The forest map identifies and delimits the areas of forest or grassland character, which are protected by the provisions of the forestry legislation and separates them from all areas of a different nature.

It is noted that the forest maps regulate the nature of the areas and do not interfere with the ownership regime, do not affect ownership rights, of the respective area.

On the contrary, they aim to delimit forest and grassland areas, supporting spatial planning, while at the same time contributing to the protection of the environment.

Areas not governed by the provisions of the forestry legislation

AA: Lands that have always been of a different form/use

PA: Ceremonial Deeds of Characterization Non-forest/Non-grassland

Areas governed by the provisions of the forestry legislation

PD: Characterization Ceremonies, Forestry

DD: Always woodlands

DA: Cleared forest lands

AD: Wooded Fields

PX: Ceremonial Acts of Characterization, Grasslands

XX: Always grassland

HA: Grasslands in 1945 aerial photographs, other form of coverage in 2007-2009 aerial photographs

AN: Areas that have been declared renewable

To date, forest maps have been posted for 95% of the territory, the remaining 5% concerns areas within settlement boundaries and city plans.

90% of the forest maps have been sanctioned. The difference is due to the fact that there has been no sanction in areas, which have been submitted objections and requests for the correction of an obvious error.

After the approval of the forest map, any transfer, constitution and in general any change in the real rights of lands classified as forests, forest or grassland, must be accompanied by a relevant certificate from the competent Directorate of Forestry, which confirms the nature of the land (law. 3889/2010, no. 20, par. 4).

If the area does not fall under the provisions of the forestry legislation (it is not a forest area in general) a responsible declaration of article 8 of Law 1599/1986 (A' 75) on the topographical diagram accompanying the relevant act of the notary is sufficient or, if there is no obligation to prepare a topographical diagram, based on a section of the forest map where the property to which the notarial deed relates is depicted and where the coordinates of the peaks of the property appear, with which it is declared responsibly by its author, that the specific property does not fall under the protective provisions of the forestry legislation (law 3889/2010, no. 20, par. 5).

For areas for which the objections of the interested parties have been accepted by EPEA decision, and until the disputed part of the forest map is ratified, a copy of this decision is attached to the relevant contract with the online posting number (A.D.A.) from " Clarity" and with an attached topographical diagram of dependent E.G.S.A. coordinates, on which the editor certifies that the property is the one in respect of which the submitted objections have been accepted (law 3889/2010, no. 20 , par. 4).

In an area that is mistakenly burdened with forest character, in order to make the transfer, the objection process must first be completed.

As long as the part of the parcel of land, designated AA, meets the conditions of adequacy, then a building permit is issued. In any case, the circular applies to the issuance of a building permit ΙΠEN/DAOKA/56321/2354/09.06.2021 (AD: Ω25Υ4653Π8-27А) directive on the declaration of forest or non-forest character when issuing building permits, after the posting of forest maps.

These areas concern city and settlement plans, the boundaries of which have not been approved by acts of the Administration but have been demarcated by other provisions, such as e.g. the contours of the legally existing settlements before the year 1923 for which a limit has not been determined, the radial settlements, the limits of the urban planning studies and city plans that are being prepared as well as the settlement limits that have not yet been approved.

For these areas, the Ministry of the Interior plans to publish a forest map within 2023, in order to clarify their forest or non-forest character.

Until then, in these areas, the procedure of article 14 of law 998/79 applies to the characterization of an area or part of the land's surface as subject or not in the cases of article 3 of law 998/79 (forest, forest area) 79, which provides for the issuance of a deed of designation of the locally competent forester or the Director of Forests.

The possibility of using the elements of the forest map, whether it is posted or approved, is provided to every public authority through a special website of the Land Registry (Law 3889/2010, no. 20, par. 6).

If written provisions require the attestation of the forest or non-forest nature of an area before the State, the OTAs of the first and second degree and the services and bodies of the wider public sector, this is carried out with a responsible declaration of Article 8 of Law 1599/1986 (A ΄ 75) on the topographic map, concerning the specific property by its author. The declaration must state whether the classification of the area as forest or not has temporary or definitive effect, depending on the stage at which the forest map is located.

The problems highlighted by the recent posting and sanctioning of the forest maps are ownership, the lands characterized as AD and DA i.e. former agricultural lands that were forested due to abandonment or forest lands that were illegally cleared for cultivation, as well as houses that have been built in forest areas areas without the required building permit, i.e. they are "arbitrary forests".

These are lands that appear in the aerial photographs of 1945 in a rural form and were later forested due to abandonment.

The Ministry of the Interior by legislative regulation (no. 93 of law 4915/2022) amended no. 67 of Law 998/1979 and enabled the economic utilization of 7,000,000 acres for agricultural and arboricultural cultivation, as well as for free use under conditions.

The State will no longer project ownership rights to these lands unless they are established on the basis of titles. This is a major reform that landowners have been waiting for for almost 45 years.

The ownership regime is not directly related to the forest maps, but is an incidental issue. Forest maps solely regulate the character of lands based on human interventions, their use in the past and the presence or absence of forest vegetation, without interfering with the ownership regime. Any ownership dispute continues to be settled either administratively or judicially.

In order to speed up the definitive resolution of the ownership regime in the areas of the Greek territory where the presumption of public ownership does not apply, the Ministry of Foreign Affairs legislated that for these areas (Ionian Islands, Crete, Lesbos, Samos, Chios, Cyclades, Kythira, Antikythira, Dodecanese and Mani) the State does not assert property rights in forests and forest lands unless it has title deeds (no. 152 of Law 4819/2021).

In practice, if a demonstrably private area is classified as forest, it is not claimed by the Greek State. It remains a private area, which does not affect its use, in relation to the previous institutional status. It should be mentioned that forest lands that are not recognized as private in one of the ways mentioned in no. 10 of Law 3208/2003, are considered public.

The Ministry of the Interior, by legislative regulation, gave the right to properties that include both forest and agricultural lands to be able to be transferred, as far as the non-forest part is concerned, without this being considered a division (no. 153 of Law 4819/2021).

A solution is also given to the issue of forest trespassers through the special online platform of par. 1 of art. 52 of Law 4685/2020, which was created in collaboration with the Hellenic Land Registry and has been in operation since October 5, 2022.

The terms and operating specifications of the online platform of par. 1 of no. 52 of Law 4685/2020 are described in No. Ministry of Internal Affairs/DPD/68161/3775/16.07.2021 K.Y.A, with the obligation to pay a fee of €250.

The owners of houses in forests and forest lands, declare their houses there, with a suspension of demolition procedures and imposition of fines for 30 years.

Then, once the information from the declarations has been collected, an economic and technical study will be prepared, based on which a Presidential Decree will be issued that will determine the conditions for the preservation, with payment of a fine, or the demolition of the houses that have been declared.

It is noted that the inclusion - in the above provisions - of buildings, which:

• do not have the character of residence,
• have been erected after 28 July 2011;
• are located in areas of the Natura 2000 network, in Ramsar wetlands and in areas for which special protective provisions of nature or landscape apply, unless they were built before the designation of these areas,
• are located within areas that have been declared reforestable due to fire and have been erected after the declaration of reforestation,
• their maintenance hinders the escape of citizens or the access of fire engines in case of fire or other danger from natural phenomena.

No, based on the opinion of the Technical Council of Forests of the Ministry of the Interior which was accepted by the Deputy Minister of Environment and Energy with YPEN/DPD/35724/2004/16.04.2021 acceptance of opinion, lands that were agricultural in the past and due to abandonment grew asphalt and scrubby vegetation are no longer classified as forest.

Also in accordance with the previous acceptance of the opinion of the Forestry Technical Council (the 182363/2395/13.5.2019), areas that are covered only by phryganic vegetation, do not meet the necessary criteria that should be taken into account in order to be considered to constitute a forest biome and consequently these areas are not classified as forests or forest but as grassland.

There is an ongoing process to resolve the issue of cleared forest lands, which are used for agricultural use, without legal administrative acts having been issued.

For land acquisitions (DA) there are specific procedures for determining the public interest through the collection of quantitative data and the preparation of economic and technical studies. The forest map helps to solve the issue by helping to count them and determine the goods produced from them. Subsequently, the State, based on scientific quantitative data, will be able to determine the required actions to resolve the issue.

An economic and technical study has already been completed to determine the public interest and a legally viable solution is being planned in accordance with the dictates of the Constitution.

In any case, the proposed regulation will definitively resolve all the issues that have arisen by protecting the State from encroachers, as well as the legal owners of these lands.

The arrangement concerns 2.3 million hectares of former forest lands that were deforested (DA) without legal administrative acts and are used for agricultural use and thousands of owners - farmers.

According to it, the lands in question maintain agricultural use for as long as they receive uniform support from OPEKEPE and are included in the Integrated Declaration Submission System (IDIS).

With recent decisions of the CoE it has been judged that during the previous period the posting times, as well as the way of publicizing the process of posting and sanctioning the forest maps, were sufficient, so that private individuals could take all the legal actions (on average the time objection period varied more than 8 months).

With recent decisions of the CoE it has been judged that during the previous period the posting times, as well as the way of publicizing the process of posting and sanctioning the forest maps, were sufficient, so that private individuals could take all the legal actions (on average the time objection period varied more than 8 months).

In addition to these, our country has undertaken international commitments, in order to achieve the sanctioning of forest maps within reasonable and at the same time binding periods of time, without being obliged as a state to pay unaffordable fines due to chronic inconsistency.

As a consequence of the above, it is not possible to once again submit objections to the whole (but not even to a part) of the sanctioned maps, that is, even in the areas where there has never been any interest until now.

They can submit a request to reform the forest map to the relevant Directorate of Forests.

The sanctioned forest map does not accept objections, but its modification is allowed according to par. 1 of no. 20 of Law 3889/2010.

The reformation of the sanctioned forest map is allowed by adding or deleting the lands that fall under it or cease to fall under it in accordance with the forest legislation, by court decisions on the ownership issue of grassland lands, by administrative acts that should have been included in the forest map by its preparation and are not depicted in it, as well as with the correction of obvious errors.

According to the Ministry of the Interior/DPD/64663/2956/2020 YA, the administrative acts are:

• Approved town planning plans, implementation acts and approved urban planning studies,
• Settlement designation decisions,
• Demarcation acts as well as town planning and zoning acts,
• Valid installation and operation permits, building permits or other permits or administrative acts covered by the presumption of legality for industrial or craft facilities included in residential control zones,
• Decisions of expropriation committees,
• Agricultural lot concessions,
• Decisions sanctioning distributions and replantings to which agricultural, livestock or mixed use has been assigned,
• Decisions of the Minister of Rural Development & Food or Prefect,
• Licenses of the Minister of Rural Development & Food,
• Decisions to dispose of estates acquired by the public pursuant to special laws,
• Administrative acts referring to expropriations and transfers.

According to Y.A. 153394/919/12.04.2017 an obvious error in the process of drawing up the forest map is defined as any obvious:

• Deviation of a technical nature or incorrect technical performance of the boundary lines observed on the photogrammetric backgrounds and resulting from either ground measurements or photointerpretive performance of the thematic content of the map, which contradicts the image presented on them,
• Inadvertently omitting to capture a clearly forested area within a wider other form (rural, etc.) and vice versa,
• Manifestly misrepresenting agricultural land as forest and vice versa,
• Omit records of map polygon elements in the database,
• Incorrect capture of thematic surface due to image (photo) shaped elements due to gradient areas,
• Performance as grassland, of an area that concerns a lowland and smoothly sloping area, which is exempt from the provisions of the forestry legislation, according to the p.d. 32/2016 (Official Gazette 46 A'),
• Performance as grassland, of an area that is recognized, according to the current provisions, against the State as private, which is exempt from the provisions of the forestry legislation,
• Performance as a forest, of an area related to an artificial forest plantation, which is exempt from the provisions of the forestry legislation and
• Failure to depict acts of management.

With regard to the operation of the Objection Review Committees (EPEA), the Ministry of Environment and Energy has proceeded with a series of institutional interventions for their more efficient operation, in order to speed up the process of examining objections.

Law 4685/2020 changed the composition of the EPEAs, who are now paid based on the monthly number of cases they examine (100 per month), with the aim of their findings being characterized by as much external objectivity as possible. The committees consist of a Lawyer (as chairman), an Engineer from the private sector and a Forester from the public sector.

It is known that the number of pending objections is large. For this reason, the formation of at least 200 committees has been foreseen, for the operation of which the necessary financial source has been secured from the Green Fund.

In addition, it has been foreseen that preparatory - supporting processes will be carried out by the Forest Directorates, so that the flow of objections is fully grouped and finally the desired pace of examination of objections is achieved.

In any case, the process will be closely monitored and if deemed necessary based on the timetables, additional committees will be established. The General Directorate of Forestry & Forestry of the Ministry of the Interior, is in close cooperation with all the agencies and services involved, so that the work of the committees can start immediately, and no time is wasted.

To date we have established 116 Objection Review Committees (OPCs) with the aim of reaching at least 200 OPCs who will review 20,000 objections per month, given that 100 cases per month are required to pay members' compensation.

According to par. 5 of no. 19 of Law 3889/2010, the citizen has the right to apply for annulment before the Council of State against the act of sanctioning the forest map for that part of the objection that EPEA did not accept. A condition of the appeal to the SC is the inclusion in the sanctioned forest map of the area in question after the rejection decision of the EPEA.