The four (4) new specialized issues that were put up for consultation in the 2021-2027 Monitoring Committee for the Just Development Transition Program concern actions with a total budget of €29.165 million, and are included in Priorities 1 (Strengthening & Promoting Entrepreneurship) and 4 (Just Labor Transition). Specifically:
Priority 1:
- Installation and operation of a pilot CHP unit using fuel cells and RES using H2 (€7,865,000)
- Utilization of four buildings of the former Tripoli Psychiatric Hospital for the development of a model innovation and applied research park (€5.3 million)
Priority 4:
- Reform of Mavrakios School in the context of vocational education and training (€6 million)
- Lifelong learning programs for the environment, green economy, digital skills and entrepreneurship (€10 million)
With regard to the first action “Installation and operation of a pilot CHP unit using fuel cells and RES using H2”, we have the following objections:
The technologies for the production and use of green H2 are crucial for the green transition and therefore their development is essential.
However, the specification document states that: “The purpose of the project is to convert a wide range of conventional (LNG) and non-fuels (“green” H2 from RES) into electricity and heat”.
However, the direct combustion of fossil gas in the CHP for the production of electricity and heat, even as a mixture with green H2, which the above document likely implies, cannot be financed by the Just Transition Fund, since, according to article 9d of Regulation 2021/1056 governing the JTF, “investments related to the production, processing, transport, distribution, storage or combustion of fossil fuels” are excluded from the scope of support.
Furthermore, the specification states that “The pilot project will be in line with the general principles of Regulation (EU) 2023/1184 laying down detailed rules for the production of liquid and gaseous transport fuels of non-biological origin from renewable sources”. However, the said Regulation clearly states that “liquid and gaseous fuels of non-biological origin produced from electricity shall be considered to come from renewable sources only where the electricity comes from renewable sources”. Therefore, the electricity that will probably be produced from the combustion of fossil gas in the CHP plant cannot be used either for the production of hydrogen through electrolysis and be in line with Regulation (EU) 2023/1184.
Finally, the beneficiary of the project seems to be pre-selected without however documenting the need for this approach. Specifically, the CHP pilot unit, the hydrogen fuel cell, the electrolyzer for hydrogen production and the PV park appear from the description to be implemented by CERTH/IDEP.
Therefore, we are not in a position to vote in favor of this specific specification unless any reference to LNG is completely removed and it is clarified that the only fuel that will generate the electricity and heat from the CHP will be green hydrogen, which in turn will be produced by the photovoltaic park or other RES.
As for actions 2, 3, and 4, we believe that they are moving in the right direction. They strengthen the governance framework of the Bioeconomy hub (ESDIM Megalopolis) and the education, training and research infrastructures, while they are addressed to users of these infrastructures as well as to people who will attend lifelong learning programs (8,000 people) and will receive a certificate of attendance (4,000). It is important that the lifelong learning programs are mainly addressed to people (young people but not exclusively) who are mostly in vocational training structures but also to university graduates, on the one hand because in addition to support for specialized scientific personnel, other (more technical) categories of professionals are crucial for addressing unemployment and strengthening social cohesion in transition regions. On the other hand, young graduates are also included, who are supported in moving from education to employment, thus creating better conditions for them to stay in their place.
Therefore, we approve these three (3) actions. We submit only one comment for the improvement of the specialization issue concerning lifelong learning: to clarify how this program is linked to other similar programs already funded by the PDAM (e.g. Skills Navigator in Kozani) or by other EU resources, and how they leverage their work in order to function in a complementary fashion.
