On March 18, Sunce submitted its opinion on the Environmental Impact Assessment (EIA) Study for the Waste management center (WMC) Lećevica in Split-Dalmatia County. For years, Sunce has been warning about the shortcomings in the planning of WMC Lećevica. Unfortunately, this Study also fails to provide long-term and sustainable solutions for waste management in the county. Moreover, the public consultation process was conducted with numerous deficiencies, further hindering transparency and citizen
involvement in decision-making. Below, we highlight the key shortcomings of the Study.
Public participation merely for show
Although the public participation process was formally carried out over 30 days, as required by law, the behavior of the Study’s authors during the public hearing suggested a lack of genuine interest in engaging the public, pointing instead to a mere procedural formality. This formalism is evident in the failure to ensure easy and accessible availability of the full Environmental Impact Study for WMC Lećevica. Had there been genuine interest in public involvement, the public notice about the EIA would have clearly included a direct link to the full Study and its non-technical summary. As it stands, the procedure is listed under 2024 cases on the Ministry of Environmental Protection and Green Transition’s website (Republic of Croatia), making it even more difficult for citizens to locate the relevant documents.
The absurd practice of ex post procedures
The public consultation and environmental impact assessment for WMC Lećevica were conducted while construction works on the project were already underway. However, environmental impact assessments are meant to be conducted before any intervention takes place!
The core purpose of the EIA process is to prevent environmental damage by evaluating various options before making decisions. Since the location has already been chosen, this Study presents no alternative siting options—even though the Lećevica location poses a risk of water pollution, especially in the event of an earthquake. Furthermore, the Study fails to sufficiently assess the project’s impact on water bodies as required by the Water Framework Directive, relying instead on outdated research data.
After every EIA procedure, a decision must be made on whether the planned project is environmentally acceptable. This decision can be appealed before an administrative court. However, when EIA procedures begin after project implementation has started, it raises serious concerns about the effectiveness of judicial protection. If works have already begun, then critical decisions have already been made without proper public involvement or a completed environmental assessment. The EIA process should form the basis for decision-making, not a formality conducted after the fact.
This reversed and absurd practice is often observed in Croatia. Projects are retroactively “legalized” as environmentally acceptable even when they’ve already been carried out, without assessing baseline environmental conditions or potential impacts. Such practice violates fundamental principles of the Aarhus Convention, EU directives, and Croatia’s Environmental Protection Act, all of which aim to prevent damage through precaution. When assessments are made post-intervention, environmental harm has likely already occurred, rendering the precautionary principle meaningless.
How CGO Lećevica will increase costs for municipalities and towns
WMC Lećevica still does not provide a systematic or long-term solution for waste management in Split-Dalmatia County and will not be able to meet the waste management needs of the entire region. Effective waste management requires establishing sustainable systems at the level of local governments. Financial resources must be directed toward achieving self-sufficiency and greater independence for municipalities and towns in this process.
However, the County systematically neglects priorities in waste management—especially waste reduction, reuse, and the establishment of effective systems for separate collection, treatment, and recycling. Without this approach, the system will be neither sustainable nor environmentally sound.
Currently, waste treatment costs at WMC Lećevica are based on the amount of mixed municipal waste delivered. This treatment is significantly more expensive than the current practice in most municipalities, where waste is simply dumped at non-compliant landfills. As a result, citizens will face a substantial increa se in waste processing and disposal costs. Those who generate more mixed waste will pay more! Therefore, it is in every municipality’s interest to reduce the amount of waste processed at the Center by prioritizing waste prevention, separate collection, and recycling.
Croatia’s Waste Management Plan covers the period 2023–2028. The Waste Management Act requires regional authorities to propose and ensure the implementation of the national Plan. However, to date, Split-Dalmatia County has not developed a regional Waste Management Plan. Additionally, the new Waste Act (OG 84/21, 142/23) has eliminated the obligation for municipalities and cities to adopt their own waste management plans. As a result, there are currently no mechanisms to monitor adherence to the waste hierarchy (1. prevention, 2. reuse, 3. recycling, 4. other recovery methods like energy recovery, and 5. disposal), as defined in Article 6 of the Act.
Many municipalities and towns use WMC Lećevica as an excuse for not taking meaningful action in waste management, assuming that the Center will solve all their problems. This is a misguided belief that has led to a lack of real progress on the ground.
Composting facility capacity
The Study states: a facility for composting separately collected biowaste (kitchen and garden waste) with a capacity of 9,700 t/year. However, this is far from sufficient to handle all the biowaste generated in the County. Estimates suggest that the city of Split alone produces around 20,000 tonnes of biowaste annually.
A systematic and efficient biowaste treatment process must be established in accordance with circular economy goals to reduce the amount of organic waste sent to landfills. Despite plans for composting facilities dating back decades, access to EU funds, and the ecological importance of this method, not a single composting facility currently exists in the Split-Dalmatia County—not even on the islands.
SRF–RDF
The summary claims that the processes under Scenario 1 will result in rational and environmentally acceptable waste management and the production of high-quality outputs. However, it is unclear why RDF (Refuse-Derived Fuel) was chosen over first-class SRF (Solid Recovered Fuel), which has better environmental properties in terms of calorific value, chlorine, and mercury content.
Furthermore, the Study does not specify where the RDF will be used, meaning that the cost estimates for citizens—and the environmental impacts of burning RDF—are not clearly defined. Will citizens have to pay additional costs for RDF disposal? Added to this are the environmental and financial costs of transporting mixed municipal waste and RDF to incinerators or cement plants.
WMC Lećevica threatens to increase costs for citizens due to its expensive waste treatment methods, while offering no real solutions for reducing waste generation. Sunce emphasizes the need for a systematic approach and more effective local-level measures to avoid long-term environmental damage and ensure sustainable waste management at the municipal and city level.