Α. Administrative procedures and problems such spaces in 25 to 30 facilities across the country, for 800 to 900 unaccompanied minors. However, we emphatically stress the fact that this measure can be implemented only on a temporary basis, and until their transfer to Accommodation Centers for Unaccompanied Minors within reasonable time, since these spaces lack the necessary specifications for the long-term stay of minors, especially when they do not meet the necessary conditions for their safe stay. Even though there is no documented study on the cost of operation of these safe spaces, according to a UNICEF representative in Greece, it is not less than the operating cost of the Accommodation Centers.79 Stay in RICs and Open Temporary Accommodation Facilities The stay in RICs and the Temporary Facilities has the purpose of registering and identifying the minors, as well as protecting them until they are referred to Accommodation Centers or more recently, to safe spaces. Their liberty is restricted only in the Lesvos (with possibility of exit) and Evros RICs, whereas in the other RICs of the country, unaccompanied minors are living in freedom, in full or in part, inside them. It was not possible to ascertain whether this different treatment was due to reasons related to the minor’s person or depended on the operating conditions of each center. In these cases it should be noted that on the one hand they are without supervision, and on the other hand that there are no rules of operation which they must comply with. This practice, which is in direct contrast to a long detention, has the same problems as detention, to the extent that there is no special provision for this vulnerable group, since it allows the development of unlawful situations and exploitation phenomena. On the other hand, unaccompanied minors in freedom, are outside the safe spaces of the Open Temporary Accommodation Facilities that were developed also in Accommodation Centers, after their referral by the competent Prosecutor, through the National Center for Social Solidarity. These Centers, numbering 46 in November of 2016, had a capacity of 1191 persons, and were accommodating 861 unaccompanied minors. In March 2017, 53 were recorded (for Theocharakis Foundation, on the subject of “The protection of unaccompanied minors in Greece”, see in a publication in Efimerida Ton Syntakton (EfSyn) newspaper, Special zones for unaccompanied refugee children http://www.efsyn. gr/arthro/eidikes-zones-gia-ta-asynodeyta-prosfygopoyla 79 See as above publication in EfSyn. 28 long and short stay),80 dispersed across the country, which in their majority are private and are operating under the responsibility of different agencies, such as legal entities of the broader public sector operating under Private Law (e.g. the Youth and Life-long Learning Foundation), but mainly under the responsibility of NGOs. Their operation is governed by the General Rules of Operation of the Accommodation Facilities for Third-country Nationals that are operating under the care of the First Reception Service (Government Gazette Β3295/2014) and by the Regulation for the quality and safety specifications of civil society organisations for processing individual reception procedures in Open Accommodation Facilities operating under the supervision of the First Reception Service (Government Gazette Β 1261/2016). However, there are no particular specifications for facilities that accommodate unaccompanied minors. The deficiencies of the Greek system for the protection of unaccompanied minors are apparent also in the matter of guardianship. Up to now, the duties of temporary guardian are undertaken mainly by the Public Prosecutor of the area where the minor was found, as well as persons from the accommodation facilities, after appointment either by a prosecutor’s order or a court decision. Today, there is a relevant provision in Article 19(1) of PD 220/2007, stating that the competent authorities shall promptly take the suitable measures in order to ensure the necessary representation of the unaccompanied minors, and to this end, the competent authorities inform the Juvenile Prosecutor, and where there is none such, the competent local Prosecutor of the First Instance Court, who acts as a temporary guardian and takes the necessary steps in order to appoint a guardian to the minor. It should be noted however that the provision is interpreted quite strictly by certain prosecution authorities, whereas the practical inability of the prosecutors to exercise the duties of a guardian is also recorded.81 In practice, the large number of the unaccompanied minors renders impossible the exercise of the duties of the temporary guardian by the local Public Prosecutor of the First Instance, whereas the assignment of guardianship to members of the accommodation centers where the minors are living, poses the risk of a conflict of Guardianship of unaccompanied minors 80 UNHCR updated status of unaccompanied minors (https://data2.unhcr.org/ en/documents/download/54239) 81 I. Papageorgiou, Unaccompanied minors seeking asylum in Greece, Elliniki Epitheorisi Evropaikou Dikaiou 2:2009 pg. 164.