Photo: CJA/ Nikola Šolić
The fundamental objection of the HND primarily focused on the procedures and foundations that should precede the proposal and subsequent adoption of the national plan for the development of culture and media. The HND believes that, before preparing the mid-term National Plan, the Ministry of Culture and Media should have proposed a higher-level long-term document, namely, a national strategy for cultural development that includes media and journalism as integral parts crucial for informing citizens in democratic societies. The competent body of state administration, namely the Ministry of Culture and Media, is proposed to initiate the creation of such a document in accordance with the procedure outlined in the Law on the System of Strategic Planning and Development Management of the Republic of Croatia. Unlike national plans proposed and adopted by the government, sectoral and intersectoral strategies are adopted by the Croatian Parliament, which would be more appropriate given that strategic documents shape media policy and anticipate the content of media laws. In 2004, the Constitutional Court included media laws among "organic laws," elaborating on constitutionally established human rights and fundamental freedoms, including freedom of speech, public appearance, and the free establishment of all public communication institutions.
Furthermore, adopting a national plan without a prior strategy is akin to discussing only a draft of a short-term action plan without a previously established mid-term national plan.
Among other things, the HND also commented on the proposer's intention to enhance the role of media and the status of journalists, believing that the proposer omitted to include activities that would improve the position of journalists, adding dimensions of material security such as salary and fee increases, as well as increased statutory autonomy within the editorial offices and protection for freelancers. In the consultation, the HND requested the inclusion of journalists in measures "ensuring stable support for the status of artists," including health and pension insurance payments for independent artists, with appropriate and legally based coefficient adjustments. The HND also called for enabling pension and health insurance for freelance journalists, members of the HND.
The HND particularly emphasized the necessity of establishing an adequate fund for the media or a fund for professional journalism with clear goals and criteria for its distribution. The main purpose of the fund should be transparent and free from political influence in publicly financing professional journalism. Possible sources of funding include a share in the gross income of digital platforms, a portion of gambling revenues, part of media concession fees, symbolic advertising tax (with the introduction of amortization for advertising brands), electronic consumer devices, revenues from internet access fees, and the use and auction of radio frequency spectrum and the state budget. The HND believes that new distribution mechanisms will need to be devised for the allocation of funds collected by the new media fund to ensure fair public financing of the media, free from conflicts of interest and political pressure.
The HND reminded the proposer that in May of this year, it published Models for Financing Local Media with an analysis and recommendations, which were submitted for consideration.