Without substantial changes to the basic philosophy of the plan that had been presented in May, but with targeted improvements that were incorporated after the public consultation, the Joint Ministerial Decision was published that institutionalises the new Special Spatial Framework for Tourism, covering an institutional gap that had remained open for more than a decade.

The new framework aspires to constitute the national roadmap for the spatial development of tourism, introducing differentiated rules according to the degree of tourist development of each area and attempting to strike a balance between the protection of already burdened destinations and the attraction of new investments in areas with developmental margins.

Indicative of the fact that the basic core of the planning remained essentially unchanged is that the first reactions of the hotel market are moving in the same direction as those that had been formulated during the consultation. The president of the Panhellenic Federation of Hoteliers, Yannis Hatzis, notes in his statement yesterday that, despite the individual improvements that were incorporated into the final text, “the core of the restrictions remains to a large extent unchanged”, stressing that the sustainable development of Greek tourism must be based on documented planning, legal certainty and trust in the potential of each destination.

Five categories of tourist areas

The most important intervention of the new spatial plan is the classification of the entire country into five distinct categories of tourist development, with different rules and building terms for each. The categorisation is carried out on the basis of the intensity of the tourist phenomenon, utilising as basic indicators the density of tourist beds in relation to the area and the permanent population of each municipal unit, while the particular geographical characteristics and protection regimes are also taken into account.

The areas are distinguished into Areas of Controlled Development, Developed, Developing, Early Development and Areas of Enhancement of Special Development. Despite the changes that occurred during the consultation, the geographical classification remained unchanged, with the interventions focusing mainly on the building terms, functional flexibility and the strengthening of investment incentives.

In the Areas of Controlled Development, where the greatest tourist pressures are recorded, the terms for new out-of-plan hotel investments are tightened, as the minimum required plot area increases to 16 acres until the completion of the primary urban planning. After the consultation, the provision was adopted that allows the development of units of up to 100 beds on the first 16 acres, while for larger areas the limit of 6 beds per acre is provided, up to the maximum bed number limit of the category of developed areas. For these areas the incentives for the conversion of listed and traditional buildings into tourist units are strengthened.

In the Developed Areas the minimum plot size limit for new hotel units is set at 12 acres, while in the Developing and Early Development Areas at eight acres. The framework places emphasis on the qualitative upgrading of existing units, the development of special forms of tourism, the creation of organised luxury living campsites (glamping) and the utilisation of abandoned settlements and traditional buildings.

A similar philosophy is followed in the Early Development Areas, where the development of hotels from two to five stars is permitted, on the condition that the two-star units meet the highest requirements of environmental performance. At the same time, incentives are provided for the modernisation of existing accommodation, the utilisation of listed buildings and the creation of destination networks.

Particular weight is given to the Areas of Enhancement of Special Development, which cover a large part of the mountainous, rural and frontier space. This is one of the main changes that emerged during the consultation, as the possibility of providing additional urban planning incentives through the Local and Special Urban Plans is provided, with the aim of attracting investments in special forms of tourism, the reuse of abandoned settlements and the stimulation of the local economy.

Special regime for the islands

A separate chapter of the new spatial plan concerns the island space, which is classified into three groups according to its area. On the large islands of more than 250 square kilometers the organised receptors are permitted exclusively under the regime of mild development, with the exception of Rhodes and Corfu. For the medium and smaller islands stricter restrictions are provided, as new hotel units cannot exceed 100 beds, while the organised receptors are permitted only as mild development with a building coefficient reduced by 50%.

Even stricter is the regime for the small islets of less than 1,000 acres, where only activities of limited environmental disturbance are permitted, such as mild installations of marine recreation, information kiosks, one tourist residence under conditions, glamping of up to 50 persons and small boat shelters.

At the same time, the protection of the natural environment is strengthened. In the coastal zone every new construction is prohibited at a distance of up to 25 meters from the coastline, with limited exceptions for works of access for persons with disabilities, emergency vehicles and institutionalised port installations. In the Natura 2000 areas exclusively mild forms of nature tourism are permitted, in accordance with the approved management plans and the Special Environmental Studies, while the mountain refuges cannot exceed 200 square meters.

Carrying capacity and new control mechanism

Continuing the regulatory framework, the concept of carrying capacity is introduced for the first time in a systematic manner as a basic tool of spatial planning and licensing of tourist activities. The preparation of a relevant special report becomes mandatory during the drafting of the Local and Special Urban Plans in the Areas of Controlled Development, in the Developed Areas and on the islands of Groups I and II.

The same obligation is extended also to the individual licensing of tourist units of more than 50 beds in settlements with a population of fewer than 3,000 inhabitants or of more than 150 beds in the larger areas. For the monitoring of the sustainability indicators the creation of a special mechanism at the Ministry of Environment and Energy is provided.

Restrictions on short-term rentals

On the front of short-term rentals, the new framework gives the possibility of imposing spatial restrictions, allowing the determination of zones where limits can be set on the operation of new accommodation or on the duration of their exploitation, according to the needs of each area. At the same time, as an immediate measure the suspension of the issuance of new Property Registry Numbers (AMA) for newly built residences in the island country is provided, with the aim of better control of the spread of short-term rentals in the most burdened destinations.

Transitional provisions and investment security

The new spatial plan is accompanied by a series of provisions that aim at securing existing investments and upgrading the old tourist stock.

Among other things, the possibility of utilising the transfer of building coefficient for legally existing but devalued tourist units that are withdrawn is introduced, while the possibility of their reconstruction in the same position with the applicable building coefficient is also provided. The relevant arrangements will be specified through the Local and Special Urban Plans, where the reception zones and the terms of application of the measure will be determined.

At the same time, the possibilities of reuse of the existing building stock in the within-plan areas are expanded, as the conversion of existing buildings into tourist accommodation and into the necessary supporting uses is permitted, where this is allowed by the applicable land uses.

The new framework also encourages the energy transition of tourism, promoting the controlled development of Renewable Energy Sources in the areas of categories A’ and B’, as well as on the islands of Group II, in accordance with the Special Spatial Framework for RES. At the same time, the establishment of incentives for the improvement of the energy efficiency of hotel units and the utilisation of renewable energy sources for covering their operational needs and accompanying infrastructures, such as desalination units, is provided. For swimming pools the provision is their use with seawater.

At the same time, the strategic investments that have been approved on the basis of laws 3986/2011 and 4864/2021 before the start of application of the new spatial plan remain in force, while the existing tourist units that do not meet the new plot size limits are also protected, giving them the possibility of expansion on the basis of the previous regime, provided that they have not exhausted the permitted building coefficient.

A corresponding provision exists also for the already environmentally licensed investments. The decisions of approval of environmental terms and the Standard Environmental Commitments that have been issued before the entry into force of the new framework continue to be valid until their expiry, allowing the completion of the projects, while the existing units can continue to be modernised, modified or expanded in accordance with the regime that applied at the time of issuance of their environmental licensing.