The environmental organizations ANIMA, ARCTUROS, ARCHELON, the Society for the Environment and Cultural Heritage, the Hellenic Society for the Protection of Nature, the Hellenic Ornithological Society, the Society for the Protection of Prespa, Callisto, iSea, MEDASSET, MedINA, and WWF Greece submitted the following joint comment to the public consultation on the Ministry of Environment and Energy draft bill regarding proposed urban development within protected areas and the horizontal regulation of certain activities:
The Ministry’s proposal to allow the expansion of settlements and urban plans within zones of sustainable natural resource management in Natura 2000 areas is highly problematic and poses serious risks to the integrity of protected areas under the guise of urban planning.
The requirement set out in the draft bill for compatibility between urban development expansions and the Special Environmental Studies (SES), which define protection measures and zoning, is superficial: the SES have not examined urban planning issues, nor have they assessed or addressed their impacts. In fact, the SES and urban plans are being completed without any substantial effort toward alignment; therefore, updating the already delayed SES at this stage would result in further delays and, inevitably, in rushed and contradictory solutions.
Furthermore, the proposed upper limit of 20% for urban development within zones of sustainable natural resource management is not substantiated, may apply to extensive areas, is not linked to key urban planning parameters, and cannot be adequately determined through the SES.
Regarding the regulation of activities, the draft bill proposes that certain activities be permitted horizontally across all protection zones and potentially subject to restrictions or prohibitions. Such broadly permitted uses are problematic, especially in zones of strict protection. Archaeological excavations or large-scale construction interventions are not compatible with undisturbed natural areas of strict protection, particularly when these areas are not even designated as archaeological sites, and such interventions should instead be specifically regulated through presidential decrees. Proposed interventions for civil protection purposes are already covered by existing legislation and do not require such provisions, while related prevention or restoration actions are already accommodated under generally permitted management and restoration activities. Even certain low-impact activities involving equipment transport or having significant effects should be restricted or even prohibited in strictly protected zones.
For these reasons, we call on the Ministry of Environment and Energy to fundamentally revise the proposed provisions by including:
- An explicit prohibition of urban development within protected areas, allowing only exceptional derogations strictly for overriding public interest and only where no alternative locations exist.
- An explicit prohibition of urban expansion for commercial, tourism, and industrial uses.
- A clear methodology justifying the necessity of such interventions, linked to urban planning parameters, without vague formulations or horizontal percentage thresholds.
- A binding and substantive appropriate assessment, including a full analysis of cumulative impacts prior to any Local Urban Plan provisions.
- An explicit provision that, in all zones and across all Natura areas (regardless of their designation stage and the establishment of protection measures), the legalization of illegal constructions is prohibited, as is the expansion of settlements for the purpose of legitimizing unlawful building.
- A clear prioritization of activities based on the level of protection of each zone, with stricter and more restrictive approaches for zones of strict nature protection and further specification of terms in other zones.
Co-signing organizations:
1. ANIMA
2. ARCTUROS
3. ARCHELON
4. Hellenic Society for the Environment and Cultural Heritage
5. Hellenic Society for the Protection of Nature
6. Hellenic Ornithological Society
7. Society for the Protection of Prespa
8. Kallisto
9. iSea
10. MEDASSET
11. MedINA
12. WWF Greece