Združenie vlastníkov spoločenstevných a súkromných lesov Banskobystrického kraja

Združenie vlastníkov spoločenstevných a súkromných lesov Banskobystrického kraja ZVSaSL BBK

Manifesto

Associations of Owners of Community and Private Forests of the Banská Bystrica Self-Governing Region and the Land Association of the Compossessorate and Urbariat of Šalková. The manifesto is developed in accordance with the basic principles and values of the European SMURF project. 

The Association of Owners of Community and Private Forests of the Banská Bystrica Self-Governing Region (hereinafter referred to as the „Association“) and the Land Association of the Compossessorate and Urbariat Šalková (hereinafter referred to as the „Community“) express their fundamental disagreement with the procedure of state administration and nature conservation bodies in proposing and approving the zoning of the Low Tatras National Park (NAPANT) and in the creation of the Care Program for this National Park and the NAPANT Protection Project

As a representative voice of the owners, we emphasize that the preparation and approval processes:

  • have not been carried out in accordance with the laws of the Slovak Republic, the Constitution of the Slovak Republic or Slovakia’s international obligations,
  • they did not respect the rights of owners and users;
  • do not meet the principles of the Carpathian Convention and its Protocol on Sustainable Forest Management (Communication of the Ministry of Foreign and European Affairs of the Slovak Republic No. 304/2013 Coll.).

I. Fundamental reservations

  1. Omission of owners and violation of constitutional rights

During the evaluation, the identification of the CKN Register parcels for the EKN Register parcels was not carried out. The beneficial owners were omitted, which violated Article 20 of the Constitution of the Slovak Republic, which guarantees equal protection of all forms of ownership. The exclusion of owners from the proceedings and the restriction of the use of their property without proper participation is an interference with Article 20 of the Constitution of the Slovak Republic.

  1. Mismatch of time horizons

The zoning proposal is prepared with a horizon of 10 years, while the Care Program with a horizon of 30 years. This inconsistency is in direct contradiction with the principles of coordination and proper planning.

  1. Omission of the parties

Owners and users were not properly invited to the processes. They were not served with a public notice and thus at least violated § 3, § 14 and § 26 of Act No. 71/1967 Coll. (Administrative Code). This violated the right to a fair trial.

  1. Deficiencies in map data

The maps (Annex No. 6 of the NAPANT Care Program and Annex No. 7 of the NAPANT Protection Project) are of an unsatisfactory scale and do not allow the identification of boundaries and plots. such maps cannot identify parcels or determine the extent of restrictions. The minimum required scale is 1:5000, otherwise the maps have no informative value.

  1. The objectivity of the Care Programme at issue

The document contains fundamental inconsistencies and inaccuracies, directly in the text it states: „Factors positively affecting 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 proposal for the zoning of NAPANT do not meet these criteria.

  1. Inclusion of urban areas in zone D

The inclusion of urban areas of municipalities and adjacent land in zone D is unacceptable. Such a step:

  • has not been properly discussed with municipalities and owners,
  • it will limit the development of municipalities, construction activities and investments;
  • increases the costs of municipalities without a clear guarantee of reimbursement pursuant to Section 61 et seq. of Act No. 543/2002 Coll.,
  • is contrary to Articles 20 and 44 of the Constitution of the Slovak Republic, Article 1 of Protocol No. 1 to the Convention for the Protection of Human Rights and Article 6 of the Aarhus Convention.
  1. Threats to sustainable farming and rural areas

The inhabitants of the Low Tatras want to live in their environment, use and manage their property, manage fields and forests, provide services and develop local business. In this way, they naturally and indirectly fulfil their obligations arising from the laws on the protection of nature, soil, forests or water. The proposed zoning threatens these activities, thus directly threatening the development of the countryside itself, its economic sustainability, job opportunities and cultural traditions.

  1. Non-compliance with the Carpathian Convention and Communication No 304/2013

The proposed zoning, oriented towards non-intervention on 75% of the territory, is contrary to the Protocol on Sustainable Forest Management, which the Slovak Republic has ratified. The Convention requires the harmonization of nature conservation with the socio-economic needs of the population and the promotion of cultural landscapes. This is ignored in its current form. The Low Tatras are a cultural landscape shaped by centuries of farming, grazing and forest management. The zoning proposal, based on 75% of the non-intervention area (according to the IUCN), does not respect the historical or current living conditions in the region and leads to a threat to the countryside itself. When creating the zoning and the NAPANT Care Project, these documents binding for Slovakia were not considered at all; were not the basis for their creation (see the Overview of professional literature and used professional documents in the documents Care Program for the Low Tatras National Park and its Protection Zone and the NAPANT Protection Project)

II. Our requirements

  1. Stop the process of approving the proposed zoning and the Care Program in the submitted form.
  2. To develop a new proposal that will respect the laws of the Slovak Republic, the Constitution of the Slovak Republic, the Carpathian Convention and the rights of owners. Complete the proper identification of parcels and parties to the proceedings,

and provide understandable map data at a scale of at least 1:5000,

  1. Ensure the full participation of owners in the process – including clear documents and accessible maps.
  2. To divide the procedure into the procedure on  the zoning of NAPANT and the procedure on the Care Program for NAPANT and its protection zone
  3. Introduce a fair system of compensation and compensation for restrictions on property rights, with the creation of a chapter in the State Budget.
  4. Assess the objectivity of the Management Program and verify whether it is based on the realistically determined state of habitats and natural values.
  5. To exclude the urban areas of municipalities and adjacent land at least within a radius of 1 – 5 km as the crow flies from zone D, according to the requirements of citizens (municipality, PS, entrepreneurs), while these areas are to be left as wild nature and development facilities of the municipality, only then, in agreement with municipalities and owners,   users, managers and entrepreneurs and other affected persons, can the creation of a protection zone be started.

 III. Nature park as an alternative

The association of owners clearly declares that it prefers the form of a nature park to a national park.

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.

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. The Low Tatras Nature Park will be:

  • provide adequate protection of natural values;
  • promote rural development as an equivalent value;
  • preserve traditional farming, agriculture, forestry and local entrepreneurship;
  • to create space for recreational and tourist services, which are a source of livelihood for the population,
  • to respect the rights of owners and to promote their active participation in the protection and development of the territory.

This model is in line with the Carpathian Convention and with the obligations of the Slovak Republic announced in the Communication of the Ministry of Foreign Affairs No. 304/2013, since:

  • combines nature conservation with sustainable development;
  • strengthens the living conditions of the population and their cultural identity;
  • supports the sustainable management and development of the region.

IV. Conclusion

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 calls on the state authorities and the NAPANT Administration to:

  • open a real dialogue with owners;
  • respect the law, constitutional rights and international obligations;
  • They have prepared a zoning that will not be in conflict with the rights of owners or the principles of sustainable management.

Our fundamental comments are aimed at the following:

  • the NAPANT zoning proposal and the NAPANT Care Program are not objective and clearly threaten the lives of rural residents,
  • management constraints are not balanced by real measures to support people living in rural areas;
  • there is a non-compliance with the obligations of the Slovak Republic under the Carpathian Convention and the Notice of the Ministry of Foreign Affairs No. 304/2013.

Therefore, we ask that the Low Tatras Nature Park be considered as an alternative – a model that protects nature, but at the same time guarantees sustainable rural development, the rights of owners and the life of the rural population in accordance with domestic and international obligations.

Our ambition is not to destroy nature, but to protect it in a way that is sustainable, fair and viable in the long term. In this way, the landscape will remain a home for both people and nature.

The manifesto, which was jointly developed by representatives of 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, was adopted and approved at the meeting of all land communities within the Banská Bystrica Region without comments.

In Banská Bystrica, on 28.08.2025

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