The Green Tank submitted comments and recommendations on the draft bill by the Greek Ministry of Environment and Energy “Provisions for renewable energy sources and the protection of the natural and spatial environment”. They refer to articles of the “Part B – Regulations for Energy” and “Part D – Provisions for the Protection of Natural Environment.
Specifically, on Regulations for Energy, we note as positive elements a) the abolition of the production license of fossil fuel plants (coal, lignite, fossil gas, oil) that do not yet hold a connection offer and b) the possibility to convert the production license of fossil gas-fired plants that do not yet hold a connection offer into electricity storage licenses, provided that the request is submitted by 30 June 2023 (Article 52). However, we consider that it is necessary that the amendments to the licenses of plants production comply with the National Energy and Climate Plan.
Regarding the First Choice Sites (go-to-areas) for Renewable Energy Projects (article 55), we consider that in addition to accelerating renewable energy projects, it is necessary to incorporate additional safeguards, and in parallel to accelerate implementation of actions that fulfill basic obligations concerning the protection of nature and to complete of the revision of the Special Spatial Plan for RES.
Regarding the Provisions on the Protection of the Natural Environment, our comments relate to Articles 64, 65, 69 and 72. Indicatively, we note, among other:
- It is positive that Greece is setting legally binding targets for both the protection and the restoration of nature, in line with international and European commitments. However, they need to be complemented with targets for a strict protection framework in line with the EU 2030 Biodiversity Strategy.
- Although the legal recognition of Key Biodiversity Areas is very important in principle, there is no definition in Greek law to determine which areas can be perceived as such (Article 64).
- While Article 65 contains provisions for the design and implementation of restoration measures within Natura 2000 sites, the same does not apply to the design of restoration measures outside Natura 2000 sites (apart from the provision for a National Action Plan to reverse the decline of pollinator populations in Article 66).
- In order to implement both the provisions on nature protection and those on nature restoration, it is extremely urgent to formulate the new – second – National Biodiversity Action Plan for the implementation of the National Biodiversity Strategy 2014-2029, which has been pending since 2020.
- The implementation of nature protection and restoration measures requires the adjustment of available resources and related funding priorities.
- It is necessary to complete the definitions of categories and protection zones of protected areas, according to international (see IUCN) and European (see European Commission) standards, so that, as we had proposed in the past, they function as a criterion/filter for the selection of land uses and permitted activities in each protection zone depending on the characteristics of each protected area.
- Given that protected areas are areas where human activities can be developed although they must be regulated, the Special Environmental Studies that document the protection measures in each protected area, should ensure, among others, that existing human activities do not interfere with the objectives of the protection, while allowing for provisions that concern adjacent areas.
- It is a positive step that the responsibilities of the members of the Natural Environment & Climate Change Agency (NECCA) in environmental control are expanded, but this should be supplemented to include additional enforcement responsibilities, in order to ensure a more effective guarding of protected areas.
In our text we point out the slippery slope of submitting such a bill with only four (4) days of public consultation (24-28/02/2023), three (3) of which were non-working days and in parallel with two (2) other bills from the same ministry. Furthermore, this bill is an example of poor lawmaking as it includes, among other things, provisions relating to energy communities at a time when there is another bill focused on energy communities also under consultation.
You can find the full text of the comments and recommendations we submitted to the public consultation here (in Greek).