Zero waste coalition

The Sunce Association, together with 53 NGOs included in the coalition of the informal name ‘Zero Waste Croatia‘, made by 44 environmental NGOs gathered at the Green Forum and 10 local citizens’ initiatives, today sent joint comments on the proposal for a Waste Management Plan 2015-2021. We request from the Ministry of Environment to amend the proposal of the Plan and to abandon the concept of mixing and incinerating waste and proposing to incorporate quality prevention, reuse and recycling measures. These measures are based on the “Zero waste” concept, respecting the waste management hierarchy, protecting the environment, and not endangering the health of citizens.

On this occasion, the activists of the Green Action organized a demonstration in front of the building in which the Ministry of Environmental Protection during which the mascot as the character of Minister Zmajlovic dumped items such as clothing, paper, bio-waste, plastic bottles and money bags in the barrel while the thick smoke was coming out of the barrel as the product of the incineration. This has stated that Minister Zmajlovic was responsible for the negative financial and environmental consequences that such a Plan would bring and a transparent “NO waste incineration” was highlighted, sending a clear message to the Ministry.

The waste management plan is an implementing document that will determine the method of collecting, processing and disposing of waste in the Republic of Croatia for the period up to 2021. The Croatian waste management system is one of the worst in the EU for years, only 15% of the total waste is separated and by 2020 we have to separate and recycle 50%. Notwithstanding these facts, neither the Ministry nor the new Plan endeavors to provide citizens with high-quality infrastructure for separation and recycling. It is planned to continue the residual system in which large quantities of mixed waste should be produced, which would be transmitted to the huge regional centers throughout Croatia, where they would be smashed and then further incinerated in cement and waste incinerators. By such a system, we will not meet the mandatory obligations, which makes the Ministry clear that it does not take care of the public interest and environmental protection while citizens will be brought to the situation of EU’s high criminal penalties and to live beside the environment that harms the environment and endangers their health.

The Ministry’s proposal of the Plan is based on incomplete data on the quantities of certain types of waste and numerous analyzes that justify the selection of a specific waste management system are missing. Thus, without previous cost-effectiveness analysis and environmental and health impacts, regional centers and incineration have been selected, which has been proven to be the most expensive and harmful waste treatment system in existing practice. Citizens will have to pay for and invest in such a system because, according to the proposed Plan, there is missing over HRK 10bn for its implementation and the EU is in the process of adopting provisions that stop funding incineration. In addition, citizens will also have to pay all unforeseen costs, such as the cost of waste transportation (to other countries)meant for incineration in case of inability to care of it in the Republic of Croatia. Such a scenario is very likely because cement plants often  give up of waste incineration because of the high costs and it is often forbidden. The best example is the verdict of the Administrative Court in Split, which prohibited waste incineration in CEMEX cement plants, one of the three cement plants planned for incineration in Croatia.

In addition to direct financial damage, it should be taken into account that by burning they destroy valuable raw materials, which can generate additional income and open new jobs, which is completely neglected in the proposal of this Plan. It is also emphasized that by burning it gets energy, yet there are no analyzes that would actually show that by burning it gets a much smaller share of energy than the energy saved by recycling resources that are planned to burn the energy that can be obtained from biogas after bio-processing. It is incorrect to emphasize that by burning waste, it solves its problem since burning generates enormous amounts of disposal slag and toxic waste for a set of exports.

Priority steps in waste management are not mixing and burning waste, but a quality system of measures that we suggest in the comments. For example, opening reuse centers, supplying citizens with chip bags and waste separation canals at home and building a sorting, recycling and composting infrastructure at the local level. These steps are considerably cheaper, environmentally acceptable, proven in world practice, delivering results very quickly and opening up a lot more jobs. These measures are mentioned in the proposal of the Plan sporadically, without qualitative elaboration and with minimal investment. This is trying to create an illusion that something will be improved in this matter, as was the case in the previous Plan, and everything else is just a dead letter on paper.

We call on the Ministry to comment on citizens and to amend the proposal. Additionally, to create a new Strategic Study to influence the Environmental Impact of the Plan, as existing non-motivated rejects potential environmental impacts, making it clear that it only serves to justify the adverse steps proposed in the Plan. The aforementioned documents must then be subjected to a new public consultation which should be transparent, not such as hiding and unavailing the documents from the general public, as well as unpublished online counseling which is contrary to legal and bylaw regulations. We require the implementation of internet consultations and the maintenance of public exhibitions in the larger Croatian cities, in order to present the proposal of the Plan and Strategic Environmental Impact Assessment to the interested public as much as possible.

Detailed comments:
Comment on the Draft Waste Management Plan of the Republic of Croatia 2015-2021
Comments on the Strategic Study on Impact of Proposals for the Waste Management Plan of the Republic of Croatia 2015-2021 on the environment
Comments of the Sunce Association on the Draft Waste Management Plan of the Republic of Croatia 2015-2021 and the Strategic Environmental Impact Assessment of the same Plan

Attached comments are signed by:
1. Association for Nature, Environment and Sustainable Development Sunce.
2. Green Action
3. Green Istria
4. ZEO Nobilis
5. Franjo Koščec,
6. Eko Pan Karlovac
7. Association for Nature Protection and Environment GREEN OSIJEK
8. Brodsko ekološko društvo BED
9. BIOM Association
10. DOOR
11. Association “Eko-Zadar”
12. Green Action Mičevec
13. The GRIFFON Preventive Center for the Protection of Birds
14. Ecological Association EKO – EKO Komin
16. Ecological Society of Koprivnica
17. The Baobab Association,
18. Ecological Association Una
19. Association Žmergo
20. Ecological Association of Krka Knin
22. Ecological Society “Žumberak”
23. Mažuran
24. Ecological Association Pineta
25. Association for Ecology and Culture Eia
27. Eko Ombla
28. Eko Omblići
29. Green Action Stari Mikanovci
30. ED Our Beautiful-Zabok
32. Divina Natura
33. Ecological Tourism Association of Šolta
34. Pulentoda Association, Ecological Society for Youth Initiative
35. Association for Sustainable Development UZOR
36. Dalmatica Viva
37. Ecological Association IZVOR
38. Argonauta
40. IRRE Institute for Rural Development and Ecology
42. Ecological action from Lika LEA
43. Ecological Association Primošten
44. Sovinjak
45. Marjan Society
46. Eko breza – Eco birch
47. EKO-Association”Ravni kotari”
48. Crisis Eco Center Kaštela
49. Crisis Eco Center Marišćina
50. Crisis Eco Park Varaždin
51. Crisis Eco Station Zagreb
52. Nature and Society
53. Association Environment
54. Environmental Protection Association Resnik