Partner Athens
"A green hydrogen strategy is a vital part of the government's sustainable transition strategy in order for renewable energy to be used for transport and heating."
Hydrogen in the context of the National Energy and Climate Plan
The Greek National Energy and Climate Plan published in 2019 (“NECP”)¹ sets out the objectives, policies and measures for the achievement of Greece’s energy and climate goals by 2030.
The implementation of hydrogen solutions may contribute especially to the following goals:
- Renewable Energy Sources (“RES”) promotion: Greece has set the following targets for 2030², aiming to achieve a RES share of at least:
– 35% in the gross final consumption of energy;
– 60% in the gross final consumption of electricity;
– 40% in the heating and cooling sector; and
– 14% in the transport sector
In this context, new applications and technologies for the generation of power from RES, such as the production of hydrogen, will likely be assessed through pilot projects.
The NECP states that “the options for coupling the electricity and gas sectors (power-to-gas) through storage applications that include conversion of electricity into renewable gas, such as hydrogen, are equally important. The gas produced by using RES energy may be fed into the existing gas network and used as fuel for heating in buildings or in transport. Moreover, an appropriate regulatory framework should enable different sources and different energy operators (hydrogen, biofuels, biomethane) to function on a complementary basis, contributing to most cost-effective and sustainable system functioning. Measures for ensuring the penetration of RES in new uses and sectors, the energy coupling of sectors and the development of relevant pilot and innovative applications are a policy priority in the context of the NECP for the following decade³“.
"In December 2020, the Greek Ministry of Environment & Energy announced the launch of a special Committee which will produce a draft National Strategy Plan for the promotion of technologies and applications of hydrogen and other gases from RES."
- Decarbonisation: The phasing out of lignite-fired power stations is one of the top priorities of the NECP, which sets a target of zero lignite-powered electricity generation by 2028. In line with these objectives, a Master Plan for Fair Development Transition was issued in December 2020, outlining the government’s commitments for the post-lignite era and also calling for investments involving renewable hydrogen⁴.
- Energy storage: High levels of RES integration in the system requires the implementation of energy storage. The NECP notes that, “there is also interest in power-to-gas (e.g. hydrogen) storage applications, in the context of which the interconnection of electricity and gas networks is also investigated⁵“.
Committee for the National Hydrogen Strategy
In December 2020, the Greek Ministry of Environment & Energy (the “Ministry”) announced the launch of a special Committee (the “Committee”)⁶ which will produce a draft National Strategy Plan for the promotion of technologies and applications of hydrogen and other gases from RES. According to the Ministry’s press release⁷, the development of new clean energy sources and technologies is a priority of the national climate and energy strategy.
The Committee’s work will include the following:
- Assessing the domestic potential for the development of applications for hydrogen (and other gases from RES) in individual energy sectors (electricity generation, natural gas network, transport, industry).
- Proposing policy measures to promote applications and technologies for hydrogen and other gases from RES.
- Identifying the technical and economic requirements for applications and technologies for hydrogen and other gases from RES.
- Proposals for the licensing and regulatory framework, where necessary.
- Comparative assessment of other European States’ hydrogen strategies.
- Assessing the compatibility of proposed national measures and policies with European Strategies, the state aid legal framework and examining whether it is possible to refer to EU funding mechanisms⁸.
"Greece is one of the 23 European countries which signed the "Manifesto for the development of a European Hydrogen Technologies and Systems value chain"."
Following its initial assessment, the Committee will indicate:
- A Roadmap for the development and use of technologies and applications for hydrogen and other gases from RES in individual energy sectors.
- The proposed policy measures by energy sector and use.
- The technical and economic data on the cost for the development and operation of applications for hydrogen and other gases from RES⁹.
The Committee is expected to complete its work and present a draft National Hydrogen Strategy Plan in September 2021.
Hydrogen in existing national legislation
The first step towards the regulation of hydrogen use as an alternative fuel in the transport sector was introduced by Law 4439/2016 on the adoption of Directive 2014/94/EU of the European Parliament and of the Council of 22 October 2014 on the development of alternative fuel infrastructures and simplification of licensing procedure (“Law 4439”).
Pursuant to Law 4439, the National Policy Framework for the development of an alternative fuel infrastructure market in the transport sector was issued in 2017 (“NPF”)¹⁰. The NPF did not provide for the creation of hydrogen refuelling points, as at that time it did not foresee the use of hydrogen as an alternative fuel in the transport sector in the near future. However, if the use of hydrogen and the development of relevant infrastructure is pursued, Law 4439 grants the authorisation for the introduction of the regulatory framework on the installation of refuelling points for hydrogen (and other alternative fuels), as well as of the regulatory framework regarding the infrastructure for the repair and maintenance of alternative fuels vehicles (including hydrogen-powered vehicles) and the accreditation of technical staff engaged in such works.
Current initiatives in Greece
The following initiatives launched recently indicate Greece’s interest in deploying hydrogen in the Greek energy market:
"Greece participates in the European Hydrogen Backbone ("EHB") initiative through DESFA as the national European gas Transmission System Operator."
- Greece is one of the 23 European countries which signed the “Manifesto for the development of a European Hydrogen Technologies and Systems value chain”. The countries involved “are pursuing ambitious low-carbon and renewable hydrogen goals” and have committed to “launching the Important Projects of Common European Interest on Hydrogen Technologies and Systems (“IPCEI“) on Hydrogen and to initiating the next steps in coordination with the European Commission, the European Clean Hydrogen Alliance and European industry¹¹“. Following this undertaking, on 8 April 2021 the Ministry of Environment & Energy and the Ministry of Development & Investments published a Call for expressions of interest, of a non-binding nature, for Greek enterprises to participate in the IPCEI in the industrial value chain “Hydrogen Technologies and Systems¹²“.
- In December 2020, a press release was published by DEPA Commercial S.A. according to which “a memorandum of cooperation was signed between the Region of Western Macedonia and DEPA Commercial SA, for the implementation of a plan for the development of green hydrogen infrastructure in Western Macedonia. This cooperation is part of the better preparation of the application dossier of the proposal titled “White Dragon”, which will be submitted as an Important Project of Common European Interest (IPCEI), in the respective European program¹³“. In a recent press release, DEPA Commercial S.A. stated that “the first national project SEKEE (Important Projects of Common European Interest / IPCEI), the White Dragon, of which DEPA Commercial S.A. is the coordinator, is designed in Western Macedonia and mainly aims to ensure adequate supply of district heating after the removal of lignite plants.This project comes to support the Region of Western Macedonia, which is most affected by decarbonization and which depends on the district heating system that currently operates with lignite¹⁴“.
- A Memorandum of Understanding was signed on 25 February 2021 between DEPA Commercial S.A., DEPA International Projects and Corinth Pipeworks S.A. for the implementation of joint actions for the promotion and expansion of the use of hydrogen in Greece’s energy system¹⁵.
- Greece participates in the European Hydrogen Backbone (“EHB”) initiative through DESFA as the national European gas Transmission System Operator. According to the EHB “the proposed expanded pan-European hydrogen backbone can further support the integration of renewable and clean energy sources in regions that were not yet included in the initial European Hydrogen Backbone plan as published in 2020. These include Finland, Estonia, large parts of central and eastern Europe, Greece, Ireland, and the United Kingdom¹⁶“. In the country narratives, the recent EHB plan provides that “Greece’s excellent conditions for both wind and solar power would allow the complete phase out of coal-based power plants by 2028 or even earlier“. It is further stated that “The two main industrial clusters, in Thessaloniki and Athens, are potential large demand sources for hydrogen. In addition, according to the recently developed Master Plan for the decarbonisation of the lignite production area of West Macedonia, there is large potential of hydrogen production in the region. This potential stems from the expected deployment of large scale PV plants, along with the potential for the use of hydrogen locally or its transportation through the new hydrogen-ready pipeline DESFA is deploying in the region¹⁷“. Finally, the EHB mentions that “by 2040, Greece’s two main industrial clusters in Athens and Thessaloniki would be connected, with new pipelines following the existing natural gas route, repurposing existing pipelines can also be an option depending on market conditions. Storage could be available in the form of an aquifer near the Island of Thasos¹⁸“.
Next Steps
The National Hydrogen Strategy Plan, which we are expecting to be published in September 2021, should provide the clarity and certainty that developers, investors and lenders need for the widespread interest in deploying hydrogen in the Greek energy market to translate into real projects across a range of sectors.
If you would like to discuss any of the issues raised in this article, please contact the authors, Athens Partner Virginia Murray, Senior Associate Maira Galani and Fotini Nassou, a trainee lawyer in our Athens office.
This is the eighth article in our ‘Hydrogen – What is the hype about?’ series, which provides an overview of the hydrogen sector and the strategy for its development in multiple jurisdictions. To read other articles in the series please click here.
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[1] Government Gazette B’ 4893/31.12.2019.
[2] National Energy and Climate Plan (2019), English translation, Table 2: Summary of national objectives under the NECP, p. 43. It can be found in: https://ec.europa.eu/energy/sites/default/files/el_final_necp_main_en.pdf.
[3] National Energy and Climate Plan (2019), English translation, p. 133. It can be found in: https://ec.europa.eu/energy/sites/default/files/el_final_necp_main_en.pdf.
[4] Master Plan for Fair Development Transition (2020), p. 16-17.
[5] National Energy and Climate Plan (2019), English translation, p. 66. It can be found in: https://energy.ec.europa.eu/system/files/2020-03/el_final_necp_main_en_0.pdf.
[6] Decision no. ΥΠΕΝ/ΔΑΠΕΕΚ/119793/4431 dated 12.12.2020 (as corrected on 15.12.2020). It can be found in https://diavgeia.gov.gr/decision/view/6%CE%A0%CE%A6%CE%A04653%CE%A08-9%CE%92%CE%9D.
[7] https://ypen.gov.gr/systasi-epitropis-gia-ti-charaxi-ethnikis-stratigikis-gia-to-ydrogono/.
[8] Article 2 par. 1 of the Ministerial Decision no. ΥΠΕΝ/ΔΑΠΕΕΚ/119793/4431/12.12.2020.
[9] Article 2 par. 2 of the Ministerial Decision no. ΥΠΕΝ/ΔΑΠΕΕΚ/119793/4431/12.12.2020.
[10] Ministerial Decision no. 77226/1/2017 (Government Gazette Β’ 3824/31-10-2017).
[11] Manifesto for the development of a European “Hydrogen Technologies and Systems” value chain (2020). It can be found in: https://www.ggb.gr/sites/default/files/announcementsfiles/Manifesto_IPCEI%20Hydrogen.pdf.
[12] https://ypen.gov.gr/prosklisi-ekdilosis-endiaferontos-gia-to-sekee-technologies-kai-systimata-ydrogonou/
[13] https://www.depa.gr/mnimonio-synergasias-perifereias-dytikis-makedonias-kai-depa-eborias-a-e-gia-tin-anaptyxi-ypodomon-prasinou-ydrogonou/?lang=en.
[14] https://www.depa.gr/depa-commercial-participated-in-the-round-table-for-the-use-of-hydrogen-in-buildings-of-the-european-clean-hydrogen-alliancesymmetochi-tis-depa-eborias-sti-strongyli-trapeza-gia-tin-chrisi-ydrogonou-s/?lang=en.
[15] https://www.depa.gr/collaboration-between-depa-commercial-depa-international-projects-corinth-pipeworks-to-promote-the-use-of-hydrogen-in-greeces-energy-system/?lang=en.
[16] Gas for Climate, Extending the European Hydrogen Backbone (April 2021), p. 3, https://gasforclimate2050.eu/gas-for-climate/who-we-are/.
[17] Gas for Climate, Extending the European Hydrogen Backbone (April 2021), p. 26, https://gasforclimate2050.eu/gas-for-climate/who-we-are/.
[18] Gas for Climate, Extending the European Hydrogen Backbone (April 2021), p. 26, https://gasforclimate2050.eu/gas-for-climate/who-we-are/.
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