Architect and former Deputy Mayor of Dubrovnik Orlanda Tokić has published an extensive critique of the planned amendments to the General Urban Plan (GUP) of the City of Dubrovnik, following the news that the hotel group Maestrali received a building permit for a new hotel on the site of the Adriatic restaurant in Uvala Lapad. In her Facebook post, Tokić argued that the new spatial plan systematically favors large hotel investors at the expense of citizens.
"Dubrovnik for citizens or for hotels? A story that raises serious questions," Tokić began her post, which was picked up by Dubrovniknet and Dulist. Her criticism is based on a detailed analysis of capacities and the chronology of decisions that, in her view, led to plans for nearly 225 new beds in the Maestrali complex.
Chronology of 'Favoritism': From the 2021 Exception to a New Hotel
Tokić reminded of the key dates that enabled the current situation. "Back in April 2021, during the first GUP amendments, the hotel group Maestrali received special status, i.e., their objection was adopted to retain their built-up area and height of 22 meters," she wrote. She added that the then-explanation that the state sold Maestrali under those conditions "didn't hold water" for her.
Only three months later, in July 2021, the first concrete permits followed. "Several location permits for reconstruction were issued: Adriatic I, Adriatic II, Vis, and the Adriatic restaurant," Tokić stated. The culmination of this process is the building permit for the new hotel, published on August 7, 2026, which will have 78 single and 72 double rooms.
The Math of Capacity: How 963 Becomes 1110, Then 1188
The core of her argument lies in the numbers. Tokić points out that the current GUP, in Article 43, stipulates that Maestrali must not increase capacities, limiting them to 963 beds. However, her calculation shows that the sum of existing and planned beds already exceeds this figure.
"The new hotel on the site of the Adriatic restaurant, 222 beds. The new Vis I, 236. The reconstructed Adriatic I, 224. The existing Splendid 113, Uvala 102, Komodor 118, Adriatic II 95. The total is 1110 beds," Tokić calculated. To stay within legal limits, the plan states that the Komodor hotel, a building with four above-ground floors, will become a warehouse in the future, which Tokić finds unbelievable.
"The location permit does not cover the reconstruction of the Komodor hotel. It covers Adriatic II, as an annex to Komodor. Komodor itself is not. So I don't know what guarantees that it will one day become a warehouse," Tokić warns.
New GUP Removes Restrictions and Opens the Door for Further Expansion
The key problem, according to her, lies in the draft of the new GUP. Urban rule 1.3.9. explicitly lists all Maestrali hotels and their reconstruction conditions, but the new hotel on the site of the Adriatic restaurant is not mentioned. At the same time, the new GUP abolishes the accommodation capacity table from Article 43, eliminating the 963-bed limit.
"In translation, this means: the Komodor hotel and its annex Adriatic II never have to become a warehouse; instead, under the new GUP, they will be reconstructed and remain hotels. The new hotel on the site of the Adriatic restaurant can, through a building permit amendment under the new GUP, present those single rooms as double rooms because there is no capacity limit," she explained.
Her final calculation is concerning: "The total number of beds, by combining the old GUP from 2021 and the new GUP, will now legally increase to 1188, plus or minus a few beds, depending on future planned reconstructions, i.e., some 225 new beds."
The Burden of Restrictions on Citizens, Hotels Exempt
Tokić agrees that the city is overbuilt and that restrictions are necessary, but she believes they should not be borne solely by residents. "Under the new GUP, citizens of the City of Dubrovnik have reduced opportunities for building new residential buildings, reconstruction of existing family houses and multi-apartment buildings is restricted, construction density is reduced, and additional restrictions are introduced," she listed.
At the same time, she claims, the opposite is happening for the tourism sector: "In tourist zones, accommodation capacities are increased, and new hotel construction is enabled (Maestrali, ALH, Valamar)." Her conclusion is sharp: "The burden of protecting transport infrastructure is almost entirely shifted onto the citizens of the City of Dubrovnik and residential construction, while hotel tourism and large tourist investors are largely exempt from such restrictions."
Tokić revealed that she submitted 50 pages of objections to the new GUP, which also cover Maestrali. She concluded her post with a series of rhetorical questions about the city's future: "Where will our fellow citizens live in the future? Will we become a city of hotels, restaurants, and Instagram photo spots at the expense of the citizens of Dubrovnik? Are we, the citizens of the city, important to this city, or are tourists and hotel companies?"