by Thymios Dimopoulos, GIS Specialist – Architect/MedINA,
Dimitris Papageorgiou, Ri-Connect Project Manager/MedINA
Alexandra Pappa, Freshwater Programme Manager/MedINA
Article editing: George Dimitropoulos, Urban Planner and Fundraising Officer/MedINA
On 27 November 2023, the Ministry of Environment and Energy designated the previously unprotected part of the Aoos River Basin, from the boundaries of the Northern Pindos National Park to the Greek-Albanian border, as a Protected Landscape and Protected Natural Formation. This is a very important, historic development for the Aoos, its biodiversity and communities, as it is the first time that the entire Aoos River Basin is institutionally protected under national or European law. Concerted efforts by the members of the “Save the Blue Heart of Europe” campaign and continuous support by our partnership through the projects “Save Europe’s last free-flowing river: Aoos/Vjosa” and “Ri-Connect: The Aoos River as a Transboundary Ecological Corridor” have contributed to this direction.
But what does this really mean for the Aoos and how does it affect the development of almost 50 Small Hydropower Plants (SHPs) planned in its catchment area? As part of our efforts to ensure that the Aoos River Basin has a uniform and effective protection regime, both at national and cross-border level, we attempt to answer this question, while documenting current data on SHPs in the Aoos River Basin, which remains the main threat to the river.
Below we present the current licensing status of SHPs in the Aoos River Basin, following the collection and analysis of data from the Geospatial Map of the Regulatory Authority for Energy (RAE), the Decentralised Administration of Epirus – Western Macedonia, the national Electronic Environmental Register, the aepo.ypeka.gr platform, the Municipality of Zagori, the Municipality of Konitsa, the Diavgeia portal and active citizens from the wider area.
As we have mentioned in the past, the process of monitoring the development of Renewable Energy Sources (RES) is particularly complex; the degree of difficulty appears higher in the case of the Aoos River Basin due to its geographical location. There is therefore a need to collect data on a platform that can be used to track the progress of each application.
Ι. Current licensing status of SHPs in the Aoos River Basin
Following up from our previous articles in March and July 2023, we examine the number of SHPs by licensing stage, according to the data collected from RAE. The table below shows the situation in March, July, and November 2023.
The total number of SHPs in the Aoos River Basin, currently in various licensing stages, according to RAE data, is forty-eight (48), of which four (4) have received an operation license, two (2) an installation license, thirty-three (33) a production license and nine (9) are under evaluation (Table 1 and Map 1). This total number remains unchanged from July 2023. Changes are recorded for the production licenses, which have decreased by two (2), and the applications under evaluation, which have increased by two (2).
Regarding the production licenses, three (3) were revoked and one (1) new permit was issued. The first revoked license is for a 15 MW project previously licensed at Agios Minas on the Sarantaporos River. The second is for a 2.62 MW project at Pyrgos, while the third is for a 1 MW SHP license at Rahovitsa on the Vourkopotamos River, which appears to have been withdrawn and resubmitted as a 0.5 MW project application for evaluation. The one (1) new production license granted is for a 0.48 MW SHP at Laista in the municipality of Zagori. Regarding new applications under evaluation, apart from the case at Rahovitsa, one new application appears at Klidonia in the municipality of Konitsa.
The total capacity decreased from 74.55 MW to 57.42 MW, mainly due to the revocation of the 15 MW license at Agios Minas.
As can be seen from the table above, cross-referenced with the official coordinates of the Protected Landscape and Protected Natural Formation as they appear in decision No. ΥΠΕΝ/ΔΔ ΦΠΒ/115155/3787 of the Director General for Environmental Policy of the Ministry of Environment and Energy (Government Gazette 6679 B/27-11-2023), a total of fourteen (14) SHPs fall entirely within this area: One (1) existing with an operation license, one (1) with an installation license, seven (7) with a production license and five (5) under evaluation. A further five (5) SHPs are located on the boundaries between different protection regimes, namely the Northern Pindos National Park or Natura 2000 sites and the Protected Landscape and Protected Natural Formation.
II. Production licenses with Environmental Impact Assessment (EIA) Approvals
Following the data presented in our previous article on the production licenses that have received an EIA Approval, in addition to the six (6) SHPs that have obtained an operation and installation license, data from the national Electronic Environmental Register and Diavgeia portal show that another six (6) SHPs have secured an EIA Approval as category A2 projects from the Decentralised Administration of Epirus – Western Macedonia. Compared to the data we had presented in July, one (1) additional SHP has been identified via aepo.ypeka.gr, having secured an EIA Approval since March 2020, with a capacity of 3.6 MW, at the Koukoumaneri stream of the Municipal Unit of Distrato.
Furthermore, one (1) SHP at the Vathylakkos stream of the Municipal Unit of Konitsa, with a capacity of 0.88 MW, appears to have an EIA Approval issued in November 2013. As EIA Approvals have a 10-year validity period, and since no relevant amendment/renewal decision has been published in the Electronic Environmental Register, the decision can be considered as out of force.
Summarising, there are currently a total of twelve (12) licensed SHPs in the Aoos River Basin (Map 2), six (6) of which are in the area designated as Protected Landscape and Protected Natural Formation (Table 2).
IV. Protected Landscape and Protected Natural Formation – The next day for Aoos
The designation of the Grammos – Konitsa – Pogoni area (i.e. the area between the Northern Pindos National Park and the Greek-Albanian border) as a Protected Landscape and Protected Natural Formation, is the first recognition of the importance of the Aoos River Basin as a single unified system. However, this positive development should not lead to complacency for the development of SHPs in this area, at least until the Minister of Environment and Energy issues a decision setting out specific development control regulations and restrictions for the area as stipulated in Article 178, Law 5037/2023.
With this decision, the Minister of Environment and Energy can block the development of eight (8) SHPs planned within the Protected Landscape and Protected Natural Formation which have not received an EIA Approval and clarify the situation regarding the six (6) SHPs that have an EIA Approval. The situation is similar in the protected areas of the Northern Pindos National Park and the Natura 2000 network, where threats such as the development of SHPs still exist, as the Special Environmental Studies and Management Plans of the protected areas have not yet been completed and the relevant Presidential Decrees have not been issued.
At the same time, the new Special Spatial Planning Framework for Renewable Energy Sources, which is still under development, will have to impose stricter conditions or even prohibit the development of projects such as SHPs in protected areas such as National Parks, Wildlife Refuges, Natura 2000 sites, Protected Landscapes and Protected Natural Formations.
In any case, the fragmentation of the Aoos River Basin by multiple institutional regimes does not ensure the protection of the river. Full protection of the Aoos and its tributaries will be ensured by the establishment of a single, uniform protection regime for the entire Aoos River Basin, that of a National Park. The expansion of the Northern Pindos National Park towards the Greek-Albanian border will allow for its unification with the neighboring Vjosa National Park, thus realizing the vision of the first Transboundary Wild River National Park in Europe, Aoos/Vjosa.
- Decentralized Administration of Epirus – Western Macedonia. https://www.apdhp-dm.gov.gr/
- Diavgeia portal, November 2023. https://diavgeia.gov.gr/
- Dimopoulos T., Pappa A. (2023). Small Hydropower Plants on Sarantaporos, Aoos and Voidomatis rivers, July 2023. https://med-ina.org/el/small-hpps-aoos-position-july23-gr/
- Dimopoulos T., Sakellarakis F.N., Pappa A. (2023) Small Hydropower Plants on Sarantaporos, Aoos and Voidomatis rivers, March 2023. https://med-ina.org/small-hpps-aoos-position/
- Electronic Environmental Register, November 2023. https://eprm.ypen.gr/
- Energy Register: Map of RES projects (2023). https://www.energyregister.gr/
- European Environmental Agency, November 2023. https://www.eea.europa.eu/data-and-maps/data/eea-coastline-for-analysis-2/gis-data
- Geospatial Map of the Regulatory Authority for Energy (RAE), November 2023. https://geo.rae.gr/
- Ministry of Environment and Energy/ΔΔ ΦΠB/115155/3787 “Characterisation of part of the Aoos River basin as a protected landscape and protected natural formation” (Government Gazette 6679/B/27-11-2023).
- Online platform for posting EIA Approvals, November 2023. aepo.ypeka.gr
Featured image: Autumn meanderings of the Sarantaporos river, tributary of Aoos, between the villages of Pyxaria and Exochi. More than 20 SHPs are planned upstream of this section © Dimitris Papageorgiou/MedINA.
This article was developed in the framework of the projects “Ri-Connect: the Aoos River as a transboundary ecological corridor”, implemented by MedINA and funded by PONT and “Aoos/Vjosa campaign”, coordinated by EuroNatur, implemented by MedINA and funded by Holdfast Collective.