The National Energy and Climate Plan is a vital tool for addressing climate change, and its submission is a positive step following a considerable period without such planning.
As part of the general commentary on the text under consultation, with an emphasis on the power generation sector, the following are noted:
• Bibliographic sources are cited in bulk, without specific reference to the relevant sections of the text, resulting in a lack of comprehensive documentation for those passages. Furthermore, the reference to existing policy measures is provided only numerically, a fact which does not contribute to the document's completeness.
• The Plan includes only one main development scenario, without addressing a range of project development by technology or potential variations of the scenario arising from failures or modifications to the initial design due to the investment framework, funding, project implementation, etc.
• The results of the planning do not provide an estimate for the evolution of electricity costs nor a comparative assessment against a baseline scenario (Business as usual)
• The plan does not explicitly outline the link between the development of RES (Renewable Energy Sources) and the corresponding development of a national RES manufacturing industry in terms of targeting and support.
More specifically, at the regional level of Western Macedonia, the following are highlighted:
In the power generation sector, mention is made of the evolution of the total capacity of thermal plants within the framework of the non-binding operation of the market, without specifying which power generation units will be decommissioned and when, nor detailing the integration or upgrading of units in line with current and future requirements according to the examined scenario. This reference is deemed essential as it bears a significant impact on local development and economic activity. A corresponding reference is also expected in PA1 of the policy guidelines for the 2020-2030 period, citing anticipated initiatives for the gradual withdrawal of polluting thermal plants (page 144).
It should be noted that Western Macedonia is one of the first four Regions in transition out of a total of 41 European coal regions, participating in the EU initiative “Coal Regions in Transition Platform”, and the integration of the relevant actions as an integral part of the national planning is proposed. Despite the general reference to development plans for the areas that will be most affected by the gradual transition to a low-carbon economy (pages 53-54), there is no proposal concerning the strategy formulation processes or the financial tools that will be used to achieve the transition. The transition process and the development of the regions in transition are influenced by the restoration and reuse of the lands of exhausted mines, a fact which must be referenced in the planning in terms of final land uses, timeframe, ownership status, and project implementation obligations. It is deemed necessary that the development of a new regional productive model of transition is also reflected in the core characteristics of the new 2021-2027 programming period (pages 194-196), alongside measures relating to the energy sector for the utilisation of the existing human resources and expertise, and corresponding provisions for its funding.
Dimitris Mavromatidis,
President of the Steering Committee of the Technical Chamber of Greece – Western Macedonia Section (TEE/TDM)