Remarks by Dynamiko TEE in the Consultation on the Territorial Plans

Remarks by Dynamiko TEE in the Consultation on the Territorial Plans [statement to the Extended Steering Committee on 12 March 2021, in the presence of the coordinator of the Just Transition Development Plan (SDAM)]

 Employment positions

 Regarding the reference year, which is set
as 2019, we believe that unemployment in Western Macedonia is underestimated, given
that the post-lignite period began at a much earlier stage, a fact
that has been repeatedly highlighted by the Technical Chamber of Greece – Western Macedonia Section (TEE/TDM).
This is also evident from the fact that the chronically high level of unemployment over
recent years in Western Macedonia was precisely a direct result of the
delignitisation process, which began in 2002–2003 according to an intervention by the TEE, but with substantial impacts on employment from 2012–2013 onwards.. 
It is not a mere statistical indicator, but a substantive issue, because it determines
the mix and extent of the policies that must be implemented in Western
Macedonia. Therefore, we believe that the jobs lost due to
deindustrialisation in the lignite industry are significantly more numerous than those
that are reported.

To this end, even
with 2019 as the reference year (which ought to have been set several years
prior), we note the following:

In the
Annex to the Territorial Just Transition Plan for Western Macedonia (TJTP),  and specifically in the chapter ‘Summary
of the process for identifying affected territories’, the process is described
for assessing the impacts of delignitisation in the Region.

On
page 106, it states:

«‘The
aforementioned analysis is based on mapping the direct impact that
lignite activity has on the economy, employment, and the energy
supply of the lignite areas. However, given the multiplier
effects generated by the correlation developing among other
business activities, it is considered appropriate to further investigate the
indirect and induced impacts. Specifically, taking into account the relevant multipliers for the sector under examination (Technical Chamber of Greece, 2012), as well as the distribution of production and
employment of workers across the individual sectors of lignite
activity (e.g., mines, thermal power plants), it is possible to estimate
the indirect and induced impacts of the lignite activity.’»

In the
TEE Study (2012), cited in the above reference, and specifically in the
chapter ‘7. Conclusions’, it is stated (in the first bullet):

«At the
level of Western Macedonia, the employment and income multipliers
created by the lignite industry are exceptionally high. For every single
permanent staff position in the mines and power generation plants, there are created and
maintained 3,28 positions in the local labour market. For every single euro
spent by the Public Power Corporation (PPC) S.A. on salaries and contracting, there is an induced outcome of more
than three euros circulating within the local economy.»

In
Table 75 of the TJTP, which follows, it is established that:

– The two Regional Units (PE) of Kozani
– and Florina, which are most severely affected by delignitisation, exhibit an
Employment Multiplier of 2,50 [=(6,09+9,14)/6,09] for the Kozani Regional Unit
and 2,51 [=(0,76+1,15)/0,76] for the Florina Regional Unit, which fall far short of
the Employment Multiplier (3,28) of the Study cited by the
TJTP. If, of course, the Employment Multiplier of 3,28 is applied to
the Kozani and Florina Regional Units, then there emerge an additional 5.330 ‘lost’
jobs (23.540 versus 18.210 in the TJTP).

– Correspondingly, also
regarding GVA (Gross Value Added), the Multiplier used 1,20 (for both
Regional Units) is far from the Income Multiplier of >3 concluded by
the TEE Study (2012), while it also differs significantly from the
Income Multiplier of 2,6 concluded by the TEE Study
(2018) «Study update: ‘Estimation of the transition cost of Western
Macedonia to a low lignite production regime’ – Assessment of the contribution
of the economic sectors to the productive model of Western Macedonia, with an emphasis
on the impact of the lignite industry.»

B.
        From Table 75 above,
it is apparent that during the reference year (2019), the total jobs
(direct, indirect and induced) that depend on the lignite industry for
the two Regional Units (Kozani and Florina) stand at 17,140, and the GVA is €1.66 billion.

In
Table 80 of the TJTP, ‘Cumulative impacts by 2029 due to the cessation of lignite
activity (compared with 2019)’, total job losses
(for the two Regional Units) amount to 10.430 and for the GVA to 1,00 billion euros.

Given
that by the year 2029 lignite production will have been completely eliminated,
it follows that the shortfalls in jobs 6,710 (17,140 – 10,430)
and in GVA 0,66 (€1.66 – 1.00 billion) will need, in the intervening period
(2020–2029), to be created through other new and/or modified
activities, something which, however, is not specified nor
calculated by the current TJTP.

District heating
(page 15)

Have the costs been priced for the district heating systems? The TEE sounded the alarm in good time.

In greater detail, the above fundamental principles can be
summarised in the following three (3) pillars:

(a) Establishment of an Inter-Municipal District Heating Enterprise for Western
Macedonia, through the merger of the three Municipal Enterprises that provide
district heating services.

(b) Development of an interconnection network for the district heating systems
of the three cities, which is linked to the primary thermal energy production points.

(c) Configuration of two primary thermal energy production points
(Kardia Thermal Power Plant, Ptolemaida 5) and the securing of necessary reserves.

Have we seen the enhancement of district heating systems with Renewable Energy Sources (RES), through a special provision of the
Just Transition Fund, in order to reduce the cost of production/supply of the
requisite thermal energy?

SPV (page 8)

For
the implementation of the stages of the transition process, a basic prerequisite is
the designation of the responsible body, a Special Purpose Vehicle (SPV), to which the
PPC’s assets intended for restoration and exploitation will be transferred,
so that the restoration procedures and the readjustments of their use
may proceed at a rapid pace. At the same time, appropriate spatial planning is required
to map the land uses and their siting scenarios,
within the framework of which these must be further specified and
institutionalised via the approval of the stipulated tools/plans of the
regulatory urban planning, in accordance with the provisions of Law 4447/2016,
as currently in force, and specifically with the provisions of Law 4759/2020.

We believe that the creation of a management company for all the territories is imperative, and not merely for their restoration..
It is a historical responsibility and an opportunity to entrust all the lands to a single company,
which, with a structured plan that encompasses the entire investment mix – 15
to 20% renewable sources, an industrial zone, lakes, infrastructure, reforestation,
agro-pastoral parks and other elements that will be determined following
substantive consultation. Otherwise, we have a logic of separation, ‘Bad bank’ and
“Good bank’, where
the Good Bank is
the photovoltaics for the Public Power Corporation (PPC) and the Bad Bank the
remaining lands which will be for restoration and which the PPC will price.
It is noted that the World Bank in its study,[1] alongside the substantive and
decisive interventions by the Ministry, refers to the creation of such a
company. However, we see that the approach is for the company to essentially cover
only the portion of the lands that will be yielded by the PPC.

The PPC also bears a significant share of responsibility
for the restoration. Has the restoration cost owed by the PPC
from its obligations been assigned to an independent expert?

A point of note: The special purpose vehicles that are
favoured by the World Bank[2] feature the good example
of Attiko Metro for the Olympic Games, et cetera, et cetera, which means that the special purpose vehicle
must have a clear geographical context, and not be a general company with
a specific remit and particular content, rather than solely focusing on restorations.
Consequently, the special purpose vehicle should be specifically for Western
Macedonia, which holds the overwhelming majority of the expanses intended for exploitation.

Special
Purpose Vehicle ‘Metavasi S.A.’ page 153

We propose that the aforementioned company not be designated as
a special purpose vehicle, given that its functions could already be carried out institutionally
potentially at a regional level as well. In the same manner,
that is, that legislation will be passed to create a company at the national level, it
could also be created at a regional level, and to this end there are
proposals which will obviously be requested of the competent regional bodies before
they are communicated to you. It is a contradiction at this moment to invest in centralised
systems by introducing specific legislative regulations while ignoring regional
bodies or regional structures that could contribute without the
corresponding legislative provisions. Obviously, we are not opposed to the
possibility of broadening the range of companies that could support
the transition as a process, particularly if this company, following a GENUINE
CONSULTATION with the local bodies, also encompasses the aspect of
restorations and the repurposing of lands.

A fundamental issue to be resolved is how the actions will
mature, and how their maturation will be accelerated so that they can be implemented at
a Regional Level. The development agencies being established by the
Municipalities, the Development Companies, and the mechanisms within the Region and the Municipalities,
namely the Technical Services, must be adequate not only for the
maturation but also for the supervision and management of the projects, backed by specific
legislative provision.

Transition clause (PAGE
77)

The extension of the transition clause is undoubtedly a positive development
and must also be extended to the implementation of the photovoltaic parks and to all those projects
that do not have an impact on the circular economy, with a specific provision for a contribution
for the region (to be integrated into the resources allocated to the areas where
they are installed), e.g., with a percentage of 10%. This reciprocation is deemed
imperative, given that these investments, which make zero contribution
to employment beyond the installation phase (not during production), can at least
supply the requisite financial resources to the local
area in order to create jobs of higher added value. It is essential to appoint an independent valuer who will determine the environmental debt owed by the PPC to Western Macedonia, based on the approved Environmental Impact Studies (obviously prior to the institutionalisation of the Delignitisation Zones).

Observatory (page 151)

Initially,
the intention to establish an Observatory as a distinct
entity within the Governance Mechanism is evaluated positively. However, this must possess a clear
regional reference and be linked to the decision-making capacity regarding the
territorial transition plans.

Employment

The
employment policies from the Centre through the OAED (Greek Manpower Employment Organisation) must be decentralised and
we ought to look at equivalent systems with European experience. 

Special Just Transition Coordination Authority (Special Managing Authority)
(page 151)

The financial framework must also be clarified because, at this
moment, it is ambiguous. To those of us in the know, it is clear that this pertains to
the consultation taking place at a national level with the European Commission
concerning the co-financed segment of the individual programmes. However,
provision should be made for the specific weighting that Western Macedonia commands,
given that, even at a conservative estimate, it is affected by the mobilisation. And
the overwhelming proportion of the Resources from the special managing authority for the developmental transition
must be apportioned to it correspondingly.
It cannot be acceptable to introduce the rationale of standard
calls, in which five of the country’s regions—namely
Western Macedonia, the Peloponnese and the three island territories—will be entered in identical fashion. It is
obvious, and on this point we seek your support, because it would constitute a clear
injustice towards the most disadvantaged region in the country.

It is also extremely important that there be
complementarity between the programmes, as well as the specific sectoral
programmes, committing Resources to Western Macedonia for the transition processes,
so that the existing programme may also be able to fund a portion
of the regional units (Grevena and Kastoria) which are essentially excluded.
For this to happen, all projects and actions that are mature or are already
due to be implemented with the commencement of the new NSRF (National Strategic Reference Framework), plausibly in January 2022,
must be incorporated for funding under the care of the SDAM. This is where central
coordination is required. Within this programme, we propose that there be a commitment not only regarding
the axes and sectors, but also concerning the Regions to which they will be
directed, so that it is made clear to Western Macedonia as well that its
substantial shortfall in employment, resulting from the abrupt
delignitisation that was triggered, will be acknowledged.

We highlight that as the TEE, we have stated the sectors
upon which the informal contract between the PPC and the local community exerted an influence, and to which
special care must be afforded.

Plan
for the Smart Specialisation Strategy of the Region of Western Macedonia 2014–2020
(page 154)

Evidently,
regarding smart specialisation, which is a substantive issue of resource direction and
policy targeting, there will be discussion and collaboration with the equivalent structure
of the Region of Western Macedonia; however, this is a specific detail
which is nonetheless vital in terms of entrepreneurship and innovation.

Spatial Planning
and ZAP (Delignitisation Zones)

It is not
scientifically sound, prior to the finalisation of the new spatial plan that will
take into account the abrupt deindustrialisation in the lignite mining sector, to
proceed with the siting of activities through the Delignitisation Zones.

Environment
and Photovoltaic Parks

In relation to
section 2.1.3, confidence is expressed that delignitisation will bring about positive
impacts on the environment. Yet the installation of RES in their stead also carries
repercussions for the ecosystems, which are not mentioned.

Other
points of note

On
page 17 it is stated that ‘the creation of business and technology
parks in areas where lignite plants currently operate, as well as in adjacent
areas, will attract businesses that will further contribute to the
economic diversification of the region’. Let them provide us with examples in
Greece where the creation of such parks has succeeded in attracting businesses, and
whether there is a correlation between the scale and the broader geographical and
economic characteristics of those areas with Western Macedonia and the Kozani Regional Unit.
Furthermore, mere institutionalisation or hard infrastructure cannot on
their own attract investments.

Also, on page 17: ‘taking into account the expertise of the existing
workforce, this could be utilised, both in the implementation
of energy infrastructure, and in the further development of the primary
sector’; meaning, they should become farmers? And has it been calculated how many will
be employed in the future energy infrastructures? And subsequently:
‘an effort is made to strengthen local products’, which has been attempted
generally for years, with results that are insufficient to robustly bolster
the economy.

Further on: ‘the promotion of the highly varied natural environment is pursued,
both in Kozani and Florina, as well as in the broader region, in the spirit
of integrated territorial interventions’; what percentage of the ITI (Integrated Territorial Investments) and the SUD (Sustainable Urban Development)
has been implemented, both having been drafted 4 years ago? The outcomes
bear little relation, firstly, to the provisions of the ITI for soft interventions, since instead
only roadworks etc. are being implemented, and secondly, the SUD plans may well be obsolete
as designs. Comprehensive planning from scratch is required at both the regional and
local level.

Tourism accounts for ~2% of arrivals; it does not substantially impact the GDP of the
region, and if there is a target to develop it, so many resources—
financial and human—are required that no policy could possibly yield
immediate results within the decade.

The territorial plan calculates affected sectors that have a direct relationship with the
lignite activity, whereas in reality the majority of the economy’s sectors
are affected. At the very least, let them be referred to as directly
affected. Moreover, the jobs are not affected; initially
they are positions of unemployment, subsequently of reskilling or migratory flows, and
ultimately they are reintegrated into production.

Page 19: ‘the establishment of new businesses is expected along the broader
supply chain, as well as in the production of equipment and materials’; upon
what grounds does this emerge?

Page 29. On sustainable urban mobility. Kozani and Grevena have an SUMP (Sustainable Urban Mobility Plan);
Florina and Eordaia have an SUMP in progress. Kastoria does not have one and is not
likely to draft one, because the funding from the Green Fund expired, while
smaller urban centres such as Amyntaio had no funding. What will be
the framework for implementing such actions?

Regarding 3.3.2, specific and structured consultation procedures should be required
with the local communities at specific timeframes during decision-making.
During these processes, the bodies must be provided with the
necessary information (spatial, tables or texts). The involved bodies must not
only be identified and invited to the consultation, but they must also be
equipped with tools to ensure their participation is meaningful. As an indicator, is the
‘number of attendances at the committees’ sufficient? We consider that it is not,
because there are also qualitative characteristics.

Page 69: ‘5 basic pillars of development: Clean energy, Industry,
craftsmanship and commerce, Smart agricultural production, Sustainable tourism, Technology
and education’; culture is not mentioned. In the region, apart from the
intangible cultural heritage, there are prehistoric, Hellenistic, Byzantine and
more modern monuments, among them that of the industrial heritage, which the
TEE has already championed as a pillar of development.

Page 72. The digital map presents significant advantages. 1) Its
functionality is not provided for; besides space, there is also time, so the
map must depict the spatial transformations over time. 2) Beyond
the form and function depicted by the map, the third dimension of
the space is its significance – semiotics. It is important that this be taken into account in the
sitings. The issue is raised concerning the recognition and promotion of spatial symbols.
Aside from the administrative units of municipalities, it would be useful to identify within
the Region developmental spatial units that could be of use in the
application of policies, e.g., mountainous areas or others with shared characteristics.

In closing…

With the majority of investments, the main problem is
time. We must work to eliminate these lengthy
time delays, which occur and are due to the bureaucracy of
Brussels, but also our own, and this cannot be tackled with conventional structures
and practices, rather we must think out of the box.

For Dynamiko TEE,

Dimitris Mavromatidis

Head of the Faction