The Association of Owners of Community and Private Forests of the Banská Bystrica

The Association of Owners of Community and Private Forests of the Banská Bystrica Self-Governing Region and the Land Association of the Compossessorate and Urbariat Šalková. Comments on the creation of the Low Tatras National Park (NAPANT) are prepared in accordance with the basic principles and values of the European SMURF project.

I. Fundamental objection to the Low Tatras National Park Protection Project (NAPANT)

1 Eco-functional spaces (EFPs) and property rights

EFPs are identified only at the level of „zone and subzone“, which has no legal basis in Act No. 543/2002 Coll.
For each EFP, the area, code, name, method of management, prohibitions and restrictions, principles, regulations and recreational use are indicated, without identifying specific cadastral areas, parcels, owners or users.
It is not clear whether the affected parties were aware of the regulations, whether they consented, or how they will be compensated for the loss.
This procedure poses a procedural risk that may lead to the illegality of the measures imposed.

2 Professional background and research methodology

The project lists the listed species of protected plants and animals, without the date of research and expert opinions that were the basis for their inclusion.
A note to the text points out that other species of European and national importance, including birds and species from red lists, may also be subject to protection.
For many species, there is a lack of systematic information on the occurrence, distribution and status of populations, which calls into question the complexity of the classification of species.
Targeted research carried out by experts and specialists is needed, including monitoring of new species related to climate change or environmental factors.

3 Use of historical data and legal certainty

The project uses data older than the effectiveness of Act No. 543/2002 Coll. (e.g. 1931, 1937, 1980, 1981, 1993, 1997).
It is not clear which data has been updated and verified so that it can be reliably used in species and habitat conservation.
This fact may call into question the professional and legal validity of the measures, as the old data may not correspond to the current state of the territory.

4 Quiet zones and legal compliance

The project sets aside quiet zones without specifying with whom this step was discussed (owner, affected municipality).
There is no demonstration of compliance with other legal regulations, such as the Forest Act, the Act on the Protection of Agricultural Land, the Spatial Planning Act.
This shortcoming creates legal uncertainty for owners and municipalities and calls into question the binding nature of the designated zones.

5 Funding and compensation for restrictions

When calculating compensation, it is not stated who prepared the expert opinion and from what documents.
It is not clear how economic factors were taken into account: VAT, transaction tax, inflation, fuel price increases, lost profits.
Government Regulation No. 7/2014 itself does not take into account the increased costs that arise from restrictions according to the levels of protection.
There is a lack of a separate budget chapter with a clear update of financial indicators, which reduces the reliability and accuracy of cost estimates.

6 Implementation and participation of professional bodies

The implementation of environmental education, marketing and monitoring is tied exclusively to the NAPANT Administration.
The involvement of professional research institutions (LVU, NLC, Agricultural Research Institute, Dionýz Štúr Geological Institute, hydrological and speleological workplaces) is recommended.
Landowners and users should be part of the implementation to ensure the practical feasibility of the measures.

7 Failure to comply with international law obligations

The project does not implement the Carpathian Convention (111/2006) and the Notification of the Ministry of Foreign Affairs of the Slovak Republic No. 304/20123
- Art. Article 7 and Article 9 of Protocol 111/2006 — Sustainable agriculture and forestry, Sustainable development of tourism
- Art. 2, Article 3, Article 4, Article 9, Article 11 and Article 12 of the Notice of the Ministry of Foreign Affairs of the Slovak Republic No. 304/2013
The absence of implementation of the protocols threatens the compliance of the Programme with international law and the obligations of the Slovak Republic.

8 Overall Evaluation

The project contains fundamental professional, methodological and procedural deficiencies that call into question its professional, legal and practical value:
1. Incomplete and outdated data on species and habitats.
2. Insufficient professional background and research methodology.
3. Use of historical data older than the effectiveness of the law.
4. Lack of transparency and participation of owners and affected entities.
5. Unreliable financing and cost estimates.
6. Insufficient involvement of professional institutions and participation of relevant entities. Failure to comply with international legal obligations (Carpathian Convention, Protocol 304/2013).

Urge:

Complementary expert investigations, updating of data, involvement of relevant research institutes and owners, a clear link between measures and international commitments, and regular updates of funding and monitoring.

II. Fundamental objection to the Programme for the Care of the Low Tatras National Park and its Protection Zone

We consider the submitted Management Programme for the Low Tatras National Park and its protection zone (hereinafter referred to as the „Programme“) to be unacceptable in the submitted form, for the following fundamental reasons:

Lack of negotiation and participation

The program was not properly discussed with the affected owners and users of the land, municipalities and other parties to the proceedings, as required by Section 50 (4) of Act No. 543/2002 Coll. on Nature and Landscape Protection. Minutes or other evidence of the discussion and evaluation of comments are completely absent from the documentation. This is a serious procedural deficiency that causes the entire document to be unreviewable and illegal.

Incorrect identification of the parties

The program is based on incomplete identification of ownership relations, there is no identification for E-KN plots and LV in EKN. This resulted in an incorrect determination of the parties to the proceedings, which violated Section 14 of Act No. 71/1967 Coll. (Code of Administrative Procedure).

Contradiction with the international obligations of the Slovak Republic

The programme is contrary to the Protocol on Sustainable Forest Management to the Carpathian Convention (No. 111/2006) and subsequently to Communication No. 304/2013 Coll., by which the Slovak Republic is bound. It lacks the essential elements required by the Protocol, in particular:

binding indicators of sustainable forest management (natural tree composition, dead wood, age structure, water retention functions),
measures to maintain green connectivity and prevent fragmentation;
the mechanism of adaptive management in calamities and climate change,
link to monitoring and reporting according to the Carpathian Convention. The absence of these elements makes the programme inconsistent with international law and jeopardises the fulfilment of the obligations of the Slovak Republic.

Omission of compensation and compensation

The program provides for extensive non-intervention areas and management restrictions, but without addressing compensations according to Section 61 of Act No. 543/2002 Coll. There is no calculation of compensation from the 2nd degree of protection and thus for the increased costs incurred resulting from respecting the restrictions from level 2 and higher. The document conceived in this way does not balance the rights and obligations of owners and users of land, which is contrary to the constitutional principle of protection of property rights.

Legal uncertainty regarding small-scale protected areas

The program assumes the abolition of several small-scale protected areas (PR, CHA) after the zoning is approved, although there is no final decision on their cancellation yet. This causes legal uncertainty and inconsistency with the current legal situation.

Solution proposal

We ask that:

the programme has not been approved in the form presented,
was returned for completion with the incorporation of the above-mentioned deficiencies,
proper consultation with the parties and the public concerned is ensured;
binding indicators of sustainable forest management and measures in accordance with the Protocol (304/2013 Coll.) have been added to it,
and that the programme is aligned with the national and international obligations of the Slovak Republic.

III. Fundamental objection: Questionable objectivity of the Care Programme

The document contains fundamental inconsistencies and inaccuracies, it states directly in the text: „Factors positively influencing the non-forest habitats of the Great Fatra National Park include, in particular…“. This reference to another national park calls into question whether proper and field-verifiable findings have been made for NAPANT. The document thus appears as a formal compilation, not as the result of an objective evaluation. This raises doubts about the reliability of the documents (whether field surveys were actually carried out at all), which should be the basis for a new division of the territory into zones. At the same time, this raises doubts as to whether the measures and proposals are based on the reliably determined state of habitats, protected areas and the landscape as such. Without reliable, professionally verified and transparently communicated data, it is not possible to enforce fundamental restrictions on the use of land. The current NAPANT Care Program and thus the NAPANT zone proposal do not meet these criteria.

Solution proposal:

Field verification of all non-forest habitats

To carry out a systematic survey of the entire NAPANT area, including all levels of protection.
To determine specific ecological parameters: vegetation status, species composition, hydrology, occurrence of endangered species.
The survey must be verifiable, with a clear record of the locations, dates, methodologies used and responsible experts.

 Differentiated assessment of factors affecting habitats

Each impact factor must be identified locally for NAPANT, without comparison with other NPs.
Evaluate both positive and negative factors for each habitat and degree of protection.

Peer review of results

Organize an independent expert committee to assess the accuracy and reliability of field data.
The Commission shall confirm that the data are relevant and sufficient for the design of zoning and measures.

Update of the decision-making documents

Based on the verified data, a new, factual basis for zoning and a proposal for measures will be prepared.
This document must be fully transparent and professionally substantiated so that restrictions on land use can be enforced legally and practically.

 Documentation and archiving of verification

Records of field surveys, methodologies and protocols are archived and serve as evidence of professional verification.
The care project will be complemented by this verified data, removing doubts about reliability.

IV. Fundamental objection to the Low Tatras National Park Management Programme and to the proposal for the NAPANT zoning

Procedural deficiencies

Vague boundary definition
- In the documents, the boundaries of NAPANT are mostly drawn in straight lines, without a link to the plots of the KN-C register and without a geometric plan. This means that only parts of the parcels are included in the different degrees of protection, which is legally unreviewable and causes legal uncertainty.
Autonomy of proceedings
- The care program (Section 54 of Act No. 543/2002 Coll.) is valid for 30 years, while zoning is only valid for 10 years. The merging of proceedings into one is contrary to the principle of legal certainty. We demand that these proceedings be conducted separately.

Documents and methodology

Outdated data
- The mapping of habitats and species is more than 10 years old and carried out only on a sample basis.
- The impacts of climate change are not taken into account.

Lack of monitoring

According to the Report of the Slovak Republic to the European Commission on the status of habitats and species of Community importance (Article 17 of the Habitats Directive and Article 12 of the Birds Directive) published on 11 August 2025, the status of most habitats and a significant part of species is unfavourable or deteriorating. This unfavourable situation also applies to protected areas with protection levels 4 and 5 and zone A – no intervention, while the funds allocated for nature conservation organisations were past and there is no information on how the care was carried out or its effectiveness.

Nevertheless, in their zoning proposal, the nature conservation authorities plan to continue without intervention and restrict the owner, although this regime does not lead to an improvement in the condition of habitats and species. The responsibility for the unfavourable situation thus lies with the nature conservation authorities, which did not ensure the effective use of the allocated funds and adequate care when creating the zoning, which creates a risk of further deterioration of the condition of protected areas and a violation of the legislative obligations of the Slovak Republic and obligations arising from EU directives.

Solution proposal:

Explore the possibility of reducing the degree of protection or re-evaluating zone A – non-intervention in parts where no improvement has been achieved.
To introduce a nature park or an integrated protection regime, allowing the combination of nature protection with sustainable management.
Ensure the active participation of owners and managers so that they can contribute to the care of habitats and species and address the unfavorable situation.“

Missing documents for non-intervention zones
- The expected across-the-board non-intervention in the 4th and 5th degree of protection is not supported by expert analyses. Contrary to Article 4 of the Carpathian Convention (No. 111/2006 Coll.), cultural landscapes and sustainable use of resources are ignored.

Ambiguity in restrictions

Grazing, forestry and agriculture
- Restrictions are defined in general and vague terms, without specifying the scope and specific parcels.
- The program lists yield reductions only for agriculture. There is a lack of quantification of the impacts on forest managers.
Impacts on business entities
- Impacts on tourism, services and municipalities have not been assessed, although according to Article 11 of the Carpathian Convention, the socio-economic development of the region must be taken into account.

Financial coverage and reimbursements

The document does not specify from which chapter of the state budget the compensation is to be paid.
It is not clear how the decrease in revenues from forest management, which are the basis of income not only for non-state owners, but also for the state, will be compensated.
It is not clear how the decrease in profits and the increase in costs for entrepreneurs will be compensated
There is no legal guarantee of timely and fair payment of compensation in accordance with Sections 60 and 61 of Act No. 543/2002 Coll.

Conflict with legal obligations

Carpathian Convention (111/2006 Coll.)
- The Convention requires an integrated approach to nature conservation, agriculture, forestry and sustainable development.
- The Implementation Protocol (Notification of the Ministry of Foreign Affairs of the Slovak Republic No. 304/2013 Coll.) also emphasizes forest management and landscape management. The design of the program and zoning ignores these aspects.
IUCN Categories
- NAPANT is presented as an area heading towards across-the-board non-intervention, which is incompatible with IUCN principles if measurable goals and feedback on conservation outcomes are not set.
EU law
- The proposal does not meet the requirement to achieve and maintain a favourable status for habitats and species (Article 6 of the Habitats Directive, Article 3 of the Birds Directive).

Solution design

Conduct separate proceedings – for the Care Programme (30 years) and for Zoning (10 years).
Refine the documents – new mapping of habitats and species, including the impacts of climate change and socio-economic analysis of the impacts on municipalities and business entities.
Introduce a zoning review every 5 years to respond to new knowledge and changes.
Legally guarantee – a separate chapter in the SR, a system of compensation and compensation for restrictions in agriculture, forestry and business
Explore the possibility of reclassifying part of the territory as a nature park, which is in line with the implementation of the Carpathian Convention and provides a more flexible protection regime.
Strengthen the participation of municipalities, owners and users in decision-making in order to ensure the principle of subsidiarity and partnership according to Article 11 of the Carpathian Convention.

Conclusion

On the basis of the above, we request that the administrative body:

has not issued a decision on the approval of the Management and Zoning Programme in the submitted wording,
ordered the completion of the documents and the development of a variant solution,
guaranteed that the resulting zone would be in accordance not only with national law, but also with the international obligations of the Slovak Republic under the Carpathian Convention and EU law.

V. Fundamental objection to the public decree on the initiation of proceedings on the proposal for the zoning of the Low Tatras National Park and the draft Programme for the Care of the Low Tatras National Park and its protection zone for the years 2026 – 2055

Parties and service

The public notice does not contain a list of parties to the proceedings to be served in this manner pursuant to Section 26 of Act No. 71/1967 Coll. on Administrative Procedure, as amended (the Code of Administrative Procedure) and pursuant to Section 50, paragraph 4 of Act No. 543/2002 Coll. on Nature and Landscape Protection, as amended, delivery to land communities.

According to Section 14 of the Code of Administrative Procedure, the parties to the proceedings are the owners of land whose rights, legally protected interests or obligations may be directly affected by the decision.
If a public notice is used (Section 26 of the Code of Administrative Procedure), it must be clearly clear to whom it is served. Otherwise, the party to the proceedings does not have the opportunity to identify whether the proceedings concern him, which is contrary to the principle of legal certainty and the fundamental rights of the parties to a fair trial (Article 46 of the Constitution of the Slovak Republic).
The mere requirement to ‚inform the public‘ addressed to the municipality cannot replace proper service on a party.
pursuant to Section 50(4) of Law 53/2002. Z .z. The nature conservation authority is obliged to notify the owner, administrator and lessee of the land affected by the intended protection, who can be identified from the records in the Land Register, the municipality concerned and the state administration authorities concerned in writing of the intention to declare a protected area, zones of a protected area or a protected tree (hereinafter referred to as the „plan“). The nature conservation authority is obliged to notify the intention on the basis of the submitted conservation project (Section 54 (13)); If the project is submitted by a nature conservation organisation, the nature conservation authority shall notify the intention within 60 days from the date of its submission. If a larger number of landowners are affected or if their whereabouts are unknown, the notification of the intention may be served by public notice; In the case of a land association, the notification of the intention shall also be delivered to its statutory body.

This procedure omitted the owners of land with permanent residence abroad and also the Land Communities, which are listed as affected in the public notice, even some were omitted, while the intention should have been delivered to the statutory body of a particular land community in writing, not by a public notice. As a result, the proceedings are conducted in violation of the law.

Scope and joinder of proceedings

The public decree combines two procedures – the zoning proposal and the draft Care Program for the years 2026-2055.

These are two separate proceedings with different purposes and legal consequences.
Joining them into a single procedure is inappropriate and contrary to the requirement of clarity and reviewability of the procedure.
We insist on their independent management: a separate procedure on zoning (according to Act No. 543/2002 Coll. on Nature and Landscape Protection) and a separate procedure on the Management Program (a strategic document approved for a longer period).

Validity of documents

The proposal provides for the validity of the Care Programme for the period 2026-2055 (30 years).
In practice, however, the zoning of the national park is updated at approximately 10-year intervals, which is logical due to changes in the natural environment and economic conditions.
Such a long period (30 years) without the possibility of regular revision is disproportionate and inconsistent with the principles of adaptive management required by international conventions.

Compliance with the legislation of the Slovak Republic and international obligations

Incorrect service and exclusion of parties from the proceedings is contrary to Sections 14 and 26 of the Code of Administrative Procedure.
This also violates the Aarhus Convention (Communication No. 43/2006 Coll.), Article 6(2) and (4), which requires real access of the public and owners concerned to decision-making processes.
Article 13 of the Carpathian Convention, which obliges the Slovak Republic to ensure the effective participation of local communities and owners in nature conservation, and Article 4 of the Communication No. 304/2013 Coll., according to which cooperation should have been defined and measures should have been taken to involve owners and managers directly affected in the process at its various stages, are also violated

Proposal for a solution

Correct the public notice to include a complete list of the parties to the proceedings to whom it is served in this way, including owners residing abroad.
Conduct separate proceedings:
- on the zoning of the Low Tatras National Park,
- on the Programme for the Care of the National Park and its Protection Zone.
Revise the proposed duration of the Care Programme and introduce a regular review mechanism (at least every 5 years).

VI. Fundamental objection to the Intention to declare the zones of the Low Tatras National Park, change its boundaries and change the boundaries of its protection zone and to the draft Care Program for the Low Tatras National Park and its protection zone for the years 2026 – 2055

We object to the incorrect determination of the circle of parties to the proceedings and the incompleteness of the documents, which is contrary to Sections 14 and 15 of Act No. 71/1967 Coll. (Code of Administrative Procedure) and Section 7 (3) of Act No. 162/1995 Coll. (Cadastral Act). When processing the documents, the administrative authority relied only on the data of the C CN register, without taking into account the identification of the parcels of the E CN register and the owners registered in this register. This led to an incorrect identification of the parties, as some of the owners were excluded from the proceedings.

We require the following modifications to the documents (tables):

The tables „Changes in the course of the boundaries of the Low Tatras National Park“ must include the identification of parcels of the C CN register to the parcels of the E CN register, including the relevant title deeds (CKN and EKN) in both tables. Types of land must be indicated verbally (e.g. built-up area and courtyard, permanent grassland, arable land, other area, etc.), not only by numerical codes.
The tables „Increase in the territory of the Low Tatras National Park“ and „Reduction from the existing territory of the Low Tatras National Park“ must explicitly state that none of the affected plots is located in the urban area of the village. Types of land must also be indicated verbally (built-up area and courtyard, permanent grassland, arable land, other area, etc.), not only by means of codes.
In the tables „Changes in the course of the boundaries of the protection zone of the Low Tatras National Park“, it is necessary to state for each plot whether it is an urban or an extravilan. For each parcel, the identification of parcels of the C CN register to the parcels of the E CN register, including the relevant title deeds (CKN and EKN) in both tables. The type of land must also be stated verbally (e.g. built-up area and courtyard, permanent grassland, arable land, other area, etc.), while the numerical code may be given in the explanatory notes after the table.

Justification:
The omission of the owners of parcels registered in Register E of the CN and the absence of unambiguous data on the urban/rural area and on the types of land makes it impossible to transparently and legally control the course of the boundaries of the national park and its protection zone. Such a procedure is contrary to Article 20 of the Constitution of the Slovak Republic, Article 1 of the Additional Protocol to the Convention for the Protection of Human Rights and Fundamental Freedoms and the Carpathian Convention, which obliges the Slovak Republic to ensure the protection of nature while respecting property rights and involving the public in decision-making processes.

Proposal for a solution:

We require the tables to be supplemented and corrected in accordance with the above requirements so that:

it was possible to unambiguously check the identification of both CKN and ECN parcels,
the urban/extravilan was transparently determined,
the types of land are indicated verbally, not just by numerical codes;
and that the circle of parties to the proceedings is thus correctly determined.

Without these modifications, the documentation is unreviewable and does not comply with national or international legislation.

VII. List of CKN parcels – fundamental objection and requirement

According to Sections 3 and 47 (2) of Act No 71/1967 Coll. on Administrative Procedure, the decision of the administrative authority must be specific, precise and comprehensible. The published list of parcels in the form of a „part of the parcel“ without further specification does not allow for precise identification of the course of the border.

The document published in this way is:

contrary to Act No. 162/1995 Coll. (Cadastral Act), according to which real estate must be unambiguously identified,
contrary to Act No. 543/2002 Coll. (Act on Nature and Landscape Protection), which requires a clear delimitation of boundaries,
contrary to Article 6 of the Aarhus Convention and Article 4 of Directive 2003/4/EC, which guarantee the right of the public to have access to intelligible information about the territory.

In addition, the published maps (Annex No. 7 of the Project and Annex No. 6 of the Program) are on such a scale that they do not allow the identification of the affected plots and the course of the border. Correctly defining the boundaries of the land plays a key role in the protection of property rights.

Demand

Therefore, we ask that the administrative body:

He added a graphic representation of the border at a scale of at least 1:5,000, or in the case of detailed areas at a scale of 1:2,000, where the border will be legibly marked.
He submitted a table of boundary break points with coordinates in the JTSK03 coordinate system.
In the event that the border passes only through parts of parcels, it ensured the preparation of a geometric plan and the creation of new parcel numbers so that the border could be legally unambiguously identified.
It extended the deadline for submitting comments, as the published documents do not meet the legal requirements for accuracy and comprehensibility.

Zoning of NAPANT – fundamental objections

I. Fundamental objection to the zoning of NAPANT – violation of the rights of owners and municipalities, procedural and legal disputes

Municipalities and landowners in the area of Horehronie and Liptov, whose territory is affected by the proposed zone of the Low Tatras National Park (NAPANT), express concern about the proposed zone, which was submitted without their actual involvement.

According to the proposal, the following are included in NAPANT:

up to 65–90% of the territory of several municipalities in the Horehronie region,
a significant part of private and community ownership (PS);
more than half of the areas are designed in zones B and C, where sustainable management is limited or completely impossible.
Zone D encroaching on the urban areas of the municipality

Contradiction with the Carpathian Convention and EU principles

The obligations of the Slovak Republic arising from the Carpathian Convention (111/2006) and its Protocol on Sustainable Forest Management (304/2013) are clear:

the land is inhabited and farmed – protection should respect traditional uses;
promoting sustainable forestry and agriculture;
respect for property rights and rural economic stability.

However, the proposed zone:

ignores the farmed land with a thousand-year history,
excludes landowners from administration;
It introduces passive protection (non-intervention) even in areas where restoration and management are essential.

II. Fundamental objection to the zoning of NAPANT – declaration of zones The proposed NAPANT zone (including its protection zone) contains changes in individual zones:

A-zone: proposed extension with level 5 protection,
B-zone: change of area and degree of protection,
C-zone: proposed level 3 of protection,
D-zone: 2nd level of protection.

Fundamental problem:

Illegal or non-existent declaration of protection levels: There are no decisions or ordinances available in the submitted zoning proposal that would legally declare the 5th degree of protection for the A-zone or changes in the protection levels for the B-, C- and D-zones.
Violation of legal procedure: According to Act No. 543/2002 Coll. on Nature and Landscape Protection (Section 12), protection levels must be declared before they are included in zoning. Zoning can only map legally effective levels of protection, not design them or assume their validity.
Invalidity of zoning in the parts referring to new degrees of protection: If a zoning contains degrees of protection that have not yet been legally declared, the part of it relating to these levels is procedurally and legally disputed, which poses a serious risk of nullity.
Insufficient information on decisions: The zoning tables include changes in the levels of protection in both the NAPANT and its protection zone, but the number of the decision or decree that would prove the legal effectiveness of the proposed changes is not provided.

Requirement:
Before approving and declaring the zoning of NAPANT and its protection zone, it is necessary to legally declare all new levels of protection and changes to the existing levels of protection for individual zones (A-D). Only when this condition is met can zoning be legally effective and acceptable.

Grounds for the comment:

The zoning proposal, which maps the degrees of protection not yet declared, violates legal procedures and poses a fundamental risk of legal ineffectiveness. Therefore, we propose that this part of the zoning be corrected and supplemented only after the legal declaration of all affected levels of protection.

Our proposal: Low Tatras Nature Park

Based on the right and legitimate expectations, we propose:

re-evaluation of the NAPANT proposal,
establishment of the Low Tatras Nature Park (in accordance with Section 17 of the Nature Protection Act),
involvement of owners, municipalities and experts in the management of the territory in the form of partnership,
contractual protection of habitats, not unilateral zoning;
respect for property rights and management as a form of protection.

Our reasons:

we live in this country and take care of it,
we know its values, possibilities and limits,
We want to preserve it as a habitable and productive cultural landscape for future generations.

Threats to rural life and natural landscape care

Owners, users and rural residents do not want to be just passive addressees of legal obligations. They live in the country, manage and take care of their property – whether in the form of agricultural or forestry activities, or by providing services, recreational and tourist activities. In this way, they naturally and indirectly fulfil their obligations under the law, while preserving the countryside as a livable, productive and attractive environment.

However, disproportionate bans and restrictions threaten this way of life – they make it impossible to manage agricultural and forest land, limit the development of local businesses and services, including agritourism or recreational activities. Instead of supporting rural development, there is a risk of its decline, the departure of inhabitants and the gradual degradation of the landscape, which has been shaped and protected for centuries by local residents.

Our fundamental comments are directed at the fact that the current zoning proposal and the NAPANT Care Program cannot be considered an objective and reliable basis, as it questions its own data and is not based on real external findings. At the same time, it threatens the life of the countryside, the economy and the development of communities that are an integral part of this country. Therefore, we ask that the Low Tatras Nature Park be considered as an alternative – a model that combines nature conservation with sustainable rural development, is in line with the international obligations of the Slovak Republic (Carpathian Convention, Communication of the Ministry of Foreign Affairs No. 304/2013) and respects the rights of the population to live, manage and develop in the country that is their home.

Conclusion

We want to protect this country – not just close it off, but actively maintain its value as it is

This is what generations before us did.

We do not agree with the transformation of the country into a non-intervention and lifeless territory.

We believe in protection through cooperation, not exclusion.

A nature park is a model that respects man as a natural part of the landscape, enables sustainable management in forests and agriculture, while protecting natural values.

In Banská Bystrica, on 15.09.2025

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