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Names of the victims would be engraved into one side of the peninsula's symbolic wound, with a observation gallery installed into the facade on the opposite side.
The jury which selected the proposal describe it as "a wound or a cut within the landscape" which symbolises "something being taken away".
The idea was hailed when it was chosen in late February --but since then the criticism has grown.
Families of some of the victims complain they were never consulted on the avant-garde installation, while residents say that it scars the landscape and experts argue that it's technically not viable.
"I'm not against the monument in itself. It's the way that it was chosen and the location that poses a problem for me," said Vanessa Svebakk, the mother of the youngest victim, aged 14.
Breivik is serving out a 21-year prison sentence for the murder of a total of 77 people in a rampage which also saw eight people die in a bomb attack outside a government building in Oslo.
"Since the process started at the end of 2012, we who were closest to the victims, the most affected, have been kept in the dark," Svebakk told AFP.
"It's arrogant to use the names of our children without asking us. The fact that they are dead does not make them any less our children."
She said it was out of the question that her daughter's name should appear several hundred metres away from the island where she was killed.
Svebakk and several other families want to see a complete overhaul of the memorial project.
- 'Tourist attraction' -
They have been joined by people who live nearby the planned site.
"It's a bit hard to accept that we'll be reminded of (the massacre of) July 22 every day for the rest of our lives," said local Ole Morten Jensen.
"I don't need those kinds of reminders. I had enough of them already," he told public broadcaster NRK.
Opponents of the memorial have started a social media campaign on Facebook -- which has attracted almost 900 members -- with some condemning the project as a "rape of nature", and a "tourist attraction" that runs the risk of becoming a pilgrimage site for Breivik admirers.
Further complicating the memorial, a geologist, Hans Erik Foss Amundsen, pointed out that the rock foundation at the project site is porous and the facade planned for the victim names would crumble into the sea.
"It's like digging in a pile of gravel," he said.
Nonetheless, the backers of the project -- which is due to be inaugurated on July 22, 2015 -- are confident that it will go ahead.
"Public art always attracts a multitude of viewpoints, especially when it concerns a work that commemorates a drama like Utoeya," said Svein Bjoerkaas, director of Koro, the Norwegian organisation responsible for public art.
"But from past experience, after some time the criticism dwindles," he told AFP.
"Let's keep in mind that this memorial is not only for those -- relatively few -- who are against it, but also the many who are in need of it."
In a statement, the chairman of the selection jury, Joern Mortensen, answered all the criticism firmly.
"The location of the memorial? It was imposed from the start by the state," he said.
"The opinion of close relatives? The vice-president of the support group of the victims' families was a member of the selection committee," he added.
Mortensen also said victims could remain anonymous and that "technical solutions exist" for any problems regarding the crumbling rock terrain.
It was possible to attract visitors and maintain the dignity of the site as shown by the Vietnam Veterans Memorial in Washington DC, Mortensen said.
"Our mission is to create a place of memory, not a place of forgetting."
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The jury which selected the proposal describe it as "a wound or a cut within the landscape" which symbolises "something being taken away".
The idea was hailed when it was chosen in late February --but since then the criticism has grown.
Families of some of the victims complain they were never consulted on the avant-garde installation, while residents say that it scars the landscape and experts argue that it's technically not viable.
"I'm not against the monument in itself. It's the way that it was chosen and the location that poses a problem for me," said Vanessa Svebakk, the mother of the youngest victim, aged 14.
Breivik is serving out a 21-year prison sentence for the murder of a total of 77 people in a rampage which also saw eight people die in a bomb attack outside a government building in Oslo.
"Since the process started at the end of 2012, we who were closest to the victims, the most affected, have been kept in the dark," Svebakk told AFP.
"It's arrogant to use the names of our children without asking us. The fact that they are dead does not make them any less our children."
She said it was out of the question that her daughter's name should appear several hundred metres away from the island where she was killed.
Svebakk and several other families want to see a complete overhaul of the memorial project.
- 'Tourist attraction' -
They have been joined by people who live nearby the planned site.
"It's a bit hard to accept that we'll be reminded of (the massacre of) July 22 every day for the rest of our lives," said local Ole Morten Jensen.
"I don't need those kinds of reminders. I had enough of them already," he told public broadcaster NRK.
Opponents of the memorial have started a social media campaign on Facebook -- which has attracted almost 900 members -- with some condemning the project as a "rape of nature", and a "tourist attraction" that runs the risk of becoming a pilgrimage site for Breivik admirers.
Further complicating the memorial, a geologist, Hans Erik Foss Amundsen, pointed out that the rock foundation at the project site is porous and the facade planned for the victim names would crumble into the sea.
"It's like digging in a pile of gravel," he said.
Nonetheless, the backers of the project -- which is due to be inaugurated on July 22, 2015 -- are confident that it will go ahead.
"Public art always attracts a multitude of viewpoints, especially when it concerns a work that commemorates a drama like Utoeya," said Svein Bjoerkaas, director of Koro, the Norwegian organisation responsible for public art.
"But from past experience, after some time the criticism dwindles," he told AFP.
"Let's keep in mind that this memorial is not only for those -- relatively few -- who are against it, but also the many who are in need of it."
In a statement, the chairman of the selection jury, Joern Mortensen, answered all the criticism firmly.
"The location of the memorial? It was imposed from the start by the state," he said.
"The opinion of close relatives? The vice-president of the support group of the victims' families was a member of the selection committee," he added.
Mortensen also said victims could remain anonymous and that "technical solutions exist" for any problems regarding the crumbling rock terrain.
It was possible to attract visitors and maintain the dignity of the site as shown by the Vietnam Veterans Memorial in Washington DC, Mortensen said.
"Our mission is to create a place of memory, not a place of forgetting."
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