The Green Tank submitted comments and recommendations to the public consultation on the draft law of the Hellenic Ministry of Environment and Energy regarding the capture, use, transport and storage of CO₂, as well as the related provisions for the energy market.
Carbon Capture and Storage (CCS)
The Green Tank notes that the establishment of a regulatory framework for CCS comes with significant delay, despite major projects having been approved for funding more than two years ago. The draft law relies on an excessive number of future regulatory and ministerial decisions, leaving critical issues open regarding permitting, monitoring, financing, and transparency.
Greece has limited capacity for CO₂ storage, so a clear hierarchy of sectors allowed to use it is mandatory. It is emphasized that CO₂ storage from power generation units should not be encouraged, since this sector already has clean alternatives – such as renewables and energy storage. CCS should be used only where no other solutions exist, mainly for hard-to-abate industrial processes, such as the chemical process of clinker production in the cement industry. At the same time, limits on state aid for CCS are necessary to prevent it from monopolizing funds at the expense of other critical decarbonization technologies.
Special emphasis is also placed on transparency. The draft law leaves wide room for critical information to be classified as confidential. The Green Tank calls for public access to data such as injection volumes, the origin of CO₂ by sector, safety inspections, monitoring results, and national reports submitted to the European Commission. Public oversight is considered essential for a technology with a high social and environmental footprint.
Energy market regulations
Regarding the energy market, the draft law introduces some positive steps, such as greater transparency in the universal service tariff and clarification of longstanding issues in private medium-voltage networks. These individual changes can improve market functioning, although they come with additional bureaucracy and costs for smaller actors, which calls for corrective measures.
On the major issues, however, the imbalance in favour of large investors is evident. The rules for energy storage projects and the possibility of shared grid connection with RES projects, although positive in terms of infrastructure integration, often exclude smaller producers who are unable to benefit from the same support schemes. At the same time, the new rules on the participation of legal entities in energy communities—aimed at preventing abuses—may ultimately affect non-profit organizations, municipalities and civil society groups operating with a social mission. A clearer distinction between for-profit and non-profit entities is needed, along with more specific oversight not only from the General Commercial Registry (GEMI) but also from the Regulatory Authority for Energy and Waste (RAAEW).
Similarly, the new fees for installation extensions and the automatic reduction of reference tariffs in case of delays risk unfairly penalizing investors when delays are not their fault but due to grid operators or other authorities. The Green Tank proposes a fairer gradation of these measures, as well as exemptions in cases of force majeure.
Finally, the temporary integration of the hydrogen market into the fossil gas market risks giving an unfair advantage to existing players in the gas sector. Green hydrogen production must be able to develop on equal terms, without institutional barriers that restrict new providers.
Read the full comments [in Greek] submitted by The Green Tank to the public consultation here.
