To the Government and Political Parties

From Network for Sustainable Cyclades

Subject: The Cyclades will not get the Local Urban Plans they deserve. The compass of public interest is sought

The Network for Sustainable Cyclades is closely following the largest urban planning operation in the country through the preparation of local urban plans (LUPs). The way the government has chosen to implement the spatial plans is not in line with the spirit of the Constitution on public policies and the public interest.

Until today, Greece has had very few comprehensive and clear urban and spatial plans. This long-standing lag has allowed arbitrariness, illegality, transaction and clientelism to continue, both with the construction industry and with citizens, and has bred the “reluctance” of the state to organise the necessary infrastructure within the urban fabric, as is the case in every civilised country. The unfortunate consequences of serious deficiencies in spatial planning for decades are already evident in both urban and peri-urban and rural areas of our country.

About three years ago we learned that a project was being organized to prepare Urban Plans throughout the country, supported by significant European funds from the Recovery Fund. And while all sane citizens were waiting with interest for these plans to bring the necessary order, which becomes even more urgent due to the upcoming climate crisis, in the process we are finding serious inconsistencies and omissions.

Spatial planning, moving forward

• without the necessary discussion with the local communities about “what development we have – what development we want” so that the teams preparing these studies have an idea of what the citizens want and try to plan it in the best possible way. Thus the exercise degenerates into ‘what is built, where it is built, who benefits and who is harmed’, and in many cases it is clear that there are interventions to serve middle and especially large interests.
• without the completion of the overlying Special Spatial Plans such as those of Tourism, RES, Industry, which when completed will have a decisive impact on the TSPs
• without having completed the Regional Spatial Planning Framework of the South Aegean Region
• without having completed the designation of the roads, which will also overturn any plan, good or bad, that is drawn up, since the designation will change the buildability of the areas outside the settlements.
• without having completed the Special Environmental Studies for the protected areas (Natura), which cover 30% of the country’s territory and which at this stage constitute “holes” in the planning of the area.
• without having abolished the strategic investments, complex accommodation and private urban planning that are decided at government level and imposed on the “lucky” places as “developmental mana from heaven”, while these are speculative investments with few positive and many negative consequences for the places, since they are treated as places of profitable investments and not as places of life, as requested by both the mayors of the islands in a recent resolution of the Aegean Regional Council and citizens’ organizations.
• without a clear and scientifically documented methodology for the Carrying Capacity (CF), while it does not necessarily link the ESRFI that the designers undertook to prepare with delay to the scenarios being prepared, so that even in cases where the designers’ data show a clear excess of the limits set by the Ministry of Environment itself, it is not taken into account in the preparation of the scenarios that have already been pre-decided.
• without having suspended the implementation and issuance of new off-site building permits that continue to be issued in droves on the islands, usually in violation of the case law of the Council of State and despite the problems they create for the sustainability of the country (as documented by the relevant report of the Ombudsman), making visible the risk of complete alteration of the islands until the IDs for the new TPAs are issued.
• Without sufficient time to inform local communities in all phases of the preparation of the TAPs with the Damocles’ sword of their withdrawal from the TAA, which expires in 2026, and their delay is entirely due to mismanagement. It is worth noting that the TPAs for Thera and Mykonos, announced as being of national interest by the Prime Minister himself in 2020 and presented only in 2024, are yet to be completed. It is also worth mentioning that the five-day time given for the supposed “consultation” after each presentation of the initial scenarios is unacceptably pushy and far from constituting an opportunity for meaningful consultation, or, much less, “Participatory Planning” as the science of Spatial Planning requires.

The combination of all the above, unfortunately, does not allow us to expect that the completion of the process will yield urban plans that will enhance the sustainability and resilience of the islands and will adequately respond to the accumulated needs, which are becoming even more critical due to the advance of the Climate Crisis, while at the same time it raises questions as to whether it responds to the constitutional requirement for spatial planning with scientific criteria that serves the public interest.

As the Network for Sustainable Cyclades, which is firmly focused on the need to ensure the sustainability and resilience of the Cycladic Islands, insisting on the necessity of protecting the special and particularly sensitive Cycladic identity and the special geophysical and ecological harmony of the islands, we stress once again the following as highly necessary:

• Carrying capacity studies with a commonly accepted methodology for all islands, the results of which must be taken into account in the proposed scenarios.
• Preparation of a roadmap for the transition to a sustainable island development model
• Protection of agricultural and rural land. Inventory of agricultural and livestock land and creation of new land with incentives to support the sector.
• Substantial restriction of building outside the settlement. Consistent application of the Presidential Decree of 1985 (Presidential Decree 24/5/85, Government Gazette 270/D-1985) and the relevant recent case law of the Council of State (Council of State decision 176/2023, etc.)
• Abolition of legislation that allows (and even encourages with special building allowances) the construction of underground buildings on islands and areas that have no tradition of underground buildings and whose soil is totally unsuitable for such interventions.
• Exclusion of tourist accommodation from the strategic investment regime. Abolition of the Composite Tourist Accommodation and the NSHASE and NSHADA which were imposed as a solution during the memorandum era.
• Change in the tourism model by abolishing the tourist accommodation that has at the same time water elements for bathing of any kind (excluding spas) – Ban on the construction of swimming pools and water elements (except for hotels)[1].
• Qualitative upgrading of the tourist product instead of quantitative growth, limitation of the creation of new tourist beds (or even prohibition on islands already saturated with tourism) with upgrading of the existing ones. Strengthening other economic sectors to enhance the economic performance and resilience of the islands.

In particular, and taking into account

Α. The constitutional imperative and the laws concerning the protection of the natural and cultural landscape, (Constitution article 24 par. 1 and 6, law 1650/1986, PD 2012/2003, etc.)

Β. The serious risks due to the climate crisis that is expected to affect the islands in particular, both with flooding and further erosion and increased drought (and therefore further deterioration of water scarcity)

Γ. The fact that in parallel with spatial planning, the process of mapping the rural road network is proceeding,

we highlight the following points on which spatial planning should provide for a number of interventions concerning:

• Streams, rivers, torrents: The frequent phenomenon that we are already witnessing on the islands with the conversion of streams into roads (both inside and outside settlements) must not only be stopped, but provision must be made for its reversal with provision for the uncovering of streams. Sections of streams that run through settlements should be delineated across their full flood width, both in the delineated settlements and in areas to be delineated.
• Dry stone structures and terraces: They are an integral feature of the Cycladic landscape and are officially recognized both for their monumental value and for their modern necessary functionality as green infrastructure, critical for protection from erosion, flooding and waterlogging. It is necessary to register them for protection purposes, to strictly prohibit their destruction and to allow for the gradual restoration of their functionality where it has already been weakened.
• Traditional paths. The paths that historically connected settlements and other points of interest on the islands, ran through the countryside, creating a complete network. Much of this network has already been destroyed or turned into dirt roads. The remaining ones should be recorded and preserved as monuments and under no circumstances should they be recognised as building roads. No right to side building on rural roads and footpaths except on the main municipal road linking settlements in accordance with existing legislation (the adjacent uses will be defined accordingly by the urban plan).
• Traditional rural buildings: Rural cottage buildings and technical works, despite their critical connection with the identity and physiognomy of the Cyclades, and the existence of many legal instruments for their protection, remain exposed to various violations of their form and function. The spatial plans for the Cycladic islands should include specific provisions for their effective protection.

We ask the Government to immediately take all the corrective steps necessary to reverse the course that creates conditions of irreversible loss of the identity of the Cyclades.

The Network for Sustainable Cyclades

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[1] The South Aegean islands are already facing significant water scarcity problems. It is estimated that the coverage of the water supply needs of the Aegean Islands through desalination is in the order of 10%. It is noted that the percentage of desalination is constantly increasing as the underground aquifers of the islands are being depleted and new desalination plants are being built, placing an economic and environmental burden on the local community. Desalination is insufficient and water is transported by ship. The cost of transporting water reaches 12 million per year and the environmental cost of transport is enormous. Importantly, many settlements are not covered by drinking water. (MOEP 2022)