17 64. The Government disputes the MFHR's interpretation of what constitutes best available techniques for reducing SO2 emissions. Whereas the MFHR argues that gas desulphurisation systems should be introduced into every power plant, the Government maintains that such systems, which themselves give rise to CO2 emissions, are only required in sites where SO2 emissions need to be reduced. This does not apply to the power stations in northern Greece, which burn lignite, with its very low sulphur content. As a result, the high alkaline (CaO) ash content means that natural desulphurisation is sufficient. The Government considers that the approach it has adopted is fully consistent with the principle of integrated pollution prevention and reduction and the document BREF LCP. 65. According to the Government, all the DEH installations are equipped with the best available techniques for reducing NOx emissions, bearing in mind the low combustion temperatures and the high humidity levels of the flue gases, namely low excess air, air staging and flue gas recirculation. 66. It states that there are no specific techniques for reducing PM10, the only one mentioned in BREF LCP being the use of electrostatic precipitators to filter particulates in general. 67. Finally, the Government states that as part of the IPPC authorisation procedure, the DEH is required to submit technical reports to the competent authority on the best available techniques being used or to be used in the plants concerned. The introduction of such best available techniques to DEH installations is subject to detailed inspections. When environmental criteria are being approved, these also include requirements to introduce best available techniques, implementation of which is then monitored by the competent administrative authorities. The Government therefore denies that Articles 10 and 11 of the IPPC directive have not been fully transposed into domestic law. More specifically, it states that Article 10 has been transposed by joint ministerial decree 11014/703Φ104, implementing Act 2010/2002, and Article 11 by joint ministerial decree 29457/1511, which makes no reference to best available techniques because it transposes Directive 2001/80. The effectiveness of environmental standards: 68. The Government maintains that compliance with environmental standards is monitored by the environmental inspectorate and by close scrutiny of the DEH annual reports, including its efforts to bring its plants into line with “best available techniques”. It states that irrespective of which body imposes them, the level of penalties always reflects the circumstances of each particular case and must be compatible with the constitutional principle of proportionality. 69. If any follow-up action is required in response to action taken by persons living in the vicinity of mines and power stations, this must be in accordance with statutory procedures and initiated by the local prefecture, which will take whatever steps are necessary, including the ordering of penalties against the DEH. For example, with reference to the request by the Megalopolis citizens' movement to the Arkadia prefecture in 2004, the Government states that in addition to the inspection visit to the mine and the resulting penalties that were imposed, a wet gas desulphurisation system is currently under construction (see the table above).