Our official comments on the Draft for the Plan for Waste Management for the City of Split

In the last month, Sunce has been actively approaching the problem of adopting the new Waste Management Plan for the city of Split through FB and media campaign in which we wanted to share our knowledge, information and comments with the public, which is related to waste management issues and current topics. In addition, our team actively researched the proposed draft Plan and discussed all its elements. Apart from the wider media, we also formally participated in the public debate by sending our comments on the proposed draft Plan to the City of Split. You can download the submitted document with our comments here, and we have a few written down below.

Given that the implementation of the Plan depends on all actors in waste management, it should be in the interest of any serious developer to participate in its participation, which significantly increases the chances for its successful implementation. We expressed our interest before and during the public debate in 2016, and then with the new Split government, which was supposed to harmonize the WMP with the national Waste Management Plan of the Republic of Croatia for the period 2017-2022. However, even during the revision of the document prepared in 2016, the developer of the Plan and the client, the City of Split, did not consider it appropriate to include Sunce or other relevant stakeholders.

In the Republic of Croatia, a new national Waste Management Plan for the period from 2017 to 2022 has been prepared (OG 3/2017). According to the Act, every lower level plan – the plan of local self-government units must necessarily be harmonized with the Waste Management Plan of the Republic of Croatia. Any connection with the old documents and the goals contained in them, which is the case in this draft, we consider inexpedient and may lead to inconsistency of the Plan, and thus call into question its legality.

The proposed Waste Management Plan of the City of Split for the period from 2017 to 2022 does not bring the measures necessary to meet the legal provisions, specific steps, deadlines and responsible persons / institutions / organizations.

The plan envisages a door-to-door waste collection system as well as a three-container waste collection system, but when and how this system will work has not been addressed. The plan does not provide clear guidelines for those responsible for implementation to take further action in terms of defining where the vessels will be placed, the dynamics of their installation, the necessary financial resources, deadlines for implementation and performance indicators. The same applies to the construction of a composting plant.

The Plan does not define indicators of implementation of success, which will enable responsible persons to monitor the implementation of the Plan, therefore we demand their introduction and propose the following: quantities of separately collected waste from households, quantities of separately collected biowaste, quantities of composted waste and compost, population covered by separate waste collection through the door-to-door system, population covered by separate waste collection through green islands and recycling yards, number of green islands and results of the collection of waste on green islands, number of established recycling yards and mobile recycling yards, number of projects related to waste prevention, quantities of waste disposed of in landfills as a result of the implementation of measures…

It is also desirable to point out that the County Center cannot be an excuse to the City for not taking all previous steps in waste management, and this view is shared by the Ministry of Environmental and Nature Protection and the Parliamentary Committee for Environmental Protection. The current concept of the County Center is based on the treatment of mixed municipal waste, which is not in accordance with the Law and the principles of circular economy.

We demand the adoption of a Plan in which separate collection will be based on a “door to door” system, which proved to be the most successful in achieving the goals related to the quantities of separately collected different types of waste and their quality, which is a prerequisite for their further marketing.