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What applies to forests and forest areas that have been cleared, to agricultural areas

that are forest lands but have title deeds, and when there are title deeds

for fields that have become forested. What happens with transfers, ownership

registration, and agricultural subsidies

-«The dominant problem highlighted by the Forest Maps is the ownership regime

in areas characterized as “AD” and “DA”, i.e., former agricultural areas

that became forested due to abandonment or forest areas that were illegally cleared

for cultivation,» notes Grammati Baklatsi, a surveyor-urban planner, engineer

and technical consultant for forest maps, to “Eleftheros Typos” and journalist

Marina Xypnitou, stating that:

-«In order to resolve this issue and provide a definitive solution to the ownership

regime in areas of Greek territory where the presumption of ownership

by the State does not apply, the Ministry of Environment and Energy legislated that for these areas

(Ionian Islands, Crete, Lesvos, Samos, Chios, Cyclades, Kythira, Antikythira,

Dodecanese and Mani) it does not assert ownership rights over forests and forest

areas, unless it possesses title deeds (Article 152 of Law 4819/2021). Practically, if

a proven private area is characterized as forest land, it is not claimed

by the Greek State. It remains private land, which does not affect its

use, in relation to the previous institutional framework».

The “new problems”

«The legislative corrections made by the Ministry of Environment, as well as the ratification

of the largest percentage of forest maps, are not enough to mark the beginning

of the end of the Forest Registry and Cadastre project in our country, since

the dysfunctions of the administration constantly create new problems. Agricultural areas

for which there are title deeds and which have become forested will require citizens to

go to the Forest Directorate and Cadastre to secure their ownership. Properties

with houses with building permits that were issued before the 1975 Constitution and

their owners had taken all necessary actions with the Forest Service,

in order for these to be excluded from the forest map as non-forest areas, remain

forest areas. Also, the 331,874 objections submitted by citizens

are pending and concern a by no means negligible area with a total

extent of 2.5 million stremmata».

-«We expect the ministry, as it has announced, to increase the number of

objection review committees to 200 to speed up the process and stop

the suffering of citizens,» emphasizes Ms. Baklatsi.

According to what the Ministry of Environment and Energy has announced, forest maps have been uploaded to date

for 95% of the territory, with the remaining 5% concerning areas within

settlement boundaries and city plans, while 90% of forest maps have been ratified. The difference

is due to the fact that ratification has not taken place for areas where objections have been submitted and

requests for correction of obvious errors.

Questions-answers regarding forested fields and cleared

areas

What owners need to know about reforested fields and cleared

areas is answered by Grammati Baklatsi, surveyor-urban planner, engineer and

technical consultant for forest maps.

-What happens when there are title deeds for fields that have become forested?

-These are areas that appear in 1945 aerial photographs as agricultural

and subsequently became forested due to abandonment. Regarding the ownership

status of areas that were demonstrably agricultural in the past and

became forested due to abandonment, the Ministry of Environment and Energy, through legislative regulation, recognizes private individuals

as owners of these areas, provided that the State does not establish ownership

rights over them based on a title deed. Thus, the forest ranger, upon request from the

citizen, will examine the following:

a) If there are public title deeds (from will, donation, court decision

etc.).

b) If the area belongs to the State’s ownership for another reason, e.g. as a common or available settlement area,

c) If it is registered in the public land books as public property. For

this, the forest ranger will ex officio request a certificate from the relevant Cadastral Service,

which will only certify whether the specific property is registered as

public property in the relevant registration book.

In case of non-response from the relevant Cadastral Service, the

forest ranger will proceed, within a reasonable time, to process the request of the

citizen who asserts ownership rights over an area that appears as “AD” in the

ratified forest map, without the response from the Cadastral Service, examining the

possible existence of State titles over the area or its possible transfer to the

State for another reason, e.g. as common or available settlement land.

-What applies to areas that are forest lands but have title deeds?

-These are areas with the designation “DD”, which appear in the

1945 aerial photographs as forest lands and in the 2007 aerial photograph again as

forest lands. The ownership status of these areas is decided by the competent

Council for Ownership of Forests, Forest, Grassland and Rocky Areas

(SIDCHVE) for the area, which is responsible for the administrative recognition by the State

of the ownership or other real rights of private individuals or public

or private law legal entities over forests, forest areas, grassland

areas, etc. The application before the Ownership Council is made by the owners

regardless of whether they have submitted objections to the forest map or not, and is very

important for the recognition of their ownership rights regardless of the

character of their property (forest, grassland, agricultural, etc.). For the submission of the

application, a title report prepared by a lawyer and a topographical map of the

property from an engineer are required.

-What applies to forests and forest areas that have been cleared?

-Forests, forest areas that were cleared for agricultural exploitation, without permission from the

relevant forest authority, which appear in the uploaded forest maps with the

primary designation “DA” or “CHA”, provided they continue this use until today

or are under fallow management and are integrated into the integrated system

of OSDI declarations, retain agricultural use for as long as they receive single

aid. These areas continue to bear the designation “DA” or “CHA” on the

forest map, which does not change.

-How will the cleared areas be registered?

-For the mapping of these areas, the Organization for Payments and Control

of Community Aid, Orientation and Guarantees (OPEKEPE) sends to the

General Directorate of Forests and Forest Environment of the General Secretariat of Forests of the

Ministry of Environment and Energy and to the Hellenic Cadastre agency the

geospatial outline of all areas declared with a Single Aid Application

in OSDI.

– Will these areas be transferable?

-After the ratification of the forest map, any transfer, establishment, alteration, and generally

any change of real rights in forest areas in general included

therein, is null and void if not accompanied by a relevant

certificate from the competent service of the relevant Forest Directorate, certifying

the character of the area. The Ministry of Environment and Energy, through legislative regulation, granted the

right to properties that include both forest and agricultural areas to

be transferable, as regards the non-forest part, without this being considered

subdivision.

–Can a private individual claim ownership of an area?

In the event that a farmer wishes to claim ownership of the area they

cultivate, there are various paths they can follow, such as through

cadastral registration or by filing an appeal before the Forest Ownership Councils or

the courts.

-How are OSDI connected to Cadastre and E9?

-A relevant OSDI 2023 circular from OPEKEPE clarified that producers must

submit evidence of legal possession of the agricultural parcels. Such as:

A. Agricultural parcel leases.

B. Registration of KAEC (National Cadastre Code Number).

C. Registration of ATAK (Property Identification Number).

The data declared by the beneficiaries via KAEC will be cross-referenced with

the Cadastre database, as well as the AADE (E9) database.

Source: https://ecopress.gr