Hopefully someone will react to the numerous criticisms of beekeepers regarding the Beekeeping Regulation

Uh, how much fierce criticism the Ministry of Agriculture is enduring due to the Proposal for the Beekeeping Regulation! All of this can be read on the e-Consultation portal. The amount of bitterness it has caused is evident from the fact that some critics have already announced that they will address the Constitutional Court. Their biggest problem is that the Croatian Beekeeping Association (HPS) receives the public authority to enforce the grazing order (Article 9).

I will not delve into how competent the people in HPS are, nor into whether there are any corrupt individuals among them, as I am neither qualified to assess someone’s competence nor do I have evidence of corruption. However, all the claims made in public comments on e-Consultations would be, if I were someone in the Ministry of Agriculture, a clear call for me to verify them and, if they prove to be at least partially accurate, to timely offer a new proposal for the regulation.

Godfather is sacred

For example, critic Stjepan Grgić (as he is signed) writes that he is a long-time secretary of one ‘beekeepers’ association, also the secretary of the county beekeeping association and an educator for the grazing commissioner,’ and emphasizes that the mentioned proposal is largely unenforceable as it leads to the destruction and privatization of beekeeping in Croatia. Namely, he writes, HPS has a professional service with four employees: the first is a university-educated lawyer without experience or contact with beekeeping, the second is an accountant with a high school diploma, also without contact with beekeeping. The third edits the monthly ‘Croatian Bee,’ and the fourth coordinates work with beekeepers. Grgić is convinced that this composition does not have the corresponding personnel potential for this job.

The current Regulation is not the best either, and the new one, he emphasizes, would strengthen and cement the situations he described as part of the criticism. ‘Beekeeper A submits a request to the commissioner for the relocation of bees to the acacia pasture about fifty days in advance and attaches a signed and certified consent from the legal entity (the owner of the plot) allowing the beekeeper to place the bees. The grazing commissioner (an active police officer) gives the beekeeper a negative response with the explanation that there are no conditions from the Beekeeping Regulation and the beekeeping pasture cadastre at the specified location.

Just before the start of the acacia pasture, the same grazing commissioner issues approval to beekeeper B (his godfather) for the placement of bees precisely at the specified location. Beekeeper A sends the collected evidence of the duplicity and nepotism of the grazing commissioner to the HPS professional service, as well as to the senior livestock inspector responsible for the specified area. Beekeeper A has not yet received a response from either the HPS professional service or the responsible senior livestock inspector, and both know that the grazing commissioner is an active police officer.’

HUP Beekeeping raises the question of whether grazing commissioners, if they decide on someone’s rights, will be state officials and whether they will have passed the state exam accordingly, concluding that the Regulation equates HPS and grazing commissioners with the State Inspectorate, which is not in accordance with any law. Rahela Grgić fears that ‘there is a dangerous lack of people who could effectively implement the provisions of Article 9.’ as she emphasizes that she does not see ‘people in HPS who could perform these tasks; they are neither sufficiently educated nor do they have experience in beekeeping to carry them out properly.’

Anger, even rage

Critics Krunoslav Kosić, Goran Bionda, Beekeeping online, the Association of Beekeepers Lonjsko Polje Kratečko… think the same. As I write this, there are a total of 75 comments, many of which are very sharp. As I mentioned, some among them threaten with a request for a review of the constitutionality of the Regulation, but legal experts are more likely to direct them to a request for an assessment of its legality since the law itself is in accordance with the Constitution, at least I assume it is so. Nevertheless, it seems to me that this is more a question of the (in)correctness of the political decision.

Of course, all of this still needs to be verified, but such a level of anger, even rage, I would say, that is felt while reading the comments should not leave anyone indifferent. Therefore, I appeal to those responsible in the Ministry to reconsider Article 9 of the Beekeeping Regulation once again.

POST SCRIPTUM

Currently, there are many proposals for amendments to the law related to the introduction of the euro. However, a person signing as Tomislav Pavošević has presented, in my opinion, a reasonable proposal for rounding numbers. For example, in the Proposal for amendments to the General Tax Law (but not only in it), the amounts in euros are identical to those obtained using the conversion rate of 1 euro = 7.5345 kuna, which loses clarity and transparency of legal provisions. Therefore, he proposes that the conversion of kuna to euro be carried out using so-called round numbers. For example, for Article 8, paragraph 7, he proposes that 100,000 kuna be replaced with 13,000 euros. If the exchange rate were applied, then the law would state 13,272.28 euros, which is indeed confusing for anyone reading the law.