As part of the public consultation process, SETE submitted its positions and comments on the draft Joint Ministerial Decision for the new Special Spatial Framework for Tourism (SSF-T) to the Ministries of Environment and Energy and Tourism. The key points are summarized below:
The Association has consistently participated actively in the public consultation on the Special Spatial Framework for Tourism, submitting numerous positions and proposals. Planning must be fundamentally strategic, and horizontal regulations should be avoided, especially given the binding nature of the Special Spatial Frameworks vis-à-vis the Underlying Planning, as they lead to generalized and simplistic solutions without taking into account the specific characteristics and development dynamics of regions.
Although the proposed plan has weaknesses, some of which we mention below, we consider the institutionalization of the ECP-T after decades to be an entirely positive development, so that, together with the Subject Planning currently being finalized, it may form the basis for environmental protection and the necessary legal certainty for new investments.
SETE has expressed its opposition to the blanket adoption of generalized horizontal restrictions. The specific proposals submitted regarding the draft Joint Ministerial Decision “Special Spatial Framework for Tourism” (SPF-T) aim to establish a more functional, practical, and sustainable spatial planning framework for tourism that takes into account local characteristics, existing public infrastructure—including public networks, airports, ports, marinas, and the availability of natural resources, in conjunction with the already established dynamics of the tourism market and the potential—or lack thereof—for further development of high-quality tourism infrastructure across all categories.
Tourism is an activity whose benefits are felt throughout society, in the strengthening of the primary and secondary sectors, in employment, and especially in regional development. Especially for island and mountainous Greece, it may be the only avenue for development and a prospect for employment and population retention.
Specifically regarding the prospects for tourism development in the island regions, the proposed grouping is not considered entirely appropriate. There are small islands where even a capacity of 100 beds may be considered large in relation to various factors, and there are islands—especially in Group (I)—where the proposed restrictions are unsustainable and uncompetitive, whether in terms of the established product and infrastructure, or in terms of the need to create the appropriate infrastructure to extend the season with specialized tourist facilities (wellness centers—spas, medical tourism infrastructure, conference rooms, gyms, themed restaurants, sports facilities, mini clubs, etc.) offered by other destinations in the Mediterranean.
To further refine the regulations on a per-island basis, the views of local communities, local stakeholders, and local government must also be taken into account within the framework of the TPS consultation, and the ECP-T should explicitly allow for feedback to the Subject Planning under strict conditions (e.g., every five years) in accordance with the development of infrastructure and other environmental and social factors, following specific documentation and assessment of local characteristics and development prospects in terms of sustainability.
Furthermore, the proposal to extend the requirement to prepare an Environmental Impact Study (EIS) to individual tourist facilities does not appear to be sufficiently substantiated from a scientific standpoint, given that carrying capacity is, in principle, assessed at the level of a specific spatial unit and not at the level of an individual project or activity.
Furthermore, such an approach may lead to fragmented or even contradictory assessments, without sufficient capacity for coordination and oversight by management. For this reason, the current provisions rightly incorporate the assessment of carrying capacity into the framework of Level A urban planning, which concerns broader spatial units, such as the municipality or municipal district, and it should be explicitly clarified that there is no obligation to prepare an EKEFI for individual investments.
The relevant framework described in the ECP-T regarding tourism and short-term leases is sufficient to serve as the basis for controlling the phenomenon through Subjective Planning in areas where development is proceeding at uncontrolled rates, with negative impacts on infrastructure networks, housing, and uncontrolled sprawl in areas outside the plan.
Regarding the proposed fee for the Green Fund, we believe that this provision was included in the original text of the study prior to the imposition of the resilience fee. Tourism investments already bear a significant burden regarding climate resilience issues due to the imposition of the corresponding fee, and for this reason, provisions for any new additional fees must be eliminated. It is proposed that the funds collected from a range of existing fees and other charges, which are not accompanied by clear reciprocity, be utilized for actions and investments that directly enhance the sustainability, infrastructure, and resilience of destinations.
Finally, regarding the transitional provisions, SETE has submitted numerous improvements to ensure legal certainty for investments and the necessary, justified trust of citizens in the state.
We hope that the final formulation of the ECP-T, together with the other Operational Programs and the Underlying Planning, will contribute decisively to what the whole of society seeks: sustainable development prospects in an environmentally and socially sustainable environment.