The Green Tank submitted its comments and proposals during the public consultation on carbon budgets across seven sectors of the economy.
It first highlighted the significant delay by the Ministry of Environment and Energy in fulfilling the relevant provisions of the National Climate Law, as well as the problematic consultation process and the very limited public attention given to this crucial issue, despite the pivotal role of sectoral carbon budgets in achieving national climate targets.
Nonetheless, the Ministry’s decision to align the sectoral budgets with the National Energy and Climate Plan (NECP), and to include emissions from international aviation in the corresponding sectoral budget, were assessed as sound choices. The results of the Ministry’s calculations closely matched those of The Green Tank’s December 2024 study “Sectoral Carbon Budgets and the NECP: The national climate policy under the spotlight,” which followed a nearly identical methodology.
As for the investment estimates required to meet the sectoral budgets, discrepancies were observed compared to the NECP. Notably, there was a reduction in investments for the decarbonization of buildings, particularly in residential heat pumps. At a time when ETS2 is about to take effect and the electrification of heating is a key tool for shielding households and businesses—especially the most vulnerable—investment in heat pumps must not be reduced under any circumstances.
Similarly, a decrease in non-CCS industrial investments was noted compared to the NECP. As electrification and energy efficiency improvements will enhance the global competitiveness of industrial processes, it is essential that these investments are not scaled back.
For the agriculture & livestock and waste sectors, investment estimates were based on national plans for NECP-proposed measures. However, since the NECP does not link these measures to specific emissions reductions, this approach is not only unfounded but also leads to illogical outcomes. For example, in the agriculture & livestock sector, the proposed NECP measures for 2026–2030 are estimated to cost €5.2 billion, yet the emissions reduction expected over the same period is just 0.3 Mt CO2eq. Similarly, for the waste sector, the €3.6 billion in projected investments would yield only 0.8 Mt CO2eq in emissions cuts.
Comparable issues arise in investment estimates for the land use, land use change, and forestry (LULUCF) sector. Therefore, The Green Tank recommends separate studies for each of these three sectors to assess the carbon footprint of every policy measure and select those that deliver the best climate results at the lowest cost.
Finally, in the LULUCF section of the consultation document, only the carbon absorption of terrestrial and especially forest ecosystems is mentioned, while the NECP also refers to the role of marine ecosystems—particularly Posidonia oceanica seagrass meadows. It is therefore proposed that these marine ecosystems also be included in the sectoral carbon budget, with corresponding investment estimates derived from the Interreg EURO-MED ARTEMIS program.
Read The Green Tank’s full comments and proposals in Greek here.
Read The Green Tank’s study “Sectoral Carbon Budgets and the NECP: The national climate policy under the spotlight” here.
