Strategic Study of the Environmental Impact of Mines: Cut and Sewn to PPC’s Size

As is known, the area of the West of Macedonia has entered into a process of transformation of its social and economic model, due to the necessary weaning of the country from lignite.

From the first day of the post-lignite transition, the restoration and utilization of the lands expropriated by PPC for the extraction of lignite emerged as a critical and pivotal issue. At the same time, the sloppiness of the government’s planning in this area, the submission to the whims of PPC, but also the serious policy deficit of the local government was revealed.

The last and shocking proof is the Strategic Environmental Impact Assessment (EIA) of the Special Town Planning Plan of the Apolignitization Zone (Z.A.P.) of the Ptolemaida Mines. The consultation file includes the Special Town Planning Plan, which briefly describes the uses of the lands of the former Mines and the conditions for their utilization.

Categories of uses. The final configuration is as follows:

A first observation is that the percentage of agricultural activities (31%) is fictitious. In practice it is quite a bit smaller, since 1) much of the agricultural uses are OUTSIDE the expropriation zone in the Akrin area and 2) another part of them appears to be near the mines, with possible low productivity for crops.

A second observation is that much of the uses have already been decided:

We are invited to give an opinion on the SMBE, but we are faced with fait accompli, since the PPC has already decided unilaterally for the use of a large part of the Apolignitization Zones. In particular, PPC has taken the lion’s share of the so-called “fillets” (restored flat areas, immediately usable) in order to install large photovoltaic plants. We have spoken negatively about this issue in the past. SPME unfortunately validates this unfair distribution and the new “monoculture”

We consider PPC’s investment pursuit to install PV in areas of its former mines to be reasonable. But this planning cannot be one-dimensional and ignore the needs of the local community, which are complex (agriculture, green entrepreneurship, energy communities, natural environment, etc.). This is also the international practice, where the investment goals of the mining company and the development priorities of the region should coexist harmoniously.

How many lands are granted and to whom is the Restoration Cost “charged”.

Evaluating the overall planning, the question arises whether in the end “the polluter really pays” or if the costs are burdened in an oblique way on the citizens and society. From the study of all the data, the following concerns arise:

According to the program contract between the Hellenic State – PPC and “Metavasis S.A.”, PPC will grant a total of 000 acres of land which are part of the Apolinitization Zones of Kozani, Florina and Megalopolis. These lands, as assets, have been valued at €162 million.

From the total of ~149,000 sq. of Z.A.P. Ptolemaida, the 42,615 square meters will remain with PPC for the installation of PV Parks, while the 50,920 square meters will be allocated to “Metavasi SA”. But what about the lands within the ZAP Ptolemaida, which are not included in the Planning Agreement and are estimated at approximately 54,036 sq.?? Their future is not specified anywhere. Apparently some of these are active mines. The obvious question is what is the timetable and institutional framework for the restoration and transfer of the above lands and where will the necessary resources come from.

According to the M.P.E. of Mines the schedule for land reclamation and availability should be completed by August 2025. Given that only 1 year and 4 months remain until then, the question arises as to whether this schedule will be met and whether the obvious need to update the schedule affects funding from the Recovery and Resilience Fund (Resilience Fund). As mentioned in the EIA of the Ptolemaidas mines, all the restorations extend well beyond 2026, so the timetables for all the restorations, as well as the funding sources, should be clarified and documented.
It is worth noting that the funding of the Recovery and Resilience Fund concerns exclusively in RESTORATION (plus equipment decommissioning costs). But PPC has the obligation to carry out the restoration at its own expense, given that it is “the polluter”. Despite this, a brave “dowry” is given to PPC from the Recovery Fund, while this endowment should finance the transition of the local community to a sustainable future. The cost of the restoration, according to the Environmental Conditions for the entire project, is estimated at 148 million € (~120 without VAT). However, it is not specified, as Green Tank rightly points out[1], if part of the resources of the T.A.A. will be attributed to PPC for the works of the already restored lands granted to “Metavasi SA”.

Therefore, the question whether PPC SA remains unanswered. as the culprit of the environmental burden will bear the cost of restoration and how much .

So far, no study has been presented that documents the value of the areas of the Apolignitization Zones, nor any study on the type and quality of their restoration.

Absence of overarching planning (Regional Spatial Plan)

Although we are in the finalization phase of the Urban Planning of the ZAPs in Ptolemaida, Amyntaio and Megalopolis, however, there is no updated Spatial Plan West. Macedonia. This is another paradox, causing important questions about the continuity that should exist in the integrated spatial planning of the West region. of Macedonia without being created first.

Consultation – Participatory Planning:

Consultation on planning the Just Development Transition continues to be deficient.

While we have passed the 5^The year since the de-lignitization was announced and now we are discussing the SMPE, there has been no substantive consultation on the Special Town Planning Studies of the Z.AP., although these are a very important tool for the utilization of the restored (and not) of lands.

Although the spatial planning for the Z.AP. of the mines is almost complete, local bodies and citizens have not been able to participate effectively.

We have pointed out many times that the transition process “goes hand in hand” with him PARTICIPATORY design. But even at this stage this logic was ignored.

Photovoltaics for Energy Communities

We believe that the zoning should be foreseen within the ZAPs, with the simultaneous construction of the necessary infrastructure, Self-production projects by Energy Communities of citizens and organizations of the region that will have a clear social character.

Water Resources Management

Although the issue of rational water management and the restoration of degraded aquifers has been repeatedly raised, the SEA is not accompanied by corresponding hydrogeological and supporting studies.

Problems and observations on the issue of water resource management have also been submitted by DEFAK in the context of the consultation on the EIA of the Ptolemais mines, the Green Tank and also experienced Mineralogists, in their own observations.

Epilogue

Although the Strategic Environmental Impact Study (SEIA) of the Mines is one of the most serious issues in the region, the relative public debate is nevertheless poor. There are, of course, exceptions to the serious approaches of the SMBE, such as that of the Green Tank, but also the observations of experienced PPC executives on geotechnical problems of restoration and on the commitment of excessive areas of the LKDM for PV.

The Municipality of Kozani, in the proposal communicated to us ahead of the Municipal Council meeting, appears to be content with objections of a legal and procedural nature. It is limited to the inconsistencies of spatial planning, without touching the essence and the political dimension of the matter, such as, for example, that PPC is largely exempted from the cost of restoration, that it acquires the land-fillets preferentially, and – with a word of mouth – that SPME is cut and sewn according to PPC’s measurements.