LETTER: "Responsibility to protect the small Aegean islands"

Honorable Prime Minister and Honorable Ministers, Honorable General,

With this letter we want to highlight the historical responsibility of our country towards Europe's last natural refuge, the small uninhabited islands of the Aegean. This responsibility becomes greater under the regime of referring our country for non-compliance with its obligations to protect the European natural heritage. The large-scale planned developments will completely alter the character of ten (10) areas of the European Natura 2000 Network, will destroy protected habitats and will lead to the extinction of entire colonies of protected bird species and more rare and / or endemic species of flora and fauna, some of which live exclusively on the islets.

The plan to install wind turbines on 14 protected islands is unprecedented and has nothing to do with other RES projects so far in Greece and Europe, because for the first time one project of this scale, together with all the accompanying projects (roads, ports, helipads and other facilities) is designed entirely in the core of 10 protected areas in the European Network Natura 2000 (Special Environmental Study for the issuance of a Presidential Protection Decree is already being prepared for them). At the same time, due to the limited space and specificity of the islands, the effects of the interventions are many times more serious than in the mainland or the large islands, while some elements which ‐in some case are of secondary importance in mainland Greece and the large islands (such as night lighting and nuisance during the construction period) on the islets have a devastating effect.

In this investment the islets are treated as "cheap platforms", while on the contrary: precisely because of the isolation, the islets are the last whole shelters for a valuable natural asset of Europe. The absence of man led to their operation as shelters for endangered marine species such as the Mediterranean Seal and for particularly rare and important bird species, such as the Aegean gull, Mychos, Artemis and Mavropetritis, species for which the islets and rocky shores of our country host 85% of the world its population. At the same time, the  long isolation of the Aegean islands has led to the development of a of particular biodiversity, adapted to the specific conditions, with high rates of endemism (endemism refers to species that are found in particular geographic regions due to factors that include isolation or certain abiotic conditions).

Dozens of endemic species and subspecies of plants, invertebrates and reptiles are found in one and only small island. It is no coincidence that the islands of the Aegean have been characterized by distinguished internationally renowned scientists as development laboratories, similar to those of the Galapagos Islands.

For the above reasons, many Aegean islands have been recognized at European level. This formal status of environmental importance by the European Union is also the main recognizable element of these areas internationally. The choice to destroy valuable and unique natural capital and to show contempt for the invaluable and their universal value is primarily a political decision and that is why we turn to political principles (scientific documentation has been sufficiently formulated in dozens of pages of testimony from the most competent bodies: the Managing Bodies of these Protected Areas).

The project is planned to be implemented on the islets of Ofidoussa and Kounoupi in Astypalea, Syrna, Plakida, Mesonisi and Megalo Sofrano in the Carpathian Sea, Pacheia and Makra Anafis, Liadi, Kinaros and Levitha between Amorgos and Leros, Kandelioussa, Pergoussa and Pacheia Nisyros of Prefecture of Kalymnos, Thira and Kos of the Region of N. Aegean and in all cases it is about islets protected and integrated into the Natura 2000 Network.

This project concerns the location of three Wind Power Plants (ASPIE) of total capacity 486MW (106 wind turbines from 3MW to 6MW). In addition to the 106 wind turbines, related projects to be implemented on the islets include 71 km of new road construction, 14 port projects, 14 heliports, dozens of ancillary facilities and extensive rockfalls. The scale is unprecedented and disproportionately large for the size of the islets that will suffer.

The location of ASPIE on these islets will cause a number of negative effects on protected species and in particular:

• Destruction of nesting sites: The road network, constructions and rockslides will irreparably destroy very important habitats, while in the case of Artemis, Mychos and the Aegean Gull will also destroy the nesting area.
• Μός Displacement of bird species and obstruction in their flight paths, as the operation of each turbine but also the constant lighting during the night affects an area of ​​hundreds meters around it - area critical when referring to islands with an area of ​​a few hundred acres. This will lead to the immediate or gradual abandonment of entire colonies of Mavropetritis, Aegean gull and other species.
• Deaths from collisions are expected to be numerous, especially in the case of Mycenae and Artemis, where the birds return overnight to their nests flying in flocks over the islets. These species will have catastrophic losses and from the constant illumination which disorients them at the critical moment when they return to nests (as occasionally with lighthouses and liners at night - but now we are talking about constant lighting on the colony where the whole population gathers).
• Huge losses are also predicted for the migratory species that use it central airway of the Aegean, both from collisions and from disorientation due to lighting at night.
• Consolidation of the human presence and eventual loss of the safe haven of the islands with the constant presence of people, ports, noise, lighting, import facility predators (eg rats) and a general ecosystem disorder.
• Intense nuisance from the long duration of the construction period (approximately 5 years), as all the islands will have been transformed into a construction site.
• Catastrophic changes in ecosystems characterized by isolation and endemic species of fauna and flora.

It should be emphasized that unlike other possible cases, in this project mitigation measures may not work. The mechanisms that stop the operation of wind turbines when passing birds cannot be applied with the way birds behave on the islets. Even though they could apply, since we are talking about colonies with hundreds of birds in the area, this will mean that the wind turbines would be stopped for a period which on some islets would last from February to October. The (already controversial) displacement measures birds away from wind turbines obviously cannot be applied to the limited area of ​​the islets. The most serious effects of night lighting cannot be mitigated. Special shades not only cannot be used, but the Civil Aviation Authority emphasizes that the lighting should be intensified not reduced. Finally, mitigation measures such as planting and "improving" the ecosystem are completely unacceptable on the islets where the basic administrative measure is the strict ban on the import of any kind fauna or flora foreign to them.

When the design of such a project on the small protected islands became known, we waited to see if the basic environmental impact assessment would suffice to cancel it. We were very surprised to find that the Environmental Impact Study and the Special Ecological Assessment excluded some islands but at the same time allowed the installation of wind turbines and a number of accompanying works on 14 islets - all protected. This unprecedented conclusion of the EIA and ESA is due to three main reasons: First, the arbitrariness, in particular the setback of just 300 meters between the wind turbines and colonies of birds - something literally unprecedented, and not based on any scientific study. Also, while in many respects the EOA, in fact, acknowledges the problem, in the conclusions the report declares the impacts as acceptable. Secondly, the ignorance of the most important parameters of islet ecology (eg the habits of pelagic seabirds) and thirdly of the study, which devoted just a few hours to each islet (used helicopter to visit several islands on the same day, while days are required in each, and did not carry out any night research) so they did not take elements of the study very seriously, such as the huge colony of Artemis on the islets of Anafi (1 A / G in Pacheia and 5 A / G in Long).

The situation, we repeat, is literally unprecedented. There are in other cases catastrophic RES projects with which we disagree, but for the first time a project is planned at the core protected areas. The Special Environmental Study is in progress and is complete certain that, in accordance with the common scientific practice of managing these ecosystems, at least 10 of the 14 smaller islets and a large portion of the rest will be proposed absolute nature protection regime. How is it possible to do this when these islets are they converted into construction sites? The case of the islet of Agios Georgios in the Saronic Gulf, both during duration of the projects as well as today that operates as a wind farm, is indicative of what will occur in the remote islands of the Aegean which - in contrast to Agios Georgios which was not protected area‐ host priority species such as Mavropetritis, Aegean gull, others predators and seabirds, seals and unique endemic species.

The only logical explanation for the fact that such a project was not canceled from the beginning is the ignorance of the ecological value of protected small islands and the "popular" perception that they are useless rocks in the middle of the sea. Only under the pressure of such a perception could move on. But the time has come for a final decision, which must be annulled of the project since, as we analyzed above, the islets are valuable natural shelters exactly due to the integrity due to their isolation and the absence of man. There are dozens of other projects that can meet the country's targets for RES development. Besides, The country's responsibilities focus not only on tackling climate change but also on biodiversity loss. For which action is needed both globally and in local level. The islets of the Aegean, although small in size, have incalculable value for global biodiversity. Our country therefore has a great responsibility for their protection.

The choice, then, of the destruction of natural capital and the valuable and unique in Greek heritage world is primarily political. No one is forcing the country to solve one problem by creating another. The road to recovery from fossil fuels and Reducing greenhouse gases has many directions. It is the duty of the country guidelines to be in line with the principles of Sustainable Development as provided by the Constitution of Greece explicitly as a fundamental "individual and social right" of the citizens. Its worth noting that other developed countries also recognize the importance of encouraging RES but they did not choose to sacrifice anything of universal value, such as the Alps. Investments for the exploitation and consequently the technological development and the improvement of the economic competitiveness of forms of RES exploitation can and should be strategically directed preferably in the built environment, close to populated areas. 

Besides, due to the absence of strategic planning for the location of ASPIE in our country, The European Commission has opened a preliminary hearing against Greece which is in stage of the Warning Letter. The new spatial planning for RES that is already in place in the review phase is sure to prevent such distortions and prevent disasters like the one that is being routed, if it is properly planned with it in mind curbing climate change while protecting biodiversity. The size of plans to block any attempt to rehabilitate it landscape and avoid vegetation damage. 11 of the 14 islets are less than 2 km2 (see Table 1 in the Annex).

The islets are treated as "cheap platforms" proving a political contempt for their invaluable and universal value. The choiceto destroy this natural capital and Greek heritage, valuable and unique in the world, is eminently political in this as well you have the ultimate responsibility. We call on you to abide by the constitutional obligation to safeguard of the natural environment of Greece and to prevent the location of ASPIE in the untouched to date islets that are one of the most valuable reserves in the world.

Yours sincerely,

The environmental organizations ANIMA, ARKTOUROS, ARCHELON, MEDITERRANEAN SOS Network, GREEK SOCIETY for Environment and Culture,

Hellenic Society for the Protection of Nature,

Hellenic ORNITHOLOGICAL SOCIETY,

PRESPA PROTECTION SOCIETY, KALLISTO, MEDASSET, MOm / Company for Study and Protection of the Mediterranean Seal,

the Hellenic Herpetological Society and the Hellenic Ecological Society