The Green Tank contributed with comments to the public consultation on the draft bill “Provisions for the simplification of environmental licensing, environmental inspections and environmental protection, urgent provisions on forestry, spatial planning and urban planning, establishment of a framework for the development of Offshore Wind Farms, addressing the energy crisis and issues of circular economy” of the Greek Ministry of Environment and Energy.
The comments focus mainly on the Chapter on “land uses and protected areas” and its specific provisions where the Green Tank observes a clear deterioration of the existing framework for protected areas planning. Specifically, Article 11 retains the predefined list of permitted uses per zone of protected areas. The Green Tank recommends the full revision of this problematic approach and that the selection and specification of permitted uses should be made by experts according to the characteristics of each area, in a way that is compatible with the definitions of the zones contained in Article 12. Alternatively, the following recommendations constitute minimum necessary revisions to the draft bill:
- linear transport infrastructure and, more generally, technical installations and infrastructure must not be permitted in the absolute protection zones,
- tourist facilities, electricity, fossil gas and renewable energy infrastructures must not be permitted in nature protection and absolute protection zones,
- hydrocarbon exploration must not be permitted in any protection zone.
In its general comments, the Green Tank highlights the Chapter on the “framework for the development of offshore wind farms” is brought in public consultation as an important development . However, this framework should be complemented by the timely preparation and adoption of a Maritime Spatial Plan, which is to be funded by the Recovery and Resilience Fund, and the revision of the Special Spatial Plan for renewable energy.
The Green Tank also draws the attention to the Chapter on the “provisions to address the energy crisis”, which, in Article 76, proposes the financing of fossil gas infrastructure projects through the Public Investment Programme (PIP). In the midst of the energy crisis, soaring energy costs and the shift of financial institutions away from fossil fuels, and also taking into account that the Greek National Climate Law was adopted, only a few weeks ago, the priorities of the PIP should be directed towards promoting and financing alternative solutions (renewable energy, electricity storage, demand management systems, energy savings, heat pumps, etc.) that will have long-term benefits for the citizens, the economy and the climate.
Finally, the Green Tank argues that the duration of public consultations should be sufficient and adequate to allow for meaningful participation of citizens and stakeholders. The period given at the beginning of the consultation for this specific draft bill (less than one week) does not even comply with the already restrictive two-week period set by Executive State Law.
The comments submitted by Green Tank are available here (in Greek).
