The report on the strategic environmental impact assessment of the Spatial Plan until 2040 lists several negative comments and requests for amendments to the Spatial Plan or the removal of certain projects, but since it is an administrative act of the Environmental Protection Agency, which the Ministry of Spatial Planning has the right to appeal, it cannot be published while this procedure is ongoing, it was explained to "Vijesti" unofficially by this institution.
The report was adopted on June 23, and the appeal period lasts 15 days. The government adopted the draft Plan on June 12 without the Report. Two parliamentary committees gave their approval to the Plan without the Report, while the Parliament began and concluded the debate yesterday, although the deputies still do not have this Report. The vote should take place in the coming days, perhaps even before the deadline for appeals and the publication of the Report, meaning that the most important document of the state after the Constitution, as the Ministry of Spatial Planning calls it, can be adopted without those voting having the most important information about it.
The law says the public must know
The Agency does not give an opinion on the Spatial Plan, but on its Strategic Environmental Impact Assessment. That Strategic Assessment was prepared by another group of drafters on behalf of the company “Entasis”, which won the job earlier in the tender. The Strategy becomes a whole with the Spatial Plan, but in this case this did not happen and it is not public at the time of the Plan’s consideration in the Parliament, which is contrary to the Law on Strategic Impact Assessment, which states that the public, before making a decision, must have access to these documents. The report and the agency’s consent to the Strategic Assessment have not been published, but are waiting for the deadline for appeals to expire.
This Report, adopted three days ago, is its second version, as the first was published in January of this year on the then version of the Spatial Plan that was under public discussion. In the meantime, after the public discussion, there were changes to the Plan, such as the addition of the Velje Brdo residential area, changes to the routes of the Adriatic-Ionian Highway and the coastal expressway... which is why the new version also includes these changes.
According to information from "Vijesti", significant objections also relate to projects that are currently underway and that the Government is trying to push through, such as Velje Brdo, Velika Plaza, Buljarica, the "Komarnica" and "Gornje Kruševo" hydroelectric power plants, parts of highways and expressways, the development of new beaches, planning of education and health facilities, opening the Bojana River to traffic... Some of these objections were published in the January report, but not a single one of these corrections was published in the final version of the Spatial Plan that was sent to MPs.
It is better to throw away the hill.
The "Velje Brdo" project, a new residential settlement of 40 thousand inhabitants, is mentioned in one paragraph in the Spatial Plan, with the note that it will be specifically defined by lower-level plans - municipal simple urban plans.
"During the preparation of the PPCG-2040, the Government of Montenegro launched an initiative and made a decision to build a residential settlement in the Velje Brdo area, with the aim of providing a certain stock of apartments under affordable conditions and with control from the state level. At a more detailed/lower planning level, spatial capacity, infrastructure equipment and protection of the area will be defined, with the aim of implementing the project, which is defined as a project of public interest," the Plan states.
The report, according to information from "Vijesti", completely rejects the idea of building a residential settlement - a new city on this hill because it was proposed without appropriate baseline studies and analyses of the natural characteristics and amenities for construction, and because the need to build so many new apartments has not been proven when Podgorica already has a significant number of apartments that are not in use.
It is also pointed out that the availability of apartments for certain categories of the population should be regulated through tax policy, and not by building a new gigantic settlement. It was also stated that Velje brdo represents an extremely important green corridor essential for reducing air pollution and climate change and that as such it should be preserved, and that this area already partly belongs to the protected area of the Zeta River Nature Park, which represents an additional limiting factor for the development of this planning solution.
What is not for the airport?
The Report states that Montenegro, as a country in the EU integration process, is obliged to establish the international Natura 27 network of protected areas by the closing of the negotiation chapter 2000, which concerns environmental protection. These areas include Velika Plaža, Ada Bojana, Solana, Buljarica, Piva, Komarnica... many areas in or near which the construction of various tourism, energy, transport and other projects is planned.
The report completely rejects the idea of building an airport in Štoj, because it is located in a protected area, but also because the new version of the Ulcinj Plan connects it to the network of highways and expressways, so passengers will arrive at the airports in Podgorica and Tivat in a short time. It also points out that this airport would destroy large areas covered by habitats that deserve the highest level of protection and a great responsibility of the country that is in the process of joining the EU, which is trying to maintain and preserve such habitats.
Preserve Solana, Velika Plaža and Bojana
The area of the Salt Pans is stated to represent a specific ecosystem complex and that it needs to be preserved in its entirety, without infrastructural interventions, with the desirable launch of limited salt production and strictly controlled ecotourism and agriculture in the surrounding area.
Velika Plaza, where the government and an investor from the United Arab Emirates plan to build a new city worth 35 billion euros, is listed in the report as a center of biodiversity due to the richness of species, the diversity of habitats, the number of endangered species and habitats, and the number of species protected by national and international legislation. The part of Velika Plaza covered by dunes and ponds, according to the EU directive, must be prohibited from any construction, as well as the remaining 50 percent of this NATURA 2000 area. The preservation of natural vegetation is required, and where possible the construction of limited accommodation capacities.
For the Ada and the Bojana Delta, it is stated that no major infrastructure works are planned in the areas of energy, tourism, or transport, while preserving the coastal zone, wetlands, the Bojana River, and surrounding streams from pollution and excessive urbanization. The idea from the Spatial Plan to introduce navigation along the Bojana River and Lake Skadar is rejected, as this is an international RAMSAR area and nautical traffic is unacceptable.
Limited construction on Buljarica
In the Buljarica area, where the Plan also leaves the possibility of developing large tourist complexes, at least 170 important species that need to be protected have been registered, as stated. The sea lagoon and Mediterranean salt meadows should be completely exempted from construction, as well as at least another 50 percent of the most representative areas of this NATURA 2000 habitat, which would be determined through a more detailed survey of the area.
It is also necessary to fully protect the Tivat Salt Flats from construction and preserve their integrity in their existing form.
It is stated that part of Luštica has already been devastated by urbanization, and that a limited area should be exempted from urban development projects, along with the development of green corridors.
In the protected area of the Zeta River, it is stated that no industrial production development, even on a small scale, should be planned. They recommend the development of ecotourism, the construction of small rustic facilities, cycling, boating, bird watching, organic farming, with strict restrictions on urbanization.
Sinjajevina only for pasture
The spatial plan for Sinjajevina still foresees the possibility of military use, but also the development of tourism and agriculture. The report states that Sinjajevina has 16 types of NATURA 2000 habitats, and that it must be fully preserved as one of the largest pastures in Europe.
For the section of the expressway from Budva to Herceg Novi, it is indicated that the location of its crossing over the bay has still not been decided. They believe that it is unacceptable to adopt the Spatial Plan without clearly defined main traffic corridors, and that the option via Luštica and the bridge to Kumbor would pass near protected areas.
The section of the highway from Andrijevica to Serbia is said to have an impact on the habitats, water network, and migratory corridors of large mammals, so it is recommended that it follows existing roads as much as possible.
It is unclear how many and where schools, health centers and hospitals are missing.
In order to realistically set specific goals for the development of education, as stated in the Report, it is necessary to provide an accurate overview of the population of Montenegro, the number of children by municipality, and the number of primary and secondary schools and preschool institutions that are missing, but are necessary to achieve an adequate level of quality education.
It is also pointed out that there are no clear indicators of the current situation that could provide clearer guidelines for further development and achievement of goals, and that the same principle should be applied to health, social and child protection.
They believe that the draft Plan lacks clear data on how many institutions are missing in each municipality, as well as on the number of health centers and health facilities for hospital treatment.
Hydropower plants are necessary, alternatives should have been thought of earlier
The Report also provides guidance for planning the development of energy facilities outside protected areas, and that this particularly applies to the “Kruševo” and “Komarnica” hydroelectric power plants.
It is also pointed out that further development of the energy sector must be viewed through the fact of the expected cessation of operation of the Thermal Power Plant, as well as that the construction of a large number of uncontrollable power plants (solar and wind) imposes the need for additional controllable (stable) hydroelectric power plants.
They accept that after the shutdown of TPPs, hydroelectric power plants are necessary to maintain the stability of production that solar and wind power plants do not provide due to their dependence on weather conditions.
However, they point out that these two hydroelectric power plants conflict with protected areas, and that the lack of a clear vision for development is causing problems in the implementation of projects.
The “Kruševo” hydroelectric power plant would be located in a part of the “Dragišnica-Komarnica” Nature Park, which is contrary to the provisions of the Nature Protection Law.
Komarnica Canyon is one of 32 areas in Montenegro that are candidates for the EMERALD protected area.
They believe that alternative solutions for locations should have been considered through the Spatial Plan.
The report rejects the possibility of building the Boka hydroelectric power plant, which remains an idea to divert water from the Montenegrin part of Lake Bileća to a hydroelectric power plant near Risan. They state that this is unacceptable because it would lead to a large amount of fresh water in the bay.
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