186 Alexandros Nikas et al.
compliance with the austerity- driven financial commitments of the country.
This is an interesting suggestion, coming from the policymaking stakeholder
group. Eventually, this gives rise to the risk of a regulatory framework that is too
demanding in relation to the maturity of the market and does not successfully
attract investments.
Most measures in the past focused on energy efficiency in public buildings,
for both central government and local authorities and municipalities. Although
this is not generally perceived as an example of poor prioritisation, the risk of
not managing to align the interests of local governments with the national commitments and directions should be acknowledged. A recent example can be
found in the issuing of Energy Performance Certificates (EPCs), where no coordination actions among stakeholders and/or between the central and local
governments reportedly took place to ensure coherent and transparent implementation (Spyridaki et al., 2016).
Ultimately, in order to take proper mitigation action, it is important to
understand the risks associated with the individual policy instruments considered by the ministry for its previous and new Energy Efficiency Action Plans
(Ministry of Environment and Energy, 2014, 2017) – see Table 11.1. These
included: the ‘Save Energy at Home II’ financial programme for incentivising
energy upgrade actions in the broader residential sector; the energy upgrade programme for public buildings, with regard to building shells, lighting, and building energy management systems (BEMS); energy efficiency and demonstration
projects for small- medium enterprises (SMEs); the implementation of an energy
management system in the broader public building sector, in accordance with
the ISO 50001 standard; an interest rate subsidy for funding energy improvement actions in commercial buildings, through energy service companies
(ESCOs); a wide- scale deployment of smart metering systems; a series of largescale environmental infrastructure projects and other interventions at the
national level, as part of the operational programme Environment and Sustainable Development (OPESD); the offset of fines on illegal residential buildings
with costs for services, tasks, and materials used for the energy upgrade of these
buildings; the definition of energy management duties and the implementation
of action plans in municipal buildings; the extension of the district heating networks from the integrated expansion of the Ptolemaida and Amyntaio network,
as well as the planned expansions of the Florina and Kozani district heating networks; the replacement of old public and private light trucks; incentives for the
replacement of old private passenger vehicles; a retrofitting programme for street
lighting; financial support for retrofitting pumping systems at the municipal
level; and dissemination activities for behavioural change oriented on the benefits of EPCs.
Eight specific implementation risks are associated with one, several, or all of
the policy instruments. These included: the inability of local governments to
align their priorities with the obligations of the central government; political
instability; complex bureaucratic processes; demanding regulatory framework in
respect to market maturity; the inadequate banking sector; limited societal
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