Comments and recommendations by The Green Tank on the multi- bill by the Ministry of Environment and Energy

The Green Tank submitted comments on the draft law of the Ministry of Environment and Energy (MEEN), which was put out for public consultation between 6 – 15 April 2024 and is titled “Regulations to address the multi-level impacts of climate change in the areas of: a) water management, b) forest management and protection, c) urban resilience and policy, d) combating unauthorized construction, e) energy security”.

On the consultation process, the Green Tank criticized the continuation of the bad practice of very limited time for submitting comments, even for multi-bills covering a multitude of issues, which in fact undermines the consultation itself.

As far the content of the bill is concerned, comments and suggestions focus on the following:

1. Apollon Programme (Articles 103 – 104)

It is positive that important energy needs of local communities are met through self-production. However, this is a centrally driven scheme, with the State taking over its implementation and local actors having a secondary role. Thus, the Citizens’ Energy Community (CEC) instrument functions as any corporate form, without taking into account the principles of cooperativism. Moreover, the Programme focuses only on the category of vulnerable citizens and does not include local entrepreneurship.


  • The CSP should be given a substantial role in the Apollo Programme through more responsibilities and operate on the basis of the principles and values of cooperativism.
  • Provide immediately for an additional programme in which the State will guarantee self-production projects for energy communities with strong participation of citizens and local SMEs, either by ensuring conditions similar to the Apollo Programme or by subsidising the cost of installing renewable energy projects and storage infrastructure.

2. Tendering procedure for renewable energy projects (Article 105)

In principle, the abolition of operating aid is correct, as photovoltaic and wind power systems are very mature technologies for electricity generation and do not need operating aid for their further development. However, this creates inequalities, does not ensure a level playing field and drastically limits the ability of local communities to participate in the energy transition.

It is proposed to create a specific tendering framework only for renewable energy projects by energy communities, in order to ensure a level playing field and at the same time to shield the institution from unfair practices, as well as to ensure the participation and benefit of local communities.

3. District heating in Kozani and Ptolemaida (Article 106)

The choice of fossil gas-based district heating to meet the needs of the cities of Kozani and Ptolemaida is a wrong choice that will burden all electricity consumers. The proposed legislative changes are estimated to seek to increase the coverage of the cost of a specific new CHP (Combined Heat and Power) plant in Kardia, Western Macedonia, by the Special Renewable Energy Account (ELAPE), thus placing a greater burden on all Greek citizens.

In contrast to this option, it is proposed to proceed with the complete redesign of the district heating system for Kozani and Ptolemaida, rejecting the economically and climatically unsustainable solution of fossil gas CHP, while using an appropriate and well-designed mix of clean energy technologies.

4. Allocation of a 10 MW margin to self-producers (Article 110)

While it is positive to secure 4 MW for self-production projects for energy communities in the secondary and tertiary sectors, placing the capacity absorption margin for self-production projects by energy communities at 200 KW, as proposed in the bill, is of little consequence, as only 8.5 MW of pending applications will be able to be electrified.

If the limit is set at 500 KW, then the pending self-production projects from energy communities that will be able to take advantage of the regulation will have a total capacity of 40.3 MW, while if it is set at 1 MW, then projects with a total capacity of 73.6 MW will be able to be electrified, i.e. more than ¼ of the total pending capacity of self-production projects from energy communities nationwide in February 2024.


  • The capacity absorption margin for self-production projects from energy communities needs to be set at 1 MW.
  • Distinguish the category of energy communities from self-producers in the secondary and tertiary sectors and clearly allocate 2 MW of space for self-production projects of energy communities separately from other self-producers and clearly.
  • Include in the regulation the self-production projects of energy communities of Law 4513/2018.

5. Abolition of net metering (Article 110)

This regulation risks to put a halt to the progress of self-production in Greece, which in the last two years has been perhaps the most promising example of the energy transition in our country. Since the main parameters for the implementation of net billing are not known, it is not legitimate to abolish net metering.

It is therefore proposed that energy communities, households and small businesses be exempted from the regulation for a reasonable transitional period until the framework of the net billing system (conditions, restrictions, charges, operating conditions, compensation prices, contracts, etc.) is finalised.

6. Offshore wind (Part B, Chapter B)

Strong safeguards need to be put in place to both accelerate the deployment of renewable energy and ensure that environmental legislation is enforced. In particular, it is proposed:

  • Ensuring the implementation of the obligation to carry out a proper impact assessment of development plans for offshore wind farms planned in or near Natura 2000 sites.
  • The simultaneous acceleration of actions to fulfil the basic obligations for nature protection.
  • The immediate completion of the revision of the Special Spatial Plan for renewable energy sources, so that their installation is not based on ad hoc plans but on a new and integrated plan that takes into account all aspects and priorities: energy, ecological, social and cultural.

7. Restrictions on the production of RES stations (Articles 117 – 118)

On the crucial issue of the curtailment framework, instead of immediately creating a predictable and reliable framework on which RES producers can rely, fragmentary and temporary-transitional (and indeed indefinite) arrangements are introduced, which go in the opposite direction.

8. Duties of staff of the Natural Environment and Climate Change Agency (Article 37)

Lastly, we propose to strengthen the staff of the Natural Environment and Climate Change Agency (NECCA) and the Protected Areas Management Units by assigning pre-investigative tasks or explicitly recognising the staff as ‘special investigative officers’ – on par with the security forces and the forestry service – for timely and effective intervention for the protection of the country’s protected areas.