Read here (in Greek) MedINA’s detailed comments and recommendations submitted as part of the public consultation process.
MedINA participated in the public consultation on the new Spatial Planning Framework for Renewable Energy Sources, submitting detailed comments and recommendations regarding the provisions for Small Hydropower Plants (SHPs).
Nearly two decades have passed since the adoption of the current framework. The new plan was therefore expected to address long-standing weaknesses and gaps that have been highlighted through scientific knowledge and recent biodiversity and nature restoration policies. However, MedINA’s submission underlines that the proposed provisions for SHPs largely remain aligned with the logic of the existing framework, without adequately addressing issues such as the effective protection of sensitive river ecosystems, the cumulative impacts of projects, the assessment of ecosystem carrying capacity, and adaptation to climate change.
In particular, MedINA’s comments highlight that:
- The National Energy and Climate Plan (NECP) foresees that SHPs will account for only 0.8% of the country’s energy mixof the country’s total installed RES capacity, while fragmenting Greek rivers through the development of more than 300 new projects.
- Of the SHPs that have already obtained a Producer Certificate, 34.5% (119 projects) are planned within the Natura 2000 network, while 64% of these are located on rivers of high ecological value.
- A key paradox of the new Spatial Plan is that the Ministry’s own Strategic Environmental Assessment (SEA) acknowledges the scale of the impacts: SHPs degrade aquatic habitats and obstruct fish migration. At a time when 42% of Europe’s freshwater fish species are already threatened with extinction and Greece hosts unique endemic species, the absence of a comprehensive and modern approach to the protection of flagship species raises serious concerns.
In this context, the need to protect free-flowing rivers is emphasised, in line with the objectives of the EU Biodiversity Strategy and the Nature Restoration Regulation.
Accordingly, MedINA calls for:
- The expansion of exclusion zones for SHP development by adding:
- Natura 2000 sites
- Protected Landscapes and Protected Natural Formations
- Free-flowing rivers
- The establishment of a clear and scientifically robust methodology for determining ecological flow requirements
- The national mapping of free-flowing rivers, with the aim of protecting them from degradation and fragmentation, in accordance with the EU Nature Restoration Regulation
- The adoption of meaningful carrying-capacity criteria for the evidence-based assessment of cumulative SHP impacts at the river basin level
- The integration of climate adaptation criteria and resilience assessments for both SHPs and river ecosystems under changing hydrological conditions
- A clear link between the siting and operation of SHPs and the objectives of the Water Framework Directive and River Basin Management Plans, to ensure non-deterioration and the achievement of good ecological status of water bodies
- The revision of the final and transitional provisions, so that the new spatial planning framework is effectively implemented and fully compatible with national and EU environmental legislation.
MedINA’s comments and recommendations aim to align renewable energy development with nature conservation through a planning approach that takes into account ecosystem resilience, the climate crisis, and increasing water scarcity.
The revision of the Spatial Planning Framework for Renewable Energy Sources represents a critical opportunity that must not be missed.
MedINA’s proposals seek to ensure that the development of green energy through SHPs goes hand in hand with the protection of water resources, biodiversity, and river ecosystems.