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Eastern Macedonia & Thrace Institute of

Technology
Dept. of Petroleum & Natural Gas Engineering
M.Sc. in Oil & Gas Technology
Course Assignment for Energy Policy - Geostrategy

"Greek Exclusive Economic Zone: A Geopolitical


Approach

Team Members:
A. Pitatzis, L. Eleftheriadis
Kavala, December 2014

What is an Exclusive Economic Zone (EEZ)?


An exclusive economic zone (EEZ) is a sea-zone prescribed by the United Nations Convention on
the Law of the Sea (UNCLOS), over which a coastal state has sovereign rights to explore and
exploit its natural resources, including wind and water energy production. The third Convention
on the Law of the Sea (UNCLOS III) in 1982 that came into force in 1994 replaced the international
agreements for the continental shelf of 1958 and established for the first time the definitions of
Exclusive Economic Zone and territorial sea.
More specifically, according to the article 55 of the UNCLOS III, and the specific legal regime of
the exclusive economic zone it is defined as an area beyond and adjacent to the territorial sea,
subject to the specific legal regime established in this Part (part V), under which the rights and
jurisdiction of the coastal State and the rights and freedoms of other States are governed by the
relevant provisions of this Convention.
The coastal State, according to article 56 of the same convention has in its exclusive economic
zone sovereign rights for the purpose of exploring and exploiting, conserving and managing the
natural resources, whether living or non-living, of the waters superjacent to the seabed and of the
seabed and its subsoil, and with regard to other activities for the economic exploitation and
exploration of the zone, such as the production of energy from the water, currents and winds. The
rights for the exploration and exploitation in the seabed and subsoil within the zone are examined
according to the provisions about the continental shelf (Part VI). At this point it is important to
mention that the rights of the continental shelf occur and belong to the coastal state regardless the
will of the sate to declare it ipso jure; while the same does not happen for the exclusive economic
zone, where the state has to declare in the International Court its exclusive economic zone, in order
to have the rights of the EEZ respectively.
The exclusive economic zone stretches beyond the territorial sea up to 200 nautical miles from the
baseline of the coast. When two (or more) states coastal baselines are less than 400 nm apart,
overlap of EEZs occurs and it is up to the states to delineate the actual maritime boundary. This
can follow the unilaterally declaration by the State of its exclusive economic zone.

EEZ Definition- www.geography.about.com

(References 1,2,8,9)

Greek EEZ Agreements with neighbor nations


Greece participated in the Convention of Law of the Seas (UNCLOS III) in 1982 and accepted the
terms of the Convention. Despite the fact that Greece had accepted the terms of the convention,
Greece never proceeds to the declaration of its EEZ. Furthermore, most of the Mediterranean
countries (13 out of 21) did not proceed to the declaration of EEZ.
Greece managed the last 12 years to progress gradually in agreements with the neighbor countries
in delineating the maritime boundaries. Starting from the west borders of the country, Greece had
an agreement with Albania, in April of 2009, in delineating their sea zone. This agreement did not
last more than two years because; the Albanian Constitutional Court, after an obvious intervention
of the government of Turkey, decided that this agreement had no valid. On the other hand, Greece
had an early agreement (1977) with Italy in respect of the continental shelf, based on the middle
point limitation.

The recent trilateral partnership and agreement for respect in International Law in Cairo, between
Greece, Cyprus and Egypt have set strong foundations in the declaration of the Greek EEZ.
Furthermore, Cyprus had agreed with Egypt, Lebanon and Israel which also recognize the Greek
EEZ. Libya, on the other hand, does not recognize the existence of Gavdos island and its
participation in the EEZ and at this point the conversation between the two countries about the
middle line is stuck.

Turkey for more than thirty years insist that an agreement between Greece and Turkey in respect
of middle line cannot happen and threats Greece with an act of war ,casus belli ,in case that the
last one proceed to the extension of the territorial sea in twelve nautical miles. Turkey despite the
fact that did not take part in the Convention of the Law of the Sea in 1982, partially declared EEZ
in the black sea in 1986, and proceeded in an agreement with Romania and Bulgaria in respect of
the middle line.

EEZ of Greece and neighboring countries based upon the International Law of the Sea (UNCLOS)- Mazis 2011

(References 3, 4)

The history of exploration activities


An approach in the historical record of hydrocarbon exploration in Greece will be presented below,
taking under consideration the continuous developing exploration techniques and the knowledge
enrichment about the general geological structure of Greece.

An early attempt in hydrocarbon exploration made back to the beginning of the 20th century
(1903).

Exploration efforts were mainly focused on on-shore areas, and were characterized by surface oil
shows evidence. These efforts were discontinuous up to the early 60s. In the next decade
exploration became more systematic and it was first established a public body, oriented to the
exploration of hydrocarbons. The systematic exploration of that period had as result the discovery
of the first exploitable hydrocarbon reserves in Prinos, an off-shore area of Thasos (1971-1974).

The establishment of the public body led in 1975 to the foundation of the Public Petroleum
Corporation (DEP). DEP was responsible for the exploration starting from its establishment till
the mid 90s. The first law governing hydrocarbon exploration (L. 468/76) was approved the next
year from the establishment of DEP. The Greek government granted to DEP and its subsidiary
company 24 on-shore and off-shore areas for hydrocarbon prospecting, exploration and
production. The main outcome of the seismic surveys in these areas was the discovery of oil in the
off-shore Katakolo area in NW Peloponnese.

Western Katakolo- www.ypeka.gr

In 1996 the first International Licensing Round, involving 6 concession areas, was performed,
following the law 2289/1995 which came into act after adopting EC Directive 94/22/EC
concerning the prospection, exploration and exploitation of hydrocarbons. The Greek government
invested in seismic surveys and drilling up to 85M , but failed to deliver results.

In 2011 following a decade with no exploration activity, the Hellenic Hydrocarbons Resources
Management Company S.A was established. The H.H.M.R.C.S.A. was established under the law
4001/2011 concerning the prospection, exploration and exploitation of hydrocarbons and replaced
the law 2289/1995. The Hellenic Republic Ministry of Environment, Energy and Climate Change
(YPEKA) in 2011 granted to Petroleum Geo-Services (PGS) MC2D data for areas in Western and
Southern Greece. The program comprised of 12,500km new data acquisition using GeoStreamer
with GeoSource and combines re-processing of 9,000km and matching of 13,000km of legacy data
into a regional interpretation.

The objectives of this program were the improvement of

understanding of regional structure and depositional basins and to identify petroleum systems.

Greece MC2D GRE-2012 www.pgs.com

(References 12,13,14)

Greek legislation framework for the exploration and exploitation of


hydrocarbons
It is important to know how the Greek legislation framework was evolved during the last half
century when the exploration of hydrocarbons became more intense and systematic. The first law
that was approved by the Greek parliament concerning hydrocarbon exploration was L. 468/76, a
year after the foundation of Public Petroleum Corporation (DEP).

The United Nations Convention on the Law of the Sea (UNCLOS III) that took part in 1982 in
Monteco Bay came into act in 1994 with the EC 94/22/EE. The law 468 was replaced by the law
2289/95, which incorporated a large part of the EC Directive 94/22/EE, concerning the
prospection, exploration and exploitation of hydrocarbons in the Greek legislation. Based on the
law 2289 the Greek government performed in 1996 the first International Licensing Round with
the disappointing results that mentioned above.

The existing legal framework concerning the procedure of granting exploration/exploitation rights,
was recently reformed with the approval by the Greek Parliament of the new law 4001/2011. The
new law modernizes and clarifies the legal framework being in force since 1995, followed by the
establishment of new attractive entrepreneurial environment. Before the approval of the law 4001,
the Hellenic Republic Ministry of Environment, Energy and Climate Change (YPEKA) has
already preceded to an International Public Invitation for the Participation in non-exclusive seismic
survey offshore Western and Southern Greece. The State, at the same time, announced the granting
of exploration and exploitation rights in three areas (Patraikos Gulf, Ioannina and Western
Katakolo) following the procedure of open door invitation which was published in the
Government Gazette (No.76/27.01.2012).

Moreover, the establishment of the Hellenic Hydrocarbons Resources Management Company S.A
was included in the law 4001/2011 and its statute in the Presidential Degree No 14 (FEK A
21/13.02.2012). The H.H.R.M S.A. has the responsibility to manage the exclusive rights of the
Greek Public related to exploration and exploitation of hydrocarbons.

In summer of 2014 Greece have reached to a historical moment in the exploration of


hydrocarbons. The Ministry of Environment, Energy and Climate Change (YPEKA) on July 31
published 20 offshore blocks in the Ionian Sea off western Greece and south of Crete. The
following week published in the Greek Official Gazette (Paper No 2186/8-8-2014) the Call for
Tenders of the 2nd International Licensing Round 2014 and invites all interested parties to apply
for granting and using authorizations for the exploration and exploitation of hydrocarbons in
respect of certain offshore acreage in Western and Southern Greece. This invitation is based
upon the law 2289/95, which is in force and is referred as Prospecting, Exploration and

Exploitation of Hydrocarbons, and other provisions. These 20 offshore blocks have a total
acreage of 225.000 square kilometers. Furthermore, on November 13 the Notice of Call for
Tenders was published in the Official Journal of European Union (2014/C 400/03). The
Application Deadline is six months after the date of publication of the Notice of Call for
Tenders, on May 14 of 2015.

20 offshore blocks south and west of Greece-Official Journal of European Union (C400/4)

(References 3, 4, 15, 16)

Operating and Interested Companies for exploration and exploitation of


Hydrocarbons
The first discovery of exploitable hydrocarbon reserves was made by Oceanic (171-1974) in the
off-shore area of Thasos island. This reserve is operated at the moment by Energean Oil & Gas. In
the open door invitation of 2012 Energean Oil & Gas was granted exploration and exploitation
rights in two out of three areas, participating in consortium with Petra Petroleum in an onshore
area (4161 KM^2) at Ioannina. In the offshore area (543 KM^2) of Katakolo, Energean Oil & Gas
participates in consortium with Trajan Oil & Gas. Patraikos Gulf was the third area that was

included in the invitation, and the rights for this area were granted to Hellenic Petroleum, Edison
and Petroceltic.

The Italian company ENEL TRADE SpA on April 14 of 2014, submitted to the Ministry of
Environment, Energy and Climate Change (YPEKA) an expression of interest in granting and
using authorization for the exploration for and exploitation of hydrocarbons within three (3)
onshore areas, Arta-Preveza, Aitoloakarnania and NW Peloponnese in Western Greece. These
three onshore areas were included in the first Licensing International Round of 1996. The Ministry
after accepting the aforementioned expression announces an invitation to other possible interested
parties to participate in this tendering procedure. The Notice of Call for Tenders was published in
the Official Journal of European Union (2014/C 390/05) on November 5. The interested companies
have three months to apply for granting the rights for exploration and exploitation of these three
areas. Hellenic Petroleum and Energean Oil & Gas, are the companies that interested for these
areas, except ENEL Trade.

Official Journal of European Union (390/05)

The second International Licensing Round 2014 were interested parties are called to apply for
granting rights for exploration and exploitation in respect of the twenty off-shore blocks west and
south of Greece is expected to attract the interest of major companies of the Oil & Gas industry.
In the International Congress Balkans and the Adriatic Oil & Gas which was hosted in Athens
on October 1, seventeen international companies were participated. Among these companies were
Shell, Statoil, Dana Gas, Exxon Mobil, Gazpromneft, Bankers Petroleum, Petromanas and OMV.

Exxon Mobil and Total are the first two international companies that bought recently for 5 million
dollars from PGS the seismic survey.
(References 5,6,15)

Pipelines and other Major connecting projects


Trans Adriatic Pipeline
The TAP pipeline designed to transport natural gas from the giant Shah Deniz II deposit in
Azerbaijan to Europe. This pipeline with 870 km length and capacity of 10 billion cubic meters
will be connected with the pipeline Trans Anatolian Pipeline (TANAP) at Kipous, near the Turkish
borders and will cross Greece, Albania and the Adriatic, before it reaches the land of south Italy.
The landing of 'TAP on the coast of Italy provides multiple opportunities for further transport
Caspian gas to some of the largest European markets, such as Germany, France, Switzerland and
Austria. BP, one of the companies participating in the consortium, announced recently their
intention to increase the capacity of the pipeline to 20 billion c.m. in the next five years after the
completion of the project. The construction of the pipeline is planned to begin in 2016.
The Interconnector pipeline Turkey - Greece
The Interconnector Greece - Turkey, as the first part of the overall interconnector pipeline
between Turkey, Greece and Italy (ITGI), was the first step to opening the Southern European
Transport Corridor gas through Turkey, from the producer countries of the Caspian Sea and
Middle East to Greece and other European countries. The Interconnector pipeline Turkey Greece, length 300 km, has as its starting point the Karacabey (Turkey) and ends in Komotini
(Greece). This pipeline is in operation since 2007 and the maximum annual capacity stands at
11.6 billion cubic meters.
The Interconnector Greece Italy
The Interconnector Greece - Italy (IGI) consists of two parts: the land part (Komotini Thesprotikes coast) and the undersea pipeline Poseidon (Thesprotikes coast - Otranto, Italy). It has
a total length of about 800 km and the maximum annual capacity that can reach is 15 billion c.m.
of natural gas. The main section of the pipeline is onshore, and has a length of 600 km and will be
constructed by the Administrator of the National Natural Gas System (DESFA). The offshore part
of the project, with a length of about 200 km, includes the underwater pipeline "POSEIDON" and
supporting facilities. The EU recognizes the strategic importance of the ITGI pipeline as a project

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of European interest, included it among the Southern Corridor projects co-financed from the
resources of the European Plan for Economic Reconstruction in the energy sector (EEPR),
approving a grant of the manufacturing cost of the amount of 100 million euro. The ITGI project
is scheduled to be operational by 2015 as the first phase of the Southern Corridor.

Project of European Interest_ NG 3

Interconnector Greece - Bulgaria (IGB)


With a total length of about 180 km and starting point Komotini, the pipeline will result in Stara
Zagora Bulgaria, thereby connecting the Greek gas system with the Bulgarian. The capacity of the
pipeline, fully developed, will be approximately 5 billion cubic meters The EU recognizes the
strategic importance of the Greek-Bulgarian interconnector pipeline as a project of European
interest, included it among the projects of the Southern corridor co-financed from the resources of
the European Plan for Economic Reconstruction in the energy sector (EEPR), approving a grant
of construction costs with the amount of 45 million euro.

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ITGI Project - www.igi-poseidon.com

Independent System of Natural Gas Alexandroupolis


The project of the Independent System Natural Gas (ASFA) Alexandoupolis is a modern,
innovative and high-tech project that consists of a floating offshore receiving unit, storage and
regasification of Liquefied Natural Gas and a submarine system and onshore pipeline through
which gas is forwarded to the National System (Transport) Natural Gas (ESFA) and from there to
the

final

consumers.

The ASFA Alexandroupolis aims to create a fourth gas inlet gate in Greece, providing capacity to
of 6.1 billion cubic meters of gas annually and storage capacity of 170,000 cubic meters LNG gas.
This project was also recognized on November 21 as a project of European interest and is part of
the Front-End Engineering and Design program (FEED) co-financed from the resources of
Connecting Europe Facility (CEF).
(References 7, 17, 18, 19)

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Euro Asia Interconnector

Nikos Lygeros Presentation- Eclass

East Med Pipeline

http://www.defencegreece.com/index.php/2012/04/southeastern-mediterranean-hydrocarbons-a-new-energycorridor-for-the-eu/

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Greece leads Europe Energy Security for the next decades through the
existence of Methane Hydrate in Greek Economic Zone (EEZ)

Source: Praeg, D., Geletti, R., Wardell, N., Naziole, I. Sperimentale, G., Gigante, B. G., Migeon, S.
(2011). The Meditteranean Sea: A natural laboratory to study gas hydrate dynamics? Vikram
Unnithan, (Icgh).

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As you can observe from the maps above of the entire Mediterranean region the majority of the
possible recoverable methane hydrate deposits are in EEZ of Greece and in the Levantine Base in
Egypt. It is an opportunity for the exploration of Methane Hydrates for the European Union for
several reasons, including the following:

Change the European Energy mix to more environmentally friendly natural resources
through the decrease of the use coal and oil and an increase in the use of natural gas from
methane hydrate- Urban Development- Unlimited safe supply of natural gas to the
European industry.

Independence from Russian Natural Gas

Increase the geopolitical impact of the European Union through common defense and
energy policies[20]

Some facts about the European Union and Methane Hydrates that can be crucial for the future are:

Europe until the given date is confused and focuses its attention on internal affairs. This
can be catastrophic because if the EU wants to enter and explore the possibility of
extracting methane hydrates it is at best lagging 20 years behind the USA and 10 behind
Japan in terms of Technology, Research, Legislation and Geopolitical planning.

According to Japanese scientists that complete the first successful drilling operation on
methane hydrates this process will be commercially available in the next 6 years until 20182020. Our personal estimation is that within the next 3 years the process will be
commercially available. This hypothesis nevertheless explains the latest American
geopolitical actions and steps, such as the focus of American strategy in South East Asia,
maybe not only in China but also the possible commercially recovery of enormous methane
hydrate deposits (refer to the map above for the methane hydrate deposits). This situation
concludes that Europes geopolitical blindness will lead this historic place to being an
energy hostage by one of the major geopolitical actors.[20]

The main message is Greeces Exclusive Economic Zone can


become the key for European Energy Independence.

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Western Alliance for the exploration of Methane Hydrates, USA - Japan


Greece
We propose an alliance in scientific and cooperation level of these 3 countries as they possess
possible commercially recoverable methane hydrate deposits. Also, these countries have common
interests through this alliance, such as:

Energy Security

Increase of their GPD

Accomplishment of their Geopolitical Goals and Plans

Increase their competitiveness in their national industries through low-cost electricity

We also want to mention that Greece does not have the capabilities of the USA nor Japan but can
provide these countries with the opportunity to perform the first commercial drilling operations
within the Greek Exclusive Economic Zone due to the proximity of the Mediterranean Sea hence
making these specific operations safer. Moreover, the USA and Greece have as a common goal
the safe energy security of the European Union.[20]

Resources Technology

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Perfect
Geography

The geopolitical footprint of methane hydrates


If over the next 10 years and by 2020 the hydrates methane extraction technology becomes
commercially exploitable and extraction costs viable, geopolitical changes will be tectonic,
including:

Total independence of Japan by imports of natural gas, partly perhaps the independence of
China as well.

Gradual crowding from countries which produce conventional forms of hydrocarbons such
as Saudi Arabia and Qatar, but not Russia, which has several possible areas with existing
deposits of methane hydrates.

Future supply of the European Union's natural gas production from methane hydrates from
the Black Sea and the Southeast Mediterranean.

Increase of the geopolitical importance of the following areas due to the presence of
methane hydrates: Southeastern Mediterranean, Southeast Asia, the Black Sea, Caspian
Sea, North Sea and of course the seas around India which appear to contain large amounts
of methane hydrates.[20]

Through extraction of Methane Hydrate when it will be commercial possible in Greek EEZ, Greece
can involve all the major Geopolitical Players and their interests, more specific USA, Japan, China,
Russia and of course European Union.

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LNG Fuel Tanks- Transportation through train from Greece to Europe- New
adding value for Greek EEZ
As Nikos Lygeros present us in this article http://www.lygeros.org/articles.php?n=15854&l=gr
LNG technology evolves rapidly and in Greece we dont exploit this. The last decades in USA
they transfer fuel (Oil mainly) through train, so we dont transfer natural gas in LNG from Greece
to European Union Market.

Opportunity here

THE LNG VALUE CHAIN. (2014), (March).CHART

http://www.centreforenergy.com/AboutEnergy/ONG/LiquifiedNaturalGas/Overview.asp?page=1

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According to the article Natural Gas Trains & Trucks Coming Through from the
http://energyindepth.org/marcellus/natural-gas-trains-trucks-coming-through/

The

Canadian

National Railway is experimenting with natural gas as a train fuel, which involves adding a
liquefied natural gas tank behind the locomotive. The switch from diesel could save money. Photo:
Canadian National Railway/San Francisco Chronicle. (Observe the photo below)

http://energyindepth.org/marcellus/natural-gas-trains-trucks-coming-through/

The main message is why to use natural gas in fuel tanks


only for fuel for train transportation and not to add more
specialized ones wagons like the one of the photo above to
transport natural gas in LNG form.

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Through the implementation of the above strategy we adding value to Greek EEZ and economy,
some suggestions which can lead us to our target:

According to the Greek government privatization program we are going to privatize our
national train companies, if we are going to sell them then we must give them to a company
or state who has a lot of cash and with the ability to make a lots of investments in our train
infrastructures because if we want to implement the above strategy we want to change all
of train transportation system. The basic idea is to give them to the Chinese due to they
already possess Piraeus port and they want to deliver their product in Europe through train.
Recently and according to this article http://www.viadiplomacy.gr/h-kina-isvali-stavalkania-kineziki-ikonomiki-diplomatia/ Chinese will invest in Serbia rail way system, this
is a signal that they want to connect Greece with Europe through train through GreeceSkopia- Serbia and then to Europe. Also they have express their interest officially and
through the media that China want to invest in Greek train infrastructure. It is a great
opportunity for Greece to expand her strategic alliance with China, a rising geopolitical
player.

Secondly, the Greek state must force the private sector of Greece to involve in the
construction of these LNG Fuel Tanks and through cooperation with foreign companies
the Greek companies must learn and adopt the know-how of LNG Technology. This
strategy can give Greece new opportunities for growth and the ability to use LNG
Technology to public and private transportation and many other things.

According to the Nash theory, this article http://www.lygeros.org/0683-gr.html and the


suggestions of Nikos Lygeros from his presentations we conclude that to maximize the geopolitical
impact of the deceleration of Greek Exclusive Economic Zone we must:

Dont act individual in this issue because we will never succeeded alone

Every one of us share the idea of Greek EEZ and the benefits which derived from this
action to the Greek citizens

All of us must unite to complete this target, for that reason Nikos Lygeros promotes the
Signatures

favor

of

establishing

the

Greek

EEZ

in

this

site

http://www.ipetitions.com/petition/elliniki_aoz . From our point of view this is the first


step to pressure our political order to declare our beloved EEZ.

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Finally to achieve maximum geopolitical impact of the deceleration of Greek Exclusive


Economic Zone Greece must involve all the major Geopolitical Players and their interests,
more specific USA, Japan, China, Russia and of course European Union. Through our
suggestions we estimate that this assumption feasible.

We know we had extend the 10 pages but we want to give to any Greek individual citizen a small
Handbook- tool in case somebody wants to present to the other Greeks, in families, organizations
or friends the benefits for Greek nation which derived from the declaration of Greek EEZ.
In terms of logic we want the transaction from the Greek term vision to the real. (Observe the
photo below)

Greek Reality vs Global Reality

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References
[1] ( 2013).PDF. (n.d.).
[2] Area, B. (2014). NOTICE ANNOUNCING THE INTERNATIONAL CALL FOR TENDERS
FOR GRANTING AND USING, 711.
[3] Gas interconnection. (2013), 3.
[4] Nations, U. (n.d.). of International Cases on the Law of the Sea United Nations.
[5] Parliament, E. (2014). Notices from member states, 411.
[6] Republic, H., Environment, M. O. F., Change, C., Secretariat, G., Energy, F. O. R., Change,
C., Policy, P. (2012). FURTHER INFORMATION & GUIDANCE ON THE OPEN DOOR
INVITATION ( Government Gazette No 76 , Part B , 27 . 01 . 2012 ) for granting and using
authorizations for the exploration and exploitation of hydrocarbons ., (76), 118.
[7], . (2014). , (20).
[8] http://www.elzoni.gr/html/ent/984/ent.29984.asp
[9] http://www.onalert.gr/stories/aigaio-ola-osa-prepei-na-xeroume-gia-aoz-yfalokripida/33581
[10] http://www.iskra.gr/index.php?option=com_content&view=article&id=18244:2014-10-2515-20-38&catid=71:dr-kinitopoiisis&Itemid=278
[11]http://www.cyprus.gov.cy/moi/pio/pio.nsf/0/AB89462E00BC0F73C22575710025E69C?ope
ndocument
[12]http://www.ypeka.gr/Default.aspx?tabid=765&locale=en-US&language=el-GR
[13] http://www.ypeka.gr/Default.aspx?tabid=766&locale=en-US&language=el-GR
[14] http://www.pgs.com/Data_Library/Middle-East-and-Mediterranean/Greece/
[15] http://www.psg.deloitte.com/newslicensingrounds_gr_140819.asp
[16] http://www.ethnos.gr/article.asp?catid=22770&subid=2&pubid=64042549
[17] http://www.tap-ag.gr/

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[18] http://www.depa.gr/home.html
[19] http://www.gastrade.gr/
[20] Article Methane Hydrates: Fuel Of The Future As It Is Called, And The Geopolitical Footprint
In The Global Energy Map, By Athanasios Pitatzis, Hatziioannou, G. (2014). E n erg y I nter n
atio n al R is k A s s es s m ent, 2(12), 115.

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