Submitted by:
 
- ARCHELON, the Sea Turtle Protection Society of Greece
- Hellenic Ornithological Society
- Hellenic Society for the Protection of Nature
- Hellenic Society for the Protection of the Environment & Cultural Heritage
- Mediterranean S.O.S. Network
- MOm – Hellenic Society for the Study and Protection of the Monk Seal
- WWF Greece
 
May 2005

REPORT ON THE STATUS OF THE PROTECTED AREAS SYSTEM IN GREECE
 
Introduction

This brief report aims to summarize the present status of the protected areas system in Greece. It has been compiled by a group of seven Greek NGOs active in nature conservation, both at a national and local level: Archelon, Hellenic Ornithological Society, Hellenic Society for the Protection of Nature, Hellenic Society for the Protection of the Environment and Cultural Heritage, Mediterranean SOS Network, MOm, and WWF Greece. The majority of issues addressed in this report have already been shared with the competent national authorities at all levels. A detailed evaluation of the protected areas system has already been carried out and was submitted to the national authorities in September 20041. Unfortunately, it has not been possible to draw the attention of the competent authorities to the gravity of the situation. A series of joint letters sent to the Ministry of Environment, Physical Planning and Public Works (hereafter referred to as MEPPPW) and the prime minister’s office have remained unanswered. 

Having failed to elicit a meaningful response from the national government, we now call on the European Commission to consider the information presented here. Taking into account the clearly European context of the issue and the overriding importance of the Habitats Directive for the conservation of nature in Europe, we furthermore urge the European Commission to take all necessary steps within its jurisdiction to press for substantial improvement of the status of the protected areas system in Greece.   

Main problems

a. Deterioration of the conservation status of Natura 2000 sites in Greece

The general lack of both site-specific and crosscutting measures for SPAs and pSCIs has diminished the value of protected areas in Greece and caused a deterioration of their conservation status. 

Greece has proposed so far 151 Special Protection Areas (SPAs) under the Birds Directive and 239 Sites of Community Importance (SCIs) under the Habitats Directive. Pursuant to Article 6(2) of the Habitats Directive member-states are required to “take appropriate steps to avoid, in the Special Areas of Conservation, the deterioration of natural habitats and the habitats of species as well as disturbances of the species for which the areas have been designated”. Therefore, Greece has to take measures to ensure that no significant deterioration or disturbance occurs in the Natura 2000 sites. These measures are of an anticipatory nature and go beyond the simple management measures necessary to ensure conservation. 

In accordance to the aforementioned rationale, it is not acceptable to wait for deterioration or disturbances to occur before taking measures. Additionally, and specifically for the SPAs, “…Member States shall take appropriate steps to avoid pollution or deterioration of habitats or any disturbances affecting the birds, in so far as these would be significant having regard to the objectives of this Article…” (Directive 79/409/EEC, Article 4(4)).

As the Commission is already aware, 27 management bodies were established in Greece in 2002-2003. In accordance to Greek legislation (Law 2742/99), these bodies have the responsibility to manage their respective protected areas. However, they lack both the funds and the political support to become operational. Moreover, with the exception of five sites, all the other protected areas where management bodies have been set up, continue to lack a clear delineation of boundaries and zoning system with approved measures for each zone. 

It is worth noting that even if these fundamental problems had been overcome and management was effective, the above management bodies would cover only 20% of both the pSCIs and SPAs. To the best of our knowledge, there is presently no plan to address the management of the remaining 80% of the pSCIs and SPAs.

In the meanwhile, the absence of both on-site management and cross-cutting decisions has resulted in the deterioration of the conservation status of the Natura 2000 sites. A series of case studies briefly described in Annex A will further support this statement.

b. Lack of overall planning and programming

Despite the clear obligations stipulated in the Habitats Directive, Greece continues to lack an overall framework or binding policy for nature conservation. 

Environmental integration is still in a rudimentary stage and Greece lacks a national strategy on the conservation of the natural environment that would allow for the better organisation of a national system of protected areas. Two relevant documents, the national strategy on wetland resources and the national strategy for sustainable development, have never been officially endorsed or gazetted nor, of course, have they been implemented. 

Under Greek Law 2742/99, a National Committee of Protected Areas, called PHYSI (=NATURE), was established in 2003 with the mandate to coordinate, supervise and evaluate the processes of programming, organising and operating the national system of protected areas. With respect to the Habitats Directive, the PHYSI committee has the responsibility to formulate management guidelines for the Natura 2000 network, to propose conservation measures and assist in their implementation, and also to monitor the work of the management bodies of the protected areas (MD 33318/3028/98, Gazette 1289Β/ 1998). Despite the commitment of many of its members, the PHYSI committee has been basically unable to fulfil its mission since it did not have the necessary funding, the appropriate staff or the administrative support that would allow it to work effectively. Its president resigned in April 2004 and has not been replaced - the committee has remained inactive ever since. Uncertainties remain regarding its legal and funding status, both responsibilities of the Ministry of Environment, Physical Planning and Public Works. It is not even clear whether the MEPPPW wishes to reactivate this committee or phase it out. Therefore, at present, this national body established under national legislation with the paramount responsibility of coordinating, supervising and evaluating the national system of protected areas, is for all effective purposes, non-existent. This significant gap has not been covered by any other public body or structure. 

Finally, while Natura 2000 designation offers a framework for legal protection, in order to achieve nature conservation and effectively pursue local sustainable development initiatives, it is clear that specific national legislation must be enacted, with zoning and land use regulations for each protected area. This too, is seriously lacking. While Greece has proposed 20.99% of the Greek territory for inclusion in the Natura 2000 network, currently, only a small portion is actually under such a comprehensive legal protection status. As was mentioned earlier, even within the restricted sample of protected areas with management bodies, only 5 sites are actually designated with a Presidential Decree or a Joint Ministerial Decision! The majority of Special Environmental Studies (funded largely by the European Commission) remain with the competent authorities and have not yet been transposed into Greek legislation.  

c. Insufficient funding

There is a general lack of adequate funding for the conservation needs of protected areas at both a strategic/planning and a local level. 

The Greek government has been unwilling to allocate sufficient funds to the conservation needs of its protected areas, and during the last year it has also been reluctant, if not openly negative, to actually fulfil what limited funding commitments had been made in the past. While Greece has utilised a variety of European funding sources (Structural Funds, Cohesion Fund, INTERREG, Leader, LIFE) for the conservation and management of the Natura 2000 network, the overall allocated budget has been minimal. 

The 3rd Community Support Framework (CSF) has been one of the basic funding sources for the environment – in Greece, only a disappointing 1.8% of the total CSF budget has been allocated to related activities. Within the 3rd CSF, the conservation needs of protected areas are primarily linked to the Operational Programme for the Environment (OP Environment) of the MEPPPW. Sites without a management body (i.e. 80% of the present Natura 2000 sites in Greece) are not eligible for funding from the OP Environment. 

According to the plans set out roughly two years ago by the MEPPPW, each protected area with a management body was initially proposed to receive a maximum of 1,500,000€ for the period 2003-2006. However, it was decided that the largest percentage of this amount was to be directed to local authorities, mainly for infrastructure works inside the protected areas. Hence each management body was to receive up to 563,000€ following the submission of proposals to the MEPPPW. Of this, the amount of 210,000€ was to cover the operational costs of the management body for 3 years. The remaining 353,000€ was to be used for management measures, however, not including as eligible costs the preparation of monitoring, wardening plans and the elaboration of a business plan for the management body. These last tasks were to be handled nationally for all protected areas but are still pending. Additionally, each management body was to receive 15,000 – 25,000€ as ‘start-up’ funding from national sources. To date, this has been the only funding from national sources that has been dispersed.

Perhaps the best way to describe the inadequacy of the abovementioned figures is to compare them to the national estimates on the funding needs of the Natura 2000 sites (article 8 of the Habitats Directive). Greece estimated that for the period 2003-2012 the management of the Natura 2000 sites will require 2,021,500,000€2.  In other words, the annual funding needs for the management of the Natura 2000 network in Greece were in the order of 200,000,000€. As it stands, the OP for the Environment foresees a total of only 54,880,000€ for the 3-year period (2003-2006). During a recent revision of the OP Environment, the MEPPPW proposed a further reduction of this budget that was opposed by the NGOs and fortunately not endorsed by the European Commission.    

However, the Ministry of Environment, Physical Planning and Public Works has failed so far to provide even these limited funds. The management bodies submitted their funding proposals in December 2003, following the relevant call of OP Environment (measure 8.1). At the same time, the majority of the management bodies had also submitted for approval their operational regulations (4 for each management body), based on blueprints provided by the MEPPPW. They should be approved and ratified by the MEPPPW in order for the management bodies to be eligible to receive funding from the OP Environment. 

According to information provided by the MEPPPW3 only 70, out of a total of 108, operational regulations have been approved, even though it has been almost 2 years after the establishment of the management bodies. Additionally, the majority of the regulations (52 out of 70) were approved after December 2004, 9 months after the change of government. For many of the management bodies (e.g. of the National Marine Park of Sporades, National Parks of Pindos, Dadia, etc) the regulation on personnel and administration issues has still not been approved. As a result these management bodies cannot employ people and thus implement wardening, monitoring or any other activities. Additionally, the members of the management bodies are considered to be in abeyance since August 2004 and have been therefore informed by the MEPPPW not to take any decisions that may prejudice the future members of the management bodies. 

The inertia, if not negligence, of the MEPPPW has resulted in an exceptionally low absorption rate of the measure 8.1 (7.26%, in November 2004) of the Operational Programme of the Environment. On top of that, the MEPPPW has repeatedly denied its responsibilities, and even accused the management bodies of being the cause of the problem4. The MEPPPW has also tried to use this low absorption rate as an excuse to contemplate further cutbacks to the overall budget.

d. Lack of political will and interest continues

In 2002, the environmental NGOs submitted to the MEPPPW specific priorities for actions regarding the conservation and management of protected areas. These proposals remain pertinent as the majority of issues remain unresolved (e.g. national strategy, provisions to avoid deterioration of conservation status, adequate funding). Additionally, even the small steps towards improvement of conservation and management (e.g. establishment of the PHYSI Committee, management bodies) are in effect being cancelled.

During the past few months, both the management bodies of protected areas and the environmental NGOs have been trying to alert the MEPPPW to the worrying situation of the protected areas. Some of the common activities of the environmental NGOs include: a Position Paper on February 2002, an open letter to the new administration of the MEPPPW (May 2004), a letter to the Minister of Environment, Physical Planning and Public Works, Mr G. Souflias, copied to the prime minister (November 2004), a second letter to the Minister of Environment Physical Planning and Public Works (December 2004), a press release (April 2005), and a letter to the prime minister (April 2005). Our efforts have been met by persistent silence. The Minister of Environment, Physical Planning and Public Works has not responded to any letters, and has not agreed to meet the presidents of the management bodies or any representatives of the NGOs. The Deputy Minister of Environment, Mr St. Kalogiannis, has been more cooperative but his jurisdiction and decision power are limited. Additionally, the activities and initiatives of the responsible services within the MEPPPW depend also on the political will of the minister.

In this context, the particular case of Zakynthos deserves further attention as a reflection of the level and quality of interest on the side of the MEPPPW. Following a barrage of complaints from NGOs, concerned citizens throughout Europe and the management body, the MEPPPW finally decided to offer the management body 90,000€ to cover only a very small portion of its debts, namely those to the national insurance fund, but not outstanding wages and salaries. Following the submission of a legal suit against the MEPPPW by the management body, the Minister G. Souflias responded by removing the president of the management body and appointing a new one, closely related to a local family which owns illegal buildings in the nesting area at Daphni and regarding whom there have already been press reports.

The situation has reached an alarming point. Due to the complete indifference of the responsible Minister of Environment, Physical Planning and Public Works to matters concerning the natural environment, the Natura 2000 sites are gradually deteriorating, the Habitats Directive is being seriously undermined, funding is both insufficient and blocked, and the management bodies of the protected areas have been left on a limb.   

Conclusions

Taking into account the clear responsibilities of Greece vis a vis the implementation of the Habitats Directive, the seven NGOs signing this report, identify a series of issues that are of great concern. These can be summarized as follows:

1. In the absence of effective conservation measures for the Natura 2000 sites, we are already witnessing a severe deterioration of the conservation status of specific sites. 

2. At a national level, planning for protected areas is extremely problematic, with the National Committee for Protected Areas (PHYSI Committee) left inert and no clear strategy for the protected areas system in sight.

3. The management bodies established in 2003, have stopped operating for lack of political and financial support. 

4. Even if the management bodies were to operate effectively in the future, they will only cover 20% of the proposed pSCIs and SPAs.  

5. While Greece has proposed 20.99% of the Greek territory for inclusion in the Natura 2000 network, currently, only a very small portion of it is actually under a comprehensive legal protection status with associated zonation systems and effective land use regulations in place.  

6. Funding for the protected areas is extremely limited – what little funds exist, are being badly managed with very poor results.

7. There is a clear lack of political will and interest on this issue, despite repeated efforts on the side of the NGOs and the management bodies to sensitise the responsible political leadership.   

Unless the above mentioned issues are resolved, it is clear that the Habitats Directive will fail to be implemented in Greece. 

We are convinced that the role of the European Commission is critical in bringing about change. The current status and main problems of the Natura 2000 sites have been presented in this report. What is needed now is the political will on behalf of the MEPPPW to reverse this totally unacceptable situation. 
 
For additional information please contact:
D. Karavellas,  d.karavellas@wwf.gr,  WWF Greece
M. Gaethlich,  hspn@hol.gr, Hellenic Society for the Protection of Nature 
D. Dimopoulos,  dimopoulos@ellinikietairia.gr, Hellenic Society for the Protection of the Environment & Cultural Heritage 
X. Kappas, xkappas@ornithologiki.gr, Hellenic Ornithological Society.

(1) Assessment of the Greek Protected Areas system: from theory to practice, WWF Greece, September 2004.

(2) Data from the Final Report on Financing Natura 2000, Working Group on Article 8 of the Habitats Directive, November 2002

(3) See table posted in the MEPPPW website http://www.minenv.gr/1/12/121/12103/foris_diaxirisis/237n.p.pdf and Press Release of 28 April, 2005.

(4) See Press Releases of 21 March, and 4 April 2005, and also the interview of Deputy Minister S. Kalogiannis at Kathimerini newspaper (OIKO - March 2005)

Annex A

Case studies 

1. The case of Zakynthos

The management body of the National Marine Park of Zakynthos was forced to stop its operation in April 2004, for lack of funding. The last nesting period (May-October 2004) was the first time, since the summer of 2000 that no protective measures were implemented. 

As a result of the absence of the management body, a series of illegal activities took place throughout the course of the summer. These have been reported to the Ministry of Environment, Physical Planning and Public Works in detail and can be summarized as follows: 

• Extensive horse riding on the nesting beaches

• Cars and motorbikes passing through nesting beaches

• Visitors on the nesting beaches during the night, at critical nesting times

• Destruction and removal of information panels 

• Illegal constructions throughout the area of the marine park

• Violations of the marine regulations concerning maximum vessel speed and presence of vessels in restricted zones

• Excessive number of umbrellas and sunbeds on the nesting beaches

2. Koronia – a lake that cannot wait 

Lake Koronia, together with lake Volvi and the Redina gorge, is a Natura 2000 site and a Ramsar wetland. The qualitative and quantitative problems of the water of the lake Koronia are well known. The dramatic decrease of its level during the late 80s and the 90s supported by the increased pollution created the conditions which allowed the occurrence of epizootic outbreaks which led to mass deaths of fish in September 1995 followed by mass deaths of birds. In the summer of 2002 the lake completely dried up. In August – September 2005 there was a second case of mass deaths of birds with thousands of dead waterbirds, among which more than 250 Dalmatian Pelicans, a globally threatened species. Botulism was identified as the cause of this incident. The main factors which are known to contribute to the occurrence of botulism are organic pollution, decomposing vegetation, dramatic water level fluctuations and high ambient temperatures. According to very recent data (23/03 – 01/04/2005) of the Department of Biology of the University of Thessaloniki that have reached the press the lake is once again in a very bad state. The phytoplankton biomass is extremely high while the zooplankton is almost extinct. Also, the pH is very high and the dissolved oxygen very low. The data shows that it is highly probable that we will face a new lethal incident during the next months especially when the temperature will rise and the water level will be at its lowest. In the meantime:

• Very little progress has been made in the almost ten years since the first incident of mass deaths. 

• Progress so far involves conferences, studies and plans, as well as some key legislation (Joint Ministerial Decision for the establishment of a National Park). 

• There is an urgent need for the implementation of measures that require sufficient funding, good planning and, above all, political will. 

• But the management body of the National Park of lakes Koronia and Volvi has no personnel, very few funds. Its administrative board is partly working since the resignation of its president one year ago.

• Most of the studies, plans and political decisions focus on construction works and infrastructure while it is a common knowledge that strong political will is needed to deal with the main causes, i.e. the irrational industrial and agricultural development of the area.

Degradation: its neither habitat nor site-specific!

• Forest fires remain a very widespread problem on both mainland Greece and the islands. In the last few years, despite some improvement, many proposed SCIs, as well as SPAs have been negatively impacted by this threat. With the approach of summer, a period of heightened risk of forest fires, several protected areas are in danger, notably the National Parks (NP) of Parnitha, Sounion, Parnon and Aenos.

• Illegal shooting and hunting are threatening and causing disturbance to protected wildlife species in many Natura 2000 sites such as in Kotichi, Amvrakikos, Evros Delta, Pindos NP and the Strofadia islands (within the area of Zakynthos NP). 

• Pressure caused by house-building activity within protected areas, is becoming an increasingly serious problem, particularly in the wetlands of Messolonghi, and in mountain areas in Parnassos NP, Sounion NP, Menalo and Taigetos. Several ski resorts are currently expanding their installations, thus encroaching on protected areas (Mounts Kaimaktsalan and Falakro) and new ones have been built (Mount Pieria), or are planned for the future (Mount Olympus). 

• Car racing on forest and mountain roads is causing serious disturbance within Oiti NP and Kallidromo pSCI, and there has also been a case of a four-wheel vehicle test drive in the Korision sand dune area (southern Corfu). 

• Many wetlands are threatened or degraded by changes in their hydrological regime (Kerkini Lake) and Minister Souflias has recently declared openly that he is prepared to go ahead with the Acheloos river diversion despite the latest ruling of the Greek Council of State. In addition, parts of the Amvrakikos and Magnesia wetlands have been filled in with rubble in order to create land for development. 

• Pollution in many Greek rivers such as the Axios, Pinios and Evrotas, has reached high levels and is thus threatening their ecosystems. Last but not least, certain priority species of the Directive 92/43/EEC, such as the Milos Viper (Macrovipera schweizeri) and the Loggerhead Sea Turtle (Caretta caretta) are not being adequately protected and their survival is in jeopardy.

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