For those less knowledgeable, the plan that is required to be adopted by all local self-government units defines all issues related to waste management in the area of that unit. It must contain an analysis of the current situation and needs in waste management and the goals to be achieved, data on the type and amount of waste produced, separately collected waste and measures for its collection, data on locations of discarded waste and its disposal, status of non-compliant landfills and measures necessary to achieve the objectives of reducing or preventing the waste generation. Also, the plan should be harmonized with higher order plans, ie the national waste management plan and laws and bylaws.
Aware of the obligations and knowing the previous approach of the City of Split to the development of this Plan, back in 2015 on behalf of the Environmental Advisory Council of the City of Split, we send a request to the City to include us in the development process in order to contribute their knowledge and experience to the development of a quality plan, but we find only silence from the authorities.
In February 2016 the draft of the new Plan of Split was published and the public was given a legal deadline of 30 days to present comments, proposals and opinions. In the meantime, a new national plan is being adopted in parallel. Sunce participates in the public debate and makes numbers of remarks regarding the shortcomings of the plan, one of the very important shortcomings being the fact that the plan is not in line with the national plan, which was adopted after a public hearing for Plan in Split in early January 2017. To date, the plan of the city of Split is in the drawer, it has not been adopted and despite numerous inquiries, we do not know what the situation is on this issue.
However, it should be emphasized that the adoption of a good plan, without a strong and determined will to ensure the implementation of priorities in waste management, does not guarantee its quality implementation and efficiency. Furthermore, the annual obligation of local self-government units for reports on the implementation of the Plan, which due to the non-specified methodology for monitoring the implementation, do not show the real state of affairs and how successful the implementation of the plan is. Also, there are no sanctions in Croatian legislation for not implementing the plan.
However, the Law on Sustainable Waste Management provides for EU sanctions for failure to achieve certain shares of separately collected waste in the total waste generated, with the EU setting that share at least 50% with a legal deadline of 1 January 2020. Ultimately these sanctions will be paid by municipalities and cities, ie citizens.
We note that although it does not guarantee successful implementation, we urgently need a quality waste management plan as a basic document that would define all important issues related to waste management. The City of Split is facing the procedure of its urgent adoption, which does not exclude a new public debate, since the plan has been substantially changed. Therefore, follow the public debate, get involved and do not allow further non-implementation of priorities in waste management: reduce waste generation, reuse and recycle !!