The Confederation of Greek Tourism Accommodation Entrepreneurs (SETKE), representing thousands of small and medium-sized non-mainstream hotel accommodation businesses throughout the country, particularly in island and remote areas, submits comments on the draft Joint Ministerial Decision under consultation regarding the Special Spatial Framework for Tourism.
The proposals were submitted in a letter from SETKE addressed to the General Secretariat for Spatial Planning and Urban Environment of the Ministry of Environment and Energy.
As noted in this regard, first and foremost, we view positively the effort to establish a modern and comprehensive spatial planning framework for tourism, as well as the need to address the consequences of overtourism and unregulated tourism development in overburdened areas of the country.
In this context, we agree with the new plan regarding the need to reduce capacity (beds). In particular, we view positively the provision for a maximum limit of 100 beds in Category A areas (controlled development) and 300 beds in Category B (developed areas), as a measure to curb the overconcentration of large tourist facilities and protect the carrying capacity of destinations.
Furthermore, for areas designated as oversaturated, we consider it absolutely necessary to immediately suspend all new tourism activity until basic public infrastructure (water supply, sewage, waste management, road networks, energy infrastructure, healthcare facilities, etc.). Overtourism does not affect individual areas in isolation, but impacts the overall functioning, sustainability, and social cohesion of entire island destinations, which must maintain a unified character and balance between tourism development and the daily lives of permanent residents.
Consequently, we believe that an exception to the above suspension should be provided exclusively for primary and non-primary hotel accommodations that have already been approved or included in existing investment or subsidized programs. At the same time, we propose suspending the issuance of new subsidized programs for the construction of new tourist accommodations in saturated areas until local authorities complete the upgrading of the necessary infrastructure.
However, the provisions of Article 8(3) of the draft, which concern non-primary hotel accommodations built under residential building regulations, are considered particularly problematic.
Specifically, the provision in Article 8, paragraph 3a, which states that:
“the permitted number of beds in non-primary hotel accommodations built under residential building regulations shall not exceed the permitted number of beds in primary hotel accommodations”
This effectively imposes a restriction on the creation of new rental rooms and apartments, without providing sufficient technical or scientific justification regarding the necessity and proportionality of the measure.
This regulation is likely to have serious and disproportionate consequences, particularly on small islands and in remote areas of the country, where non-mainstream hotel accommodations have traditionally been the primary form of tourism activity and where, in many cases, the capacity of private rooms for rent exceeds that of hotels. Imposing restrictions exclusively on non-hotel accommodations risks leading to a decline in small family-run businesses and a further concentration of tourism activity in large hotel complexes.
On many small islands, particularly in the South Aegean, non-mainstream hotel accommodations account for approximately 90% of the tourism supply. These provide a supplementary income for permanent residents, encouraging them to remain in their communities and preventing the depopulation of island and remote areas.
For these reasons, it is deemed appropriate not only to repeal Article 8, paragraph 3a, but also to set clear limits on the development of large hotel complexes on small islands and in remote mainland areas. The establishment of hotel facilities, for example with 300 beds or even 100 beds, can create conditions of unfair competition and jeopardize the sustainability of local communities.
It is therefore proposed to establish a maximum capacity limit of 50 beds for the construction of new hotel facilities on small islands. This measure will help maintain social cohesion, strengthen the local economy, and ensure a sustainable balance between tourism development and the quality of life for permanent residents.
Equally problematic is the provision of paragraph 3b of Article 8, according to which:
“the creation of different Furnished Rooms and Apartments for Rent (FRAR) businesses within the same building shall not be permitted.”
The above provision is in direct conflict with the current Ministerial Decision 12868/2018 (Government Gazette B’ 3119/July 31, 2018) regarding the technical and operational specifications of EEDD, which explicitly provides in Article 2, paragraph 2.2 that:
“It is possible to establish different EEDD enterprises within the same building.”
Consequently, the proposed plan abruptly overturns the existing regulatory framework, affects existing family-owned and co-owned business structures, and introduces a restriction that is not directly linked to spatial planning or urban development considerations, but rather to the business organization of the accommodations.
Small and medium-sized tourism accommodation businesses are a key pillar of the Greek periphery, insularity, and sustainable tourism development, and for this reason we urgently call for a review of the above provisions, with the aim of establishing a balanced spatial planning framework that will protect both the carrying capacity of destinations and the sustainability of small local businesses.