Overall, the document includes many positive proposals – from investment in both onshore and offshore renewable energy installations and battery storage, to measures to ensure that renewable energy is accessible and energy overall remains affordable. We applaud the Minister and Ministry for their intention to present a bold new vision and action plan for Malta’s clean energy transition.

However, the document lacks a clear plan and timeline with important milestones and targets, as well as monitoring and evaluation measures. The plan promises many things but lacks depth and transparency about proposed measures, such as cost-benefit analyses, emissions accounting methodologies and long-term financial risks.

Clear targets are needed particularly for the proposed increase in production of renewable energy. While renewable energy currently accounts for 17.2% of Malta’s energy consumption, which represents a significant improvement over the past decade, this figure needs to be significantly higher for Malta to be truly resilient and transition away from the climate impacts and unpredictable fluctuations of fossil fuels. We urge the Government to give greater consideration to the potential role of renewable energy communities in Malta, and create the supportive enabling framework and designing support schemes for renewable energy communities.

We reiterate our deep concern about the proposed Melita gas pipeline, due to its continued use of fossil fuel gas (“natural gas”), and only potentially later ‘green hydrogen’, and its connection to corruption at Electrogas and the murder of journalist Daphne Caruana Galizia. Green hydrogen production is hyped, but in reality still minimal. The electrolysis process which produces hydrogen from renewable electricity is known to be energy and water intensive and inefficient.  There is excessive focus on the potential of hydrogen to solve complex issues (such as baseload capacity, and its role as a potential fuel source for some transport modes) and provide economic opportunities, with the technology still at an experimental stage. Guidance from experts and the EU specifically stress that, due to hydrogen’s inefficiency, its role should be limited to hard-to-decarbonise sectors rather than in guaranteeing baseload capacity or in land based transport.

We urge for a revision of Malta’s energy subsidies, transforming them into progressive subsidies which protect people from energy poverty while moving away from subsidising fossil fuels. The document lacks a plan for the phase out of fossil fuels and fossil fuels subsidies.

On stakeholder engagement, we reiterate our concerns over the government’s limited stakeholder engagement with MCESD. This body does not include a single environmental NGO and does not represent or include organisations like ours. Stakeholder engagement should be open and public, to all. The development of a new policy on energy should also include participation at earlier planning stages rather than after major policy directions and infrastructure decisions have been already determined.

The document repeatedly emphasizes economic growth and electricity demand as inevitable and desired rather than questioning whether Malta’s current development model is environmentally sustainable in the long term. A real just transition cannot rely only on replacing fossil fuels with renewable energy. There should be a greater emphasis on demand reduction, sustainable urban planning, sustainable mobility and reducing overconsumption. The document lacks a discussion on behaviour change, consumption reduction and systemic reforms which are essential for a just energy transition.

In all, the document provides a largely coherent vision with many positive elements and a clear policy direction emphasising energy sustainability, affordability and resilience. However, there are some elements that need to be seriously reconsidered, as they go diametrically against the clean energy shift, notably the proposed Melita gas pipeline and the continued fossil fuel subsidies. Finally, our question remains how the Government intends to move from political vision to implementation.

We demand that the final version of the Malta Energy Shift policy includes:

• A clear timeline and plan for implementation
• Removal of the Melita gas / hydrogen-ready pipeline from the policy and the PCI list
• A supportive framework for renewable energy communities
• A phase-out plan for fossil fuel subsidies
• A plan on behaviour change and demand reduction

Feedback on specific measures

Pillar 1 – Affordability

4.1 It is very important to shield those who are vulnerable and at risk of energy poverty from rising energy costs. However, Malta’s current energy and fuel subsidies are de facto fossil fuel subsidies and delay the shift to renewable power sources, and are applied at a blanket rate across all sectors of society and business. Apart from overlooking the potential to encourage investments in energy efficiency and savings, as well as in renewable energy installations, the current subsidies actually benefit those who use more energy and fuel more. These public funds should be adjusted to subsidise basic energy needs only, and be designed to benefit vulnerable cohorts, not all energy and fuel users. To ensure energy affordability and protect people from energy poverty, Malta’s energy subsidies should be redesigned to be progressive, i.e. they should benefit lower-income households at a higher rate than high-income households, and capped after a certain amount of energy use, so that they subsidise basic energy needs and prevent overuse. The policy  lacks a long-term roadmap for the phase-out of fossil fuel subsidies in line with climate targets and EU decarbonization objectives.

4.2 Gas is often promoted as a transition fuel, with lower carbon emissions per unit than dirty fossil fuels, such as the heavy fuel oil that was Malta’s main source of energy. However, when taking methane leakage and the emissions along the LNG supply chain into account, the real GHG emissions of gas usage in Malta seem to be underestimated. We would welcome a critical assessment of the greenhouse gas emissions of Malta’s LNG supply chain.

4.3 Please refer to our feedback submitted on the Draft Offshore Renewable Energy Policy from 2023: https://foemalta.org/blog/offshore_energy_feedback/

On the issuance of energy and water bills, the monitoring of actual consumption is not accessible or intuitive as implied in the text. On the contrary, data on real time usage is not accessible or continuously available on the online portal, and should be urgently improved, to give households the tools to assess their energy consumption and adjust accordingly.

We applaud the continued commitment to protect those at risk of energy poverty.

4.4 We urge the Government to give greater consideration to the potential role of renewable energy communities in Malta, and create the supportive enabling framework and designing support schemes for renewable energy communities, which it is required to provide by law as per the transposed from article 22 of the Renewable Energy Directive (RED) (2018/2001), which was (partially) transposed in S.L. 545.35. The recently launched ‘Pannelli bla Bejt’ is a very good initiative, which provides options for households who do not have their own roof space to invest in solar panels. However, it cannot be considered a renewable energy community project as it is managed and governed by a government entity – Water Services Corporation. Friends of the Earth Malta published a report ‘People Power Up’ on the potential of renewable energy communities in Malta, with clear recommendations, which may be found here: https://foemalta.org/download/people-power-up-report/

Pillar 2 – Security of Power Supply

5.1 We applaud the recognition of the importance of diversified renewable energy production and storage as a measure of resilience and future proofing for Malta.

5.2 We remain highly concerned and critical about the proposed Melita gas pipeline. The vast majority of hydrogen on the market today comes from fossil fuels (95-99%), with green hydrogen accounting only for a very small percentage of the hydrogen currently available on the market. Furthermore, the creation of hydrogen through electrolysis is an energy and water intensive process. Hydrogen is not an efficient energy carrier; the electricity

from renewable sources needed to create ‘green’ hydrogen can be used more efficiently directly as electricity. Therefore, the EU hydrogen strategy emphasises the importance of targeting the use of hydrogen only in specific processes for which there are limited or no climate-neutral energy alternatives, hard to decarbonise sectors such as steel production, and shipping and aviation industries (EC, 2020). We highly discourage the use of hydrogen to ensure baseline power generation and urge the Government to prioritise Battery Energy Storage Systems instead. When discussing our local (not ‘indigenous’, they don’t “occur naturally in this place”) power plants, it is false to present these as providing inherent resilience. Our power plants run on imported LNG, a fossil fuel, dependent on suppliers and supply chains in unstable regimes such as Azerbaijan, the Middle East and the United States. This is energy dependence, not independence. Instead, we should improve our energy resilience via locally produced renewable energy and storage systems, as discussed in other sections of the document. We have discussed our issues with the Melita gas pipeline and hydrogen-readiness in detail in our report ‘Towards a Fossil Free Malta’: https://foemalta.org/download/towards-a-fossil-free-malta/

5.3 While investment in grid modernization, storage integration and grid resilience is welcomed, grid expansion should be accompanied by stronger transparency regarding projected demand increases, renewable integration capacity and climate resilience planning.

5.4 Good. However, it is important to note that there is currently a limited window of opportunity to get this right. Battery deployment strategies should also include plans regarding lifecycle sustainability, recycling infrastructure, material sourcing, and end-of-life management to minimize future environmental impacts.

5.5 Although interconnectors can improve grid resilience and flexibility, Malta should try to limit dependence on imported electricity and should prioritize maximizing local renewable energy generation and decentralised energy systems. The plan also lacks transparency on the long-term emissions of the imported electricity, a large share of which in the current energy mix of Italy is generated from fossil fuels.

5.6 The flow of energy between North Africa, Malta, and Sicily must be able to go both ways and should not be framed as taking advantage of Libya and Tunisia’s energy resources in a  colonial fashion. A possible energy link between Libya, Malta and Sicily should be cooperative and collaborative in nature, respecting and benefitting local communities and protecting ecosystems in North Africa, not furthering a potential form of green extractivism.

Pillar 3 – Sustainability of Power Supply

6.1 The per capita energy consumption rates for Malta do not include shipping or aviation. It would be insightful and transparent to also provide a figure including the emissions associated with international transport. 

6.2 Good. Priority should be given to solar PV deployment in urban areas, close to where energy is being consumed. Opportunities should be provided to citizens, local authorities and SMEs participating in renewable energy communities to develop renewable energy projects on identified public land, such as roofspaces and carparks. 

6.3 The current shore-to-ship infrastructure is a positive initiative but is extremely underutilised thus far. We urge the Government to adopt regulations to ensure that ships are obliged to connect to ship-to-shore infrastructure. Ships that are not equipped with the necessary technology to connect to such infrastructure should not be allowed to berth in Malta’s ports. We urge that by 2030 all cruise liners visiting Malta’s Grand Harbour connect to shore-to-ship infrastructure, and call upon the government to develop and implement a clear national roadmap leading to 2030 which sets out the progressive rollout and utilisation of ship-to-shore power infrastructure, with timelines for implementation, targets for utilisation and the categories of vessels expected to connect. Public authorities should publish regular and accessible information on the utilisation of ship-to-shore power infrastructure within the Grand Harbour, including the number of ships connecting to shore power, the duration of connection, utilisation rates of the installed infrastructure, and estimated emissions reductions achieved.

To ensure international connectivity, Malta should also advocate for and invest in improved ferry connections to other countries and Mediterranean ports (and integration with subsequent high speed rail connections) to reduce reliance on aviation. The aviation sector is notoriously difficult to decarbonise and has a very high carbon footprint when compared to other means of transport. The technology is also currently unlikely to improve significantly enough to allow meaningful decarbonisation of this sector. We thus urge the Government to shift demand to less polluting forms of transport which is more easily decarbonised than aviation.

The transition to EVs is framed as ‘greener transport,’ but 80–90% of electricity is still generated from fossil fuels. This merely shifts emissions from cars to the power station, a phenomenon known as the ‘long tailpipe problem.’ There is an extremely urgent need for transport modal shift, away from private car use to active and public transport. This was also identified in the Low Carbon Development Strategy as a short-term priority measure. 

Rather than framing it as a negative, compact urban form is actually an opportunity for active travel and public transport – if given the dedicated space and protected infrastructure. Transport equity and accessibility remain inadequate, with little emphasis on active transport infrastructure. Safe, comfortable pavements are crucial for elderly individuals, people with reduced mobility, and parents with pushchairs, yet they are often neglected. Meanwhile, cycling has the potential to serve as a cost-effective and healthy transport option, provided that safe cycling infrastructure is developed to support it. Public transport is a much more efficient way of transporting people than private cars, making sense in our dense and constricted urban space, if there is the willingness to prioritise public transport over private car use, by creating increased and connected dedicated public transport lanes. 

To encourage further electrification of the transport system, we urge the government to more widely roll out electric vehicle charging infrastructure, as these are not yet readily available to encourage more widespread adoption of such technology, and to ensure this is paired with a rapid increase in the share of renewable energy in the mix. 

A discussion on the electrification of Malta’s ferry system is lacking. 

Hydrogen as a green transport fuel must be avoided at all costs, as it is not delivering on its promise. A recent case study from Poland (“Hydrogen buses: Where did it all go wrong?”) shows that public investment in hydrogen buses has led to huge stranded assets, due to the lack of available / affordable hydrogen, let alone that green hydrogen is not available on the market at all. Electrification of public transport is much more straightforward and resilient. 

6.4 Energy efficiency is good, but the energy hierarchy needs to be observed. Reducing demand (‘energy saving’) comes before energy efficiency measures, meaning demand reductions should be included and need to be prioritised.

6.5 Good.

6.6 Friends of the Earth Malta continues to express its concern about the construction of a waste-to-energy incinerator, noting that this does not help reduce the amount of waste generated which should be the first course of action, and it discourages recycling and reuse. Furthermore, the burning of municipal waste produces harmful chemicals and pollutants, including greenhouse gas emissions. Energy generated from such plants thus cannot be considered ‘green’ or ‘renewable.’ For this reason, numerous organizations across Europe are seeking a ban on incinerators. While recognizing that this initiative is likely being considered in order to achieve the Landfill Directive [Amending Directive (EU) 2018/850], which requires that all Member States must reduce the amount of municipal waste sent to landfills to 10% or less of total municipal waste generated by 2035, Malta should be fulfilling the measures laid out in the Long Term Waste Management Plan 2021-2030 and following best practices such as Extended Producer Responsibility, Pay as You Throw, MRBT (Material Recovery Biological Treatment), or other measures. Malta has made much progress with its waste system with waste separation efforts and BCRS, and we appreciate the modular design of the proposed incinerator. However, we emphasize that properly sized incineration facilities for any residual waste may be a valid consideration only once all other waste reduction and materials reuse measures have been implemented. This approach would also likely be less costly.

6.8 See feedback under point 5.2. The claim that this project is “fully aligned with the European Green Deal” is an unsubstantiated statement. 

6.10 See feedback under point 5.2. Also, kindly note that although the burning of hydrogen does not produce carbon dioxide and other traditional pollutants, it produces water vapour which is technically still a greenhouse gas.

7.2 See feedback under point 5.2.

7.3 Good.

Pillar 5 – Consumer Centred Approach

8.4 See feedback under point 4.4.