COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review Country Report - GREECE Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions The EU Environmental Implementation Review: Common Challenges and how to combine efforts to deliver better results - Hoofdinhoud

Council of the European Union

Brussels, 6 February 2017 (OR. en)

5967/17 ADD 10

ENV 103 ECOFIN 70 SOC 68 COMPET 74 POLGEN 9 CONSOM 37

COVER NOTE

From: Secretary-General of the European Commission, signed by Mr Jordi AYET PUIGARNAU, Director

date of receipt: 6 February 2017

To: Mr Jeppe TRANHOLM-MIKKELSEN, Secretary-General of the Council of the European Union

No. Cion doc.: SWD(2017) 41 final

Subject: COMMISSION STAFF WORKING DOCUMENT

The EU Environmental Implementation Review

Country Report - GREECE

Accompanying the document

Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions

The EU Environmental Implementation Review: Common Challenges and

how to combine efforts to deliver better results

Delegations will find attached document SWD(2017) 41 final.

Encl.: SWD(2017) 41 final

EUROPEAN COMMISSION

Brussels, 3.2.2017 SWD(2017) 41 final

COMMISSION STAFF WORKING DOCUMENT

The EU Environmental Implementation Review

Country Report - GREECE

Accompanying the document

Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions

The EU Environmental Implementation Review: Common Challenges and how to

combine efforts to deliver better results

{COM(2017) 63 final i}

{SWD(2017) 33 - 40 final}

{SWD(2017) 42 - 60 final}

Greece 2

This report has been written by the staff of the Directorate-General for Environment, European Commission. Any comments are welcome to the following e-mail address: ENV-EIR@ec.europa.eu

Greece 3

More information on the European Union is available on the internet ( http://europa.eu ).

Photographs: p.9 – ©LIFE09 ENV/GR/000294, p.11 – ©Dimitar Glavinov/iStock, p.17 – ©Maciej

Noskowski/iStock, p.22 – ©Alexander Hafemann/iStock

For reproduction or use of these photos, permission must be sought directly from the copyright holder.

©European Union, 2017

Reproduction is authorised provided the source is acknowledged.

Table of Content

EXECUTIVE SUMMARY .................................................................................................................................... 4

PART I: THEMATIC AREAS ............................................................................................................................... 6

• 1. 

  TURNING THE EU INTO A CIRCULAR, RESOURCE-EFFICIENT, GREEN AND COMPETITIVE LOW-

  CARBON ECONOMY ............................................................................................................................... 6

  Developing a circular economy and improving resource efficiency ..................................................... 6

  Waste management .............................................................................................................................. 7

PROTECTING, CONSERVING AND ENHANCING NATURAL CAPITAL .............................................................. 10

Nature and Biodiversity ....................................................................................................................... 10

Green Infrastructure ........................................................................................................................... 12

Soil protection ..................................................................................................................................... 12

Marine protection ............................................................................................................................... 13

• 3. 

  ENSURING CITIZENS' HEALTH AND QUALITY OF LIFE .......................................................................... 14

  Air quality ............................................................................................................................................ 14

  Noise ................................................................................................................................................. 15

  Water quality and management ......................................................................................................... 15

  Enhancing the sustainability of cities .................................................................................................. 17

  International agreements ................................................................................................................... 17

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS ..................................................................... 19

• 4. 

  MARKET BASED INSTRUMENTS AND INVESTMENT .................................................................................. 19

  Green taxation and environmentally harmful subsidies ..................................................................... 19

  Investments: the contribution of EU funds ......................................................................................... 20

• 5. 

  EFFECTIVE GOVERNANCE AND KNOWLEDGE ........................................................................................... 22

  Effective governance within central, regional and local government ................................................. 22

  Compliance assurance ......................................................................................................................... 23

  Public participation and access to justice ........................................................................................... 24

  Access to Information, knowledge and evidence ............................................................................... 25

Greece 4 Greece 5

Executive summary

About the Environmental Implementation Review environmental legislation. This can be demonstrated by

In May 2016, the Commission launched the the high number of infringement cases currently ongoing Environmental Implementation Review (EIR), a two-year against the country, very often at an advanced stage. cycle of analysis, dialogue and collaboration to improve Waste management is the area where the biggest the implementation of existing EU environmental policy problems can be observed, with illegal landfilling, very and legislation 1 . As a first step, the Commission drafted low recycling rate and the management of hazardous 28 reports describing the main challenges and waste at the top of the list. Challenges remain in the field opportunities on environmental implementation for each of urban waste water treatment, as well as regarding air Member State. These reports are meant to stimulate a quality, particularly in urban centres. Greece has a rich positive debate both on shared environmental challenges natural environment that can create numerous for the EU, as well as on the most effective ways to opportunities for sustainable development and growth. address the key implementation gaps. The reports rely on However, its protection needs to be strongly enhanced. the detailed sectoral implementation reports collected or Finally, it can often be observed that complex issued by the Commission under specific environmental administrative structures and procedures can be the legislation as well as the 2015 State of the Environment cause of significant delays and bottlenecks and Report and other reports by the European Environment sometimes represent the main obstacle for the Agency. These reports will not replace the specific implementation of environmental legislation in Greece. instruments to ensure compliance with the EU legal Financing is also a significant issue, particularly for areas obligations. where EU funding is not available.

The reports will broadly follow the outline of the 7th Main Challenges

Environmental Action Programme 2 and refer to the 2030 The three main challenges with regard to

Agenda for Sustainable development and related implementation of EU environmental policy and law in

Sustainable Development Goals (SDGs) 3 to the extent to Greece are:

which they reflect the existing obligations and policy

objectives of EU environmental law 4 .  Addressing the main waste management problems (closure of illegal landfills, treatment of hazardous

The main challenges have been selected by taking into waste) as a matter of absolute priority. account factors such as the importance or the gravity of  Putting in place an efficient national system for the the environmental implementation issue in the light of comprehensive administration and functioning of the impact on the quality of life of the citizens, the protected areas, raising awareness about Natura distance to target, and financial implications. 2000 and creating incentives for investments

The reports accompany the Communication "The EU promoting its benefits, improving capacity of Environmental Implementation Review 2016: Common competent authorities, ensuring effective challenges and how to combine efforts to deliver better environmental assessments at plan and project level, results", which identifies challenges that are common to and improving enforcement of legislation on the several Member States, provides preliminary conclusions ground. on possible root causes of implementation gaps and  Completing implementation of the Urban Waste proposes joint actions to deliver better results. It also Water Treatment Directive, giving priority to those groups in its Annex the actions proposed in each country agglomerations that are subject to an infringement report to improve implementation at national level. case.

General profile Main Opportunities

Greece faces significant difficulties in implementing EU Greece could perform better on topics where there is already a good knowledge base and good practices. This applies in particular to:

1 COM(2016) 316 final : Communication "Delivering the benefits of EU

environmental policies through a regular Environmental  Invest in separate collection and recycling and use

Implementation Review". economic instruments to improve the country's

2 Decision No. 1386/2013/EU of 20 November 2013 on a General Union

Environmental Action Programme to 2020 " Living well, within the overall waste management performance, which can

limits of our planet ". result in the creation of jobs and revenues.

3 United Nations, 2015. The Sustainable Development Goals  Effectively protect, restore and ensure sustainable

4 This EIR report does not cover climate change, chemicals and energy.

Greece 5

use of the country's natural capital, especially under the Natura 2000 network, so as to maximise potential benefits deriving from ecosystem services which can serve as powerful economic drivers, including through green tourism and other sustainable activities.

 Simplify administrative procedures and improve cooperation of public authorities involved in the application of environmental policies, which will allow for smoother and quicker implementation.

Points of Excellence

Where Greece is a leader on environmental implementation, innovative approaches could be shared more widely with other countries. Good examples are:

 According to the EEA report 'European Bathing

Water quality in 2015, 97.2 % of bathing waters in Greece were of excellent quality.

 Greece reaches very high compliance rates of 99-

100% for microbiological, chemical and indicator parameters laid down in the Drinking Water Directive.

 Greece made good and early use of LIFE funds for proposing a substantial national list of sites for Natura 2000 under the Habitats Directive. Close collaboration of authorities and conservation NGOs in some cases has allowed building expertise and putting in place effective measures in specific areas.

Greece 6

Part I: Thematic Areas

• 1. 

  Turning the EU into a circular, resource-efficient, green and

  competitive low-carbon economy

  resource productivity has increased steadily but modestly

Developing a circular economy and improving since 2007. Resource productivity has increased slightly

resource efficiency compared to 2014.

The 2015 Circular Economy Package emphasizes the need Figure 1: Resource productivity 2003-15

8

to move towards a lifecycle-driven ‘circular’ economy, with a cascading use of resources and residual waste that is close to zero. This can be facilitated by the development of, and access to, innovative financial instruments and funding for eco-innovation.

SDG 8 invites countries to promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all. SDG 9 highlights the need to build resilient infrastructure, promote inclusive and sustainable industrialization and foster innovation. SDG 12 encourages countries to achieve the sustainable management and efficient use of natural resources by 2030.

The Operational Programme on Competitiveness,

Measures towards a circular economy Entrepreneurship and Innovation under the new NSRF (2014-2020) will allocate EUR 28.8 million on the

Transforming our economies from linear to circular offers promotion of innovative technologies for environmental an opportunity to reinvent them and make them more protection and resource efficiency in the areas of waste sustainable and competitive. This will stimulate management, water management, soil contamination investments and bring both short and long-term benefits and air pollution. The support will include research & for the economy, environment and citizens alike. 5 development (R&D) activities in businesses for the

Environmental policy in Greece focuses on the promotion development and uptake of antipollution technologies

of renewable energies and energy efficiency measures, and monitoring mechanisms. Another EUR 28.3 million will be allocated to supporting green growth and ecowhich

can promote eco-innovations. These measures,

along with the new national Waste Management Plan innovation both in the private and public sectors. The

(WMP) can facilitate the transition towards a circular supported activities will include actions to increase the technological know-how on environmental protection

economy. and the eco-design of products.

Greece established a Green Fund in 2010, whose objective is to stimulate growth through protecting the

environment and providing support for environmentally SMEs and resource efficiency

friendly projects and initiatives. According to the Flash 426 Eurobarometer, the resource

Greece is performing below EU average in terms of efficiency actions undertaken by Greek SMEs allowed the resource productivity 6 (how efficiently the economy uses reduction of production costs for 65% of them.

material resources to produce wealth), with 1.35 EUR/kg The Flash Eurobarometer shows that 48% of the SMEs in

(EU average is 2) in 2015 7 . Figure 1 shows that Greece's Greece have one or more full time employee working in a green job 9 at least some of the time. Greece has an

5 European Commission, 2015. Proposed Circular Economy Package

6 Resource productivity is defined as the ratio between gross domestic product (GDP) and domestic material consumption (DMC). 8 Eurostat, Resource productivity , accessed October 2016

7 Eurostat, Resource productivity , accessed July 2016 9 The Flash 426 Eurobarometer "SMEs, resource efficiency and green

Greece 7

average number of 2.8 full time green employees per On the administrative side, it is an often repeated SME. complaint that Greece’s complex bureaucratic

stipulations (despite the progress achieved in the last

Eco-innovation years) dissuade if they do not prevent actors and investors from developing eco-innovations 11 . Moreover,

As illustrated in Figure 2, with a score of only 72 (on an the regulatory framework changes frequently, thus EU-28 average of 100), Greece ranks seventh from the limiting the ability of involved actors to plan and organise bottom in the EU-28 ranking of eco-innovative countries. investments.

Figure 2: Eco-Innovation Index 2015 (EU=100) 10 Finally, social barriers towards eco-innovation remain,

mostly related to public attitudes and ignorance of the benefits of innovation (especially in the area of energy

efficiency in the built environment) 12 .

In the past 2 years, efforts to introduce eco-innovations in the construction sector have continued. Due to the economic crisis, companies have sought to explore opportunities afforded by eco-innovation focusing (amongst others) on transparent solar cells which can be used in windows, nanotechnology products to improve indoor air quality and smart meters for energy efficiency. The size of the sector was reduced further due to the economic crisis and its share dropped from 7% of GDP in 2007 to 2.9% of GDP in 2014. As a result, the uptake of eco-innovation also decreased.

Greece also benefits from its significant natural capital in renewable energies – solar, wind, tidal – growth in green and alternative tourism and innovation in agriculture and the food industry.

Suggested action

• Incentivise the savings of energy and water and increase the level of recycling among SMEs.

• Facilitate the development of eco-innovation initiatives in the country, especially at the local level.

Waste management

Greece continues to lack a clear and cohesive framework

for the support of eco-innovation and eco-industries. Turning waste into a resource requires:

Nevertheless, the framework has improved through the − Full implementation of Union waste legislation,

2014 Action Plan for the Implementation of the National which includes the waste hierarchy; the need to Strategy for Research, Technological Development and ensure separate collection of waste; the landfill Innovation for the period 2015-2021, which promotes diversion targets etc. specific activities in relation to eco-innovation. − Reducing per capita waste generation and waste

generation in absolute terms.

The long-lasting deterioration of the economy has made − Limiting energy recovery to non-recyclable materials any kind of systematic funding for eco-innovation and phasing out landfilling of recyclable or unrealistic. Austerity policies have had a major impact on recoverable waste. public funding leading to stagnation in terms of R&D SDG 12 invites countries to substantially reduce waste expenses and delays in payments. generation through prevention, reduction, recycling and

reuse, by 2030.

markets" defines "green job" as a job that directly deals with information, technologies, or materials that preserves or restores environmental quality. This requires specialised skills, knowledge,

training, or experience (e.g. verifying compliance with environmental 11 Valavanidis A. et al., 2015, Atmospheric Pollution in Urban Areas of

legislation, monitoring resource efficiency within the company, Greece and Economic Crisis. Trends in air quality and atmospheric promoting and selling green products and services). pollution data, research and adverse health effects.

10 Eco-innovation Observatory : Eco-Innovation scoreboard 2015 12 Knight and Bell, 2013

Greece 8

The EU's approach to waste management is based on the meeting the packaging waste recycling target of 55%. As

"waste hierarchy" which sets out an order of priority shown in Figure 4, Greece has not yet reached the when shaping waste policy and managing waste at the recycling target. Only if it steps up its efforts significantly operational level: prevention, (preparing for) reuse, will it be able to up recycling rates to reach the 50%

recycling, recovery and, as the least preferred option, recycling target by 2020 16 .

disposal (which includes landfilling and incineration

without energy recovery). Figure 4: Recycling rate of municipal waste in 2007-13

17

The progress towards reaching recycling targets and the

adoption of adequate WMP/WPP 13 should be the key

items to measure the performance of Member States.

This section focuses on management of municipal

waste 14 , for which EU law sets mandatory recycling

targets.

The waste management situation in Greece is a major structural problem. As shown in Figure 3, municipal waste generation in Greece has remained at the same level over the past few years, being now (2013 figures) slightly over the EU average (510kg/y/inhabitant compared to EU average of around 477 kg). Greece landfills the majority of its municipal waste (81%, compared to 31% for EU-28 average), with only 16% being recycled (EU-28 – 27%) and 4% composted (EU-28

– 15%). A landfill tax has been in force since 1 January 2014.

Figure 3: Municipal waste by treatment in Greece 2007- However, its effective implementation remains unclear to

13 15 date. In addition, despite the major waste management

problems the country needs to address, only 5% of the landfill tax revenues are to be allocated for support to local authorities to improve their waste management performance, with the rest being devoted to the reimbursement of the public debt. The use of economic instruments is insufficient and the existing schemes are performing poorly.

Additional measures will be needed to promote the diversion of biodegradable waste from landfill and to establish and control separate collection infrastructure and schemes, specifically to implement door-to-door separate collection. There are limited Extended Producer Responsibility (EPR) schemes (few waste streams covered) or equivalent systems in place, not able to cover the full costs of separate collection and recycling of the main waste streams. No incentive systems exist to favour prevention and participation to separate collection (PAYT schemes) and no incentives are provided for local

Greece has failed to comply with the first (2010) landfill authorities to develop separate collection. Care must be diversion target. In addition, Greece decreased its taken not to move from landfilling to poor quality packaging waste recycling in 2013 (from 58.6% in 2012 to Mechanical and Biological Treatment installations.

52.4% in 2013). Therefore, the country is no longer Addressing the issue of illegal landfilling is a key priority,

as whilst illegal landfills remain open (or new ones are

13 Waste Management Plans/Waste Prevention Programmes

14 Municipal waste consists of waste collected by or on behalf of

municipal authorities, or directly by the private sector (business or 16 Member States may choose a different method than the one used by

private non-profit institutions) not on behalf of municipalities.

15 ESTAT (and referred to in this report) to calculate their recycling rates Eurostat,

and track compliance with the 2020 target of 50% recycling of

http://ec.europa.eu/eurostat/documents/2995521/7214320/ municipal waste.

8-22032016-AP-EN.pdf/eea3c8df-ce89-41e0-a958- 17 Eurostat, Recycling rate of municipal waste , accessed October 2016. 5cc7290825c3 . For Greece, 2014 data were not available.

Greece 9

being created), it is difficult to make an economic success Suggested action

of legal waste management operations and the jobs and

growth potential of the recycling sector cannot be • Address the issues of closure and rehabilitation of realised. The proper treatment of hazardous waste illegal landfills and of the treatment of hazardous

throughout the country is of equal importance. waste as matters of absolute priority. • Properly enforce and gradually increase landfill taxes to

As regards the EU structural and cohesion funds for the phase-out landfilling of recyclable and recoverable programming period 2014-2020, Greece has foreseen the waste. Use the revenues to support the separate allocation of significant amounts for waste management collection and alternative infrastructure in conjunction projects. However, as at the time of adoption of the with a better allocation of the cohesion policy funds to Operational Programmes the country had not fulfilled the the first steps of waste hierarchy. Avoid building relevant ex-ante conditionality (T0 6.2), it submitted an excessive infrastructure for the treatment of residual action plan and added a clause of self-suspension of waste. funds for waste management projects, until a new • Invest in separate collection, sorting and recycling national Waste Management Plan and a Waste (including composting) in the coming years, in order to Prevention Programme in line with the requirements of reach the 2020 recycling target.

the Waste Framework Directive were put in place. • Extend and improve the cost-effectiveness, monitoring

and transparency of existing EPR schemes and eliminate free-riding

• Complete missing Waste Management Plans in order to cover the whole territory.

The Waste Prevention Programme was adopted in 2014 and the National Waste Management Plan (not covering all waste streams) in December 2015. According to national legislation, the updating of Regional Waste

Management Plans in line with the national one is also obligatory – the 13 Regional Plans were expected to be ready by the end 2016 and some were adopted by that time.

Improving its waste management performance, preventing and reducing waste generation as well as increasing reuse and recycling rates will improve resource efficiency of the Greek economy, create jobs and provide business opportunities. Full implementation of the existing legislation could create more than 15,900 jobs in Greece and increase the annual turnover of the waste sector by EUR 1.675 million. Moving towards the targets of the Roadmap on resource efficiency which outlines how we can transform Europe's economy into a sustainable one by 2050, could create over 19,000 additional jobs and increase the annual turnover of the

waste sector by almost two million euros 18 .

18 Bio Intelligence service, 2011. Implementing EU Waste legislation for

Green Growth , study for European Commission. The breakdown per country on job creation was made by the consultant on Commission demand but was not included in the published document.

Greece 10

•

Protecting, conserving and enhancing natural capital

Nature and Biodiversity While the terrestrial part of the Greek Natura 2000

The EU Biodiversity Strategy aims to halt the loss of network is largely complete, the marine part still presents significant insufficiencies in terms of designation

biodiversity in the EU by 2020, restore ecosystems and both of SCIs and SPAs 21 (see Figure 5).

their services in so far as feasible, and step up efforts to

avert global biodiversity loss. The EU Birds and Habitats For 239 SCIs the 6-year deadline laid down by the

Directives aim at achieving favourable conservation Habitats Directive for designating them as Special Areas status of protected species and habitats. of Conservation (SACs) and establishing appropriate

SDG 14 requires countries to conserve and sustainably conservation objectives and measures has expired, but as use the oceans, seas and marine resources, while SDG 15 of April 2016, Greece had not fulfilled these obligations.

requires countries to protect, restore and promote the Figure 5: Sufficiency assessment of SCI networks in sustainable use of terrestrial ecosystems, sustainably Greece based on the situation until December 2013

manage forests, combat desertification, and halt and (%) 22

reverse land degradation and halt biodiversity loss.

The 1992 EU Habitats Directive and the 1979 Birds

Directive are the cornerstone of the European legislation aimed at the conservation of the EU's wildlife. Natura

2000, the largest coordinated network of protected areas in the world, is the key instrument to achieve and implement the Directives' objectives to ensure the longterm protection, conservation and survival of Europe's most valuable and threatened species and habitats and the ecosystems they underpin.

The adequate designation of protected sites as Special

Ares of Conservation (SAC) under the Habitats Directive and as Special Protection Areas (SPA) under the Birds

Directive is a key milestone towards meeting the objectives of the Directives. The results of Habitats

Directive Article 17 and Birds Directive Article 12 reports and the progress towards adequate Sites of Community

Importance (SCI)-SPA and SAC designation 19 both in land

and at sea, should be the key items to measure the

performance of Member States. SPAs benefit from horizontal protection measures under

national legislation, but a number of key implementing

27.9% of the national land area of Greece is covered by acts necessary to enact legal provisions are still missing.

Natura 2000 (EU average 18.1%), with Birds Directive

SPAs covering 20.94% (EU average 12.3%) and Habitats Greece has adopted a sound and comprehensive law on

Directive SCIs covering 16.21% (EU average 13.8%) 20 . biodiversity

23 and a national biodiversity strategy 24 based

Greece has so far designated 419 Natura 2000 sites, thereon. Neither is significantly implemented. including 241 SCIs under the Habitats Directive and 202 Management plans and other site protection tools (legal SPAs under the Birds Directive. acts, management bodies) have been developed for a

number of sites, in most cases through LIFE or European Regional Development Fund (ERDF) financing. However,

19 Sites of Community Importance (SCIs) are designated pursuant to the

Habitats Directive whereas Special Areas of Protection (SPAs) are

designated pursuant to the Birds Directive; figures of coverage do 21 For each Member State, the Commission assesses whether the species

not add up due to the fact that some SCIs and SPAs overlap. Special and habitat types on Annexes I and II of the Habitats Directive, are Areas of Conservation (SACs) means a SCI designated by the Member sufficiently represented by the sites designated to date. This is States. expressed as a percentage of species and habitats for which further

20 Sites of Community Importance (SCIs) are designated pursuant to the areas need to be designated in order to complete the network in that

Habitats Directive whereas Special Areas of Protection (SPAs) are country. The current data , which were assessed in 2014-2015, reflect designated pursuant to the Birds Directive; figures do not add up due the situation up until December 2013.

to the fact that some sites are designated as both SCIs and SPAs. 22 European Commission, internal assessment. Special Areas of Conservation (SACs) means a SCI designated by the 23 Law 3937/2011 Member States. 24 Ministerial Decision 40332/2014

Greece 11

few are actually being implemented in a coordinated and policies and to enforce legal provisions, are also stable way. acknowledged as major obstacles to achieving the

According to the latest report 25 of Greece on the objectives of the Nature Directives.

conservation status of habitats and species covered by These deficiencies are illustrated by the high number of

the Habitats Directive 26 , only 60% of the assessments for complaints and infringement cases on issues such as the

Mediterranean habitat types and 13% for species degradation of designated sites, poor quality of indicate a favourable conservation status, while for 65% Appropriate Assessments under Article 6(3) of the of the species and 20% of marine habitats the status is Habitats Directive, lack of strategic assessments and

unknown 27 . This is depicted in Figure 6. insufficient protection of species and habitats, also as a

Figure 6: Conservation status of habitats and species in result of illegal activities.

Greece in 2006 (%) 28

The main causes of loss of biodiversity in Greece are related to past and current policies concerning unsustainable land use, agriculture, fisheries, forest use, transport, tourism and production and consumption patterns.

In 2014 Greece adopted its National Biodiversity Strategy, which officially refers to ecosystem services. The project "Towards a Natural Capital Accounting" was officially approved. The Hellenic Ecosystem Services Partnership (researchers, Civil Society Organisations,

A major obstacle to the effective protection and decision makers and professionals dedicated to the management of the Natura 2000 sites as a whole is the research into and application of Ecosystem Services

29 in

lack of a national system for the comprehensive the Greek part of the Mediterranean Basin) is involved in administration and functioning of protected areas this project.

(including strategy, structure, management schemes, Suggested action

responsibilities, financing, enforcement, monitoring). • Complete site designations, especially in the marine

The lack of awareness (among authorities, stakeholders, part, and put in place clearly defined conservation public) about Natura 2000 and its benefits, coupled with objectives and measures for the sites that are a lack of incentives for investments promoting those adequately resourced. Strengthen communication with benefits, as well as the poor capacity to support stakeholders. sustainable land management and integration with other • Establish a stable and efficient national system for the

administration and functioning of protected areas that 25 The core of the ‘Article 17’ report is the assessment of conservation can also recognise and harness the full economic

status of the habitats and species targeted by the Habitats Directive.

26 potential of healthy ecosystem services. Due to the overdue submission of the Greek Art. 17 report for the

period 2007-2012, data are drawn from the 2001-2006 report. • Build capacity of competent authorities (central,

27 Conservation status is assessed using a standard methodology as regional, site management bodies) for implementing being either ‘favourable’, ‘unfavourable-inadequate’ and Management Plans, increasing awareness about

‘unfavourable-bad’, based on four parameters as defined in Article 1

of the Habitats Directive. Natura 2000 and incentives for investments promoting

28 These figures show the percentage of biogeographical assessments in

each category of conservation status for habitats and species, respectively. The information is based on Article 17 of the Habitats 29 Ecosystem services are benefits provided by nature such as food, Directive reporting - national summary of Greece clean water and pollination on which human society depends.

Greece 12

its benefits, and tackling illegal activities affecting of food, fibre and biomass for renewable energy, carbon

wildlife through enhanced enforcement, both within sequestration, water purification and flood regulation,

and outside Natura 2000 areas. the provision of raw and building material. Soil is a finite

• Improve the overall quality of Appropriate Assessments and extremely fragile resource. Land taken by urban

at plan and project level. development and infrastructure is highly unlikely to be

• Secure efficient use of available ERDF and European reverted to its natural state; it consumes mostly

Agricultural Fund for Rural Development (EAFRD) funds agricultural land and increases fragmentation of habitats.

for nature conservation, based on the Prioritised Action Soil protection is not subject to a comprehensive and

Framework (PAF). Greece can also capitalise on its rich coherent set of rules in the EU. Existing EU policies in

natural capital to create sustainable jobs and income, areas such as agriculture, water, waste, chemicals, and

notably in tourism. prevention of industrial pollution however contribute to

• Engage and provide government support to the the protection of soils but the continuous degradation of

mapping and assessment of ecosystems and their soil suggests that it is insufficiently protected.

services, valuation and development of natural capital

accounting systems. Figure 7 shows the different land cover types in Greece in 2012.

Figure 7: Land Cover types in Greece 2012 31

Green Infrastructure

The EU strategy on green infrastructure 30 promotes the

incorporation of green infrastructure into related plans and programmes to help overcome fragmentation of habitats and preserve or restore ecological connectivity, enhance ecosystem resilience and thereby ensure the continued provision of ecosystem services.

Green Infrastructure provides ecological, economic and social benefits through natural solutions. It helps to understand the value of the benefits that nature provides to human society and to mobilise investments to sustain and enhance them.

In Greece, restoration and rehabilitation of degraded habitats and species has been carried out within some protected areas, e.g. the restoration of Lake Carla, of a burned fir forest in Parnitha National Park and of Grecian

Juniper Woods in Prespa National Park.

Soil protection

The EU Soil Thematic Strategy highlights the need to ensure a sustainable use of soils. This requires the prevention of further soil degradation and the preservation of its functions, as well as the restoration of degraded soils. The 2011 Road Map for Resource

Efficient Europe, part of Europe 2020 Strategy provides Artificial land cover is used for settlements, production that by 2020, EU policies take into account their direct systems and infrastructure. It may itself be split between and indirect impact on land use in the EU and globally, built-up areas (buildings) and non-built-up areas (such as and the rate of land take is on track with an aim to linear transport networks and associated areas). The achieve no net land take by 2050. percentage of built up land in Greece in 2009 was 1.35%, SDG 15 requires countries to combat desertification, well below the EU-average (3.23%)

32 .

restore degraded land and soil, including land affected by The annual land take rate (growth of artificial areas) as desertification, drought and floods, and strive to achieve provided by CORINE Land Cover was 0.7% in Greece over a land-degradation-neutral world by 2030. the period 2006-12, well above the EU average (0.41%). It

Soil is an important resource for life and the economy. It provides key ecosystem services including the provision

31 European Environment Agency, Land cover 2012 and changes country

analysis [publication forthcoming] 30 European Union, Green Infrastructure — Enhancing Europe’s Natural 32 European Environment Agency, 2016. Imperviousness and

Capital, COM/2013/0249 imperviousness change

Greece 13

represented 2657 hectares per year 33 . introduction of invasive alien species presents an

The soil water erosion rate in 2010 was 4.13 tonnes per important threat in the Mediterranean Sea Region with

hectare per year, above EU-28 average (2.46 tonnes) 34 . the number of invasive alien species increasing significantly since 1970. Finally, the unique biodiversity of

There are still no EU-wide datasets enabling the provision the Mediterranean Sea Region is also threatened by of benchmark indicators for soil organic matter decline, pollution from land-based sources, such as discharges of contaminated sites, pressures on soil biology and diffuse excess nutrients and hazardous substances, marine litter, pollution. An updated inventory and assessment of soil over-fishing, and degradation of critical habitats. protection policy instruments in Greece and other EU

Member States is being performed by the EU Expert With regard to the specificities of the implementation of

Group on Soil Protection. the MSFD, there is a lack of clarity in what constitutes GES, as there is no systematic use of the 2010

Commission's Decision criteria and indicators and in most

Marine protection cases no threshold values and baselines are provided. Thus, the criteria for GES were not considered as

The EU Coastal and Marine Policy and legislation require measurable 37 .

that by 2020 the impact of pressures on marine waters is

reduced to achieve or maintain good environmental It is therefore too early to say whether Greek waters are status and coastal zones are managed sustainably. in good status.

SDG 14 requires countries to conserve and sustainably Greece has not yet reported on its monitoring use the oceans, seas and marine resources for programme under the MSFD, therefore no assessment

sustainable development. has been carried out, contrary to other Member States, for which the Commission provided guidance in its report

The Marine Strategy Framework Directive (MSFD) 35 aims assessing monitoring programmes under the MSFD 38 .

to achieve Good Environmental Status (GES) of the EU's

marine waters by 2020 by providing an ecosystem In 2012, Greek marine protected areas covered 7,413.5 approach to the management of human activities with square kilometres of its marine waters, with 2,521.6 impact on the marine environment. The Directive square kilometres in the Ionian and Central requires Member States to develop and implement a Mediterranean Sea, 74.1 square kilometres in the marine strategy for their marine waters, and cooperate Adriatic Sea and 4,817.8 square kilometres in the Aegean with Member States sharing the same marine region or and Levantine Sea

39 .

subregion. Suggested action

As part of their marine strategies, Member States had to • Continue work to improve the definitions of GES, make an initial assessment of their marine waters, including through regional cooperation by using the

determine GES 36 and establish environmental targets by work of the relevant Regional Sea Convention with the

July 2012. They also had to establish monitoring aim to make GES measurable. programmes for the on-going assessment of their marine • Urgently report and implement the national waters by July 2014. The next element of their marine programme of measures 40 . strategy is to establish a Programme of Measures (2016). • Finalise, implement and report to the Commission the The Commission assesses whether these elements monitoring programme of Greek marine waters as constitute an appropriate framework to meet the soon as possible. requirements of the MSFD. • Further develop approaches assessing (and

The Mediterranean Sea region has been identified by the quantifying) impacts from the main pressures in order

EEA in its 2015 State of the Environment report as one of to lead to improved and more conclusive assessment the main climate change hotspots (i.e. one of the areas results for 2018 reporting.

most responsive to climate change) due to water scarcity, concentration of economic activities in coastal areas, and 37 Commission Staff Working Document Accompanying the Commission reliance on climate-sensitive agriculture. The Report on "The first phase of implementation of the Marine Strategy

Framework Directive (2008/56/EC) - The European Commission's assessment and guidance" ( SWD(21014) 049 final and

33 European Environment Agency Draft results of CORINE Land Cover COM(2014)097 final )

(CLC) inventory 2012 ; mean annual land take 2006-12 as a % of 2006 38 Report from the Commission assessing Member States' monitoring

artificial land. programmes under the Marine Strategy Framework Directive

34 Eurostat, Soil water erosion rate , accessed June 2016 (COM(2017)3 i) and its accompanying Staff Working Document

35 European Union, Marine Strategy Framework Directive 2008/56/EC (SWD(2017)1 final).

36 The MSFD defines Good Environmental Status (GES) in Article 3 as: 39 2012 Data provided by the European Environmental Agency – Not

“The environmental status of marine waters where these provide published ecologically diverse and dynamic oceans and seas which are clean, 40 As of 7.10.2016, Greece had not yet reported its programme of healthy and productive” measures to the Commission

Greece 14

• 3. 

  Ensuring citizens' health and quality of life

  (-53%) ensure air emissions for these pollutants are

Air quality within the currently applicable national emission ceilings 43 .

The EU Clean Air Policy and legislation require that air At the same time, air quality in Greece continues to give

quality in the Union is significantly improved, moving

closer to the WHO recommended levels. Air pollution cause for concern. For the year 2013, the European

and its impacts on ecosystems and biodiversity should be Environment Agency estimated that about 13,730 premature deaths were attributable to fine particulate

further reduced with the long-term aim of not exceeding 44

critical loads and levels. This requires strengthening matter concentrations, more than 840 to ozone

45

efforts to reach full compliance with Union air quality concentrations and 1,490 to nitrogen dioxide

46

concentrations. 47 This is also due to exceedances above

legislation and defining strategic targets and actions the EU air quality standards, such as shown in Figure 8 48 .

beyond 2020.

For 2014, exceedances above the EU air quality standards

The EU has developed a comprehensive suite of air were registered for nitrogen dioxide (NO 2 ) and particulate matter (PM

quality legislation 41 , which establishes health-based 10

) in one air quality zone each

Figure 8: Attainment situation for PM10, NO2 and O3 in 2014

standards and objectives for a number of air pollutants. 43

As part of this, Member States are also required to The current national emission ceilings apply since 2010 ( Directive 2001/81/EC ); revised ceilings for 2020 and 2030 have been set by

ensure that up-to-date information on ambient Directive (EU) 2016/2284 on the reduction of national emissions of concentrations of different air pollutants is routinely certain atmospheric pollutants, amending Directive 2003/35/EC i and

made available to the public. In addition, the National repealing Directive 2001/81/EC i. 44

Emission Ceilings Directive provides for emission Particulate matter (PM) is a mixture of aerosol particles (solid and liquid) covering a wide range of sizes and chemical compositions.

reductions at national level that should be achieved for PM10 (PM2.5) refers to particles with a diameter of 10 (2.5) main pollutants. micrometres or less. PM is emitted from many anthropogenic

sources, including both combustion and non-combustion sources.

The emission of several air pollutants has decreased 45 Low level ozone is produced by photochemical action on pollution

significantly in Greece 42 . Reductions between 1990 and and it is also a greenhouse gas. 46

2014 for sulphur oxides (-71%), nitrogen oxides (-24%), NOx is emitted during fuel combustion e.g. from industrial facilities and the road transport sector. NOx is a group of gases comprising

ammonia (-28%) as well as volatile organic compounds nitrogen monoxide (NO) and nitrogen dioxide (NO2).

47 European Environment Agency, 2016. Air Quality in Europe – 2016 Report . (Table 10.2, please see details in this report as regards the

41 European Commission, 2016. Air Quality Standards underpinning methodology)

42 See EIONET Central Data Repository and Air pollutant emissions data 48 Based on European Environment Agency, 2016. Air Quality in Europe viewer (NEC Directive) – 2016 Report. (Figures 4.1, 5.1 and 6.1)

Greece 15

(Athens and Thessaloniki, respectively). Furthermore, in requirements, including assessing the exposure to several air quality zones the target values and long-term environmental noise through noise mapping, ensuring objectives regarding ozone concentrations are not being that information on environmental noise and its effects is

met. 49 made available to the public, and adopting action plans

The persistent breaches of air quality requirements (for with a view to preventing and reducing environmental

PM noise where necessary and to preserving the acoustic 10 ), which have severe negative effects on health and environment, are being followed up by the European environment quality where it is good.

Commission through infringement procedures covering The implementation of the Environmental Noise

all the Member States concerned, including Greece. The Directive 53 in Greece is delayed. Due to the

aim is that adequate measures are put in place to bring implementation method adopted, an in-depth analysis is all zones into compliance. not possible at the moment.

It is estimated that the health-related external costs of Suggested action

air pollution in Greece are above EUR 7 billion/year

(income adjusted, 2010), which include not only the • Complete noise mapping and action plans for noise intrinsic value of living a full, healthy life, but also direct management.

costs to the economy. These direct economic costs relate

to 3 million workdays lost each year due to sickness Water quality and management

related to air pollution, with associated costs for

employers of EUR 396 million/year (income adjusted, The EU water policy and legislation require that the

2010), for healthcare of above EUR 27 million/year impact of pressures on transitional, coastal and fresh

(income adjusted, 2010), and for agriculture (crop losses) waters (including surface and ground waters) is of EUR 108 million/year (2010) 50 . significantly reduced to achieve, maintain or enhance

good status of water bodies, as defined by the Water

Suggested action Framework Directive; that citizens throughout the Union

• Maintain downward emissions trends of air pollutants benefit from high standards for safe drinking and bathing in order to achieve full compliance with air quality limit water; and that the nutrient cycle (nitrogen and values - and reduce adverse air pollution impacts on phosphorus) is managed in a more sustainable and health, environment and economy. resource-efficient way.

• Reduce nitrogen oxide (NOx) emissions to comply with SDG 6 encourages countries to ensure availability and currently applicable national emission ceilings 51 and/or sustainable management of water and sanitation for all. to reduce nitrogen dioxide (NO2) (and ozone The main overall objective of EU water policy and concentrations), inter alia, by reducing transport legislation is to ensure access to good quality water in related emissions - in particular in urban areas. sufficient quantity for all Europeans. The EU water • Reduce PM10 emission and concentration, inter alia, acquis

54 seeks to ensure good status of all water bodies

by reducing emissions related to energy and heat across Europe by addressing pollution sources (from e.g.

generation using solid fuels, to transport and to agriculture, urban areas and industrial activities), physical

agriculture. and hydrological modifications to water bodies) and the management of risks of flooding.

Noise River Basin Management Plans (RBMPs) are a

The Environmental Noise Directive provides for a requirement of the Water Framework Directive and a common approach for the avoidance, prevention and means of achieving the protection, improvement and reduction of harmful effects due to exposure to sustainable use of the water environment across Europe. environmental noise. This includes surface freshwaters such as lakes and rivers, Excessive noise is one of the main causes of health groundwater, estuaries and coastal waters up to one

issues 52 . To alleviate this, the EU acquis sets out several

World Health Organization, Regional Office for Europe , Copenhagen, Denmark

49 See The EEA/Eionet Air Quality Portal and the related Central Data 53 The Noise Directive requires Member States to prepare and publish,

Repository every 5 years, noise maps and noise management action plans for

50 These figures are based on the Impact Assessment for the European agglomerations with more than 100,000 inhabitants, and for major

Commission Integrated Clean Air Package (2013) roads, railways and airports.

51 Under the provisions of the revised National Emission Ceilings 54 This includes the Bathing Waters Directive (2006/7/EC); the Urban

Directive, Member States now may apply for emission inventory Waste Water Treatment Directive (91/271/EEC) concerning adjustments. Pending evaluation of any adjustment application, discharges of municipal and some industrial waste waters; the Member States should keep emissions under close control with a Drinking Water Directive (98/83/EC) concerning potable water view to further reductions. quality; the Water Framework Directive (2000/60/EC) concerning

52 WHO/JRC, 2011, Burden of disease from environmental noise, water resources management; the Nitrates Directive (91/676/EEC)

Fritschi, L., Brown, A.L., Kim, R., Schwela, D., Kephalopoulos, S. (eds), and the Floods Directive (2007/60/EC)

Greece 16

nautical mile. The nitrate vulnerable zone designation has been

In its first generation of RBMPs Greece reported the improved, but Greece still needs to improve the status of 1142 rivers, 48 lakes, 43 transitional, 133 coastal measures implementing the Nitrates Directive and and 366 groundwater bodies. 49% of natural surface establish proper action programmes for all nitrate water bodies achieve a good or high ecological status 55 vulnerable zones (existing and new ones)

(while the status of 21% is unknown) and only 6% of As regards drinking water, Greece reaches very high heavily modified or artificial water bodies achieve a good compliance rates of 99-100% for microbiological, or high ecological potential (43% unknown). Only 44% of chemical and indicator parameters laid down in the

surface water bodies (51% unknown), 13% of heavily Drinking Water Directive 60 .

modified and artificial water bodies (60% unknown) and

85% of groundwater bodies achieve good chemical As shown in Figure 9, in Greece in 2015 out of 1542 status 56 . 83% of groundwater bodies are in good bathing waters, 97.2% were of excellent quality and 0.6%

quantitative status 57 . of good quality, while it was not possible to assess the remaining 34 bathing waters.

The main pressure on the Greek surface waters is diffuse

pollution 58 , which affects 63% of water bodies. Point Figure 9: Bathing water quality 2012 – 2015

61

sources of pollution affect 44% of water bodies and abstraction 6%. There are significant regional differences, e.g. diffuse sources of pollution affect all water bodies in the Northern and Western Peloponnese river basin district but only 15% in the Western Macedonia river basin district.

The Greek RBMPs have some deficiencies that result in uncertainties about the status and effectiveness of

Programmes of Measures (PoMs). In particular there are weaknesses in monitoring, methodologies for status assessment and the link between pressures and PoMs.

The planned measures are expected to result in the improvement of the ecological and chemical status of surface water bodies by 11% and 3% respectively. The measures should also bring about the improvement of ecological potential of artificial and heavily modified

water bodies 59 by 8% and of chemical status by 3%. With a total generated load of 12.3 million population

The adoption of the second generation of all (14) Greek equivalents (p.e.) and 492 agglomerations above 2000

RBMPs, which was expected in December 2015, has been p.e., Greece demonstrates high general compliance rates significantly delayed. with the Urban Waste Water Treatment Directive: 100%

Greek legislation related to nitrates is obsolete and there for collection (Article 3), albeit with large part of its are currently two infringement procedures open agglomerations served by individual systems, and 96.4% concerning the Nitrates Directive: one concerning the for secondary treatment of waste water (Article 4). need to designate further nitrate vulnerable zones and to However, some areas have been very slow to comply, establish proper action programmes for these new zones resulting in advanced legal action.

and one concerning the non-adequacy of the action 99.6% of the waste water load collected is subject to programmes for the existing nitrate vulnerable zones. more stringent treatment in accordance with Article 5 of

the Urban Waste Water Treatment Directive. It should be

55 Good ecological status is defined in the Water Framework Directive, noted that 23% of the Greek territory is considered as

referring to the quality of the biological community, the hydrological sensitive, i.e. more stringent treatment is applicable only

characteristics and the chemical characteristics. there and in the agglomerations whose size is above

56 Good chemical status is defined in the Water Framework Directive

referring to compliance with all the quality standards established for 10,000 p.e. However, 16% of the above-mentioned total

chemical substances at European level. p.e. is addressed via individual or other systems, whose

57 For groundwater, a precautionary approach has been taken that appropriateness to protect the environment might be

comprises a prohibition on direct discharges to groundwater, and a requirement to monitor groundwater bodies.

58 Diffuse pollution comes from widespread activities with no one 60 Commission's Synthesis Report on the Quality of Drinking Water in discrete source. the Union examining Member States' reports for the 2011-2013

59 Many European river basins and waters have been altered by human period, foreseen under Article 13(5) of Directive 98/83/EC i;

activities, such as land drainage, flood protection and building of COM(2016)666 i

dams to create reservoirs. 61 European Environment Agency, State of bathing water , 2016

Greece 17

questionable 62 . environment poses particular challenges for the

Management and prevention of floods is an area where environment and human health, whilst also providing potentially more economical nature-based solutions opportunities and efficiency gains in the use of resources.

could improve resource efficiency through reducing costs and delivering multiple benefits. Over the last decade

Greece has claimed damages to the EU Solidarity Fund for one major and three regional floods, which caused damages of over EUR 3 billion. The total EU aid granted amounts to EUR 112.7 million.

The absence of flood risk and flood hazard maps in

Greece is the subject of an infringement procedure initiated in 2015.

Suggested action

• Improve water policy in line with the intervention logic

of the Water Framework Directive 63 , i.e. update as

soon as possible the first RBMPs, do a more detailed The Member States, European institutions, cities and

assessment of pressures to improve monitoring in stakeholders have prepared a new Urban Agenda for the EU (incorporating the Smart Cities initiative) to tackle

order to know the status of water bodies and design

effective PoMs that address all the main pressures these issues in a comprehensive way, including their

identified. Improve assessment methods to provide connections with social and economic challenges. At the heart of this Urban Agenda will be the development of

more certainty about the water status. twelve partnerships on the identified urban challenges,

• Cover all identified pressures and implementation gaps including air quality and housing 65 .

in PoMs and ensure adequate funding.

• Assess new physical modifications of water bodies in The European Commission will launch a new EU line with article 4(7) of the Water Framework Directive. benchmark system in 2017

66 .

In these assessments alternative options and adequate The EU stimulates green cities through awards and

mitigation measures have to be considered. funding, such as the EU Green Capital Award aimed at

• Move forward quickly with the preparation of new cities with more than 100,000 inhabitants and the EU

Action Programmes fully compliant with the provisions Green Leaf initiative aimed at cities and towns, with

of the Nitrates Directive. between 20,000 and 100,000 inhabitants.

• Complete implementation of the Urban Waste Water

Treatment Directive, giving priority to those

agglomerations that are subject to an infringement International agreements

case. The EU Treaties require that the Union policy on the

Enhancing the sustainability of cities environment promotes measures at the international level to deal with regional or worldwide environmental

The EU Policy on the urban environment encourages problems.

cities to implement policies for sustainable urban Most environmental problems have a transboundary planning and design, including innovative approaches for nature and often a global scope and they can only be urban public transport and mobility, sustainable addressed effectively through international co-operation. buildings, energy efficiency and urban biodiversity International environmental agreements concluded by conservation. the Union are binding upon the institutions of the Union

SDG11 aims at making cities and human settlements and on its Member States. This requires the EU and the

inclusive, safe, resilient and sustainable. Member States to sign, ratify and effectively implement all relevant multilateral environmental agreements

Europe is a Union of cities and towns; around 75% of the (MEAs) in a timely manner. This will also be an important

EU population are living in urban areas 64 . The urban contribution towards the achievement of the SDGs,

62 European Commission, Eighth Report on the Implementation Status 65 http://urbanagendaforthe.eu/ and the Programmes for Implementation of the Urban Waste Water 66 The Commission is developing an Urban Benchmarking and Directive (COM (2016)105 final) and Commission Staff Working Monitoring ('UBaM') tool to be launched in 2017. Best practices Document accompanying the report (SWD (2016)45 final ). emerge and these will be better disseminated via the app featuring

63 The full set of recommendations in relation to the WFD are here the UBaM tool, and increasingly via e.g. EUROCITIES, ICLEI, CEMR,

64 European Environment Agency, Urban environment Committee of the Regions, Covenant of Mayors and others.

Greece 18

which Member States committed to in 2015 and include many commitments contained already in legally binding agreements.

The fact that some Member States did not sign and/or ratify a number of MEAs compromises environmental implementation, including within the Union, as well as the Union’s credibility in related negotiations and international meetings where supporting the participation of third countries to such agreements is an established EU policy objective. In agreements where voting takes place it has a direct impact on the number of votes to be cast by the EU.

Currently, Greece has signed but not yet ratified the

Offshore Protocol of the Barcelona Convention, the

Protocol concerning Specially Protected Areas and

Biological Diversity in the Mediterranean, the Protocol on

Integrated Coastal Zone Management, three agreements under the Convention on Long-range Transboundary Air

Pollution (the Gothenburg Protocol to Abate

Acidification, Eutrophication and Ground-level Ozone, the Persistent Organic Pollutants Protocol and the Heavy

Metals Protocol), the Kiev Protocol on Pollutant Release and Transfer Registers, the African-Eurasian Migratory

Waterbird Agreement, the Protocol on Strategic

Environmental Assessment to the Espoo Convention, and

the Nagoya Protocol 67 .

Suggested action

• Increase efforts to be party to relevant multilateral environmental agreements, by signing and ratifying the remaining ones.

67 Protocol on Access to Genetic Resources and the Fair and Equitable

Sharing of Benefits Arising from their Utilization to the Convention on Biological Diversity.

Greece 19

Part II: Enabling Framework: Implementation Tools

• 4. 

  Market based instruments and investment

Green taxation and environmentally harmful abstraction tax. This accounts for EUR 0.96 billion in 2030

subsidies (real 2015 terms), equivalent to 0.35% of GDP.

The Circular Economy Action Plan encourages the use of

financial incentives and economic instruments, such as Figure 10: Environmental tax revenues as a share of total taxation to ensure that product prices better reflect revenues from taxes and social contributions (excluding environmental costs. The phasing out of environmentally imputed social contributions) in 2014 71

harmful subsidies is monitored in the context of the

European Semester and in national reform programmes submitted by Member States.

Taxing pollution and resource use can generate increased revenue and bring important social and environmental benefits.

Revenues from environment-related taxes reached 3.68% of GDP in 2014 in Greece against an EU average of 2.46%.

This percentage share is up from 3.55% in the preceding year. Energy taxes amounted to 2.94% of GDP,

significantly above the EU average of 1.88% 68 . In the

same year environmental tax revenues accounted for

10.24% of total revenues from taxes (excluding socialsecurity contributions) (EU-28 average: 6.35%) as shown in Figure 10.

A 2016 study suggests that there is considerable potential for shifting taxes from labour to environmental

taxes 69 . Under a good practice scenario 70 these could

generate an additional EUR 1.41 billion in 2018, rising to

EUR 3.01 billion in 2030 (both in real 2015 terms). This is equivalent to an additional 0.72% and 1.09% of GDP in

2018 and 2030, respectively. The largest potential source of revenue would come from the proposed amendments to taxes on transport fuels: currently Greece taxes diesel fuel much lower than petrol, which is not justified by the level of environmental impacts those fuels have. The increase could account for EUR 1.12 billion in 2030 (real

2015 terms), equivalent to 0.4% of GDP. The next largest contribution could come from the introduction of a water

Greece provides a full refund of excise duty paid on fuels 68 Eurostat, Environmental tax revenues, accessed June 2016 used for domestic shipping purposes. As of 1 April 2012, 69 Eunomia Research and Consulting, IEEP, Aarhus University, ENT, it has been providing a partial refund of excise duty paid

2016. Study on Assessing the Environmental Fiscal Reform Potential

for the EU28. N.B. National governments are responsible for setting on diesel used in agriculture. The excise duty paid on

tax rates within the EU Single Market rules and this report is not diesel used for industrial or commercial purposes is also

suggesting concrete changes as to the level of environmental reduced. Tax exemptions and reductions exist for coal

taxation. It merely presents the findings of the 2016 study by and coke used exclusively for electricity generation. In

Eunomia et al on the potential benefits various environmental taxes

could bring. It is then for the national authorities to assess this study addition, electricity used in agriculture is exempt from

and their concrete impacts in the national context. A first step in this excise tax

72 . Such subsidies go against the climate and

respect, already done by a number of Member States, is to set up expert groups to assess these and make specific proposals.

70 The good practice scenario means benchmarking to a successful 71 Eurostat, Environmental tax revenues , accessed October 2016

taxation practice in another Member State. 72 OECD, 2013. “Foreword”, in Taxing Energy Use: A Graphical Analysis, OECD Publishing.

Greece 20

energy policy objectives; removing them would be implementation and spread of best practice. beneficial both for the environment and the budgetary

debt reduction. For the 2014-2020 programming period Greece has adopted 20 operational programmes (OPs). In particular,

Green Public Procurement 13 Regional multi-fund Programmes (ERDF & ESF) and 7

The EU green public procurement policies encourage

Member States to take further steps to reach the target national sector-specific programmes, namely one for of applying green procurement criteria to at least 50% of Competitiveness, Entrepreneurship and Innovation (ERDF public tenders. & ESF), one for Transport Infrastructures, Environment & Green Public Procurement (GPP) is a process whereby Sustainable Development (ERDF & CF), one for Reform of public authorities seek to procure goods, services and Public Sector (ERDF & ESF), one for Human Resources, works with a reduced environmental impact throughout Education and Lifelong Learning (ESF), one for Technical their life-cycle when compared to goods, services and Assistance (ERDF, ESF & CF), one for the European works with the same primary function that would Agricultural Fund for Rural Development (EAFRD) and otherwise be procured. one for the European Maritime and Fisheries Fund The purchasing power of public procurement equals to (EMFF) are foreseen.

approximately 14% of GDP 73 . A substantial part of this In the new period the total amount that Greece will money is spent on sectors with high environmental receive is EUR20.6 billion (EC contribution).

impact such as construction or transport, so GPP can help

to significantly lower the impact of public spending and The biggest share – EUR 8.1 billion (40.1%) of funding is foster sustainable innovative businesses. coming from the European Fund for Regional

Development (ERDF). Currently there is no National Action Plan (NAP) or

National Strategy on GPP in Greece. Legislation is under EUR 4.7 billion (23.1%) – from the European Agricultural preparation, stipulating the development of a GPP NAP. 74 Fund for Rural Development (EAFRD).

According to a 2010 study, the share of Greek authorities EUR 3.6 billion (18.1%) - from the European Social Fund that included GPP requirements in between 50% and (ESF).

100% of their contracts is estimated between 10 and EUR 3.2 billion (15.9%) - from the Cohesion Fund (CF).

20% 75 .

EUR 388.7 million (1.9%) from the European Maritime and Fisheries Fund (EMFF).

Investments: the contribution of EU funds In total, EUR 4.2 billion is dedicated to Thematic objective

European Structural and Investment Funds Regulations (TO) 6 Environment Protection and Resource efficiency, provide that Member States promote environment and EUR 1.73 billion through the CF, EUR 1.39 billion through climate objectives in their funding strategies and the EAFRD programme, EUR 1 billion through the ERDF programmes for economic, social and territorial programme and EUR 136 million through the EMFF. In cohesion, rural development and maritime policy, and addition, EUR 2.1 billion is foreseen for TO4 Low Carbon reinforce the capacity of implementing bodies to deliver Economy (ERDF, CF, EAFRD and EMFF) and EUR 1.2 billion cost-effective and sustainable investments in these areas. for TO5 Climate Change Adoption and Risk Prevention Making good use of the European Structural and (EAFRD, ERDF and CF) (see Figure 11).

Investment Funds (ESIF) 76 is essential to achieve the Greece is a major user of the European Investment

environmental goals and integrate these into other policy Portal. This may help to attract investment into Greek areas. Other instruments such as the Horizon 2020, the environmental projects.

LIFE programme and the EFSI 77 may also support Figure 11 depicts the 2014-2020 EU Structural and

Investment Funds budget allocation for Greece.

73 European Commission, 2015. Public procurement

74 European Commission, 2015. Documentation on National GPP Action

Plans

75 Adelphi et al. 2011. Strategic Use of Public Procurement in Europe ,

Study for the European Commission 76 ESIF comprises five funds – the European Regional Development

Funds (ERDF), the Cohesion Fund (CF), the European Social Fund (ESF), the European Agricultural Fund for Rural Development (EAFRD), and the European Maritime and Fisheries Fund (EMFF). The ERDF, the CF and the ESF together form the Cohesion Policy funds.

77 European Investment Bank, 2016 European Fund for Strategic

Investments

Greece 21

For the first pillar, the national direct payment envelope

Figure 11: European Structural and Investment Funds is EUR185bn/year, for which 30% is allocated to greening.

2014-2020: Budget Greece by theme, EUR billion 78 Given the prevalence of small farms and permanent crops in Greece, the impact of greening is reduced.

It is too early to draw conclusions as regards the use and results of ESIF for the period 2014-2020, as the relevant programmes are still at an early stage of their implementation. As for the 2007-2013 period, data suggest that the total use of ERDF and CF as of September 2016 is 99.5% for all investment categories,

including the environmental sector 80 .

One good practice example is the Environmental

Network, a network of national and regional environmental and managing authorities ensuring

integration through the ESIF activities 79 .

With regard to the integration of environmental concerns into the Common Agricultural Policy (CAP), the two key areas for Greece (as for all Member States) are, firstly, using Rural Development funds to pay for environmental land management and other environmental measures, while avoiding financing measures which could damage the environment; and secondly, ensuring the effective implementation of the first pillar of the CAP with regard to cross-compliance and first pillar 'greening'.

With regard to the Rural Development second pillar, the total EAFRD budget for Greece is EUR354m, of which 7.5% is allocated to the agri-environment-climate measure. Many of the Greek environmental measures remain near the baseline, lacking environmental ambition. Poor coverage by Natura 2000 management plans puts biodiversity at risk, and this should have been given more focus. The situation with regard to irrigation and water management also needs to be kept up to date with the implementation of the Water Framework Directive.

78 European Commission, European Structural and Investment Funds

Data By Country 80 Final data for the period 2007-2013 will only be available at the end

79 http://www.eysped.gr/el/Pages/epedi.aspx of 2017.

Greece 22

• 5. 

  Effective governance and knowledge

SDG 16 aims at providing access to justice and building

effective, accountable and inclusive institutions at all Capacity to implement rules

levels. SDG 17 aims at better implementation, improving

policy coordination and policy coherence, stimulating It is crucial that central, regional and local science, technology and innovation, establishing administrations have the necessary capacities, skills and partnerships and developing measurements of progress. training to carry out their own tasks and to co-operate Effective governance of EU environmental legislation and and co-ordinate effectively with each other, within a policies requires having an appropriate institutional system of multi-level governance.

framework, policy coherence and coordination, applying The Ministry of Environment & Energy is responsible for legal and non-legal instruments, engaging with nonthe elaboration of a global environmental policy, the governmental stakeholders, and having adequate levels preparation of plans and programmes, and the control of

of knowledge and skills 81 . Successful implementation their execution. The Ministry is also in charge of the depends, to a large extent, on central, regional and local transposition of EU environmental Directives into government fulfilling key legislative and administrative national law. tasks, notably adoption of sound implementing legislation, co-ordinated action to meet environmental objectives and correct decision-making on matters such as industrial permits. Beyond fulfilment of these tasks, government must intervene to ensure day-to-day compliance by economic operators, utilities and individuals ("compliance assurance"). Civil society also has a role to play, including through legal action. To underpin the roles of all actors, it is crucial to collect and share knowledge and evidence on the state of the environment and on environmental pressures, drivers and impacts.

Equally, effective governance of EU environmental legislation and policies benefits from a dialogue within

Member States and between Member States and the At the decentralised level, the regional and municipal

Commission on whether the current EU environmental authorities exercise, within their areas, certain legislation is fit for purpose. Legislation can only be environmental competences and assure the practical properly implemented when it takes into account application of various environmental measures (e.g. experiences at Member State level with putting EU water quality, waste management, impact assessments). commitments into effect. The Make it Work initiative, a An environmental inspectorate has been operational Member State driven project, established in 2014, since 2004, but its decisions and reports are often organizes a discussion on how the clarity, coherence and ignored.

structure of EU environmental legislation can be Reaching the deadlines and requirements imposed by EU improved, without lowering existing protection environmental legislation appears to remain an issue of standards. concern. This could be explained by the relatively low

(and reduced during the last years) number of human

Effective governance within central, regional resources dealing with the huge environmental acquis, combined with the bottlenecks created by the lengthy

and local government and complicated administrative procedures in place,

Those involved in implementing environment legislation which often involve many actors from various levels of at Union, national, regional and local levels need to be public administration.

equipped with the knowledge, tools and capacity to The number of open cases is very high (27 infringement improve the delivery of benefits from that legislation, cases, of which 19 at 258 stage and 8 at 260 stage). In and the governance of the enforcement process. general, there are no significant problems regarding the

quality of transposition of the EU Directives (the

81 The Commission has work ongoing to improve the country-specific problems are essentially related to their

knowledge about quality and functioning of the administrative implementation). The Court of Justice has imposed fines

systems of Member States.

Greece 23

on Greece for non-compliance with EU law provisions in damage from an accident using liability rules) and the fields of solid waste and urban waste water contractual law (e.g. measures to require compliance treatment and penalty payments remain due as long as with nature conservation contracts). Taken together, all the judgments of the Court are not fully executed by the of these interventions represent "compliance assurance" Member State. as shown in Figure 12.

The transposition of the revised EIA Directive 82 will be an Figure 12: Environmental compliance assurance

opportunity to streamline the regulatory framework on environmental assessments. The Commission encourages the streamlining of the environmental assessments to avoid overlaps in environmental assessments and accelerate decision-making, without compromising the quality of the environmental assessment procedure. The

Commission has issued a guidance document in 2016 83

regarding the setting up of coordinated and/or joint procedures that are simultaneously subject to assessments under the EIA Directive, Habitats Directive, Water Framework Directive, and the Industrial Emissions Directive.

Suggested action

• Simplify environmental administrative procedures and

improve cooperation of public authorities (at national, Best practice has moved towards a risk-based approach

regional and local levels) involved in the application of at strategic and operational levels in which the best mix

environmental policies. of compliance monitoring, promotion and enforcement is directed at the most serious problems. Best practice also

recognises the need for coordination and cooperation

Compliance assurance between different authorities to ensure consistency,

avoid duplication of work and reduce administrative EU law generally and specific provisions on inspections,

other checks, penalties and environmental liability help burden. Active participation in established pan-European lay the basis for the systems Member States need to networks of inspectors, police, prosecutors and judges, have in place to secure compliance with EU such as IMPEL

85 , EUFJE 86 , ENPE 87 and EnviCrimeNet 88 , is a

environmental rules. valuable tool for sharing experience and good practices.

Public authorities help ensure accountability of duty Currently, there exist a number of sectoral obligations on holders by monitoring and promoting compliance and by inspections and the EU directive on environmental

taking credible follow-up action (i.e. enforcement) when liability (ELD) 89 provides a means of ensuring that the

breaches occur or liabilities arise. Compliance monitoring "polluter-pays principle" is applied when there are can be done both on the initiative of authorities accidents and incidents that harm the environment. themselves and in response to citizen complaints. It can There is also publically available information giving involve using various kinds of checks, including insights into existing strengths and weaknesses in each inspections for permitted activities, surveillance for Member State.

possible illegal activities, investigations for crimes and For each Member State, the following were therefore

audits for systemic weaknesses. Similarly, there is a range

of means to promote compliance, including awarenessreviewed: use of risk-based compliance assurance; coordination and co-operation between authorities and

raising campaigns and use of guidance documents and participation in pan-European networks; and key aspects

online information tools. Follow-up to breaches and

liabilities can include administrative action (e.g. of implementation of the ELD based on the Commission's recently published implementation report and REFIT

withdrawal of a permit), use of criminal law 84 and action evaluation 90 .

under liability law (e.g. required remediation after

85 European Union Network for the Implementation and Enforcement of 82 The transposition of Directive 2014/52 i/EU is due in May 2017. Environmental Law

83 European Commission, 2016. Commission notice — Commission 86 European Union Forum of judges for the environment guidance document on streamlining environmental assessments 87 The European Network of Prosecutors for the Environment conducted under Article 2(3) of the Environmental Impact 88 EnviCrimeNet

Assessment Directive (D irective 2011/92/EU of the European 89 European Union, Environmental Liability Directive 2004/35/CE , p.56 Parliament and of the Council, as amended by Directive 2014/52 i/EU). 90 COM(2016)204 final and COM(2016)121 final of 14.4.2016. This

84 European Union, Environmental Crime Directive 2008/99/EC highlighted the need for better evidence on how the directive is used

Environmental Crime Directive 2008/99/EC in practice; for tools to support its implementation, such as guidance,

Greece 24

Over the last decade, Greece has made efforts to appears to have had positive effects on taking preventive improve its system of inspections of industrial facilities. measures and addressing environmental damage, but Some relevant data collection and analysis are lack of resources presents a challenge. undertaken and annual activities reports are published

online by the Hellenic Environmental Inspectorate, which Suggested action

is empowered to carry out inspections and other • Improve transparency on the organisation and compliance assurance tasks across environmental policy functioning of compliance assurance and on how

subject-areas 91 . significant risks are addressed, as outlined above.

Up-to-date information is lacking in relation to the • Encourage greater participation of competent following: authorities in environmental compliance networks.

− data-collection arrangements to track the use and • Step up efforts in the implementation of the effectiveness of different compliance assurance Environmental Liability Directive (ELD) with proactive interventions; initiatives, in particular by drafting national guidance.

− the extent to which risk-based methods are used to

direct compliance assurance at the strategic level Public participation and access to justice

and in relation to critical activities outside of

industrial installations 92 , especially specific problem The Aarhus Convention, related EU legislation on public areas highlighted elsewhere in this Country Report, participation and environmental impact assessment, and i.e. illegal landfills, the threats to protected habitat the case-law of the Court of Justice require that citizens types and species, poor air quality and the pressures and their associations should be able to participate in on water quality from diffuse and point sources of decision-making on projects and plans and should enjoy pollution, including deficient urban and domestic effective environmental access to justice.

waste-water systems. Citizens can more effectively protect the environment if

− how the Greek authorities ensure a targeted and they can rely on the three "pillars" of the Convention on

proportionate response to different types of non Access to Information, Public Participation in Decisioncompliant

behaviour, in particular in relation to making and Access to Justice in Environmental Matters

serious breaches detected, given indications that ("the Aarhus Convention"). Public participation in the

there is a low probability of being criminally administrative decision making process is an important

prosecuted and sentenced for environmental element to ensure that the authority takes its decision on

offences. the best possible basis. The Commission intends to

examine compliance with mandatory public participation

Greece does not actively participate in the activities of requirements more systematically at a later stage.

the European networks of environmental professionals,

in particular since the beginning of the financial crisis. Access to justice in environmental matters is a set of

guarantees that allows citizens and their associations to

For the period 2007-2013, Greece reported 52 cases challenge acts or omissions of the public administration handled according to the requirements of the before a court. It is a tool for decentralised Environmental Liability Directive. The country established implementation of EU environmental law.

a supporting administrative office for the implementation

of the Directive and has participated in the Commission's For each Member State, two crucial elements for training programme for competent authorities and other effective access to justice have been systematically stakeholders. It also decided to establish mandatory reviewed: the legal standing for the public, including financial security (to pay for remediation where NGOs and the extent to which prohibitive costs represent operators cannot) which however has not become a barrier. operational to date. The implementation of the Directive Greece grants the public, notably individuals and NGOs, a

broad access to justice in environmental cases. The costs

training and ELD registers; and for financial security to be available in for bringing a case to a court are also not prohibitively

case events or incidents generate remediation costs. high. This guarantees that members of the public are 91 Hellenic Environmental Inspectorate provided with good conditions for asking for a judicial

92 Weaknesses have been identified concerning strategic planning and

preparation of inspection plans and programmes, see Study on review in environmental matters in Greece. However, the

'Assessment and summary of the Member States' implementation court procedures, including environmental cases, in reports for the IED, IPPCD, SED and WID. Industrial Emissions Greece are very long 93 .

Directive, 2016, Amec Foster Wheeler Environment&Infrastructure UK Ltd in collaboration with Milieu Ltd, p. 234-235.. Weaknesses have also been identified in relation to control of water abstraction, see European Court of Auditors, Special Report No 4, 2014, Integration of EU water policy objectives with the CAP: a partial 93 European Commission, 2012/2013 access to justice in environmental success, p. 31f matters

Greece 25

without procedural obstacles are available but not fully implemented. Although it is mandated by Greek law that spatial data have to be exchanged free of charge

Access to Information, knowledge and between public authorities, the implementation of this

evidence legislation within Greek administration is in many cases problematic. Of 600 spatial data sets that have been

The Aarhus Convention and related EU legislation on identified by Greece, only 30 have been made available access to information and the sharing of spatial data for publication. require that the public has access to clear information on

the environment, including on how Union environmental Assessments of monitoring reports

99 issued by Greece

law is being implemented. and the spatial information that Greece has published on the INSPIRE geoportal 100 indicate that not all spatial

It is of crucial importance to public authorities, the public information needed for the evaluation and and business that environmental information is shared in implementation of EU environmental law has been made an efficient and effective way. This covers reporting by available or is accessible. The larger part of this missing businesses and public authorities and active spatial information consists of the environmental data dissemination to the public, increasingly through required to be made available under the existing electronic means. reporting and monitoring regulations of EU

The Aarhus Convention 94 , the Access to Environmental environmental law (Annex III of the INSPIRE Directive),

Information Directive 95 and the INSPIRE Directive 96 which may be due to lacking or insufficient coordination together create a legal foundation for the sharing of in Greece between INSPIRE stakeholders.

environmental information between public authorities Suggested action

and with the public. They also represent the green part of

the ongoing EU e-Government Action Plan 97 . The first • Critically review the effectiveness of data policies and two instruments create obligations to provide amend them, taking 'best practices' into consideration. information to the public, both on request and actively. • Identify and document all spatial data sets required for The INSPIRE Directive is a pioneering instrument for the implementation of environmental law, and make electronic data-sharing between public authorities who the data and documentation at least accessible 'as is' can vary in their data-sharing policies, e.g. on whether to other public authorities and the public through the access to data is for free. The INSPIRE Directive sets up a digital services foreseen in the INSPIRE Directive.

geoportal which indicates the level of shared spatial data in each Member State – i.e. data related to specific locations, such as air quality monitoring data. Amongst other benefits it facilitates the public authorities' reporting obligations.

For each Member State, the accessibility of environmental data (based on what the INSPIRE Directive envisages) as well as data-sharing policies ('open data') have been systematically reviewed.

Greece's performance on the implementation of the

INSPIRE Directive as enabling framework to actively disseminate environmental information to the public leaves room for improvement. Greece has indicated in

the 3-yearly INSPIRE implementation report 98 that the

necessary data-sharing policies allowing access and use of spatial data by national administrations, other

Member States' administrations and EU institutions

94 UNECE, 1998. Convention on Access to Information, Public

Participation in Decision-Making and Access to Justice in Environmental Matters

95 European Union, Directive 2003/4/EC on public access to

environmental information 96 European Union, INSPIRE Directive 2007/2/EC 97 European Union, EU eGovernment Action Plan 2016-2020 -

Accelerating the digital transformation of government COM(2016) 179 final 99 Inspire indicator trends

98 European Commission, INSPIRE reports 100 Inspire Resources Summary Report

Met de EU Monitor volgt u alle Europese dossiers die voor u van belang zijn en bent u op de hoogte van alles wat er speelt in die dossiers. Helaas kunnen wij geen nieuwe gebruikers aansluiten, deze dienst zal over enige tijd de werkzaamheden staken.

De EU Monitor is ook beschikbaar in het Engels.