The promulgation of legislation facilitating investment in renewable sources of energy, together with financial incentives, have been instrumental in encouraging investment to achieve Malta’s 10 per cent benchmark in renewable energy, in accordance with the EU 2020 targets.
The draft National Renewable Energy Action Plan (NREAP) highlights that since the introduction of financial subsidies and advantageous feed-in tariffs, installation of solar panels has increased substantially. This has resulted in a yield of 4.4 per cent in energy produced through renewable sources, primary among them solar energy.
This figure is expected to increase in the near future, particularly since the draft NREAP confirmed the impetus on solar energy as Malta’s primary source of renewable energy to reach the 2020 targets. This policy will be aided by the establishment of solar farms, announced by the government in recent months.
The draft solar farms policy developed by then Mepa in 2014 establishes guidelines for the development of solar farms by the private sector. Nonetheless, the development of solar farms may be problematic to achieve – not only due to the Maltese islands’ diminutive size but also due to the specifications enshrined in this draft development brief.
This brief limits the definition of a ‘solar farm’ to installations covering a footprint of equal to or greater than 1,000m2.
Since the policy aims to limit solar farms to urban areas, it is unlikely that such open areas are available for similar developments within development zones.
This renders cooperation between the public and private sector imperative if we are to ensure that the existing infrastructure can be upgraded to cater for the development of jointly owned solar installations.
The draft policy identifies rooftops, open spaces and disused quarries as ideal property which may be considered for the development of solar farms. However, the greatest obstacle in this regard will be the footprint criteria, since some ideal sites may not allow the required level of development. A potential solution would be to decrease or remove the footprint criteria in its entirety and bestow its incentives to installations which produce an established output, saving – of course – planning and design considerations which must always be taken into account.
It would be erroneous to become over-reliant on governmental schemes to invest in renewable energy
Additionally, the development of such installations on the rooftops of existing commercial buildings may be more feasible to achieve. Decreasing or removing the established footprint would enable additional participation by private investors and cater for technological advances, through which a greater output may be achieved from smaller photovoltaic cells, as well as integrated photovoltaic cells.
This option may also be more financially feasible than repurposing dilapidated and unused quarries as solar farms. Considerable investment must be undertaken to successfully develop a solar farm on such sites, leading to a longer return on investment. Depending on the actual size of the proposed site, this end up being economically unfeasible on a long term basis.
The draft policy identifies areas in close proximity to urban areas with high electrical consumption as preferred areas for investment in solar farms. This is a reasonable approach given that one of the greatest problems concerning the generation of renewable sources of energy is its high rate of dissipation due to inefficient storage. However, issues pertaining to the lack of available space to qualify any installation as a solar farm would persist, given the lack of land available to be used primarily for such projects.
A possible solution would be to extend the benefits envisioned for solar farms to developments in condominia, mirroring an approach taken by Germany and France to promote solar energy. Through such a scheme, generated electricity could be fed into the electric grid through the feed-in tariff system in the form of credits, which are then deducted from the electric bill of the tenants.
Such an approach could be encouraged with regard to new buildings through deductions in licensing and building fees. The establishment of a set footprint or potential output with regard to rooftops could be set through a voluntary licensing scheme, with building licenses increasing or decreasing depending on whether the proposed benchmark is met.
Additional consideration should also be made for photovoltaic cells integrated with construction materials and infrastructure, especially considering the potential of this technology in relation to high-rise buildings.
Nevertheless, it would be erroneous to become over-reliant on governmental schemes to invest in renewable energy, mostly since the government is itself constrained by the EU State Aid Directive. It is important to ensure that prior to embarking on a sustained programme of photovoltaic proliferation, the proposed plan is both environmentally and economically sustainable, in order to contribute towards sustainable development as part of a long-term plan spanning beyond the EU 2020 targets.
Edward Camilleri is a lawyer at SAGA Juris Advocates.
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