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The Green Tank

The Green Tank is an independent, non-profit think tank, which aims to present well-documented recommendations and to advance policy solutions for a sustainable future.

Lobbying Activity

Response to Revision of the EU’s energy security framework

10 Oct 2025

The Green Tank welcomes the Commission's initiative to revise the EU Energy Security Framework. The revision comes at a critical moment. Following the 2022 energy crisis, the EU advanced key initiatives such as REPowerEU, the Gas Demand Reduction Regulation, and higher renewable energy ambitions under the revised Renewable Energy Directive under Fit for 55 package. These steps aimed to enhance energy security and reduce gas dependency. Yet, Europe's energy system remains heavily reliant on fossil fuels. As the EU moves toward climate neutrality, energy security must be redefined around renewables, electrification, efficiency, clean flexibility, new clean carriers such as green hydrogen and citizen participation. Energy security & transition from fossil fuels to renewables The revision must provide safeguards to end the fossil fuel era which has led to insecurity and price volatility. New LNG and gas infrastructure should be limited and carefully managed, to avoid becoming stranded assets. Member States should be required to adopt fossil fuel phase-out plans with specific end dates; so far only coal phase out dates exist to the majority of MS. A binding methane reduction target of at least 75% by 2030 for the energy sector should be set. Security of supply must be built on diversified renewable energy sources, combined with wider electrification, energy efficiency, storage, and demand-side management to ensure grid stability and affordability. Green hydrogen should play a key role, in decarbonizing hard-to-abate sectors - industry and transport. The framework should integrate existing policies such as ETS2 which promote electrification through e-mobility and replacement of gas boilers with electricity-based heating (e.g. PV and heat pumps). It should prioritize cross-border interconnections to enable higher renewable penetration and faster electricity decarbonization. Digitalization must be supported to enhance clean flexibility such as storage and demand response, while safeguarding cybersecurity and ensuring social inclusion in the digital energy landscape. Distributed RES and Citizens participation Energy communities, energy sharing, and self-consumption must be explicitly supported, as they enhance local resilience and empower citizens to participate directly in the clean energy transition, while contributing to demand-side flexibility. In Greece, citizen engagement is already evident, with self-consumption projects reaching 1 GW of capacity. The revised framework should build on the Citizens Energy Package to remove financial, regulatory, and technical barriers, enabling fair and widespread participation in the transition. Governance, regulation, financing Besides ensuring consistency with climate neutrality, transparency, monitoring, must be central principles. Streamlining should enhance efficiency without leading to deregulation. Financing mechanisms must prioritize consumer protection and align with climate objectives. Fossil fuels should no longer receive support through instruments such as capacity remuneration schemes. Where such schemes are considered, as in Greece, they should explicitly incentivize non-fossil flexibility solutions and safeguard consumers from price volatility. Feedback on policy options Smart streamlining: Simplification can accelerate implementation but must not weaken environmental safeguards, transparency, or monitoring obligations. Targeted reinforcement: Crisis-specific provisions and EU alert levels are welcome but should explicitly support decarbonization, efficiency, and electrification. Cross-sectoral transformation: Integrating renewables, electricity, interconnections, storage, and demand-side management enables a holistic, EU-wide energy security strategy and should be the frameworks core. EU-driven action: Centralized governance improves coordination, but excessive centralization can hinder citizen participation, local energy projects, and small-scale flexibility solutions
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Response to Roadmap towards Nature Credits

30 Sept 2025

The ARTEMIS Interreg Euro-MED project (https://artemis.interreg-euro-med.eu/) - developing Payment for Ecosystem Services (PES) schemes based on seagrass biodiversity and blue carbon - partnership welcomes the initiative. We recognize its timeliness and potential to mobilize private investment to fill the current nature financing gap, provided it builds on integrity, scientific credibility, and sound governance. Importantly, the European Commission (EC) must ensure that the introduction of nature credits will mobilize additional resources and not substitute public funds, which shall remain central to nature financing. Several interconnected points should be considered: 1. Governance Clear governance must be outlined to ensure ecological and market integrity, taking international best practices into account. The EC must ensure across the EU: uniform standards, definitions - including claim codes - and transparent oversight institutions and processes to avoid greenwashing, double counting, and perverse incentives. Integration of nature credits and other market-based instruments into nature planning documents at MS-level (PAFs Art. 8, Habitats Directive and NRPs Art. 15, NRR), alignment with voluntary and private disclosure and reporting frameworks (CSRD, TNFD) and activity classification systems (EU Taxonomy) is essential. Τhe EC and the expert group (EG) must consider a proposal for an EU legislative framework for the 2027 period to ensure a fair playing field, in line with the internal market& environmental EU acquis. Consider lessons from the EU-ETS, especially on price triggers and potential reinvestment of revenues into conservation & restoration. 2. Integrity The roadmap must address pitfalls of voluntary carbon markets through strict additionality, robust metrics, independent third-party verification and baselines. Failure risks undermining ecological outcomes, credibility, and market trust. The roadmap lacks clarity on the use utility for nature credits, which should be aligned to EU Environmental acquis (i.e. prioritising net gain). Use must guide market analysis, monitoring, and further development. 3. Scientific credibility There will not be a one-size-fits-all solution: ecosystem heterogeneity across geographies & local settings must be captured. Conservation and restoration timescales must be respected to avoid short-term accounting and pressures to issue credits at scale, underestimating long-term ecological needs. 4. Pilots The roadmap should clarify what is meant by a pilot project. We suggest coordinated calls under existing RDI programmes (e.g. HE, LIFE, Interreg) covering priority marine areas and co-designed with local communities to ensure legitimacy. The roadmap must include large-scale financial solutions to reduce operational risk and liquidity issues in early project stages. ARTEMIS highlights the need for initial seed funding to support project development. 5. Marine and coastal ecosystems Marine and coastal ecosystems remain underrepresented. Explicit inclusion is needed for seagrass, kelp, saltmarshes, reefs, and other blue carbon habitats. We support: ecosystem-specific standards (e.g. measuring biodiversity uplifts) and practices (e.g. regional restoration guides); an EU registry with marine-specific tags and data layers; marine-specific methodologies (e.g., acoustic biodiversity indices, satellite mapping); guarding against crediting business-as-usual protected areas unless enhanced activities are demonstrated; respecting tenure rights and including local knowledge; addressing risks of leakage and permanence. ARTEMIS stands ready to contribute knowledge to ensure Europes nature credit system delivers real, measurable, and equitable biodiversity gains. Our PES cookbook for seagrass, pilot schemes in three countries, and policy recommendations offer insights on valuing and financing ecosystem services.
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Response to Citizens energy package – protecting and empowering consumers in the just transition

9 Sept 2025

The Green Tank welcomes the committee's initiative to introduce the Citizens Energy Package. The EU must systematically integrate just transition principles into its policy frameworks, ensuring that social fairness, citizen participation, and consumer protection are not treated as add-ons but as core dimensions of the Green Deal and related strategies. In this regard, the continuation of the Just Transition Mechanism in the next EU budget (2028 to 2034) for coal regions is of paramount importance. Moreover, the introduction of the new ETS2 system in 2027 for buildings and road transport should be seen not only as a tool to accelerate the phase-out of fossil fuels, but also as an opportunity to place social justice at the heart of the energy transition. Given the high levels of energy poverty across Member States, the EU should also consider extending the Social Climate Fund beyond 2032, thereby ensuring sufficient funding for long-term decarbonization measures that will protect citizens. At the national level, Member States must guarantee that all revenues from ETS2, as well as eligible funds from ETS1, are effectively directed towards citizens in support of clean, long-term solutions that phase out fossil fuels. This approach is particularly critical for Greece, which remains highly exposed in both energy and transport vulnerability affecting 26.5% and 13.9% of households, respectively. The estimated funds of up to 15.5 billion EUR from all sources (SCF, ETS1 & ETS2) could not only reduce vulnerability but also make a decisive contribution to achieving climate goals in the building and road transport sectors. The urgency of phasing out fossil fuels has been widely recognized not only by scientists, governments, civil society organizations, and climate activists, but also by citizens themselves. In Greece, the energy crisis has further mobilized citizens, who are increasingly investing in self-consumption projects, either individually or through energy communities. These projects are now approaching the milestone of 1 GW, highlighting citizens active role in the transition. However, persistent technical, financial, and regulatory barriers hinder further expansion. Removing these obstacles and setting ambitious national targets for self-consumption should therefore be a top priority. Equally important for ensuring energy democracy is fostering community engagement and fair benefit sharing from renewable energy projects. Such practices are essential to building public acceptance and trust. This requires the involvement of local communities from the earliest planning stages, as well as continuous open dialogue among all stakeholders. Local and regional authorities, in particular, can play a pivotal role in facilitating this process and ensuring inclusive governance. Consumer protection must also remain a core EU priority. Simplified and harmonized billing, strict enforcement against unfair practices, and robust safeguards for vulnerable groups are critical. At the same time, awareness campaigns, education initiatives, and local advisory services can further strengthen trust and citizen engagement. Digital tools, such as Greece's tariff comparison platform, enhance transparency, but they must be user-friendly, provide up-to-date and comprehensive information, and be complemented by offline support to ensure accessibility for all. Finally, promoting demand flexibility is vital to making consumers active participants in the transition. Flexible supply contracts, such as time-of-use or hybrid tariffs, can align consumption with system needs, reduce costs, and improve grid stability. Overall, the Citizens Energy Package should prioritize fairness, participation, and consumer protection as core pillars of the EUs energy transition. By channeling revenues into long-term solutions, dismantling barriers to citizen and community engagement, and reinforcing strong safeguards for vulnerable, it can ensure that no one is left behind.
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Response to EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

8 Jul 2025

The Green Tank supports strengthening the EU ETS and MSR to better drive a socially just clean energy transition. The EU ETS has already cut emissions from the power and industrial sectors by 51.2% since 2005, moving toward the -62% target for 2030. The MSR has played a key role by invalidating 3.15 billion allowances, boosting carbon prices and driving emission cuts in the power sector, which hasnt received free allowances since 2013. These elements have added value to the ETS and should be maintained or reinforced. However, free EUA allocations have slowed emission cuts in industrial sectors, while aviation emissions continue to rise. These weaknesses must be addressed. Free allowances for industrial sectors should be phased out, with CBAM expanded to drive decarbonization investments and increase resources for the Innovation Fund. Indirect cost compensation should also be phased out, while including indirect emissions in CBAM to protect industrial competitiveness. The MSR should be strengthened by keeping the 24% intake rate post-2030 and lowering the threshold range, as emission reductions in the power sector have altered hedging demand. In aviation, the current EU ETS scope covers less than 10% of the sectors full climate impact, excluding international flights and non-CO2 effects. The EU should phase out remaining free allowances and extend coverage to all departing flights, with the aim of covering all flights to and from the EU. Public funding for unsustainable fuels should end, with a focus on efuels. Exemptions for outermost region flights should be removed, increasing the available SAF allowance volume, funded by revenues from free allowance phaseouts. All private jets should face a carbon price multiplier. The European Commission must improve scrutiny on how ETS funds affect the carbon footprint, especially where funds indirectly subsidize fossil fuel use under the guise of social support. Member States should publish ETS revenue use reports and introduce clawback clauses for projects that dont align with ETS principles. The Modernization Fund should extend beyond the 4th ETS phase to bridge intra-EU energy gaps, with a far more transparent project selection process at EU and national levels. Fossil fuel projects should be made ineligible, and priority projects more clearly defined. The Innovation Fund remains vital for industrial decarbonization but should not fund projects that deter emission reductions at the source. Big CCS projects must be paired with maximum emission cuts through fossil fuel substitution and electrification. The Commission should disclose expected and achieved reductions for each project and enforce clawbacks if targets arent met on time. The Green Tank supports extending ETS1 in line with the Polluter Pays Principle by including: a) municipal waste incineration and other waste management processes, b) additional maritime emissions from smaller (4005000 GT) and offshore ships, c) international aviation emissions, and d) smaller thermal power units. Conversely, The Green Tank opposes integrating Carbon Dioxide Removal (CDR) into the ETS, given serious mitigation deterrence risks. Separate EU policies are needed to prevent removals substituting for emissions cuts. Alternatives include channeling ETS revenues to CDR projects without allowing units into the ETS, creating a distinct Removal Trading Scheme targeting major polluters and wealthier sectors (like fossil fuel producers and tech companies), and introducing national CDR targets.
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Response to Modernisation Fund - first evaluation of the operating rules

23 May 2025

We, at the Green Tank appreciate the opportunity to contribute to the improvement of the Modernisation Funds implementation. We were engaged in advocacy efforts regarding this instrument in the previous two revisions of the EU ETS directive and we consider the MF as a crucial funding mechanism for the modernization of the energy systems in lower-income member states.
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Response to Uniform format for national restoration plans

7 Feb 2025

This submission is made by The Green Tank on behalf of the Interreg Euro-MED ARTEMIS project, which aims at Accelerating the Restoration of Seagrass Meadows in the Mediterranean area through Innovative ecosystem-service based Solutions. You can find additional information on the projects website: https://artemis.interreg-euro-med.eu/. This submission expresses the majority of the partners, and the comments are by no means binding for all collaborating parties. The proposed uniform format draft is a step in the right direction in order to ensure timely, consistent and effective implementation of the Nature Restoration Law. The ARTEMIS project with its planned deliverables can support the Member States and the European Commission, by providing methodological support and updated information for the identification of the areas, measures, institutional and financial mechanisms that will support the restoration of Posidonia oceanica in the Mediterranean, as a top priority by 2030 and beyond. As such, we provide feedback on selected sections of the proposed uniform format. Please find attached the feedback of the Interreg Euro-MED ARTEMIS project.
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Response to Environmental Implementation Review 2025

5 Jul 2024

The Green Tank is an independent think tank aiming to develop policy solutions for a sustainable future. We monitor and research scientific, political and legal developments and build our work on facts and data analysis. Being based in Athens, Greece, we participate in this Call for Evidence, providing insights and documentation relevant to the implementation of EU environmental law in Greece, which can complement information that the European Commission already gathers. Based on the structure of Greeces Country Report of the 2022 Environmental Implementation Review, our contribution relates to the following thematic areas: - Biodiversity and Natural Capital - Climate Action - Environmental Governance Please see the document attached.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and Sandbag Climate Campaign CIC

18 Jan 2023 · RePowerEU implementation

Response to Regulation on REPowerEU chapters

20 Jul 2022

Funding of the REPowerEU plan by auctioning allowances from the MSR worth 20 billion (articles 4 and 5), is a really dangerous measure which must be avoided. A few months back the European Commission rightfully refused to allow Member States to bring forward their share of allowances and auction them in order to tackle the energy price crisis because that would undermine the carbon price, and now it proposes a far more damaging measure. First, it will decrease the carbon prices, thus reducing the efficiency of the EUETS, which has undoubtedly been EU’s most effective climate policy tool since the rise in the carbon prices in the second half of 2018. Especially since this measure will send a message to all carbon market participants that the EU will interfere with the market whenever it is arbitrarily decided that extra funds are necessary or the carbon price is too high. This will in turn threaten a more structural come-back of coal and lignite across Europe, thus, jeopardizing EU’s 2030 climate targets (both EU ETS and overall). Second, as analysis by Sandbag shows, it is highly possible that the extra allowances auctioned will not return back to the MSR by the end of the 4th EUETS phase, thus risking extra emissions to the atmosphere and further undermining the achievement of the EU climate targets. Overall, considering the relatively low amount of money that will be gathered and the potential damage caused by this measure, it becomes clear that alternative funding sources should be pursued. In case funding from the EU ETS is the instrument of choice, then one way of gathering 20 billion would be through a speedier phase out of free emission allowances which are currently being offered to the energy intensive industry in excessive quantities, and are to a large extent responsible for the fact that industrial emissions remain high. If a forward bearing phase out trajectory of free emission allowances is chosen, the extra funds collected from the auctioning of these allowances, could be used to fund the REPowerEU plan, without risking destabilizing the carbon market or releasing more greenhouse gases to the atmosphere. An additional benefit of such a measure would be the creation of incentives to decarbonize industrial processes and the utilization of a much larger Innovation Fund (or Climate Investment Fund) for this purpose. Another very dangerous aspect of the proposed chapters of the Regulation on REPowerEU in Recovery and Resilience Plans is the waiving of the Do No Significant Harm (DNSH) principle for investments “contributing to security of supply” (article 21). First of all, such fundamental principles should not be put aside in crises. It is especially in crises that such principles and corresponding objectives should be reinforced, as was the case with the handling of the covid pandemic 2 years ago when the commitment of the EU to climate neutrality and all provisions and goals of the Green Deal were tested and doubted but finally reinforced. Second, there is no proof that security of supply is not feasible without waiving the DNSH principle. In fact, there is the analysis of four think tanks (Ember, RAP, E3G, Bellona) which shows that it is possible to eliminate the dependence on Russian fossil gas faster than the REPowerEU plan through a speedier and larger-scale deployment of renewables, and heat pumps, a reduced amount of gas from other sources and without any new fossil gas infrastructure. Third, the DNSH principle is the only “shield” in the RRPs preventing investments in fossil fuels, including coal. Waiving it, especially in conjunction with a reduction in carbon prices caused by the auctioning of MSR allowances, might create incentives for prolonging the lifetime of coal plants across Europe further, with devastating effects for the climate.
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Meeting with Petros Kokkalis (Member of the European Parliament)

7 Feb 2022 · Carbon Border Adjustment Mechanism

Response to Social and labour aspects of the climate transition

19 Nov 2021

The Green Tank welcomes the European Commission’s initiative to address social and labour aspects of the just transition towards climate neutrality, and provide guidance to EU Member States on how best to confront the social and labour challenges towards the green transition. Supporting community energy schemes, such as public benefit and non-for-profit energy communities, that aim to cover the energy needs of local communities, should be of high priority towards climate neutrality. Financial support of these schemes should be an essential component of a comprehensive policy package since it would definitely promote the inclusive participation of social partners and would constitute optimal use of public and private funding, including the new Social Climate Fund and cohesion policy funds, and instruments at all levels, to ensure complementarity and coherence.
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