of the General Secretariat for Reception of the Ministry of Migration Policy, respectively. There are however facilities still operating based on the General Rules of Operation143 established pursuant to Article 8A of Law 3907/2011, which was repealed with Law 4375/2016, whereas in most cases there are no Internal Rules. tion Policy, the Ministry of Defence, the local Municipality and humanitarian organisations (e.g. Chios (VIAL), Ritsona and Oinofyta in Viotia, Polykastro in Kilkis). This fact creates an overlap of competences and removes the possibility of comprehensive supervision and effective coordination by the main agency that has been appointed for this purpose. General Secretariat for Reception According to the above, the Ministry of Migration Policy is responsible for the overall supervision and operation of the facilities. The structures operate at sector level, the management of which is assigned to a head of sector. The appointment of the head follows specific procedures (article 11(5) of Law 4375/2016). Each sector is structured into distinctive operating levels, as follows: a) logistics level, which is competent for the administrative support, housing and nourishment of the residents and cleaning of the spaces; b) medical care and psychosocial support level; c) information provision level which is responsible for the provision of information to the residents regarding their rights and obligations and d) level of external guarding and security (Article 13(4)). According to Law 4375/2016, competent for the establishment, operation and supervision of open Temporary Reception and Temporary Accommodation Facilities are the Reception and Identification Service (Article 8(2)(b) and (d)) and the Accommodation Department of the Reception Directorate (Article 27(2)) that are under the General Secretariat for Reception of the Ministry of Migration Policy (Article 26). The Reception Directorate is also responsible, inter alia, for: a) the coordination of the Reception actions across the country; b) the study, drafting and monitoring of the implementation of the policy for meeting the accommodation needs of international protection applicants and unaccompanied minors; c) the cooperation with co-competent ministries, the Directorate General of Home Affairs of the European Commission, the UNHCR, civil society organisations and other competent agencies in each case, for the planning and implementation of the above policy; d) the study, development and processing of the institution framework of specifications related to the establishment and operation of the reception centres and accommodation facilities for applications for international protection and unaccompanied minors, and e) the care for the communication and cooperation with the involved public agencies and services of the State, with Independent Authorities, International Organisations, NGOs, other organisations of the civil society and legal entities, with the purpose of managing the humanitarian aid (Article 27(2)). In practice, the management and coordination of the actions for the transport, accommodation, food and health care of the refugees and migrants is carried out by the Central Coordinating Body for the Management of the Refugee Crisis that reports directly to the Chief of the Hellenic National Defence General Staff, in cooperation with the Asylum Service and the Reception and Identification Service.144 At the same time there are facilities, where responsible for the management of specific issues are simultaneously the Ministry of Migra143 MD 11.1/6343/2014. The management of the facilities The management of a large number of structures has been assigned to IOM, the UNHCR or to NGOs and they operate without any substantial supervision by the ministry and without the required structure. As a result, in many cases we witness a lack of a direct view of the situation and the needs of these facilities by the competent General Secretariat. Difficulties arise therefore in addressing these issues as well as a vagueness regarding the responsibilities that correspond to each agency (e.g. settlement at the former airport of Elliniko, Ritsona in Viotia, camps of the Ministry of Rural Development in Lavrio). A special case is the camp in Moria, Lesvos, since its operating framework is particularly unclear. The camp is laid out surrounding the fenced area of the RIC and is guarded by the Police. However, formally, the director of the RIC is not responsible for the operation of the other facilities, which operate informally. Finally, we must mention that there are sites the responsibility of which is assumed by no state or other agency. A typical example was up to May 2016, the camp in Eidomeni, and to a much smaller scale, the site in Neraki, Lavrio, with approximately 100 people. 144 Law 4368/2016, Article 96(1) and JMD Φ. 000/8/245258/Σ. 37/2016 (Government Gazette Β 630/9-3-2016). 45

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