles and buses, national navigation and other sources. As at base year 2017, Malta exceeded

The energy sector is the major source of NOx emissions the emission reduction commitment as set for 2020 in the Maltese Islands. The overall NOx emissions (2.5kt) in the NEC Directive. This could be due to an decreased by 41.6% between 2005 and 2017, mostly overestimation in emission calculations from domestic due to improvements in the power generation sector solvent use.

(See Figure 4). The key category with the highest NOx emissions, amounting to 3.3kt in 2017 is the road transport sector, comprising of passenger cars, light 6.1.3 Sulphur oxides (SOx) and heavy-duty vehicles and buses. Other key sources of NOx emissions are international aviation, power SOx emissions have decreased from 11.98kt in 2005 to generation and national navigation. As at base year 0. 63kt in 2017: a reduction of 94.8%, mainly due to the 2017, Malta is in compliance with the 2020 emission use of cleaner fuels. Following this major decrease in reduction commitments as set in the NEC Directive, emissions, the situation at present indicates that 87% of however more effort needs to be employed for Malta to the SOx emissions in the Maltese Islands in 2017 derive be able to reach its NOX ceiling for 2030. from public electricity and heat production, amounting

to 0.55kt of emissions. Other sources of SOx emissions are stationary sources (commercial/institutional), 6.1.2 Non-methane volatile organic compounds international aviation (civil) and other sources. Public (NMVOCs) electricity and heat production used to be a major

source of SOx emissions, however this changed as a NMVOC emissions have decreased by 9.9% between result of recent developments in the power generation 2005 and 2017. NMVOC emissions are mainly the sector (as discussed in chapter 5). As at base year 2017, result of road transport (passenger cars and gasoline Malta is in compliance with the 2020 (2.53kt) emission evaporation), domestic solvent use, biological treatment reduction commitments as set out in the NEC Directive. of waste, manure management (non-dairy cattle), distribution of oil products, mopeds, motorcycles,

NOX Sources (2017)

NOx Sources (2017)

Road transport: passenger cars, light and 12% heavy duty vehicles and buses

7% International aviation LTO (civil)

9% Public electiricity and heat production

62% 10% National navigation (shipping)

Others

Figure 15: NOX Sources (2017) 40 Malta’s National Air Pollution Control Programme - 2019

NMVOC Sources (2017)

Road transport: Passenger cars

Domestic solvent use including fungicides 18% 22% Biological treatment of waste - Solid waste disposal on land Road transport: Gasoline evaporation 3% 3% Manure management - Non-dairy cattle

4% Distribution of oil products 16% 4% Road transport: Mopeds & motorcycles

5% Road transport: Heavy duty vehicles and buses

National navigation (shipping) 12% 13% Others

Figure 16: NMVOC Sources (2017)

SOX Sources (2017)

SOx Sources (2017)

4% Public electricity and heat 4% production 5%

Commerical/insitutional: Stationary

International aviation LTO (civil)

Others 87%

Figure 17: SOX Sources (2017) Malta’s National Air Pollution Control Programme - 2019 41

6.1.4 Ammonia (NH3) 6.1.5 Fine particulate matter (PM2.5)

The agricultural sector is the main source of NH3 Between 2005 and 2017, PM2.5 emissions decreased emissions. Between 2005 and 2017, NH3 emissions by 56.5%. This reduction is mainly due to the power decreased by 22.5% which can be mainly attributed to a generation sector, followed by a smaller reduction decrease in animal heads. The main agricultural sources from road transport and agriculture. The main sector are the animal manure as applied to soils and manure responsible for these emissions is the road transport management of dairy cattle, laying hens, non-dairy sector (passenger cars, light and heavy-duty vehicles cattle, broilers, swine and other animals. As at base year and buses, automobile tyre and brake wear). Other 2017, Malta is in compliance with the 2020 (1.5kt) and sources include national navigation (shipping), public 2030 (1.3kt) emission reduction commitments as set electricity and heat production. As at base year 2017, out in the NEC Directive. Malta is in compliance with the 2020 (0.98kt) and the 2030 (0.35kt) emission reduction commitments as set out in Annex II of the NEC Directive.

NH3 Sources (2017) NH3 Sources (2017)

Animal manure applied to soils

Manure management - Dairy cattle 14% 22% Manure management - Other animals 8% Manure management - Laying hens

9% Manure management - Non-dairy 14% cattle Manure management - Broilers 10% Manure management - Swine 13% 10% Others

Figure 18: NH3 Sources (2017)

PM2.5 Sources (2017) PM2.5 Sources (2017)

Road transport: Passenger cars,light and heavy duty vehicles and buses 12% National navigation (shipping) 5%

5% 41% Road transport: Automobile tyre and brake wear

12% Public electricity and heat production

Road transprot: Automobile road abrasion 25% Others

Figure 19: PM2.5 Sources (2017) 42 Malta’s National Air Pollution Control Programme - 2019

6.2 DEGREE OF COMPLIANCE WITH limit value in 2011. Both exceedances were registered AMBIENT AIR QUALITY in the agglomeration, specifically at the traffic station in LEGISLATION Msida. To this effect an Air Quality Plan was published in 2010, which focused on traffic measures with the main measure being the reform of the public transport Malta has divided its territory into zones and system. agglomerations, as required by the Ambient Air Quality Directive. Figure 20 shows the designation of the Malta The State of the Environment Report published by ERA agglomeration , following the assessment carried out in 2018, presents air quality trends from 2009 to 2015. by Stacey and Bush in 2002. The area consists of the It is evident that the traffic station registers higher Valletta-Sliema agglomeration, further extended to levels of traffic generated pollutants when compared to cater for the most densely populated areas. Although the urban background and background sites. However, most of the real time monitoring stations are located following deduction of natural sources (such as Saharan in the agglomeration, two other stations are situated dust and sea salt), Msida station remains within the in the Malta zone , so as to continuously improve the limits stipulated by Directive 2008/50/EC, although knowledge on air quality trends throughout the Maltese hovering around the limit values for PM and NO . This Islands. 10 2 identifies the need to tackle road transport with priority. Since accession, Malta has surpassed the allowed number of exceedances of the PM10 daily limit value in 2010 (after deduction of natural contributions), and the allowed number of exceedances of the NO2 hourly

Figure 20: The Malta agglomeration Malta’s National Air Pollution Control Programme - 2019 43

PROJECTED FURTHER EVOLUTION ASSUMING NO CHANGE TO ALREADY ADOPTED POLICIES AND MEASURES

07 44 Malta’s National Air Pollution Control Programme - 2019

Projections provide the necessary information to assess The projected NMVOC emissions exceed the 2020 the future emission reductions. They provide a clear and 2030 emission reduction commitments. Emission indication if a Member State is projected to comply with calculations for the sector related to ‘Domestic Solvent emission reduction targets on the basis of the current Use including Fungicides’ are estimated using a very basic adopted PaMs, or whether additional PaMs need to be methodology, possibly leading to an overestimation of implemented for compliance purposes. emissions. Therefore, these projections are still subject to further studies and verification.

7.1 PROJECTIONS FOR THE WM NH3 emissions are projected to be compliant with the SCENARIO 2020 ceiling. A minor non-compliance of 0.07kt with the 2030 ceiling is being projected. NOx emissions The baseline (WM) scenario assumes that Malta are projected to be compliant with the 2020 ceiling, implements the same measures adopted as at end however a non-compliance with 2030 ceiling is 2017 throughout until 2030. Table 2 below displays projected. For this reason, the WaM scenario focuses on the sector accountable for the majority of the NO Malta’s emission reduction commitments as set for x 2020 and 2030 for NO , NMVOC, SO , NH and PM , emissions, i.e. the transport sector, which is responsible x 2 3 2.5 for 62% of the total NO emissions in 2017 (Figure 15). and the projected emissions of the same pollutants for x years 2020 and 2030, taking into account the baseline scenario (WM).

The projected emissions for the baseline scenario show that SO2 and PM2.5 will be in compliance with the emission reduction commitments as set in 2020 and 2030.

2017 emissions 2020 ceilings Projections for 2030 ceilings Projections for Pollutants in kt in kt year 2020 in kt in kt year 2030 in kt

NOX 5.37 5.33 5.10 1.93 4.88

NMVOC 3.45 2.95 3.37 2.8 2.91

SOX 0.63 2.76 0.10 0.6 0.13

NH3 1.13 1.4 1.19 1.11 1.18

PM2.5 0.32 0.55 0.32 0.37 0.31

Table 2: Emission projections for NEC pollutants for 2020 and 2030 considering the "With Measures" scenario as compared to 2020 and 2030 ceilings of the NEC Directive Malta’s National Air Pollution Control Programme - 2019 45

POLICY OPTIONS CONSIDERED TO COMPLY WITH THE EMISSION REDUCTION COMMITMENTS FOR THE PERIOD BETWEEN 2020 AND 2029 AND FOR 2030 ONWARDS

08 46 Malta’s National Air Pollution Control Programme - 2019

As per Section 7.1 of this programme, NOx emissions The government devised a measure whereas students need to be substantially reduced to be in compliance attending state, Church or private schools are picked with the NEC 2030 ceiling as set for Malta in the up by public transport vehicles (mini-vans) from their NEC Directive. Therefore, the future policy options localities and dropped off to their respective schools, considered focus mainly on measures which can reduce and vice versa. This measure has been in effect since the

NOx emissions from road transport. start of the scholastic year 2018-2019, where about 28,000 students benefitted from this incentive, making The following measures are being considered in the a positive contribution towards the environment as “With additional Measures” (WaMs) scenario. the number of cars on the road during peak hours is estimated to have reduced by 15,000 vehicles (Malta TRANSPORT NRP, 2019).

Some of the measures are aimed at improving road networks by implementing infrastructural interventions, 8.2 TALLINJA CARD INCENTIVES while others are aimed at improving the efficiency of the transport system in a sustainable manner. Regular commuters using public transport can register for a personalised tallinja card, an intelligent bus card designed to make it easy for the user to use the bus. It 8.1 FREE SCHOOL TRANSPORT offers reduced fares and the ability to top up the card online or through a phone call. There are different card Most of the morning rush hour traffic in Malta is categories, and fares vary from one category to another: attributed to the starting times of both schools and child, student, adult, Gozo resident, and Concession work places coinciding in the same hour. This is also (seniors and Special ID cardholders). Making use of the reflected in ambient air pollution trends at the traffic tallinja card offers incentives and intermodal services, site (see Figure 21), whereby CO concentrations are such as the IoScoot motorbike-sharing service and the seen to experience a higher peak during the winter ferry service, thus reducing dependency on private cars. period, which is not present in summer. A less obvious evening rush hour peak is also present in winter.

CO diurnal variation summer vs. winter (2014 - 2017)

CO diurnal variation summer vs. winter (2014 - 2017) 1400

1200

1000 ) 3 g/m

µ 800

600 CO concentration (

400

200

0 00 01 02 03 04 05 06 07 08 09 10 11 12 13 14 15 16 17 18 19 20 21 22 23 time (hr)

summer winter

Figure 21: Diurnal variation of CO concentrations during the Summer and Winter periods at Msida traffic site from 2014 to 2017 (Summer is June, July and August, while Winter is December, January and February) Malta’s National Air Pollution Control Programme - 2019 47

are no monthly membership fee or any other cost. 8.2.1 Tallinja’s Capping System

The tallinja card offers a capping feature, which allows The IoScoot’s fleet is currently available in St Julian’s, cardholders to enjoy unlimited travel in a specified Sliema, Msida and Valletta, and users can travel beyond period, being either a single day, a week or a calendar these zones. month. Capping differs from one card category to another. The capping system was introduced with the 8.2.3 Tallinja Ferry Service Tallinja Card in July 2015. Before that, passengers could buy a 30-day ticket for €26. The difference between In 2017, Malta Public Transport and Valletta Ferry the capping system and the previous ticket system is a Services have teamed up to offer tallinja cardholders cost-benefit to the customer, since there may have been discounted rates when paying with their tallinja card for “wastage” in the previous system, for example, when their journey by ferry from Sliema to Valletta and vice the customer is not able to use the public transport for versa, and from Cospicua to Valletta and vice versa. a whole week. In the capping system, if the passenger travels less during a particular month, and spends €15 8.2.4 TD Plus for example, there would be a saving compared to the previous system. Moreover, when the total cost of The public transport system in Malta has various routes all journeys reaches a pre-determined limit, a cap is meant to offer a quicker connection between popular applied to the applicable fares and no further charges localities, a system called ‘tallinja direct’. Malta Public are imposed on the card. Transport also offers an on-demand service called the TD Plus, providing greater flexibility, more comfort and 8.2.2 IoScoot: An electric motorbike sharing service benefit while saving time. The TD Plus uses technology that matches the requests made by different passengers In August 2018, the first motorbike-sharing service, the when booking through the tallinja mobile application, IoScoot, was launched. The fleet consists of 40 electric to select the most efficient route, on a specific date motorcycles, with a charge of €0.25c per minute of and within a specific time bracket. TD Plus is currently drive time. The IoScoot and the Malta Public Transport operating between Valletta and Pembroke, including St. have teamed up in order to offer tallinja cardholders Julian’s, Swieqi, San Gwann, Msida, Pietà and Floriana. with discounted rates (€0.20c per minute of drive time) on the electronic bike sharing service. The electric motorbike sharing service offers an easy, convenient 8.3 FREE PUBLIC TRANSPORT FARES and environmentally friendly way to travel. The user FOR YOUTHS, STUDENTS AND needs to have a moped licence and booking is done on ELDERLY PERSONS the Meep smartphone application by locating the closest electric motorbike, unlock it and ride it to destination. Up to end of December 2018, take-up of the tallinja card The user is only charged on the journey time, and there increased to 317,626. Passengers between January and December 2018 amounted to 53,467,404, representing an 11% increase on the previous year (Malta NRP, 2019). The increase in passengers could be associated with the following measures.

To encourage the use of public transport, all 18 year olds in 2017 in Malta benefited from the first phase of the free Public Transport as part of an EU initiative. In 2018, the scheme was extended to a second phase, whereby youths aged between sixteen and twenty years benefited from it. Around 28,000 were eligible to this scheme in 2018, of which 24,000 of them actually benefitted (Malta NRP, 2019).

As from 2019, free public transport fares were extended to a third phase, which includes youths aged between 14 and 20 years and fulltime students over the age of 21 (Malta NRP, 2019). This age group has been specifically selected since it is the age when one normally chooses their means of transport. It is planned that this last phase is extended up to 2030. 48 Malta’s National Air Pollution Control Programme - 2019

As announced in the Budget Speech 2020 (Ministry 8.5 REVIEW OF MALTA’S NATIONAL for Finance, 2019), elderly persons who have reached ELECTRO-MOBILITY ACTION PLAN the age of 75 will benefit from free public transport. (MNEAP) More than 19,000 elderly persons will benefit from this measure. The MNEAP is currently being revised to reflect the National Transport Strategy and National Transport Master Plan. The current electric vehicle grants will 8.4 DEVELOP AND INCENTIVISE continue through the revised action plan. The measures SCHEMES TO PROMOTE MULTIPLE that will be included in the revised MNEAP will be OCCUPANCY tested and simulated through an Interreg Med funded Project (NECP, 2018). Further to Chapter 5.8.5, the following initiatives can further reduce the need for the individual to travel It is planned that the revised plan will outline Malta’s during the morning peak hour, or shift to cleaner travel continued efforts in implementing sustainable mobility means, as suggested in TM’s Master Plan (2016). These initiatives, tackling the key transport hubs, aiming to include: have more than one mode of transport in one specific location, to facilitate cleaner mobility. Work is ongoing • Financial incentives to shift from private cars to to increase charging infrastructure, safe cycling routes car-pooling or bicycle use. and the upgrading of ferry landing sites. There are also plans to implement pilot projects on the conversion of • Parking-priority for shared mobility services. heavy-duty vehicles from conventional fuels to cleaner • Rewarding companies implementing ‘Green Travel technology. Plans’; a 2019 Action Plan for the Green Travel Plan is currently being put together for the Ministry Phase one of this measure refers to the current grants for Infrastructure, Transport and Capital Projects offered in sections 5.10.3 and 5.10.4. The second phase (MTIP) as a pilot project to later implement similar of this measure refers to new packages of grants that initiatives in other Ministries based on the resultant are being proposed and which will cover a larger extent experience (Malta NRP, 2019). of vehicle types.

The implementation period for these schemes is envisaged between years 2021-2025. Malta’s National Air Pollution Control Programme - 2019 49

8.6 CAR SHARING SCHEMES 8.7 STUDY THE INTRODUCTION OF LOW EMISSION ZONES In the recent months, the MNEP launched the first electric car sharing service in Malta, the GoTo Car Low Emission Zones (LEZ) are designated areas in Sharing Scheme. The aim of this initiative is to decrease which higher levels of air pollutants are controlled the number of cars on the road and encourage the general through the management of the vehicles entering the public to use electric vehicles. There are currently area. Different European countries have implemented 2,500 subscribers to the GoTo Car Sharing smartphone the LEZ concept in different ways e.g. by letting the application,13 with a €7 monthly membership fee (the cleaner vehicles access the zone or through behaviour first two months of registration are free) and a charge changing methods. Malta is considering this not only to of €0.28c per minute of drive time. Through the app, honour the European Union targets, even though this subscribers book a car and a parking in their place of is a priority within the context of this plan, but also to destination. The scheme is mostly used in Valletta, improve the quality of the air of our citizens and also to Sliema, Ta’ Xbiex, l-Imsida, the airport and Cirkewwa. preserve their health. There are currently 150 electric vehicles registered to this scheme, and 225 charging pillars are dedicated to Transport Malta (2016) identified two potential areas this EV charging network (Malta NRP, 2019). Since this (Figure 22: the capitals of Victoria Gozo, and Valletta, initiative has proven to be successful, it is planned that and surrounding areas) where congestion is already an this scheme is extended further. issue and therefore have the potential to exceed the identified targets in the future and thus need urgent

Figure 22: Key congestion hub identified in the National Transport Model (TM, 2016)

13 https://www.tvm.com.mt/en/news/car-sharing-company-surprised-by-how-much-this-service-has-caught-on-in-malta/ 50 Malta’s National Air Pollution Control Programme - 2019

attention. In the National Transport Master Plan, TM models two scenarios for the LEZ measure whereby both scenarios moderate the management of private cars entering the designated area and increase support of public transport and alternative modes. Both scenarios examine the effect of restricting the entry of vehicles into the area and this is carried out for two emission standards (Euro 1 and 2, exempting cars manufactured after the years 1996 and 2000 respectively).

Apart from systems intended to achieve similar results in terms of air quality, the LEZ could be based on a system similar to the Controlled Vehicular Access (CVA) System implemented in Valletta as part of the SUMP carried out in Malta between 2006 and 2010. The combined effect of several integrated actions, which includes the implementation of a CVA system, led to a modal shift of 10% away from the car and onto alternative modes of into ways to further consolidate existing schemes or transport (TM, 2016). combination of, including car-pooling, combined park and ride systems, feasible electric car-sharing systems, Transport Malta, in collaboration with the Environment extended scrappage schemes, and an improved public and Resources Authority, aim to undertake a study in transportation system. 2020 to look at the different options available to Malta and Gozo, and to assess which ones would deliver the The aim of this measure is to encourage people to travel desired results swiftly. The suggested study would outside peak hours, to get rid of old polluting vehicles, assess the size of a feasible LEZ within the already and change commuting behaviour. Whether the system identified potential zones to achieve the greatest should operate on a five-day traditional working week positive impact to the environment, with the greatest scenario, six days a week to include the busiest shopping benefit to citizens’ everyday lives. day of Saturday, or every day will also be looked at.

The study would involve a multi-Ministry and agency taskforce comprised of experts who would also assess 8.8 DEVELOP A NATIONAL BICYCLE what measures would best suit the situation and the STRATEGY future scenarios. The priority shall be to make this LEZ a successful system and thus the requirement Cycling is a healthy way of travelling. It does not cause to attract the citizens’ confidence that this scheme is air or noise pollution. Practicing cycling itself does not beneficial on all fronts and to avoid failure and distrust. require expensive infrastructure, albeit the necessary With the ultimate aim to induce a long-term (especially space has to be made available to ensure safe cycling. commuter) behavioural change of how people get to- and-from congested areas, which would lead to cleaner Unfortunately, cycling cannot be considered as totally air throughout the Maltese Islands. safe, especially as it has to share the same road network as for conventional modes of road transport. In 2016, The study will have to take into consideration the national statistics show that injuries sustained by current scenario on private car ownership and the cyclists amounted to 36 (out of a total 1852 casualties, impacts of the measures proposed. It may also consider in all ranges of severity, reported)14. the management of the area in phases, allowing the car owners to adjust. The underlining priority of Throughout the last decade or so, cycle lanes started introducing an LEZ shall be that it will accelerate being incorporated in the road infrastructure design for the shift towards alternative means of transport, arterial roads with the aim of making it safer for cyclists ensuring their availability, and less polluting vehicles to use the road network. There are currently 25km of on the roads. Therefore, the LEZ shall not stand on designated cycle lanes, and another 7.7km are planned its own. Other initiatives and measures shall look to be incorporated within or alongside the main road

14 https://nso.gov.mt/en/nso/Media/Salient-Points-of-Publications/Pages/Transport-Statistics-2017.aspx Malta’s National Air Pollution Control Programme - 2019 51

network, as part of ongoing and future improvements between 2006 and 2010, was an initiative with the aim of the road network. However, cycle lanes are not of reducing traffic congestion and improve accessibility interconnected, are limited in length and do not form a and air quality in that area. This strategy included the continuous safe cycling network. extension of the existing pedestrian zones, reduced parking needs in Valletta, a Controlled Vehicular Access To further promote and support cycling in Malta as (CVA) System that was a ‘pay as you go’ system and a sustainable mode of transport, the Ministry for alternative means of transport and connecting different Transport, Infrastructure and Capital Projects kick- areas of the Capital City. The Valletta Strategy led started a consultation on the National Cycling Strategy to a 10% modal shift from the use of private cars to and Action Plan in November 2018. This was prepared alternative modes of transport. From this experience, it in conjunction with Transport Malta, and most of the was noted that a SUMP cannot be developed only for measures being recommended are in accord with one locality, but rather on a regional scale, which should what is being suggested in the National Transport be defined at a functional level. Master Plan 2025 with respect to cycling, including the implementation period (2025). A new stakeholder Figure 12 clearly shows the large dependency on cars platform has been created, named Cycling Malta, which as the main mode of transport of Malta in 2010. In will be chaired by Transport Malta. This new platform fact, the stock of licensed motor vehicles has been will be bringing together the relevant stakeholders to increasing throughout the years, as shown in Figure promote the use of bicycles in Malta and to implement 23. The framework development for the introduction the National Cycling Strategy and Action Plan. and implementation of SUMPs is included in the National Cycling Strategy and Action Plan as well as in the National Transport Master Plan 2025. Following 8.9 SUSTAINABLE URBAN MOBILITY recent analysis of regional mobility and trip demand PLAN (SUMP) FOR VALLETTA the Valletta Extended Region has been developed for this framework. Since the SUMP must be created at a The aim of SUMPs is to tackle accessibility and traffic localised aspect, the two regions will have their own congestion problems at a local level. In consultation implementation plan made up of a set of policy related with local councils and other stakeholders, TM has measures. The first SUMP to start its implementation in identified a number of local transport hubs which 2016 was the Valletta Extended Region. It includes the necessitate improvement in transport mobility. This further integration of Marsamxett ferry landing place specific measure focuses on the implementation of the with the public transport network through a shuttle bus SUMP in Valletta and the neighbouring areas. route and an option analysis to connect Marsamxett ferry landing site with Central Valletta (this is discussed The Valletta Strategy, a SUMP carried out in Valletta in section 8.18). The SUMP also includes ITS applications

Stock of licensed motor vehicles

Stock of licensed motor vehicles 390 000

380 000

370 000

360 000

350 000

340 000

330 000

320 000

310 000 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 2015 2016 2017 2018

Figure 23: Stock of licensed motor vehicles (NSO, 2019) 52 Malta’s National Air Pollution Control Programme - 2019

to provide information in real time about the current 8.11 SMART PARKING SYSTEM FOR conditions of the road and vehicles using the road (this is ` VALLETTA discussed in section 8.17). Moreover, the Valletta SUMP includes the bike-sharing scheme which has already Vehicle access to Valletta is limited due to the restricted been implemented (this is discussed in Section 5.10.5). car space available, few parking spaces and limited by road pricing. Because of this, car drivers end up roaming around the city to try and find a parking spot, which 8.10 LAST-MILE DELIVERY FOR VALLETTA in turn causes congestion, pollution and a waste of time and resources. This new system will be providing Valletta consists of an increasing number of catering real-time information on the available parking spaces, establishments and boutique hotels, and is also the avoiding the need for car drivers to go around the city administrative centre of the island, therefore hosting to try and find a parking. Around 850 sensors will be a large number of offices. This means that the city installed, and this system will be integrated in the SUMP experiences an increased demand for the delivery of of Valletta15. goods within the city. Further to this, urban centres like Valletta frequently experience congestion as a result of the inefficient delivery of goods, illegal parking and air 8.12 PILOT CYCLING CORRIDORS pollution problems due to the large and high polluting vehicles. To address this issue, a new project is being Pilot cycle corridors have been selected in the main introduced in the Valletta Extended Region, the “last- ‘hub’ area based on the potential of achieving a modal mile delivery”. This consists of the delivery of goods from shift from car to other sustainable modes of transport. stores in Ta’ Qali, which are then collectively delivered Moreover, this selection was further encouraged by the to Valletta using an electric van. This will be reducing fact that the topography of the selected region consists the congestion caused by freight transport in the region of low-lying surroundings, making it easier to cycle. since the vehicle is shared for various deliveries. This The two possible pilot cycle corridors are between: in turn improves the quality of life of the residents and visitors, and reduces the impact on air quality. • Valletta and St. Julian’s and • Mosta and Mater Dei

Figure 24: Possible Pilot Cycling Corridors to Valletta in red (TM, 2016)

15 https://civitas.eu/projects/destinations/measures/smart-parking Malta’s National Air Pollution Control Programme - 2019 53

The pilot cycling corridor route St. Julian’s to Valletta will 8.14 INTRODUCTION OF ELECTRIC allow commuters to travel to Valletta and back, and will BUSES IN GOZO also allow the commuters to travel to their destination by using cycling and ferry services in combination since Gozo will be introducing six electric buses on the island this route would link to the St. Julian’s ferry landing site, which will serve as a mode of mass transportation Sliema’s ferry landing site and ta’ Xbiex/Msida ferry between the Park and Ride in Xewkija and Mġarr landing site. Harbour. The Park and Ride project will itself facilitate emission reduction from vehicles since the kilometres travelled per conventional vehicle using the Park and 8.13 DEVELOP A SHORE SUPPLY ACTION Ride would be reduced. The Park and Ride will be PLAN FOR THE TEN-T PORTS equipped with charging points for the electric buses. In November 2018, the Ministry for Gozo issued a tender Both the TM Master Plan 2025 and the National for the delivery and commissioning of six fully electric Policy Framework Alternative Fuels Infrastructure for powered buses. Transport in Malta (2018 – 2023) include considerations for shore-supply infrastructure for berthing vessels in the Maltese harbours. An action plan for the two ports 8.15 INFRASTRUCTURE INTERVENTIONS (Valletta and Marsaxlokk) will be developed to assess whether shore supply is feasible. The availability of shore Infrastructure Malta (IM) is responsible with the supply infrastructure has a number of environmental development, maintenance and upgrading of the road benefits, including the reduction of air, sea and noise network and other public infrastructure in the Maltese pollution. The implementation for such measure is Islands. Major infrastructural interventions are planned envisaged between 2016 and 2020 (TM, 2016). The to be implemented within the next decade. These MNEP carried out a feasibility study on the technology infrastructural projects will accommodate the increasing which is being reviewed due to current development in traffic flows when roads experience heavy traffic, thus the sector. reducing queuing times and alleviate congestion. As indicated in TM Master Plan, infrastructural provisions should be linked to improvements in bus service, cycling and walking infrastructure. 54 Malta’s National Air Pollution Control Programme - 2019

8.16 PUBLIC TRANSPORT QUALITY and journey times of public transport routes, improve CORRIDORS (PTQC) monitoring of operations along these corridors, traffic signal control to favour buses, improved quality of bus The current public transport system could be improved shelters, provision of real time information system by the creation of Public Transport Quality Corridors and improved service on-board buses. These in turn (PTQCs) along a selected network. Several bus improve accessibility, attracting new passengers and corridors have been identified that require further thus increasing its usage and reducing traffic congestion actions, and are listed in Table 3 below. The idea of a and air pollution. In total, 22 bus shelters were installed PTQC is to dedicate road space to public transport in different localities in Malta (Malta NRP, 2019). routes and removing obstructions, improve reliability

Public Transport Quality Corridors Implementation period

PT 1 SLIEMA – MSIDA – VALLETTA 2016 – 2020

PT 2 TARXIEN – FGURA – MARSA – VALLETTA 2016 – 2020

PT 3 MOSTA – BIRKIRKARA – MSIDA – VALLETTA 2021 – 2025

PT 4 NAXXAR – BIRKIRKARA – HAMRUN – VALLETTA 2021 – 2025

PT 5 MOSTA – BIRKIRKARA – UNIVERSITY – MSIDA 2021 – 2025

PT 6 ATTARD – BIRKIRKARA – HAMRUN – VALLETTA 2021 – 2025

PT 7 QORMI – HAMRUN - VALLETTA 2021 – 2025

Table 3: Key Corridors to be developed into Public Transport Quality Corridors (TM, 2016)

8.17 INCREASE THE USE OF INTELLIGENT and the relevant scenarios will be outlined through the TRANSPORT SYSTEMS IN TRAFFIC completion of the ITS Action Plan. It is planned that the MANAGEMENT implementation timeframe of this measure is extended to 2030. Intelligent Transport System is one of the four main components of the MODUS Project. The MODUS Project encourages a modal shift in land transportation, 8.18 IMPROVEMENT OF FERRY LANDING by making public transport more efficient and reliable. PLACES This system provides real-time information on the current conditions of the road and vehicles on the Transport Malta is currently working on the first road, with the aim of increasing the performance and phase to improve the ferry-landing sites at Sliema, improve the safety of the road network. Road users Valletta, Marsamxett and Cottonera. Upgrades include can be notified by various methods, including message the inclusion of ferry landing places with the public signs, radio and internet, and consequently they can transport network and alternative modes of transport adapt their journey at short notice, according to the and the improved provision of information or updates notifications provided. This measure also aims to further on bus and ferry schedules. The second phase of this improve the ITS for public transport, by increasing measure, which shall start in 2020, will entail further road-side cameras and incorporating them into the studies on additional landing sites so as to further new National Traffic Control Centre, by installing more extend the service. Sea connections will further extend Dynamic Message Signs (DMS) to notify road users and a to Marsaxlokk, Marsascala, St. Paul’s Bay, St. Julian’s, web-based application providing real-time information Mellieha, and other sites (Ministry for Finance, 2019). journey planning information for public transport. Phase two of this measure is currently being deployed Malta’s National Air Pollution Control Programme - 2019 55

8.19 FAST FERRY LINK BETWEEN MALTA a larger fleet consisting of no ICE vehicles has been AND GOZO determined. The next steps will involve the utilisation of such ‘baseline data’ to arrive at possible cut-off dates In addition to the measure discussed above, there are for the importation of conventionally fuelled vehicles. ongoing discussions for a fast ferry link between Malta and Gozo. This would reduce a number of vehicles from Besides increasing the number of charging points the roads and would at the same time encourage the use around Malta and Gozo, cheaper electricity tariffs of a collective transport system for Gozitans who need (€0.1298 per unit) will be introduced when individuals to go to Valletta or in the vicinities. The implementation charge their electric vehicles within their residential period for the fast ferry link is being envisaged from homes (Ministry for Finance, 2019). 2020 to 2030. 8.20.1 Electric Vehicles (taxis and Government fleet)

8.20 INITIATIVES RELATED TO In addition to current efforts related to establishing a cut-off date for the importation of Internal Combustion ELECTRIFICATION OF THE FLEET Engine (ICE) vehicles, and in the light of the recent Climate Change motion, it is being proposed that the By the end of 2015, Malta had 246 registered electric Maltese Government will set a date by when taxis will cars and some 439 hybrid vehicles which result in lower become electric. emissions at the point of use. The take up of hybrid and electric cars in Malta is therefore behind European In addition, Government vehicles are also to become averages and more efforts are needed to incentivise the fully electric by a set date, so as to lead by example. uptake of these low and zero-emission vehicles.

Towards the end of 2017, the Maltese Government 8.21 INCREASE IN FINANCIAL GRANTS decided that a cut-off date for the importation and registration of conventionally fuelled vehicles on FOR MORE EFFICIENT INTERNAL the Maltese Territory needs to be established and COMBUSTION ENGINES (ICE) targets need to be set. This is similar to what other EU Countries are doing with respect to the phasing To ensure a higher uptake of cleaner vehicle technology, out of conventionally fuelled vehicles. So as to assess it is being proposed that financial grants for the and move forward towards the achievement of such purchasing of cleaner ICE vehicles when the older targets, a committee was set up by the Minister for the vehicle is scrapped will be increased. Such a measure Environment, Sustainable Development and Climate will eventually lead to a rejuvenation of the age of the Change which is chaired by ERA and comprising fleet whereby more efficient technology of the newer members from MECP, EWA, TM, MTIP and MRA. vehicles will lead to a reduction in emissions. The current system is considered to be adequate, whereby The e-CAR committee has been assigned the task of: the lower the emissions of the new vehicle, the higher is the grant. Government might also consider carrying • Drafting the consultation document on the cut-off out a financial feasibility study to verify at which level date for the implementation of all ICE imports in the grant will truly incentivise a phasing out of older Malta; vehicles. The grant should also be provided even if the user opts not to purchase a new vehicle. • Conducting close consultations with policy makers and relevant stakeholders involved; • Submitting recommendations to Minister for 8.22 REFORM OF PUBLIC SERVICE Cabinet approval; GARAGES

While carrying out its task, the committee needs to Transport Malta regulates the registration and licensing assess the different impacts that such a cut-off date of garage hire (chauffeur-driven) vehicles, vehicles may have on various fronts, including economic, for hire or lease, and operators of such vehicles under infrastructural, environmental and social impacts. one licensing regime termed the Public Service Garage Permit System. The current framework lacks service A study has been commissioned to assist the committee standards that should be expected from operators, in such an assessment through which informed drivers and their vehicles, and needs to be updated to decisions on a national level may be taken in this regard. cater for new technological developments (Transport Work to date has involved the analysis of statistical Malta, n.d.). information, together with national and EU- wide studies where the natural progression towards having 56 Malta’s National Air Pollution Control Programme - 2019

The reform of the public service garage regime includes • Repair and maintenance of small vehicles, vessels, changes that will improve air quality. These include aircraft and other transport equipment exceeding 3 the introduction of a maximum age limit after the date tonnes/unit on average; of registration of 10 years for leased vehicles. This is • Installations emitting VOCs considered to be positive from an air quality perspective since these cars are used for long hours during the day, therefore produce more emissions than a normal passenger car. In the case of leased taxi/chauffer-driven passenger vehicles, the maximum age limit is being set at 15 years.

INDUSTRY

8.23 ENVIRONMENTAL AUTHORISATIONS REGULATIONS

The ERA is currently working on draft regulations related to the authorisation of specific activities which give rise to emissions to the air, water or land. These regulations provide a framework for environmental authorisations laying down the thresholds, procedure and guidance for the Authority to authorise and regulate any activity, operation, intervention, project or land use that may have an effect on the environment. The legislation covers activities and operations which are currently not covered by the EU or local legislation, A set of operating permit conditions will be determined however their cumulative effect is considered to be by the Authority following submission of an application important to air quality and national emissions. by the operator. Provisions include operating conditions on emission to air, effluent discharges, emissions to land, The activities which will be covered by these waste storage, acceptance, handling and treatment. Regulations, which might give rise to emissions to the The operator will be obliged to report to the Authority air, and for which an authorisation is required, include, according to its monitoring programme. The Authority amongst others: can direct the operator to improvement programmes, depending on the progress noted during inspection and • Industrial Zones, Industrial Complexes, SMEs and enforcement activities. SME Complexes; • Crematoria; The adoption and entry into force of the Regulations is envisaged during the period 2020 onwards. • Manufacture of refined petroleum products; • Wholesale and retail of solid, liquid and gaseous fuels and related products; 8.24 A MORE SUSTAINABLE CONSTRUCTION INDUSTRY • Fuel terminals; • Storage and Distribution of Petrol from Terminals Malta Enterprise will be incentivising operators in the to Service Stations; industrial sector to scrap their old polluting machinery and invest in environment friendly machinery that • Retail sale of fuel, operation of fuel road tankers; decreases pollution. The grant is of a maximum • Manufacture of asphalt and concrete products; of €200,000. In addition, operators who invest in additional machinery to reduce the negative impact • Quarrying operations, cutting, shaping andfinishing on the environment will also be eligible for this grant of stone; (Ministry for Finance, 2019). • Manufacture of pharmaceutical products and pharmaceutical preparations excluding production of APIs and Intermediates excluding repackaging only; Malta’s National Air Pollution Control Programme - 2019 57

AGRICULTURE 8.26 AMENDMENT TO S.L. 549.66 FOR THE UTILISATION OF SPENT Ammonia emission reduction measures from the MUSHROOM SUBSTRATE agricultural sector In 2018, an amendment was made to S.L. 549.66 on As per Annex III of the NEC Directive, every Member the Nitrates Action Programme Regulations whereby State shall set forth emission reduction measures it included provisions for the use of soil conditioners, related to the agricultural sector. In addition to the which is used to improve the soil’s properties. If spent agricultural measures described in Section 5, further mushroom substrate fulfils the requirements of measures are envisaged for implementation in the these provisions, this substrate could be used as soil National Agricultural Policy (NAP) for the Maltese conditioner. Islands (2018-2028). The NAP was developed following a strategic review on the sector, carried out in 2013. The review focused on a detailed economic analysis, on the relevant documentation and in consultation with 8.27 DEVELOP A SOIL ACTION PLAN the relevant stakeholders. The NAP was established with the aim of making the Maltese agricultural sector Various soil conservation measures identified in the a sustainable one. The following measures, stemming Agricultural Policy in the National Biodiversity Strategy from the NAP, shall likely conduce to a reduction in the and Action Plan will be incorporated in a Soil Action formation of nitrates, which would lead in a reduction of Plan that is required to address these goals in terms of ammonia emissions. how to mitigate the threats to Maltese soils and adopt measures aimed at integrated soil conservation. The Soil Action Plan together with other national relevant 8.25 THE CREATION OF SUSTAINABLE policies shall contribute towards the requirements of the Convention to Combat Desertification (UNCCD) to ALTERNATIVE STRATEGIES RELATED develop desertification national action programmes. TO LIVESTOCK WASTE MANAGEMENT INCLUDING The development of the Soil Action Plan involves the TREATMENT OF BY-PRODUCTS pertinent stakeholders, including but not limited to, measures that: This measure includes the implementation of the Agricultural Farm Waste Management Plan and the a. Support initiatives at the field level which contribute identification of possible solutions to turn farm waste towards improved soil quality thereby improving into a resource. The agricultural sector is encouraged its moisture retention ability as well as its nutrient through the NAP to transform waste into resources, content; thus moving towards a circular approach. As mentioned b. Promote the use of steam soil sterilizers for the in Section 5.16, the Governance of Agricultural Bio- sterilization of farmland that could assist in the Resources (MECP) was set up in 2017 and its overall reduction of soil borne diseases and nematodes; mission is to sustainably manage agricultural bio- resources in a manner that supports the Maltese c. Improve knowledge on Maltese soils by updating agricultural sector. GAB is also in charge of updating, the available pedological data; co-ordinating and implementing the Agricultural Waste d. Incentivize processes and practices on the build- Management Plan for Malta. up and maintenance of soil organic matter, the enhancement of soil biodiversity, the reduction of The GAB is currently working on a major research project soil erosion, compaction and contamination; on the sustainable management of animal manure and slurry, turning it into clean water. This project should e. Assess the impact of correct application of manure avoid the disposal of thousands of tonnes of farmyard and other organic matter in Malta’s soils particularly waste every year. As a result of reusing manure (and not on the level of nitrates in order to ensure effective left piled up on the fields), it would lead to less ammonia implementation of the Nitrates Directive and align emissions since manure is not subjected to ammonia the plan with the farm waste management plan. volatilisation. 58 Malta’s National Air Pollution Control Programme - 2019

ENERGY DEMAND while the share of advanced biofuels must increase to at least 3.5% by 2030 (EWA, 2018).

8.28 PROJECTS IN PRIMARY WATER NETWORK 8.30 DEVELOPMENT OF RESEARCH & INNOVATION STRATEGY FOR The Water Services Corporation is the authority ENERGY AND WATER responsible for the supply of water across Malta and Gozo, and takes care of the disposal of waste water. MCST is expected to develop a new national Research & Groundwater sources in Malta are not enough to meet Innovation (R&I) strategy by the end of 2020, covering the current demand, therefore Reverse Osmosis is used the period 2021-2030, with smart specialization to convert seawater into high-purity drinking water. The remaining a key component. This implies that a bottom- converted sea water is then blended with groundwater. up approach, focused on stakeholder consultations, will There are three Reverse Osmosis plants; in Pembroke, be the prevalent approach for selecting future areas in Cirkewwa and in Ghar Lapsi. There are currently of investment for R&I. The inclusion or otherwise of ongoing works at the Pembroke Reverse Osmosis Plant, low-carbon technologies in the next national general where a 9.5km tunnel is being drilled from the plant R&I strategy covering the period up to 2030 will to the Ta’ Qali Reservoirs. This project will improve depend on the outcome of the Smart Specialisation and the overall water quality and will also improve the Entrepreneurial Discovery Process. operation efficiency and environmental sustainability. This means that less water is pumped and therefore In order to foster research & innovation specifically saving electricity generated for pumping. in the area of energy and low-carbon technologies, a separate strategy for R&I specific to the energy and water sectors is expected to be developed by the 8.29 BIOFUELS SUBSTITUTION beginning of 2020 by EWA. This new strategy will aim ` OBLIGATION (2021-2030) to boost research and innovation efforts by the public and private sectors in the next decade. Further to Section 5.24, and in line with Article 25 of the recast of Directive 2009/28/EC on the promotion The National Energy Policy (2012) focused on the RES of the use of energy from renewable sources, Malta will in terms of R&I purposes, specifically on technologies extend the substitution obligation to 2030. The share relevant to solar and marine resources. This objective of renewable energy supplied for final consumption in is also reflected in Malta’s National Renewable Energy the road transport sector must increase to at least 14%, Malta’s National Air Pollution Control Programme - 2019 59

Action Plan (2017), where the R&I is being further The new WtE facility will therefore reduce non-GHG encouraged in the development and commercialisation emissions from landfill, whilst emissions from the stack of RES technology, also focusing on the solar and marine will be controlled to minimise the effect of emissions on resources. residents of nearby settlements. Once in operation, the facility will be regulated by ERA and will operate under the emission requirements of the Industrial Emissions 8.31 WASTE TO ENERGY FACILITY Directive and thus according to the Best Available Techniques (BAT). In 2017, the Government decided that the Waste-to- Energy (WtE) facility was to be an integral option to the long-term sustainable management of Municipal Solid 8.32 FINANCIAL INCENTIVES TO Waste. The concept of the WtE facility is to limit the rate INCREASE THE USE OF RENEWABLE of landfilling and recover the energy produced by the ENERGY SOURCES AND PROMOTE remaining fraction of waste that is beyond the targets. ENERGY EFFICIENCY Even if EU 2020 targets are achieved (MESDC, 2018), (which are to recycle 50% of paper, plastics, metal and The Government is extending already-existing support glass waste from households by 2020, and to allow only schemes beyond 2020 with the aim of increasing the 35% of biodegradable municipal waste, based on 2002 use of renewable energy sources mainly through solar levels, to be landfilled), it is acknowledged through PV and solar water heaters (SWH) (NECP, 2018). Malta’s Waste Management Plan (2014-2020) that a considerable amount of residual waste would still need to be landfilled or further treated through a WtE facility. 8.32.1 Financial support schemes for Solar PVs The development of a WtE facility is being earmarked as a major project in Malta (MESDC, 2018). The existing schemes, focusing on a grant and operating aid for households, will be extended beyond 2020 with the aim of increasing the deployment of renewable energy. The Government also intends to design schemes to encourage battery integration in PV systems where appropriate.

8.32.2 Solar Water Heaters Scheme

Further schemes on solar water heaters in the residential sector will be introduced post-2020.

Apart from solar water heaters, the scheme will also target heat pump water heaters in the residential sector. Malta intends to provide support for the installation of 800 unit per year by 2030.

8.32.3 Energy efficiency: electricity tariffs

Electricity tariffs are intended to promote energy efficiency among consumers. Residential electricity tariffs post 2020 shall continue to incorporate a built-in mechanism which will incentivise end-users to reduce consumption below an established threshold and deter high consumption. The objective of this measure is to reach the 2030 energy efficiency contribution. The implementation period for this measure is 2021 – 2030. 60 Malta’s National Air Pollution Control Programme - 2019

8.32.4 Support scheme for Services and Industry

Services and Industry will be offered support schemes as from 2021 to promote and address energy efficiency investment.

8.32.5 Energy Efficient Street Lighting

Around 33,000 lamps from the present lighting luminaries are expected to be replaced by energy efficient LEDs. This project has started in 2018 and is expected to be finalised by 2022. Malta’s National Air Pollution Control Programme - 2019 61

STAKEHOLDER AND PUBLIC CONSULTATION

09 62 Malta’s National Air Pollution Control Programme - 2019

9.1 STAKEHOLDER CONSULTATION 9.2 PUBLIC CONSULTATION

The NAPCP was finalised following extensive A public consultation on the aims and objectives of consultations carried out with various authorities, the NAPCP was held during the period between 22nd Ministries and public bodies. The bodies consulted were March and 19th April 2019 (consultation brief can be the following: found in the following link: https://era.org.mt/topic/napcp/). • Transport Malta The submissions received were taken into consideration • Energy and Water Agency during the drafting of the NAPCP and are outlined in • Agricultural Directorate Annex 3. • Agriculture and Rural Payments Agency The draft NAPCP was available for public consultation • Diversification and Competitiveness Directorate for a seven-week period from 22 November 2019 to 24 January 2020. The feedback received is outlined in • Governance of Agriculture Bio-Resources Annex 4. Where relevant, the programme was amended • E-Cars Committee to take into consideration the comments received. • Malta Resources Authority • Environmental Health Directorate • Eco-Gozo • Malta Public Transport • Ministry for Finance

In addition, the authorities and Ministries directly involved in the implementation of the measures are outlined in Annex 2. Malta’s National Air Pollution Control Programme - 2019 63

POLICIES AND MEASURES SELECTED FOR ADOPTION IN THE ‘WAM’ SCENARIO

10 64 Malta’s National Air Pollution Control Programme - 2019

The following measures are selected for adoption in the WaM scenario.

Measure No. Name of PAMs/package of PAMs

5.6 Vehicle tracking for public transport

5.7 Facilitate the development of a real-time multi-modal journey planner

5.10.5 Bike sharing schemes

8.1 Free school transport

8.2.1 Tallinja Capping System

8.2.2 IoScoot: An electric motorbike sharing service

8.2.3 Tallinja Ferry Service

8.2.4 TD Plus

8.3a Free Public Transport fares for youths, students and elderly persons (phase 1)

8.3b Free Public Transport fares for youths, students and elderly persons (phase 2)

8.3c Free Public Transport fares for youths, students and elderly persons (phase 3)

8.4 Develop and incentivise schemes to promote multiple occupancy

8.5a Review of Malta’s National Electro-Mobility Action Plan (MNEAP) (phase 1)

8.5b Review of Malta’s National Electro-Mobility Action Plan (MNEAP) (phase 2)

8.6 Car sharing scheme

8.7 Study the introduction of Low Emission Zones

8.8 Develop a national bicycle strategy

8.9 Sustainable Urban Mobility Plan (SUMP) for Valletta

8.10 Last mile delivery for Valletta

8.11 Smart parking system for Valletta

8.12 Pilot cycling corridors

8.13 Develop a shore supply action plan for the TEN-T ports

8.14 Introduction of electric buses in Gozo

8.15 Infrastructure interventions

8.16 Public Transport Quality Corridors (PTQC)

8.17a Increase the use of Intelligent Transport systems in traffic management (phase 1)

8.17b Increase the use of Intelligent Transport systems in traffic management (phase 2)

8.18a Improvement of Ferry Landing Places (phase 1) Malta’s National Air Pollution Control Programme - 2019 65

Measure No. Name of PAMs/package of PAMs

8.18b Improvement of Ferry Landing Places (phase 2)

8.19 Fast ferry link between Malta and Gozo

8.20 Initiatives related to electrification of the fleet

8.20.1 Electric Vehicles (taxis and Government fleet)

8.21 Increase in financial grants for more efficient internal combustion engines (ICE)

8.22 Reform of Public Service Garage

8.23 Environmental Authorisation Regulations

8.24 A more sustainable construction industry

The creation of sustainable alternative strategies related to livestock waste management including 8.25 treatment of by-products

8.26 Amendment to S.L. 549.66 for the utilisation of spent mushroom substrate

8.27 Develop a Soil Action Plan

8.28 Projects in primary water network

8.29 Biofuels Substitution Obligation

8.30 Development of R&I Strategy for Energy and Water

8.31 Waste to Energy facility

8.32.1 Financial support schemes for Solar PVs

8.32.2 Solar Water Heaters Scheme

8.32.3 Energy Efficiency: electricity tariffs

8.32.4 Support scheme for Services and Industry

8.32.5 Energy Efficient Street Lighting

Table 4: PAMs/Packages of PAMs selected for adoption in the 'WaM' Scenario

Emissions projections for the measures in Table 4 were The road transport model developed by EWA also carried out based on the activity data available, and are estimates the stock of electric vehicles and plug-in specified below. hybrid electric vehicles, which is expected to increase

based on the new EU regulations imposing stricted CO2 ROAD TRANSPORT: emission standards for passenger cars and light commercial vehicles post-2020. The fleet of brand This sector involved the compilation of a road transport new vehicles purchased in Malta tends to reflect that model (by the Energy and Water Agency) which includes available on the EU market. the change in fleet composition with time. The policy s c e n a r i o o f t h i s m o d e l t a k e s i n t o c o n s i d e r a ti o n t h e ENERGY DEMAND: change in kilometres travelled as a result of a number of sustainability and road infrastructure measures. The quantification of emission reduction from other sectors was possible where projections on fuel used 66 Malta’s National Air Pollution Control Programme - 2019

(sourced from EWA) were available. Measures projected a. Implement a number of road infrastructure under this category are measures 8.28 to 8.32.5 projects aimed at removing traffic bottlenecks (excluding measure 8.31). at nodes and urban communities (referred to as RD1 to RD6 in the Masterplan). A number of WASTE TO ENERGY FACILITY: indicators were used to assess the BCR, ENPV and EIRR for RD3, RD5 and RD6, namely: Data on the quantification of the impact of this measure peak hour travelled distance for private and (section 8.31) was obtained from MECP. public vehicles, modal split, peak hour light vehicles and public transport average speed,

Other measures not modelled at the time of writing: cost of congestion, cost of accidents, CO2 and air pollutant emissions (using Tier 1 emission The calculation of emission reductions related to specific factors, fuel consumption per km and distance measures was not possible when detailed information travelled by vehicle per vehicle type). was not available at the time of assessment, since the b. Implement two corridors for public transport project would be at its early stages. Measures that are for high passenger load, journey planners, not modelled are measures 8.23, 8.24, 8.25, 8.26 and real-time vehicle tracking systems, improving 8.27. interchange facilities. c. Improve frequency of ferry from 30 minutes to 10.1 ASSESSMENT OF ROAD TRANSPORT every 20 minutes. MEASURES d. Implement a cycling corridor from Valletta to Sliema to reach 35km of corridors. ROAD TRANSPORT: e. Implement a low emission zone in the Valletta- As indicated earlier on in the NAPCP, the focus of this Sliema hub which charges €1 for entry for programme is on traffic measures. An assessment of vehicles which are over 20 years old and which the various policy scenarios considered in the National are pre-EURO and EURO I (model predicts that Transport Masterplan 2025 has been carried out at the private vehicles will pay 19% of the fee, and time of issuing of the plan in December 2016, with the heavy vehicles will pay 39% of the fee). base year of assessment being 2014. The following is a summary of the outcome of the assessment, as laid Carpooling and High-occupancy vehicle lanes that down in the National Transport Masterplan, 2025. This increase current 1.2 pax/veh to 1.3 pax/veh. assessment forms the basis of which traffic measures were selected for adoption in the WaM scenario: 4. Do-Something 2 (DS2):

Three economic indicators were used for this a. Implement RD1, RD2, RD3, and RD6. R6 and R3 assessment: were preferred over R4, as these were located in busy urban areas, and these were designed 1. Benefit-cost ratio (BCR), which provides a ratio of specifically to aid cycling and walking. discounted benefits and costs. b. Implement seven corridors for public transport. 2. The Economic Net Present Value (ENPV), which c. Improve frequency of ferry from 30 minutes to provides the total amount of benefits and costs at every 15 minutes. the end of a project’s life span (in this case 2050), accounting amongst other factors inflation with d. Implement a cycling corridor from Sliema to time. Valletta to Fgura that reaches 42km. 3. The Economic Internal Rate of Return (EIRR), works e. Implement a low emission zone in the Valletta- along with the ENPV. However, this indicator takes Sliema hub which charges €1 for entry for into account the initial investment. vehicles which are over 15 years old and which are pre-EURO, EURO I or II (model predicts The following four options were studied: that private vehicles will pay 40% of the fee, and heavy vehicles will pay 60% of the fee). 1. Do-nothing scenario f. Carpooling and High-occupancy vehicle lanes 2. Do-minimum scenario: This scenario modelled that increase current 1.2 pax/veh to 1.4 pax/ measures which were already implemented by the veh. base year, at measures committed up to 2020. g. Replace 12 out of 33 buses in Gozo with 3. Do-Something 1 (DS1): electric buses. Malta’s National Air Pollution Control Programme - 2019 67

h. Fast ferry between Malta and Gozo. This currently is not effective as DS1 and DS2, therefore it was used does not exist, therefore the demand was induced as a baseline. The BCR value was above 1 for both DS1 as a reduction of 300 vehicles at peak hour. Freight and DS2, meaning that both options provided more vehicles would in turn be transported once daily benefits than costs; with the Do-Something 2 option (per direction) that results in a decrease of 36 resulting in a higher benefit ratio. The ENPV values for medium/heavy goods vehicles per day. both options were positive, and thus both are expected to bring benefits. However, the Do-Something 2 option The indicators used for DS1 and DS2 are the following: had a higher value, thus it is expected to bring more benefit. Both scenarios bring a positive value to the • Peak-hour travelled distance [vkm] – number of EIRR, however, the EIRR value for Do-Something 2 is private vehicles in link and length of link significantly higher than that of Do-Something 1. • Modal split – percentage of vehicle type use In conclusion, the combination of the three economic • Peak-hour travelled distance [pkm] – number of indicators shows that Do-Something 2 provides a public and private vehicles in link and length of link greater benefit than Do-Something 1. • Peak-hour LV and PT average speed [km/h] – ratio In early 2019, Transport Malta performed an update of travelled distance and time vehicle in use of the national transport model. The base year was • Cost of congestion - cost of lost time compared to updated from 2014 to 2017, taking into consideration speed at free flow and cost of consumption at idle all changes in infrastructure, public transport systems, land use patterns and transport policies since 2014. • Cost of accidents – uses number of km driven vs a Following this update, the modelling of future scenarios historical figure of accidents/km was also performed for 2020, 2025 and 2030, taking

• Environmental externalities: CO2 and Air Pollution into consideration the demand forecast, for two supply Emissions, using Tier 1 emission factors, fuel scenarios which are used as a basis to analyse future consumption per km and distance travelled by transport interventions: vehicle per vehicle type. • Do-Nothing scenario: a reference scenario The following table summarises the outcome of the which includes all the recently implemented and study: committed developments up to 2018; • Do-Something scenario: includes the road The Do-Nothing scenario delivered the least economic infrastructure projects and sustainability and environmental benefits, and was therefore interventions planned up to 2020, 2025 and 2030. discarded. The Do-Minimum scenario showed that it

Do-Something 1 (€m) Do-Something 2 (€m)

Socioeconomic benefits 1,626.68 2,814.55

Congestion time savings 1,282.43 2,161.28

Consumption at idle savings 96.69 161.89

Externalities - environmental costs savings 32.31 63.14

Externalities - accidents savings 215.25 428.24

Operation and maintenance costs -159.98 -150.91

Investments (including RD1 and RD2) -474.64 -401.67

ENPV (€M) 992.06 2,261.97

EIRR (%) 12.94 24.53

BCR 2.56 5.0

Table 5: Summary of analysis of costs and benefits for the Do-Something 1 and Do-Something 2 scenarios 68 Malta’s National Air Pollution Control Programme - 2019

proposed to implement this measure in 2020, rather Sustainability interventions are aimed at improving than 2025. the efficiency of the transport system and including a number of measures building on the DS2 2014 Package 2 – Measures not modelled at the time of scenario, and including additional measures which writing are further described in Chapter 8. The resultant reduction in annual vehicle kilometres as a result of the The second package of measures which is being implementation of transport measures could not be reported will be assessed in 2020, when the Transport quantified for all measures. This is due to the fact that Masterplan is due for mid-term review. This assessment the relevant information was not available at the time of will be informed by an updated National Household modelling, and specific data gathering exercises and/or Travel Survey which will provide valuable updated studies are necessary as input to the transport model. information as input data to the model. Transport Consequently, it was not possible to calculate emission measures that are not modelled are measures 8.2.1, savings from each measure, however emissions savings 8.2.2, 8.2.3, 8.4, 8.5, 8.6, 8.8, 8.9, 8.10, 8.12, 8.13, 8.14, could be calculated for one ‘package’ of measures as 8.20, 8.20.1, 8.21 and 8.22. follows: 10.2 PROJECTIONS FOR THE WAM Package 1 – Measures modelled by Transport Malta SCENARIO

The modelling exercise carried out by TM in February Table 6 below displays Malta’s emission reduction 2019 quantified the reduction in vehicle km through commitments for 2020 and 2030 for NO , NMVOC, the implementation of Measures 5.6, 5.7, 5.10.5, 8.1, x SO2 and PM2.5, and the projected emissions of these 8.3, 8.11, 8.15, 8.16, 8.17, 8.18, 8.19. Measure 8.7 was pollutants for years 2020 and 2030, taking into account modelled for 2025 and 2030 as per DS2 conditions the WaM scenario. outlined earlier on in this Chapter. However, it is being

2017 emissions 2020 ceilings Projections for 2030 ceilings Projections for Pollutants in kt in kt year 2020 in kt in kt year 2030 in kt

NOX 5.37 5.33 5.25 1.93 4.47

NMVOC 3.45 2.95 3.07 2.8 2.6

SOX 0.63 2.76 0.11 0.6 0.13

NH3 1.13 1.4 1.19 1.11 1.18

PM2.5 0.32 0.55 0.32 0.37 0.3

Table 6: Emission projections for NEC pollutants for 2020 and 2030 considering the "With Additional Measures" scenario as compared to 2020 and 2030 ceilings of the NEC Directive

The projected emissions for the WaM scenario Use including Fungicides’ sector are overestimated. demonstrate that SO2 and PM2.5 will be in compliance ERA is working to improve this sector with a view to also with the emission reduction commitments as set for improve projected emissions. Once the methodology is 2020 and 2030. improved, projections for NMVOC will be revised.

NH3 emissions are projected to be compliant with the Although the WaM scenario focused on the major

2020 ceiling. However, a minor non-compliance of sources of NOx emissions, the reduction between the 0.07kt with the 2030 ceiling is being projected. A slight two scenarios was not sufficient to reach the emission increase of 0.02kt can be noticed beyond 2020 for the reduction commitments. The major contributors to projected emissions of SO2. This increase is due to the NOx projected emissions in 2030 are road transport fast ferry service (refer to section 8.19). (41.7%), followed by aviation (17%), manufacturing industry and construction (14.4%), public electricity The projected NMVOC emissions in the WaM scenario and heat production (8.6%), commercial, institutional exceed the 2020 emission reduction commitment, and residential (7.6%) and others (national navigation, however, as per comment made in Section 7.1, there is waste, plant production and agricultural soils sectors). a possibility that emissions from the ‘Domestic Solvent Malta’s National Air Pollution Control Programme - 2019 69

ASSESSMENT OF HOW SELECTED POLICIES AND MEASURES ENSURE COHERENCE WITH PLANS AND PROGRAMMES SET UP IN OTHER RELEVANT POLICY AREAS

11 70 Malta’s National Air Pollution Control Programme - 2019

The selected policies and measures were assessed in The draft NECP has been an important reference during the light of coherence with the following: the drafting of the NAPCP. All measures outlined in the draft NECP have been taken into consideration when AIR QUALITY OBJECTIVES developing both WM and WaM emission projections, and during the selection of the measures themselves The main challenge for ambient air quality in the in the context of the NECD. Other important national Maltese Islands is road transport. Malta had registered policy documents are the National Transport exceedances of the NO2 hourly limit value in 2011 and Masterplan for 2025, and the Malta National Electro-

PM10 daily limit value in 2010 in the agglomeration, Mobility Action Plan which was given due importance more specifically from the traffic site. For this reason, as a result of road transport being the major contributor an air quality plan was designed and published by the to NOx emissions in Malta. then MEPA in 201016. A general assessment of possible positive and negative Since then no exceedances of any pollutant regulated impacts of these measures was carried out, and the by Directives 2008/50/EC and 2004/107/EC have measures which were thought to deliver most benefit to been recorded, however the PM10 and NO2 levels in the the reduction of NEC pollutants were selected. In terms same traffic site are too close for comfort. It is therefore of any negative impacts, there is no specific measure evident that the focus of future measures is to be on which is thought to negatively impact any of the NEC road transport, especially in areas with heavy traffic. pollutants, however a more detailed impact assessment To this effect, the measures included in the NAPCP might be necessary so as to confirm this. have been devised taking into consideration the Air Quality Plan of 2010, whilst performing an update of In terms of the effect of the PaMs on other national those measures in consultation with Transport Malta, policies, a general assessment has also been carried which is the authority responsible for road transport out in this respect. There is no specific measure in the in Malta. The update has taken into consideration new NAPCP which is thought to effect other policies in a information available since 2010, such as traffic flow negative manner. demand, measures implemented and measures for which a commitment has been made. In this way, it was The Energy and Water Agency is working on the ascertained that the measures included in the NAPCP Strategic Environment Assessment (SEA) of the NECP. will also benefit ambient air quality objectives, with a Conclusions emanating from this assessment will also particular focus on pollutants generated by road traffic. provide information on the environmental benefits for measures which are common for both plans.

OTHER PLANS AND PROGRAMMES

A review of all national policies which might have an impact on air emissions has been carried out as a basis for the drafting of Malta’s NAPCP. Measures which could contribute to a reduction in any of the NEC pollutants has been included and classified as a ‘WM’ or WaM’ policy measure (where applicable), depending on a number of factors. Such policies include transport, energy, climate change and agricultural policies. The relevance of the measures to their respective national policy are outlined in Annexes 1 and 2.

16 https://era.org.mt/wp-content/uploads/2019/05/AQ-Plan.pdf Malta’s National Air Pollution Control Programme - 2019 71

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Annex 1: 'WM' Scenario

Measure Relevant Implementation Authorities responsible for Name of PaMs no. national policy period implementation

Shift to ultra-low sulphur 5.1 2004 Enemalta Corporation fuel in power plants Reform in the power 5.2 2015 Enemalta Corporation generation sector Closure of Marsa Power 5.3 2015 Enemalta Corporation Station

5.4 The ban of leaded petrol 2003

Ministry for Infrastructure, 5.5 Public transport reform 2011 Transport and Communications Transport Malta; Vehicle tracking for Public 5.6 2017 Ministry for Transport, Transport Infrastructure and Capital Projects Facilitate the development Transport Malta; Transport Master 5.7 of a real time multi-modal Ministry for Transport, Plan 2025 journey planner Infrastructure and Capital Projects Increase roadside checks Transport Malta; Transport Master 5.8 and roadworthiness 2016-2020 Ministry for Transport, Plan 2025 testing Infrastructure and Capital Projects Transport Malta; Transport Master 5.9 The Kappara Junction 2016-2018 Ministry for Transport, Plan 2025 Infrastructure and Capital Projects Malta National Electro-Mobility Platform; Transport Malta; 5.10.1 The scrappage scheme 2010 – Ministry for Transport, Infrastructure and Capital Projects

Malta National Electro-Mobility Platform; Transport Malta; 5.10.2 Gas conversion scheme 2013 – Ministry for Transport, Infrastructure and Capital Projects

Grants and schemes on Malta National Electro-Mobility the purchase of new Malta National Platform; environment friendly 5.10.3 Electro-Mobility 2016 – Transport Malta; vehicles and to encourage Action Plan 2013 Ministry for Transport, the use of two-wheeled Infrastructure and Capital Projects vehicles 74 Malta’s National Air Pollution Control Programme - 2019

Annex 1 cont.

Measure Relevant Implementation Authorities responsible for Name of PaMs no. national policy period implementation

Malta National Electro-Mobility Incentives for the Malta National Platform; 5.10.4 purchase of electric and Electro-Mobility 2011 – Transport Malta; hybrid vehicles Action Plan 2013 Ministry for Transport, Infrastructure and Capital Projects Malta National Electro-Mobility Platform; Transport Master 5.10.5 Bike sharing schemes 2016 - 2030 Transport Malta; Plan 2025 Ministry for Transport, Infrastructure and Capital Projects Promoting multiple Transport Malta; Transport Master 5.10.6 options not to travel 2016 – Ministry for Transport, Plan 2025 during peak hours Infrastructure and Capital Projects Environment and Resources Authority; 5.11 Environment Permitting N/A 2010 – 2019 Ministry for the Environment, Climate Change and Planning Code of Good Fertiliser plan and Ministry for the Environment, 5.12 Agricultural Practice 2001 – application Climate Change and Planning 2001 Code of Good Ministry for the Environment, 5.13 Manure storage facilities Agricultural Practice 2001 – Climate Change and Planning 2001 Code of Good Ministry for the Environment, 5.14 Animal housing Agricultural Practice 2001 – Climate Change and Planning 2001 Code of Good Livestock feeding Ministry for the Environment, 5.15 Agricultural Practice 2001 – strategies Climate Change and Planning 2001 Subsidiary Legislation 497.22: Ministry for the Environment, The Governance of Governance of Climate Change and Planning; 5.16 Agricultural Bio- Agricultural Bio- 2017 – The Governance of Agricultural Resources Agency resources Agency Bio-Resources Agency (establishment) order National Energy Provision of professional 5.17 Efficiency Action 2014 - The Energy and Water Agency advice to households Plan

Replacement of National Energy The Energy and Water Agency; 5.18 Appliances in Vulnerable Efficiency Action 2018 - LEAP centre within Foundation for Households Scheme Plan Social Welfare Services Malta’s National Air Pollution Control Programme - 2019 75

Measure Relevant Implementation Authorities responsible for Name of PaMs no. national policy period implementation

Exploit all reasonable The Energy and Water Agency; potential indigenous RES 5.19 2010 – 2020 Regulator for Water and Energy through PV technology Services deployment Feed-in tariffs scheme The Energy and Water Agency; 5.20 (electricity generated from 2010 – 2020 Regulator for Water and Energy solar PV installation) Services Competitive bidding The Energy and Water Agency; process for PV systems 5.21 2017 – 2020 Regulator for Water and Energy equal or larger than 1 Services MWp The Energy and Water Agency; 5.22 PV grant schemes 2009 – 2018 Regulator for Water and Energy Services The National Solar Water Heaters and Regulator for Water and Energy 5.23 Renewable Energy 2011 – 2020 Collectors Scheme Services Action Plan 2017 The National The Energy and Water Agency; Biofuels Substitution 5.24 Renewable Energy 2011 – 2020 Regulator for Water and Energy Obligation (2011-2020) Action Plan 2017 Services National Energy Enemalta Plc; Energy Efficiency 5.25 Efficiency Action 2014 – 2020 Regulator for Water and Energy Obligation Plan Services The Energy and Water Agency; Managing Authority; Malta Enterprise; National Energy Financing schemes and Water Services Corporation; 5.26 Efficiency Action 2014 – 2020 fiscal incentives Wasteserv Malta; Plan Regulator for Water and Energy Services

National Energy The Energy and Water Agency; Regulations and voluntary 5.27 Efficiency Action 2014 – 2020 Malta Business Bureau; agreements Plan EEIPI Signatories Public sector leading by National Energy The Energy and Water Agency; 5.28 example in the energy Efficiency Action 2014 – 2020 Managing Authority demand sector Plan 76 Malta’s National Air Pollution Control Programme - 2019

Annex 2: 'WaM' Scenario

Relevant Measure Implementation Review Authorities responsible Name of PaMs national no. period period for implementation policy Transport Malta; Transport Vehicle tracking for Ministry for Transport, 5.6 Master Plan 2017 – 2030 Annual public transport Infrastructure and Capital 2025 Projects Facilitate the Transport Malta; Transport development of a Ministry for Transport, 5.7 Master Plan 2017 – 2030 Annual real-time multi-modal Infrastructure and Capital 2025 journey planner Projects Malta National Electro- Mobility Platform; Transport Transport Malta; 5.10.5 Bike sharing schemes Master Plan 2016 – 2030 Annual Ministry for Transport, 2025 Infrastructure and Capital Projects Ministry for Education and 8.1 Free school transport N/A 2018 – 2030 Annual Employment National Tallinja’s Capping 8.2.1 Transport 2015 - Malta Public Transport System Strategy 2050 IoScoot: an electric National 8.2.2 motorbike sharing Transport 2018 - Malta Public Transport service Strategy 2050 National 8.2.3 Tallinja Ferry Service Transport 2017 - Malta Public Transport Strategy 2050 National 8.2.4 TD Plus Transport 2019 - Malta Public Transport Strategy 2050 Transport Malta; Free Public Transport Malta Public Transport; fares for youths, 8.3a N/A 2017 – 2030 Annual Ministry for Transport, students and elderly Infrastructure and Capital persons (phase 1) Projects Transport Malta; Free Public Transport Malta Public Transport; fares for youths, Ministry for Transport, 8.3b N/A 2018 – 2030 Annual students and elderly Infrastructure and Capital persons (phase 2) Projects

Transport Malta; Free Public Transport Malta Public Transport; fares for youths, Ministry for Transport, 8.3c N/A 2019 – 2030 Annual students and elderly Infrastructure and Capital persons (phase 3) Projects Malta’s National Air Pollution Control Programme - 2019 77

Annex 2 cont.

Relevant Measure Implementation Review Authorities responsible Name of PaMs national no. period period for implementation policy Transport Malta; Develop and incentivise Transport Ministry for Transport, 8.4 schemes to promote Master Plan 2021 - 2025 Annual Infrastructure and Capital multiple occupancy 2025 Projects Malta National Electro- Review of Malta’s Malta National Mobility Platform; National Electro- Electro- Transport Malta; 8.5a 2013 - 2019 Annual Mobility Action Plan Mobility Action Ministry for Transport, (MNEAP) (phase 1) Plan 2013 Infrastructure and Capital Projects Malta National Electro- Review of Malta’s Mobility Platform; National Electro- Transport Malta; 8.5b N/A 2019 - Annual Mobility Action Plan Ministry for Transport, (MNEAP) (phase 2) Infrastructure and Capital Projects Malta National Electro- Malta National Mobility Platform; Electro- Transport Malta; 8.6 Car sharing scheme 2018 - Annual Mobility Action Ministry for Transport, Plan 2013 Infrastructure and Capital Projects

Transport Malta; Malta National Electro- Mobility Platform; Ministry for Transport, Transport Study the introduction Infrastructure and Capital 8.7 Master Plan 2020 - Annual of Low Emission Zones Projects; 2025 Environment & Resources Authority; Ministry for the Environment, Climate Change and Planning

Transport Master Plan Malta National Electro- 2025; Mobility Platform; Develop a national Draft National Transport Malta; 8.8 2019 - 2025 Annual bicycle strategy Cycling Strategy Ministry for Transport, and Action Plan Infrastructure and Capital for the Maltese Projects Islands 78 Malta’s National Air Pollution Control Programme - 2019

Annex 2 cont.

Relevant Measure Implementation Review Authorities responsible Name of PaMs national no. period period for implementation policy Malta National Electro- Mobility Platform; Sustainable Urban Transport Transport Malta; 8.9 Mobility Plan (SUMP) Master Plan 2016 - 2020 Annual Ministry for Transport, for Valletta 2025 Infrastructure and Capital Projects Malta National Electro- Malta National Mobility Platform; Last-mile delivery for Electro- Transport Malta; 8.10 2021 - 2025 Annual Valletta Mobility Action Ministry for Transport, Plan 2013 Infrastructure and Capital Projects Transport Malta; Transport Smart parking system Ministry for Transport, 8.11 Master Plan 2020 – 2030 Annual for Valletta Infrastructure and Capital 2025 Projects Transport Malta; Transport Ministry for Transport, 8.12 Pilot cycling corridors Master Plan 2016 – 2020 Annual Infrastructure and Capital 2025 Projects Malta National Electro- Mobility Platform; Develop a shore supply Transport Transport Malta; 8.13 action plan for the Master Plan 2016 - 2020 Annual Ministry for Transport, TEN-T ports 2025 Infrastructure and Capital Projects Transport Malta; Malta National Ministry for Transport, Introduction of electric Electro- 8.14 2018 - 2020 Annual Infrastructure and Capital buses in Gozo Mobility Action Projects; Plan 2013 Ministry for Gozo Transport Malta; Transport Infrastructure Ministry for Transport, 8.15 Master Plan 2020 - 2030 Annual interventions Infrastructure and Capital 2025 Projects Transport Malta; Transport Public Transport Quality Ministry for Transport, 8.16 Master Plan 2025 – 2030 Annual Corridors (PTQC) Infrastructure and Capital 2025 Projects Malta’s National Air Pollution Control Programme - 2019 79

Annex 2 cont.

Relevant Measure Implementation Review Authorities responsible Name of PaMs national no. period period for implementation policy Transport Master Plan Increase the use of Transport Malta; 2025; Intelligent Transport Ministry for Transport, 8.17a National ITS 2018 – 2030 Annual Systems in traffic Infrastructure and Capital Action Plan for management (phase 1) Projects Malta (2013 – 2017) Transport Master Plan Increase the use of Transport Malta; 2025; Intelligent Transport Ministry for Transport, 8.17b National ITS 2020 – 2030 Annual Systems in traffic Infrastructure and Capital Action Plan for management (phase 2) Projects Malta (2013 – 2017) Malta National Electro- Mobility Platform; Transport Improvement of Ferry Transport Malta; 8.18a Master Plan 2020 – 2030 Annual Landing Places (phase 1) Ministry for Transport, 2025; Infrastructure and Capital Projects Malta National Electro- Mobility Platform; Transport Improvement of Ferry Transport Malta; 8.18b Master Plan Annual Landing Places (phase 2) Ministry for Transport, 2025 Infrastructure and Capital Projects Transport Malta; Transport Fast ferry link between Ministry for Transport, 8.19 Master Plan 2020 – 2025 Annual Malta and Gozo Infrastructure and Capital 2025 Projects Initiatives related to 8.20 electrification of the N/A 2019 - 2020 Annual E-Cars Committee fleet Ministry for Transport, Electric Vehicles (taxis Infrastructure and Capital 8.20.1 N/A 2020 - Annual and Government fleet) Projects; Ministry for Finance Increase in financial Ministry for Transport, grants for more efficient Infrastructure and Capital 8.21 N/A 2020 - Annual internal combustion Projects; engines (ICE) Ministry for Finance 80 Malta’s National Air Pollution Control Programme - 2019

Annex 2 cont.

Relevant Measure Implementation Review Authorities responsible Name of PaMs national no. period period for implementation policy Transport Malta; Reform of Public Service Ministry for Transport, 8.22 Annual Garage Infrastructure and Capital Projects Environment and Resources Environmental Environment Authority; 8.23 Authorisations Protection Act 2020 – 2030 Annual Ministry for the Environment, Regulations (2016) Climate Change and Planning A more sustainable Malta Enterprise; 8.24 2020 - Annual construction industry Ministry for Finance The creation of sustainable alternative National Governance of Agricultural strategies related Agricultural Bio-resources; 8.25 to livestock waste 2018 – 2027 Annual Policy (2018 – Ministry for the Environment, management including 2028) Climate Change and Planning treatment of by- products Amendment to National S.L. 549.66 for the Agricultural Agricultural Directorate 8.26 2018 – 2027 Annual utilisation of spent Policy (2018 – (MECP) mushroom substrate 2028) SDECC Environmental Directorate (MECP); Rural Development Directorate (RPD); National Veterinary Phytosanitary Develop a Soil Action Agricultural 8.27 2020 – 2022 Annual Regulation Department Plan Policy (2018 – (VPRD); 2028) Environment and Resources Authority (ERA); Governance of Agricultural Bio-Resources (MECP) Projects in primary 8.28 2021 – 2030 Annual Water Services Corporation water network Energy and Water Agency; Biofuels Substitution 8.29 2021 – 2030 Annual Regulator for Water and Obligation Energy Services Development of R&I 8.30 Strategy for Energy and 2020 – 2030 Annual Energy and Water Agency Water Ministry for the Environment, 8.31 Waste to Energy facility 2023 – 2050 Annual Climate Change and Planning Malta’s National Air Pollution Control Programme - 2019 81

Annex 2 cont.

Relevant Measure Implementation Review Authorities responsible Name of PaMs national no. period period for implementation policy Regulator for Energy and Financial support 8.32.1 2021 – 2030 Annual Water Services (REWS); schemes for Solar PVs Energy and Water Agency

Solar Water Heaters Regulator for Energy and 8.32.2 2021 – 2030 Annual Scheme Water Services (REWS);

Enemalta Corporation; Energy Efficiency: 8.32.3 2021 – 2030 Annual Regulator for Energy and electricity tariffs Water Services (REWS) Energy and Water Agency; Support scheme for 8.32.4 2021 – 2030 Annual Ministry of Tourism; Services and Industry Malta Enterprise Energy Efficient Street Ministry for Energy and 8.32.5 2018 – 2022 Annual Lighting Water Management 82 Malta’s National Air Pollution Control Programme - 2019

Annex 3: Public Consultation on Aims and Objectives - Submissions and Responses

Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

1 Etienne Scicluna My family resides near Bulebel Industrial The aim of the NAPCP is to include measures Estate. It is a very well known fact that no to reduce emissions at a national level. Whilst 22/03/2019 studies has ever been conducted about the the comment is noted, the nature of the type of air quality and the type of pollution comment is more oriented towards local air the factories in the Bulebel area are quality and nuisance. releasing. Very often, especially during the night, we have to close our windows because we could not resist the pungent odours Complainant was advised to report coming from the factories, let alone those immediately upon noticing such incidents. harmful chemicals which are being released in the air that are odourless. In fact, this situation is affected my children who both of them suffer from allergies through the year.

The least that could be done is to dispatch some experts to conduct random checks near the Bulebel Industrial Estate in order to identify the source.

2 Mark Cassar Putting it bluntly, if enforcement is carried Comment is noted. While agreeing with the out as it should be wrt the VRT and on- fact that the VRT/on the road inspections 24/03/2019 the-road visual inspections the number of should ensure that the more polluting vehicles emitting noxious fumes would be vehicles are tackled, it should be noted that drastically reduced but also the following the NAPCP’s approach is more at a macro- mitigating measures would decrease the level in that it looks at issues such as total amount of air-pollutants: fuel burn by the road transportation sector, vehicle kilometres driven, age of the vehicle fleet etc.

Therefore, such a measure would have no impact on the total national emissions from road transport, because it mostly concerns the state of individual vehicles, which is not possible to include in the currently available models. This however does not mean that the measure will not reap benefits at a local level.

De-registration of vehicles older than 20-25 This comment is noted and will be considered years should be considered - being the worst for further studies. offenders of noxious fumes. Car engines' efficiency is reduced and inversely, pollution increases exponentially even after 5 years of use. Malta’s National Air Pollution Control Programme - 2019 83

Annex 3 cont.

Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

Planting of more trees to reduce CO2 levels Comment noted. CO2 emissions are targeted and removal of other air pollutants and by the National Energy and Climate Plan, increase in the number of green-areas to a draft of which has been completed by mitigate air-pollution. the Energy and Water Agency (EWA). The

NAPCP deals with air pollutants (SO2, NOx,

nmVOC, NH3 and PM2,5).

More incentives/subsidies for the Comment noted. It is always better to shift importation of electric and hybrid vehicles emissions to a stationary source such as a should be considered before the 2030- power plant because, in the case of the power 2040 deadline which has already been set plant the waste gases are emitted at a certain anyway by many car manufacturers and EU height above ground level. In addition the countries. Electricity from the power-station abatement technology for stationary sources moves the pollution from the road (albeit to has already delivered significant reductions the environs of the power-station); though with respect to emissions. the efficiency is higher than the individual internal combustion engines of hundreds On the other hand cars emit air pollution in of thousands of vehicles on the road) and a diffusive manner and at ground level. In the power-station emissions are also more addition, abatement of emissions from cars strictly controlled. is known to be less effective than those of stationary sources, particularly when the engine is still cold. Therefore the suggestion to financially support the importation of cleaner vehicles is supported and is also included in the NAPCP.

Also HGVs (by far the worst offenders in See previous reply regarding local air quality terms of volume of air pollution and the fact above. that hundreds of such vehicles are ubiquitous and constantly on the road - unlike passenger vehicles which are utilised on the whole twice per day and for specific errands - need to be specifically included in the plan and subsequent enforcement thereon otherwise the programme would be a non-starter and the goal (reducing the rate of mortality/ morbidity and to have cleaner air) would be far from being achieved. 84 Malta’s National Air Pollution Control Programme - 2019

Annex 3 cont.

Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

Infringement of the EU Directive (EU) Comment noted. The NAPCP includes 2016/2284 on the reduction of national measures to improve air quality at a national emissions of certain atmospheric pollutants scale. ERA agrees that reducing harmful (National Emission Ceilings (NEC) Directive) effects on human health is a very important and the Ambient Air Quality Directive consideration. While the cause and effect (2008/50/EC) may be financially wasteful relationship between air pollution and health and politically damning but the premature can be considered to be quite established one deaths of hundreds of people (the scientific should however be very careful when quoting estimate is between 473 and 677 - Thomas studies on premature deaths. For example, Münzel, University Medical Centre Mainz, in the WHO relies on scores of studies and not Germany published in the European Heart just particular study. Journal) dying every year in Malta from air pollution should be more than enough an incentive to implement air pollution reduction policies and get things done right.

3 Jon Camilleri I read your online consultations, as usual I like Noted. The NAPCP includes a number of researching and I think that the way forward measures related to the use of renewable 26/03/2019 is establishing incentives for manufacturing energy. to produce using renewable energies and using better materials. Noted, the NAPCP does not deal with such issues. The use of iron tends to result in rust for example how healthy is that for our skin if we do not dispose of rusted metals in good time?

What is the price for value we are paying?

4 Mark Cassar Further to the below please find link to a This comment is noted. scientific article (the Lancet) wrt to the link

13/04/2019 between asthma and nitrous oxide (NO2) as well as the possible mitigating measures that can be considered; such as replicating London's Ultra Low Emission Zone (ULEZ).

The Lancet Planetary Health https://www.thelancet.com/journals/lanpla/ article/PIIS2542-5196(19)30046-4/fulltext Malta’s National Air Pollution Control Programme - 2019 85

Annex 3 cont.

Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

Millions of child asthma cases linked to traffic This comment is noted. pollution every year https://www.newscientist.com/ article/2199322-millions-of-child- asthma-cases-linked-to-traffic-pollution- every-year/??utm_medium=NLC&utm_ source=NSNS&utm_campaign=2019-0412- GLOBAL-NSDAY&utm_content=NSDAY

The scientific evidence is clear, what is required - today before tomorrow - is the political will from ALL sides to act on it.

5 Gertrude Buttigieg The principle aim of Directive (EU) Comment noted. The NAPCP is more 2016/2284 i.e. the protection of human oriented towards reducing emissions at a OBO Malta Health health, must be the principle aim and national scale. Notwithstanding this, the Network priority of the proposed Malta’s National Air NAPCP includes a number of measures Pollution Control Programme. Therefore, the related to electro-mobility and sustainable

15/04/2019 priority should be to reduce pollutants (NOx, transportation, which aim to contribute in

SO2, nmVOCs, NH3, and PM2.5) especially improving air quality also in residential areas. in residential zones. Specific reference and As regard road transport, the NAPCP consideration to residential areas, urban prioritises measures in this sector. cores and areas frequented by vulnerable populations/sensitive human population Regarding emissions from cruise ships, it is groups e.g. children (school, sport and to be noted that the NEC Directive is limited playground areas); the sick and elderly to national navigation and this does not (hospitals, long term facilities), etc must be included cruise liner visits. However, studies made in the proposed programme. apart from the NAPCP may be considered.

The programme should consider measures Regarding the smaller industry, the NAPCP applicable to road transport as a priority also addresses this sector by proposing a since such a measure will beneficially affect new set of Regulations targeting the smaller all areas especially residential. Shipping emitters, which are currently not regulated (cruise liners, containers ships, other by EU legislation. commercial shipping, etc) in Malta’s ports should also be considered as a priority due to the large population residing around the harbour areas (including Marsaxlokk and B’Bugia areas). 86 Malta’s National Air Pollution Control Programme - 2019

Annex 3 cont.

Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

Domestic heating (note the possible increase in household fireplaces) and small industries such as bakeries, automotive spray painters, etc and construction processes often present within residential areas should be included in further measures to adopt in order to comply with the emission reduction commitments and improve health and wellbeing of population.

Objectives should include effective This comment is noted. implementation and monitoring (not just emission levels but also environmental permitting or other conditions set for their operation). Penalties applicable to infringements of provisions laid down in the proposed programme should be immediate, effective and dissuasive.

The national air pollution control The NAPCP will be updated every 4 years in programmes should be updated at least line with the requirements of Article 6(3) of every four years as per Article 6(3) of (EU) Directive 2016/2284 in consultation with all 2016/2284 with appropriate stakeholder relevant stakeholders and the general public. involvement and consultation including the The objectives of the plan were issued for competent authorities (especially Health public consultation whilst the draft of the Ministry), local councils, public and NGOs. plan is also being published for a 6 week Article 14 (Access to information) of (EU) consultation period. 2016/2284 must be adequately reflected in proposed programme, namely ensuring the active and systematic dissemination to the public of the stated information by publishing it on a publicly accessible website.

Last but not least the Malta Health Network This comment is noted. has been on the forefront in Malta promoting the European Charter of Patients’ Rights – first right is the Right to Preventative measures. Having better Air Pollution control is in line with the rights which we believe could help to prevent many illnesses and alleviate the quality of life of patients who have health conditions especially respiratory problems. Malta’s National Air Pollution Control Programme - 2019 87

Annex 3 cont.

Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

6 Dr. Christine Bellizzi In brief I would like the NAPCP to focus and The NAPCP’s approach is more at a macro- prescribe effective remedies in relation to level in that it looks at issues such as total 23/04/2019 pollution from construction sites which are fuel burn from the road transportation

a significant source of PM2.5, PM10 and NOx. sector, vehicle kilometres driven, age of the The emissions from construction sites is to vehicle fleet etc. The document does not look be given additional attention in the context into local air quality issues. of Malta, in view of the intensity and extent of construction industry. Enforcement of the very scant legislation relating to dust control (mentioned in the Air Quality Plan) is severely lacking and the Building Regulations Office has been effectively been reduced to a toothless hound. Even when enforcement action is taken the penalties are too low to offer a real deterrent. Insufficient attention is being given to the height of buildings that are continuing to rise, thus creating polluted air traps.

Furthermore, due attention is to be given to Please refer to previous comment in relation air pollution emitted by docked cruise liners. to same subject. Malta is a popular port with multiple large cruise liners docking in the Grand Harbour for severely hours, nearly every day.

Considering, the ever growing intensity of Please refer to previous comments on local construction sites, the docking of cruise air quality issues. ships, intense traffic and congestions, industrial activities such as Palumbo are all concentrated in the Valletta - Sliema agglomeration due care should be given to the effects on human health and the public is to be given due warning of the hazards that these present. 88 Malta’s National Air Pollution Control Programme - 2019

Annex 4: Public Consultation on Draft NAPCP - Submissions and Responses

Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

1 Mario Sammut If air pollution is truly to be reduced, one Comment has been noted. The NAPCP of the main measures to be taken is to prioritises the sectors which contribute most 22/11/2019 cut down, or better still replace by laser to the pollutants regulated by the National technology, the use of fireworks. Not only Emission Ceilings Directive. When compared

they produce CO and CO2, but also NOx, SO2 to other sectors, fireworks generate minimal and tons of heavy metal oxides that pollute emissions of these pollutants. air, land and water.

2 Michael Briguglio I am hereby proposing that this policy Comment has been noted. ERA agrees that process incorporates Social Impact such assessments provide useful information 03/12/2019 Assessments. for the formulation of environmental policy. ERA is currently developing the National A social impact assessment reviews the Strategy for the Environment (NSE), a social effects of development and social strategic governance document that will set change, both intended and not. the policy framework for the preparation of The International Association for Impact plans, policies and programmes issued under Assessment defines an SIA as the process the Act or under any other Act related to the of analysing, monitoring and managing protection and sustainable management of the intended and unintended social the environment until 2050. Social criteria consequences, both positive and negative, of have been taken into due consideration planned interventions and any social change for the selection of the lead scenario for processes invoked by those interventions. 2050, which will formulate the basis for the Such changes may range from natural development of the strategy. disasters to population growth and from policy interventions to singular development projects. Consequently, SIAs investigate the effects on people’s everyday lives in terms of culture, politics, community, health, well-being, aspirations, needs, rights and responsibilities, to name a few. They provide data for policymaking, which is based on evidence.

Social impacts under assessment should include all those things relevant to people’s everyday life. This may include one’s culture, community, political context, environment, health, well-being, personal and property rights as well as fears and aspirations. Malta’s National Air Pollution Control Programme - 2019 89

Annex 4 cont.

Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

Social impact assessments can help verify the consequences and impacts of development proposals in relation to the communities involved. Hence, a basic starting point for such assessments should be the compilation of a community profile. A social impact assessment that does not understand the society in question is practically worthless.

This can help bring about genuine processes of engagement between communities, developers and authorities as well as identify and implement mitigation measures and compensation mechanisms. As things stand in Malta, various developers do quite the opposite, often causing huge inconvenience to residents and leaving a mess behind in surrounding infrastructure.

Various methods, both quantitative and qualitative could be used within social impact assessments. The former refers to generalisable data especially through numbers, while the latter produce in-depth data on matters.

Research methods in SIAs may therefore include surveys of concerned populations who are asked questions on their perceptions of the change in question.

Ethnographic methods may involve a deeper look into everyday practices of people, while elite interviews may verify the advice, concerns and interpretations of persons who are experts or who have experience in the respective field under analysis.

Methods may also involve the analysis of discourse on the subject in question, for example by looking at what is being 90 Malta’s National Air Pollution Control Programme - 2019

Annex 4 cont.

Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

pronounced in the public sphere, whether by the public, civil society, political actors, the media and the like.

SIAs should involve the participation of different stakeholders, ideally through mixed research methods.

Some other factors which should be included in social impact assessments include the consideration of reasonable alternatives to development proposals as well as comparative analysis of similar development proposals and related good or bad practices. Analytic indicators should be provided and the entire process should be subject to peer review by independent experts in the field. Social impact assessments should not be one-off exercises which are rubber-stamped by authorities without any sense of critical engagement. To the contrary, they should be ongoing processes which engage with various stakeholders and which report back so as to ensure effective policy processes. They should also use complementary research methods so as to ensure reliable and valid data.

Recommendations and mitigation measures could therefore be in place, and these would be based on social-scientific evidence.

It is also important that SIAs are peer- reviewed. This means that if a study is being carried out by a team of social scientists, this should be scrutinised by other independent social scientists. This could help identify shortcomings, conflicts and possible improvements to the same SIA. Malta’s National Air Pollution Control Programme - 2019 91

Annex 4 cont.

Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

3 Mark Sammut Below please find MFIN's feedback to ERA has taken note of this clarification. Ministry for Finance some of the points raised during the public As also mentioned in the NAPCP, the consultation: Government fleet consists of a number of 06/12/2019 electric or hybrid vehicles. Measure 8.20.1 1. Government Fleet Circular - one of the of the NAPCP aims to continue to increase attendees claimed that the vehicle value the number of cleaner vehicles in the thresholds are low which automatically government fleet. disqualify EVs from being eligible. MFIN clarifies that the circular’s thresholds apply to ICE vehicles and the circular specifically states that environmental-friendly vehicles would be considered on their own merits. In fact to date, more than 150 EVs and hybrid vehicles have been approved for fleet purposes. MFIN also stresses however that replacement plans of fleets should be sustainable and backed by CBAs and also included in the ministry/department’s business plan.

2. Leasing vs Procurement for government Comment has been noted. fleet – MFIN acknowledges that procurement is favoured over leasing and this due to the fact that CBA simulations confirm the procurement's cost effectiveness over the leasing option. Yet when leasing proves to be more cost effective or appropriate, the leasing option is considered favourably.

3. Old vs New Tax Regime for Registration Comment has been noted. Tax (RT) and Annual Circulation Tax (ACT) – during the consultation session, mention was made of possibly eliminating the discrepancy which currently exists. MTIP reaffirmed that one needs to look into other aspects, including the social aspect of introducing such a change. MFIN concurs with this line of thought and this is also reflected on the points MFIN raises during related discussions. 92 Malta’s National Air Pollution Control Programme - 2019

Annex 4 cont.

Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

4. RT for SUVs – one of the attendees Comment has been noted. remarked that these vehicles should be taxed more than the average vehicles due to their size. MFIN clarifies that one of the variables which is used to determine RT for such M1 category vehicles is the length of the vehicle and consequently SUVs and larger vehicles do pay more RT on the length element when compared to average sized vehicles.

5. Schemes and Grants – mention was made The NAPCP includes a number of measures of possibly extending the scrappage scheme focused on schemes and grants to deliver further, raising grants, introduce grants for improved results in sustainable mobility and the conversion of delivery/sales rep fleets the purchasing of cleaner vehicles. to EVs, schemes for businesses which encourage car pooling and car sharing, etc. The concept of car-pooling is also mentioned Currently there are already schemes which in the NAPCP, however it is aimed at cater for environmental considerations individuals rather than businesses. The latter such as the various scrappage schemes, will be taken into consideration for the electric vehicles grants, bicycle and pedelec upcoming Air Quality Plan. grant, bicycle rack grant, EV registration tax exemption, LPG conversion grant, free public transport for students and senior citizens, etc. MFIN is also open to discuss further any other schemes which could be considered as further options to the current schemes.

4 Janina Marie We welcome Malta’s intentions to reduce Comment has been noted, background Laurent air pollutant emissions for the purpose information is factual. BirdLife Malta of reaching compliance with the national emission reduction commitments, as set out 12/12/2019 in Annex II of the National Emission Ceilings (NEC) Directive.

Despite the fact that clean air is a basic requirement for human health and well- functioning ecosystems, air quality is globally in a constant decline. In 2012, the World Health Organization identified that 95% of Europeans living in urban environments are exposed to levels of air pollution considered Malta’s National Air Pollution Control Programme - 2019 93

Annex 4 cont.

Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

dangerous to human health and about 420,000 premature deaths are known as a result in the European Union.

Primary particulate matter (PM), Sulphur dioxide (SO2) and Nitrogen oxides (NOx) emissions caused by road transport and shipping are of our major concern for Malta. We are aware that some of these pollutants – especially PM - originate from natural sources such as sea salt, soil and sand, however, in the case of natural causes only adaptation measures can be imposed whereas human-induced pollutants can be minimized to a great extent and mitigation measures put into force by the government. In our comments we would mainly like to focus on pollutants heavily emitted from combustion of shipping.

1. Background Comment has been noted. The scope of Irrespective whether cruise or container the National Emission Ceilings Directive ships, ferries, or yachts – ships gather a is limited to national maritime traffic, and broad range of fuming smokestacks, which therefore does not cover international emit a great deal of air pollutants causing shipping such as cruise liner activities. damage to our climate, environment and However, this does not mean that ERA health. The reason for this is that seagoing is underestimating the impact that vessels run on heavy fuel oil, which is highly international shipping has on Malta’s air charged in Sulphur, as well as emits black quality. In this regard, ERA will be carrying carbon, heavy metals, fine particulates out an air quality study downwind of the (primary and secondary), and sulphur dioxide Grand Harbour to better understand the in the air. The sulphur content of marine impacts of cruise liners on local air quality. fuels is currently capped at a maximum of 3.5 per cent (so called „Heavy Fuel Oil“, With regard to the sulphur content in the HFO). This is 3,500 times more than is heavy fuel oil, the International Maritime permitted in the diesel fuel used in cars and Organisation (IMO) has decreased the trucks (0,001%). maximum permitted level of sulphur content in the fuel from 3.5% to 0.5%, applicable as In Malta - even though surrounded by sea from 1 January 2020. and highly dependent on shipping traffic - knowledge and awareness on the problems resulting from ship emissions remain widely 94 Malta’s National Air Pollution Control Programme - 2019

Annex 4 cont.

Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

unknown and action from responsible government authorities is not being taken. Ships, vessels and other types of boats berthing in harbours which are often located in close proximity to dense urban areas, contribute massively to air pollution in these areas. Shipping air pollution can represent up to 40% of all Mediterranean coastal city air pollution. It represents a significant threat to human health, environment and climate. As pollutants are carried over long distances, it is not only the inhabitants of littoral zones but also the populations in inland regions, who are subject to respiratory issues as well as inflammations and cardiovascular diseases.

Recent study results published by the Department of Geosciences of the University of Malta, show the extent of air pollution caused by ships around the Maltese island. Atmospheric physicist Prof. Raymond Ellul and his team have assessed an area of 200km by 200km around Malta with 1,774,448 ship data points, showing 84,500 ship movements which were detected in the area in 2015 alone. Prof. Ellul highlights the problem of air pollution from ships in Malta, stating, “One big tanker that passes by has an engine of about 80 megawatts. A Maltese power station outputs a maximum of 450 megawatts. So a tanker is a fifth of that. But we get 200 ships of that size passing by Malta like that going through every day! It’s like having a couple of hundred mini-power stations going past every day,’ emitting sulphur dioxide and everything else a power station would emit” (THINK Magazine 2017). More detailed and technical information highlights that Malta is suffering 50.9 kilotonnes of nitrous oxide, 30.3 kilotonnes of sulphur dioxide, 3 kilotonnes of carbon Malta’s National Air Pollution Control Programme - 2019 95

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monoxide, along with a 2080 kilotonnes of carbon dioxide. If the numbers are compared to emissions from cars, they equal nitrous oxide emitted from 4.1 billion cars, sulphur dioxide from 1,515 billion cars and carbon dioxide from 365.000 cars (comparison to average value of a car with emission standard Euro 4 in 2012).

Running engines of ships contribute Comment has been noted, information is considerably to emissions of sulphur factual. oxides (SOx), nitrogen oxides (NOₓ) and particulate matter (PM). The latter includes soot emissions (black carbon) which are in particular harmful to health and climate. NOₓ emissions diminish the function of the lungs and increase the risk of cardiovascular disease. NOₓ is also a powerful greenhouse gas causing climate warming due to its contribution in the formation of ozone (O₃). High concentrations of O₃ in cities are responsible for the death of elderly people and people with poor health conditions. Emissions of sulphur oxides such as sulphur dioxide (SO₂) are harmful for our environment, not least because it causes acid rain which leads to the eutrophication of soils and coastal areas and it damages buildings and structures, particularly those made of limestone. Air pollutant emissions are furthermore responsible for a significant loss of productivity in agriculture and have a negative impact on biodiversity.

Countries that are facing the same problem Comment has been noted. ERA is aware – including Northern European countries, of these studies and will be conducting a the USA, Canada and China - took action study in 2020 in Senglea, closer to the area to reduce the pollution caused by ships in of influence of international shipping, to their territorial waters. Air pollution from better understand the impact of shipping on ship traffic in the Mediterranean Sea can be ambient air quality. significantly reduced by the introduction of an Emission Control Area (ECA). 96 Malta’s National Air Pollution Control Programme - 2019

Annex 4 cont.

Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

A recent impact assessment by the French Government, which started in 2017, investigated potential air quality improvements in the region following a switch to better grade marine fuels as well as the related socio-economic benefits of reduced health costs and environmental damage obtainable by the designation of an ECA in the Mediterranean Sea. The key finding is that the region would benefit most from a combined Sulphur Emission Control Area (SECA) and Nitrogen Emission Control Area (NECA). SO₂ would be reduced by 77% and in port areas even by 100%. NO₂ would decline by up to 76% in coastal areas and the east of the Mediterranean Sea. The annual mean of particulate matter (PM2.5) would go down by 15 to 20%. Shipping emissions cause 50,000 premature deaths per year in Europe and cost €60 billion just in health costs per year in the European Union (EU). In the Mediterranean region only, about 6,000 premature deaths could be avoided due to the reduction of the particle pollution.

Declaring the Mediterranean Sea as an Comment has been noted. Emission Control Area is one of the many existing solutions. Beside political measures, governments and private port authorities can implement technical and infrastructural measures, which address the issue of air pollution from ships directly. In July 2017, the European Commission published a study on port infrastructure to promote environmentally friendly maritime transport activities and sustainable transportation. The study highlights best-practice examples from various ports worldwide, benefits and costs, including the economic aspect and environmental potential of certain schemes and guidelines to equip other ports on how these practices can be developed in their Malta’s National Air Pollution Control Programme - 2019 97

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respective countries.

2. Recommendations Malta is participating in the respective We urge our national government to support negotiations on the designation of a SECA in the designation of the Mediterranean Sea the Mediterranean Sea. as a combined SECA and NECA by 2020 and recommend to put a strong focus on the reduction of air pollutants emitted from ships into Malta’s National Air Pollution Control Programme. Suitable measures have to be identified and implemented to reduce the air pollution from ships in Malta and the Mediterranean to create less damage to our environment and health.

Suitable measures for Malta for cleaning and Comment has been noted. Malta is greening the shipping sector could include participating in the respective negotiations for instance: on the designation of a SECA in the Mediterranean Sea. • Political measures: reduction of sulphur dioxide and nitrogen dioxide emissions by establishing a so-called emission control areas (ECAs) in territorial waters – ideally including Hurd’s Bank. A maximum value for sulphur content could be 0.1 percent, compared to a current 3.5%. Another idea would be the creation of a national tailor-made policy framework on shipping emissions

• Technical measures: promote (1) the Comment has been noted. installation of diesel particulate filters (DPF) on all (cruise) ships and ferries berthing and shipping in Malta, which reduce soot emissions almost completely; (2) install selective catalytic reduction systems (SCRs) which can eliminate most of the NOx from ships exhaust fumes; and (3) closed-loop seawater scrubbers and port facilities to cater for toxic waste 98 Malta’s National Air Pollution Control Programme - 2019

Annex 4 cont.

Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

• Infrastructural measures: provision of Comment has been noted and will be a power supply for electric ferries (e.g. discussed further with the relevant Gozo Channel, Birgu – Valletta – Sliema authorities. connection); suitable for Malta but tackling emissions from cars at the Gozo terminal would be the installation of roof shading structures for cars and mandatory switched- off engines

• Voluntary measures for ports and ship Comment has been noted and will be owners: air pollution reduction measures discussed further with the relevant can be introduced, such as ecological port authorities. fees (ships pay their port fees depending on environmental performance, including their respective emission balance, creating incentives for ship operators to invest in clean technologies); own incentive programs for ships that go beyond the legal requirements can be promoted, such as the “Green Ship Program” that rewards ships with cleaner engines per call, greening national sea transport including ferries and local ship transport by installing technical measures (see above) on these ships (these could also be useful to promote/increase sea transport in Malta to reduce air pollution from cars)

3. Further information: Information has been noted. ERA is aware of ECAMED: a Technical Feasibility Study for the relevant studies. the Implementation of an Emission Control Area (ECA) in the Mediterranean Seas (2019): https://www.ecologique-solidaire. gouv.fr/sites/default/files/R_DRC-19- 168862-00408A_ECAMED_final_Report_ V5.pdf

Position Paper: Emission Control Area (ECA) for the Mediterranean Sea - Effective measure to tackle air pollution from ships (2018): Malta’s National Air Pollution Control Programme - 2019 99

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https://birdlifemalta.org/wp-content/ uploads/2019/01/NGOs-backgroundpaper- on-the-MedECA.pdf

THINK Magazine (2017), Issue 20: Stuck in the middle with the fumes, University of Malta. https://www.um.edu.mt/think/stuck- in-the-middle-with-the-fumes/

BirdLife Malta’s Together against Air Pollution from Ships project: https:// birdlifemalta.org/conservation/current- projects/together-air-pollution-ships

5 Jim Wightman The document Malta's National Air Pollution This comment has been noted and will be Malta Road Safety Control Programme 2019 refers to cycling in referred to the relevant authorities. Council three areas sections 8.5, 8.8 and 8.12.

13/12/2019 Referring to section 8.8 National Air Pollution Control Programme, the national cycling policy (NCS) under the National Transport Strategy and Master Plan 2025 this has indeed been released for public consultation, behind schedule, point 2.2.4 (NTS&MP) develop a NCS was supposed to commence in 2016 and complete by 2017, and is therefore very much overdue already by the consultation phase, in late 2018, and has to date still to be published.

In addition only the policy portion of This comment has been noted and will be the NCP was open to consultation and referred to the relevant authorities. not the actual technical infrastructural specifications. Without these it cannot be said that the complete policy was opened for consultation. Point 2.2.2.4 (NTS&MP) Develop a cycling strategy focusing on the hub, was supposed to commence in 2016 and complete by 2017 as part of the SUMP process is completely absent. Point 2.4.2.5 (NTS&MP) Provide and regulate space for 100 Malta’s National Air Pollution Control Programme - 2019

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bicycles, under the development of transport hubs to encourage intramodality (2.4.2), was supposed to commence in 2017 and complete by 2021, and this should have seen a number of positive interventions but most have been quite negative and even the goals set have not been reached;

a. Reduced the total amount of cycle lanes and protected segregated lanes, while using inappropriate methodologies to segregate speed differentiated traffic (see also the note about Kappara below) and selects lifts (which do not accept bicycle lengths, see photo of Mriehel lift) and bridges instead of easier direct straight-through (not serpentine) underpasses for instance.

b. Placed ‘new’ ‘cycle lanes’ in areas where there is space but are unconnected to any other cycling routes, and clearly failed to use big data such as ‘Strava Metro’ *to determine where such lanes would be most effective.

c. Resulted in a reduced level of protection to vulnerable road users.

d. Is consistently behind schedule.

e. Fails to meet stakeholders needs or that of the state with regards to National Air Pollution Control Programme as cycling levels are growing exponentially (better than EV’s and hybrids together) but remain depressed as a modal share while they are out striped by car ownership and particularly larger SUV’s which cancel out the positive benefits of EV growth and cycling combined.

f. Failed to reach the 2% modal share target suggested in the D-AIR project, due to poor policy decisions and infrastructural interventions Malta’s National Air Pollution Control Programme - 2019 101

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Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

8.15 of Malta's National Air Pollution Control This comment has been noted and will be Programme refers to improvements by referred to the relevant authorities. Infrastructure Malta linked to the NTS&MP. Unfortunately there is a fundamental error in the failure of the regulator Transport Malta to ‘get on with’ the ministries own separate entity Infrastructure Malta, and for the latter to engage in meaningful dialogue with stakeholders, in some cases as noted above this resulted in quite dangerous infrastructure being placed in the way of the general public. Infrastructure Malta has also stated publicly things which stakeholders like the BAG have never agreed to or suggested. There is also a ‘rush factor’ of making the most expedient quick fix solution that ensure that built infrastructure deadlines are kept ensuring full EU funding.

The most glaring example of this was the contemplation of the Kappara junction project without cycle lanes, despite the obvious fact that many cyclists used the route to/from university given that there was ‘contingency space’ in the form of a tarmacked verge/hard shoulder and the obvious continuation from the Coast Road as a route. The single sided cycle lane was only envisaged after the suggestion by the BAG to include cycle friendly minor roads off the scheme. This was rushed into the project in the space of almost 48Hrs and enabled planners to encroach more of the valley than previously planned under the guise of a bike lane. This bikewash process saw the introduction of a lane that could not be two way over its entire length connecting university, creating enough space for 2 car lanes next to the singled cycle lane portion on one side of Kappara. The opposite side was the site of the only cycling fatality in that year, of a cycle commuter from the 102 Malta’s National Air Pollution Control Programme - 2019

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Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

Coast road. The Kappara cycle lane still remains to this day unconnected to the university and can only be used by fearless riders brave enough to use the roundabouts at either end and ride the 300m slip lane. It is a glaring example of both bikewash and how the ‘cycle lanes where there is space’ policy has failed. Similarly Mohammed Bharket was killed on HalFar Road where the cycle lane is one way and could not be reached by Bharket, who had to cycle 300m against traffic to reach it, to cycle wrong way and again against traffic to leave it.

National Air Pollution Control Programme This comment has been noted and will be section 8.12 refers to safe cycling corridors referred to the relevant authorities. as part of the SMITHS project, see photo montages attached. These again are described in 2.2.2.5 (NTS&MP) to develop pilot cycle corridors, were supposed to commence in 2016 and complete by 2020. However again these were not subject to public or more importantly stakeholder consultation by the Italian firm contracted to draw them up and contain a significant number of errors, and impractical design features. Such routes should be given criteria such as Comfort, Efficiency, Security and Ease of Use especially by novice riders. Safe routes as dictated in section 8.5 (NAPCP) should be a given, not something new. The slogan safe roads for everyone should already embody this.

Clearly to place non-polluting cycle lanes This comment has been noted and will be where they will not be used, and importantly referred to the relevant authorities. not alongside polluting car routes for fear of losing car space, will not address or transfer polluting car trips to non-polluting bicycle trips. It is therefore very important that Malta's National Air Pollution Control Programme 2019 takes a controlling and Malta’s National Air Pollution Control Programme - 2019 103

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Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

accountable approach to *to determine where such lanes would be most effective, in reducing pollution by increasing bicycle use over car use. Importantly the current trend to rely on vehicular cycling will not see cycling uptake grow beyond 2%, of dedicated fearless riders. To encourage general commuting cycling these routes should be prioritized, segregated, efficient and comfortable, that non cyclists are willing to get on a bicycle and use. The removal of car parking, disincentivizes car use and at the same time frees up dead vehicle space to moving active transport space and should be, strongly encouraged.

To sum up, the National Air Pollution Control This comment has been noted and will be Programme 2019 should promote pollution referred to the relevant authorities. free cycling by addressing the deviation from the reality of cycle commuting by;

• Expedite the publication of the National Cycling Policy including the actual technical infrastructural specifications, and revise its (the NAPCP) text accordingly.

• Observe that the number and quality of cycle lanes has been reduced not increased (note many of these are also one way or single sided, sharrow markings are signage not cycle lanes in themselves).

• Observe that protected segregated lanes are better and that their placement needs to be appropriate and effective rather than convenient (cycle lanes where there’s space).

• Methodologies need to be bicycle friendly and big data based.

• Make failures in deadlines and effective provision accountable. 104 Malta’s National Air Pollution Control Programme - 2019

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Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

• Set a goal of increased cycling uptake of 10% modal share by 2025.

• Resolve the breach between Infrastructure Malta and Transport Malta.

• Address dangerous and below specification (it is suggested in 2020 that the Dutch CROW standards are used) infra and set goals to upgrade single sided and 6KPH shared paths.

• Revise the plans for the SMITHS project safe cycling corridors with stakeholders.

• Base cycling and walking infra on Comfort, Efficiency, Security and Ease of Use.

• Prioritize non-polluting cycle lanes over parking and polluting car routes (such as the planned flyovers in Msida and parking lanes in Tower Road)

• Move away from vehicular cycling to segregated cycling to encourage general commuting by bicycle.

We noted that within the agriculture ERA is informed that the Maltese Code for 6 Mary Camilleri sections in the Malta's National Air Pollution Good Agricultural Practice is being revised. Mgarr Farmers Control Programme there is continuous However, it is not envisaged that the Cooperative Society reference to the Maltese Code for Good agriculture section in the “With Additional Ltd Agricultural Practice (2001). This directive Measures” section of the NAPCP will be is already in place and it's useless to provide affected by the CoGAP since the listed 23/12/2019 feedback on it; during the consultation measures derive from a different plan, stage we were not given enough time to go National Agricultural Policy for the Maltese through it and submit our suggestions and Islands (2018 – 2028). comments. With respect to consultation timelines, the NAPCP was available for public consultation for a duration of 7 weeks, which is in line with the requirements of the Environment Protection Act (Cap. 549). Malta’s National Air Pollution Control Programme - 2019 105

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Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

7 Nicoletta Moss Thank you for setting up the National Air CO2 emissions do not fall within the scope Debono Group Pollution Control Programme. of the NAPCP, and are being targeted by the National Energy and Climate Plan (NECP) 13/01/2020 As transport is one of the main issues of COx coordinated by the Energy and Water pollution all our comments and suggestions Agency (EWA). will be around mobility. However, there are synergies between the Vehicle: NAPCP and the NECP since both plans • Facilitate the change from internal largely include similar measures and actions combustion engines to alternative sources of to reduce air pollutant emissions. Some of energy: Tax what you don’t want, subsidies the measures being suggested are already the preferred option (Compare to Norwegian included in the NAPCP, such as incentives legislation) for electrification of the fleet (Measure 8.20) and the study of the introduction of a low • Electrification of the fleet through emission zone (Measure 8.7). The remaining incentives measures will be discussed further with the relevant authorities. • End of the 2-tier taxation system (lower tax for older cars)

• Limit access to certain areas of cities for cars with old engines / Diesel trucks (According to EURO 3-6)

• Pedestrian zones: Make certain areas car free (except for last mile deliveries, which should be limited to a certain time of the day)

• Charge for congestion / emissions

• Facilitate the introduction of Autonomous Vehicles

• Hydrogen trial

Other modes of transportation Car-sharing and sustainable delivery services • Incentivize sharing of rides/vehicles as this (Measures 8.6, 8.10) are included in the will bring down congestion and fleet NAPCP. The third point will be discussed with the relevant authorities. 106 Malta’s National Air Pollution Control Programme - 2019

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Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

• One vehicle should be able to be used for different purposes (taxi, rental, deliveries etc. according to demand rather than forced by the number plate)

• Subsidies not only for projects from Transport Malta or Malta Public Transport, but also for initiatives from other entities

Infrastructure As outlined in the NAPCP, improvement of • Reducing parking areas and planting trees cycling infrastructure is being implemented instead, or alternatively put up underground through the National Cycling Strategy. The parking and add on top a green recreation first point will be discussed with the relevant area for the public (as it was suggested in the authorities. Cottonera)

• Add bike lanes and pedestrian walkways to make walking and bicycling easier (if possible add trees, so people can move in the shade)

Other: The NAPCP already includes a measure • Subsidize and support companies who set which states that a Green Travel Plan is up a Green Mobility Plan for their employees being put together for the Ministry for Infrastructure, Transport and Capital Projects (MTIP) as a pilot project (Measure 8.4), to later implement similar initiatives in other Ministries. This can be extended to private companies.

8 Nicole Klaesener- As a foundation focussing its intervention Most of the suggested measures are already Metzner on the topic of sustainable mobility we will included in the NAPCP. The remaining Project Aegle focus our comments on mobility and the suggestions will be discussed further with Foundation resulting emissions in general: the relevant authorities. Proposed: 15/01/2020 • Subsidise and support companies, which With regards the suggestion on the implement a Green Travel Plan (reducing publication of air quality data, ERA is emissions from commutes) currently working on an air quality index which will be displaying information on • Incentivise sharing of rides/vehicles as this the status of air quality in a way that can will bring down congestion and number of be more readily understood by the general vehicles public. Malta’s National Air Pollution Control Programme - 2019 107

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Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

• Allow multiple use of vehicles as taxi/ delivery/private

• Facilitate the change from internal combustion engines to alternative sources of energy

• End of the 2-tier taxation system (lower tax for older cars)

• Limit access to certain areas of cities for cars with old engines / Diesel trucks (According to EURO 3-6)

• Pedestrianise village cores (car free zones)

• Paid parking to disincentivize car use in general

• Increase construction of appropriate active travel infrastructure (sidewalks and bike lanes)

• Incentivise the use of alternatives to the car per community (competition for the village with the cleanest air)

• Publication of air quality data in a way the general public understands it easily so behaviour change is motivated

9 Laura Jasenaite As representatives of the transport Some of the recommendations are already Cool Ride-Pooling sector, we provide suggestions related to included in the NAPCP, however the other transport only. The transport sector is one recommendations have been noted and 23/01/2020 of the leading causes of air pollution, and will be discussed further with the relevant unfortunately, NOx emissions from the road authorities. transport sector have not been reduced between 2005 and 2017. The following recommendations are suggested: 108 Malta’s National Air Pollution Control Programme - 2019

Annex 4 cont.

Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

• Vehicles fueled by alternative energy sources:

• Electrification of the fleet

• Development of EV charging network

• Introduction of hydrogen vehicles

• Facilitate the trial of autonomous vehicles

• Incentives the purchase of cars with alternative sources of energy through subsidies or existing scrappage scheme

• Disincentives for old and high polluting vehicles such as ending the 2-tier taxation system (lower tax for older cars), limiting access to residential neighbourhoods for vehicles with old engines/diesel trucks (according to EURO 3-6)

• Pedestrianise certain areas

• Tax emissions

Alternative modes of transportation: Some of the recommendations are already • Promote shared vehicles to reduce car in-cluded in the NAPCP, however the other ownership (car-sharing and bike-sharing rec-ommendations have been noted and schemes) will be discussed further with the relevant authorities. • Incentivise carpooling to reduce the share of single-occupancy trips in rush hours (one person per car). It could be achieved by providing tax incentives to corporates to use shared public transportation instead of private vehicles

• To enable the use of the same fleet across multiple services such as ride-hailing, deliveries and car-sharing. The same fleet can service different purposes during Malta’s National Air Pollution Control Programme - 2019 109

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Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

different hours reducing the fleet and the need for parking spaces (at the moment Y plate can only be used to carry passengers, CSH for car-sharing)

• Incentives for the public to use alternative mobility options rather than owned vehicle. An idea would be to issue a mobility wallet for the public with monthly funds that can be used for transport. Different social groups would be receiving different funds. This wallet could also incentify people to scrap their car and use only alternative modes of transport.

Infrastructure Some of the recommendations are already • Build a network of bike lanes to incentify in-cluded in the NAPCP, however the other the use of traditional and electric bikes, kick rec-ommendations have been noted and scooters and electric mopeds will be discussed further with the relevant authorities. • Monetise parking in highly populated areas

10 Michelle Borg Further to the public consultation process Comment has been noted. Planning Authority concerning the subject in caption, the Planning Authority takes note of the 24/01/2020 proposed measures included in the draft NECD National Air Pollution Control Progamme. Considering that a number of the measures are influenced by their spatial context, the PA looks forward to future consultations with ERA and relevant authorities, to support their implementation where relevant.

11 Ralph Cassar Alternattiva Demokratika notes that Air pollution remains one of ERA’s major Alternattiva the National Air Pollution Control concerns and it is not the intention to Demokratika Programme (NAPCP), for which public minimise the issue. ERA has always been consultation closes today fails to call for the consistent in stating that the major source 24/01/2020 implementation of effective measures to of air pollution in urban areas is road traffic. reduce substantially dangerous emissions This is confirmed by data emanating from 110 Malta’s National Air Pollution Control Programme - 2019

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Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

from vehicles, namely NOx (nitrogen oxides). the air quality monitoring stations managed by the Authority. The main effects of NOx is the increased likelihood of respiratory problems, especially It should be acknowledged that there have in children and older people. NOx inflames been improvements in the past years, both the lining of the lungs, and it can reduce in terms of tonnes of pollutant emissions immunity to lung infections. This can cause per year and in ambient air pollutant problems such as bronchitis. This pollutant concentrations due to the overall reform of can also cause more frequent and more the power generation sector. The reform intense asthma attacks. of the public transport system has also achieved results, whilst Malta has also made While the NAPCP on page 44, table 2 says progress in the implementation of a number that in the scenario "with measures" Malta of sustainable mobility measures. Of course, will emit a total of 4.9 kt of NOx when the more needs to be done in this area, as the limits are only 2 kt. With so called “additional NAPCP itself explains and acknowledges. measures” proposed in the draft action plan emissions go down marginally to 4.5kt (page Here, a comparison of NOx emissions for 68). This is unacceptable. two emission scenarios is being made, which are compared with Malta’s emission ceiling ERA and the Ministry should come up with for this pollutant. Whilst this comparison is a revised plan which will achieve the 2 kt correct, it is to be noted that this ceiling is to NOx target. On page 49 of the document, it be reached by 2030. Emission projections for is stated that so called ‘low emission zones’ 2020 show that Malta will not have difficulty in congested and polluted roads will only ‘be in reaching the 2020 ceilings, however studied’. The time for just studying things more effort is needed to reach our 2030 when it comes to pollution should have long targets; this is why solid air quality policy, been over. We demand the implementation accompanied with relevant studies are both of low emission zones which restrict the important to deliver the required results. access of vehicles to polluted areas and the implementation of other effective measures With regards the comment on LEZs, it would to tackle pollution from vehicles. not be wise to implement a low emission zone without first studying various options It is imperative that pollution from road on how it can be implemented to achieve transport as a major contributor of NOx the required environmental benefits. As emissions (41.7% in 2030) is tackled the NAPCP explains, the study will look effectively. at the different options available to Malta and Gozo, and to assess which ones would Failure to take effective measures mean a deliver the desired results swiftly. The study breach of Directive 2016/2284. The aims would also assess the size of a feasible LEZ of this Directive as explained in recital 27, within the already identified potential zones states clearly that citizens of EU member to achieve the greatest positive impact to states have a right to expect that member the environment, with the greatest benefit Malta’s National Air Pollution Control Programme - 2019 111

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Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

state governments comply to the directive to citizens’ everyday lives. since non-compliance has a direct effect on their health. The priority is to make LEZ a successful system and thus the requirement to attract Note: the citizens’ confidence that this scheme is Directive 2016/2284 Recital 27: "The aim beneficial on all fronts and to avoid failure of this Directive, inter alia, is to protect human and distrust, with the ultimate aim to health. As the Court of Justice has pointed induce a long-term (especially commuter) out on numerous occasions, it would be behavioural change of how people get incompatible with the binding effect which the to-and-from congested areas, which would third paragraph of Article 288 of the Treaty lead to cleaner air throughout the Maltese on the Functioning of the European Union islands. (TFEU) ascribes to a directive to exclude, in principle, the possibility of an obligation imposed by a directive from being relied on by persons concerned. That consideration applies particularly in respect of a directive which has the objective of controlling and reducing atmospheric pollution and which is designed, therefore, to protect human health."

12 Claire Bonello The document submitted for public Here, a comparison of NOx emissions for Futur Ambjent consultation is disappointing and shows two emission scenarios is being made, which Wiehed a lack of readiness to address air quality are compared with Malta’s emission ceiling problems and issues - especially caused by for this pollutant. Whilst this comparison is 24/01/2020 road transport, ever-increasing personal correct, it is to be noted that this ceiling is vehicle use and the relentless increase in to be reached by 2030. Emission projections highway capacity. show that Malta will not have difficulty in reaching the 2020 ceilings, however Particular reference is being made to more effort is needed to reach our 2030 Nitrogen Oxides emissions from vehicles. targets; this is why solid air quality policy, ”The NAPCP on page 44, table 2 says that accompanied with relevant studies are both in the scenario “with measures” Malta will important to deliver the required results. emit a total of 4.9kt of NOx when the limits are only 2kt. With so called “additional measures” proposed in the draft action plan emissions go down marginally to 4.5kt (page 68).

Why is this being taken so lightly, with no real and effective attempts to address the 112 Malta’s National Air Pollution Control Programme - 2019

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Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

situation? A genuine commitment has to be made towards sustainable transport such as walking and cycling and of encouraging public transport whilst discouraging personal vehicle use.

Instead, the document presented for consultation continues to present "greenwash" measures which fall short in several respects and do not address the real problems with regards to deteriorating air quality and not ever really addressing traffic and transport issues which are inextricably linked to air quality.

The following are some of the ineffectual measures in the document presented for public consultation:

1. Incentivising measures such as Green Comment has been noted. It is recognized Travel Plans. that this is a soft measure, however it is to A GTP is currently only mandatory be acknowledged that it is not applied in in the case of high rise and intensive locations experiencing severe increase in developments. It is a soft (useless) traffic. The NAPCP includes other concrete unenforceable measure - usually consisting measures (such as the study on the LEZ). of ineffectual measures such as printing The fact that these GTPs are not enforceable pamphlets indicating bus routes, allocating does not mean that they cannot be applied a couple of showers for cyclists. In one in situ. Green Travel Plans should not be case – where the development in question considered as useless: but rather to raise was going to generate an obscene amount awareness. of traffic - the suggestion was to provide vouchers for sports wear. It is not clear how Having said so, Green Travel Plans are not providing sportswear will alleviate traffic. only being suggested for new developments. It is submitted that road safety is a more As stated in the NAPCP, a Green Travel Plan pertinent consideration for cyclists and is being put together for the Ministry for pedestrians than having subsidized running Infrastructure, Transport and Capital Projects gear. (MTIP) as a pilot project, to later implement similar initiatives in other Ministries. Moreover GTPs are merely monitored - there is practically no way of ensuring that they have met their traffic mitigation targets. If they don't, the traffic-inducing development Malta’s National Air Pollution Control Programme - 2019 113

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Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

would long have been in operation and everybody is all the worse off for it. The GTP is merely a sop to alleviate concerns at the time of the Planning application. It is ineffective, unenforceable and useless.

2. Encouraging cycling and walking. Comment has been noted and will be The document presented for consultation referred to the relevant authorities. makes a lot out of the financial incentives for cycling. Whilst this is a step in the right direction, it is not enough. The major obstacle to wider cycling uptake and walking is the dangerous and inaccessible infrastructure and roads. Ironically this is exacerbated by a government agency - namely Infrastructure Malta which has obstinately persisted in its road widening spree, increasing highway capacity in total disregard of sustainable transport principles as well as the National Transport Masterplan which advocates:

"In Malta, several sections of the conventional strategic roads pass though busy urban areas which act as bottle-necks. Here it is difficult to increase road capacities for motor vehicles by road widening or new road building, so the general approach will be to increase road capacities through measures to enhance numbers of travellers passing through the link rather than the number of vehicles.” (NTM, page 132)

Particular reference is being made to Comments have been noted. However, the the Central Link Project where a totally NAPCP is focused at a national strategic retrograde highway increase of capacity level rather than on specific cases. Individual was not coupled with sufficient measures cases are addressed through Environmental to improve the modal shift and sustainable Impact Assessments or other assessment transport options. procedures.

The PDS for this project identified a number of social impacts of the project, some with a direct impact on accessibility and mobility, 114 Malta’s National Air Pollution Control Programme - 2019

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Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

whilst others having a direct link to public health (beyond those related to emissions). The scheme shows a reduction in the number of pelican crossings (from 14 to 9) along the southern and northern sections of Attard. According to the PDS, apart from the social implications associated with reduced accessibility and social exclusion, there will be severance experienced by the Attard community living in proximity of the scheme... “The reduction in pedestrian crossings and the increased vehicular speed will act as a deterrent for those unable to drive as it will most likely discourage walking.”

Noise and air pollution were also mentioned as likely impacts of increased traffic and increased speed at various locations along the road section. Nevertheless - despite these issues being highlighted and the cycling advocacy group expressing its concerns at the inadequate, unsafe cycling infrastructure provided, ERA gave its approval for the project. This - despite the fact that ERA acknowledged that there is clear evidence that widening roads rapidly fill with induced traffic (Maltatoday 2nd June 2019). If the environmental authority fails to stand firm against such a large project which will augment and encourage personal vehicle use to the detriment of other modes of transport, what hope is there?

The excuse that this is the implementation of the TEN-T network as per the relevant legislation is just an excuse - both the regulation, the National Transport Plan and the Local Plan militate against the predict and provide approach assumed by Infrastructure Malta and prioritise safe, integrated multi-modal transport modes. Malta’s National Air Pollution Control Programme - 2019 115

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Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

The issue of safety is of paramount importance to encourage sustainable modes of transport. In this respect, the mandatory requirements of road safety audits even at the conceptual stage, should be observed. Unfortunately – they are not – a case in point is the Tal-Balal Road. It is far more difficult if not impossible to address road safety issues when the project has been completed and road users simply have to risk their lives because of the developer’s failings and the authorities’ lack of scrutiny.

3. Pilot cycling corridors Comment has been noted and will be Mention is made of this proposal. It is noted referred to the relevant authorities. that whilst these pro-cycling measures remain at "pilot" stage, or are localised in nature, massive infrastructural projects which incentivise personal vehicle use are actually implemented. The Central Link is a case in point . The Malta-Gozo tunnel is another massive project which is more imminent than a nation-wide cycling network and pedestrian pathway.

4. Public Transport improvement and quality Comment has been noted and will be corridors referred to the relevant authorities. The rise in the number of public transport and bus users is cited as a certification that things are improving on this front. There is no recognition of the fact that this is also due to the increase in population, and that the increase in bus patron-age is not proportionate to the increase in personal vehicle take up.

It is not clear what is meant by "quality corridors". The con-cept of Strategic Bus Corridors and Bus Selection technology has been required since 2006 in the Local Plans - yet it has been totally and utterly disregarded and dismissed. 116 Malta’s National Air Pollution Control Programme - 2019

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Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

Again - a particular case in point - the Central Link Project - where the mandatory Local Plan requirement was ignored and instead bus lay bys were introduced. These are no substitute to Strategic Bus Corridors as buses encounter delays when exiting laybys as oncoming traffic does not let up to allow the buses to exit. There was no enforcement of this mandatory Local Plan requirement (one also found in the NTM). It is not understood how the vague notion of "quality" corridors will fare better.

5. Refusal to implement low emission zones Solid air quality policy, accompanied with as soon as possible relevant studies are both important to This is a scandalous renegation of deliver the required results, that of improved responsibility for air quality deterioration. air quality. It is therefore important to first Only a vague reference to carrying out study the various options on how a Low a "study" is indicated in the document. Emission Zone can be implemented for it to No time frames are included, no real achieve the required environmental benefits. commitment to do anything concrete about As the NAPCP explains, the study will look this effective measure of introducing low at the different options available to Malta emission zones. and Gozo, and to assess which ones would deliver the desired results swiftly. The study This - despite the fact that creating would also assess the size of a feasible LEZ disincentives for personal vehicular traffic within the already identified potential zones has been found to work in altering public to achieve the greatest positive impact to behaviour. A case in point is the 10% shift the environment, within the greatest benefit from car to bus when the Valletta road to citizens’ everyday lives. pricing scheme (CVA) was introduced in 2007. Ten per cent of car trips to The priority is to make the LEZ a successful Valletta recorded in the 1998 Household system, with the ultimate aim to induce a Travel Survey shifted to bus in the 2010 long-term (especially commuter) behavioural Household Travel Survey as a result of change of how people get to-and-from reduced circulation and parking due to congested areas. pedestrianisation in the commercial centre, parking management and introduction of a pay-as-you go charge for access into the City. Malta’s National Air Pollution Control Programme - 2019 117

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Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

6. Incentivising renewable energy sources Comment has been noted and will be Again - any measures in this regard will referred to the relevant authorities. be ineffective unless a legal regime of solar access rights and easements is introduced and enforced. What is the point of incentivising solar energy if high rise developments limit or stop access to solar energy?

In view of the above the document presented for consultation does not provide any solutions or efficacy and will not address Malta’s air quality issues. 118 Malta’s National Air Pollution Control Programme - 2019

Annex 4 cont. Submissions Made During Consultation Meeting held on 3/12/2019

Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

1 Anonymous Recently an article was published which The National Emissions Ceilings (NEC) 03/12/2019 stated that cruise liners emit as much air Directive covers internal navigation, i.e. pollutants as small cities. However, there maritime activities involving ships which is no reference to cruise liners in the depart and arrive in local harbours, such presentation. Does this mean that they are as the Gozo Channel, fishing vessels and not being considered, or does it mean that recreational vessels. Therefore, international they don’t emit as much as claimed? cruises are not covered by the Directive and not included in the NAPCP.

This does not mean that cruise liners do not affect local air quality. A local peer- reviewed study, carried out at the Msida Air Monitoring Station on PM2.5 found that international cruise liners were responsible for 5% of emissions in 2016, while road transport was responsible for 27%. Visual air pollution emitted from cruise liners does not necessarily mean that they are having a substantial impact on local air quality, since meteorological parameters are an important consideration in the process. In this regard, road transport is being targeted as the major source and therefore a major priority.

Since the Msida Station is not in the main path of emissions from cruise liners from the cruise port, ERA will be conducting a study in 2020 closer to Senglea, which is downwind from the Grand Harbour, to better understand the situation.

2 James Gabaretta It is alarming that certain aspects (like cruise This plan is a deliverable for an EU Directive, Nature Trust Malta liners) are not being considered, since this which clearly stipulates what should be is a national action plan, therefore national included in the plan. Therefore, international 03/12/2019 interests should be given priority over EU shipping cannot be included for the sake targets. I agree that international cruise of comparability with other Member liners need to be included. States. This does not mean that ERA is underestimating the impact of international Most of the mentioned measures target shipping on air quality. ERA acknowledges transport. I fail to understand why ERA that this is of national concern and therefore should be the competent authority on this will be intensifying studies on the effect of Malta’s National Air Pollution Control Programme - 2019 119

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Name of Ref Stakeholder / Comments Received Response / Remarks No. Date

and how ERA and Transport Malta will be international shipping on local air quality in working together to ensure that these the near future. measures are actually implemented. This document has been drafted by ERA What is ERA doing to incentive its following extensive discussions with employees to use alternative modes of Transport Malta (TM) and other authorities transport? ERA needs to set the right and entities. Although ERA does not example. Most measures are focused on car have a direct remit on traffic, it is ERA’s use, but not everyone has a car e.g. I use a environmental responsibility to spearhead motorbike. Alternative means of transport this programme. ERA has always cooperated exist, and we need to move away from the with TM, who will have to implement a idea that everyone is a car driver. number of the measures of this programme that have been streamlined from their National Transport Strategy.

This plan is a deliverable for an EU Directive, which clearly stipulates what should be included in the plan. Therefore, international shipping cannot be included for the sake of comparability with other Member States. This does not mean that ERA is underestimating the impact of inter-national shipping on air quality. ERA acknowl-edges that this is of national concern and therefore will be intensifying studies on the effect of international shipping on local air quality in the near future.

This document has been drafted by ERA follow-ing extensive discussions with Transport Malta (TM) and other authorities and entities. Alt-hough ERA does not have a direct remit on traf-fic, it is ERA’s environmental responsibility to spearhead this programme. ERA has always co-operated with TM, who will have to implement a number of the measures of this programme that have been streamlined from their National Transport Strategy.

ERA has a green travel plan. Incentives are offered to employees to use alternative 120 Malta’s National Air Pollution Control Programme - 2019

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modes of transport, including incentives to use public transport and to cycle to work by increasing cycling infrastructure (e.g. bicycle racks, showers). We try to lead by example, however it then depends on each individuals’ decisions.

3 Stephen Camilleri Cruise liners in a port does require significant Incentives for shore power are an interesting Transport Malta power. These often run on diesel, therefore proposal. ERA will be looking into this there are emissions happening at all times. further in relation to future measures to be 03/12/2019 TM did a study a few years ago on the included in the upcoming air quality plan. possibility of plugging in cruise liners into Since it is internal travel, the Gozo Channel the national electricity grid network, to take is covered by this plan and it is good to note advantage of the cleaner energy. However, that these ships are already using shore this study was inconclusive since there was power in the Mġarr Harbour. no clear policy direction about whether ships need to be encouraged to be cleaner or not. There is a need to look at what incentives and disincentives can be offered to plug in ships to the national network. This includes national navigation such as the Gozo Channel, which plug into a generator at night, and could include tug boats and all other vessels which don’t power off and could easily be plugged in. Cruise liners are probably the most difficult to plug in because of the power requirements.

With reference to aviation, emissions from Commenter was asked to submit a proposal Landing and Take-off (LTO) cycles are set in writing. to increase. Since it is difficult to make actual changes to aircraft, there is a policy opportunity to make improvements on the ground operations in the airport, to make processes more efficient.

In the studies carried out for the Transport Master Plan and the National Transport Strategy, one of the most effective, but also most difficult, policy measures was the Malta’s National Air Pollution Control Programme - 2019 121

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implementation of quality public transport corridors. This was holistically looking at making the public transport experience better overall.

One of the best ways to prevent pollution of any type is not to burn fuel, therefore we should be using active travel more (i.e. walking, cycling, etc.). Anything which does not need a battery is positive (electric cars will still need to use fuel at the power stations).

4 Anonymous I come from the area of producing Commenter was asked to submit a proposal 03/12/2019 carbohydrates, which set free pure oxygen. in writing. The 114 sq km of plots, parcels and fields in Malta and Gozo are capable of producing more fresh air than they have been doing over the last few years, perhaps since accession to the EU. So my observation is that MEPs have been tardy in recognising what croplands are capable of producing.

5 Nicoletta Moss Most areas which are subsidised are where With regards to micromobility, we can Debono Group Malta Public Transport or Transport Malta discuss your suggestion with the Ministry are involved. There are several private responsible for transport, to see whether we 03/12/2019 companies that provide alternative modes can develop any measures to include in the of transport such as micromobility and plan. carpooling. It would be beneficial if these are also included in the proposal. ERA supports all alternative fuels. The Ministry responsible for transport is looking There is a lot of emphasis on electric into a number of options for alternative vehicles, while hydrogen power is not being fuels. considered. There are several areas where hydrogen power can be implemented, such Apart from having a Green Travel Plan, ERA as hydrogen buses. also reviews development proposals. We always take the opportunity when reviewing Debono Group is also working on a green major development applications to add mobility plan. It would be beneficial to learn requirements for the inclusion of green travel from other companies who have such plans plans for employees. 122 Malta’s National Air Pollution Control Programme - 2019

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in place (like ERA’s). Incentives should be provided to encourage large corporations to adopt green mobility plans. It is a first step – if your neighbour does it, other people will follow.

It would be beneficial to get rid of the two-tier taxation system in place, to encourage changing multiple family cars with alternative means of transport.

6 Ruben Abela It appears that the largest contributor to With reference to projections, these require pollution is road transport. The presentation a long reference time period. Reporting 03/12/2019 showed data up to 2017 and states that cycles for air quality data are retrospective, the concentration of NO2 will remain since the data processing takes time. stable. It is not clear whether this took into consideration the number of vehicles being registered today, compared to 2017. As we have, there is a large tie between individuals and their cars, and it is not easy to make a cultural change.

The government and policy makers are giving With reference to planning tools, ERA will the direction to increase the use of electric consider exploring this further with the vehicles. So far, a significant change has not Planning Authority. There is good scope been seen. First of all, planning policies give for obligations to be imposed on large no consideration to electro-mobility. For developments for electric charging points. example there are no obligations emerging from the DC15 for developers to include facilities such as charging stations for electric vehicles (including charging stations). From an infrastructure perspective, current road works are not giving consideration to infrastructure required for electrification. How are people who don’t have garages going to charge their vehicles? The charging points currently available around the country are not economically viable, since a contract has to be signed with the provider to pay a monthly fee regardless of the amount of charging. Currently, there are only three free Malta’s National Air Pollution Control Programme - 2019 123

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charging points in Marsa, Cirkewwa and Ta’ With reference to projections, these require Xbiex. a long reference time period. Reporting cycles for air quality data are retrospective, In the 2017 electoral programme, one of the since the data processing takes time. government policies is for public entities to have electric fleets of cars. However, the With reference to planning tools, ERA will Ministry of Finance has a circular which caps consider exploring this further with the the value of cars which can be bought, thus Planning Authority. There is good scope excluding electric cars from being able to for obligations to be imposed on large be bought. This circular has to be removed developments for electric charging points. or revised. The government is giving a direction that cars should be bought rather MFIN has clarified that the circular’s than leased. No department can publish thresholds apply to ICE vehicles and tenders for electric cars, as these will not be the circular specifically states that accepted by the Ministry for Finance. environmental-friendly vehicles would be considered on their own merits. One of It is true that grants for electric vehicles the measures included in the draft NAPCP, exist, however these grants have changed. which has been endorsed by government, is Before it was feasible to get an almost that the government should lead by example new second hand car from the UK, since and electrify its fleet. This measure will help the grant was €5000. Now the grant was to address any issues related to capping of reduced to €3000, presumably to safeguard costs. cars from local businesses. We have to see why these changes are happening, as these This policy and other government policies are not incentivising people to buy electric are clear that grants for electric vehicles will vehicles. contin-ue. One needs to look at individual grants in de-tail to see how they will be We speak about grants, but are afraid to implemented. mention taxes, since government policy is not to introduce new taxes. A large volume Discussions on registration taxes are of SUVs are being imported, which are more ongoing. expensive than electric cars. These should be taxed since they have large engines. They ERA is giving due attention to cruise liners, already pay higher licenses, but these need and will be carrying out intensive studies to be increased, to reduce issues of parking with our mobile monitoring station in the spaces and pollution. The money from taxes Senglea area, which are potentially affected can then be used to offer more grants. by cruise liner emissions. With reference to international shipping, the Gharb While it is conceded that this plan is being monitoring station is intended to measure done as part of an EU obligation, the health the background concentrations of air of Maltese citizens should be given priority pollutants, as well as to gauge the levels of over EU obligations. Cruise liners do not transboundary pollution (including from 124 Malta’s National Air Pollution Control Programme - 2019

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affect most of Europe, bearing in mind international shipping). So far, there is no several countries are mostly land-locked. I significant evidence that Malta is significantly am not sure whether there is a directive on affected by emissions from shipping. We are transboundary emissions. The volume of affected by other transboundary pollutants tankers passing around Malta is very large. such as ozone, which does not originate These tankers use Heavy Fuel Oil (HFO) directly from shipping. since it is cheaper and can use it outside territorial waters. What effect are these emissions having on Malta? A black cloud can be seen over the horizon on calm days.

Aviation traffic has increased drastically. Malta has benefitted economically from this as flights passing over Malta have to pay a tax. How is Malta being affected by emissions from such aircraft?

7 Christopher Cutajar With reference to electromobility, we are Comments are noted with thanks. ERA looks Permanent currently in the process of transposing a forward for further collaboration with TM/ Secretary Ministry directive related to making buildings more MTIP. for Transport, suitable to sustain electro-mobility. This Infrastructure and aspect falls under building regulations, rather Capital Projects than planning applications. We are currently at an advanced stage of this transposition, 03/12/2019 and will be presenting to cabinet.

With reference to the charges for users to charge electric cars. From January 2020, the system will be pay per use per unit of consumption, rather than monthly fees and requirements to register. This will act as a further incentive for local as well as foreign users to use electric vehicles.

Furthermore, there are 90 charging points from the DEMO EV project, which served as a pilot project offering electrification infrastructure, and three solar charging stations from the PORT-PVEV project. These should be used at a charge also, as there were situations where users would take Malta’s National Air Pollution Control Programme - 2019 125

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advantage of this free service.

As part of the 2020 budget, Enemalta announced that it will be offering favourable rates for those who charge their electric vehicles overnight.

It is beneficial that this policy is under the watch of the Ministry for the Environment, because ultimately all policies are implemented for the benefit of our environment. The e-cars committee is the ideal forum for holding discussions between representatives from the transport, energy and environmental sectors. The social and financial aspects also have to be taken into consideration.

When focusing on financial considerations, it is important to recognise that current car registration is producing considerable revenue. Thus, a thorough exercise has to be carried out to assess the implications of implementing the polluter pays principle; such that when the fleet starts converting to alternative mobility, users of the road network are taxed for the maintenance of the road network as is the practice in other countries. This exercise, together with the carrying out of relevant consultations will also feed into improved knowledge on the cut-off date for the importation of ICE vehicles.

A survey on the use of alternative use of transport was carried out within the Ministry for Transport, which resulted that 30% use alternative modes of transport. For Green Travel Plans, it is important to start by consolidating what we already have, by incentivising those who are already using green transport. Further efforts need to be 126 Malta’s National Air Pollution Control Programme - 2019

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made by Government entities to strongly invest in Green Travel Plans.

8 Nicholas Bellizzi I would like to know whether ERA puts ERA will be discussing this very positive NBEngineering pressure on the government to put common suggestion further with other responsible Services gas reserves in industrial estates, for entities. 03/12/2019 companies who would like to shift to gas from HFO. The current problem is that the companies have no place where to put a gas tank, due to the parameters given by REWS and CPD. Several users of HFO, such as laundries, cannot shift to alternative fuels.

Certain businesses require constant Subsidies are being proposed in the plan, travelling. Is it possible for the government although ERA has not gone into detail in to give specific subsidies to such businesses, the document since further discussions are which pollute extensively due to the nature required to set up these schemes. However, of the work involved? Currently it is too ERA will consider businesses that require expensive to shift an entire fleet to electric frequent travelling in future discussions. vehicles.

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