The civil sector strongly condemns the actions of the Government of Montenegro and the Environmental Protection Agency, as well as the manner of work of the parliamentary committees responsible for document adoption and spatial planning during the process of adopting the Spatial Plan of Montenegro (PPCG) as the most important strategic document in the country. Of particular concern is the fact that the revised Strategic Environmental Impact Assessment for the Spatial Plan of Montenegro, as well as the accompanying consent of the Environmental Protection Agency, are still not available to the public, nor were they an integral part of the documentation considered by the Government and the Parliament, according to a statement signed by the non-governmental organizations Center for the Protection and Study of Birds, KANA/ko akto ne arhitekt, Center for Investigative Journalism, Montenegrin Society of Ecologists, Dr Martin Schneider-Jacoby Assoc. - MSJA, Green Home and CEE Bankwatch Network.
"According to available information, the Agency issued the approval only the day before the session of the parliamentary committee, with the explanation that the document was 'high quality' and contained 'good recommendations' - although it was clear that these recommendations would not be included in the final version of the Plan. The Agency had the legal right to refuse approval if key recommendations were not taken into account, but it decided not to do so. According to the information we currently have, we can assume what happened - instead of protecting legality and public interest, the Agency suspended the procedure and thus enabled the Government to invoke Article 102 of the Law on Administrative Procedure and, under the pretext of 'public interest', obtain approval for a document whose recommendations were not fully incorporated into the PPCG. Thus, the Agency became an accomplice in the non-transparent and illegal adoption of the most important strategic document for spatial planning in the country," the joint statement of these NGOs states.
They called on the Agency to explain how the procedure went, why they issued the consent two days before the final decision of the Parliament of Montenegro, which "puts a seal" on it, i.e. closes the possibility of further changes to the plan, and to publicly deny their suspicions if they are not true.
"Of particular concern are the differences between the draft Spatial Plan that was the subject of public debate and the version adopted by the Government. Amendments were subsequently inserted into the final document that change the status of numerous areas — including those proposed for protection within the Natura 2000 network.
"The conversion of protected areas, such as Buljarica and Ćemovsko polje into construction zones, was done without any legal basis and without prior public involvement. The megalomaniacal Velje brdo project — an urban development project for 40.000 residents — was included in the Plan without discussion — contrary to current spatial policies. Also, serious contradictions were noted between the textual and graphical parts of the document: the same location is planned for urbanization in the text, while on the map it is marked as a protected natural area. Such inconsistencies lead to legal uncertainty, render the purpose of the public debate meaningless and violate the basic principles of the rule of law," the aforementioned NGOs said in a statement.
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It is emphasized that all this is happening with the tacit consent of the Agency, which has refused to use its legal mechanisms and clearly stand up for the protection of the territory of Montenegro.
"On June 12, the Government of Montenegro adopted the Spatial Plan, but the document was not available to the public for days after its adoption — which immediately raised reasonable doubts about the correctness of the procedure. Instead of publishing the complete document with accompanying annexes, only the textual part was submitted to the Legislative Committee, without the decision on adoption, which is its mandatory part. The Committee gave a positive opinion within ten minutes of the session, which speaks volumes about the seriousness with which the most important strategic document was treated. The process continued by referring the document to the Committee on Tourism, Agriculture, Ecology and Spatial Planning, where a series of contradictory information was presented yesterday. The Committee session itself, originally scheduled for June 26, was suddenly postponed to the 24th, so that the document would be on the Parliament's agenda on June 25th. If this scenario sounds familiar to you, this is the "speed" that the Prime Minister told us about — the speed that tramples on the laws of Montenegro and for which we will soon pay a high price," the aforementioned NGOs state.
They assess that transparency and public involvement in this process are practically non-existent.
"The Chairman of the Committee, Dejan Đurović, openly denied the need for civil sector participation, claiming that 'professional organizations have nothing more to say'. This attitude is an indicator of the systematic suppression of dialogue and the marginalization of professional and civic voices. The public did not have the opportunity to familiarize themselves with the final document, and institutional control mechanisms were turned into a mere formality.
Today, MPs are deciding on a document that does not contain key recommendations from the environmental impact assessment, that changes the status of protected areas without basis, and that creates legal uncertainty and deepens institutional chaos. The question is: how will spatial planning in Montenegro be carried out in the future, when one and the same document simultaneously proposes protected areas, urbanized zones and energy projects — without criteria, without argumentation, and without citizen participation?" ask the NGOs.
This practice must stop, the statement says.
"We demand that the Environmental Protection Agency take responsibility for its failure and publicly explain why it did not use its legal powers to prevent the adoption of a document that threatens the natural resources and chances for sustainable and fair future spatial planning of Montenegro in the long term," the statement concludes.
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