The civic initiative "Zdravi Mojkovac", which previously requested the termination of the contract with the company "Brskovo Mine" from Podgorica, on the concession for detailed geological research and the exploitation of sulphide polymetallic ore in the exploration and exploitation area of the former mine "Brskovo" near Mojkovac, announced that in the document submitted by the Ministry of Capital Investments at the Government session on Thursday, in which the conclusion of the contract annex is proposed, contains "a series of illogicalities and unprecedented scams".
In the document, as they said, it is stated, among other things, that the documentation prepared by the working group was submitted to the Government on November 31, 2018, which is a non-existent date.
"On Thursday, at the 67th session of the Government of Montenegro, the Ministry of Capital Investments headed by Ervin Ibrahimović submitted a document entitled 'Information on activities in the area of concessions for the exploration and production of solid mineral resources (without discussion)', in which they propose the conclusion of the Annex 7 of the Agreement, which opens up the possibility for the state to be financially damaged and the concessionaire is given an additional deadline to obtain the necessary documentation. Also, in the Information submitted to the Government, it is emphasized that the priority requested by the concessionaire be fulfilled, and it refers to Drafting a proposal for a decision on determining the public interest in the expropriation of immovable property, and all this so that the concessionaire could begin the exploitation of mineral resources. Regardless of the opposition of the local community and the population and the countless comments from experts and laymen that we sent, we are now truly convinced that corruption threatens to reach its peak and that everyone those who work in the institutions for the benefit of the concessionaire must face justice. Namely, the Ministry of Capital Investments proposes all this to the technical government, whose decisions have no legitimacy," the announcement states.
They also point out that everything is proposed "through Information, not through a decision and without discussion".
"In the text of the above-mentioned document, which was published on the Government's website, there are a number of illogicalities and unprecedented hoaxes that point to general manipulation in order to satisfy the concessionaire's interests," added GI "Zdravi Mojkovac".
They stated, as they said, illogicalities in the document on the basis of which the Government "needs to decide 'something', based on the information compiled by the Working Group".
"Lack of details on spatial documentation: The preparation of the Detailed Spatial Plan of Brskovo is mentioned. The working group and the Ministry ignore the fact that the preparation of that plan is at a standstill, which the public has been familiar with for a long time, and they behave as if the situation is "regular". Because it is important : The detailed spatial plan cannot be completed in a situation when the manager of the preparation of that Plan (Sonja Radović Jelovac) requested its withdrawal due to inconsistency with higher order plans and the absence of mandatory documentation which the mining company did not submit.
"From the document that was submitted to the Government, it can be seen that the mining company did not respect the agreed deadlines for the submission of documentation before (p. 30-31). It did not submit a significant part of the documentation within the deadline for the implementation of Annex 4 of the Agreement (by November 21.11.2018, XNUMX). , they have already received an additional half a year, during which the missing documents, reports and the like were submitted," the announcement states.
As they said, how much hard work was done in the Ministry and the mining company "is best expressed by the following data":
"Date 31.11.2018/31.11.2018/31.11.2018: The document states: '...with the documentation submitted on XNUMX/XNUMX/XNUMX...'. Does anyone know how many days there are in November? So, in the official document that was submitted to the Government and which is prepared by the above-mentioned Working Group, the date XNUMX/XNUMX/XNUMX is indicated as the day when the company submitted certain documents, and only so that their contract would not be terminated. We question whether these documents were filed in the archive on the same date".
From GI "Zdravi Mojkovac" they also pointed out, as they say, the date in the Government document and the DPP Brskovo do not match. "How do the Ministry and the Government explain the fact that in the document submitted on Thursday, the Feasibility Study is from November 2018, while in DPP Brskovo they mention two Feasibility Studies, but from November 2020 and April 2022? Why is the plan not based on the mentioned Feasibility Study from 2018? Can we doubt that the aforementioned Study from 2018 was not even done or was invalid, but was only attached in any condition, in order to satisfy the form and obtain the Annex," they asked.
They also pointed to "non-specific references". The text mentions 'delay by state authorities' and 'issuance of documentation', but does not provide specific information about which authorities are late or what documentation is involved (except for the delay of the Environmental Protection Agency). This leaves room for incorrect interpretations, because the only mentioned delay can be a day or a week, which is not a justified reason for the concessionaire to be 'honored' with a new Annex to the Agreement," they add.
They also believe that details about the working group are missing: "The text mentions the formation of the Working Group, but does not provide information about the members of the group, their references and names, as well as their roles or mandate. Except for the information from which departments/institutions/institutions they were appointed."
There is also, as they stated, a lack of a clear explanation of the reasons for the delay in the permitting process. "The text mentions the delay in the issuance of urban-technical conditions, but does not provide a detailed explanation of the reasons for the delay, which raises questions about what is being covered up here. Who is late? From the information submitted to the Government, it is concluded that the concessionaire is the only one who is late because he annexes, the contract has already been extended six times, because they never fulfilled their obligations within the stipulated deadlines".
GI "Zdravi Mojkovac" also points to the "lack of clear information" about the rules and procedures, saying that the text does not provide enough information about the rules and procedures regarding the extension of deadlines, contract terminations and other relevant aspects that are important for the proposal related to contract extension.
They also said that there is a lack of information on sanctions, that is, that the text does not mention possible sanctions or consequences if the concessionaire does not fulfill its obligations within the set deadlines. "True, it is mentioned in the Agreement which therefore expired on July 25 of this year".
They also pointed out the inaccuracy regarding the roles of the institutions: "The text mentions various institutions such as the Ministry of Economy, the Ministry of Capital Investments, the Ministry of Ecology, Spatial Planning and Urbanism, but it is not clearly defined which institution is responsible for what. A clear division of roles and responsibilities should be a priority here, and this government and the ministries are playing ping-pong with the responsibilities all the time and smearing the eyes of the public."
They also believe that there are insufficient details about the project and economic parameters: "The text does not provide enough information about the mining project itself, mineral reserves, planned exploitation, economic justification of the project and other important economic parameters that are essential for assessing the feasibility of the project. But it contains information that it is valid to meet the concessionaire."
They also assess that there is insufficient information on the social acceptance of the project, saying that the text does not provide information on the social acceptance of the project by the local community or other interested parties, "and we have been talking and writing since April".
They also pointed to the change in the name of the company. "The text of the document refers to the 'Concessionaire DOO Brskovo Mine - Podgorica', which suggests that the company changed its name from 'DOO North Mining' to 'Brskovo Mine' without explanation or clear information about that process. In terms of the change in the ownership structure and especially to a question that worries the public, and the mining companies do not have an answer: how many mines do they manage at the moment? How many workers do they have in exploitation? What heavy machinery do they have? What property do they have in Montenegro", said GI "Zdravi Mojkovac".
They asked if this was a valid document.
"And what are we going to do now? Is this a valid document? Which counts the days forward and backward? Should the minister, who does not know how many days are in which month, decide about our lives? There are no valid reasons for concluding Annex 7, nor does the working group mention them except for trying to meet the concessionaire for reasons known to them, and every day more and more to the entire public. We say: Stop the Brskovo mine," the announcement concludes.
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