COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review Country Report - GREECE Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions The EU Environmental Implementation Review: Common Challenges and how to combine efforts to deliver better results
Date: 2017-02-03
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, EU initiative, Greece, application of EU law, environmental law, environmental protection, pollution control measures

EN 

   EN 

   EUROPEAN COMMISSION  Brussels, 3.2.2017  SWD(2017) 41 final   COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review Country Report - GREECE   Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions The EU Environmental Implementation Review: Common Challenges and how to combine efforts to deliver better results   {COM(2017) 63 final} {SWD(2017) 33 - 40 final} {SWD(2017) 42 - 60 final}  
 
 
Greece  2 

This  report  has  been  written  by  the  staff  of  the  Directorate-General  for  Environment,  European 
Commission. Any comments are welcome to the following e-mail address: ENV-EIR@ec.europa.eu  

More information on the European Union is available on the internet (http://europa.eu). 

Photographs: p.9 – ©LIFE09 ENV/GR/000294, p.11 – ©Dimitar Glavinov/iStock, p.17 – ©Maciej 
Noskowski/iStock, p.22 – ©Alexander Hafemann/iStock 

For reproduction or use of these photos, permission must be sought directly from the copyright holder. 

©European Union, 2017 

Reproduction is authorised provided the source is acknowledged. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Greece  3 

Table of Content 

EXECUTIVE SUMMARY .................................................................................................................................... 4 

PART I: THEMATIC AREAS ............................................................................................................................... 6 

1. 

TURNING  THE  EU  INTO  A  CIRCULAR,  RESOURCE-EFFICIENT,  GREEN  AND  COMPETITIVE  LOW-
CARBON ECONOMY ............................................................................................................................... 6 

Developing a circular economy and improving resource efficiency ..................................................... 6 
Waste management .............................................................................................................................. 7 

PROTECTING, CONSERVING AND ENHANCING NATURAL CAPITAL .............................................................. 10 

Nature and Biodiversity ....................................................................................................................... 10 
Green Infrastructure ........................................................................................................................... 12 
Soil protection ..................................................................................................................................... 12 
Marine protection ............................................................................................................................... 13 

3. 

ENSURING CITIZENS' HEALTH AND QUALITY OF LIFE .......................................................................... 14 

Air quality ............................................................................................................................................ 14 
 ................................................................................................................................................. 15 
Noise 
Water quality and management ......................................................................................................... 15 
Enhancing the sustainability of cities .................................................................................................. 17 
International agreements ................................................................................................................... 17 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS ..................................................................... 19 

4. MARKET BASED INSTRUMENTS AND INVESTMENT .................................................................................. 19 

Green taxation and environmentally harmful subsidies ..................................................................... 19 
Investments: the contribution of EU funds ......................................................................................... 20 

5. EFFECTIVE GOVERNANCE AND KNOWLEDGE ........................................................................................... 22 

Effective governance within central, regional and local government ................................................. 22 
Compliance assurance ......................................................................................................................... 23 
Public participation and access to justice ........................................................................................... 24 
Access to Information, knowledge and evidence ............................................................................... 25 

Environmental Implementation Report – Greece 

 
 
 
 
Executive summary 

Greece  4 

About the Environmental Implementation Review 

launched 

reports  describing 

the 
the  Commission 
In  May  2016, 
Environmental  Implementation  Review  (EIR),  a  two-year 
cycle  of  analysis,  dialogue  and  collaboration  to  improve 
the  implementation  of  existing  EU  environmental  policy 
and  legislation1.  As  a  first  step,  the  Commission  drafted 
28 
the  main  challenges  and 
opportunities on environmental implementation for each 
Member  State.  These  reports  are  meant  to  stimulate  a 
positive debate both on shared environmental challenges 
for  the  EU,  as  well  as  on  the  most  effective  ways  to 
address the key implementation gaps. The reports rely on 
the detailed sectoral implementation reports collected or 
issued  by  the  Commission  under  specific  environmental 
legislation  as  well  as  the  2015  State  of  the  Environment 
Report  and  other  reports  by  the  European  Environment 
Agency.  These  reports  will  not  replace  the  specific 
instruments  to  ensure  compliance  with  the  EU  legal 
obligations.  

The  reports  will  broadly  follow  the  outline  of  the  7th 
Environmental Action Programme2 and refer to the 2030 
related 
for  Sustainable  development  and 
Agenda 
Sustainable Development  Goals  (SDGs)3  to  the  extent  to 
which  they  reflect  the  existing  obligations  and  policy 
objectives of EU environmental law4.  

The  main  challenges  have  been  selected  by  taking  into 
account factors such as the importance or the gravity of 
the  environmental  implementation  issue  in  the  light  of 
the  impact  on  the  quality  of  life  of  the  citizens,  the 
distance to target, and financial implications. 

The  reports  accompany  the  Communication  "The  EU 
Environmental  Implementation  Review  2016:  Common 
challenges  and  how  to  combine  efforts  to  deliver  better 
results", which identifies challenges that are common to 
several Member States, provides preliminary conclusions 
on  possible  root  causes  of  implementation  gaps  and 
proposes  joint  actions  to  deliver  better  results.  It  also 
groups in its Annex the actions proposed in each country 
report to improve implementation at national level. 

General profile 

Greece  faces  significant  difficulties  in  implementing  EU 
environmental  legislation.  This  can  be  demonstrated  by 
the high number of infringement cases currently ongoing 

1  COM(2016)  316  final:  Communication  "Delivering  the  benefits  of  EU 
Environmental 
through 

regular 

a 

environmental 
policies 
Implementation Review". 

2 Decision No. 1386/2013/EU of 20 November 2013 on a General Union 
Environmental  Action  Programme  to  2020  "Living  well,  within  the 
limits of our planet". 

3 United Nations, 2015. The Sustainable Development Goals  
4 This EIR report does not cover climate change, chemicals and energy. 

against  the  country,  very  often  at  an  advanced  stage. 
is  the  area  where  the  biggest 
Waste  management 
problems  can  be  observed,  with  illegal  landfilling,  very 
low  recycling  rate  and  the  management  of  hazardous 
waste at the top of the list. Challenges remain in the field 
of urban waste water treatment, as well as regarding air 
quality,  particularly  in  urban  centres.  Greece  has  a  rich 
natural  environment 
create  numerous 
opportunities  for  sustainable  development  and  growth. 
However,  its  protection  needs  to  be  strongly  enhanced. 
Finally, 
that  complex 
administrative  structures  and  procedures  can  be  the 
cause  of  significant  delays  and  bottlenecks  and 
the 
sometimes 
implementation  of  environmental  legislation  in  Greece. 
Financing is also a significant issue, particularly for areas 
where EU funding is not available. 

it  can  often  be  observed 

the  main  obstacle 

represent 

that 

can 

for 

Main Challenges 

three  main 

The 
to 
implementation  of  EU  environmental  policy  and  law  in 
Greece are: 

challenges  with 

regard 

  Addressing  the  main  waste  management  problems 
(closure  of  illegal  landfills,  treatment  of  hazardous 
waste) as a matter of absolute priority. 

  Putting  in  place  an  efficient  national  system  for  the 
comprehensive  administration  and  functioning  of 
protected  areas,  raising  awareness  about  Natura 
2000  and  creating 
investments 
improving  capacity  of 
promoting 
competent 
effective 
environmental assessments at plan and project level, 
and  improving  enforcement  of  legislation  on  the 
ground. 

its  benefits, 
authorities, 

incentives 

ensuring 

for 

  Completing  implementation  of  the  Urban  Waste 
Water  Treatment  Directive,  giving  priority  to  those 
agglomerations  that  are  subject  to  an  infringement 
case. 

Main Opportunities 

Greece  could  perform  better  on  topics  where  there  is 
already a good knowledge base and good practices. This 
applies in particular to: 

 

Invest  in  separate  collection  and  recycling  and  use 
economic 
improve  the  country's 
overall  waste  management  performance,  which  can 
result in the creation of jobs and revenues.   

instruments  to 

  Effectively  protect,  restore  and  ensure  sustainable 
use of the country's natural capital, especially under 
the  Natura  2000  network,  so  as  to  maximise 
potential  benefits  deriving  from  ecosystem  services 
which  can  serve  as  powerful  economic  drivers, 

Environmental Implementation Report – Greece 

 
 
                                                            
including 
sustainable activities. 

through  green 

tourism  and  other 

  Simplify  administrative  procedures  and 

improve 
cooperation  of  public  authorities  involved  in  the 
application  of  environmental  policies,  which  will 
allow for smoother and quicker implementation. 

Points of Excellence 

Greece  5 

leader  on  environmental 
Where  Greece 
implementation,  innovative  approaches  could  be  shared 
more widely with other countries. Good examples are: 

is 

a 

  According  to  the  EEA  report  'European  Bathing 
Water  quality  in  2015,  97.2  %  of  bathing  waters  in 
Greece were of excellent quality. 

  Greece  reaches  very  high  compliance  rates  of  99-
100%  for  microbiological,  chemical  and  indicator 
in  the  Drinking  Water 
parameters 
Directive. 

laid  down 

  Greece  made  good  and  early  use  of  LIFE  funds  for 
proposing  a  substantial  national  list  of  sites  for 
Natura  2000  under  the  Habitats  Directive.  Close 
collaboration  of  authorities  and  conservation  NGOs 
in  some  cases  has  allowed  building  expertise  and 
putting in place effective measures in specific areas. 

Environmental Implementation Report – Greece 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Part I: Thematic Areas 

1. Turning the EU into a circular, resource-efficient, green and 

competitive low-carbon economy 

Greece  6 

Developing a circular economy and improving 
resource efficiency 

The 2015 Circular Economy Package emphasizes the need 
to  move  towards  a  lifecycle-driven  ‘circular’  economy, 
with a cascading use of resources and residual waste that 
is  close  to  zero.  This  can  be  facilitated  by  the 
development  of,  and  access  to,  innovative  financial 
instruments and funding for eco-innovation. 

SDG  8  invites  countries  to  promote  sustained,  inclusive 
and  sustainable  economic  growth,  full  and  productive 
employment  and  decent  work  for  all.  SDG  9  highlights 
the  need  to  build  resilient 
infrastructure,  promote 
inclusive  and  sustainable  industrialization  and  foster 
innovation.  SDG 12  encourages countries  to  achieve  the 
sustainable  management  and  efficient  use  of  natural 
resources by 2030. 

Measures towards a circular economy  

Transforming our economies from linear to circular offers 
an  opportunity  to  reinvent  them  and  make  them  more 
sustainable  and  competitive.  This  will 
stimulate 
investments and bring both short and long-term benefits 
for the economy, environment and citizens alike.5 

Environmental policy in Greece focuses on the promotion 
of  renewable  energies  and  energy  efficiency  measures, 
which  can  promote  eco-innovations.  These  measures, 
along  with  the  new  national  Waste  Management  Plan 
(WMP)  can  facilitate  the  transition  towards  a  circular 
economy.  

in  2010,  whose 
Greece  established  a  Green  Fund 
objective  is  to  stimulate  growth  through  protecting  the 
environment  and  providing  support  for  environmentally 
friendly projects and initiatives.  

Greece  is  performing  below  EU  average  in  terms  of 
resource productivity6 (how efficiently the economy uses 
material resources to produce wealth), with 1.35 EUR/kg 
(EU average is 2) in 20157. Figure 1 shows that Greece's 
resource productivity has increased steadily but modestly 
since  2007.  Resource  productivity  has  increased  slightly 
compared to 2014. 

5 European Commission, 2015. Proposed Circular Economy Package 
6 Resource productivity is defined as the ratio between gross domestic 

product (GDP) and domestic material consumption (DMC). 

7 Eurostat, Resource productivity, accessed July 2016 

Figure 1: Resource productivity 2003-158 

The  Operational  Programme  on  Competitiveness, 
Entrepreneurship  and  Innovation  under  the  new  NSRF 
(2014-2020)  will  allocate  EUR  28.8  million  on  the 
promotion  of  innovative  technologies  for  environmental 
protection  and resource  efficiency  in  the  areas  of  waste 
management,  water  management,  soil  contamination 
and  air  pollution.  The  support  will  include  research  & 
development  (R&D)  activities 
in  businesses  for  the 
development  and  uptake  of  antipollution  technologies 
and  monitoring  mechanisms.  Another  EUR  28.3  million 
will  be  allocated  to  supporting  green  growth  and  eco-
innovation  both  in  the  private  and  public  sectors.  The 
supported  activities  will  include  actions  to  increase  the 
technological  know-how  on  environmental  protection 
and the eco-design of products.    

SMEs and resource efficiency 

According to the Flash 426 Eurobarometer, the resource 
efficiency actions undertaken by Greek SMEs allowed the 
reduction of production costs for 65% of them. 

The Flash Eurobarometer shows that 48% of the SMEs in 
Greece have one or more full time employee working in a 
green  job9  at  least  some  of  the  time.    Greece  has  an 
average  number  of  2.8  full  time  green  employees  per 
SME.  

8 Eurostat, Resource productivity, accessed October 2016 
9  The  Flash  426  Eurobarometer  "SMEs,  resource  efficiency  and  green 
markets"  defines  "green  job"  as  a  job  that  directly  deals  with 
information,  technologies,  or  materials  that  preserves  or  restores 
environmental  quality.  This  requires  specialised  skills,  knowledge, 
training, or experience (e.g. verifying compliance with environmental 
legislation,  monitoring  resource  efficiency  within  the  company, 
promoting and selling green products and services). 

Environmental Implementation Report – Greece 

 
 
 
                                                            
                                                            
 
Eco-innovation  

As illustrated in Figure 2, with a score of only 72 (on an 
EU-28  average  of  100),  Greece  ranks  seventh  from  the 
bottom in the EU-28 ranking of eco-innovative countries.  
Figure 2: Eco-Innovation Index 2015 (EU=100)10 

Greece continues to lack a clear and cohesive framework 
for  the  support  of  eco-innovation  and  eco-industries. 
Nevertheless,  the  framework  has  improved  through  the 
2014 Action Plan for the Implementation of the National 
Strategy  for  Research,  Technological  Development  and 
Innovation  for  the  period  2015-2021,  which  promotes 
specific activities in relation to eco-innovation.   

The long-lasting deterioration of the economy has made 
any  kind  of  systematic  funding  for  eco-innovation 
unrealistic. Austerity policies have had a major impact on 
public  funding  leading  to  stagnation  in  terms  of  R&D 
expenses and delays in payments.  

that  Greece’s 

On  the  administrative  side,  it  is  an  often  repeated 
complaint 
bureaucratic 
stipulations  (despite  the  progress  achieved  in  the  last 
years)  dissuade  if  they  do  not  prevent  actors  and 
investors  from  developing  eco-innovations11.  Moreover, 
the  regulatory  framework  changes  frequently,  thus 

complex 

Greece  7 

limiting the ability of involved actors to plan and organise 
investments.  

Finally,  social  barriers  towards  eco-innovation  remain, 
mostly  related  to  public  attitudes  and  ignorance  of  the 
benefits  of  innovation  (especially  in  the  area  of  energy 
efficiency in the built environment)12.  

In  the  past  2  years,  efforts  to  introduce  eco-innovations 
in  the  construction  sector  have  continued.  Due  to  the 
economic  crisis,  companies  have  sought  to  explore 
opportunities  afforded  by  eco-innovation 
focusing 
(amongst others) on transparent solar cells which can be 
used  in  windows,  nanotechnology  products  to  improve 
indoor air quality and smart meters for energy efficiency. 
The  size  of  the  sector  was  reduced  further  due  to  the 
economic crisis and its share dropped from 7% of GDP in 
2007  to 2.9% of  GDP in  2014.  As  a  result, the uptake  of 
eco-innovation also decreased. 

Greece also benefits from its significant natural capital in 
renewable energies – solar, wind, tidal – growth in green 
and alternative tourism and innovation in agriculture and 
the food industry.  

Suggested action 

  Incentivise  the  savings  of  energy  and  water  and 

increase the level of recycling among SMEs. 

  Facilitate the development of eco-innovation initiatives 

in the country, especially at the local level. 

Waste management  

Turning waste into a resource requires: 
 

implementation  of  Union  waste 

legislation, 
Full 
which  includes  the  waste  hierarchy;  the  need  to 
ensure  separate  collection  of  waste;  the  landfill 
diversion targets etc. 

  Reducing  per  capita  waste  generation  and  waste 

 

generation in absolute terms. 
Limiting energy recovery to non-recyclable materials 
and  phasing  out 
recyclable  or 
recoverable waste. 

landfilling  of 

SDG  12  invites  countries  to  substantially  reduce  waste 
generation  through  prevention,  reduction,  recycling  and 
reuse, by 2030. 

The EU's approach to waste management is based on the 
"waste  hierarchy"  which  sets  out  an  order  of  priority 
when  shaping  waste  policy  and  managing  waste  at  the 
operational 
level:  prevention,  (preparing  for)  reuse, 
recycling,  recovery  and,  as  the  least  preferred  option, 
disposal  (which 
incineration 
includes 
without energy recovery). 

landfilling  and 

The  progress  towards  reaching  recycling  targets and the 

10 Eco-innovation Observatory: Eco-Innovation scoreboard 2015 
11  Valavanidis  A.  et  al.,  2015,  Atmospheric  Pollution  in  Urban  Areas  of 
Greece  and  Economic  Crisis.  Trends  in  air  quality  and  atmospheric 
pollution data, research and adverse health effects.  

12 Knight and Bell, 2013 

Environmental Implementation Report – Greece 

 
 
                                                            
                                                            
adoption  of  adequate  WMP/WPP13  should  be  the  key 
items  to  measure  the  performance  of  Member  States. 
This  section  focuses  on  management  of  municipal 
waste14,  for  which  EU  law  sets  mandatory  recycling 
targets. 

The  waste  management  situation  in  Greece  is  a  major 
structural  problem.  As  shown  in  Figure  3,  municipal 
waste  generation  in  Greece  has  remained  at  the  same 
level  over  the  past  few  years,  being  now  (2013  figures) 
slightly  over 
(510kg/y/inhabitant 
compared  to  EU  average  of  around  477  kg).  Greece 
landfills  the  majority  of 
its  municipal  waste  (81%, 
compared  to  31%  for  EU-28  average),  with  only  16% 
being recycled (EU-28 – 27%) and 4% composted (EU-28 
– 15%).  

the  EU  average 

Figure 3: Municipal waste by treatment in Greece 2007-
1315 

In  addition,  Greece  decreased 

Greece has failed to comply with the first (2010) landfill 
diversion  target. 
its 
packaging waste recycling in 2013 (from 58.6% in 2012 to 
52.4%  in  2013).  Therefore,  the  country  is  no  longer 
meeting the packaging waste recycling target of 55%. As 
shown  in  Figure  4,  Greece  has  not  yet  reached  the 
recycling target. Only if it steps up its efforts significantly 
will  it  be  able  to  up  recycling  rates  to  reach  the  50% 
recycling target by 202016. 

13Waste Management Plans/Waste Prevention Programmes 
14Municipal  waste  consists  of  waste  collected  by  or  on  behalf  of 
municipal  authorities,  or  directly  by  the  private  sector  (business  or 
private non-profit institutions) not on behalf of municipalities.  

15Eurostat, 

http://ec.europa.eu/eurostat/documents/2995521/7214320/
8-22032016-AP-EN.pdf/eea3c8df-ce89-41e0-a958-
5cc7290825c3. 

16 Member States may choose a different method than the one used by 
ESTAT (and referred to in this report) to calculate their recycling rates 
and  track  compliance  with  the  2020  target  of  50%  recycling  of 
municipal waste. 

Figure 4: Recycling rate of municipal waste in 2007-1317 

Greece  8 

A  landfill  tax  has  been  in  force  since  1  January  2014. 
However, its effective implementation remains unclear to 
date.  In  addition,  despite  the  major  waste  management 
problems  the  country  needs  to  address,  only  5%  of  the 
landfill  tax  revenues  are  to  be  allocated  for  support  to 
local  authorities  to  improve  their  waste  management 
performance,  with  the  rest  being  devoted  to  the 
reimbursement  of  the  public  debt.  The  use  of  economic 
instruments  is  insufficient  and  the  existing  schemes  are 
performing poorly. 

(EPR)  schemes 

Additional  measures  will  be  needed  to  promote  the 
diversion  of  biodegradable  waste  from  landfill  and  to 
establish  and  control  separate  collection  infrastructure 
and  schemes,  specifically  to  implement  door-to-door 
separate collection. There are limited Extended Producer 
Responsibility 
(few  waste  streams 
covered) or equivalent systems in place, not able to cover 
the  full  costs  of  separate  collection  and  recycling  of  the 
main waste streams. No incentive systems exist to favour 
prevention and participation to separate collection (PAYT 
schemes)  and  no 
local 
authorities to develop separate collection. Care must be 
taken  not  to  move  from  landfilling  to  poor  quality 
Mechanical and Biological Treatment installations. 

incentives  are  provided  for 

Addressing the issue of illegal landfilling is a key priority, 
as  whilst  illegal  landfills  remain  open  (or  new  ones  are 
being created), it is difficult to make an economic success 
of legal waste management operations and the jobs and 
growth  potential  of  the  recycling  sector  cannot  be 
realised.  The  proper  treatment  of  hazardous  waste 
throughout the country is of equal importance. 

As  regards  the  EU  structural  and  cohesion  funds  for  the 
programming period 2014-2020, Greece has foreseen the 
allocation of significant amounts for waste management 

17 Eurostat, Recycling rate of municipal waste, accessed  October  2016. 

For Greece, 2014 data were not available. 

Environmental Implementation Report – Greece 

 
 
                                                            
 
  
                                                            
projects.  However,  as  at  the  time  of  adoption  of  the 
Operational Programmes the country had not fulfilled the 
relevant  ex-ante  conditionality  (T0  6.2),  it  submitted  an 
action  plan  and  added  a  clause  of  self-suspension  of 
funds  for  waste  management  projects,  until  a  new 
national  Waste  Management  Plan  and  a  Waste 
Prevention  Programme  in  line  with  the  requirements  of 
the Waste Framework Directive were put in place. 

Greece  9 

collection and alternative infrastructure in conjunction 
with a better allocation of the cohesion policy funds to 
the  first  steps  of  waste  hierarchy.  Avoid  building 
excessive  infrastructure  for  the  treatment  of  residual 
waste. 

  Invest  in  separate  collection,  sorting  and  recycling 
(including composting) in the coming years, in order to 
reach the 2020 recycling target. 

  Extend and improve the cost-effectiveness, monitoring 
and  transparency  of  existing  EPR  schemes  and 
eliminate free-riding 

  Complete  missing  Waste  Management  Plans  in  order 

to cover the whole territory. 

The  Waste  Prevention  Programme  was  adopted  in  2014 
and the National Waste Management Plan (not covering 
all  waste  streams)  in  December  2015.  According  to 
national  legislation,  the  updating  of  Regional  Waste 
Management  Plans  in  line  with  the  national  one  is  also 
obligatory  –  the  13  Regional  Plans  were  expected  to  be 
ready  by  the  end  2016  and  some  were  adopted  by  that 
time. 

Improving 
its  waste  management  performance, 
preventing  and  reducing  waste  generation  as  well  as 
improve 
increasing  reuse  and  recycling  rates  will 
resource  efficiency  of  the  Greek  economy,  create  jobs 
and provide business opportunities. Full implementation 
of the existing legislation could create more than 15,900 
jobs  in  Greece  and  increase  the  annual  turnover  of  the 
waste  sector  by  EUR  1.675  million.  Moving  towards  the 
targets  of  the  Roadmap  on  resource  efficiency  which 
outlines how we can transform Europe's economy into a 
sustainable  one  by  2050,  could  create  over  19,000 
additional  jobs  and  increase  the  annual  turnover  of  the 
waste sector by almost two million euros18. 

Suggested action 

  Address  the  issues  of  closure  and  rehabilitation  of 
illegal  landfills  and  of  the  treatment  of  hazardous 
waste as matters of absolute priority. 

  Properly enforce and gradually increase landfill taxes to 
phase-out  landfilling  of  recyclable  and  recoverable 
waste.  Use  the  revenues  to  support  the  separate 

18 Bio Intelligence service, 2011. Implementing EU Waste legislation for 
Green Growth, study for European Commission. The breakdown per 
country on job creation was made by the consultant on Commission 
demand but was not included in the published document. 

Environmental Implementation Report – Greece 

 
                                                            
 
 
Protecting, conserving and enhancing natural capital 

Greece  10 

Nature and Biodiversity  

The  EU  Biodiversity  Strategy  aims  to  halt  the  loss  of 
biodiversity  in  the  EU  by  2020,  restore  ecosystems  and 
their services in so far as feasible, and step up efforts to 
avert  global  biodiversity  loss.  The  EU  Birds  and  Habitats 
Directives  aim  at  achieving  favourable  conservation 
status of protected species and habitats.  

SDG  14  requires  countries  to  conserve  and  sustainably 
use the oceans, seas and marine resources, while SDG 15 
requires  countries  to  protect,  restore  and  promote  the 
sustainable  use  of  terrestrial  ecosystems,  sustainably 
manage  forests,  combat  desertification,  and  halt  and 
reverse land degradation and halt biodiversity loss. 

The  1992  EU  Habitats  Directive  and  the  1979  Birds 
Directive are the cornerstone of the European legislation 
aimed  at  the  conservation  of  the  EU's  wildlife.  Natura 
2000, the largest coordinated network of protected areas 
in  the  world,  is  the  key  instrument  to  achieve  and 
implement the Directives' objectives to ensure the  long-
term  protection,  conservation  and  survival  of  Europe's 
most  valuable  and  threatened  species  and  habitats  and 
the ecosystems they underpin. 

The  adequate  designation  of  protected  sites  as  Special 
Ares  of  Conservation  (SAC)  under  the  Habitats  Directive 
and  as  Special  Protection  Areas  (SPA)  under  the  Birds 
Directive 
is  a  key  milestone  towards  meeting  the 
objectives  of  the  Directives.  The  results  of  Habitats 
Directive Article 17 and Birds Directive Article 12 reports 
and  the  progress  towards  adequate  Sites  of  Community 
Importance (SCI)-SPA and SAC designation19 both in land 
and  at  sea,  should  be  the  key  items  to  measure  the 
performance of Member States. 

27.9%  of  the national  land area of  Greece  is  covered  by 
Natura  2000  (EU  average  18.1%),  with  Birds  Directive 
SPAs  covering  20.94%  (EU  average  12.3%)  and  Habitats 
Directive  SCIs  covering  16.21%  (EU  average  13.8%)20. 
Greece  has  so  far  designated  419  Natura  2000  sites, 
including  241  SCIs  under  the  Habitats  Directive  and  202 
SPAs under the Birds Directive. 

While  the  terrestrial  part  of  the  Greek  Natura  2000 

19 Sites of Community Importance (SCIs) are designated pursuant to the 
Habitats  Directive  whereas  Special  Areas  of  Protection  (SPAs)  are 
designated  pursuant  to  the  Birds  Directive;  figures  of  coverage  do 
not add up due to the fact that some SCIs and SPAs overlap. Special 
Areas of Conservation (SACs) means a SCI designated by the Member 
States. 

20 Sites of Community Importance (SCIs) are designated pursuant to the 
Habitats  Directive  whereas  Special  Areas  of  Protection  (SPAs)  are 
designated pursuant to the Birds Directive; figures do not add up due 
to  the  fact  that  some  sites  are  designated  as  both  SCIs  and  SPAs. 
Special Areas of Conservation (SACs) means a SCI designated by the 
Member States. 

is 

network 
largely  complete,  the  marine  part  still 
presents significant insufficiencies in terms of designation 
both of SCIs and SPAs21 (see Figure 5).  

For  239  SCIs  the  6-year  deadline  laid  down  by  the 
Habitats  Directive  for  designating  them  as  Special  Areas 
of  Conservation  (SACs)  and  establishing  appropriate 
conservation objectives and measures has expired, but as 
of April 2016, Greece had not fulfilled these obligations.  

Figure  5:  Sufficiency  assessment  of  SCI  networks  in 
Greece  based  on  the  situation  until  December  2013 
(%)22  

SPAs benefit from horizontal protection measures under 
national  legislation,  but  a  number  of  key  implementing 
acts necessary to enact legal provisions are still missing.  

Greece has adopted a sound and comprehensive law on 
biodiversity23 and a national biodiversity strategy24 based 
thereon. Neither is significantly implemented. 

Management plans and other site protection tools (legal 
acts,  management  bodies)  have  been  developed  for  a 
number of sites, in most cases through LIFE or European 
Regional  Development  Fund  (ERDF)  financing.  However, 
few are actually being implemented in a coordinated and 
stable way.  

21For each Member State, the Commission assesses whether the species 
and  habitat  types  on  Annexes  I  and  II  of  the  Habitats  Directive,  are 
sufficiently  represented  by  the  sites  designated  to  date.  This  is 
expressed as a percentage of species and habitats for which further 
areas need to be designated in order to complete the network in that 
country. The current data, which were assessed in 2014-2015, reflect 
the situation up until December 2013. 
22 European Commission, internal assessment. 
23 Law 3937/2011 
24 Ministerial Decision 40332/2014 

Environmental Implementation Report – Greece 

 
 
                                                            
 
                                                            
Greece  11 

latest  report25  of  Greece  on  the 
According  to  the 
conservation  status  of  habitats  and  species  covered  by 
the Habitats Directive26, only 60% of the assessments for 
Mediterranean  habitat  types  and  13%  for  species 
indicate  a  favourable conservation  status,  while  for  65% 
of  the  species  and  20%  of  marine  habitats  the  status  is 
unknown27. This is depicted in Figure 6. 

Figure 6: Conservation status of habitats and species in 
Greece in 2006 (%)28 

objectives of the Nature Directives.  

These  deficiencies  are  illustrated  by  the  high  number  of 
complaints and infringement cases on issues such as the 
degradation  of  designated  sites,  poor  quality  of 
Appropriate  Assessments  under  Article  6(3)  of  the 
Habitats  Directive,  lack  of  strategic  assessments  and 
insufficient  protection  of  species  and  habitats,  also  as  a 
result of illegal activities.   

The  main  causes  of  loss  of  biodiversity  in  Greece  are 
related 
to  past  and  current  policies  concerning 
unsustainable land  use,  agriculture,  fisheries,  forest  use, 
transport,  tourism  and  production  and  consumption 
patterns. 

In  2014  Greece  adopted 
its  National  Biodiversity 
Strategy,  which  officially  refers  to  ecosystem  services. 
The  project  "Towards  a  Natural  Capital Accounting"  was 
officially  approved.  The  Hellenic  Ecosystem  Services 
Partnership  (researchers,  Civil  Society  Organisations, 
decision  makers  and  professionals  dedicated  to  the 
research  into  and  application  of  Ecosystem  Services29  in 
the Greek part of the Mediterranean Basin) is involved in 
this project. 

Suggested action 

  Complete  site  designations,  especially  in  the  marine 
part,  and  put  in  place  clearly  defined  conservation 
objectives  and  measures  for  the  sites  that  are 
adequately resourced. Strengthen communication with 
stakeholders.  

  Establish a stable and efficient national system for the 
administration and functioning of protected areas that 
can  also  recognise  and  harness  the  full  economic 
potential of healthy ecosystem services.  

  Build  capacity  of  competent  authorities  (central, 
regional,  site  management  bodies)  for  implementing 
increasing  awareness  about 
Management  Plans, 
Natura 2000 and incentives for investments promoting 
its  benefits,  and  tackling  illegal  activities  affecting 
wildlife  through  enhanced  enforcement,  both  within 
and outside Natura 2000 areas. 

29  Ecosystem  services  are  benefits  provided  by  nature  such  as  food, 

clean water and pollination on which human society depends. 

A  major  obstacle  to  the  effective  protection  and 
management  of  the  Natura  2000  sites  as  a  whole  is  the 
lack  of  a  national  system  for  the  comprehensive 
administration  and 
functioning  of  protected  areas 
(including  strategy,  structure,  management  schemes, 
responsibilities, financing, enforcement, monitoring).  

The  lack  of  awareness  (among  authorities, stakeholders, 
public) about Natura 2000 and its benefits, coupled with 
a  lack  of  incentives  for  investments  promoting  those 
benefits,  as  well  as  the  poor  capacity  to  support 
sustainable land management and integration with other 
policies  and  to  enforce 
legal  provisions,  are  also 
acknowledged  as  major  obstacles  to  achieving  the 

25 The core of the ‘Article 17’ report is the assessment of conservation 
status of the habitats and species targeted by the Habitats Directive. 
26  Due  to  the  overdue  submission  of  the  Greek  Art.  17  report  for  the 

period 2007-2012, data are drawn from the 2001-2006 report. 

27  Conservation  status  is  assessed  using  a  standard  methodology  as 
being 
and 
‘unfavourable-bad’, based on four parameters as defined in Article 1 
of the Habitats Directive. 

‘unfavourable-inadequate’ 

‘favourable’, 

either 

28 These figures show the percentage of biogeographical assessments in 
each  category  of  conservation  status  for  habitats  and  species, 
respectively.  The  information  is  based  on  Article  17  of  the  Habitats 
Directive reporting - national summary of Greece 

Environmental Implementation Report – Greece 

 
 
                                                            
                                                            
  Improve the overall quality of Appropriate Assessments 

at plan and project level.  

  Secure  efficient  use  of  available  ERDF  and  European 
Agricultural Fund for Rural Development (EAFRD) funds 
for nature conservation, based on the Prioritised Action 
Framework (PAF). Greece can also capitalise on its rich 
natural  capital  to  create  sustainable  jobs  and  income, 
notably in tourism. 

  Engage  and  provide  government  support  to  the 
mapping  and  assessment  of  ecosystems  and  their 
services, valuation and development of natural capital 
accounting systems. 

Green Infrastructure  
The  EU  strategy  on  green  infrastructure30  promotes  the 
incorporation  of  green  infrastructure  into  related  plans 
and  programmes  to  help  overcome  fragmentation  of 
habitats  and  preserve  or  restore  ecological  connectivity, 
enhance  ecosystem  resilience  and  thereby  ensure  the 
continued provision of ecosystem services. 
Green  Infrastructure  provides  ecological,  economic  and 
social  benefits  through  natural  solutions.  It  helps  to 
understand the value of the benefits that nature provides 
to human society and to mobilise investments to sustain 
and enhance them. 

In  Greece,  restoration  and  rehabilitation  of  degraded 
habitats  and  species  has  been  carried  out  within  some 
protected  areas,  e.g.  the  restoration  of  Lake  Carla,  of  a 
burned fir forest in Parnitha National Park and of Grecian 
Juniper Woods in Prespa National Park. 

Soil protection  

further  soil  degradation  and 

The  EU  Soil  Thematic  Strategy  highlights  the  need  to 
ensure  a  sustainable  use  of  soils.  This  requires  the 
prevention  of 
the 
preservation of its functions, as well as the restoration of 
degraded  soils.  The  2011  Road  Map  for  Resource-
Efficient  Europe,  part  of  Europe  2020  Strategy  provides 
that  by  2020,  EU  policies  take  into  account  their  direct 
and  indirect  impact  on  land  use  in  the  EU  and  globally, 
and  the  rate  of  land  take  is  on  track  with  an  aim  to 
achieve no net land take by 2050. 
SDG  15  requires  countries  to  combat  desertification, 
restore degraded land and soil, including land affected by 
desertification, drought and floods, and strive to achieve 
a land-degradation-neutral world by 2030. 

Soil is an important resource for life and the economy. It 
provides  key  ecosystem  services  including  the  provision 
of food, fibre and biomass for renewable energy, carbon 
sequestration,  water  purification  and  flood  regulation, 
the provision of raw and building material. Soil is a finite 

30 European Union, Green Infrastructure — Enhancing Europe’s Natural 

Capital, COM/2013/0249 

Greece  12 

its  natural  state; 

and  extremely  fragile  resource.  Land  taken  by  urban 
development  and  infrastructure  is  highly  unlikely  to  be 
reverted  to 
it  consumes  mostly 
agricultural land and increases fragmentation of habitats. 
Soil  protection  is  not  subject  to  a  comprehensive  and 
coherent  set  of  rules  in  the  EU.  Existing  EU  policies  in 
areas  such  as  agriculture,  water,  waste,  chemicals,  and 
prevention  of  industrial  pollution  however  contribute  to 
the protection of soils but the continuous degradation of 
soil suggests that it is insufficiently protected. 

Figure 7 shows the different land cover types in Greece in 
2012. 
Figure 7: Land Cover types in Greece 201231 

Artificial  land  cover  is  used  for  settlements,  production 
systems and infrastructure. It may itself be split between 
built-up areas (buildings) and non-built-up areas (such as 
linear  transport  networks  and  associated  areas).  The 
percentage of built up land in Greece in 2009 was 1.35%, 
well below the EU-average (3.23%)32.  

The  annual  land  take  rate  (growth  of  artificial  areas)  as 
provided by CORINE Land Cover was 0.7% in Greece over 
the period 2006-12, well above the EU average (0.41%). It 
represented 2657 hectares per year33.  

31European Environment Agency, Land cover 2012 and changes country 

analysis [publication forthcoming] 

32European 

Environment  Agency,  2016. 

Imperviousness 

and 

imperviousness change 

33  European  Environment  Agency  Draft  results  of  CORINE  Land  Cover 
(CLC) inventory 2012; mean annual land take 2006-12 as a % of 2006 
artificial land. 

Environmental Implementation Report – Greece 

 
 
                                                            
 
                                                            
The soil water erosion rate in 2010 was 4.13 tonnes per 
hectare per year, above EU-28 average (2.46 tonnes)34. 

There are still no EU-wide datasets enabling the provision 
of  benchmark  indicators  for  soil  organic  matter  decline, 
contaminated sites, pressures on soil biology and diffuse 
pollution.  An  updated  inventory  and  assessment  of  soil 
protection  policy  instruments  in  Greece  and  other  EU 
Member  States  is  being  performed  by  the  EU  Expert 
Group on Soil Protection. 

Marine protection 

The EU Coastal and Marine Policy and legislation require 
that by 2020 the impact of pressures on marine waters is 
reduced  to  achieve  or  maintain  good  environmental 
status and coastal zones are managed sustainably. 

SDG  14  requires  countries  to  conserve  and  sustainably 
use  the  oceans,  seas  and  marine  resources 
for 
sustainable development. 
The Marine Strategy Framework Directive (MSFD)35 aims 
to  achieve  Good  Environmental  Status  (GES)  of  the  EU's 
marine  waters  by  2020  by  providing  an  ecosystem 
approach  to  the  management  of  human  activities  with 
impact  on  the  marine  environment.  The  Directive 
requires  Member  States  to  develop  and  implement  a 
marine  strategy  for  their  marine  waters,  and  cooperate 
with  Member  States  sharing  the  same  marine  region  or 
subregion. 

As part of their marine strategies, Member States had to 
make  an  initial  assessment  of  their  marine  waters, 
determine  GES36  and  establish  environmental  targets  by 
July  2012.  They  also  had  to  establish  monitoring 
programmes for the on-going assessment of their marine 
waters  by  July  2014.  The  next  element  of  their  marine 
strategy is to establish a Programme of Measures (2016). 
The  Commission  assesses  whether  these  elements 
constitute  an  appropriate  framework  to  meet  the 
requirements of the MSFD. 

The Mediterranean Sea region has been identified by the 
EEA in its 2015 State of the Environment report as one of 
the  main  climate  change  hotspots  (i.e.  one  of  the  areas 
most responsive to climate change) due to water scarcity, 
concentration of economic activities in coastal areas, and 
The 
climate-sensitive 
reliance 
introduction  of 
invasive  alien  species  presents  an 
important  threat  in  the  Mediterranean  Sea  Region  with 
the  number  of invasive  alien 
increasing 
significantly since 1970. Finally, the unique biodiversity of 

agriculture. 

species 

on 

Greece  13 

the  Mediterranean  Sea  Region  is  also  threatened  by 
pollution from land-based sources, such as discharges of 
excess nutrients and hazardous substances, marine litter, 
over-fishing, and degradation of critical habitats. 

With regard to the specificities of the implementation of 
the  MSFD,  there  is  a  lack  of  clarity  in  what  constitutes 
GES,  as  there 
is  no  systematic  use  of  the  2010 
Commission's Decision criteria and indicators and in most 
cases  no  threshold  values  and  baselines  are  provided. 
Thus,  the  criteria  for  GES  were  not  considered  as 
measurable37.  

It is therefore too early to say whether Greek waters are 
in good status. 

Greece  has  not  yet  reported  on 
its  monitoring 
programme  under  the  MSFD,  therefore  no  assessment 
has  been  carried  out,  contrary  to  other  Member  States, 
for which the Commission provided guidance in its report 
assessing monitoring programmes under the MSFD38.  

In  2012,  Greek  marine  protected  areas  covered  7,413.5 
square  kilometres  of  its  marine  waters,  with  2,521.6 
and  Central 
square 
the 
in 
Mediterranean  Sea,  74.1  square  kilometres 
in  the 
Adriatic Sea and 4,817.8 square kilometres in the Aegean 
and Levantine Sea39. 

kilometres 

Ionian 

Suggested action 

  Continue  work  to  improve  the  definitions  of  GES, 
including  through  regional  cooperation  by  using  the 
work of the relevant Regional Sea Convention with the 
aim to make GES measurable. 

  Urgently 

report  and 

implement 

the  national 

programme of measures40. 

  Finalise, implement and report to the Commission the 
monitoring  programme  of  Greek  marine  waters  as 
soon as possible. 

  Further 

develop 

(and 
approaches 
quantifying) impacts from the main pressures in order 
to  lead  to  improved  and  more  conclusive  assessment 
results for 2018 reporting. 

assessing 

37 Commission Staff Working Document Accompanying the Commission 
Report on "The first phase of implementation of the Marine Strategy 
Framework  Directive  (2008/56/EC)  -  The  European  Commission's 
assessment 
and 
COM(2014)097 final) 

(SWD(21014) 

guidance" 

final 

and 

049 

34 Eurostat, Soil water erosion rate, accessed June 2016  
35 European Union, Marine Strategy Framework Directive 2008/56/EC 
36  The  MSFD  defines  Good  Environmental  Status  (GES)  in  Article  3  as: 
“The  environmental  status  of  marine  waters  where  these  provide 
ecologically  diverse  and  dynamic  oceans  and  seas  which  are  clean, 
healthy and productive” 

38  Report  from  the  Commission  assessing  Member  States'  monitoring 
programmes  under  the  Marine  Strategy  Framework  Directive 
(COM(2017)3)  and 
its  accompanying  Staff  Working  Document 
(SWD(2017)1 final). 

39  2012  Data  provided  by  the  European  Environmental  Agency  –  Not 

published 

40  As  of  7.10.2016,  Greece  had  not  yet  reported  its  programme  of 

measures to the Commission 

Environmental Implementation Report – Greece 

 
                                                            
                                                            
3. Ensuring citizens' health and quality of life 

Greece  14 

Air quality  

The  EU  Clean  Air  Policy  and  legislation  require  that  air 
quality  in  the  Union  is  significantly  improved,  moving 
closer  to  the  WHO  recommended  levels.  Air  pollution 
and its impacts on ecosystems and biodiversity should be 
further reduced with the long-term aim of not exceeding 
critical  loads  and  levels.  This  requires  strengthening 
efforts  to  reach  full  compliance  with  Union  air  quality 
legislation  and  defining  strategic  targets  and  actions 
beyond 2020. 

The  EU  has  developed  a  comprehensive  suite  of  air 
legislation41,  which  establishes  health-based 
quality 

the  currently  applicable  national  emission 

within 
ceilings43. 

At the same time, air quality in Greece continues to give 
cause  for  concern.  For  the  year  2013,  the  European 
Environment  Agency  estimated  that  about  13,730 
premature  deaths  were  attributable  to  fine  particulate 
matter44  concentrations,  more  than  840  to  ozone45 
to  nitrogen  dioxide46 
concentrations  and  1,490 
concentrations.47  This  is  also  due  to  exceedances  above 
the EU air quality standards, such as shown in Figure 848.  

registered 

For 2014, exceedances above the EU air quality standards 
were 
(NO2)  and 
particulate  matter  (PM10)  in  one  air  quality  zone  each 
(Athens  and  Thessaloniki,  respectively).  Furthermore,  in 

for  nitrogen  dioxide 

Figure 8: Attainment situation for PM10, NO2 and O3 in 2014 

that  up-to-date 

standards  and  objectives  for  a  number  of  air  pollutants. 
As  part  of  this,  Member  States  are  also  required  to 
ensure 
information  on  ambient 
concentrations  of  different  air  pollutants  is  routinely 
made  available  to  the  public.  In  addition,  the  National 
for  emission 
Emission  Ceilings  Directive  provides 
reductions  at  national  level  that  should  be  achieved  for 
main pollutants.  

The  emission  of  several  air  pollutants  has  decreased 
significantly  in  Greece42.  Reductions  between  1990  and 
2014  for  sulphur  oxides  (-71%),  nitrogen  oxides  (-24%), 
ammonia  (-28%)  as  well  as  volatile  organic  compounds 
(-53%)  ensure  air  emissions  for  these  pollutants  are 

41 European Commission, 2016. Air Quality Standards 
42 See EIONET Central Data Repository and Air pollutant emissions data 

viewer (NEC Directive) 

43 The current national emission ceilings apply since 2010 (Directive 
2001/81/EC); revised ceilings for 2020 and 2030 have been set by 
Directive (EU) 2016/2284 on the reduction of national emissions of 
certain atmospheric pollutants, amending Directive 2003/35/EC and 
repealing Directive 2001/81/EC. 

44  Particulate  matter  (PM)  is  a  mixture  of  aerosol  particles  (solid  and 
liquid)  covering  a  wide  range  of  sizes  and  chemical  compositions. 
PM10  (PM2.5)  refers  to  particles  with  a  diameter  of  10  (2.5) 
micrometres  or  less.  PM  is  emitted  from  many  anthropogenic 
sources, including both combustion and non-combustion sources. 
45  Low  level  ozone  is  produced  by  photochemical  action  on  pollution 

and it is also a greenhouse gas. 

46  NOx  is  emitted  during  fuel  combustion  e.g.  from  industrial  facilities 
and  the  road  transport  sector.  NOx  is  a  group  of  gases  comprising 
nitrogen monoxide (NO) and nitrogen dioxide (NO2). 

47  European  Environment  Agency,  2016.  Air  Quality  in  Europe  –  2016 
Report.  (Table  10.2,  please  see  details  in  this  report  as  regards  the 
underpinning    methodology) 

48 Based on European Environment Agency, 2016. Air Quality in Europe 

– 2016 Report. (Figures 4.1, 5.1 and 6.1) 

Environmental Implementation Report – Greece 

 
 
 
                                                            
                                                            
 
several air quality zones the target values and long-term 
objectives regarding ozone concentrations are not being 
met.49 

The  persistent  breaches  of  air  quality  requirements  (for 
PM10), which have severe negative effects on health and 
environment,  are  being  followed  up  by  the  European 
Commission  through  infringement  procedures  covering 
all the Member States concerned, including Greece. The 
aim  is  that  adequate  measures  are put  in place  to  bring 
all zones into compliance.  

It  is  estimated  that  the  health-related  external  costs  of 
air  pollution  in  Greece  are  above  EUR  7  billion/year 
(income  adjusted,  2010),  which  include  not  only  the 
intrinsic value of living a full, healthy life, but also direct 
costs to the economy. These direct economic costs relate 
to  3  million  workdays  lost  each  year  due  to  sickness 
related  to  air  pollution,  with  associated  costs  for 
employers  of  EUR  396  million/year  (income  adjusted, 
2010),  for  healthcare  of  above  EUR  27  million/year 
(income adjusted, 2010), and for agriculture (crop losses) 
of EUR 108 million/year (2010)50. 

Suggested action 

  Maintain  downward  emissions  trends  of  air  pollutants 
in order to achieve full compliance with air quality limit 
values  -  and  reduce  adverse  air  pollution  impacts  on 
health, environment and economy. 

  Reduce nitrogen oxide (NOx) emissions to comply with 
 and/or 
(and  ozone 
(NO2) 
inter  alia,  by  reducing  transport 

currently applicable national emission ceilings51
to 
concentrations), 
related emissions - in particular in urban areas. 

reduce  nitrogen  dioxide 

  Reduce  PM10  emission  and  concentration,  inter  alia, 
by  reducing  emissions  related  to  energy  and  heat 
generation  using  solid  fuels,  to  transport  and  to 
agriculture. 

Noise 

The  Environmental  Noise  Directive  provides  for  a 
common  approach  for  the  avoidance,  prevention  and 
reduction  of  harmful  effects  due  to  exposure  to 
environmental noise. 
Excessive  noise  is  one  of  the  main  causes  of  health 
issues52.  To alleviate  this,  the  EU  acquis  sets  out  several 

49  See  The  EEA/Eionet  Air  Quality  Portal  and  the  related  Central  Data 

Repository 

50 These figures are based on the Impact Assessment for the European 

Commission Integrated Clean Air Package (2013) 

51 Under the provisions of the revised National Emission Ceilings 

Directive, Member States now may apply for emission inventory 
adjustments. Pending evaluation of any adjustment application, 
Member States should keep emissions under close control with a 
view to further reductions. 

52  WHO/JRC,  2011,  Burden  of  disease  from  environmental  noise, 
Fritschi, L., Brown, A.L., Kim, R., Schwela, D., Kephalopoulos, S. (eds), 

Greece  15 

including  assessing  the  exposure  to 
requirements, 
environmental  noise  through  noise  mapping,  ensuring 
that information on environmental noise and its effects is 
made  available  to  the  public,  and  adopting  action  plans 
with  a  view  to  preventing  and  reducing  environmental 
noise  where  necessary  and  to  preserving  the  acoustic 
environment quality where it is good. 

implementation  of 

The 
the  Environmental  Noise 
Directive53 
the 
implementation method adopted, an in-depth analysis is 
not possible at the moment. 

is  delayed.  Due 

in  Greece 

to 

Suggested action 

  Complete  noise  mapping  and  action  plans  for  noise 

management. 

Water quality and management 

(including  surface  and  ground  waters) 

The  EU  water  policy  and  legislation  require  that  the 
impact  of  pressures  on  transitional,  coastal  and  fresh 
is 
waters 
significantly  reduced  to  achieve,  maintain  or  enhance 
good  status  of  water  bodies,  as  defined  by  the  Water 
Framework Directive; that citizens throughout the Union 
benefit from high standards for safe drinking and bathing 
water;  and  that  the  nutrient  cycle  (nitrogen  and 
phosphorus)  is  managed  in  a  more  sustainable  and 
resource-efficient way. 
SDG  6  encourages  countries  to  ensure  availability  and 
sustainable management of water and sanitation for all. 
The  main  overall  objective  of  EU  water  policy  and 
legislation  is  to  ensure  access  to  good  quality  water  in 
sufficient  quantity  for  all  Europeans.  The  EU  water 
acquis54  seeks  to  ensure  good  status  of  all  water  bodies 
across Europe by addressing pollution sources (from e.g. 
agriculture, urban areas and industrial activities), physical 
and  hydrological modifications  to  water  bodies)  and  the 
management of risks of flooding.  

River  Basin  Management  Plans 
(RBMPs)  are  a 
requirement  of  the  Water  Framework  Directive  and  a 
means  of  achieving  the  protection,  improvement  and 
sustainable use of the water environment across Europe. 
This includes surface freshwaters such as lakes and rivers, 
groundwater,  estuaries  and  coastal  waters  up  to  one 

World Health Organization, Regional Office for Europe, Copenhagen, 
Denmark 

53 The Noise Directive requires Member States to prepare and publish, 
every  5  years,  noise  maps  and  noise  management  action  plans  for 
agglomerations  with  more  than  100,000  inhabitants,  and  for  major 
roads, railways and airports.  

54  This  includes  the  Bathing  Waters  Directive  (2006/7/EC);  the  Urban 
Waste  Water  Treatment  Directive 
(91/271/EEC)  concerning 
discharges  of  municipal  and  some  industrial  waste  waters;  the 
Drinking  Water  Directive  (98/83/EC)  concerning  potable  water 
quality;  the  Water  Framework  Directive  (2000/60/EC)  concerning 
water  resources  management;  the  Nitrates  Directive  (91/676/EEC) 
and the Floods Directive (2007/60/EC) 

Environmental Implementation Report – Greece 

 
                                                            
                                                                                                 
nautical mile. 

In  its  first  generation  of  RBMPs  Greece  reported  the 
status of 1142 rivers, 48 lakes, 43 transitional, 133 coastal 
and  366  groundwater  bodies.  49%  of  natural  surface 
water  bodies  achieve  a  good  or  high  ecological  status55 
(while  the  status  of  21%  is  unknown)  and  only  6%  of 
heavily modified or artificial water bodies achieve a good 
or high ecological potential (43% unknown). Only 44% of 
surface  water  bodies  (51%  unknown),  13%  of  heavily 
modified and artificial water bodies (60% unknown) and 
85%  of  groundwater  bodies  achieve  good  chemical 
status56.  83%  of  groundwater  bodies  are 
in  good 
quantitative status57. 

The main pressure on the Greek surface waters is diffuse 
pollution58,  which  affects  63%  of  water  bodies.  Point 
sources  of  pollution  affect  44%  of  water  bodies  and 
abstraction 6%. There are significant regional differences, 
e.g. diffuse sources of pollution affect all water bodies in 
the  Northern  and  Western  Peloponnese  river  basin 
district  but  only  15%  in  the  Western  Macedonia  river 
basin district.  

The  Greek  RBMPs  have  some  deficiencies  that  result  in 
uncertainties  about  the  status  and  effectiveness  of 
Programmes of Measures (PoMs). In particular there are 
weaknesses  in  monitoring,  methodologies  for  status 
assessment  and  the  link  between  pressures  and  PoMs. 
The  planned  measures  are  expected  to  result  in  the 
improvement  of  the  ecological  and  chemical  status  of 
surface  water  bodies  by  11%  and  3%  respectively.  The 
measures  should  also  bring  about  the  improvement  of 
ecological  potential  of  artificial  and  heavily  modified 
water bodies59 by 8% and of chemical status by 3%.  

The  adoption of  the  second generation  of all  (14)  Greek 
RBMPs, which was expected in December 2015, has been 
significantly delayed. 

two 

Greek legislation related to nitrates is obsolete and there 
are  currently 
infringement  procedures  open 
concerning  the  Nitrates  Directive:  one  concerning  the 
need to designate further nitrate vulnerable zones and to 
establish proper action programmes for these new zones 
and  one  concerning  the  non-adequacy  of  the  action 
programmes  for  the  existing  nitrate  vulnerable  zones. 

55 Good ecological status is defined in the Water Framework Directive, 
referring to the quality of the biological community, the hydrological 
characteristics and the chemical characteristics. 

56  Good  chemical  status  is  defined  in  the  Water  Framework  Directive 
referring to compliance with all the quality standards established for 
chemical substances at European level. 

57  For  groundwater,  a  precautionary  approach  has  been  taken  that 
comprises  a  prohibition  on  direct  discharges  to  groundwater,  and  a 
requirement to monitor groundwater bodies. 

58  Diffuse  pollution  comes  from  widespread  activities  with  no  one 

discrete source. 

59 Many European river basins and waters have been altered by human 
activities,  such  as  land  drainage,  flood  protection  and  building  of 
dams to create reservoirs. 

Greece  16 

The  nitrate  vulnerable  zone  designation  has  been 
improved,  but  Greece  still  needs  to 
improve  the 
measures 
implementing  the  Nitrates  Directive  and 
establish  proper  action  programmes  for  all  nitrate 
vulnerable zones (existing and new ones)  

As  regards  drinking  water,  Greece  reaches  very  high 
compliance 
for  microbiological, 
chemical  and  indicator  parameters  laid  down  in  the 
Drinking Water Directive60. 

rates  of  99-100% 

As  shown  in  Figure  9,  in  Greece  in  2015  out  of  1542 
bathing waters, 97.2% were of excellent quality and 0.6% 
of  good  quality,  while  it  was  not  possible  to  assess  the 
remaining 34 bathing waters. 
Figure 9: Bathing water quality 2012 – 201561 

With  a  total  generated  load  of  12.3  million  population 
equivalents  (p.e.)  and  492  agglomerations  above  2000 
p.e., Greece demonstrates high general compliance rates 
with the Urban Waste Water Treatment Directive: 100% 
for  collection  (Article  3),  albeit  with  large  part  of  its 
agglomerations  served  by  individual  systems,  and  96.4% 
for  secondary  treatment  of  waste  water  (Article  4). 
However,  some  areas  have  been  very  slow  to  comply, 
resulting in advanced legal action.  

99.6%  of  the  waste  water  load  collected  is  subject  to 
more stringent treatment in accordance with Article 5 of 
the Urban Waste Water Treatment Directive. It should be 
noted  that  23%  of  the  Greek  territory  is  considered  as 
sensitive, i.e. more stringent treatment is applicable only 
there  and  in  the  agglomerations  whose  size  is  above 
10,000 p.e. However, 16% of the above-mentioned total 
p.e.  is  addressed  via  individual  or  other  systems,  whose 
appropriateness  to  protect  the  environment  might  be 

60  Commission's  Synthesis  Report  on  the  Quality  of  Drinking  Water  in 
the  Union  examining  Member  States'  reports  for  the  2011-2013 
period, 
foreseen  under  Article  13(5)  of  Directive  98/83/EC; 
COM(2016)666 

61 European Environment Agency, State of bathing water, 2016 

Environmental Implementation Report – Greece 

 
                                                            
 
                                                            
questionable62. 

Management and  prevention  of  floods is  an  area where 
potentially  more  economical  nature-based  solutions 
could improve resource efficiency through reducing costs 
and  delivering  multiple  benefits.    Over  the  last  decade 
Greece  has  claimed  damages  to  the  EU  Solidarity  Fund 
for  one  major  and  three  regional  floods,  which  caused 
damages of  over EUR 3  billion.  The total EU  aid granted 
amounts to EUR 112.7 million.  

The  absence  of  flood  risk  and  flood  hazard  maps  in 
Greece  is  the  subject  of  an  infringement  procedure 
initiated in 2015.  

Suggested action 

  Improve water policy in line with the intervention logic 
of  the  Water  Framework  Directive63,  i.e.  update  as 
soon  as  possible  the  first  RBMPs,  do  a  more  detailed 
assessment  of  pressures  to  improve  monitoring  in 
order  to  know  the  status  of  water  bodies  and  design 
effective  PoMs  that  address  all  the  main  pressures 
identified.  Improve  assessment  methods  to  provide 
more certainty about the water status.  

  Cover all identified pressures and implementation gaps 

in PoMs and ensure adequate funding.  

  Assess  new  physical  modifications  of  water  bodies  in 
line with article 4(7) of the Water Framework Directive. 
In these assessments alternative options and adequate 
mitigation measures have to be considered. 

  Move  forward  quickly  with  the  preparation  of  new 
Action Programmes fully compliant with the provisions 
of the Nitrates Directive. 

  Complete  implementation  of  the  Urban  Waste  Water 
those 
Treatment  Directive, 
agglomerations  that  are  subject  to  an  infringement 
case.  

giving  priority 

to 

Enhancing the sustainability of cities  

The  EU  Policy  on  the  urban  environment  encourages 
cities  to 
implement  policies  for  sustainable  urban 
planning and design, including innovative approaches for 
urban  public 
sustainable 
buildings,  energy  efficiency  and  urban  biodiversity 
conservation.  

transport  and  mobility, 

SDG11  aims  at  making  cities  and  human  settlements 
inclusive, safe, resilient and sustainable. 

Europe is a Union of cities and towns; around 75% of the 
EU  population  are  living  in  urban  areas64.  The  urban 

Greece  17 

the 
environment  poses  particular  challenges 
environment  and  human  health,  whilst  also  providing 
opportunities and efficiency gains in the use of resources.  

for 

 The  Member  States,  European  institutions,  cities  and 
stakeholders have prepared a new Urban Agenda for the 
EU  (incorporating  the  Smart  Cities  initiative)  to  tackle 
these  issues  in  a  comprehensive  way,  including  their 
connections with social and economic challenges. At the 
heart  of  this  Urban  Agenda  will  be  the  development  of 
twelve  partnerships  on  the  identified  urban  challenges, 
including air quality and housing65.  

The  European  Commission  will 
benchmark system in 201766. 

launch  a  new  EU 

The  EU  stimulates  green  cities  through  awards  and 
funding,  such  as  the  EU  Green  Capital  Award  aimed  at 
cities  with  more  than  100,000  inhabitants  and  the  EU 
Green  Leaf  initiative  aimed  at  cities  and  towns,  with 
between 20,000 and 100,000 inhabitants.  

International agreements  

The  EU  Treaties  require  that  the  Union  policy  on  the 
environment  promotes  measures  at  the  international 
level  to  deal  with  regional  or  worldwide  environmental 
problems. 

Most  environmental  problems  have  a  transboundary 
nature  and  often  a  global  scope  and  they  can  only  be 
addressed effectively through international co-operation. 
International  environmental  agreements  concluded  by 
the Union are binding upon the institutions of the Union 
and  on  its Member  States. This  requires  the  EU and the 
Member  States  to  sign,  ratify  and  effectively  implement 
all  relevant  multilateral  environmental  agreements 
(MEAs) in a timely manner. This will also be an important 
contribution  towards  the  achievement  of  the  SDGs, 
which Member States committed to in 2015 and include 

62  European  Commission,  Eighth  Report  on  the  Implementation  Status 
and the Programmes for Implementation of the Urban Waste Water 
Directive  (COM  (2016)105  final)  and  Commission  Staff  Working 
Document accompanying the report (SWD (2016)45 final). 
63 The full set of recommendations in relation to the WFD are here 
64 European Environment Agency, Urban environment 

65  http://urbanagendaforthe.eu/ 
66 

  The  Commission 
is  developing  an  Urban  Benchmarking  and 
Monitoring  ('UBaM')  tool  to  be  launched  in  2017.  Best  practices 
emerge and these will be better disseminated via the app featuring 
the  UBaM  tool,  and  increasingly  via  e.g.  EUROCITIES,  ICLEI,  CEMR, 
Committee of the Regions, Covenant of Mayors and others. 

Environmental Implementation Report – Greece 

 
                                                            
                                                            
Greece  18 

many  commitments  contained  already  in  legally  binding 
agreements. 

The  fact  that  some  Member  States  did  not  sign  and/or 
ratify  a  number  of  MEAs  compromises  environmental 
implementation,  including  within  the  Union,  as  well  as 
in  related  negotiations  and 
the  Union’s  credibility 
international  meetings  where 
the 
participation of third countries to such agreements is an 
established  EU  policy  objective.  In  agreements  where 
voting takes place it has a direct impact on the number of 
votes to be cast by the EU. 

supporting 

Currently,  Greece  has  signed  but  not  yet  ratified  the 
Offshore  Protocol  of  the  Barcelona  Convention,  the 
Protocol  concerning  Specially  Protected  Areas  and 
Biological Diversity in the Mediterranean, the Protocol on 
Integrated Coastal Zone Management, three agreements 
under  the  Convention  on  Long-range  Transboundary  Air 
Pollution 
to  Abate 
Acidification,  Eutrophication  and  Ground-level  Ozone, 
the Persistent Organic Pollutants Protocol and the Heavy 
Metals  Protocol),  the Kiev  Protocol  on  Pollutant Release 
and  Transfer  Registers,  the  African-Eurasian  Migratory 
Waterbird  Agreement, 
the  Protocol  on  Strategic 
Environmental Assessment to the Espoo Convention, and 
the Nagoya Protocol67.  

(the  Gothenburg 

Protocol 

Suggested action 

  Increase  efforts  to  be  party  to  relevant  multilateral 
environmental agreements, by signing and ratifying the 
remaining ones. 

67  Protocol  on  Access  to  Genetic  Resources  and  the  Fair  and  Equitable 
Sharing of Benefits Arising from their Utilization to the Convention on 
Biological Diversity. 

Environmental Implementation Report – Greece 

 
 
 
                                                            
Greece  19 

Part II: Enabling Framework: Implementation Tools 

4. Market based instruments and investment  

Green taxation and environmentally harmful 
subsidies  

abstraction tax. This accounts for EUR 0.96 billion in 2030 
(real 2015 terms), equivalent to 0.35% of GDP.  

The Circular Economy Action Plan encourages the use of 
financial  incentives  and  economic  instruments,  such  as 
taxation  to  ensure  that  product  prices  better  reflect 
environmental costs. The phasing out of environmentally 
harmful  subsidies  is  monitored  in  the  context  of  the 
European  Semester  and  in  national  reform  programmes 
submitted by Member States. 

Taxing pollution and resource use can generate increased 
revenue  and  bring  important  social  and  environmental 
benefits. 

Revenues from environment-related taxes reached 3.68% 
of GDP in 2014 in Greece against an EU average of 2.46%. 
This percentage share is up from 3.55% in the preceding 
year.  Energy  taxes  amounted  to  2.94%  of  GDP, 
significantly  above  the  EU  average  of  1.88%68.  In  the 
same  year  environmental  tax  revenues  accounted  for 
10.24%  of  total  revenues  from  taxes  (excluding  social-
security contributions) (EU-28 average: 6.35%) as shown 
in Figure 10.  

is  considerable 
A  2016  study  suggests  that  there 
potential for shifting taxes from labour to environmental 
taxes69.  Under  a  good  practice  scenario70  these  could 
generate an additional EUR 1.41 billion in 2018, rising to 
EUR 3.01 billion in 2030 (both in real 2015 terms). This is 
equivalent  to  an  additional  0.72%  and  1.09%  of  GDP  in 
2018 and 2030, respectively. The largest potential source 
of revenue would come from the proposed amendments 
to taxes on transport fuels: currently Greece taxes diesel 
fuel much lower than petrol, which is not justified by the 
level  of  environmental  impacts  those  fuels  have.  The 
increase could account for EUR 1.12 billion in 2030 (real 
2015 terms), equivalent to 0.4% of GDP. The next largest 
contribution could come from the introduction of a water 

68 Eurostat, Environmental tax revenues, accessed June 2016 
69  Eunomia  Research  and  Consulting,  IEEP,  Aarhus  University,  ENT, 
2016.  Study on Assessing the Environmental Fiscal Reform Potential 
for the EU28. N.B. National governments are responsible for setting 
tax  rates  within  the  EU  Single  Market  rules  and  this  report  is  not 
suggesting  concrete  changes  as  to  the  level  of  environmental 
taxation.  It  merely  presents  the  findings  of  the  2016  study  by 
Eunomia et al on the potential benefits various environmental taxes 
could bring. It is then for the national authorities to assess this study 
and their concrete impacts in the national context. A first step in this 
respect,  already  done  by  a  number  of  Member  States,  is  to  set  up 
expert groups to assess these and make specific proposals. 
The  good  practice  scenario  means  benchmarking  to  a  successful 
taxation practice in another Member State.  

70

Figure  10:  Environmental  tax  revenues  as  a  share  of 
total  revenues  from  taxes  and  social  contributions  
(excluding imputed social contributions) in 201471 

Greece provides a full refund of excise duty paid on fuels 
used for domestic shipping purposes. As of 1 April 2012, 
it has been providing a partial refund of excise duty paid 
on  diesel  used  in  agriculture.  The  excise  duty  paid  on 
diesel used for industrial or commercial purposes is also 
reduced.  Tax  exemptions  and  reductions  exist  for  coal 
and  coke  used  exclusively  for  electricity  generation.  In 
addition,  electricity  used  in  agriculture  is  exempt  from 
excise  tax72.  Such  subsidies  go  against  the  climate  and 

71 Eurostat, Environmental tax revenues, accessed October 2016 
72OECD, 2013. “Foreword”, in  Taxing Energy  Use: A Graphical Analysis, 

OECD Publishing.   

Environmental Implementation Report – Greece 

 
 
                                                            
 
 
 
 
                                                            
energy  policy  objectives;  removing  them  would  be 
beneficial  both  for  the  environment  and  the  budgetary 
debt reduction. 

For  the  2014-2020  programming  period  Greece  has 
adopted 20 operational programmes (OPs). In particular, 
13 Regional multi-fund Programmes (ERDF & ESF) and 7  

Greece  20 

Green Public Procurement  

The  EU  green  public  procurement  policies  encourage 
Member States to take further steps to reach the target 
of applying green procurement criteria to at least 50% of 
public tenders. 
Green  Public  Procurement  (GPP)  is  a  process  whereby 
public  authorities  seek  to  procure  goods,  services  and 
works  with  a  reduced  environmental  impact  throughout 
their  life-cycle  when  compared  to  goods,  services  and 
works  with  the  same  primary  function  that  would 
otherwise be procured.  

The  purchasing  power  of  public  procurement  equals  to 
approximately  14%  of  GDP73.  A  substantial  part  of  this 
money  is  spent  on  sectors  with  high  environmental 
impact such as construction or transport, so GPP can help 
to  significantly  lower  the  impact  of  public  spending  and 
foster sustainable innovative businesses. 

Currently  there  is  no  National  Action  Plan  (NAP)  or 
National Strategy  on  GPP in  Greece.  Legislation  is  under 
preparation, stipulating the development of a GPP NAP.74 

According to a 2010 study, the share of Greek authorities 
that  included  GPP  requirements  in  between  50%  and 
100%  of  their  contracts  is  estimated  between  10  and 
20%75. 

Investments: the contribution of EU funds  

social  and 

in  their 
for  economic, 

European  Structural  and  Investment  Funds  Regulations 
provide  that  Member  States  promote  environment  and 
funding  strategies  and 
climate  objectives 
programmes 
territorial 
cohesion,  rural  development  and  maritime  policy,  and 
reinforce the capacity of implementing bodies to deliver 
cost-effective and sustainable investments in these areas. 
Making  good  use  of  the  European  Structural  and 
Investment  Funds  (ESIF)76  is  essential  to  achieve  the 
environmental goals and integrate these into other policy 
areas.  Other  instruments  such  as  the  Horizon  2020,  the 
LIFE  programme  and  the  EFSI77  may  also  support 
implementation and spread of best practice. 

national  sector-specific  programmes,  namely  one  for 
Competitiveness, Entrepreneurship and Innovation (ERDF 
& ESF), one for Transport Infrastructures, Environment  & 
Sustainable Development (ERDF & CF), one for Reform of 
Public  Sector  (ERDF  &  ESF),  one  for  Human  Resources, 
Education  and  Lifelong  Learning  (ESF),  one  for  Technical 
Assistance  (ERDF,  ESF  &  CF),  one  for  the  European 
Agricultural  Fund  for  Rural  Development  (EAFRD)  and 
one  for  the  European  Maritime  and  Fisheries  Fund 
(EMFF) are foreseen. 

In  the  new  period  the  total  amount  that  Greece  will 
receive is EUR20.6 billion (EC contribution).  

The biggest share – EUR 8.1 billion (40.1%) of funding is 
coming 
for  Regional 
the  European  Fund 
Development (ERDF). 

from 

EUR 4.7 billion (23.1%) – from the European Agricultural 
Fund for Rural Development (EAFRD). 

EUR  3.6  billion  (18.1%)  -  from  the  European  Social  Fund 
(ESF). 

EUR 3.2 billion (15.9%) - from the Cohesion Fund (CF). 

EUR  388.7  million  (1.9%)  from  the  European  Maritime 
and Fisheries Fund (EMFF). 

In total, EUR 4.2 billion is dedicated to Thematic objective 
(TO)  6  Environment  Protection  and  Resource  efficiency, 
EUR 1.73 billion through the CF, EUR 1.39 billion through 
the  EAFRD  programme,  EUR  1  billion  through  the  ERDF 
programme  and  EUR  136  million  through  the  EMFF.  In 
addition, EUR 2.1 billion is foreseen for TO4 Low Carbon 
Economy (ERDF, CF, EAFRD and EMFF) and EUR 1.2 billion 
for  TO5  Climate  Change  Adoption  and  Risk  Prevention 
(EAFRD, ERDF and CF) (see Figure 11). 

Greece  is  a  major  user  of  the  European  Investment 
Portal.  This  may  help  to  attract  investment  into  Greek 
environmental projects. 

Figure  11  depicts  the  2014-2020  EU  Structural  and 
Investment Funds budget allocation for Greece. 

73 European Commission, 2015. Public procurement 
74 European Commission, 2015. Documentation on National GPP Action 

Plans 

75  Adelphi  et  al.  2011.  Strategic  Use  of  Public  Procurement  in  Europe, 

Study for the European Commission 

76  ESIF  comprises  five  funds  –  the  European  Regional  Development 
Funds  (ERDF),  the  Cohesion  Fund  (CF),  the  European  Social  Fund 
(ESF),  the  European  Agricultural  Fund  for  Rural  Development 
(EAFRD), and the European Maritime and Fisheries Fund (EMFF). The 
ERDF, the CF and the ESF together form the Cohesion Policy funds. 
77  European  Investment  Bank,  2016  European  Fund  for  Strategic 

Investments 

Environmental Implementation Report – Greece 

 
                                                            
 
 
 
 
 
 
 
 
Figure  11:  European  Structural  and  Investment  Funds 
2014-2020: Budget Greece by theme, EUR billion78 

Greece  21 

is EUR185bn/year, for which 30% is allocated to greening. 
Given  the  prevalence  of  small  farms  and  permanent 
crops in Greece, the impact of greening is reduced.  

It is too early to draw conclusions as regards the use and 
results of ESIF for the period 2014-2020, as the relevant 
programmes  are  still  at  an  early  stage  of  their 
implementation.  As  for  the  2007-2013  period,  data 
suggest  that  the  total  use  of  ERDF  and  CF  as  of 
September  2016  is  99.5%  for  all  investment  categories, 
including the environmental sector80. 

is  the  Environmental 
One  good  practice  example 
Network,  a  network  of  national  and 
regional 
environmental  and  managing  authorities  ensuring 
integration through the ESIF activities79. 

With regard to the integration of environmental concerns 
into  the  Common  Agricultural  Policy  (CAP),  the  two  key 
areas  for  Greece  (as  for  all  Member  States)  are,  firstly, 
using Rural Development funds to pay for environmental 
land  management  and  other  environmental  measures, 
while  avoiding  financing  measures  which  could  damage 
the  environment; and  secondly,  ensuring  the  effective 
implementation of the first pillar of the CAP with regard 
to cross-compliance and first pillar 'greening'. 

to 

is  allocated 

the  baseline, 

With regard to the Rural Development second pillar, the 
total  EAFRD  budget  for  Greece  is  EUR354m,  of  which 
7.5% 
the  agri-environment-climate 
measure.  Many  of  the  Greek  environmental  measures 
remain  near 
lacking  environmental 
ambition.  Poor  coverage  by  Natura  2000  management 
plans puts biodiversity at risk, and this should have been 
given more focus. The situation with regard to irrigation 
and water management also needs to be kept up to date 
implementation  of  the  Water  Framework 
with  the 
Directive.  

For the first pillar, the national direct payment envelope 

78  European  Commission,  European  Structural  and  Investment  Funds 

Data By Country 

79 http://www.eysped.gr/el/Pages/epedi.aspx  

80 Final data for the period 2007-2013 will only be available at the end 

of 2017.   

Environmental Implementation Report – Greece 

 
 
                                                            
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                            
5. Effective governance and knowledge 

Greece  22 

and 

technology 

SDG  16  aims  at  providing  access  to  justice  and  building 
effective,  accountable  and  inclusive  institutions  at  all 
levels. SDG 17 aims at better implementation, improving 
policy  coordination  and  policy  coherence,  stimulating 
science, 
innovation,  establishing 
partnerships and developing measurements of progress. 
Effective governance of EU environmental legislation and 
policies  requires  having  an  appropriate 
institutional 
framework,  policy  coherence  and  coordination,  applying 
legal  and  non-legal  instruments,  engaging  with  non-
governmental  stakeholders,  and  having  adequate  levels 
of  knowledge  and  skills81.  Successful  implementation 
depends, to a large extent, on central, regional and local 
government  fulfilling  key  legislative  and  administrative 
tasks,  notably  adoption  of 
implementing 
legislation,  co-ordinated  action  to  meet  environmental 
objectives  and  correct  decision-making  on  matters  such 
as  industrial  permits.  Beyond  fulfilment  of  these  tasks, 
to  ensure  day-to-day 
government  must 
compliance  by  economic  operators,  utilities  and 
individuals  ("compliance  assurance").  Civil  society  also 
has  a  role  to  play,  including  through  legal  action.  To 
underpin the roles of all actors, it is crucial to collect and 
share  knowledge  and  evidence  on  the  state  of  the 
environment  and  on  environmental  pressures,  drivers 
and impacts. 

intervene 

sound 

implemented  when 

Equally,  effective  governance  of  EU  environmental 
legislation  and  policies  benefits  from  a  dialogue  within 
Member  States  and  between  Member  States  and  the 
Commission  on  whether  the  current  EU  environmental 
legislation  is  fit  for  purpose.  Legislation  can  only  be 
properly 
into  account 
experiences  at  Member  State  level  with  putting  EU 
commitments  into  effect.  The  Make  it  Work  initiative,  a 
Member  State  driven  project,  established 
in  2014, 
organizes a discussion on how the clarity, coherence and 
legislation  can  be 
structure  of  EU  environmental 
improved,  without 
protection 
existing 
standards. 

lowering 

it  takes 

Effective governance within central, regional 
and local government 

Those  involved  in  implementing  environment  legislation 
at  Union,  national,  regional  and  local  levels  need  to  be 
equipped  with  the  knowledge,  tools  and  capacity  to 
improve  the  delivery  of  benefits  from  that  legislation, 
and the governance of the enforcement process. 

81  The  Commission  has  work  ongoing  to  improve  the  country-specific 
knowledge  about  quality  and  functioning  of  the  administrative 
systems of Member States. 

Capacity to implement rules 

is 

that 

crucial 

regional  and 

 It 
local 
central, 
administrations  have  the  necessary  capacities,  skills  and 
training  to  carry  out  their  own  tasks  and  to  co-operate 
and  co-ordinate  effectively  with  each  other,  within  a 
system of multi-level governance. 

The Ministry of Environment & Energy is responsible for 
the  elaboration  of  a  global  environmental  policy,  the 
preparation of plans and programmes, and the control of 
their  execution.  The  Ministry  is  also  in  charge  of  the 
transposition  of  EU  environmental  Directives 
into 
national law. 

their  areas, 

At  the  decentralised  level,  the  regional  and  municipal 
authorities  exercise,  within 
certain 
environmental  competences  and  assure  the  practical 
application  of  various  environmental  measures  (e.g. 
water quality, waste management, impact assessments). 
An  environmental  inspectorate  has  been  operational 
since  2004,  but  its  decisions  and  reports  are  often 
ignored. 

Reaching the deadlines and requirements imposed by EU 
environmental  legislation  appears  to  remain  an  issue  of 
concern.  This  could  be  explained  by  the  relatively  low 
(and  reduced  during  the  last  years)  number  of  human 
resources  dealing  with  the  huge  environmental  acquis, 
combined  with  the  bottlenecks  created  by  the  lengthy 
and  complicated  administrative  procedures  in  place, 
which  often  involve  many  actors  from  various  levels  of 
public administration.  

The number of open cases is very high (27 infringement 
cases,  of  which  19  at  258  stage  and  8  at  260  stage).  In 
general,  there  are  no  significant  problems  regarding  the 
quality  of  transposition  of  the  EU  Directives  (the 
problems 
their 
implementation). The Court of Justice has imposed fines 
on Greece for non-compliance with EU law provisions in 
the  fields  of  solid  waste  and  urban  waste  water 

essentially 

related 

are 

to 

Environmental Implementation Report – Greece 

 
 
                                                            
 
treatment  and  penalty  payments  remain  due  as  long  as 
the judgments of the Court are not fully executed by the 
Member State. 
The transposition of the revised EIA Directive82 will be an 
opportunity  to  streamline  the  regulatory  framework  on 
environmental assessments. The Commission encourages 
the  streamlining  of  the  environmental  assessments  to 
avoid  overlaps 
in  environmental  assessments  and 
accelerate  decision-making,  without  compromising  the 
quality of the environmental assessment procedure. The 
Commission  has  issued  a  guidance  document  in  201683 
regarding  the  setting  up  of  coordinated  and/or  joint 
to 
procedures 
assessments  under  the  EIA  Directive,  Habitats  Directive, 
Water Framework Directive, and the Industrial Emissions 
Directive. 

simultaneously 

that  are 

subject 

Suggested action 

  Simplify  environmental  administrative  procedures  and 
improve cooperation of public authorities (at national, 
regional and local levels) involved in the application of 
environmental policies. 

Compliance assurance 

in  place 

EU  law  generally  and  specific  provisions  on  inspections, 
other  checks,  penalties  and  environmental  liability  help 
lay  the  basis  for  the  systems  Member  States  need  to 
secure  compliance  with  EU 
to 
have 
environmental rules. 
Public  authorities  help  ensure  accountability  of  duty-
holders by monitoring and promoting compliance and by 
taking credible follow-up action (i.e. enforcement) when 
breaches occur or liabilities arise. Compliance monitoring 
can  be  done  both  on  the 
initiative  of  authorities 
themselves  and  in  response to  citizen  complaints. It  can 
including 
involve  using  various  kinds  of  checks, 
inspections  for  permitted  activities,  surveillance  for 
possible  illegal  activities,  investigations  for  crimes  and 
audits for systemic weaknesses. Similarly, there is a range 
of  means  to  promote  compliance,  including  awareness-
raising  campaigns  and  use  of  guidance  documents  and 
online  information  tools.  Follow-up  to  breaches  and 
liabilities  can 
(e.g. 
withdrawal of a permit), use of criminal law84 and action 
law  (e.g.  required  remediation  after 
under 
damage  from  an  accident  using 
liability  rules)  and 
contractual  law  (e.g.  measures  to  require  compliance 

include  administrative  action 

liability 

82 The transposition of Directive 2014/52/EU is due in May 2017. 
83  European  Commission,  2016.  Commission  notice  —  Commission 
guidance  document  on  streamlining  environmental  assessments 
conducted  under  Article  2(3)  of 
Impact 
Assessment  Directive  (Directive  2011/92/EU  of  the  European 
Parliament and of the Council, as amended by Directive 2014/52/EU). 
84European  Union,  Environmental  Crime  Directive  2008/99/EC 

the  Environmental 

Environmental Crime Directive 2008/99/EC 

Greece  23 

with  nature  conservation  contracts).  Taken  together,  all 
of these interventions represent "compliance assurance" 
as shown in Figure 12.  

Figure 12: Environmental compliance assurance 

Best  practice  has  moved  towards  a  risk-based  approach 
at strategic and operational levels in which the best mix 
of compliance monitoring, promotion and enforcement is 
directed at the most serious problems. Best practice also 
recognises  the  need  for  coordination  and  cooperation 
between  different  authorities  to  ensure  consistency, 
avoid  duplication  of  work  and  reduce  administrative 
burden. Active participation in established pan-European 
networks  of  inspectors,  police,  prosecutors  and  judges, 
such as IMPEL85, EUFJE86, ENPE87 and EnviCrimeNet88, is a 
valuable tool for sharing experience and good practices. 

Currently, there exist a number of sectoral obligations on 
inspections  and  the  EU  directive  on  environmental 
liability  (ELD)89  provides  a  means  of  ensuring  that  the 
"polluter-pays  principle" 
is  applied  when  there  are 
accidents  and  incidents  that  harm  the  environment. 
There 
information  giving 
insights  into  existing  strengths  and  weaknesses  in  each 
Member State.  

is  also  publically  available 

For  each  Member  State,  the  following  were  therefore 
reviewed:  use  of  risk-based  compliance  assurance; 
coordination  and  co-operation  between  authorities  and 
participation in pan-European networks; and key aspects 
of implementation of the ELD based on the Commission's 
recently  published  implementation  report  and  REFIT 
evaluation90. 

85 European Union Network for the Implementation and Enforcement of 

Environmental Law 

86 European Union Forum of judges for the environment 
87 The European Network of Prosecutors for the Environment 
88 EnviCrimeNet  
89 European Union, Environmental Liability Directive 2004/35/CE, p.56 
90  COM(2016)204  final  and  COM(2016)121  final  of  14.4.2016.  This 
highlighted the need for better evidence on how the directive is used 
in practice; for tools to support its implementation, such as guidance, 
training and ELD registers; and for financial security to be available in 
case events or incidents generate remediation costs. 

Environmental Implementation Report – Greece 

 
                                                            
 
                                                            
Over  the  last  decade,  Greece  has  made  efforts  to 
improve  its  system  of  inspections  of  industrial  facilities. 
Some 
relevant  data  collection  and  analysis  are 
undertaken  and  annual  activities  reports  are  published 
online by the Hellenic Environmental Inspectorate, which 
is  empowered  to  carry  out 
inspections  and  other 
compliance  assurance  tasks  across  environmental  policy 
subject-areas91.  

 

Up-to-date  information  is  lacking  in  relation  to  the 
following: 
  data-collection  arrangements  to  track  the  use  and 
effectiveness  of  different  compliance  assurance 
interventions; 
the extent to which risk-based methods are used to 
direct  compliance  assurance  at  the  strategic  level 
and 
in  relation  to  critical  activities  outside  of 
industrial installations92, especially specific problem-
areas  highlighted  elsewhere  in  this  Country  Report, 
i.e.  illegal  landfills,  the  threats  to  protected  habitat 
types and species, poor air quality and the pressures 
on  water  quality  from  diffuse  and  point  sources  of 
pollution,  including  deficient  urban  and  domestic 
waste-water systems. 

  how  the  Greek  authorities  ensure  a  targeted  and 
proportionate  response  to  different  types  of  non-
compliant  behaviour,  in  particular  in  relation  to 
serious  breaches  detected,  given  indications  that 
low  probability  of  being  criminally 
there 
is  a 
for  environmental 
prosecuted  and 
offences.  

sentenced 

Greece  does  not  actively  participate  in  the  activities  of 
the  European  networks  of  environmental  professionals, 
in particular since the beginning of the financial crisis.  

to 

requirements  of 

For  the  period  2007-2013,  Greece  reported  52  cases 
handled  according 
the 
the 
Environmental Liability Directive. The country established 
a supporting administrative office for the implementation 
of the Directive and has participated in the Commission's 
training programme for competent authorities and other 
stakeholders.  It  also  decided  to  establish  mandatory 
financial  security 
for  remediation  where 
operators  cannot)  which  however  has  not  become 
operational to date. The implementation of the Directive 
appears to have had positive effects on taking preventive 
measures  and  addressing  environmental  damage,  but 

(to  pay 

91 Hellenic Environmental Inspectorate  
92  Weaknesses  have  been  identified  concerning  strategic  planning  and 
preparation  of  inspection  plans  and  programmes,  see  Study  on 
'Assessment  and  summary  of  the  Member  States'  implementation 
reports  for  the  IED,  IPPCD,  SED  and  WID.  Industrial  Emissions 
Directive,  2016,  Amec  Foster  Wheeler  Environment&Infrastructure 
UK  Ltd  in  collaboration  with  Milieu  Ltd,  p.  234-235..  Weaknesses 
have also been identified in relation to control of water abstraction, 
see    European  Court  of  Auditors,  Special  Report  No  4,  2014, 
Integration  of  EU  water  policy  objectives  with  the  CAP:  a  partial 
success, p. 31f 

Greece  24 

lack of resources presents a challenge. 

Suggested action 

  Improve 

transparency  on 

the  organisation  and 
functioning  of  compliance  assurance  and  on  how 
significant risks are addressed, as outlined above. 

  Encourage 

greater  participation  of 

competent 

authorities in environmental compliance networks.  

  Step  up  efforts 

implementation  of  the 
Environmental  Liability  Directive  (ELD)  with  proactive 
initiatives, in particular by drafting national guidance. 

in  the 

Public participation and access to justice 

The  Aarhus  Convention,  related  EU  legislation  on  public 
participation and environmental impact assessment, and 
the case-law of the Court of Justice require that citizens 
and  their  associations  should  be  able  to  participate  in 
decision-making  on  projects  and  plans  and  should  enjoy 
effective environmental access to justice. 

Citizens  can  more  effectively  protect  the  environment  if 
they can rely on the three "pillars" of the Convention on 
Access  to  Information,  Public  Participation  in  Decision-
making  and  Access  to  Justice  in  Environmental  Matters 
("the  Aarhus  Convention").  Public  participation  in  the 
administrative  decision  making  process  is  an  important 
element to ensure that the authority takes its decision on 
the  best  possible  basis.  The  Commission  intends  to 
examine compliance with mandatory public participation 
requirements more systematically at a later stage. 

Access  to  justice  in  environmental  matters  is  a  set  of 
guarantees  that  allows  citizens  and  their  associations  to 
challenge  acts  or  omissions  of  the  public  administration 
before  a  court. 
for  decentralised 
It 
implementation of EU environmental law. 

is  a 

tool 

For  each  Member  State,  two  crucial  elements  for 
effective  access  to  justice  have  been  systematically 
reviewed:  the  legal  standing  for  the  public,  including 
NGOs and the extent to which prohibitive costs represent 
a barrier. 

Greece grants the public, notably individuals and NGOs, a 
broad access to justice in environmental cases. The costs 
for  bringing  a  case  to  a  court  are  also  not  prohibitively 
high.  This  guarantees  that  members  of  the  public  are 
provided  with  good  conditions  for  asking  for  a  judicial 
review in environmental matters in Greece. However, the 
court  procedures, 
in 
Greece are very long93.  

including  environmental  cases, 

93 European Commission, 2012/2013 access to justice in environmental 

matters  

Environmental Implementation Report – Greece 

 
 
                                                            
 
                                                            
Greece  25 

between  public  authorities,  the  implementation  of  this 
legislation  within  Greek  administration  is  in  many  cases 
problematic.  Of  600  spatial  data  sets  that  have  been 
identified  by  Greece,  only  30  have  been  made  available 
for publication.  
Assessments  of  monitoring  reports99  issued  by  Greece 
and the spatial information that Greece has published on 
the  INSPIRE  geoportal100  indicate  that  not  all  spatial 
and 
for 
information 
implementation of EU environmental law has been made 
available  or  is  accessible.  The  larger  part  of  this  missing 
spatial  information  consists  of  the  environmental  data 
required  to  be  made  available  under  the  existing 
reporting 
EU 
environmental  law  (Annex  III  of  the  INSPIRE  Directive), 
which may be due to lacking or insufficient coordination 
in Greece between INSPIRE stakeholders. 

and  monitoring 

regulations 

evaluation 

needed 

the 

of 

Suggested action 

  Critically  review  the  effectiveness  of  data  policies  and 
amend them, taking 'best practices' into consideration.  
  Identify and document all spatial data sets required for 
the  implementation  of  environmental  law,  and  make 
the  data  and  documentation  at  least  accessible  'as  is' 
to  other  public  authorities  and  the  public  through  the 
digital services foreseen in the INSPIRE Directive. 

Access to Information, knowledge and 
evidence 

The  Aarhus  Convention  and  related  EU  legislation  on 
access  to  information  and  the  sharing  of  spatial  data 
require that the public has access to clear information on 
the environment, including on how Union environmental 
law is being implemented. 

authorities 

public 
the  public, 

and 
increasingly 

It is of crucial importance to public authorities, the public 
and business that environmental information is shared in 
an  efficient  and  effective  way.  This  covers  reporting  by 
active 
and 
businesses 
through 
to 
dissemination 
electronic means. 
The  Aarhus  Convention94,  the  Access  to  Environmental 
Information  Directive95  and  the 
INSPIRE  Directive96 
together  create  a  legal  foundation  for  the  sharing  of 
environmental  information  between  public  authorities 
and with the public. They also represent the green part of 
the  ongoing  EU  e-Government  Action  Plan97.  The  first 
to  provide 
two 
information  to  the  public,  both  on  request  and  actively. 
The  INSPIRE  Directive  is  a  pioneering  instrument  for 
electronic  data-sharing  between  public  authorities  who 
can  vary  in  their  data-sharing  policies,  e.g.  on  whether 
access to data is for free. The INSPIRE Directive sets up a 
geoportal which indicates the level of shared spatial data 
in  each  Member  State  –  i.e.  data  related  to  specific 
locations,  such  as  air  quality  monitoring  data.  Amongst 
other  benefits 
it  facilitates  the  public  authorities' 
reporting obligations.  

create  obligations 

instruments 

For  each  Member 
accessibility  of 
State, 
environmental data (based on what the INSPIRE Directive 
envisages)  as  well  as  data-sharing  policies  ('open  data') 
have been systematically reviewed.  

the 

Greece's  performance  on  the  implementation  of  the 
INSPIRE  Directive  as  enabling  framework  to  actively 
disseminate  environmental  information  to  the  public 
leaves  room  for  improvement.  Greece  has  indicated  in 
the  3-yearly  INSPIRE  implementation  report98  that  the 
necessary  data-sharing  policies  allowing  access  and  use 
of  spatial  data  by  national  administrations,  other 
Member  States'  administrations  and  EU 
institutions 
without  procedural  obstacles  are  available  but  not  fully 
implemented. Although it is mandated by Greek law that 
spatial  data  have  to  be  exchanged  free  of  charge 

94UNECE,  1998.  Convention  on  Access 

to 

Participation 
Environmental Matters 

in  Decision-Making  and  Access 

Information,  Public 
in 

Justice 

to 

95European  Union,  Directive  2003/4/EC  on  public  access 

to 

environmental information 

96European Union, INSPIRE Directive 2007/2/EC  
97European  Union,  EU  eGovernment  Action  Plan  2016-2020 

- 
Accelerating  the  digital  transformation  of  government  COM(2016) 
179 final 

98European Commission, INSPIRE reports 

99 Inspire indicator trends  
100 Inspire Resources Summary Report 

Environmental Implementation Report – Greece