What is the status of the transposition of Art 25.6(EDD) and its implementation ?
Regulatory adjustments and establising a comprehensive support framework will be necessary to make the transposition of EED article 25.6 feasible in Greece.
In Greece, there is no legal obligation nor incentive in place for local authorities to develop local heating and cooling plans as such, although recent obligations for a municipal emissions’ reduction plans is a promising signs for more favourable regulation. Greek municipalities owe very limited support to develop such plans, and the support mechanisms need to be substantially strengthened to make a transposition of the EED article 25.6 feasible in Greece. Recent heatwaves and increased cooling demand have illustrated the urgency in Greece to develop localized strategies for decarbonised and more resilient thermal systems for the built environment.
The legal framework and the obligations
The new requirement for municipal emissions reduction plans is insufficienct to cover the provisions of the EED article 25.6
Overview of the legal frameworks per governance level in Greece
National | Greece’s main energy and climate objectives are enshrined in its National Climate Law adopted in 2022, and in its National Energy and Climate Plan, published in 2019. Greece has set a a target of 43 % in 2030 for the share of renewable energy in the heating and cooling consumption, but without clear energy efficiency targets. |
Local | The National Climate Law contains an obligation for all Greek municipalities (article 16) to draft municipal emission reduction plans by 31 March 2022. The submission of the plans is a condition from 2023 on for accessing the national financial instruments in the fields of energy and climate. The Law introduced mandatory content, guidelines, and a monitoring system for these plans. It lacks specific objectives or content regarding the heating and cooling of buildings and will mainly cover the public sector emissions and not the residential or private sector. The municipal emissions’ reduction plans must be updated every 5 years with a report issued annually. The first stage of the plans consists in doing an inventory of the energy consumption of municipal buildings and assets. The second plan will consist in calculating the carbon footprint of the municipalities and the third phase to propose mitigation measures. |
The financial, technical, and skills support available to local authorities is very limited
There is no support framework in place to support the development of local heating and cooling plans in Greece, or for other energy-related planning documents drafted at the local level. Greek municipalities lack access to technical guidance and dedicated streams of funding for drafting such plans. Greek local authorities are today highly restricted in their capacity to carry out energy and climate related tasks due to substantial staff and skills shortages in their administrations, which today are almost exclusively outsourced to external contractors. Greek municipalities are also restricted by limited access to readily available and sufficiently detailed energy-related geodata. Substantial efforts will therefore be needed to provide Greek local administrations with technical and financial support mechanisms to develop local heating and cooling plans, to improve access to energy-related geodata, and to build staffing capacities.
Provided Support
Technical and organisational | 1/5 | There is no technical support regarding heating and cooling plans. Some municipalities are working on the topic only thanks to the expertise of some EU projects. Some support has been developed for the preparation of municipal emission reduction plans, which however do not cover heating or cooling. |
Financial | 1/5 | There is no dedicated fund regarding heating and cooling projects or planning. More broadly, cities can access a new national program that supports climate and energy projects but does not provide any specific support for heating and cooling planning. |
Staff & skills | 1/5 | There is a substantial lack of expertise and staff in Greek municipalities on climate and energy-related issues. Almost all municipal plans (SECAPs or municipal emissions reduction plans) are assigned to external consultants. The recent National Climate Law makes it mandatory to have at least one energy officer in each Greek municipality. However, no additional budget is foreseen for the municipalities to develop a skills or staff strategy. |
Access to data | 1/5 | Greek Municipalities lack access to energy-related geodata. Utilities are not obliged to cooperate with municipalities and the building information and RES potential data are not available. The municipal emissions’ reduction plan will mainly concern the collection and analysis of data on the energy consumption of publicly owned assets and buildings. This could work as an initial steppingstone for developing heating and cooling assessments but will be insufficient for the purpose of heating and cooling planning. |