The Malta Environment and Planning Authority (MEPA) has warned that in the absence of alternative sources of energy, SmartCity could cost the country €1.95 million a year in carbon allowances.
“If SmartCity is to purchase its electricity from Enemalta, this cost would either have to be borne by Enemalta itself or passed through to the client,” MEPA said in its reactions to the Environment Impact Statement presented by the developers.
In comments attached to the Environment Impact Study presented by the developers, MEPA warned that by 2013, all allowances to electricity generation installations would be allocated through an auctioning syste:; set at a base price of €20 per tonne of CO 2.
This is envisaged by EU Directive 2003/87/EC, which regulates emissions trading in the European Union. According to this directive EU member states can buy an allowance to compensate for carbon emissions which exceed their EU allocation.
MEPA estimates that SmartCity will cost Enemalta €1.95 million annually in emissions if these costs are not passed to the developers.
According to MEPA the energy demand projected in the EIS is 20% higher than that envisaged in Malta’s National Allocation Plan (NAP) – a document submitted to the European Union to set Malta’s allocation of carbon emmisions.
In the NAP it was envisaged that SmartCity would consume 87.6 GWh (Gigawatt hours) per year. But in the EIS the developers are projecting a load of 110 GWh. This is equivalent to the consumption of 30,000 Maltese households.
Enemalta has been allocated 2.1 million tonnes of CO2 emissions a year as from 2008. But the NAP had predicted that this would already be exceeded by 2008, before SmartCity commences operations. SmartCity will increase electricity demand by around 5% and thus add the equivalent of almost two million tonnes of emissions a year on Enemalta.
In its comments on the EIS, MEPA pointed out that any energy derived from renewable sources on the SmartCity site would be free of any allowance-related costs.
MEPA also recommended the use of alternatives, such as Combined Heat & Power (CHP), which are more efficient than conventional electricity generation.
But this option was ruled out by the consultants of the SmartCity project.
Combined Heat and Power (CHP) is the simultaneous generation of usable heat and power in a single process. CHP is a highly efficient way to use both fossil and renewable fuels and can therefore make a significant contribution to the Malta’s sustainable energy goals, bringing environmental, economic, social and energy security benefits.
The use of CHP would have required the installation of a couple of efficient diesel generators whose electricity-generating efficiency could be as high as 40% compared to Enemalta's 25% efficient power plant.
The heat produced by CHP could be used to provide SmartCIty with free central heating. Moreover in summer it is possible to use the waste heat to drive a refrigeration cycle to get electricity-free air conditioning.
The need to carry out technical, economical and environmental studies on the use of renewables and CHP for a development of the size of SmartCity is actually a requirement of the Energy Performance of Buildings Directive.