MM Phase 1

Strategy for Renewable
Electricity Exploitation
in Malta
Volume 1: Renewable
Electricity Target
Final Report
July 2005
Potential Exploitable Renewable Electricity Study Malta Mott MacDonald
Malta Resources Authority

Millennia 2nd Floor
Aldo Moro Road
Marsa LQA 06
Malta
Strategy for
Renewable Electricity
Exploitation in Malta
Volume I: Renewable
Electricity Target
July 2005
Mott MacDonald
Victory House
Trafalgar Place
Brighton BN1 4FY
United Kingdom
Tel 01273 365000

Fax 01273 365100
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F:\PROJECTS\206106 Malta\Phase 1 deliverables\Phase 1 report\Final Report\Final Report Volume 1 main report.doc
Strategy for Renewable

Electricity Exploitation in
Malta
Volume 1
Issue and Revision Record

Rev Date Originator Checker Approver Description
(Print) (Print) (Print)
(Signature) (Signature) (Signature)
Isabel Philip
A July 2005 John Porter First Issue
Boira-Segarra Napier-Moore
This document has been prepared for the titled project or named part thereof and should not be relied upon or
used for any other project without an independent check being carried out as to its suitability and prior written
authority of Mott MacDonald being obtained. Mott MacDonald accepts no responsibility or liability for the
consequences of this document being used for a purpose other than the purposes for which it was commissioned.
Any person using or relying on the document for such other purpose agrees, and will by such use or reliance be
taken to confirm his agreement to indemnify Mott MacDonald for all loss or damage resulting therefrom.
Mott MacDonald accepts no responsibility or liability for this document to any party other than the person by
whom it was commissioned.
To the extent that the report commissioned is to be based on information supplied by other parties,
Mott MacDonald accepts no liability for any loss or damage suffered by the client, whether contractual or
tortious, stemming from any conclusions based on data supplied by parties other than Mott MacDonald and used
by Mott MacDonald in preparing this report.
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List of Contents
Glossary G-1
Summary S-1
Sections and Appendices
1 Introduction 1
1.1 Objectives 1
1.2 Context 1
1.3 Conclusions and Recommendations 2
1.3.1 Conclusions 2
1.3.2 Recommendations 2
1.4 Report Structure 2
2 Methodology 4
2.1 Model Inputs 4
2.1.1 Screening Exercise 5
2.1.2 Resource Characterisation 5
2.1.3 Environmental and Planning Barriers 6
2.1.4 Legislative Review 6
2.1.5 Project Costs 7
2.1.6 System Costs 7
2.1.7 Summary of Model Inputs 8
2.2 Constraints 9
2.3 Scenarios 9
2.3.1 Scenario A: Reaching 5% of Demand by 2010 9
2.3.2 Scenario B: Feasible Technology Penetration Rates 10
2.3.3 Scenario C: Windfarm Installation post-2010 10
2.4 Sensitivities 10
2.5 Format of Results 11
3 Results 13
3.1 Scenario A: Reaching 5% of demand by 2010 13
3.1.1 Characteristics 13
3.1.2 Results 14
3.1.3 Conclusions 15
3.2 Scenario B: Feasible Technology Penetration rates 16
(i) Feasible Penetration Levels for Medium Scale Wind 16
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(ii) Feasible Penetration Levels for PV 17

3.2.2 Results 17
(i) Scenario B1: One Large Onshore Windfarm 18
(ii) Scenario B2: No Large Onshore Wind 19
3.3 Scenario C: Windfarm installations post-2010 20
3.3.2 Results 20
(i) Scenario C1: Two Large Onshore Windfarms (one by 2010 the other post 2010) 21
(ii) Scenario C2: One Large Onshore Windfarm post 2010 21
(iii) Scenario C3: No Large Onshore Wind and One offshore Windfarm post 2010 22
3.4 Sensitivities 23
3.4.1 Cost Sensitivities 23
3.4.2 Demand Sensitivities 24
3.4.3 Wind Turbine Size Sensitivities 24
4 Conclusions and Recommendations 26

4.1 Conclusions 26
4.2 Recommendations 27
Tables
Table 2-1: ACP results by technology................................................................................................... 11
Table 3-1: Results Scenario A ............................................................................................................... 14
Table 3-2: Results Scenario B1 ............................................................................................................. 18
Table 3-3: Results Scenario B2 ............................................................................................................. 19
Table 3-4: Results Scenario C1 ............................................................................................................. 21
Table 3-7: Capital Costs Sensitivities.................................................................................................... 23
Table 3-8: Operational Costs Sensitivities ............................................................................................ 24
Table 3-9: Demand Sensitivities ........................................................................................................... 24
Table 3-10: Results 850kW Large Wind Turbines................................................................................ 24
Table 3-11: Results 20kW Medium Turbines ....................................................................................... 25
Figures
Figure 2-1: Demand Scenarios to 2020 ................................................................................................... 8
Figure 3-1: Technology Costs ............................................................................................................... 15
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Glossary
ACP Average Cost of Power
EIA Environmental Impact Assessment
KW Kilowatt
KWh Kilowatt hours
MM Mott MacDonald
MRA Malta Resources Authority
MW Megawatt
MWp Peak Megawatt
MWh Megawatt hours
PV Photovoltaic
RES Renewables Energy Sources
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1 Introduction
1.1 Objectives
Mott MacDonald has been commissioned by the Malta Resources Authority (MRA) to assist in
developing a policy framework for the support of renewable electricity in Malta. The specific project
objectives are:
• to recommend and develop a national indicative target for generation of electricity from
Renewable Energy Sources (RES) in accordance with the requirements of the EU Directive
2001/77/EC
• to support with related information and documentation the submission to the EU on how
Malta can comply with the provisions of the Directive
• to provide a roadmap for implementation of support for RES for electricity generation.
To achieve the objectives the study adopts a three phased approach as follows:
• Phase 1 – characterise the resource, consider the barriers to renewable electricity
development and make suggestions for a renewable target, expressed as a percentage of
demand, to be achieved by 2010.
• Phase 2 – develop and present a policy options analysis of measures to support renewable
electricity in Malta.
• Phase 3 – complete an implementation roadmap guiding the MRA through the process of
implementing the selected option.
This report is part of Phase 1 and it recommends a national indicative renewable target for Malta.
1.2 Context
As part of the requirements for Malta to join the European Union, the European Commission set a
provisional target of 5% of renewable electricity generation, expressed as a percentage of demand, to
be met by 2010 as follows:
• 3% by waste
• 2% by wind
This study does not comment on the possible role of waste-derived renewable resources as a waste
generation analysis is outside of the present scope and undertaken by other entities. But based on the
information provided by WasteServe 1 and data contained in the Maltese Waste Strategy 2001, this
study assumes that 0.5% of Malta’s energy demand may be met from waste projects by 2010. 2 The
1
A.1.1 WasteServ Malta Ltd. was established in November 2002. The company is responsible for organizing,
managing and operating integrated systems for waste management including integrated systems for minimisation,
collection, transport, sorting, reuse, utilistation, recycling, treatment and disposal of solid and hazardous waste.
2
A.1.2 Based on communications from WasteServe dated 5th January 2005.
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focus of this report is then to determine whether meeting the remaining 4.5% target can be achieved by
2010. In doing so the study explores a range of renewable targets with varying contributions made by
different technologies suitable to Malta.
1.3 Conclusions and Recommendations
1.3.1 Conclusions
• Large onshore wind development is the most cost-effective technology; visual impact and
cumulative effects are likely to prevent more than one or two large onshore windfarms to be
built in Malta.
• Offshore wind is the second best technology option in terms of costs. There is one marginal
site identified in Malta, developing it would require resolving technical issues as well as
issues relating to the conflicting use of the site. Even if a developer was prepared to develop
this marginal site, it is unlikely that the windfarm would be installed before 2015.
• Micro-wind has not been considered a feasible option for Malta because of the planning
constraints that are likely to originate due to visual impacts on the Maltese townscape.
• The current Maltese planning framework sis more favourable to medium scale wind
exploitation but this comes at an economic cost and has implications on the overall
renewable electricity target that may be achievable.
• The PV resource potential in Malta is enormous, but the cost implications of supporting PV
are likely to be very high.
• Meeting 4.5% of electricity demand in 2010 by wind and PV is not feasible.
1.3.2 Recommendations
Based on the modelling analysis, the following recommendations are made:

• It is recommended that Malta sets a national indicative target for generation of electricity
from RES of 1% of demand by 2010 (assuming 2.8 TWh demand in 2010).
• To achieve this target it would be necessary to develop one large onshore windfarm on
mainland Malta. To ascertain whether this is feasible, it is recommended that MRA carries
out a visual impact study and a public awareness campaign as a matter of urgency.
• It is recommended that Malta that reduces barriers and develops policies to encourage
medium scale wind and PV to levels commensurate with the rates assumed in this report; 40-
80 rooftops/year for PV and 5x60kW wind turbines a year. This would require developing
incentives aimed at commercial users in particular.
1.4 Report Structure
The results of Phase 1 are presented in two volumes:

• Volume I: Renewable Electricity Target. This is the present report and it contains the
analysis of the national indicative target for generation of electricity from RES.
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• Volume II: Technical Annexes. These contain the supporting material used in the calculation
of the targets presented in Volume I. The annexes include:
− Annex A – Technology Alternatives
− Annex B – Wind Resource Characterisation
− Annex C – PV Resource Characterisation
− Annex D – Planning Barriers
− Annex E – Legislative Review
− Annex F – Technology Costs
− Annex G – System Costs
Volume I of the study is structured as follows:
• Section 2 outlines the modelling methodology

• Section 3 presents the modelling results
• Section 4 discusses conclusions drawn from the study and presents the recommendations.
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2 Methodology
The study focuses on 2010, as indicted by the EU Directive 2001/77/EC, but it extends the analysis to
2020 to give more time for constraints to be alleviated or removed and therefore a wider range of
options to be considered.
The different target levels presented in this report are calculated using an optimisation model
developed by Mott MacDonald. The model is based on the principle of cost optimization, using linear
programming to determine the optimal solution. The model is primarily developed in Microsoft Excel
but uses What’s Best® version 7.0 as a solver, at the back end. The version of the model being used
to generate the outputs is “Rengenmod v8 03.02.05”.
The salient features of the modelling process are explained below and they include:
• Model inputs
• Treatment of constraints
• Scenarios
• Sensitivities
2.1 Model Inputs
The information used in this study has been gathered from stakeholder consultation in Malta, data
provided by MRA and the Enemalta Corporation combined with industry knowledge and with
assumptions and extrapolations in instances where insufficiently detailed studies were available. This
information has been used to distil the inputs to the model through a number of steps:
• A screening exercise to identify the renewable technologies appropriate for Malta.
• A characterisation of the available resource for the selected technologies to identify the
maximum potential renewable capacity.
• An analysis of environmental and planning barriers to the exploitation of the available

resource to ascertain how much renewable capacity may be installed in Malta.
• A legislative review to identify any potential legislative barriers to the implementation of

renewables in Malta.
• An analysis of the project and systems costs that may stem for the integration of renewables
into the Maltese electricity system to allow the calculation of the costs associated with
different renewable technology mixes.
To allow a more accurate representation of the situation in Malta, inputs are structured by Local Plan
area:
• Central Local Plan Area (CLP)
• Gozo & Comino Local Plan Area (GCLP)
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• Great Harbour Local Plan Area (GHLP)
• Marsaxlokk Bay Local Plan Area (MBLP)
• North Harbours Local Plan Area(NHLP)
• North West Local Plan Area (NWLP)
• Malta South Local Plan Area (MSLP).
The following sections summarise the main steps taken in deriving the model inputs. Full details are
contained in the Study’s Technical Annexes.
2.1.1 Screening Exercise
A technology screening exercise was undertaken to select the renewable energy technologies with
available resource within Malta, before progressing to detailed analysis of appropriate technologies.
Details of the screening exercise are contained in Annex A.
The screening exercise identified onshore and offshore wind and photovoltaic (PV) together with
biomass waste, landfill and sewage gas as the most suitable sources of renewable energy for
exploitation in Malta.
As this study does not consider waste-derived renewable projects, the following technology options
were chosen to consider further:
• Onshore large scale wind farms (up to 2MW wind turbines)
• Medium scale single turbines (here defined as between 5kW and 100kW) at farmsteads and
similar buildings scattered around the islands (20-60kW turbines)
• Grid-connected micro-scale wind with 1kW machines fitted to roofs/buildings
• Offshore large wind farms (3MW turbines)
• PV installations fitted to existing buildings
• PV installations integrated into new buildings.
2.1.2 Resource Characterisation
Information gathered from MRA and from a number of publications of the Institute of Energy
Technology (IET) together with industry knowledge was used to characterise the maximum available
wind and PV resource for Malta.
Details of the analysis are contained in Annex B for wind and Annex C for PV. Annex B characterises
the wind resource in the Maltese Archipelago for wind energy exploitation. This is undertaken in two
steps:3
3
SgurrEnergy (a wind specialist consultancy) has assisted Mott MacDonald in the calculation of site wind speeds and energy
yields.
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• Step1: Calculation of the maximum available wind potential. This combines estimates of
suitable wind speeds with possible areas for exploitation without considering constraints.
This analysis results in the following:
− identification of potential sites for large wind exploitation (onshore and offshore) and
calculation of their associated maximum potential capacity installed (MW) and energy
yield (GWh). The maximum capacity and energy figures are inputted into the model in
the Local Plan area for each site.
− identification of the maximum levels of penetration for medium and micro-scale wind
and calculating the maximum potential capacity installed (MW) and energy yield
(GWh). This requires determining the maximum number of farmsteads etc that could
have a medium scale wind turbine and the maximum number of dwellings that could fit
micro-wind. In both cases, the unconstrained results assume 100% uptake. These
numbers are inputted into the model by Local Plan area.
• Step 2: Constraining the maximum wind potential to account for technical, environmental,
planning and legislative barriers that may be present in Malta. Applying constraints to the
maximum resource renders unviable some of the sites identified for large scale exploitation
and it reduces the penetration of medium and micro-scale wind. The representation of
barriers in the model is discussed in section 2.2.
Annex C contains the analysis for PV. The maximum potential is calculated first based on
unconstrained availability of the resource with 100% uptake of the maximum possible PV installed.
This maximum resource is then constrained to account for barriers. The resulting figures are inputted
into the model by Local Plan area.
2.1.3 Environmental and Planning Barriers
Annex D provides a high level analysis of how the current town planning framework in Malta, as it is
largely through the planning process that the specific nature and shape of renewable electricity
deployment and penetration will be dictated. The analysis includes consideration of the main
environmental impacts associated with the proposed development options identified in Annex B
(wind) and Annex C (PV). This analysis also highlights environmental and planning issues that have
the potential to restrict or halt development and offers recommendations for reducing such potential
issues. The discussion of environmental issues only highlights potential areas that, based on
experience, may cause problems during the planning consent procedure but it does not negate the need
to complete a project specific environmental impact assessment should it be required.
The barriers identified are then used in Annex B and Annex C to constrain the maximum wind and PV
resource respectively.
2.1.4 Legislative Review
Annex E provides recommendations on the legal framework required to enable the generation of
electricity from renewable energy sources in compliance with and within the parameters of Malta’s
EU membership.4 It reviews the current legislative framework in Malta and identifies gaps that need
4
This review has been carried out with the assistance of AVMT Advocates from Malta.
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to be addressed relating to renewable electricity resources. In addition, this annex forms the basis for
the legal recommendations that will be made during phase II and phase III of the project.
As with environmental and planning barriers, any legislative issues that may restrict the deployment of
renewables are integrated into Annex B and Annex C and used to constrain wind and PV.
2.1.5 Project Costs
Annex F evaluates the likely cost of wind farm developments within Malta on each of the potential
onshore and offshore sites identified in Annex B and for medium and micro-scale wind. The results
feed into the modelling process through the expected capital expenditure and operating costs. The
capital costs categories considered include the following:
• Equipment costs
• Transport and shipping
• Contracting, electrical equipment and installation costs
• Financing and legal costs
• Road construction
• Land purchase
• Grid connection
• Developer’s profit margin
These capital costs estimates are based on similar wind projects in Europe with specific allowances
made for the proposed sites in Malta.
For PV, Annex F presents capital and O&M costs for PV installations retrofitted to existing buildings
and for integrated PV systems. The later are incorporated into buildings either on roofs or within
facades and are most suitable for new build where the expense of the PV system is offset by the
expense of the building.
All costs have been forecast to 2020 and assumptions have made about potential cost reductions. (See
Annex F for details).
Both capital and O&M cost estimates are associated with an uncertainty range which is based on the
variety of costs found in the literature. The model uses the mid-range values as inputs in the main
scenarios and the impact of the cost variation is analysed as a sensitivity.
2.1.6 System Costs
The integration of renewable projects into the Maltese system results in some system costs. These are
principally:
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• Network reinforcement costs. Enemalta Corporation has provided a range of costs that would
be required if renewables were introduced into the system under a range of scenarios. (See
Annex G for the results and Mott MacDonald’s comments). These costs are integrated into
the model and associated to specific projects.
• Spinning reserve costs incurred as a result of the intermittent nature of wind. Annex G also
provides the costs associated with providing spinning reserve under a range of scenarios for
wind penetration. Again, these costs are inputs to the model.
2.1.7 Summary of Model Inputs
The model uses the following inputs derived from the Technical Annexes:
• Maximum capacity that may be installed in Malta by Local Plan area for wind and PV
• Maximum energy that may be produced from the capacity installed in each Local Plan area.
The capacity factors for each the wind options are obtained in Annex B. The average annual
daily irradiance factor and PV efficiencies are derived in Annex C.
• Typical current and future (to 2020) capital costs and operational costs for large onshore
wind farms, offshore wind farms, medium scale single turbines (20-60kW turbines) and 1kW
machines.
• Typical and future (to 2020) capital costs and operational costs for PV installations
retrofitted on existing buildings and integrated on new buildings.
• Electricity demand projections to 2020 under three different growth assumptions; low,
medium and high. These projections were provided by the Enemalta Corporation. The three
demand schedules are shown in Figure 2-1 and included in the analysis of sensitivity.
Figure 2-1: Demand Scenarios to 2020
4000
3800
3600
3400
3200
High
GWh
3000 Medium
Low
2800
2600
2400
2200
2000
2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020
Years
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These inputs are used by the model to determine the targets that may be achieved in Malta based on a
number of combination of the technology types considered.
2.2 Constraints
The key way the model deals with constraints is by limiting the capacity that a particular Local Plan
area can reach. This feature incorporates qualitative factors like technical, environmental, legislative
and planning constraints and it captures their impact on reduction of capacity actually available on the
ground for installations.
The analysis of possible technical constraints undertaken by Enemalta indicates that the maximum
large onshore capacity that may be accommodated by the Maltese system at present is 40 MW. This
constraint is integrated in the model by limiting the capacity at different sites and ensuring that the
total installed is 40 MW or below, until the present constrain is removed. (See Annex G for details on
technical constraints). In some instances the maximum capacity of a certain Local Plan area is set to
zero. This is the case, for example, in the Marsaxlokk Bay Local Plan Area, where the disused Hal
Far Airfield is located. This is because the analysis undertaken in Annex D (see Table B-2) on
planning constraints suggests that this proposed site is compromised by its proximity to the Luqa
airport.
In the case of medium and micro-scale wind and PV, planning restrictions and financial constraints are
likely to reduce the level of penetration well below the 100% uptake assumed when calculating
maximum potential. Penetration levels are constrained in the model by limiting the capacity that may
be reached in each Local Plan area according to the scenarios discussed below.
2.3 Scenarios
This study considers three main scenarios for RES deployment in Malta:
• Scenario A: Reaching 5% of Demand by 2010
• Scenario B: Feasible Technology Penetration Rates
• Scenario C: Windfarm Installation post-2010
2.3.1 Scenario A: Reaching 5% of Demand by 2010
This scenario explores the feasibility of meeting the European Commission’s provisional target of 5%
electricity generation from renewable sources by 2010, assuming 0.5% is met from waste-derived
renewable projects and the rest from combinations of the most cost effective technology options for
Malta.
Scenario A uses the cost-minimisation function of the model to produce the least-cost mix, with large
onshore wind constrained to 40 MW and all other technologies deemed initially feasible in Malta
unconstrained.
Details on the scenarios and the results are included in section 3.
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2.3.2 Scenario B: Feasible Technology Penetration Rates

Scenario B explores a more plausible target which may be met by renewables, excluding waste-
derived projects. Under the Scenario B cases, onshore wind is more heavily constrained by planning
than in Scenario A; micro-wind is not considered a viable option due to urban landscape restrictions
(see Annex D). The penetration of medium wind is assumed to be lower than the resulting rates
obtained in Scenario A and PV, although the most expensive option, is included at penetration rates set
using other countries as reference.
Scenario B is broken down into the following cases:

• B1: Constrained to one large onshore windfarm, constrained to zero micro wind, moderately
constrained medium wind and PV based on EU penetration rates.
• B2: Constrained to no large onshore windfarms, constrained to no micro wind, moderately
constrained medium wind and PV, based on EU penetration rates
2.3.3 Scenario C: Windfarm Installation post-2010
Scenario C considers the possibility of a lag time in cultivating public understanding and support for
RES. A moderate level of support is therefore assumed to 2010, as in the B scenarios above. Under
Scenario C the installations before 2010 are taken as demonstration projects, which combined with
education campaigns are assumed to be capable of improving public acceptance of RES in the interval
2010 to 2020. With improved public support, this scenario therefore explores more aggressive
support, such as in scenario A, from 2010 onwards.
There are a number of possibilities that may be open to Malta in this lagged response situation:
• Scenario C1: This is Scenario B1 (one large windfarm prior to 2010 with some medium scale
wind and PV) plus a further onshore wind farm developed post 2010.
• Scenario C2: This is Scenario B2 (no large windfarms prior to 2010 with some medium scale
wind and PV) with one large onshore farm developed post 2010. This situation would be
very similar to that proposed under Scenario B1 but with some delay.
• Scenario C3: This scenario explores a different option. It assumes that large onshore wind
development remains unfeasible in Malta. In this case, an alternative means of increasing
renewable capacity would be an offshore windfarm installation at the Sikka-Il-Bajda site
from 2015.
2.4 Sensitivities
The model is capable of handling different sensitivities. In addition to a response from varying the
described inputs, the model has an in-built flexibility to handle user-defined sensitivities by
incorporating different sets of constraints. Pre-defined sensitivities in the model are outlined below:
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• There are three capital expenditure scenarios for both the wind and PV alternatives. These
scenarios take the average costs and allow the user to vary them across a range. The range is
user defined and can be changed accordingly. These sensitivities are tested with the help of
switches in the model.
• The second set of sensitivities work on the same lines as those for capital expenditure, but
instead relate to operational expenditure.
• The third set of sensitivities deals with electricity demand projections. Here, three demand
patterns are taken into consideration namely ‘Low’, ‘Medium’ and ‘High’.
• The fourth set of sensitivities deals with the use of turbines for medium wind farms. Two
types of turbine sizes which are considered – 20kW and 60kW. This examines the impact on
the capacities that various sites can offer.
• The fifth set of sensitivities deals with the use of turbines for large wind farms. Two types of
turbine sizes which are considered – 850kW and 2MW. This examines the impact on the
capacities that various sites can offer.
2.5 Format of Results
After the inputs have been processed, constraints defined, and scenarios chosen, the model generates
an output expressed in terms of €/MWh. The model picks up the least cost technological solution
(wind, PV or a combination of the two) on the basis of capital and operational expenditure, installs the
capacity of the chosen technology type on cost effective sites and resolves the average cost in €/MWh.
It is also possible to force the model to choose certain technology options by indicating the capacity to
be installed per area per year. In these instances the model also resolves the average cost in €/MWh.
The average cost of power (ACP) is derived by summing an annuity for the plant and operational costs
over the period of concern divided by the cumulative energy produced over the same period. For
discounting purposes, life of the project and discount rate considered are fifteen years and 3%5
respectively. The ACP for given proportions of renewable energy in Malta’s generation mix is given
as an indication of the relative costs of the different technologies. The total expenditure embodied by
the different targets and different technology mixes is also calculated by the model. Disaggregated
ACP model results are shown in Table 2-1 below. These results are for installed costs in 2008 and are
based on average capital and operational expenditure, for each RES technology included in the
scenarios:
Table 2-1: ACP results by technology
RES Technology ACP (€/MWh)

Large Onshore Wind 51.4
Large Offshore Wind 72.7
60kW Medium Wind 102.4
1kW Micro Wind 118.3
3kWp Solar PV 334.5
Conventional Plant 54.0
5
http://www.centralbankmalta.com/site/pr1main.asp?ItemId=368
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The RES capacity optimisation in the model is based on capital and operational costs per megawatt
installed for each technology and, where relevant, specific site. The model does not use the constraint
that integer numbers of the generation unit must be installed, since the results are intended to create a
guide to the costs for a given total RES capacity based on typical generation costs, rather than outline
realistic plans for a specific site. A result of this is that Table 3-1 effectively shows 4.4 offshore
turbines of 3MW each installed by 2020. While this is self-evidently not a feasible outcome, the result
nonetheless provides an indication of the scale and cost of installation required to meet a 5% RES
generation target. Similarly, this feature of the modelling process is evident in Tables 3-2, 3-4, 3-5, 3-
6 and 3-11.
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3 Results
3.1 Scenario A: Reaching 5% of demand by 2010
3.1.1 Characteristics
This scenario explores the most cost-effective means of meeting 4.5% of electricity demand by 2010.
As indicated in Annex B, this represents the case where the maximum large onshore wind is
developed taking into account the technical constraints of integrating wind into the Maltese electricity
system. In this scenario, it is assumed that large onshore wind farm installations receive strong
backing within Malta, permitting and in particular visual impact, are not a significant obstacle and
suitable developers are readily available to complete works at both sites before 2010.
The main characteristics of Scenario A are summarised as follows:

• The percentage of demand met by renewables by 2010 is set to 4.5%. This target is then
maintained through the period to 2010-2020, to track increasing demand.
• Of the total available resource, two large onshore windfarm sites are selected for inclusion in
this analysis, based on the technical, environmental and social features of the potential sites
in Malta (see Annexes B and D). The sites selected are Marfa Ridge and Bajda Ridge.
• Each large onshore wind farm is run using 2MW turbines.
• The capacity of the Marfa Ridge and Bajda Ridge sites is limited to 20 MW each to account
for system technical constraints (see Annex B).
• The model does not add any large onshore wind developments post 2010. Even if the current
technical constraints were to be resolved, more than two large wind farms in the Maltese
Islands would be extremely unlikely as cumulative impact would be significant due to the
country’s size and characteristics of the landscape (see Annex D).
• No potential offshore wind sites are included in the period to 2010, since none of those
identified are deemed viable with the technology available before 2010 (see Annex B). One
offshore development is considered from 2015.
• The offshore wind farm is run using 3MW turbines.
• Medium wind is run assuming that 60kW turbines are used.
• The scenario is run using the medium demand growth assumptions.
• The scenario is run using the medium level costs assumptions.
• Energy is not generated from projects until 2008. This is to allow for construction and the
removal of the present planning and legislative barriers.
Scenario A uses the cost-minimisation function of the model to produce the least-cost mix, with large
onshore wind constrained to 40 MW and all other technologies deemed initially feasible in Malta
unconstrained.
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3.1.2 Results
The results from this scenario are summarised in Table 3-1 and discussed below:
Table 3-1: Results Scenario A
2010 2020
Large Medium Micro Large Offshore Medium Micro Wind
Onshore Wind Wind Onshore Wind Wind
Wind Wind
Size of turbine 2 MW 60 kW 1 kW 2 MW 3 MW 60 kW 1 kW
MW Installed 40 29.8 0 40 13.21 36.7 0.61
% Capacity 57.3 42.7 0 44.2 14.6 40.5 0.7
# Installations (small scale) - 497 units 0 - - 613 units 610 units
Penetration Rate - 166 units/yr - - - 12 units/yr 61 units/yr
Total Capacity 69.84 MW 90.52 MW
Target (% of demand) 4.5% 4.5%
ACP €72.06 per MWh €73.43 per MWh
Of which, network and €2.43 per MWh €2.62 per MWh
spinning reserve costs
Total Capital Cost €15.37 million €112.38 million
• After large onshore windfarm capacity is filled, the shortfall in generation required to meet
4.5% of electricity demand by 2010 is met by medium scale wind, as the second most cost-
effective option (see Figure 3-1).
• During the period 2010-2020 the 4.5% target is maintained by increasing levels of medium
scale wind until this reaches its maximum potential (one 60kW unit installed in 613
farmsteads etc, see Annex C). It is then followed by micro-wind and offshore wind.
• PV is too expensive to be considered by the cost optimiser in the model (see Figure 3-1).
• To meet 4.5% of demand by 2010 with only 40 MW of onshore wind possible, it implies a
penetration rate for medium scale wind of 166 units per year for three years. This penetration
rate is totally unrealistic for the following reasons:
− It would require 82% of the maximum suitable sites in Malta to install one 60 kW
turbine each.
− It would entail strong incentives given to end users to incur the required capital
expenditure. Pay back periods for one 60 kW turbine at present tariff levels in Malta
and with no subsidy, would be in the range of 18 years,6 which falls significantly short
of an attractive investment for the relevant landowners.
− It would require an extremely effective public education and public awareness
campaign to ensure that such levels of penetration were realised.
6
This is based on a simple payback period calculation for displacement of grid electricity. A capital cost of €114,000 and
annual operational cost of €1,400 apply for 60kW medium wind (see Annex F), with a capacity factor of 18% (see Annex B).
The electricity consumption charge is 3.4 Malta cents per kWh, which applies to commercial users with power factor
equipment installed, on the assumption of a net metering arrangement for power spilled to the grid.
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− The cumulative impact of installing 497 wind turbines of 60 kW capacity each by 2010
would be enormous in the Maltese Islands due to its size and characteristics of the
landscape (see Annex D). This would inhibit such high levels of penetration.
− It is most likely that the construction resources would not be available in the Maltese
Islands to install such high levels of medium scale turbines in such a short period.
• To maintain the 4.5% target from 2010 to 2020 without any further additions of large
onshore wind, the cost optimiser in the model introduces micro-wind (at a very high rate of
penetration) until 2015 when the offshore wind farm is introduced. By 2015, only 14.5 MW
of offshore wind are required to satisfy the 4.5% target.
Figure 3-1: Technology Costs
8.00
7.00
6.00
5.00
Euromillions/MW
Micro Wind
Medium Wind
4.00 On-Shore >1MW
Off-Shore Wind >1MW
PV
3.00
2.00
1.00
-
2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020
Years
3.1.3 Conclusions
Scenario A highlights the following:

• It is not possible to meet 4.5% of electricity demand by renewable generation by 2010 with
onshore wind constrained to 40 MW and with no offshore wind development. 7
• Maintaining the 4.5% target to 2020 without increases in onshore wind would only be
possible if one offshore wind site is developed.
7
This target excludes waste-derived renewables.
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3.2 Scenario B: Feasible Technology Penetration rates
Reaching the 5% target using scenario A is not feasible. Scenario B explores a more plausible target
which may be met by renewables, excluding waste-derived projects. The following assumptions are
made in Scenario B:
• Onshore wind is more constrained by planning than in Scenario A.
• Offshore wind is not developed because the only possible site is considered too marginal or
because it conflicts with bunkering activities (see Annex D).
• Micro-wind is not considered a viable option due to urban landscape restrictions (see Annex
D).
• The penetration of medium wind is assumed to be lower than the resulting rates obtained in
Scenario A and it is set using experiences in other countries as a reference (see below for
more details).
• PV, although the most expensive option, is considered. Penetration rates at set using other
countries as a reference (see below for more details).
removal of some of the present planning and legislative barriers.
Feasible targets for medium scale wind and PV are discussed below.
(i) Feasible Penetration Levels for Medium Scale Wind
The US has relatively few planning constraints on small wind turbine use on farmsteads, and shows a
penetration rate of approximately 6,700 installations under 100kW a year, of an estimated total market
of 7,600,000 (AWEA, 2002). The total market was defined as homes with more than ½ acre of land
and an adequate wind resource. If this penetration rate is directly scaled down to the total estimated
potential market in Malta, of 613 farmsteads etc (see Annex B), a penetration rate of 1 installation
every two years is inferred.
Germany has also created an enabling environment for wind generators of all turbine sizes, and gives
an indication of what has been achieved with medium wind. In 2001, an estimated total of 136 new
wind turbines in the range 5-80 kW, with an average capacity of 60kW, were installed (Ender, 2002).
Scaling by head of population, in the absence of reliable small wind market potential data, a similar
estimated penetration rate as for the US is seen, giving 0.4 units per year in Malta.
German distribution of installed capacity is varied, with the maximum number of wind turbines per
federal state being 3.7 times the average number per state. With a concerted policy effort focussed on
medium wind, Malta might be able to achieve a higher penetration than that suggested by 0.4 turbines
per year. Accordingly, Scenario B considers a level of penetration of 5 units per year.
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(ii) Feasible Penetration Levels for PV
Average penetration of on-grid solar PV across the original EU15 from 2000 to 2002 was at the rate of
0.14Wp installed capacity per person per year (EurObserv'ER, 2003). This would be equivalent to 19
rooftop installations each year in Malta, each of 3kWp. Considering that the Maltese Islands have one
of the highest solar radiation indices in Europe, (Suri et al, 2004) this level of penetration would seem
low.
Under the "1000 Roofs" program with up to 70% cost-sharing from the German government, 2,500
roof-top PV systems were installed on 1- and 2-family homes across Germany over 4 years, with a
total overall capacity of 4 MWp. If such successful incentivisation could be duplicated in Malta,
installed capacity would rise by 3MW between 2008 and 2010. This would correspond to a
penetration rate by household of 300 per year, taking into account the larger installation capacities
available in Malta compared with Germany due to the greater solar resource.
In Malta, payback periods for 3kWp PV installations, without subsidy, would be in the order of 97
years.8 Assuming that PV is subsidised to a level commensurate to that in the ‘1000 roofs’ program
(i.e. 70% of capital costs), the consumer pay back period would be reduced to 29 years. For
investment in energy saving equipment, most end users would expect to have a pay back period of up
to five years. This means that with payback periods of 29 years or longer, the installation of PV
modules may not be widely adopted in Malta making penetration rates of over 300 households per
year unrealistic. Planning restrictions are also likely to inhibit such high levels of penetration (see
Annex D). It may be possible to lower the required subsidy and the pay-back period if incentives are
aimed at commercial rather than domestics users. These consume more electricity and pay higher
prices for it. They can also obtain economies of scale by fitting either bigger installations or a number
of them.
Using average penetration levels in Germany gives around 1Wp per person per year. Total installed
on-grid capacity in Germany reached 258MWp in 2002 (EPIA, 2003). If Malta were to achieve the
same penetration level from 2008 to 2010, a total of 1.12MW of installed PV capacity would need to
be installed. This is equivalent to around 120 rooftop installations of 3kWp a year. This would still
require high levels of subsidy, although the burden could be lower than in the previous example.
Taking all these factors into account, it is suggested that a plausible rate of penetration for PV in the
Maltese Islands may be between 40 to 80 rooftops per year. This is lower than that obtained through
strong support policies such as the ‘1000 Roofs’ scheme in Germany but higher than the European
average. The extent to which government support would in fact be required to meet these penetration
levels would, however, depend on the willingness to pay exhibited by the potential buyers of PV
systems in the Maltese Islands.
3.2.2 Results
As mentioned in section 2.3.2, there are two cases explored under Scenario B:
8
This assumes an electricity price of 2 Malta cents per kWh, which applies to Block 2 domestic users, with the assumption of
a net metering arrangement for power spilled to the grid. Again, this is based on a simple payback period calculation for
displacement of grid electricity. A capital cost of €20,460 (see Annex F) and a production of 4,580 kWh/annum for each
3kWp system is used (see Annex C).
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• B1: Constrained to one large onshore windfarm, constrained to zero micro wind, moderately
constrained medium wind and PV based on EU penetration rates.
• B2: Constrained to no large onshore windfarms, constrained to no micro wind, moderately
constrained medium wind and PV, based on EU penetration rates.
(i) Scenario B1: One Large Onshore Windfarm
Scenario B1 considers the following:

• a single onshore windfarm at Marfa Ridge with a reduced capacity of 15 MW due to
environmental constraints (see Annex B).
• a penetration level of medium scale wind of 5 x 60 kW turbines per year, sustained through
the period to 2020.
• a penetration level for PV of 40 rooftops x 3 kWp per year, sustained through the period to
2020.
• no offshore wind and no micro-wind.
The results are summarised in Table 3-2 and discussed below.
Table 3-2: Results Scenario B1
2010 2020
Large Medium PV Large Medium PV
Wind Wind Wind Wind
Size turbine/system for PV 2 MW 60 kW 3 kWp 2 MW 60 kW 3 kWp
MW Installed 15 0.9 0.36 15 3.9 1.56
% Capacity 92.25 5.54 2.21 73.31 19.06 7.62
# Installations (small-scale) - 15 120 - 65 520
Penetration Rate - 5 units/yr 40 rooftops/yr - 5 units/yr 40 rooftops/yr
Total Capacity 16.26 20.46
The results indicate the following:

• With one 15 MW large onshore wind farm and moderate support for medium scale wind and
PV, the renewable target that may be achieved by 2010 in Malta as a percentage of demand
is 1.13%.
• The European Commission suggested that 1.93% of demand in 2010 may be met by 15 MW
of wind alone. The reasons for the difference are as follows:
− The European Commission assumed 30% capacity factor for wind and an energy
production of 0.03888 TWh. In this study and as a result of analysing the wind resource
in Malta (see Annex B), the capacity factor for the site at Marfa Ridge is estimated at
24%, giving a net energy production of 0.03022 TWh.
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− The level of demand assumed by the European Commission in 2010 is 2 TWh. This
study, based on figures provided by Enemalta, assumes a demand of 2.837 TWh.
− The average cost of power for Scenario B1 is €57.29 per MWh. This compares with
around €54 per MWh for conventional generation presently in operation in Malta.9
(ii) Scenario B2: No Large Onshore Wind
Scenario B2 assumes the following:

• no onshore wind developments to represent the case that these are considered to be unviable
following detailed visual and environmental assessment.
• a penetration level for medium scale wind of 5 x 60 kW turbines per year sustained through
the period to 2020, as in Scenario B1.
• greater support for PV than in Scenario B1 with a penetration level of 80 rooftops x 3 kWp
per year sustained through the period to 2020.
• no offshore wind and no micro-wind, as in Scenario B1.
The results are summarised in Table 3-3 and discussed below.
Table 3-3: Results Scenario B2
2010 2020
Medium Wind PV Medium Wind PV
Size turbine/system for PV 60 kW 3 kWp 60 kW 3 kWp
MW Installed 0.90 0.72 3.90 3.12
% Capacity 55.56 44.44 55.56 44.44
# Installations (small- 15 240 65 1,040
scale)
Penetration Rate 5 units/yr 80 rooftops/yr 5 units/yr 80 rooftops/yr
The results indicate the following:

• With no large onshore wind farm development and moderate support for medium scale wind
and moderate-strong support for PV, the renewable target that may be achieved by 2010 in
Malta as a percentage of demand is 0.09%.
• The average cost of power for Scenario B2 for 2010 is €198.06 per MWh. This is
significantly higher than that obtained under Scenario B1 reflecting the fact that PV is more
expensive per MWh than onshore wind.
9
A.1.3 This value is based on information provided by Enemalta, see Annex G for details.
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• Network and spinning reserve costs are negligible for low levels of distributed
autogeneration.
3.2.3 Conclusions
Scenario B highlights the following:

• Without large onshore wind development, the level of renewable electricity that may be
generated in Malta by 2010 by renewables, excluding waste-derived renewable projects, is
very low, 0.09% of demand and well below the levels expected by the European
Commission.
• Even if planning restrictions were to be relaxed in favour of medium scale wind and PV,
supporting a renewable target solely based on medium scale wind and PV would be very
costly for Malta.
• It is unlikely that more than one large onshore windfarm will be approved in Malta due to
expected high visual impact and environmental restrictions. Without any other large scale
developments, such as offshore wind, the percentage of demand met by renewables,
excluding waste-derived projects, is likely to be between 1 to 1.13% depending on the level
of support provided to medium scale wind and PV.
3.3 Scenario C: Windfarm installations post-2010
The following assumptions are made in Scenario C:

• There is a lag time in cultivating public understanding and support for RES with a moderate
level of support assumed to 2010, as in the B scenarios above, followed by improved public
support from 2010 onwards.
• The levels of medium scale wind and PV assumed are the same as those in Scenario B.
• Micro-wind is not considered a viable option due to urban landscape restrictions (see Annex
D).
removal of some of the present planning and legislative barriers.
3.3.2 Results
This section presents the results for the following options:

• Scenario C1: This is Scenario B1 (one large windfarm prior to 2010 with some medium scale
wind and PV) plus a further onshore wind farm developed post 2010.
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• Scenario C2: This is Scenario B2 (no large windfarms prior to 2010 with some medium scale
wind and PV) with one large onshore farm developed post 2010. This situation would be
very similar to that proposed under Scenario B1 but with some delay.
• Scenario C3: This is Scenario B2 with an offshore windfarm developed in 2015.
(i) Scenario C1: Two Large Onshore Windfarms (one by 2010 the other post 2010)
This scenario assumes that public opinion and the planning system allow a further wind farm to be
developed in mainland Malta. In this case, 10 MW have been added at Bajda Ridge as it is considered
that environmental constrains will limit the full potential of the site (See Annex B).
The results from this scenario are summarised in Table 3-4. The Tables shows that prior to 2010, the
level of the target and the costs associated with it are the same as per Scenario B1. Adding a further
wind farm post 2010 increases the renewable target to 1.7% of demand by 2020 but the effect on the
average cost of power is minimal.
Table 3-4: Results Scenario C1
2010 2020
Wind Wind Wind Wind
MW Installed 15 0.9 0.36 25 3.90 1.56
% Capacity 92.25 5.54 2.21 82.07 12.80 5.12
Target (% of demand) 1.13% 1.71
(ii) Scenario C2: One Large Onshore Windfarm post 2010
This scenario is a combination of B1 and B2. The results are summarised in Table 3-5.
2010 2020
Medium Wind PV Large Medium PV
Wind Wind
Size turbine/system for PV 60 kW 3 kWp 2 MW 60 kW 3 kWp
MW Installed 0.90 0.72 15 3.90 3.12
% Capacity 55.56 44.44 68.12 17.71 14.17
# Installations (small-scale) 15 240 - 60 1040
Penetration Rate 5 units/yr 80 rooftops/yr - 5 units/yr 40 rooftops/yr
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Prior to 2010 the results are the same as those in Scenario B2. Adding a 15 MW onshore wind farm in
2015 increases the target to just under 1.2%. Average network and spinning reserve costs in the
period 2010 to 2020 are lower than in Scenario B1 simply because they are incurred in a shorter
timespan.
(iii) Scenario C3: No Large Onshore Wind and One offshore Windfarm post 2010
This scenario has the same characteristics as Scenario B2 with the addition of one offshore wind farm
at the Sikka-Il-Bajda site developed in 2015. The results are summarised in Table 3-6.
2010 2020
Medium PV Offshore Medium PV
Wind Wind Wind
Size turbine/system for PV 60 kW 3 kWp 3MW 60 kW 3 kWp
MW Installed 0.90 0.72 27 3.90 3.12
% Capacity 55.56 44.44 79.37 11.46 9.17
# Installations (small- 15 240 - 65 1,040
scale)
Penetration Rate 5 units/yr 80 rooftops/yr - 5 units/yr 80 rooftops/yr
• The results are the same as in Scenario B2 for the period to 2010:
− the renewable target that may be achieved by 2010 in Malta as a percentage of demand
is 0.09%.
− the average cost of power in 2010 is €198.06 per MWh.
• With the development of a offshore wind farm in 2015:

− the renewable target can be increased to 2% by 2020
− the average cost of power drops to €86.22 per MWh
− the network and spinning reserve costs are the most significant of all the options.
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3.3.3 Conclusions
Allowing time for cultivating public understanding and support for RES gives an opportunity to raise
the renewable target from 0.09 to 2%, depending on the options chosen.
The most cost effective means of raising the contribution of renewbales, excluding waste-derived
projects, is by developing two onshore windfarms during 2005 to 2020. If this option is not feasible
due to the likely cumulative impact that two wind farms would have, developing an offshore windfarm
would be the second best alternative.
3.4 Sensitivities
The sensitivities are run for Scenario B1 and they explore the following:
• Cost uncertainty
• Changes in demand
• Changes in wind turbine size
Tables 3-7 through 3-11 in sections 3.4.1, 3.4.2 and 3.4.3 below give the sensitivity analysis results
data where this is different from Scenario B1.
3.4.1 Cost Sensitivities
Uncertainty in the cost estimates made for this study have the potential to alter the results of the
modelling process, and the corresponding implications for Malta’s renewable energy policy. This
sensitivity analysis explores the impact on ACP and total capital costs of a ‘high’ and ‘low’ project
cost scenario, both for project capital and operational costs. The ‘high’ and ‘low’ costs are based on
the full range of cost data observed for each technology, as referenced throughout Annex F. As stated
above, this analysis is based on Scenario B1, which along with the other Scenarios A through C3 uses
‘medium’ or mid-range estimates for both capital and operational costs.
Results from the analysis of project capital cost range are given in Table 3-7 below, which includes the
results of Scenario B1 in Table 3-2 above. This comparison shows an overall uncertainty of between
10% and 15% in the ACP and total RES capital cost estimates. This level of uncertainty is significant
and it will need to be considered when defining suitable support policies. This uncertainty does not
affect the conclusions and recommendations made in Section 4, however.
Table 3-7: Capital Costs Sensitivities
2010 2020
Low Medium High Low Medium High
ACP (€/MWh) 50.75 57.29 63.84 57.90 65.14 72.37
Total Capital Cost (€m) 3.92 4.54 5.16 22.01 25.28 28.56
The possible range of operational costs affects ACP in a minor way, as seen in Table 3-8. The
variation in ACP is equivalent to an uncertainty of around 2%, which would not be highly significant
for policy planning.
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Table 3-8: Operational Costs Sensitivities
2010 2020
ACP (€/MWh) 56.18 57.29 58.40 64.04 65.14 66.23
3.4.2 Demand Sensitivities
The level of consumer demand for electricity does not affect the choice of most appropriate renewable
energy technology or support policy, but does affect Malta’s eventual renewable generation target as
this is expressed as a percentage of demand. This study uses electricity demand projections provided
by the Enemalta Corporation, as shown in Figure 2-1 above, where Scenarios A through C3 apply the
‘medium’ projection.
Results from the analysis of the ‘high’ and ‘low’ demand projections are given in Table 3-9.
Comparing these outcomes with the results of Scenario B1, the proportion of total demand met by
RES varies by around 0.05% in 2010 and 0.1% in 2020. This is small on the scale of total national
demand. Given targets of approximately 1% put forward in Scenario B1, however, this could
represent up to 10% of the RES target adopted by Malta.
Table 3-9: Demand Sensitivities
2010 2020
Target (% of demand) 1.18 1.13 1.09 1.25 1.12 1.02
3.4.3 Wind Turbine Size Sensitivities
In Annexes B and F, two alternatives sizes of wind turbine are presented, both in the large and
medium categories. In the large turbine category this alternative is the 850kW turbine with a hub
height of 50m, as opposed to the 2MW turbine used in the model, with a hub height of 70m. In the
medium turbine category a 20kW turbine with a hub height of 18m is proposed as an alternative to the
60kW turbine used in the model, with a hub height of 24m. The smaller turbine in each category will
have a different visual impact, with a larger number of shorter machines to give the equivalent
capacity.
Table 3-10 below shows the variation in results using 850kW large turbines in Scenario B1 instead of
2MW turbines. In the case of a single 15MW farm at Marfa ridge it is assumed that space is available
to meet the same capacity as with 2MW turbines. In this way, only the total capital cost of RES
installation and the ACP vary; the former falling by 4-8% and the latter by 12-15%. This alternative
would in fact be lower cost as well as lower height, providing that planning permission could be
obtained for the relevant number of turbines and land purchase costs apply only to the built area, as
assumed in Annex F.
Table 3-10: Results 850kW Large Wind Turbines
2010 2020
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Table 3-11 considers the use of 20kW instead of 60kW medium turbines. In this case, the same
penetration rate of 5 units per year on farmsteads and similar buildings is assumed, which reduces the
nominal capacity of medium wind installed by 67%. Overall, this reduces total estimated RES
capacity in 2020 by 13%, with total capital costs and ACP falling accordingly. A generation target of
1% demand is still achieved, however, providing all other sensitivity variables are assumed to take
their ‘medium’ levels.
Table 3-11: Results 20kW Medium Turbines
2010 2020
Wind Wind Wind Wind
MW Installed 15 0.3 0.36 15 1.3 1.56
% Capacity 95.79 1.92 2.30 84.00 7.28 8.73
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4 Conclusions and Recommendations
4.1 Conclusions
The conclusions in this section relate to the results of the modelling process. More detailed
conclusions covering all aspects of Phase I are included in each of the Technical Annexes.
Based on the analysis, meeting 4.5% of electricity demand in 2010 by wind and PV is not feasible.
Large onshore wind development is the most cost-effective technology; it can contribute significantly
to meeting electricity demand and it places the lowest burden on the country in terms of need for
financial support.
Malta has significant wind potential (see Annex B) but this is greatly limited by the sensitivity of the
Maltese landscape and the current planning process. The landscape is open with little tree cover
affording long distance views. Large onshore wind farms are likely to be seen from any panoramic
location within Malta and from high points in Gozo. There are numerous sites of ecological and
cultural heritage value that will restrict development. Also, the Maltese archipelago is very small,
(around 300 square kilometres) so the cumulative impact of wind farm development is likely to be
significant. Taking all these factors into account, it is most unlikely that more than one large onshore
windfarm will ever be built in Malta.
Offshore wind is the second best technology option in terms of costs. Offshore wind potential around
the Maltese Islands is not very significant; the resource analysis (see Annex B) identified only one
possible site. Although this site is marginal in terms of the resource, if onshore wind is proven to be
unviable in Malta due to environmental constraints, developing this offshore site would allow a greater
contribution to meeting demand at a lower financial burden than small scale renewables.
Developing the offshore windfarm would require resolving technical issues as well as issues relating
to the conflicting use of the site. Even if a developer was prepared to develop this marginal site, it is
unlikely that the windfarm would be installed before 2015.
Malta also has significant resource for medium and micro-scale wind and massive solar energy
potential; Malta has one of the highest solar radiation indices in Europe.
Micro-wind has not been considered a feasible option for Malta because of the planning constraints
that are likely to originate due to visual impacts on the Maltese townscape. The current Maltese
planning framework seems to be more favourable to medium scale wind exploitation, however, as
seen through the modelling exercise this comes at an economic cost and has implications on the
overall renewable electricity target that may be achievable.
While there is enormous PV resource potential in Malta, there appear to be a number of planning
barriers to the installation of PV units on domestic rooftops. Industrial rooftops, however, may prove
to be an area where the planning requirements are less onerous and where reasonable track record can
be gained and maintained.
Even if planning restrictions were to be relaxed in favour of medium scale wind and PV, supporting a
renewable target solely based on these more expensive small scale options would be very costly for
Malta.
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4.2 Recommendations
The recommendations in this section relate to the results of the modelling and to the level of
renewable target, excluding waste, that may be achieved in the Maltese Islands. Specific
recommendations relating to other aspects of Phase I of the study are included in the Technical
Annexes.
Based on the modelling analysis, the following recommendations are made:

• It is recommended that Malta sets a national indicative target for generation of electricity
from RES of 1% of demand by 2010 (assuming 2.8 TWh demand in 2010).
• To achieve this target it would be necessary to develop one large onshore windfarm on
mainland Malta. To ascertain whether this is feasible, it is recommended that MRA carry out
a visual impact study and a public awareness campaign as a matter of urgency.
• It is recommended that Malta reduces barriers and develops policies to encourage medium
scale wind and PV to levels commensurate with the rates assumed in this report; 40-80
rooftops/year for PV and 5x60kW wind turbines a year. This would require developing
incentives aimed at commercial users in particular.
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Annex A Analysis of Alternatives Draft Mott MacDonald
Annex A
Analysis of Alternatives
Final Report, July 2005

Isabel Philip
i
F:\PROJECTS\206106 Malta\Phase 1 deliverables\Phase 1 report\Final Report\Final Report Annex A - Alternatives.doc/
List of Contents
Annex A Analysis of Alternatives 1

A.1 Introduction 1
A.2 Methodology 1
A.3 Wind 3
A.3.1 Onshore Wind 3
A.3.2 Offshore Wind 5
A.3.3 Micro-Wind 8
A.4 Photovoltaic 9
A.5 Biomass Fuels (Energy Crops) 11
A.6 Biomass Wastes 14
A.7 Hydro 17
A.8 Geothermal 17
A.9 Wave 17
A.10 Tidal 20
A.11 Landfill Gas 20
A.12 Sewage Gas 22
A.13 Conclusions 24
ii
F:\PROJECTS\206106 Malta\Phase 1 deliverables\Phase 1 report\Final Report\Final Report Annex A - Alternatives.doc/
Annex A Analysis of Alternatives
A.1 Introduction
The objective of this study is to consider the potential for renewable electricity sources in Malta,
evaluate potential renewable energy targets and policy options for associated support mechanisms.
This section of the study aims to consider the alternative sources of renewable energy available in
Malta, which might contribute to the electricity generation mix. The renewable technologies that are
best suited for electricity generation in Malta are then used in the main report, which evaluates the
feasibility of different renewable energy targets for 2010.
The ultimate driver behind the push for renewable energy (electricity in this case) is as part of the
multi-frontal approach to reducing carbon emissions. At the highest strategic level it may be argued
whether the exploitation of renewable electricity sources provides the most cost effective stance to
reducing greenhouse gas emissions from electricity generation. Mott MacDonald believes that while
consideration of alternatives at this level would be interesting it would not bring significant benefit to
this study as there is a legal requirement to set an indicative renewable target for electricity generation
and implement the corresponding support measures (in order to comply with the European Directive
2001/77/EC).
The focus of the consideration of alternatives is, therefore, on the alternative sources of renewable
electricity that can be exploited in Malta.
A.2 Methodology
Our approach considers the alternatives in two phases. The first phase analyses whether there is any
potential renewable resource, under each category considered below. If there is no resource available
then the technology/resource is not considered further in this assessment. If there is either the resource
or the possibility for the resource in the future then a further screening process is applied.
The factors that are considered when analysing the resource include:
• Development opportunities – Are there any sites? Are there significant barriers that may
prevent or limit the resource (such as town planning restrictions, network capability etc)?. It
should be noted that this Annex forms only a very brief overview and a more detailed
analysis has been undertaken in other parts of this study for the technologies in question.
• Technology status – What is the likely technical and commercial maturity of the
technologies in 2010, 2015 and 2020?.
• Environmental constraints – renewable energy projects have the potential to raise
environmental concerns. Many of the larger schemes within the Maltese Islands may be in a
rural location and their construction could introduce a new element into the landscape. The
environmental constraints section, therefore, introduces some of the key environmental
impacts typically related to the exploitation of that resource and considers whether
mitigation is a realistic option to avoid significant adverse impact on the character, integrity,
quality and setting of a designated resource, more detailed analysis of these issues is
undertaken in Annexes B and C of the study.
1
F:\PROJECTS\206106 Malta\Phase 1 deliverables\Phase 1 report\Final Report\Final Report Annex A - Alternatives.doc/S
• When considering the environmental impacts we have not focussed on any particular phase
of development. Attention has, however, been given to identifying where the most likely
(and potentially significant) impacts could arise and any mitigation measures that can be
implemented. This means that for some technologies the issues are associated with
construction or operation, while for others they may on the unit fabrication level.
• Finally a conclusion regarding the potential for that technology/resource for the production
of renewable electricity in Malta.
The technologies under consideration in Directive 2001/77/EC are as follows:

• Wind – onshore, offshore and micro-wind (less than 0.1 MW)
• Solar photovoltaic (PV)
• Biomass energy crops - conventional, co-firing with fossil fuels and advanced conversion
• Biomass waste – including agricultural and biodegradable fractions of Municipal Solid waste
(MSW) and water treatment residues.
• Hydro – large scale, small scale, run-of-river and micro-hydro
• Geothermal
• Wave
• Tidal
• Landfill gas
• Sewage gas.
The following subsections consider each technology using a tabular presentation of the relevant
concerns.
2
A.3 Wind
A.3.1 Onshore Wind

Resource For some areas of Malta, Gozo and Comino the average wind speeds are above 5 m/s at a height of 50 m above ground level, making the resource
available suitable for the purposes of electricity generation.
Development It is likely that some suitable sites will exist. Barriers to development potentially include lengthy planning approval process, public and lobby
opportunities group acceptability, areas of environmental protection, cultural heritage protection areas, proximity to built up areas including areas of high
tourism value, construction and maintenance access to the site for development and the ability of the distribution grid to maintain stability of the
electricity system.
Technology Status Wind technology has improved over recent years with turbines now available for sites with a range of wind speeds and the ability to operate in
both hot and cold climates. The range of turbine sizes is now extensive and is typically between 50 m and 120 m (tower and nacelle height plus
the rotor diameter) for turbines of up to 3MW nominal capacity. Onshore wind technology is considered mature and in many countries is now
competing (with the help of support mechanisms) with fossil fuel generation. Advances in design in the future may see less over-design in the
blades making them more responsive to wind speeds.
Environmental While wind technologies do not emit particulates or harmful gases to the atmosphere or water, or produce wastes they can have a range of
Issues negative environmental impacts. The list below introduces some possible impacts, however this is not exhaustive and the specific nature of
impacts are determined by the design and siting of a particular onshore wind energy project. Environmental impacts are required to be
considered in detail when undertaking a project specific Environmental Impact Assessment (EIA).
Potential Impact Possible Mitigation and Management
1. Visual impacts in relation the scale and size of the proposed 1. Education, careful siting and sympathetic design. Policies in various
development, its relationship with the surrounding landform and Local Plans with potential development opportunities and the
current land use are important considerations. Many proposed associated revisions to the Maltese Structure Plan should address the
developments across Europe have been opposed due to insensitive minimisation of visual effects (e.g. the siting, landscaping, layout,
design, locations and the potential for cumulative impacts from design and colour of wind energy developments). Research in Scotland
neighbouring developments, including other wind energy schemes. on behalf of the Scottish Executive Central Research Unit entitled
“Public Attitudes to Wind Farms” has found that concerns have often
been found to reduce considerably once the development and
associated mitigation measures are in place, particularly if public
3
consultation has been managed carefully.
2. Landscape impacts with wind turbines and associated infrastructure 2. Completion of landscape character assessment studies for the whole
detrimentally impacting on the fabric of the landscape due the of rural Malta, sympathetic siting/design
landscapes inability to accept and absorb this type of development.
3. Light flicker and shadow effects are serious issues in some 3. Careful study of the potential effects of these is possible and impacts
countries, causing nuisances (such as when driving past on the local should be mitigated through siting away from sensitive receptors and
road network) and potentially affecting quality of life or businesses design/layout of the project.
(tourism etc.)
4. Electromagnetic Interference (EMI) – Wind turbines can cause EMI: 4. Siting away from homes receptors and sensitive receptors of
physical interference 'scattering' of signals, as the wind turbine strategic or military importance or installing technical fixes if
provides a second path between the transmitter and receiver of the necessary. Siting away from airport operations and associated
signal. This leads to a phenomenon called 'ghosting' on television peripheral facilities such as radar installations. Consideration of low-
screens which in most instances is rectifiable. Electrical interference fly zones, runway approaches and other aviation factors should occur.
principally comes from signals generated within the wind turbine
which may impact on communications equipment. This effect is
considered negligible due to the standards to which wind turbine
construction has to comply. Wind turbines have been installed
worldwide with few instances of recorded EMI.
5. Ecological – bird strikes from the blades have been a problem in 5. Surveys and monitoring of species in the adjacent areas, including
some locations. The bird protection lobby groups can provide potential feeding and roosting locations. Survey of main avian
significant opposition to wind energy developments. migratory routes. Careful siting and layout, especially away from
migratory routes, can mitigate the problem
6. Noise and vibration – the process by which wind turbines convert 6. Wind farm noise assessments should be completed to a standard
wind energy into electricity produces two distinct sources of noise in similar to the UK ETSU-97 methodology entitled “The assessment and
this process - mechanical noise from the gearing mechanisms and other rating of noise from windfarms” which was undertaken for the UK
machinery within the nacelle of the turbine, and aerodynamic noise Department for Trade and Industry. This procedure ensures that sites
from the movement of turbine blades through the air. It is commonly are chosen appropriately, and that noise levels are assessed and rated
said that "low frequency noise" or "infrasound" can be produced by appropriately as part of the overall planning assessment process. The
4
wind turbines. While this was true of some early models, the introduction of such mitigation measures should ensure that wind
technology has moved on and modern turbines produce very low levels energy developments are located with minimum separation distances
of noise, including infrasound. Noise can also be caused by from noise sensitive receptors and designed in such a way to minimise
maintenance procedures and associated traffic movements. increases in ambient noise levels.
7. Tourism and recreation – throughout the Maltese Archipelago 7. Sensitive siting and design considerations can minimise potential
tourism and recreation are a significant part of the local economy and impacts, especially landscape and visual implications, however a
to varying degrees urban and rural locations are closely linked with the residual effect is likely to remain. Nevertheless, it can be argued that
quality of the local townscape and rural landscape. Large scale such developments, especially on an island with no current wind
renewable energy developments such as multiple high capacity wind energy schemes, can in themselves be of interest to tourists and the
turbines can therefore reduce this sense of tranquillity which is an domestic population alike. In addition, the limited footprint of
integral part of the appeal of Malta, especially in rural settings. individual turbines should not adversely interfere with rural
recreational activities.
Conclusions There are likely to be some restrictions in the opportunities for exploitation of onshore wind in Malta. Such restrictions will relate to
environmental (e.g. ecological) and cultural designated areas, proximity to the built environment, characteristics of the wind resource and public
acceptance of the first wind turbines. Early indications based on information gathered during a site visit suggest that the visual impacts of any
proposed developments are likely to be the most significant issue. Currently Malta and Gozo are predominantly ‘low-rise’ with only one
‘high-rise’ building measuring approximately 105 m above mean sea level existing. We understand that the development of this building was
controversial and noted that this can be seen from anywhere on the islands when the line of sight is not obscured. As the current average height
of wind turbines are at least this, it is likely that visual impacts will be a critical issue.
A.3.2 Offshore Wind

Resource There are some areas off the coast of Malta and Gozo where the average wind speeds are above 6 m/s at a height of 50 m above sea level, making
available the resource suitable for the purposes of electricity generation.
Development The sea bed around the islands falls off very steeply within short distance from the shoreline (approximately 100 m). With current technology
opportunities development levels and the unproven mechanisms for deepwater foundations (>40 m deep) and tower structures it is unlikely that there will be
exploitable areas where the seabed shows the necessary characteristics. There are however shallower areas of the seabed around Malta. Some of
these zones may be ruled out due to ecological conditions including the presence of sea grass, but there are a few areas of reefs/sand banks that
could be suitable. These are subject to competing uses such as ship bunkering and mooring for fish farms (two sources of income in Malta). In
addition, the wind resource remains uncertain around the reefs/banks: these locations are selected for bunkering and mooring as they are less
5
exposed than other areas during storm times and no wind speed monitoring has been carried out on those sites. In summary, it is likely that some
suitable sites may exist, however there appear to be a number of social (political), technical and environmental barriers to overcome prior to
development.
Technology Status Offshore wind is the new frontier for the international wind industry. The main motivation for going offshore is the higher more predictable wind
speeds at sea. The relative remotness of offshore turbines can not only reduce objections on visual grounds but also can allow for faster rotor
speeds, which in turn increases the potential power output. The range of turbine sizes is now extensive and is typically above 100 m to the tip of
the rotor blade. Offshore wind technology is based on the principles of the mature onshore technologies, however the transition to offshore has
not been as smooth and seamless as originally hoped with survivability being a critical element. Advances in design in the future are likely to
revolve around the survivability of design and materials in a corrosive salt water environment. The potentially higher costs of equipment,
installation and operation and maintenance raise issues of commercial viability in addition to the current lack of commercially proven
technologies/designs.
Environmental As with onshore wind, offshore wind technologies do not emit to the atmosphere, water, or produce wastes but they can have negative
Issues environmental impacts. The list below introduces some possible impacts of offshore turbines, however this is not exhaustive and the specific
nature of impacts are determined by the design and siting of a particular project. Environmental impacts are required to be considered in detail
when undertaking a project specific EIA.
1. Coastal and offshore processes – potential interference with coastal 1. Careful siting and baseline studies prior to construction and adoption
and offshore sediment transport systems arising from such activities as of best practice for the construction process. Some impacts are not
constructing foundations, cable laying and from fixed structures over avoidable but design should seek to minimise the potential long term
the wind farm lifetime. Other specific impacts may include: effects.
interference in mobility of sandbanks, sediment redistribution
(including contaminants), changes in erosion and accretion processes
and changes to seabed morphology.
2. Biological environment – ecological impacts may arise because of 2. Careful baseline studies should be completed encompassing
physical alterations of offshore processes, such as through exploration potential seasonal changes. Focus to minimise potential impacts and
activities and the long-term footprint of towers, cable routes, and ensure the protection of key species (protected, endangered). Design,
associated foundation structures in the area. Possible seabed impacts development and siting can influence the magnitude of effects.
include changes to habitats structure (e.g. substrates), loss or break-up
of ecological corridors, changes to food-chains and feeding grounds,
changes to shellfish beds, spawning grounds, over-wintering ground or
6
migration routes. Water column potential impacts include that from

underwater noise and vibration on fish, birds and marine mammals
during all construction and operational phases, interference with fish
migration and potential impacts of electric fields from cables on certain
species such as sharks and rays. Surface and air potential impacts may
include potential bird strikes on migration and foraging birds and
potential disturbance or habitat changes.
3. Ecological – bird strikes from the blades. There is little real evidence 3. Seasonal surveys of main avian migratory routes should occur prior
that bird strikes on wind turbines present any real problem providing to design and development to minimise impacts.
the turbines are placed with care and thought. There concerns were first
raised by several windfarms built in the 1980s in California. These
wind farms were built without consideration of aesthetic or
environmental issues and caused many problems, including large
numbers of raptor deaths, particularly at the Altamont Pass wind
development which is the subject of much debate. The wind industry
worldwide has learnt from this experience and most local authorities
require study of bird movements to be undertaken prior to giving
planning approval to ensure there will be no significant impact on the
local bird population before. In the UK, the Royal Society for the
Protection of Birds is generally in favour of wind farm developments
as they recognise the benefits of wind farms in the fight against climate
change, which is the largest threat to bird life. RSPB is consulted on
every proposed wind farm in the UK and has objected to a number
which threaten bird life, but has supported other developments that are
appropriately located.
4. Nature Conservation – possible impacts on protected areas (e.g. 4. Design and siting issues should be considered. Marine surveys are
Natura 2000 sites), protection of important marine features. advisable to ensure potential impacts can be reduced or avoided.
5. Cultural heritage and visual impacts – issues may arise due to 5. Landscape and visual impacts should consider the changes in quality
changes in coastal and maritime archaeological features, land and or character, perceived value and viewpoints. Design and siting along
7
seascape quality changes, impacts on protected areas (including from with education and public acceptance are important issues.
cables and shoreline infrastructure etc.), potential influence on humans
and wildlife of navigational lighting.
6. Other uses – impacts from the displacement of fishing activities, 6. Careful design and siting, active consultation with the public and
increased collision risks, interference with positioning and visibility of other stakeholders such as statutory consultees and potential technical
navigational aids, commercial shipping routes and possible viability of fixes for problems may mitigate many of these concerns.
commercial and recreational ports and harbours. Interference with
recreational users, interference with military practice ranges and
electromagnetic interference with radar and telecommunications.
Conclusions There are likely to be restrictions in the opportunities for exploitation of offshore wind in Malta. Such restrictions may relate to environmental
and cultural designated areas, and to technology viability and increased costs. Potentially the most significant issue may be the competing uses of
the sites with seabed characteristics and sea depths suitable for offshore wind turbines. The opportunity costs and associated social impacts of
developing offshore wind farms in some areas should be considered carefully.
A.3.3 Micro-Wind
Resource As noted for onshore wind for some areas of the Mala, it is likely that there is sufficient resource to allow electricity production from micro-wind
available turbines (including at heights less than 50 m).
Development The focus of micro-turbine technology has to date been on attachment to the exterior of man-made structures (e.g. buildings, bridges, sea walls
opportunities etc). Barriers to development potentially include public and lobby group acceptability, areas of environmental protection, cultural heritage
protection areas, access to the sites/buildings for installation and the ability of the distribution grid to maintain stability. An additional barrier
could include the existing planning policy framework although planning authorities could actively encourage the development of such schemes,
where appropriate, on new developments through positively expressed policies in local plan documents.
Technology Status The technology has improved over recent years with turbines now becoming available for lower costs. The range of micro-turbine sizes are now
extensive and typically generate a few hundred watts to several kilowatts. Micro-wind technology is considered mature in many respects,
although reliability and financial viability remain to be demonstrated. Advances in design in the future should result in cost reductions.
Environmental As with the other types of wind turbines outline above micro-wind technologies do not emit to the atmosphere, water, or produce wastes,
Issues however, they can have environmental impacts. The list below introduces some possible negative impacts, however this is not exhaustive and the
specific nature of impacts are determined by the design and siting of a particular project. It is likely that developments will consist of a single or
a couple of turbines per building or structure such as a bridge or sea wall.
8
1. Visual and urban landscape (townscape) impacts are important and 1. Education, careful siting and sympathetic design, along with area
may be critical with many proposed developments opposed due to planning considering the cumulative impact of higher turbine numbers
visual interference. While micro-turbines are small, they can have a are important.
significant impact on the fabric and appearance of the built
environment especially in areas of historic or conservation importance.
2. Light flicker is a potential nuisance issue particularly in 2. Sympatetic design and consideration of the siting of any turbine
neighbouring buildings. should be taken into account.
3. Electromagnetic Interference (EMI) – the EMI impacts from small 3. Careful siting and design including technical fixes where applicable
wind turbines are considered to be less significant than those from may be necessary.
larger turbines. Electrical interference principally comes from signals
generated within the wind turbine which may impact on
communications equipment and should be considered during the siting
of turbines.
4. Noise and vibration – The scale of the micro-turbines and higher 4. Consideration of design and siting as well as technology and area
background noise levels in towns reduces the risks of interference from will be important stages in the planning process. Many impacts can be
noise. reduced or resolved in the early stages.
Conclusions There are likely to be some restrictions in the opportunities for exploitation of micro-wind in Malta. Such restrictions are likely to relate to
environmental issues (particularly visual), cultural designated areas and the planning process.
A.4 Photovoltaic
Resource The islands of the Maltese Archipelago experience about 3000 hours of sunshine per year. The islands typically have a daily average of 5 to 6
available hours sunshine in mid-winter to more than 12 hours in summer. The potential for the generation of solar electricity is high.
Development There are essentially two generic forms of installations producing solar electricity; commercial scale solar farms and domestic scale grid
opportunities connected installations. Solar concentrators are also being developed but as with commercial scale solar farms, they require large areas of land.
This means that the opportunities for theses types of development are very limited in Malta due to competing demands for limited open land.
The potential for domestic grid connected solar installations is much higher. The possible limitations to the exploitation of this resource include
9
restrictions on the generating capacity of an installation at any one building. Enemalta has currently limited the size of the generating capacity to
equivalent to the size of the supply to the property. This is not considered a barrier because due to the current high cost associated with PV, it is
likely that the mean output of installations per household will not exceed typical summer daytime load levels, so as to minimise the amount of
electricity “spilt” into the distribution system with zero or a lower return. This allows the household to be within the level indicated by Enemalta.
There may be issues related to planning permissions that have to be resolved such as alteration of the fabric of the area. Many roofs have dual
purposes which may limit the size of the exploitable rooftops on domestic dwellings. In addition, competition of roof space with solar water
heating units may prove problematic. Protection of cultural heritage may limit the potential in some of the more culturally significant regions of
Malta. Shared ownership of rooftops for apartments may also be an issue that limits the penetration of the technology. The shortage of land in
Malta may increase the requirements to build taller buildings. In some areas this means extending upward the existing building stock, subject to
the prevailing planning policy framework in the area. Such increases in building height may change the shadows from buildings (and associated
levels of light penetration to adjacent properties) and may also make some rooftops unviable for PV exploitation.
Technology Status .Solar concentrators are emerging technology. Traditional PV technology has improved over recent years with costs reducing considerably. The
use of photovoltaic technologies in isolated sites is now well established, and PV systems are competitive with alternatives at remote locations,
provided that they require only relatively small amounts of power. The cost of PV modules is continuing to decline steadily, but there has also
been a substantial fall in the cost of other PV system components (balance of system) during the last 5 years. Substantial growth has taken place
recently in building integrated PV applications, where the costs of the PV modules can be off-set against the costs of the building cladding
materials which they replace. If the expected future PV cost goals are to be achieved, then substantial further basic research is needed to develop
thin film PV module technologies, and lower cost "solar grade" silicon for the manufacture of solar cells. The cost when coupled with the rate of
return on investment is still one of the most significant barriers to development. A range of photovoltaic cells are now available each having
slightly different properties and therefore costs and benefits but they remain expensive. The improvements in building’s integrated PV are now
making the possibility of all new buildings generating electricity more likely (subject to codes and incentives). Solar PV technology is
considered to be relatively mature, however the cost is still high and in many cases is commercially prohibitive, requiring extensive support
mechanisms to increase the viability. Advances in design and materials in the future should result in cost reductions.
Environmental As is the case with wind; solar PV technologies do not emit to the atmosphere, water, or produce wastes during operational periods, however,
Issues they do have potential negative environmental impacts. The list below introduces some possible impacts, however this is not exhaustive and the
specific nature of impacts are determined by the design and siting of a particular project. Developments in Malta are likely to consist of a single
or a couple of PV panels per building for domestic households and larger installations on the roofs of hotels, schools, hospitals, offices and
industrial facilities.
1. The primary environmental issues arise during manufacture of solar 1. Energy required to manufacture solar is reducing and is anticipated
10
PV units and include the significant proportions of energy used in the to reduce over time as processes and materials are improved and
manufacture process. Excavation and handling of the materials economies of scale are realised. The potential effects from the
required for the construction of solar PV units can have significant excavation, handling and processing of materials in the production of
environmental (and health and safety) impacts and often include the solar cells can be minimised through the application of industrial
arsenic, cadmium and the reasonably inert silicon. best practice measures. It is now no longer the case that solar PV units
emit more during their manufacture (through energy consumption) than
are emitted during their operation. It has been suggested that payback
of emissions are within 2 – 3 years.
2. Visual and urban landscape (townscape) impacts are potentially an 2. Education, careful siting and sympathetic design, along with area
issue in some areas such as cultural and historical protection zones of planning considering the cumulative impact of higher proportion of
the built environment in Malta. As with micro-wind turbines the units solar PV are important.
are small, however, collectively they could have a significant impact
on the fabric and appearance of the built environment particularly
related to visual glare.
Conclusions There are likely to be some restrictions in the opportunities for exploitation of Solar PV in Malta. Costs may be the most significant potential
barrier to investment. Other restrictions are likely to be related to the maximum allowable size of electricity exported to the grid, the available
exploitable roof space, competition with solar thermal for roof space and the planning approval process particularly in areas designated for their
cultural and historical importance.
A.5 Biomass Fuels (Energy Crops)

Resource The islands of the Maltese Archipelago are unlikely to generate enough biomass resource to power a unit in isolation from fuel imports from
available abroad. The climate in Malta is such that it will limit the growth of large amounts of woody biomass due to a lack of water. The lack of suitable
available land will also constrain the development of energy crops as they are unlikely to be considered a viable use of the land in comparison to
1
For example, the yield projections for Miscanthus grass growing in non-ideal conditions can be optimistically estimated at 9 dry-tonnes per hectare per year. At 9 tonnes per Ha per year and
17 MJ/kg, then each hectare gives 153,000 MJ per year (thermal). For biomass combustion power plants, a conversion efficiency of 25% could be assumed, giving 10.6 MWh
(electrical) per Ha per year. At 7500 hours per year operation, this is an average output of 1.4 kWe per Ha. Therefore, 1 MWe = 700 Ha
A.1.1
11
alternatives. 1 The proximity to other areas of Europe may allow the import of biomass fuels to be used in the generation of electricity. This
would, however, lead to an increase in costs.
Development Turning biomass into energy is possible both through stand-alone new plant and through co-firing with fossil fuel in existing plant (co-firing
opportunities means burning a percentage of energy crops mixed with fossil fuels in existing power plants). In Malta, any of these two options would rely
largely on imported fuel which is likely to be problematic as biomass fuels are often bulky and light there can be considerable transport/storage
issues and costs. Also, renewables targets exist throughout Europe therefore there may be increasing demands for energy crops to be consumed
domestically which could have the effect of either increasing the costs or reducing the availability of a reliable imported fuel source.
Technology Status The term biomass energy crops refer to the conversion of solid organic materials, specially grown for energy production, to heat and electricity.
In the case of stand-alone new plants, the use of energy crops to generate electricity can be done in two principal ways: by direct combustion
with heat recovered to produce electricity or by advanced conversion (gasification) where biomass is heated in an airtight chamber and then
oxidized to produce a gas. This gas can be burned to produce heat and electricity. The technology for direct combustion is well established and
proven throughout the world for a variety of fuels such as grasses, coppice, and other energy crops, although some aspects of fuel preparation and
supply for energy crops requires further development. Advanced conversion is potentially cleaner and more efficient but the technology is
currently in the demonstration phase. There are a few plants running in Europe, however, some of these plants have experienced both technical
and fuel supply problems. There is greater uncertainty regarding the financing and commercial viability of advanced conversion technologies
with further R&D and demonstration needed to increase efficiencies and reliability and to reduce costs.
In the case of co-firing of biomass with fossil fuel in an existing plant, this is an established technique that can achieve significant carbon
savings. The long-term potential of this option in Malta depends on the fuel supply and storage (including the associated costs), potential
refurbishment of existing plant to allow it to occur and/or increased maintenance, all of which will increase costs.
Environmental The large-scale production and harvesting of biomass specifically for energy crops concerns some environmentalists and critics of renewable
Issues energy alike. Many fear that it will be necessary to convert large tracts of valuable agricultural land or wildlife habitat to monoculture (single
species) energy plantations requiring heavy inputs of fertilizers and pesticides. In response, biomass energy proponents argue that it is possible to
grow and harvest bioenergy crops on an economically and ecologically sustainable basis on lands that have marginal agricultural value. Impacts
relating to crop growth are not likely to occur in Malta as growing indigenous energy crops is not a viable option due to the lack of water and
land. Biomass power based on fuel imports could be possible in Malta and this would raise more environmental issues, such as air pollution from
transport and combustion, than either wind and solar PV.
1. If improperly managed any kind of energy crop production could 1. The climate in Malta does not lend itself to the growth of energy
result in harmful environmental impacts. Energy crops could affect crops, so this is unlikely to happen. In any event, regulation and
12
biodiversity through the destruction of species habitats, especially if monitoring of energy crop development could mitigate some of these
farmland is more intensively managed. concerns
2. For biomass projects the need to transport biomass fuels to the 2. The potential impacts of biomass fuel transportation can be reduced
energy production plant does have the potential to lead to increases in by ensuring that generation plants are located in as close proximity as
traffic movements and volumes. This introduces both environmental possible to sources of fuel or in the case of the Maltese Archipelago
and social issues with increased pollution and noise and a potential which is likely to require imports from other areas of Europe near a
increased risk from traffic related safety issues. port. In addition, the planning authority (MEPA) should recognise that
there are other considerations such as electrical grid connections and
the potential to use heat generated from any biomass project which
may influence location options.
3. Visual impacts – normally a biomass development will include a 3. Careful siting and design can to some extent mitigate the visual
series of buildings and a stack. Operationally the visual impact of intrusion of these. The visual impact of the exhaust plume is often
exhaust plumes can cause direct conflict but also create the impression related to the water content and therefore the combustion
of pollution. The visual impacts of these should be considered. characteristics should be monitored. There may also be mitigation that
can arise through public consultation and education, for example, in
modern plant water vapour in the exhaust air often gives it the
visibility.
4. There are a number of issues that can arise because of noise and 4. Careful design and siting of the plant and routing of all transport to
vibration. These can be related to the collection and transportation of avoid unnecessary interference with receptors. Consideration of other
fuel and the activities on-site including preparation and movement of developments/land uses in the surrounding area is another important
fuel, combustion and the collection and disposal of waste residues. element (i.e. agricultural, industrial).
5. Odour from the collection, transport, storage and combustion can 5. This is often dependent on the fuel type, design and siting and in
cause some localised concerns. most cases are easily mitigated during the design and consultation
processes.
6. There is the potential for pollution problems to water and land as 6. Careful design of facilities to the latest standards can alleviate many
well as to the atmosphere through the transportation, storage, of the problems.
combustion and disposal of residues.
13
7. Burning biomass energy crops can produce local and regional air 7. Efficient combustion and treatment of the combustion gases will
quality impacts including potentially carcinogenic polycyclic aromatic control particulates in air emissions. In electric generating plants as
hydrocarbons (PAHs, organic compounds such as benzo(a)pyrene) and much as 70% of these air pollutants can be removed by installing the
particulates found in biomass smoke. Sulphur and nitrogen oxides, appropriate air-pollution control devices in the combustion system. Air
carbon monoxide, and aldehydes also are released in small though quality emission specifications are often more stringent than fossil fuel
significant quantities and can contribute to reduced local/regional air plant. CO2 emissions are considered to be neutral and only releasing
quality. the carbon equivalent to that locked up during growth. More advanced
technologies, such as the whole-tree burner (which has three successive
combustion stages) and the gasifier/combustion turbine combination,
should generate much lower emissions, perhaps comparable to those of
power plants fuelled by natural gas.
Conclusions The growth of energy crops on Malta is likely to be severely limited. If biomass energy crop generation is to occur the fuel is likely to come
from international imports. Impacts from transportation and storage of the fuel supplied will prohibitively drive up the costs of electricity
production. It is concluded that for the generation of electricity there are no realistic opportunities for energy crops.
A.6 Biomass Wastes

Resource Biomass wastes are any waste product or fraction of waste that is biodegradable (please note that biomass waste consideration here excludes
available landfill and sewage gases). The agricultural sector is an important industry in Malta. A significant proportion of this is not centralised and
comprises of smaller land-holdings. Availability of adequate biomass fuel will be very limited and it would require significant centralisation. The
biodegradable fraction of the municipal waste streams may offer opportunities for renewable energy supply. In addition the import of biomass
wastes from elsewhere in Europe could offer some potential for biomass waste electricity generation although this option has cost issues
associated with fuel transport and storage which are similar to those described above for energy crops. Co-firing of biomass waste fuels with
conventional fuels in either of the existing power plants may also be a possibility.
Development There may be potential for the development of energy from biomass waste plants (these are being assessed under a separate study and are outside
opportunities of the scope of this study). Limitations on the economic viability of such a development may include the costs of collection, sorting,
transportation and storage for biomass wastes, particularly if sourced from abroad.
Technology Status Direct combustion of biomass wastes with the recovery of energy is an established technology with wide ranging experience in various locations
throughout Europe. Co-firing of biomass wastes with fossil fuel while a relatively new area relies on established techniques and experiences
gained through the combustion for fossil fuels. The long-term potential of direct combustion depends on the fuel supply and construction of new
14
facilities or the potential refurbishment of existing plant (if co-firing). Advanced conversion of biomass waste (gasification and pyrolysis) are
becoming commercially viable in some areas, although the specifics of the waste streams, fuel preparation and storage and disposal of the
residues can still pose problems. Advanced conversion of biomass wastes are still comparatively expensive with other energy from waste
technologies and are largely unproven commercially.
Environmental For biomass wastes, or the biomass fraction of Municipal Solid Waste (MSW), disposal can often be an issue. Using biomass wastes as an
Issues energy source can therefore provide an environmentally acceptable method of waste disposal as well as providing economic benefits in the form
of electricity production. Incinerating MSW is of more concern environmentally than advanced conversion or segregated biomass wastes, mainly
because of the non-biomass materials in MSW, like plastics, heavy metals, and chemicals. As a result, burning MSW releases numerous
hazardous elements and compounds into the combustion gases. The ash may also be heavily contaminated. MSW incinerators must meet much
stricter air emission and ash disposal regulations than facilities that burn pure biomass materials. Other environmental impacts can arise from the
transport and storage of wastes, however these exist to a large extent with the waste stream regardless of the disposal route.
1. For biomass waste projects the need to transport biomass fuels to the 1. The potential impacts of biomass fuel transportation can be reduced
energy production plant can lead to increases in traffic movements and by ensuring that generation plants are located in as close proximity as
volumes. This introduces both environmental and social issues with possible to sources of fuel. In addition, the planning authority (MEPA)
increased pollution and noise and a potential increased risk from traffic should recognise that there are other considerations such as electrical
related safety issues. grid connections and the potential to use heat generated from any
biomass project which may influence location options.
2. Visual impacts – normally a biomass waste developments will 2. Careful siting and design can to some extent mitigate the visual
include a series of buildings and a stack. Operationally the additional intrusion of these. The visual impact of the exhaust plume is often
visual impact of exhaust plumes can cause direct conflict but also related to the water content and therefore the combustion
create the impression of pollution. The visual impacts of these should characteristics should be monitored. There may also be mitigation that
be considered. can arise through public consultation and education, for example, in
modern plant water vapour in the exhaust air often gives it the
visibility.
3. There are a number of issues that can arise because of noise and 3. Careful routing and timing of transportation routes in addition to the
vibration. These can be related to the collection and transportation of siting of any facility can mitigate these impacts to some extent. The
fuel and the activities on-site including preparation and movement of adoption of the latest technology and siting away from sensitive
receptors can alleviate concerns related to the operation of the facility.
15
fuel, combustion and the collection and disposal of waste residues. Consideration of other developments/land uses in the surrounding area
is another important element (i.e. agricultural, industrial).
4. Odour from the collection, transport, storage and combustion can 4. This is often dependent on the fuel type, design and siting and in
cause some localised concerns. most cases are easily mitigated during the design and consultation
processes.
5. There is the potential for pollution problems to water and land as 5. Careful design of facilities to the latest standards can alleviate many
well as to the atmosphere through the transportation, storage, of the problems.
combustion and disposal of residues.
6. Burning biomass wastes can produce local and regional air quality 6. One of the most effective forms of control is through the careful
impacts including potentially carcinogenic polycyclic aromatic separation and sorting of the waste streams to remove potentially
hydrocarbons (PAHs, organic compounds such as benzo(a)pyrene) and problematic elements e.g. some plastics. Incorporation of knowledge
particulates found in biomass smoke. Sulphur and nitrogen oxides, of the waste stream content into the design can allow the design to be
carbon monoxide, and aldehydes also are released in small though modified to reduce are pollution issues. Efficient combustion and
significant quantities and can contribute to reduced local/regional air treatment of the combustion gases will control particulates in air
quality. emissions. Air quality emission specifications are more stringent than
fossil fuel plant. More advanced technologies such as
gasifier/combustion turbine combination, should generate much lower
emissions, perhaps comparable to those of power plants fuelled by
natural gas.
7. Facilities that burn mixed municipal waste present a unique 7. Careful design of the combustion conditions and pollution abatement
pollution-control problem. This waste often contains toxic metals, techniques can mitigate the emissions from biomass waste plants to
chlorinated compounds, and plastics, which generate harmful some extent. The most significant way of controlling the more harmful
emissions. This problem is much less severe in facilities burning chemicals is through the careful management and sorting of the fuel
sorted fuels such as refuse-derived fuel (RDF)-pelletised or shredded supply.
paper and other waste with most inorganic material removed.
Conclusions High level consideration of the potential for renewable energy derived from waste (biomass fraction) in Malta suggests that there may be
opportunities for such facilities. In Malta this may prove to be strategically a significant environmental opportunity as this would also help to
deal with waste management and assist Malta in meeting current and future European legislation related to waste management. The
16
consideration of all waste related renewables is being completed in a separate study and therefore these technologies are not considered further in
this study.
A.7 Hydro
Resource Malta has a very dry, hot climate. Water is a very valuable resource with limited surface water for much of the year and reliance on desalination
available plants for water supply. The potential for any type of hydro-power is considered low and likely to be unreliable and uneconomical.
Conclusions This potential technology is not considered any further.
A.8 Geothermal
Resource Malta is not located in an area of the world with any discernable geothermal resource.
available
A.9 Wave
Resource Malta, Gozo and Comino form an archipelago that is located in the Mediterranean Sea about 100 km off the south coast of Sicily. The resource
available in the waters close to Malta for offshore wave appears to be limited with significant wave height not exceeding 4.5 m on an annual basis, or 3.5 m
in the summer period (Wave Height Study, Scott Wilson for Malta Maritime Authority, December 2003). These wave heights will not be
sufficient for energy conversion based on current designs that operate at peak power at wave heights above 4.5 m. As for offshore wind, the
depth of the sea-bed may cause problems related to mooring of the devices and the connection to the grid.
Shoreline wave power is another option for the exploitation of wave energy (such as oscillating water column devices, OWC). The resource
available is likely to be very limited based on the low wave height out to sea around Malta, not exceeding 4.5 m significant wave height, and the
fact that much of the exposed coastline that may be suitable for such devices is protected under national and international environmental
designations.
Development For offshore wave, there may be opportunities in the future as technology develops that is able to operate at lower wave heights. In such case, the
opportunities deepwater off the west coast of Malta (the likely area of wave energy potential) may pose severe engineering issues with regards to anchorage
17
and collection and transport of the power to the shoreline thus affecting the successful exploitation of the resource.
For onshore exploitation, even if the technology develops in the future capable of generating effectively at lower wave heights, it is expected that
development opportunities will be severely limited as the protection of the coastline is likely to take priority.
Technology Status For offshore wave energy exploitation, the race for developing the ‘winning’ design is still on. There are a few devices that are nearing
commercial demonstration although these may still be 5-10 years off full commercial exploitation. One of the leading devices at the moment is
Ocean Power Delivery’s Pelamis which is a hydraulic sea snake design. This is currently undergoing sea demonstration. The average wave
height that generates Pelamis’s rated energy is likely to be around and over 4.5 m and it is unlikely that wave heights suitable for good levels of
generation will be around Malta.
As technology improves over time the responsiveness to smaller wave heights may improve thus leading to opportunities to exploit this resource
in Malta. Given that the currently emerging devices are likely to reach commercial deployment during the next 5-10 years it is not likely that the
technology will be available before 2020, unless a technological step change occurs before that date.
For shoreline wave electricity production the device being deployed worldwide is the oscillating water column. This device consists of a partially
submerged hollow tube that is open to the sea below the waterline. This then encloses a column of air on top of a column of sea water. Incoming
waves cause a raise and fall in the water column, compressing and enlarging the air column. The trapped compressed air then passes through a
turbine which then generates electricity. There are limited number of commercially viable projects throughout the world as there are relatively
few areas that have both the suitable coastline structure and sufficient wave energy to make such devices work effectively. As already
mentioned, it is unlikely that there are either the sites or the resource for this in Malta.
Environmental As with wind energy devices, wave devices produce no emissions during the generation of electricity. There are, however, wider environmental
Issues impacts that should be considered when evaluating the environmental impacts of wave devices.
1. Coastal and offshore processes – potential interference with coastal 1. Careful siting and baseline studies prior to construction and adoption
and offshore sediment transport systems arising from such issues as of best practice for the construction process. Some impacts are not
constructing foundations/anchoring points, cable laying and from fixed avoidable but design should seek to minimise the potential long term
structures over the wave farm lifetime. Other specific impacts may effects.
include interference in mobility of sandbanks, sediment redistribution
(including contaminants), changes in erosion and accretion processes,
and changes to seabed morphology.
18
2. Biological environment – ecological impacts may arise because of 2. Careful baseline studies should be completed encompassing
physical alterations of offshore processes, as a direct result of potential seasonal changes. Focus to minimise potential impacts and
exploration activities and the footprint foundation/anchoring structures ensure the protection of key species (protected, endangered). Design,
in the area. In the case of oscillating water column type devices, development and siting can influence the magnitude of effects.
potential impacts include that from underwater noise and vibration on Offshore wave devices should require less offshore engineering than
fish, birds and marine mammals in both the construction and offshore wind as many of the emerging devices can be assembled close
operational phases, interference with fish migration and potential to the shore and transported to their mooring positions.
impacts of electric fields from cables on certain species such as sharks
and rays.
3. Nature Conservation – possible impacts on protected areas (e.g. 3. Design and siting issues should be considered.
Natura 2000 sites), protection of important marine features.
4. Cultural heritage and visual impacts – issues may arise due to 4. Landscape and visual impacts should consider change in quality or
changes in coastal and maritime archaeological features, land and character, perceived value, viewpoints. Design and siting along with
seascape quality changes, impacts on protected areas (including cables education and public acceptance are important issues.
etc.), potential influence on humans and wildlife of navigational
lighting. Visual impacts are likely to be more pronounced on the
shoreline and nearshore areas than offshore facilities.
5. Other uses – impacts from the displacement of fishing activities, 5. Careful design and siting, active consultation with the public and
increased collision risks, interference with positioning and visibility of other stakeholders such as statutory consultees and potential technical
navigational aids, commercial shipping routes and possible viability of fixes for problems. Adequate visual and radar warning devices can be
commercial and recreational ports and harbours. Interference with built into most devices
recreational users, interference with military practice ranges and
electromagnetic interference with radar and telecommunications.
6. Noise: this would come primarily from the Wells turbines of 6. These can be fitted with sound proofing to mitigate this impact.
shoreline/nearshore OWCs
Conclusions Given the state of current wave energy conversion devices and the wave height and wave length required to operate at maximum rated output it is
unlikely that there is significant potential for offshore exploitation of wave devices. Beyond 2020 there may be opportunities for capturing this
19
potential energy although the significance of the wave resource remains questionable. Shoreline devices are unlikely because of their significant
environmental impact on the protected coastal areas.
A.10 Tidal
Resource There are two main ways to exploit energy from tidal systems. Traditionally this technology focussed on the rise and fall of tides capturing this
available kinetic movement through barrages across estuaries. More recently tidal stream has begun to emerge as a new technology that seeks to exploit
strong tidal/marine currents that are found in shallow seas/areas of coastline, particularly where natural constrictions exist, such as around
headlands or between islands. Malta is in the Mediterranean where there is very little tidal movement so there is no resource for traditional tidal
technology. Around the island there are unlikely to be any opportunities to develop tidal stream devices as currents are too slow to generate
from. It may be possible to complete significant engineering and channelling works which act to constrain the flow in the area between Malta
and Gozo although such an action would cause significant environmental impacts. There are no plans for this to occur, therefore it is concluded
that the currents are too weak to sustain generation.
A.11 Landfill Gas

Resource Landfill gas (LFG) is a mixture of approximately 50% methane and carbon dioxide resulting from the biodegradation, in the absence of oxygen,
available of organic landfilled waste. This is potentially available in the landfill sites present and planned in Malta.
Development Malta is currently investigating waste management options. There are two old landfills that were uncontrolled and are now no longer used, there
opportunities may be potential to reverse engineer these existing landfill sites so that landfill gas can be collected and turned to energy. A new waste disposal
facility is being designed, if this includes some element of landfill then it should be ensured that energy recover (and landfill gas collection) is
taken into consideration. The opportunities for the development of landfill gas are subject to a separate study being completed by other
consultants.
Technology Status Technologies to produce electricity from landfill gas are now well established, and environmental legislation which requires the collection of the
methane at landfill sites is being widely introduced throughout the EU. Continuing growth can therefore be expected in the EU of the production
of energy from landfill gas in the short to medium term. However, legislation is also being introduced to limit the use of landfill for waste
disposal, so in the longer term the market for landfill gas is expected to decline.
Landfill gas to energy is a well established and mature technology. There are few technical barriers to the exploitation of the resource the most
significant being the engineering of the site to safely and efficiently collect the methane gas. The equipment and components used for landfill gas
20
energy recovery are for the most part adapted and modified from existing technologies and as such require little further development. The
remainder of the generation package is also standard equipment found in any generation plant, so there are unlikely to be areas for major
technical development.
Environmental Landfill gas capture and combustion converts a major greenhouse gas into useful energy. As the turbines are often located close to the source of
Issues the landfill gas they are often brownfield sites and therefore a number of environmental concerns associated with greenfield developments do not
arise.
1. Emissions of gases in an uncontrolled manner from landfill sites 1. The control of emissions through energy recovery schemes should
and/or controlled flaring of the gas are both harmful to the environment be preferred wherever possible. There are abatement techniques that
and wasteful of the energy potential. Collecting and burning landfill should minimise the negative environmental impacts from recovering
gas reduces both global and local environmental effects of uncontrolled the energy from landfill gas.
releases. However, emissions from flares and energy recovery systems
include CO2, CO, NOx, SOx and other components all of which may
have local and global environmental effects (although smaller than
uncontrolled releases).
2. Visual impact of pipeworks, pump extraction equipment and flare 2. Screening, sympathetic siting and design will help to mitigate the
stacks as well as buildings to contain transformers, control panels and negative potential impacts. It is not anticipated that this will be a
switchgear etc. may be an issue although if these are located at or close significant issue.
to landfill sites this issue may not be as severe as with other renewable
energy types.
3. Landscape impact – can often be limited due to possible close 3. Careful design, consultation and siting are usually sufficient to
proximity to a landfill. But if landfill works are ended and restoration mitigate the concerns.
underway there is potential for visual intrusion into the landscape.
4. Liquid effluent and residue control. 4. Any extraction equipment would normally be located on a concrete
slab and bunded to ensure that no liquid effluent can escape to ground
or surface waters. This should be designed into the landfill as opposed
to the energy recovery system although it is noted that if the
reverse-engineering for recovery of gases is to occur then this should
21
reduce such risks and as a minimum should not increase the risk of
additional contamination.
5. Noise from mechanical equipment – it is possible that there may be 5. Careful siting and design, appropriate equipment selection and
noise associated with the operation of a landfill gas turbine. proximity to the landfill are likely to be key factors in mitigating the
impacts from such a plant. Should a detailed study show noise to be an
issue then appropriate building design, noise screening and public
consultation will all be important elements. It is likely that there will
be noise associated with the operation of a landfill these should not be
confused. If the landfill and energy recovery is new then this should be
considered during the planning and application process.
Conclusions Gas from a landfill site is potentially hazardous; health and safety is of paramount importance in any proposed energy recovery process. It is
considered that Malta has the potential for exploitation of landfill gas both through the retrofitting of the existing landfill sites and the
development of new landfill sites. The consideration of all waste related renewables is being completed in a separate study and are therefore not
considered further in this study.
A.12 Sewage Gas

Resource Malta is likely to have a potential resource through the waste water treatment sector. Waste is being considered as part of a separate assessment
available for Malta.
Development Developments using sewage gas digestion systems can be constructed at existing wastewater treatment facilities were the additional buildings and
opportunities tank structures are likely to be acceptable to the planning policy decision makers and the general public. Malta may consider the centralisation of
this renewable resource although this introduces some issues regarding the safe and efficient transport and storage of the sewage waste.
Technology Status As with landfill gas the technology principles are established. Advancements can be made through improvements of the efficiency of the overall
process. There may be opportunities to link this with other forms of strategic waste disposal to reduce the mass of the waste once digestion has
occurred (incineration, energy from waste).
Environmental There are potential environmental issues associated with the exploitation of sewage gas, these are outlined below. The important element of this
Issues technology is that, as is the case with landfill gas and energy from waste, benefits can be obtained by utilising a resource that is otherwise
potentially problematic to the environment.
22
1. Uncontrolled emissions of gases or releases to land/water from 1. Design of the capture and storage devices should minimise the
waste water treatment works, e.g. liquid effluent and residues. potential problems here.
2. Collecting and burning sewage gas reduces both global and local 2. The control of emissions through energy recovery schemes should
environmental effects of uncontrolled releases. However, emissions be preferred wherever possible. Design of the combustion facility
from flares and energy recovery systems such as CO2, CO, NOx, SOx should seek to minimise the emissions of pollutants and should reduce
and other components may have local and global environmental the risks of impacts.
effects.
3. Visual impact of pipeworks, pump extraction equipment and flare 3. Screening, sympathetic siting and design will help to mitigate the
stacks. As well as buildings to contain transformers, control panels and negative potential impacts
switchgear etc. may be an issue although if these are located at or close
to waste water treatment centres this issue may not be as severe as with
other renewable energy types.
4. Odour from the treatment of sewage sludge may be a problem. 4. This is more likely to be associated with the waste water treatment
works than the power generation facility. However, if there is
collection and storage on a centralised basis this issue should be
considered in detail and transport routes given due care and attention.
5. Noise from mechanical equipment – it is possible that there may be 5. Careful siting and design, appropriate equipment selection and
noise associated with the operation of a gas turbine. proximity to the landfill are likely to be key factors in mitigating the
impacts from such a plant. Should a detailed study show noise to be an
issue then appropriate building design, noise screening and public
consultation will all be important elements.
Conclusions Gas from sewage treatment site is potentially hazardous with health and safety being of paramount importance in any proposed energy recovery
process. Malta may have the potential to exploit this resource. The consideration of all waste related renewables further are being completed in a
separate study and are therefore not considered further in this study.
23
A.13 Conclusions
The above screening exercise has considered the renewable technologies that are outlined under the so
called EU Renewables Directive (2001/77/EC). The screening first considered the resource
availability then, where applicable, considered development opportunities, technology status and
outlined some of the potential environmental impacts that exploitation of such technologies would
bring.
The screening has identified some technologies which may be suitable for Malta and that warrant
further investigation. These are as follows:
• Onshore wind
• Offshore wind
• Micro-wind
• PV
• The recovery of renewable electricity from biomass wastes, landfill gas and sewage gas
Further consideration of this resource is nevertheless outside the scope of this study and is
subject of assessments being carried out by others. The present study will therefore not
consider these technology options any further.
This screening exercise has also identified technologies which are not suitable for Malta due to the
lack of resource and will therefore not be considered further in this study. These are:
• Tidal flow
• Geothermal
• Hydro (large, small and micro)
• Biomass energy crops. In this case it was concluded that there are not sufficient resources
available without the import of significant quantities of fuel for both generation in new
plants and co-firing in existing plants. This is likely to be prohibitively expensive and
environmentally unsustainable once transport considerations are taken into account.
• Offshore wave: This technology was ruled out base on the designs which are likely to be
available in the next 10 years. If technology develops that is more responsive to lower wave
heights, exploitation of this resource in Malta may become more feasible.
• Onshore wave: In this case even if technology develops that is able to exploit the energy
from waves with low crests, it is unlikely that this will become an option as the Maltese
coastline is highly protected.
This study will therefore consider the contribution to electricity consumption in Malta that may be
obtained from:
• Onshore wind
• Offshore wind
• Micro-wind
• PV.
206106//04 Feb 2005/ 24 of 1

24
Annex B Wind Resource Characterisation Mott MacDonald
Annex B
Wind Turbine Generation
Resource Characterisation

Isabel Philip
i
F:\PROJECTS\206106 Malta\Phase 1 deliverables\Phase 1 report\Final Report\Final Report Annex B - Wind Resource.doc
List of Contents
Annex B Wind Resource Characterisation 1

B.1 Introduction 1
B.2 Maximum Wind Potential 1
B.2.1 Methodology 1
(i) Site Selection 2
(ii) Maximum Capacity 3
(iii) Maximum Energy Yield 3
B.2.2 Large Onshore Wind 5
(ii) Maximum Energy Yield 6
B.2.3 Medium Scale Wind 10
(ii) Maximum Energy Yield 10
B.2.4 Micro-Wind 12
(ii) Maximum Potential 13
B.2.5 Large Offshore Wind 14
(ii) Maximum Potential 14
B.3 Constrained Wind Potential 17
B.3.1 Large Onshore Wind 17
(i) Electromagnetic Interference 17
(ii) Access 19
(iii) Electricity System Stability 19
(iv) Ecology and Landscape Impacts 19
(v) Visual Impact 19
B.3.2 Medium Scale Wind 19
B.3.3 Micro-Wind 20
B.3.4 Large Offshore Wind 20
Tables
Table B-1 Offshore Windfarm Precedents ............................................................................................. 2
Table B-2: Target Areas & Maximum MW ............................................................................................ 5
Table B-4: Maximum Onshore Wind Energy Yield (850kW Wind Turbines) ....................................... 8
Table B-5: Maximum Onshore Energy Yield potential (2MW Wind Turbines) .................................... 9
Table B-6: Total Number of Rural Buildings........................................................................................ 10
Table B-7: Medium-Scale Wind Production (20kW Turbines) ............................................................ 11
Table B-8: Medium-Scale Wind Production (60kW Turbines) ............................................................ 11
Table B-9: Maximum Medium-Scale Potential - 20kW Case............................................................... 12
Table B-10: Maximum Medium-Scale Potential - 60kW Case............................................................. 12
Table B-11: Individual Domestic Rooftops Available for Micro-turbines ........................................... 12
Table B-12: Micro-Wind Potential (1kW wind turbine) ....................................................................... 13
Table B-13: Maximum Micro-Wind Potential ...................................................................................... 13
Table B-14: Maximum Offshore Wind Energy Yield potential (3MW Wind Turbines)...................... 16
Table B-13: Constrained Wind Potential .............................................................................................. 17
ii
Table B-15: Onshore Sites: Airport Interference Analysis ................................................................... 18
Figures
Figure B-1: Potential Sites for Onshore and Offshore Wind Exploitation.............................................. 7
iii
Annex B Wind Resource Characterisation
B.1 Introduction
This annex characterises the wind resource available for electricity generation in Malta and considers
the maximum potential levels of resource exploitation. This is carried out in two major steps:
• The maximum available wind potential is calculated based on unconstrained availability of
the resource combined with unconstrained sites on the islands, for example wind and areas of
exposed ground for wind generation.1
• The maximum potential is then constrained to account for technical, environmental, planning
and legislative barriers that may be present in Malta.
The results of this analysis includes a series of scenarios for wind and PV (refer to Annex C)
exploitation that consider the relative influences of the constraints and the effects of removing or
reducing them in Malta. These scenarios are then used to estimate potential levels of indicative targets
for wind and solar in Malta whilst providing an indication of the costs of doing so (see Volume 1 main
report).
B.2 Maximum Wind Potential
This section characterises the wind resource in the Maltese Archipelago for wind energy exploitation
and presents the maximum potential available in terms of capacity installed (MW) and energy yield
(GWh). At this stage, focus has been on combining an estimate of suitable wind speeds with
approximate areas of exposed land making no considerations of constraints that may reduce the
maximum potential, these are analysed and their impact assessed in detail in Section 1.1.1(i)B.3
below.
The following types of wind generation have been considered in evaluating the maximum potential
resource:
• Onshore large scale wind farms (2MW wind turbines)
• Medium scale single turbines at farmsteads scattered around the islands (20-60kW turbines)
• Grid-connected micro-scale wind with 1kW machines fitted to roofs/buildings
• Offshore large wind farms.
B.2.1 Methodology
The methodology used for calculating maximum potential resource comprises the following steps:
• Selection of unconstrained suitable sites
1
SgurrEnergy (a wind specialist consultancy) has assisted Mott MacDonald in the calculation of site wind speeds and energy
yields.
1
• Calculation of maximum capacity considering reasonable layouts in the unconstrained areas

of exposed land and sea for windfarms and single installations of medium and micro-wind
(MW)
• Calculation of maximum energy yield (MWh/year)
(i) Site Selection
For large scale onshore wind farm development, the present study identifies target areas for large scale
wind farm development based on ground elevation. The analysis explores realistic turbine layouts for
the sites and excludes turbines from steep slopes and densely populated areas but, as already
mentioned, at this stage no consideration has been given to constraints that may impact on the
potential capacity installed (such as environmental designations or planning barriers).
In the case of medium and micro-scale wind exploitation, potential sites have been defined by the total
number of farmsteads or similar buildings in agricultural areas, and domestic dwellings in urban areas
respectively.
For large scale offshore wind farms, site selection is based on the depth of the sea using a 20m depth
contour. This combines current thinking on offshore wind turbine foundations and the characteristics
of the Maltese environment. The following arrangements are currently suggested for general offshore
project development:
• Gravity Base: 0 – 15m depth
• Monopile: 0 – 25m depth
• Tripod: 0 – 40m depth
A list of offshore windfarms currently operational or soon to come on line is provided in Table B-1
below. While the first two foundation options are proven by these examples, Horns Rev in the North
Sea of the coast in Denmark, at a nominal 13.5m water depth is the deepest commercial offshore wind
farm. Proposed projects using other foundation technologies and at greater depths than this are
currently at the demonstration stage and are unlikely to be suitable for commercial exploitation in the
medium-term. Nevertheless, as the wave and tidal regimes in the Mediterranean are less onerous than
the North Sea, considering water depths up to 20m as exploitable in the medium-term is realistic.
Table B-1 Offshore Windfarm Precedents
Windfarm name Distance Offshore Water Depth

Arklow Bank 10km <10m
Blyth 1km 8.5m
Dronton 6km 5m
Gotland, offshore 4km 6m – 8m
Gunfleet Sands - 0m – 5.5m
Horns Rev 14km to 20km 6m – 14m
Lely 0.8km 5m – 10m
Middlegrunden 2km to 3km 3m – 6m
North Hoyle - 12m
Nysted - 6m – 10m
Tuno Knob 6km 3m – 5m
Uttgrunden 8km 7m – 10m
2
Vindeby 1.5km 2m – 5m
Yettre Stengrund - 9m
This study has followed standard practice by limiting offshore wind farm prospecting to the territorial
limit of the candidate country, normally 20 km (12 miles). This has precluded consideration of the
Hurd Bank. This site is also at a water depth of 35m, however, which is beyond the limit of 20m taken
above as the maximum for economic operation of offshore wind farms.
(ii) Maximum Capacity
Once the unconstrained sites for large wind farm developments (both onshore and offshore) are
identified, maximum potential installed capacity at each site is based on the following assumptions:
• The dimensions of the turbines considered, a 2MW Vestas V80 for onshore sites and 3MW
Vestas V90 for offshore sites
• The shape and area of the unconstrained sites
• Realistic turbine layouts: taking account of typical nominal spacing between turbines
(e.g. 4 Rotor Diameters x 6 Rotor Diameters) and orientation of the turbines (e.g. turbine
“rows” perpendicular to the prevailing wind).
In the case of medium scale wind exploitation, it is assumed that each farmstead on the island installs
one medium size turbine (20 or 60kW) for generating electricity and contributing to their energy
needs. The maximum potential for the development of this option therefore relates to the total number
of rural dwellings around the islands in agricultural areas.
For micro-scale wind, it is also assumed that each domestic building fits one micro-turbine of 1kW
rated capacity on their roof/building. Maximum capacity is therefore dictated by the total number of
domestic buildings in the Maltese islands.
(iii) Maximum Energy Yield
Wind resource information for Malta has been presented in a thesis by R. N. Farrugia (1999). This
information has provided some useful reference points for evaluation of the wind resource at specific
sites around Malta:
• It provides a reference wind speed allowing basic wind speed extrapolation. The reference
wind speed is the long-term wind speed at Luqa airport (VLuqa, 11m = 4.6m/s) adjusted by
adding 0.35m/s to the figure presented in the thesis to account for macro and micro-wind
effects in the vicinity of the airport mast.
• It states that the prevailing wind is from the NW, which is supported by information in a
number of other studies/papers including the Malta significant Wave Height Study prepared
for the Malta Maritime Authority in 2003.
• It is a useful tool aiding the identification of sites with a potentially suitable wind resource.
The reasons why the wind resource map and information presented in the thesis have not been adopted
directly as part of this assessment stem from the following:
3
• The thesis uses WAsP as an extrapolation tool. WAsP cannot model mesoscale wind flow
and it is known to overpredict wind speed on ridges. These are important limitations for
Malta as the wind flow on Malta is complicated by topography and the seasonal winds that
frequent the Mediterranean.
• The site measurements undertaken as part of the thesis and used to support the WAsP
predictions have not been recorded over a sufficiently long period for the purposes of a full
wind resource evaluation.
• The onshore wind resource information currently available for Malta is based on a 10m
anemometer mast located at Luqa Airport, which has an elevation of around 80m.
Experience shows an exposed anemometer mast, with instrumentation sufficiently remote
from turbulent air close to the ground, located in a simple environment in terms of surface
roughness and terrain, can provide an accurate indication of wind speeds within a radius of
say 1500m – 2000m from the mast location. It is considered that the Luqa Airport mast does
not fulfil these requirements sufficiently to provide a realistic level of data particularly with
regard to accurately characterising the wind regime at potential wind farm sites.
The information available does provide a useful starting point for a wind assessment at this spatial
scale. Information manipulated from the Luqa site has allowed an analysis of the wind energy yield
potential at the Luqa Airport and indicates that there is likely to be sufficiently high wind speeds in
Malta for wind generation, reinforcing the conclusions of the Ferrugia thesis. The estimated wind
speeds at different locations are then used to calculate the maximum potential energy yield using an
industry recognised methodology.
The wind speeds estimated in this study at each of the locations for both onshore and offshore
developments compare with the European Wind Atlas estimates of wind speed in the region (Southern
Italy/Sicily) and the MET Office predictions (Wave Height Study, Scott Wilson for Malta Maritime
Authority, December 2003) of offshore wind speed. These comparisons indicate that the figures
presented by Farrugia thesis are too optimistic.
It should be noted that this assessment would not be sufficient to base any commercial decisions
regarding the siting and size of potential wind farms. In order to achieve a more accurate site specific
wind assessment it is recommended that in due course site specific wind monitoring takes place at the
reference heights for a period of twelve months.
The high level analysis completed for this study for onshore wind, entails the following steps:
• The 10m wind speed was adjusted to turbine hub-height by applying a wind shear exponent
of 0.15, which was judged to be appropriate for Malta.
• The shape of the wind speed frequency distribution at a site is very site specific and normally
defined by the Weibull parameters. In the absence of any site, data the Luqa airport data is
used, namely Weibull c = 1.13 and Weibull k = 1.84.
• The wind speed and Weibull parameters are then used to calculate the energy production of
the candidate wind turbine, which is then multiplied by the number of turbines thought
appropriate for the area in question.
• This gives a gross yield figure which is then adjusted to reflect wake losses, availability, grid
losses and so on. This overall conversion figure is estimated at 81%, which is reasonable in
SgurrEnergy’s experience.
4
For offshore wind the wind speed (5.7m/s at 10m height) was adjusted downwards to between 5.1m/s
and 5.3m/s to account for the sheltering effect of Malta and Gozo and then adjusted to turbine hub
height using a wind shear of 0.11.
The analysis required a number of assumptions to be made including:

• Nominal average elevation an estimate of the average ground surface height of wind
turbines located on a site.
• Nominal capacity the number of turbines that can be fitted onto the sites in question taking
into account: the prevailing wind direction, appropriate spacing (4Dx6D) and obvious
constraints such as topography and villages.
• Reference wind speed is the long-term wind speed at Luqa Airport as adjusted (plus
0.35m/s) to account for macro- and micro-wind effects in the vicinity of the airport mast.
• Site wind speed, at 10m, this is calculated using a basic algorithm which accounts for
elevation difference between the airport and potential site only.
• Site wind speed at rotor height calculated by applying a wind shear coefficient of 0.15 to
the site wind speed at 10m.
• Weibull c & k are based on the long term data for the Luqa mast.
• Nominal turbine production is based on the power curves of typical wind turbines and
estimates of the wind speed.
• Gross annual production is the nominal turbine production multiplied by the number of
turbines.
• Net annual production is the gross annual production less all losses, such as wake losses,
electrical distribution losses and so on. This is estimated based on experience.
• Capacity factor is the equivalent on-time at rated output per annum expressed as a
percentage of the number of hours in a year.
• Uncertainty
B.2.2 Large Onshore Wind
(i) Site Selection
Table B-2 indicates the unconstrained sites considered to have potential for large onshore wind farm
development and the maximum capacity that could be installed at each site in the absence of any
barriers. Figure B-1 shows their location in Malta.
Table B-2: Target Areas & Maximum MW
Sites Height above sea MW

level (m)
Gebel Cantar, 210-250 16 This appears to be the highest site on Malta and is
Malta located due south of Rabat. The population density is
low and there are quarries around this location.
Ghemieri, Malta 180-210 44 This region is to the north and northwest of Rabat.
5
Sites Height above sea MW

level (m)
While population density is higher in this area there
may be opportunities to site turbines giving due
consideration to visual impact and noise.
Qasam Ben Gorg, 150 32 This site is located on the south west of Gozo, which is
Gozo considered to be limited in terms of capacity due to the
elevated areas being populated, available land being
too steep and the density of population.
Wardija Ridge, 105-140 40 There are a series of conveniently orientated ridges to
Malta the North West (NW) of the Victoria Lines, which lend
Bajda Ridge, 60-75 36 themselves to positioning wind turbines to face to the
Malta prevailing wind direction. Wardija Ridge is the most
Marfa Ridge, 30-120 22 southerly of these ridges, all of which reduce in height
Malta as we move in a NW direction. These area have
pockets of development which would require
consideration in any siting exercise.
Ta‘ Hammud, 30-55 24 This in an area of low population density to the SE of
Malta Bugibba, which seems reasonably well exposed to the
NW prevailing wind.
Hal Far Airfield 45 16 This site is likely to be too close to the airport.
(Disused), Malta
Total Maximum MW 230
(ii) Maximum Energy Yield
Using the methodology explained in section B.2.1 (iii), the maximum energy yield at each site has
been calculated using both 850kW and 2MW wind turbines. These two size turbines have been chosen
because although the 2MW machines will generate more power, the 850kW turbines may be less
visually intrusive in the Maltese countryside, although this would require more robust evaluation.
Turbine size may be an important factor when considering development options. The results are
summarised in Table B-3 and Table B-4 respectively.
The resulting capacity factors compare with those for developments in the UK, Italy and Germany. In
the UK, higher figures would be sought for commercially viable schemes, but in Germany and Italy,
wind farms with capacity factors at the low end of what is presented would be considered viable.
Therefore, even with the high uncertainty it is recommended that further investigation of the wind
resource be progressed through site specific measurements.
6
Figure B-1: Potential Sites for Onshore and Offshore Wind Exploitation
Source: SgurrEnergy
7
Table B-3: Maximum Onshore Wind Energy Yield (850kW Wind Turbines)
Gebel Qasam Wardija Bajda Marfa Ta' Hal Far

Cantar Ghemieri Ben Gorg Ridge Ridge Ridge Hammud Airfield
Nominal Average
Elevation (m) 231 200 154 123 77 77 46 46
Nominal Capacity (MW) 16 44 32 40 36 22 24 16
Reference Wind Speed (m/s) 4.95 4.95 4.95 4.95 4.95 4.95 4.95 4.95
Site Wind Speed, 10m (m/s) 5.53 5.41 5.23 5.10 4.92 4.92 4.79 4.79
Weibull, c - 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13
Weibull, k - 1.84 1.84 1.84 1.84 1.84 1.84 1.84 1.84
Nominal Turbine
Production (GWh/annum) 2.44 2.34 2.20 2.10 1.95 1.95 1.85 1.85
Gross Annual
Production (GWh/annum) 46 121 83 99 83 51 52 35
Net Annual Production (GWh/annum) 37 98 67 80 67 41 42 27
Capacity Factor (%) 26% 25% 24% 23% 21% 21% 20% 19%
Energy Yield
Uncertainty ±(GWh) 9 24 17 20 17 10 10 7
Capacity Factor
Uncertainty ±(%) 7% 6% 6% 6% 5% 5% 5% 5%
Vestas V52 850kW turbine
8
Table B-4: Maximum Onshore Energy Yield potential (2MW Wind Turbines)
Gebel Qasam Wardija Bajda Marfa Ta' Hal Far

Cantar Ghemieri Ben Gorg Ridge Ridge Ridge Hammud Airfield
Nominal Average
Elevation (m) 231 200 154 123 77 77 46 46
Reference Wind Speed (m/s) 4.95 4.95 4.95 4.95 4.95 4.95 4.95 4.95
Weibull, c - 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13
Weibull, k - 1.84 1.84 1.84 1.84 1.84 1.84 1.84 1.84
Nominal Turbine
Gross Annual
Production (GWh/annum) 50 132 90 108 91 55 57 38
Capacity Factor (%) 29% 28% 26% 25% 24% 24% 22% 21%
Energy Yield
Uncertainty ±(GWh) 10 26 18 22 18 11 11 8
Capacity Factor
Uncertainty ±(%) 7% 7% 6% 6% 6% 6% 5% 5%
Vestas V80 70m Hub Height
9
B.2.3 Medium Scale Wind
(i) Site Selection
Malta has used wind pumps for many years, and there are over 300 wind pumps scattered across the
Maltese islands’ countryside, although only a few of those have been constructed in the last five
years.2 As the principle of operation of medium scale wind energy is already established in the country
there is an opportunity to build on such knowledge by installing medium size wind turbines in
farmsteads around Malta.
The total number of rural farmsteads that may be suitable for medium-scale wind development is
given in Table B-5 per Local Plan area.
Table B-5: Total Number of Rural Buildings
Local Area Number of Buildings (2005)

Central Local Plan Area 50
Gozo & Comino Local Plan Area 105
Great Harbour Local Plan Area 0
Marsaxlokk Bay Local Plan Area 33
North Harbours Local Plan Area 0
North West Local Plan Area 340
Malta South Local Plan Area 84
Total 613
Source: Adapted from The Rural Topic Strategy Paper, MEPA, March 2003.
The figures include the following assumptions:
- 50% of inhabited buildings in the "mixed dwelling" settlements are farmhouses with land that could
accommodate a medium-scale wind turbine
- 100% of inhabited buildings in the "old dwelling" settlements are farmhouses with land that could accommodate
a medium-scale wind turbine
- Of the small proportion of unclassified new dwellings, which were only approved on appeal, an equal
proportion are rural as for the initially approved new developments that comprise the majority of the data.
(ii) Maximum Energy Yield
Two turbine sizes, 20kW and 60kW, have been chosen to explore the potential of medium scale wind
exploitation in Malta. This is because although greater energy will be obtained by using the larger
machines, the smaller units will be less costly, less obtrusive in the flat and open Maltese countryside
and therefore may be more favourable when considering development options.
Table B-6 and Table B-7 show the energy yield from one 20kW and one 60kW turbine respectively
estimated for a typical central location in Malta.
2
Census of Agriculture, National Statistics Office, Malta, 2001.
10
Table B-6: Medium-Scale Wind Production (20kW Turbines)
Site Central Location

Nominal Average Elevation (m) 97
Nominal Capacity (kW) 20
Reference Wind Speed (m/s) 4.95
Site Wind Speed, 10m (m/s) 5.00
Weibull, c - 1.13
Weibull, k - 1.84
Nominal Turbine Production (kWh/annum) 30240
Gross Annual Production (kWh/annum) 30240
Net Annual Production (kWh/annum) 28728
Capacity Factor (%) 16%
Energy Yield Uncertainty ±(kWh) 6048

Capacity Factor Uncertainty ±(%) 3%
Vergnet 20kW 18m Hub Height
Table B-7: Medium-Scale Wind Production (60kW Turbines)
Site Central Location

Nominal Average Elevation (m) 97
Nominal Capacity (kW) 60
Reference Wind Speed (m/s) 4.95
Weibull, c - 1.13
Weibull, k - 1.84
Nominal Turbine Production (kWh/annum) 102060
Gross Annual Production (kWh/annum) 102060
Net Annual Production (kWh/annum) 96957
Capacity Factor (%) 18%
Energy Yield Uncertainty ±(kWh) 20412

Capacity Factor Uncertainty ±(%) 4%
Vergnet 60kW 24m Hub Height
Making the unrestricted assumption that each of the rural buildings installs a turbine (Table B-5) and
combining this information with the nominal capacity and net energy production that may be obtained
from one turbine (Table B-6 and Table B-7) provides the maximum potential that may be achieved
under this option. This is summarised in Table B-8 for the 20kW case and in Table B-9 for the 60kW
turbine.
11
Table B-8: Maximum Medium-Scale Potential - 20kW Case
CMLP GCLP GHLP MBLP NHLP NWLP SMLP Total

Nominal Capacity
(MW) 1.0 2.1 0.0 0.7 0.0 6.8 1.7 12.3
Production
(MWh/annum) 1,438 3,020 0 948 0 9,777 2,417 17,600
Number of
Farmsteads 50 105 0 33 0 340 84 613
Table B-9: Maximum Medium-Scale Potential - 60kW Case

Nominal Capacity
(MW) 3.0 6.3 0.0 2.0 0.0 20.4 5.0 36.8
Production
(MWh/annum) 4,855 10,192 0 3,200 0 32,996 8,158 59,401
Number of
Farmsteads 50 105 0 33 0 340 84 613
B.2.4 Micro-Wind
(i) Site Selection
Table B-10 presents the number of urban buildings in the Maltese islands by Local Plan area.
Table B-10: Individual Domestic Rooftops Available for Micro-turbines
Local Area Number of buildings (2005)

Central Local Plan Area 24,650
Gozo & Comino Local Plan Area 10,502
Great Harbour Local Plan Area 5,789
Marsaxlokk Bay Local Plan Area 2,733
North Harbours Local Plan Area 14,130
North West Local Plan Area 10,007
Malta South Local Plan Area 27,632
Total 95,443
The figures in the table originate from the Census 1995, Planning Authority Datasets. The census classifies
dwelling stock into apartments, maisonettes, houses and ‘others’. The latter includes converted farmhouses,
kerrejja, farmhouses, yachts, cellars and basement flats.
To calculate the number of buildings associated with the dwellings presented in the census data, the following
assumptions have been made:
- Each apartment block built prior 2005 has 10 apartments
- There are two maisonettes per building
- 15% of the ‘others’ category has been assumed to constitute an urban building.
The figures from the census have been updated to 2000 by applying percentages of approved dwellings by type
from 1994-2000 from the State of The Environment Report for Malta, 2002.
The 2000 figures have then be projected to 2005 by using the Medium Scenario for housing requirements by Local
12
Plan area from the Housing Topic Strategy Paper, MEPA, March 2003 and assuming liner growth to 2005.
(ii) Maximum Potential
The problem with assessing the energy that can be obtained at a micro-scale is that wind flows are
extremely complex and very difficult to predict in and around buildings. An adequate estimation can
be obtained from calculating the wind energy yield from micro-turbines operating at 3, 4, 5 and 6 m/s
and then apportioning 25% of the housing stock to each wind speed band to build up the contribution.
A micro-turbine of 1kW has been selected as the basis for this assessment as it is this turbine size that
is most likely to penetrate the domestic market in Europe. The results from such calculation are
presented in Table B-11.
Table B-11: Micro-Wind Potential (1kW wind turbine)
Reference Wind Speed (m/s)

Site 3 4 5 6
Nominal Average Elevation (m) 0 0 0 0
Nominal Capacity (kW) 1 1 1 1
Weibull, c - 1.13 1.13 1.13 1.13
Weibull, k - 1.84 1.84 1.84 1.84
Nominal Turbine Production (kWh/annum) 472.00 1123.00 1989.00 2923.00
Capacity Factor (%) 5% 13% 23% 33%
Average Turbine Production (kWh/annum) 1627

Average Capacity Factor (%) 19%
Figures based on 1kW Bergy wind turbine from the US
Combining the number of urban buildings in Malta (Table B-10) with the average energy production
of one turbine (Table B-11) provides the maximum potential that may be achieved under this option
assuming in an unrestricted case that each of the buildings installs a turbine. This is summarised in
Table B-12 per Local Plan area.
Table B-12: Maximum Micro-Wind Potential

Number of rooftops
available 24,650 10,502 5,789 2,733 14,130 10,007 27,632 95,443
Nominal Capacity
(MW) 24.6 10.5 5.8 2.7 14.1 10.0 27.6 95.4
Production
(MWh/annum) 40,105 17,086 9,418 4,447 22,990 16,282 44,957 155,285
13
B.2.5 Large Offshore Wind
(i) Site Selection
Unrestricted sites have been selected by considering water depths up to 20m. In Malta, water depth
increases rapidly with distance from the shore in such a way that the 20m depth contour is generally
tens or hundreds of metres from the shoreline of the islands, with shelves or spits on which turbines
could be located appearing in a few locations around the islands. The seabed to the west of the islands
(areas best exposed to the prevailing winds) falls to depths exceeding 50m even more rapidly than off
the eastern coast, thus excluding these sites from potential development. The offshore sites are located
off the eastern and north-eastern coasts of Malta and are marked in Figure B-1 and listed below: 3
• Sikka-Il-Bajda
• Hamrija Bank
• Secca Il Munxar
• Marku Shoal
• Madalena Shoals
• St. George Shoals
• Ghallis Rocks
• Il Ponta Tal-Qawra
(ii) Maximum Potential
Table B-13 presents the estimates of energy production from offshore wind farm development at the
sites around the Maltese islands that fit the sea depth requirements.
Of the potential offshore sites around Malta, Sikka-Il-Badja appears to offer the best site but is
estimated to still be marginally suitable for offshore wind exploitation and with none of the locations
identified likely to be more economic than onshore locations outlined above. Sikka-Il-Bajda is a reef
located around 2km from Malta, but even this location cannot be considered to gain the main benefits
of moving a wind farm development offshore, which are:
• Higher long-term annual wind speed
• Lower wind turbulence
• Lower wind shear
• Increased inter-turbine spacing and a corresponding reduction in wake losses and wake loads
33
In Offshore Wind Potential for a Central Mediterranean Archipelago’ by R.N. Farrugia, & E. Scerri, Institute of Energy
Technology, University of Malta, another possible site was identified at Benghisa Patch. This has not been
considered in the present Study as it aligns with the main runway at Luqa Airport
14
• Reduced visual impact

• Increased noise emission allowing higher rotor speeds and therefore smaller rotors.
Sikka-Il-Badja is still too close to the shoreline to benefit for long-term annual wind speed, lower wind
turbulence and wind shear and it is sheltered from the prevailing NW winds. Also, the estimated
capacity factor of 25%, together with the uncertainty in the capacity factor of 6%, gives an upper limit
of 31%. This compares poorly with the 40% capacity factor for proposed North Sea sites.
If Tripod technology became mainstream in the future, this would enable deeper areas around Malta to
be exploited and it would be reasonable to expect the above capacities to double as further areas
become available. However, the wind speed and corresponding capacity factors are not considered to
be high enough to make these options economic and the position of the offshore wind farms are likely
to still be too close to the shoreline. Unless there is significant improvement in foundation design and
large reductions in the cost for offshore wind farms, economic exploitation of offshore wind farms in
water depths up to and beyond 40m around Malta is very unlikely.
15
Table B-13: Maximum Offshore Wind Energy Yield potential (3MW Wind Turbines)
Sikka-Il- Hamrija Secca Il Marku Madalena St. George Ghallis Il Ponta

Bajda Bank Munxar Shoal Shoals Shoals Rocks Tal-Qawra
Nominal Average
Elevation (m) 0 0 0 0 0 0 0 0
Reference Wind Speed,
10m (m/s) 5.70 5.30 5.10 5.30 5.30 5.30 5.30 5.30
Weibull, c - 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13
Weibull, k - 1.84 1.84 1.84 1.84 1.84 1.84 1.84 1.84
Nominal Turbine
Gross Annual Production (GWh/annum) 71 41 44 34 20 20 41 34
Capacity Factor (%) 25% 22% 20% 22% 22% 22% 22% 22%
Energy Yield
Uncertainty ±(GWh) 14 8 9 7 4 4 8 7
Capacity Factor
Uncertainty ±(%) 6% 5% 5% 5% 5% 5% 5% 5%
Vestas V90 80m Hub Height
16
B.3 Constrained Wind Potential
This section considers limits to the exploitable wind resource in Malta, based on the conclusions of
Annex D, E and G, which deal with planning, environmental, legal and network connection
considerations respectively. A constrained maximum exploitable resource, at defined sites where
appropriate, is derived that feeds into the scenarios presented in Volume 1 of the Study.
B.3.1 Large Onshore Wind
The unconstrained onshore wind potential for Malta estimated at 230MW is likely to be constrained
less than 40MW (see Table B-14). The final figure and the number of sites that may be developed in
Malta can only be determined after undertaking project specific Environmental Impact Assessments.
Table B-14: Constrained Wind Potential
MW
Maximum Unconstrained 230
Likely cumulative impact of different constraints:
- Interference with airport 114
- Lack of access 82
- Electricity system stability 40
- Visual impact 15-25
The way the onshore wind resource is likely to be constrained is summarised below.
(i) Electromagnetic Interference
As referred to in Annex D, section D.3.1(iv), electromagnetic interference from large wind turbines
can affect aviation through impacts on radar and flight paths. A full assessment of aviation impacts
would need to be carried out for any large wind development in Malta.
Based on maps provided by MRA, we have undertaken a preliminary analysis of whether any of the
Airport's Obstacle Protection Surfaces would be penetrated by any of the potential windfarms in
Malta. This is known as Physical safeguarding. As indicated in Table B-15, the analysis of Physical
safeguarding indicates that the Hal Far and the Gebel Cantar sites should be ruled out and that the sites
at Ghemieri and Wardija are highly compromised.
The remaining sites would require analysis of Technical safeguarding, or the potential impact of the
windfarms on the navigational instruments at the airport, because the rotating blades can have an
impact on the propagation of electromagnetic waves (with a specific issue in relation to the Radar).
17
Table B-15: Onshore Sites: Airport Interference Analysis
Site Height AOD Height Possible to Use Distance Slope Notes

(ft) AOD (m) (Physical Only) Out
Airport 78 Height is for ARP. According to maps provided, this is also IHSRP.
Inner Horizontal (AOD) 123
Hal Far Airfield 200 60.96 No
Gebel Cantar 750 228.6 No
Ghemieri 700 213.36 Possible to 10000 2% Although possible to south of site on physical grounds, would need
south of site Technical analysis with regard to radar reflections. Believe these will
have an impact.
Warjda Ridge 450 137.16 Possible with 10000 Horizontal There is a penetration of the surface, but if it was deemed the best site, it
Argument might be possible to argue for the penetration, as aircraft height would be
over 300m above turbine. However, might be issues over Technical
interference.
Bajda Ridge 263 80.1624 Possible Turbine would not penetrate surface, but Technical safeguarding might be
an issue, as site is on approach and could affect radar and ILS.
Marfa Ridge (North) 175 53.34 Possible No physical safeguarding issues, but potential requirement for Technical
safeguarding check, as on approach path
Marfa Ridge (South) 424 129.2352 Possible As above
Ta'Hammod 175 53.34 Possible
Qasam Ben Gorg 150 Possible No impact expected as Site is too distant from airport.
AOD Above Ordinance Datum

ARP Aerodrome Reference Point
"IHS" Inner Horizontal Surface
IHSRP Inner Horizontal Surface Reference Point
TOC Take Off Climb
18
(ii) Access
Access constraints are considered serious barriers at Qasam Ben Gorg, located in Gozo. As discussed
in Annex D, this proposed windfarm would extend over a number of sites designated as of
international importance, and require extensive development of temporary roads since the existing
minor roads through small villages would not make it possible for articulated turbine delivery vehicles
to get through.
(iii) Electricity System Stability
The analysis contained in Annex G suggests that the wind capacity that the Maltese system will
withstand is 40 MW. Therefore, the scenarios developed in Volume 1 of this study do not consider
more than 40 MW in total.
(iv) Ecology and Landscape Impacts
The three potential windfarm sites that are less compromised by the discussions above are Ta
Hammond, Marfa ridge and Bajda ridge. The maximum capacity available in each of these sites
though is likely to be reduced by planning constraints stemming from the ecological value and the
landscape sensitivity of some of the area covered by the proposed sites. (This is discussed in Annex D,
section D.3.1(vii)). For example, Bajda ridge is limited by bird sanctuaries to the South and East as
well as designated landscape areas to the East and West, and Marfa ridge is surrounded by various
grades of designated landscape areas.
Ecological value and the sensitivity of the Maltese landscape may be important barriers to large
onshore wind farm development, which will require difficult policy decisions at MEPA about how to
best safeguard the environment.
(v) Visual Impact
Visual impact is also likely to be a very important barrier to onshore wind development in Malta (See
Annex D). Considering the characteristics of the Maltese landscape and the scale of the proposed
developments, it is likely that no more than one or two windfarms will be developed in Malta. Taking
into account other planning restrictions, this could constrain the resource to a maximum of 15-25MW.
B.3.2 Medium Scale Wind
There are not considered to be any major technical, or legal obstacles to prevent installation of
medium scale wind turbines at suitable rural sites, such as inhabited farmhouses. Annex D indicates
that environmental and planning constrains for medium scale wind are likely to be less severe that for
large scale windfarms. There is also a tradition in Malta for windpumps which suggests that the
development of medium scale wind turbines may not encounter major public opposition.
Nevertheless, 100% penetration at the potential sites identified would only be possible with very
strong governmental incentives such as a full governmental subsidy on the capital cost and installation
19
and full local support. The scenarios considered in this study take annual penetration rates based on
other EU countries, as described in Volume 1, section 3.2.1(i).
Outstanding legal issues highlighted in Annex E, section E.5.1, include certification of origin and
ensuring dispatch for distributed generation at a medium and micro scale. These are not, however,
factors that should constitute a barrier if the relevant EU directives are fully implemented.
B.3.3 Micro-Wind
As with medium scale wind, no major technical or legal obstacles exist to prevent micro-wind
installations at domestic and commercial premises. Planning barriers may however be significant for
widespread use of micro-wind, as discussed in Annex D, section D.5.2.
In Europe, the focus of micro-turbine technology has been on attachment to the exterior of man-made
structures such as buildings, bridges, sea walls etc. In Malta however, experience to date regarding
aerials and satellite dishes suggests that the collective visual impact may result in significant planning
restrictions. It is likely that in some areas, especially those of historic and/or cultural importance, that
this would prevent buildings from installing micro-wind.
Planning restrictions taken together with the visual, structural and noise concerns of roof-mounted
turbines mean that micro-wind is not considered the most promising renewable electricity generation
alternative for Malta.
As stated in B.3.2 above, outstanding legal issues for distributed RES generation include certification
of origin and ensuring dispatch, but these should not constitute serious barriers.
B.3.4 Large Offshore Wind
The main constraining factor at the moment analysed in this study for offshore windfarm development
is technical. Based on preliminary wind speed estimates, only one of the potential sites considered in
B.2.5(i) offers sufficient energy for an installation to be cost effective. This site, Sikka-Il-Badja,
would also be considered marginal compared with other offshore windfarm sites currently under
development in Europe.
Other planning issues relating to for example, navigational interference would need to be studied in
detail as part of a project specific EIA
20
Annex C Solar Resource Characterisation Mott MacDonald
Annex C
Solar Photovoltaic Resource
Characterisation

Isabel Philip
i
F:\PROJECTS\206106 Malta\Phase 1 deliverables\Phase 1 report\Final Report\Final Report Annex C - PV Resource.doc
List of Contents
Annex C Solar Photovoltaic Resource Characterisation 1

C.1 Introduction 1
C.2 Maximum Available Unconstrained PV 1
C.2.1 Methodology 1
C.2.2 Results 2
(i) The Building Stock 2
(ii) Maximum Capacity 8
(iii) Maximum Energy Yield 9
C.3 Constraining the PV Resource 10
Tables
Table C-1: Malta Dwelling Stock by Type and Area 1995..................................................................... 2
Table C-2: Domestic Approvals to 2000................................................................................................. 3
Table C-3: Percentage of Approved Dwellings by Type ........................................................................ 3
Table C-4: Additional Housing Requirements in 2020 ........................................................................... 3
Table C-5: Estimated Housing Stock in 2005 ......................................................................................... 4
Table C-6: Estimated Additional Housing Stock per year to 2020 ......................................................... 4
Table C-7: Estimated Available Domestic Rooftop Area (m2) ............................................................... 5
Table C-8: Estimated Developed Industrial Area in Malta 2005 and per year increase to 2020 (m2) .... 5
Table C-9: Estimated Warehouse Floor-space in Malta 2005 and per year increase to 2020 (m2)......... 6
Table C-10: Estimated Retail Floor-space in Malta 2005 and per year increase to 2020 (m2) ............... 6
Table C-11: Maximum PV Potential in Malta (unconstrained) .............................................................. 9
Table C-12: Maximum PV Electrical Potential in Malta (unconstrained) ............................................ 10
ii
Annex C Solar Photovoltaic Resource Characterisation
C.1 Introduction
This annex characterises the solar photovoltaic (PV) resource available for electricity generation in
Malta and considers the maximum potential levels of resource exploitation. As with wind this has
been achieved through two major steps:
• The maximum available PV potential is calculated based on unconstrained availability of the
resource combined with unconstrained sites on the islands, for example, PV modules per
square-metre and square-metres of rooftops available for PV generation assuming a 100%
uptake. In this manner, each rooftop would have the maximum possible PV installed.
• The unconstrained maximum potential was then reduced to account for technical,
environmental, planning and legislative barriers that may be present in Malta.
The results of this analysis include a series of scenarios for PV exploitation that consider the relative
influences of the constraints and the effects of removing or reducing them in Malta. These were then
used to estimate potential levels of indicative targets for PV in Malta whilst providing an indication of
the costs of doing so (see Volume 1 main report).
C.2 Maximum Available Unconstrained PV
C.2.1 Methodology
During the site visit it became apparent that land is of a premium in Malta and with many competing
demands for land this can make land expensive and difficult to acquire. Due to the extensive land
required for the exploitation of PV on commercial scales, i.e. PV farms, it was considered that these
do not offer practical opportunities on Malta. Attention has therefore been focused on building and/or
roof mounted PV.
The methodology used for calculating maximum potential unconstrained resource comprised the
following steps:
• First, a calculation of unconstrained suitable sites in terms of number of rooftops/building
stock was made. This was then converted to available metre-squared space for PV modules.
In calculating this figure a number of assumptions have been made which are set out in the
applicable results sections.
• Second, the maximum capacity in terms MW peak (MWp) of solar panels installed was
calculated. This assumed that each building installs PV modules and is based on a calculated
potential of PV per square-metre (explained in more detail below).
• Finally, a calculation of potential maximum energy yield per year (in GWh/year) has been
made based on a published estimation methodology.
1
C.2.2 Results
(i) The Building Stock
A total figure for the number of buildings in Malta was not readily available in the format required for
this study. An estimation has, therefore, been made relying on data from a number of sources and
some broad assumptions suitable for the purposes of this assessment. The available statistical material
for both Malta and other countries makes cross-comparison of PV available building stock and
building density almost impossible to complete. We have therefore solely relied on Maltese statistics.
The total estimate for building stock numbers were built up using a bottom-up analysis starting with
the determination of the broad categories of building types. The following broad list was drawn up:
• Domestic – apartments, houses, maisonettes, farmhouses etc.
• Industrial – warehouses, factories, workshops etc.
• Commercial – shops, car showrooms, offices, hotels, passenger terminals etc.
• Other – schools, hospitals and other health care facilities, police stations etc.
The basis of the building stock inventory was to estimate the current building stock (i.e. for 2005) by
type and where possible by Local Plan area. Where statistical data by Local Plan area was not
possible to identify the total figure for Malta was estimated. Estimation of growth in the number of
dwellings by type to 2020 then occurred. Where projections of growth were available these have been
used in the assessment (adopting the middle scenario), where they were not available then
conservative assumptions have been made in a consistent manner, these are noted in the relevant
section. Finally assumptions were made of the numbers of dwellings per building in order to estimate
the amount of available roof-space.
Domestic Building Stock
The Malta Census, completed in 1995, provided the starting point for the building stock calculations.
This data outlined the dwelling stock by type and for each Local Plan area for 1995 (Table C-1)
Table C-1: Malta Dwelling Stock by Type and Area 1995
Local Plan
Apartment House Maisonette Others* Total
Location code
Central CMLP 7,551 17,468 6,155 5,108 36,282
Gozo and
GCLP 1,089 7,830 152 6,377 15,448
Comino
Grand
GHLP 5,151 4,025 1,400 2,741 13,317
Harbour
Marsaxlokk
MBLP 1,002 1,751 407 1,529 4,689
Bay
North
NHLP 9,083 9,052 2,529 5,903 26,567
Harbours
North West NWLP 3,015 5,680 918 9,740 19,353
Malta South SMLP 7,662 19,939 5,034 6,911 39,546
Total 34,553 65,745 16,595 38,309 155,202
* converted farmhouses, kerrejja, farmhouses, yachts, cellars, basement flats
Source: Census 1995, Planning Authority Datasets available at http://www.mepa.org.mt
2
The State of the Environment Report for Malta (2002) provides a summary of the number of approvals
between 1995 and 2000 by Local Plan area. This document also outlines an approximate breakdown
of the approvals by domestic building type (Table C-2 and Table C-3 respectively).
Table C-2: Domestic Approvals to 2000
Local Plan 1995 1996 1997 1998 1999 2000 Total

code
CMLP 717 850 652 629 407 475 4,022
GCLP 560 516 529 428 185 357 2,776
GHLP 42 14 68 25 24 15 234
MBLP 137 91 91 117 72 160 718
NHLP 516 361 466 298 802 391 3,417
NWLP 942 501 516 483 327 386 3,379
SMLP 1,159 922 1,084 904 424 563 5,822
Total 4,073 3,255 3,406 2,884 2,241 2,347 20,368
Source: State of the Environment Report Malta 2002, Table 3.73
Table C-3: Percentage of Approved Dwellings by Type
Terraced
Year Apartments Maisonettes Villas Totals
Houses
1995 46% 25% 27% 2% 100%
1996 48% 35% 15% 2% 100%
1997 47% 33% 17% 3% 100%
1998 58% 26% 14% 2% 100%
1999 65% 21% 13% 1% 100%
2000 62% 25% 12% 1% 100%
Source: Adapted from State of the Environment Report Malta 2002, Table 3.72
Combining the above data allowed an estimation of the total dwellings in the year 2000 to be made.
As there was no statistical data available to provide an estimate of the housing stock in 2005
projections of additional houses were required. The Housing Topic Paper (2003) provided a series of
scenarios (low, medium and high) of the housing requirement between 2000 and 2020 (Table C-4).
Table C-4: Additional Housing Requirements in 2020
Category Low Medium High

Projected household growth 32,000 32,000 32,000
Second homes 4,000 6,000 8,000
Scrap 500 500 500
Allowance for non take up (7%) 2,550 2,700 2,850
Housing requirements 39,050 41,200 43,350
Source: Housing Topic Paper 2003 page 99.
The Housing Topic Paper also provided a breakdown of the scenarios by Local Plan area and housing
type. Assuming the medium growth scenario occurred in a linear profile over the period 2000 to 2020
and calculating the split of housing type for these projections it was possible to derive an estimate of
3
the housing stock in 2005 along with an estimated growth per year through to 2020 (Table C-5 and
Table C-6 respectively).
Table C-5: Estimated Housing Stock in 2005
Type of
residence CMLP GCLP GHLP MBLP NHLP NWLP SMLP Total
Apartment 11,277 3,232 5,353 1,664 12,066 5,966 12,375 51,934
House 18,445 8,466 4,085 1,921 9,861 6,520 21,338 70,636
Maisonette 7,958 1,225 1,497 715 3,882 2,340 7,350 24,967
Others* 5,108 6,377 2,741 1,529 5,903 9,740 6,911 38,309
Total 42,788 19,299 13,676 5,829 31,713 24,567 47,974 185,845
Table C-6: Estimated Additional Housing Stock per year to 2020
Type of
residence CMLP GCLP GHLP MBLP NHLP NWLP SMLP Total
Apartment 322 139 16 55 224 238 338 1,331
House 39 17 2 7 27 29 41 162
Maisonette 136 59 7 23 94 100 142 561
Others* 0 0 0 0 0 0 0 0
Total 497 215 25 84 346 367 521 2,055
The final step at this stage was to calculate the approximate rooftop area that may be suitable for PV.
Due to variations in architecture of buildings such as the direction and slope of the roof, materials,
style of building, shading etc., the potential surface areas for different building types can vary
significantly. In Malta, however, many of the building have flat or near-flat rooftops and are built in a
similar style. The second consideration which indirectly relates to the available rooftop space is that
some roofs have duel purposes. For example, some rooftops are verandas or they are used for laundry.
This may restrict the available rooftop to, for example, the washroom roof. The final restriction that is
placed on PV on domestic roofs in Malta is that the total quantity of PV that can be installed on any
domestic roof is limited to the size of a buildings electricity supply. This is established in Enemalta’s
Draft Grid Code to 3 kWp limit on the PV installed per building that in turn can be translated to a
rooftop area equivalent to approximately 25.4 m2 (this is explained further in the maximum capacity
section below).
Bringing all this together and making the following assumptions regarding the numbers of dwellings
per building an estimate of the available roof-space in 2005 and the growth in rooftops per year to
2020 was possible (Table C-7):
• existing apartment blocks have 10 dwellings per building
• new apartment blocks have 3 dwellings per building
• maisonettes consist of two dwellings per building
• houses and semi-detached houses are single dwellings per building
• 15% of the ‘others’ category have usable rooftops for PV.
4
Table C-7: Estimated Available Domestic Rooftop Area (m2)
Type of residence CMLP GCLP GHLP MBLP NHLP NWLP SMLP Total
Apartment 38,114 12,316 14,053 5,835 37,219 22,158 41,366 171,060
House 467,676 214,650 103,571 48,705 250,021 165,315 541,030 1,790,968
Maisonette 100,882 15,525 18,983 9,063 49,219 29,670 93,175 316,516
Others* 19,427 24,253 10,425 5,815 22,451 37,044 26,284 145,699
Total 626,099 266,744 147,032 69,417 358,909 254,188 701,854 2,424,243
Additional per year 5,435 2,353 274 923 3,782 4,014 5,702 22,483
Industrial Rooftops
The State of the Environment Report for Malta 2002 provided an estimate of the total square-metres
area of industrial land and warehousing in Malta for the year 2000. The industrial land is subdivided
into three sections:
• privately owned
• Malta Development Corporation owned
• Illegal developments.
For the purposes of this assessment the illegal category was excluded as in addition to potential
ownership disputes there is the possibility that such areas would either change or be demolished in the
future.
Taking industrial areas first the State of Environment Report provided a breakdown of all the
industrial areas into total area and area remaining undeveloped hence allowing an estimation to be
made of the developed area. These figures were then allocated to a Local Plan area. In order to
project to the 2005 baseline and to provide an indication of growth through to 2020 it was assumed
that the remaining undeveloped land in each of these areas would be developed by 2020 in a linear
fashion. Pulling this together, an estimate was made of the total developed industrial area in Malta
(Table C-8).
Table C-8: Estimated Developed Industrial Area in Malta 2005 and per year increase to
2020 (m2)
Type CMLP GCLP GHLP MBLP NHLP NWLP SMLP Total

Government 211,075 116,275 818,375 907,200 235,575 0 553,450 2,841,950
Private 271,630 9,816 19,559 0 1,238 0 64,403 366,645
Total 482,705 126,091 837,934 907,200 236,813 0 617,853 3,208,595
Per year increase
1,215 1,235 11,955 32,260 1,955 0 17,630 66,250
Government
Per year increase
9,466 1,232 1,545 0 248 0 2,592 15,082
Private
Source: Calculated using data from the State of the Environment Report for Malta, 2002 page 111.
Warehousing information was also provided in the State of the Environment Report with information
providing warehouse space, by Local Plan area, from 1994 through to 2000. The assumption that this
5
was set to double to 2020 (as estimated in the State of Environment Report, page 125) in a linear
fashion was then made in order to estimate the total space in square-metres for 2005 and the per
annum growth to 2020. The growth of warehousing was assumed to follow the same proportional
distribution by Local Plan area as occurred during the period 1994 to 2000. The results can be found
in Table C-9.
Table C-9: Estimated Warehouse Floor-space in Malta 2005 and per year increase to
2020 (m2)

Total 2005 116,585 22,637 35,906 40,211 12,855 20,592 64,590 313,375
Per year increase 4,629 899 1,426 1,596 510 818 2,564 12,442
The assumption that the developed industrial land and the warehouse floor-space translate directly into
available rooftops was made.
Commercial
The commercial sector in Malta has grown considerably over the past 10 years according to the State
of the Environment Report. Due to the availability of the data this section has been split into the
following categories:
• retail
• motor showrooms
• offices
• hotels and guesthouses
• passenger terminals.
The retail sector information has been derived using data contained in the State of the Environment
Report which estimated the floor-space by Local Plan area in 2001. It was considered that the rapid
growth over the last 10 years was unsustainable and therefore it was assumed that the retail space
would double to 2020 in a linear fashion, as was the case with warehouses. This data has been used to
estimate the 2005 levels and an annual growth, in terms of square-metre floor-space, to 2020 (Table
C-10).
Table C-10: Estimated Retail Floor-space in Malta 2005 and per year increase to 2020
(m2)

Total 2005 94,607 24,296 32,983 4,605 72,328 31,002 71,716 331,538
Per year increase 4,113 1,056 1,434 200 3,145 1348 3,118 14,415
The State of the Environment Report estimated the floor-space of motor showrooms in 2001 to be
approximately 176,000 m2. It was not thought that this would grow significantly to 2020.
6
As with the retail floor-space the figures for offices show rapid growth over the past 7 years. Figures
estimating the levels in 2000 were available in the State of Environment Report which were assumed
to double by 2020 showing a linear growth per annum. The results estimated a total floor-space of
approximately 223,500 m2 of offices in 2005 with a per annum growth of around 9,000 m2.
Data for hotels and guest houses were not easy to derive. The State of Environment Report split the
hotels and guest house information. For hotels the estimated number of beds in 2000 was in the region
of 50,000 in 136 hotels providing an average of approximately 370 beds per hotel. Assuming that
each bed had on average a 25 m2 floor-space associated with it (i.e. room and bathroom etc.) and an
average of four floors per hotel an estimate of total hotel rooftop area for 2000 in the region of
312,500 m2 was possible.
The same report estimated that there were 115 guesthouses in 2000. Based on the assumption that
these were domestic type dwellings converted to bed and breakfasts, cottages, villas etc. and the
assumption outlined earlier that restricts the usable roof-space to 25.4 m2 an estimate of approximately
3,000 m2 of rooftop for guesthouses in 2000 was made.
Assuming, as has been the case with other factors, this was to double in a linear fashion to 2020 the
annual growth would be in the region of 15,600 m2 and 150 m2 for hotels and guesthouses
respectively. The estimates of rooftop space for hotels and guesthouses in 2005 therefore totalled
approximately 395,000 m2.
There are a few passenger terminals on the Maltese Archipelago these were not considered likely to
grow significantly so the figures estimated for 2000 were assumed to remain until 2020. The State of
the Environment Report estimated these to be about 100,000 m2.
As is the case with the industrial facilities it has been assumed that the above areas equate to available
rooftop space for PV.
Others
There were a number of other key building types that did not readily fit within the above categories
but for which some estimates of rooftop space were possible to derive. These included:
• educational facilities – schools and libraries
• police stations
• recreational facilities – sports complexes, gyms etc.
• health and care – including hospitals and clinics but excluding dispensaries as these were
considered to be included in the retail estimates.
An estimate of the rooftop areas for churches was also possible, however, due to the religious,
historical and cultural value of these buildings the figures have been excluded from any calculations.
The State of Environment Report estimated that there were approximately 600 schools and libraries
across the Islands. The roof-space estimate for 2000 was not considered likely to grow to 2020 as it
was thought that any new properties were more likely to replace existing ones than be additional.
Making the assumption that these buildings had on average a roof-top of 200 m2 an estimate of
approximately 112,000 m2 of roof-space was made.
7
In 2000 there were 72 police stations across the islands (State of Environment Report, 2002). While it
is acknowledged that some of these may be part of other buildings they were assumed, for the
purposes of this calculation, to each have their own rooftop of 200 m2 and not to grow in total numbers
beyond the current levels. This provided an estimate of about 1,800 m2 of rooftop space.
There are a number of areas of recreational facilities throughout Malta, Comino and Gozo. The State
of Environment Report estimated the area covered by these in 2000 to be in excess of 550,000 m2.
This figure is made up of indoor and outdoor facilities with no indication of the approximate
proportions of each. It was assumed, therefore, that 25% of this area was built up and that there would
be no growth in this roof area to 2020. The approximate roof-space for recreational facilities was
estimated to be about 86,000 m2.
There are about 30 health and care facilities (including hospitals) in Malta and Gozo and by making
the following assumptions a estimate of roof-space was possible:
• Hospitals – restricted by the size of their electrical connections to 760 m2 potential
roof-space for PV which equates to about 90 kWp of PV installed.
• Clinics and health centres – assumed to be the same electrical connections as a domestic
building and therefore restricted to 25.4 m2 per building (equivalent to 3 kWp of PV
installed).
This allowed a total estimate of approximately 9000 m2 roof-space to be made for health and care
facilities. This figure includes the new hospital and as such is not considered to dramatically change
in over the coming years.
As before, it was assumed that all the rooftop areas were available for PV development.
In summary, the estimated rooftop space available in Malta in 2005 totalled approximately
7.4 million m2 with a maximum possible roof-space by 2020 being in the region of 9.7 million m2.
(ii) Maximum Capacity
The next step in calculating the maximum capacity available for PV was to translate the calculated
rooftop space into an amount of PV installed. This assumed that every available piece of roof was
equipped with PV panels. This is of course highly unlikely and in reality PV will penetrate at a much
slower and gradual rate. In the next phase of the resource calculation this large total figure is
constrained to more realistic levels for the purposes of modelling and exploring the potential support
mechanisms. (see section C.3)
The maximum capacity for PV was calculated by estimating the peak PV electrical potential per
meter-square on average in Malta. This is simply achieved based on the following equation.
(B * C)
A=
1000
Where: A = the kWp PV installed per square-metre
B = the maximum clear sky irradiation (W/m2)
C = the conversion efficiency for a PV module
8
Making the assumptions that about 980 W/m2 irradiation occurs in Malta (European Commission Joint
Research Centre http://sunbird.jrc.it) and that the conversion efficiency is 12% the estimated kWp per
m2 is about 0.118 kWp/m2.
Combining this with the estimate of maximum roof-space provided an estimate of the PV potential in
terms of kWp installed (Table C-11). It is once again noted that these figures are very large and this
level of penetration is not anticipated.
Table C-11: Maximum PV Potential in Malta (unconstrained)
Year Total m2 rooftop PV Potential kWp PV Potential MWp

2005 7,382,113 871,680 872
2010 8,159,239 963,443 963
2015 8,936,365 1,055,206 1,055
2020 9,713,491 1,146,969 1,147
As noted the above figures are not the levels currently in place nor the levels anticipated they are
included as part of the calculation process as the ‘big’ figure that can then be manipulated and
constrained to develop more realistic scenarios. However, before completing the constrained numbers
these figures were converted to estimate the maximum energy yield from such levels of installation.
(iii) Maximum Energy Yield
The maximum energy yield is calculated to demonstrate the calculation method used and the levels
that could be expected from very large levels of PV penetration.
The calculation method is a simple approximation method as developed by the European Commission
Joint Research Centre. The calculation method is intended for preliminary design by providing order
of magnitude estimates of a PV systems production. This makes this calculation suitable for the type
of assessment being performed for Malta. The essential input into this calculation is the annual mean
of daily sums of global irradiation available to solar panels. With the aim to maximise the annual
electricity production the optimum panel slope angle at south orientation is determined from the
maximum annual global solar irradiation computed at 0, 15, 25 and 40 degrees inclination. The
optimum angle and the annual mean of daily sums of global irradiation for Malta were obtained
through the European Commission Joint Research Centre database (accessed online at
http://sunbird.jrc.it).
The annual total electricity output from the PV installed in kWh was calculated based on the following
standard approximation:
E = 365 * Pk *η p * Gi ,h
Where: E = is the annual total electrical output from the PV installed in kWh
Pk = is the peak power installed over the relevant area in kWp
ηp = is the system efficiency typically 0.75
Gi,h = is the annual mean of daily global irradiation on the inclined solar panel facing south in
kWh/m2/day.
Taking the peak kilowatts of PV installed from the calculations in the previous step, the assumed
system efficiency of 0.75 and the annual mean of daily global irradiation, on an inclined south facing
9
solar panel, of 5.491 kWh/m2/day (optimised at an angle of 32 degrees) an estimate of electrical

energy per year can be made (Table C-12).
One peculiarity of the above formula is that peak power, measured in ‘kWp’, is an index of
performance for a given area of PV panel, measured under standard test conditions of 1000W/m2
irradiance and 25oC temperature. The units of the index are therefore m2 rather than kW, a fact that
allows the units of the power output approximation equation above to balance.
Table C-12: Maximum PV Electrical Potential in Malta (unconstrained)
Year kWh/year GWh/year

2005 1,310,275,397 1,310
2010 1,448,210,042 1,448
2015 1,586,144,686 1,586
2020 1,724,079,331 1,724
Obviously this is extremely high with the Delimara and Marsa power stations predicted to produce
2420 GWh/year in 2005. It should be noted again that these figures are for indicative and calculation
purposes only and in reality due to the many likely constraints and barriers to installation the real
figures will be significantly lower than this.
C.3 Constraining the PV Resource
This section considers more realistic limits to the exploitable PV resource in Malta, based on the
findings of Annex D, which deals with planning and environmental considerations, and on precedent
penetration levels in the EU. This gives a constrained maximum exploitable resource, feeding into the
scenarios presented in Volume 1.
Annex D describes the main limitations associated with solar PV resource exploitation as:
• high capital costs
• visual impacts on the urban landscape and of reflective glare, particularly in areas protected
by cultural and historical designations
• changing shadow patterns with upward extension of existing building stock
• shared ownership of rooftop space, limited land available apart from building roofs, wall and
windows
Of these potential barriers, high capital cost is the factor considered most likely to limit market
penetration of distributed solar PV generation in Malta. Even with very high subsidies of up to 70%
of capital costs, PV penetration rates in the EU do not translate to more than 80 installations per year
when scaled by head of population to Malta (see Volume 1, section 3.2.1(ii)). Over the total
timeframe considered by this study, from 2008 to 2020, this annual rate of penetration would result in
0.25% of total market penetration, otherwise expressed as 0.13% of projected electricity demand in
2020.
10
In an unconstrained scenario (Scenario A in Volume 1 of this study), the cost-optimiser model used in
calculating possible renewable targets does not select PV as a viable option due to its high costs in
comparison with the other renewable technologies considered. Volume 1 of this study explores other
scenarios where penetration rates of either 40 or 80 installations are assumed. This level of
penetration is commensurate with rates in other European countries and it is also significantly lower
than expected growth in the housing stock, so that all new systems could easily be buildings-
integrated, benefiting from the cost advantages this approach brings.
11
Annex D Environmental and Planning Barriers Mott MacDonald
Annex D
Environmental and Planning
Barriers

Isabel Philip
i
F:\PROJECTS\206106 Malta\Phase 1 deliverables\Phase 1 report\Final Report\Final Report Annex D - Env & planning.doc
List of Contents
Annex D Environmental and Planning Barriers 1

D.1 Introduction 1
D.2 Planning Framework 1
D.2.1 Overview 1
D.2.2 Designated Areas 3
(i) Rural Conservation Areas 3
(ii) Management of Protected Areas 6
D.3 Planning and Barriers 7
D.3.1 Large Scale Onshore Wind 7
(i) Overview 7
(ii) Agriculture 8
(iii) Ecology 8
(iv) Electromagnetic Interference 10
(v) Historic and Cultural Effects 11
(vi) Tourism and Recreation 11
(vii) Landscape Impacts 11
(viii) Visual Impacts 15
(ix) Shadow Flicker and Flashing 16
(x) Noise 17
(xi) Health and Safety 17
(xii) Cumulative Effects 17
(xiii) Construction and Maintenance Disturbance 18
(xiv) Decommissioning 19
D.3.2 Potential Planning Implications 19
D.4 Medium Scale Wind 25
D.5 Micro-Wind 25
D.5.1 Main Environmental Impacts 26
(i) Visual and Townscape Impacts 26
(ii) Electromagnetic Interference 26
(iii) Noise and vibration 26
D.6 Offshore Wind 27
D.6.1 Environmental Impacts 27
(i) Coastal and Offshore Processes 27
(ii) Biological Environment 28
(iii) Airborne Noise 29
(ii) Underwater Vibration and Noise 29
(iii) Cultural Heritage 29
(iv) Seascape and Visual 30
(i) Other Potential Impacts 30
D.1.2 Offshore Approval Mechanisms 30
D.2 Photovoltaic 31
D.2.1 Introduction 31
D.2.2 Potential Environmental Impacts 31
(i) Manufacturing Impacts 32
(ii) Visual Impact and Glare 32
ii
(iii) Cultural Heritage 32

(i) Location and Design 32
(ii) PV Systems and Building Roofs 34
(iii) PV Systems and Building Walls and Windows 34
(iv) PV Systems and Buildings of Historic Value 35
(v) Potential Changes in MEPA’s Planning Conditions 35
D.1 Planning Barriers Removal 36
D.1.1 UK Developments 36
D.1.2 Potential Recommendations for Malta 38
iii
Annex D Environmental and Planning Barriers
D.1 Introduction
This Annex provides a high level analysis of how the current town planning framework in Malta is
likely to deal with the exploitation of renewable electricity. It is largely through the planning process
that the specific nature and shape of renewable electricity deployment and penetration will be dictated.
It is at the planning level where specific local development guidelines will be implemented, it is also
through the planning system where the local population and other interested stakeholders will be able
to influence development decisions. The analysis includes consideration of the main environmental
impacts associated with the proposed development options identified in Annex B (wind) and Annex C
(PV). This analysis also highlights environmental and planning issues that have the potential to
restrict or halt development and offers recommendations for reducing such potential issues. Specific
understanding of these potential barriers and expert judgement relating to the effectiveness of
measures to reduce barriers have been used to inform the process of modelling and the likely
constraints to the exploitation of renewables that the planning policy pose.
It should be noted that any discussion of environmental issues is only included to highlight potential
areas that, based on experience, may cause problems during the planning consent procedure. At no
point does this analysis negate the need to complete a project specific environmental impact
assessment should one be required.
This Annex first considers the current planning framework including the land designations, as this sets
the context of the current planning system in Malta and potential major development constraints.
Next, on a technology basis some of the main environmental elements and potential problems are
explored in relation to planning objections/barriers. Finally, selected recommendations for reducing or
removing barriers in the planning system are considered.
D.2 Planning Framework
D.2.1 Overview
In 1992 Malta adopted new planning legislation and established a planning authority with national
jurisdiction. Recently the planning authority was declared the competent authority to implement the
Environment Protection Act, thus bringing together land use planning and environmental protection
within an enlarged and renamed Malta Environment and Planning Authority (MEPA).
In a short time span of just under 10 years, land use planning has been transformed, with a zoning
system without legislation replaced by a comprehensive system, strong planning legislation, a
planning authority, and strategic guidance provided by the structure plan (approved in 1992). Perhaps
the most fundamental departures from the past are in the transparency, openness and accountability of
the plan preparation and decision making processes1; the comprehensive, holistic and integrated
1
RTPI, 24 January 2003, “Letter from Malta: A new and comprehensive Planning System”, Planning, Issue 1503, RTPI,
London, UK
1
approach to dealing with the extensive range of responsibilities; and the growth of a culture for
planning within and outside government and of public awareness.
The planning system in Malta has similarities with that of the UK. The Planning Authorities gain
primary powers through legislative acts supported by legal and government notices. The primary
guidance in relation to planning activities is the Structure Plan. With the constraints on land and the
density of the population the Structure Plan is a very significant item of planning that forms the basis
of future land use and development decisions. It should be noted that the Structure Plan in Malta is
undergoing review with elements currently progressing through the consultation processes. It is
through the Structure Plan guidance and supporting planning policies that planning can affect quality
of life in rural, urban and coastal zones of the Maltese Islands and therefore affect the exploitation of
renewable electricity.
To assist the Planning Authorities in successfully securing the implementation of the Structure Plan a
series of more detailed plans covering particular areas or sectors of activities have been established.
These plans comprise the following:
• Local Plans – prescribe for particular areas the development intentions in greater detail than
the Structure Plan. Local Plans also anticipate that substantial development is likely to be
initiated by the private sector. These are site specific plans.
• Action Plans – are similar in character to Local Plans but deal with smaller areas. These are
appropriate where the public sector intends to positively intervene in the development
process by, for example, developing or redeveloping land within the Action Plan area.
• Subject Plans – deal with specific issues relevant to the strategy as set out by the Strategic
Plan and may relate to the whole of the territory as might be the case in respect of
environmental protection, or to a particular activity such as quarrying.
• Planning Briefs – set out all the planning requirements, limitations, opportunities, and targets
which must be met in preparing a plan for the area. They may also be used as an interim or
preliminary document prior to the preparation of a Local Plan or alternatively as guidance to
the developer.
• Development Briefs – are somewhat similar in nature to Planning Briefs but relate to single
sites and should prescribe all matters affecting the form, content and design of the
development. They need not be confined to planning requirements.
Participation in the process of plan production and review has been crucial in gaining wide acceptance,
for the new planning system and in facilitating implementation of MEPA activities. To enable this to
happen “a range of mechanisms have been used to involve the public, Government departments, local
councils, environmental and other interest groups, in plan preparation and in the development control
process”1. As part of the development of this new planning regime “particular emphasis has been
placed on securing 'ownership' of strategic policy documents by Government departments, through a
liaison committee and through the Office of the Prime Minister. The ultimate aim, through a long-
term "education" process, is to create a positive image of planning. Success is evident in the extent of
participation in the local planning process, from representations on applications and the growth of
planning consultancies in the private sector”2.
However, despite this comprehensive plan preparation and associated decision making process limited
policy development has been undertaken with regard to renewable energy schemes and wind energy in
particular. Increasing interest from the Maltese private sector to implement such schemes has
identified a need for strategic policy direction including the associated potential need for training of
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government officials to assist in the decision making process. Experience of consultation and
education creating ownership in the revised planning process will be invaluable tools in gaining public
support and acceptance or whatever renewable electricity policy is developed.
D.2.2 Designated Areas
One of the most likely major constraints to the exploitation of renewable electricity sources relates to
the general shortage of land in Malta and the objective of protecting sites of interest and preserving the
traditional ‘Maltese’ landscape. As part of the developments of the planning system MEPA have been
very active in the areas of urban and rural conservation/management particularly through the
establishment of designations and scheduling of sites/areas/buildings of interest.
There are a number of areas of planning control designed to protect, conserve and enhance Malta’s
natural and built environment. This sub-section outlines the basis of some of these designation as they
have the potential to restrict the renewable electricity development potential in some areas.
(i) Rural Conservation Areas
The Structure Plan prohibits urban development outside of the development zone through designating
most of the countryside as a Rural Conservation Area (RCA). Areas within RCAs may be protected
according to the following categories (the key designations are discussed in more detail over the
following sections):
• AAV – Areas of Agricultural Value – areas of high grade agricultural land including
irrigated and partly irrigated land.
• AEI – Areas of Ecological Importance – relatively large areas designated to protect typical
and rare habitats.
• SSI – Sites of Scientific Importance – sites containing individual species, groups of species
and geological features.
• SAC – Special Area of Conservation under Natura2000 (EU Habitats Directive) and of
international importance
• AAI – Areas of Archaeological Importance – concentrations of valuable archaeological sites.
• SAI – Sites of Archaeological Importance – individual and/or isolated archaeological sites.
• NP – National Parks – relatively large areas of national significance not materially altered by
human use, with managed visitor access and amenities.
There are differing levels of existing development in rural areas which means that there are differing
levels of conservation value within RCAs. RCAs are protected through national legislation covering
both conservation and environmental protection elements.
Protected Natural Areas
Protected Natural Areas are designated as Scheduled Properties under the Development Planning Act
(DPA) of 1992 (as amended in 2001) and Nature Reserves under the Environment Protection Act
(EPA) of 2001.
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There are 52 sites designated as “Nature Reserves” under the Environmental Protection Act (EPA)
although only 3 are protected as strict nature reserves. Another 20 sites are Bird Reserves where
shooting and trapping is prohibited; the remaining 29 sites are designated as Tree Reserves. The State
of the Environment Report notes that most nature reserves are “protected not for the habitats and biota
they support, but to protect public and private property and to reduce nuisances”. This implies that in
some cases it may be the activities that occur on a site that drive the designation although this should
be discussed with MEPA for specific sites.
The Rural Issues Paper notes that MEPA is reviewing the areas designated so as to protect them in
accordance to their conservation values. This review has been stimulated due to the Habitats Directive
with protected natural areas being designated as Special Areas of Conservation (SACs), according to
IUCN Area Management Categories.
Scheduled Natural Areas are, according to the Structure Plan definition, natural habitats can be
classified as Areas of Ecological Importance (AEIs) and Sites of Scientific Interest (SSIs). These are
determined with different degrees of importance namely:
• Level 1 – Important habitat types present only in small areas and/or sites with unique species
or features.
• Level 2 – Important habitat types present in relatively large areas and/or sites with rare
species or features
• Level 3 (Buffer Zone) – Include areas where control is necessary to preserve
habitats/species/features in adjacent sites
• Level 4 – Include habitats and/or features of general interest.
Natural areas scheduled as either AEIs or SSIs cover about 12% of the Maltese Islands (37.4 km2).
There are 52 sites, with a total land area of 0.4 km2 scheduled as Level 1 AEIs/SSIs. Another 46 sites
(20.5 km2) as scheduled as Level 2 AEIs/SSIs). Most of the level 3 designations represent buffer
zones around more sensitive areas. It should be noted that developments are not necessarily prevented
in any of the above designated areas although the type, nature and scale of the development may be
restricted. Within Level 1 areas recent developments have been largely restricted to restoration type
work. Level 2 recent approved developments were related to existing uses and included installation of
dish antennas, signs, amendments to car parking, redevelopment of a farmhouse and other internal
alteration to existing structures. New developments in Level 2 zones included amongst other things
new buildings although it is noted that these applications were approved prior to scheduling.
Areas of High Landscape Value
Approximately 36 km2 of the Maltese Islands are protected as Areas of High Landscape Value
(AHLVs) these included the following in 2000:
• Grand Harbour Area – protects the urban landscape of the old harbour area
• Coastal Cliffs (Malta) – the largest AHLV in Malta.
• Victoria Lines – protects the heritage and scenic value of the lines together with the
surrounding rural context.
• Mdina – protects the setting of the old city by protecting the rural context.
• Cittadella (Gozo) – protects the setting of the old city by protecting the rural context.
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• Buskett – protects the setting of Verdala Palace including the natural woodland and the
surrounding agricultural land.
In addition to areas protected for their significant landscape value several individual or group of trees
are protected through Tree Preservation Orders (TPOs). The Rural Topic Paper page 158 states that
“The nature of impact on different AHLVs depends on the visual imposition caused by the different
forms of approved developments”. It is possible that large scale wind will impact on a number of these
AHLVs in terms of affecting the views from these areas; this would need to be explored in detail for a
specific site.
Areas of Archaeological Value
The Structure Plan provides four protection ratings for areas and sites designated as Areas of
Archaeological Importance (AAIs) and Sites of Archaeological Importance (SAIs) namely:
• Class A – Top priority conservation. No development to be allowed which would adversely
affect the natural setting of these monuments or sites. A minimum buffer zone of at least
100m around the periphery of the site will be established in which no development will be
allowed.
• Class B – Very important to be preserved at all costs. Adequate measures to be taken to
preclude any damage from immediate development.
• Class C – Every effort must be made for preservation, but may be covered up after proper
investigation, documentation and cataloguing. Provision for subsequent access shall be
provided.
• Class D – Belonging to a type known from numerous other examples. To be properly
recorded and catalogued before covering or destroying.
Areas scheduled as either AAIs/SAIs cover a total area of 10 km2 (including buffer areas) and are
protected in terms of both their value and their setting. 86 areas or sites are considered to be Class A
archaeological sites (covering a total area of 2.6 km2) with a further 149 classified as Class B
(covering an area equal to 0.4 km2).
Areas of Architectural and Historic Value
The Structure Plan aims to protect isolated or groups of buildings of architectural and/or historical
interest in the Maltese Islands. It does this by giving such buildings equivalent protection as that
afforded to Urban Conservation Areas; which is as follows:
• Grade 1 – Buildings of outstanding architectural or historical interest that shall be preserved
in their entirety. Demolition or alterations that impair the setting or change the external or
internal appearance, including anything contained within the cartilage of the building, will
not be allowed. Any interventions allowed must be directed to their scientific restoration and
rehabilitation. Internal structural alterations will only be allowed in exceptional
circumstances where this is paramount for reasons of keeping the building in active use.
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• Grade 2 – Buildings of some architectural or historical interest or which contribute to the

visual image of an Urban Conservation Area. Permission to demolish such buildings will
not normally be given. Alterations to the interior will be allowed if proposed to be carried
out sensitively and causing in the least detriment to the character and architectural
homogeneity of the building.
• Grade 3 – Buildings that have no historical importance and are of relatively minor
architectural interest. Demolition may be permitted provided the replacement building is in
harmony with its surroundings.
It is noted in the Rural Issues Paper (page 164) that “Other approved developments that affected
scheduled property include…..the erection of dish antenna”. Within the context of renewable
electricity developments this may provide planning precedent at the current time for the erection of
solar PV panels and may allow some lessons to be learnt with regards to allowing PV to go ahead
where suitable.
Areas of Agricultural Value
The Structure Plan states that Areas of Agricultural Value (AAVs) should consist of “high-grade
agricultural land, including irrigated and partially irrigated land”. It goes on to clarify that the
“designation of AAVs in the Structure Plan is intended primarily as an instrument of protection and as
a statement of the importance of such areas in the resolution of conflicts with scenic, ecological,
archaeological and mineral interests…”.
The key elements of this designation are related to the protection of high-grade agricultural land and
that where agricultural land is associated with the fabric of the Maltese visual landscape it is included
under the designation of AAIs, SSIs and SAIs.
(ii) Management of Protected Areas
The above summarises the main designations for important sites across Malta. The significance of
such designations is that they could affect the exploitation of renewable electricity sources by allowing
restrictions to be imposed through the planning system. Such restrictions could affect PV and smaller
scale technologies but are more likely to have an influence on any larger scale projects such as wind.
It is noted, however, that due to many of the designations being declared around the management and
penetration of some activities there is a potential for some development to occur even on designated
sites. Currently it is unclear as to the level of protection afforded by some of the designations. This
may become clearer if the IUCN guidance on the designation categories is adopted fully.
It is intended that through the Structure Plan, National Parks would be established as tools for
management of rural areas. Currently, despite the identification of some areas as National Country
Parks there are no managed Parks in the Maltese Islands. To ensure the effective protection and
management of important areas the functioning of the scheduling process may be revised to include
the use of the definitions set out in IUCN Protected Area Management Categories (IUCN, 1994):
• Category 1a – Strict Nature Reserve – protected area managed mainly for science.
• Category 1b – Wilderness Area – Protected area managed mainly for wilderness protection.
• Category 2 – National Parks – Protected area managed mainly for ecosystem protection and
recreation.
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• Category 3 – Natural Monument – Protected area managed mainly for conservation of

specific natural features.
• Category 4 – Habitats/Species Management Area – Protected area managed mainly for
conservation through management intervention.
• Category 5 – Protected Landscapes/Seascapes – protected mainly for landscape/seascape
conservation and recreation.
• Category 6 – Managed Resource Protected Area – Protected area managed mainly for the
sustainable use of natural ecosystems.
While it is possible that such designations could restrict the exploitation of renewable electricity
resources in any particular area, it will be the specific nature and form of development that will dictate
what the influence of such designations will have. Some of the potential material reasons for different
development types are outlined below.
D.3 Planning and Barriers
Malta is divided into seven Local Plan areas each with different landscape characteristics. As stated
earlier there is little renewable electricity policy development there are no clear guidelines for
renewable electricity to follow, hence this section focuses on selected Local Plans but also draws on
international experience of planning barriers to highlight the possible planning restrictions.
Experience throughout Europe and the rest of the world provides evidence that potential
environmental impacts through the planning systems are often material reasons for the refusal of
planning authorisation. Discussions of the local planning context and potential barriers have been
structured around the technologies in question. This section seeks to scope some of the key
environmental impacts that may cause issues under the planning system. It is not intended that this
scoping forms an exhaustive review as such a study would be the subject of a project specific
environmental impact assessment.
D.3.1 Large Scale Onshore Wind
(i) Overview
Wind energy developments are often perceived as being beneficial to the global environment, but on a
local scale (or in the case of Malta – countrywide scale) they are not always viewed as such. In many
parts of Europe this has been underlined by the growth over the last 10 years of the NIMBY “not in
my backyard” and BANANA “build absolutely nothing anywhere near anything” syndromes. This
level of opposition has developed due a number of reasons including:
• a public which is in general badly informed about wind energy and its likely environmental
impacts and benefits
• the distribution of inaccurate information concerning wind energy
• a failure by some wind energy developers to provide the public with complete information
about their schemes and/or to engage in consultation with communities near proposed
developments, especially in the early years of commercial wind energy developments
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• a failure by some town planners or other decision makers to fully assess local public opinion
on a project, thus wrongly interpreting an opposing minority as representative of broader
sentiments.
This section describes the major environmental impacts of developing large scale onshore wind energy
schemes and then it indicates how the sites identified in Annex B may be affected.
(ii) Agriculture
Typical wind farms consisting of 10 to 30 turbines may be dispersed over an area of 1 to 3 sq. km.
Within this land take the turbines themselves have an extremely small footprint. On average only a
7m diameter foundation is required for each turbine, and experience in the United Kingdom (UK) has
often found that some of this area can be re-grassed, reducing the exposed diameter to between 2 to
3m. Thus, they can co-exist with the present agricultural land use, including in many places across
Europe livestock farming. It should be noted that additional permanent land take is required for
service roads, generators and wind monitoring equipment, which in total normally can occupy up to
1% of the land area of a site. Unless the proposed site is in an area of high agricultural value, for
example, high grade land (AAIs and particularly those associated with the presence of SSIs or SAIs) it
is unlikely that agriculture will form a serious material issue.
(iii) Ecology
There are a number of concerns about the effects of wind energy developments upon local ecology,
including damage to fragile ecosystems and the effect on wildlife, especially bird populations. Fragile
ecosystems may be damaged during the construction period, although these effects can be mitigated
through the adoption of appropriate environmental good practice during the construction phase.
Nevertheless, some permanent losses of habitat is likely to occur due to the construction of turbine
foundations, transformers, substations and access and maintenance roads.
The importance of habitats loss depends upon the original significance of the habitat concerned
typically defined as a habitats relative ‘rarity’. For example, the ecological value of a site may not be
significantly reduced if it is a common type with a land-use such as grazing for livestock or low grade
agricultural production, but if it has a special designation it may be extremely difficult to justify the
loss of habitat. It is important that an appraisal of these and associated matters is initially undertaken,
since after the event, it is impossible in practice to re-establish the loss in ecological value which has
occurred. A carefully designed and sited wind turbine should reduce the impact on ecological
habitats.
It is proposed that the existing protection designations be adapted to more accurately reflect IUCN
designations which will make decisions regarding the conservation/ecological value of the land clearer
for both the Planning Authority and a potential project developer. International designations are likely
to present greater obstacles to development than National designations as they tend to be associated
with habitats that have special value in an international context, for example, they may protect a
world-wide rare species. National designations have been outlined earlier and may still prove to be
significant barriers to wind energy exploitation.
As explained in previous sections, there a numerous designated areas in the Maltese Islands. The
North West Local Plan (NWLP) favours renewable energy projects if such projects are not situated
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within scheduled, designated or protected areas.2 As seen in Figure D-1, there are a number of Level 1
and Class A Protected Areas for Ecology, Archaeology, Natural Reserves and Special Areas of
Conservation (SAC) in the area. This is an important planning policy statement as the NWLP covers
all the sites in mainland Malta most likely to have a suitable resource for wind energy development.
In addition, the Island of Gozo is indicated as a Rural Conservation Area in the Structure Plan for the
Maltese Islands. A significant proportion of the rural hinterland in Gozo is either cultivated or
abandoned agricultural land and land sections of the coast of very high scenic value and of
considerable ecological and geological importance. These planning policy designations may restrict
potential wind energy development opportunities to the south of Gozo.
Certain bird species may be affected by displacement of their existing habitats, habitat loss or damage
and by collision with turbine blades. Disturbance can be minimised by sensitive siting/design away
from narrow bird migration routes and concentrated feeding, breeding and roosting areas, as well as
through the restriction of maintenance operations during breeding periods.3 Nevertheless migratory
birds and their migration patterns pose a particular concern when locating a wind farm. For example,
in the early stages of the development of commercial wind farms in Europe 13 different species were
involved in avian mortalities at a wind farm consisting of 269 turbines in Tarifa, Spain due to its
location within a major migration flight path from Africa to Europe.4
There are likely to be a number of concerns within Malta regarding the potential impacts of wind farm
developments on birds. Careful design and sensitive siting along with research recording the seasonal
bird species variation and habitats present on a particular site, both prior to and during construction
along with operational monitoring may help to characterise the impact and reduce concerns in this
area. If the potential impact on birds is to be sufficiently high to form a material impact on the
approval of a proposed project then this will more likely be the case where such an impact is on a rare
or significant species or on a supporting habitat.
2
Policy NWPU 1 - Part ii of Malta’s the North West Local Plan (September 1994)
3
Royal Society for the Protection of Birds (RSPB), 2004.
4
Luke, A., et al, February 1994 and RSPB 2004.
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Figure D-1: North West Local Plan Area Designated Sites
Source: MEPA, North West Local Plan, Map 18.
(iv) Electromagnetic Interference
Any large structure within the landscape especially one that moves, is at risk of causing
electromagnetic interference, effecting television and radio reception. Impairment to television
reception may be caused by signal obstruction for those viewers situated behind wind turbine
structures, or by reflection of the signal, thus causing ‘ghosting’ for those viewers where the turbines
are located to one side of the signal path. Before a wind energy developments construction, computer
signal strength predictions should be calculated to assess the surrounding areas quality of television
reception. Generally this effect is negligible due to the standards to which wind turbine construction
has to comply with wind turbines being installed worldwide with few instances of recorded
electromagnetic interference. However, if problems occur these can typically be remedied with the
introduction of signal amplification and repeater stations Impacts upon telecommunication systems,
such as microwave links, Malta’s Luqa International Airport communication systems or other
equipment of strategic or military importance can present more difficult problems.
In Malta it is generally considered that the majority of electromagnetic interference issues with regards
to television and radio signals would be possible to resolve to the satisfaction of Planning Authorities.
The issues with regards to Aviation in Malta are likely to be more pronounced. An assessment of
impacts to radar and flight paths would need to be carried out. Issues related to the obstacle Protection
Surfaces for the airport, the size of these zones and potential sites for wind farms could prevent
projects from proceeding. As typical statutory consultees for wind farms throughout Europe, the
aviation industry in Malta may be able to prevent a number of potential wind sites from being
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developed. The constraints on wind farm development introduced by activities at Luqa airport are
discussed in Annex B, section B.3.1.
(v) Historic and Cultural Effects
The Maltese Archipelago has a significant cultural heritage resource in the form of historic buildings,
culturally significant locations both in urban and rural locations and archaeological remains. In
particular the island of Gozo has been occupied for millennia and the archaeological heritage in parts
of the island is very rich. It is possible that during the installation of wind energy schemes
archaeological remains are disturbed or destroyed by, for example by foundation structures for the
individual wind turbines, or by temporary construction trenches for the laying of under ground
electrical cabling. In particular, designated sites such as “Areas or Sites of Archaeological Importance
(including a buffer zone under Class A and B ratings)” and other areas of cultural heritage significance
such as Malta’s “Cultural Scenic Areas”, require protection from physical disturbance or aesthetic
change, caused to the surrounding area through the construction of a wind energy development.
It is possible that a project could be delayed or even prevented due to archaeological concerns.
Investigations of the already designated sites and their density within an area proposed for wind farm
development will be crucial to ensure that irreversible loss of archaeologically heritage is not incurred
without preservation and/or documentation. There are a number of sites around Malta where
development may not be permitted on archaeological grounds. It is noted, however, that careful siting
with proper investigations completed should mitigate potential impacts.
(vi) Tourism and Recreation
Throughout the Maltese Archipelago tourism and to a lesser extent recreational activity are significant
parts of the local economy and are closely linked with the quality of the local townscape and rural
landscape (discussed below). Large scale renewable energy developments such as multiple high
capacity wind turbines can therefore reduce the sense of tranquillity which is an integral part of the
appeal of Malta, especially in rural settings. Sensitive siting and design considerations can minimise
potential impacts, especially landscape and visual implications, however a residual effect is likely.
Nevertheless, it can be argued that such developments, especially in an island which currently has no
wind energy schemes, can in themselves be of interest to tourists. In addition, the limited footprint of
individual turbines should not adversely interfere with rural recreational activities including walking,
hiking and cycling. Hunting and trapping is also an important recreational activity in Malta which
should not be negatively affected by the introduction of wind energy developments if carefully
planned and managed.
(vii) Landscape Impacts
Wind farms may be located in a variety of landscapes ranging from open countryside to semi-
industrial areas. Since they operate most efficiently at relatively high average wind speeds and areas
with minimum wind speed variations, they are most often located in areas of relatively smooth and
rounded relief or on exposed high ground.5 Thus, the turbines may be visually intrusive, with the
5
Scottish Executive, January 2002. Planning Advice Note (PAN) 45 “Renewable Energy Technologies”, Scottish Executive
Development Department, Edinburgh, Scotland
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requirement for adequate spacing between the turbines and the rotation of blades increasing their
conspicuousness. Furthermore, suitable sites can often be near sensitive landscapes, which may be
designated as areas of local, national or international importance.
The factors influencing the landscape and visual impact of wind farms fall into the following main
categories:
• the attributes of the landscape in which the wind farm is sited
• the siting and design of the wind farm itself, including ancillary components like access
track, power lines and electrical sub-stations
• how the wind turbines relate to the skyline
• the atmospheric conditions prevalent at the time of viewing
• the distance of the viewer
• the perception of the viewer6.
A landscape study carried out by MEPA for the Maltese Islands characterises the landscape and it
classifies areas in accordance to the following:
• Areas of Very High Landscape Sensitivity (AVHLS)
• Areas of High Landscape Sensitivity (AHLS)
• Areas of Significant Landscape Sensitivity (ASLS)
• Areas of Requiring Landscape Upgrading (ARLU).
Section three of the Landscape Assessment Study of the Maltese Islands includes descriptions of both
Marfa Peninsula and the Rdum tal-Wardija Coastal Cliffs in Gozo, these are the two areas most likely
to be suitable for the location of wind energy developments in Malta from a technical viewpoint, due
to their high wind resource.
The Landscape Assessment Study of the Maltese Islands described the Marfa Peninsula as a remote
area, the central part of the peninsula is a “… ridge which commands extensive views towards Gozo
and Comino towards the north, and the rest of the Maltese mainland towards the south. There is some
farmland, but garrigue and semi-natural woodland tend to dominate. There are no large permanent
settlements. Structures are mainly concentrated near the north-western coastal flank of the peninsula.
… The historic red tower dominates the skyline of the peninsula. Carriageway density is relatively
low and roads are generally arranged in an orthogonal manner” (Para 3.2.1).
The Landscape Assessment Study of the Maltese Islands goes on to state that the watch tower and a
number of other military structures on the peninsula and a relatively substantial stretch of surrounding
afforested area are enhancing features on the landscape. However, the study also identifies the ferry
terminal for Gozo, the various hotel developments and caravan settlements as detracting features, due
to the ad-hoc manner in which they were developed and in some circumstances the wrong choice of
colour for their external facades. “The string of high-tension power line lattice towers, which transect
the area, presents additional marring to the landscape” (p. 27).
6
Stevenson, R., et al, October 1994 and Scottish Executive, January 2002
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With regard to Gozo, the Gozo and Comino Local Plan states that the “…Maltese landscape and its
appreciation in terms of general public perception is considered to be a major natural resource. … the
intimate relationship between topography, the urban skylines and the rural context creates a
landscape with a special appeal that attracts many visitors from Malta and abroad. The protection of
this landscape is therefore essential to improve the quality of life. The economy of Gozo is also heavily
dependent on the picturesque land scape and this reinforces the argument for protection …”.
The Landscape Assessment Study of the Maltese Islands also describes Gozo and in particular makes
reference to the Rdum tal-Wardija Coastal Cliffs area and adjacent coastline as being dominated by
the cliffs. “These rise gradually from il-wied Tax-Xlendi towards il-Ponta tal-Wardija but then the
coastline veers suddenly towards north and the brow of the cliffs dips gently towards il-Bajja tad-
Dwejra. The area of il-Ponta tal-Wardija represents the highest plunging cliffs in the Maltese island
rising almost vertically from sea level to a height of 150m” (p. 74).
The Landscape Assessment Study of the Maltese Islands goes on to state that the string of cliffs are
spectacular with their steep or nearly vertical profiles. However, around Xlendi the area is marred by
the mass of tourism related development which is totally incongruous with its natural setting.
The ability for the landscape to absorb such renewable energy developments depends on careful siting,
the skillfull use of landscape architecture principles and the character of the landscape including
vegation type and cover, surrounding landforms such as hills and valleys etc. Determining the
capacity of the landscape to accommodate wind energy depends on two considerations:
• The level of impact the proposed wind energy scheme will have on the existing character of
the landscape
• The extent to which the potential impact can be modified and reduced by design5.
Consideration should be given to the possibility of cumulative wind energy developments which could
cause an unacceptable change in landscape quality. A more detailed examination of cumulative
impact is given below.
For each of these areas, planning and development policies are suggested aimed at protecting the
landscape. These policies allow increasing levels of development flexibility as the sensitivity of the
landscape decreases.
Policy NWPU 1 - Part ii of Malta’s the North West Local Plan (September 1994) states that
“proposals for the production of energy from renewable sources will be approved, provided that the
location is not within a scheduled, designated or protected area … [including] … Areas of High
Landscape Value [and] Natural/National Landmark”.
In addition, the North West Local Plan – Marfa Action Plan - Public Consultation Draft (June 2002),
Section 4 entitled Landscape contains a number of policies with regard to areas of high landscape
value (Policy MLA1). This states that “… MEPA will not permit the development of any structure of
activity which, in the view of the Authority, would adversely affect Areas of High Landscape Value
… because it would break a presently undisturbed skyline, visually dominate or disrupt its
surroundings because of its mass, location or design … introduce alien forms, materials, textures or
colours to the natural landscape”.
This is an important planning policy statement as this Local Plan covers the area of mainland Malta
most likely to have a suitable wind resource for wind energy developments. A landscape assessment
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of the area undertaken in 1994 and entitled “An Exploration and Celebration of the Landscape of
North West Malta” states that a major proportion of Malta’s true natural landscape lies in the North
West Plan area. For example the NWLP area contains some of the countries best coast scenery and
inland rural landscapes. However, it also contains some degraded landscape areas caused by
agricultural intensification, road infrastructure, ribbon development from urban areas, quarrying and
other mineral extraction activities. Therefore the possible impact of wind turbines must be assessed
with these unique characteristics of the local area in mind. Landscape/visual impacts could be deemed
significant enough to pose a major barrier to large scale exploitation of wind. It is often through
objections on landscape and visual grounds that NIMBY and BANANA attitudes can cause problems.
The sites identified in Annex B for large onshore development located in the North West Local Plan
Area and in Gozo stretch for the most part over rural AVHLS and AHLS (see Figure D-2).
Planning policy indicates that ‘AVHLs are the most sensitive landscapes in the Maltese Islands and
intervention should be guided with the utmost attention [and] long distance views from these areas
should be strictly safeguarded’.7 Greater flexibility is afforded in AHVLs with medium scale
development such as pump houses, being entertained on a case by case basis. In Malta this may mean
smaller scale wind exploitation may be favoured, however, this comes at an economic cost and has
implications on the overall renewable electricity target that may be achievable.
Figure D-2: Landscape Sensitivity
Source: The landscape Assessment Study of the Maltese Islands,2003
The sensitivity of the Maltese landscape may be an important barrier to large onshore wind farm
development. The best sites in terms of wind speeds and elevations are located in sensitive landscape
areas. This suggests that difficult policy decisions may need to be taken about how to best safeguard
7
The Landscape Assessment Study of the Maltese Islands, 2003
14
the environment. These issues are normally determined during project specific EIAs. In the case of the
Maltese Archipelago and because of its size and limited experience in renewable electricity system
exploitation, it is recommended that this issue is explored with MEPA and possibly with the public
through a proactive education and visual impact study prior to developing any project specific EIAs.
This would allow consequent project development to be better targeted and may increase ‘ownership’
of renewable electricity projects thereby reducing public opposition.
(viii) Visual Impacts
The operational characteristics required for the efficient operation of wind energy developments
means that they are often located in open land therefore, in highly visible locations. The visual impact
in such situations will be dependent upon a number of factors including the distance over which the
development will be viewed, weather conditions, the size of the development and the character of the
surrounding landscape. In the UK, the Scottish Executive has undertaken research on this issue and
has produced a general guide to the effect which distance has on the perception of such a development
in an open landscape (see Table D-1).
Table D-1: Guide on the Effect of Distance
Distance from Viewer Perception
Up to 2 km Likely to be a prominent feature
2-5 km Relatively prominent
5-15 km Only prominent in clear visibility – seen as part of the wider landscape
15-30 km Only seen in very clear visibility – a minor element in the landscape
Source: Planning Advice Note (PAN) 45 – Renewable Energy Technologies, (January 2002)
The Maltese archipelago is very small, Malta is the biggest island and it is approximately 316 sq km.
The landscape is open with little tree cover affording long distance views. The skyline is dominated by
the copulas of churches and historic buildings. There is one tall building in the urban south east of
Malta, the Business Tower which rises some 70m from the ground. This tower can be seen from any
panoramic location within Malta and from high points in Gozo. Moreover, the weather is the Maltese
Archipelago is characterised by low number of days with poor visibility and very good natural light.
A combination of all these factors suggests that large onshore wind farm development within the
Islands is likely to have a significant visual impact and is likely to be prominent from a large number
of areas.
There are strategies that can be adopted to ameliorate visual impact. For example, grouped turbines
and well designed peripheral facilities such as substation and access tracks will look acceptable as a
single isolated feature in an open landscape. However, in an agricultural landscape with defined field
boundaries, rows of turbines may be more visually acceptable. Whatever the potential location within
Malta the design of any development must be appropriate to its site and aim to reduce the perception
of visual clutter between the turbines and associated facilities and any surround landscape features.
Section 8.2.2 of the Gozo and Comino Local Plan entitled “Renewable energy” states that Gozo
depends on energy generation facilities on Mainland Malta. The generation of energy from renewable
15
resources is therefore commendable in principle. However, such facilities suffer from a number of
drawbacks including “very large scenic impact especially in sensitive rural areas and the proximity of
cultural landscapes” (p. 62). The local plan goes on to state that wind generation facilities on isolated
farms may be considered provided that visual impact can be contained. Such conclusions indicate that
large scale wind exploitation on Gozo may not be possible to achieve. If a similar stance is adopted on
Malta the effect could prevent large scale wind exploitation from occurring which will have separate
policy impacts, these are discussed in the main document.
Since most wind farms are located on high ground and the turbines are often viewed against the
background of the sky, it is advisable for turbines to be painted a non-reflective off white colour. The
colour chosen would depend upon testing to determine the most common sky colour in a particular
part of Malta. In addition, modern turbine designs are normally solid tapering towers which appear
more elegant than lattice support structures.
The significance of visual impact as a barrier to wind energy development in Malta needs to be
assessed with a visual impact study. This entails the provision of descriptive material on potential
visual impacts together with a supplementary visual representation often in the form of viewpoint
analysis or photo-montages. Depending on the development’s size, a more sophisticated practice is to
use computer generated zone of visual influence data to predict possible landscape impacts. The
required form of visual assessment would normally be agreed between the wind farm developer and
the planning authority, in this case MEPA. In the case of Malta, it is recommended that a visual impact
study is carried out prior to submitting a project specific EIA. This will allow issues to be highlighted
prior to project development and it would provide an opportunity to educate the general public if this
was to be considered necessary. Such a study could be combined with an assessment of the landscape
impacts and a wider public education programme.
(ix) Shadow Flicker and Flashing
Under certain circumstances, due to location, the time of day or year, the sun may pass behind a wind
turbine, thus casting a shadow over a section of the surrounding area. When these shadows cause a
visible fluctuation in light levels, the effect is often referred to as shadow flicker. For outdoor
observers, such an effect is not a cause for concern, but if the shadow crosses a window of a nearby
residential property or other building the effect can on occasion be noticeable, especially if the
window is narrow or provides the only source of light in the room. In such circumstances general
irritation may be caused. Since the path of the sun throughout the year is predictable, with best
practice incorporated into a wind farm's location and layout, the problem can normally be mitigated
through adequate separation distances between an individual wind turbine and any nearby buildings.
Rotating turbine blades may sometimes reflect the sun, as they repeatedly pass through a certain angle.
The subsequent flashing effect may cause irritation and possible driver distraction. This problem can
be mitigated by coating the surfaces of the blades with a semi-matt rather than a gloss finish or with a
colour of low reflectance (e.g. grey rather than white). Within the Maltese landscape experimentation
would be required to both gauge the correct colour treatment to stop flashing and also to blend in
against the most common sky colour for a chosen location.
The climate and small size of the Maltese Islands means that there is a potential for impacts to be
caused related to shadow flicker. Such impacts could require changes to project design or even add to
the decision of whether or not to grant planning approval. Shadow flicker should be considered at the
project specific design stage.
16
(x) Noise
Wind turbines generate two distinct types of noise. Firstly, an unavoidable aerodynamic noise, which
is rhythmic in nature, caused by the production of vortices as the blades pass through the air and the
interaction with the tower as each blade passes it. Secondly, a mechanical noise, which is tonal in
quality, is produced by the turbine gearing mechanism, hydraulic pumps and electrical equipment
within the nacelle. Many modern turbines designs have incorporated acoustic enclosures, specially
designed gear systems and vibration isolating materials to minimise this problem, to the extent that
mechanical noise is now usually less than, or of a similar level to aerodynamic noise. It is commonly
said that "low frequency noise" or "infrasound" can be produced by wind turbines. While this was true
of some early models, the technology has moved on and modern turbines produce very low levels of
noise, including infrasound.
Wind turbines may often be located in areas of low background noise, where the noise from turbines
may be intrusive. Problems normally occur during lower wind speed operation or during the cut-in,
run-up period. To overcome this problem, various modern turbine designs have incorporated a two
speed generator to provide for lower rotational speeds.
The likely rural location of large wind generators in Malta means that there is a possibility for noise to
become an issue particularly in the localised areas of a site. Wind farm noise assessments should be
completed to a standard similar to the UK’s Energy Technology Support Unit (ETSU) - 97
methodology entitled “The assessment and rating of noise from wind farms” which was undertaken
for the Department for Trade and Industry (DTI). This procedure ensures that sites are chosen
appropriately, and that noise levels are assessed and rated as part of the overall planning assessment
process. The ETSU 97 methodology also includes a series of good practice recommendations. The
adoption of such a methodology is likely to ensure that “any effect from noise … generated by such a
development is kept to a base minimum” which would be in keeping with Policy NWPU 1 - Part iii of
the North West Local Plan (September 1994).
(xi) Health and Safety
The only risk to the general public and animal life arises from structural failure of turbine components
especially blades, when a section of the turbine blade, or the whole blade, may disconnect from the
turbine assembly. With the development of wind energy technology over the past 10 to 15 years such
events have a low probability of occurrence. The possibility of lighting strikes applies to wind
turbines, in common with all similarly tall structures. Modern wind turbines incorporate lighting
protection measures to ensure that lighting is conducted past the sensitive components contained
within the turbine and into the surrounding earth.
It is not likely that this will be an issue of concern in Malta. If concern does exist a risk analysis
considering the impacts of catastrophic failure could be completed although a detailed study of this
would be unusual as part of the planning process.
(xii) Cumulative Effects
The cumulative impact of neighbouring wind energy developments or other infrastructure schemes
may in some circumstances have an additional environmental impact, mainly in landscape and visual
terms. These effects can arise as the combined consequences of:
17
• an existing wind energy development and a proposed extension to that development
• proposals at the same time for more than one wind energy development or other
infrastructure schemes within an area
• proposals for a new wind energy development in an area with one or more existing
developments
• any combination of the above. 8
The potential impacts of a number of schemes should be assessed as part of an environmental impact
assessment. Due to the constraints on suitable sites, designations and other barriers it may be that
opportunities for large scale wind developments do not exist and therefore such impacts would not be
significant in Malta. However, this is countered to some extent due to the size of the Island meaning
that wind farms of commercial scale are likely to be visible from most areas, therefore, cumulative
effects may arise with the installation of only a couple of projects.
(xiii) Construction and Maintenance Disturbance
The amount of disturbance caused during construction and maintenance is dependent upon the scale
and nature of the development as well as the length of the construction period. Public perception of
the construction activity will mainly depend upon the perceived physical impact and the amount of
traffic movement to and from a proposed site. The expected construction and maintenance traffic
movements may include:
• vehicles transporting removed spoil
• vehicles transporting concrete for foundations
• articulated vehicles containing component sections of the wind turbines and associated
machinery
• transport for site construction and maintenance workers
• a crane to erect the individual wind turbines or access turbine components during
maintenance procedures
During the operational period, a little traffic will be also generated due to maintenance requirements.
Such movements are likely to be infrequent, since a wind turbine would normally be serviced
approximately once every six months.
If the selected site is in a remote location, which is very likely in Malta and Gozo, it may only be
served by minor rural roads with a limited maintenance regime. In addition, temporary haul roads
may need to be constructed in order to get the articulated vehicles containing component sections of
the wind turbines and associated machinery to the proposed rural locations in Malta or Gozo. If this is
required it is likely that MEPA will require various planning condition to be meet to remove the haul
roads and restore the land to its former use once the turbines have been installed.
8
ETSU, 2000, ETSUW/14/00538/REP – “Cumulative Effects of Wind Turbines – A Guide to Assessing the Cumulative
Effects of Wind Energy Development”, ETSU, Harwell, UK.
18
In some cases the construction of temporary roads may not be practical for economic or environmental
reasons, i.e. the quantity of road being significant. It is possible to use helicopters to import
equipment and materials to a worksite although this will alter the economics of a project and may
result in a project not being cost effective.
(xiv) Decommissioning
It is simple and quick to decommission and remove a wind turbine at the end of its working life,
returning the land to its original use. After the turbine nacelle, tower and cabling has been removed,
the foundations are excavated or buried and access roads are returned to grassland or their previous
land use. In addition, the scrap value of a turbine can contribute to the decommissioning costs. Thus,
there are normally no residual waste or land contamination issues.
D.3.2 Potential Planning Implications
As noted earlier, all the environmental impacts discussed above will be considered as part of any
project specific EIA and it is only then that their significance can be ascertained in detail. It is,
however, possible that there will be interactions with the planning process which may cause suitable
sites or potential projects to be prevented. At this stage of assessment it is possible to analyse
potential planning barriers to development based on the siting of the potential wind farms, the
ecological and cultural heritage value of the area, the sensitivity of the landscape and the location in
relation to settlements and other important sites such as the airport.
Visual impact is likely to be an issue for all the proposed sites. It is considered that visual impacts,
including associated impacts on the landscape, will be significant constraints in Malta. There is not
currently any experience of projects that have a visual influence on this scale, in fact the tallest
building on Malta is around 90 m, and 105m above sea level. The approximate height of the onshore
turbines that are likely to be considered will be around 70 m to the hub and 110 m to the tip. The sites
considered have a median elevation of around 120m, giving an approximate total height of 230m
above sea level. It is considered that potential objections to structures of this magnitude may result in
the emergence of NIMBY attitudes and scrutinisation of a projects impacts in detail. Such attention
may prevent or at minimum slow the development of large scale wind farms in Malta if nothing is
done to alleviate concerns.
Annex B outlines some potential sites for large scale wind exploitation in Malta. These have been
considered in general terms to evaluate some of the potential planning stances/environmental impacts
that may be of importance at each example site. This assessment has not been completed in detail and
would be superseded by any site specific fuller evaluation that should be completed. Table D-2
summarises the results of this evaluation. As the impacts on visual and landscape are not site specific
and have been outlined above these are not considered within this summary table. This also applies to
other environmental impacts associated with wind development that are common to all sites and that
would need to be analysed on a case by case basis, which include noise, flicker, health and safety and
construction disturbance.
For each of the sites, the table shows in red issues which may present serious restrictions or halt
development, however, this is only indicative as all issues have the potential to develop into serious
problems.
19
The important thing to bear in mind is that without any changes either in design or in public perception
all of the issues mentioned could prevent a wind project from arising. Potential mitigation measures in
terms of international experience of breaking down such barriers are explored in the barrier removal
section. The potential sites described above were identified as part of the resource evaluation. The
potential impacts of constraints above have been applied through the restriction of sites and
exploitable energy source amounts. This is discussed in the resource assessment Annex B.
20
Table D-2: Large Scale Onshore Wind Site Specific Constraints (Excluding visual/landscape issues)
Site Constraints
Gebel Cantar • There are Special Areas of Conservation (SAC) of international importance under the Natural 2000 Sites to the south and north
east (see Figure D-1). The site to the north east if an internationally important bird sanctuary called Buskett-Girgenti. The area to
the south is the international designation for the coastal cliffs
• The site extends across AVHLS and AHLS (see Figure D-2)
• There is a Scheduled Level 1 SSI/AEI (as indicated in Figure 32 of the Rural Strategy Topic Paper)
• There is a Scheduled Class A Archaeological site (cave dwellings) (see Figure D-1)
• There is a Nature Reserve on the north east of the site (see Figure D-2)
• The site is within the conical surface area to the Luqa airport and therefore interference is possible
Ghemieri • The site extends across AVHLS and AHLS (see Figure D-2)
• The Cliff area west of the site have been designated as a SAC of international importance under Natura2000 (see figure D-1)
• AEI/SSI called Wied il-Bahrija, Wied Rini u Wied Gerzuma to the west of the site
• The east of the site is about 2 km from Mdina and in direct view of the Mdina fortifications. This city is a protected historic city
with the landscape around it protected as this sets the context of the city.
• There may be possible flicker problems in Mdina
• There are a number of archaeological sites that may be significant in this area. The density suggests that this should be carefully
assessed.
• The Victoria Lines are located to the north of the worksite boundary, these are protected under national law
• There may be issues with the airport and surface obstacles that require assessment
Qasam Ben Gorg • The site extends across AVHLS and AHLS (see Figure D-2)
• The island of Gozo is indicated as a Rural Conservation Area in the Structure Plan for the Maltese Islands
21
• The Gozo and Comino Local Plan emphasises the need to protect the landscape
• The proposed site in Gozo extends over the Rdum tal-Wardija Coastal Cliffs area which is described as spectacular in the
Landscape Assessment Study of the Maltese Islands
• The site extends over a protected site (L’Ghadira Ta’Sarraflu) in the south west this is a SAC of international importance
• Natura2000 SAC site of international importance (Dwejra-Qawra Area inkluz Hagret il-General) possibly intersecting with
western section of the site
• Natura2000 SAC site of international importance (Xlendi-Wied tal-Kantra Area) to the south east of the proposed site
• The site is only served by minor rural roads that pass through small villages making it impossible for the articulated vehicles
containing component sections of the wind turbines and associated machinery to get through. Temporary haul roads would need
to be constructed and considering Gozo’s very high scenic value and considerable ecological and geological importance, it is most
likely that an alternative route would encounter major planning consent issues.
Bajda Ridge • The east of the site extends over AVHLS and AHLS
• Possible shadow flicker on St Paul’s Bay to the east
• There is a Natura2000 SAC of international importance (Wied Il-Mizieb) in close to the site (see Figure D-1)
• The cliffs near the west side of the site are important ornithological sites (as indicated in the Figure 2 of the Coastal Strategy Topic
Paper)
• This site is located close to the towns of Mellieha and Manikata.
• Nature Reserve close to the site (Wied il-Mizieb u Wied tax-Xaqrabi)
• There is a bird sanctuary to the eastern extreme of the site
• The coastal cliffs areas covering the western edge of the site are protected as a SAC of International Importance
• Simar bird sanctuary is a Natura2000 SAC of international importance and Is-Simar Ramsar site wetland of international
importance are both south of the site.
Marfa Ridge • The east and west of the site are SAC (see Figure D-1). These coincide with AVHLS and AHLS (see Figure D-2) and Scheduled
Level 2 and level 3 Areas of Ecological and Scientific Importance under the Environmental Protection Act (as indicated in Figure
22
32 of the Rural Strategy Topic Paper)

• The area to the west of the site are the Natura2000 coastal cliffs a SAC of international importance (Qammieh Area) the areas to
the east of the site is a Natura2000 SAC of international importance covering the White Tower Bay coastal cliffs (Tal-Madonna
Area)
• There are a number of AEIs/SSIs for saline marshland near Ta’Qassisa, another at Ir-Ramla Ral-Bir and at Ramlet il-Qortin
• AEI/SSI freshwater wetland at Il Qammieh
• AEI/SSI watercourse at Wied Musa north of the site
• AEI/SSI at Armier Bay north of the western proportion of the site
• AEI/SSI coastal cliffs from ic-Cirkewwa till Benghajsa and from il-Ponta ta l-Ahrax till il Hmar
• There are two areas of woodland conservation (as per Map 9.4 of the Marfa Action Plan)
• There are two heritage sites in the area The cliffs on both the west and east of the Marfa Ridge are important ornithological sites
(as indicated in Figure 2 of the Coastal Strategy Topic Paper)
• The site is close to towns of Mistra and Mellieha
Wardija Ridge • The potential site is close to towns of Mgarr and Zebbiegh with St Pauls Bay to the east
• There may be some issues with regards to interference with the airport’s obstacle surface
• Ghajn Tuffieha is an AEI/SSI to the west of the site
• The coastal cliffs (Rdumijiet) to the west of the site are protected under international designation
• There is a Natura2000 SAC of international Importance east of the site (Il-Ballut tal-Wardija)
• There are a number of trees of Antiquarian importance to the east
• Simar bird sanctuary is a Natura2000 SAC of international importance and Is-Simar Ramsar site wetland of international
importance are both north of the Warjda Ridge.
Ta’ Hammud • There are a number of archaeological sites in the area (Map 9 of the Central Malta Local Plan)
• A Listed Site of Scientific Importance (Is-Salini SAC of international importance) runs through the west of the potential site (Map
8 of the Central Malta Local Plan)
23
• There is a listed ecological site towards the south of the proposed site (see Map 7 of the Central Malta Local Plan)
• There is the Natura2000 L-Ghadira S-Safra SAC of international importance
• AEI/SSI (Qalet Marku) to the south-east of the site
• SSI Challis Rocks to the north-east of the site
Hal Far Airfield • Close to Luqa Airport and within the obstacles zone and therefore likely to be unsuitable
(Disused)
• AEI/SSI coastal cliffs from ic-Cirkewwa till Benghajsa to the south part of the site
• The Cliff area south-east of the site have been designated as a SAC of international importance under Natura2000 (see figure D-1)
All these issues together with other environmental impacts not specifically mentioned such as visual and landscape impact, noise, use of agricultural land etc, will need to be assessed as a part of
a project specific EIA to determine their significance in detail.
24
D.4 Medium Scale Wind
Potential environmental issues with regards to medium scale wind turbines are similar to those
highlighted for large scale wind, however, the significance of such developments is diminished for a
number of reasons including the following:
• the size of the turbines is much smaller
• it is likely that installations would be single turbines per location
• it is anticipated that such wind turbines would be located within farming areas perhaps close
to buildings/pump-houses.
The visual intrusion of such turbines is less significant due to their individual sizes, although there is
the potential for cumulative impacts to arise if there is a high level of penetration in a particular area.
Noise and shadow flicker could be potential issues if the turbines are very poorly located although the
reduced size will, in the majority of cases, mitigate much of this potential impact.
There is the potential for bird strikes to occur although these are less common on turbines of this scale.
As with larger turbines, consideration of potential impacts on rare or important species during the
siting of the turbines will be valuable. Consideration of the area in terms of its landscape value, other
developments and areas of archaeological or cultural importance will also be important.
On the planning side it is likely that the process will be significantly easier than for larger scale
developments. In Section 8.2.2 of the Gozo and Comino Local Plan entitled “Renewable energy”
states that Gozo depends on energy generation facilities on Mainland Malta. The generation of energy
from renewable resources is therefore commendable in principle. However the Local Plan goes on to
state that wind generation facilities on isolated farms may be considered provided that visual impact
can be contained. Such conclusions indicate that in Gozo these projects may be considered more
favourably. If a similar stance is adopted on Malta the opportunities for exploitation of wind from
medium scale plants may be greater than for larger scale wind projects.
D.5 Micro-Wind
In Europe, the focus of micro-turbine technology has to date been on attachment to the exterior of
man-made structures such as buildings, bridges, sea walls etc. However, there have been a number of
potential barriers to its wide spread application including acceptability by certain public and lobby
groups, areas of environmental and cultural heritage protection areas, planning restrictions and the
ability of the transmission grid to maintain stability.
This section concentrates upon examining the potential environmental impacts and planning
implications to the successful development of a micro-wind resource in Malta. As these impacts are
on a smaller scale to that of large turbines the impacts are outlined first then specific planning issues
highlighted.
25
D.5.1 Main Environmental Impacts
(i) Visual and Townscape Impacts
While modern micro-turbines are often no bigger than a roof mounted TV aerial or satellite dish,
collectively they can have a significant visual and townscape (urban landscape) impacts on the fabric
and appearance of the built environment especially in areas of historic or conservation importance.
This can be mitigated through education, careful siting to reduce visual intrusion and light flicker and
sympathetic design, along with appropriate planning policy in Malta’s various Development and
Structure Plans.
While the visual townscape impacts can to some extent be resolved, experience to date regarding
aerials and satellite dishes in Malta suggests that the collective visual impact may result in significant
issues on the planning front. It is likely that in some areas, especially those of historic and/or cultural
importance this could prevent certain buildings from installing micro-wind technologies.
(ii) Electromagnetic Interference
Wind turbines can cause Electromagnetic Interference (EMI) which is defined as the physical
interference 'scattering' of signals, as the wind turbine provides a second path between the transmitter
and receiver of the signal. This often leads to a phenomenon called 'ghosting' on television screens
which in most instances is rectifiable. Electrical interference principally comes from signals generated
within the wind turbine which may impact on communications equipment. Careful siting and design
can normally mitigate such problems. Wind on this scale is unlikely to impact on the airport radar
systems.
(iii) Noise and vibration
The size of the micro-turbines and higher baseline noise levels in many urban areas reduces the risks
of noise impacts upon sensitive receptors. Consideration of design and siting can further reduce the
potential impact. Careful consideration should also be given to the structural integrity of buildings
and whether the mounting of micro-turbines to external surfaces compromises safety
recommendations.
MEPA’s Policy and Design Guidance produced in 2004 to promote the creation of high quality
residential development, and to a lesser extent, other forms of development including industrial,
contains a series of policy statements and performance standards that development should achieve
against the Maltese Planning System.
Part 13 entitled “Energy and Infrastructure” includes information on designing for energy conservation
and the use of solar water heaters and photovoltaic cells (Section 13.2). However, no consideration is
given to the use of micro-wind turbines for electricity generation. The Policy and Design Guidance
states that MEPA will encourage the use of renewable energy sources which have far reaching
environmental and economic benefits. However, MEPA have introduced a set of criteria that must be
met with regard to the approval of domestic PV systems.
26
The criteria states that a PV system is located on the roof of a building it must:
• ’Not exceed an overall height of 1.9 metres above the roof level.
• Be located where, from long range views, it is viewed against the background of an existing
structure on the roof, such as a washroom or stairwell.
• Not break or intrude into a skyline or roofscape which it is desirable to protect, particularly
within an Urban Conservation Area or other protected area’. 9
This criteria is in process of being updated (see Section D.2.3).
It is likely that within a Maltese context more stringent planning restrictions to those for PV may be
applied to the use of micro-wind turbines because of their greater visual impact on the townscape.
Planning authorities should actively encourage the development of such micro-wind schemes, where
appropriate, through positively expressed policies and target setting in local plan documents. Within
this context, MEPA’s Policy and Design Guidance includes the criteria for identifying major projects
of various different development types such as residential, schools, hospitals, tourism developments
etc. 10 These criteria could be used as the basis for an economic threshold to consider renewable
options like micro wind generation for any new built developments.
In addition, as micro-wind market matures there maybe the potential to include an element of local
manufacturing capacity. This would broaden the benefits of micro-wind generation to the general
economy of the Maltese Islands.
D.6 Offshore Wind
D.6.1 Environmental Impacts
The paragraphs below introduce the main potential impacts of offshore turbines. As with large onshore
wind, the discussion is not exhaustive as the specific nature of impacts are determined by the design
and siting of a particular project.
(i) Coastal and Offshore Processes
Impacts may include:

• potential interference with coastal and offshore sediment transport systems arising from such
issues as constructing foundations, cable laying and from fixed structures over the offshore
wind farm lifetime, interference in mobility of sandbanks, sediment redistribution (including
contaminants)
• changes in erosion and accretion processes
• changes to seabed morphology.
9
MEPA January 2004, Policy and Design Guidance produced in 2004 to promote the creation of high quality residential
developments, Pgs 100-101.
10
Appendix Three of Policy and Design Guidance, MEPA, 2004, p. 118.
27
Any proposed scheme will require a full investigation of the surrounding wave and coastal process
prior to approval and construction. This is required to ensure correct siting and to enable the adoption
of best practice for the construction process. Some impacts are not avoidable but design should seek
to minimise the potential long term effects.
(ii) Biological Environment
Ecological impacts may arise because of physical alterations of offshore processes, as a direct result of
exploration activities and as a result of the long-term footprint of towers and associated foundation
structures in the area. Potential ecological impacts are examined below and possible mitigation
measures suggested were possible.
Birds
The impact of offshore wind farms on birds is generally considered the most significant environmental
issue. As previously shown, much is known of effects of onshore wind turbines on birds, derived from
studies conducted since the early 1990s.
However, with regard to offshore developments only a few studies have been widely published, based
on research at developments in Demark, Sweden and the Netherlands. This limited research has shown
that certain species such as Eiders and Common Scoter seem to maintain a greater distance from the
turbines and fly at low altitudes (10 m) above the sea’s surface reducing collision risks during poor
visibility. Due to this limited information it is difficult to predict the risks upon bird populations.
However as a general rule it is likely that offshore developments could affect birds in the following
ways:
• collisions with turbine structure for migrating or feeding birds
• changes to traditional feeding and roosting grounds
• wind turbines acting as potential barriers between feeding and roosting grounds or in
migrations routes.
The level of potential impacts would be dependent upon a range of factors including the scale and
intensity of construction work, especially if noisy monopiling is used, noise levels from operational
turbines and maintenance vessels, the type of bird species in the local area and associated flight paths
and heights, the number of avian movements, distance from shore, local feeding conditions, water
depth, weather conditions, time of day etc. Mitigation measures could include bird monitoring
programmes and post evaluation studies.
The area identified as part of the resource characterisation is located off the coast of Marfa. The cliff
areas around this area of Malta are protected under international designation. In addition there are a
couple of bird sanctuaries on Malta towards the North of the island. Potential impact would need to
consider flight paths and seasonal variations in such patterns.
Fish
Offshore wind farms may have beneficial long term impacts on fish due to the turbine foundations
acting as artificial reefs with a resultant increase in fish populations from the new food supply.
However, the location of the turbines may exclude fishing in the area which can lead to conflicts with
28
the fishing industry. During the construction process potential negative effects include noise and
vibration and increased level of local turbidity and sedimentation which can have a particular effect
upon fish larvae.
Sea Mammals
The effect from offshore wind farms on sea mammals including seals, dolphins, whales is generally
not considered to be very important unless located in a known sensitive location. Potential impacts are
likely to include low frequency emissions from turbine structure and associated cables, loss of habitat
areas through noise disturbance especially during construction and maintenance operations and
possibly visual disturbance due to a moving structure.
Flora
The foundations will directly affect the plant life on the sea-bed and this could have a negative impact
on the overall ecological balance in the area if the damage is significant. The potential site identified
in Annex B for offshore development is located in an area of Posidonia Oceanica settled on matte
structures with no significant clear patches. This sea-grass is considered to be a very important basis
for ecosystems in the Mediterranean. Any development would need to complete the necessary surveys
and mitigate the potential impacts to such plant species if possible. As sea-grass meadows are
typically protected this may result in development of an offshore wind project at this site being more
difficult.
(iii) Airborne Noise
Offshore wind turbines like onshore turbines generate two distinct types of noise. Firstly, an
unavoidable aerodynamic noise caused by the production of vortices as the blades pass through the air
and the interaction with the tower as each blade passes it. Secondly, a mechanical noise, is produced
by the turbine gearing mechanism, hydraulic pumps and electrical equipment within the nacelle. The
airborne noise may impact upon birds, local marine habitats and the public if it is audible from nearby
shores.
(ii) Underwater Vibration and Noise
Construction operations including piling or drilling is likely to have a significant impact upon fish and
sea mammals. Mitigation measures should include the avoidance of especially noisy construction
techniques such as monopiling which can on occasion stun nearby fish if other construction techniques
such as caisson and concrete foundations are available.
(iii) Cultural Heritage
The development of offshore wind energy schemes may lead to changes in coastal and maritime
archaeological features. Mitigation measures would include the avoidance of areas of known
archaeological interest and the completion of seismic site surveys and a review of historic records as
part of an EIA.
29
(iv) Seascape and Visual
Visual impact alongside impact upon birds would normally be considered the most potentially
significant impact of an offshore development. This may be caused by the introduction of man made
structures in an otherwise open landscape. In addition, if the development is near shore this can
increase levels of potential opposition from the public and other stakeholders, especially if located
near heavily used recreational areas or areas valued for their scenic beauty. These issues may apply in
the case of the potential offshore site identified in Annex B as this would be a near shore development
off a very popular tourist location in the north east of Malta. 11 However as with onshore developments
offshore wind energy schemes can often become tourist attractions in their own right.
As a general rule many offshore wind farms in Europe have been developed around 8km offshore
when visibility issues can be considered negligible if viewed near sea level and the turbines have no
significant markings such as extremely bright navigational lights or bright coloured blades although
this is unlikely to be the case with the proximity of the suitable site to the shoreline and the alternative
uses of the sites.
The potential site in Malta is located only a few kilometres off the coast before the sea bed deepens
beyond what it is currently possible to engineer. It is likely that any development here would result in
significant visual and seascape impacts. Given that there are environmentally protected areas, areas of
housing and areas of tourism on the north-east coast this would require careful assessment as part of a
project specific EIA.
(i) Other Potential Impacts
Other potential impacts include for example, the displacement of fishing activities, increased collision
risks, interference with positioning and visibility of navigational aids, commercial shipping routes, as
well as conflict of interest with recreational users, interference with military practice ranges and
electromagnetic interference with radar and telecommunications. Careful design and siting, for
example away from fish spawning areas or high commercial value fishing areas, active consultation
with the public and other stakeholders such as statutory consultees together with technical fixes can
reduce potential problems.
In the case of the potential offshore site identified in Annex B, conflicts are likely to arise due to
competing uses of the site such as bunkering and fishing which are economically important to the
Maltese economy.
D.1.2 Offshore Approval Mechanisms
Within a Maltese context, the method for approval is in theory is much easier than in many parts of the
world, including the UK due to simpler land ownership and statutory consultee issues. For example
MEPA or the Government Property Division of the Ministry for Justice and Home Affairs would be
the responsible government organisations for leasing areas of seabed and areas of government land on
the various Maltese Islands. In addition, MEPA would the main statutory consultee for any necessary
planning and environmental approvals, including those associated with a marine or land based EIA.
Currently the leasing of seabed for mooring purposes is done on an annual basis. It is likely that an
11
The site is less that 2 km away from the east of the Marfa peninsula and about 6 km from the coast at Mellieha Bay.
30
offshore wind developer would require more certainty to the longevity of the seabed lease than this
arrangement would provide. Lack of certainty of the seabed lease may prove to be a barrier to the
successful exploitation of offshore wind.
There is no planning guidance to the development of offshore wind turbines. It is likely that issues
related to safety of other sea users and visual impacts/alteration of the seascape along with potential
impacts on the seagrass meadows will be the most significant of the material planning issues. As with
onshore wind, there are a number of actions that can be taken to evaluate the impacts and to reduce
these. In the case of visual and seascape issues studies exploring the impacts and the potential reaction
to developments, perhaps through visual assessments, are important measures that could reduce
concerns in this area.
D.2 Photovoltaic
D.2.1 Introduction
There are essentially two generic forms of PV installations producing solar electricity; commercial
scale solar farms and domestic scale connected installations. Due to the large areas of land required
for the establishment of commercial scale solar farms, the opportunities for this type of development
are very limited in Malta due to competing demands for open land. The potential for domestic
connected solar installations is much higher, in the form of either building-integrated systems or
building-attached “retrofits”: These use PV technologies in place of, or in addition to, traditional roof
or facade materials, and the electricity generated is used mainly by the building concerned. Any
surplus can be exported to the local electrical distribution network.
One of the key limitations to the exploitation of this resource is the high capital costs of PV
installations (see Annex F). There may also be issues related to planning permissions that have to be
resolved such as alteration of the fabric of the buildings or the surrounding area, especially if located
in a historic environment. The shortage of land in Malta may increase the requirements to build taller
buildings. In some areas this means extending upward the existing building stock, subject to the
prevailing planning policy framework in the area. Such increases in building height may change the
shadows from buildings (and associated levels of light penetration to adjacent properties) and may also
make some rooftops unviable for exploitation. In addition, many roofs have dual purposes which may
limit the size of the exploitable rooftops on domestic dwellings. Shared ownership of rooftops for
apartments may also be an issue that limits the penetration of the technology. (These issues are
discussed in more detail in Annex C)
Nevertheless, it should be remembered that the Islands of the Maltese Archipelago experience
approximately 3000 hours of sunshine per year. The Islands typically have a daily average of 5 to 6
hours sunshine in mid-winter to more than 12 hours in summer. The potential for the generation of
solar electricity is therefore high.
D.2.2 Potential Environmental Impacts
As with wind energy production, solar PV technologies do not emit to the atmosphere, water, or
produce wastes during operation, however, they do have a range of potential negative environmental
impacts. The list below outlines some possible impacts, however it should be noted that this is not
exhaustive and the specific nature of impacts should be determined by the design and siting of a
31
particular PV project. Developments in Malta are likely to consist of a single or a couple of PV

modules on domestic buildings to larger installations on the roofs of hotels, schools, hospitals, offices
and industrial facilities.
(i) Manufacturing Impacts
Although other technologies (wind, wave etc.) have manufacturing impacts with PV it is at this stage
that the most significant impacts arise. Such impacts for PV arise due to the the significant
proportions of energy used in the manufacturing process. The excavation and handling of the primary
materials required for the construction of solar PV units can also have significant environmental and
associated health and safety impacts, often including the use of arsenic, cadmium and silicon. At
present these impacts will not accrue in the Maltese Islands as there is no excavation and no
manufacturing of PV nationally. This would change if manufacturing capability was to be developed
nationally in the future.
Advances in the manufacturing process have enabled the energy required to manufacture solar PV
modules to reduce and it this is anticipated to continue as processes and materials are improved and
economies of scale are realised. In addition, the potential effects from the excavation, handling and
processing of materials in the production of the solar cells can be minimised through the application of
good environmental and health and safely best practice.
(ii) Visual Impact and Glare
Visual and urban landscape (townscape) impacts are a potential issue in some locations, including
areas protected by cultural and historical designations. As with micro-wind turbines, individual PV
modules are small however, collectively they could have a significant cumulative impact on the fabric
and appearance of the built environment. In addition, the installation of PV modules can lead to
reflective glare. Sympathetic design and careful siting of PV modules within an urban environment
can mitigate glare and visual or cumulative impact.
(iii) Cultural Heritage
There is the potential for impacts to occur on historical housing stock that should be protected for its
cultural and/or architectural importance. A number of buildings and areas have been designated as
protected zones in Malta. While this may not prevent projects from arising on these buildings or in
these areas, designs will have to take account of the relative sensitivity of such locations.
(i) Location and Design
Location of PV modules is important from the point of view of performance; they need to have the
right orientation to capture as much sun light as possible and avoid over shading and dirt collection.
The latter may be increased if the PV module is located near to a busy road or below a structure on
32
which birds or other animals may perch. However, PV systems are designed to be, as far as possible,
self cleaning, with smooth glazed surfaces that limit the adhesion of dirt.12
PV systems have the advantage that they make little or no sound and have no moving parts. However,
the installation of PV modules on the roof, windows or walls of a building will undoubtedly have
implications for the design and appearance of an individual building and the surrounding wider
townscape. Visual appearance may be a planning consideration to ensure that PV modules are not
detrimental to the attractiveness of an area this may become more significant on a cumulative impact
basis.
There are a growing range of PV integrated building materials available which provide an enhanced
opportunity for architects and town planners to incorporate PV arrays without compromising
established design objectives. Building material choices include for example, roof tiles,
semi-transparent glass and flexible modules for use in place of conventional cladding. 13
As already mentioned, MEPA’s Policy and Design Guidance includes information on the use of
photovoltaic cells and a set of criteria that must be met with regard to the approval of domestic PV
systems:
• “Where there are no obstructions at ground level to the path of the sun, the PV system shall
be located at ground level where it would not have a significant visual impact.
• Where a PV system must be located on the roof of a building because of obstructions it shall:
• Not be located on the roof of a washroom, stairwell, penthouse, or other structure on
the roof
• Be sited at least 4.5 metres back from the front façade of the building
• Not exceed an overall height of 1.9 metres above the roof level
• Not more than 2.5 metres wide
• Be located where, from long range views, it is viewed against the background of an
existing structure on the roof, such as a washroom or stairwell.
• Not break or intrude into a skyline or roofscape which it is desirable to protect,
particularly within an Urban Conservation Area or other protected area”. 14
With regard to the use of PV systems on industrial buildings no guidance is contained within the
Policy and Design Guidance document, however the Malta Structure Plan encourages the provision of
multi-storey buildings for industrial use, since that is an efficient use of land and enables the
concentration of industrial uses, with consequent amenity benefits elsewhere in Malta. MEPA’ Policy
and Design Guidance states that the development of new or extended industrial buildings need to be of
an appropriate design, scale and height, especially if located near to potentially sensitive receptors
12
The Annex on Photovoltaics from the UK’s previous Planning Policy Guidance 22 entitled “Renewable Energy”, 2002
and ETSU, 1999.
13
ETSU, 1999, ETSU S/P2/00304/REP 1999 “Photovoltaics in Buildings: Town Planning Considerations”, ETSU, Harwell,
UK p. 11.
14
MEPA January 2004, Policy and Design Guidance produced in 2004 to promote the creation of high quality residential
developments, Pgs 100-101.
33
such as residential areas. Such principles are likely to also apply to the introduction of PV systems on
industrial buildings.
As with micro-wind, the criteria included in Appendix Three of MEPA’s Policy and Design Guidance
could be used as the basis for an economic threshold to consider renewable options like PV generation
for any new built developments.
(ii) PV Systems and Building Roofs
The installation of PV systems on the roofs of buildings has a number of advantages, including:
• A roof is often an under utilised part of a buildings structure, flat roofs, roof slopes on the
rear of buildings and the saw tooth pattern of roofs often found on industrial buildings all
present opportunities to employ PV electricity generation.
• Roof mounted PV systems will generally be safe from accidental damage or vandalism.
• Due to their higher position, roof mounted PV modules may be less prone to overshadowing
from nearby buildings and vegetation, as well as being less susceptible to overshadowing
from any future adjacent developments.
• The roof void inside a building may be suited for housing associated PV equipment therefore
reducing the visual clutter on any external roof structure. 13
With regard to the introduction of PV modules on buildings the Gozo and Comino Local Plan states
that “proposals for the generation of power from solar energy through the utilization of large surfaces
on existing permitted buildings (e.g. factories), will be given favourable consideration in areas
earmarked for industry but measures to mitigate against visual impact shall be incorporated in the
design of the generating scheme …”. The Gozo and Comino Local Plan goes on to state that “… there
is scope for supplementing the national grid through solar collection panel on the roofs of factories at
Xewkija industrial estate”. 15
By implication this may mean that PV applications on non-industrial areas will not be welcomed. If
this same view is adopted across Malta then the opportunities for PV applications may become
seriously constrained from a planning perspective.
(iii) PV Systems and Building Walls and Windows
Building walls and windows offer an additional opportunity for introducing PV modules, especially to
new buildings. As building walls often incorporate glazing, the reflective top-surface of PV materials
can often appear less unusual. Indeed, if the units are “flush fitted and colour matched with adjacent
glazing, it might not even be evident that the building is fitted with the technology”. 13
However, wall mounted PV modules may be prone to vandalism, accidental damage or

overshadowing from vegetation and adjacent buildings.
15
Policy GZ-UTIL-4 of the Gozo and Comino Local Plan, p. 62.
34
(iv) PV Systems and Buildings of Historic Value
Installation of a PV array on a building listed for its special architectural merit or historic interest - or
on another building or structure in its curtilage - could be seen as an unacceptable alteration of the
building's character. In such situations, MEPA should assess each case on its merits.
While there is a massive PV resource potential there appear to be a number of planning barriers to the
installation of PV units on domestic rooftops. Industrial rooftops, however, may prove to be an area
where the planning requirements are less onerous and where reasonable track record can be gained and
maintained.
(v) Potential Changes in MEPA’s Planning Conditions
Since the publication of Policy and Design Guidance 2004, and due to various complaints resulting
from their implementation, MEPA are proposing amendments to the criteria for siting PV systems.
These revisions still await Ministerial approval and they are as follows:
MEPA will positively encourage the provision of photovoltaic (PV) modules (solar modules).
These can be integrated in the building envelope or mounted on separate dedicated supports
(stand-off arrays). Stand-off arrays can be placed on existing roofs without any structural
alterations. These arrays are generally light and mounted on free-standing frames, which can be
tilted and rotated to the most suitable orientation and pitch according to site’s location and seasonal
variation to maximise collection. The areas required for solar electricity generation are larger
than for solar water heater, although the arrays are likely to have less visual impact because of
the absence of a water tank and their smaller bulk.
Solar Modules integrated into the building fabric or envelope are likely to be generally
acceptable where they would not adversely affect the character or appearance of an historic
building or area (particularly UCAs) or elsewhere have an adverse impact on the townscape.
The Malta Environment and Planning Authority will encourage the provision of photovoltaic
solar modules
(1) within the curtilage of buildings – provided they would not have a significant visual impact;
(2) on the roofs of buildings provided that the requirements of policy 13.5 relating to services
on roof structures are adhered to.
(3) within the fabric of a building - the Authority will have regard to:
(a) the overall visual impact of the installation on the building;
(b) the relationship of the installation with the overall design of the building and the extent
to which it has been satisfactorily integrated into that design;
(c) the overall visual impact of the installation on the site and its surroundings;
(d) the orientation of the building and associated requirements on PV systems;
35
(e) the materials proposed to be used and will generally grant permission provided
that the installation does not have an adverse impact on the appearance of the building or of
the area. 16
The language of these revisions embodies more willingness to accept PV installations, particularly
those integrated in to buildings. Nevertheless, there are quite vague in their formulation which means
that their effectives at removing planning barriers will not really be known until applications are filed
D.1 Planning Barriers Removal
Throughout this section a number of issues have been highlighted that either individually or
collectively form potential barriers to the exploitation of renewable electricity sources in Malta. Many
of these barriers are, however, not unique to Malta and have or are being experience in other parts of
the world. As such there are some recommendations that can be made which could assist in the
minimisation and where possible removal of some of the planning barriers. Due to similarities with
the UK planning system UK experience and a number of UK based measures have been considered as
potential learning opportunities for Malta.
D.1.1 UK Developments
Planning consent is the key permit required, in the UK, for any form of renewable energy development
to proceed, and planning applications are assessed against a set of policies at national, regional, county
and ultimately local level. Planning Policy Statement (PPS) 22 in England and National Planning
Policy Guidance note (NPPG) 6 and the associated Planning Advice Note (PAN) 45 in Scotland sets
out national planning policy against which the lower tiers of tiers of plans from regional to local level
must conform.
PPS 22 entitled “Renewable Energy” (August 2004) replaces the former Planning Policy Guidance
Note 22 (PPG22) issued in 1993, and the photovoltaics annex issued in 2002. PPS’s sets out the UK
Government’s national policies for different aspects of land use planning in England. The renewable
energy policies included in PPS 22 need to be taken into account by regional planning bodies
throughout England in the preparation of regional plans and spatial strategies and by local planning
authorities in the preparation of local plans and development documents. In the UK system PPS 22
may also be material to decisions on individual planning applications.
PPS 22 was developed within the context of the UK Governments Energy White Paper produced in
February 2003. The aim of the White Paper is to “put the UK on a path to cut its carbon dioxide
emissions by some 60% by 2050, with real progress by 2020, and to maintain reliable and competitive
energy supplies” (PPS 22, p.4). The PPS goes on to state that the “development of renewable energy
… will make a vital contribution to these aims. The Government has already set a target to generate
10% of UK electricity from renewable energy sources by 2010” (PPS 22, p.4).
PPS 22 notes that a positive planning policy framework which facilitates renewable energy
developments can also contribute to sustainable development, through:
• social progress which recognises the needs of everyone
16
Communication from MRA, 15th March 2005.
36
• effective protection of the environment

• prudent use of natural resources
• maintenance of high and stable levels of economic growth and employment.
The PPS identifies eight key objectives that should be applied to renewable energy projects through
England to ensure that such developments are appropriately developed and that any environmental,
economic and social impacts can be adequately addressed. A particular reference is made to the
benefits of micro-generation and the it is stated that planning authorities should not “reject planning
applications simply because the level of output is small” (p. 5).
Within a Scottish context national planning policy is contained with NPPG 6 (2000) entitled
“Renewable Energy Developments” and the associated PAN 45 (January 2002) entitled “Renewable
Energy Technology”. NPPGs provide statements of Scottish Executive policy on nationally important
land use and other planning matters, supported where appropriate by a locational framework. PANs
are used to provide advice on good practice and other relevant information. Statements of Scottish
Executive policy contained in NPPGs are material considerations to be taken into account in Scottish
Local Authorities in the preparation of development plans and development control decisions.
Encouraging more electricity generation from renewable sources is an integral part of both the UK and
Scottish Climate Change Programmes and through the publication of NPPG 6 and PAN 45 the
Scottish Executive has demonstrated a commitment to increasing the amount of renewable energy
generated and used in Scotland. NPPG 6 has been developed against a background of the UK
Government's energy policy and within it, the policy for renewables. The NPPG is used to “define the
factors to which Scottish Ministers will have regard when considering policies for renewable energy
developments in development plans, and when considering applications for planning permission which
come before them on appeal or call-in. Likewise, it indicates the considerations which planning
authorities should take into account when drawing-up policies in structure and local plans and when
determining planning applications” (NPPG 6, para 16).
NPPG 6 makes a series of strong planning policy statements which support the need for renewable
energy and recognise the benefits for the Scottish economy. Within the context NPPG 6 states that the
Scottish planning system should:
• facilitate and guide renewable energy developments through up-to-date structure and local
plans
• ensure that development control decisions are taken efficiently, consistent with national and
international climate change policy commitments and obligations
• prevent the unnecessary sterilisation of renewable energy resources, while at the same time:
meeting the international and national statutory obligations to protect designated areas,
species and habitats of natural heritage interest and the historic environment from
inappropriate forms of development; and minimising the effects on local communities
(NPPG , 2000).
In support of NPPG 6 the purpose of PAN 45 is to provide more detailed technical information and
environmental planning advice on the technologies for harnessing renewable energy for electricity
generation, including wind energy.
Research published by the British Wind Energy Association (BWEA) in November 2003 has
identified a difference between planning approval rates for wind farm development between countries
37
in the UK. The BWEA found that over a 5 year period between 1999 and 2003 England has had an
average approval rate at local level of just 50% compared to 94% in Scotland. The BWEA believed
that “This is testament to the strong policy guidance set out in NPPG6 in Scotland in 2000, and to the
commitment of the Scottish Executive who recognise both the need for renewable energy generation,
and the benefits for the Scottish economy in creating a new and vibrant renewables industry” (BWEA,
November 2003).
In addition to the problems of differences in planning approval rates for wind farm development
between countries in the UK, there is a issue of timescales. Within the UK town planning system most
infrastructure developments which would require an EIA should take approximately 16 weeks for a
local authority to reach a decision. However, research by the BWEA has found that the average wait
is almost a year and when planning gain legal agreements and final consent is considered this
increases to approximately 18 months. In Wales and Northern Ireland the average wait is 2 years and
approximately 3 years respectively for the local authority to make a decision (BWEA, August 2004).
The BWEA believes that “the planning process [in the UK] is still clearly taking much longer than it
should, and it is only one stage of the development process – there are numerous post-planning delays
and barriers, such as concluding agreements with the landowner, grid connection and construction
contracts. Post-consent barriers can add an additional 1 or 2 years to the project duration” (BWEA,
August 2004). This difference in approval rates and timescales throughout the UK has historically led
to uncertainty for private sector wind energy developers and ultimately may even pose a threat to the
UK Government’s renewable energy targets.
D.1.2 Potential Recommendations for Malta
Traditional sources of electricity production, including the burning of fossil fuels can produce a
plethora of environmental impacts. These impacts are of a larger magnitude and a different quality
from the possible negative effects consequent upon the introduction of wind power technology.
Planning authorities throughout Europe have over the past 10 years grappled to strike an equitable
balance between the global environmental benefits of an energy source which does not contribute to
global warming and the need to limit localised environmental concerns including visual intrusion and
noise impact. Nevertheless, these possible impacts can be ameliorated through the implementation of
good planning policy and practice. Suggested policy mechanisms for Malta include:
• Information concerning the environmental benefits as well as disadvantages (such as issues
of intervisibility and cumulative impact) of wind energy technology should be introduced
into the Maltese planning policy framework, to enable MEPA, other interested stakeholders
and the general public form a balanced view of the situation. Reporting and educating on the
positive elements of a project in addition to the impacts can alleviate concerns.
• When assessing proposals for renewable energy in general and wind energy in particular, the
wider environmental and socio-economic benefits are material considerations that should be
given significant weight in determining whether proposals should be granted planning
permission.
• MEPA and the various local authorities should where possible attempt to accommodate
renewable energy developments and that the Maltese Structure Plan and the various Local
Plans should contain criteria based policies designed to ‘promote and encourage’, rather than
restrict, the development of renewable energy resources such as micro generation wind
turbines, PV systems or large scale onshore wind energy schemes.
38
• Island wide renewable energy targets should be introduced into the Maltese Structure Plan as
minimum targets to be monitored and increased if and when they are met.
• MEPA should where applicable foster community involvement in renewable energy projects
and seek to promote knowledge of and greater acceptance by the public of prospective
renewable energy developments, from the micro-generation level upwards, that are
appropriately located. Public opinion is likely to be more favourable if MEPA and the
developer provides information and consults with the local community. Such a process can
give the community a sense of ‘ownership’ which may ameliorate, or perhaps solve, many of
the possible problems that arise. Such education processes could include visualisation work
for large scale projects in order to increase exposure and understanding of renewables.
Education and monitoring should include pre-construction, during construction and
post-construction to foster involvement and ownership and monitor/mitigate impacts.
• Continuing Professional Development (CPD) regarding wind energy is recommended for all
MEPA planning officials and statutory consultees. It is clear that interest in wind energy and
other forms of renewable energy production from the private sector is rapidly increasing in
Malta. However it is likely that many of the planning officers in MEPA and other statutory
consultees have had little practical experience of wind energy planning applications.
• Amendment to planning guidance and regulations to require the inclusion of renewable
energy considerations during design and build of new buildings can assist in the penetration
of some renewable technologies such as PV. Amendments to the buildings control
guidelines to include the safe installation of renewable electricity schemes on buildings. The
development of renewable electricity planning guidance at the policy level but also targeted
on specific areas of protection such as listed buildings and conservation areas. All of these
elements will add to the suite of measures available to the planners and may assist in the
penetration of renewable electricity projects.
The continued involvement, consultation and education of the public in conjunction with the sensitive
siting of developments by the wind energy industry is vital, especially while it is still a fledgling
industry in Malta. At the same time the Maltese Authorities must realise that the development of
environmentally benign energy sources including wind power will contribute towards a reduction in
the dependency upon finite fossil fuel reserves and the production of greenhouse gas emissions.
In the future, two alternatives can be pursed. We can preserve the countryside in its present state,
through the continued reliance upon traditional sources of energy generation, which are
environmentally damaging and unsustainable. Alternatively, we can attempt to protect the global
environment by utilising a greater amount and variety of renewable energy resources, including wind
energy. While simultaneously accepting that aspects of the Maltese countryside’s appearance may
have to change to accommodate these new energy sources. What is clear in Malta is that some
difficult choices will have to be made with regards to renewable electricity.
39
Annex E Legislative Review
Annex E
Legislative Review

Isabel Philip
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List of Contents
Annex E Legislative Review 1

E.1 Introduction 1
E.2 EU Directives relating to Energy 1
E.2.1 Directive 2001/77/EC 2
(i) Indicative Targets 2
(ii) Support Systems 3
(iii) Guarantees of Origin 3
(iv) Administrative Matters 3
(v) Costs and Fees 4
(i) Public Obligations 4
(ii) Generation Plants 5
(iii) Transmission and Distribution 5
(iv) Access to the Market 6
(v) Direct Lines 6
(vi) Competition Issues 6
(vii) Competent Authority 6
(viii) Derogations 7
E.3 EU Directives and Malta’s International Obligations relating to the Environment 7
E.3.1 Introduction 7
E.3.5 Directive 85/337/EC as amended 10
E.3.6 Climate Change 11
E.4 National Legislation 12
E.4.1 Malta Resources Authority Act 12
(i) LN 186/04 13
(ii) LN 511/04 14
E.4.2 Enemalta Act 16
E.4.3 Environment Protection Act (EPA) 16
(i) LN 329/02 17
(ii) LN 216/01 18
(iii) LN 204/01 18
(iv) LN 230/2004 19
E.4.4 Land Issues 22
(i) Land Acquisition Act 22
(ii) Disposal of Government Land Act 23
E.5 Legislative Barriers 23
E.5.1 Outstanding Issues 24
E.5.2 Non Transposed Obligations 25
E.5.3 Land Issues 26
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E.1 Introduction
As part of this project, Mott MacDonald, with the assistance of the AVMT Advocates, provides
recommendations on the legal framework required to enable the generation of electricity from
renewable energy sources in compliance with and within the parameters of Malta’s EU membership. 1
This annex provides a review of the current legislative framework in Malta and identifies gaps that
need to be addressed relating to renewable electricity resources. In addition, this report forms the basis
for the legal recommendations that will be made during phase II and phase III of the project.
This annex contains the following:

• Section E.2: EU Directives relating to energy. This provides a review of the obligations
placed on Malta that stem from its EU membership regarding electricity generation,
distribution and supply from renewable energy resources.
• Section E.3: EU Directives and Malta’s international obligations relating to the environment.
This provides a review of the international legislation that is relevant to Malta within the
context of promoting renewable energy sources for the generation of electricity.
• Section E.4: National Legislation This section reviews the current legislative framework in
Malta within which renewable energy needs to be incorporated.
• Section E.5: Legislative Barriers. The comparison and contrasting of sections E.2, E.3 and
E.4 leads to the conclusions in section E.5. Section E.5 considers the regulations, measures
and criteria that are still required for the liberalisation of the electricity sector (specific to the
exploitation of renewables) and the promotion of electricity generation from renewable
energy sources (RES). It also highlights any other legislative barriers that may be present.
E.2 EU Directives relating to Energy
This section reviews the obligations placed on Malta that stem from its EU membership regarding
electricity generation, distribution and supply from renewable energy resources.
The EU Directives that are of interest to this study are those that promote electricity generated from
renewable energy sources and those that deal with the creation of the European internal market for
energy. The liberalisation of the energy sector is important because its transposition into Maltese Law
will create a new framework within which new generation capacity (including renewables) will
operate and gain access to the distribution networks.
1
A.1.1 Renewable energy sources are defined in EU Directive 2001/77 to include: wind, solar, geothermal, wave, tidal,
hydro power, biomass, landfill, gas, sewage treatment plant gas and biogases.
S-1
F:\PROJECTS\206106 Malta\Phase 1 deliverables\Phase 1 report\Final Report\Final Report Annex E - Legal.doc
By way of summary, as a result of the transposition of the relevant EU legislation, Malta should have a
legal regime for renewables that:
• encourages the use of electricity produced from renewable energy sources in accordance
with national targets that it is obliged to review from time to time
• regulates the guarantees of origin for electricity produced from renewable energy sources
• guarantees distribution of electricity from renewable energy sources and ensures
non-discriminatory access to the networks
• sets out procedures based on objective transparent and non-discriminatory criteria for
construction of new renewable generation capacity.
The two EU Directives that are reviewed in this section are:

• Council Directive 2001/77/EC of 27th September, 2001 on the promotion of electricity
produced from renewable energy sources in the internal electricity market (Directive
2001/77)
• Council Directive 2003/54/EC of the 26th June, 2003 concerning common rules for the
internal market in the electricity (Directive 2003/54), which repealed Council Directive
96/92/EC of 27th December, 1996 (Directive 96/62).
E.2.1 Directive 2001/77/EC
Directive 2001/77 aims at promoting an increase in the contribution of renewable energy sources to
electricity production in the European internal market for electricity, and to create a basis for a future
Community framework thereof.
The elements of the Directive most relevant to this study are summarised below and discussed in the
following sections:
• indicative targets
• support mechanisms
• guarantees of origin
• administrative matters
• costs and fees regarding electricity produced from renewable energy sources.
(i) Indicative Targets
Under Directive 2001/77 Malta is obliged to encourage the use of renewables in generation of
electricity by setting indicative targets for the consumption of electricity produced from renewable
energy sources. The targets need to be reviewed, the success in achieving them assessed and reports
submitted to the Commission periodically. Such assessments would include analyses of barriers to the
promotion of renewables and actions that must be completed in order to remove such barriers.
The Commission has the right to impose mandatory targets if Malta has unjustifiably failed to achieve
its national indicative targets.
2
(ii) Support Systems
The Directive allows for the establishment of support systems to encourage the realisation of
renewable electricity sources in each Member State. It is the responsibility of each Member State to
evaluate, design and implement the necessary support systems although the Directive does not specify
the nature of such support mechanisms. The Directive does, however, indicate that the European
Commission will review the different mechanisms used across Member States, their success and cost
effectiveness and will present its report by not later than 27th October 2005. Based on this evaluation,
the Commission will, if necessary, make proposals for a Community framework on support schemes
for electricity produced from renewable energy that takes account of the following, amongst others:
• the achievement of national indicative targets
• the need to encourage investors
• the compatibility with the internal electricity market of the measures proposed.
This means that the support mechanisms implemented in Malta will be under scrutiny by the
Commission and may require revision based on the results of the Commission’s evaluation. If
possible, Malta’s choice of support measures for RES should take into account any developments in
the Commission’s stance on renewable support policy, which might indicate the direction of energy
policy harmonisation in a Community framework.
(iii) Guarantees of Origin
Under the Directive, renewable energy generators need to obtain a certificate that demonstrates that
the electricity is produced from renewable energy sources. In this respect, Malta must appoint a
competent body, independent of generation and distribution activities, that establishes objective,
transparent and non-discriminatory criteria to issue the guarantees of origin. In pursuant of this clause,
the only renewable generators that will receive financial support (if appropriate) and contribute to
achieving the Maltese renewable target will be those that are adequately certified.
Certificates of origin will be recognised throughout the European Community. This means that
Maltese renewable generators may be able to trade across Europe if Malta establishes an
interconnector with mainland Europe in the future.
(iv) Administrative Matters
As a result of Directive 2001/77, Malta is obliged to evaluate existing legislation to:

• reduce regulatory and non-regulatory barriers to generating electricity from renewable
energy sources
• expedite administrative procedures
• ensure that all rules are objective, transparent and non-discriminatory.
3
(v) Costs and Fees
Under the Directive, the Government of Malta is obliged to ensure that the owner and operator of the
electricity transmission and distribution system:
• guarantees the transmission and distribution of electricity produced from renewable energy
sources
• sets up and publishes the rules for bearing the costs of integrating renewable generators into
the grid
• provides a comprehensive and detailed estimate of connection costs to any renewable
generator wishing to be connected to the grid
• sets up and publishes rules relating to sharing system costs between all producers
Directive 96/92 is aimed at introducing competition in the electricity sectors across Member States
creating a European internal electricity market. The Directive established rules relating to the
organisation and functioning of the electricity sector, access to the market, the introduction of new
capacity and the operation of the system. The effectiveness of the Directive was assessed by the
Commission and as a result Directive 96/92 was repealed by Directive 2003/54. Directive 2003/54
covers the same areas but it is designed to promote liberalisation further by clarifying some of the
rules and through setting targets for the opening of markets to supply competition.
The most relevant elements of the Directive are summarised below and discussed in the following
sections:
• public obligations
• procedures for ensuring that new generation capacity is built
• responsibilities for transmission and distribution
• third party access to the networks
• direct lines
• competition issues
• establishment of an industry regulator
• Malta’s derogations.
(i) Public Obligations
Directive 2003/54 allows for Member States to impose public sector obligations on economic
undertakings. These are to be defined by Member States and must be transparent, non-discriminatory
and verifiable. This means that ensuring that a percentage of the electricity generated in Malta comes
from renewables sources could be promoted in the country’s public interest.
4
Directive 2003/54 also requires Member States to ensure that they provide universal supply to all
household customers and small enterprises at reasonable, clearly comparable and transparent prices.
Therefore consumers which have renewables fitted to their premises cannot be refused a connection to
the grid subject to network capacity availability and compliance with the Grid Code.
(ii) Generation Plants
Pursuant to Directive 2003/54, new capacity must enter the system via an authorisation procedure.
Authorisations can be granted or refused based on objective, transparent an non-discriminatory certain
criteria and applicants can appeal in the case of refusal. Where the authorisation procedure is not
sufficient to ensure security of supply or is not in the interest of environmental protection and the
promotion of infant new technologies, Member States can adopt a tendering procedure. Member States
must designate an independent authority responsible for the organisation, monitoring and control of
such tendering procedures.
This means that new renewable generators may enter the market by obtaining an authorisation granted
by the relevant authority. New renewable capacity could also be introduced in Malta as a result of a
call for tenders based on the need to protect the environment and/or promote new technologies.
(iii) Transmission and Distribution
Pursuant to Directive 2003/54, Member States need to designate a transmission system operator for
operating, maintaining and developing the transmission system and any interconnections to guarantee
security of supply. Member States also need to designate a distribution system operator for operating,
ensuring the maintenance of and developing the distribution system. 1
The Directive imposes certain responsibilities on these operators. The most relevant to this study
include:
• ensuring that generating installations using renewable energy sources are given priority
dispatch when producing electricity
• providing sufficient information for efficient and non-discriminatory network access to
users, i.e. large and small renewable generators
• establishing network access tariffs to be paid by renewable generators that are applied in a
non-discriminatory basis.
In the case of Malta, the network system is small and as there is no transport of electricity at voltages
higher than 132 kV. Malta will only need to designate a distribution system operator that is
independent from other activities not relating to distribution system operations.
Currently the Enemalta Corporation (Enemalta) is the owner and operator of the electricity distribution
network but it also provides generation and supply of electricity. In this case, the Directive dictates
that the operator ensures that the supply and distribution functions are kept independent one from the
1
A.1.2 Transmission refers to systems that transport electricity on high-voltage (>132 kV) interconnected systems with
a view to delivering to final customers or distributors. Distribution companies are those that transport electricity
on medium and low voltage systems (132 kV, 66kV, 33kV, 11kV) with a view to delivering it to customers.
5
other in form, organisation and decision making. Directive 2003/54 sets down minimum criteria to
ensure such independence.
(iv) Access to the Market
Directive 2003/54 promotes non-discriminatory third party access (TPA) to the electricity networks as
a key requisite for opening electricity markets to competition.
Under the Directive , TPA is only allowed on published tariffs, applicable to all eligible customers and
applied objectively and without discrimination between system users. From 1st of July 2007 eligible
customers will include domestic users effectively opening the market to full supply competition.
An operator may refuse access where it lacks the necessary capacity but shall give substantiated
reasons for such refusal. Member States on the other hand are obliged to ensure that the operator
provides information on measures to be taken to reinforce a network where access is refused.
(v) Direct Lines
Under Directive 2003/54, electricity generators and suppliers are allowed to set up direct lines
complimentary to the interconnected system. This means that if network capacity is not available and
this signifies a delay in a project, project developers including renewable generators, could chose to
build their own lines.
(vi) Competition Issues
Under Directive 2003/54 Member States are required to ensure the creation of appropriate and
efficient mechanisms for regulation, control and transparency so as to avoid abuse of any dominant
positions or any predatory behavior. This should safeguard the position of new renewable generators
in Malta as they will be new entrants in a market dominated by one larger player, Enemalta.
(vii) Competent Authority
Directive 2003/54 obliges Member States to appoint a competent body which shall be independent of
electricity undertakings and shall be responsible for ensuring non-discrimination, effective
competition and efficient functioning of the market. Amongst its more important functions such
regulatory authority shall undertake the following:
• approve or fix tariffs or methodologies for fixing tariffs for connection and access to national
networks
• ensure the monitoring of security of supply, in particular the supply/demand balance on the
national market, the level of expected future demand and envisaged additional capacity
being planned or under construction
• ensure that technical safety criteria are defined and minimum technical design and
operational requirements are developed
• guarantee that terms, conditions and tariffs for connecting new producers of electricity are
objective and non discriminatory whilst taking full account of renewable energy sources
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• promote effective unbundling of accounts

• establish mechanisms to deal with congested capacity within the national system.
(viii) Derogations
Member States may apply for derogations from certain Chapters of Directive 2003/54 if they have a
micro-isolated system or a small-isolated system.1 This is an extremely crucial issue for Malta.
During negotiation proceedings prior to its accession to the EU, Malta claimed that it falls within the
description of a small isolated system because of its size and isolation, its low level of consumption
and the fact that it will not be feasible for it to split the transmission and distribution functions. The
main issues for Malta in this respect relate to:
(a) the establishing of a transmission system operator, since Malta’s electricity system has little
transmission
(b) the single buyer concept, since Malta would like to retain this.
Negotiations with the EU are still going on and the matter relating to derogations has not yet been
decided. In principle however the EU does appreciate that there is no need to have a transmission
system operator.
E.3 EU Directives and Malta’s International Obligations relating to the

Environment
E.3.1 Introduction
The importance of considering selected environmental legislation and obligations and their potential
impacts, either direct or indirect, on electricity generation/markets in Malta is a key element of
considering the potential exploitation of renewable sources in Malta. It is noted that there are a
number of pieces of environmental legislation relating to waste, waste disposal and the recovery of
energy from such processes. As waste is beyond the scope of this assessment and subject to a separate
study these are not included in this Annex.
The environmental legislation covered in this review deals with the following:
• control framework; Council Directive 96/61/EC on Integrated Pollution Prevention and

Control (IPPC)
• tightening emissions from combustion plants operating within the energy sector; Council
Directive 2001/80/EC of 23rd October 2001 on the limitation of emissions of certain
pollutants into the air from large combustion plants
• improving air quality and management; Council Directive 96/62/EC of 27th September 1996
on ambient air quality assessment and management and its subsequent Daughter Directives
1
A.1.3 Small isolated systems refer to any system with consumption of less than 3000 GWH in the year 1996, where
less than 5 percent of annual consumption is obtained through interconnection with other systems.
7
• reducing environmental impact of projects; Council Directives 85/337/EEC (as amended) on

environmental impact assessment
• combating climate change; Protocol to the United Nations Framework Convention on

Climate Change (UNFCCC), Council Directive 2003/87/EC on greenhouse gas allowance
emissions trading.
These regulations are relevant to this study because:

• their implementation is likely to result in emissions restrictions increased costs of
conventional generation and thus make electricity generation from renewable sources more
cost-competitive
• they set emission limits that plants fuelled by certain renewable sources such as biomass will
need to comply with
• they dictate that the environmental impact of renewable electricity projects need to be
assessed and therefore have the potential to restrict developments.
The Directive on Integrated Pollution Prevention and Control (IPPC) came into force on 30 October
1996 and had to be implemented by 30 October 1999 when it applied to all new installations and those
undergoing substantial change. Existing installations (i.e. operating before 31 October 1999) must
comply with the Directive by 31 October 2007 unless they undergo a substantial change prior to that
date.
The main purpose of this Directive is to “achieve integrated pollution prevention and control” from
listed activities. This is to be achieved by preventing, or where that is not practicable, reducing
emissions to air, water and land by potentially polluting industrial and other installations “so as to
achieve a high level of protection of the environment taken as a whole”.
Annex I to the Directive lists the industrial activities to which this Directive applies including, but not
limited to, energy industries in Malta. The Directive requires that each operator must apply for a
permit to operate from the Competent Environmental Authority (MEPA in Malta). The permit must
take account of the whole environmental performance of the plant and thus conditions attached to it
will relate to the operation of the plant, including:
• Emissions limit values for certain substances and preparations listed in Annex III to the
Directive based on Best Available Techniques.
• Local environmental conditions, geographical location and other technical characteristics.
• Consumption of raw materials, energy efficiency, heat noise, light and vibration, and
accident prevention.
• Waste management practices to avoid pollution following closure of the site.
The permit conditions should ensure that there will be no breach of EU environmental quality
standards or other EU legislation and ensure “a high level of protection for the environment taken as a
whole”. The permit must also contain monitoring requirements, specifying methodology and
frequency.
8
The IPPC Directive essentially sets out the framework through which environmental management of
certain specified industries can occur. When implemented by Member States the Directive must
provide the legal mechanism through which environmental enforcement can occur, including the
suspension of operation on the basis of environmental concerns.
The relevance of this Directive in Malta is that it is the mechanism through which restrictions to
operation of the energy industries in order to comply with other Environmental Directives can occur.
The Directive also legally implements the requirements for emissions trading and the declaration of
allowances equal to emissions for the applicable industries (explained further below).
Directive 96/61/EC is implemented in Malta by legal notices 234 of 2002 and 230 of 2004.
The Revised Large Combustion Plants Directive (LCPD, 2001/80/EC) applies to combustion plants
with a thermal output of greater than 50 MWth. The revised LCPD takes into account advances in
combustion and abatement technologies. It will replace the original LCPD adopted in November 1988
(88/609/EEC as amended).
The LCPD aims to reduce acidification, ground level ozone, and particles throughout Europe by
controlling emissions of sulphur dioxide (SO2), nitrogen oxides (NOx), and dust (particulate matter
(PM)) from large combustion plants (LCPs). These plants include power stations, petroleum refineries,
steelworks, and other industrial processes running on solid, liquid, or gaseous fuel.
The purpose of the LCPD reduces emissions of SO2, NOx, and dust, as these pollutants are major
contributors to acid deposition, which acidifies soils and freshwater bodies, damages plants and
aquatic habitats, and corrodes building materials. NOx reacts with volatile organic compounds in the
presence of sunlight to form ozone that can adversely affect human health and ecosystems.
The Directive applies to:

• “existing” plants, licensed prior to 1st July 1987. Member States may choose to meet the
required emissions reductions through the adoption of Emissions Limit Values (ELVs) or via
a National Plan that would set an annual national level of emissions, calculated by applying
the ELV approach to existing plants, on the basis of the plants' average actual operating
hours, fuel used, and thermal input, over the 5 years to 2000. If an operator of an existing
plant seeks to be exempt from the ELVs or inclusion in a National Plan, the operator must
submit a written declaration to the competent authority not to operate the plant for more than
20,000 operational hours starting January 2008 and ending no later than December 2015.
Marsa Power Station in Malta falls under the remit of this aspect of the Directive. The
National Emissions Reduction Plan is in its early stages of development.
• “new” plant, licensed on or after the 1st July 1987 but before 27 November 2002 and which
come into operation before 27 November 2003. These must comply with the Directive and
meet the emissions limit values from 27 November 2002. Delimara Power Station in Malta
was commissioned in 1992-1999. It is therefore a new plant under the Directive and should
comply with the emissions limit values.
9
• “new-new” plants, which are subject to request a licence on or after 27 November 2002
These must comply with the Directive and meet emissions limit values from when they are
brought into operation if the are under the remit of the Directive. Any other new combustion
plant (conventional and/or renewable) that may be constructed in the future will also be
subject to emission limits pursuant to the Directive.
The effect of this Directive is that it is likely to require additional pollution abatement and monitoring
measures to be installed on the existing power generation facilities in Malta. The effect of this may be
to cause an increase in the operating costs of a power plant which could, amongst other effects, feed
through to increased electricity prices.
Directive 96/62 defines and establishes the framework under which Daughter Directives establish
specific objectives for ambient air quality that are designed to reduce and limit effects on human
health and the environment. To date there have been three Daughter Directives (99/30/EC,
2002/31EC and 2000/69/EC) setting out the ambient air quality limits for SO2, NO2, oxides of
nitrogen, ozone, carbon monoxide and benzene.
This Directive dictates that Malta should assess ambient air quality against limit values and alert
thresholds and draw up Air Quality Action Plans indicating short term measures to be taken where
there is a risk that the limit values or alert thresholds are to be exceeded. Malta should also identify the
following:
• zones or agglomerations where pollutants are at a higher level than their limit value plus the
margin of tolerance
• areas where the limit value is not being exceeded
• zones and agglomerations where the levels of pollutants are somewhere in between the two.
This Directive impacts on renewable electricity in two ways:

• It may impose restrictions on the operation of conventional fossil-fuelled plant on the basis
of ambient air quality and thus place a premium on renewable generators.
• If biomass-fuelled renewable generators are developed in Malta, they will need to consider
how their emissions affect ambient air quality limits and Air Quality Action Plans.
Any limits imposed through other environmental legislation shall be enforced through the mechanisms
established under the IPPC Directive (outlined earlier). The effect of this Directive could be to require
alteration of the existing electricity generating plant either leading to a physical change to the plant or
an alteration to the operational regime.
E.3.5 Directive 85/337/EC as amended
Directive 85/337 as subsequently amended by other Directives including Directive 97/11/EC set out
the requirement that the environmental impacts of a project should be evaluated and minimised during
the planning phases of a project falling under the remit of the Directive.
10
The Directive lays down a minimum environment assessment framework whilst leaving details to each
individual Member State. An assessment should, as a minimum, identify, describe and evaluate the
likely significant environmental effects of implementing a project. The assessment should also
consider reasonable alternatives taking into account the objectives and geographical scope of the
project. These elements are to be summarised in a report which together with the draft proposed
project is submitted for consultation to relevant competent authorities and the public.
Such an environmental assessment should include consideration of impacts on a variety of areas

including, but not limited to: atmospheric, water, land, ecology, waste, social, landscape, visual,
cultural heritage, noise and vibration.
Once projects are developed, Member States must monitor them to ensure that any unforeseen adverse
effects to the environment are immediately detected, and that remedial action is taken.
Although project thresholds exist for many types of projects it is likely that any wind farm considered
would require a full environmental impact assessment compliant with the Maltese legislation and the
approval of MEPA. The installation of solar PV panels on domestic scale installations is unlikely to
require a full EIA although consideration of environmental impacts, particularly impacts on the
cultural and built heritage, would be required through the planning process in the evaluation of
planning permission. Should the scale of PV installation increase significantly there is the potential
for MEPA to require a full EIA to be completed.
The process of environmental impact assessment includes large elements of public consultation along
with the evaluation of environmental impacts. As such it is possible for this process to change the
design of any project, restrict the project, increase the time taken to get planning permission and
potentially prevent the project from being carried out.
E.3.6 Climate Change
In response to increasing concerns about climate change, the United Nations Framework Convention
on Climate Change (UNFCCC) was agreed at the Earth Summit in Rio de Janeiro in 1992. Under the
1992 Convention all developed countries agreed to aim at returning their greenhouse gas emissions to
1990 levels by 2000.
The 1992 Convention commitment was only a first step in the international response to climate
change. Climate prediction models showed that deeper cuts in emissions may be needed to prevent
serious interference with the climate. The Kyoto Protocol, drafted in 1997 and entering into force in
February 2005, was designed to begin addressing this issue. Under this Protocol developed countries
agreed to emissions reduction targets for a basket of six greenhouse gases (GHGs) (carbon dioxide,
methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons and sulphur hexafluoride) of 5.2 %
below 1990 levels over the period 2008-2012.
Under the Kyoto Protocol the European Community and its member states were able to agree to meet
their commitments jointly. This ‘bubble’ arrangement allowed the Community’s target (8 % below
1990 levels by 2008-2012) to be redistributed between member states to reflect their national
circumstances, requirements for economic growth, and the scope for further emission reductions and
was completed through the Burden Sharing Agreement (1998).
In 1994 Malta became a ratified member of the United Nations Framework Convention on Climate
Change and followed this by ratifying the Kyoto Protocol as a Non-Annex I country in 2001. As a
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Non-Annex I country Malta does not have any specific emissions reduction targets but is obliged to
quantify, monitor and where possible manage greenhouse gas emissions. In addition ratification of the
Protocol opens opportunity for investment to occur in Malta that could assist in reducing emissions,
such as through the flexible mechanisms.
In January 2005 the first phase of the EU Emissions Trading Scheme officially started. Established
under Directive 2003/87/EC emissions trading at the European level is the largest proposed scheme of
this type covering all EU States. The Directive required each member state to establish a national
allocation plan covering the amount of emissions allowances (in tones of CO2 equivalent) that will be
issued to the relevant sectors and installations within their country. The Directive provides guidance
on this process and defines the sectors that should be included under such a plan. In Malta this
includes both of the power generation facilities. While the Maltese National Allocation Plan includes
sufficient allowances for both the generating plants it is unlikely that this will directly affect the cost
of electricity generation. However, it is anticipated that the National Allocation Plan continue into the
future and therefore there remains the potential for emissions trading to affect the bottom line of fossil
fuel electricity generating costs. Renewable energy is exempt from requiring CO2 emissions
allowances as renewables (or the renewable fraction of generation in hybrid schemes) are deemed to
be carbon neutral in their generation.
E.4 National Legislation
This section reviews how the EU Directives and other commitments relating to renewable energy have
been transposed to Maltese law by covering:
• The Malta Resources Authority Act. The Malta Resources Authority (MRA) is the body
designated to regulate the energy sector. Any entity interested in generating, distributing and
supplying electricity must be authorised by MRA.
• The Enemalta Act. Enemalta is responsible for the operation, maintenance and development
of network operations. MRA has powers to ensure Enemalta’s independence from all other
activities connected to electricity and carried out by it, and to ensure there is no
discrimination between system users. Enemalta is also appointed as the single buyer
responsible for organising access to the network subject to published tariffs.
• The Environment Protection Act (EPA) which lays down a duty on everyone including the
Government of Malta to take preventive and remedial measures to protect the environment
and manage natural resources in a sustainable manner. The EPA nominates the Malta
Environment and Planning Authority (MEPA) as the relevant competent authority and as
such responsible for environmental matters.
• Land issues. Land issues are important because problems may arise when acquiring land for
generating electricity from renewable energy sources. Land can either be acquired from
private persons or from the Government of Malta. In the latter case, this would need to be
subject to a tendering procedure or an act of Parliament.
E.4.1 Malta Resources Authority Act
The MRA was constituted on 2nd February 2001 pursuant to the Malta Resources Authority Act (the
MRA Act).
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MRA’s functions include the regulation and monitoring of all operations and activities relating to
energy. Energy includes electrical energy, fuels, heat when transmitted as a commercial activity and
energy derived from renewable sources. MRA’s energy related activities, include amongst others:
• issuing licenses for operation
• regulating the interconnectivity, transmission and distribution of energy and development

and maintenance of efficient systems
• safeguarding fair competition and security of supply
• formulating and implementing policies and strategies
• promoting, encouraging and regulating the harnessing, generation and use of all forms of
energy and incoming use of alternative sources of energy.
The MRA Act provides for the Resources Appeal Board to which any person aggrieved by a decision
of the MRA can appeal. Each party to a decision has the right to appeal to the Court of Appeal on a
point of law.
The MRA Act empowers the Minister responsible for resources to make regulations in respect of any
of MRA’s functions or for the better carrying out of the provisions of the MRA Act. The MRA Act
specifically empowers the Minister to regulate the granting, suspension, termination and renewal of
licenses, the regulation of price structures for energy, and the determination of tariffs for supply,
storage and distribution of electricity and the use of grids, and matters concerning the construction,
condition and maintenance of facilities.
Pursuant to the provisions of the MRA Act, the Resources Minister has issued subsidiary legislation
regulating the energy sector:
• Legal Notice (LN) 511 of 2004 Electricity Regulations 2004 (LN 511/04).
• Legal Notice 186 of 2004 Promotion of Electricity produced from Renewable Energy
Sources Regulations 2004 (LN 186/04).
The MRA Act has also made its own all subsidiary legislation on energy issued pursuant to the
Enemalta Act, which previously regulated the energy market. No such legislation is relevant for
purposes of this study
(i) LN 186/04
This legal notice implements Directive 2001/77 and accordingly, its purpose is to promote the
contribution of renewable energy sources to electricity production in Malta and to create a basis for
future development.
• LN 186/04 imposes the following obligations on MRA:
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• MRA must advise the Resources Minister by not later than 27th June 2005, on feasible
national indicative targets for future consumption of electricity produced from renewable
energy sources. This needs to be expressed as a percentage of electricity consumption for the
next ten years. MRA should also propose measures to achieve such national targets and to
facilitate access to the network of electricity produced from renewable energy sources.
LN186/04 establishes 5% of total consumption as the national indicative target for the
consumption of electricity form renewable sources by 2010 and indicates that MRA needs to
consider such indicative target when setting the national target. Failure to achieve the target
would need to be justified.
• MRA must report on the success in meeting the national target at frequent intervals.
• MRA is responsible for issuing guarantees of origin of electricity produced from renewable
energy sources.
• MRA must ensure that regulatory and non-regulatory barriers are reduced by expediting
procedures at an administrative level, and ensuring that procedures are objective, transparent
and non-discriminatory.
• A person interested in generating electricity from renewable energy sources requires a permit
from MRA pursuant to LN 511/04. Small scale renewable projects, less than 3.7KW, will
not require authorisation, but will require notification.
LN 186/04 imposes the following obligations on Enemalta as the network operator:

• Guaranteeing conveyance of electricity, and this with priority where requested by MRA.
• Guaranteeing priority to generating installations in so far as the national electricity system
permits, and according to criteria established in the grid code.
• Establishing with MRA’s approval costs for technical adaptations to integrate new
procedures feeding electricity from renewal energy sources into the network. The network
operator may be requested by MRA to bear such costs in full or in part.
• Providing new producers wishing to connect to the network a detailed estimate of the costs
involved.
MRA is authorised to issue compliance orders in the event that any of these regulations are breached.
Failure to abide with compliance order entitles MRA to impose penalties. A person is also guilty of a
criminal offence where such person is found to be in breach of these regulations or of a license issued
pursuant thereto.
(ii) LN 511/04
This legal notice implements Directive 2003/54. In the following section only the aspects of the
regulations that are likely to have a significant impact on the adoption of renewables are discussed.
Assessment of the aspects that relate to the overall function of the market and the overall adequacy of
the transposition of the EU Directive are not included.
Licenses
LN 511/04 stipulates that licenses to produce, distribute and supply final consumers will only be given
to Enemalta and that the only other parties that will licensed to enter the Maltese electricity system
will be those that generate electricity for their own use and for supplying Enemalta. Renewable
14
generators with a total peak generation capacity of less than 3.7kW are exempt, provided the MRA is
notified prior to construction. This means that new renewable generators with capacity greater than
3.7kW will only be allowed to either generate for their own use or to sell to Enemalta and that they
will not be able to sell electricity directly to end users. Also, LN 511/04 does not spell out an
obligation on Enemalta to buy electricity produced by others but it does place an obligation on
Enemalta to provide access to all system users unless it cannot do so on the basis of one of the grounds
provided by LN 511/04 section 17(2).
The legal notice states in clause 13(7) that the grid code is to be non-discriminatory. Section 17 states
that the distribution system operator 'shall offer' access to anybody wishing to become a system user
(and system user is persons supplying to or being supplied). The operator does not seem to have a
choice. The offer shall be based on published tariffs, the grid code (which is approved by MRA) and
directions issued by MRA. There are defined parameters pursuant to article 17(2) on the basis of
which the operator can refuse such access.
Given that the conditions for RES under the grid code and the direction issued by MRA are in place,
the system operator will not be able to refuse a producer access to the system.
Under the regulations and complying with Directive 2003/54, MRA is vested with powers to grant the
licenses, to monitor the activities of all licensees and to ensure that they conform to the conditions of
the license. The licensee has to monitor, record and maintain all information and records as prescribed
in the license. Licenses may be suspended, withdrawn or amended, should the licensee fail to abide by
the conditions. It may also be amended or revoked by MRA within certain defined parameters. It also
ceases to be valid in those cases laid out in LN 511/04.
New generation capacity
As required by Directive 2003/54, LN 511/04 indicates that new capacity will enter the market via the
authorisation procedure with MRA being responsible for granting or refusing authorisations and it also
allows for new capacity to be constructed following a tendering process. This will take place when the
authorisation procedure is not sufficient to ensure security of supply or is not in the interests of
environmental protection and the promotion of infant new technologies. This means that renewable
generators can enter the market either by obtaining an authorisation or as the result of a tendering
process. LN 511/04 provides details on how the call for tenders should take place
If renewable generation enters the market as a result of a tendering process, any contractual
obligations that stem from this process need to be considered by Enemalta when scheduling and
dispatching plant. If renewable generators (with capacity greater than 3.7 kW) enter the market via the
authorisation procedure, it is not clear in the regulations how the electricity will be taken up by
Enemalta. However, LN 186/04 does impose an obligation on an operator to give priority when
dispatching generating installations to installations generating RES. The law specifically mentions
contractual obligations regarding tendering specifications but does not exclude the authorisation
procedure, so that MRA also has the power to request Enemalta to set up such rules for those
authorised through the authorisation procedure.
Distribution system operator
Enemalta is appointed sole distribution system operator. As required by Directive 2003/54, Enemalta
must provide separate accounts for the activities relating to distribution but under LN 511/04 it is
allowed to provide consolidated accounts for other electricity activities not relating to distribution.
15
This means that it may be difficult to establish the costs of conventional generation obtain
transparency between generation and supply and ensure that there is no cross-subsidisation.
Direct Lines
LN 511/04 allows for direct lines to be constructed if access to the network is refused due to lack of
capacity. This could be an option open to renewable generators.
Grid code
Connection to the distribution network may be refused, amongst others, on the basis of a breach of the
grid code. It is important that Enemalta’s grid code does not discriminate against renewables. A draft
grid code has been produced by Enemalta which is awaiting approval by MRA. The treatment of
renewables within the code will be assessed by Mott MacDonald during the course this study.
Tariff setting and market monitoring
MRA has the responsibility for approving tariffs for connection, balancing services, supply of
electricity to final users and purchase of electricity by Enemalta. It will be important that these tariffs
do not discriminate against renewable generators. Tariffs are ultimately subject to the formal decision
of the Resources Minister.
MRA is also response to monitor the functioning of the market and ensure that Enemalta does not
abuse its dominant position and discriminate against renewable generators.
E.4.2 Enemalta Act
The key issues for this study that stem from the Enemalta Act are as follows:
Enemalta is authorised to generate, purchase, transmit, transfer, distribute and supply electrical energy
to domestic, commercial, industrial and all other purposes and accordingly its main duties include:
• The development and maintenance of an efficient electricity system.
• The construction and maintenance of the installations it operates and manages.
• The provision of harnessing, generation and use of other sources.
The Enemalta act means that independent renewable generators will depend on Enemalta to ensure
that the electricity system that delivers their electricity works adequately.
Enemalta fixes the terms and conditions, tariffs and prices. Subject to LN 511/04, these are now
subject to approval by MRA, and ultimately subject to the formal decision of the Resources Minister.
This means that the price paid for electricity paid to a renewable generator and the tariff charged to the
end user for ‘green’ electricity will be set by Enemalta and approved by MRA and ultimately subject
to the formal decision of the Resources Minister.
E.4.3 Environment Protection Act (EPA)
The EPA imposes a duty on everyone including the Government of Malta to assist in taking preventive
and remedial measures to protect the environment and manage natural resources in a sustainable
manner for the benefit of present and future generations.
16
The EPA nominates MEPA as the competent authority in matters relating to environmental protection.
MEPA is also and responsible for transposing most of the environmental directives issued by the
European Union.
The EU Directives discussed in this study have been transposed via the following secondary
legislation:
• Legal Notice 329 of 2002 on Limitations of Certain Pollutants into the Air from Large
Combustion Plants Regulations 2002 (LN 329/02)
• Legal Notice 216 of 2001, amended by Legal Notice 235 of 2004 on Ambient Air Quality
Assessment and Management Regulations 2001 (LN 216/01)1
• Legal Notice 204 of 2001 – Environmental Impact Assessment Regulations 2001 –
Development Planning Act (LN 204/01)
• Legal Notice 234 of 2002 as amended by Legal Notice 230 of 2004 - Integrated Pollution
Prevention and Control Regulations 2002 as amended by Integration Pollution Prevention
and Control (Amendment) Regulations 2004 (LN234/02)
(i) LN 329/02
LN329/02 transposes Directive 88/609 (as amended) and 2001/80 and consequently regulates large
combustion plants designed for the production of energy. As in the Directives, the legal notice makes
a distinction between existing new and ‘new new’ plants (defined in Section E.3.3).
Existing plants (licensed prior to 1st July 1987) need to comply with emission ceilings provided in the
legal notice until MEPA establishes programmes for the progressive reduction of total annual
emissions, the National Emission Reduction Plan is in early stages of drafting. The relevant ceilings
cater for reductions up to 2003 from which point onwards it appears that no new initiatives have been
taken.
Marsa Power Station is categorised as an existing plant. Measures will be taken to ensure that it
reduces its emission levels in accordance with the National Emission Reduction Plan, once in force. It
is also the intention that following 2008 and if the plant does not succeed in reducing its emissions, it
will be operated for not more than 20,000 hours and is then closed down. Directive 2001/80 allows
this through the plant adopting a limited life derogation that restricts the operating hours for the period
January 2008 to December 2015 to 20,000 hours.
For new plants, LN 329/02 makes a distinction for plants operating prior to 27 November 2003 and
those commencing operations following this date. The conditions currently attached to Delimara
Power Station are less stringent that those that will apply to new generation.
There are currently no plant qualifying, being built or planned that will as ‘new-new’ under the
directive.
Under the legal notice, MEPA is obliged to achieve further significant reductions by 1st January 2008
and for this purpose shall take measures to ensure that:
1
This legal notice implements Directive 96/62
17
• existing plants comply with emission limit values for new plants
• existing plants are subject to the emission reduction plan.
(ii) LN 216/01
MEPA has been entrusted with establishing and making public the limit values and alert thresholds for
ambient air quality and with developing criteria and techniques for measuring and assessing ambient
air quality, with respect to the pollutants dictated in the Daughter Directives of Directive 96/62.
Under LN 216/01 MEPA is bound to take measures to ensure compliance with limit values and to
ensure an integrated environmental approach which has no significant negative effects on the
environment, on the protection of health and safety of workers at work, and the environment in other
member states. For this purpose it is to draw action plans to indicate non-compliance with LN216/01,
and to recommend measures in this respect. MEPA is to draw up lists of zones and agglomerations
where levels are below limit values, where limit values plus margin of tolerance are being exceeded or
where these are somewhere in between, and is required to take action to rectify any such non-
compliance. The public is to be informed where alert thresholds are exceeded, namely levels reached
beyond which there is a risk to human health from brief exposure.
Whilst monitoring has already commenced, the current monitoring network still needs to be upgraded.
Plans and programmes required pursuant to monitoring will therefore only be drawn up when accurate
air monitoring can be carried out following the setting up of a complete network. The public will also
only start being informed once the air monitoring network is set up and reliable and correct data can
then be given. Until this occurs the powers to control power plant operation will not be enforceable.
(iii) LN 204/01
Directive 85/337, as amended has been implemented through LN 204/01.
The legal notice states that an EIA is intended to identify, describe and assess the direct and indirect
effects certain developments would have on various environmental factors. Any development falling
within the parameters of the schedule attached to the legal notice is to undergo an environment impact
assessment, this includes electric power stations, wind farms, and the transmission of electrical energy
by overhead cables.
LN 204/01 lays down the requirements for completing an EIA. This needs to include a description of
the proposed development, a description of the existing environment, an assessment of the effects of
the proposed development, including any mitigation measures and a scheme for monitoring and
managing the impacts that may arise during the construction and operational phase.
The draft EIA is submitted to all competent government departments for their comments. Once all
comments have been addressed and the report is certified by the Director of Environment and
Planning, the report is made public. The general public is then allowed to express their views at a
public hearing held for the purpose.
LN204/01 also sets up a procedure for notifying other States that may be significantly affected from an
environmental point of view by a project in Malta. MEPA shall in such cases pass reasonable
information to such states who shall also be informed on the final decision that is taken, including
reasons and considerations on which such decision is based.
18
(iv) LN 230/2004
Legal Notice 230 of 2004 entitled the ‘Integrated Pollution Prevention and Control (Amendment)
Regulations, 2004’1 amends the ‘Integrated Pollution Prevention and Control Regulations, 2002’2.
The purpose of these amending regulations is to:

• achieve a phased schedule for the implementation of the principal regulations arising from
the activities listed in Schedule 1 thereof;
• make corrections to the text of the Principal Regulations; and
• to transpose the provisions of directive 2003/35/EC.
To achieve these aims LN 230/2004 makes the following changes and additions:
• The Term “substantial change” has been widened to include the fact that “any change to or
extension of an operation shall be deeded to be substantial if the change or extension in itself
meets the thresholds, if any, set out in the Schedule 1 of these Regulations.”
• The definitions of the terms “the Public” and “the public concerned” have been added to the
Principal regulations. These terms are described as follows:
• “The Public” means one or more natural or legal persons and, in accordance with
national legislation or practice, their associations, organizations or groups.
• “the public concerned” means the public affected or likely to be affected by, or having
an interest in, the taking of a decision on the issuing or updating of a permit or of permit
conditions; for the purposes of this definition, non-governmental organizations
promoting environmental protection and meeting any requirements under national law
shall be deemed to have an interest.”
• The time limit of 31st December 2002 imposed on operators as the time limit within which
they were to apply to the Competent Authority for a permit in terms of the Principal
regulations has been extended as follows:
(i) Power plants, Shipyards by April 2004
(ii) Industry by June 2004
(iii) Waste installations by December 2004
(iv) Farms by January 2005.
• Permit application in terms of Regulation 6 of the Principal Regulations shall now also
contain “the main alternatives, if any, studied by the applicant in outline.”
1
A.1.4 The Amending Regulations
2
A.1.5 The Principal Regulations
19
• The time limit of the 31st March 2003 within which existing installations were obliged to
submit for approval by the Competent Authority a plan on how they intended to meet the
requirements imposed by the Principal Regulations has been removed.
• The Information to be exchanged between states in matters having transboundary

environmental negative effects has been defined to include all matters that under the
regulations are to be made publicly available. Any consultations in terms of the foregoing are
to be taken into consideration when the competent authority reaches a decision on the
application and shall inform the state concerned of the decision reached on the application in
question and shall make available to the public in Malta all relative information.
• The Competent Authority is obliged to make available to the public, for a period of thirty
days before the competent authority reaches its decision, applications for permits for:
• new installations;
• any substantial change in the operation of an installation; or
• for the updating of a permit or permit conditions for an installation
The purpose of this regulation is to enable the public to comment on the above. The
procedure set out in Schedule on Public Participation shall apply.
• The Competent Authority is obliged to make available to the public the content of decisions
of the competent Authority, including a copy of the permit and of any conditions and any
subsequent updates.
• The Competent Authority is obliged to make available to the public, having examined the
concerns and opinions expressed by the public concerned, the reasons and considerations on
which the decision is based, including information on the public participation process.
• The Composition of the IPPC Committee has been clarified and now is as follows:
(a) the Director of the Environment Protection Directorate of the Malta Environment
and Planning Authority or his authorized representative as Chairman;
(b) an officer being responsible for pollution prevention and control, designated by the
Chairman of the Malta Environment and Planning Authority;
(c) an officer being responsible for waste management, designated by the Chairman of
the Malta Environment and Planning Authority;
(d) an officer being responsible for land use planning, designated by the Chairman of
the Malta Environment and Planning Authority;
(e) a senior environmental health officer having experience of these issues, designated
by the Minister responsible for public health;
(f) a senior officer having experience of the management of resources, designated by
the Chairman of the Malta Resources Authority;
(g) an officer being responsible for the control of discharges into the marine
environment, designated by the Chairman of the Malta Environment and Planning
Authority;
(h) a senior public officer having experience of economic services, designated by the
Minister responsible for finance;
20
(i) a senior officer having experience of maritime affairs, designated by the Chairman
of the Malta Maritime Authority
(j) a senior officer having experience of occupational health and safety, designated by
the Chairman of the Occupational Health and Safety Authority;
(k) a senior public officer having experience of civil protection, designated by the
Minister responsible for the civil protection;
(l) a senior public officer having experience of agriculture and fisheries, designated by
the Minister responsible for agriculture and fisheries; and
(m) A senior police officer, designated by the Minister responsible for the police
• A new schedule 8 entitled Public Participation in decision-making has been included. This
sets out the following:
1. The public shall be informed (by public notices or other appropriate means such
as electronic media where available) of the following matters early in the
procedure for the taking of a decision or, at the latest, as soon as the information
can reasonably be provided:
(a) the application for a permit or, as the case may be, the proposal for the
updating of a permit or of permit conditions in accordance with regulation 9(1),
including the description of the elements listed in regulation 6(1);
(b) where applicable, the fact that a decision is subject to a national or

transboundary environmental impact assessment or to consultations between
States in accordance with regulation 8;
(c) details of the competent authorities responsible for taking the decision, those
from which relevant information can be obtained, those to which comments or
questions can be submitted, and details of the time schedule for transmitting
comments or questions;
(d) the nature of possible decisions or, where there is one, the draft decision;
(e) where applicable, the details relating to a proposal for the updating of a permit
or of permit conditions;
(f) an indication of the times and places where, or means by which, the relevant
information will be made available
(g) details of the arrangements for public participation and consultation made
pursuant to article 5 hereof.
2. The Competent Authority shall ensure that, within appropriate time-frames, the
following is made available to the public concerned:
(a) in accordance with national legislation, the main reports and advice issued to
the competent authority or authorities at the time when the public concerned were
informed in accordance with article 1 hereof;
21
(b) in accordance with the provisions of the Freedom of Access to Information on

the Environment Regulations, 2001, information other than that referred to in
article 1 hereof which is relevant for the decision in accordance with regulation 14
and which only becomes available after the time the public concerned was
informed in accordance with article 1 hereof.
3. The public concerned shall be entitled to express comments and opinions to the
competent authority before a decision is taken.
4. The results of the consultations held pursuant to this Schedule must be taken into
due account in the taking of a decision.
5. The detailed arrangements for informing the public (for example by bill posting
within a certain radius or publication in local newspapers) and consulting the
public concerned (for example by written submissions or by way of a public
inquiry) shall be determined by the Competent Authority. Reasonable time-frames
for the different phases shall be provided, allowing sufficient time for informing
the public and for the public concerned to prepare and participate effectively in
environmental decision-making subject to the provisions of this Schedule.
E.4.4 Land Issues
Land issues are important because problems may arise during the process of acquiring land for
generating electricity from renewable energy sources. Land can either be acquired from private
persons through a private transaction or expropriated by Government. In the latter case, this is subject
to the Land Acquisition (Public Purposes) Ordinance (Chapter 88 of the Laws of Malta) (the Land
Acquisition Act). Land can also be acquired that is originally owned by Government (and not
following an expropriation); such transactions are governed by the Disposal of Government Land Act.
(i) Land Acquisition Act
The Land Acquisition Act deals with the acquisition of land by the Government of Malta through the
Commissioner of Lands where such land is required for a public purpose. The definition of public
purpose found in the Act refers to any purpose connected with exclusive government use or general
use, or connected with or ancillary to the public interest or utility. The use of land or any right in
connection with the supply, storage or distribution of fuels or other sources of energy is also
considered as a public purpose. Whilst energy is considered as a form of public utility, therefore, the
wording of the law seems to limit public purpose to ‘supply, storage and distribution’ of energy
sources. Once it is established that the creation of an infrastructural project for the generation of
electricity can be classified under ‘supply, storage and distribution’, then it is probable that
expropriation for energy generation will be considered as a ‘public purpose’. The definition also states
that public purpose shall also include anything specified as public, by an enactment, but will require
specific legislation to this effect.
Land can be acquired by the Commissioner of Lands pursuant to the Land Acquisition Act by absolute
purchase or for possession and use for a stated time period or on public tenure. Land can be so
acquired on behalf of and for use of a third party, provided this is for a purpose connected with or
ancillary to the public interest. In such cases, land is acquired by absolute purchase. Prior to
acquiring any such land, it shall also be lawful for the Commissioner of Lands to enter any land and
conduct such surveys as may be required, provided certain conditions referred to in the law are
adhered to. The Land Acquisition Act also allows the Commissioner of Lands to declare clearance
22
rights and subsoil rights for a public purpose, over certain parcels of land subject to terms and
conditions laid down in the Act. Where the Commissioner of Lands declares clearance rights, no
owner shall build or erect any structure on any land declared to be so subject, or increase the height of
any existing structure without the permission of the Board established under the Land Acquisition Act.
Where the Commissioner of Lands claims subsoil rights, no owner shall make any new or extend any
existing underground work or excavations without the permission of the Board.
There is however case law to the effect that the Commissioner of Lands cannot expropriate land to
give to third parties, where third parties will utilise that land for their own commercial gain, even
though the use is one that falls within the definition of a public purpose. A more recent judgment
pronounced by the Constitutional Court in the case Mario Cutajar noe vs Commissioner of Lands does
however state that expropriation is still for the public purpose where it indirectly benefits a private
commercial company. The case did not however explicitly deal with the same set of circumstances,
since the expropriated land was not given to third parties to develop themselves commercially but was
used by Government for a public purpose. The use made by Government therefore indirectly
benefited the commercial interest of a private interest.
It is not clear whether land expropriated by government for a public purpose falls within the ambit of
the Land Acquisition Act, where such public purpose is to be pursued by a private individual intent on
making gain.
(ii) Disposal of Government Land Act
Any disposal of government property is subject to the provisions of the Disposal of Government Land
Act. Disposal is defined very widely and includes ‘any transfer or grant of any land under any title
whatsoever’.
Government property can only be disposed in one of five ways:

• by means of a tendering procedure
• in accordance with a policy applicable to the land to be disposed of and approved by a
resolution of the House of Representatives
• in accordance with a special resolution of the House of Representatives
• to a corporate body established by law subject to certain terms and conditions
• in accordance with the provisions of any other law.
E.5 Legislative Barriers
The relevant EU directives have in large been transposed to Maltese law and there is now a legal
framework designed to promote the use of renewables within the context of a new electricity market.
For example, in the last national budget the Government of Malta announced a number of measures to
start from 1st January 2005:
23
• The Government will reimburse a sum equivalent to 15.25% of the CIF (Cost Insurance
Freight) value of solar energy products purchased by households up to a maximum of Lm50.
In the budget speech no limitations were made to solar energy and therefore it does not
appear that this is limited to solar thermal (water heaters). The budget speech will however
now need to be implemented through an Act of Parliament which is not however yet in force.
The Bill preceding the act of Parliament likewise is not yet issued, so that it is not possible to
indicate yet whether this will also cover PV installations.
• Enemalta will waive the network connection fee equivalent to Lm70 for new households that
install a solar water heater. This excludes existing properties.
The following measures are already in force:

• Transitional arrangements have been agreed with Enemalta regarding small scale generation
of electricity using photovoltaic panels
• Enemalta is purchasing excess electricity generated and fed into the grid from PV
installations at the rate of 2c/kWh subject to the installation conforming to established
conditions, which currently are those referred to in the draft grid code.
Nevertheless, these actions are not enough to satisfy Malta’s obligations under the legislation
discussed in previous sections and there are a number of potential barriers that may hinder the growth
of renewables in Malta, which can be grouped into the following categories:
• Issues that remain outstanding because although European legislation has been transposed
adequately into Maltese law, the relevant measures have not yet been developed. If action is
taken within the next few months most of these barriers will disappear.
• Obligations that have not been adequately integrated into national legislation. This may be
more difficult to resolve as it may require further legislation.
• Barriers which are intrinsic to the Maltese legislative framework in the case of land
acquisition.
E.5.1 Outstanding Issues
The following issues have nee transposed into Maltese law but they have not been acted upon yet.
They need to be undertaken and developed within the next few months to avoid them acting as barriers
to the increase of renewable electricity consumption:
• MRA needs to develop the criteria for issuing and for refusing guarantees of origin and for
ensuing that they are accurate and reliable.
• A draft of the grid code is awaiting approval by MRA. It is important that the technical and
operational parameters set out in the grid code do not discriminate against renewables.
• Pursuant to LN 511/04 Enemalta, subject to approval by MRA, needs to develop criteria for
dispatch of electricity generators.
• Enemalta needs to develop, for MRA’s and the Resources Minister’s approval,
methodologies and tariffs for connection and access to the network, provision of balancing
services, supply of electricity to final consumers and purchase of electricity. It will be very
important that these tariffs do not discriminate against renewable generators.
24
• Enemalta has a dominant position in the Maltese electricity system. MRA is responsible for
ensuring that Enemalta does not abuse such dominance and discriminate against renewable
generators.
• Under Directive 2003/54 Enemalta would need to submit separate accounts for its activities
as distribution operator but it is not required by LN 511/04 to provide separate accounts for
generation and supply. This limited unbundling is not yet in place.
• MEPA has to set emission ceilings post 2003 from existing plants and to develop and
implement the National Reduction Plan for existing plants in accordance with the limits
established in Directive 2001/80. The emission limits and the National Reduction Plan will
most likely lead to the closure of Marsa Power Station, which will change the shape of the
Maltese electricity market, and could have an indirect impact on the integration of
renewables into the system by changing cost structures. This could result in increased costs
making renewable technologies more cost-competitive.
• The air quality monitoring network is not yet complete. Consequently plans and programmes
for the reduction air pollution in order to achieve the limit values can not yet be developed
and the public can not be informed until correct and reliable data is available. Until these
are established the ability of MEPA to require (through the operational permit) the power
plants to operate in a particular fashion does not exist.
E.5.2 Non Transposed Obligations
The following issues have not been transposed to Maltese law and they are potential barriers to the
development of renewables:
• Under LN 5211/04, Enemalta is the only entity that will be licensed to supply electricity to
end users. This means that new renewable generators with capacity greater than 3.7kW will
only be allowed to either generate for their own use or to sell to Enemalta. The EU requires
competition in supply but it seems that a derogation is being requested in this respect.
• There is no definition of eligible user although with only one supplier allowed, Enemalta,
there is no supply competition and therefore no need to define eligible consumers This
means that end users will not be able to choose to be supplied by a renewable generator
directly unless they become autogenerators.
• Authorisation for construction of direct lines is, according to the Directive 2003/54, subject
to objective and non-discriminatory criteria laid out by a competent authority. LN 511/04
does not make authorisation subject to such criteria
• Enemalta is exempt from payment of stamp duty which arises for example in cases of
purchases of property [section 13 of the Enemalta Act]. This may create a financial
advantage in favour of Enemalta, to which other competitors are not entitled. Any stamp
duty so paid increases costs for parties other than Enemalta
• Enemalta can request financing from the Government of Malta where this is required for the
carrying out of its obligations. Such advances are made subject to such terms and conditions
as Government deems fit. It may create a competitive disadvantage for others wishing to
compete.
25
E.5.3 Land Issues

• Unless a future developer can acquire the land voluntarily, it may prove difficult for the
Government of Malta to expropriate that land on the basis that it is intended for a public
purpose.
• Any disposal of Government owned property, whatever the title of disposal, can only be
disposed of following a tendering procedure or an Act of Parliament.
• Government land can be transferred to Enemalta without an act of Parliament or tendering
procedure because Enemalta is a corporation established by law. This again creates an unfair
advantage over other competitors in the market who may find greater difficulty in accessing
the market.
26
Annex F Technology Costs
Annex F
Technology Costs

Isabel Philip
i
F:\PROJECTS\206106 Malta\Phase 1 deliverables\Phase 1 report\Final Report\Final Report Annex F - Technology Costs.doc/
List of Contents
Annex F Project Development Costs 1

F.1 Introduction 1
F.2 Wind Turbines 1
F.2.1 Technology Overview 1
F.2.2 Market Overview 3
F.2.3 Wind Turbine Costs 4
(i) Large Onshore Wind Turbines below 1MW 4
(ii) Large Onshore Wind Turbines above 1MW 7
(iii) Offshore Wind Turbines 8
(iv) Medium Onshore Turbines 8
(v) Roof-mounted Micro Turbines 9
F.2.4 Future Wind Turbine Costs 9
F.3 Photovoltaics 10
F.3.1 Technology Overview 10
F.3.2 Market Overview 11
F.3.3 PV Project Costs 11
(i) Grid Connected Stand alone PV systems 12
(ii) Building Integrated PV (BIPV) Systems 13
F.3.4 Future PV Costs 14
Appendix I Wind Turbine Sizes 15
Appendix II Variation of Large Onshore Windfarm O&M Costs with Nominal Capacity 19
ii
Annex F Project Development Costs
F.1 Introduction
The purpose of this annex is to review the technologies under consideration in this study, namely wind
and photovoltaics (PV) and discuss the project development costs that need to be borne in the
development of the renewable strategy for Malta. These costs form the basis of the inputs to the
calculation of the renewable target, as explained in the main report for Volume 1 of this study.
The costs associated with developing wind farms and PV projects in Malta are derived by considering
the following:
• published capital costs for products presently available in the international market
• costs that are specific to Malta i.e.: land acquisition/leasing and road building
• the effect on capital costs of selling into an island, for example shipping costs for equipment.
• typical operational costs based on experience of similar international projects
• expected costs reduction in the future based on market trends.
This information is combined to provide current and estimated future (to 2020) prices per kW for
projects of varying sizes that may be developed in Malta.
F.2 Wind Turbines
This section provides a brief overview of wind technology and its market and then it presents typical
current and expected costs.
F.2.1 Technology Overview
The wind can be a complex energy resource: it is intermittent in nature and is strongly influenced by
location and topography. In addition, the amount of energy produced by a modern wind turbine is
dependent upon the strength of the wind and the area swept by the turbines rotor.
There are two basic wind turbine design configurations, depending on the axis of rotation of the drive
shaft: horizontal axis machines, similar to a traditional windmill; and vertical axis machines. More
research and development has been undertaken into horizontal axis designs which is reflected in their
use in most commercial wind farms.
A typical horizontal-axis megawatt-turbine has the following main components:

• A rotor comprising a hub at the centre of three blades
• A nacelle which holds the turbine's mechanical and electrical machinery and a control
computer. The ‘drive train’ consists of a low speed shaft attached to the rotor at one end and
the gearbox at the other; the gearbox is in turn connected via a high-speed shaft to the
generator. The nacelle is capable of yawing (turning) on a bearing at the top of the tower to
face the wind as the direction changes.

1
• A tower that supports the nacelle and rotor. This is generally made of steel, although
concrete is occasionally used. The correct height for a turbine will vary from location to
location and turbines are usually available in three or four tower-height options.
A wind energy development often also contains a wind monitoring station, which provides control
information for the site, consisting of anemometers and wind vanes mounted on a slender mast. This
data is used by an on-site computer linked to an off-site headquarters to help optimise the energy
output from the individual turbines. The electricity generated by large wind turbines is generally sent
through a transformer located at the base or inside the tower to step-up the voltage and from then
transmitted to the grid. (See Figure F-1)
Figure F-1: Wind Turbine Components

Wind Plant
Wind turbine Electrical Services

Systems
Rotor Nacelle Tower Switchgear Development Construction & Operation and

& Foundations Substation Installation Maintenance
HV Lines
Transformer
Blades Generator Ancillary Electrical Planning Transportation
Pitch control Gearbox Equipment Design Access roads
Bearings Brakes Project Management Cranes
Shaft Control & Advice Specialised vessels
Hub Instrumentation
Yaw mechanisms
Typical rotation speeds for a wind turbines rotor would be between 30 and 50 rotations per minute,
which can be easily followed by the human eye. Most grid connected wind turbines operate at a
constant speed of rotation, regardless of the wind speed, except during periods of very low or high
wind speeds, when operation will cease due to technical or safety reasons. A typical modern turbine
start rotating (‘cut-in’) when the wind speed at hub height exceeds 5 or 6 m/s and stop automatically
(‘cut-out’) when the wind speed exceeds 25 m/s. Wind turbines are available in a range of sizes,
(Table F-1) currently the largest machines available are 3.6MW and have over 100m rotor diameters
and 90m high towers. Even larger machines, up to 5 MW, are being developed for offshore
applications.
Table F-1: Wind Turbine Characteristics
Max Power Rotor Typical hub Cut-in wind Optimum Cut-out Design Life
Rating MW Diameter height speed wind speed wind speed (years)
(m) (m) (m/s) (m/s) range
(m/s)
3 MW and over 90-107 75-90 4 15 25 20-25
2 - 3 MW 66-90 57-80 3-4 13-15 25 20-25
0.5- 1 MW 27-54.5 30-74 3-4 13-15 25 20-25
< 0.1 MW 2.5-15 9-18 2.5-5 11-16 25 / none 20-25
Note: more details are included in Appendix I Wind Turbine Sizes

2
Core wind energy technology associated with onshore development is commercially proven in the
current market although development work is undertaken by some manufacturers and electric utilities
focused on cost reductions and increases in efficiency. Offshore wind technology is still to be
commercially proven although there are some operational projects and some under construction.
Research and development work continues in a number of areas such as reducing foundation and
installation costs, increasing size, turbine reliability improvements and access techniques. There is
also some research activity investigating the possibilities for novel designs such as vertical axis but in
the main, wind projects involve a large number of identical turbines which are of a standard design
and the product is turned out repeatedly.
Offshore wind is currently characterised by higher costs and technical risks. While these costs are
expected to reduce such that the cost of generating electricity from offshore wind farms becomes
comparable with onshore wind farms during the next 20 years or so, at the current time offshore wind
development requires additional financial support.
F.2.2 Market Overview
Global wind power has quadrupled in the last five years, growing from 7600 MW at the end of 1997 to
more than 31000MW at the end of 2002. Despite the growing global nature of the industry the bulk of
installations have to date taken place in four countries; Germany, Denmark, Spain and the US1. This
largely reflects the presence of effective policies supporting wind development in these countries.
At present Europe leads the wind industry (see Table F-2) and in terms of electricity generation, wind
turbines already generate 2% of European electricity, with nearly 5% in Germany and 20% in
Denmark.
Table F-2: Top 10 Manufacturers of Wind Turbines
Company Country Sales, 2001 (MW) Number of European market

employees, 2001 share (%)
Vestas‡ Denmark 1630 5500 23.3
Enercon Germany 989 4100 14.1
NEG Micon‡ Denmark 875 1805 12.5
GE Wind* US 861 1500 12.3
Gamesa Spain 649 1114 9.3
Bonus† Denmark 593 500 8.5
Nordex Denmark 461 725 6.6
MADE Spain 191 - 2.7
Mitsubishi Japan 178 - 2.5
REpower Germany 133 300 1.9
*Was Enron Wind until May 2002, † Siemens Wind Power since December 2004, ‡Vestas purchased NEG Micon in
December 2003, giving a 35% market share.
Market assessments and industry analysts indicate that Europe will be the most significant market over
the short term. The world wind energy market has been growing at an average of 32.6% over the five
1
A.1.1 Japan, the Netherlands and Italy are playing smaller but still significant roles.

3
years up to 2002. (See Table F-3) The European market grew even faster, by an average of 35% per
year, during the same period year, and could be worth €25bn by 2010.
Table F-3: Growth in the World Wind Power market 1997-2002
Year Installed capacity Increase (%) Cumulative Increase (%)

(MW) capacity (MW)
1997 1568 - 7636 -
1998 2597 66 10153 33
1999 3922 51 13932 37
2000 1195 15 18449 32
2001 6824 52 24927 35
2002 7227 6 32037 29
Average growth over 5 years 35.7 33.2
Wind Force 12, EWEA 2003a.
The turbine manufacture market has been moderately consolidated since the 1990’s and is continuing
to concentrate, as shown by the two major buyouts since December 2003, as seen in Table F-2.
Currently, 62% of market share belongs to the largest three companies, with further consolidation
expected. Current high levels of demand are further raising the market power of manufacturers, which
could slow the cost reductions up to 2020, forecast by the EWEA.
F.2.3 Wind Turbine Costs
This section evaluates the likely cost of windfarm developments within Malta on each of the potential
sites previously identified (refer to Annex B). The results of this cost evaluation feed into the
modelling process through the expected capital expenditure and operating costs. The tables and
discussion below outline the four wind energy types considered, falling into the categories of onshore
turbines below 1MW, onshore turbines above 1MW, offshore turbines and roof-mounted micro
turbines.
(i) Large Onshore Wind Turbines below 1MW
The cost and capacity estimates for this category of wind energy use the technical and economic
profile of turbine model ‘V52’, from the Danish manufacturer Vestas. These turbines each have a
nominal output of 850kW, with an assumed hub height of 50m.

4
Table F-4: Onshore Wind Turbine Costs – 850kW Turbines in eight selected sites
Gebel Qasam Ben Wardija Badja Marfa Ta' Hal Far

Cantar Ghemieri Gorg Ridge Ridge Ridge Hammud Airfield
Site capacity estimate (MW)* 16 44 32 40 36 22 24 16
Estimated Capital Cost (€) 15,219,285 40,056,366 29,565,209 37,255,764 33,471,274 20,306,738 22,171,923 14,657,063
Transport and shipping (€) 240,000 240,000 240,000 240,000 240,000 240,000 240,000 240,000
Turbine set purchase cost (€) 10,070,000 27,560,000 20,140,000 24,910,000 22,260,000 13,780,000 14,840,000 10,070,000
Contracting and Installation cost (€) 1,107,700 3,031,600 2,215,400 2,740,100 2,448,600 1,515,800 1,632,400 1,107,700
Financing and Legal cost (€) 604,200 1,653,600 1,208,400 1,494,600 1,335,600 826,800 890,400 604,200
Road construction cost (€) 333,333 250,000 312,500 833,333 833,333 208,333 416,667 0
Land purchase cost (€) 174,028 167,222 182,778 434,583 429,722 122,500 221,667 18,472
Connection to grid (€) 704,900 1,929,200 1,409,800 1,743,700 1,558,200 964,600 1,038,800 704,900
Developer's margin 1,894,494 4,976,703 3,675,072 4,635,258 4,165,478 2,524,685 2,758,430 1,821,161
Capital cost uncertainty 14% 14% 14% 14% 14% 14% 14% 14%
Annual Cost of Operation and

Maintenance (€) 240,000 660,000 480,000 600,000 540,000 330,000 360,000 240,000
O&M cost uncertainty 12% 12% 12% 12% 12% 12% 12% 12%
* Refer to Annex B for details of site capacity estimates. Prices are for 2005, except for the land purchase and road
construction costs provided by MRA, which are indicative.
The sections below explain how each of the costs categories in Table F-4 have been calculated:
Capital costs
The majority of cost estimates are based on similar wind projects within Europe, calculated on the
basis of the proportion of capital costs allocated to different project areas, as illustrated for a typical
5MW onshore project (BWEA, 2004) in Figure F-2 below. Cost estimates specific to the proposed
sites in Malta are applied for the turbine units, land purchase, road construction and shipping.
Figure F-2: Typical Capital Cost Breakdown for a 5MW Windfarm

5
• The €240,000 allocated for transport and shipping in each project case is intended to cover
loading, land transit and the charter of a heavy-loader ship for 10 days at €4,000/day. This
expenditure would, for example, allow two journeys from Denmark (where Vestas turbines
are manufactured) to Malta. Although turbine equipment for the smaller sites could be
transported in one journey, a consistent level is assumed for each site, allowing the
contractor to transport and install the turbines in two phases as they are manufactured. On
the basis of experience, ship hire itself comprises an estimated 30-40% of total shipping cost,
while the remaining 60-70% is incurred for loading, unloading and road transport to the
construction site. Total shipping costs are therefore taken as three times ship hire costs.
Total shipping costs are 1.3% of freight value, comparing well with a typical value of 1% for
power generation equipment. This analysis assumes that import duties are wavered.
• The V52 turbine set purchase cost is taken as €530,000 for the duration of 2005 and 2006.
This price is based on a quote from the manufacturer in January 2005. The assumptions
detailed here result in a turbine value that is 68% of total capital costs. Turbine expenditure
is typically between 64% and 82% of total capital costs, with BWEA online resources giving
64% as ‘typical’ for a 5MW onshore project and the EWEA (2003) giving a range of 74% to
82% for turbines of 850-1500 kW. This means the total average investment cost in Malta is
at the high end of the normal documented range, after an allowance is made for the
developer’s margin (see below).
• Contracting, electrical equipment and installation costs are typically 11% of equipment costs,
taking the midrange of data from Europe for 2001/02 (EWEA, 2003). This does not include
shipping of necessary construction and transportation equipment, which has been considered
separately above. Other than transportation and shipping, which could affect Malta
particularly as an island, midrange costs for Europe can reasonably be said to apply.
• Using the same data source as above (EWEA, 2003), financing and legal costs are typically
6% of equipment costs. This situation should apply equally to Malta as to mainland Europe.
• This study has assumed that access roads will run the full length of the windfarm site and
connect to an existing secondary road, or larger highway. Where existing roads are in place,
it is assumed these will be used and expanded where necessary. All new roads are assumed
to be 6m wide and sufficiently straight for a 30t, 60m long truck to deliver the turbines.
Prices of road construction are those supplied by MRA, of 15 Maltese Liri (Lm) per metre
squared excluding land purchase. Road construction costs are low as a percentage of total
costs when compared with typical figures for Europe (EWEA, 2003). This is considered
reasonable due to the high density and coverage of Malta's existing road network.
• Land purchase costs include the turbine foundations, the area for new access roads and the
area for ancillary equipment. This study follows current practice in Britain, where only the
land built on requires purchasing or rental, since the remainder can still be used for
agriculture. Based on available data, the land price applied is the mid-range value for
agricultural purchases supplied by MRA – Lm 7 per metre squared. Although this approach
gives a low total land cost (0.7% of total costs) in comparison with a European average (3%
of total costs; EWEA, 2003), the alternative of purchasing the total windfarm area would
increase project costs by around another 100%. This would seriously limit the potential for a
private-sector development and is not therefore considered a scenario worth further
exploration. Each turbine requires an estimated 40 metres squared of hard-standing and the
ancillary equipment is assumed to require a further 5% of the windfarm hard-standing area.

6
• The maximum distance of any potential windfarm site from a transmission line is 11km,
following roads and avoiding towns where relevant. The cost of a physical grid connection
is typically 7% of equipment costs, assuming the midrange of EWEA data (2003). This
value is applied in this study but can be considered a conservative estimate in this case, since
all the proposed sites are close to the transmission system in comparison with established
sites in Europe. Charges for 'use of system' are assumed to be zero, although this will
depend on the legislation chosen to govern Enemalta.
• A developer's margin is introduced to represent the interest of a commercial project

developer, assumed to be 15% of total project costs.
Total average cost for the windfarms, using 850kW turbines, is €920 per kilowatt installed. This is at
the low end of the typical range for installations in mainland Europe of €900-1200 (EWEA, 2003).
Capital cost uncertainty, both for the entire windfarm installation and the turbine equipment, are based
on the range of European windfarm costs given in the same data source, which gives a +/-13% cost
range on the turbine alone and +/-14% on total capital costs.
O&M costs
For onshore windfarm installations in the ‘high range’ of over 15MW, O&M Costs are taken as
€15,000 per MW installed, accurate to +/- 12%. For farms in the ‘medium range’ of 10-15MW, O&M
Costs are taken as €17,000 per MW installed, accurate to +/- 10%. For farms in the ‘low range’ of 5-
10MW, O&M Costs are taken as €21,000 per MW installed, accurate to +/- 11%. These costs are
calculated using the trendline through data from a sample of 22 existing windfarms (see 0).
Uncertainty figures represent variation of weighted average costs over a capacity range, embodied by
the trendline, rather than the full range of documented values for individual windfarms.
(ii) Large Onshore Wind Turbines above 1MW
The cost and capacity estimates for this category of wind energy use the profile of Vestas turbine
model ‘V80’, with a hub height of 70m and a nominal output of 2MW. Both capital and O&M costs
are calculated in the same way as for the lower-output 850kW onshore case detailed above.
Table F-5: Onshore Wind Turbine Costs – 2MW Turbines in eight selected sites
Gebel Qasam Ben Wardija Badja Marfa Ta' Hal Far
Cantar Ghemieri Gorg Ridge Ridge Ridge Hammud Airfield
Transport and shipping (€) 240,000 240,000 240,000 240,000 240,000 240,000 240,000 240,000
Turbine set purchase cost (€) 12,400,000 34,100,000 24,800,000 31,000,000 27,900,000 17,050,000 18,600,000 12,400,000
Contracting and Installation cost (€) 1,364,000 3,751,000 2,728,000 3,410,000 3,069,000 1,875,500 2,046,000 1,364,000
Financing and Legal cost (€) 744,000 2,046,000 1,488,000 1,860,000 1,674,000 1,023,000 1,116,000 744,000
Road construction cost (€) 333,333 250,000 312,500 833,333 833,333 208,333 416,667 0
Land purchase cost (€) 163,333 138,056 161,389 408,333 406,389 107,917 206,111 7,778
Connection to grid (€) 868,000 2,387,000 1,736,000 2,170,000 1,953,000 1,193,500 1,302,000 868,000
Developer's margin 2,305,300 6,129,908 4,496,683 5,709,250 5,160,258 3,101,288 3,421,617 2,231,967

Maintenance (€) 240,000 660,000 480,000 600,000 540,000 330,000 360,000 240,000
* Refer to Annex B for details of site capacity estimates. Prices are for 2005, except for the land purchase and road
construction costs provided by MRA, which are indicative.

7
Overall cost per kilowatt installed is €1,138 for the 2MW turbines, compared with €920 for the 850kW
turbines. The increase in cost is due to the cost of the turbine equipment itself, which is estimated at
€1,550,000 per unit for the duration of 2005 and 2006. This price is again derived from a supplier
quotation in January 2005.
(iii) Offshore Wind Turbines
The cost and capacity estimates for this category of wind energy use the profile of Vestas turbine
model ‘V90’, with a hub height of 80m and a nominal output of 3MW.
Table F-6: Offshore Wind Turbine Costs – 3MW Turbines in eight selected sites
Sikka-Il- Hamrija Secca Il Marku Madalena St. George Ghallis Il Ponta Tal-
Bajda Bank Munxar Shoal Shoals Shoals Rocks Qawra

Maintenance (€) 990,000 660,000 770,000 550,000 330,000 330,000 660,000 550,000
* Refer to Annex B for details of site capacity estimates. All prices are for 2005.
Capital Costs
Total project costs for offshore wind turbine installations are typically 30-50% higher than onshore, as
calculated by the BWEA (Parliamentary Yearbook, May 2003). The capital cost estimates for 2MW
onshore windfarms in Malta, discussed in the subsection above, result in an average cost of €1,138 per
kilowatt installed. For the purposes of this report, capital costs for offshore windfarms in Malta are
taken as 40% higher than onshore farms, based on the midrange of the BWEA statistic and putting
offshore capital cost at €1,590 per kilowatt installed. The additional capital cost uncertainty
represented by the 30-50% scale-up range are compounded with the original 14% uncertainty in
onshore project costs, giving a 20% overall capital cost uncertainty for offshore projects.
O&M Costs
There is limited data for the operating costs of offshore windfarms, particularly outside of sheltered
bay locations. A UK DTI-sponsored report by Garrad Hassan Consulting (2003) gives £70,000 per
turbine per year based on commercial sites observed in their review. O&M Cost uncertainty is
estimated at 50%, on the basis of the 'wide variance' in cost noted in the report and the limited sample.
(iv) Medium Onshore Turbines
The number of rural farmsteads available for a medium-scale wind turbine installation is estimated as
described in Annex B, for each Local Plan area. It is assumed that both 20kW and 60kW models are
from the French manufacturer Vergnet. Based on industry experience the installed cost of these
turbines is estimated at €1900/kW and annual O&M costs are 1% of the total installation cost.
Uncertainty levels are taken to be the same as for Large Onshore projects below 15MW , at +/-14% of
Capital Costs and +/-11% of O&M costs.

8
(v) Roof-mounted Micro Turbines
The number of urban rooftops available for a micro-wind turbine installation is estimated as described
in Annex B, for each Local Plan area. It is assumed that a 1kW model from the US manufacturer
Bergey is used, which would have an installed cost in the range €2200-2900 and annual O&M costs of
1% this amount, based on industry experience. A midrange installed cost level of €2500, annual
O&M costs of €25 per turbine and an uncertainty of +/-16% are therefore applied for the purposes of
this study.
Table F-7: Medium and Micro Turbine Costs – by Local Plan Area
Local Plan Area: CMLP GCLP GHLP MBLP NHLP NWLP SMLP Total
1kW
Nominal Capacity (MW)* 24.6 10.5 5.8 2.7 14.1 10.0 27.6 95.4
Capital Cost (€) 61,623,946 26,254,295 14,471,610 6,832,423 35,325,690 25,018,464 69,080,149 238,606,576
Annual O&M Cost (€) 616,239 262,543 144,716 68,324 353,257 250,185 690,801 2,386,066
20kW
Capital Cost (€) 1,902,668 3,994,680 0 1,254,000 0 12,932,087 3,197,328 23,280,762
Annual O&M Cost (€) 19,027 39,947 0 12,540 0 129,321 31,973 232,808
60kW
Capital Cost (€) 5,708,003 11,984,039 0 3,762,000 0 38,796,260 9,591,984 69,842,286
Annual O&M Cost (€) 57,080 119,840 0 37,620 0 387,963 95,920 698,423
* Refer to Annex B for details of site capacity estimates. All prices are for 2005.
F.2.4 Future Wind Turbine Costs
The project cost elements for construction of a windfarm in Malta are not expected to vary before
2020 in real terms, assuming that building materials, electrical equipment and labour costs will rise in
line with inflation. Wind Turbine equipment could, however, vary significantly in price. EWEA
forecasts (2003a) suggest an approximate fall in real costs of 3% per year, giving a 40% overall
reduction in investment costs by 2020. This forecast should be qualified by the increasing market
power of turbine manufacturer’s noted in Section F.2.2, however, as this may put a conflicting upward
pressure on ex-works turbine equipment prices.
This study applies the turbine cost reductions indicated by EWEA (2003a) only from 2010, to
represent the effect of concentration in the market over the five years from 2005. Investment costs
during the period 2003-2006 are taken as €920/kW, the level calculated above for 850kW onshore
turbines in Malta. This investment cost level conforms well to conservative data for Europe from a
separate EWEA report (2003), although it should be noted that the organisation’s two reports do differ
by around 25%.
Table F-8: Projected Investment Costs of Installed Capacity to 2020
Year Average Percentage

investment decrease (%)
(€/kW)
2003-2010 920 0
2011-2015 782 15
2016-2020 665 15
Percentage decrease taken from EWEA, 2003a and applied from 2010

9
F.3 Photovoltaics
This section provides a brief overview of PV technology and its market and then it presents typical
current and expected costs.
F.3.1 Technology Overview
Photovoltaic (PV) technology refers to the generation of electricity from sunlight. Every year the earth
receives 1700kWh1 of energy per square meter from the sun, if explored properly, PV could have a
very significant contribution in meeting the world’s future energy needs. PV systems do not produce
any of the harmful emissions emitted by fossil-fuel generation. They also have a good energy balance
with the CO2 emissions produced during manufacturing being paid back within the first three to four
years of operation.2
The most important part of PV systems are the cells, which form the basic building blocks. Modules
bring together a large number of cells and an inverter, which converts the low-voltage DC electricity
generated by the PV module, typically into 220 V alternating current (AC).
The cells are generally made of either thick crystalline silicon or thin films. The former (single of
multi-crystalline) are widely available and well understood, using technology developed by the
electronics industry. The efficiency of crystalline silicon cells is 13-16% for commercial products but
values exceeding 25% have already been achieved in laboratory situations. Thin film technology uses
layers of photosensitive materials a few microns in thickness on a low cost substrate such as glass,
stainless steel or plastic.
PV modules contain a number of PV cells joined together and sealed under a sheet of glass. (See
Figure F-3)
In Europe, PV module production remains based on crystalline silicon technologies (55% single, 26%
multi-crystalline, 19% miscellaneous other). For thin film technology to have a significant impact on
the market, it needs to reach higher efficiencies and lower costs.
Conventional PV technology is relatively mature, with research and development occurring in a range
of key areas from materials through to integration and monitoring systems. The emphasis is on
development for particular applications and in refining the cell characteristics to make the technology
cheaper or more efficient. Areas of development for particular applications include: integration of PV
within buildings, application of PV in developing countries and impacts on the electricity grid and
town planning. Those investigating the efficiency and costs of the technology are considering aspects
such as the energy intensity of the manufacturing process, cell thickness, material performance and
sustainability.
1
A.1.2 Renewable Energy In Europe, Building Markets & Capacity, EUREC Agency, London, UK, 2004, p104.
2
A.1.3 Ibid., p125.

10
F.3.2 Market Overview
Globally the PV industry has been growing rapidly over the last two decades and now has an
estimated annual market size of €4-5.5 billion. The PV market has been dominated by companies
located in countries that have strong domestic support programmes and/or high demand for PV goods.
The supply base is characterised by the presence of companies from large internationals to small
electrical installation companies. Some of the larger international companies include:
• BP Solar (mainly Australia, India, Spain, US)
• Evergreen Solar Technology (US)
• Isofoton (Spain)
• Kyocera (Japan)
• PowerLight (USA)
• RWE Schott Solar Gmbh (US and Germany)
• Sanyo (Japan)
• Sharp (Japan)
• Shell Solar, includes Siemens (US, Germany)
• Solarworld (Germany)
The manufacture of PV cells require clean rooms and high quality control, and until now it has been
largely carried out in higher cost markets such as Japan, the US and parts of Europe. Sharp, Kyocera,
Shell Solar, BP Solar account for approximately 50% of the production of cells. The process is also
subject to large economies of scale and manufacturing efficiency. Some assembly activities are being
established in China and India. Although there have been some concerns with quality control in these
facilities, it is expected that they will be overcome – achieving recognised quality certification is
critical to PV products as customers need this to qualify for subsidies in some country schemes.
Quality certificates and life guarantees are increasing in importance with many end-users identifying
them as important for purchases.
There are currently a relatively small number of recognised specialist suppliers of the various
electrical components. Batteries are required only for off-grid installations. Inverters and controllers
require high quality electronics and are currently typically sourced in Europe (or the US).
F.3.3 PV Project Costs
This study focuses on grid-connected PV installations which can be divided into stand alone and
integrated PV systems. The later are incorporated into buildings either on roofs or within facades and
are most suitable for new build where the expense of the PV system is offset by the expense of the
building.
Information was collected from various sources, as indicated in the text. These sources focussed
mainly on the American and European markets. Effort was made to use information from European
sources as much as possible but where data was not available, American sources were used as
benchmark. Figures available in US Dollars were converted to Euros using the reference exchange rate
of $1.34/€.

11
(i) Grid Connected Stand alone PV systems
The main cost components of PV systems are depicted in Figure F-3.
Figure F-3: PV Components
PV
PV Modules Balance of plant Installation Others O&M
PV Cells PV Panels Inverter Module Support Structures

Meter Builder
Electricians
PV modules are the building blocks of a PV system and consist of PV cells fitted in a frame. PV
modules need certain equipment, balance of plant (BOP), to allow the electricity they generate to be
transmitted into the building’s electricity system. The BOP elements include inverters, cables, charge
controllers and fault detectors. The BOP components usually amount to 7-12% of the total costs of a
PV system, they tend to be mature technology and have benefited from economies of scale in
manufacture (See Figure F-4).
Design and installation costs can vary significantly depending upon the location, system
requirements, labour costs etc. If a system is installed by as a Do-It-Yourself project by a house
owner/occupant, the costs incurred will be limited to the price of the mounting frame. On the other
hand, if the PV system is installed on a commercial building, these costs will be significantly higher
mainly due to the cost of the labour component.
Other costs refer to shipping costs, permit fees, administrative costs, financing costs, cost of
consultancy etc
A typical cost breakdown for a fully installed grid connected PV system is given in Figure F-4.
Figure F-4: Breakdown of PV Costs
5%
23%
PV Modules
BOS
Design & Installation
60% Other
12%
Source: This is based on figures provided in ‘Potential Costs Reductions in PV Systems’ ETS & DTI 2001 &
http://www.pvresources.com/en/economics.php

12
Table F-9 provides unit cost figures for American PV systems together with price information
acquired from European sources per peak Watt (Wp), which suggest that a grid-connected PV system
would cost around € 6.5/Wp - €7.5/Wp inclusive of all costs.1
Table F-9: Cost of PV Systems
PV Module Rated Output Cost/unit Cost/Wp €/kWh Type

(W) (€) (€)
EARTHS10-24 2000 € 12,654 € 6.327 0.388 Monocrystalline Silicon

Source: http://www.nooutage.com/SolarPVMod.htm
A study carried out by the Institute for Energy Technology, University of Malta indicates that cost of a
grid-connected 1800Wp PV system to be around €7.7/Wp. 2 This is consistent with the estimates from
other sources.
Operation and maintenance costs are estimated at between €0.01 and €0.1 per kWh of electricity
production3. A median level of €0.05 per kWh is used by this study with an uncertainty of +/-100%
applied in the model.
(ii) Building Integrated PV (BIPV) Systems
A BIPV system consists of same components as for a stand alone system but its costs are assumed to
be 30%4 lower. Reduced costs are associated with BOP equipment and installation. For example, in a
study of a PV application for commercial building facades in the United States the cost of installing a
traditional PV system was €4.35/Wp whereas the cost of a BIPV system amounted to €3.14/Wp — a
cost reduction of approximately 32%. 5
1
A.1.4 These costs are based on BP Solar estimates for Southern Europe on 13/12/04.
2
A.1.5 Iskander, C. & Sceri, E., ‘Photovoltaic Solar Energy Applications in Malta’,3rd Biennial Conference of the
Malta Council for Science and Technology, Valletta, Malta, June 1996.
3
A.1.6 Data available on www.pvresources.com/economics.
4
A.1.7 Renewable Energy In Europe, Building Markets & Capacity, EUREC Agency, London, UK, 2004.
5
A.1.8 Building Integrated Photovoltaic Systems, Guidelines for Economic Evaluation, International Energy Agency,
2002.

13
F.3.4 Future PV Costs
PV technology is relatively mature and has been characterised by steady cost reductions brought about
by incremental improvement in cell efficiency, materials and economies of scale associated with the
manufacturing processes. Reductions in manufacturing costs have been experienced at a rate of
approximately 5% for the last twenty years and it is projected to continue to fall at the same ratio for
this study period. 1
Further cost reduction for conventional PV manufacture may be restricted due to the lack of
availability of low cost constituent materials. Cost reductions are expected with further advances in
the technology and PV technology innovation, for example the developments in thin film, organic
cells or nano-rod technology, that could result in cost reductions beyond that which the current
technology could achieve. Cost reductions could also be stimulated if energy prices are inflated
through carbon taxes or if carbon prices rise.
Currently, the economics of PV installations do not allow it to compete with conventional generation
without the support provided through incentive mechanisms. As costs and incentive mechanisms
lower, the application of on-grid installations will require demonstration to increase confidence on
their financial returns.
New technologies that bring about significant cost reductions will require a period of demonstration in
order to develop a track record and make the products marketable.
1
A.1.9 Renewable Energy In Europe, Building Markets & Capacity, EUREC Agency, London, UK, 2004.

14
Appendix I Wind Turbine Sizes
RD
TH
HH
TC
RD = Rotor diameter; TH = Tip height; HH = Typical Hub height; TC = Tip clearance
Note that the sizes of the blades for each turbine are stable. The other sizes and heights (namely HH)
will vary based on site specifics. Where there are single figures given in the table this is the reference
height provided by the manufacturer. Where there is a range of heights then this approximately covers
the heights that the turbines have been installed at.
Selected Turbine Sizes

Manufacturer Name Max Power RD TH HH TC
Rating kW (m) (m) (m) (m)
3 MW and over
Bonus Energy A/S 3.6 MW 3600 107.2 143.6 90 36.4
Vestas Wind Systems A/S V90 3MW 3000 90 120 - 125 75 - 80 30 - 35
Vestas Wind Systems A/S V90 3MW 3000 90 125 80 35
2 - 3 MW
NEG Micon A/S NM 80/2750 2750 80 100 60 20
NEG Micon A/S NM 80/2750 2750 80 100 - 110 60 - 70 20 - 30
NEG Micon A/S NM 80/2750 2750 80 118 78 38
NEG Micon A/S NM 80/2750 2750 80 118 78 38
NEG Micon A/S NM 92/2750 2750 92 116 - 124 70 - 78 24 - 32

15

NEG Micon A/S NM 92/2750 2750 92 116 - 124 70 - 78 24 - 32
NEG Micon A/S NM 80/2750 2750 80 100 60 20
NEG Micon A/S NM 80/2750,
Tjæreborg 2750 80 100 60 20
NEG Micon A/S NM 80 alt. NM
80/2750 2750 80 97 57 17
NEG Micon A/S NM 92/2750 2750 92 116 70 24
NEG Micon A/S NM 80 alt. NM
80/2500 2500 80 97 57 17
Bonus Energy A/S 2.3 MW 2300 82 117 - 121 76 - 80 35 - 39
Bonus Energy A/S 2.3 MW Nysted
Havmøllepark 2300 82 111 70 29
Bonus Energy A/S 2.3 MW 2300 82.4 117.2 - 121.2 76 - 80 34.8 - 38.8
Bonus Energy A/S 2.3 MW Nysted
Havmøllepark 2300 82.4 111.2 70 28.8
Bonus Energy A/S 2.3 MW Samsø 2300 82.4 101.2 60 18.8
Bonus Energy A/S 2.3 MW 2300 82.4 120.2 79 37.8
Bonus Energy A/S 2.3 MW
Offshore 2300 82.4 106.2 65 23.8
N90 R80
Nordex LM43.8 DKC 2300 90 125 80 35
Nordex N90 Offshore 2300 90 125 80 35
Bonus Energy A/S 2MW 2000 76 108 70 32
NEG Micon A/S NM 80/2000,
Tjæreborg 2000 80 97 57 17
NM 72 alt. NM
72/2000 or NM
NEG Micon A/S 2000/72 2000 72 100 64 28
Vestas Wind Systems A/S V80 / 2.0 MW 2000 80 100 - 120 60 - 80 20 - 40
V80-2.0 MW,
Vestas Wind Systems A/S VCS Offshore 2000 80 110 70 30
Bonus Energy A/S 2 MW 2000 76 117 79 41
2 MW,
Bonus Energy A/S Ejstrupholm 2000 73.4 104.7 68 31.3
NEG Micon A/S NM 2000/72 2000 72 104 68 32
Vestas Wind Systems A/S V66-2.0 MW 2000 66 93 60 27
1 – 2 MW
NM 2000/72
NEG Micon A/S (1750 kW) 1750 72 104 68 32
Vestas Wind Systems A/S V66-1.75 MW 1750 66 93 - 100 60 - 67 27 - 34
Vestas Wind Systems A/S V66-1.75 MW 1750 66 101 68 35
Vestas Wind Systems A/S V66-1.65 MW 1650 66 79 - 100 46 - 67 13 - 34
NM 64C/ alt.
NM 64C/1500 or
NEG Micon A/S NM1500C/64 1500 64 75 - 100 43 -68 11 -- 36

16

NEG Micon A/S NM72C 1500 72 98 - 114 62 - 78 26 - 42
NM72C IEC II
NEG Micon A/S 50 Hz Arctic 1500 72 98 62 26
NEG Micon A/S NM 1500C/64 1500 64 92 60 28
NEG Micon A/S NM 1500C/72 1500 72 96 60 24
Bonus Energy A/S 1.3MW LM29 1300 62 81 - 101 50 - 70 19 - 39
Bonus Energy A/S 1.3MW B30 1300 62 81 - 101 50 - 70 19 - 39
Izar Bonus
Bonus Energy A/S 1.3MW LM29 1300 62 81 - 101 50 - 70 19 - 39
Bonus Energy A/S 1.3 MW, BBO 1300 62 99 68 37
Nordex N60 - 1300 kW 1300 60 76 46 16
Bonus Energy A/S 1MW 1000 54 72 - 87 45 - 60 18 - 33
Bonus Energy A/S 1MW 1000 54.2 69.1 - 87.1 42 - 60 14.9 - 32.9
Bonus Energy A/S 1MW, Test 1 1000 54.2 77.1 50 22.9
500kW – 1 MW
NEG Micon A/S NM54 950 54 80 - 99 55 - 72 28 - 45
NM54 alt.
NEG Micon A/S NM54/950 950 54.5 82.3 - 100.3 55 - 73 27.8 - 45.8
NEG Micon A/S NM54 950 54.5 82.3 - 100.3 55 - 73 27.8 - 45.8
NM900-200/52-
A alt. NM52 or
NEG Micon A/S NM52/900 900 52 70 - 81 44 - 55 18 - 29
NEG Micon A/S Multipower 52 900 52 70 - 81 44 - 55 18 - 29
NM900/52
NEG Micon A/S PEAB 4320 900 52 70 - 81 44 - 55 18 - 29
NM900/52,
NM52/900-
IECII or NM52-
NEG Micon A/S IECII Arctic 900 52 75 - 98 49 - 72 23 - 46
NM52 alt.
NM52/900 or
NM900/52-IEC
NEG Micon A/S II 900 52 70 - 98 44 - 72 18 - 44
NM 900-200/52
NEG Micon A/S AL 900 52 75 49 23
NM 900-200/52
NEG Micon A/S LM 900 52 75 49 23
NEG Micon A/S NM 52 900 52 70 - 81 44 - 55 18 - 29
NM 52 Plst U-
NEG Micon A/S tube damper 900 52 70 - 81 44 - 55 18 - 29
Vestas Wind Systems A/S V52-850 kW 850 52 66 - 100 40 - 74 14 - 48
Vestas Wind Systems A/S V52-850 kW 850 52 75 49 23
Vestas Wind Systems A/S V52-850 kW 850 52 70 44 18
N50s R46/50
Nordex LM23.3 DK-A 800 50 71 - 75 46 - 50 21 - 25

17

Nordex N50 - 800 kW 800 50 71 46 21
A/S Wincon West Wind W755/48 755 48 69 45 21
NM 44/750 alt.
NM 750-175/44
NEG Micon A/S or NM 44 750 44 62 - 72 40 - 50 18 - 28
NM 48/750 alt.
NEG Micon A/S NM48 750 48 69 - 79 45 - 55 21 - 31
NM 750-200/48
IEC2 LM23.5
NEG Micon A/S Arctic 750 48 69 - 79 45 - 55 21 - 31
NM 48 alt. NM
48/750 or
NM750-200/48
NEG Micon A/S IEC2 AL23A4 750 48 69 - 79 45 - 55 21 - 31
NM 750-200/48
NEG Micon A/S IEC2 LM23.5 750 48.2 69.1 45 20.9
NEG Micon A/S WW750/52 750 52 71 45 19
Norwin A/S 46-ISR-750 kW 750 46 68 45 22
Vestas Wind Systems A/S V47-660 kW 660 47 58.8 - 78.5 35 - 55 11.5 - 31.5
V47-660/200
Vestas Wind Systems A/S kW 660 47 63.5 - 88.5 40 - 65 16.5 - 41.5
Vestas Wind Systems A/S V47-660 kW 660 47 68.5 45 21.5
Bonus Energy A/S 600kW Mk IV 600 44 62 - 82 40 - 60 18 - 38
Izar Bonus
Bonus Energy A/S 600kW Mk IV 600 44 62 - 82 40 - 60 18 - 38
N43
MK2/MK3/600
Nordex kW 600 43 61.5 40 18.5
A/S Wincon West Wind W600/45 600 45 67.5 45 22.5
Norwin A/S 46-ASR-599 kW 599 46 68 45 22
Norwin A/S 47-ASR-599 kW 599 47 68.5 45 21.5
V39-500 kW, 42
Vestas Wind Systems A/S m rotor 500 41.8 60.9 - 62.9 40 - 42 19.1 - 21.1
Medium, 20kW – 500kW
A/S Wincon West Wind W250/29 250 29 44.5 30 15.5
Vestas Wind Systems A/S V27 225 27 44.5 - 63.5 31 - 50 17.5 - 36.5
Vergnet SA A/S GEV 15/60 40 15 31.5 - 47.5 24 - 40 16.5 - 32.5
Vergnet SA A/S GEV 10/20 20 10 23 - 35 18 - 30 13 - 25
Micro-scale, under 20kW

Gaia Wind 11
Gaia Wind A/S kW 11 13 21.5 - 24.5 15 - 18 8.5 - 11.5
Calorius Type
Calorius/Westrup A/S 37B 4.3 5 12 - 17.5 9.5 - 15 7 - 12.5
Bergey Wind A/S XL.1 1 2.5 10.25 - 33.25 9 -32 7.75 - 30.75

18
Appendix II Variation of Large Onshore Windfarm O&M Costs with

Nominal Capacity
35000
y = 38226x-0.31
30000 R2 = 0.5499
O&M Cost (Euro/MW)
25000
20000
15000
10000
5000
Low Medium High
Range Range Range
0
0 5 10 15 20 25 30 35
Wind Farm Capacity (MW)

19
Annex G System Costs
Annex G
System Costs

Isabel Philip
i
F:\PROJECTS\206106 Malta\Phase 1 deliverables\Phase 1 report\Final Report\Final Report Annex G - System Costs.doc/
List of Contents
Annex G System Costs 1

G.1 Introduction 1
G.2 Network Reinforcements Costs 1
G.2.1 Network Connection Studies and Cost Estimates by Enemalta 1
(i) Criteria for maximum voltage step-change amplitudes 2
(ii) Proposals for 10 MW Wind Farm at Ta’ Sarraflu (Gozo) 2
(iii) Proposals for 10 MW Wind Farm at Bahrija 2
(iv) Proposals for 20 MW Wind Farm at Marfa Ridge 3
(v) 40 MW Wind Farm (unspecified location) 3
(vi) Summary of Comments on Enemalta Studies and Cost Estimates 4
G.2.2 Adapting Enemalta windfarm option results to study scenarios 4
(i) Cabling or Overhead Lines. 5
(ii) Redundancy 5
(iii) Standard Cables and Estimated Site Ratings 5
(iv) Technical Limitations 5
(v) Cost Estimates 5
G.2.3 Small Scale Generation – proposals from Enemalta 6
G.2.4 Small Scale Generation – MM Response to Enemalta’s proposals 7
(i) Low Voltage Networks 7
(ii) Metering 8
(iii) Distribution Network Reinforcement Costs 9
(iv) Larger Consumers 9
(v) Overall impact of notional 16 MW of small-scale Generation 9
G.3 Spinning Reserve Costs 9
G.3.1 Current Operational Practice in Malta 10
(i) Spinning Reserve Margins 10
(ii) Load Shedding 11
G.3.2 Marginal Energy Costs 11
G.3.3 Impact of Wind Generation on Spinning Reserve 14
(i) Operational Demand & Load Forecast Errors 14
(ii) Wind Forecast Errors 14
(iii) Wind Generation Scenarios and Combined Uncertainty 15
(iv) Increase in Spinning Reserve Required by Addition of Wind Generation 16
(v) Costs of Reserves 16
Tables
Table G-1 – Network reinforcement costs for large windfarm sites considered in study scenarios ....... 6
Table G-2 – Typical Capacity-Load Daily Profiles............................................................................... 11
Table G-3 – Marginal Spinning Reserve Cost, Enemalta Estimate....................................................... 12
Table G-4 – Marginal Spinning Reserve Cost, MM Revised Estimate................................................. 13
Table G-5 – Standard deviation of wind power fluctuations (% of rated power) ................................. 15
Table G-6 – Net Combined Uncertainty with Wind.............................................................................. 16
Table G-7 – Costs of Providing Spinning Reserve, by Wind Scenario................................................. 17
ii
G.1 Introduction
This annex considers the costs that will accrue to the Maltese electricity system as a result of
integrating renewables – specifically, the impact on the system of adding large and micro-scale wind
and PV. The impact of other renewables that may be exploited in Malta, such as biomass waste, is
outside of the scope of this study.
Costs associated with the integration of renewables are divided into two main categories:
• Network reinforcement costs
• Spinning reserve costs
G.2 Network Reinforcements Costs
Studies performed by Enemalta provide the basis for assessment of network reinforcement costs in the
case of both large and small renewable electricity generation. In the case of large wind, the windfarm
options provided by Enemalta have been discussed and adapted to the scenarios used in this study. In
the case of small and micro scale wind or PV, the contribution from Enemalta is used directly.
G.2.1 Network Connection Studies and Cost Estimates by Enemalta
Preliminary analysis of the network reinforcement costs for large scale generation, performed by
Enemalta1, examined three wind farm options presented in the table below, which were suggested at
an early stage in this study. The results of these three options have subsequently been adapted to the
scenarios selected for this study, which are described in Volume 1.
Capacity At voltage
Site (MW) Connected to (kV)
Ta’ Sarraflu (Gozo) 10 Qala DC 11
Bahrija 10 Mosta DC 11
Marfa Ridge 20 Tee into 33 kV lines Mellieha-Vendome 33
The analysis of the network reinforcement costs for these sites included loadflow studies under the
following conditions:
• Steady state generation at Peak Summer demand period
• Steady state generation at Minimum night load
• Sudden loss of wind farm generation at Peak Summer demand period
• Sudden loss of wind farm generation at Minimum night load
The principal purpose of the load-flow studies was to establish voltage extremes as loads and
generation vary according to the conditions stated above.
Conclusions have been drawn on the technical viability of each scheme and an estimate made of the
connection costs. Drawings of the routes selected for the wind farm interconnection to the existing
1
power distribution network have been provided by Enemalta. A summary description of the main
features of Enemalta’s analysis, including commentary from MM, is given in subsections (i) through
(v) below. MM’s commentary is drawn from email correspondence with Enemalta, together with
information taken from the detailed route drawings. The conclusions drawn from Enemalta’s options
analysis, including the implications of the analysis results for network reinforcement costs in study
scenarios A through C, are discussed in subsection (vi).
(i) Criteria for maximum voltage step-change amplitudes
Enemalta postulated a worst-case of increasing wind speed taking all wind turbine generators (WTG)
to the point at which generation could not be sustained and safety cut-outs operated, dropping
generated output to zero in a short time-scale (2 minutes). Enemalta’s criterion for the amplitude of
the maximum voltage step on the network resulting from a sudden loss of generation appears to be
6%. MM stated that for such a rare event a higher criterion might be applicable, say –12% to +6%.
It is agreed that the magnitude of voltage steps is highly dependent on the pre-trip generated power
factor and is corrected, at least in part, by subsequent tap-changer action.
Enemalta proposes limiting generated power factor to the range unity to 0.95 leading to minimise the
volt drop when wind generation trips suddenly. MM confirms that generators using doubly-fed
induction generator (DFIG) technology, the most likely to be employed for WTG in the range 1-3 MW
each, should be capable of operating within these limits.
(ii) Proposals for 10 MW Wind Farm at Ta’ Sarraflu (Gozo)
Enemalta proposes two 5 MW cabled 11 kV circuits over a route estimated as over 12 km in length
from Qala DC (33/11 kV substation) to the wind-farm intake.
The estimated connection cost, by Enemalta, is € 2,141,000 (Lm 931,000). This is around
€ 92/circuit-m (Lm 40/circuit-m), dominated by installed cable cost. The cost estimate appears
reasonable in terms of comparisons with international 11 kV cabling costs, but at € 214/kW
(Lm 93/kW) this connection cost is high.
The cable impedance, on a 5 MVA base, is approximately 8.1+j4.5%, resulting in a voltage at the
wind farm intake ranging from 1.06 – 1.09 p.u. with 5 MW generated over the power factor range 0.95
lag to 0.95 lead., assuming that Qala 11 kV bus is maintained at 11 kV or 1.0 p.u. volts. This is too
high, and does not include for any transient voltage steps prior to tap-changer operation.
It is recommended that a single overhead 33 kV line would have a much lower cost and better voltage-
regulation than the 11 kV case.
Cabled connections have the benefit of better security and lower impedance than equivalent overhead
line connections. However we believe that in this example the cost of a cabled connection is too high
and the technical performance marginal at best.
(iii) Proposals for 10 MW Wind Farm at Bahrija
Enemalta proposes two 5 MW cabled 11 kV circuits over a route estimated as over 9 km in length
from Mosta DC (33/11 kV substation) to the wind-farm intake.
2
Our findings regarding cost and technical performance are similar to those found for Ta’ Sarraflu
(Gozo).
The estimated connection cost by Enemalta is € 1,754,000 (Lm 763,000). This is also around
€ 92/circuit-m (Lm 40/circuit-m), dominated by installed cable cost. The cost estimate appears
reasonable in terms of comparisons with international 11 kV cabling costs, but at € 175/kW
(Lm 76/kW) this connection cost is high.
The cable impedance, on a 5 MVA base, is approximately 6.0+j3.3%, resulting in a voltage at the
wind farm intake ranging from 1.046 – 1.067 p.u. with 5 MW generated over the power factor range
0.95 lag to 0.95 lead., assuming that Mosta 11 kV bus is maintained at 11 kV or 1.0 p.u. volts. This is
only marginally unacceptable, and does not include for any transient voltage steps prior to tap-changer
operation.
It is recommended that a single overhead 33 kV line would have a much lower cost and better voltage-
regulation than the 11 kV case.
(iv) Proposals for 20 MW Wind Farm at Marfa Ridge
Choice of a 33 kV connection level, and splitting the wind farm output between two existing 33 kV
circuits reduces the technical problems to manageable proportions, even taking into account transient
voltage steps prior to tap-changer operation.
The connection cost estimated by Enemalta is € 569,000 (Lm 247,500). With a route length for the
two 33 kV cable circuits of approximately 900 m, this can be expressed as € 317/circuit-m
(Lm 138/circuit-m) which is a little higher than expected from international comparisons, but may
include an estimate for terminations and other sundry works, which will be significant with such a
relatively short route length.
As with the other wind-farm options, there are potential savings to be made by using overhead
connections rather than cabled circuits. However, even the cabled connection cost at € 27.5/kW
(Lm 12/kW) is far lower than the specific cost associated with the 10 MW wind farm cases, and is
unlikely to be a factor affecting the viability of a project.
(v) 40 MW Wind Farm (unspecified location)
Enemalta has performed studies of the impact of a 40 MW wind farm on the power system, with
particular regard to its suitability for parallel running with existing generation.
The conclusions presume that conventional generation will be disconnected and replaced by WTG
generation. Since the WTG’s are presumed to be unable to support voltage at the extreme conditions
of light and peak loads, there is a risk of overloading the remaining thermal generators (at peak load)
or forcing it to operate at leading power factor at light load.
Since wind generation cannot be considered as firm generation for planning purposes, there should be
sufficient conventional generation installed to cover for periods where there is no wind. On this basis,
the connection of wind generation can be accommodated by “backing off” conventional generation,
thereby achieving substantial energy savings, yet having sufficient plant connected to meet reactive
power demands at all times.
3
To cover short-term needs for reactive power at peak times switchable capacitor banks may be
installed at moderate cost.
(vi) Summary of Comments on Enemalta Studies and Cost Estimates
To summarise from above subsections (i) through (v), the following conclusions are drawn from
Enemalta’s analysis:
• Enemalta has identified problems with the connection of windfarms unless these are
specified to operate at close to unity power factor.
• The choice of a rapid disconnection event resulting from excessive wind speed is plausible,
but will be rare. Under such circumstances, voltage steps prior to tap-changer operation in
excess of 6% might be deemed acceptable, particularly since the magnitude of such steps
occurs only with WTG power factor at 0.95. Better power factor control reduces such
voltage steps to below 6%.
• The costs of connection of the two 10 MW wind farm sites by duplicate 11 kV cables are
high with poor performance in terms of both losses and voltage regulation. It is
recommended that a replacement single 33 kV overhead connection be studied, as it would
be expected to demonstrate significantly lower cost and better technical performance.
• The same may apply to the 20 MW option at Marfa Ridge, although in this case proximity to
existing 33 kV overhead line circuits keeps the connection cost down to an acceptable level,
even if cables are used.
• The installation of a larger wind farm of nominal 40 MW capacity can be shown to result in
difficulties in the supply of reactive power from remaining thermal generation. These
difficulties can be overcome by reducing the output of conventional generation rather than
disconnecting it, leaving sufficient reactive capability (leading or lagging) serving the
network. The saving in fuel is not so great, but the option of dealing with reactive energy
deficits could be addressed by installing switchable capacitors (or reactors, but this is less
likely). This would permit greater fuel cost savings to offset the installation cost.
• The studies have not addressed whether fault current contribution from the proposed wind
farms would lead to existing switchgear being overstressed.
With respect to the study scenarios, A through C, Table G-1 below gives the network reinforcement
costs for each relevant combination of large windfarm explored in the scenarios.
G.2.2 Adapting Enemalta windfarm option results to study scenarios
Revised Large Scale Generation scenarios applied in Volume 1 of this study differ from the
preliminary scenarios studied and costed by Enemalta.
In order to update the cost estimates and estimate whether the technical performance of the network
connection will be adequate, the following assumptions have been made for application to the new
scenarios.
4
(i) Cabling or Overhead Lines.
It has been indicated by Enemalta that there may be difficulty and delay in obtaining consents for
overhead lines, accordingly the cost estimates for the Volume 1 scenarios are based on underground
cabling costs.
(ii) Redundancy
We agree with Enemalta, particularly if relatively reliable underground cables are installed, that there
is no case for providing redundant connections to wind farm sites. There may be technical reasons
linked with the capacity of standard network components for more than one circuit to be provided, but
this is on the basis of 2*50% (or 3*33% etc.) connections.
(iii) Standard Cables and Estimated Site Ratings
Enemalta studies and costs are based on 300 sq.mm. Al 3c 33 kV cable and 240 sq.mm. Al 3c 11 kV
cable.
MM estimates the site rating for these cable sizes, taking into account probable poor soil conditions in
the elevated and remote areas where the wind farms are likely to be situated, as 5 and 16 MVA for the
11 kV and 33 kV cables respectively. Assuming that the wind farms have a power factor better than
0.95, a desirable target for reasons of voltage performance as noted previously, this corresponds to
approximately 5 MW and 15 MW.
(iv) Technical Limitations
The regulation on the 11 kV cables carrying 5 MW has been established as marginal at 9 km, (Mosta-
Bahrija study), hence likely to be acceptable at less than 7–8 km route length. Voltage performance is
much improved at 33 kV, with only a 2% volt drop for 15 MW, 0.95 pf over 10 km.
Scenarios which have route lengths less than these limits are likely to be satisfactory from a voltage
regulation standpoint.
(v) Cost Estimates
Revised connection costs are based on the estimates by Enemalta, modified to separate out a notional
cost for terminations and a rate for installing cables.
Assumed termination costs are:

• 11 kV terminations – Lm 10,000/circuit (€ 23,000/circuit)
• 33 kV terminations – Lm 20,000/circuit (€ 46,000/circuit)
Cable supply and installation costs:

• 11 kV – Lm 39/m (€ 90/m)
• 33 kV – Lm 115/m (€ 265/m)
5
The 11 kV costs are a mean between the costs calculated by Enemalta for the Gozo and Bahrija
options. The above costs are used to estimate the connection costs for the Volume 1 scenarios shown
in Table G-1 following.
Table G-1 – Network reinforcement costs for large windfarm sites considered in
Volume 1 study scenarios
Route No.
Marfa Ridge (15 MW) kV length km Circuits Cost (Lm) Cost (€) Note
33 0.9 1 124,000 285,000 1
Marfa Ridge (15 MW) & Route No.

Bajda Ridge (10 MW) kV length km Circuits Cost (Lm) Cost (€)
Marfa Ridge (15 MW) 33 0.9 1 124,000 285,000
Bajda Ridge (10 MW) 11 3 2 256,000 588,000 2
Total 380,000 873,000
Offshore wind farm Route No.

(27 MW) kV length km Circuits Cost (Lm) Cost (€)
33 6 2 1,423,000 3,274,000 3
Marfa Ridge (20 MW) & Route No.

Bajda Ridge (20 MW) kV length km Circuits Cost (Lm) Cost (€)
Marfa Ridge (20 MW) 33 0.9 2 248,000 569,000 4
Bajda Ridge (20 MW) 33 3 2 732,000 1,683,000 5
Total 979,000 2,252,000
The above scenarios are based on the same unit costs for 11 kV and 33 kV cabling and terminations.
The following notes should be read in conjunction with this table:
• Note 1: New 15 MW load permits single 33kV cable, otherwise as before
• Note 2: Bajda cost using mean 11kV cabling cost at estimated distance 3km from Mellieha
• Note 3: Estimated route length from Mellieha to shore termination using mean 33kV cabling
cost. Load requires two cables
• Note 4: Increased load 20 MW requires two 33kV cables
• Note 5: Increased load 20 MW requires two 33kV cables (to Mellieha, over same route as
11kV cables for 10MW case)
As noted above, significant cost savings could be achieved on the longer routes by using part overhead
line, part cable.
G.2.3 Small Scale Generation – proposals from Enemalta
This section outlines Enemalta’s position2 on small scale generation, both for domestic and
commercial/industrial electricity users.
6
At the domestic level, the allowable level of micro generation per household is equal to the diversified
load at peak, here taken as 4kWp assuming that the level of such distributed penetration will be very
low. The worst-case network scenario with micro-generation is when all customers are generating
without consuming the power locally, so that all the power that they generate is fed into the grid. In
this case the LV (low voltage) circuits and the MV (medium voltage)/LV transformer would be fully
loaded. This scenario in itself would not entail any costs for Enemalta. The only costs to the grid
operator would be to replace the existing domestic metering equipment, which incorporates a single
phase import only meter, with two meters. One of the two new meters would register import and
export required for billing purposes, while the other will register the amount of electricity generated
required by MRA for statistical purposes. The 4kWp limit and the above metering arrangement is the
result of discussions held between Enemalta and MRA and is now in force.
If a greater capacity limit than 4kWp were required at a high level of penetration, reinforcement work
would be required on the LV circuits. A typical LV circuit would cost around € 9,600 (Lm 4,000).
This could also necessitate the construction of additional MV/LV substations at an average cost of
€ 96,000 (Lm 40,000). The current arrangement between Enemalta and MRA is aimed at avoiding
this high cost outcome.
Adoption of a similar approach is expected for commercial and industrial customers, so that the level
of micro generation would be limited to the diversified load at peak to avoid incurring network
reinforcement costs. The majority of commercial and industrial customers are supplied at LV and
directly fed from an MV/LV transformer. The capacity limit level will vary case by case, however, to
match each individual diversified load at peak. This level is expected to be in the region of 30% of the
contracted load, so that a customer with a contract for 300 kW would be limited to 90kWp of micro
generation capacity, for example.
If the factor of 0.3 of the contracted load is to be exceeded then it will be required to construct
additional MV/LV substations at an average cost of € 96,000 (Lm 40,000). Again, Enemalta hopes to
avoid this high cost outcome.
At this early stage the level of penetration for micro generation is very low, with only 2 PV systems of
1 kWp capacity installed at domestic premises. This could of course change if there are incentives,
with the level of penetration depending largely on the final cost of micro generation to the customer
and the price of the exported kWh into the grid. Since both these are unfavourable at present the level
of penetration is likely to remain low and of no consequence. A scenario of 2% penetration (i.e. 4,000
customers) could generate 16 MW in an extreme case of 4 kWp per installation, and hence start to have
effect on generation in general including wind. Assuming this capacity is dispersed and each limited
to 4 kWp, however, then Enemalta would not predict any significant effect on the transmission and
distribution circuits.
G.2.4 Small Scale Generation – MM Response to Enemalta’s proposals
(i) Low Voltage Networks
There is a problem when the daily and seasonal load profiles of domestic electricity consumption and
micro-generation do not match. For example, photovoltaic generation peaks at around midday, but
household demand may peak in the evening. Wind generation can peak at the time of system
minimum demand.
7
At a low penetration of renewable generation, the flow of power back into the network when
generation is at its maximum output only extends to the local LV feeder immediately adjacent to the
property. Effectively, the surplus power is absorbed by the generator’s immediate neighbours. As a
consequence, there are unlikely to be any adverse effects in terms of loading or voltage regulation on
the remainder of the network.
At high penetration levels, power must flow back into the high voltage network at certain times when
generation is a maximum and the load is low. The degree of penetration when this will occur depends
on the quantity of generation relative to the maximum after-diversity demand that the network has
been designed for, and the ratio of actual load at the time of maximum generation to the maximum
load.
The quoted diversified (=”after diversity”) load in Malta is 4 kW per household at the time of peak
demand. This seems high (the comparable figure in the UK is less than 1.5 kW), and may conceal a
large variation between relatively large and affluent households and the majority of small properties.
In the worst case of 100% penetration, even if the installed generation capacity only equalled the peak
load, power will flow back into the high voltage network at times other than peak load, leading to a
significant voltage rise on the distribution network. The network will not be overloaded as such, but
the range of voltage variation will rise to maybe 50% greater than the permitted limits (the exact value
depending on the lowest load at the time of maximum generation). This would require a proportionate
amount of reinforcement to the network in order to restore its performance.
(ii) Metering
The cost of metering, billing and settlement can be substantial with small-scale generation, and a
different philosophy may be adopted in comparison to large scale projects.
If, as is probable, existing single-phase domestic meters will not register export units, the simplest
arrangement is to permit the consumer to net off small-scale generation by connecting the generators
to the consumers side of the existing meter. The consumer receives the full purchase price for
generated electricity up to the level of his demand. Thereafter he gets no benefit, so there is a strong
disincentive to install more generation capacity than his load warrants.
Separate export metering would permit the consumer to obtain a benefit from installing a higher
capacity, but the price for exported energy would usually be lower than the electricity purchase price.
(Separate export metering could be achieved by installing a second meter, alternatively replacing the
existing meter with a combined import/export meter with dual registers.)
Rather than netting off the domestic load by connecting small scale generation into the household
wiring circuits, the gross output from the generator may be separately metered (this requires internal
wiring from the generator to the metering position) and paid for separately. The price paid is likely to
be less than the purchase price for all generated units, rather than those exported, hence this is less
attractive to the consumer than the other alternatives, and he also has to bear the cost of the additional
wiring in the property.
If however a premium price is paid for renewable energy, higher than the domestic selling price, then
separate gross metering is the best option for the consumer.
8
Whichever option is selected, there is a benefit in recording generated energy for statistical purposes.
However, because of the cost of installing and reading additional meters, this would probably be done
on a sample of consumers with small-scale generation rather than the whole population.
(iii) Distribution Network Reinforcement Costs
Enemalta quotes around € 9,600 (Lm 4,000) for a “typical LV circuit”. This probably relates to a low
voltage feeder serving typically 20-40 consumers, rather than a single consumer’s service connection.
The estimate of an average cost of € 96,000 (Lm 40,000) for the construction of additional MV/LV
substations probably accounts for some HV and LV cabling as well as the new distribution substation
itself. This is reasonable since it is obviously necessary to include the “tie-in” costs as well.
This expenditure is probably unnecessary until overall penetration levels exceed about 15–20%1,
thereafter for reasons explained above this expense will be incurred progressively as penetration
increases.
(iv) Larger Consumers
Enemalta is proposing a limit of 30% of contracted capacity for the installed capacity of small-scale
generation. This seems appropriate as it probably approximates to less than the typical consumer’s
demand at the time of maximum generation, particularly if the generation is photo-voltaic. It may be
expected that there will be no net export, or zero load, which is probably the case already used in the
design of the network to determine the upper voltage limit. In this case, no further reinforcement
should be required.
(v) Overall impact of notional 16 MW of small-scale Generation
In the context of the Malta total load profiles, the conclusion that negligible reinforcement costs would
be incurred on the network after connecting 16 MW of small-scale generation is probably correct.
Although “clustering” could lead to local difficulties, the cost of small scale generation is quite high,
and will probably be taken up by more affluent households and businesses, which are likely to have a
relatively high electricity consumption anyway. The 4kW limit for domestic consumers is likely to be
acceptable on these grounds.
G.3 Spinning Reserve Costs
In addition to network reinforcement requirements, addition of wind generation to the Malta power
system will have an impact on the mode of operation of conventional generation, since it will be
necessary to carry a larger amount of spinning reserve (SR) to deal with the fluctuations in the output
of the wind turbines.
Carrying additional spinning reserve incurs costs as a consequence of the need to operate conventional
thermal generation at lower capacity factors and efficiency. There is also an implied cost incurred by
1
The spread of small-scale generation is likely to show typical “clustering” behaviour, whereby certain areas have
penetration well above the average, and these will need reinforcement first.
9
the need for more capacity in order to provide this level of spinning reserve. These issues are a feature
of renewable generation that is intermittent in nature. Nevertheless, with the growing quantities of
wind generation around the world, data is becoming available which permits reasonably accurate
predictions of the behaviour of wind generation.
G.3.1 Current Operational Practice in Malta
Generator ratings range up to 60 MW on the Malta system with typical peak demand around 400 MW.
Discussions were held with Enemalta3 to establish local practice regarding the actual operational
margins held at peak and other times and the provision of load-shedding or other measures to deal
with forced outages which might exceed the quantities of spinning reserve held.
Following the discussion, information was also provided by Enemalta on spinning reserve and the
impact on unit generation costs by submission of typical load profiles and the re-scheduling of
generator loads for a hypothetical 10 MW load reduction4.
(i) Spinning Reserve Margins
Enemalta practice is to minimise spinning reserve to a level down to 5 MW at times of peak load
(typical duration 2 hours) but at other times when loads are over 300 MW, spinning reserve is
typically 25 MW or greater. Analysis of the typical daily load and generation schedules provided by
Enemalta confirms this practice, with typical peak spinning reserve being 5-12 MW at peak times in
the summer and autumn, but rising to 22-28 MW at other times. Over the 24 hour period as a whole
the average margin is 42 MW.
Table G-2 summarises the statistics extracted from Enemalta data in terms of the mean spinning
reserve margins expressed as percentages (of connected capacity) and MW in each season, averaged
over a day and over a peak period, defined for this purpose as the peak period and one hour each side.
When 10 MW of load is removed, the reserve margin rises by 10 MW, since the quantity of connected
plant remains constant.
10
Table G-2 – Typical Capacity-Load Daily Profiles
Average spinning Average spinning

reserve 24 hr reserve Peak ±1 hr
Load Profile Period Date Percent MW Percent MW
Actual Load Curve 20% 64 7% 28
Winter 24-Jan-04
Actual Load - 10MW Curve 23% 74 10% 38
Spring 14-May-04
Summer 12-Aug-04
Autumn 16-Nov-04
Mean, all seasons 14% 42 5% 17
Mean, all seasons -10 MW 18% 52 8% 27
(ii) Load Shedding
Load shedding relies on a modern system which trips selected 33 kV feeders in various stages using
both rate-of-change of frequency (“df/dt”) and underfrequency measurements. This enables the
quantity of load shed to be matched to the magnitude of the disturbance and its urgency as indicated
by the df/dt measurements.
Load shedding occurs some 6–10 times a year, with up to 1/3 of the island load disconnected. This
finding is as expected, noting that loss of a CCGT block or large steam turbine results in the loss of
55-60 MW capacity, and the level of spinning reserve, even over a 24 hour period, averages only
42 MW. There is therefore a high probability of a trip of a larger unit coinciding with the reserve
margin being less than the output of the set.
For the purposes of examining the impact of an intermittent generation source, the present spinning
reserve margins and consequences in terms of the frequency of load-shedding events in Malta are
presumed to continue, noting that there are large cost implications, particularly on relatively small
power systems, of increasing and maintaining sufficient generation capacity to reduce the number of
load-shedding events.
G.3.2 Marginal Energy Costs
In order to evaluate the cost of holding additional spinning reserve to cover for renewable generation,
Enemalta was requested to provide estimates of the impact of increasing generation margins, using the
local practices for scheduling capacity and despatching sets.
An estimate of the cost impact of a reduction of 10 MW of load was provide by Enemalta4, based on
four typical 24-hour periods in summer, autumn, spring and winter. The estimated cost impact
expressed in terms of Maltese cents/kWh is summarised in Table G-3:
11
Table G-3 – Marginal Spinning Reserve Cost, Enemalta Estimate
Units Unit Cost Increase

Generated Maltese in unit
Period Date MWh Cents/kWh cost
Actual Load Curve 6589 1.705
Winter 24-Jan-04
Actual Load - 10MW Curve 6349 1.713 0.49%
Spring 14-May-04
Summer 12-Aug-04
Actual Load - 10MW Curve 7906 1.741 -0.01%
Autumn 16-Nov-04
The typical impact of operating plant at lower efficiency, as shown in Table G-3, was significantly less
than expected from European experience where it is found that average heat rates degenerate by up to
10% when plant load is reduced by the maximum amount, say down to 50% of nominal maximum
continuous rating. The results for the summer period were also anomalous and need checking (see
Table G-4).
A probable reason for the small impact of increasing margins by 10 MW in Malta is that the average
reduction in plant loading is very much less than 50%. This arises as a consequence of the relatively
small number of units on the Enemalta system, necessitating a much higher proportion of sets
operating in regulating mode, particularly off-peak, compared to European practice.
In order to check the above estimate, use was made of the data provided in Enemalta’s summary of
plant capacity and performance “Short Term Options to meet load demand for the next four years,
Generation”5, which included figures showing monthly results for the 24 months from October 2002
to September 2004. The key data is on four figures entitled:
• Fuel Costs
• Unit Cost at Yearly Average Fuel Cost
• Capacity Factor
• Efficiency
Data is provided on each figure for MPS (Marsa), DPS (Delimara) and CCGT (combined cycle plant
at Delimara).
Establishing a relationship between capacity factor and efficiency for each station/generation type
provides an independent measure of the change in effective heat rate as the plant utilisation rises or
falls month to month. Linear regression analysis on the data for each power station demonstrated that
the effective heat rate at Marsa has a medium to low correlation with capacity factor, at Delimara
correlation is very low, but there is a good match with the CCGT efficiency. These results are
dependable in that they are based on historic operating records for two years.
Knowing the fuel cost and monthly unit costs and applying these to the typical plant scheduling
provided by Enemalta in the data used to prepare Table G-3 permits a separate calculation with results
shown below:
12
Table G-4 – Marginal Spinning Reserve Cost, MM Revised Estimate
Units Unit Cost Increase

Generated Maltese in unit
Period Date MWh Cents/kWh cost
Winter 24-Jan-04
Spring 14-May-04
Summer 12-Aug-04
Autumn 16-Nov-04
Mean, all seasons 1.799
Mean, all seasons -10 MW 1.811 0.67%
Summary Statistics Cost Lm
Annual energy MWh 2,383,632 42,892,359
Annual energy MWh, load –10 MW 2,296,032 41,591,561
Differences 87,600 1,300,798
Marginal unit rate for reduced thermal generation M¢/kWh 1.485

Actual annual energy (generated) 2003/4 MWh 2,214,892
Annual Cost of 10 MW spinning reserve (based on 2215 GWh p.a.) 265,787
For these calculations the following apply:
• Fuel cost taking average for the last 12 months HFO Lm57/Mton
• Diesel Lm120/Mton
In both scenarios the same units were run to meet demand.
The overall finding of a 0.67% increase in unit rate when the load is reduced by 10 MW, taking each
of the typical days as typical of each season, is of a similar order to the calculations performed by
Enemalta as shown in Table G-3.
The summary statistics show that the effect of reducing existing generation so that its runs at slightly
lower capacity factors results in a lower marginal return in the energy saved of M¢1.485/kWh
(€¢3.42/kWh), compared to a mean unit cost of M¢1.8/kWh (€¢4.14/kWh), see Table G-4. This is a
consequence of forcing existing plant to run at lower efficiency.
When considering the overall cost of carrying spinning reserve, separately from the benefit of saved
fuel cost which is given by the above net marginal unit rate, the cost of reducing load is equivalent to
raising the level of spinning reserve. For a 10 MW increase in spinning reserve for a year this cost is
Lm 265,787 (€ 611,300), calculated by multiplying the difference in the two unit costs by the energy
generated in 2003/4.
The calculated energy generated using the four typical load profiles is 2,383,632 MWh, which is about
7% higher than the actual energy generated in 2003/4 (2215 GWh). The match is sufficiently close to
validate the typical load profiles.
13
G.3.3 Impact of Wind Generation on Spinning Reserve
The methodology of assessing the impact of intermittency, the variability of wind generation when
applied to power systems, is based on a number of studies on European networks with a significant
penetration of wind power.
Analysis of the impact of wind generation in Malta is based on a methodology developed by David
Milborrow6, which has been adapted for the local power system.
The principles and procedure underlying the methodology for assessing the impact of a variable source
such as wind-turbine generators are summarised below:
1. Demand and load forecast errors can be combined and modelled as a Gaussian distribution
with a mean of zero, and a standard distribution that is a function of the time ahead.
2. Wind forecast errors can be modelled in a similar way. It will depend on amount of wind and
time ahead.
3. Combined error for electricity systems with wind is established from a “sum of squares”
calculation.
4. Spinning reserves are scheduled based on “3sigma” criterion, although some utilities use
“4sigma”.
5. Costs of reserves: Varies, depending on type, and between utilities, but most report values in
range € 3-6/MWh. That is separate from energy charge realised if it is actually used.
(i) Operational Demand & Load Forecast Errors
The level of spinning reserve held at any time is determined by either anticipation of an event such as
loss of a generator or by the uncertainty in assessing the system load for a short period ahead, typically
the two to three hours of a peak demand period. This period is also influenced by the time required to
start standby plant.
Predicting load an hour or more ahead can be achieved on large networks to an accuracy down to 1%,
but for typical medium-sized systems the error may be in the order of 3%. For Enemalta, the probable
short-term forecasting error of 3%, or 12 MW with peak load 400 MW, is applicable, given that
historical evidence has shown that it is possible to operate with even closer margins at peak times in
the summer, as shown in Table G-2.
Enemalta practice has been to accept load-shedding as a means of dealing with an unforeseen event
such as the loss of a large generator.
(ii) Wind Forecast Errors
Any installation of wind turbine generators in Malta should be treated as a single wind farm, since
installations will be in a small geographical area with essentially the same wind regime prevailing
everywhere.
Data on the variability of wind generation has been collated from a number of sources, as shown in
Table G-5 (from Milborrow, 2004):
14
Table G-5 – Standard deviation of wind power fluctuations (% of rated power)
Data Source Lead time, hours

1 2 4
National
NGC (England and Wales) 3.1 6.0 (at 3.5 hr)
West Denmark 3 5.6 10
Single wind farm 11.8 16.0 20.8
The variability associated with a single wind farm for a period of 2 hours is selected as the most
appropriate, for consistency with the typical peak load period and selected load forecasting error.
(iii) Wind Generation Scenarios and Combined Uncertainty
The costs of providing spinning reserve for large wind projects are established for the following
scenarios, which are applied in Volume 1 of this study:
Location Capacity MW
Single wind farm at Marfa Ridge 15
Farms at Marfa Ridge (15 MW) and Bajda (10 MW) 25
Offshore wind farm 27
Farms at Marfa Ridge (20 MW) and Bajda (20 MW) 40
Taking the mean forecasting error as 12 MW at peak times and using the uncertainty of wind
generation as 16% of the installed capacity for a period of two hours from Table G-5 permits a
combined level of uncertainty to be derived from a sum of squares calculation. However, as shown in
Table G-2, the typical levels of spinning reserve are well in excess of the reference level of 3% or
12 MW during off-peak periods. It is recommended, for the purposes of costing the increase in
spinning reserve necessitated by the addition of wind generation, that peak and off peak hours are
treated separately, then combined to obtain the total cost. The mean spinning reserve level off-peak
will be higher than yearly average of 42 MW, hence this value is chosen for assessment purposes.
This procedure is valid given uncertainty in two quantities which are otherwise unrelated. The
principal influence on the magnitude of peak demand for electricity is ambient temperature rather than
wind speed, so this assumption is sufficiently valid for this application.
Table G-6 summarises the calculation of combined uncertainty for the four stages of implementation
of large wind projects summarised above.
15
Table G-6 – Net Combined Uncertainty with Wind
Scenario Wind MW Peak/- Load (Target Combined Sigma

Uncertainty Off-Peak or actual MW MW
(at 16%) S.R.) MW
2.4 Peak 12 12.24 0.24
Marfa Ridge (15 MW)
2.4 Off-peak 42 42.07 0.07
Marfa Ridge (15 MW) 4.0 Peak 12 12.65 0.65
& Bajda Ridge (10 MW) 4.0 Off-peak 42 42.19 0.19
Offshore wind farm (27 4.3 Peak 12 12.75 0.75
MW) 4.3 Off-peak 42 42.22 0.22
Marfa Ridge (20 MW) 6.4 Peak 12 13.60 1.60
& Bajda Ridge (20 MW) 6.4 Off-peak 42 42.48 0.48
(iv) Increase in Spinning Reserve Required by Addition of Wind Generation
In order to obtain a high level of confidence, better than 99%, in the predicted combined uncertainty,
the Sigma value should be multiplied by 3 or 4, in order to assess the desired increase in spinning
reserve.
It is proposed to use a “3-sigma” value, reflecting the approximate nature of the data which does not
warrant the unnecessary precision implied by a choice of “4-sigma”.
(v) Costs of Reserves
It has been demonstrated in Section G.3.2 that the cost of adding 10 MW of spinning reserve for a
whole year is € 611,300 (Lm 265,787).
The values in Table G-2 are based on the peak hour and the hour either side, or three hours/day. If
weekends/public holidays are ignored, this totals 1095 hours/year, and the cost of providing an
additional 10 MW of spinning reserve in that period only is € 76,400 (Lm 33,223). The balance of
cost € 534, 900 (Lm 232,564) is spread over the remainder of the year.
The cost impact of providing additional spinning reserve to support the introduction of large wind-
farms onto the Malta power system is summarised in Table G-7.
16
Table G-7 – Costs of Providing Spinning Reserve, by Wind Scenario
Scenario Capacity Peak/- 3*Sigma Cost p.a. Total Total

MW Off-Peak MW (Lm) Cost p.a. Cost p.a.
(Lm) (€)
Peak 0.71 2,369
Marfa Ridge (15 MW) 15 7,149 16,442
Off-peak 0.21 4,780
Marfa Ridge (15 MW) & Peak 1.95 6,470
25 19,729 45,377
Bajda Ridge (10 MW) Off-peak 0.57 13,259
Offshore wind farm Peak 2.26 7,514
27 22,974 52,841
(27 MW) Off-peak 0.66 15,460
Marfa Ridge (20 MW) & Peak 4.80 15,947
40 Off-peak 1.45 33,826 49,773 114,477
Bajda Ridge (20 MW)
These costs are incurred solely as a consequence of increased part-load running and lower efficiency.
Expressed as a cost per unit of wind-generated energy, these values are small, ranging from .050 to
0.131 €¢/kWh (0.022 to 0.057 Lm¢/kWh).
1 Enemalta Network Studies “Preliminary investigation for Wind Farms at Ta’ Sarraflu, Marfa
and Bahrija”, letter dated 8th February 2005
2 Email from C Grixti 30th Nov, 2004
3 Telephone discussions with Edwin Gauci of Enemalta on 24th Nov. 2004
4 Email from Edwin Gauci 24th Nov. 2004, attaching file MRA_RES_Report.xls
5 Email from Anthony Sammut (MRA) 1st Nov. 2004 enclosing report extract on file
“MRA_RES_Report.doc”
6 Milborrow, D., (Nov 2004), “Wind Energy Variability: Small System Issues”
17
Annex H Glossary
AQMA Air Quality Management Area
AQAP Air Quality Action Plan
BWEA British Wind Energy Association
CCGT Combined Cycle Gas Turbine
CO2 Carbon Dioxide
df/dt Rate-of-change of frequency
DFIG Doubly-fed induction generator
DTI Department of Trade and Industry, UK
EU European Union
EU ETS European Union Emissions Trading Scheme
EWEA European Wind Energy Association
GHG(s) Greenhouse Gas(es)
O&M Operation and Maintenance
kWh Kilowatt hours
Lm Malta Liri
LN Malta Legal Notice
LV Low Voltage
M¢ Malta Cents
MM Mott MacDonald
MV Medium Voltage
MW Megawatt
MWth Megawatt of thermal power
NO2 Nitrogen dioxide
NOx Nitrogen oxides

PM10 Particulate matter with a mean diameter of 10 microns or less
RES Renewable Energy Sources
SR Spinning Reserve
tCO2 Tonnes of Carbon dioxide
UNFCCC United Nations Framework Convention on Climate Change
Wp Peak Watt
WTG Wind Turbine Generators
WTP Willingness to Pay

Annex I References
I.1 Primary Sources
1 Telephone discussions with Edwin Gauci of Enemalta on 24th Nov. 2004
2 Email from Edwin Gauci 24th Nov. 2004, attaching file MRA_RES_Report.xls
3 Email from Anthony Sammut (MRA) 1st Nov. 2004 enclosing report extract on file
“MRA_RES_Report.doc”
I.2 Bibliography
American Wind Energy Association (AWEA), (2002), “Roadmap: A 20-year industry plan for small
wind turbine technology”, p.14, National Wind Technology Center, National Renewable Energy
Laboratory (NREL), Golden, Colorado
British Wind Energy Association (BWEA), (November 2003), “Briefing Sheet - PPS22: Renewable
Energy”, BWEA, London, UK.
British Wind Energy Association (BWEA), (August 2004), “Wind Energy & Planning: An
Overview”, BWEA, London, UK.
British Wind Energy Association (BWEA), (2004), “Wind Energy Economics”, Online Factsheet.
Clausager, I., (2000), “Impact assessment studies of offshore wind parks on seabirds with special
reference to the Tuno Knob Park”, in: Merck & von Nordheim: Technische Eingriffe in Marine
Lebensraume, Tagungsband. BFN-Skripten 29. Bundesamt fur Naturschut,z 2000.
Ender, Carsten (2002) "Wind Energy Use in Germany - Status 31.12.2001" in DEWI Magazin, Nr. 20,
February 2002
Energy Technology Support Unit (ETSU), (1997), Methodology - 97 “The Assessment and Rating of
Noise from Wind Farms”, ETSU, Harwell, UK.
EurObserv'ER, (2003) Photovoltaic Energy Barometer (www.observ-er.org/)
European Wind Energy Association (EWEA), (2003), “Wind Energy – The Facts”, EWEA, Brussels,
Belgium.
European Wind Energy Association (EWEA), (2003a), “Wind Force 12: A Blueprint to achieve 12%
of the World’s Electricity from Wind by 2020”, EWEA, Brussels, Belgium.
ETSU, (1999), ETSU S/P2/00304/REP 1999 “Photovoltaics in Buildings: Town Planning

Considerations”, ETSU, Harwell, UK
ETSU, (2000), - ETSUW/14/00538/REP – “Cumulative Effects of Wind Turbines – A Guide to

Assessing the Cumulative Effects of Wind Energy Development”, ETSU, Harwell, UK.
EUREC, (2004), “Renewable Energy In Europe, Building Markets & Capacity”, EUREC Agency,
London, UK
Farrugia, R. N. & Scerri, E., (1999), “A Wind Resource Assessment for the Maltese Islands”, Institute
for Energy Technology, M’Xlokk, Malta
Garrad Hassan Ltd, (2003), “OFFSHORE WIND: Economies of scale, engineering resource and load
factors”, DTI, London, UK.
Her Majesty’s Stationary Office (HMSO), (2002), Planning Policy Guidance (PPG) note 22:
“Renewable Energy - Annex on photovoltaics”, HMSO, London, UK.
HMSO, (August 2004) Planning Policy Statement PPS 22 “Renewable Energy”, HMSO, London,
UK.
IEA, (2002), “Building Integrated Photovoltaic Systems, Guidelines for Economic Evaluation”,
International Energy Agency
Iskander, C. & Sceri, E., (June 1996), ‘Photovoltaic Solar Energy Applications in Malta’,3rd Biennial
Conference of the Malta Council for Science and Technology, Valletta, Malta.
Luke, A. & Watts-Hosmer, A., (February 1994), “Bird Deaths Prompt Rethink on Wind Farming in
Spain”, in Wind Power Monthly, February, Vol. 10, No. 2, pp. 14-16.
Malta Chamber of Planners (MaCP), (January 2004), “President’s Report on the Situation of Spatial
Planning in Malta – 2003”, MaCP, Malta
Malta Environment and Planning Authority (MEPA), (March 2003), “Rural Strategy Topic Paper –
Volume 1”, MEPA, Floriana, Malta
Milborrow, D., (Nov 2004), “Wind Energy Variability: Small System Issues”
MEPA, (September 1994), North West Local Plan, MEPA, Floriana, Malta
MEPA, “Landscape Assessment Study of the Maltese Islands”, MEPA, Floriana, Malta
MEPA, “Gozo and Comino Local Plan”, MEPA, Floriana, Malta
Royal Society for the Protection of Birds (RSPB), (February 2004), Information Sheet “Wind Farms and
Birds”, RSPB, Sandy, UK
Royal Town Planning Institute (RTPI), (22 February 2002), “Baptism of Fire: The First Nine Years of
Malta’s New Planning System”, Planning, Issue 1457, RTPI, London, UK
RTPI, (24 January 2003), “Letter from Malta: A new and comprehensive Planning System”, Planning,
Issue 1503, RTPI, London, UK
Scottish Executive, (2000), National Planning Policy Guidance note (NPPG) 6 “Renewable Energy
Developments, Scottish Executive Development Department, Edinburgh, Scotland
Scottish Executive, (January 2002), Planning Advice Note (PAN) 45 “Renewable Energy Technologies”,
Scottish Executive Development Department, Edinburgh, Scotland
Stevenson, R. & Griffiths, S., (October 1994), “The Visual Impact of Wind Farms: Lessons from the UK
Experience”, ETSU, Harwell, UK
Suri, M., Huld, T. A., Dunlop, E. D., (2004), “Regional differences of the PV electricity production in
EU25 countries”, European Commission - DG Joint Research Centre, Institute for Environment and
Sustainability, Renewable Energies Unit, Ispra , Italy.

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Strategy for Renewable

Malta Resources Authority

Tel 01273 365000

Strategy for Renewable

Issue and Revision Record

Sections and Appendices

(ii) Feasible Penetration Levels for PV 17

4 Conclusions and Recommendations 26

ACP Average Cost of Power

EIA Environmental Impact Assessment

KWh Kilowatt hours

MRA Malta Resources Authority

MWp Peak Megawatt

MWh Megawatt hours

RES Renewables Energy Sources

206106/00/July 2005/ G-1 of G-1

206106/00/July 2005/ S- of S-27

1.3 Conclusions and Recommendations

Based on the modelling analysis, the following recommendations are made:

1.4 Report Structure

The results of Phase 1 are presented in two volumes:

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Volume I of the study is structured as follows:

• Section 2 outlines the modelling methodology

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2.1 Model Inputs

• A screening exercise to identify the renewable technologies appropriate for Malta.

• An analysis of environmental and planning barriers to the exploitation of the available

• A legislative review to identify any potential legislative barriers to the implementation of

• Central Local Plan Area (CLP)

• Gozo & Comino Local Plan Area (GCLP)

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• Great Harbour Local Plan Area (GHLP)

• Marsaxlokk Bay Local Plan Area (MBLP)

• North Harbours Local Plan Area(NHLP)

• North West Local Plan Area (NWLP)

• Malta South Local Plan Area (MSLP).

2.1.1 Screening Exercise

2.1.2 Resource Characterisation

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2.1.3 Environmental and Planning Barriers

2.1.4 Legislative Review

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2.1.5 Project Costs

• Transport and shipping

• Contracting, electrical equipment and installation costs

• Financing and legal costs

• Developer’s profit margin

2.1.6 System Costs

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2.1.7 Summary of Model Inputs

Figure 2-1: Demand Scenarios to 2020

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2.3.1 Scenario A: Reaching 5% of Demand by 2010

Details on the scenarios and the results are included in section 3.

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2.3.2 Scenario B: Feasible Technology Penetration Rates

Scenario B is broken down into the following cases:

Details on the scenarios and the results are included in section 3.

2.3.3 Scenario C: Windfarm Installation post-2010

Details on the scenarios and the results are included in section 3.

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2.5 Format of Results

Table 2-1: ACP results by technology