E. Greece

Unofficial AI-generated summary based on the public title and abstract. Not an official translation.

🔬研究者:EU加盟国の気候法制定プロセスとエネルギー政策の矛盾を理解するためのケーススタディ。

🏢実務担当者:炭素報告義務やEV導入義務など、企業に課される具体的なコンプライアンス要件の例として参照可能。

🏛政策担当者:気候法の設計における目標設定と執行メカニズムのギャップ、再エネ許認可の簡素化と環境保護のバランスを検討する際の参考。

Faced with the negative consequences of the COVID-19 pandemic, this year saw Greece taking the first steps towards implementing its €30.5 billion national recovery and resilience plan that was approved by the European Commission in June 2021. Greece’s green transition will receive 37.5 percent of the reform package. In addition, after Russia’s launch of a full-scale invasion of Ukraine in February, the concomitant energy crisis has led to a series of regulatory interventions with important implications for Greece’s environmental law and policy. This report pinpoints the key developments concerning environmental law in Greece during the past year. In May, Law 4936/2022 was enacted (Government Gazette A/105/27.05.2022). It is Greece’s first National Climate Law endorsing the climate neutrality objective of the European Climate Law (EU Regulation 2021/1119 Establishing the Framework for Achieving Climate Neutrality). The Greek Climate Law prohibits electricity generation from lignite-power plants from 31 December 2028, with the possibility to set the prohibition earlier if the responsible minister finds no risk to energy supply and security (Article 11). Notwithstanding this, following Russia’s military aggression against Ukraine, which has shaken energy markets and put Europe’s energy security at risk, in July, the Greek government launched the operation of a new lignite-fired plant in Ptolemaida, Western Macedonia, and announced a 200 percent increase in the total production of electricity from lignite. In contrast with lignite, the Greek Climate Law sets no specific timeframe for the phasing out of natural gas but only a requirement for gradual phase-out and replacement by renewable gases, such as biomethane and green hydrogen (Article 10(1)(d)). While the adoption of a national strategy on hydrogen in November was welcome, paving the way towards including green hydrogen in the country’s energy mix, Greece’s continuing reliance on fossil fuels is apparent. At the twenty-seventh Conference of the Parties (COP-27) of the United Nations Framework Convention on Climate Change, the Greek prime minister, Kiriakos Mitsotakis, stressed the need for further investments in gas infrastructure and the importance of liquified natural gas imports. A few months earlier, however, it was announced that oil exploration and drilling is no longer the government’s priority, which may count as a win for local communities and environmental non-governmental organizations (ENGOs), which have argued that the hydrocarbon activities go against the obligations under the Paris Agreement and have major environmental implications. The development of hydrocarbon exploration and exploitation projects—notably oil and gas, in- and offshore—remained high on the government’s agenda. Except for one, all hydrocarbon projects in Greece concern gas exploration and offshore exploitation. The hurdles in approving the environmental terms for these projects, which are based on concession agreements between the state and foreign investors ratified by law, are major, but, as the case law demonstrates, not insurmountable. For example, with Decision no. 2462/2022, the Greek Council of State (Symvoulio tis Epikrateias) dismissed the petition for annulment (aitisi akiroseos) lodged by ENGOs in 2019, claiming procedural irregularities in the adoption of the Approval of Environmental Terms (AET) for the hydrocarbon exploration and exploitation southwest and west of Crete. Relying on its settled case law, the Council of State refused to accept the claimant’s argument that the maritime spatial planning, which was not conducted for the designated area, was a prerequisite for the AET. Nor did it accept that substantive errors in the environmental impact assessment (EIA)—notably, the fact that the limits of seven Natura 2000 sites falling within the area designated for hydrocarbon exploration and exploitation were incorrectly stated—affected the completeness of the EIA and, by logical implication, the validity of the AET. This decision is yet another unsuccessful attempt of ENGOs to block the continuation of projects on environmental grounds. Apart from setting targets on the phasing out of lignite, the Climate Law also introduces several important obligations for corporations. Specifically, carbon reporting obligations are imposed on specific categories of undertakings—for example, insurance companies, investment firms, and listed companies—that shall submit carbon footprints of the previous year at a publicly accessible register from 2023 onwards. Also of note is that licensed installations and projects that are classified as posing significant effects on the environment are compelled to reduce their emissions by 30 percent until 2030 using the year 2019 as a calculation basis. Similarly, a reporting obligation to submit emission reduction reports annually is placed from 2026. Another positive development introduced by the Greek Climate Law concerns the targets for electric mobility. According to the new law, 25 percent of corporate vehicles shall be either electric or hybrid from 1 January 2024. In addition, one-third of rental cars need to be electric or hybrid from 1 January 2026, while all new taxis in Athens and Thessaloniki must be zero emission from that date. Further, in line with the EU legislation, only zero-emission passenger vehicles and light commercial vehicles will be placed on the market from 1 January 2030. With respect to energy efficiency, the Climate Law establishes new annual final energy savings, but, regrettably, there is no legal consequence in case the targets are not met. Moreover, although oil boilers for heating purposes will no longer be sold or installed after 1 January 2025, and renewable liquid fuels must be mixed with heating oil from 1 January 2030, there is no reference to energy democracy or concrete measures on how to tackle energy poverty under the new law. On public participation, a National Climate Change Council is established, acting as the public’s representative body (Article 28), whereas the dialogue between the government and the public is enhanced by creating a ‘climate dialogue’ website (Article 26). The Climate Law also establishes five sectoral carbon budgets in line with EU legislation and the country’s National Energy and Climate Plan. Also encouraging is the adoption of a Strategic Development Framework (GR-eco islands) to ensure that Greek islands become energy autonomous and climate neutral by 2050. All things considered, the Climate Law moves Greece in the right direction. However, certain loopholes in the legislation show that the government needs to take additional measures to ensure full compliance with international and EU commitments. The period of reference is marked by the adoption of Law 4951/2022 (GG’ Α 129/04.07.2022), which simplifies the process for the licensing of projects from renewable energy sources (RES) and sets up the regulatory framework for the installation of energy storage facilities in Greece in line with EU Directive 2019/944 on Common Rules for the Internal Market for Electricity as well as Law 4964/2022 (GG’ Α 150/30.07.2022), which sets forth the requirements for the exploration, development, and operation of offshore wind projects. In regard to Law 4951/2022, the introduced changes speed up the final stages of the licensing process considerably, thus bearing no impact on the operators’ obligation to acquire an environmental permit—that is, AET—at the first stage. Noteworthy is that the law introduces the requirement to apply for an AET for energy storage facilities—namely, those used exclusively for energy storage or those combining electricity production with energy storage. Turning to the new offshore wind energy law (that is, Law 4964/2022), it serves as the legal basis for developing wind projects in designated areas referred to as ‘organized development areas.’ Before doing so, the Hydrocarbons and Energy Resources Management Company, controlled by the Greek state and granted exclusive rights for the exploration and exploitation of the country’s offshore wind potential, is tasked with the preparation of a National Development Programme defining the potential sea areas for the development of the projects. Pursuant to Article 67 of said law, the National Development Programme shall be based on a strategic environmental impact assessment (SEIA) and approved by a joint ministerial decision. The organized development areas specified in separate presidential decrees will also be subject to a SEIA. Interested operators are required to apply for an exploration license and only holders of these licenses will be entitled to enter the competitive bidding process for granting operating aid. The installation of the project in a specific installation area of an organized development area will be assigned to the successful bidder. The construction of offshore wind energy projects is expected to commence in 2028. In the meantime, the regulatory measures necessary for the implementation of Law 4964/2022 may give rise to new controversies between ENGOs and the Greek state if the impacts of the projects on the marine environment and biodiversity are not taken seriously. During the period of reference, the Council of State rendered several decisions relating to the environmental licensing of RES projects and activities. Notably, by Decision 1378/2022, the court invalidated the AET of a wind park due to the latter’s proximity to Crete’s most well-known cultural heritage site, Knossos Palace. Another example is Decision 1429/2022, where the court tried to strike a balance between the development of RES projects, which are by default considered environmentally friendly and necessary for the green transition, with the constitutional protection of the environment (Article 24 of the Greek Constitution). In this case, the court held that the principle of sustainable development does not preclude the in

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