The Hellenic Society for the Protection of the Environment and Cultural Heritage (ELLET) opposes changing the use of Windmills A and B, located on the western hill above the port of Hydra. In a letter sent to Olympia Vikatou, Secretary-General of the Central Archaeological Council (KAS), and to the Council’s members, the Society expressed its strong opposition to the Municipality of Hydra’s proposal to convert the two windmills from exhibition spaces into temporary accommodation.

The Society points out that the windmills have been designated as ancient monuments and that the proposed conversion into accommodation is completely at odds with the approved restoration study and the building permit that has received preliminary approval. It also stresses that residential use conflicts with Article 46 of Law 3028/2002, which stipulates that immovable monuments are intended exclusively for public visitation and cultural events.

Furthermore, ELLET warns that funding could potentially have to be repaid, since restoration of the monuments is being financed through the “Antonis Tritsis” Programme of the Ministry of the Interior exclusively for restoration purposes, with no provision for a change of use. Finally, it alleges that unauthorized works are already underway, including the construction of bathrooms and kitchens and the installation of a heat pump at the monuments. ELLET is calling for the KAS to immediately reject the proposed change of use and for the Ephorate of Antiquities of Piraeus and Islands to urgently intervene and issue a stop-work order.

The letter

A document from the Ephorate of Antiquities of Piraeus and Islands forwarded to the competent services of the Ministry of Culture the Municipality of Hydra’s proposal to change the use of two of the three windmills located on the western hill above the port of Hydra (Windmills A and B), from cultural-promotion/exhibition spaces into temporary accommodation. The matter is expected to be referred to the Central Archaeological Council for a final decision. These windmills have been designated as ancient monuments under the relevant official designation.

With this letter, we are submitting our reasoned objections so that they may be taken into consideration by you and by the members of the Central Archaeological Council before any decision is made.

A. The change of use conflicts with the approved restoration study, which was approved by a decision of the Minister of Culture and forms the basis on which the preliminary building permit was issued.

Specifically, the approved restoration study makes no reference to residential use. Instead, it approves the restoration of the complete operating mechanism of all three windmills, namely: the moving mechanism (sails, shaft, tail pole and associated components), the power-transmission mechanism, the grinding mechanism (wheel, millstones and associated equipment), as well as the mechanism for orienting the sails (movable cap).

The proposed conversion into accommodation, however, calls for the removal of the internal mechanism from Windmills A and B and its replacement with a kitchen, bathroom and sleeping area. It would also involve removing the millstones and wheel, because the interior of the windmill—up to 5.75 metres high, with an internal diameter of 3.30–3.60 metres—cannot simultaneously accommodate a functioning milling mechanism and residential use.

The proposed change of use therefore constitutes a substantial departure from the approved restoration study, and cannot be approved without revising the existing approval decision.

Moreover, under Article 46(1) of Law 3028/2002, the permitted uses of immovable monuments are limited to: (a) public visitation and (b) cultural or other events compatible with their character as monuments. Even the granting of use is permitted only in the context of events, following authorization by the Minister of Culture and an opinion from the Council.

Temporary accommodation does not fall into either of these categories. It would amount to exclusive private occupation of the monument during the period of stay, which conflicts with the public character that the legislation assigns to monuments.

B. The change of use conflicts with the terms of funding under the “Antonis Tritsis” Programme.

It should be taken into account that restoration of the three windmills is being financed by the Ministry of the Interior’s “Antonis Tritsis” Programme. When submitting its funding application, the Municipality requested public funds for the “restoration of windmills,” without any reference to changing their use. This creates a risk that the funding could be required to be repaid.

The KAS should take into account that approving a change of use while the funding was granted for a different purpose could create a problem.

C. Important information requiring immediate action

According to information that has come to our attention, work is already being carried out on the monuments. This reportedly includes the construction of bathrooms and kitchens and the installation of an external heat pump—facilities intended specifically for accommodation use and incompatible with both the approved restoration study and the preliminary building permit that was issued.

The permit concerns exclusively the “restoration of three ruined windmills.”

Based on the above, we request:

A. That the Ephorate of Antiquities of Piraeus and Islands be urgently notified of the need to carry out an ex officio inspection and issue a stop-work order for the work currently being carried out, so as to prevent the creation of a fait accompli before the KAS reaches its decision. Under Article 10(5) of Law 3028/2002, the competent authority has explicit power to halt works by issuing an order, without requiring a prior opinion or decision by the KAS, as also confirmed by case law (Council of State ruling 1017/2020).

B. That the proposal to change Windmills A and B into temporary accommodation be rejected, on the basis of Articles 6 and 46 of Law 3028/2002 and their approved restoration study. As ancient monuments, they should be accessible to the general public and serve the cultural and educational purpose for which their restoration was approved and funded.