Positions of the Hellenic Society for Environment & Culture on energy and environment

ELLET is working systematically to ensure through its actions and proposals, the successful and sustainable transition to a climate-neutral economy, with the preservation of nature and cultural heritage as its central focus. 

ENERGY, ECOLOGICAL FOOTPRINT AND ENVIRONMENT: TEXT OF THE ELETT POSITION PAPER 

Introduction 

The HELLENIC Society for the Environment and Culture (ELLET), realizing from the many questions that we constantly receive the reasonable confusion that pervades public opinion regarding the above issues, of capital importance for the evolution of our world, has decided to prepare the present note as an aid for the evaluation of administrative, political and private proposals. It is understood that it will be updated from time to time as developments occur. The note is largely based on the papers presented at the successful Workshop on 28 January 2020 at the Acropolis Museum (https://paris-reinforce.eu/el/climate-change-energy-environment), but also in subsequent work, mainly in the Special Energy Council (SENFOM). 

Energy is a basic necessity of human life. The development of fossil fuels has been one of the technological developments that have determined and still determine the structure and structure of states and societies and the relationship between them. The challenge of the now dangerously increased ecological footprint of humanity, as well as of each individual country or region on the planet, is not, however, limited to the extensive use of fossil fuels and the urgent need to replace them with renewable energy sources (RES). The cleanest - and in the long term probably the cheapest - energy is the energy that is neither produced nor consumed, because human societies will now be organised in such a way that they will no longer need it. Maximising this future «avoided energy» must be the first objective of a prudent ecological policy. 

Below we will outline proposals for practical solutions to pressing problems. However, we should not forget that existential concerns arise in relation to various theological, moral-philosophical, ideological and economic approaches, of which we will refer to just four that are of particular importance: 

An ethico-philosophical approach, because of the fundamental existential principle espoused by the Golden Rule, i.e. to treat our «neighbour», using the broadest sense of the word, in the same way we would wish him or her to treat us. 

An ideological approach, in the sense that while our actions must indeed be largely local, they cannot achieve the necessary goals unless we manage not only to think globally but to act in a coordinated way, both locally and globally, by all the societies of our world. 

An economic approach, since the ecological crisis highlights another example of three objectives that are impossible to achieve simultaneously, or in other words an unattainable triad, namely, firstly, solving the problem of the global ecological footprint, secondly, achieving the necessary sustainable development of the poorest countries, and thirdly, maintaining the current model of consumer society in wealthy countries such as ours. In other words, a fundamental rethink of the development model is required, based on the environmental and ecological challenges of our time. 

A theological approach, insofar as the present context can be interpreted as if the whole of humanity is living the first chapter of Genesis, with all human beings now facing the dramatic choice between the Tree of Life and the Tree of Experience of Good and Evil, the taste of which has shaped a world where both good and evil - not in opposition, but additively - have led and are leading us to an existential crisis par excellence. 

Besides, while the transition from fossil fuels, whose use triggers the ongoing global warming, to renewables is indeed an urgent challenge for the whole of humanity at the present juncture, it is equally true that it is not the only such challenge. The problem of our dangerously expanding ecological footprint is certainly due in part to climate change, but also to two other phenomena: on the one hand, the rapid extinction of species and a dangerous reduction in biodiversity, and on the other hand, the combination of the growth and concentration of the exercise of power in specific parts of the world with unequal production and consumption of energy at the expense of their regions. 

For this reason, ELLET believes that we must focus on the urgent need to address not one but three energy challenges in the modern world. First, the challenge of changing the energy mix from fossil fuels to renewable energy sources. Secondly, to the immediate concern for endangered biodiversity and the preservation of landscapes. Thirdly, the gradual decentralisation of responsibility for managing these problems as far as possible from centralised - and sometimes almost colonial - centres of power consuming energy produced in their regions to the regions themselves, each of which, in accordance with sound environmental and ecological principles, will be responsible for equally clean energy production to meet local needs and effective mitigation of energy consumption. 

This is the reason for the structure of the following note. We start from the challenge of not producing unnecessary energy with the aim of gradually but in the long term drastically reducing the ecological footprint of our society. Any other prioritisation would have the fatal consequence of a constant increase in energy needs, particularly in the megacities, and therefore a constant need to install additional renewable energy sources of ever greater capacity, with consequent damage to cultural and natural landscapes and biodiversity, increasing the country's overall ecological footprint, whereas there is an urgent need to reduce it. 

Ι. National Objectives and Preferred Means: energy saving first 

ELLET welcomes Greece's commitment to de-lignification by 2028 and then its energy transition to a climate-neutral economy by 2050. There are, of course, reasonable doubts about the valid achievement of these targets, doubts that do not concern our ecological or environmental priorities but the stability of the energy system itself, especially at a time when, due to climate change, extreme weather events are increasing. The energy transition must be achieved while maintaining a sufficient proportion of stable base energy to compensate for the seasonality of wind and photovoltaic energy. 

However, if we attempt to reach the goal of fossilization only through the fastest possible transition from fossil fuels to renewable energy sources without limiting our overall ecological footprint, we will cause irreparable damage to nature, cultural heritage and biodiversity in Greece, which is internationally recognized as a cradle of civilization and one of the richest countries in biodiversity in Europe. Our primary concern should therefore be the reduction of the national energy footprint, while the setting of specific targets for electricity production from specific renewable energy sources, as was done in the NSEC (2019), should follow and not precede in the order of our targets.

I.1.Energy upgrading of buildings: 

The figures for the European Union of 28 (until Brexit) countries/members are eloquent. Buildings account for 40% of final energy consumption and 36% of greenhouse gas emissions. The data therefore confirms the priority that ELLET gives to reducing the overall ecological footprint. It is obvious that the energy upgrading of buildings, which is not a transition from fossil fuels to renewable energy sources but will reduce emissions through a noticeable reduction in energy consumption, must be a top priority for both the state and every citizen. 

The goal should be zero energy buildings, a development that will not only reduce greenhouse gas emissions, but will directly improve the quality of life and gradually the economic vitality of Greeks. With some exceptions, the temperate climate, especially in the Mediterranean climate regions, will assist in achieving the necessary goals (Alice Korovesi, 2020, Energy Saving in Buildings in the Light of the Green Agreement and the Clean Energy Package [presentation], Acropolis Museum, Available on the website of the Workshop CLIMATE CHANGE, ENERGY & GREEK ENVIRONMENT https://paris-reinforce.eu/el/climate-change-energy-environment). 

Fortunately, the challenge of upgrading housing (Home Economics) has been recognised by the Administration. This popular programme (with an enthusiastic popular response so far) supports small businesses specialising in particular in better insulation techniques to reduce the heating and cooling needs of each building. 

The truth is that the road to the goal is long. All existing buildings, including pre-war and post-war apartment buildings, are in immediate need of energy upgrading as soon as possible and as a top priority. All publicly owned buildings, not just a select few, should be energy upgraded, equally those of central and local government. 

It will be important to replace the approach of the current KENAK (Energy Performance of Buildings Regulation) with the promotion of passive bioclimatic architecture systems. Technical solutions based on mechanical installations (air conditioners, etc.), even if they are technically improved to achieve a reduction in energy consumption during operation, are much more energy-intensive than optimal natural ventilation and sunlight solutions. An example is the traditional Cycladic architecture with narrow openings to the north, large openings to the meridian and through ventilation. ` 

I.2.Preservation of traditional buildings: 

At the same time, there is a need to strengthen the «Preserve at Home’ programme, which encourages the restoration and upgrading of traditional houses, which are remarkable not only in themselves but for the harmony and human scale they offer in many city and town districts across the country. ELLET made representations to the Ministry of Environment when it appeared that the project could not be included in the national proposals for the Recovery Fund and is awaiting the outcome at a time of increased risk, since the administration has institutionally facilitated (Order with Amendment No. 44 A»/26.03.2021 of Law 4787) the demolition of buildings later than 1830.. 

Legal ways must be found to ensure that listed or protected abandoned buildings can be restored without expropriation or change of ownership, a problem that ELLET has specialised in solving over the last three years. We are now advancing specific legislative proposals with the support of municipalities that are facing this problem intensely and also of officials of the Administration, who are looking forward to the restoration and exploitation of valuable elements of cultural heritage. 

I.3.Mandatory Bioclimatic Design in New Buildings and Urban Renewal: 

It is an immediate challenge to change the regulations governing modern construction to make bioclimatic design mandatory. Since 2008, ELLET has hosted a series of lectures on the principles of bioclimatic design: today, however, the main issue is not the promotion of the idea but the regulatory implementation in order to drastically reduce the ecological footprint, primarily of the two megacities of Athens and Thessaloniki, but also of the other cities in the Greek territory. 

Bioclimatic design can be combined with the selective installation of photovoltaic panels that will produce energy locally (see also II.6). Lightweight green roofs and green walls should also be encouraged. 

Finally, any urban regeneration necessary to reduce the existing and growing phenomenon of heat islands, especially in densely populated areas of megacities that suffer from a lack of greenery, must be implemented in order to avoid further deterioration of an already unpleasant and potentially dangerous reality. The policy of integrated urban regeneration to reduce this phenomenon is inactive among the competent bodies, with the result that municipalities, in the absence of guidance, are promoting fragmentary «beautification» interventions in public space, whereas the current climate crisis requires that this policy be activated and prioritised. 

I.4.Sustainable Mobility in Cities: 

The undoubted elements of sustainable mobility that we should encourage immediately and over time are cycle paths and walking. These two forms of mobility reduce the overall ecological footprint of cities in an ecologically «clean» way, which cannot be disputed. 

In contrast, electric cars are «clean energy» only to the extent that the electricity they rely on comes from renewable energy sources (e.g. hydroelectric, photovoltaic, wind turbines) and not from fossil fuels (e.g. natural gas, oil, lignite). Of course, as we move towards 2050 this mix will become cleaner and it is good to regularly publicise where we are so that misinterpretations and misunderstandings are not encouraged. It should also be pointed out that the use of electric cars is an ecological option that is less polluting for the city than internal combustion engine cars, but uses lithium batteries, which is a rare metal and difficult to recycle. 

So while the use of metro, electric buses and electric cars is positive compared to conventional cars, they are not a «green panacea» for now and will contribute to the collective ecological footprint until the national electricity generation mix changes drastically, which will be achieved gradually. The use of hydrogen, e.g. in hydrogen buses, has the same characteristic as electricity. Its ecological purity depends on its source, fossil fuel or renewable energy. 

This finding should not discourage us from strengthening Public Transport (PMT) and especially Fixed Railways (LRV), even if their ecological purity depends, in these cases too, on the national electricity production mix. This is because the overall ecological footprint of society is effectively reduced when many citizens use the same common means of transport, especially public transport, rather than individual means of transport such as cars. 

However, the opportunity for the exclusive use of electric cars on those islands that have access to high enthalpy geothermal energy, such as Milos and Nisyros and their neighbouring islands (such as Thera) should not be missed. Such a development would create an impressive comparative advantage for these islands in the international travel and tourism market. Therefore, an administrative decision is urgently needed to plan and implement the relevant connections, hopefully with resources from the Recovery Fund. 

I.5.Sustainable Mobility Outside Cities: 

The conversion of Greeks during the recent decade towards cycling and walking, as physically and energetically healthy ways of recreation, should be further encouraged in every way. The country will gain in every way, both from the response of foreign travellers who already enjoy the trail networks in various parts of the country and from the trend towards healthy and ecologically clean sport among Greeks. We have only to compare these two exercises, as well as sailing and swimming, for example with motocross, the (successfully named) «pigs» or water skiing! 

Inter-city railways and suburban railways are in the same category as the metro within cities, which we discussed in I.4, but with the big difference that when compared, not so much with cars, which in a few relatively few years will be powered by electricity, even for individual use, but with aeroplanes, where any transition will be delayed, the advantages of railways increase dramatically. Across Europe there has been serious investment in recent decades to upgrade railways. In north-west Europe in particular, these investments are also aimed at cross-border rail connections. The Greek Government, together with other EU Member States, should encourage the funding of modern, high-speed railways in other regions of the Union. 

Given that transport is a component - albeit in a very different way - of the two main economic activities of the Greek people, namely tourism within the country and merchant shipping outside the country, it is necessary to investigate the possible developments in these two main national «industries», or rather services, because these developments will inevitably affect almost all Greek citizens. 

Until recently these two most important activities were not a central concern of those who were seriously addressing the dangerously enlarged footprint of humanity, because other sectors of economic activity (e.g. housing, steel and cement production, cars) contributed much more directly and dangerously to it. Tourism in particular has not been subjected to thorough monitoring, also because, while it increases the building stock, which requires additional cooling or heating, tourist accommodation is not distinguished from buildings for other uses, nor is it counted separately. 

But this situation has already changed and will change further in the future. Air transport, which contributes about 2.5% of total global greenhouse gas emissions, is a component of international mass tourism. Airplanes are powered by fossil fuels, with no technological alternative yet. Normally, therefore, as the challenge of humanity's ecological footprint becomes the central concern of the world's active citizens, air transport will be subject to scrutiny. The same is already happening with maritime transport. Ships run on fossil fuels without, for the moment at least, any technologically easy alternative on the horizon. Thus both the two strongest Greek industries are vulnerable, albeit to different degrees, to the coming period of forced transition to a climate-neutral state by 2050. 

The challenge of climate change is growing - the international meeting in Glasgow in autumn 2021 will certainly confirm this - and the international community has already developed a complex arsenal to push every specific sector of the international economy towards compliance with the demands of the times. 

There are three weapons in the quiver of the international community. The most recent, but highly effective, is the financial one. Contrary to the belief of those who classify people into separate groups according to their financial interests, those who are engaged in collecting savings to finance investments have the same concerns as the rest of the people, i.e. they are equally affected by the impending existential crisis. The already obvious result is that in recent years the world's credit markets, and particularly those of Europe, have been happy to finance pro-environmental investments, while making any investments that are considered to be harmful to the environment or contrary to the fight against climate change of dubious economic viability, since they are now only difficult to finance. 

A more familiar weapon is that of cash squeeze, either through indirect taxation or through an auction system for emission permits. Once such a system is set up, it is only a matter of time before the authorities deprive the offending activity of the necessary oxygen. We have experienced this in Greece in the case of lignite, an experience that ultimately moved even part of the otherwise usually insensitive Greek political class. It is good in future to prevent such situations instead of running after the facts.

The third weapon invented decades ago, notably by the state of California, is that of the system of evolving regulations, which requires an industry to improve its ecological performance in order to achieve a reduced level of emissions by a certain date, knowing full well that once achieved the whole process will be repeated with even lower targets. This is the main mechanism that has been successfully used in the case of the car industry, where we have also seen Volkswagen and other manufacturers attempting - ultimately unsuccessfully - to fool the authorities with misleading or false measurements. However, in the case of an activity where there is no technological possibility of compliance, this third weapon is equivalent to the second. The entire economic activity in question is gradually becoming less competitive in an international economy characterised by intense, albeit complex, competition. 

As is immediately apparent, mass tourism will be particularly vulnerable to successive increases in a possible coal tax on airline tickets, a risk that will probably become threatening about a year after the end of the pandemic brings to this economic activity an illusory sense of return to normality. 

Man is a mobile animal but the mass tourism of the last sixty years is a very specialised form of mobility, based on low airfares, sharp temperature differences between richer/cooler and poorer/warmer countries and low wages in the host countries. It might be useful to consider that before the First World War travellers, mainly due to malaria, visited Greece not in summer but in winter and spring. Are we at a moment of radical change?; 

It is indeed likely that airline tickets will gradually increase to a noticeable degree due to taxation, while it is also certain that summer temperatures in Northern Europe and North America are rising to their advantage as tourist destinations. But the Mediterranean will remain attractive in autumn and winter for residents of the northern countries, while in spring it will be attractive for the now rising Indians, who will be able to avoid the peak of their own unbearable summer by travelling in our spring in the Mediterranean. 

So we are not talking about the destruction of tourism in Greece, but about a possible redefinition of tourism, which no one can describe in detail, but for which we must all prepare.

Since the model of Greek tourism that has prevailed over the past sixty years is probably coming to a gradual end, the Administration should discourage rather than encourage new tourism investments based on cheap airline tickets, off-plan construction for hotel building or the exploitation of landscapes within protected areas. Instead, some of the country's older and some of its newer comparative tourism advantages remain intact, allowing us to cope with the coming revolution of climate change and forced energy upgrading. In particular we are likely to see: 

α) Serious reduction of mass summer tourism to the benefit of both the northern countries and the poorer countries in the Mediterranean or in tropical climates. 

b) Stabilisation of high-income tourism, as long as wealthier travellers are not seriously affected by increases in ticket prices. 

c) Permanent increase in teleworking for the benefit of the Greek economy, especially during the non-summer seasons of the year. 

d) Strengthening the phenomenon of dual residence, no longer only within one country but between two countries. Many northern Europeans, reducing their air travel as prices and environmental sensitivity rise, will stay from September to March in the Mediterranean and from March to August in their own country. 

Such a development will be an opportunity for those Greek islands, towns and villages that will have preserved quality landscapes and settlements, especially if they also offer medical services acceptable to the elderly, a point on which the pandemic has raised the country's profile, but much more needs to be done. 

e) A return to the priority of cultural pilgrimage culture, based on the need of many of our fellow human beings to visit once or twice in their lives those countries, including our own, which are considered essential for the evolution of human civilization or unique in their nature. 

g) Strongly strengthening special interest tourism, such as sports, spa, sailing, diving, hiking and others, which will be able to strengthen many local communities in our country. ELLET, having been at the forefront in strengthening walking tourism, starting from the difficult years of bankruptcy, has already had experience of what can be achieved under the necessary condition of protecting the country's unparalleled landscapes, especially mountainous and island landscapes.

ELLET's experience is that younger travellers in this category are particularly sensitive to environmental and ecological values. They live in a different existential world from the political leadership of our country, which in recent years has been more interested in the exploitation than in the promotion of Greece's cultural and natural heritage. 

One of the many points that will be noticed by aware future visitors is precisely sustainable mobility in Greece. Already in Norway they are experimenting with electric ferries, something that could be implemented in many parts of Greece, where a ship or ferry moves steadily between two ports (e.g. Piraeus/Aigina, Thira/Therasia, Spetses/Kosta, Naxos/Small Cyclades and many more) and thus has the possibility to regularly recharge its batteries. Of course there are other cases, such as small ships operating in large ports, where electrification will also be possible, but there seems to be no technologically easy solution on the horizon to enable ocean-going vessels to run on electricity. It will take many years of research and experimentation before a new standard of mobility can be found that can be enforced over a long period of time. 

In the meantime, however, the framework of the transition will be gradually defined by the weapons of international society that we have mentioned. Already the process of evolving regulations aimed at reduced fossil fuel consumption has begun, which will lead to lower emissions, although the process in this case is encountering considerable implementation difficulties. Fortunately, however, in the field of global shipping, which requires a broad knowledge of both technical developments and the international economy, it has often been the case that constructive proposals have come from within the industry. In this case, an important proposal was presented at the ELLET workshop at the Acropolis Museum on 28/1/2020 (https://paris-reinforce.eu/el/climate-change-energy-environment), that of “slow steaming” or reduced speed. 

That proposal for a general reduction in the speed of ocean-going vessels from their maximum possible speed to their economic speed (which would have the parallel benefit of reducing the number of collisions with marine mammals) has not been accepted internationally, but it is widely accepted that something which in essence has the same effect, namely that until there are alternative technical solutions which can be applied without risk, at least in newer vessels, the best intermediate solution is to reduce the horsepower of internal combustion engines to the point where they can be used without risk. 

Of course, ocean shipping, and even coastal shipping, can and should follow this recipe and apply a similar tariff to coastal shipping. policy. But for the predominantly tourist form of shipping, namely cruise ships, the coming, albeit gradual, increase in fossil fuel prices may prove as deadly - at least for the big players - as the meteorite that once fell on the Yucatan for the dinosaurs. The huge and fast cruise ships of the last generation, with thousands of passengers each, suffered a first, semi-lethal blow with the pandemic. Soon they will have to face gradually rising fuel costs as well as the air tickets necessary for the arrival and departure of most of their passengers. It is doubtful whether these developments will leave them with sufficient profit margin. 

Merchant shipping serves the most vital needs of the entire world, while the huge cruise ships of recent passenger shipping, the pleasure and entertainment of a small part of the world's population. It is not difficult to predict which of the two will survive and which will not be doomed, at least in its present form, to go from being a commercial reality and an ecological burden for the destinations concerned, to a museum exhibit as a silent witness to the consequences of the gradual global shift towards an era of sustainable mobility. 

Of course there will continue to be smaller, luxury cruise ships. Of course there will also be experiments with partial use of wind power, a reminder of the glorious age of sailing ships. But any experiment will only survive if it combines sustainability with commercial competitiveness. 

By far the largest part of Greek merchant shipping is seagoing and commercial. For this segment the use of economic speed will provide the necessary time to experiment with various new forms of mobility, such as hydrogen. But no one knows the final outcome. It just seems that international maritime transport will remain more important than any other mode of freight transport, albeit with a relative reduction in competitiveness for short distance transport compared to an electric railroad. 

I.6.Sustainable Diet 

Until recently, joint evaluation of research results on health and their relationship to the environment has been limited, although ecologists studying food systems have pointed to the relationship between high intake of food of animal origin and its adverse impact on the environment. Recently, however, interdisciplinary bridges have been developed linking food and nutrition to the environment, such as the production of greenhouse gases which is linked to the production of food of animal origin. Thus, shifting consumption to a plant-based diet, such as the Greek traditional Mediterranean diet, could contribute substantially to addressing climate change (A. Trichopoulou, 2012, Diversity v. Globalization, Public Health Nutr., 15(6):951-4). 

Studies show that the traditional Mediterranean diet, which was the standard diet of the Mediterranean oil-producing regions until the 1960s, is associated with good health. These beneficial effects are linked to traditional foods, which form the backbone of the traditional Mediterranean diet. Traditional foods are generally produced using locally produced products. The cultivation of local products contributes to biodiversity, to the achievement of a sustainable environment and to the employment of human resources, while at the same time expressing the timeless cultural history of the place. In this context, and following UNESCO's recognition of the Mediterranean diet as an intangible cultural heritage, the Mediterranean diet is considered to be not only healthy but also sustainable. It is sustainable because it has a low environmental impact and contributes to a healthy lifestyle for present and future generations by linking food, environment and cultural heritage. 

In the «Dietary Guidelines for Adults in Greece» formulated in 1999 by the Supreme Special Scientific Council of the Ministry of Health based on the traditional Mediterranean diet, which remain up-to-date and compatible with modern scientific data, it is recommended that the frequency of meat consumption should not exceed once a week (Ministry of Health and Welfare. Supreme Special Scientific Health Council, 1999, Dietary Guidelines for Adults in Greece, Archives of Greek Medicine, 16:615-62). It should be noted that internationally it is recommended to reduce meat consumption for health reasons. In addition, as mentioned above, relevant studies show that the production and consumption of red meat (especially beef) increases greenhouse emissions, especially methane emissions, to an alarming degree. Reducing meat consumption can have beneficial consequences not only for the health of the population and the environment, but also for the country's economy due to the resulting reduction in meat imports. 

Therefore, action measures should be developed to monitor and improve the dietary choices of Greeks, such as measures to limit meat consumption, with an emphasis on red imported meat, and measures to ensure the proper availability of pulses, fruits and vegetables. Also the formulation of the diets of the organisations operating under the supervision of the Ministries of Education and Health, so that vegetables, pulses, fish and less meat and its products are more frequently included among the foods on offer. 

The traditional Greek Mediterranean diet is a model of a healthy and environmentally positive diet. This Mediterranean diet should be promoted and supported by the State at every opportunity, in contrast to the consumer model that we introduced in the 1960s from economically advanced countries. 

Nutrition is a key element not only for longevity but also for an ecologically and environmentally positive lifestyle. Apart from reducing the consumption of red meat (especially beef) and increasing the consumption of legumes, vegetables and fruit, we must take measures in relation to the collapse of fish stocks in Greek waters in order to reverse the continuous decline in marine wealth. It is an urgent challenge to effectively protect the NATURA marine protected areas in Greece and, in particular, to establish numerous areas of temporary closures until the recovery of fish stocks, which have collapsed internationally in recent decades. 

I.7.Circular economy 

The circular economy is an economic model that focuses on reducing the waste of resources used in the production process - especially in the energy-intensive industries of steel, aluminium and cement - by emphasising the use of renewable resources, plant and animal by-products and biodegradable materials, the recovery and reuse of products, the production of energy from waste from production processes, the maintenance of a product in good working order for a long period of time, the use of energy from waste, the use of energy from the production process, and the use of energy from waste. In other words, the circular economy comes as a response to the ambition for sustainable development, taking into account the growing concern about the depletion of natural resources and environmental degradation. 

Many countries have already put the circular economy at the core of their development strategy, as it contributes to saving energy and using natural resources more rationally, to reducing pollution of the atmosphere, soil and water, and to tackling climate change. In addition to its environmental benefits, it can contribute to social and economic well-being, creating jobs and being a source of growth and innovation.

ELLET believes that the circular economy can be a catalyst for the productive reconstruction of Greece as: 

• promotes the decentralisation of manufacturing through reuse and recycling, 
• promotes the use of available natural resources and waste, 
• is based on the knowledge and specialisation economy, generates high added value, exploits and respects natural and environmental resources, 
• improves resource and energy productivity indicators, 
• adopting consumer trends towards environmentally friendly products, without underestimating the importance of achieving safe waste disposal solutions, 
• supports the competitiveness and viability of businesses by ensuring cheap raw materials, 
• addresses possible increases in raw material prices and helps to save costs in industries and energy production, 
• is fully compatible with the small and medium-sized entrepreneurship and the social economy that characterise the Greek productive fabric, a key feature of which is the small size of enterprises, 
• fuels a qualitative leap in the economy, which will be a growth transformation and at the same time supports the creation of new jobs, 
• promotes the creation of new professions and the social economy, which is still at a very low level in Greece. 

II. Renewable Energy Sources & ELLET Positions 

II.1.Geothermal energy the most socially beneficial form of RES 

For the last 20 years ELLET has been fighting for the promotion of geothermal energy as the most socially and environmentally friendly form of RES. 

Based on the recent fundamental commitment of Greece to achieve a climate neutral economy by 2050, there is an urgent need to exploit the so far neglected geothermal potential recorded in the Greek territory. 

ELLET considers the use of geothermal energy as an environmentally friendly and cheap form of renewable energy, with absolutely safe and advanced technology, which also supports the equally important objective of preserving the Greek natural and cultural heritage, if there is prudent planning. The visual disturbance created by geothermal energy is generally the least of any other form of renewable energy, because geothermal energy requires a limited area of land and few accompanying works compared to those required by photovoltaic and wind energy systems. 

Geothermal energy is also a preferred form of RES because it is a base energy, providing clean electricity 24 hours a day, without dependence on any weather conditions such as sunshine or wind power. It is noted that geothermal power plants in countries such as Iceland, Italy and Croatia have a utilisation factor of up to 90%, while the utilisation factor of a hydroelectric plant is up to 70% and for solar and wind plants it reaches 35% [App. Arvanitis, Head of Geothermal and Thermal Natural Resources Department (Geothermal Resources and Thermal Resources), Directorate of Water Resources and Geothermal Energy (D.Y.PO.GE.), Hellenic Authority for Geological and Mineral Exploration (Hellenic Geological and Mineral Research) & E. Spyridonos (Head of Geothermal Energy Department, Geothermal & Biomass Division, PPC Renewable Energy S.A.) & E. Spyridonos (Head of Geothermal Energy Department, Geothermal & Biomass Division, PPC Renewables S.A.).E.), 2016, “Combination of Geothermal Exploitation and Conservation of the Natural Beauty of an Area Based on International Experience and Practice”, Presentation, International Geo-volcanological Conference, Methana, 10-12 June 2016]. 

The exploitation of geothermal energy could also bring substantial economic benefits for those local communities that have it, through the institution of Energy Communities. 

Based on the above, ELLET considers it imperative to exploit the largest, so far known, geothermal field of medium and high enthalpy, which is found in Greece, namely the island complex of Milos-Kimolos-Polyaios, through the construction of the necessary interconnection infrastructure, on the one hand with Santorini (Milos-Folegandros-Sikinos-Ios-Santorini line) and on the other hand with Syros (Milos-Kimolos-Sifnos-Syros). The geothermal potential of this island cluster could cover about half of the energy needs of the Cyclades in a way that would benefit the inhabitants of Milos. Similar could be the benefits of Nisyros in the Dodecanese from meeting the energy needs of neighbouring islands. 

The Recovery Fund is an immediate opportunity to promote this goal in 2021, as the use of European funds - as our neighbour Italy has already achieved - can minimise public spending. This unique opportunity must not be missed. 

Meeting the needs for clean electricity of many Cycladic islands will also allow a rapid transition to an era of sustainable mobility, which will benefit the image of these islands, which are very busy with visitors. 

Shallow enthalpy, also very useful, is found in most parts of the country and is suitable for heating and cooling needs (see section I.1). Despite the undoubted value of high and medium enthalpy geothermal energy, it may turn out that this widespread use of shallow enthalpy is the most important contribution of geothermal energy to the fight to mitigate climate change and reduce society's ecological footprint. 

II.2.Onshore wind turbines 

Onshore wind turbines have proven to be the most successful form of renewable energy in the last decades, with impressive cost reduction rates and, fortunately, a corresponding penetration in the energy production mix. However, the relative cost reduction has been achieved partly due to their increasing size. They are thus necessarily heavy structures due to their ever-increasing dimensions, concrete bases and, lastly, the necessary access roads that destroy hilltops, paths and terraces in sensitive landscapes, alongside, of course, their impact on birdlife. Onshore wind turbines are certainly a good choice when located near energy consumption centres or existing roads, while in many other parts of the country they are debatable options. In other sensitive areas they are assessed as clearly destructive to biodiversity, landscape, nature and culture. 

As is well known, there is a controversy over the currently proposed massive installations of onshore wind turbines, including on islands that have carefully preserved their landscapes. The Administration and the investment community should be able to easily understand that in these cases the proposed installations are not designed to meet energy needs in the proposed installation sites - as long as their own energy needs are measured - but in other areas, especially of course in Athens, where only a prudent environmental policy of reducing the ecological footprint has not, so far, been followed. This is therefore not ’green development’ but a policy that violates basic «green values» of biodiversity and the preservation of the cultural/natural landscape. It is therefore logical that the inhabitants of specific islands and mountainous areas should see these proposals as both discrediting their own principles and struggles for quality of life and as economically unsustainable, since they will lead to a vertical decline in the tourism from which they themselves and, through them, the whole country, live. 

Fortunately, the European Commission has issued guidelines for the siting of onshore wind turbines (as well as offshore wind turbines) (https://ec.europa.eu/environment/news/commission-issues-guidance-reconciling-wind-energy-developments-and-nature-2020-11-19_el , https://ec.europa.eu/environment/nature/natura2000/management/docs/wind_farms_en.pdfUnfortunately, these guidelines, which emphasise the need for a strategic approach and spatial planning, are often ignored in practice in our country, just as the European regulations on Protected Areas have been ignored and even violated. 

II.3.RES and NATURA 2000 Protected Areas 

The NATURA 2000 network is one of the European Union's greatest successes over the years, as it has competence for the natural environment in all Member States. Its interest in the subject is clearly demonstrated by the relevant guides to the management of protected areas, which are available on the following websites: https://ec.europa.eu/environment/nature/natura2000/management/guidance_en.htm and https://ec.europa.eu/environment/nature/natura2000/management/index_en.htm. 

Member States were obliged to adopt the necessary conservation objectives and measures within 6 years of the Commission's adoption of the list of sites for each biogeographical zone. In Greece, this deadline, which according to national legislation includes the preparation of Special Environmental Assessments and management plans, expired in 2012. In the meantime, unfortunately, some heavy interventions in protected areas took place because national law allowed investors to present impact studies paid for by themselves, without meeting the criteria of European legislation, a practice that was also accepted by national courts in some cases. The long delay in the preparation of management plans and the adoption of the necessary conservation measures led the European Commission to finally take legal action against the country and the Ministry of Environment in 2019 to accelerate the preparation of management studies for these protected areas, studies which are however still pending. 

Based also on the precautionary principle under the Treaty on the Functioning of the European Union, it would be reasonable, until the completion of the management studies and the adoption of the necessary conservation objectives and measures (officially planned to be completed around mid-2022), to suspend the siting of any heavy installations in Natura 2000 sites because any siting is likely to cause irreversible impacts on the natural and cultural capital of these sites. This proposal was submitted by ELLET to the Ministry of Environment already in early 2020 but was not accepted. Heavy installations, depending on the siting conditions, may include photovoltaic and onshore wind turbines. 

Since then, the condemnation of Greece by the Court of Justice of the European Union (ECLI:EU:C:2020:1047, decision C-849/19) proved the validity of ELLET's position and put the Greek courts before the dilemma whether they should continue to accept imperfect national procedures such as. in the case of Prespes, where the problematic operation of a wind farm has resulted in the death of silver pelicans, a rare and valuable species, or to comply with the decisions of the European Court of Justice, in a matter of undoubted Community competence and responsibility. 

Subsequently, nine Greek environmental companies and organisations (ANIMA, Arcturos, ELLET, Nature Conservation, Ornithology, Prespes Conservation, Callisto, MEDASSET, MoM), believing first of all in the need to comply with the European Courts‘ decision, adopted a valid study by the University of Ioannina (Kati, V. et al, 2021, ’The biodiversity wind energy land use nexus in a global biodiversity hotspot', Science of the Total Environment, vol. 768, Article 144471) which demonstrates with documented evidence that the current national targets for wind energy production could be met without the installation of further wind turbines in the protected areas of the NATURA 2000 network. Of course, the management studies themselves, when completed, will naturally allow the use of a certain percentage of these areas for the installation of Wind Power Plants (WPPs) if they are necessary and compatible with the conservation objectives of the areas. Below is the enlightening text of our joint statement: «JOINT PRESS RELEASE February 11, 2021 

Developing renewable energy sources with respect for biodiversity: 

A viable scenario for Wind Farm development with minimal environmental costs 

Nine Environmental Organisations welcome the conclusions of a recent scientific study on the siting of onshore Wind Power Plants (WPPs) in Greece for renewable energy without significant impacts on biodiversity. The research published in a prestigious international scientific journal and was led by the Department of Biological Applications and Technologies of the University of Ioannina. 

The study proposes a viable scenario for the deployment of RES-E, dividing Greece into two zones. The exclusion zone for NPPs includes the Natura 2000 network areas as the most ecologically sensitive areas of Greece and landscapes of high naturalness, i.e. those with a low degree of fragmentation by artificial surfaces and roads. The rest of Greece is defined as a potential investment zone and it is proposed to encourage applications for ESIA investments hierarchically from the most fragmented areas to the least, within the zone. In this zone it is proposed that NPPs can be licensed, provided they meet the other criteria and receive approval of environmental conditions and positive opinions from the competent bodies, following the legal procedure. The rationale is to reduce the main threat to biodiversity, which is land use change, including the increase in artificial surfaces and the expansion of the road network. 

Examining the effectiveness of the proposal in relation to the existing applications for licensing of RES-E in March 2020, it is found that only the applications within the proposed investment zone are sufficient to meet and exceed Greece's climate target for installed RES-E capacity by 2030. The researchers demonstrate the great contribution of the proposed siting to the conservation of biodiversity, including birds and protected species at European level. They conclude that the viable siting scenario will protect Greece's unique biodiversity, while ensuring a safer and less conflictive investment environment for the wind energy sector. 

Reports by international organisations stress that biodiversity loss and climate change are the two equally important global crises that act synergistically and endanger the future of humanity. Biodiversity, which includes all natural ecosystems such as forests, wetlands, alpine areas, etc., is recognised as the most important shield against climate change as it makes a significant contribution to tackling it and mitigating its impacts. Climate change is a threat to biodiversity, but is assessed as less important than land use changes, i.e. the direct destruction and/or degradation of natural ecosystems by human interventions such as agriculture or development projects in ecologically sensitive areas. The paradox of undermining biodiversity conservation through climate change mitigation policies has been identified on a global scale. The problem is particularly acute in Greece, which is also a Global Biodiversity Hotspot and therefore bears a great responsibility for the conservation of its important natural heritage. 

The siting of Renewable Energy Sources (RES) in Greece is based on the outdated Special Framework for Spatial Planning and Sustainable Development for RES (hereafter referred to as the Spatial Plan for RES). It was approved in 2008 and is particularly problematic, as it has wind potential as its main siting criterion without taking into account environmental parameters and the existing European legislation regarding the objectives of the NATURA network. Biodiversity today remains unarmored against the negative impacts of incorrectly sited and inadequately studied RES-EEs. Almost 13 years later, and while the revision of the Land Use Plan for RES has been dramatically delayed, we are witnessing the planned siting or installation of RES on the basis of inadequate environmental studies, in areas of huge ecological importance such as the Agrafa mountain range, Pindos, the Saos of Samothrace, Evros - one of the most important migratory corridors for birds of prey in Europe - and Mani, on a major bird migration corridor. Even the unprecedented, to launch the siting of ESDP on the islands of the South Aegean, eliminating the basic characteristic for which the islands are protected: the absence of human activities!

At the same time, many appeals against such zoning are filed with the Council of State, while at the same time local communities express their objections, as they were not informed in time and adequately about the planned ASPEEs in their areas and because they oppose the off-scale zoning that causes destruction to natural monuments and historical landmarks of their areas. 

The need to implement such a scientifically reputable research is great and the timing is critical, as the revision of the Land Use Plan for RES and the preparation of the Special Environmental Studies (SEAs) are in progress, on the basis of which the Presidential Decrees will be issued, which will determine the land use and permitted activities within the protected areas. This research can form the basis of the public debate on the siting of the RES in Greece, with the aim of mitigating conflicts at both environmental and social levels. To this should be added the ecological corridors in which studies by the EIA or other scientists have documented that the installation of ESCOs poses a significant risk to protected species.» 

The position of the environmental organisations was therefore clear, but not for a long time the position of the administration. Twice, on 22 December 2020 and 25 December 2020.η January 2021, successive responsible Deputy Ministers of the Ministry of Environment have stated in Parliament that they agree with the exemption of protected areas from heavy investment. And yet on 23 February 2021, as a bolt from the blue, a Bill of the Ministry of Development was submitted to the Parliament with the signature - consent of the Ministry of Environment, which essentially, with the then proposed Article 219, now Article 218 of the adopted law «Determination of a sub-area of protection in cases of soft development projects», proposes the derogatory promotion of installations based on a study of a prospective investor in a protected area against the obligations of the acquis communautaire and even national legislation. So blatantly unacceptable was Article 218 that it led the members of the Nature Committee of the Ministry of the Environment itself to protest unanimously against this article. 

Since Article 218 in question is in direct contradiction with both the EU regulations and the basic principles governing protected areas, the 3η March 2021 thirty Environmental Organisations protested with the following statement: 

«KOINH ANNOUNCEMENT 3 March 2021 

29,630 citizens and dozens of environmental organisations call for the withdrawal of Article 218 of the public procurement bill 

In just 5 days, 29,630 citizens joined their voices against the unacceptable provision of the bill that is being put to the plenary session of the Greek Parliament. In addition, following a recommendation by 23 organizations to the Nature 2000 Committee, the central scientific advisory body of the state for biodiversity, a statement was issued for the withdrawal of article 218 of the Ministry of Development and Investment's bill on public procurement.

Environmental organisations, which have already submitted interventions to the government and all MPs, are calling for the withdrawal, even at the last minute, of the provision that paves the way for fragmentary protection of parts of Natura 2000 sites for investment projects. 

In an open letter, 30 organisations make a last-ditch appeal to the Prime Minister to intervene for the withdrawal of Article 218. 

If the government insists on keeping the provision in the bill, the organisations are asking MPs to vote against it. 

As has already been pointed out in communications from the organisations, Article 218: 

 It is contrary to Article 6 para. 1 of Directive 92/43/EEC, which requires conservation measures to be taken to meet the ecological requirements of the protected habitats and species. Defining «sub-areas of protection» and their «protective» status on the basis of the implementation of development projects, rather than on ecological criteria, is clearly contrary to the Directive. With the procedure introduced by Article 218 of the Bill, investment projects and interests will in effect dictate the status of the «sub-area». 

• It contradicts the rational way of planning a protected area, which should be based solely on the preservation of valuable, rare or threatened elements of nature. 
• Creates ad hoc regimes into «sub-areas» leading to fragmentation of Natura 2000 sites and their fragmented protection, contrary to the requirements of Directive 92/43/EEC, as interpreted by the Court of Justice of the EU, for an integrated and systematic formulation of biodiversity conservation measures. 
• It conspicuously ignores the fact that Greece has been violating Article 6 of Directive 92/43/EEC on habitats for years, for which our country has been condemned by the EU Court of Justice. 
• It undermines the work of the special environmental studies, management plans and presidential decrees that are already underway for all Natura sites in the country, under the supervision of the Ministry of Environment and Energy, with European co-financing. 
• It increases the administrative burden as it burdens the competent authorities with a parallel procedure for the approval of studies. 
• It introduces an extremely dangerous bypass of the planning law, as it has been shaped even by the recent law 4759/2020 passed by the government in December 2020. According to this law, special protection regimes, such as those of protected areas, are apparently given priority and incorporated into urban plans, not the other way around. The provision that special urban plans will shape the protection measures for Natura sites is a blatant circumvention of the protective status of the country's biodiversity cores. 

Article 218 contradicts Greece's commitment to the objectives of the European Green Deal, which places biodiversity conservation at the heart of the European Union's development strategy. 

The organisations call on the government, with the responsibility that now obviously rests with the Prime Minister himself, to stop treating the country's natural wealth as a plot of land to be built on and to meet our national obligations under EU law to protect our precious biodiversity. 

The environmental organisations: 

1. Alcyone, 

2. ANIMA, 

3. Arion, 

4. Arcturus, 

5. ARCHELON, 

6. Action for Wildlife, 

7. Hellenic Society for Environment and Culture, 

8. Hellenic Society for the Protection of Nature, 

9. Hellenic Ornithological Society, 

10. Corinthian-Patraikos Gulf Environmental Protection Association «Nereus», 

11. Prespa Protection Society, 

12. Tapestry, 

13. Citizens« Movement for the Protection of the Aoos River »Protect Aoos", 

14. Pelagos Institute of Cetological Research, 

15. Ecological Recycling Company, 

16. Earth Organization, 

17. Federation of Ecological Organizations of Corinthian Gulf «The Alkion», 

18. PANDOIKO, 

19. Environmental Initiative of Magnesia, 

20. Pindos Environmental, 

21. Association “Tulipa Wulimi”, 

22. Friends of Nature, 

23. ECOCITY, 

24. Greenpeace, 

25. The Green Tank, 

26. iSea, 

27th MedINA, 

28. MEDASSET, 

29th MOm 

30. WWF Hellas 

For any reader who may have the slightest doubts, we attach the moderately expressed article of the experienced journalist of the newspaper «Kathimerini» George Lialios, published on the website “inside story” on March 5th 2021 (The article is available at the following link: https://insidestory.gr/article/natoyra-se-kindyno?token=48IQB4ZR03&fbclid=IwAR33FIdYEUypA-1OQmglXcJnqzOqdGNqZDTvHnQx3R_aKGL9AxMbwc0daQI), which recounts the case, a tragic confirmation of the administrative inefficiency of successive political leaderships: 

«The problem with Article 219 on Natura sites 

«We cannot all subscribe to the logic of doing nothing in the 30% of Greek territory. Something must be done. Somehow people have to live and eat bread.» 

The position of the Minister of Development, Adonis Georgiades, in the Parliament a few days ago, apart from being an example of populism, indicates the basic dichotomy with which the systematic degradation of environmental legislation has been communicated over the last decade. The collapse of environmental legislation in crisis Greece: the protection of the environment (as something arterial, obsessive) versus development (as a vehicle for survival). This is a false dichotomy that has been used extensively over the last decade to justify regulations that favour specific activities or business sectors. It could be tolerable under certain circumstances if such regulations did not ultimately work against the public interest. 

Mr Georgiades« statement concerned Article 219, which was inserted in a draft law on public procurement and public works. What does it provide for? That until the Special Environmental Studies (SEAs) for Natura sites are completed, »sub-areas« for »soft development projects of public interest« can be defined within the latter. A procedure is laid down: the interested party will have to prepare an EIA specifically for this »sub-area', which will in fact modify the broader EIA under preparation and a strategic environmental impact assessment (SEA), and the whole process will ultimately be approved by presidential decree. 

This arrangement is problematic from the outset, but to understand why we need to go back a few decades.

Greece and Natura: The vine was crooked... 

In 1992, the European Union adopted the Habitats Directive, on the basis of which the Natura 2000 network was created - Environment - European Commission. Each Member State, including Greece, submitted a «national list» of these sites, which has been updated and enriched over the years (Greece did this for the last time in 2017). The problem is that our country has not gone much beyond this: it has established some national parks or other types of protected areas (by presidential decrees or joint ministerial decisions, which fell to the Council of State, which insisted on presidential decrees), created protected area management bodies (underfunded and with an advisory role in decision making), but invested little in the substance, i.e. monitoring of protected species of flora and fauna and protected habitats, the preparation and implementation of a list of protected areas, the monitoring of protected areas, and the monitoring of protected species of flora and fauna and protected habitats. 

From the beginning of the last decade it was clear that our country was heading towards the European Court of Justice. In an attempt to halt this development, in 2011 the Ministry of Environment designated all protected areas as «Special Conservation Zones». It provided for the preparation of «Special Environmental Assessments» (SEAs) in order to define objectives and management measures. One year later, the six-year deadline for our country to adopt these objectives and measures expired. In 2015 the first stage of the referral process starts. Greece before the European Court of Justice for inadequate protection of the country's Natura 2000 network in the European Court of Justice. In 2020 came the conviction of Greece by the EU Court of Justice for insufficient protection of biodiversity (case 849/19C-849/19 - Commission v. Greece). 

The decision is a mockery of Greece's unwillingness to protect the Natura 2000 network in practice. As it states (paragraph 76), in each designated area the necessary measures must be implemented in relation to the conservation objectives that have been set. The obligation concerns not only «the adoption of the conservation measures necessary to maintain the protected habitats and species within the area concerned in a satisfactory conservation status, but also, and above all, their effective implementation by means of complete, clear and precise measures, so that this provision is not rendered ineffective in practice» (paragraph 77). At the same time, any room for assessment by the Member States of the existence of an obligation is excluded and any regulatory or decision-making powers are restricted. The definition of conservation objectives in Natura sites is «a necessary prerequisite in the context of the designation of sites as SPAs and the definition of conservation priorities and measures» (paragraph 50). 

And it concludes: «in the light of the conservation objectives, it is necessary to determine the content of the obligation to carry out a proper assessment of the impact of a plan or project on a protected site and, secondly, that the Habitats Directive requires the competent national authority to identify and assess all those aspects of a plan or project which are likely to affect the conservation objectives of the protected site before granting the relevant authorisation» (paragraph 51). 

...the donkey ate it too 

With all these facts, it was obvious from the very first moment that Article 219 is not only not in the spirit of the ECJ ruling, but may accelerate the country's return to the dock of the ECJ (the second conviction leads to the imposition of a fine). The explanatory memorandum of the regulation «On the modernisation, simplification and reform of the regulatory framework for public procurement, special procurement rules in the fields of defence and security and other provisions for development and infrastructure» is just as misleading as what Mr Georgiades claimed from the floor of the Parliament: «[The] implementation of the institutional framework on protected areas to date shows significant variations in the interpretation of the same basic provisions of the legislation from time to time, which makes it difficult to formulate a clear and unambiguous view of what is practical in the context of the study in the case of specific proposals of public interest for the use of land within the zones or protected areas (such as, for example, soft organised forms of ecological tourism, cultural projects, upgrading of facilities of a cultural nature). The protection of areas requires regulating the planning and control procedure in protection areas for projects of public interest within a transitional stage until the completion of the preparation and approval of Special Environmental Studies,» it says. Why is this justification misleading? Environmental legislation does not «make it more difficult to form a clear view of the deed», it makes it more difficult to approve any «deed» relating to protected areas. That is, after all, the reason for its existence. 

The argument of the Minister of Development, that the approval will be made by presidential decree, so each case will be (pre-judicially) controlled by the Council of State, shows the political management of the issue: if someone «cuts it», it will not be «us» (the government of the day) but the supreme court of annulment. 

As expected, environmental organisations protested from the very first moment. Within a few days, 23 of them repeatedly called for the withdrawal of the article in question, pointing out the points where it contradicts national and Community legislation. In five days, WWF collected 30,000 signatures of citizens against the regulation. 

But the case did not end there. In a rare (in recent years) moment, the view of environmental organisations was unanimously endorsed by the Nature 2000 Commission, the official scientific advisory body of the State for the protection of biodiversity «Nature 2000 Commission Communication 1 March 2021». As it states, this regulation «is proposed without documentation, is not consistent with the rational planning of permitted uses and activities within a protected area, which must be done with the conservation of biodiversity in mind, complicates the process of preparing Special Environmental Assessments and Management Plans and issuing Presidential Decrees for all Natura 2000 sites, which is currently underway, and is expected to increase the administrative burden and complexity of their implementation». 

A day later, the report on the bill by the Scientific Service of the Parliament came to dispel any last doubt: «[...] it is observed that the preparation of individual special environmental study (ed.The fact that a specific environmental impact assessment study (for the sub-region) has been carried out for a particular sub-region, while no study has been carried out for the whole of the area in question, creates a risk of fragmented management of a certain area, the importance of which is assessed on the basis of a number of parameters that go beyond its geographical boundaries and encompass the wider area to which it belongs from an ecological point of view». In other words, any business activity cannot change the protection plan for an area. Furthermore, the Scientific Committee notes that the term «soft development project in the public interest» is vague and therefore ... is interpreted in an ambiguous manner (i.e. «dubbed» at will). 

What's the «doctrine»? Who is the Ministry of Development trying to serve, putting the country at risk of being condemned again by the European Court of Justice? Those involved in the field have a first, very interesting observation: the regulation does not concern «small fish», as the process of preparing EIAs and SEAs is costly. So by definition it concerns large investments. Which business areas could it concern? According to the report, the regulation was «proposed» to the Ministry of Environment and in 2020 by hotel industry players, without being accepted then... 

George Lialios» 

One can reasonably conclude that this is one of the biggest and most damaging national shames of the recent decade and unfortunately it proves the long-standing lack of administrative and political concern for one of the most basic components of Greece, namely the nature of the country, in which the Greek people have developed since antiquity.

II.4.Marine Wind Turbines and Marine Spatial Planning 

ELLET considers the Marine Spatial Planning as an imperative and necessary condition for the promotion of Offshore Wind Turbines. There are three reasons. 

Firstly, the obligation for Greece to have developed a framework for maritime spatial planning by 31 March 2021, in accordance with EU Directive 2014/89. Second, the need to ensure the distinct needs of safe navigation, the establishment of fish farms and the protection of marine biodiversity, as well as the migratory passage of migratory birds. Thirdly, the urgent challenge of meeting national energy targets, combined with international expert estimates that the largest percentage increase in renewables in the coming decades will be offshore, as has already happened to an impressive extent in the North Sea (EU strategy on offshore renewable energy | Energy (europa.eu), https://ec.europa.eu/energy/sites/ener/files/offshore_renewable_energy_strategy.pdfIn fact, some countries in that region no longer locate onshore wind turbines anywhere, since offshore wind turbines are preferred, while about 10% of the UK's energy needs are already met by offshore wind turbines, with a target of 30% by 2030. Objections to the ever-increasing size of onshore wind turbines are naturally much smaller when it comes to offshore. 

Offshore wind is expected to become one of the major sources of electricity generation in Europe by 2040. Since, due to rapid technological development, it is now mainly floating wind turbines or offshore wind energy is suitable for Greek waters and can turn part of the Greek seas into a centre for the production and perhaps even export of clean energy. Of course, such a development will be favoured by the extension of national and territorial waters from 6 to 12 nm to the south, as has already been done to the west, and hopefully will also be done in the future by settling national territorial waters in the Aegean in a way that will create wider areas for their installation. 

Due to the advanced technology of offshore wind turbines, their development can also boost domestic value added and local employment by developing infrastructure across the supply chain (ports, shipyards, cable industry). In contrast, one of the disadvantages of onshore wind turbines at present is the relatively low rate of domestic value added.

The exploitation of offshore wind energy could be an alternative to the great pressures that island and mountainous areas, important for Greek nature and culture, are already under from industrial-scale onshore wind farms. For the above reasons, ELLET, in a letter of 5 February 2021, asked the Ministry of Environment to immediately start a public dialogue under the auspices of the Administration on marine spatial planning and is pleased with the recent news that such a dialogue is already underway. 

It goes without saying that there will be differences in terms of individual siting, since marine wind turbines, together with the facilities required to connect them to the national grid, can certainly in many cases have negative impacts on marine and coastal ecosystems. But the way to minimise these differences is to conduct a public dialogue in good time as part of an effort to gradually build up the necessary consensus on the areas where offshore wind turbines are appropriate over the coming decades. Such a choice by the administration would represent a constructive change from the authoritarian and anti-European behaviour it has displayed over the last decade in the case of the protection of - supposedly - protected areas 

II.5.Energy storage: Pumped Storage and Batteries 

The high penetration of floating RES (photovoltaic, wind) in the energy mix requires a corresponding development of storage facilities. High-capacity pumped storage projects or batteries - which, however, require the use of rare and expensive earths, mainly lithium - must be included in energy planning. Sufficient electricity storage capacity is needed during the peak production periods of RES to stabilise the electricity system in Greece, since it is certain that in the coming years RES will have more installed capacity than today. Otherwise, the problem of the stability of an energy system during the transition from fossil fuels to renewables will be seriously aggravated, especially at a time when, largely due to climate change, extreme weather events are on the increase. There have already been serious cases of total loss of electricity in Australia, California and Texas, so the continuation of research and development of storage systems in Greece is a matter of urgency. 

Fortunately there are already two pilot examples, in Ikaria and Crete, but many more will be needed. Pumped storage is also an appropriate solution for many islands that are not connected to the national grid. 17 islands, apart from Crete, already have suitable infrastructure, either reservoirs or ponds, which are suitable for pumped storage in the first instance [See Annex I]. Energy and Water in Greece, Edited by Loukas G. Christoforou, Energy Committee of the Academy of Athens, 2020. There is no doubt that the current polluting installations on all islands must be urgently removed. Each island must meet its own energy needs with renewable energy sources, even if it is connected to the national grid, and even more so if it is not connected. Pumped storage is therefore a model that can provide clean and cheap electricity to the islands. 

More generally, pumped storage is also the most important form of storage of electricity generated from RES. Firstly, it is known worldwide. Already the installed capacity of pumped storage systems reaches about 160 GW, representing almost 95% of the storage systems of all currently available technologies. Secondly, the geomorphology of Greece makes it an ideal solution for our country. Third, the other main solution for electricity storage based on the use of batteries, mainly lithium, suffers for two main reasons, that it is economically uncompetitive for large scale applications and furthermore that it is ecologically modest in relation to the central problem posed by the ecological crisis, namely the overall footprint of humanity. It would take, it is estimated, four times the established reserves of raw materials such as lithium to meet the necessary production of batteries for renewable energy storage on a global scale. 

II.6.Photovoltaic parks 

Photovoltaics are preferable to be located in already altered or degraded areas, as PPC rightly plans for the abandoned lignite mines in Ptolemaida and Megaloupolis. A second favourable case in the countryside concerns semi-improved or unimproved agricultural land without steep land slopes. A third concerns flat areas close to existing roads. 

Within cities, photovoltaics are offered for the degraded urban environment of modern Greek megacities, where energy upgrading is an urgent need, to which photovoltaics can contribute without further burdening an already burdened visual image (See also I.3.The challenge for architects and designers remains to create and install stylish photovoltaic systems for new housing in cities, suburbs and countryside.

On the contrary, photovoltaic systems should not be placed on productive agricultural land, in forests, in traditional settlements or in traditional districts of big cities. In short, solar energy has an important role to play, but photovoltaics, like wind power, must be sited according to strict selection criteria. 

II.7.Hydropower: the pros and cons 

Large hydroelectric projects have a decades-long tradition in Greece. Their construction generates a significant amount of domestic added value (mainly civil engineering projects undertaken by Greek construction companies independently and/or in cooperation with international companies). Large hydropower plants offer significant amounts of electricity without greenhouse gas emissions and in a flexible way. This flexibility is particularly necessary in the new energy era, as it comes to cover fluctuations, due to weather conditions, in the production of photovoltaic and wind turbines. However, as Greece has few large rivers, the number of new large hydroelectric projects that can be planned and built is limited, even if climate change does not lead to a reduction in rainfall, as it is likely to do. 

Obviously in our country we do not have to face the negative consequences of large hydroelectric projects on the scale experienced by regions of China and Africa, with the displacement of millions of people for the construction of projects of tens of gigawatts in China and the threat of warfare between the countries crossed by the Nile as a result of the construction of the new huge hydroelectric dam in Ethiopia. However, attention should also be paid by the administration in our country to minimize the impact on fauna, flora and alteration of the natural mountain environment from the construction of any proposed new projects. 

Small and very small hydroelectric projects are a special case for Greece. Despite the potential of hundreds of megawatts for production from such projects, in practice only a small proportion has been exploited and, especially in the last fifteen years, very few have been built. These projects have the extraordinary advantage of involving and usually activating the local community, as they are generally owned by small and very small local business units. In this way, the acceptance of renewable energies by local communities is of course also increased. They also do not cause the visual disturbance (due to their size and location) that large hydroelectric projects cause, which sometimes harmonise with nature (e.g. Kerkini) but more often damage it.

The main disadvantage of small hydropower plants is that they divert significant amounts of water for lengths of 1-3 km from the bed of streams and small rivers. This means that we cannot and should not go overboard with several consecutive hydroelectric plants in the same stream to avoid significant cumulative impacts on the ecosystem. It is fortunate that the existing institutional framework prevents such excesses. We acknowledge, of course, that in many cases the narrowness of the institutional framework removes the possibility of developing a significant number of small hydropower plants with increased climate and local added value. We therefore urge the Administration to investigate and, where it sees fit, revise the institutional framework so that small hydro can proceed where it does not harm biodiversity. It is a difficult exercise, but that is how we will generally proceed from now on, in other words, with difficult exercises in balancing climate objectives and biodiversity protection, taking particular account of the objective of the new European biodiversity strategy on the restoration of free-flowing rivers (https://ec.europa.eu/environment/nature/natura2000/management/docs/hydro_final_june_2018_el.pdf). 

III. The licensing procedure 

The main milestones and steps of the RES licensing process are presented below. More specifically, the main stages are: 

1. Issuance of an Electricity Producer Certificate by the Independent Administrative Authority «Regulatory Authority for Energy (RAE)» 

2. Issuance of an installation permit by the competent Decentralized Administration, which requires the approval of Environmental Conditions - EPO where required, approval of small works by the Town Planning Department, Offer of connection terms by the Greek Electricity Distribution Network Operator -ΔEDΔΗΕ (or the Independent Electricity Transmission Operator - ADMIE for projects to be connected to High Voltage) and signing of the operational support contract with the Operator of Renewable Energy Sources and Guarantees of Origin - ΔΑΠEEΠ 

3. Issue of an operating license by the competent Decentralized Administration. 

In the case of small photovoltaic systems, with power up to 1 MWp, the steps required are: 

1. A certificate of exemption from an EPO - subject to specific exceptions where an EPO is required -, issued by the competent Region (projects within organised industrial activity receptors are exempt from this obligation), 

2. Approval of minor works by the Planning Department, 

3. Offer of connection terms by the DEDDEO and 

4. Signing of the operational support contract with the IACSIF. 

With regard to the first step of the RES licensing procedure, i.e. the issuance of an Electricity Producer's Certificate by RAE, the legislator's objective was to establish a very short licensing procedure, reducing to a minimum the required documentation and using automated checks, essentially turning the producer's certificate into a feasibility license, so that the would-be investor can start the actual maturation of his project. As a result, issues related to environmental nuisance, degradation and/or land use conflicts are not addressed by the RAO at all. 

Given the uproar of local communities across the country about the production certificates issued, and the relevant maps showing the country «flooded» with RES (with certificates even on the same plot), we at ELLET believe that this stage should be modified. We believe that before the certificate application is filed, there should have been cooperation with local communities and the carrying capacity of each area should have been taken into account, something that is currently only considered during the EIA phase. It is also necessary to launch, immediately, the updating of the Special Spatial Framework for RES and the explicit definition of exclusion zones. 

In the current climate crisis, humanity is faced with a multitude of environmental, social and economic problems. The effects of climate change and the scarcity of natural resources are increasingly intensifying, with their impact spreading alarmingly around the world. In this context, the production of energy from renewable sources (RES) is a one-way street, widely recognised as one of the key factors in reducing the ecological footprint and mitigating the climate crisis. 

However, the development of renewable energy sources sometimes causes major local reactions. The usual reasons why a renewable energy project will not be socially acceptable are related to: (a) the potential environmental impact of access and installation works in the area where the renewable energy plant is located; (b) the visual disturbance caused by the project; and (c) land use conflicts. At the same time, taking into account the great backwardness of land-use planning and decision-making in general, which usually does not take account of local sensitivities and specificities, the negative attitude of the local community is justified. 

Climate change is «a fact» and it should be immediately understood that all local communities, including the big cities, are being asked to accept a very big change: that the energy they consume will be produced as much as possible on site and from clean energy sources. All regions, in all countries of the world will have to address the issue of installing some form of renewable energy in their neighbourhood. This difficult transition, which justifiably causes friction and reactions, should be carried out, on the one hand, with respect for nature and culture, and on the other hand, after an investigation of social acceptance on the part of the local communities concerned, as expressed directly or indirectly through the elected authorities or through associations and environmental organisations, such as ELLET, which is ready to take a leading role in the relevant developments.

The following participated in the compilation: 

Charis Dukas (Vice-Chairman of the Energy and Tax Reform Council), 

Maro Evaggelidou (President of the Institutional Framework Council), 

Costas Karras (Chairman of the Life-IP Monitoring Committee), 

Miltiadis Lazoglou (Associate of the Life-IP Monitoring Committee, Associate of the Institutional Framework Council), 

Fotis Papoulias (Vice-Chairman of the Natural Environment Council), 

Vasiliki Pugakioti (Associate of the Energy and Tax Reform Council), 

Ioannis Tzortzis (Member of the Energy and Tax Reform Council), 

Antonia Trichopoulou (President of the Quality of Life Council)