Greek Hydropower Production and The European Union (EU) Water Framework Directive: Potentially Conflicting Interests and Sustainable Governance of River Basins

: Hydropower-based electricity production provides approximately 23% of renewable energy in Greece - an activity, however, associated with adverse environmental effects on watercourses. Therefore, it should be considered as a key factor of water management programs ensuring safety and optimising environmental performance of hydropower facilities in accordance to Greece’s obligations towards European Union (EU) water policy. W ater Framework Directive (WFD) was created by the EU in order to help member states to protect and improve the status of water bodies and was incorporated in Greek legislation by Law 3199/2003 . Within the scope of this study, we assessed 1. both Hydroelectric power generation and Water Resources Management in Greece and we recorded the 2. current status of the EU Water Framework Directive implementation in this field. Given that social-ecological systems emphasise the link between people and the ecosphere, we investigated possible 3. conflicts that arise between hydropower-related renewable electricity production and water courses conservation, according to both national and EU legislation. 4. We also studied the tools that WFD provides in order to solve potential problems, maintain economic viability and ensure good ecological status between hydropower utilisation and water protection in the face of increased demands to a more effective and sustainable management of environmental resources.


Introduction
Climate change is already affecting water availability. According to the European Environmental Bureau' s (EEA) report, "Northern Europe has generally become wetter in recent decades (up to 70mm per decade), whereas southern Europe has generally become drier (up to 90mm per decade). "Decreasing river flows are projected for southern European countries (particularly Cyprus, Greece, Italy, Malta, Portugal, Spain and Turkey) and increasing flows for northern European countries." As the EEA points out, these changes will impact hydropower production and challenge hydropower storage capacities with the risk of power outages [1].
Today hydropower plants are contributing towards European Union (EU) energy targets for 2020-2030 playing a key role in Renewable Energy Directive implementation and CO2 emissions reduction as they do not pollute the air like power plants. However, they have many negative effects on biodiversity, river flows and aquatic communities as they cause changes in river morphology and riverine habitats.
Water Framework Directive (WFD) is the key point of the institutional framework of the third phase of European's Union water resources management and its purpose is to establish a framework for the protection of inland surface waters, transitional waters, coastal waters, and groundwater (Article 1). This provision indicates the intention of the EU to establish an integrated management policy for all water resources in relation to the previous directives dealing with the issue fragmentally and individually [2]. It also promotes sustainable water use based on protection of available water resources, ensures the progressive reduction of pollution of groundwater, and prevents its further pollution and aims at enhanced protection and improvement of the aquatic environment, inter alia. This means that WFD sets environmental objectives considering economic development as well as social effects and geographic and climatic conditions. The use of water to generate power goes back centuries, with water wheels being used since the times of ancient Greece. Urban water management in ancient Greece resulted in many constructions and during oligarchic periods the emphasis was on the construction of large-scale hydraulic projects. In Greece, the first dam was built in ancient Alyzia (between 1st and 5th century BC) [3][4] which was constructed in distinct stages aiming to reduce the coarse sediments of the Varnakas stream deposited on the cultivated Mytikas plain.
According to the data given from Greek Committee on Large Dams [5] the table below contains the Public Power Center dams that produce hydroelectric energy: Except from these dams there are many other dams that serve irrigation and water supply which were constructed by the Ministry of Agriculture such as dams Apo, Akkias Rhodes (1989), Lefkogion Drama (1994), Doxa Feneou Korinthias (1996) and Livadiou Astypalea (1997).
The objective of this study was to assess both Hydroelectric power generation and Water Resources Management in Greece considering the conflicts that arise between hydropower-related electricity production and water courses conservation. The work was based on data collection and analysis of hydropower in Greece, literature review and analysis of the legislation for watercourses resources both in Greece and the EU?
The paper is structured as follows: The first part describes the methodological approach adopted in the study, the second part presents the results of our data analysis for Greek Hydropower Production, Definitions of the Water Framework Directive and Greek legislation on water resources protection. The third part discusses the challenges to ensure good ecological potential and faces the conflicts between hydropower utilisation and water protection.

Materials and Methods
Available data on Greek Hydropower Production, Definitions of the Water Framework Directive, Greek legislation on water resources protection and designation of heavily modified water bodies, were analysed to synthesize the current knowledge and resolve conflicts between water use for energy production and conservation of vulnerable water resources. The analysis was based on literature review and the study of the Greek legislation on Water Resources Protection.
The approach that we developed is organised in three steps: 1) Hydroelectric power generation in Greece (Section 3.1) 2) definitions of hydropower utilisation and water protection at WFD 2000/60 (Section 3.2); 3) designation of heavily modified water bodies within the context of WFD implementation in Greece (Section 3.3).

Hydropower today
Hydropower-based electricity production provides approximately 23% of renewable energy in Greece (2019)-an activity, however, associated with adverse environmental effects on watercourses. Renewable energy sources include wind, hydroelectric, solar, biofuels and waste.  Hydroelectric-powered energy share remains steady while wind and solar energy production show an increasing trend. The most interesting statistic in Hydroelectric-powered energy is the contribution of hydroelectric installed capacity for 2019 in Greece, which accounts towards 8.4% of the total installed capacity in Greece that amounted to 48,742 GWh. More specifically, the energy supply share consisted of coal/lignite (10,805 GWh), oil (4,471GWh), natural gas (16,303GWh), hydroelectric power (4,059 GWh) , wind energy (7,278 GWh), biofuels (1,579 GWh), waste incineration(0.29GWh) and photovoltaic / solar PV (3,961GWh).
According to the data given at Figure 2 the percentage of installed power of hydroelectric energy, among renewable energy sources amounts to 27% in Greece for 2019.

The Water Framework Directive 2000/60: hydropower utilisation and water protection
The Community's institutional framework of water resources management and protection was developed in three phases. The Water Framework Directive 2000/60 is the main tool of the third phase as it incorporates a more coherent policy and explicitly determines for the first time, the scope of the new legal framework for protection of surface, transitional, coastal and groundwater (Article 1).
[6] The main environmental objectives of the Directive are in particular to achieve "good ecological and good chemical status" for surface water bodies in general and "Good ecological potential" as the status of a heavily modified or an artificial body of water by 2015. The WFD also requires the reduction and ultimate elimination of priority hazardous substances and the reduction of priority substances to below set quality standards.
According to No 23 of Article 2: "Heavily modified water body, means a body of surface water which as a result of physical alterations by human activity is substantially changed in character, as designated by the Member State in accordance with the provisions of Annex II." and member States may designate a body of surface water as artificial or heavily modified, when (Article 4 paragraph 3) : (a) the changes to the hydromorphological characteristics of that body which would be necessary for achieving good ecological status would have significant adverse effects on: ii)……………………………………………………………………………….
(iii) activities for the purposes of which water is stored, such as drinking-water supply, power generation or irrigation".
According to Article 4.7 of the WFD, exemptions can be approved by the authorities for new modifications and sustainable human development activities that result in the deterioration of the status of the water body or that prevent the achievement of good ecological status or potential, or good groundwater status under certain conditions. This potentially includes new developments related to hydropower. [7] According to these provisions all hydropower installations and projects are subject to environmental provisions of WFD to ensure their sustainability. The main objectives of Law 3199/2003 which is divided in six basic chapters are: • long-term protection of water resources, the prevention of deterioration and the protection and restoration/remediation of degraded water resources and wetlands, • reduction and, in cases, the phase out of harmful and polluting discharges, • reduction of groundwater pollution and the prevention of its further deterioration as well as the mitigation of the effects of floods and droughts. Law 3199/03 has also incorporated the 'polluter pays principle' and the 'good ecological status or potential' for all water resources and has provided a detailed identification of 13 River Basin Districts (RBDs) according to the administrative units of the country. The active involvement of the interested parties is ensured by their representation at the National and Regional Water Councils and the incorporation of the public participation requirements of the WFD [2].
At a central level, Law 3199/2003 provided for the establishment of a National Water Board, a National Water Council (Article 3) and a Central Water Authority (Article 4). With regard to the development of the River Basin Management Plans, the national competent authority, the "Special Secretariat for Water" is responsible for coordination of water management issues; implementation of the WFD; monitoring of water quality and quantity; management and reuse of wastewater; floods management according to the Presidential Decree 24/2010 OJ A 56/15.04.2010 and Law 3199/2003 [9]. At decentralized level the 7 Decentralized Administrations and the 13 self-governed Regions are identified as Competent Authorities and they share the responsibilities.
Article 10 provides for the various water use and water supply subheadings; it provides that this is prioritized against any other use, i.e. irrigation, industrial use, energy use and recreational use. This article also makes the sole reference to the entire legislative text on the energy use of water, a very vital factor in Greece [10].
As far as it concerns hydropower-related electricity production and water resources protection according to WFD Article 4(3): Member States may designate a body of a surface water as artificial or heavy modified, when the changes to the hydromorphological characteristics of that body which would be necessary for achieving good ecological status would have significant adverse effect on activities for the purposes of which water is stored, such as power generation; Heavily modified water bodies are bodies of water which as a result of physical alterations by human activity are substantially changed in character and cannot, therefore, meet "good ecological status" (GES).
Greece has classified the HMWB's in accordance with the guidelines of the European Commission and the provisions of WFD beginning with an early stage identification of heavily modified water bodies and the measures need to be taken in order to achieve good status of the water body. The decision whether a water body is heavily modified or not is yet to be determined, therefore, at the Management Plans οf the River Basins of Greek Districts environmental objective for HMWB and AWB is to achieve the 'good ecological potential' that corresponds to the type of natural water body to which it most closely resembles. The map below depicts the ecological potential of artificial and heavily modified bodies based on data of WISE, Eurostat and corrections/additions provided by EL in late 2014 [11] . According to data of Kanakoudi's article on progress regarding the River Basin Management Plans (RBMPs) in Greece 2014 (see the Table below), "…..During the final delineation process for the HMWB and AWB, there is deficiency in information, measurements, adopted limits and reference conditions" [12]. Table 2. Overview of Implementation of Greek RBMR's.

Discussion
There are some aspects that are considered important in order to solve potential problems, maintain economic viability and ensure good ecological potential between hydropower utilisation and water protection. The transition from the general provisions of the Directive to its implementation in the HMWB is particularly difficult. There are ambiguities and questions that arise through legislation-implementation feedback.
So, the main conflict between hydropower production and the WFD arises a question whether to use water to produce renewable energy or to protect water resources and achieve good ecological potential. Understanding the linkages between the natural and socio-economic systems of HP electricity production can lead to improved and more sustainable management of ecosystems [13]. Hydropower, among other RES, is crucial in any transition towards low carbon energy solutions. There is an emergence of a new policy era with relation to HP to address the global challenge of climate change by using renewable energy systems and to facilitate the incorporation and expansion of other sources of renewable energy [14].
Adapting measures by implementing the provisions of WFD on good ecological potential and HMWB alongside with planning could minimise the environmental impacts by HP. However, legislation provisions and strict implementation of the WFD could cause potential conflict with the hydropower industry due to bureaucracy, smaller revenues, increasing of costs and reduction of HP production. But what about the aim of RES-directive to achieve 20 % renewable energy by 2020? Does RES-directive and the WFD are contradicting each other? Table 3 [15] below gives an accurate answer to all these questions as it represents hydroelectric energy share in the energy mix of European countries. The largest percentage is observed in Albania, whose energy supply comes entirely from hydroelectric power, followed by Norway with 96%. The last places are occupied by Hungary (1%), Poland (2%) and the United Kingdom (2%). There are many advantages of Hydroelectric power in comparison with other energy sources: a. It does not produce air pollutants and noise, b. it is a "clean" and renewable energy source saving foreign exchange and natural resources, c. it is an inexhaustible source of energy that helps to reduce dependence on conventional energy resources, d. reservoirs may meet needs related to water supply, irrigation, sports and e. despite their high construction costs most of the times the energy output absorbs this cost [16]. On the other hand, costly and time consuming completion of dams and environmental alterations in the area of the reservoir (possible movement of populations, degradation of areas, change in land use, in the flora and fauna of areas and the local climate, increase of seismic risk, etc.) are some of the disadvantages of hydropower production.
However, the conflict between water resources protection, good ecological potential of water and HP production in Greece still exists. Based on the information submitted by EL in late 2014, "….the water uses that are linked to the water bodies designated as HMWB as well as the types of physical modifications leading to the designation are mentioned briefly in most but not all RBDs, with differences regarding the way relevant information is presented in each group of RBMPs." Even though WFD provides regulation against economic interests of HP installations the lack of data (hydro-morphological, physicochemical, biological) in Greece make river basin management, planning of measures and establishing of monitoring systems for heavily modified surface water almost impossible. In Greece's report on WFD implementation uncertainties are mentioned in general in most RBDs concerning the HMWB/AWB designation process, due to the lack of relevant monitoring data [11].
According to data of the Working Document Report on the implementation of the Water Framework Directive River Basin Management Plans, Greece has not yet distinctly defined good ecological potential (GEP) and Greek authorities, given the lack of methodologies, define GEP as equal to Good Ecological Status (GES). This is implausible from the point of view of the WFD [17] and an underlying difficulty is the lack of assessment methods which are sensitive to hydromorphological modifications.

Conclusions
Given the fact that hydroelectricity accounted for about 23% of total Greek utility-scale renewable electricity generation it appears to be an attractive, sustainable alternative to conventional energy sources that may assist in the achievement of key performance indicators related to EU commitments to the Paris Agreement.
In this respect, WFD is a reliable tool to minimize environmental impacts of HP, provides the necessary legal means to solve potential discrepancies between hydropower utilisation, water protection and ensure good ecological potential of HMWB and contribute towards the harmonization of national legislations across the EU irrespectively of certain technical and, or physical characteristics of hydropower facilities.
Greece should develop concrete methodologies to address hydro-morphological pressures and provide a clear frame for the designation of HMWB in Greek legislation in accordance with WFD.
Given the absence of a central body to implement a water resources management strategy despite harmonization of Greek legislation with the Community Framework Directive 2000/60 / EC may cause the lack of development of GEP and impede further renewable energy substitution and watercourses preservation.