The Green Tank’s comments and recommendations in the public hearing on the new bill by the Ministry of Environment and Energy

After contributing to two separate public consultations on the drafts of the new bill (see relevant blogposts here and here), The Green Tank participated in the public hearing at the relevant Committee of the Greek Parliament on the Ministry of Environment and Energy’s bill titled “Renaming of the Regulatory Authority of Energy to Waste, Energy and Water Regulatory Authority and broadening its scope with responsibilities for water services and urban waste management, strengthening of water policy – Modernization of the legislation on the use and production of electricity from renewable energy sources through the transposition of the EU Directives 2018/2001 and 2019/944 – Special Provisions for renewable energy sources and the protection of the environment”. The Green Tank was represented by Ioli Christopoulou, Co-Founder and Policy Director.

Of all the comments and recommendations, The Green Tank’s intervention focused on the provisions on the energy communities, which transpose the EU Directives 2018/2021 and 2019/944, the energy regulations and the provisions for the protection of the natural environment.

Regarding energy communities, the provisions in Article 60 for the financial support of net metering, virtual net metering and energy storage projects by public funding as well as the inclusion in the development law were highlighted as positive.

Similarly, the legislation in Article 64 of electricity space up to 2 GW exclusively for net metering and virtual net metering projects is considered extremely positive.

However, amendments are deemed necessary in the following areas:

  • The provision for 3 categories of energy communities can be confusing as to their definition and the purpose of each category.
  • Priority should be given to access to the grid and resources of self-production projects, especially by citizen energy communities.
  • In articles 47 and 88, the minimum number of members required for the creation of citizen energy communities should be reduced from 60 to 30. As it stands, it makes it almost impossible to set up an EnCom in distant, mountainous or island regions with small populations.
  • The provisions in Article 109 for new extensions to the feed-in tariffs to energy communities for solar and wind projects, i.e. mature technologies, are not in the right direction, especially if they relate to for-profit projects by energy communities. This is because they undermine the positive provisions in Article 54 which rightly limit the profit making of energy communities.

With regard to regulations on energy, the abolition of the production license of fossil fuel plants, as provisioned in Article 160, is noted as positive. However, the amendments to the licenses must comply with the National Energy and Climate Plan. In addition, the targeted provision for Ptolemaida 5 (par. 14) seems to leave open the possibility of replacing the lignite-fired Ptolemaida 5 with a fossil gas plant of even a larger capacity, which according to earlier PPC announcements could reach 1100 MW. Given that PPC has not yet decided on the future of Ptolemaida 5 after the end of its lignite operation by 2028 at the latest – in accordance with national climate law 4936/2022 – it is necessary to keep open the possibility of converting it into a renewable electricity storage facility in the form of heat (thermal storage).

Also, it is considered necessary to incorporate additional safeguards for the First Choice Sites (go-to-areas) for Renewable Energy Projects, in Article 164, as foreseen by the extraordinary European Regulation for the Acceleration of Deployment of Renewable Energy.

Regarding the provisions on the protection of the natural environment, it is noted as positive that for the first time legally binding targets are set for the protection and restoration of nature, in line with the latest international and European commitments for 2030 (Articles 174 and 175). However, these targets should also be complemented by targets for areas of strict protection.

Ioli Christopoulou also pointed out a number of potential problems regarding the way in which changes in the design of protected areas are formulated (Articles 178 and 179), namely that:

  • They may further delay the implementation of the Special Environmental Studies and the fulfilment of the country’s EU obligations.
  • It creates the risk that existing activities could tie up protection objectives and conditions.
  • It precludes the designation of regulations on adjacent areas.

Thus, The Green Tank re-submitted its proposal to abolish the land use provisions and complete the definitions of the categories and zones of protected areas, in line with international and European standards.

In addition, The Green Tank welcomed the strengthening of the Natural Environment & Climate Change Agency (NECCA) powers in environmental control (Article 184) and suggested that this should be complemented with the assignment of pre-investigative tasks for more effective nature conservation.

Finally, it was stressed that it is extremely urgent to draft a new National Biodiversity Action Plan and to adjust the financial priorities for the implementation of all nature provisions.

The public hearing was held on Tuesday March 07, 2023.

The Green Tank submitted a memo with its full comments and recommendations which is available here (in Greek).

You can watch the full session of the Committee (in Greek) at

Here follows the contribution by The Green Tank (in Greek):