Environmental classification of mining activities
Environmental permitting is performed pursuant to L.4014/2011, as amended and valid. It is the most time consuming and demanding procedure within the licensing/permitting process of the mining projects and activities in Greece. The complexity and time duration of the environmental permitting is affected by the category of the project, as set in the MD37674/2016 as amended and valid, that classifies projects and activities into Groups and Types.
Mining Projects and Activities constitute Group 5 of Annex V of this decision, entitled “Extractive and related activities” which includes twelve (12) types of projects/activities. Each type of project/activity defined is classified into categories A and B. Category A is further subdivided in A1 and A2 subcategories. A summary of this classification per type of mineral raw material, processed by the authors, is presented in Table 2.1.2-1. Click here to see the related Table of Annex V of MD 37674/2016.
The classification of a project/activity in a specific category depends on the significance of the expected environmental impacts of that project. Sub-category A1 corresponds to projects/activities with significant environmental impacts. The provisions for the environmental permitting for such projects are complicated and lengthy, considering the legal timeframe set in L.4014/2011. Sub-category A2 lists projects / activities with less significant environmental impacts and its procedures for environmental permitting are easier. For each of the above subcategories, an EIA Study is prepared according to MD170225/2014 as amended, submitted and evaluated. The permit is granted with the Environmental Terms Approval Decision (AEPO).
Projects and activities listed under category B are characterized by insignificant environmental impacts and for this reason they do not require an Environmental Impacts Assessment Study (EIA Study) for environmental permitting (article 8 of L.4014/2011). These projects and activities are subject to Standard Environmental Commitments (SEC) or Standardized Environmental Terms.
For all projects and activities classified into Sub-category A1, the competent authority for the evaluation of the EIA study is the Ministry of Environment and Energy (YPEN). The AEPO takes the form of a MD issued by YPEN. The projects and activities that are included in Sub-category A2 are submitted to the De-Centralised Administration for environmental permitting. In the latter case, the AEPO is issued by the De-Centralised Administration.
Table 2.1.2-1: Processed summary of extractive and related activities’ classification per type of mineral raw material
|Type of mineral raw material||Project description||Category|
|Ores||Exploitation of ores and exploration drillings for ores||Sub-category A1|
|Solid energy minerals||Exploitation of solid energy minerals and exploration drillings for solid energy minerals||Sub-category A1|
|Hydrocarbons||Hydrocarbons’ extraction and hydrocarbon exploration drillings||Sub-category A1|
|High enthalpy geothermal fields||Drillings for exploration or/and exploitation of high enthalpy geothermal fields||Sub-category A2|
|Low enthalpy geothermal fields||Drillings for exploration or/and exploitation of low enthalpy geothermal fields||Category B|
|Industrial minerals – Marbles – Slate slabs||Surface exploitation of industrial minerals, marble, and slate slabs. Area of intervention E ≥25ha.||Sub-category A1|
|Surface exploitation of industrial minerals, marble, and slate slabs. Area of intervention E ≥15ha and within Natura 2000 network.||Sub-category A1|
|Surface exploitation of industrial minerals, marble, and slate slabs. Area of intervention (E): 15 < E < 25ha and outside Natura 2000 network||Sub-category A2|
|Underground exploitation of industrial minerals, marble, and slate slabs within Natura 2000 network.||Sub-category A1|
|Underground exploitation of industrial minerals, marble, and slate slabs, outside Natura 2000 network.||Sub-category A2|
|Minerals other than solid energy, ores, hydrocarbons and geothermal ones||Exploration drillings for minerals other than solid energy, ores, hydrocarbons and geothermal ones. Drillings within the frame of geotechnical research are not included.||Category B|
|Other than drilling exploration activities that may cause long-term alteration to the ground, the sea bottom or lakes. Note: Environmental licensing is not required for exploration activities like geophysics, seismics, geochemical sampling etc. that do not cause long-term alteration to the ground, the sea bottom or lakes.||Category B|
|Aggregates (crushed rock)||Exploitation of aggregates. Area of intervention E ≥25ha.||Sub-category A1|
|Exploitation of aggregates. Area of intervention E <25ha.||Sub-category A2|
|Aggregates and soil material||Borrow pits of aggregates and soil material exclusively for the needs of public infrastructure projects||Classification according to the category of the project they serve. If this is sub-category A1, the provisions of Art. 7, paragraph 3 of L.4014/2011 apply.|
|Sand||Extraction of sand not included in the category of aggregates||Sub-category A2|
|Extractive waste||Facilities for the management of extractive waste run by single operators as defined in JMD 39624/2209/103/2009||Sub-category A1|
|Category A facilities for the management of extractive waste run by joint operators as defined in JMD 39624/2209/103/2009||Sub-category A1|
|Other than category A facilities for the management of extractive waste run by joint operators as defined in JMD 39624/2209/103/2009||Sub-category A2|
|Other||Deep drillings for radioactive waste storage||Sub-category A1|
|Project type||Sub-category A1||Sub-category A2||Category B||Remarks|
|1||Exploitation of solid energy minerals and exploration drillings for solid energy minerals||X|
|2||Exploitation of ores and exploration drillings for ores||X|
|3||Exploitation of industrial minerals, marble, and slate slabs||Surface exploitation:
a) E ≥25ha
b) E ≥15ha and within Natura 2000 network
Underground exploitation within Natura 2000 network
a) 15<E <25ha and outside Natura 2000 network
b) E <15ha
Underground exploitation outside Natura 2000 network
|E: area of intervention|
|4||Exploitation of aggregates||E ≥25ha||E <25ha|
|5||Aggregates’ extraction for the implementation of public infrastructure projects||They are classified according to the category of the project they serve.
For the extraction of aggregates that serve sub-category A1, the provisions of Art. 7, paragraph 3 of L.4014/2011 apply.
|6||Sand extraction not included in the category of aggregates||X|
|7||Hydrocarbons’ extraction and hydrocarbon exploration drillings||X|
|8||Exploration and exploitation drillings of geothermal fields||Geothermal Fields of national importance (High Enthalpy)||Geothermal Fields of local importance (Low Enthalpy)|
|9||Exploration drillings for minerals (1,2,7,8 cases are excluded)||X||Geotechnical drillings are excluded|
|10||Other exploration activities (excluding drillings) that may cause long-term alteration to the
ground, the sea bottom or lakes
|X||Exploration activities that do not cause any long-term alteration to the ground, the sea bottom, or lakes like the geophysical surveys (including seismic, gravimetric, or magnetic surveys etc.) geochemical sampling surveys etc.|
|11||Facilities for the management of extractive waste||a) All facilities run by “Single Operators”
b) All facilities that fall in
Category A, run by “Joint
|Facilities not falling in Category A, run by “Joint Operators||The terms “Single
Operators” and Joint
Operators” according to the JMD 39624/2209/103/2009
|12||Deep drillings for radioactive waste storage||X|