8
25.
With regard to the reduction of particle emissions, the MFHR complains that
very old and inefficient electrostatic precipitators still operate in three of the four units
of the Aghios Dimitrios plant, even though they are unable to withhold the most
dangerous particles produced in the course of lignite combustion. It also argues that
the technologies used are an inefficient way of reducing particle emissions because
electrostatic precipitators are not used in combination with flue-gas desulphurisation,
as recommended under the ‘best available technology’ requirements.
26.
Similarly, in connection with SO2 abatement, the MFHR maintains that the
DEH relies almost exclusively on natural desulphurisation and has not installed fluegas desulphurisation systems in the majority of its units, whereas according to the
‘best available technology’ standards natural desulphurisation is not enough to abate
SO2 and can also contribute to the emission of higher levels of particulate matter
27.
The MFHR maintains that in any case there is nothing in domestic law to
ensure that developments in the ‘best available techniques’ and their application in
practice are properly monitored, pursuant to article 10 of Directive 96/61/EC
concerning integrated pollution prevention and control (the IPPC directive), and that
the latter has therefore not been fully transposed.
28.
Finally, the MFHR criticises Greece for being the only European country to
have secured the right to increase its SO2 emissions under Directive 2001/81/EC of
the European Parliament and of the Council of 23 October 2001 on national emission
ceilings for certain atmospheric pollutants. It also criticises the use of the national
necessity argument to authorise violations of limit values under Directive 2001/80/EC
of the European Parliament and of the Council of 23 October 2001 on the limitation of
emissions of certain pollutants into the air from large combustion plants.
The monitoring of environmental standards
29.
The MFHR argues that the environmental inspectorate is inadequately
financed, equipped and staffed. For example, although Presidential Decree 165/2003
creates 78 posts for the environmental inspectorate, there are only 28 in the general
section and southern Greece and 4 in northern Greece.
30.
It also alleges that the fines imposed are not sufficiently disuasive to persuade
violators to change their conduct. It cites several examples of the financial penalties
imposed on the DEH by the Kozani prefecture because the Aghios Dimitrios plant
had exceeded emission limit values, with fines ranging from € 5 000 in May 2003 to
€ 60 000 in January 2001, the latter being the maximum on the scale of fines. It
argued that these sums were manifestly inadequate when compared with the DEH's
annual earnings (€ 4.1 billion in 2004).
31.
It criticises the authorities' near or total failure to respond to requests for action
from persons living in the vicinity of mines or power stations. It cites a 2004 request
to the Arkadia prefecture from a local citizen’s movement in Megalopolis to
investigate the monitoring of pollution levels, the maintenance and replacement of
equipment, the follow-up to the inspectorate's finding that damage had been caused
to archaeological sites, access to information on air pollution values and
measurements of pollution levels, etc. The result was a visit from the mines
inspectorate and a fine of € 10 000 for minor infringements in the organisation of the
activities of certain work teams.