Posted on May, 31 2022

The Greek climate law, which was voted on May 26^th, is marked with a double gap: its targets fall far short of the global target of limiting climate change to 1.5 ° C, in order to prevent the looming climate collapse (ambition gap), while it also lacks the necessary measures and policies that will guarantee front-loaded and smart fossil fuel phase-out (implementation gap). 

According to a joint statement issued by 11 environmental, humanitarian and labour organisations before its voting, Greece’s 4935/2022 “National climate law – Transition to climate neutrality and adaptation to climate change”: 

• Reiterates targets already in force under EU law, such as those set out in Regulation 2021/1119 establishing a framework for achieving climate neutrality. 
• Leaves open the door for rollback on the intermediate emissions reduction targets, instead of provisioning that they can only be improved in order to reflect a progression over time. (art. 8).
• States that more specific climate targets will be "pursued" in various sectors (art. 10 par. 1, par. (C)), but a specific and binding deadline is only set in relation to lignite phase-out (31.12.2028). The silence about the necessary end to all fossil fuels - with a few special exceptions (burning fuel oil on the islands, oil burners in buildings) – raises serious concerns about the prospects of new oil and gas exploration and drilling projects in many land and marine areas.
• Introduces measures of minimal ambition in relation to emissions reductions in buildings, and allows for significant exceptions.
• It provides for scientifically unsubstantiated exceptions to high carbon footprint sectors, such as land and air transport projects, ports, and energy and fuel transport projects from the obligation to reduce emissions by 30% (art. 19 par. 1).  

Some of the positive elements of the Greek climate law concern are the provisions about climate impact assessment as part of the environmental licensing process. Also positive, although they could be accelerated, are the ban on the installation of oil burners (1.1.2025), and the burning of fuel oil for electricity generation in non-interconnected islands (1.1.2030). Respectively, the proposals for the calculation of the carbon footprint and emissions reduction plans can be considered positive, but they need more clarity in terms of their transparency, comparability, accuracy and ultimately their reliability. 

A huge missed opportunity is the absence of provisions on:

• Nature: Unfortunately, nature conservation is not a priority and a component in the effort to mitigate the climate crisis. Mention to nature base solutions is limited to vague directions or as a tool for adaptation. 
• Climate democracy: Consultation and participation are not part of the climate law. There is no mention of the need for broad public engagement in critical parts of the decision making process, for example on the sectoral budgets. Participation in the context of the digital Climate Forum is limited to certain bodies (art. 27), while the composition of the National Council for Climate Change (art. 29) is limited and unrepresentative.
• Scientific independence: The role of the scientific community in the climate governance system is extremely weak. The bill should provide for an independent climate authority, which will not report to the political leadership of the ministry but to the Parliament.  
• Just transition to climate neutrality: The law does not contain anything substantial about the just transition of sectors and regions that will inevitably be affected by mitigation and adaptation strategies to climate neutrality. There is also no mention on the crucial chapter of just labor transition, which will provide a protective shield to the workers affected by the phasing out of fossil fuels.
• Energy democracy: No target for strengthening energy democracy and the role of citizens in producing clean energy for self-consumption. The targets of the European Commission’s REPowerEU plan to create at least one renewable energy community in every municipality with a population of over 10,000 by 2025 should be incorporated into the draft law which should be much more ambitious in terms of citizen participation in clean energy self-production. Accordingly, the necessary measures should be adopted to ensure the access of energy-poor and vulnerable consumers to solar energy while strengthening the role of solar strategy, which is virtually absent in this draft law.
• Solar strategy: The government must amend article 17, incorporating the REPowerEU targets and extending the measure for the mandatory installation of photovoltaics to:
• new public and commercial buildings (covering more than 250 sq.m.) until 2026
• existing public and commercial buildings (covering more than 250 sq.m.) until 2027
• all new residential buildings by 2029.

All new buildings must be "solar ready", hence improvements are needed in the law.

• Renewables: Absence of legally binding targets that will transform the energy system into 100% renewables by 2035 in terms of environmental sustainability and social justice, and will lay the foundations to overcome the technical obstacles to the expansion of the electricity network. new RES projects while promoting clean energy storage projects. The answer to the question "how many network expansion and storage projects will be needed to host final RES projects that by 2050 at the latest will produce the overwhelming percentage of the required energy in our country" is "what is needed". This should also indicate the ambition of a national climate law, especially in Greece, which can be an example of such projects for the rest of the EU.
• Energy savings: The climate law does not contain ambitious energy saving targets and does not provide incentives addressed to  citizens and economic sector. 
• Climate education: No reference is made to the need for climate and environmental education. Every substantial effort to tackle the climate crisis must include education planning that includes all levels and forms of education.
• Agri-food sector: The fact that a sector with a significant and ever-increasing contribution to the climate crisis, such as the agricultural and food sector, is completely absent. The gap needs to be filled with the necessary policies and actions combined with the removal of actions in the exact opposite direction. 

We also point out that the climate law was submitted to Parliament on the same day that the European Commission announced through the REPowerEU program the upgrade of its climate policy with enhanced targets for RES and energy efficiency, targeted measures for the production of RES by citizens and mandatory specifications in the building sector.  

The great challenge for Greece is the socially just, participatory, science-based and environmentally sound transition to climate neutrality. 

The organisations that formulated the initial proposal for a people-powered Greek climate law commit to further pursuing the development of a robust national climate policy framework which will align Greece with the 1.5oC target through socially just, science-based and nature positive policies.

The joint statement on the Greek climate law is signed by the following organisations:

1. General Confederation of Greek Workers
2. Doctors of the World Greece
3. Hellenic Society of Environment and Culture
4. Hellenic Society for the Protection of Nature
5. Hellenic League for Human and Civil Rights
6. Callisto
7. Nomos & Physis
8. Ecological Recycling Society
9. Greenpeace
10. MEDASSET
11. WWF Greece