View of the Committee of the Slovak Academy of Sciences for environmental issues and climate changeon the planned division of the Poloniny National Park
As an expert advisory body of the SAS with a nationwide scope, the Committee of the Slovak Academy of Sciences (SAS) for environmental issues and climate change follows with concern the plans and activities for the division of the current Poloniny National Park into a reduced Poloniny National Park (NP) and a new Poloniny - Low Beskids Nature Park.
At the same time, we would like to remind that the territory of the Poloniny National Park is an area with exceptional natural values and one of the most valuable territories in Slovakia regarding natural and cultural heritage. These values are also recognized and honoured at the international level, either by their inclusion in the Natura 2000 network of protected areas (e.g. SKUEV0229 Bukovské vrchy and SKUEV0234 Ulička), inclusion in the trilateral East Carpathians Biosphere Reserve of the UNESCO´s MaB programme, awarding of the European Diploma by the Council of Europe and by including the most important forests of the territory in the “Ancient and Primeval Beech Forests of the Carpathians and Other Regions of Europe” UNESCO World Heritage Site.
We have very few such valuable territories in Slovakia and Europe, and their protection and preservation in the best possible condition for future generations should be the highest priority, also from the point of view of fundamental and binding international documents, such as the Convention on Biological Diversity (CBD) and its new strategic plan for 2030 (Kunming-Montreal Global Biodiversity Framework), EU Biodiversity Strategy for 2030, EU Birds and Habitats Directives, IUCN Guidelines for Applying Protected Area Management Categories, the IUCN guidelines for conserving connectivity through ecological networks and corridors, but also according to national documents such as the National Biodiversity Strategy and Action Plan for 2030, Greener Slovakia - Strategy of the Environmental Policy of the Slovak Republic until 2030, the Adaptation Strategy of the Slovak Republic to Climate Change and other.
The prepared proposal for the division of the territory of the Poloniny National Park contradicts the above-mentioned priority and the related obligation of the Slovak Republic.
Adoption of the proposal would mean a significant reduction of the area of the National Park by almost two-thirds, its fragmentation into mutually isolated parts, and the division of nature protection management into two entities, one of which currently does not exist.
We anticipate a reduction in the degree of protection in the territory proposed for exclusion from the national park, since the principle of the superiority of nature protection over other activities, which is typical for a national park, does not apply to the nature park category.
We see no reason to exclude almost two-thirds of the territory from the Poloniny National Park, as the affected area is dominated by natural forests and semi-natural grasslands, which by their nature meet the definition of a national park as an area “mainly with ecosystems substantially unchanged by human activity or in a unique and natural landscape structure”. Its exclusion would, among other things, significantly worsen the conditions for the protection of large mammals, birds and several other groups of animals that prefer a continuous, unfragmented territory and require the preservation of the country's connectivity.
The proposed change reduces the protection of the territory, its connectivity and the overall coherence of the Natura 2000 network, threatens to worsen the state of preservation of protected areas, does not allow for sufficiently high-quality management of nature and environment protection, ensuring the protection of the state interests and its international obligations, including those valid specifically for NP Poloniny.
The proposed territory division of the Poloniny National Park is also in direct contradiction with the Slovak Republic's commitment to the protection and management of the “Ancient and Primeval Beech Forests of the Carpathians and Other Regions of Europe” UNESCO World Heritage Site, where Slovakia is one of the three leading countries and hosts a permanent secretariat for this location.
Of the several significant risks of dividing the territory of the Poloniny National Park, we emphasize that the Havešová Nature Reserve and the Udava Nature Reserve (both of which are part of the above-mentioned World Heritage Site) would be outside the contiguous territory of the national park, which would worsen the possibilities of their protection also by reducing their so-called buffer zones. In addition to its own territory, for the territory of this World Heritage Site, the size of the buffer zone is also specified, including the territory of the Poloniny National Park (Havešová 6,470.84 ha; Rožok 1,138.71 ha; Stužica – Bukovské vrchy 5,694.11 ha; Udava 814, 62 ha). The proposed division of Poloniny NP would directly affect these buffer zones.
By joining the Carpathian Convention in 2004, the Government of the Slovak Republic committed itself to the protection and sustainable development of the Carpathians. By ratifying five protocols of the Carpathian Convention, including the Protocol on Conservation and Sustainable Use of Biological and Landscape Diversity (2011), the Protocol on Forestry (2013) and the Protocol on Sustainable Agriculture and Rural Development (2021), it has refined and expanded its obligations. The planned division of the Poloniny NP contradicts the efforts for the sustainable development of the Carpathians, the spirit of the above-mentioned documents and their provisions, and we rightfully fear that it would mean a violation of the obligations of the Slovak Republic in the Carpathian Convention, its protocols and other mentioned international documents.
However, effective management of national parks with the participation of landowners is practised in several European countries.
For the above reason, we recommend the Ministry of the Environment to:
- stop the process of the planned division of the Poloniny National Park;
- continue preparing the zoning of the Poloniny National Park within its current boundaries, including aligning the interests of landowners and users with the interests of nature and landscape protection;
- find an appropriate way to involve land owners in the management of the national park;
- prepare zoning based on professional documents and expertise, with the participation of the relevant
experts;
- design the zoning of the Poloniny National Park in such a way that:
- the interests of nature protection and the international obligations of the Slovak Republic were fully ensured, taking into account the sufficient size of the nuclear zone, its representativeness, connectivity and other important features,
- the prerequisites were created for the use of the territory in accordance with the principles of sustainable development,
- the municipalities and economic activities were developed respecting their location in the National Park with the use of participatory integrated spatial planning.
The opinion was given by RNDr. Pavol Siman, PhD., Chairman of the SAS Committee
Foto: Facebook/NP Poloniny a Vihorlatské vrchy s okolím