Reading through the Green Paper entitled “Towards Cleaner Vehicles on Our Roads” it is evident that this consultation process is flawed. After being four years in the making, instead of proposing solutions it just asks questions which should have been answered by the Green Paper itself as part of the consultation process.

This is symptomatic of a government which has been continuously emitting conflicting signals on transport issues. The Green Paper recognises the obvious when it states that transport combustion emissions increased by 86 per cent over the period 1990-2018. The massive investment in unnecessary road infrastructure has been a major contributor in this respect, a point which is conveniently ignored by the Green Paper.

The proposed shift to cleaner vehicles on our roads is welcome, but on its own it is not sufficient. This measure will definitely reduce combustion emissions. It will however also shift the said emissions from our roads to the sources of the electrical energy used to electrify our roads. Knowing that government is planning to install a second interconnector to the Sicilian mainland for the supply of electricity it is clear that part of the emissions will be shifted 80 kilometres to the north, the rest to Delimara. It is still unclear how this will be reflected in the price we pay for electricity, as information on the matter is conveniently absent from the Green Paper.

The Green Paper rightly discusses the need to upgrade the skills of the technical personnel required in servicing and maintaining electric and hybrid vehicles. It also points towards the need for substantial investments in the infrastructure required particularly for charging points. However, it fails to address a number of points of controversy which require urgent resolution and should have been addressed through this consultation process.

The consumption of petrol and diesel is bound to decrease as a result of the drive towards the electrification of our roads. The rate of decrease of fuel consumption will depend on the manner in which the electrification exercise will proceed throughout the transition period. Why then has no moratorium been announced on the development and construction of new fuel stations? A number of controversial applications for fuel stations are still burdening the land use planning process when it should be crystal clear to all that in view of the electrification process, they will no longer be required. The consultation process is conveniently silent on the matter thereby encouraging unnecessary pressures on the planning process.

Simultaneously it is pertinent to point out that the sale of fuel contributes a substantial income to the exchequer which income will now slowly taper to near zero through the transition period. The Green Paper fails to volunteer information in this respect. How will this substantial income be substituted? Will the electrification process itself provide the substitute financial resources or will other areas of activity be tapped to make good? The amounts involved are substantial. In fact, the budgetary estimates for 2021 indicate a projected income of €154 million from excise duties on petroleum products. What are government plans for the substitution of this income? The Green Paper is once more completely silent on the matter.

The Green Paper refers to Low Emission Zones but it does not have the courage to make specific proposals. It is imperative that the transition period from now until the full electrification of our roads gradually adopts the identification of Low Emission Zones within which internal combustion engine vehicles will have a prohibited access. The Green Paper fails in this respect too.

The Green Paper refers to two studies which have been commissioned by the Cleaner Vehicles Commission on the electrification of our roads. These studies are not however available to inform this public consultation.

Notwithstanding having been announced four years ago, with ample time for preparation, this consultation process is deficient. It fails to address the basics: it fails to inform. It is a fake consultation.

An architect and civil engineer, the author is Chairperson of AD + PD - The Green Party in Malta.  [email protected] ,   http://carmelcacopardo.wordpress.com