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Letters • 11 June 2006


The challenge of climate change

Reference is made to the article ‘Government pulls up socks over climate change’ (4 June 2006).
Unfortunately, although already corrected in previous instances, the journalist again refers erroneously to emission reduction targets for Malta under the Kyoto Protocol. It needs to be reiterated that Malta has no obligation to limit or reduce national greenhouse gas emissions under any legislative instrument, whether European Union or international. At the same time it is important to note that Malta is actively working on the implementation of EU legislation that will directly or indirectly control emissions of greenhouse gases (ex. the EU emissions trading scheme).
Reference is also made to Malta’s emissions per capita and emissions per square meter said to be, at 7,000kg. It has to be noted that Malta has the third lowest rate of emissions per capita, which is certainly a significant positive result. It is also interesting to note the reference to emissions per square metres; the fact that Malta is a very small island makes it difficult to lower the rate of emissions per square metre to any significant extent.
In referring to emissions quotas for the industrial sectors, the journalist should have made reference to the EU emissions trading scheme rather than the Kyoto Protocol. Besides, if an installation exceeds its ‘quota’ of emissions, it can purchase allowances, from other installations falling within the scope of the emissions trading scheme, to increase its ‘quota’ and thus have no need to pay the penalties envisaged by law.
The article also says that Malta has even reserved an extra 2.3million tonnes for the possibility of new entrants in the power sector. The new entrant is not solely reserved for any new installations in the power sector, but for any new installations under any of the activities as listed in Annex I to Directive 2003/87/EC. While, when compared to the total Maltese allocation, the new entrant reserve may be seen as being relatively high, in absolute terms it is not; also, allocation from this reserve will be made on the basis of a number of criteria such as the use of Best Available Technology.
What is truly mystifying is the assertion that Malta has to reduce emissions from Marsa and Delimara by a staggering 42 percent in the next three years to reach 1990 emissions levels. This is a highly erroneous statement as no such obligation exists.
It is true that pressure is mounting for more stringent allocations. The Commission cannot review downwards allowances, first because it cannot do so with respect of allocations for the trading period 2005-2007, which allocations have already been accepted by the Commission and cannot be changed; and secondly because estimates for allocations for the period 2008-2012 have yet to be submitted by member states through their National Allocation Plans.
This article again highlights the great challenge in understanding complex and specific sectoral issues in the environment. Writing on climate change issues in general and emissions trading in particular is not an undertaking to be dived into lightly. It is also to be noted that despite great efforts made with regards to the public consultation process on the draft National Allocation Plan, only a very few comments were received, and these mainly from stakeholders.

Sylvana DeBono
PRO
Malta Environment and Planning Authority





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