Assessment and recommendations

After a long, deep recession, the Greek economy started to recover in 2017. The country has undergone extensive fiscal and structural reforms, but faces difficult challenges in improving well-being, income and employment and reducing poverty. Between 2009 and 2017, some environmental pressures, notably emissions of greenhouse gases (GHGs), sulphur oxides (SOX) and nitrogen oxides (NOX), declined faster than GDP (Figure 1). Since 2013, however, energy consumption, municipal waste generation and pesticide use have grown more quickly than economic activity.

Although the energy mix has been shifting from oil and coal (lignite) to natural gas and renewable resources, Greece ranks among the ten most carbon-intensive economies in the OECD due to its strong reliance on fossil fuels. In addition, agriculture, transport, tourism and fisheries put pressure on the country’s biological wealth.

Greece surpassed its Kyoto target for the first commitment period and is on track to meet the 2020 and 2030 targets for emissions not covered by the EU Emissions Trading System (EU ETS) (Section 4). In a welcome move, the government that was elected in July 2019 announced a lignite phase-out by 2028 and committed to the objective of climate neutrality by 2050.

The country developed a National Energy and Climate Plan (NECP) and a Long-term Strategy to 2050 in 2019 (MoEE, 2019) (MoEE, 2020). By 2030, the plan aims to i) reduce total GHG emissions, excluding those from land use, land use change and forestry (LULUCF), by 56% from 2005 levels (42% from 1990 levels); ii) reduce GHG emissions not covered by the EU ETS by 36% from 2005 levels, more than twice the reduction required for Greece by the relevant EU directive (16%);1 iii) raise the share of renewables in gross final energy consumption to at least 35%; and iv) limit final energy consumption to 16.5 million tonnes of oil equivalent. The NECP expects promotion of renewables and improvement of the power system (decommissioning of all lignite power plants, expansion of gas-fired generation, interconnection of certain islands with the mainland grid) to contribute the most to GHG emission reduction.

Energy supply and demand dropped significantly in the aftermath of the economic crisis. Energy intensity (energy supply per unit of GDP) is below the OECD average but has decreased more slowly than in most other OECD countries. Transport accounts for the highest share of final energy consumption, followed by the residential sector and industry. Despite an increase in energy consumption since 2013, Greece is on track to reach its 2020 target on energy efficiency.

Significant progress has been made in deploying renewables (mainly wind and solar photovoltaics). In 2018, renewables accounted for 13% of total primary energy supply and 31% of electricity generation, above the respective OECD averages of 10% and 26%. The country achieved the overall binding target of 18% share of renewables in gross final energy consumption, set for Greece by the EU Renewable Energy Directive for 2020, but is unlikely to meet the sub-targets on electricity and transport.

Since 2009, emissions of major air pollutants have decreased faster than economic activity. Reduced energy consumption, flue gas desulphurisation, changes in the electricity mix (increased use of gas and renewables, decommissioning of old coal power plants), reduction of fuels’ sulphur content and scrapping of old vehicles have been the main drivers of this decline. However, levels of emission intensity per unit of GDP remain high, especially for NOX emissions, mainly due to oil-based transport (OECD, 2019a). According to national projections, Greece is on track to meet its 2020 and 2030 emission reduction commitments under the National Emission Ceilings Directive. However, it has fallen behind in developing a national air pollution control programme.2

Although concentrations of the main air pollutants have decreased in the past decade, progress has stalled since fuel consumption started to grow again in 2013. In 2017, exceedances of EU air quality standards were recorded for NO2, PM10, benzene, benzo[a]pyrene and ozone (EEA, 2019a). Premature mortality statistically attributed to exposure to PM2.5 and ozone pollution is among the highest in the OECD (OECD, 2019b). Natural sources, such as Saharan dust, are a significant factor in particulate pollution, especially in the south (Klein et al., 2019). Improving the air quality monitoring system would help in increasing the accuracy of exposure estimates and designing appropriate measures to reduce the health impact of air pollution.

In the aftermath of the financial crisis, domestic material consumption decreased faster than GDP as construction and coal extraction declined and renewables use increased. However, the material intensity of the economy remains higher than the OECD average, mainly owing to significant use of fossil energy material (OECD, 2019c).

According to the State of the Environment report, waste management is the most challenging environmental area (NCESD, 2018). Since 2013, municipal waste generation has been increasing faster than private consumption. In 2017, 80% of municipal waste generated was sent to landfill, nearly twice the OECD average. Greece missed the EU target of halving the amount of landfilled biodegradable municipal waste from the 1995 level by 2013. It is at risk of missing the 2020 Waste Framework Directive target of preparation of half of municipal waste for reuse/recycling.

In 2018, Greece adopted a National Circular Economy Strategy and a two-year action plan, later extended to 2023.The 2017 Law on Recycling aligned existing legislation with circular economy principles. The country also established a multi-stakeholder forum to promote circular economy business models and innovations. It has made strides in closing illegal landfills and expanding extended producer responsibility systems. However, more than 50 dumping sites3 still do not comply with EU requirements, and hazardous waste management remains a challenge. Major efforts are needed to set up adequate treatment infrastructure and better enforce waste regulations (BiPRO, 2017) Data quality issues persist despite the establishment of an electronic waste registry in 2017. There is room to improve performance and oversight of extended producer responsibility systems.

In a welcome move, Greece introduced a tax in 2018 that significantly reduced consumption of single-use plastic bags. A 2019 law provides for a long-awaited landfill tax as part of a pricing policy based on regional and local waste management authorities’ performance in recovering and diverting waste from landfill. Waste collection charges are generally based on property size. There is thus room to develop “pay as you throw” systems as part of instruments to encourage people to reduce waste.

As Greece is generously endowed with freshwater resources, water stress at the national level is moderate but spatial and seasonal distribution and use vary widely (OECD, 2019d). Climate change is expected to increase pressure on water availability, especially in Attica, Central Macedonia, Thessaly, East Macedonia-Thrace and the South Aegean islands (MoEE, 2016). The country has one of the OECD’s highest rates of water abstraction per capita, due in part to irrigation, which benefits from partial cost recovery and reduced electricity prices, and in part to leakage in the distribution system (EC, 2018a) (National Bank of Greece, 2015). The 2017 law on water pricing is expected to ensure cost recovery and promote sustainable water management.

The second River Basin Management Plans show that slightly more than 60% of surface water bodies achieved good ecological status, while 89% of surface water bodies and 85% of groundwater bodies reached good chemical status. Greece has improved its water monitoring system but changes in methods make it hard to infer trends in water abstraction and quality. Compliance rates with Drinking Water Directive requirements are high. Most bathing waters are of excellent quality.

Greece has made progress in wastewater treatment in large agglomerations: 90% of the wastewater load is collected and treated in urban wastewater treatment plants. However, the remaining 10% of the load is dealt with by individual systems which should be replaced by collecting systems and treatment plants where population density is high enough (EC, 2017).

Over the past decade, nutrient surpluses have declined, but the use of fertilisers and pesticides has increased in recent years. The 2013 National Action Plan on Sustainable Use of Pesticides helped in certifying professional users and reducing acute poisoning incidents, although the targets to inspect sprayers4 and reduce non-compliance with maximum pesticide residue limits5 have not been achieved (Bourodimos et al., 2018). More than half of professional users dispose of empty pesticide packages in common waste bins, a further 12% do so without rinsing them, 19% burn or bury containers and less than 10% participate in collection/recycling programmes (MRDF, 2016). It is imperative to establish a system for the collection and safe disposal of empty pesticide containers and to further educate farmers about pesticide risks.

Diffuse pollution and abstraction for irrigation are the main agricultural pressures on water. Groundwater is threatened by salinisation caused by intensive groundwater pumping in coastal areas, leading to seawater intrusion. Water conservation efforts mostly focus on improving irrigation efficiency. Investment in infrastructure contributed to a slight reduction in abstraction for irrigation per hectare of cultivated area between 2015 and 2018, though the volume abstracted increased with the expansion of irrigated areas (AUA, 2019). Under the Rural Development Programme, agri-environmental measures have been found to have positive effects on soil erosion and reduction of nitrogen surplus. Their net effect on water savings and quality and on biodiversity would require a more detailed assessment. In 2019, Greece adopted an action plan to protect water from agricultural pollution covering all 30 vulnerable areas for nitrate pollution.

Since the last Environmental Performance Review (EPR), Greece has made major efforts to streamline its environmental and spatial planning legislation so as to lessen the administrative burden on businesses. Increased government transparency has helped strengthen environmental democracy. However, ensuring compliance with environmental laws and regulations in the country’s decentralised governance system is a significant challenge, further complicated by shortages of human and financial resources due to extensive fiscal and structural reforms. Reduced regulatory pressure combined with weak compliance represents an environmental risk, and many good international practices of environmental policy implementation have only recently been introduced.

The Ministry of Environment and Energy (MoEE) holds most environmental policy and regulatory powers at the central level. Decentralised administrations of the national government have significant environmental management responsibilities, particularly with respect to spatial planning. Multiple horizontal co-ordination mechanisms are dedicated to the pursuit of policy coherence, implementation of Sustainable Development Goals (SDGs), environmental information exchange and key issues such as climate change, water and waste management, spatial planning and circular economy.

The regional and municipal government levels are administratively and financially independent and manage local matters in accordance with the subsidiarity principle. Regions regulate activities with low environmental impact, and municipalities deliver water- and waste-related environmental services. Decentralised administrations supervise local governments only with regard to the legality of their actions, not the substance of their policies. However, vertical co-ordination between the national and local governments’ environmental policies should be enhanced.

Greece has updated and streamlined core environmental legislation to meet European Union (EU) and wider international obligations and enhance its coherence. However, the country still has a significant number of EU directive infringements, particularly in the area of waste. It simplified planning and licensing procedures to reduce the administrative burden on the regulated community, facilitate investment and create a business-friendly environment.

The 2011 Law on Environmental Permitting and its implementing regulations joined the environmental impact assessment (EIA) and permitting processes and completed cross-media integration of environmental permits. Importantly, low-impact activities, which account for about 70% of operators, became subject to standard environmental obligations (attached to an operating licence), in line with good international practice. However, extension of environmental permits for certain projects (e.g. power plants on off-grid islands, hotels, quarries) through special regulations without appropriate EIA (WWF, 2018) weakens environmental governance.

Strategic environmental assessment (SEA) of plans and programmes is regularly used. However, Greece ranks among the bottom five OECD countries on the quality of regulatory impact assessment (RIA) of laws and regulations (OECD, 2018). Cost-benefit analysis is seldom used. Many policies and programmes have implementation monitoring provisions. Ex post evaluations are envisaged in a 2019 law on government operations but are not yet part of established management tools.

Greece has committed to finally complete its land cadastre by mid-2021 after several attempts over the past 25 years. The land-use planning system is a complex combination of territorial, sector-specific and special regimes, all of which undergo SEA. However, local spatial plans are often absent. Special plans for strategic investments and public estates may override regional and local plans to fast-track strategic investment projects, often with expedited environmental permitting, creating a potential environmental risk (OECD, 2017a).

Illegal construction, particularly in coastal and forest areas, remains a major environmental concern. Addressing illegal construction is a government priority. The 2009 EPR recommendation to strictly enforce spatial plans and building permit regulations has not been fully implemented (OECD, 2010). Recent legislation preserved certain conditions that allow retroactive legalisation of illegal housing development. The spatial planning framework for marine and coastal areas adopted in 2018 is a positive step, with a National Maritime Spatial Strategy expected in 2020.

The rate of environmental non-compliance is high. Yet drastic staff cuts at the MoEE’s environmental inspectorate have led to a sharp decline in the number of inspections at the national level. Compliance monitoring is predominantly in reaction to incidents and complaints. Despite the adoption in 2017 of a first five-year national environmental inspection plan, inspections based on risk assessment represent a small percentage of the total inspections conducted. Administrative fines are high, on average, but about a third remain unpaid.

The 2018 Law on Supervision of Economic Activities de-emphasises enforcement sanctions in favour of softer treatment of businesses. In line with good international practice, the government uses regulatory incentives (longer permit terms, licensing fee and insurance premium reductions) to encourage operators to adopt and certify environmental management systems. However, other instruments to promote environment-friendly behaviour, such as voluntary agreements and green public procurement (GPP), should be used more.

Greek law establishes strict liability for environmental damage (fault-based for damage to biodiversity) and specifies criteria for its assessment and remediation. Dedicated institutions at the national and regional levels handle environmental liability cases. The use of financial guarantees against environmental damage is mandatory for high-risk activities but in practice has so far been limited to hazardous waste management activities. This puts a significant burden on the state for environmental remediation if the responsible party is insolvent.

Greece is assessing and remediating several dozen contaminated sites of illegal municipal and industrial hazardous waste landfills, mostly with EU support. However, action plans on closing remaining illegal waste dumps are implemented with delays. No coherent regulatory process or standards for soil remediation exist.

Greek law guarantees broad access to justice on environmental matters for individuals and non-government organisations, which can file suits in administrative or regular courts. Accountability is enhanced by the office of the ombudsman, which has a dedicated team of investigators. It addresses cases of poor administrative practices related to the environment and urban planning, including wrongful permitting, illegal construction, and violation of protected areas and the coastline.

Greece has enhanced the effectiveness of public consultation and environmental information dissemination by using online platforms. Public participation in EIA, SEA and river basin management planning is mandatory, as is consultation on draft primary legislation. However, public consultation on draft regulations is sometimes too short to be meaningful, and supporting and explanatory materials may be lacking (IEEP, 2019).

The MoEE has launched a national geoportal which provides access to environmental geospatial data. Access to environmental information is legally guaranteed, but practical accessibility and adequate interpretation could be improved through a coherent framework for data collection, classification and maintenance by various authorities.

After a severe recession, the economy started to recover in 2017. Despite progress on some environmental commitments made in economic adjustment programmes, the economy remains highly reliant on fossil fuels, road transport is predominant and compliance with EU requirements on waste and water management is a challenge.

In 2018, Greece renewed its commitment to sustainable development in a voluntary national review on implementation of the 2030 Agenda that was presented at the 2018 UN High-level Political Forum on Sustainable Development (Government of Greece, 2018). Among its eight priorities are strengthening protection and sustainable management of natural capital as a basis for social prosperity and transition to a low-carbon economy. The 2019 National Strategy for Sustainable and Fair Growth 2030 (NSSFG) was expected to guide SDG implementation until an action plan was developed (Government of Greece, 2019).

The NSSFG was a welcome update of the previous growth strategy. It put greater emphasis on sustainable development, climate change adaptation and risk management, while keeping a focus on circular economy and GHG emission reduction. However, the coherence between environmental and economic objectives was not always clear; examples include developing both mega-yacht chartering and eco-tourism, promoting renewable energy resources along with hydrocarbon exploration, and reducing GHG emissions in the transport sector while becoming a leading regional logistic hub. While the new government should partly reconcile environmental and energy ambitions in the updated Growth Strategy, improving environmental-economic accounts would help in understanding and managing the trade-offs between policies. Available information on environmental protection expenditure, the environmental goods and services sector, material flow and natural capital accounts is not sufficient to support policy making.

In 2018, Greece recorded one of the OECD’s highest levels of revenue from environmentally related taxes: 3.7% of GDP (Figure 2). The share nearly doubled over the past decade due to increased energy taxation, especially on electricity (to cover the cost of support to renewables) and transport fuels. Greece has some of the highest petrol prices and taxes in the OECD. However, the taxation gap with diesel was among the largest in the OECD in 2018 and has widened since the beginning of the crisis despite diesel’s higher carbon and local air pollutant emissions. This, combined with the introduction of CO2 emission criteria in the circulation tax in 2010 and the end to a ban on diesel cars in metropolitan areas in 2011, helped boost sales of diesel cars.

Overall, effective tax rates on CO2 emissions from energy use are high compared with other OECD countries. However, tax variation across fuels and uses, as well as tax concessions, provides inconsistent carbon price signals. Although decreasing, support to fossil fuel consumption accounts for more than one-quarter of energy tax revenue, among the highest rates in the OECD. This includes tax expenditure compliant with the EU Energy Taxation Directive (e.g. excise tax exemption on specific industrial use of coal and coke and on diesel for aircrafts and vessels, plus reduced excise on oil for heating) and budget transfers (subsidies for oil-based power generators in non-interconnected islands, oil heating allowances to households, capacity payments to gas- and coal-based electricity producers). There is room to improve the monitoring of these direct and indirect subsidies and evaluate their social costs and benefits. In the NECP, the phasing out of fossil fuel subsidies is seen as an effect of the energy transition rather than as an incentive to speed it up. CO2 emissions are also priced via the EU ETS. The recent rise in allowance prices makes coal-based power costly (Section 4).

Transport tax revenue has decreased, driven by a sharp drop in car registrations. In 2016, Greece introduced a CO2 component in the registration tax in addition to the Euro emission criteria. This is a welcome step to encourage renewal of the car fleet, which is among the oldest in Europe. However, vehicle tax reductions for old vehicles have helped increase the share of used vehicles in registrations since the recovery of the market in 2013. Greece plans to introduce a distance-based charging system, varying with vehicle emission class, on the motorway network, which would be a cost-effective way to tackle air pollution (van Dender, 2019). Until the system is in place, it could set criteria on local air pollutants in the annual road tax for cars and heavy-duty vehicles. The taxable benefit of using a company car for private purposes has not encouraged employees to drive less and there was no incentive for companies to buy cleaner vehicles or limit their use. The law on Tax Reform, enacted in December 2019, introduces environmental criteria in the tax treatment of personal use of company cars and provides incentives for the use of public transport. While the metro network is being extended in Athens and under construction in Thessaloniki, Greece should further develop incentives to commute by public transport or bicycle. Access restrictions for the most polluting vehicles in Athens and Thessaloniki are not enforced.

Greece is among the few OECD countries that do not raise revenue from other environmentally related taxes (single-use plastic bags is a recent exception). Collecting taxes on landfilling, as provided by the 2019 legislation on waste pricing, would encourage moving up the waste hierarchy (Section 1). There are also opportunities to better reflect environmental and resource costs in water charges, as envisaged by the 2017 law on water pricing, and to address diffuse pollution with taxes on fertiliser and pesticide.

Social tariffs have been introduced to improve the affordability of electricity and water services, but have not been effective in targeting the poorest6 (Marini et al., 2019). Greece developed an energy poverty observatory, which is a positive step to identify households in need. However, social tariffs distort prices, do not promote efficient resource use and reduce capacity for investment in key infrastructure. They could be replaced with direct payments, not linked to energy or water use, as part of the Social Solidarity Income programme supporting the poorest households since 2017. Supporting renovation of the building stock, as in the Saving at Home programme, and expanding gas central heating would also help alleviate energy poverty.

In a context of overall decline in investment, environmental protection7 has been particularly affected (OECD, 2019e). Public investment in waste and wastewater management collapsed during the crisis, rebounded over 2013-15 but has since fallen. EU funds are the main source of public investment. As part of the financial assistance programmes, the co-financing rate of Cohesion Policy programmes over 2007-13 was increased to make the national contribution negligible. Greece spent about 30% of EU funds8 for this period on roads. Only 13% was spent on environmental protection (mainly for wastewater treatment) and water supply in addition to 12% on energy saving and clean urban transport (EC, 2016). Projects on waste infrastructure, rail and public transport have been delayed by poor planning and limited capacity problems, notably for small municipalities, utilities and other local beneficiaries. Allocations to these areas were increased under the Operational Programme on Transport, Infrastructure, Environment and Sustainable Development 2014-209 to catch up with the backlog from the previous period and address high needs.

Greece should continue to strive to make the best use of EU funds to meet environmental goals. Investment worth EUR 1.6 billion is needed to ensure that urban wastewater is properly collected and treated (EC, 2019a). While nearly EUR 1.5 billion in EU funds is allocated to water and wastewater management over 2014-2010, projects have been delayed by the late adoption of the laws on water pricing and public procurement and the second round of River Basin Management Plans. Combined with a new system for benchmarking water utilities, these measures should help prioritise investment, improve water provision sustainability and enhance accountability and co-ordination of the sector (EC, 2019b).

Greece is actively promoting public-private partnerships in waste management, combining private capital and Cohesion Policy funds (European Parliament, 2017). However, investment in residual waste treatment seems too high, compared with investment in separate collection, sorting and recycling infrastructure (EC, 2019a). High operational expenditure on waste management (0.5% of GDP in 2016-17) is not reflected in the performance of services provided by municipalities, highlighting the need to better control costs.

Most GHG emission reductions to 2030 are expected to come from development of renewables-based electricity and energy efficiency improvement (Section 4). Related investment needs are estimated at more than 2% of 2018 GDP annually. As in other OECD countries, overly generous feed-in tariffs and decreasing costs have supported impressive growth in solar and wind power generation capacity, but changes in support policy have discouraged solar photovoltaic investment. In addition to a recent feed-in premium system, developing renewables will require investing in the grid to interconnect islands with the main network, where cost-effective, and in hybrid systems with energy storage technology for smaller islands (IEA, 2017). There is significant potential to improve energy efficiency in buildings, most of which were built without insulation. Beyond effective use of EU funds, developing private funding through energy performance contracts, as planned by the NECP, can help overcome limits on access to bank loans (Section 4).

The motorway network has doubled over the past decade. In 2017, investment in roads accounted for 2.3% of GDP, a higher share than in any other OECD country. This contributes to better connectivity and growth but does not support long-term climate targets. The shares of rail in passenger and freight transport are among the lowest in the EU. Despite significant funding to extend public transport systems, a lack of sustainable urban mobility plans and poor development of soft transport modes have resulted in continued reliance on cars. While the National Transport Plan 2019-37 projects increased investment in rail infrastructure, expected growth in transport activity means the dominance of road in the modal split is not expected to change significantly (MIT, 2019).

Despite significant progress in recent years, Greece’s eco-innovation performance is modest, ranking in the bottom third of EU countries in 2017 (EC, 2019c). The government research and development (R&D) budget on environment has increased since 2012 but the trend on energy is unclear (OECD, 2019f). While an information system is in place for public-funded R&D projects, there is no inventory of private spending on energy-related R&D or on beneficiaries and outcomes that would allow assessment of the technological outlook in the sector (IEA, 2017). In a context of limited green patent applications, those related to climate change mitigation (mostly energy generation, transmission and distribution) have been declining.

Important demonstration projects have been achieved thanks to EU research programmes. For example, Tilos island is now fossil-fuel free thanks to a pioneer hybrid system combining renewables and energy storage technology. Environmental issues, energy and transport are among the eight priorities11 of the 2015 National Research and Innovation Strategy for Smart Specialisation 2014-2020, which has been allocated EUR 1.1 billion in EU funding. However, there is a need to focus investment on Greece’s strengths and long-term needs. The 2018 Circular Economy Strategy, 2019 NECP and long term mitigation strategy provide opportunities to develop a coherent approach on eco-innovation.

More efforts are needed to monitor the transition to a circular and low-carbon economy. There is insufficient information on the environmental goods and services sector. While waste management accounts for a high share of total value added, circular economy sectors12 are underdeveloped compared with other EU countries. In 2017, the renewables industry provided employment for 25 000 people, twice the upper-bound estimate of coal-related jobs (EurObserv'ER, 2018) (Alves Dias et al., 2018). The NECP expects to create nearly 60 000 full-time jobs in the renewables and energy efficiency sectors (MoEE, 2019). National statistics need to be improved to support reallocation of labour from shrinking to growing activities.

Fragmented R&D policies, limited research activity, weak business participation and limited co-operation between academia and business are barriers to eco-innovation (MoEE, 2019) (EC, 2018b). The policy mix is mainly composed of financial R&D support while demand-side instruments, including regulations, standards and certification, are undermined by weak enforcement of environmental policies. GPP uptake is low (Section 2).

GHG emissions fell by 33% between 2005 and 2018. Greece achieved the second largest decline in the OECD over 2005-17. The financial and economic crisis, which reduced energy demand, explains much of the decline, although a shift from coal and oil towards natural gas and renewable resources also played a role. Greece surpassed its target for the first Kyoto Protocol commitment period of limiting the increase of GHG emissions (excluding those from LULUCF) to 25%, achieving a 17% rise over 2008-12 from 1990 levels (Figure 3). GHG emissions not covered by the EU ETS decreased by 28% between 2005 and 2018, putting Greece on track to meet its targets to reduce related emissions by 4% by 2020 and by 16% by 2030.

Greece’s emission profile is similar to that of most other OECD countries, with most emissions coming from energy use, notably power generation and transport. The LULUCF sector is a small net sink. Per capita emissions are below the OECD average. However, the economy’s carbon intensity is high owing to significant reliance on lignite for power generation and on oil for transport, heating and power generation on many islands. Greece does not use nuclear energy and is not considering this option. Lignite, which is particularly carbon intense, is the only significant domestic fossil fuel. Even though lignite use has declined, in line with climate targets, it still accounted for one-fifth of energy supply and one-third of electricity generation in 2018 (IEA, 2019).

In December 2019, the government endorsed an NECP with more stringent targets for 2030 than the EU requirement (MoEE, 2019). Greece should be commended for increasing its ambition, in line with the Paris Agreement. The NECP expects that emissions will decline primarily due to falling emissions from power generation, and that emissions in non-EU ETS sectors will slightly decrease from today’s level mostly thanks to energy efficiency measures in the residential sector (Figure 3). Emissions from transport are expected to decline only moderately.

Greece has also developed a Long-term Strategy to 2050 reviewing possible evolution of the energy system to bring the economy to a long-term net-zero emission pathway by mid-century (MoEE, 2020). According to projections, should the country achieve its 2030 goals, additional measures will need to be implemented. Continuation of NECP measures beyond 2030 would reduce total GHG emissions by 58% from 1990 levels by 2050. The expected intensification of these measures would lead to a 75% reduction.

The merger of the energy and environment ministries in 2009 raised the profile of climate change and facilitated integration of climate change, energy and air pollution policies, as recommended by the 2010 EPR. The MoEE now bears the main responsibility for national climate change mitigation and adaptation activities, while line ministries are responsible for implementing climate action in their areas. Inter-ministerial committees aim to facilitate collaboration among ministries and stakeholders. About one-third of Greek cities have developed climate change action plans through the Mayors for Climate and Energy initiative; several of them also cover adaptation activities.

Climate-related targets and goals are largely set by EU legislation. The NECP, which integrates climate objectives and energy planning up to 2030, is the most comprehensive document outlining how Greece plans to meet its mitigation commitments. It puts particular emphasis on the energy and energy-related sectors. However, mitigation policies in sectors other than energy could be further detailed (agriculture, LULUCF, transport, waste). In addition, Greece should specify options to enhance the LULUCF sink to achieve its long-term goal of carbon neutrality.

Greece’s GHG emission reporting complies with EU requirements and guidelines and those of the UN Framework Convention on Climate Change. Reports on mitigation efforts and progress made towards climate-related targets (e.g. on renewables and energy savings) are published regularly, in line with EU requirements. Nevertheless, oversight of climate policy development and implementation could be strengthened. Emission reduction trajectories of individual non-EU ETS sectors could be specified to ensure accountability in these sectors.

Mitigation efforts are focused on decarbonising energy industries, which accounted for 42% of national GHG emissions in 2017. The NECP sets an objective to diversify the energy mix and reduce its CO2 intensity while increasing energy security and making the sector more competitive. The NECP aims to reduce emissions in non-EU ETS sectors by 36% compared to 2005 levels, to reach a renewables share of at least 35% in gross final energy consumption and to limit final energy consumption to 16.5 million tonnes of oil equivalent by 2030. Most emission reductions are expected to be achieved through promotion of natural gas and renewables, interconnection of islands with the mainland grid and faster decommissioning of lignite power units.

Greece has seen remarkable growth in renewables. Their share in electricity generation increased from 11% in 2005 to 31% in 2018. This increase was driven by a boom in solar and wind that was supported by generous feed-in tariffs, lower technology costs and simplified licensing and permitting. In 2016, a feed-in premium programme was put in place to replace a feed-in tariff system that had become too costly, as in other OECD countries. Since 2018, the aid has been granted to specific solar photovoltaic and wind installations that have successfully participated in competitive bidding processes. The feed-in premium is more market-oriented than feed-in tariffs and should help bring down public support costs. The feed-in premium and auctions are considered the most important policy measures supporting renewables through 2030. To encourage decentralised renewables-based power generation, Greece is promoting energy communities through which citizens and/or local authorities own or participate in the production and/or use of renewables, as well as net metering, which offsets electricity costs for customers who generate their own power.

Interconnection of islands to the mainland electricity grid is a government priority that has considerable potential to foster renewables development, reduce emissions of GHGs and other air pollutants and increase energy security. Despite high renewables potential, the lack of storage systems results in many islands relying on diesel generators, which are both expensive and environmentally undesirable. Investment in renewables-based electricity generation combined with battery storage is the preferred alternative when interconnection is not cost-effective. Other priorities of the NECP include implementing the new electricity market model13 to facilitate participation of renewables, improving the licensing system and revising the spatial plan for renewables.

Stricter EU emission standards and increasing CO2 prices under the EU ETS make lignite-fuelled power generation increasingly expensive. The NECP outlines a roadmap for decommissioning all currently operating units (3.9 GW) over 2019-23. Ptolemaida V (0.7 GW), under construction, will be the only lignite power plant in operation beyond this date. Adjustments are being studied to fire it with other fuels by 2028 (energypress, 2019). As the new plant will need to acquire emission allowances under the EU ETS, there is a risk of it not being profitable without additional subsidies. Greece is starting to address the impact of the clean energy transition on lignite-producing areas through its engagement in the EU Coal Regions in Transition initiative and its Fair Transition Fund, which since 2018 has redistributed some revenue from EU ETS allowances to development activities in coal-dependent areas. Developing a Just Transition Plan will allow the country to get access to funding from the recently launched EU Just Transition Mechanism.

Improving energy efficiency should be a priority. Efficiency improvement was modest over the review period, as the economic situation, lack of funding and insufficient data limited the effectiveness of implemented measures. The establishment of energy audits (2016) and an energy efficiency obligation (EEO) programme (2017) are important steps in the right direction. The EEO programme is in pilot phase but could be strengthened for its second implementation period, starting in 2020. While Greece is on track to meet its 2020 energy savings targets, its 2030 target seems to require limited additional saving (-1.8%) compared to 2017 final energy consumption. There is potential for Greece to improve efficiency in its building stock. The NECP proposes improving the energy performance of between 12% and 15% of the current building stock by 2030, which corresponds to 60 000 buildings renovated annually until 2030. The 2018 long-term renovation strategy will have to be strengthened to decarbonise the building stock by 2050, as required by the revised EU Energy Performance of Buildings Directive.

Transport’s contribution to mitigation is expected to be relatively small, even though the sector accounts for nearly 20% of GHG emissions. Most reductions are expected to be achieved through increased use of biofuels. The NECP sets a target for electric passenger cars to reach a 30% share of new registrations by 2030, which is challenging given the limited deployment of such cars to date (0.3% of new cars sold in 2019). An Inter-ministerial Committee has been mandated to develop an operational electro-mobility development plan by 2020. Mitigation potential also lies in promotion of electric powering of docked ships. The NECP includes projections but no overall target for emission reductions in transport; a lack of information on estimated quantified emission reduction from envisaged measures limits transparency and accountability for climate action in the sector. Coherence with the National Transport Plan should be ensured.

As a Mediterranean country with thousands of islands, Greece is highly vulnerable to the impact of climate change (Barros, 2014). It has already experienced rising mean temperatures and changes in precipitation levels and is prone to extreme climate events such as heatwaves, fires (including a deadly 2018 event) and floods (Bank of Greece, 2011). By the end of the century, the decrease in precipitation levels is estimated to range from 5% to 19% countrywide while air temperature is projected to increase by between 3.0ºC and 4.5ºC. Sea level rise and freshwater shortage are the priority risks. Sea level rise is projected between 0.2 to 2 metres by 2100, rendering 1 000 km of Greece’s 18 400 km of coastline highly vulnerable to climate change.

To prepare for these risks, Greece has improved the evidence base on potential impact and vulnerability. The Bank of Greece published a comprehensive study with detailed climate projections and models of the environmental, social and economic impact. The study concluded that, without action, climate change may reduce GDP by up to 2% per year by 2050 and up to 6% by 2100.14 Agriculture is among the sectors expected to be hardest hit, but the impact on tourism and coastal areas will also particularly affect household income as well as the economy as a whole (Bank of Greece, 2011). An update of the study is envisaged for 2021. In addition, a geospatial database including climate data, maps and projections for the 13 regions is expected to be released online in 2020.

Greece has strengthened its policy and institutional framework for adaptation. The National Adaptation Strategy was formally endorsed through Law 4414/2016 (MoEE, 2016). It sets out general objectives, principles and implementation tools for adaptation and lists potential measures for 15 priority sectors identified in the Bank of Greece study. It does not provide for a national adaptation action plan. Instead, the 13 regions are expected to develop regional action plans, taking into account their circumstances and needs, to operationalise and implement the national strategy. The regional plans are required to identify local impact and vulnerabilities, prioritise actions based on their cost-effectiveness, identify synergies with other policies (e.g. land use), outline budget needs and potential finance sources, and include a mechanism to monitor progress. The relatively significant responsibility assigned to regional governments necessitates capacity building and cross-government co-ordination to align actions and share information and knowledge. A National Climate Change Adaptation Committee acts as the formal co-ordination and advisory body at the national level for adaptation policy monitoring, evaluation, formulation and implementation. It has been convened only once to date, however.

Progress has been made in considering adaptation in sector strategies, such as the National Biodiversity Strategy, the National Strategy for Forests, the Maritime Spatial Planning Law and the National Research and Innovation Strategy for Smart Specialisation. There is room, however, to clarify how the various objectives interact. The NECP, for example, does not outline how climate change may affect energy supply (e.g. through reduced hydropower potential, cooling water shortages and the impact on biomass resources) or how the plan will make the energy system more resilient. Plans call for such an analysis to feed into the 2023 NECP update. Implementation of adaptation measures in agriculture and water management plans remains to be assessed.

The Greek authorities expect the regional action plans, which will include sectoral activities, to facilitate integration of adaptation considerations. Once the plans are finalised, the MoEE will assess whether additional action is needed at the national level. While this bottom-up approach reflects and accounts for regional circumstances, it may delay national-level action, notably in sectors considered highly vulnerable (e.g. agriculture, tourism). It may also miss cross-cutting risks (e.g. concerning water, infrastructure, energy) and risks that go beyond regional boarders (e.g. regarding coastal zones, health). Nevertheless, the first results of the regional risk assessments, expected in June 2020, will provide a useful basis to inform national-level action. While climate resilience is considered in EIA, it is not explicitly mentioned in the national legislation on SEA (EC, 2018c).

Greece has yet to establish a monitoring and evaluation framework that would track integration of climate risk in sectoral policies, as well as the implementation and effectiveness of adaptation actions. It plans to develop a national framework in 2020, however, learning from other OECD countries such as Austria, Finland, Germany, Spain and the United Kingdom. There is also a need to build capacity and disseminate knowledge. The national adaptation committee could play a role in advising and supporting regional governments in developing their plans, identifying knowledge and action gaps at the sectoral level and establishing a monitoring and evaluation mechanism. Building on the experience of other OECD countries, such as France and Spain, Greece plans to establish a national adaptation platform or hub to inform target groups by 2020.

Greece is home to abundant European and Mediterranean flora and fauna, including a large number of endemic species, and a wide variety of ecosystems and habitats, many of which are of international interest.

The conservation status of habitats has improved in recent years (63% have favourable status), but more than half of species (55%) are in an unfavourable state (EC, 2019a). The main causes of biodiversity loss in Greece are natural system modifications, including urbanisation and habitat fragmentation, pollution, invasive alien species, climate change and fires. Key pressures come from agriculture, fisheries, transport and tourism (especially coastal).

Greater effort to improve biodiversity is urgently required in light of rising pressures, many of which stem from policies outside the purview of the MoEE, such as fisheries, agriculture and tourism.

Since the last EPR, Greece has made notable progress in improving its legal biodiversity framework. It issued important laws on biodiversity conservation (2011) and on management bodies of protected areas (2018). In 2017, the Natura 2000 network was expanded, especially with regard to marine areas, albeit starting from a low base, in order to address gaps in protected marine habitats and species.

The National Biodiversity Strategy and Action Plan (NBSAP, 2014) provides a solid framework with detailed targets and sub-targets to improve knowledge and the status of biodiversity and mainstream it into sectoral policies. Preparation of the new action plan beyond 2019 offers an opportunity to assess achievements and address remaining challenges, including updating the 2009 red list of threatened species.

Despite positive ad hoc initiatives aimed at filling data gaps, Greece has not yet established a comprehensive national monitoring system for biodiversity. The NBSAP includes targets for monitoring and evaluating its implementation, which should facilitate access to scientific knowledge regarding Greek flora and fauna and fill remaining data gaps.

As in many OECD countries, protected areas are the main regulatory instrument to protect biodiversity. According to national data, they cover an extensive share of terrestrial areas (32%), while marine protected areas account for 20%15 of territorial sea. Greece has thus largely achieved the 2020 Aichi target 11. To date few protected areas have management plans. The current objective is to develop management plans for all protected areas by 2022. Additional obstacles to effective management of protected areas are insufficient funding, especially in light of the expansion of territorial responsibilities under the 2018 law establishing management bodies for protected areas, and lack of capacity and awareness among authorities and the public (EC, 2019a). Capacity building and awareness raising are being done through LIFE Integrated Project LIFE-IP 4 NATURA, which should boost overall efforts.

Greece lacks an overarching framework for green infrastructure, which is also an NBSAP sub-target and a target of the EU 2020 Biodiversity Strategy. Further integration of biodiversity concerns into spatial planning would go a long way towards reducing illegal activities harmful to biodiversity and ultimately ensuring sufficient protection of habitats and species. There is not yet any legally binding national maritime spatial plan (EEA, 2019b), but Greece plans to develop its National Maritime Spatial Strategy in 2020. Economic instruments related to biodiversity are underused.

Greece needs to better mainstream biodiversity into economic sectors by making explicit links between ecosystem services, biodiversity conservation and sustainable resource use in key policy areas. NBSAP target 5 indicates the need to enhance synergies among the main sectoral policies for biodiversity conservation. The eight sub-targets focus on integration of biodiversity considerations into key sectors such as tourism, agriculture, fisheries and forestry.

As tourism expands in Greece, it will be increasingly important to create links between this sector and national biodiversity priorities. Tourism significantly contributes to the Greek economy in terms of direct GDP and employment, shares of which are among the largest in the OECD. The strongest environmental impact of tourism occurs in coastal areas due to infrastructure, including roads leading to tourist destinations, and overcrowding on beaches. The NBSAP includes actions to achieve the sub-target on compatibility of tourist activities with biodiversity conservation. To date, however, it is unclear where Greece stands with respect to this target. The development of the National Maritime Spatial Strategy in 2020, along with the updated Spatial Planning Framework for Tourism, could lead to more effective management of coastal and marine areas.

NBSAP actions related to mainstreaming biodiversity into agriculture are not very specific; they refer to improving sustainable management of agricultural ecosystems. Biodiversity mainstreaming into agriculture is mostly done through the Rural Development Programme (RDP). However, the net effects of agri-environmental measures of the RDP on biodiversity would require a more detailed assessment to improve their effectiveness under the next RDP. Unlike in other countries, there are no quantitative national targets on organic farming. The organic share in agricultural area increased from 7% in 2005 to 9% in 2018, above the 2017 OECD average (7%) (OECD, 2019g). It has grown less rapidly than in most countries despite significant EU support.

Fish stocks in 2015-16 indicated overfishing of hake in the Aegean Sea, while other species remained stable or increased (OECD, 2017b). Mainstreaming of biodiversity into fisheries is mainly done through regulatory instruments, including banning of drift nets and of pelagic trawling, and restricted areas for fish juveniles. In addition, fishing is restricted in certain areas to conserve marine habitats and protect endangered aquatic organisms. NBSAP targets include revising the regulatory framework for fisheries, based on conservation needs of species and habitat types, and enhancing port authorities’ ability to control illegal recreational fishing.

A National Forest Strategy was adopted for 2018-38. It identifies specific objectives as well as the necessary resources and means of implementation. It also endorses the Mediterranean forestry model in Greece's management of forest ecosystems, which aims at strengthening their multifunctional role. However, national data gaps on forestry make it difficult to determine forest cover and intensity of use. As of 2019, forest maps had been drafted for most of the country, and the objective is to complete the mapping by the end of 2020.


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← 1. An EU-wide cap is in place to reduce emissions in the ETS sectors by 21% from the 2005 level by 2020 and by 43% by 2030.

← 2. The programme was due by April 2019 according to 2016/2284/EU.

← 3. As of mid-2018, 14 illegal landfills were still in use, 24 sites were not in use but had not been restored, and 19 had been restored but not fully closed in accordance with the legal framework.

← 4. Only 19% of pesticide application equipment had been inspected by early 2018 while all equipment should have been tested by 2016 under the Sustainable Use of Pesticides Directive (2009/128/EC).

← 5. Partly due to more active substances being detected.

← 6. In 2018, less than half of Social Solidarity Income recipients took advantage of social tariffs on electricity and 10% benefited from social tariffs on water.

← 7. Including the following domains of the Classification of the Functions of Government: waste and waste water management, pollution abatement, protection of biodiversity and landscape, and R&D related to environmental protection.

← 8. Cohesion Fund and European Regional Development Fund, after decommitment and correction.

← 9. EUR 4.6 billion budget excluding national contribution. Environment and transport each account for half of the budget.

← 10. Under the various operational programmes.

← 11. Agrofood; life sciences and health – pharmaceuticals; information and communication technologies; energy; environment and sustainable development; transport and logistics; materials – construction; culture – tourism – cultural and creative industries.

← 12. The waste recycling sector, repair and reuse sector and rental and leasing sector.

← 13. Greece will introduce a forward, intraday, and balancing market over a transition period to 2020, to complement the day-ahead market.

← 14. The Bank of Greece study estimated that a mitigation scenario would cut this by 40% and an adaptation scenario by 20%.

← 15. Using harmonised international data for the denominator, the percentage of marine protected areas in Greece is less than 5% (OECD, 2019h).

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