The start of the process for submitting objections to the forest maps posted after their revision is marked by the first postings that began last Friday.

The goal is to achieving the ratification of forest maps by the end of 2021, but much will depend on the number of objections submitted and the speed with which they are reviewed by the Objections Examination Committees (EEPE). Moreover, the decision posted today regarding compensation for members of the Objections Examination Committees stipulates that it will be valid for two years.

However, concern has been raised among stakeholders by the fact that, while they were waiting for the forest maps to be reposted, it has now been decided that For areas with an approved forest map, objections are only accepted for the revised section of the posted forest map and only for sections for which no objections or requests for preliminary errors have already been submitted.

It should be noted that The posts began with forest maps for the regions of Kavala, Pieria, Drama, Arcadia, Kastoria, Lefkada, Kefalonia, and Zakynthos., while the posting program is scheduled to be completed by the end of February.

However, a decision signed by Deputy Minister of the Environment Nikos Tagaras and Deputy Minister of Finance Theodoros Skylakakis has already set the monthly compensation for participants in the Objections Examination Committees.

Specifically, compensation is defined as follows:

President, lawyer, €400
Member who is a forestry scientist employed by the State or a public entity or a broader public sector body: €250.
Member engineer, €250.
Secretary employed by the State or a public entity or a broader public sector body: €150.
It should be noted that The amount of compensation is directly linked to the efficiency and speed of processing by the EPEAs. Consequently, the total compensation per person, with the exception of August, is paid provided that the minimum mandatory number of four meetings per member is observed each month, in combination with the completion of 25 cases per meeting and a total of 100 cases at the end of each month.
Exceptionally for August, provided that 100 cases are examined by the E.P.E.A., compensation shall be paid, equal to the fraction of the number of cases in the examination of which the member participated, the president or secretary by the total number of cases examined during the month by the E.P.E.A., on the monthly compensation of the respective member, without the requirement to meet the conditions for participation in the meetings.

Objections to the posted forest maps

During the posting of the Forest Map, interested parties should check whether their property is located in a forest or grassland area.

If they agree with the classification of an area, they do not need to take any further action. Otherwise, if they dispute the classification of the area (or part thereof) as shown on the forest map, they may, as appropriate:

submit their objections exclusively electronically on the Greek Land Registry website, paying the relevant special fee.
if no fee is required, submit their objections to the Forest Map Posting Support Point (SYADX)
submit, free of charge, an electronic application for correction of an obvious error on the website of the Hellenic Cadastre or in person at the competent Forestry Directorate.
In each area for which a forest map is posted, Forest Map Posting Support Points (SYADX) are set up, which operate for as long as the posting lasts.

The SYADX provides information on the content of the posted forest map and explains how to submit objections.

All documents accompanying an objection (within the deadlines set in the relevant decision) are also submitted to SYADX by post, courier, or in person, and objections submitted free of charge are accepted.

Objections concern disputes over the nature or form of the areas shown on the forest map or the accurate representation of the geographical location of the boundaries of forests and forest/grassland areas.
The deadline for submitting objections begins on the date specified in the decision of the competent Forestry Directorate and lasts for 105 calendar days, or 125 days for residents abroad.

It should be noted that For each separate area whose classification on the forest map is disputed, a separate objection must be submitted. If, for example, someone has two different plots of land and disputes the classification of both, they will submit two objections together with the necessary supporting documents, including documents establishing their legal interest in submitting an objection (e.g., notarial deeds, court decisions, concessions, settlement deeds, compulsory expropriation decisions, etc.) relating to:

Real property rights, such as ownership, mortgage, and easements (personal easements: usufruct, habitation/real easements: right of way, logging, grazing, water pumping, etc.).
Contractual rights, such as leases, agricultural leases, timeshares, preliminary agreements for the sale or donation of real estate, etc. Please note that for property leases, you must submit a notarial document registered with the Land Registry, while for preliminary agreements for property donations, you must submit a notarial document.
A copy of form E9 of the property details declaration submitted to the tax office, provided that it shows the identity of the property.

End of Objections

The following objections are exempt from the payment of the special fee for filing objections:

areas that have been included in the forest map as forest areas due to the failure to record the boundaries of approved settlements and the approved boundaries of urban planning studies or street plans (paragraph 2a of Article 23 of Law 3889/2010, as applicable)
areas corresponding to the minimum plot size requirement at the time of issuance of the relevant building permit and falling under the previous case (paragraph 3b of Article 31 of Law 4280/2014, as applicable)
areas that appear as forest in the photo interpretation of older aerial photographs, but are included in plots of settled land or land redistribution
areas that appear as grassland or rocky or stony, either in older or recent aerial photographs, but are included in areas of settlement or land consolidation
areas for which final Characterization Acts have been issued by the competent Forestry Service (Article 14 of Law 998/1979), which are not shown on the posted forest maps due to an oversight
areas with pending applications for the issuance of a Characterization Act and cases subject to this procedure

Furthermore, no fee is charged by central government bodies (e.g. ministries) and first and second-level local government bodies (regional units, municipalities).

Endless objections are only submitted to SYADX.

If the interested party does not fall under one of the above cases, when submitting an objection, they must pay a fee, the amount of which depends on the size of the area whose classification they are contesting and is set as follows:

up to 100 sq. m., €10
up to 1,000 sq. m., €40
over 1 to 5 acres, 90 euros
over 5 to 10 acres, €180
over 10 to 20 acres, €350
over 20 to 100 acres, €700
over 100 to 300 acres, €1,400
over 300 acres, €3,300

The fee is paid either during the submission of the objection electronically, using a card, at the last stage of the process, or at a bank branch or via web banking.