Of the 23 Special Environmental Studies, which were meant to define land use in protected areas in Greece, only five have been approved, and none have been formally established through a Presidential Decree, as required.
The most crucial project for the protection of Greece’s natural environment—also a key developmental tool for the country—has been entangled in a maze of delays, lack of oversight from the central government, and setbacks in study implementation.
The 23 Special Environmental Studies (SES) were intended to regulate land use in Natura 2000 (or Φύση 2000) protected areas, specifying what is permitted, under what conditions, and what is prohibited. However, only five have been approved, and none have been formalized via a Presidential Decree.
As a result, Natura sites—which cover approximately 28% of Greece’s land and 18% of its seas—remain protected only on paper, lacking both environmental safeguards and a clear development framework.
The delay in drafting the SES also disrupts urban planning, which is currently underway in 80% of Greece’s territory. The integration of the Natura areas’ land-use regulations into spatial planning remains stalled, further complicating the process.
A 39-Year-Old Obligation
The requirement for a Special Environmental Study and a Presidential Decree for all protected areas was established 39 years ago under Law 1650/1986, a landmark environmental regulation. Since then, designation procedures have been repeatedly modified.
One of these changes allowed for the temporary issuance of Ministerial Decisions setting conditions, restrictions, and management measures for up to six years until the SES were completed. However, these decisions are now expiring in many areas (e.g., Gyaros, Axios), while the studies have yet to be finalized.
Natura 2000: Delays Since 2019
The 23 studies covering Greece’s 446 Natura 2000 sites were commissioned in March 2019 with a completion deadline of two and a half years. However, setbacks began almost immediately.
According to Giorgos Kotzageorgis, head of Enveco—the firm tasked with the technical and scientific coordination of the studies by the Ministry of Environment and Energy (MoEE)—the primary cause of delays was a legal amendment (Law 4685/2020), which introduced new requirements that were not included in the original scope of the studies, forcing a revision of ongoing work.
The law mandated that each of the four Natura protection zones be assigned specific land uses, ensuring clarity when the Presidential Decrees were issued. “This was a major shift, requiring new specifications and modifications to all ongoing contracts. Essentially, the process had to restart in spring 2022, almost two years later,” Kotzageorgis explained.
Subsequent delays were caused by the simultaneous submission of numerous deliverables, the slow response of MoEE services, delays by some consulting firms, and the sheer volume of requirements that could not be met within the tight deadlines.
“As supervisors, we must review study proposals at least three times—before public consultation, after revisions based on public feedback, and during final approval. This process alone takes at least six months,” Kotzageorgis noted. He estimated that all SES could be approved by the end of the year.
So far, five have been approved (Evros–Rhodope, Serres–Kilkis, Laconia–Messinia, Larissa–Magnesia, Karditsa–Trikala), while public consultation has concluded for 15 others. The remaining three are in progress, with two (Preveza–Arta and Aetolia-Acarnania–Achaia–Elis) set to be published soon, while the final one (covering Pella, Imathia, and Pieria, including Mount Grammos) is expected to face further delays.
Administrative and Legislative Hurdles
According to Petros Varelidis, General Secretary for Environment and Water at MoEE, delays stem from understaffing, difficulties in meeting deadlines, and repeated extensions to public consultation periods.
“These delays complicate matters further because, in the meantime, developments on the ground continue—new constructions, infrastructure projects, and regulatory changes—leading to additional setbacks,” Varelidis emphasized.
However, the biggest challenge may still lie ahead. Key institutional issues must be resolved before the Presidential Decrees can be finalized. A major obstacle is again Law 4685/2020, which assigned specific land uses to each Natura zone—some of which are considered impractical.
For example, the law bans swimming in three out of four zones, prohibits road, gas, and sewage networks in certain areas, and allows residential and hotel construction in stricter protection zones while limiting hotels in lower-protection zones. These inconsistencies sparked strong opposition during public consultations.
The rigid framework prevents experts from recommending the most appropriate land uses, forcing them to make exceptions in certain SES, which may lead to legal challenges during the final approval process.
Varelidis stressed the need for “legislative improvements, such as lifting the swimming ban in three of the four zones, allowing limited urban expansion in the fourth zone where justified by local urban plans, and granting conditional approval for certain activities based on ecological assessments.”
Ioli Christopoulou, Vice President of the Natura 2000 Committee, pointed out that despite progress in the studies, “without the Presidential Decrees to legally secure protected areas, the regulatory framework remains unclear. This means neither environmental protection nor sustainable development can be effectively implemented.”
She emphasized the urgency of finalizing the decrees to close a critical chapter and ensure effective management of Greece’s natural environment. After all, Greece has already faced condemnation by the European Court of Justice in 2000 for failing to designate Special Areas of Conservation, eight years after the deadline.