OBJECTIONS TO THE REGULATORY AUTHORITY FOR ENERGY
OPINIONS-OBJECTIONS OF NISYRIAN COMMUNAL ASSOCIATIONS TO THE REGULATORY AUTHORITY FOR ENERGY REGARDING THE APPLICATION OF PPC RENEWABLES S.A. FOR THE ISSUING OF AN EXPLOITATION LICENCE FOR THE GEOTHERMAL FIELD OF NISYROS
Piraeus 132, Athens 11854
Subject: Application of PPC Renewables S.A.
Dear Sirs / Mesdames
Having as sole guidance the interest of our border island and the safekeeping of the health of our fellow citizens, and with the suitable sense of responsibility, we hereby set forth our opinions and objections regarding the application of PPC to RAE for an exploitation license of the geothermal field of Nisyros for power production.
Our intent is plain and sincere, without ulterior motives or aiming at any kind of illicit profit. We share the authorities’ concern to reduce the use of hydrocarbons in order to comply with European Union Directives; however, we are not inclined to allow the degradation of our island, while insensible technocrats pursue their own personal goals and advancement, disregarding everything in their way. This is how the ecology of Attica has been destroyed, as well as of many other unfortunate areas in Greece, by setting up cumbersome industrial units. Now we lament over the ruins left behind by the senseless decisions of those in office; Asopos, Pache, Agioi Theodoroi, Keratsini etc. But it is of no use. Prevention is more important than regret.
We are not from the outset negatively disposed towards the use of geothermal energy in general, even in the case of high enthalpy geothermal for power production.
Nevertheless Nisyros is a small island at the borders of the Aegean sea, covering 40 km2 of area and with a small, just 3,5 km2, geothermal field (Hellenic Ministry for Development Decision, Official Gazette Issue B 1012/2005), which presents certain peculiarities (as we will later on discuss) that make its exploitation extremely dangerous and destructive for our small island.
- “Nisyros belongs to a high enthalpy volcanic area and is considered one of the two most dangerous volcanic formations in our country, as it is also referenced in a relative essay of IGME. The Ministry of Research and Technology has long been informed on the dangers regarding the exploitation of high enthalpy geothermal fields of active volcanic arcs, especially on or around active volcanic formations, as in the case of Nisyros. The explosions following the drillings and the geothermal unit set up at the volcano of Pinatubo, Philippines, have confirmed my predictions and fears.” (see attached Informatory / Recommendatory Note of the Head of the Geothermal Department, Ministry of Research and Technology, dated 9/9/1992)
- Besides the scientifically based warnings of the above mentioned scientist, who is specialized in geothermal energy, there have also been more recent facts, which prove the same point. In 2006 Geothermal Explorers started drilling works in Basel, Switzerland, through hard rock layers, to reach the 3km deep geothermal field. As usual, “specialists” assured that there will be absolutely no problem, but seismic activity began on December of that same year and the tremors caused destruction and panic to the populace of the adjacent areas. The scientific committee, which was set up for the events, concluded that the seismic activity was owing to the drillings, all work was halted and the drilling corporation paid 8 million dollars in compensation to the affected populace. Seismic activity went on for the whole next year, amounting to more than 3.500 earthquakes.
Recently, in California, the corporation Alta Rock Energy started similar efforts to those in Basel and the population also began to protest, while the President of the Basel Special Committee Rudolph Braun warned that “it will be a mistake if you act in haste and do not take into consideration what has happened here” (see attached, James Glanz at New York Times, reprint, Eleutherotypia, 5/7/2009).
The aforementioned cases are very important in proving that – despite former claims – new technology has not yet succeeded in eliminating the danger of seismic outbreak in the cases of drilling for geothermal fields situated within volcanic areas, as is the case of Nisyros.
For the reasons scientifically explained in the above-mentioned Informatory / Recommendatory Note, the energy tapped from the reservoirs is not replenished soon enough, resulting in the reduction of supercritical fluids inside the reservoir. In Larderello, Italy, the geothermal wells were maintaining their useful water and temperature load for 10 years only, after which new drills were made – sufficiently distanced from the old ones – to continue the energy production.
Since Greece and Italy belong to the same orogeny, the Alpic, (a position accepted by all scientists), it is but expected that the lifespan of each geothermal well would be the same in the case of Nisyros as well. But Nisyros covers a total area of 40 km2 and therefore “there is no adequate space for expansive geothermal exploitation”.
The scientist who wrote the above mentioned report concludes: “It is possible to say that human interference in natural systems with delicate equilibria, like those of active volcanic arcs, can have unpredictable consequences. (see attached Informatory / Recommendatory Note).
On the subject of the lifespan of each drill, please see attached articles of Dr. N.Nikolopoulos, A.Sfakianakis, N. Frantzis.
- Besides the above, it should be noted that, according to recent measurements made by both Greek and foreign geologists, the magmatic chamber of the volcano of Nisyros has recently reached a distance of 1.700 m. from the crater, a distance which for many years was 6.000 m.; therefore, any human intervention is even more dangerous, since it could disturb the delicate equilibrium of the volcano, even though the magma shows signs of recession.
- During a meeting of Nisyrians with the former Executive Officer of PPC Renewables, Mr. Garis, and the Head of Geothermal Section, Mr. Chlaboutakis, that took place in the Parliament as an initiative of a former Minister, the President of the Nisyrian Studies’ Society asked of the techno-economic data which prove the feasibility of an undertaking that will cost hundreds of millions of Euro, given that the production will span no more than 10 years, since the reservoir covers an expanse of 3.5 km2 only. Mr. Chlaboutakis, without any objection from Mr. Garis, replied that the lifespan will not be 10 but approximately 20 years! When the Head of the pertinent Section of PPC makes such a declaration, what evidence do we need that the operations will last about 10 years?
- Doctor Chr. Koronaios of the University of Columbia, professor of Postgraduate Studies Department “Environment and Development” of the NTUA, mentions in a relative essay: “Nisyros is unlike other areas were power from geothermal energy is produced. The examples cited by PPC have nothing to do with the case of Nisyros, which is smaller than 50 km2 in area and has an exploitable geothermal field of merely 3 km2. No competent engineer knowing the subject could guarantee that the production of 10MW from up to hundreds of thousands of m3 per year of chemical-containing fluids would operate without problems and that those fluids could reenter the ground. No one could guarantee that the fluids will not end up in the sea. No one could guarantee that a proper gaseous emissions cleaning system would be installed. The only islands that could potentially be compared to Nisyros are those of Mylos, Pantelleria and Guadeloupe. I won’t touch on the case of Mylos, since we all know what happened there because of the irresponsibility of PPC. Pantelleria, an island that covers an area of 83 km2 (almost double the one of Nisyros) and numbering 8.000 dwellers, has rich geothermal potential. The plans for the exploitation of its field were not carried out because of the opposition of the populace…” (see attached letter of Mr. Koronaios).
- To confirm Doctor Koronaios’ fears, we state that the unit set up site was chosen deliberately next to the sea, although there is a number of other drawbacks (e.g. no harbor or road infrastructure). If the criterion was the distance from residential area or the caldera, why was not a site close to a municipal road? It is certain that the choice was made in order to facilitate the disposal of wastes into the sea – either secretly or overtly. For the issue of the – uncontested - toxicity of those wastes, we refer to the essay of Ch.Koronaios and the article of N.Nikolopoulos, A.Sfakianakis, N.Frantzis.
- Nisyros (apart from a small area at its north end), the islet Strogyli and the coastal zone are enlisted in the NATURA 2000 program, under the code GR 4210007, category SCI.
Besides that, Nisyros and the surrounding islets have been characterized as “Important Areas for the birds of Greece”, under the code GR 167.
Greece ratified the International Convention on Biodiversity on 4/8/2001 and the Cartagena Protocol on 21/5/2004 and became a member on 19/8/2004. At the same time, Greece incorporated into national law Directive 79/409/EEC “on the conservation of wild birds” with the Joint Ministerial Decree 414985/85 and the Directive 92/43/EEC “on the conservation of natural habitats and of wild fauna and flora” with the JMD 33318/3028/98.
Quoting a recent edition of IGME regarding Nisyros: “It is situated on the eastern migratory route of birds, being most significant for their migration to Greece and Asia Minor. The recorded presence of 450 flora species, 85 avifauna species and 7 reptile species, as well as the presence of the Monachus-monachus seal at the coast of the island, make it a place worthy of particular interest.” (see attached excerpt from the edition “Designation of geosites-geoparks, contribution to sustainable development” of IGME).
According to this legal framework, Greece is obliged to take measures so as to prevent any project or intervention that could disturb the species under protection. Should the deafening sound of the drilling equipment, the monstrous scaffoldings, saline residue and toxic waste that will be disposed of in the air, sea and land both during the unit set up period as well as during its operation not be counted towards Greece’s effort to honor its commitments? We have to make clear that in case PPC advances its unlawful plans, we will resort to the European Union Court of Justice.
- According to Directive 2003/35/EC “in respect of the drawing up of certain plans and programs relating to the environment”, every member of EU must safeguard the effective participation of local communities to the decision making procedures. This Directive was incorporated into national law with JMD 37111/2021/26/26-9-2003, Official Gazette 332 B’/2003, while there already was an equivalent regulation according to JMD 71961/91, Official Gazette 541Β΄/1991. The populace of Nisyros, which will have to bear the consequences of a functioning PPC unit, has expressed its will through the referendum organized by the Municipality, voting 87% against such a possibility. The Municipal Council has submitted its negative decision to your Department on March 2001, when a similar effort for license acquisition was made. The people of Nisyros, wherever they may live, have explicitly expressed through their associations in 2001 and in the present, their opposition to such an eventuality. There is not a single Nisyrian society or association that supports the proposal of PPC. Anyone having a positive outlook on the subject expresses their personal opinion alone, and should be evaluated as such. Regarding the matter of the credibility of PPC, it suffices to refer to the following:
a. The attempt to exploit the geothermal field of Mylos is the epitome of irresponsibility, thoughtlessness and disregard towards the populace, the environment and the ecosystem and no further comment is necessary.
b. Almost thirty years after the test drills in Nisyros, and despite our reminders, PPC has left rusted scaffoldings and mile long tubing abandoned and exposed at the most touristic area of our island, the volcano, and it has shown no interest at all in removing this sordid sight.
c. Although according to paragraph 11, article 2 of the Presidential Decree 26/2002 (Official Gazette 237 D’/2002) regarding general and specific building regulations for the traditional settlements of Mandraki, Nikia and Emborio of Nisyros, PPC is obliged to put underground its network cables, no measure has been taken up to this day, and the poles, with their carcinogenic sprayings, remain standing in their places.
d. Many years now, after the connection of the power network of our island to that of Kos, we still lack of a reliable power supply and have to put up with many hours long blackouts, especially during summer, with obvious consequences for the health of the populace, who are forced to consume spoiled foodstuffs and replace their appliances, destroyed by electricity fluctuations. Despite those, PPC refuses to put into use the two power generators that are set up on the island in order to ensure the unimpeded power supply during blackouts.
We characteristically refer to the recent blackout that lasted from the morning of Friday, the 5th of March, to the evening of Saturday, the 5th of March. During this period the entire island was without power supply, something which, among other things, hampers access to water, since it is collected in underground individual cisterns for each house. For 30 hours, the populace had to use ropes and buckets to reach water and if this reminds you of the Dark Ages, this is where PPC has driven us. The power generators remained inactive all the while, if of course they still do exist, a plain example of the concern and sensibility of PPC.
The most important fact is that our island was connected to the network of Kos through two cables. The master cable broke down and the power supply was conducted since then with the slave cable, which also broke down. As to the master cable? No further interest from PPC since summer. This is how PPC operates.
e.Greece has already been convicted from the European Court because of the idleness of PPC, for the use of the banned liquid CLOFFEN, for the pollution caused by the Linoperamata unit, in Heraklion, Crete, as well as for other cases, since its units in Ptolemaida and Agios Dimitrios have been assessed as the most “polluting” in Europe.
The argument against the improvement of the Linoperamata unit is characteristic of PPC mentality: the emission filters are too costly. (EU Court Decision Case 364/03 07/07/2005).
f. In every area where PPC units are set up, the populace protests against it, because of its indifference towards environmental issues.
g. Although the opposition of the Nisyrians have been made well known, PPC is provocatively indifferent and continues to pursue its objectives, without even bothering to reply to any of our memoranda. This PPC we do not trust. Environmental problems are major problems of our time and PPC demonstrates a policy completely untrustworthy of the environmental equilibrium of our island.
- Finally, since much is said about the characterization of Nisyros as a “green island”, Mechanical Engineers Dr. Nikolopoulos and MSc A.Sfakianakis, have performed a study on alternative solutions, which, if applied, ensure power supply to Nisyros, create new jobs for the local population, provide water by desalination, heating and cooling to houses and other benefits for the island and its populace, without the use of high enthalpy geothermal energy, but only low enthalpy combined with other forms of renewable energy - a plan to which Nisyrians have acquiesced. (see attached study).
- It is indicative that PPC is unconcerned with the destruction of the island, the reaction of the populace, the huge cost of the investment and the short life of the geothermal field and obstinately insists on its plan dismissing any alternative. There has been no discussion of wind parks, on an island constantly swept by winds in both summer and winter, there has been no discussion of photovoltaics, on an island with yearlong sunlight. There has only been a firm persistence on high enthalpy geothermal energy regardless of costs. Each one of us can draw one’s conclusions.
Nisyros, through the increase of tourism, has lately entered a period of growth. The derelict houses are being repaired, expatriates are returning home and set up permanent residence, Greeks and foreigners buy houses and live here for long periods of time and, combined with the pumice mine on Giali, new jobs are being created.
All of the above are mainly due to the growth of tourism, which relies upon the unsurpassed beauty of the volcano and the natural harmony of the island. We characteristically mention that a few years ago, a central part of London hosted a huge poster that invited the English to visit Nisyros, “a rare unpolluted paradise”.
In the aforementioned edition of IGME, one can read: “It is the only active volcano in the Aegean with such a profusion of high and low vegetation, and harboring a rich variety of fauna. A paradise, not only for the volcanologist, but for any visitor who loves and respects the natural world and strives to learn about his/hers own ephemeral moment of existence from the eternal wisdom of Earth’s activities”. (see attached excerpt of the IGME edition).
We expect from the state to put its proclamations about its interest in border islands into action and promote the development of touristic infrastructure, like the ecological-geological park, the restoration of the old thermal baths (build up by the love of the Nisyrians for their island at the beginning of the 20th century), which could be turned into health spas, and other projects that respect the ecological harmony of the island and offer new perspectives to its populace. No pipes, smog and cement where one can today admire the unspoiled beauty of nature. Tourists could very well see pipes in their home countries, in Northwestern Europe. They won’t come to Nisyros to see them.
For all the aforementioned reasons, we would like to express our opposition to the plans for the exploitation of the high enthalpy geothermal field by PPC or anyone else, we ask that you hearken our distress, rise to the occasion - as becomes your office - do not be misled by the power of PPC and reject the application.
Many have asked how we could oppose PPC, the largest corporation in Greece, since it is certain that there is nothing we could achieve. We are however, armed with the confidence given to us by the sense of justice; we reply paraphrasing the known saying: “There are judges not only in Berlin, but also in Athens”. We hope we will not be belied.