Based on the article published on the Dalmatinski portal, which conveys various insinuations about Sunce, we felt it necessary to present our key positions regarding the protection and management of Marjan to clarify any misunderstandings or misinterpretations.
For many years, Sunce has been actively involved in nature conservation, and in this context, we are also committed to preserving Marjan. We believe that constructive dialogue is the only way to protect Marjan, one of the most valuable natural resources of our city.
Besides it was published on the Dalmatinski portal, we are sharing these views below.
What needs to change for more effective nature protection? The Marjan management plan needs improvement
For over 25 years, Sunce has been tirelessly working on the preservation of nature and the environment. Our commitment and positions are clear and consistent, and collaboration is the foundation of our approach. This is evidenced by numerous projects aimed at the preservation of protected areas (including Marjan) which have been successfully implemented in collaboration with various associations, experts, public institutions, and ministries from Croatia and abroad.
Although we work throughout Croatia, as an association based in Split, Marjan has been important to us since our inception. We have always openly and cooperatively pointed out ways to improve the management of this area, and through our activities, we have contributed to it. Despite the ongoing political upheavals over the years related to the management of the Marjan Forest Park, we have remained consistent in our stance on the need to protect Marjan and its importance and value to the citizens of Split, as well as the principles of cooperation, support, transparency, and the rule of law.
Sunce’s key positions on the protection and management of Marjan
We firmly believe that the scope and boundaries of the protected area must not be changed. The Marjan Forest Park is protected due to the forest ecosystem, but other important habitats, such as grasslands, are also present on Marjan. This diversity is the foundation for ecosystem resilience and the preservation of Marjan’s overall biodiversity. Therefore, it is necessary to consider other ecosystems and habitats within the Marjan Forest Park and ensure measures for their conservation.
All the comments we submitted in writing to the Public Institution during public discussions are based on our expertise, knowledge of Marjan, and experience in creating management plans for 27 protected areas and 70 ecological network sites, which have been officially adopted by the relevant public institutions and ministries. It is up to the Public Institution to professionally process, accept, or reject them and adopt the Management Plan.
We find the spread of malicious insinuations about Sunce, systematic ignoring, and rejection of constructive dialogue unacceptable for an institution that should serve the public interest. Such behavior not only undermines the institution’s credibility and hinders the establishment of transparent and effective management, but also actively contributes to the spread of misinformation and the encouragement of further conflicts, jeopardizing the preservation of the Marjan Forest Park.
Sunce strongly opposes illegal construction, especially in protected areas like the Marjan Forest Park. If you review our positions, campaigns, and statements in the media over the years, it will be clear that our principles are consistent and firm when it comes to the preservation of natural resources and adherence to legal frameworks.
We actively support legal processes that ensure the preservation of natural values, including the removal of illegally constructed objects. The legality or illegality of a structure is determined by existing legal acts in the Republic of Croatia, regardless of the (non)existence of a management plan for the protected area. Action does not require a Management Plan, nor does it justify delaying its adoption. It is the responsibility of state institutions, such as ministries, the police, inspections, the state prosecutor’s office, and courts, to take concrete action against illegal construction, and for public institutions and other interested parties to encourage more effective action.
We are particularly saddened by the recent public statement from the Public Institution for the management of the Marjan Forest Park, in which Sunce is accused of supporting illegal activities on Marjan, as well as the way the expertise and motives of Sunce’s representatives in the management plan development process are being questioned.
A call for open and constructive dialogue with the Public Institution for the Marjan Forest Park
We call on the Public Institution for open, civil, and constructive dialogue with all relevant stakeholders and the use of professional assistance in stakeholder consultation processes. Transparency in decision-making processes, especially those related to managing protected areas like the Marjan Forest Park, is of great importance for the long-term preservation of natural values. Sunce firmly believes that stakeholders should not be excluded from these processes and must be actively involved – exclusion is not an option. The effectiveness of managing the Marjan Forest Park is closely tied to the level of understanding, support, and involvement of stakeholders in the planning and management process.
Stakeholders are clearly defined: they are all individuals, groups, or organizations that can have an impact on the management plan or be affected by it (whether positively or negatively). Sunce believes that stakeholders were not adequately involved in the process of drafting the Marjan Forest Park Management Plan, and their positions were not clearly expressed in any of the plan versions. Holding just one workshop for stakeholders cannot be considered sufficient for a quality consultation process, especially given the complexity and importance of this area for the citizens of Croatia’s second-largest city.
Sunce has emphasized the lack of transparency since 2022
In 2022, Sunce expressed concerns regarding the proposed plan due to insufficiently detailed activities, which made it difficult to understand the proposed goals and measures. We also raised concerns about the lack of transparency in presenting the Public Institution’s annual revenues and expenditures, as well as insight into personnel, real estate, and assets, which hindered a realistic assessment of the capacity to implement the Management Plan. The Management Plan should increase the transparency of the Public Institution’s work, and the public must have access to all relevant information. Additionally, the 2022 version was not aligned with the Management Planning Guidelines, and although certain revisions were made in the 2024 version, we continue to express concerns about visible shortcomings in the proposed Plan.
In our comments on the 2024 version, we pointed out the need for further refinement of the area description, as topics like light pollution and noise, particularly concerning events planned within the park where strictly protected species are present, were not addressed. Furthermore, the new proposal again lacks a comprehensive review of the Public Institution’s real estate and assets, as well as a review of income and expenses over the past three to five years, which adds to the Plan’s lack of transparency.
Moreover, Sunce calls for additional consideration of the zoning and zone descriptions in the 2024 plan, particularly regarding areas that are long under public scrutiny and inspection. The terms like “parking areas”, “gravel beaches”, and “hospitality facilities” used in the zone description are not clear enough. The last proposed version also insufficiently addresses the protection of grasslands and other habitats in the Marjan Forest Park, and that could negatively impact Marjan’s biodiversity. Additionally, the Sturine garden is not mentioned in any of the protected area zones, nor is there an indication of how it will be managed, so we believe it should be included in the zoning.
We believe that the total cost of each activity in the Management Plan should be broken down by the costs for each year of implementation. This would make the planned investments significantly clearer and more transparent, and the implementation of the Management Plan easier to track through annual programs and reports from the Public Institution, both by the Institution itself and by the wider public, which is the fundamental purpose of the Management Plan.
The proposed Management Plan was ultimately rejected again by the competent Ministry, with an explanation stating that the plan generally follows the Management Planning Guidelines and that the activities generally align with the needs for preserving the area’s values and management objectives. However, it was also noted that the management zoning in several areas does not match the established state, digital orthophoto maps, maps of non-forest habitats of the Republic of Croatia, and other sources. Sunce agrees with the Ministry’s position, which is evident from all our publicly available comments.
In conclusion, we believe that greater stakeholder involvement and increased transparency in decision-making processes regarding the Marjan Forest Park are necessary. This Management Plan must focus on the actual preservation of the values of this protected area. We again emphasize the shortcomings of the revised Management Plan and the need for its further refinement and alignment with the actual situation on the ground.
Despite our disappointment with the entire process and the current outcome, we remain motivated and committed to our goals. We will continue advocating for the long-term preservation of nature and the environment, including Marjan, regardless of the current or future political structures on or around Marjan. We invite citizens to join our efforts and actively participate in protecting nature so that together we can ensure that natural values like Marjan are preserved for future generations.