The Faculty of Architecture did not have adequate permission to prepare the Impact Assessment Study on the Heritage and Natural and Cultural Historic Area of Kotor (HIA), with which the Government is trying to prevent the United Nations Educational, Scientific and Cultural Organization (UNESCO) from removing this city from the list of world cultural and natural heritage.
This is proven by the documents obtained by the Network for the Affirmation of the Non-Governmental Sector (MANS).
Kotor is under the scrutiny of UNESCO due to the consequences of excessive urbanization of this protected area.
According to the documents obtained by MANS, the Faculty of Architecture in Podgorica, at the time when it entered into a contract with the Ministry of Culture on the creation of the HIA, it did not have the necessary conservation license, but received it only three months later.
The Ministry of Culture claims to "Vijesta" that "as then, as now, it is not necessary to have a conservation license to prepare a Heritage Impact Assessment", and that therefore the HIA carried out by the Faculty of Architecture in September 2017 is a valid document.
The contract on the financing of this project, worth 50.000 euros, was signed in December 2016 by the then Minister of Culture, Janko Ljumović, and the Dean of the Faculty of Architecture, Svetislav Popović.
The Faculty of Architecture contracted by September 1, 2017 to prepare a comprehensive Heritage Impact Assessment (HIA), based on the ICOMOS guidelines, "in relation to the Heritage Impact Assessment for cultural properties on the World Heritage List in order to establish a clear framework for the protection of the exceptional universal value of the cultural property and its characteristics, and to promote sustainable and compatible forms of development".
The creation of this document by the Government was done by UNESCO, at the session in July 2016.
In February 2017, the Government adopted the Action Plan for the implementation of decisions related to the area of Kotor. According to the plan, the Faculty of Architecture is "recognized as the bearer of the preparation of the subject assessment", while the partners in the preparation of the HIA are the Administration for the Protection of Cultural Properties and the Montenegrin National Commission for UNESCO.
At the time of the conclusion of the contract, according to the documents obtained by MANS, the Faculty of Architecture did not have a conservation license.
It was issued to him only three months later - on March 6, 2017, based on the application submitted to the Commission for the issuance of a conservation license in December 2016 and supplemented documentation from February 2017.
This means that the Faculty of Architecture did not have a conservation license even at the time when, adopting the Action Plan for the Conservation of Kotor on the UNESCO list on February 2, 2017, the Government of Montenegro "recognized it as the holder of the preparation" of the key document - the HIA study.
"Given that the assessment of the impact on heritage - HIA, was not recognized in the national legislation at the time, it was not necessary for the person preparing it to have a conservation license, since it is issued for the preparation of studies for the protection of cultural assets, for the preparation of conservation projects and for implementation of conservation measures on cultural assets, in accordance with the Law on the Protection of Cultural Assets.
A conservation license is not a condition for the preparation of the Assessment that the Government has adopted", claim the department, which is headed by Aleksandar Bogdanović.
Kapetanović: It is logical that such a study should be done by someone who has experience with cultural heritage
Experts who constantly warn against the destruction of Kotor, believe that there are many undefined things "that allow those for whom it is not a primary activity, such as the Faculty of Architecture, to deal with the highly specialized work of creating HIA".
"When it was drafted, the HIA was not legally defined in our country. Even with the latest amendments to the Law on the Protection of the Natural and Cultural-Historical Area of Kotor from this year, it is not clearly defined who can do HIA and whether they need conservation licenses for that. In any case, it would be logical for someone who has experience with cultural heritage to do it," architect-conservator Aleksandra Kapetanović from the NGO "Expeditio" from Kotor, a member of the Council for the Management of the Natural and Cultural-Historical Area of Kotor, told "Vijesti" .
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