Green Tank comments on the draft law “Modernization of Environmental Legislation”

The Green Tank submitted its detailed comments and proposals during the public consultation on draft law titled “Modernization of Environmental Legislation”, which concluded yesterday. The Green Tank’s submission concentrated on the following:

1. Protected area designation, categories and land use: The provisions of the draft law presented by the Ministry of Environment and Energy essentially cancel the concept of planning a protected area and adjusting the necessary regulatory framework to each area’s unique characteristics. The Green Tank proposed specific revision which aimed to:

  • clearly define the categories of protected areas,
  • integrate the Natura 2000 sites into the national system of protected areas, but also enable the conservation of elements of Greek nature that would otherwise remain unprotected, and
  • enable the selection (rather than pre-determination) of uses and activities to be permitted in each area based on the particular natural elements protected in that specific area and the provision for a clear scaling of measures from looser to strict, closer to the core of each protected area.

2. Governance of protected areas: The draft law also provides for the reform of the management of the national system of protected areas, only two years after the previous reform. Fortunately, it retains some of its positive elements, namely, it still covers all Natura 2000 sites and includes provisions for financing from the regular national budget. By establishing an Environment and Climate Change Agency and local Protected Areas Management Units, Greece could acquire a central coordination mechanism for the country’s protected area system, supervised by the Ministry of Environment and Energy. In its comments, the Green Tank points out that:

  • Further clarifications are needed on the new Agency’s operation and, in particular, the relation between the Agency and the Ministry must be further clarified.
  • Critical responsibilities that management bodies of protected areas had to date are being eliminated in the draft law; the most important of which being the expression of opinion on planned projects and activities that could impact a protected area. Revisions are needed to ensure that these responsibilities are reinstated
  • The transition to the new system should go forward only if all necessary prerequisites for its smooth operation are secured, including necessary  regulatory acts, staff, equipment and resources.

When a protected area system, from its design to its governance, is coherent and operational then it can fulfill effectively its central role in biodiversity conservation and contribute to local sustainable development. 

3. Environmental licensing process:  The process of environmental licensing stems from the prevention principle. As a result, while trying to speed up processes, the procedures of environmental licensing must not be considered as a time-consuming hurdle. Rather, it must be considered as an indispensable tool aimed to ensure the best possible protection of the environment, healthy business competitiveness and sustainable development.

Read the full text (in Greek)