Ε. Conclusions Findings Recommendations in the legislation with fast-track reception procedures248 and specific deadlines for deportation decisions based on readmission, appeal against those decisions, etc. There was provision only for the asylum process at the first and second instance, especially for the hotspots (Article 60 of Law 4375/2016). The deportation decisions based on readmission were finalised with a circular of the Hellenic Police in July 2016.249 However, even where there were special legislative provisions, as for example in the review of asylum applications, it should be noted that they did not remain constant: the provisions for the Appeals Authority were amended already twice in 2016, in April and June, and a new amendment is expected.250 Even more problematic for legal certainty is the fact that the competence for deciding an appeal against an asylum decision at the 1st instance is distinguished into 4 different categories provided for by usually transitional provisions.251 The constant legislation of extraordinary procedures for direct award due to emergency, as well as the special spatial planning and property designation procedures, with more recent example the amendment on 9.3.2017 on the facilities for minors by the Ministry of National Defence, are a regression from issues of transparency of public tenders and procurements.252 The lack of clear rules is identified mainly in areas where these rules are needed the most: in the provisions for guardianship of unaccompanied minors, the specifications for the various welfare structures and the clear rules of 248 See Article 14(2) of Law 4375/2016 that provides for the completion within 25 days of the first reception procedures at the hotspots, in comparison to the overall time of also 25 days (initially 15 and extension of another 10) of Article 11(5) of Law 3907/2011. 249 https://www.synigoros.gr/?i=foreigner.el.metanastis-egkyklioi.379856 250 According to Article 4 of Law 4375/2016, which replaces the repealed Article 3 of law 3907/2011 (repeal of the entire chapter A of Law 3907/2011 with Article 81 of Law 4375/2016). Subsequently, with Article 86 of Law 4399/2016, that was introduced with an amendment (Art. 496/25) and brought about, inter alia, a change in the composition of the Appeals Committees (see Chapter D.2 above). With Article 86(3) of Law 4399/2016 the submission of reports by the Appeals Authority to the Greek Ombudsman was also repealed (Article 4(3) of Law 4375/2016) for the monitoring of the procedures followed. A late amendment again for the Appeals Authority was submitted to the Parliament on 13.3.2017 http://www.hellenicparliament.gr/UserFiles/bbb19498-1ec8431f-82e6-023bb91713a9/9969803.pdf 251 See Article 81(27) of Law 4375/2016, Article 86(27) of Law 4332/2016. 252 http://www.hellenicparliament.gr/UserFiles/bbb19498-1ec8-431f-82e6023bb91713a9/9966464.pdf 86 operation of the open or closed facilities. The halting throughout 2016 and up to this day of the draft law for the guardianship of unaccompanied minors deprives them of a basic institutional guarantee for the protection of their rights. The minors’ representation, as well as the management of their daily problems, are impossible without such as person, who, considering the particular circumstances, is essentially exercising their guardianship. Significant rights in the minors’ lives, such as access to education and health, as well as general issues of their social inclusion, become a dead letter without substantial guardianship. As regards the lack of rules for closed or open facilities: • T he Detention Centers were operating in 2014 as Identification Centers, a category outside the legislative authorisation (Law 3907/2011), before the establishment, as provided for by law, of Pre-removal Centers with JMD of 21-1-2015 (B 118), which also includes the Rules of their Operation. At the hotspots (Reception and Identification Centers of the islands), which have crucial importance both for the endeavour of the EU-Turkey Statement, and for the rights of the involved parties, the clear determination of the standard operating procedures is still a basic shortcoming. The Ombudsman recommends253 the immediate issue of internal rules for the operation of the hotspots. • T he temporary accommodation sites for refugeesmigrants are operating in practice without implementation of the framework of Law 4375/2016. Nearly a year after the provision for Facilities of a) Temporary accommodation and b) Temporary Reception with Law 4375/2016 (Article 10), we see a piecemeal approach to the implementation of the provisions pertaining to the facilities, the majority of which were still operating unofficially until the beginning of 2017, and without meeting the formal and essential requirements of the applicable laws. Indicatively, the issue of a JMD is pending for the establishment of the open Temporary Reception and Temporary Accommodation Facilities, the establishment of General Rules for the Operation of the Facilities, the issue of Internal Rules of Operation for each one of them, as well as the specialisation of the terms 253 And so does the European Commission.