On 5 December, the Mepa Board held a hearing on its proposal to grant a temporary IPPC permit to Enemalta for running the Delimara Power Station Extension (DPSE) on heavy fuel oil (HFO) rather than gas oil from January 2012 to September 2012.

Three local councils – Marsaxlokk, Birzebbuga and Zejtun – opposed the use of HFO in DPSE, making quite a direct case. Air quality measurements and emission calculations supplied by both Mepa and Enemalta, especially those relating to fine particulate matter (PM10 and PM2.5) with the most adverse health effects, indicated that the situation at the measuring stations was already compromised in terms of EU air quality regulations. The coming on stream of DPSE could only make matters worse. An installation of national significance should not be stopped or hindered except for the most serious reasons. So the local councils argued that Enemalta was obliged to choose the least polluting fuel available − in this case gas oil instead of HFO – especially as it could do this without incurring “disproportionate” increase over present cost. In fact, it was shown that for the same amount of electricity, DPSE using gas oil worked out cheaper than Marsa using HFO, as the former, being twice as efficient as the latter, would use half the amount of fuel that Marsa is using per unit generated.

The main effort of Enemalta went into keeping public attention firmly fixed on the future. Given the price difference between HFO and gas oil, the use of these fuels in DPSE is bound to favour HFO in terms of overall cost. Even then, in the Cost Benefit Analysis that Enemalta presented with its IPPC permit application, there were points where HFO was incorrectly favoured.

Enemalta argued that some of those high readings for particulates mentioned by the local councils were due to sporadic arrivals of Sahara dust. In any case, if HFO is “dirtier” than gasoil, the DPSE filters were going to trap all PM2.5 and PM10 – an unproven assertion and one which might make as much engineering sense as sticking a potato in your Euro2 diesel exhaust to get it up to Euro5.

So far so fairly good; but when assertions about increases to current utility charges started to be made, Enemalta’s position started to erode. Mepa delivered the final blow with its proposal for a temporary permit. At the hearing, Enemalta presented a ‘study’ by KPMG (not part of the original submission), which was supposed to determine the cost of running DPSE for eight months (May-December 2012) on HFO or gas oil. Truth to tell, any Enemalta engineer could have done the job in a couple of hours, but clearly a prestigious name behind the “study” would increase its credibility.

The first result was that gas oil use over eight months would require €19.9 million more than HFO. And then, so as to make matters clear to the meanest intelligence, KPMG concluded: “The Cost Impact Analysis estimates that if the Extension is operated on gas oil for eight months during 2012, the target variable revenue to be recovered through consumption charges underlying the current tariff (my emphasis) for this period would need to be increased by 10.16 per cent.” Any idiot, particularly one railing against the current tariffs, could see that that was “a disproportionate” cost.

The problem with this conclusion is that it is mistaken at every level. The “scenario” used by KPMG, with all of DPSE (144 MW) running 24 hours day for 240 days is engineering nonsense. The engines cannot be run at that rate, and if they were so run, they would generate some 2.5 times the electricity we would be losing from the partial closure of Marsa, without there being any demand for it. KPMG passed that buck to the Enemalta engineers present at the hearing. The engineers were dumb. The local councils side was not. A correct DPSE generating schedule designed to supply the amount of electricity we would need after the partial closure of Marsa brought the HFO cost advantage down to €7.6 million and the “necessary “ tariff increase to four per cent.

But the final KPMG conclusion quoted above was not just quantitatively wrong, but also wrong in principle. Current rates are determined partly by Marsa using HFO, and not by an as-yet-dormant DPSE. So to determine the effect on current utility charges, the correct HFO-gas oil comparison is between cost of present Marsa running on HFO and cost of future DPSE running on gas oil to produce the same amount of electricity. It turns out that gas oil DPSE is cheaper than HFO Marsa, because DPSE will use half the amount of fuel Marsa uses per unit of electricity generated. The KPMG “study” suffered the fate of Humpty Dumpty, and it could be not be put together again by complaints that comparison with Marsa was not within the KPMG brief. Maybe it was not but the final conclusion on the “unavoidable” increase in current tariffs if gas oil was used in DPSE logically implied a comparison with Marsa.

And Enemalta was found to be pushing its case with a totally erroneous report its engineers were quite unable to defend. Yet despite this being made evident to the Mepa board, no questions were asked and all but one raised their hands in favour of HFO use in DPSE during this so-called trial period. In the face of this, well may we cry “Poor fellow my country”.

E.A. Mallia

ATTARD