Note: I limit myself mainly to Kythera, which I believe I understand better.
- General observations
First of all, it is very positive of course that the issue of the formulation of the Local Urban Plan for Kythera and Antikythera has been opened. Our islands are suffocating in a maelstrom of inadequate planning, lack of infrastructure and anarchic development of tourism and stagnation in other sectors. In my opinion, despite its shortcomings and failures, it is a serious basis for positive change
However, I believe that the way the plan/proposal is formulated and the consultation is far behind the needs, with the result that there is a risk of both missed opportunities and the formation of wrong directions. I do not know how this could be remedied given the tight deadlines. But I would suggest that at a later stage, corrections/interventions should be given the opportunity for real consultation. Not just with the planning/technical specialists/engineers (who obviously have a weighty opinion) but more broadly, especially with the productive stakeholders (mainly Co-operatives and associations) and the Municipality locally and centrally and of course the Domestic Property Commission (DPC)
A general observation on the substance . I believe the Local Urban Plan should primarily serve a development perspective for Kythera and Antikythera. Such that will be based on their competitive advantages that are historically documented (e.g. livestock farming) and the perspective that is formed in the modern environment, e.g. vertical integration of the agro-food sector. Such a perspective should primarily aim at :
Α. The decisive increase in the value of the produced goods in Kythera and Antikythera. By extension, the increase of the population with highly skilled residents
Β. In conjunction with the above, to safeguard the natural, environmental and cultural characteristics of Kythera
Notes: I acknowledge that the lack of a Strategic Plan from the Municipality (which unfortunately is not mandatory for small municipalities, but could have been formulated) does not help the study group that needs to gather ideas from everywhere, as much as possible
- Specific observations
In this direction I believe the priorities should be
- The development/regeneration of the primary sector in an integrated form of agri-food chain. Its main characteristic should be the standardization and quality upgrading of both existing products and other products that the history of Kythera shows can thrive (e.g. livestock and its derivatives). And in addition new opportunities that an integrated study can highlight (and the Municipality, through the Region and the Ministry of Rural Development) to shape)
- In conjunction with the above, the development of manufacturing enterprises. While the link with agricultural production is obvious (e.g. standardisation of olive products, honey, fruit, etc.), other related sectors (e.g. bread and nut products) as well as building materials, herbs, etc. should not be excluded.
- It is crucial that the development of the tourism sector be subject to rules such that its development will not alter the characteristics of the island. The size of the tourist units should be limited to the «human» sizes that have so far made Kythera an attractive destination. However, a small increase in bed capacity may be needed to make the units viable. However, the emphasis in the development of the tourism product should be on the «experiential» dimension of tourism, i.e. what the visitor gets out of tourism, beyond the sun and the sea. In order to achieve this goal, it is necessary to dramatically improve the infrastructure (including ports and airport - with an immediate study on the management of Natura 2000), the promotion of the natural heritage (gorges, paths, forests, monasteries, etc.). In this context, it is necessary to better study the development of marinas both in Diakofti and in Agia Pelagia and Kapsali. It is a promising sector (see the reality in the Ionian Islands) with potential for development.
- To support this development, it is essential to improve the health infrastructure (here the issue is mainly staffing, of course) and from a TPA point of view, the development of «well-being» areas, e.g. sports areas, walking and exercise areas.
- But perhaps the most critical and immediate issue for Kythera is the water management infrastructure. Both for «production» (in application of the Master Plan which is ignored by 80% and obviously needs updating) and for distribution and most importantly recycling. It is surprising that the plan does not mention the need for a WWTP in the northern part of the island . Whereas it should be the main direction
- Finally, there should have been provision for the development of modern communications infrastructure e.g. High Speed Internet (Fiber optics) which, apart from facilitating life and business activity, will also allow the increase (already present) of remote workers (Digital Nomads) with obvious positive effects on the population and the quality of life.
- Commenting on the proposals and scenarios
First of all, there are significant shortcomings in the basic guidelines (see slide 23 of the study presentation) for the «Local Economy and Employment» axis. There are no real references to productive opportunities. For example, it is ignored that last year Kythera had a strong «export» activity of sheep and cattle. And which, with the creation of the slaughterhouses, can be revived and in a different dimension, covering at least in the first instance the internal market. This may be the result of inadequate consultation, which may have concentrated on the spatial dimension rather than on the production dimension. With the exception of the reference to the planned slaughterhouses (rightly so, since this will have a multiplier effect on the agri-food sector), there is no reference at all to productive restructuring. No mention of the development potential, no mention of the island's historical productive potential. For example, the strong productive position (and «exports worldwide) of bakery products says something.
In slide 25 (SWOT analysis) in the strengths, nowhere is the uniqueness of Kythera mentioned with the (unique for Greece) ownership by the Local Government of all the non-private land (managed by EEPKA). Kythera and Antikythera have at their disposal a unique advantage and tool, having almost 80% of the surface area of Kythira, to mobilize resources for a truly dynamic development plan. The TAP must allow this possibility . It is a big question whether there has been consultation with the EIFC on the plan. In any case, it must be done
Possibly predictably, the scenario proposed is scenario 2 , classified as a soft growth scenario. Which I am afraid essentially orients Kythera towards a tourist destination basically (further reinforcing the almost monoculture of tourism) with obvious consequences (periodicity of employment, very low-skilled work, sensitivity to external conditions, low added value)
In my opinion, the TAP should adopt the most development-intensive scenario (3), which is also insufficient, but in any case much better than 2. But it should strengthen its developmental direction
In particular, it has to predict (and reconfigure all the special zone predictions etc - which is particularly difficult for a non-expert like me to follow) so that :
- Key considerations for necessary provisions of the Kythera TSP
Α. There should be provision for general manufacturing activity (the distinction «soft» scares me because it leaves room for interpretation. For example, a nuclear or pellet mill, which could be a possible option, would be tolerated?
Personally I see rather negatively the exclusive zoning in one area, I believe that it is more realistic and preferable in every respect to provide for development along the central axis , at least River - Country so as to use existing infrastructure and keep costs at reasonable levels. On the other hand, of course, I believe that «commercial» structures, should be subject to strict rules both in terms of size (building factors / coverage) and aesthetics to «blend» with the residential environment. And not to see abominations as we have unfortunately seen in some cases. Perhaps Architectural Council approval should be required
Β. Provide for the development of larger commercial activities in the same manner. In my humble opinion, large shopping centres should be developed on the central axes and not in the villages
C. To allocate (as foreseen) areas for the development of livestock farming but to manage the boundaries especially in consultation with the EEPKA which could make available, even through PPPs, suitable land
D. I believe it is necessary to establish settlement boundaries, with provision for town plans in all settlements, starting with the largest ones. I am very surprised that the priorities do not include the formation of settlement boundaries in Potamos, the largest village on the island, which is suffocating within the antiquated building framework with its 800-metre zone, and there is only an inadequate reference to its centre. Of course the centre should be reformed but in the context of an integrated regeneration of the village taking into account the SDC. In this direction, in the long term, regeneration studies should be carried out in all the large villages at least.
Ε. I believe the building factor restriction on «buffer zones» as stated is too restrictive. In the prevailing conditions of land parcel fragmentation, there is a possibility of excluding a large segment of the population from adequate housing (and/or concentrating ownership to fewer and more affluent people). It should probably be a little higher e.g. 0.40
SD. The reconfiguration of the road network, both on the central and complementary peripheral networks, should be foreseen in the TAP with a perspective of at least 10 years. As part of it the formation/improvement of peripheral roads in critical villages like Livadi, Potamos, Karvounades, etc. that will relieve through traffic and give another life locally. This of course includes parking networks, charging stations etc.
Finally, an observation on the evaluation of the scenarios. Very well the study group formulated a methodology for evaluating the scenarios. In these cases there is always a high degree of subjectivity and the reality may be very different. For example, if the weighting of the criteria is changed with more weight on the «Economic Development and Social Cohesion» and «Organisation of Supporting Infrastructures for Productive Activities» axis and the scoring is more realistic (e.g. I believe the higher development is absolutely acceptable to the population and it is unacceptable that it was scored 5 out of 10) then scenario 3 is clearly the best.
I should also note that the possibility of funding is also a dynamic issue. The future does not stop with the TAA. And citizen demands can change the game
It would therefore be worthwhile to discuss different approaches to evaluation. An example is shown in the table below which changes the final assessment:

Notes: The reference to wind turbines in scenario 3 is inappropriate and unnecessary. Kythera and Antikythera have enough potential for their development, including future energy needs (up to tripling) without the need for wind turbines through photovoltaics (see Municipality study that led to the creation of EnKoin Kythera).
For this reason it is important that the provision for PV parks leaves significant degrees of freedom within the special zoning for RES and that other areas are allowed and not only the one mentioned in Fratsia.
I hope others, more expert, will shed more light on the details
Thank you
Spyros Michalakis
February 2025













