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Landmark decision by RAAEY on Energy Communities

Joint Press Release

A fundamental step towards cleaning up the sector, prompted by the Akarnanika Mountains case.

A decision of utmost importance for the integrity of the institution of Energy Communities (ECs), Citizen Energy Communities (CECs) and Renewable Energy Communities (RECs) was announced last week by the Regulatory Authority for Waste, Energy and Water (RAAEY).

According to the Authority’s announcement, published on its website last week, RAAEY issued an interpretation of the relevant legislative provisions to address the issue of ownership concentration that has arisen during the licensing process of ECs—an issue that leads to the abuse of the rights granted under the Energy Communities legislation.

The extensive and detailed announcement leaves no room for misinterpretation regarding cases of abuse of the Energy Communities framework. Its main points can be summarised as follows:

  • It emphatically states that ownership concentration in ECs, CECs and RECs contradicts their cooperative nature and, in practice, undermines their non-profit character (which is clearly stipulated in the law), revealing commercial exploitation of these schemes.
  • It clarifies that the correct interpretation and application of the legal framework leads to the understanding that the legal entities participating in such energy communities must be independent from each other. In other words, they must not be linked through any natural or legal person that participates directly or indirectly in their management or holds a shareholding, partnership or membership interest—regardless of the percentage involved.
  • RAAEY explicitly states that it has the authority to examine the ownership structure of ECs, either on its own initiative or following a complaint, and—in cases where the independence of members is not ensured—to proceed even with the revocation of Certificates/Production Licences.

This significant decision by RAAEY was prompted by the joint intervention and complaint of 22 environmental organisations concerning the abuse of the institutional framework by ECs operating 15 Wind Farms (WPPs) in the Akarnanika Mountains.

In this particular case—brought to light by the Hellenic Ornithological Societythere is clear ownership concentration and a breach of the independence requirement for EC members, since nearly half of each EC’s members are single-member companies controlled by the same economic entity. Although this deviation from the law had been repeatedly highlighted, no action had been taken by the Administration to clarify the relevant legislative framework—something now achieved decisively through RAAEY’s announcement.

The undersigned organisations welcome RAAEY’s announcement, considering it an essential and foundational step towards restoring integrity to the sector and highlighting genuine Energy Communities. The next step is the implementation of this decision—starting with the case of the Akarnanika ECs—and the adoption of related initiatives by the Ministry of Environment and Energy, such as issuing clear guidance to all services involved in the licensing of RES projects to identify such abusive cases.

The undersigned organisations:

  1. Alkyoni – Association for the Care and Protection of Wild Animals
  2. ALKYON – Federation of Ecological Organisations of the Corinthian Gulf
  3. ANIMA – Hellenic Wildlife Care Association
  4. ARION – Research Centre for the Rescue and Care of Cetaceans
  5. ARCHELON – The Sea Turtle Protection Society of Greece
  6. Hellenic Society for the Protection of Nature
  7. Hellenic Ornithological Society
  8. Thrace Biodiversity Protection Society
  9. Society for the Protection of Prespa
  10. CALLISTO
  11. Ecological Recycling Society
  12. PANDOIKO – Panhellenic Network of Ecological Organisations
  13. Pindos Environmental
  14. Naxos Wildlife Protection Association
  15. Tulipa Goulimyi Association
  16. Friends of Nature Greece
  17. Greenpeace
  18. iSEA
  19. MEDASSET
  20. MedINA – Mediterranean Institute for Nature and Anthropos
  21. The Green Tank
  22. WWF Greece