How energy smart is Smart City?

The Environmental Impact Statement (EIS) for Smart City has just been published. Respected environmentalists have criticised the energy demands of the proposed development, while the developers have attempted to justify the energy demands indicated in the EIS, confirming their compliance to the LEED (Leadership in Energy and Environmental Design) voluntary 'green' building rating system.

Professionals in the local construction industry are currently coming to terms with the implementation of the Energy Performance of Buildings Directive, due to come into force throughout the EU by not later than January 1.

Legal notice 238 of 2006 introduced the minimum requirements on the energy performance of buildings regulations. Although these requirements did not really involve radical changes in the local construction techniques, mainly reinforcing traditional requirements which had, however, been put aside by time, the implementation of these regulations is still in its initial stages.

Although the majority of professionals in the construction industry have been informed about the introduction of the minimum requirements and the framework of the energy performance of buildings directive, it is still not clear how this legislation is to be applied in practice. One reason for this uncertainty can be attributed to the fact that while practically all requirements in relation to the planning process are defined by or channelled through Mepa, the responsibility for the legislation related to the energy performance of buildings has so far been entrusted to the Malta Resources Authority.

Now the question in relation to Smart City's environmental credentials as published in the EIS is whether the EIS reflects the energy performance of buildings directive.

The terms of reference for the EIS clearly state that:

A) A framework for an energy and water management plan shall be submitted, which will take into account:

• Energy performance of the design, construction materials, etc.;

• Integration of low/zero carbon technologies to meet, as far as possible, the building's energy needs; and

• Consideration of energy efficiency measures in the finishing and operation of the building.

B) Features which increase energy consumption unnecessarily should be avoided. For example, by taking into account issues such as building orientation, natural ventilation, etc., energy requirements can be significantly reduced.

The Energy Performance of Buildings Directive, Article 5, states:

"Member States shall take the necessary measures to ensure that new buildings meet the minimum energy performance requirements referred to in Article 4.

"For new buildings with a total useful floor area over 1,000 square metres, member states shall ensure that the technical, environmental and economic feasibility of alternative systems such as:

• decentralised energy supply systems based on renewable energy,

• CHP (combined heat and power),

• district or block heating or cooling, if available,

• heat pumps, under certain conditions, is considered and is taken into account before construction starts."

In general terms, the Mepa terms of reference cover the same ground as the directive, although the directive is more specific in its requirements. When considering the voluminous report presented by the Smart City consultants, it does not seem that attention has been given to the technical, environmental and economic feasibility of alternative systems or renewable energy.

Unfortunately, the only focus on energy in the report appears to be on the overall energy requirements of the project, based on a conventional energy supply, and oriented towards establishing the necessity of strengthening the power generation and distribution network in the area to be able to meet the projected energy requirements. At no point in the document is any analysis of the possibility of alternative energy use outlined, nor is there any indication of the percentage energy use of the project that is to be met by alternative energy. The developers and their consultants must have invested considerable time and money in the preparation of the EIS, and this was requested by Mepa. The question is "Are we getting our money's worth?" Sadly, this does not seem to be the case.

In spite of the requirements of the EIS terms of reference, it definitely appears that little or no consideration has been given to the possibility of minimising the power consumption of the development, or to the use of alternative sources of power. This is of particular concern due to both the size of the development and the fact that this consideration should become a legal requirement as of January 1.

The executive summary of the Infrastructure preliminary design report states that "it is understood that Enemalta have agreed to provide 19MVa of power to Smart City but calculations show that the demand generated by the development will be approximately 42MVa. Enemalta would expect the developer to pay for any additional power requirements over the 19MVa."

This statement should be considered as an opportunity for the project design team to tackle the expected shortfall by both minimising the demand generated by the development and by generating the difference on site using alternative technologies. Nowhere in the extensive report does any of this feature, but instead there is a repeated reference to 'conventional cooling systems' as major contributors to the energy demand.

I is unacceptable for an environmental impact statement to be carried out for such a large scale development with no analysis of the environmental impact of the energy requirements of the project.

Mr Abela is a building services engineer with an active interest in energy conservation and environmental issues.