by Thymios Dimopoulos, GIS Specialist – Architect/MedINA Fanourios – Nikolaos Sakellarakis, Biodiversity and Ecosystems Expert/MedINA Alexandra Pappa, Freshwater Programme Manager/MedINA
The increased demand for energy production from Renewable Energy Sources (RES), expressed at European level through the European Green Deal and the REPowerEU project, intensifies the pressure for the construction of new hydroelectric power plants. At the national level, the new National Energy and Climate Plan (NECP), signed in 2019, foresees a 15% increase in installed capacity of hydroelectric power plants by 2030. One of the areas where strong interest has been expressed for the installation of new hydropower projects – exclusively through the creation of Small Hydropower Plants (SHPs) – is the Aoos River Basin in Epirus. The Aoos river basin consists of a complex of rivers, tributaries and streams that remain almost untouched to date. It is remarkable how in a period of great changes and increasing demands on water consumption, the Aoos (or Vjosa in Albanian) has retained this character and is today one of the last free-flowing rivers in the wider Balkan region, but also in Europe, excluding the Nordic countries (Sovinc, 2021)! Therefore, the imminent construction of numerous SHPs is today one of the greatest threats recorded in the Aoos river basin (Papaioannou et al., 2023).
Multiple protection regimes have been established to protect the rare species and ecosystems found in the Aoos river basin. Its largest part overlaps with the Northern Pindos National Park (NPNP) (Map 1), and it also includes thirteen (13) Natura 2000 sites (Map 2). Eleven (11) of the thirteen (13) Natura 2000 sites overlap with the NPNP. The remaining two (2), namely GR1320002 – ‘Peaks of Mount Grammos’ and GR2130010 – ‘Mount Duskon, Oreokastro, Meropi Forest, Gormos Valley, Lake Delvinakiou’ are situated in the borders with Albania, as depicted in Map 2. For these areas, Special Environmental Studies (SES) and Management Plans (MP) are currently being prepared by the Ministry of Environment and Energy (MEE), which will be eventually ratified via Presidential Decrees (PD). The SES 11a “Natura 2000 sites of the Regional Units of Thesprotia, Ioannina and Grevena” has been posted on the website of the Ministry of Environment for public consultation until 30/04/2023, while the SES for the Natura 2000 site “Peaks of Mount Grammos” is expected in the next period.
The question is, is the existing and proposed in the SES protection status adequate to address the challenges Aoos is currently facing? We raise this question specifically in relation to the threat posed to the river by the creation of SHPs, taking into account the rare species and ecosystems that exist in and around it and the local communities living and operating in the area. To properly address this issue, it is important to first present the permitting process for SHPs development.
Ι. Licensing procedure for SHPs
RES projects are implemented following the successful completion of a complex licensing process, which includes distinct stages of assessment and approval, involving different administrative authorities and bodies (Graph 1) . The stages are as follows:
Stage A: Production License
The Regulatory Authority for Energy (RAE) is the competent authority to examine the submitted application and issue, or not, the production license, according to the provisions of Law 3468/2006. It should be noted that for plants up to 1 MW no production license is required. RAE examines the existence of sufficient energy space in terms of saturation of the distribution network, considering potential overlap between different projects, their distance from other RES projects, and their compliance with the provisions of the Special Spatial Plan for RES (Government Gazette B 2464/03.12.2008) regarding zones of exclusion for RES installations. Accordingly, the production license confirms that an interested entity has validly registered its interest to construct a RES project in the geo-information system of RAE and has acquired the right to attempt to initiate the licensing process for the specific site, as described below.
Stage B: Environmental Licensing
This stage is the critical milestone in the licensing procedure of a RES project, where its environmental impacts are thoroughly examined and the feasibility of its implementation is being assessed. At this stage, the investor submits an Environmental Impact Assessment (EIA) study for category A projects (sub-categories A1 and A2), and if the study is approved, an EIA Approval is issued. It should be noted that category B projects are subject to compliance with Standard Environmental Commitments (SEAs) . The competent authority for issuing the EIA Approval is the Ministry of Environment for sub-category A1 projects, and the competent Decentralised Administration for sub-category A2 projects and the competent Region for category B projects. After EIA Approval, the binding Grid Connection Offer (GCO) is issued by ADMIE/DEDDIE, securing access to the electricity grid. The GCO specifies the point of the grid where the RES power plant will be connected, the required works for this purpose and their costs.
Stage C: Installation license
This license is issued either by the competent Decentralised Administration either by the Ministry of Environment and Energy, depending on the category of the project. The competent authority is bound to issue the Installation License, as far as a binding Grid Connection Offer has been obtained and various formal prerequisites have been met (such as payment of taxes and fees, securing land-use rights etc.). The Installation License grants the right to proceed with the construction of the project.
Stage D: Electricity Sales contract
Depending on the support scheme, the signing of an electricity sales contract with DAPEEP SA or DEDDIE SA is required. In the event that the RES investment is not subject to any state aid regime, then the sale of electricity is made by concluding bilateral Purchasing Power Agreements (PPAs) with Electricity Suppliers or through participation in the market by a RES Cumulative Representation Body (FOSE).
Stage E: Operation License
This is the last stage of the process, where the Operation License is issued following the construction and successful trial operation of the power plant.
ΙΙ. Current status of SHPs licensing in Aoos river basin
The total number of SHPs under different licensing stages in the Aoos river basin is currently 49 (Figure 1). Below we analyze the number of SHPs according to their licensing stage and planned construction site:
- SHPs in the final licensing stages with operation or installation license inside and outside the Northern Pindos National Park
- SHPs in early licensing stages with production license or under evaluation inside the Northern Pindos National Park
- SHPs in early licensing stages with production license or under evaluation inside Natura 2000 sites
- SHPs in early licensing stages with production license or under evaluation outside protected areas
SHPs in the final licensing stages with operation or installation license inside and outside the Northern Pindos National Park
To date, there are six (6) licensed SHPs within the Aoos river basin (Figure 2). Four (4) of them are operational/possess an operation license, and the other two (2) have obtained an installation license following EIA approval. Two (2) of the operational SHPs are in Giotsa stream, one (1) in Vourkopotamos stream and another one (1) on the stream that crosses the Skarvena bridge. Of the SHPs with installation license, one (1) is planned in Vourkopotamos stream and the other one (1) in Giotsa stream. Their location in relation to the Northern Pindos National Park is as follows: Three (3) of the operational SHPs are inside the NPNP and the other one (1) is on its external boundary. One (1) SHP that has installation license is situated inside the NPNP and the other one (1) outside (Figure 2).
SHPs in early licensing stages with production license or under evaluation inside the Northern Pindos National Park
One of the biggest imminent threats for Aoos river is the construction of new SHPs which are currently in the early licensing stages. Specifically, twenty eight (28) SHP projects have acquired a production license, gaining the right to initiate the licensing procedure, and fifteen (15) are under evaluation by the Regulatory Authority for Energy (RAE) (Figure 1). Their location in relation to the Northern Pindos National Park is as follows: Thirteen (13) SHPs with production license and four (4) under evaluation are located inside the NPNP. Among the thirteen with production license, two (2) are located in the peripheral zone of the NPNP (Figure 3).
SHPs in early licensing stages with production license or under evaluation inside Natura 2000 sites
Natura 2000 sites include Sites of Community Importance (SCI) according to the EU Directive 92/43/EEC and Special Protection Areas (SPA) according to EU Directive 79/409/EEC. These two categories often interlap (SCI-SPA). Any SHPs planned inside these areas are considered as projects of sub-categories A1 or A2 during the stage of environmental licensing, therefore being subject to Environmental Impact Assessment;, the competent authority for their environmental licensing is either the Ministry of Environment and Energy or the competent Decentralised Administration. As mentioned above (Map 2), Aoos river basin includes thirteen (13) Natura 2000 sites, the majority of which overlaps with the Northern Pindos National Park. There are twenty four (24) SHP projects located inside the Natura 2000 sites of Aoos river basin. Eleven (11) of them are also located inside the NPNP, while another eleven (11) are found in the Natura 2000 site “Grammos mountain Peaks”, one (1) in the Natura 2000 site “’Mount Duskon, Oreokastro, Meropi Forest, Gormos Valley, Lake Delvinakiou” and one (1) in the “Smolikas mountain Peaks” site near the boundary of the NPNP at Vourkopotamos stream. The majority of these projects are located in Sites of Community Importance (SCI or SCI-SPA) (Figure 4). These sites include priority habitat types of Annex I of Directive 92/43/EEC, which are a-priori exclusion zones according to the Special Spatial Plan for RES (Government Gazette Β΄ 2464/03.12.2008, article 14).
SHPs in early licensing stages with production license or under evaluation outside protected areas
Thirteen (13) SHP projects are planned in parts of the Aoos river basin that do not enjoy any kind of environmental protection status (Figure 5). Almost all of them are located in Sarantaporos sub-basin, which is entirely unprotected (Map 3 & Picture 1).
In addition, under the current legislation, SHPs which fall under category B of environmental licensing, do not require EIA Approval, but are only subject to Standard Environmental Commitments (SEAs) .
III. Proposed regulations of Special Environmental Study 11a for SHPs in the Aoos river basin
SES 11a addresses the Northern Pindos National Park and Natura 2000 sites in a unified manner, defining zones and land uses for all protected areas of the Aoos river basin, with the exception of Natura 2000 site “Mount Grammos Peaks” – GR1320002, which falls in the jurisdiction of another SES. According to Law 4685/2020, there are four (4) categories of protection zones, where different land uses are allowed. The zone with the highest degree of protection between those proposed by SES 11a is the Nature Protection Zone, where no RES projects are allowed. Then come the Habitat & Species Conservation Zones and the Sustainable Natural Resources Management Zones, where the SES allows only the construction of already licensed RES projects, subject to their EIA Approval and applicable legislation. At the same time, the rest of the Northern Pindos National Park is characterized as a Buffer Zone, and the area outside the National Park, namely the sections of the Aoos River and its tributaries which are currently unprotected, is designated as an Ecological Corridor. It should be noted that the construction of category B SHPs is allowed in the Buffer Zone, whereas SHP development is allowed in the proposed Ecological Corridor, subject to specific conditions. Taking into account the RAE data and the existing legal provisions, this means that in the Habitat & Species Conservation Zones and the Sustainable Natural Resource Management Zones, one (1) SHP with installation license will definitely proceed, four (4) SHPs that are under evaluation will be rejected, while for an additional thirteen (13) projects that have a production license we do not know if they have obtained EIA Approval, in order to be considered as already licensed or not. In the Buffer Zone where category B SHPs are allowed, there are two (2) projects with production license. Finally, regarding the proposed Ecological Corridor, the regulations proposed by the SES in fact give the green light to all 3 planned SHPs [one (1) has an installation license, one (1) has a production license and one (1) is under evaluation], as well as any future applications. In conclusion, considering the RAE data, and the proposed land use regulations of SES 11a for the Aoos river basin, there are four (4) SHPs with operation license, two (2) SHPs with installation license (one of which in the proposed Ecological Corridor), fifteen (15) SHPs that can be licensed under conditions, and thirteen (13) SHPs located within protected areas which may be licensed if they obtain EIA Approval before publication of the SES Management Plan in the Government Gazette, otherwise they will be rejected together with the four (4) SHPs currently under evaluation. The eleven (11) SHPs located within Natura 2000 site GR1320002 ”Peaks of Mount Grammos” will be regulated by the SES for this area.
The construction of all these SHPs inside and outside of the Northern Pindos National Park will undermine the national and transnational effort of recent years to protect the Aoos River as the last wild river in Europe, practically cancelling the recent commitments of the political leadership. Furthermore, it will put significant additional pressure on the populations of very important fauna and flora species and habitat types of Community and national interest. The vision of the ‘Save The Blue Heart of Europe’ campaign, of which the Mediterranean Institute for Nature and Anthropos (MedINA) has been a member since 2017, is to preserve the Aoos/Vjosa River and its tributaries in their wild and free-flowing character, keeping them free for nature and people. In this context, we have submitted our proposals to the public consultation of SES 11a proposing the prohibition of SHPs in in the entire Aoos river basin (including the main rivers, tributaries and streams). The public consultation is an opportunity for all of us, stakeholders and citizens, to express our views and arguments to keep the Aoos/Vjosa free-flowing. Aoos/Vjosa is the last wild and free-flowing river in Europe, excluding the Nordic countries, and it is our duty to hand it over to future generations in an even better state than the one handed over to us.
References:
Kati V., Petridou M., Theodoropoulos Y. & Bukas N. (2019). Contribution to biodiversity knowledge of the Aoos River Basin. Greece, Pindos Perivallontiki, 65pp.
Papaioannou H., Manolopoulos A., Petridou, M. & Kati V. (2023). Description of the Connectivity Conservation Area (CCA) in North-Western Greece: a PONT study. Charitakis Papaioannou EE. 109pp. Funded by the Prespa Ohrid Nature Trust (PONT).
Sovinc, A. (2021). Protection study of the Vjosa River Valley based on IUCN protected area standards. Belgrade, Serbia: IUCN. iv+40pp.