7 The creation of a specialised Asylum Service and decentralised offices has without any doubt resulted in considerable improvements, notably with respect to the accessibility and quality of the first instance of the asylum procedure.17 On the basis of a Memorandum of Cooperation, UNHCR provides legal and technical support to the caseworkers of the Asylum Service with a view to building their capacity and improving and maintaining the quality of decision-making as part of quality assurance of the asylum process. Such support is provided to all the Regional Asylum Offices and, as a result, UNHCR staff is present both in the Regional Asylum Office of Southern and Northern Evros. The 2011 law also established a new Appeal Authority, which coordinates the work of independent Appeals Committees, responsible for examining appeals against negative decisions or decisions to grant subsidiary protection by the Asylum Service. It was initially envisaged that 19 Appeals Committees would be established, but the number was reduced to 10 since September 2014. In addition, from June to mid-September 2014, the Appeal Committees did not function at all because the legality of the procedure of appointment of their members was contested and later challenged before the Council of State.18 Progress was also made in addressing the backlog at the appeal stage of the procedure, according to the European Asylum Support Office (EASO), which reported a significant reduction of the backlog of appeals with 15,528 cases out of 52,000 pending appeal cases under the old procedure removed from the backlog.19 At the end of September 2014, it was reported that 37,306 cases remained pending at second instance of the old asylum procedure.20 However, whereas progress was made to a certain extent in these areas, important gaps remain in Greece’s asylum system. Reception conditions for asylum seekers remain extremely problematic for asylum seekers in Greece today as the reception capacity is largely insufficient in light of the number of asylum seekers present on the territory. While close to 9,500 persons applied for asylum in Greece in 2014,21 there are about 1,100 places available in reception centres and apartments.22 The lack of reception places, including for particularly vulnerable asylum seekers such as unaccompanied children and victims of torture, is worrying as it often results in prolonged periods of detention in substandard conditions and people having to fend for themselves.23 Despite the above-mentioned progress made with regard to the quality of the asylum procedure, delays in the registration of asylum applications both in Athens and the Regional Asylum Offices continue to exist. According to the Director of the Asylum Service, its first priority is to maintain the current policy of ensuring that those applying for asylum in Greece receive a first instance decision within three months from the registration of their application. As a result it is not possible for the Asylum Service to register every potential asylum seeker immediately as this would be impossible to handle by the Asylum Service with its limited resources.24 While 150 to 250 people present themselves on a daily basis in Athens, the Office is able to register only about 30 applications per day.25 A new pilot project was launched in August 2014 whereby persons wanting to apply for asylum can ask for a registration appointment through Skype (in French, English, Arabic Farsi and Dari), an initiative that is in principle welcomed by refugee organisations.26 However, those who are not able to register their application are not provided with any written proof of their intention to apply as the policy of the Asylum Service is to register the asylum applications insofar as there is capacity to process asylum applications within a reasonable time. According to the Director of the Asylum Service, the previous practice of the Hellenic Police to issue appointment slips to asylum seekers before their application was actually registered resulted in abuses as those documents were often passed on or sold on the black market.27 In ECRE’s view, the approach described above potentially exposes refugees and other persons in need of international protection to refoulement. Not having had the opportunity to register their asylum application and lacking any proof of the fact that they presented themselves at the Asylum Service for the purpose of registering their claim, asylum seekers are at risk of being arrested by the Police and removed without their need for international protection being examined. Moreover, such an approach is in breach of Article 6 of Directive 2013/32/EU on common procedures for granting 17 See AIDA, Country Report Greece - Registration of the Asylum Application, Update August 2014. 18 See a Public Statement on this issue published on 30 October 2014 by the Greek National Commission on Human Rights. 19 See EASO, EASO Operating Plan for Greece. Interim Assessment of Implementation (hereinafter ‘EASO Interim Assessment Greece’), 28 July 2014, p. 9. 20 European Commission, Staff Working Document on the Assessment of the implementation Greek Action Plan on Asylum and Migration management, 6 October 2014, SWD(2014) 316 final, p. 11 21 Greek Asylum Service, Statistical data January to December 2014. 22 According to the European Commission, 1160 places were available as of September 2014, while the latest UNHCR report mentions a total number of 1063 by the end of October. See European Commission, Assessment Implementation Greek Action Plan, p. 12 and UNHCR, Greece as a Country of Asylum, p. 19. 23 As discussed below, the absence of a well resourced reception system in Greece jeopardizes the successful operation of the first reception model in practice to a large extent. See sections 5 and 6 of this report. 24 Interview with Mrs. Maria Stavropoulou, Director of the Asylum Service, 4 December 2014. 25 See AIDA, Country Report Greece, Registration of the Asylum Application, Update August 2014. 26 According to UNHCR, a total of 215 appointments had been scheduled by 17 October 2014. See UNHCR, Greece as a Country of Asylum, p. 17. 27 Interview with Mrs. Maria Stavropoulou, 4 December 2014.