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Technical Chamber of Greece – Western Macedonia Section (TEE/TDM): Positions regarding the Ministry of Environment and Energy's consultation on the National Just Transition Fund

The European Union, as part of tackling climate change, has formulated a network of policy initiatives and measures for reducing its carbon footprint, which includes developing a new energy model alongside supporting the productive sectors that will be affected, as well as advancing technological innovation.

A positive measure towards supporting regions highly dependent on the lignite industry, such as Western Macedonia, is the Hellenic State's decision to establish the Just Transition Fund, supporting—with resources from the auctioning of greenhouse gas emission allowances—projects that will allow for the diversification of economic activity and create jobs.

The Technical Chamber of Greece – Western Macedonia Section (TEE/TDM) considers that this decision acts in support of Western Macedonia's effort, which is already exploring issues regarding its structural transformation, always towards a new developmental and productive model consistent with modern social and environmental challenges, participating as one of the four pilot Regions in the European Commission's “Coal Regions in Transition Platform” initiative.

Furthermore, the Technical Chamber of Greece – Western Macedonia Section (TEE/TDM), by decision of its Delegation, resolved to support the transition process and the Region of Western Macedonia for the Coal Platform with all of its Standing Committees. Indeed, it was the first to complete the “Assessment of the economic sectors' contribution to Western Macedonia's productive model, with an emphasis on the impact of the lignite industry”, highlighting recently as well, during its intervention in Parliament, the need to secure capital by calling for “…the obligations/commitments of the new companies to the local community to be mapped out, and primarily, for the essence of the problem to be highlighted—that of finding capital so that there will be investments and a halting of the downward trajectory of the lignite regions and obviously of Western Macedonia’s energy heartland…”. What must primarily be ensured is the existence of a well-structured and thoroughly considered contribution plan by Western Macedonia that will maintain it as the country’s “Energy Centre”, and it is to this that the Just Transition Fund must respond as a strategic choice.

The Technical Chamber of Greece – Western Macedonia Section (TEE/TDM), taking into consideration the planning and actions of the Region of Western Macedonia within the framework of the European Initiative, highlights the necessity for a common focus and complementarity of actions across all initiatives and measures supporting the transition process.

The National Just Transition Fund is a distinct instrument. In contrast, its resources derive from a portion of the revenues from auctioning greenhouse gas emission allowances, which fall under the central administration of the state.

For the National Just Transition Fund it was pointed out “The administration of the Special Account will be managed centrally by a state agency operating under the supervision of the Ministry of Environment and Energy”. We point out that the proposed approach will increase complexity with no substantial benefit, sending the wrong message. It is proposed that the aforementioned agency that will manage and supervise the overall undertaking should be based in the region of interest. According to the existing structure, such a public entity could be the Regional Development Fund, which operates under all legal procedures, or, if NSRF-style procedures are selected, the Managing Authority of the respective Regional Operational Programme.

However, we venture to suggest that its actions should not follow NSRF-style procedures, ensuring better targeting and implementation of actions/projects with swifter and more direct results, which will be pre-defined and unambiguous, thereby avoiding the mistakes of the past. Regarding the above, we obviously agree that legislative regulation should be pursued. The Technical Chamber of Greece – Western Macedonia Section (TEE/TDM) will assist in this direction with Working Groups in accordance with its institutional framework, as it has proven to date with the well-substantiated interventions it has submitted.

It is noted that, obviously, the option should also be provided for final beneficiaries and bodies outside Western Macedonia to participate, provided their actions serve a coherent action plan that Western Macedonia is already developing in cooperation with the Ministry of Environment and Energy via the Coal Platform.

If the Ministry of Environment and Energy insists on its view, then we propose the creation of a special measure exclusively for actions supporting the Coal Platform, with the aforementioned bodies as beneficiaries, so that the efforts of Western Macedonia's stakeholders are not derailed but, on the contrary, reinforced by resources from the Just Transition Fund.

The actions should also predominantly involve the private sector or public-private partnerships, with a focus on innovation, within which the number of new jobs expected to be created must be outlined. It is obvious that there is potential for the establishment of heavy industry by private individuals, given the appropriate incentives and, of course, always in compliance with environmental terms and rules. An industrial culture exists in the region, the human capital is here; what is needed is willpower and proper management.

The energy conservation and clean energy actions referenced are important, but they are not the objective of the transition; rather, they are a consequence thereof, especially Renewable Energy Sources (RES). Energy conservation is an issue for which, as has been communicated to you multiple times by the Technical Chamber of Greece – Western Macedonia Section (TEE/TDM), it is a significant action where resources were not correctly allocated, because the harshest climate zone—in which Western Macedonia falls in its entirety—was not taken into account.

Our proposal is for an adaptation of the Just Transition Fund to the financing needs of a Business Plan for Western Macedonia, in consultation and alignment with the Technical support of the SRSS and the World Bank, which the Region of Western Macedonia is coordinating and to which the Technical Chamber of Greece – Western Macedonia Section (TEE/TDM) is contributing wherever required.

For the Steering Committee of the Technical Chamber of Greece – Western Macedonia Section (TEE/TDM)

The President

Dimitris Mavromatidis

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