Open letter to the Committee on Agricultural Economy, Environment & Rural Economy Development

Date: 3 August 2025
Lampros Sakellariou

Ladies and Gentlemen

It is with great concern and a deep sense of responsibility that I address this letter to you. You are facing a critical decision regarding the CO₂ storage project in Prinos – a project that is presented as a “green” solution, but which may have serious, irreversible consequences for the marine environment, the local economy, the safety and health of the citizens of the Gulf of Kavala and especially Thassos.

With respect to your institutional role, I would like to give you some information that you may not know and which I think is crucial to the decision you may take.

Ι. Implementing Decision of the Council of the European Commission COM(2025) 367 final of 30.6.2025

Greece requested the withdrawal of measure 16997, citing “apparent disruptions in the supply chain”. The Milestone 373 of this measure concerned the technological maturation and promotion of infrastructure CCS (capture and storage CO₂). The consequences of withdrawal are obvious. Failure to complete the milestone means that the project is not yet ready for implementation or funding. The withdrawal of milestone 373 blurs the picture, not only for the progress of the project but also for any organisational or administrative delays. Withdrawal means

• Loss of contractual funding through TAA. The project loses (for the time being) the funding from the CDF, which was considered a key source of support
• Lack of transparency and justification
  The general invocation of “disruption in the supply chain” instead of a detailed justification does not meet the standards of transparency and adequate justification as required by Articles 41 and 47 of the EU Charter of Fundamental Rights. Withdrawal on the grounds of ‘supply chain’ may function as a diplomatic formulation, instead of clearly naming the failure in administrative preparation.
• Does the reference to “supply chain” mask institutional or regulatory dysfunctions? Is this why you are being called upon to make a decision?
• Ambiguity about the role of the project in the Prinos. Is the Prinos project mature, or does it remain technically/administratively problematic?

With this amendment, the project “CO₂ storage in Prinos” (Measure 16997) is removed from the list of funded projects of the CDF. This appears to lead to the loss of part of the €150 million grant, while the €120 million grant from the European Commission’s Innovation Fund remains in place. And there is a possibility that the project will be limited to private use by Energean, without transnationality by triggering Carbon Contracts for Difference (CCfD or Climate Contracts) or other cost recovery mechanism. You should be aware that the sources of funding for CCfDs are National resources (state budget or special funds), Emission Trading System revenues and limited for pilot uses from the Innovation Fund. Recovery Fund (RRF) is not allowed to finance CCfDs due to the nature of the mechanism

Perhaps this decision also led to the withdrawal of the project file from the Electronic Environmental Register (EER). Otherwise, why would it be withdrawn? Why? The EEM was created in order for any interested party to gain full, detailed and unhindered access and knowledge during the consultation period. Please note that the deletion of its contents is prohibited by law. This applies even if the project is not ultimately licensed.

II. Compensatory measures.

Energeanhas asked the Greek government to cover the cost of compensatory measures to the local community through the inclusion of the Prinos area in a Fair Development Transition Plan (FDP) for strategic and political reasons. What do we mean when we talk about compensatory works? Which projects is Energean requesting to be covered by the EMS? Examples: Strengthening local infrastructure, Employment and retraining, Environmental and health measures, Local contribution or “social acceptance clause”. Energean wants to relieve the Prinos CCS project from social and political tensions by transferring part of the social costs (e.g. local responses, environmental offsets, social infrastructure) to the state. In this way it enhances the bankability of the project, so that it can attract European co-financing (e.g. from Innovation Fund, InvestEU) or private capital.

The suspicion that Energean is seeking through the inclusion of the project in the Fair Development Transition Plan (FDP) to avoid compensatory obligations and pass on costs to the state is well-founded, but has not been officially confirmed.

If an investment is included in the GMS (i.e. as a national green transition project), then Energean is relieved of major costs, such as

• Restoration of the marine environment after the end of operation of the installation.
• Platform removal or conversion based on strict protocols.
• Liability guarantees for possible CO₂leaks in case of drilling failure.
• Monitoring/Monitoring

Therefore, it is very likely that Energean, through the inclusion of the project in the Fair Transition, is seeking relief from costs that would otherwise be borne exclusively by the company (compensation, liability insurance, rehabilitation) and to transfer the responsibility and maintenance costs of the old infrastructure to the public sector.

In conclusion, I address you with a sense of responsibility towards the environment, public health and the legal security of the local community. This project, despite its projection as a contribution to the “green transition”, has significant legal, environmental and institutional deficiencies that do not allow for a safe or informed opinion in its favour at the level of the Committee on Rural Economy Environment & Development.

Apart from the legal uncertainties and uncertainties, the lack of compliance with the consultation process, the risk of possible exposure of your institution to liability is visible. The issuance of a positive opinion by your Commission in the absence of the necessary documentation may be used as a presumption of social acceptance by the project proponent and undermine the institutional credibility of the Committee for Rural Economy Environment & Development.

The responsibility that your Commission assumes with such a decision is substantial and potentially lasting. The local community must not be turned into a field of experimentation… I hope your decision is made with a conscience because conscience does not fade away, it just waits. And when it returns, it bites deeper than we imagined.

Thank you
Lampros Sakellariou