hellenic republic - european commission · references: (a) p.d. 148/2009 “environmental liability...

HELLENIC REPUBLIC

MINISTRY OF ENVIRONMENT, ENERGY AND CLIMATE CHANGE, SPECIAL SECRETARIAT FOR THE ENVIRONMENT AND ENERGY INSPECTORATE, Independent Coordination Office for the Implementation of Environmental Liability (ICOIEL) Postal address: 119 Mesogeion Ave.

101 92 Athens Info: C. Kourenti Tel.: 210 6974764 Fax: 210 6969708 E-mail: [email protected]

Athens, 26 November 2013 Ref. 518

To: 1) Permanent Representation of Greece to

the European Union - Brussels (to be sent by email, encl.) Rue Jacques De Lalaing 19-21 1040 Bruxelles, Belgique 2) Ministry of Environment, Energy and Climate Change Department of International Activities & EC Affairs (to be sent by email, encl.) 15 Amaliados Street, 115 23 Athens

Cc.: Ministry of Environment, Energy, and Climate Change (encl.)

- Office of the Minister for the Environment, Energy and Climate Change, 119 Mesogeion Ave., 101 92

- Office of the Deputy Minister for the Environment, Energy and Climate Change

- Office of the Secretary General of the Ministry of Environment, Energy and Climate Change, 17 Amaliados Street, 115 23 Athens

Subject: Report on the implementation of Directive 2004/35/EC “On environmental liability with

regard to the prevention and remedy of environmental damage” References: (a) P.D. 148/2009 “Environmental liability for the prevention and remedy of

environmental damage – Harmonisation with Directive 2004/35/EC of the European Parliament and of the Council, of 21 April 2004, on environmental damage, as currently in force” (Government Gazette, Series I, No 190) . (b) Document ref. Η.Π.54352/1745/2-10-2013 of the Department of International Activities and EEC Affairs (ref. ICOIEL 414/ 3-10-2013)

We hereby submit the Report on the implementation of Directive 2004/35/EC on Environmental Liability in Greece, as provided for in Article 18 thereof. The report contains the information and data specified in Annex VI to the Directive, and all other available information on developments and actions initiated by the competent authority (ICOIEL) for the effective implementation of environmental liability in Greece. We kindly request that you officially forward the Report to the European Commission.

The Head of ICOIEL

Stavroula Pouli Attached: Report (63 pages) Internal Distribution - Office of the Special Secretary for the Environment & Energy Inspectorate - Archives of ICOIEL

HELLENIC REPUBLIC

MINISTRY OF ENVIRONMENT, ENERGY AND CLIMATE CHANGE SPECIAL SECRETARIAT FOR THE ENVIRONMENT AND ENERGY INSPECTORATE

Independent Coordination Office for the Implementation of Environmental Liability (ICOIEL)

REPORT ON THE IMPLEMENTATION OF DIRECTIVE 2004/35/EC IN GREECE

ATHENS

OCTOBER 2013

from 63

FOREWORD This report presents the progress of the implementation in Greece of Directive 2004/35/EC on

environmental liability with regard to the prevention and remedy of environmental damage

The purpose of the report is to record the experience gained from the implementation of

environmental liability in Greece, as provided for in Article 18 of the Directive.

The report was prepared by the Independent Coordination Office for the Implementation of

Environmental Liability (ICOIEL) of the Special Secretariat for the Environment and Energy

Inspectorate (SSEEI), of the Ministry of Environment, Energy and Climate Change, in collaboration

with the Greek Regional Committees for the Implementation of Environmental Liability (RCIEL).

from 63

CONTENTS

Page

Explanation of Acronyms 3

1. GENERAL SECTION 5

1.1 Introduction 5

1.2 Transposition of Directive 2004/35/EC into the Greek Law 7

1.3 The bodies responsible for the implementation of Directive 2004/35/EC in Greece 8

1.4 Actions by the central competent authority (ICOIEL) for the implementation of

Directive 2004/35/EC in Greece 11

1.4.1 Cooperation and coordination of the competent authorities at central and regional level 12

1.4.2 Cooperation with competent authorities, the European Commission and other Member 16

States and with stakeholders

1.4.3 Implementation of the financial guarantee 17

1.4.4 Issues concerning the staffing - organisation - funding of the central competent authority 19

2. SPECIAL SECTION 21

2.1 Methodology used for the collection of material - information for the preparation of this

report 21

2.2 Summary presentation, analysis and interpretation of results 22

2.3 SPECIAL CASES-ASOPOS RIVER 40

2.3.1 Implementation issues of environmental liability in the area of Asopos river 42

3.1 Problems and challenges for improving the implementation of Directive

2004/35/EC in Greece 44

3.2 Targets and subsequent actions 46

ANNEXES

ANNEX I 47

Uncontrolled discharges of unknown origin

ANNEX II 51

Register of environmental liability cases in Greece - Tables

TABLE 1: Register of environmental liability cases in Greece - “closed” cases 52

TABLE 2 Register of environmental liability cases in Greece -”open” cases 53

Legislative regulations listed in Tables 1 and 2 of Annex II 61

from 63

Explanation of Acronyms

EU European Union

YPEKA Ministry of Environment, Energy, and Climate Change

SSEEI Special Secretariat for the Environment and Energy Inspectorate

ICOIEL Independent Coordination Office for the Implementation of Environmental

Liability

HEI Hellenic Environmental Inspectorate

SES Special Environment Service (Licensing Authority of the Ministry of

Environment, Energy, and Climate Change)

Directorate for the Control of Air Pollution and Noise (EARTH) Directorate for Air

Pollution and Noise Control (Licensing Authority of the Ministry of Environment, Energy, and

Climate Change)

CIEL Committee for the Implementation of Environmental Liability (at central level)

DAA Decentralised Administration of Attica

DATCG Decentralised Administration of Thessaly and Central Greece

DAMT Decentralised Administration of Macedonia and Thrace

DAEWM Decentralised Administration of Epirus and Western Macedonia

DAPWGI Decentralised Administration of Peloponnese, Western Greece and the

Ionian

DAAE Decentralised Administration of the Aegean

DAC Decentralised Administration of Crete

S.G. Secretary General (of the relevant competent decentralised administration,

unless it refers to another administrative body)

DESP Directorate for the Environment and Spatial Planning (of the relevant

competent decentralised administration)

RCIEL Regional Committee for the Implementation of Environmental Liability (at

regional level)

KEPPE Environmental Quality Control Unit

HCMR Hellenic Centre for Marine Research

NGO Non Governmental Organisation

R.U. Regional Unit

P.G. Prefectural Government

M.U. Municipal Unit

M.C. Municipal Community

L.C. Local Community

Gaz. Government Gazette

L. Law

P.D. Presidential Decree

JMD Joint Ministerial Decision

MD Ministerial Decision

DAEC Decision on the Approval of the Environmental Conditions

from 63

Explanation of Acronyms

par. paragraph

No number

WEEE Waste Electrical and Electronic Equipment

ELV End-of-Life Vehicles

IA Industrial Area

BP Business Park

NNR New National Road

UWDA Uncontrolled Waste Disposal Area

LS Landfill Site

m3 Cubic Metre

m metre

1000 m2 stremma

m2 square metre

km kilometre

EWC European Waste Catalogue

OPESD Operational Programme "Environment and Sustainable Development"

NSRF National Strategic Reference Framework

STAKOD Statistical Classification of Economic Activities

VAT Value Added Tax

SPA Special Protection Areas (Special Protection Areas-SPA-as defined in Directive

79/409/EEC)

SCI Sites of Community Importance (Sites of Community Importance-SCI-as defined in

Directive 92/43/EEC)

from 63

1. GENERAL SECTION

1.1 Introduction

Directive 2004/35/EC establishes a common framework at EU level for the implementation of

environmental liability based on the "polluter pays" principle, aiming to prevent and remedy

environmental damage, caused directly or indirectly by activities involving:

protected species and natural habitats

water

soil, where contamination poses a serious risk to human health.

Environmental liability and its allocation to operators applies to environmental damage (or the

imminent threat thereof) caused by commercial activities as specified in Annex III to the Directive,

provided that there is a causal link between the activity and the damage. The framework set by the

Directive for the assumption of liability by business operators creates incentives for the prevention of

environmental damage and the adoption of preventive measures. If an imminent threat of

environmental damage is noted, and also when the damage is established, the competent authority,

as defined in the Directive, must, inter alia:

oblige the operator to take appropriate preventive or remedial measures, or

the authority shall itself take appropriate preventive or remedial measures and then recover

the cost of the measures from the operator.

Finally, cases which are exempt from environmental liability under Annex IV to the Directive (e.g.

cases of armed conflict, cases falling within the scope of international conventions such as the 1992

Convention on Civil Liability for Oil Pollution Damage, national defence, etc.) are expressly provided

for, along with the time limits for implementation (the Directive applies to damage caused by activities

that took place after 1 May, 2007).

rrrr

This report is submitted in accordance with Article 18 of the Directive whereby Member States are

required to report to the European Commission on the experience gained from the implementation of

environmental liability, for the first time in 2013. The reports include information and data specified in

Annex VI to the Directive.

The report has the following aims:

to present the steps taken by Greece to incorporate Directive 2004/35/EC since national

legislation was harmonised with it in 2009, the establishment of the competent authorities for

supervision and implementation, the provision of guidance from the monitoring authority for

effective functioning of the mechanisms, under the provisions of the Directive;

the application of Article 18 and Annex VI, namely the declaration of environmental liability

cases in Greece (with analysis / statistical processing of results and information, and

conclusions drawn) from the time the Directive came into force, detailing the following:

o Type of environmental damage, date of occurrence and/or discovery of the damage,

and date on which the environmental liability proceedings were initiated under P.D.

148/2009, as in force;

o Activity classification code of the liable individual or legal entity (STAKOD code for

from 63

activities for which this code can be provided)

o If there is a judicial appeal either by the liable parties or by official bodies (with details

on the type of claimants and the outcome of the proceedings);

o Result of the restoration process;

from 63

o Completion date of the process;

the highlighting of problems encountered during the implementation of the Directive (specific

provisions and/or in its entirety);

information on the next steps the central competent authority plans to take;

the presentation of specific issues arising during the implementation.

1.2 Transposition of Directive 2004/35/EC into the Greek Law

Directive 2004/35/EC was transposed into Greek law by Presidential Decree 148/2009

(Government Gazette, Series I, No 190/2009) “Environmental liability for the prevention and remedy

of environmental damage – Transposing Directive 2004/35/EC of the European Parliament and of the

Council, of 21 April 2004, on environmental damage, as currently in force”.

Presidential Decree1 148/2009 makes explicit reference to the correspondences between its articles

and the articles of Directive 2004/35/EC. The Annexes to the Directive were annexed to Article 21 of

the Decree.

P.D. 148/2009 was subsequently amended/supplemented with the following legislation:

• Joint Ministerial Decision (JMD) 39624/2209/E103/2009 (Government Gazette, Series II, No

2076/2009) which incorporated Directive 2006/21/EC on the management of waste extractive

industries and amending Directive 2004/35/EC, which refers to an addendum to Annex III of the

Presidential Decree;

• Law 4014/2011 (Government Gazette, Series I, No 209/2011) for the "Environmental

authorisation for works and activities... and other provisions " within the competence of the

Ministry of Environment. The amendments concerning P.D. 148/2009 are included in Article 22 of

the said Law and refer to issues concerning the administrative organisation and implementation of

financial guarantee;

1 Presidential Decree, hereinafter “P.D.”

from 63

• JMD IP 48416/2037/E.103/2011 (Government Gazette, Series II, No 2516/2011) on the

”geological storage of carbon dioxide - amending P.D. 148/2009”. The amendments pertaining to

P.D. 148/2009 are included in Article 31 of the said JMD which pertains to an addendum to Annex

III of the Presidential Decree.

1.3 The bodies responsible for the implementation of Directive 2004/35/EC in Greece

A. Central level

According to the provisions of Article 6 of P.D. 148/2009 (Article 11 of the Directive), the Ministry of

Environment, Energy, and Climate Change (former Ministry of Environment , Physical Planning and

Public Works), and in particular the Independent Coordination Office for the Implementation of

Environmental Liability (ICOIEL), supported by the Committee for the Implementation of

Environmental Liability (CIEL), was centrally appointed as the competent agency for the

implementation of environmental liability. The Independent Coordination Office for the Implementation

of Environmental Liability and the Committee for the Implementation of Environmental Liability are

based in Athens.

The Independent Coordination Office for the Implementation of Environmental Liability, according to

Article 6 of Law 3818/2010 (Government Gazette, Series I, 2010), reports to the Special Secretariat

for the Environment and Energy Inspectorate (SSEEI), which is a single administrative division of the

Ministry of Environment, Energy, and Climate Change, with key areas of responsibility the prevention

and remedy of environmental damage from pollution, the supervising and monitoring of the

implementation of the environmental, urban planning and energy law and policy of Greece, as well as

the compliance, at a central, regional and local government level, and the coordination of the actions

of the competent agencies.

Specifically, the following Agencies report to the Special Secretariat for the Environment and Energy

Inspectorate:

• Independent Coordination Office for the Implementation of Environmental Liability (ICOIEL),

which is supported by the Committee for the Implementation of Environmental Liability.

• Hellenic Environmental Inspectorate (HEI). The Hellenic Environmental Inspectorate was

established under Article 9 of Law 2947/2001 (Government Gazette, Series I, No 228/2001) and

P.D. 165/2003 (Government Gazette, Series I, No 137/2003) and provides substantial assistance

to the Independent Coordination Office for the Implementation of Environmental Liability (ICOIEL)

because of its auditing role concerning: (a) the examination and acceptance (or not) of requests

for action remedying environmental damage made by legal or natural persons; (b) the

identification of the responsible operators as provided for in Article 13 of P.D. 148/2009 (Articles

12 and 13 of the Directive); and (c) in cooperation with ICOIEL, the imposition of administrative

sanctions in cases where operators do not comply with the decisions taken to remedy damage

(P.D. 148/2009, Article 17).

from 63

The Office for the Inspection and Demolition of Illegal Constructions also reports to HEI.

• Hellenic Building and Energy Inspectorate (HBEI).

CHART 1: SSEEI ORGANISATION CHART

SSEEI

SPECIAL SECRETARIAT FOR THE ENVIRONMENT AND

ENERGY INSPECTORATE

HEI

HELLENIC ENVIRONMENTAL INSPECTORATE

ICOIEL

INDEPENDENT COORDINATING OFFICE

FOR THE IMPLEMENTATION OF ENVIRONMENTAL

LIABILITY

HEBI

HELLENIC ENERGY & BUILDING INSPECTORATE

OIDOC

OFFICE FOR THE INSPECTION & DEMOLITION OF ILLEGAL

CONSTRUCTIONS

HEI

HELLENIC ENERGY INSPECTORATE

HBEI

HELLENIC BUILDING INSPECTORATE

from 63

B. Regional level

At regional level, the competent authorities are the Decentralised Administrations (which were

established by Law 3852/2010, Government Gazette, Series I, No 87/2010), and in particular the

Regional Committees for the Implementation of Environmental Liability (RCIEL), which are

established in each region of the country, by decision of the Secretary-General of the Decentralised

Administration, with a scientific and advisory role in determining the remedial measures. Action is

decided on by the Secretaries-General of the Decentralised Administrations, after taking into account

the suggestions of RCIEL. A total of thirteen (13) RCIEL, which have been established and cover the

entire country are based at the respective headquarters of the Regions of Greece, with territorial

competence coinciding with the administrative boundaries of the respective Region, and in particular:

RCIEL of Attica based in Athens, reporting to the Secretary-General (SG) of the

Decentralised Administration of Attica (DAA).

RCIEL of Thessaly based in Larissa, and RCIEL of Central Greece based in Lamia, reporting

to the Secretary-General of the Decentralised Administration of Thessaly and Central Greece

(DATCG))

RCIEL of Eastern Macedonia and Thrace based in Komotini, and RCIEL of Central

Macedonia based in Thessaloniki, reporting to the Secretary-General of the Decentralised

Administration of Macedonia andThrace (DAMT).

RCIEL of Epirus based in Ioannina, and RCIEL of Western Macedonia based in Kozani,

reporting to the Secretary-General of the Decentralised Administration of Epirus and Western

Macedonia (DAEWM)

RCIEL of Peloponnese based in Tripoli, RCIEL of Western Greece based in Patras, and

RCIEL of the Ionian Islands based in Corfu, reporting to the Secretary-General of the

Decentralised Administration of Peloponnese, Western Greece and the Ionian (DAPWGI)

RCIEL of the North Aegean based in Mytilini, and RCIEL of the South Aegean based in

Ermoupoli, reporting to the Secretary-General of the Decentralised Administration of the

Aegean (DAAE).

from 63

RCIEL of Crete based in Heraklion, reporting to the Secretary-General of the Decentralised

Administration of Crete (DAC).

1.4 Measures taken by the central competent authority (ICOIEL) to implement Directive

2004/35/EC in Greece

ICOIEL as a central institution reporting to SSEEI, has the following responsibilities (Article 6 of P.D.

148/2009):

It supervises and monitors the implementation of the provisions of P.D. 148/2009,

coordinating the actions of the competent authorities at regional level, and the jointly

competent agencies which are involved in matters related to the application of environmental

liability.

As the competent authority, it advises the Minister for the Environment, Energy and Climate

Change on steps to be taken and measures for prevention and/or remedy, in cases where the

damage or imminent threat of damage affects natural resources or services of national

importance, the protection and/or management of which lies within the responsibility of a

public authority, or when it affects natural recipients or services that extend over the

administrative boundaries of more than one Region, or the territory of other neighbouring

Member States. For damage or imminent threat of damage that affects natural resources or

services which do not fall within the above cases, the role of the competent authority is

assumed by the respective Decentralised Administration through the RCIEL.

It cooperates with the competent authorities of other Member States and the European

Commission for the implementation of environmental liability across borders.

It cooperates with scientific institutions nationally and abroad to collect scientific or other

information on issues of prevention and remedy of environmental damage.

It offers its opinion to the Minister for the Environment, Energy and Climate Change on issues

concerning the implementation of financial guarantee (Article 14 of P.D. 148/2009).

It monitors the progress of the implementation of preventive and remedial measures.

from 63

It ensures the preparation of the reports which are required by Article 20 of P.D. 148/2009

(Article 18 of the Directive).

In the context of its responsibilities, ICOIEL has to date taken the following action and measures:

1.4.1 Cooperation and coordination of the competent authorities at central and regional level

The ICOIEL issued Circular 65/2011 (Internet Posting Number: 45700 - ΔΡ62), “. for the cooperation

and coordination of the competent authorities on matters concerning the implementation of P.D.

148/2009 on environmental liability for the prevention and remedy of environmental damage”. That

Circular clearly describes the responsibilities of the ICOIEL and RCIEL, and defines the framework for

the cooperation of those agencies with the HEI. The clarifications provided in the Circular include the

following:

Where the Hellenic Environmental Inspectorate accepts a request for action (by natural or

legal persons), the request should be accompanied by the information needed to locate and

identify the operator causing the environmental damage (through inspection and on-the-spot

check), and all relevant data should be duly communicated to the ICOIEL or the relevant

RCIEL, in order to proceed with the allocation of environmental liability.

In cases of complaints, after the examination of which it has been ascertained that there is

environmental damage but the responsible operator has not been identified, the decision of

the General Inspector is forwarded to the corresponding competent authority in order for it to

take action.

2 http://static.diavgeia.gov.gr/doc/45700-%CE%94%CE%A16

http://static.diavgeia.gov.gr/doc/45700-%CE%94%CE%A16

from 63

In cases where it is established during environmental inspection that there is a threat of

environmental damage or imminent environmental damage, both the HEI and the competent

audit authorities should specifically ask the operator not only to bring his activities in line

approved environmental condition, but also to take any additional measures for prevention

and remedy of environmental damage, according to P.D. 148/2009, under the supervision of

the competent authority, where appropriate.

Whenever an inspection by the competent agencies determines that an activity causes

environmental damage or may cause (threat of) environmental damage, and if for that

particular activity there is an ongoing environmental licensing procedure (renewal or

modification of environmental conditions), the relevant competent authority in each case shall

immediately inform the licensing authority, in order to address the issue through the Decisions

on the Approval of Environmental Conditions (DAEC), specifying both the obligation to take

preventive and remedial measures within a specified and reasonable time-frame and the

appropriate measures.

At the central level, the ICOIEL issued a decision establishing the Committee for the Implementation

of Environmental Liability (CIEL), which was established by Decision No 73/2012 of the Minister for

the Environment, Energy and Climate Change (Internet Posting Number: B44Y0- 8Θ03), according to

the provisions of Article 6(5) of P.D. 148/2009. The CIEL supports the work of the ICOIEL, offers

suggestions and provides directions on issues relating to:

how to address environmental damage (or potential threat of environmental damage) in soil,

water and protected species / natural habitats, in order for the ICOIEL to propose appropriate

preventive and remedial measures to the Minister for the Environment, Energy and Climate

Change;

3 http://static.diavgeia.gov.gr/doc/%CE%9244%CE%A50-8%CE%980

http://static.diavgeia.gov.gr/doc/%CE%9244%CE%A50-8%CE%980

from 63

the financial evaluation of environmental damage;

the allocation of the costs of prevention and remedy in case of more than one responsible

operators;

the implementation of the financial guarantee system;

the addressing of implementation issues of environmental liability in areas of high

environmental risk (see Section 3.2 Targets and subsequent actions of this report, page 46).

The CIEL is convened by its Chairman, following a recommendation by the ICOIEL. As members of

CIEL they have been appointed representatives of the competent Environmental Agencies of the

Ministry of Environment, Energy, and Climate Change relevant in each case, and the Ministries of

Finance, Rural Development & Food, Infrastructure - Transport and Networks, Health, Culture &

Sports, Marine & the Aegean, if, in a particular case, they are involved in matters related to the

application of P.D. 148/2009. Additionally, the CIEL also includes representatives of other relevant

bodies from the public sector, scientific bodies, institutions or organisations, such as the Technical

Chamber of Greece (TCG), the Hellenic Federation of Enterprises (HFE), the Greek Mining

Enterprises Association (GMEA), the Greek Biotope/Wetland Centre (GVWC), the Hellenic

Association of Insurance Companies, and representatives of Environmental Organisations, as

appropriate in each case, since it was considered that “enlargement of the composition of CIEL with

other members, including the aforementioned groups, will offer substantial aid in its work” (Article

6(5)e of P.D. 148/2009).

Moreover, the ICOIEL supervises and assists the work of the Regional Committees for the

Implementation of Environmental Liability (RCIEL), monitors the work of the RCIEL and directs their

actions if it deems that this is appropriate and/or upon request, based on compliance with the

provisions of P.D. 148/2009, and also based on the faster execution of procedures, especially in

cases involving serious environmental risks and where the immediate response of all competent

agencies becomes imperative. The supportive function of the ICOIEL so far involves the provision of

written explanations and recommendations (a) of a general nature and (b) specific to each case

separately, as these cases are presented in Appendix I of this report.

from 63

The RCIEL, as mentioned above, are established by decision of the relevant Secretary General, and

their appointed members are representatives of the Directorates of Environment and Spatial Planning

(DESP) and Water Directorates and of any other relevant in regional agencies if such agencies are

involved in matters concerning the application of P.D. 148/2009 due to their jurisdiction. The same

decision determines the manner and procedure of making decisions, the operation of the RCIEL and

all necessary details for the completion of their work. In this regard and for the concerted operation of

the RCIEL, in order to support the proper implementation of P.D. 148/2009 and also in order to

achieve the necessary coordination with the Central Agency (ICOIEL), the SSEEI determined, with

document ref. 1724/2010, on "Operating Rules of the Regional Committees for the Implementation of

Environmental Liability (RCIEL) and other issues," the general operating framework which has been

adopted and which facilitates the operation of the RCIEL. Moreover, the competent regional

authorities were asked to ensure that:

a special code is entered in their annual budget, for any cases of restoration of environmental

damage which arise and which fall within the scope of the application of P.D. 148/2009;

they gather data demonstrating the situation of the environment at regional level;

they identify the need for studies and recommend the necessary financing through the

Regional Operational Programmes under the NSRF;

they inform the ICOIEL at regular intervals, not less than six (6) months, on cases for which

they have begun procedures according to P.D. 148/2009 and the state of implementation of

preventive and remedial measures.

from 63

The RCIEL inform the ICOIEL about all their activities regarding cases of environmental liability within

their geographical and administrative competence (such as minutes of meetings, advice to the

corresponding Secretaries General concerning measures for the prevention and remedy of

environmental damage, and the corresponding Decisions of the Secretaries General, in situ reports,

and findings from compliance checks carried out on the activities of operators under this obligation,

expenditure approvals for action, partnerships with other competent local agencies and bodies, etc.).

These data are collected in the relevant register which is maintained by the ICOIEL.

1-4.2 Cooperation with the competent authorities, the European Commission and other

Member States, and with other bodies involved

The ICOIEL organised and / or participated in the following events organised in Brussels and Athens,

for maximum penetration of the implementation of Directive 2004/35/EC:

Participation in the biannual meetings of national experts from Member States organised

by the European Commission;

Bilateral cooperation in Brussels (November 2011) with representatives of the European

Commission;

Bilateral cooperation in Athens (December 2011) with representatives of the European

Commission, officials and representatives from the insurance and banking sector;

A two-day workshop in Athens (January 2012), on the implementation of the Directive on

environmental liability, with the distribution of information material and the participation of

representatives from the European Commission and EU Member States, competent

Agencies and stakeholders: representatives of the Hellenic Federation of Enterprises,

insurance companies, experts, non-governmental organisations (NGOs), etc.;

from 63

Workshop & Open Consultation in Athens (February 2012), on the progress of the

“Program of Integrated Management of the Environmental Crisis in the Asopos River" (See

Section 2.3 Special Cases - Asopos of this report, page 40), with the participation of

representatives from the ministries, the local Decentralised Administration of Thessaly &

Central Greece and the Region of Central Greece, municipalities and businesses in the

region, universities and NGOs which are active in the region.

1.4.3 Implementation of the financial guarantee

Financial security (Article 14 of P.D. 148/2009) is mandatory for the operators of Annex III of P.D.

148/2009. Article 22(7) of Law 4014/2011 (Government Gazette, Series I, No 209/2011), which

partially amends Article 14 of P.D. 148/2009 (see also Section 1.2. Transposition of Directive

2004/35/EC into the Greek legislation of this report, p. 6) provides for the issuance of a Joint

Ministerial Decision by the Minister for the Environment, Energy & Climate Change and the Minister

for Finance and Development - Competitiveness, which will determine the type and amount of the

financial guarantee for the activities of Annex III of P.D. 148/2009, taking into account the type of

activity, the severity of any possible contamination and the environmental impact of this on the soil,

water and protected species / natural habitats, the degree of the risk of occurrence of environmental

damage and every other detail.

A working group for the issuance of this Joint Ministerial Decision was established at the Ministry of

Environment, Energy, and Climate Change, with the participation of all stakeholders (Hellenic Bank

Association, Hellenic Association of Insurance Companies, Hellenic Federation of Enterprises).

The main points of the draft Joint Ministerial Decision include:

The operator of the professional activities in Annex III of P.D. 148/2009, as the party bearing

the main financial responsibility for taking preventive and/or remedial measures for the

environmental damage and to cover their liability, shall make use of financial instruments

(private insurance and/or other forms of financial guarantees) through appropriate economic

and financial organisations.

The operator shall ensure that the financial guarantee, or a combination of different types of

financial securities that they select, achieves the fullest possible coverage for the remedy of

potential environmental damage.

The risks covered by the financial guarantee shall include at least the restoration costs for

environmental damage to soil and water.

The activities listed in Annex III of P.D. 148/2009 shall be covered by a compulsory insurance

scheme and, in order to determine the amount of insurance coverage, three main categories

of risk are established, in proportion to the classification of activities of Law 4014/2011 on

environmental licensing. For classification in the three main categories of environmental

damage (high risk, medium risk and low risk), and the identification of the appropriate amount

of insurance, the following criteria are taken into account:

o characterisation as to the location of the activity such as: land uses - protection zones,

from 63

distance from the body of water, type and volume of waste, methods of waste

treatment, waste monitoring indicators, impact on public health, risk of expansion -

diffusion and dispersion of pollutants;

o characterisation as to the operating risks of the activity such as: compliance with DAEC

terms, implementing a prevention policy, existence of a contingency plan, quality

management/environmental protection system, history of infringements, damage

causing factors, possible types of damage, likely extent and intensity of damage, cost

of remedial measures for the optimal remedial method.

The Draft Joint Ministerial Decision will be made available for consultation on the opengov website.

from 63

In addition, according to Article 14(3) of P.D. 148/2009, for those activities that are listed in Annex III

for which a system of compulsory financial guarantee was already established before the enactment

of the Presidential Decree (in the form of private insurance and other forms of financial guarantees)

for their legitimate exercise, such as for example waste management operations, these activities

remain under the said financial guarantee scheme after the entry into force of the Decree.

1.4.4 Issues concerning the staffing - organisation - funding of the central competent

authority

The ICOIEL is staffed by officials of the Ministry of Environment, Energy, and Climate Change or

officials seconded to it from other Agencies of the Ministry or other ministries and public sector bodies.

At the current stage, the ICOIEL occupies 6 staff of which:

Two (2) are specialists in the Environment;

Two (2) are specialist geotechnical engineers;

One (1) is a specialist in administration-economics; and

One (1) provides secretarial support to the Agency.

Moreover, for the proper functioning and support of the work of the Agency, funding (start-up) from the

Operational Programme "Environment and Sustainable Development" (OPESD - Priority 10), which

forms part of the National Strategic Reference Framework (NSRF 2007-2013) has been approved.

The approved activities include conducting in situ inspections to determine an imminent threat or the

causing of environmental damage, organising seminars/one-day seminars to raise the awareness of

target groups and the public, training staff, financing studies for environmental risk assessments,

performing environmental sample analyses, meeting operational needs, and developing methods to

improve administrative procedures concerning the implementation of environmental liability.

from 63

The studies prepared by the ICOIEL, aim to create the appropriate tools for environmental damage

assessment and the selection of the appropriate remedial measures, and in particular:

1. Study on the "Development and determination of the methodology and the minimum standards for

the content of studies determining the measures to prevent the expansion of environmental

damage and remedial studies of environmental damage caused by activities listed in Annex III of

P.D. 148/2009 for Environmental Liability"

2. Study for the determination of the "initial state" of soil, water and protected species / natural

habitats for:

(a) the determination of the initial state parameters ;

(b) the development-interface with IT platform-Database

3. Study on the application of environmental liability with regard to the determination of

(a) preventive measures;

(b) remedial measures (primary, supplementary, replacement);

(c) compliance and administrative sanctions - fines;

(d) the development of an IT application for decision making.

from 63

2. SPECIAL SECTION

2.1 Methodology used for the collection of material - information for the preparation of this

report

The information recorded in this report was collected from two main sources:

1) The ICOIEL archives, to which requests for action as part of the environmental liability

scheme are submitted and from which they are announced;

2) The data collected from the Decentralised Administrations, following a written request4 by

the ICOIEL. The document was accompanied by the electronic delivery of a standard

form (in Excel), for recording the information:

(a) as provided for in Annex VI of Article 21 of P.D. 148/2009;

(b) as proposed in the supplementary instructions issued by the European Commission

in July 2012 (02.07.2012) on the structure and content of the report.

All the Decentralised Administrations responded through their competent agencies (Directorates for

the Environment & Spatial Planning and RCIEL), and returned the completed Excel files to the ICOIEL

in electronic form, with updated information on cases of environmental liability which they had handled

due to their geographical jurisdiction.

The evaluation, final configuration and statistical processing of the data was completed by the

ICOIEL.

Below is a summary of the cases, and the analysis and interpretation of the results. More details

about the cases are listed in Tables 1 & 2, in Annex II of this report.

4 Document Ref. 12/11.01.2013 on the ”Collection of data for the preparation of a report to the

European Commission concerning the implementation of P.D. 148/2009 in Greece, according to Article 20 thereof”

from 63

2.2 Summary presentation, analysis and interpretation of results

In Greece, 52 cases which were handled according to P.D. 148/2009 on environmental liability

and according to the requirements of Directive 2004/35/EC, have been submitted and recorded so far,

and these are divided into (Chart 2):

closed (17%)

partially open - Ongoing implementation of remedial measures (21%)

open (60%)

under investigation -check for inclusion or not under the Directive (2%).

CLOSED

OPEN (PENDING RECOMMENDATION OF MEASURES/COMPLIANCE WITH MEASURES/NOTIFICATION FOR THE IMPLEMENTATION PHASE OF MEASURES)

PARTIALLY OPEN (REMEDIAL - IMPLEMENTATION OF MEASURES IN PROGRESS)

UNDER INVESTIGATION (FOR INCLUSION UNDER

THE DIRECTIVE)

CHART 2: "CLOSED" AND "OPEN" CASES

from 63

Geographically, the cases ("closed" and "open") are distributed among the regions of Greece as

follows:

REGISTER OF ENVIRONMENTAL LIABILITY CASES IN GREECE -

BREAKDOWN BY REGION

REGION TOTAL

CASES “CLOSED” “OPEN”

Attica 4 1 3

Central Greece 25 5 20

Thessaly 1 0 1

Central Macedonia 3 0 3

Eastern Macedonia -

Thrace 2 2 0

Epirus 1 1 0

Western Greece 3 0 3

Peloponnese 5 0 5

Ionian 1 0 1

Northern Aegean 2 0 2

Southern Aegean 2 0 2

Crete 3 0 3

TOTAL 52 9 43

It is noteworthy that twenty five (25) cases, which account for 48% of all cases, concern activities

which are located in the Central Greece Region, one of the major industrial areas of Greece (Chart 3).

from 63

A. Closed Cases

There are nine (9)“closed” cases, for which preventive/remedial measures have been completed, they

account for 17% of all cases and are presented in detail in Table 1 of Annex II.

The main information on “closed cases” is summarised in the box below:

“OPEN” CASES

“CLOSED” CASES

Attica Central Greece

Thessaly

Central Macedonia

Eastern Macedonia - Thrace

Epirus

Western Greece

Peloponnese

Ionian Northern Aegean

Southern Aegean

Crete

CHART 3: GEOGRAPHICAL DISTRIBUTION OF CASES

from 63

Ref. “CLOSED” CASES OF ENVIRONMENTAL LIABILITY - SUMMARY

1. AT/1 On 06.10.2010, leakage into the soil from 25 tonnes of stored chemical waste was

found on the grounds of an abandoned plant in Athens, which had manufactured

sealing and insulating materials. The operator had gone bankrupt. The SSEEI

ordered the site to be secured and sealed and at the same time it informed the

official receiver. The Secretary General of the Decentralised Administration issued

decisions for the implementation of remedial measures (collection and removal of

materials and any contaminated soil by a duly licensed operator, at the expense of

the Municipality of Athens). The remedial measures were completed. Information

about cost recovery is anticipated.

2. ΣΤ/5 On 10.11.2010, soil contaminated with mineral oils from a storage tank was found, at

a power plant, in Evia. The Secretary General of the Decentralised Administration

issued a decision for the implementation of remedial - restoration measures

(bioremedial with in situ application). The remedial measures were completed.

3. ΣΤ/3 On 15.06.2010, an IMMINENT THREAT of soil damage was found, as a result of the

disposal of treated liquid waste into septic tanks, at a galvanising & metallic

structures plant, in Viotia. The subsurface disposal of waste was stopped. The

Secretary General of the Decentralised Administration issued a decision for the

implementation of preventive and remedial measures (opening of septic tanks and

removal of any water and sludge from their bottom, management of their waste by a

licensed operator, sealing of the exits of the piping leading to the septic tanks with

concrete, filling up of the septic tanks with appropriate material and resealing). The

remedial measures were completed.

4. ΣΤ/7 On 17.12.2010, soil polluted with mineral oils was found at a construction equipment

warehouse in Viotia. The Secretary General of the Decentralised Administration

issued a decision for the implementation of preventive measures (removal of the

surface layer and submission of a potential pollution assessment study). The

Decision decreed, as a precautionary measure, the periodic sampling and analysis of

borehole water. The remedial measures were completed.

5. ΣΤ/8 On 20.12.2010, soil polluted with mineral oils was found at a shipyard, in Evia. The


implementation of remedial - restoration measures (removal of contaminated soil and

restoration/filling up of the site). The remedial measures were completed.

from 63


6. ΣΤ/10 On 20.01.2011, an IMMINENT THREAT of soil damage was found, due to the

disposal of hazardous waste in septic tanks at a metal working plant, in Viotia. The


implementation of preventive and remedial measures (modification of the method of

waste management, sealing of septic tanks after the removal of sludge and any

water, and filling-up of the septic tanks with inert material). The remedial measures

were completed.

7. ΘΡ/1 On 22.06.2010, an IMMINENT THREAT of soil and water damage was identified due

to emissions following a fire at an outdoor used car tires storage site, in the Region

of Drama. The following direct and urgent measures were imposed: a ban on free

grazing and the consumption of raw milk and meat, the compulsory stabling of the

animals in the surveillance zone, the covering-up (backfills) of combustion residues

with the laying of concrete and earth materials (soil), in two phases. The costs were

partially covered by the State (putting out the fire). The backfill was completed and a

written assessment report of the pollution was prepared. No pollutants were detected

in the soil or in the water. The possibility of retesting with new samplings, as well as

the continuous monitoring over time of the groundwater status are under

examination. The remedial measures were completed.

8. ΘΡ/2 On 26.07.2011, an IMMINENT THREAT of soil and water damage was found, due to

emissions after a fire at a compound & flexible packaging materials printing factory,

in the Industrial Area (IA) of Komotini. In a letter, the relevant Directorate for the

Environment and Area Planning of the Decentralised Administration of Macedonia &

Thrace, requested the construction of a trench for the collection of water for fire-

fighting purposes, the collection-compacting of scrap and the removal of combustion

residues by licensed operators. A remedial study was prepared. No pollutants were

detected in the soil or in the water. The remedial measures were completed.

from 63


9. ΗΠ/1 On 17.06.2010, pollution of slopes, soil and water was found, due to the leakage of

fuel oil into the river Arachthos in Arta, from a fuel storage tank at an abandoned

juice plant. Given the urgent nature of the incident, and at the suggestion of

Secretary General of the Region, the Deputy Minister for Finance issued a Decision

for the approval of funding from the Public Investments Programme (PIP), for: the

cleaning of the river, slopes and soil, the interruption of the flow of the river at the

POURNARI II dam, the dismantling and sealing of pipelines and canals, temporary

overlays in the riverbed with greenhouse nylon and quarry sand, the removal of

contaminated materials by a licensed operator, as well as the monitoring of water,

soil, organisms and agricultural products, and, finally, the noting of any plants near

the aquatic ecosystems of the region. The remedial measures were successfully

completed. The competent RCIEL is in the process of recovering the costs.

B. Cases which are Partially Open - Open - Under Investigation For Inclusion

There are forty three (43) ‘open cases’, which are listed in Table 2 of Annex II, and consist of:

Partially open cases, eleven (11) in total, account for 21% of all cases, for which the

preventive/remedial measures are already implemented and are in the process of completion.

Open Cases, thirty-one (31) in total, account for 60% of all cases, with the following

procedures pending, depending on each case: (a) the submission of data (studies,

documents, etc.) to the competent authorities by the operators ; or (b) the evaluation of the

submitted data for the issue of final recommendations/Decisions; or (c) the communication of

information to the central competent authority concerning the progress of implementation of

the measures, and/or concerning the compliance of the operators (e.g., if remedy is in

progress, or if the time tables set out in the Decisions are observed, any problems

encountered, etc.).

Finally, one case (accounting for 2%, Ref. Ν.ΑΙΓ./2) is under consideration for inclusion (or

not) under P.D. 148 /2009, where the causing of environmental damage has not been

established due to lack of evidence. However, in this case too, the local authorities have

already have taken the necessary preventive measures to reduce pollution and safeguard

public health.

Specifically:

Ref. “OPEN” CASES OF ENVIRONMENTAL LIABILITY - SUMMARY

from 63

1. AT/2 On 07.10.2010, soil contamination and an IMMINENT THREAT of water

damage (risk of pollution caused by nitrates in groundwater and surface

water) were found, due to the uncontrolled dumping of liquid manure from a

poultry farm in western Attica. A study of possible remedial measures was

requested and this information is still pending.

2. AT/3 On 22.06.2011, a leakage of tarry material in the soil from plastic/metal

drums/containers and IBC tanks with chemical residues (mineral oils, oily

liquids, concentrated acids, acidic solutions, aggregates) was found, at an

illegal junkyard in western Attica. It was requested from HEI to immediately

seal the facility, to remove the materials and to submit a decontamination-

remedial plan for the site. The facility was sealed, and there was partial

removal of hazardous materials. Information on the removal of the remaining

material of unknown chemical composition is pending.

3. AT/4 On 04.10.2011, soil contamination and an IMMINENT THREAT of damage to

the underground aquifer were found, due to the uncontrolled dumping of non-

hazardous and potentially hazardous waste in a former uncontrolled waste

disposal area in eastern Attica. The SSEEI ordered the prevention of

unauthorised access, the securing of the site and appropriate arrangements

for the rainwater. The RCIEL of Attica has yet to issue its decision on the

remedial measures to be taken.

4. ΣΤ/1 On 21.10.2009, uncontrolled hazardous solid waste management and soil

pollution due to shoddy outdoor storage were found, at an aluminum foundry,

in Evia. The business was temporarily shut down. The submission of a

remedial study was required, with no response from the operator. A new in

situ inspection and the referral of the case to the RCIEL of Central Greece are

pending.

5. ΣΤ/2 On 06.05.2010, soil pollution by mineral oils was found during the

construction of a building, in Evia. An update is anticipated on the steps taken

by the Directorate of Environment and Spatial Planning (DESP) of Central

Greece and the Region of Evia.

from 63


6. ΣΤ/6 On 04.12.2010, soil pollution and an IMMINENT THREAT of damage to

water were found, due to the uncontrolled dumping of hazardous waste at an

outdoor site without a rainwater collection network, with the waste flowing

uncontrollably into the soil, at a batteries and cathodic protection anodes

manufacturing and recycling plant, in Viotia. A Decision was issued by the

S.G. for the implementation of preventive measures and the preparation of a

remedial study. Some of the waste (lead slag) has been moved inside the

industrial building. The operator is expected to take action, following

recommendations from the DESP of Central Greece.

7. ΣΤ/9 On 14.01.2011, soil and water damage was found, due to the presence of

solid and liquid waste in the soil and within the lake Yliki exclusion zone, at a

plant packaging carrots and onions, in Viotia. The operation was shutdown.

The Secretary General of the Devolved Administration issued two decisions

for the implementation of preventive and remedial measures and for

additional remedial measures. An update is anticipated on the progress of the

implementation of the measures in the second decision.

8.ΣΤ/11 On 23.03.2011, an IMMINENT THREAT of soil and water damage was found

due to the dumping of solid and liquid waste into the soil at a paper mill, in

Fthiotida. The Secretary General of the Decentralised Administration issued a

decision for the implementation of preventive and remedial measures. There

was no response from the operator. The file has been sent to HEI for the

imposition of sanctions.

9. ΣΤ/12 On 26.04.2011, soil damage was found, caused by two aggregate quarries,

in Fthiotida. The Secretary General of the Decentralised Administration

issued a decision for the implementation of remedial measures. Remedial

work has already started and information concerning the progress of the

implementation of pending measures is anticipated.

10. ΣΤ/14 On 10.05.2011, soil pollution from mineral oils (waste lubricating oils - WLO)

was found at a mineral oil regeneration, grease production, and slops

processing plant, in Viotia. The Secretary General of the Decentralised

Administration issued a decision for the implementation of remedial-

restorative measures. An update on the progress of the implementation of the

measures is anticipated.

from 63


11. ΣΤ/15 On 27.05.2011, soil damage and an IMMINENT THREAT of groundwater

damage were found, as a result of historical dumping of powders at three (3)

uncontrolled waste disposal areas around the grounds of a metalworking

complex, in Fthiotida. The Secretary General of the Decentralised

Administration issued a Decision for the implementation of remedial-

restorative measures. Remedial work has already begun and an updated

time table of the implementation of pending measures is anticipated.

12. ΣΤ/16 On 13.06.2011, soil and water damage (diversion of a stream bed) was

found, due to uncontrolled dumping from the operation of a borrow pit for

highway projects, in Fthiotida. The Secretary General of the Decentralised

Administration issued a decision for the implementation of preventive and

remedial measures. Remedial work has already started and information

concerning the progress of the implementation of pending measures is

anticipated.

13. ΣΤ/17 On 22.08.2011, an IMMINENT THREAT of soil damage (risk of leakage) was

found, due to the storage of 32,000 litres of hazardous substances

(fertilizers, etc.), inside an agricultural supplies warehouse (pesticides-

biocides-fertilizers), in Viotia. The Secretary General issued decisions for the

approval of remedial-restorative work. Funds were committed for an

invitation to tender (at the expense of the competent authority and followed

by cost recovery).

14. ΣΤ/18 On 31.10.2011, soil damage and an IMMEDITAE THREAT of water damage

were found, due to uncontrolled dumping of hazardous - ecotoxic liquid

waste in a pit in the ground, in Viotia, by a seed oil operation. A check was

performed by the HEI and the results are anticipated.

15. ΣΤ/21 On 28.11.2011, groundwater pollution (borehole) by hexavalent chromium,

and an IMMINENT THREAT of soil damage (concentrations of heavy

metals) were found, due to the dumping of treated hazardous waste in septic

tanks, at an aluminum products plant, in Viotia. The Secretary General of the

Decentralised Administration issued a decision for the implementation of

remedial-restorative measures. An update on the progress of the

implementation of the measures is anticipated. The ICOIEL is cooperating

with the relevant agencies and scientific bodies in order to provide guidance

in dealing with pollution of the groundwater in the area.

from 63


16. ΣΤ/23 On 07.12.2011, soil damage was found, due to deposit residues in old mining

sites, in Mantoudi, Evia. The Directorate of Environment and Spatial Planning

(DESP) of Central Greece has requested a remedial Technical Report from

the operators who are expected to take action.

17. ΣΤ/24 07.12.2011, soil pollution and an IMMINENT THREAT of water damage were

found, due to the dumping of various hazardous and non-hazardous wastes

(lubricating oils, ELV, used tires, WEEE, scrap, gangue) from iron-nickel ore

enrichment and processing facilities, in Evia. The Secretary General of the

Decentralised Administration issued a decision for the implementation of

remedial-restorative measures. Information on the progress of the

implementation of the measures is anticipated.

18. ΣΤ/25 On 14.12.2011, an IMMINENT THREAT of soil and water damage was found,

due to the dumping of treated hazardous waste in septic tanks (heavy metal

concentrations), at a screw and binder manufacturing plant, in Evia. A

pollution assessment study was submitted, along with additional information,

by the operator. Completion of the review of the additional information

submitted is pending.

19. ΣΤ/27 On 31.01.2012, soil pollution was found, due to the disposal of hazardous and

non-hazardous solid and liquid waste and hazardous gases, at a former

secondary fusion aluminum production plant, in Fokida. The Secretary

General of the Decentralised Administration issued a decision for the

implementation of preventive and remedial measures. An update on the

progress of the implementation of the measures is anticipated.

20. ΣΤ/28 On 08.03.2012 and 15.03.2012, soil and water damage was found, due to the

illegal dumping of treated industrial wastewater, at a brass products

manufacture and plating plant in Viotia. The Secretary General of the

Decentralised Administration issued a Decision for the implementation of

remedial-restorative measures. An update on the progress of the


from 63


21. ΣΤ/29 On 22.03.2012, soil damage and an IMMINENT THREAT of water damage

were found, due to the uncontrolled disposal of hazardous and non hazardous

solid and liquid waste, at a metal and non-metal waste recycling and vehicle

dismantling and recycling (ELVs) plant, in Evia. By decision of the Deputy

Head of the Region, the plant was ordered to close temporarily until the

restoration of the site is complete. A remedial study has been submitted by

the operator. There is communication with the operator for the completion of

the submitted remedial study, following relevant instructions from ICOIEL and

DESP of Central Greece.

22. ΣΤ/31 On 21.05.2012, soil pollution was found, due to hazardous solid waste, at a

former secondary fusion aluminum - and possibly lead - production plant, in

Evia. The Secretary General of the Decentralised Administration issued a

Decision for the implementation of remedial measures. So far, the waste has

been transported indoors and waste characterisation and removal to a

licensed site are pending.

23. ΣΤ/33 On 26.06.2012, soil pollution was found, due to wastewater disposal from a

car wash - lubrication operation in an open, earth reservoir, in Evia. An update

is anticipated, following the activities of the DESP of Central Greece and the

Region of Evia, to take all the prescribed measures for the remedy-restoration

of the reservoir.

24. ΘΕ/1 On 02.03.2010 and 04.03.2010, an IMMINENT THREAT of soil and water

damage was found, due to uncontrolled outdoor dumping amounting to

approximately10,000 tonnes, at a plant producing ceramic products, in the

Region of Larissa. By Decision of the Prefect, the plant was shutdown and the

facilities were sealed. A Decision on the Approval of Environmental

Conditions (DAEC), which includes compliance-remedial measures

recommended by the SSEEI Special Secretary, was issued by the Directorate

for the Control of Air Pollution and Noise (EARTH)/Ministry of Environment,

Energy and Climate Change. Update on the progress of the case is pending.

25. ΜΑΚ/1 On 23.02.2009, an IMMINENT THREAT of soil and water damage was found,

due to the dumping of waste asbestos (asbestos pipes) in the Suburban

Forest of “Sheikh Sou”, Thessaloniki. The Directorate for Forests of the

Thessaloniki Prefecture issued a decision for the approval of a remedial

study. An update on the approval of funding for the remedial cost is

anticipated.

from 63


26. ΜΑΚ/2 On 19.10.2011 and 20.10.2011, an IMMINENT THREAT of soil and water

damage was found, due to the dumping of aggregates, solid industrial waste

and phosphogypsum, in Pieria. The charging of the owner of the waste with

the cost of remedy is pending, following the prosecutor’s inquiry requested by

the DESP of Central Macedonia (Decision of the Secretary General of the

Decentralised Administration).

27. ΜΑΚ/3 On 29.05.2012, soil pollution was found, due to the uncontrolled disposal of

industrial waste, from a spelter craft operation, in Thessaloniki. The Secretary

General of the Decentralised Administration issued a decision approving a

remedial study. The remedy is underway and an update on the progress of its

implementation is expected.

28. ΔΥΤ/1 On 11.03.2011, soil pollution and an IMMINENT THREAT of surface water

and groundwater damage were found, due to the dumping of 80,000 m3 of

hazardous waste (materials containing asbestos and mineral oil residues), at

a former asbestos production plant, in Achaia. The Secretary General of the

Decentralised Administration issued a Decision approving collection, removal

(cross-border transportation) and remedial-restoration works at the property.

An appeal for annulment by the operator against the decision to the Council of

State is pending.

29. ΔΥΤ/3 On 03.10.2012, the competent Operator submitted a request for the

restoration of the linear island between the wetland biotope and the sea, at

the Kotychi lagoon, in Ilia (habitat NATURA 2000, codes Nos

GR2330009/SPA and GR2330006/SCI). Following the proposals made by

HEI, the local agencies of the Regional Unit performed an in situ inspection

on 11.10.2012. As a result of the inspection, uncontrolled earthworks

(removal and deposition of sediments), uncontrolled diversions of freshwater

to the sea and interventions up to the depth of the aquifer were identified. A

recommendation for the undertaking of a remedial study has been submitted

to the competent Regional Council. The selection of a contractor for the

preparation of the study is pending.

from 63


30. ΔΥΤ/4 On 26.10.2012, an IMMINENT THREAT of soil and water damage (risk of

leakage) was found, due to the storage of 23,300 litres of expired pesticide-

plant protection products against the olive fruit fly, weighing approximately 29

tonnes, inside and outside a warehouse of the Directorate for Rural Economy

& Veterinary Medicine of the Regional of Ilia, at Epitalio airport. The Region of

Ilia issued an open invitation to tender for the removal and destruction of the

pesticides and the cleaning of the warehouse by a licensed operator, and a

contractor was selected. An update on the progress of the award procedures

is anticipated.

31.ΠΕ/1 On 16.07.2010, soil pollution and an IMMINENT THREAT of water damage

were found, due to the disposal of untreated wastewater into the area

surrounding a dairy - cheese operation, in Arcadia. Update on the progress of

the case is pending.

32. ΠΕ/2 On 11.07.2011, ecosystem alteration and destruction of vegetation and

avifauna habitat by a natural person were found, due to the uncontrolled

disposal of demolition and excavation materials within an officially established

wetland (Mount Parnonas - Moustos Wetland, Arcadia). The immediate

removal of rubble and refuse was recommended, as well as the reaching of

an understanding with the Mount Parnonas - Moustos Wetland Ecological

Park concerning all possible prevention-remedial actions. Update on the

progress of the case is pending.

33. ΠΕ/4 On 15.12.2011, the degradation of a coastal ecosystem, the destruction of

dunes and natural vegetation and alterations of a sea turtle breeding habitat

were found, in Messinia (habitat IMATURA 2000, code No GR2550005/SCI).

The Secretary General of the Decentralised Administration issued a decision

to block access by wheeled vehicles and for the submission of a remedial

study. The competent committee is currently working “on the promotion of a

framework and measures for the NATURA 2000 area of Kiparissia”.

34. ΠΕ/5 On 04.10.2012, soil pollution and an IMMINENT THREAT of water damage

were found, due to an illegal landfill of mixed hazardous and non-hazardous

waste by natural persons, at a forest area in Arcadia. The work of the RCIEL

of Peloponnese is ongoing.

from 63


35. ΠΕ/6 On 10.12.2012, soil damage was found, at a state-owned marble quarry site

leased by its operator, in Argolida. The Secretary General of the

Decentralised Management issued a decision for the termination of the lease

and the environmental restoration of the site. An update on the progress of

the implementation of the measures is pending.

36.10/1 On 02.04.2013, a non-governmental organisation (NGO) submitted a request

for the prevention and remedy of environmental damage as a result of an

extensive landslide at the Zakynthos landfill, which is located within the

National Marine Park of Zakynthos and within the NATURA 2000 network,

with the code GR2210002/SCI. A JMD was issued for the modification and

extension of the DAEC, for the restoration and subsequent maintenance of

the landfill. The findings of the HEI are anticipated, following an in situ

inspection performed jointly by the ICOIEL and HEI, in April 2013.

37. Β.ΑΙΓ./1 On 17.01.2011, a non-governmental organisation (NGO) submitted a request

for action in response to the degradation of the coastal environment - the

coastal zone, on the island of Ikaria, within the NATURA 2000 network, code

No 4120005 /SPA. The competent services performed in situ inspections and

found: (a) the dumping of surplus material from excavations at a communal

rocky foreshore-beach area of approximately 4,180 m2, creating the risk of

landslides during rains; and (b) an IMMINENT THREAT of water damage and

potential adverse effects on the ecological potential of the sea, due to the

escape of surplus material from excavations to the sea. The opinion of the

RCIEL of the Northern Aegean was released, recommending primary

restoration and the preparation of a study. A DAEC was issued by the

SES/Ministry of Environment, Energy, and Climate Change, for the

submission of a Special Ecological Assessment and a Final Planning

Compliance file. An update of the implementation of the recommendations is

anticipated.

from 63


38. Β.ΑΙΓ./2 On 13.05.2011, soil damage and an IMMINENT THREAT of damage to the

underground aquifer (erosion from uncontrolled mining and dumping, surface

disposal of waste lubricant oils, illegal temporary storage of hazardous waste,

and abandonment of solid waste, such as drums, old metals, plastic

packaging , ELVs) were found at a public area of approximately 150.000 m2,

on the island of Chios, where a vehicle maintenance workshop and asphalt

concrete/ready-made concrete production plant, and equipment and

construction materials warehouse facilities were operating illegally and/or

unsupervised. Following the recommendation of the PEAPX of the Northern

Aegean, the Secretary General of the Decentralised Administration issued a

decision for the implementation of preventive and remedial measures. An

appeal by the Municipality of Chios (as owner of the land), against a decision

imposing a fine, is pending. Update on the progress of the case is pending.

39. Ν.ΑΙΓ./1 On 27.07.2011, soil and water damage was found (destruction of the

geomorphological structure of the coastal zone and destruction of the natural

bed of watercourses, with possible consequences such as flooding and

erosion), due to the illegal opening up of a dirt road with a length of 1000

metres and an average width of 6.5 metres, inside a foreshore - public beach

zone, on the island of Kos. A report on the actions of the competent Agencies

is anticipated, following the classification of the case under the environmental

liability regime by the HEI.

from 63


40. Ν.ΑΙΓ./2 On 17.07.2012, residents of the island of Andros reported the risk of damage

to the soil, water and public health, due to uncontrolled waste disposal and

possible leakages to the sea at the onshore zone of Batsi Port. By decision of

the Deputy Head of the Region, preventive measures were taken for the

protection of public health. The site was cleaned and measures were taken for

future licensing, and the installation and operation of a baler. After a partial

inspection by the HEI, placement under the Directive was not deemed to be

warranted. A decision by the Inspector General for the Environment,

according to Article 13 of P.D. 148/2009, is pending.

41. ΚΡ/1 On 07.12.2011, the degradation of a sensitive ecological area was found, at

the estuary of the Aposelemis River, in the Municipality of Chersonisos, in the

Region of Heraklion, Crete (habitat classified as a Wildlife Sanctuary and

Protected Wetland), due to illegal interventions (embankments, filling, illegal

constructions) by unknown parties. The competent Agencies recommended

some immediate preventive and remedial measures. The case is pending

consideration by the RCIEL of Crete.

42. ΚΡ/2 On 06.02.2012, soil and water damage was found, due to failures recorded in

a landfill, in the Region of Rethymno, Crete (insufficient coverage and

dispersion of waste outside the landfill, non-compliance with the

environmental conditions regarding the management of leachate). The case is

pending consideration by the RCIEL of Crete.

43. ΚΡ/3 On 21.05.2012, degradation of a coastal ecosystem, destruction of dunes and

natural vegetation and alterations of a sea turtle breeding habitat were found,

at the coastal zone of Kommos, in the Municipality of Faistos, in the Region of

Heraklion, Crete (area within an IMATURA 2000 network, with the code

GR4310004/SCI), due to illegal interventions within the foreshore (total

destruction of geological formations) by a private development company. The

opinion of the RCIEL of Crete concerning action has been released. The

competent Agencies are investigating the appropriate preventive/remedial

measures, in order for them to be forwarded to the DESP of Crete.

C. Types of Damage - Imminent Threat

Chart 4 lists the cases according to the type of environmental damage recorded. It is noted that the

majority of cases, 41% of all cases, relate to soil damage, mainly due to the uncontrolled disposal of

solid and liquid wastes, hazardous and non-hazardous. The next largest group are cases of confirmed

water damage, 11% of all cases, mainly due to dumping in streams or the leakage of polluted-

contaminated leachate into underground aquifers. Regarding the cases of damage found in

species/habitats, they account for 8% of all cases, and mainly involve the destruction of dunes and

natural vegetation, due to interventions such as excavations and the dumping of surplus excavation

from 63

material, the opening up of roads and the building of illegal structures.

In Tables 1 & 2 of Annex II, as well as in Chart 4, a clear distinction is made between Confirmed

Damage and Imminent Threats of Damage, according to the additional guidance of the European

Commission.

It is observed that, in contrast to confirmed damage, the cases of imminent threats to the water are

more than the cases of imminent threats to soil (25% versus 15%, respectively). This is probably due

to the fact that water damage detection and confirmation is technically more difficult compared to soil

damage, especially when it comes to groundwater where a direct opportunity for sampling may not

exist.

SOIL-DAMAGE

SOIL-IMMINENT THREAT

WATER-DAMAGE

WATER-IMMINENT THREAT

SPECIES & HABITATS - DAMAGE

CHART 4: TYPES OF DAMAGE - IMMINENT THREAT

from 63

Finally, it is evident that an environmental liability case may result in damage and/or an imminent

threat of damage, affecting (or expected to affect) at the same time more than one category of natural

resources / agencies (species/habitats, waters and soils). This is observed in thirty-one (31) cases,

60% of all cases (Tables 1 & 2 of Annex II).

D. Classification of Activities - Liable Operators

Concerning classification under STAKOD 2008 of the liable operators, relevant data were provided

for those activities for which this was possible.

The activities of the manufacturing sector (sector C) amount to thirty-two (32) in total, of which more

than half (nineteen, 19) are industries producing basic metals and industries manufacturing metal

products.

Nine (9) of the activities relate to waste management (sector E). Note that an activity or an operator

can take as many STAKOD codes as their production processes.

The aforementioned data are presented in detail in the following Table:

from 63

CLASSIFICATION OF ACTIVITIES - OPERATORS BY SECTOR (STAKOD 2008)

STAKOD 2008

DESCRIPTION NUMBER OF ACTIVITIES - OPERATORS

SECTOR A (TOTAL)

AGRICULTURE, FORESTRY & FISHERIES 1

1.47 RAISING OF POULTRY 1

SECTOR B (TOTAL)

MINING & QUARRYING 4

7 MINING OF METAL ORES 1

8 MINING & QUARRYING 3

SECTOR C (TOTAL)

PROCESSING 32

10 MANUFACTURE OF FOOD PRODUCTS 4

16.29 MANUFACTURE OF WOOD PRODUCTS 1

17 MANUFACTURE OF PAPER & PAPER PRODUCTS 1

18.1 PRINTING AND RELATED ACTIVITIES 1

23 MANUFACTURE OF NON-METALLIC MINERAL PRODUCTS 4

24 MANUFACTURE OF BASIC METALS 10

25 MANUFACTURE OF METAL PRODUCTS (EXCEPT MACHINERY &

EQUIPMENT) 9

30.1 SHIPYARDS 1

31.0 MANUFACTURE OF FURNITURE 1

SECTOR D (TOTAL)

SUPPLY OF ELECTRICITY, GAS, STEAM & AIR CONDITIONING 2

35.11 ELECTRICITY GENERATION 2

SECTOR E (TOTAL)

WATER SUPPLY. SEWERAGE, WASTE MANAGEMENT & REMEDIAL ACTIVITIES

9

38 REFUSE COLLECTION, PROCESSING & DISPOSAL - MATERIALS

RECOVERY 9

SECTOR F (TOTAL)

CONSTRUCTION 4

41 CONSTRUCTION OF BUILDINGS 1

42.11 CONSTRUCTION OF ROADS & HIGHWAY 3

SECTOR G (TOTAL)

WHOLESALE & RETAIL TRADE. REPAIR OF MOTOR VEHICLES &

MOTORCYCLES 2

45.20 MAINTENANCE & REPAIR OF MOTOR VEHICLES 1

47.30 RETAIL TRADE OF AUTOMOTIVE FUEL 1

SECTOR H (TOTAL)

TRANSPORT & STORAGE 2

52.10 STORAGE 2

- UNDIFINED CLASSIFICATION 4

- UNCHECKED INTERVENTIONS IN HABITATS 3

from 63

E. Bodies Forwarding the Cases

As to the bodies forwarding the cases of environmental liability to the competent authorities (Chart 5),

it is noted that the bodies which are listed are the ones through which the cases were forwarded for

the first time to the ICOIEL, or through which the cases were forwarded to the Decentralised

Administrations which recorded the said information on the standardised form (Excel file) that was

sent to them.

According to Chart 5, twenty-seven (27) cases (52%) have been forwarded by Agencies of the

Decentralised Administrations, and twenty (20) cases (38%) have been forwarded by Agencies of the

Ministry of Environment, Energy, and Climate Change, 15 of which by the HEI. It is further noted that

the submission of requests for action by natural and legal persons, such as Non-Governmental

Organisations (NGOs), account for 4% of all cases, and these requests were submitted to ICOIEL.

F. Cost of the Measures

As to the cost of the preventive/remedial measures which were taken, the amounts for approximately

17% of the cases (9 out of 52 cases), as disclosed to ICOIEL, or as specified in the relevant

administrative acts (decisions determining preventive/remedial measures), are listed in Tables 1 and 2

of Annex II. Although these data do not provide a basis from which to draw definite conclusions, it is

estimated that the relevant expenditure incurred in Greece and/or budgeted on average for each

case, excluding special and isolated cases, amounts to approximately €60 000.

YPEKA - HEI

YPEKA-OTHER AGENCIES

(SSEEI, ETC)

DECENTRALISED ADMINISTRATIONS

MUNICIPALITIES

NON-GOVERNMENTAL ORGANISATIONS (NGOS)

OTHER (PRIVATE ENTITIES, INDIVIDUALS, ETC)

CHART 5: FORWARDING BODIES

from 63

Despite the fact that the responsible operators are known in all cases, for three (3) cases (Ref. AT/1,

ΗΠ/1 and ΣΤ/17), the remedial cost was initially undertaken entirely by the Greek state (although the

responsible operator was not the Greek state). This happened because these cases of environmental

damage were the result of accidents in abandoned operations or plants and required an immediate

response because of the high risk level. The ICOIEL awaits information on the action taken by the

competent regional authorities to recover the costs incurred by them.

G Judicial appeals

Finally, with respect to appeals made to the Greek judicial authorities against Decisions which

enforced measures and which were issued according to Articles 8, 9 and 10 of P.D. 148/2009, and

according to the data reported to ICOIEL, there is one pending case (Ref. ΔΥΤ/1). In this case, the

operator appealed to the Greek courts against a decision by the Secretary-General of the

Decentralised Administration ordering the implementation of remedial measures. A ruling by the

Council of State (CoS), Greece's supreme administrative court, is pending.

from 63

2.3 SPECIAL CASES - ASOPOS

The pollution of the wider area of the Asopos river mostly became known of August 2007, on the

publication of measurements of the Hellenic General Chemical State Laboratory, and other accredited

laboratories, according to which high levels of heavy metals, hexavalent chromium and nitrates were

detected in the aquifer of the region, as well as exceedances of the parametric values defined by

Community legislation on the quality of water intended for human consumption, according to Directive

98/83/EC (JMD Y2/2600/2001, Government Gazette, Series II, No 892/2001).

In 2007, the Ministry of Environment, Energy and Climate Change declared the area of Asopos a case

of "Special National Intervention" and the Hellenic Environmental Inspectorate (HEI) was instructed to

intensify the inspection and control activities in the area. Note that during the 2004-2012 period there

have been in total more than 250 checks and rechecks of works and activities in the area.

From 2010 onwards, the Ministry of Environment, Energy and Climate Change has taken action to

address the issue of pollution in the Asopos area (Inofita - Schimatari) and to examine the issues

closely in order to address the problem directly.

In February 2010, the "Programme of Integrated Management of the Environmental Crisis in the

Asopos River" was presented, which took into account the constant demands of the Local

Community, and which was formed following systematic cooperation with all stakeholders and

agencies. The coordination of action was undertaken by the Special Secretariat for the Environment

and Energy Inspectorate (SSEEI), its coordinating role according to Law 3818/2011, and the Special

Secretariat for Water of the Ministry of Environment, Energy and Climate Change. This program

consists of measures for immediate implementation and measures of medium- and long-term effect,

including the establishing of rules, guidelines and procedures governing the control of sources of

pollution and the way that industry operates, the clarification of responsibilities between agencies,

informing the citizens and all stakeholders, etc., and measures which are implemented gradually, with

the following objectives:

from 63

the protection of public health;

the containment and eradication of pollution;

the planning of the industrial area of Inofita, Schimatari;

ensuring the implementation of the measures.

As a first and immediate measure, JMD 20488/2010 (Government Gazette, Series II, No 749/2010)

“Determination of Environmental Quality Standards in the Asopos River and Limits for Emissions of

Industrial Wastewater in the Asopos Watershed” was issued by the Ministry of Environment, Energy,

and Climate Change , which lays down stringent quality thresholds for both Asopos and the emissions

of industrial wastewater in the area.

To intensify the coordination of actions for the implementation of JMD 20488/2010 and the monitoring

of the progress of the implementation of the "Program of Integrated Management of the

Environmental Crisis in Asopos River", at central and regional level, the SSEEI established a

Committee by Decision 270/2012 (Internet Posting Number: ΒΟΖΝΟ-ΛΨ45), with the primary task of

processing proposals and the taking of initiatives and action concerning the following:

compliance of industrial and other activities with JMD 20488/2010 on Asopos;

issues of water disposal for urban and industrial use and irrigation;

implementation issues of environmental liability;

exploring the possibility of creating a central industrial waste treatment unit, while

finding temporary solutions for the treatment and management of industrial waste

(hazardous and non-hazardous);

planning of the unofficial industrial area (Inofita - Schimatari);

examination of the practices followed in other Member States of the EU.

5 http://static.diavgeia.gov.gr/doc/%CE%92%CE%9F%CE%96%CE%9D0-%CE%9B%CE%A84

http://static.diavgeia.gov.gr/doc/%CE%92%CE%9F%CE%96%CE%9D0-%CE%9B%CE%A84

from 63

2.3.1 Implementation issues of environmental liability in the area of Asopos river

Specifically, with regard to the implementation of environmental liability in the Asopos area, the

Decentralised Administrations of Thessaly - Central Greece, and Attica, with their advisory bodies (the

RCIEL of Central Greece and the RCIEL of Attica, respectively) and in cooperation with the ICOIEL,

have placed a total of seven (7) activities (13% of all cases of environmental liability), presented in

Annexes I and II of this report, in the area of Asopos (within or at the boundaries of the river basin)

under environmental liability status, of which:

five (5) are located in Central Greece and two (2) in Attica;

four (4) concern the unchecked disposal of hazardous waste in the soil and subsoil from

metal industries (Ref. ΣΤ/6, ΣΤ/10, ΣΤ/21 and ΣΤ/28);

one (1) concerns the uncontrolled burial of hazardous and non-hazardous waste (Ref. AT/4);

two (2) concern the unchecked disposal of waste by unknown operators (Ref. AT/7.30 and

ΣΤ/26).

two (2) cases of remedial measures have been completed (Ref. AT/7.30 and ΣΤ/10).

Regarding damage to the aquifer in the area and considering the high concentration of activities, the

imputation of the liability to more than one liable operator requires that all agencies cooperate with the

ICOIEL, since the appropriate tools must be developed, based on which it will be possible to

determine the remedial objectives and allocate the relevant costs.

It is estimated that the modification of the decisions on the Approval of the Environmental Conditions

(AEPO) for the activities in the Asopos basin, as required by the applicable legislation (JMD

20488/2010), with the parallel carrying out of preventive, scheduled and unscheduled environmental

inspections (as provided for in Article 20 of Law 4014/2011 on the environmental authorisation of

projects and activities), will contribute to the compliance of the activities. Moreover, according to the

provisions of Circular 65/2011 of the SSEEI, when amending decisions on environmental conditions,

the remedy of environmental damage may be included in the relevant AEPOs. In parallel with the

compliance of the activities, the securing of funding for the implementation of the proposed remedial

measures (e.g. artificial enrichment of alluvial aquifers in the area through drilling) is expected to

contribute to the recovery of the system.

from 63

3.1 Problems and challenges for the improvement of the implementation of Directive

2004/35/EC in Greece

Implementation of the Directive on environmental liability in Greece positively affects both the

administration and the operators towards taking appropriate preventive measures and addressing the

damage caused to the environment. At the same time, a number of challenges are identified

concerning the following:

Operators in some cases fail to take preventive measures to avoid an imminent threat of

environmental damage and do not comply with the decisions of the administration on the

application of the preventive measures. Full application of the waste management and disposal

procedures, especially for hazardous waste, in combination with ensuring adequate

infrastructures, may help towards improving compliance so that eventually the “polluter” is

burdened with the full cost.

The issuance of the Joint Ministerial Decision on a compulsory financial guarantee (through

insurance or other financial securities) will ensure the assumption of the liability by the operators,

and the ICOIEL’s actions have been intensified to this end.

Close cooperation with other agencies which are responsible for the implementation of the

relevant Directives which are included in the definitions of Directive 35/2004/EC, such as the

Directives for the protection of species and habitats (92/43/EEC and 79/4C19/EEC), for the

protection of water (2000/60/EC), and the implementation of Directive 2008/98/EC, will improve

the efficiency of the actions of the Public Administration.

A number of limitations was noted during the moving forward of the administrative procedures for

the determination of preventive and remedial measures, including:

o a lack of funds at the regional level, due to cost reductions, which affects: the approval of

expenditures for conducting inspections and the determination and/or assessment of the

environmental damage; the performance of rechecks to determine the degree of compliance

(or non-compliance) of the operators with the decisions of the administration; the monitoring

of the implementation of the remedial measures (the above are a source of additional

administrative costs for the administration, which cannot be costed because they depend on

various factors such as the severity of the incidents, the degree of compliance of the

operators, the number of the operational units involved due to the overlapping of

responsibilities; etc.);

o the staffing of the competent authorities;

o the taking of immediate preventive and/or remedial measures when an accident has occurred

and the operator cannot be identified.

the lack of a legislative framework especially for the soil (failure to adopt national environmental

quality standards). For the resolution of this issue, partnerships are being developed with

research and scientific institutions (such as the National Centre for Sustainable Development -

Institute of Geology and Mineral Exploration & Research EKVAA-IGMEM, and the National

Agricultural Research Foundation NAGREF) for the adoption of methods in order to reach the

targets and to identify remedial measures. Under the 7th Action Programme for the Environment,

from 63

the relevant initiatives will be undertaken.

Online access to environmental information on the state of the environment, which is expected to

improve significantly with the implementation of Directive INSPIRE, will become a common basis

for operators, the administration, insurance companies, banks, NGOs.

from 63

3.2 Targets and subsequent action

In addition to the above responsibilities (as set out in Article 6 of P.D. 148/2009), the ICOIEL directs

its activities towards the implementation of the following targets, with a projected date for their

accomplishment of the end of 2013:

Issuing of the Joint Ministerial Decision for the financial security, as mentioned above.

Issuing of a Ministerial Decision concerning the manner in which the stakeholders (natural and

legal persons who submit a request to undertake activities) will be informed about the

implementation of environmental damage remedial decisions, including the persons in whose

properties remedial measures must be performed and who are invited to express their opinion

(Article 10(3) of P.D. 148/2009).

Mobilisation of the CIEL for the taking and implementation of horizontal measures in high

environmental risk management areas of particular national importance at an environmental and

socioeconomic level (addressing the environmental damage in the basin of the Asopos River).

Implementation of the actions envisaged under the project “Support for the operation of the

ICOIEL” by the NSRF-OPESD, with particular emphasis on the drafting and preparation of

supporting base studies, and the creation of an integrated database so that the information on

the initial state of the environment will be available.

Organisation of workshops in order to inform the competent authorities, with the participation of

representatives of four Regional Committees for the Implementation of Environmental Liability for

the second half of 2013, while such workshops are planned for the remaining RCIELs for next

year (2014), in order to strengthen implementation at regional level.

Cooperation with the Green Fund for the financing of activities towards accomplishing the targets

of P.D. 148/2009 in cases where the operator can not be identified, with the establishment of

priority criteria.

Staffing of the ICOIEL and restructuring/reconfiguration of the website.

from 63

ANNEX I


from 63


43 cases involving unchecked discharges of solid and liquid waste of unknown origin, hazardous and

non-hazardous (Chart 6), most of which were in areas of Attica, Viotia and Evia, were forwarded to

the ICOIEL. The improper disposal of waste by unidentified operators has emerged as a major threat

to the environment and public health. The cost of collection and removal of “orphan" waste and the

restoration of polluted sites is ultimately borne by the Greek government, with little chance for the

subsequent recovery of the cost, since it is impossible to identify the owner - operator who caused the

environmental damage (or the threat thereof).

These cases are governed by the legislative framework for hazardous waste (JMD 13588/725/2006

”Measures, conditions and restrictions for the management of hazardous waste in compliance with the

provisions of Council Directive 91/689/EEC of 12 December 1991 ‘on hazardous waste’”.

Replacement of Joint Ministerial Decision 19396/1546/1997 ‘Measures and conditions for the

management of hazardous waste’ (B'604)”, (Government Gazette, Series II, No 383/2006), in

conjunction with P.D. 148/2009. Overlapping of responsibilities is avoided by combining the two

legislative frameworks which apply to cases of unchecked dumping by an unknown operator (JMD

13588/725/2006 and P.D. 148/2009).

KNOWN OPERATORS

UNKNOWN OPERATORS (UNCHECKED

DISCHARGES) CHART 6: NUMBER OF KNOWN - UNKNOWN OPERATORS

from 63

As shown in Chart 7, for thirty nine (39) of those cases (accounting for 91% of all unchecked

dumping) the remedial cost has already been borne by the Greek state while action is still pending for

the remaining four (4) cases. Eighteen (18) cases (42% of all unchecked dumping) are already

closed, i.e. the remedial measures have been completed.

As to the cost for the restoration of sites where unchecked dumping has occurred, there are available

data for approximately 88% of the cases (38 out of 43 cases), which are disclosed to the ICOIEL, or

are provided for by the relevant administrative acts (Decisions for the determination of

preventive/remedial measures). Although this information does not provide a basis from which to draw

definite conclusions (due to the volume and composition of the waste), the relevant expenditures that

were incurred in Greece and/or budgeted on average for each case, amount to approximately

€11,000.

The ICOIEL took the initiative of advancing the handling of these requests due to the accumulation of

these cases, which cause or may cause environmental damage to species/habitats, waters and soils,

and in this context, the ICOIEL submitted a proposal for the inclusion of these cases in a financing

programme under the Green Fund of the Ministry of Environment, Energy, and Climate Change,

established by Law 3889/2010 (Government Gazette, Series I, No 182/2010). A recent decision of the

Minister for the Environment, Energy, and Climate Change (March 2013, Internet Posting Number:

ΒΕΔΣ46Ψ844- 9Ω06) provided approval for the granting of credit under a financing programme which

includes the actions of “collection and management of hazardous waste in order to reduce

environmental damage and to assist the work of the Administration in the implementation of remedial

measures in cases where the party responsible for the damage cannot be identified.” The requests

were submitted by the Decentralised Administrations, which conducted in situ inspections, checked

the traceability of the responsible operators and forwarded the cases of unidentified operators to the

ICOIEL for evaluation. Subsequently, the procedures for the financing of the relevant operations for

the removal and management of waste, which will be completed by December 2013, were advanced.

6 http://static.diavgeia.gov.gr/doc/%CE%92%CE%95%CE%94%CE%A346%CE%A8844-9%CE%A90

COST BORNE BY THE STATE- KNOWN OPERATORS- COST RECOVERY PROCEDURES UNDERWAY

COST BORNE BY THE STATE- UNKNOWN OPERATORS (UNCHECKED DISCHARGES)

CHART 7: NUMBER OF CASES WHERE THE COST IS BORNE

BY THE COMPETENT AUTHORITIES

http://static.diavgeia.gov.gr/doc/%CE%92%CE%95%CE%94%CE%A346%CE%A8844-9%CE%A90

from 63

ANNEX II:

Register of environmental liability cases in Greece –

Tables

from 62

TABLE 1: REGISTER OF ENVIRONMENTAL LIABILITY CASES IN GREECE - “CLOSED” CASES (9)

Type of Environmental Damage

Implementation of Measures & Cost Estimates

Ref.

Date of occurrence and/or

discovery of damage

Agency or Forwarding Body Activity - Operator

Geographic Location /

Municipality / Regional Unit

Competent Authority Water Species & Habitats

Date of placing under the Directive

Other legislative

framework involved (besides the Directive) Preventive/remedial Measures

Measures Implementation Cost

Measures

Completion Date Measures Implementation Phase and/or Actions Phase

AT/1

06-10-2010

Inspection by the HEI. HEI

Abandoned plant of

sealing and insulating materials.

Area of VOTANIKOS/

ATHENS/ ATTICA CENTRAL SECTION

DAA, RCIEL of Attica

Storage of 25 tonnes

of chemical waste used in the manufacture of

polyurethane products. Leakage in the soil.

Decisions of 04-05-2012 & 22-05-2012 of the Secretary General for the

implementation of remedial measures.

Sealing and securing the site, and, in parallel, notice to the liquidator (SSEEI Special Secretary). Collection and removal of materials and any contaminated soil, from a duly licensed

operator, at the expense of the Municipality of Athens (Decisions of the Secretary General).

€73,800 (VAT included) BORNE BY THE STATE 29-04-2013 Completed

ΣΤ/3 15-06-2010

DATCG,

DESP of Central Greece

Galvanising- Metal structures. STAKOD 2008: 25.61

ROVITSEZA location, M.U. of Schimatari/ TANAGRA/ VIOTIA

DATCG, RCIEL of Central Greece

IMMINENT THREAT Inspection for soil damage due to the

disposal of treated wastewater in septic tanks.

Decision of 24-05-2013 of the Secretary General for

the implementation of preventive and remedial measures. JMD 13588/725/2006

The subsurface disposal of waste was stopped. The measures

decided included the opening-up of the septic tanks, the pumping out of water and the collection of sludge from their bottom (if any) and the management of the waste by a

licensed operator, the sealing with concrete of the exits of the piping leading to the septic tanks with appropriate material and their resealing (Decision of the Secretary General).

24-07-2013 Inspection by the DESP of Central Greece. Completed

ΣΤ/5 10-11-2010

DATCG,


Power plant. STAKOD 2008: 35.11

M.U. of Aliveri/ KYMI-ALIVERI/ EVIA


Pollution of soil by mineral oils from a storage tank.


the implementation of remedial-restoration measures.

Bioremedial with in situ application (Decision of the Secretary

General). Decision in force until 26-07-2016 Completed

ΣΤ/7 17-12-2010

DATCG,


Warehouse of construction equipment

DRAGANIA location of Ipatos / THIVA/ VIOTIA


Soil pollution by mineral oils.

Decision of 26-07-2011 of

the Secretary General for the implementation of preventive measures. JMD 13588/725/2006

The surface layer was removed and a potential pollution

assessment study was submitted. Decision of the Secretary General for the periodic sampling and analysis of borehole water, as a preventive measure. 17-12-2010 Completed

ΣΤ/8

20-12-2010

Directorate of Environment of the P.G. of Evia.

DATCG,


Shipyard. STAKOD 2008: 30.1

ORMOS MEGALO VATHI location, Avlida M.U./ CHALKIDA/ EVIA




the implementation of remedial-restoration measures.

Removal of contaminated soil and restoration- filling up -of the site (Decision of the Secretary General). 03-02-2012 Completed

ΣΤ/10

20-01-2011 Inspection by the

HEI.

DATCG, DESP of Central

Greece

Metal working plant. STAKOD 2008: 25.61

and 24.42.2

PATIMA location, M.U. of Schimatari/

TANAGRA/ VIOTIA

DATCG, RCIEL of

Central Greece

IMMINENT THREAT Disposal

of hazardous waste in septic

tanks.

Decision of 28-11-2011 of

the Secretary General for the implementation of preventive and remedial

measures.

Modification of the method of waste management, sealing of septic tanks after emptying (removal of sludge and any water) and filling-up of the septic tanks with inert material (Decision of

the Secretary General). 17 & 18-05-2012 Completed

ΘΡ/1


HEI, fire on 20-06-2010. HEI

Warehouse (outdoor) of used car tires. STAKOD

2003: 372.0 STAKOD 2008: 38.32 (with reservation)

M.C. of Xiropotamos / DRAMA/ DRAMA

DAMT, RCIEL of Eastern Macedonia & Thrace

IMMINENT THREAT

Risk of damage to the soil due to emissions after a fire.

IMMINENT THREAT Risk

of water damage due to emissions after a fire.

Ban on free grazing and consumption of raw milk and meat.

Compulsory stabling of the animals in the surveillance zone. Covering-up (backfill) of combustion residues with the laying of concrete and earth materials (soil), in two phases.

PARTIAL PUBLIC EXPENDITURE (FIRE EXTINCTION)

Fire fully extinguished

on 23-07-2010. Completion of backfill on 29-04-2011.

Completed. A pollution assessment report was prepared. No

pollutants were detected in the soil or in the water. However, the possibility of retesting with new samplings is under examination. Need for longitudinal monitoring of groundwater status.

ΘΡ/2

26-07-2011

Inspection by the RCIEL of Eastern Macedonia &

Thrace, following a fire on 22-07-2011.

DAMT, DESP of

Eastern Macedonia & Thrace

Printing factory of compound & flexible packaging materials.

STAKOD 2003: 222.2 STAKOD 2008: 18.1 (with reservation)

Industrial Area of

Komotini/ KOMOTINI/ RODOPI

DAMT, RCIEL of Eastern Macedonia & Thrace

IMMINENT THREAT

Risk of damage to the soil due to emissions after a fire.


of water damage due to emissions after a fire.

26-07-2011 DESP of Eastern Macedonia & Thrace

Construction of a trench for the collection of water for fire-fighting purposes, collection-compacting of scrap. Removal of combustion residues by licensed operators. 22-11-2011

Completed. A remedial study was prepared. No pollutants were detected in the soil or in the water.

ΗΠ/1 17-06-2010

DAEWM, DESP of Epirus

Abandoned

juice plant. STAKOD 2008: 10.32

IMARET location/ ARTA/ ARTA

DAEWM, RCIEL of Epirus

Pollution of slopes and soil due to the leakage

of fuel oil into the river Arachthos from a fuel storage tank.

Leakage of fuel oil

into the river Arachthos from a fuel storage tank.

Decision of 29-07-2010 of the Deputy Minister of Finance for financing with

€150,000 from the Public Investment Programme (PIP).

Cleaning of the river (by pumping out the fuel oil), the slopes and soil (by collecting contaminated soils), interruption of the flow of the river at the POURNARI II dam, dismantling and

sealing of pipelines and canals, temporary overlays in the riverbed with greenhouse nylon and quarry sand coatings. Removal of contaminated materials by a licensed operator.

Monitoring of water, soil, organisms and agricultural products. Inventory of existing plants near the aquatic ecosystems of the area.

€70,000 (excluding VAT) for

cleaning the river. €23,000 (excluding VAT) for cleaning the slopes and soil. BORNE

BY THE STATE. COST RECOVERY PROCEDURE IS UNDERWAY.

Cleaning the river 19-20/06/2010. Cleaning the slopes and soil 22-

23/06/2010. Removal of contaminated materials 22/07/2010.

Completed successfully. Disappearance of the oil spills from the river and irrigation ditches.

from 62

TABLE 2: REGISTER OF ENVIRONMENTAL LIABILITY CASES IN GREECE - “OPEN” CASES (43)

Type of environmental damage Implementation of Measures & Cost Estimates

Ref.

Date of occurrence and/or discovery of

damage Agency or

Forwarding Body Activity - Operator

Geographic Location/ Municipality/ Regional

Unit Competent Authority Soil Water Date of placing under the

Directive Other legislative framework

involved (besides the Directive)

Judicial Appeals/ Outcome Preventive/remedial Measures


Measures Completion

Date Measures Implementation Phase

and/or Actions Phase

AT/2

07-10-2010 Inspection by the HEI. HEI

Laying house with a feed mill. STAKOD 2008: 01.47

SOUSOUNIZA or AVDELLA location,

M.U. of Erithres/ MANDRA- IDILLIA / WESTERN ATTICA DAA, RCIEL of Attica

Contamination of the soil

due to the unchecked dumping of liquid manure from a poultry farm.

IMMINENT THREAT Risk of pollution

caused by nitrates in groundwater and surface water, where

the leachate or overflows may end-up due to rain.

Submission of a remedial study has been requested. Pending update.

AT/3


HEI. HEI

Outdoor storage/ handling of hazardous materials. STAKOD

2008: 38.12

NEOKTISTA area/ ASPROPYRGOS/

WESTERN ATTICA DAA, RCIEL of Attica

Plastic/metal

drums/containers and IBC tanks with chemical residues (mineral oils, oily

liquids, concentrated acids, acidic solutions, aggregates). Leakage of

tarry material in the soil. 23-06-2011 HEI

Immediate sealing of establishment, removal of materials, submission of site decontamination-remedial plan

(HEI).

20-07-2011 Sealing of establishment

and partial removal of hazardous materials. Information on the removal of the remaining material of unknown

chemical composition is pending.

AT/4

04-10-2011

Inspection by the HEI. SSEEI

Uncontrolled Waste Disposal

Area. STAKOD 2008: 38.1 and 38.2

BOURDECHTI location,

former Municipality of Sikamino/ OROPOS/

EASTERN ATTICA DAA, RCIEL of Attica

Soil pollution due to the unchecked dumping of non-

hazardous and potentially hazardous waste.

IMMINENT THREAT

Convergence of two streams at the site. Imminent threat to the

underground aquifer from any leaks.

13-09-2012 Opinion of the RCIEL of Attica for the

implementation of preventive-remedial measures.

Prevention of unauthorised access,

securing of the site, arrangements for the rainwater (SSEEI Special Secretary). Submission of a

remedial-restoration study (RCIEL of Attica).

A Decision is pending, to determine the remedial measures.

ΣΤ/1

21-10-2009


Aluminium smelter. STAKOD 2008: 24.42.1

VATONTAS area, M.U.

of Nea Artaki/ CHALKIDA/ EVIA


Uncontrolled hazardous solid waste management

and soil pollution due to shoddy outdoor storage. JMD 13588/725/2006

Temporary shutdown of the operation. The submission of a

remedial study was required, with no response from the operator.

> €500,000 (Estimated cost)

A new in situ inspection and the

referral of the case to the RCIEL of Central Greece are pending.

ΣΤ/2 06-05-2010 DATCG, DESP of Central Greece

Building project. STAKOD 2008:41

MAGOULA or AG.

GEORGIOS location, M.U. of Anthidona/ CHALKIDA/ EVIA



An update is anticipated, following action by the DESP of Central Greece and the Region of Evia.

ΣΤ/6


HEI.

DATCG, DESP of

Central Greece

Manufacturing and recycling plant of batteries and cathodic protection anodes. STAKOD

2008: 24.43.1

LISIA location, M.U. of Inofita/ TANAGRA/

VIOTIA

DATCG, RCIEL of

Central Greece

Uncontrolled hazardous waste and material management, and soil

pollution due to their unchecked dumping at an outdoor site without a

rainwater collection network, with the waste flowing unchecked into the

soil. IMMINENT THREAT

Decision of 14-09-2011 of the

Secretary General for the implementation of preventive measures and the preparation

of a remedial study.

Transfer of lead slag inside the industrial building, sealing of the site and submission of an additional

management plan. Removal of non-hazardous waste by a licensed operator. Decontamination of the

grounds and possibly of the groundwater, as will be prescribed by the remedial study (Decision of

the Secretary General).

Partial transfer of lead slag inside the

industrial building. The operator is expected to take action, following recommendations from the DESP of

Central Greece.

from 62



Ref.


damage Agency or



Unit Competent Authority Soil Water Species & Habitats Date of placing under the





Measures Completion



ΣΤ/9


HEI.

DATCG, DESP of

Central Greece

Carrots and onions packaging

plant. STAKOD 2008:10.3

LAPSANA location, L.C. of Mouriki/ THIVA/

VIOTIA

DATCG, RCIEL of

Central Greece

Presence of solid and liquid waste in the soil and within the Lake Yliki exclusion

zone.

Presence of solid and

liquid waste in the soil and within the Lake Yliki exclusion

zone.

1) Decision of 16-12-2011 of the Secretary General for the implementation of preventive and remedial measures. 2)

Decision of 12-08- 2013 of the Secretary General for the implementation of additional

remedial measures. JMD A5/2280/1983

1st Decision of the Secretary General: Immediate shutdown of the operation. Removal of waste by

licensed operators. Quality measurements on the soil. Preparation and submission of an

environment remedial study by the operator, and of a timetable for the removal of facilities and equipment.

2nd Decision of the Secretary General: Removal of washing mud from the reservoirs, filling-up of reservoirs with healthy soil, fencing

and a ban on agricultural use of the area for a period of five years, with a review for lifting the ban after 10

years.

Within four (4) months after the signing of the second Decision of the

Secretary General.

Information on the progress of the implementation of the measures of

the second Decision is anticipated.

ΣΤ/11

23-03-2011

Inspection by the HEI.

DATCG, DESP of Central Greece

Paper mill. STAKOD 2008:17

PALAIA THIVA location, Kato Tithorea

area/ AMFIKLIA - ELATIA/ FTHIOTIDA


IMMINENT THREAT Check for soil damage due to the

disposal of solid and liquid waste.

IMMINENT THREAT Check for water damage due to the

disposal of solid and liquid waste in the soil.

Decision of 02-03-2012 of the Secretary General for the

implementation of preventive and remedial measures.

Identification of waste and removal

of waste by a licensed operator, sampling of soil and borehole water, and performance of quality

measurements (Decision of the Secretary General).

There was no response from the

operator. The file has been sent to HEI for the imposition of sanctions.

ΣΤ/12

26-04-2011

Inspection by the DESP of Central Greece.


Two (2) quarries. STAKOD 2008:08

MESOLOFOS location, L.C. of Kiparisi,

M.U. of Atalanti/ LOCRI/ FTHIOTIDA

DATCG, RCIEL of Central Greece YES

Decisions of 14-02-2012 & 28-12-2012 of the Secretary

General for the implementation of remedial measures.

Ministerial Decision Δ7/Α/off. 12050/2223/ 2011

Removal of stored materials and equipment. Restoration of the sites, through additional measures relating

to another relevant legislative framework (Decisions of the Secretary General).

Second Decision in force until 30-11-2013.

Restoration in progress. Information

on the progress of the implementation of the measures is anticipated.


Mineral oil regeneration, grease production, and slops processing plant.

LAMARI location at Stefani/ TANAGRA/ VIOTIA


Soil pollution by mineral oils (WLO).


Secretary General for the implementation of remedial-restoration measures.

Removal of contaminated soil and restoration- filling up of the site (Decision of the Secretary General).

Decision in force until 07-11-2013

An update on the progress of the implementation of the measures is anticipated.

ΣΤ/15 27-05-2011

DATCG, DESP of

Central Greece

Metalworking complex.

STAKOD 2008:07

Larimna, M.U. of Malesina/ LOCRI/

FTHIOTIDA

DATCG, RCIEL of

Central Greece

Historic depositions of powders in three (3) uncontrolled waste disposal

areas around the grounds.

IMINNENT THREAT to

groundwater.

Decision of 19-06-2012 of the Secretary General for the implementation of remedial-

restoration measures. JMD 13588/725/2006

1. Waste characterisation of historical deposits (hazardous or

not). 2. Transportation of historical deposits to a licensed landfill, if found non-hazardous. 3. Removal of

surface soil layer. 4 Control of pollution in the underlying layer. 5. Plant restoration at the sites

(Decision of the Secretary General). Unknown.

Step 1 has been completed. Step 2 will start after amending the DAEC of

the landfill and the preparation of a site for the historical deposits. An updated implementation schedule of

the pending measures is anticipated.

ΣΤ/16


Inspection Committee


Borrow pit for highway projects. STAKOD 2008:42.11

PALIOURA location,

181st km of the Athens - Lamia road, M.U. of Kamena Vourla/

MOLOS-AG. CONSTANTINOS/ FTHIOTIDA


Unchecked dumping due to the operation of a borrow pit.

Diversion of a stream bed and unchecked dumping into the old

stream bed, due to the operation of a borrow pit.


Secretary General for the implementation of preventive and remedial measures.

JMD 39624/2209/Ε103/2009,

Ministerial Decision Δ7/Α/off. 12050/2223/ 2011

Removal of all facilities.

Restoration of the flow of the stream. Fencing and restoration of the site, through additional measures relating

to another relevant legislative framework (Decision of the Secretary General).

€50,000 (forfeited letter of guarantee in favour of the State).

Work will be completed

by 10/28/2012 (Decision of the Secretary General).

The bulk of the facilities have been

removed. Information on the progress of the implementation of the measures is anticipated.

from 62



Ref.


damage Agency or



Unit Competent Authority Soil Water Date of placing under the





Measures Completion




Warehouse of agricultural supplies: pesticides-biocides -

fertilisers. STAKOD 2008: 52.10.19 (with reservation)

Settlement of Stroviki, M.U. of Akrefnia/

ORCHOMENOS/ VIOTIA


IMINNENT THREAT Storage of 32,000 litres of hazardous substances

(fertilisers, etc.) inside a building on the grounds.

Decisions of 22-06-2012 & 18-09-2012 of the Secretary

General for the approval of remedial-restoration works.

Identification and removal of waste and contaminated soil by licensed operators. Sampling of soil and

performance of water quality measurements. Submission of remedial - risk assessment studies

(Decisions of the Secretary General).

> €50,000. BORNE BY THE COMPETENT AUTHORITY. RECOVERY

OF THE COST SUBSEQUENTLY. Within 2013.

Commitment of funds and invitation to tender. An invitation to tender was

also issued in 2012, but was declared unsuccessful.


Seed oil operation. STAKOD 2008:10.41

KATAVOTHRA location- STENI/ ALIARTOS/ VIOTIA


Unchecked dumping of dangerous - ecotoxic liquid waste in a pit in the ground. IMMINENT THREAT

Check by the HEI on 21/06/2013. Information is anticipated.

ΣΤ/21

28-11-2011 The damage was initially

discovered on 28-09-2007 (inspection by the HEI).


Aluminum products plant. STAKOD 2008: 24.42

MEGALI RACHI

location, M.U. of INOFITA/ TANAGRA/ VIOTIA


IMMINENT THREAT Check

for soil damage due to the disposal of treated hazardous waste in septic

tanks. Concentrations of heavy metals.

Established

groundwater pollution (borehole) with hexavalent chromium.


Secretary General for the implementation of remedial-restoration measures. JMD 13588/725/2006

Dismantling of septic tanks and filling-up of the empty pits with argillaceous material, after removing

the bottom sludge and temporarily storing it at a suitable place inside the plant, in order to dispose of it at

a licensed hazardous waste collection operation (Decision of the Secretary General).

Within three (3) months from the notification of the Decision.

An update on the progress of the

implementation of the measures is anticipated. The ICOIEL cooperates with relevant Agencies and scientific

bodies in order to provide guidance in dealing with the pollution of the groundwater in the area.

ΣΤ/23 07-12-2011 SSEEI Restoration of old mining sites.

Mantoudi Business

Park, FOURNI location/ LIMNI - AG. ANNA - MANTOUDI/ EVIA


Deposition residues within old mining sites. JMD Φ/Α.5.33/15088/945/ 2012

A Technical Report on remedial measures has been requested from the operators (DESP of Central

Greece document of 03.11.2013, following publication of the JMD Φ/Α .5.33/15088/945/2012).

Action by the operators, following a document from the DESP of Central Greece, is pending.

ΣΤ/24 07-12-2011

DATCG, DESP of

Central Greece

Iron-nickel ore enrichment and processing facilities. STAKOD

2008: 24.1 & 24.4

VRISAKIA location at Politika/ DIRFIES -

MESSAPIA/ EVIA

DATCG, RCIEL of

Central Greece

Soil pollution due to the deposition of various hazardous and non-

hazardous waste (lubricant oils, ELVs, used tyres, WEEE, scrap, enrichment

gangue). IMMINENT THREAT

Decision of 22-06-2012 of the Secretary General for the implementation of remedial-

restoration measures. JMD 13588/725/2006

Removal of contaminated soil and other waste disposed in a disorderly manner at the site, by licensed operators. Removal and

management of gangue as provided for by DAEC and restoration of the site (Decision of the Secretary

General). December 2012

Documentation regarding waste removal and the restoration of the

site is anticipated.


Screw and binder manufacturing plant. STAKOD 2008: 25.94

KARAVOS location at Aliveri/ KIMI - ALIVERI/ EVIA


IMMINENT THREAT Check

for soil damage due to the disposal of treated hazardous waste in septic

tanks. Concentrations of heavy metals.

IMMINENT THREAT Check for water

damage due to the disposal of treated hazardous waste in

septic tanks. Concentrations of heavy metals. JMD 13588/725/2006

A pollution assessment study was submitted, along with additional information, by the operator.

Completion of the review of the additional information which was submitted by the operator is pending.

ΣΤ/27 31-01-2012 Fire on 10- 01-2012.


Former secondary aluminum

production plant. STAKOD 2008: 24.42

Gravia /DELPHI /FOKIDA


Disposal in the soil of

hazardous and non-hazardous solid and liquid waste and hazardous

gases. Fire due to the presence of these.


implementation of preventive and remedial measures. JMD 13588/725/2006

Preventing access to the site, safe

removal and management of gas (LPG), reporting on the risk of the waste, submission of a site

remedial-restoration study (Decision of the Secretary General).



from 62



Ref.


damage

Agency or



Unit Competent Authority Soil Water Species & Habitats

Date of placing under the

Directive

Other legislative framework


Judicial Appeals/

Outcome Preventive/remedial Measures

Measures Implementation

Cost

Measures Completion

Date

Measures Implementation Phase


ΣΤ/28

08 & 15-03-2012

Inspections by the EQCU and HEI.


(a) Brass products

manufacture and ironmongery metal parts plating plant, and (b) Woodcraft workshop

producing wooden doors and melamine products. STAKOD 2008: 25.61, 24.54,

25.71, 25.72, 25.73, 25.99,16.29 and 31.0

MAEDROSI location, AGIOS DIMITRIOS, Agios Thomas, M.U. of

Inofita/ TANAGRA/ VIOTIA


Illegal disposal of treated industrial wastewater.

Illegal disposal of treated industrial

wastewater.


implementation of remedial-restoration measures.

Decision of the Secretary General

for: 1) General measures (arrangements for a rainwater pipe, filling and sealing of septic tank,

clearing of the unused grounds of the plant and sampling at representative points and reference

points of the grounds). 2) Dealing with surface pollution (removal and transport of polluting surface layer).

3) Addressing of deeper pollution (solidification mixing processes). > €25,000

Within seven (7) months

from the notification of the decision.



ΣΤ/29

22-03-2012 Inspection by the HEI. HEI

Metal and non-metal waste recycling and vehicle

dismantling and recycling (ELVs) plant. STAKOD 2008: 38.32 (with reservation)

SCHINEZA location, M.U. of Avlida/ CHALKIDA/ EVIA


Soil pollution due to the uncontrolled disposal of

hazardous and non-hazardous solid and liquid waste. IMMINENT THREAT 12-09-2013 ICOIEL

A decision of the Deputy Head of the

Region of 01-06-2012 imposed the temporary total shutdown of the plant, until completion of the

restoration of the site. A remedial study has been submitted by the operator.

Implementation of the recovery plan prior to

environmental licensing for expansion, modernisation, etc.

There is communication with the operator for the completion of the

submitted remedial study, following relevant instructions from ICOIEL and DESP of Central Greece.

ΣΤ/31 21-05-2012

DATCG, DESP of

Central Greece

Former secondary aluminum - and possibly lead - production plant. STAKOD 2008: 24.42 &

24.43

MNIMA KATI location, Ritsona area/

CHALKIDA/ EVIA

DATCG, RCIEL of

Central Greece

Presence of solid hazardous

waste.

Decision of 26-06-2010 of the Secretary General for the implementation of preventive

measures. JMD 13588/725/2006

Transportation of waste indoors, characterisation and removal to licensed disposal or treatment site

(decision of the Secretary General). Unknown.

Waste has been transferred indoors. Pending characterisation and removal

to a licensed site.

ΣΤ/33 26-06-2012

DATCG, DESP of

Central Greece

Petrol Station-Car Wash-Lubrication Operation.

STAKOD 2008: 45.20 & 47.30

6th km of New National Road Psachna - Triada/ DIRFIES -

MESSAPIA/ EVIA

DATCG, RCIEL of

Central Greece

Soil pollution due to the

disposal of liquid waste from a car wash - lubrication operation in an

open earth reservoir.

Appropriate actions for the remedial-

restoration of the reservoir.

An update is anticipated, following the activities of the DESP of Central

Greece and the Region of Evia.

ΘΕ/1

02 & 04-03-2010 Inspections by the

HEI. SSEEI

Plant producing ceramic products. STAKOD 2008:

23.20

6th km Larissa - Sikouri/ LARISSA/

LARISSA

DATCG, RCIEL of

Thessaly


of soil damage due to unchecked outdoor dumping of approximately

10,000 tonnes.

IMMINENT THREAT Risk of water damage due to

unchecked outdoor dumping of approximately 10,000

tonnes.

Documents of 18-03-2011 and 08-03- 2012 of the

Secretary General of SSEEI, on the recommendation of compliance-remedial

measures.

A decision of the Prefect issued on 24-11-2010 imposed a permanent total shutdown of the plant and the

sealing of the premises. The as of 24-09-2012 DAEC issued by EARTH Directorate of the Ministry of

Environment, Energy, and Climate Change, included compliance-remedial

measures recommended by the Special Secretary of SSEEI (inventory and identification of

deposits, submission of a removal and/or management plan, submission of a site remedial-

restoration study).

Sealing on 25-11- 2010. DAEC in force until 20-

03-2014. Pending update.

from 62



Ref.


damage Agency or



Unit Competent Authority Soil Water


Other legislative framework involved (besides the Directive)



Measures Completion



ΜΑΚ/1


HEI.

DAMT, Forestry Office of

Thessaloniki

Forestry Office of Thessaloniki (Improvement and technical

construction works for the Forest Fire Lane Network of the Suburban Forest of

Thessaloniki).

Suburban Forest of

Thessaloniki SEICH SOU/ THESSALONIKI/

THESSALONIKI

DAMT, RCIEL of Central

Macedonia

IMMINENT THREAT Risk of soil damage due to deposits of asbestos waste

(asbestos pipes) in a forest.

IMMINENT THREAT Risk of water damage due

to the dumping of asbestos waste (asbestos pipes) in a

forest.


Directorate for Forests of the Thessaloniki Prefecture for the approval of a remedial

study. Law 998/1979 Management of asbestos waste. EUR 18,197.10

An update on the approval of funding

for the remedial cost is anticipated.

ΜΑΚ/2

19 & 20-10-2011 Inspections by the HEI. HEI

(A prosecutor’s inquiry is underway to identify the owner of the dumped waste).

1) Area of common land close to Eginio

road junction 2) REMA VOUTHNIKA, settlement of

Kolindro/ PIDNA - KOLINDROS/ PIERIA

DAMT, RCIEL of Central Macedonia

IMMINENT THREAT Risk of soil damage due to the dumping of aggregates, solid

industrial waste and phosphogypsum (estimated quantity 1200 m

3 at site 1).

IMMINENT THREAT Risk of water damage due

to the dumping of aggregates, solid industrial waste and

phosphogypsum (estimated quantity of 6 tuck-loads at site 2).

1) Decision of 14-07-2012 of the RCIEL of Central Macedonia to recommend to

the Secretary General the removal of waste from site 1. 2) Decision of 08/01/2013 of

the Secretary General to charge the waste owner with the cost of recovery.

Waste removed from site 2, one day after their dumping. Radioactivity

measurements were performed on-site. Measurement values were found to be within permissible limits.

Pending removal of waste from site 1 (Decision of RCIEL of Central

Macedonia). The charging of the waste owner with the recovery cost is pending, after a prosecutor’s inquiry

requested by the DESP of Central Macedonia (Decision of the Secretary General).

ΜΑΚ/3

29-05-2012 Thessaloniki Water Supply & Sewage

Company.

DAMT, DESP Central

Macedonia

Spelter craft operation. STAKOD: 25.99 (with

reservation)

Thessaloniki/ THESSALONIKI/

THESSALONIKI

DAMT, RCIEL of Central

Macedonia

Soil pollution due to uncontrolled disposal of

industrial waste.

Decision of 09.01.2013 of the Secretary General for the

approval of a remedial study.

Removal of contaminated soil, filling with healthy soil, periodic sampling and analyses for one year (Decision

of the Secretary General).

Decision in force until

28-02-2013

Restoration in progress. An update on the progress of the implementation is

anticipated.

WEST/1 11-03-2011 SSEEI Former asbestos production plant. STAKOD: 23.65

L.C. of Drepani, M.U. of Rio/ PATRA/ ACHAIA

DAPWGI, RCIEL of Western Greece

Soil pollution due to the dumping of 80,000 m

3 of

hazardous waste (materials containing asbestos and mineral oil residues).

IMMINENT THREAT to surface water and groundwater.


Secretary General for the approval of collection, removal (cross-border

transportation), and remedial-restoration works at the property. JMD 13588/725/2006

An application for

annulment by the operator against the Decision of the

Secretary General, at the Council of State is pending.

Collection, removal (cross-border transportation) of hazardous waste

and contaminated soils (remedial-restoration of property, Decision of the Secretary General). €40,641,500 Information is anticipated.

WEST/3

03-10-2012. The damage appears to

have occurred in early September 2012.

Managing authority of KOTICHI -

STROFILIA WETLANDS (Request for the

restoration of the linear island between the

wetland and the sea, at the Kotichi lagoon).

Unidentified - Various (Unchecked interventions within habitat).

Location of “Kotichi lagoon”,

northern part of the linear island/ ILIA


Geological degradation due to

unchecked earthmoving interventions (removal and deposition of sediments).

Damage to surface water and possibly groundwater, due to

unchecked diversion of freshwater to the sea, and also due to

interventions reaching the depth of the aquifer.

Degradation of coastal ecosystem. Destruction of

the sand zone. Within the NATURA 2000 network, code No

GR2330009(SPA) and GR2330006 (SCI): Kotichi lagoon

JMD 33318/3028/1998, JMD Η.Π. 37338/1807 / E. 103/2010

Anticipating a study for the determination of remedial measures.

Following the suggestions made by the HEI, the local Agencies of the

Region of Ilia performed an inspection on 11.10.2012, during which the damage was found. A

recommendation for the assignment of a remedial study has been submitted to the competent Regional

Council. The selection of a contractor for the preparation of the study is pending.

WEST/4 26/10/2012 HEI

R.U. Ilia (Storage of pesticides

- plant protection products. STAKOD 2008: 52.10.19 with reservation).

Inside and outside the

warehouse of the Directorate for Rural Economy & Veterinary

Medicine of the Region of Ilia, at Epitalio airport/ ILIA.


IMMINENT THREAT 23,300

litres of expired pesticides - plant protection products for combating the olive fruit fly,

weighing 29 tonnes. EWC: 02/01/08 *. Risk of soil damage due to a possible leakage.

IMMINENT THREAT In

case of leakage in the soil, risk of water damage.

31-10-2012 Open invitation to

tender from the Region of Ilia, for the removal and destruction of the pesticides.

Removal and destruction of pesticides and cleaning of the warehouse by a licensed operator. €82,000 (VAT included)

Tender implementation on 03-12 - 2012, or

18/12/2012 if canceled or declared unsuccessful.

A contractor has been selected. An update on the progress of the award procedures is anticipated.

from 62



Ref.


damage

Agency or



Unit Competent Authority Soil Water Species & Habitats


Directive



Judicial Appeals/



Cost

Measures Completion

Date



ΠΕ/1 16-07-2010 HEI Dairy - cheese operation. STAKOD 2008: 10.51

PSALIDI area, L.C. of Panagitsa, M.U. of

Levidi/ TRIPOLI/ ARKADIA

DAPWGI, RCIEL of Peloponnese

Soil pollution due to the disposal

of untreated wastewater in the surrounding area. IMMINENT THREAT Pending update.

ΠΕ/2 11-07-2011 HEI

Natural Person (Unchecked

disposal of demolition and excavation materials).

GLYFADA or VALTOS-KANALAKIA

area Kato Vervena/ NORTHERN

KINOYRIA/ ARCADIA


Ecosystem alteration,

destruction of vegetation and avifauna habitat. Wetland inside an officially

demarcated area under applicable national provisions: Mount

Parnonas - Moustos Wetland. JMD 33999/2010

Immediate removal of rubble and refuse. Reaching of an

understanding with the managing authority of Mount Parnonas - Moustos Wetland Ecological Park

concerning all possible preventive-remedial actions. Pending update.

ΠΕ/4 15-12-2011 HEI

Hotel-tourist-building and other enterprises (road construction -

habitat alteration). STAKOD 2008: 42.11).

Sand dunes of

Kiparissia - Neochori Kiparissia/

TRIFILIA/ MESSINIA


Degradation of coastal

ecosystem. Destruction of dunes and natural vegetation. Alterations of

sea turtle breeding habitat. Within the NATURA 2000 network, code No

GR2550005 (SCI): Sand dunes of Kiparissia.

Decision of 11-07-2012 of the Secretary General for barring access by wheeled vehicles

and for the submission of a remedial study. JMD 33318/3028/1998

Complaint 2156/2011 to the European

Commission. At pre-trial stage (Reasoned Opinion stage). Reply

to Reasoned Opinion, on 23-11-2012.

Direct barring of access by creating

embankments, using plant materials (Decision of the Secretary General).

A remedial study for the sand dunes was to be submitted by 15-09-

2012 (Decision of the Secretary General)

The competent Committee is currently working “for the promotion

of a framework and action for the NATURA 2000 area of Kiparissia”.

ΠΕ/5 04-10-2012 Municipality of Megalopoli

Natural Persons (Illegal burial

of mixed, hazardous and non-hazardous waste).

Forest area of the L.C. of Gefira/

MEGALOPOLI / ARKADIA


Soil pollution due to illegal landfills. IMMINENT THREAT 16-11-2012 HEI

Identifying waste, determining its volume and composition, and appropriate management (document

from the SSEEI Special Secretary 24-01-2013).

The work of the RCIEL of Peloponnese is ongoing.

ΠΕ/6 10/12/2012

DAPWGI, Technical Control Directorate -

Department of Natural Resources

Quarry - Marble cutting

operation. STAKOD 2008: 08.11 & 23.70

Public marble quarrying

site, hired by the operator, PSILI VIGLA /

EPIDAYROS/ ARGOLIDA

DAPWGI, RCIEL of Peloponnese YES

Decision of 10-12-2012 of the Secretary General for the termination of the lease and

the environmental restoration of the site.

Removal of mechanical equipment,

implementation of safety measures (fencing, appropriate signs, etc), documentation of the current state,

activation of P.D. 148/2009 (Decision of the Secretary General).

Decision in force until 10-02-2013


implementation of the measures is pending.

10/1

02/04/2013.

Extensive landslide occurred on 26/01/2013, but falls

of materials had occurred as early as October 2011

(inspection by EQCU).

CISD Organisation - CITIZENS INSPECTORATE

FOR SUSTAINABLE DEVELOPMENT

(Request for the prevention and remedy of

environmental damage resulting from an extensive

landslide at a landfill).

Managing authority of the

Landfill. STAKOD 2008: 38.21.21

GRYPARAIKA location

Vasilikos, Zakynthos, Gulf of Laganas/

ZAKYNTHOS/ ZAKYNTHOS

ICOIEL/ MINISTRY OF ENVIRONMENT,

ENERGY, AND CLIMATE CHANGE

Pollution of surface and coastal

waters due to leaks of leachate.

Landfill within the National Marine Park of Zakynthos. Sea turtle habitat

degradation within the NATURA 2000 network, code No GR2210002

(SCI): Gulf of Laganas of Zakynthos.

JMD of 08-06-2011 for the modification and extension of the DAEC, for the restoration

and subsequent maintenance of the landfill.

JMD 33318/3028/1998, P.D. 906/1999

Complaint 103/00 to

the European Commission. Suspension of Decision

imposing a fine by the European Court.

JMD of 08-06-2011 for the modification and extension of the DAEC, for the restoration and

subsequent maintenance of the landfill.

Extension of DAEE until 31-12 - 2015

The findings of the HEI are anticipated, following an in situ

inspection performed jointly by the ICOIEL and HEI, in April 2013.

from 62



Ref.


damage

Agency or



Unit Competent Authority Water Species & Habitats


Directive



Judicial Appeals/



Cost

Measures Completion

Date



Β.ΑΙΓ./1

17-01-2011. The damage is estimated to have occurred in

2010.

ARCHIPELAGOS Institute of Marine

Conservation

Hybrid power plant. STAKOD

2008: 35.11

KATO PROESPERA location, Raches,

Ikaria/ IKARIA/ IKARIA

DAAE, RCIEL of the

Northern Aegean

Dumping of surplus excavation materials, during the construction of a plant,

at a communal rocky foreshore-beach area of approximately 4,180 m

2.

Risk of landslides during

rainfall.

IMMINENT THREAT Environmental

degradation - degradation of the coastal zone, and

possible adverse effects on the ecological potential of

the sea, due to the escape of surplus excavation materials to

the sea.

Degradation of the coastal environment - coastal zone.

Within the NATURA 2000 network, code No 4120005 (SPA): Ikaria

Island (southwestern part).

The opinion of the RCIEL of

the Northern Aegean, of 02-05-2012, recommending first stage recovery and the

preparation of a study.

JMD 33318/3028/1998, JMD

Η.Π. 37338/ 1807/ E.103/ 2010

Stopping any non-licensed dumping of aggregates, until the granting of the required approvals (Documents

of the HEI and the SSEEI Special Secretary). Submission of a Special Ecological Assessment and a Final

Planning Compliance File (DAEC Amendment of 04-07-2012 by SES/Ministry of Environment,

Energy, and Climate Change).

DAEC in force until 31-

12-2013.

An update of the implementation of

the recommendations is anticipated.

Β.ΑΙΓ./2 13-05-2011 HEI

1) Asphalt concrete production plant

2) Ready-made concrete production plant and equipment and construction

materials warehouse 3) Municipality of Chios (as owner of the land). STAKOD

2008: 08.12.1, 23.63

Public area of approximately 150,000 m

2, THOLOS area/

CHIOS/ CHIOS

DAAE, RCIEL of the

Northern Aegean

Soil erosion due to unchecked mining and

materials dumping. Illegal operation of vehicle maintenance workshop.

Surface dumping of waste lubricant oils. Illegal temporary storage of

hazardous waste. Illegal discarding of solid waste (barrels, old metal, plastic

packaging, ELVs).

IMMINENT THREAT

Possible degradation of underground aquifer from waste lubricant

oils.

1) The as of 02-05-2012 opinion of the RCIEL of

Northern Aegean for the implementation of preventive and remedial measures. 2)

The as of 21- 06-2012 document of the Secretary General for the

implementation of preventive and remedial measures. 3) The as of 09-

07-2012 document of the RCIEL of the Northern Aegean for clarifications on

the opinion. Law 998/1979

Removal of ELVs, assessing the situation and preparation of a soil

decontamination study, if required. Safeguarding the rights of the state, demarcation of leased land, stopping

or licensing of illegal activities (RCIEL of the Northern Aegean and document from the Secretary

General). Pending update.

Ν.ΑΙΓ./1


HEI. HEI

Municipality of KOS (Illegal construction of a dirt road of

1000 metres in length and with an average width of 6.5 meters, in a state-owned seashore - beach area.

STAKOD 2008: 42.11).

KAMARI, KEFALOS,

Kos Island/ KOS/ KOS

DAAE, RCIEL of the

Northern Aegean

Destruction of the geomorphological structure

of the coastal zone.

Destruction of the

natural bed of the watercourses, with possible consequences such as flooding and

erosion. 27-09-2012 HEI

Expecting notification on the action of

the competent Agencies.

Ν.ΑΙΓ./2 17-07-2012

Complaint by the residents

of Batsi in Andros

Municipality of ANDROS (Dumping of domestic and

other waste. STAKOD 2008: 38.11 & 38.21).

Land area of Batsi Port,

Andros Island/ ANDROS/ ANDROS

DAAE, RCIEL of the Northern Aegean

IMMINENT THREAT due to

uncontrolled waste disposal.

IMMINENT THREAT due to unchecked waste disposal and

possible leakages to the sea.

PENDING (After a partial inspection by the HEI, it was decided that placement under

the Directive was not warranted).

Preventive measures were taken for the protection of the public health

(Decision of the Deputy Head of the Region of 02-08- 2012). Immediate removal of accumulated waste, informing the residents, moving of

bins away from the sea (Marine Environment Protection Directorate).

Refuse collection and

cleaning of the site, on 24-07-2012. Actions for the future licensing, installation and

operation of a baler, as of 27-08-2012.

A decision by the Inspector General for the Environment, according to

Article 13 of P.D. 148/2009, is pending.

from 62



Ref.

Date of occurrence

and/or discovery of damage

Agency or Forwarding Body Activity - Operator

Geographic Location/

Municipality/ Regional Unit Competent Authority Soil Water Species & Habitats


Other legislative framework involved (besides the Directive)

Judicial

Appeals/ Outcome Preventive/remedial Measures


Measures

Completion Date

Measures Implementation Phase and/or Actions Phase

ΚΡ/1

07-12-2011


Unidentified - Various (Illegal interventions in a sensitive ecological area -

embankments, polders, illegal constructions).

Estuary of the Aposelemis River/

CHERSONISOS/ HERAKLION DAC, RCIEL of Crete

Habitat degradation. Area classified as a Wildlife Sanctuary and Protected

Wetland under existing national provisions.

Decisions 1456/2001 &

787/2010 of the Secretary General of the Region of Crete

Restoration of embankments, polders and illegal constructions (DESP of the Region of Crete). Prevention of access by vehicles,

placement of information signs (Heraklion Forest Directorate).

Pending examination by the RCIEL of Crete.

ΚΡ/2


Public Health Directorate and sampling of sewage.

Office of the Secretary General of the Ministry of

Environment, Energy, and Climate Change

Managing authority of the Landfill. STAKOD 2008: 38.21.21 R.U. of RETHYMNON DAC, RCIEL of Crete

Contamination of soil due to

the inadequate coverage of waste and its spreading outside the landfill.

Contamination of surface and

groundwater due to non-compliance with the Environmental

Conditions as regards the management of leachate.

Pending examination by the RCIEL of Crete.

ΚΡ/3


HEI. The interventions were discovered on 22-04-2012. HEI

Private development company (Illegal interventions within the foreshore).

Coastal zone of Kommos/ FAISTOS/ HERAKLION DAC, RCIEL of Crete

Alteration of the physical relief morphology of the coastline (total destruction of geological formations).

Degradation of coastal

ecosystem. Destruction of dunes and natural vegetation. Alterations of

sea turtle breeding habitat. Within the NATURA 2000 network, code No

GR4310004 (SCI): West Asterousia (from Agios Faraggos to Kokkinos Pyrgos).

As of 21-06-2012 opinion of the RCIEL of Crete concerning action. JMD 33318/3028/1998

Investigated by competent bodies (EQCU of Heraklion and HCMR). Forwarding of information to the DESP of Crete is pending.

The competent Agencies are

investigating the appropriate preventive/remedial measures, in order for them to be forwarded to the DESP of Crete.

from 62

Legislative regulations listed in Tables 1 and 2 of Annex

II

1. JMD 13588/725/2006 “Measures for conditions and restrictions on the management of hazardous waste in

compliance with the provisions of Council Directive 91/689/EEC of 12 December 1991 on hazardous waste.

Replacement of Joint Ministerial Decision 19396/1546/1997 ‘Measures and conditions for the management

of hazardous waste’ (B'604)”, Government Gazette, Series II, No 383/2006.

2. JMD A5/2280/1983 "Protection of water used for irrigation of the Capital area from contamination and

infection," Government Gazette, Series II, No 720/1983.

3. Ministerial Decision Δ7/Α/off.12050/2223/2011 "Mining and Quarry Works Regulation”, Government Gazette,

Series II, No 1227/2011.

4. JMD 39624/2209/Ε103/2009, “Measures for conditions and restrictions on the management of waste from

extractive industries, in compliance with the provisions of Directive 2006/21/EC of 15 March 2006 on the

management of waste from extractive industries and amending Council Directive 2004/35/EC of 15 March

2006” (Government Gazette, Series II, No 2076/2009).

5. JMD Φ/Α.5.33/15088/945/2012 ”Approval for the development of the Type A Mantoudi Business Park

(MANTOUDI BUSINESS PARK) at Fourni location of Mantoudi, Municipality of Mantoudi - Limni - Ag. Anna

of the Region of Evia”, Government Gazette, Series II, No 3540/2012.

6. Law 998/1979 "Protection of forests and wooded areas in general", Government Gazette, Series I, No

289/1979.

7. JMD 33318/3028/1998 “Determination of measures and procedures for preserving natural ecotypes

(habitats) as well as the wild fauna and flora”, Government Gazette, Series II, No 1289Β/1998. Compliance

with the provisions of Council Directive 92/43/EEC of 21 May 1992 , "For the conservation of natural habitats

and of wild fauna and flora", and Council Directive 97/62/EC of 27 October 1997 "for adapting to scientific

and technical progress Directive 92/43/EEC ... etc. ".

8. P.D. 906/1999 "Characterisation of terrestrial and marine areas of Laganas Bay and the Strofades islands as

a National Marine Park and characterisation as a peripheral zone of the National Marine Park of the land

area of the municipality of Zakynthos (former municipality of Zakynthos and communities of Vassilikos,

Ambelokipi and Argassi) and the municipality of Laganas (former communities of Kalamaki, Mouzaki, Keri,

Pantokratoras and Lithakias), Prefecture of Zakynthos », Government Gazette, Series IV, No 906/1999.

9. JMD Η.Π. 37338/1807/Ε.103/2010 “Determination of measures and procedures for preserving wild avifauna

and its ecotypes/ habitats, in compliance with the provisions of Council Directive 79/409/EEC of 2 April 1979,

on the conservation of wild birds, as codified by Directive 2009/147/EC”, Government Gazette, Series II, No

1495/2010.

10. JMD 33999/2010 "Determination of uses, conditions and building restrictions for the protection of land and

water areas of the Municipalities of Northern Kynoyria, Leonidion, Skiritida and Apollonas of the Prefecture of

Arkadia; of the Municipalities of Therapnes, Oinounta and Geronthri of the Prefecture of Lakonia; and of the

communities of Kosmas (Prefecture of Arkadia) and Karyes (Prefecture of Lakonia) of the Mount Parnonas -

Moustos Wetland region”, Government Gazette, Series I, No 353ΑΠ/2010.

11. Decision 1456/2001 of the Secretary General of the Region of Crete "Establishment of a permanent Wildlife

Sanctuary at the Aposelemis area of the Chersonisos Municipality, Prefecture of Heraklion, Region of Crete”,

Government Gazette, Series II, No 754/2001.

12. Decision 787/2010 of the Secretary General of the Region of Crete “Approval of the Open City Spatial and

Residential Organisation Plan of the Municipality of Gouves, Prefecture of Heraklion”, Government Gazette,

Series I, No 60ΑΠ/2010.