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Destruction of Croatia’s Coastal Biodiversity Intensifies – With the State’s Blessing
Waved through
The project to build a marina on the Cetina estuary is a typical example of how projects that are potentially harmful to the natural environment are given the green light in Croatia.
The possibility of building a marina on the estuary was included in the Omis town spatial plan as far back as the 1990s. The EU’s Natura 2000 network of protected natural sites was subsequently established in 2013. This could have played a role in a revised urban development strategy for the town, yet despite some changes made to the spatial plan, the marina project remained.
Five years ago, the Dubrovnik-based company Dubrovnik Nekretnine submitted a request to Croatia’s Environment Ministry to evaluate the possible environmental impact of its project called “Marina Omis-Ribnjak” as a first step toward gaining a location permit (lokacijska dozvola) – the first phase of a construction project which precedes the obtaining of a building permit.
Under Croatia’s current regulation governing environmental impact assessments (EIA), only larger harbours open to the public transportation of national and international economic interest as well as those of special national interest have to go through a full EIA procedure. This needs to estimate the reach, intensity and duration of the impacts on the environment, and suggest measures towards protection and monitoring.
Smaller marinas that are designed to accommodate 100-200 berths, and include the filling, deepening or drying of the seabed or construction of objects longer than 50 metres into the sea, are not automatically obliged to go through a full EIA procedure. Instead, investors can request the Environment Ministry carry out an evaluation about whether such a procedure is required.
For this basic evaluation (OPUO, in the Croatian acronym), investors need to submit only a less-detailed impact assessment report, which they usually contract one of a number of private companies authorised by the Environment Ministry to carry out.
If the commission appointed by the Environment Ministry decides that the project has to go through a full EIA procedure, the investor would then need to order and pay for a more detailed environmental impact study. This is more costly, prolongs the time until the location permit can be issued and, in theory, could jeopardise the whole project. However, BIRN investigated last year how this whole process is flawed and designed to favour investors over the environment, with the OPUO procedure being the most problematic part.
According to the request submitted by Dubrovnik Nekretnine to the Environment Ministry, the marina project in the Cetina estuary would include two breakwaters of up to 190 metres in length and two floating docks with a planned capacity for 162 berths. The marina would cover a sea area of 29,663 square metres. Among other interventions, this part of the estuary would need to be deepened to accommodate yachts.
In 2021, the Environment Ministry decided that a full EIA procedure would not be needed, but an appropriate assessment of whether the project is harmful to the Natura 2000 network was still required. A year later, the ministry decided the project would be “acceptable” to the ecology of the area, although the study upon which the decision was based conceded it would affect the estuary and the sandy seabed, both important habitats for the area’s many marine species.
In 2023, another investor, the Dugopolje-based Orvas, requested an evaluation from the Environment Ministry for its marina project under the same name of “Marina Omis-Ribnjak”. This project too was released from the obligation of going through a full EIA procedure in 2024, but likewise required the mandatory Natura 2000 assessment.
This time, though, the plan to build the marina triggered a larger public outcry and prompted protests by the local community and ecological activists.
“As the most important impact, the construction of the marina in the Cetina estuary would wipe out from this location the strictly protected seagrass Zostera noltii, which locally has become critically endangered due to previous human influence in the estuary,” Jelena Kurtovic Mrcelic, a biologist with the More i krš (“Sea and karst”) nature protection institution, explains.
Seagrasses like Zostera noltii play a key role in the feeding, reproduction and growth of fish species and numerous small organisms that the fish feed on.
The estuary itself, where freshwater and saltwater mix, Kurtovic Mrcelic explains, is a unique ecosystem with several important functions. The juvenile specimens of different fish species use it as a shelter from predators. This habitat serves as home to a variety of crab and clam species that thrive in the muddy seabed. At certain times of year, the estuaries are important for the upstream or downstream migration of species, which is why the EU wants the revitalisation of these biodiversity hubs. This kind of project would, on the contrary, narrow the passage for migration and endanger the wildlife, says Kurtovic Mrcelic.
In February of this year, despite the protests, the Split-Dalmatia County gave permission to the company Nekretnine Dubrovnik to submit a request for a location permit after, apparently, the company Orvas chose not take part in this particular public tender.
BIRN asked the county and the Environment Ministry whether a location permit has already been issued, but our enquiry went unanswered.
Life’s a beach
Examples of permitted construction along the Croatian part of the Adriatic coast, even in some of the most extraordinary natural sites, are legion.
Four years ago, the citizens of the village of Bol on the Island of Brac were astounded to learn that the municipality wanted to deposit a large amount of gravel and similar material and build concrete structures to expand the shore in the vicinity of one of the most beautiful beaches in the world, Zlatni rat.
Shaped as a horn that cuts into the clear blue sea and moves with the currents, tides and winds, this pebble beach is a unique geomorphological phenomenon that came into existence due to erosion of the nearby Vidova gora (Mount St. Vitus).
The surrounding sea is also home to Posidonia oceanica, a highly protected seagrass indigenous to the Mediterranean Sea. Its large underwater meadows, known as “the lungs of the Mediterranean”, are immensely important for the ecosystem. Posidonia produces 14 to 20 litres of oxygen per square metre every day in the Mediterranean; serves as a food, shelter and breeding area for different sea species; and, like other seagrasses, captures a large amount of carbon more efficiently than tropical rainforests.
The Environment Ministry decided in 2019 that there was no need for an EIA procedure nor even an assessment of the impact on the area’s ecology. But Alen Soldo, a biologist and professor at the Department of Marine Studies at the University of Split, argued the report on which the ministry based its decision did not adequately estimate the level of impact and is littered with errors.
In his analysis which he shared with BIRN, Soldo pointed out that contrary to what the report stated, the Posidonia meadows are sited inside the borders of the construction work, which can be proved with the maps of habitats from the Natura 2000 network.
Soldo also stated the data used for the climate and wind conditions are irrelevant for that particular area and not one of the experts involved in the report specialiseds in marine environments. He concluded that the impact on the ecosystem and protected species would be larger than estimated, while warning that the destruction of protected species is against the law in Croatia.
After complaints from local citizens who said they were not even aware of the short public consultation period during the OPUO assessment, the Croatian civil society organisation Sunce, based in Split, requested the Environment Ministry conduct a new assessment. When it rejected this, the group filed a lawsuit in an attempt to annul the EIA decision in court.
The case is still pending at the Administrative Court in Split (Upravni sud u Splitu), according to a spokesperson for Sunce.
The Posidonia meadows are also one of the habitats for Pinna Nobilis, better known as the Noble Pen Shell – a large clam species indigenous to the Mediterranean, which has been almost entirely wiped out in recent years due to a parasite that thrives in warming seas. Scientists estimated last year that only around 30 specimens are left in the Croatian part of the Adriatic, and preserving the juvenile clams is proving to be extremely difficult. Every new finding of juvenile or adult specimens is important enough to warrant mention in the news.
However, some of the recent Environment Ministry decisions show how little consideration is given by investors and the ministry itself to these important or endangered species.
In September 2023, the Environment Ministry decided that the marina project Racice near Stari grad on the Island of Hvar did not need to go through an EIA procedure, despite the initial assessment concluding that construction would “take over” part of the existing Posidonia meadow. The ministry decided that mere observation of the seabed to determine whether any Noble Pen Shell specimens were present would be enough to mitigate the problem.
This particular solution has been offered in more than one case in recent years. In the decision from 2024 that released the future small harbour of public significance Sveta Marina in Rasa county from the EIA procedure, one of the prescribed measures for the protection of this area that was actually known to be a habitat for Noble Pen Shells was the relocation of specimens.
However, experts note that the juvenile specimens of Pinna Nobilis are notoriously difficult to spot in the sea and there is only a handful of experts in Croatia who are specialised in this task. Silvija Kipson, one of the top Croatian biologists experienced in this, told BIRN that only once did an investor contact her requesting this service. And even then, there was no follow-up to the initial enquiry.
In another example, the Environment Ministry in 2024 decided that a planned marina in the small bay of Smrka on the Island of Hvar would not need a full EIA assessment, or even an assessment of the Natura 2000 network, even though the location is listed inside the zone.
In the ministry’s document explaining its decision, it stated that this would be the third marina along the 25-kilometre-long stretch of coastal area, bringing the cumulative number of berths to 419. The marina on Smrka would cause some degradation of the Posidonia meadow, but this was declared unimportant. “Since this habitat type on this location is already damaged, the project will not have a significant negative impact on the Posidonija meadows,” it argued.
A problem of data and systems
Soldo of the University of Split points out the main problem with the initial assessment reports and studies is that they are paid for by investors and the conclusions are always there will be no big impact on the environment”. However, if you throw a large quantity of material into the sea, he explains, it’s practically impossible it won’t have a significant impact. “The whole EIA system is pointless if it’s arranged like this,” he adds.
Milvana Arko-Pijevac, a biologist, retired professor and former head of the Natural History Museum in Rijeka, researched the effectiveness of the regulations governing the protection of the Adriatic. In an analysis of 645 reports on construction projects from 2016 to 2024, she concluded that for 96 per cent of the ones planned on the coast, an expert field survey of habitats and species was not conducted. Rather, the main source was always Bioportal.hr, the web portal of the Nature Protection Information System, which lacks data about the distribution and structure of seabed communities and the potential presence of protected species.
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