The Ramsar Convention on Wetlands

Expression of opinion on Greek Ramsar wetlands and possible removal from the Montreux Record, 1999

Editor’s note: From the establishment of the Montreux Record (the "record of Ramsar sites where changes in ecological character have occurred, are occurring or are likely to occur") by Recommendation 4.8 of COP4 in Montreux, Switzerland, in 1990, all ten of Greece’s Wetlands of International Importance have been present on the list. The following report was prepared in 1998-99 and submitted by the Government in March 1999 as part of the process of deciding upon the appropriateness of removing some of those sites from the Record, in a procedure outlined by the Guidelines for operation of the Montreux Record adopted by Resolution VI.1 (1996). The matter was discussed further during COP7 in May, at which time alternative interpretations were offered on several issues, particularly by WWF-Greece. In the end  three sites – Artificial Lake Kerkini (10,996 ha), Evros delta (9,267 ha), and Lake Mikri Prespa (5,078 ha) – were removed from the Record on 18 May 1999.

The report on the advisability of removing certain Greek Ramsar sites from the Montreux Record is included here as an example of  the Guidelines for the operation of the Montreux Record in practice.

 5 March 1999

P. A. Gerakis
School of Agriculture
Aristotle University of Thessaloniki

Maria Anagnostopoulou
Greek Biotope/Wetland Centre

K. Georghiou
School of Biology
University of Athens

M. J. Scoullos
School of Chemistry
University of Athens

Preamble

1. Introduction

1.1. Reprimands and recommendations by the Ramsar Convention
1.1.1. Reprimands and recommendations of the 4th, 5th, 6th COP
1.1.2. Conclusions and proposals by the Ramsar Bureau
1.2. Prerequisites for removal
1.3. Purpose of the report

2. Progress in the conservation of the Greek Ramsar wetlands

2.1. National Policy and Strategy
2.1.1. National Policy for wetlands
2.1.2. National Strategy for Wetland Resources for the period 2000-2005
2.2. Delineation, legislative institution
2.3. Wise use
2.3.1. Management plans
2.3.2. Management bodies
2.3.3. Infrastructure for information, wardening etc.
2.3.4. Programme Agreements

3. Developments with regard to the Acheloos issue

4. Thoughts of the Committee on the issue of removal

5. Synopsis of the Committee's opinion

ANNEXES
ANNEX I Conclusions and recommendations of Ramsar technical reports
ANNEX II Conservation and management measures for the Ramsar wetlands
ANNEX III Programme Agreements for the Ramsar wetlands
ANNEX IV Completed Montreux Questionnaires for the Wetlands
ANNEX IV-1 Lake Mikri Prespa
ANNEX IV-2 Artificial Lake Kerkini
ANNEX IV-3 Evros Delta
ANNEX IV-4 Lake Volvi
ANNEX V Axios - Loudias - Aliakmon Delta & Aliki Kitrous

 PREAMBLE

The present report was prepared in response to the 54825/2715/9.7.98 letter of the Ministry of Environment. It expresses the personal opinions of the Committee members who prepared it. These opinions were based on information that the Committee was able to gather until November 1998.

The Committee, acknowledging that several issues and questions of the report may be subjected to numerous and diverse evaluations, express the wish that these evaluations are communicated to them.

The Committee warmly thank all the staff of the Ministry of Environment for supplying information as well as all the agencies, NGOs and colleagues who contributed additional information orally or in writing.

1. INTRODUCTION

1.1. Reprimands and recommendations by the Ramsar Convention to the Greek State concerning Greek wetlands of international importance

1.1.1. Reprimands and recommendations by the 4th, 5th and 6th Conference of the Contracting Parties of the Convention

During the last 3 Conferences of the Contracting Parties of the Ramsar Convention (Montreux 1990, Kushiro 1993, Brisbane 1996), certain reprimands and the relevant recommendations were addressed to Greece, as follows:

1. The boundaries of most Greek Ramsar wetlands have not been precisely described, nor delineated in maps, as required by article 2 of the Convention (COP 1990, REC 4.9.5)
2. All Greek wetlands were marked at the Regina Conference (doc. C.3.6), as having suffered or potentially threatened by alteration of their ecological character (COP 1990, REC 4.9.5)
3. In spite of the measures already taken or to be taken soon by the Greek State for the protection of the Ramsar wetlands, the threatening agents are evident (COP 1990, REC 4.9.5)
4. The Greek Ramsar wetlands, except Amvrakikos and Prespa, have not been definitely delineated, and this should be done soon by the Greek State (COP 1990, REC 4.9.5, COP 1993, REC 5.5.1) and also
5. The final maps of Amvrakikos and Prespa have not been submitted to the Ramsar Bureau (COP 1993, REC 5.5.1)
6. No final maps have been submitted to the Ramsar Bureau for three out of the 11 Ramsar wetlands, and this should be done by April 1997 (COP 1996, REC 6.17.1)
7. The Ramsar Bureau is concerned about damages at Messolonghi and also about threats from plans of diversion of the rivers Acheloos and Evinos, and urges the Greek State to proceed to all necessary actions in order to prevent the adverse impacts from the implementation of these plans (COP 1993, REC 5.5.1)
8. The Greek State should elaborate management plans for the Ramsar wetlands in its territory according to RES. 5.7 of COP 1993 (COP 1993, REC 5.5.1)
9. The Greek State ought to ensure their wise use, (COP 1993, REC 5.5.1, COP 1996, REC 6.17.1), e.g. by reinforcing the implementation of existing regulations and/or by implementing the Wise Use Guidelines of the Ramsar Convention, with the technical aid of the Ramsar Bureau (COP 1996, REC 6.17.1)
10. The Ramsar Convention hopes that, when Turkey becomes a party, article 5 of the Convention will be implemented in the Evros Delta (bilateral consultations for the fulfilment of obligations derived from the Convention, co-ordination and support of policies and rules/regulations concerning the maintenance of transboundary wetlands, as well as their flora and fauna) (COP 1993, REC 5.5.1)
11. In spite of the progress made by the signature of 3 JMDs for equal number of Greek Ramsar wetlands, they all still lack i). a permanent legal validation via PDs and ii). management plans, issues which should be urgently settled by the Greek State (COP 1996, REC 6.17.1)
12. Following the decision of the Greek government to proceed to the implementation of the plan for the diversion of river Acheloos (with a discharge of 600 millions cubic metres per year instead of 1.1 billion cubic metres per year as in the original plan), the continuing discussion of the issue in academic circles and in the circles of environmental NGOs, as well as the preoccupation that the said works are already under way, the Convention asks the Greek government to reconsider the entire plan and proceed to the elaboration of a study on the hydrology and management of water resources of the Thessaly Plain and the area of Etoloakarnania (COP 1996, REC 6.17.1)

1.1.2 Conclusions and recommendations from the technical reports of the Ramsar Bureau

The said technical reports deal with legislative, institutional and, at a lesser degree, technical issues immediately concerned with the preservation and wise use of the Greek Ramsar wetlands, and proceed to relevant recommendations, more detailed than those expressed during the Conferences. These reports were composed by the expert appointed by the Ramsar Bureau Dr. Cyrille De Clemm, following his visits to Greece in November 1988 and May 1989. In Annex I the conclusions and recommendations of those reports which concern the Ramsar wetlands in general (and not each wetland individually) are presented.

1.2 Prerequisites for formulating a request for removal from the Montreux Record

From the above it is inferred that the issues whose progress the Greek State must document to the Ramsar Bureau, in order to proceed to the formulation of a request to remove a number of Greek wetlands of international importance from the Montreux Record, are mainly the following:

1. The precise delineation of all Greek Ramsar wetlands and the submission of the relevant maps to the Ramsar Bureau.
2. The permanent establishment of the said wetlands via legislative acts
3. The development of the issue of the river Acheloos diversion and the impacts of this work on the wetlands of Messolonghi
4. The elaboration of management plans for Greek Ramsar wetlands
5. The ensuring of the maintenance of the ecological character and the wise use of Greek Ramsar wetlands, with all existing resources and manners (enforcing the implementation of existing rules and regulations, technical support by the Ramsar Bureau, implementation of the Wise Use Guidelines of the Ramsar Convention)

1.3 Purpose of the report

This report aims at submitting to the competent for Ramsar issues service of the State, an opinion on the degree to which the prerequisites for the formulation of a request for the removal of Greek wetlands from the Montreux Record are today fulfilled.

2. PROGRESS CONCERNING THE CONSERVATION OF GREEK WETLANDS OF INTERNATIONAL IMPORTANCE

The progress achieved during the past few years and the ever increasing interest of the Greek State in the protection of wetlands, particularly those of international importance, is reflected mainly in three texts, which have been forwarded by the Natural Environment Management Section of the Ministry of the Environment (IPEHODE) to the Ramsar Bureau from 1996 to 1998. These texts have been used as the basis for the composition of the general part of this report:

1. Reference text 1: Ramsar Convention. 1998. Greek Report (36 pp.). Forwarded to the Ramsar Bureau (translated in English) with ref. num. 56901/3931/28-9-1998
2. Reference text 2: Additional Information to Greek National Report of 1996 on measures taken by Greece for the protection of wetlands in Montreux Record (6 pp.). Forwarded to the Ramsar Bureau with ref. num. 51057/598/19-2-98
3. Reference text 2: Ramsar Convention. 1996. National Report: Greece (17 pp.). Forwarded to the Ramsar Bureau with ref. num. 13264/900/5-3-96

Moreover, an advanced draft of the National Strategy for Wetland Resources (see 2.1.2), which is now nearing the final stage, includes quite detailed information on the positive actions promoting the conservation of Greek Ramsar Wetlands.

2.1 Forming a national policy and strategy for wetlands

2.1.1. National Policy for Wetlands

The main characteristics of the national policy for wetlands concerning the time-span 1995-2000, which forms a part of Greek Environmental Policy, are described in reference text 1, par. 2.1. Most of the actions form a part of the Operational Programme "Environment" of IPEHODE and are included in the sub-programme "Natural Environment". National policy on wetlands focuses on:

1. Their assessment at a national level with European criteria (and inclusion of the most valuable ones in the Natura 2000 Network)
2. Precise delineation, description and safeguarding of the protected item by determining the prohibited and permitted uses, for each of the most important wetlands, and validation of all the above by legislative acts (JMDs, directed to the respective PDs)
3. Management planning for wetlands (elaboration of relevant studies, Specific Environmental Studies)
4. Implicating the local communities in wetland conservation, through financial support of wetland-neighbouring communities for application of sustainable practices in the primary production, as well as for information, awareness, environmental education and training activities.
5. Prevention of degradation of wetland resources in general, through the institution of Environmental Impact Assessment (EIA), and of water quality in particular through monitoring in large rivers and coastal areas.
6. Promotion of relevant scientific research and observation
7. Re-creation, restoration and rehabilitation of wetlands
8. Promotion of international co-operation on sustainable management of wetlands in the Mediterranean, and finally
9. Incorporation of the concept of multiple wetland values in sectorial policies for fisheries and tourism

The national wetland policy includes actions and measures resting mainly in the competencies of the Ministries of Environment (IPEHODE), of Agriculture, and of Development. Apparently, in the implementation of the above policy, wetlands of international importance are a priority. Particularly concerning the Ministry of Agriculture, its policy is to encourage environmentally friendly crop and animal farming in significant wetland sites, in the context of obligations and opportunities provided by Regulation 2078/92 of the Council of the European Community. At this moment the Physical Planning and Environmental Protection Division is promoting two agri-environmental projects: 1. The "project for the protection of especially important habitats (Natura 2000 Network)", applied in riparian zones of sites of the Natura 2000 Network in Northern Greece, among others the lakeside areas of lakes Prespa, Koronia and Volvi, Kerkini, Ismaris and Vistonis and 2. The work of a comparative applied research entitled "Observation and development of organic farming", which will determine certain parameters (socio-economic, agricultural and environmental) in organic and conventional farming systems, aiming at the acquisition of the necessary knowledge for the promotion and exercise of organic farming.

On the part of IPEHODE, an action indicative of its concern for the natural areas is the promotion, as part of the Operational Programme "Environment" (2nd Community Support Framework - CSF), of a project entitled "Mapping and description of habitat types in sites of Community and National Importance for the conservation of nature", whose implementation, following an extensive preparation, is expected to start in the first months of 1999. This work concerns all sites of the Natura 2000 Network which constitute the Scientific Catalogue (246). The work is expected to contribute to the sustainable management of the Ramsar and other important Greek wetlands in the near future, as it will fill knowledge gaps.

The Environmental Protection Division recently formed in the Ministry of Foreign Affairs is expected to enhance international co-operation on the conservation of transboundary wetland resources of the country. This new service will be dedicated entirely to natural resources protection issues, promoting actions that contribute to tackling transboundary environmental problems. The Division has already opened a channel of communication with national NGOs, inviting them to participate in an informal consultation forum.

2.1.2 National Strategy for Wetland Resources for the period 2000-2005

The said strategy is at an advanced preparation stage and is to be completed in the first semester of 1999. The national strategy on wetlands is being prepared following an initiative and under responsibility of the Environmental Planning Division of IPEHODE. This action, on the one hand will fulfil the relevant commitment of our country as a contracting party to the Ramsar Convention, and on the other, will express the strategic choice of the State on wetland resources, as it is formed in view of the existing strategic options at a national, European and international level. Its general objective is "the conservation and rehabilitation of all functions and values of wetland resources of Greece as a contribution to the sustainable development of the country", while the specific objectives and the respective actions prescribed for their fulfilment, correspond to a great extent to the specific objectives and actions of the Ramsar Strategic Plan.

Further specification of the National Strategy in an action plan for the most important wetlands of Greece, will be completed within the same time period, in co-ordination with the Master Plan for Nature, elaborated by IPEHODE (to be completed within the first semester of 1999) and in combination with the financial framework of the 2nd CSF. In the Action Plan priority is given to the Ramsar wetlands, and next to them, to the rest of the wetlands in Natura 2000 Network (a total of 100 wetlands). An aid to the specification and prioritisation of conservation actions in wetlands, is the existence, since 1994, of the "Inventory of Greek Wetlands as Natural Resources", as well as the Property Registration (first stage of the work for the production of a National Cadastre), which, by a national decision, began with the Ramsar wetlands.

2.2 Delineation, map submission and legal validation

Final maps for all Greek wetlands of international importance have been sent to the Ramsar Bureau.

Joint Ministerial Decisions (JMD) have been signed for all wetlands except Lakes Volvi and Koronia and Lake Mikri Prespa, from 1990 to the end of 1998. Lake Mikri Prespa, as well as the Evros Delta, is protected by a PD before that time. The JMDs delineate precisely the item of protection in each site, define the zoning corresponding to various degrees of protection, and describe the permitted or prohibited activities, as well as the conditions for exercising the permitted activities in each zone. The exact data of the JMDs are given in Annex II. The JMDs have a three-year duration. It has not been possible to issue PDs. We note that, nevertheless, the boundaries, zones and protection measures defined in them, appear to be valid even after the expiry of the three year period up to the issuing of a PD with a permanent duration (as an example we quite the relevant Decision of the Council of the State ref.no. 2343 of 1987, rejecting the appeal of a citizen who, invoking the lack of a legally valid delineation, asked for a permission to install a ship dismantling unit in a location which, according to the then recent delineation study of IPEHODE (1986), fell within the protection core area of the Nestos Delta wetland). In the past few years, the local authorities and communities have begun to realise this fact, as the concern of the State for these sites is consistent.

Within the scope of the "Programme for handling specific environmental problems and system for the operation and management of protected areas" elaborated within the 2nd CSF from 1996 to this day, Specific Environmental Studies (SES) have been elaborated for the Ramsar sites, leading to draft PDs. At this moment draft PDs are ready for certain sites, while for the rest of the sites the draft PDs are about to be delivered. These drafts are going to be forwarded to the local communities with corresponding information campaigns, in order to facilitate social consent. This procedure will definitely require time.

The "Programme for handling specific environmental problems and system for the operation and management of protected areas" in its various stages has been described to the Ramsar Bureau in reference text 2.

2.3. Wise use

2.3.1. Management plans

The JMDs for the Ramsar sites, as mentioned above at 2.2, define rough management guidelines, via the zoning of the subject of protection, the definition of prohibited or permitted activities and the definition of conditions (i.e. stricter EISs) for exercising these activities. The SESs, whose structure greatly coincides with that of a management plan, also proceed to the formulation of management guidelines for each site, namely describing and documenting the necessity for certain projects, regulations and generally all kinds of interventions (e.g. technical, administrative, financial, institutional etc.). Specific operation and management regulations for protected areas (management guidelines) will be included in the forwarded PDs. In other words, the PDs will prescribe a management programme. For management issues of greater maturity, this programme may be specific, while for issues which require further specification, the studies and other steps required for full specification of the relevant management measures will be prescribed. The elaboration of detailed management plans will be co-ordinated by IPEHODE.

Some of the projects that have emerged within the scope of the "Programme for handling specific environmental problems and system for the operation and management of protected areas", considered by the local authorities and by the central competent authority of IPEHODE to have priority, have already begun to be implemented, under Programme Agreements (PA), which have been signed for all Ramsar sites (see 2.3.4).

It should be noted that since 1986, when the first delineation studies of the Ramsar wetlands were drafted, up to now, other management studies for the sites have also been elaborated, and although they were not formally adopted, they have been and still are useful, to a various degree, as reference material for the recent studies.

Legislatively established permanent management bodies have not yet been created for any of the sites. The SESs elaborated within the scope of the 2nd CSF include, among other things, suggestions of the researchers for the creation of management bodies (MB) of the sites in question. IPEHODE has clarified the basic prerequisites for the formation and function of the MBs, as well as the specifications these must fulfil with regard to their objective, their main and supportive functions, their organisation and administration, based on the obligations and opportunities provided by the existing institutional framework. At a next stage, it will assess the relevant proposals, and proceed to the creation of the MBs, which will again be validated through PDs. Moreover, the idea of constituting an interministerial council charged with the co-ordination and supervision of the operation of the entire MB system is considered.

Given the existence of an infrastructure (Information Centres, guardhouses, observation towers, vehicles, environmental interpretation equipment etc.), and until the creation of the Management Bodies, Preliminary Management Schemes (PMS) in the form of Joint Committees have already been established at the Ramsar sites, via the Programme Agreements signed by the Ministers of the Environment and of Agriculture, the Regional and the Local Services. These Joint Committees receive administrative and secretarial support by the relevant Local Development Institutions. NGOs are invited to participate in these schemes, depending on their specialisation. These schemes, which prepare the ground for the oncoming institution of the permanent MBs, aim at i). directly responding to the arising management problems of the sites and ii). executing projects related to the infrastructure, monitoring and management. Moreover, they informally act as co-ordinators of the individual activities which are subject to sectorial management by the relevant services. The PMSs have been staffed with specialised scientific personnel. The operation cost of the first stage is covered by the 2nd CSF of the European Community. Since the beginning of the PAs (see Annex III), the PMSs meet at least once every three months, so as to monitor the PAs’ projects, discuss the proposals of the Consulting Committee, or other urgent matters associated to the management of the relevant wetlands. The Consulting Committee consists of representatives of users’ groups and meets twice or thrice a year.

The problem of guarding the sites is very serious and its gravity varies greatly among various Ramsar sites and among various locations within a single site. The respective personnel of the Forestry Service, already very thinly spread, are not being replaced after retirement. The practice of non- replacement or partial replacement has been going on for years in almost all public services. In any case, the sites are large (from 5200 ha to 34000 ha) and their absolutely effective guarding would require a very large investment in human and material resources. It is pointed out, however, that in all sites the PMSs have already, since 1997, hired "wardens-ecoguides", who may not have the authority to arrest violators, but it seems that their presence in the area may act against illegal acts through both prevention (by persuasion) and suppression (by pressing charges at the state authorities). This fact is enhanced by the awareness of the local population, which has been increasing during the past few years in many sites (not in all).

Since 1992 and by the use of several funding sources, Information Centres have been constructed and equipped (office and environmental interpretation equipment) in all sites, coupled with guardhouses and observation towers. For each site, the completion of this infrastructure and mainly of its equipment, in order for it to become fully operational as a focus of information, touring, ecotourism and other activities, has been included in the relevant PAs, through which the problems of construction defects, damages etc. are also being tackled.

These Agreements have an annex with scheduled projects and activities, a time plan and a budget, for each of the Ramsar sites. The signature date and the budget per site are cited at Annex III. The projects included in the PAs are financed mainly by the 2nd CSF, and secondarily by other funding sources. The time span for their implementation is the four-year period 1996 -1999, but most of them were signed on 6-5-97. At this moment, the individual projects are at various stages of implementation.

The objectives of the PA for each site are:

a) To promote the procedures for the setting up of the Union for the Protection and Promotion. For each site, the 1st stage (4 months), foresees the establishment of the Union for the Protection and Promotion by the respective competent Local Authority Organisations, which, from that moment on, takes over from them entirely and replaces them in the interests and obligations arising from the PA. The Union for the Protection and Promotion is obliged to facilitate all contracting parties in the implementation of their commitments, to proceed to all necessary actions for the provision of supplementary equipment for the operation of the infrastructure, to receive the existing infrastructure and equipment and use it for the implementation of the PA’s objectives or to concede the equipment to another contracting party for its use, and finally, to deliver to IPEHODE the infrastructure and the equipment in a good and serviceable condition to the future MB.

b) To organise a one-day conference for the support of the Union as well as to publish the necessary support material.

c) To operate the Information Centre as a reference and information point for the functions - values of the site, as a promotion mechanism for information and sensitisation and as a mechanism for implementation of touring and ecotouristic programmes and other specific activities. A number of actions, studies and projects are provided for this function: i. procedures for the support, co-ordination, continuous information and pinpointing of problems to the competent authorities, ii. planning and implementation of projects for information and awareness of the competent bodies and the public, iii. planning and implementation of projects for the attraction, reception, information and guiding of visitors and specific groups in the Information Centre and in the protected area, iv. organisation and operation of archive and library, v. organisation of 1-day conferences, vi. publication of information material, production of video tapes and other audio-visual systems for the illustration of the site, and publication of a quarterly information bulletin, vii. elaboration of specific projects (study for promotion projects, training of wardens - guides and personnel of the Information Centre, monitoring of environment quality).

d) To plan a project for the guarding of the site by the competent forestry authority (and by the Prefecture of Thessaloniki for lakes Koronia and Volvi).

It is apparent (see par. c above) that particular importance has been placed in information and awareness actions in general. This is not incidental; rather it is based on the belief that true protection can be accomplished only under the condition that local communities know and appreciate the special values of their area and embrace the need for their conservation. Also according to the opinion of the scientists working at the Information Centres, the part these have begun to play as cores of information and co-ordination of individual actions, appears to be significant. Moreover, there has been a definite increase of environmental education activities developing in these wetlands. For other education and information - awareness actions, see reference text 1, Ramsar Strategic Plan - General Purpose 3: To raise awareness of wetland values and functions throughout the world and at all levels.

The PAs directly implicate the Local Authorities, and consequently the local communities they represent, in management and protection affairs of the respective wetlands.

3. DEVELOPMENTS ON THE RECOMMENDATIONS CONCERNING THE ISSUE OF THE RIVER ACHELOOS DIVERSION (see 1.1.1, points 7 and 12)

Following the political decision of the Greek State to proceed with the implementation of the project of partial diversion of Acheloos with a discharge of 600 millions cub.m./year instead of 1.1 billion cub.m./year of the original project, a joint decision was issued, with ref.no. 23271/15-12-95, with the title: "Adoption of environmental terms for the construction and operation of works for the partial diversion of the upper part of the river Acheloos towards Thessaly". The Environmental Impact Statement (EIS) which led to the issuing of this decision is based on the aforementioned political decision. Nevertheless, five NGOs (see below) claim that no technical review of the works was done, and the works continue on the basis of the original technical studies, which referred to the originally planned discharge. On 15-2-96, these five NGOs, namely the Hellenic Ornithological Society, the Hellenic Society for the Protection of the Environment and Cultural Heritage, the World Wide Fund for Nature, the Hellenic Society for the Protection of Nature, and New Ecology, submitted to the Council of the State a petition for the annulment of the decision for issuing environmental terms. The case will be tried on 19-3-99. The arguments against the decision are associated to the adequacy of the EIS, the omission of the consideration of alternatives, the violation of prevention and sustainable development principles, the quality of the EIS’s contents and the procedures for the public access to the EIS.

4. THOUGHTS OF THE COMMITTEE ON WHETHER OR NOT TO REMOVE GREEK WETLANDS OF INTERNATIONAL IMPORTANCE FROM THE MONTREUX RECORD

4.1 It should be noted in the first place that in this report, the members of the Committee express their personal opinions, which are not necessarily in agreement with the opinions of the bodies they work for or participate in or co-operate with. These opinions are based on their personal experience (whenever and wherever it exists) and on the assessment of the existing information they have been able to assemble. The existence of other data, which could affect value judgement, cannot be excluded.

4.2 We interpret the inclusion of a wetland of international importance in the Montreux Record as a motive for the competent authorities to correct the deficiencies with regard to their obligations under the Ramsar Convention. In the case of Greek wetlands, the main deficiencies, according to the resolutions and recommendations of the relevant Convention organs (see Introduction) are mainly concerned with the institutional status of the wetlands (delineation, issuing of specific regulatory acts for the regulation of uses, establishment and legal validation of management bodies etc.). There are also motivations concerning technical deficiencies, e.g. for the sustainable use of wetland resources.

4.3 The institutional deficiencies verified by competent organs of the Convention are described rather clearly in the introduction of this report. Indeed, there has been a delay in their fulfilment on the part of the central authority. For example, the 10 delineation studies for an equal number of Ramsar sites, of good quality even with current standards, which were produced in 1986 through an initiative of IPEHODE, could have been used as a basis for the issuing of basic regulatory acts before 1988. Today, many of these deficiencies have been corrected or are at the stage of completion, except for the management bodies issue, which has proceeded at a lower pace.

4.4 From 1982 to this date several hundreds of documents have been published (studies, reports, letters), some of which were co-signed by us, stressing with great emphasis the necessity to establish and to legally safeguard management bodies for the wetlands (and other natural areas). Today, judging by the result of the last two years, we have the view that the emphasis placed during all these years on this issue may have been rather excessive. We are not sure that a type of management body, which will be large, complex and intricate, as most of the suggested patterns were, and indeed still are today, can greatly improve the management conditions of an area without prior fulfilment of the most important prerequisite. As such we believe to be a satisfactory level of environmental awareness of the inhabitants, in order for them to approve of regulations in favour of the natural values of the wetlands. Not only was this prerequisite not fulfilled in all wetlands during the last decade, but also in some there has even existed a negative attitude. We presume, therefore, that the establishment of such bodies for wetlands in the past decade may not have produced the expected results. A possible exception may be Lake Mikri Prespa, because there are indications that if a special and appropriately staffed forestry office had been established since 1976 for the Prespes National Park, today the situation there would have been better in several aspects.

4.5 We do not know whether the motive impelling the Greek State to prefer the formation of rather informal preliminary management schemes to the direct establishment of legally validated bodies was hesitation or prudence. The results now show that it was prudence, because the schemes deal with problems of various form and gravity, both objectively and subjectively. Let us not forget that there is not sufficient experience in Greece for the formulation and function of relevant institutions; therefore the preliminary stage may be considered useful. Indeed, we are not quite certain whether the conditions in all Ramsar wetlands will be mature until the end of 1999 for the legal validation of the final management bodies. We quote here the opinion of the expert researchers on the subject of the management bodies (T. Arapis and E. Pappas 1994 personal communication), according to which it is advisable that the establishment of bodies moves parallel to or even follows the implementation of protection and promotion projects and actions.

4.6 The institutional deficiencies that clearly exist should probably not be considered as an absolute argument against the removal of the Greek wetlands of international importance from the Montreux Record. A great number of measures have been (and are still being) taken in favour of the protection and sustainable management, in spite of these institutional deficiencies. The settling of pending issues is definitely demanded, and in many cases it may promote and safeguard certain issues to a much higher degree, e.g. by facilitating the legal suits against illegal or unwise actions.

4.7 The committee’s attention inevitably focused less on institutional matters, where the above-mentioned deficiencies exist, and more on substantial matters (i.e. actual conservation). In our opinion, the most essential exhortation of the Convention bodies to the Greek State is to promote the sustainable use of wetland resources. Has the state (and the Greek society in general) responded to this exhortation? Chapter 2 of this report, as well as the answers to the attached questionnaires, indicates that there has been a definitely greater response in this decade compared to the past one. Can this be considered satisfactory? We believe that in general it cannot, if we assess the result, using the ideal management objective for each wetland as a criterion. Nevertheless, we believe that, if we use the operational management objective as a criterion, a remarkable progress has been achieved in certain wetlands and in certain individual units of wetland complexes, while in others the situation is stationary or deteriorating. Generally, the factors inducing positive change have not yet been able to reverse the factors inducing negative change (e.g. ignorance, wrongly intended interests of certain social groups). It is, however, remarkable that negative trends have been observed to be decreasing in several cases. Of course, we also express our disappointment about the fact that in some wetlands (i.e. Nestos Delta, Lake Vistonis - Porto Lagos, Lake Ismaris and Rodopi Lagoons) aggravation phenomena are observed today compared to the past decade.

4.8 During the formulation of our opinions, we were preoccupied about those Ramsar sites, which virtually consist of complexes of distinct individual wetland units (e.g. lakes Volvi - Koronia, Amvrakikos Gulf). We observed obvious differences in the condition of individual wetland units. Scientifically there can be no doubt that the fragmentation of a protected area in sections of various protection degrees can often be problematic for the whole. Nevertheless, we have decided to suggest to IPEHODE to consider the separation of individual wetland units with great differences in their current condition, with respect to their inclusion in or removal from the Montreux Record. In the judgement of the Committee, such a separation might possibly function in favour of a more effective protection of the remaining sections. We do not know whether our suggestion is compatible to the existing procedures.

4.9 There are indications that the signing of the Ramsar Convention by the Greek State had a positive effect on the protection of Greek wetlands. In the case of Lake Mikri Prespa, however, the contribution was smaller, due to the practically stricter protection status offered to the lake by the fact that it is part of the National Park. There are no indications that the inclusion of the Greek Ramsar wetlands in the Montreux Record had any positive or negative effect at a prefecture or local level. On the other hand, we presume that the maintenance of certain wetlands in the Montreux Record and the possible notification of this fact to the local population and the staff of the public services, who, in the current decade are making sincere positive efforts, would cause a disappointment or even greater difficulties in regulation implementation. We note that the social ambient in these areas is equally sensitive and change-prone to the natural environment.

4.10 We are of the opinion that the questionnaires of the Ramsar Bureau for inclusion - removal, in the way they are structured and worded do not fully facilitate the formulation of answers. They allow for improvement both in form and in substance. We suggest to IPEHODE that it proposes to the Ramsar Bureau the improvement of the questionnaires.

4.11 We must place emphasis on a principal preoccupation, but also a constraint affecting the entire report and particularly the final proposition and categorisation of the wetlands with regard to maturity for removal. The preoccupation consists in whether the deficient institutional protection of the sites is a factor sufficient for maintaining them in the "black list" or whether one should focus on what really happens in the field. If the second is more important, a limitation results from the lack of reference levels at an international scale. What comparison can there be between the condition of Greek wetlands and the condition of other countries’ wetlands? Is it scientifically sound to compare the condition (or the potential for conservation or rehabilitation) of a freshwater wetland in an arid or semi-arid climatic zone and a similar wetland in a wetter zone? Should the inclusion - removal criteria be applied with the same strictness in both cases? Are wetlands of international importance in Greece, all of which are blacklisted, more neglected compared to non "black-listed" wetlands in other countries, even with a similar climate, similar financial and social dependence on wetland resources, similar geomorphology, equal or higher know-how and equal or higher standard of living? If it were possible to answer these questions, then the assessments and proposals of this report might have been different.

4.12 It is probable that many members of the scientific community and staff of public administration as well, will strongly disagree with many individual points and with the entire point of view of the report and with the proposals in particular. We hope that these disagreements will also be expressed in writing, particularly concerning possible errors or omissions of facts. It would also be useful to hear the different philosophies concerning the criteria, the way of their application among wetlands of the same country and among wetlands of different countries.

4.13 Finally, we repeat our general observation that in the period 1990-1998 in Greek wetlands of international importance several problems appear to be in the prospect of resolution (notwithstanding some retrogression) but progress has also been noted (there has also been progress in preparing the ground for the restoration of certain wetlands which are not of international importance). Although it is not immediately related to the question put to the committee, we cannot refrain from mentioning the preoccupation caused by the notification of the rather recent intentions of certain public services and social groups to drain parts of non internationally important wetlands for "development" purposes. The timely intervention of citizens, expert scientists and of the Environmental Planning Division of IPEHODE has averted the implementation of these intentions so far, but the danger of harmful interventions remains for numerous other small wetlands.

5. SYNOPSIS OF THE COMMITTEE’S OPINION

Based on the information we have been able to assemble on wetlands of international importance in Greece, our assessment of this information and within the limitations expressed previously and in Annex IV, we have the opinion that:

5.1 The arguments in favour of the removal are stronger than those against for the following three wetland sites: Lake Mikri Prespa, Artificial Lake Kerkini and Evros Delta. Completed questionnaires for these three sites are attached (Annex IV-1 to IV-3).

5.2 The arguments against removal are stronger than those in favour for the site Lakes Volvi - Koronia in its entirety, because Koronia, as it is known, has been degraded so much as to have lost most of its values. Considering Volvi, however, if examined separately, the arguments in favour of the removal are stronger than those against. A completed questionnaire for lake Volvi is attached (Annex IV-4), in case the relevant procedures of the Ramsar Convention allow individual distinct units to be excluded from a Ramsar site consisting of a wetland complex.

5.3 The request for the removal of Axios - Loudias - Aliakmon Delta at this moment would probably be premature, due mainly to pollution of the river Loudias and continuing accumulation of solid domestic wastes in the delta. Nevertheless, if the resolution of these two problems is put forward within 1999, the request for removal of this wetland complex could be forwarded. A completed questionnaire can be found in Annex V.

5.4 The arguments against removal are rather stronger than the ones in its favour for the following two wetland sites: Amvrakikos Gulf and Kotychi Lagoon - Strofylia Forest. No completed questionnaires are attached for these two sites, but the most important arguments against the removal are noted below for each site:

Amvrakikos Gulf: Reduced inflow of fresh water to the lagoons, doubtful sustainability of fish production works, completely inadequate control of illegal hunting.

Kotychi Lagoon - Strofylia Forest: completely inadequate control of harmful activities in Strofylia Forest, completely inadequate control of illegal hunting in the site in general.

5.5 Arguments against removal are definitely much stronger than those in its favour for the following three sites: Nestos Delta, Lake Vistonis - Porto Lagos - Lake Ismaris - Rodopi Lagoons and Messolonghi Lagoon. No completed questionnaires are attached for these sites, but the most important arguments against the removal are noted below for each site:

Nestos Delta: The argument that the water needs of the natural ecosystems of the delta were ignored by those responsible for the function of the upstream dams, can be considered conclusive. Moreover the construction of works in the lagoons often proceeds in ways which are not compatible with the conservation of their multiple values.

Lake Vistonis - Porto Lagos - Lake Ismaris - Rodopi Lagoons: Construction of various works, mainly for land reclamation, and also road opening, resort housing etc., as if the entire site had been completely insignificant ecologically.

Messolonghi Lagoon: Extensive illegal housing in sensitive areas, inability of even an elementary control of illegal hunting, waste disposal. Even if these problems did not exist, the great issue of the river Acheloos diversion casts a very heavy shadow on the broader area.

We are of the opinion that these three sites of paragraph 5.1 above could be immediately removed (lake Volvi as well, should this be allowed under normal procedures), the site of paragraph 5.3 can be removed very soon, while the sites of par. 5.4 can be removed in the immediate future when there is an unquestionable progress in diminishing most of their problems. For the three sites of paragraph 5.5 we cannot proceed to estimates on the time required before their removal is considered. What worries us especially in these three latter areas is the lack of a significant progress in the issue of environmental awareness of certain, politically powerful, social groups, in spite of the ingenious efforts made by NGOs and public services.

Annex I: Conclusions of technical reports and recommendations of the expert appointed from the Ramsar Bureau, Dr Cyrille de Klemm, from his visits to Greece (1988 & 1989)

Annex II: Instituted protection and management measures for Ramsar wetlands

Annex III: Program agreements for the protection and promotion of Ramsar wetlands (1996-1999)

Annex IV: Completed questionnaires for each of the wetlands proposed for removal from the Montreux Record

Annex IV-1: Completed questionnaire for Lake Mikri Prespa

Annex IV-2: Completed questionnaire for Artificial Lake Kerkini

Annex IV-3: Completed questionnaire for the Evros Delta

Annex IV-4: Completed questionnaire for Lake Volvi (part of Lakes Volvi & Koronia)

Annex V: Completed questionnaire for the Delta of Axios - Loudias - Aliakmon (and Aliki Kitrous)

For further information about the Ramsar Convention on Wetlands, please contact the Ramsar Convention Bureau, Rue Mauverney 28, CH-1196 Gland, Switzerland (tel +41 22 999 0170, fax +41 22 999 0169, e-mail ). Posted 16 November 2001, Dwight Peck, Ramsar.