By means of a detailed presentation to the parliamentarians, the environmental organization WWF Hellas raises a number of serious issues concerning the National Recovery & Resilience Plan which are important to be raised during the relevant discussion.

On the process, WWF Greece points out a serious lack of transparency and community participation, especially as the text which was presented in November 2020 to be discussed was a summary paper, while at the same time negotiations with the Commission concerning specific project proposals were taking place.

In the list of projects which were referred to in the plan, there are many which seem to have a positive environmental significance  (for example, the creation of a national system of tracking biodiversity and the digitalization of natural history associations, investments in energy, upgrading of existing buildings throughout the country, the transition to a sustainable transportation system and projects for the preservation and sustainable use of water resources). But for most of them though estimating the cost is impossible, as they are only mentioned as titles, which results in making it impossible to make a logical choice among those projects. Another major point of concern is that the list which was made public and presented in Parliament does not constitute the full package of works which will be included in the official submission of Greece to the EU for funding by the Recovery and Resilience Facility. There is even conflicting information and leaks to the media about projects of great environmental significance which will be submitted to the Commission, but do not appear on the list, while it is not clear if fossil gas projects will or will not be eventually included in the Greek proposal. Finally, a positive point is that in the end it seems waste incineration plants will not be included in the plan.

However, it seems that the plan is inadequate, in critical sectors of the circular economy, in investments that promote the participation of citizens in the energy transition, organic farming and in general sustainable food production, sustainable fisheries and the development of nature-based solutions, among other things. Therefore, we consider that the Recovery and Resilience Plan needs to be significantly improved before it is officially submitted to the European Commission for approval.

In the comments on the projects included in the summary table of reforms and investments, WWF Hellas points out that for the projects which are supported through the national recovery plan, it is necessary to ensure that any reduction in environmental protection procedures will be avoided.

WWF Greece requests each member of the Hellenic Parliament during the discussion to put the following points to the government and the relevant minister:
1. Given that there does not exist any declaration that the plan which was announced will be the official Greek submission for elaboration and approval by the EU, it is necessary that the government commit itself to the fact that there will not be any ‘surprises’. The list made public must be the final one and the addition of other activities must be avoided, especially in the case of projects of a great environmental impact.

2. It is necessary to exclude from the whole plan activities and projects which have a significant negative impact on the environment. Indicatively, economic activities and projects with a great environmental footprint are fossil fuel infrastructure, waste incineration, intensive fishing and agriculture without strict sustainability criteria.

3. The activities and the projects which will be promoted must be determined from the beginning with clear criteria of environmental sustainability.

4. Especially in relation to the possibility of projects being financed by the Recovery Fund, if such projects should be within Natura 2000 sites or other protected areas and have a significant impact on such areas, it is necessary to exercise continuous and persistent parliamentary scrutiny in response to  the country‘s obligation to properly implement and implement the due diligence procedure in accordance with directive 92/43/EEC. It is noted that the services of the Commission have already sent to Greece a request EU Pilot (EUP(2021)9806) relative to the incorrect transposition in the national legal order of article 6 para. 3 of the directive 92/43/EEC for the conservation of natural habitats as well as wild flora and fauna.

5. It is also essential to ensure that for the entire duration of the plan, licensing and development of projects on land or sea protected sites, all activities within these areas, the interactions of the sectors, must take into account the cumulative effects on ecosystems and species, and also their compatibility with national but also European or regional obligations and commitments.

FOR MORE INFORMATION:

Comments of WWF Hellas in the consultation on the strategic directions of the Greek Plan for Recovery and Sustainability
Comments of WWF Hellas in the Development Plan for the Greek Economy (Pissaridis Committee)
Building resilience: WWF recommendations for a just & sustainable recovery after COVID-1
Green Recovery for Blueprint for a green recovery in Greece)

 

Translation from Greek by Jeannette A. Arduino, We are looking for volunteers!