The project to build the Komarnica hydroelectric power plant (HPP) is unprofitable for Montenegro, claim numerous experts from the country and abroad. The country would lose a canyon of immeasurable value, and the plant would produce only a few percent of the energy the country needs.
There are many other more efficient solutions that would replace the energy that Montenegro will lose with the inevitable shutdown of the Pljevlja Thermal Power Plant.
EPCG says about Center for Investigative Journalism of Montenegro (CIN-CG) on the contrary, that the Komarnica HPP is the most mature energy project, and that their partner for this project could be one of the leading global players in the energy sector, the French EDF Power Solutions (EDF).
The Montenegrin energy company recalls that in September 2024, they signed a Memorandum of Understanding with representatives of the French energy company EDF. This created the conditions for more intensive cooperation, EPCG says.
They also state that the project to build the dam on the Komarnica River will also be contributed to by the signing of an intergovernmental agreement between Montenegro and France, which is expected soon, and which will, among other things, include the field of energy.
EPCG states that the EDF expert team conducted an analysis of the Kruševo and Komarnica HPP projects.
"EDF Power Solutions, as a responsible company, places environmental protection and social aspects at the center of its projects and partnerships," the French company told CIN-CG, adding that their focus is exclusively on the Kruševo HPP project.
"Both parties are considering potential forms of cooperation in the field of hydropower. We are currently exclusively focused on the Kruševo project, as well as in the field of other renewable energy sources and storage solutions, to ensure sustainable and flexible electricity supply with low CO2 emissions," EDF told CIN-CG.
They emphasized that their company is globally recognized for its commitment to high international standards, "showing that energy and sustainability can go hand in hand."
The government pulled the project out of the closet.
The idea of sinking the Komarnica Canyon for the sake of a hydroelectric power plant is over half a century old. Due to numerous doubts, primarily regarding the sustainability of energy, economy and ecology, that accompanied this project, as well as pressure from experts and the civil sector, the project was suppressed until December last year. Then the Government Milojko Spajić brings it back to light and puts it at the top of the list of Priority Infrastructure Projects in Energy in Montenegro, planned for financing by the European Union.
A few months after this project was put on the priority list, the European Parliament spoke out. The government received a warning that the protection of Komarnica, as well as the Saltworks and dunes in Ulcinj, would be crucial for the closure of Chapter 27.
It seems that no one in the government heard this. The recently adopted Spatial Plan of Montenegro (PPCG) plans the construction of the Komarnica hydroelectric power plant, despite the fact that the same plan also plans the area for protection.
"We consider the recently adopted Spatial Plan illegal because public comments were not adequately taken into account and the plan was significantly changed after public review," he told CIN-CG. Pippa Gallop, an energy expert within the Bankwatch network, who points out that it is inappropriate for the Komarnica HPP to be located in the Montenegro-Montenegro region.
Before the plan was adopted, in April of this year, an expert commission composed of 19 domestic and international experts assessed that one of the key documents necessary for the decision on the construction of the Komarnica HPP - the Environmental Impact Assessment Study - was unacceptable! The commission assessed that the Study was poorly done, and that EPCG, as the customer of this document, did not meet numerous requirements regarding research related to biodiversity and the environment, the Montenegrin Society of Ecologists (CDE), which has been closely monitoring this process, told CIN-CG.
Several Montenegrin and foreign experts have appealed in recent years for a feasibility analysis of the projects, and in particular for all key facts to be updated, because the project, which was initiated several decades ago, is based on outdated data, and is completely at odds with modern environmental standards.
CDE is concerned that the Spatial Plan states that the Komarnica HPP could produce 670 GWh of electricity annually - which represents 40 percent of the average annual production of the Pljevlja TPP.
"This is completely new and previously unknown information, and experts assess it as inaccurate and technically unattainable. The official EPCG project documentation for the Komarnica HPP states that it would produce only 213 GWh per year, which is only a seventh of the energy provided by the Pljevlja TPP," the organization states.
"The Komarnica HPP construction project would be very expensive, extremely demanding and complex in construction, and long-lasting, providing a minimum annual production amount, which would be slightly above one percent of total production in Montenegro, taking into account the amount of production planned to be installed in the period until 2030," states the Komarnica Canyon case study, which was conducted by a team of experts from various fields under the auspices of the CDE.
"The 172 MW Komarnica HPP project would consist of a concrete dam 171 meters high and a huge reservoir 17,6 kilometers long. It would produce only 213 GWh of electricity per year, which is quite small for such a large construction project," warns Galop, adding: "For comparison, the Piva HPP has twice the capacity - 342 MW, but four times the production - an average of 860 GWh. It has never been convincingly proven to the public that the Komarnica HPP project is economically viable," claims this well-known European expert.
The Komarnica HPP would flood part of the area nominated for the Emerald Area - the Komarnica River and the Dragišnica and Komarnica Regional Park. The project would also affect three potential Natura 2000 areas: the Bukovica Valley, the Vojnik Mountain, the Komarnica and Pridvorica areas. Furthermore, the Komarnica River has also been identified as a potential area for the expansion of the Durmitor National Park and a UNESCO site, but so far it has only been granted the status of “Regional Park”.
An expert in this field, who insisted on anonymity, told CIN-CG that he doubts that, if there is even a little common sense, the Komarnica HPP project will be implemented:
"Montenegro has a small territory and it is unnecessary to submerge part of the land for a hydroelectric power plant that would bring little energy, and is also very expensive. The missing energy can be replaced from solar and wind power plants using batteries for energy storage and other alternatives that are current in Europe."
EPCG deaf to the arguments of the profession
"Hydropower plants enable stable energy production from renewable sources, with minimal CO2 emissions, thus directly contributing to climate goals and the sustainability of the energy system. Their construction also involves the formation of significant water reserves which, in addition to their energy function, also play a role in flood protection and improving the irrigation system," EPCG claims.
They emphasize that this project stands out for its strategic and energy potential. They also state that in earlier planning documentation this project was clearly defined as an integral part of the long-term development of Montenegro's electricity capacities.
"In light of climate change and unclear hydrological predictions for the future, large hydropower projects have been abandoned around the world in the last 10 years and are becoming fewer and fewer... Very often they have reduced or almost no production during periods of extreme weather conditions or insufficient filling of watercourses," states the Case Study: Komarnica Canyon.
Reliance on hydrological conditions should not be the basis for a long-term energy strategy, the study argues. It cites an example from 2022, when, due to unfavorable hydrological conditions and external price shocks, the Montenegrin power system and EPCG were significantly exposed and dependent on electricity imports.
"The premise that the Komarnica HPP is necessary for energy stability and to replace the shutdown of the Pljevlja TPP is completely untrue. The Pljevlja TPP produces an average of around 1.400 to 1.500 GWh of electricity annually, which is seven times more than the projected production of the Komarnica HPP under ideal hydrological conditions," he tells CIN-CG. Milan Niković, electrical engineer.
Niković believes that a serious Feasibility Study should be financed for such a project, but not according to domestic, but rather international banking standards, which would provide answers to all possible details and aspects of entering into such an investment.
"This study should also show multi-year projections of parameters that measure the profitability of implementing large hydroelectric power plant construction projects: projections of electricity price movements on the stock exchange, market volatility, estimates of total energy yields, hydrological conditions, etc.," explains Niković.
EPCG, however, claims that all key preparations for this project and assessments have already been made.
In Montenegro, there are practically no experienced personnel for the design and construction of such complex projects, says Niković.
"It would be necessary to entrust the complete design and works to foreign companies. It is questionable whether workers and construction operatives would be found in Montenegro to survey such a project," Niković points out.
EPCG's plans are still being hidden from citizens, but we have recently learned that the Government has definitely decided that a hydroelectric power plant should be built, even though we can get more energy from other sources for less money, while preserving nature, he claims. Vuk Iković, biologist.
"Every government has certain projects and programs. The Komarnica HPP project is a project of the previous government, and despite the fact that experts knew at the time that it was an economically and energetically unprofitable project, the new government continued to promote it and spend citizens' money on the realization of this disastrous, long-overdue project," says Iković.
The European Union does not support the project.
According to CDE's findings, the European Commission made it clear several years ago that the Komarnica and Kruševo HPPs would not be financed from the EC's Western Balkans Economic and Investment Plan (WBIF), despite the fact that they are on the list of projects that Montenegro plans to apply for this funding.
"These projects were not selected because they are not aligned with the Green Agenda for the Western Balkans. Instead, the Commission recommends that projects for the reconstruction and improvement of existing hydropower plants in Montenegro be supported, which is also in line with the WBIF analysis," the CDE biologist's letter states. Jelena Popovic.
As a candidate country for EU membership, Montenegro has an obligation under the Bern Convention to protect candidate Emerald sites and to conduct a so-called "appropriate assessment" for any project that may have a significant impact on Emerald or Natura 2000 sites, explains Bankwatch associate Pipa Galop.
If it is determined that the impact will be significant, the project cannot be implemented unless a special assessment shows that it is a project of “overriding public interest”.
According to the EU Water Framework Directive, projects that would deteriorate the status of a river are not permitted unless an exemption is granted under Article 4(7) of the directive. This also requires a detailed assessment, which in the case of Komarnica was also not carried out.
"The Komarnica Canyon is wild, inaccessible, and not easy to explore. However, in order to assess the impact on the environment, all of this must be known," he explains to CIN-CG. Andrijana Mićanović from CDE
During the preparation of the Study, biodiversity was described very briefly, and scientists entered only four locations due to the inaccessibility of the canyon. Mićanović explains that the current project for the HPP is based on data from the 70s, and that in the world of climate change, data cannot be older than five years.
The area where the HPP is planned is home to a number of protected species, including wolves, bears, Balkan chamois, otters, stone crabs, golden eagles, rock partridges and harvestmen. However, the full extent of the likely damage to these and other species from the project is not yet known as only partial field research has been conducted.
"The sooner the Government gives up on this project, the better it will be for Montenegro, and if it does not give up - we will defend both Komarnica and our Elektroprivreda, because it is a company of the citizens of Montenegro," says Iković.
Numerous alternatives
In today's energy practice, faster and more efficient solutions are primarily used, which are significantly more cost-effective and faster to build than large hydropower plants, which, as less cost-effective projects in today's energy transition, have been almost completely abandoned in the world in the last ten years, says electrical engineer Milan Niković.
He believes that solutions that would permanently ensure energy stability and independence of the energy system in Montenegro are the massive construction of larger wind and solar power plants, the installation of larger battery facilities for energy storage and balancing the energy system, the mandatory construction of at least one hybrid power plant, and the possible future substitution of thermal power plants with small nuclear underground reactor technology.
"We should certainly consider more significant investments in energy efficiency, the creation of virtual power plants, the production of green hydrogen as a fuel for a future gas power plant, as one of the possible solutions. The state and the government must take precise positions on all of this and create precise operational plans for the energy transition," says Niković.
As an alternative solution, Niković proposes the construction of a possible gas-fired power plant instead of the existing thermal power plant.
It is also possible to build a larger hydroelectric power plant, which would not have a major impact on the environment, nor would it cause major damage to the landscape or relief. According to Niković, a good solution would be the Boka hydroelectric power plant with an underground production hall, which would primarily serve as a battery for balancing a larger number of existing and future solar and wind power plants.
Another expert consulted by CIN-CG, despite serious criticism of the EPCG management for emphasizing outdated projects, as well as irrational business policy, especially regarding excessive employment, spending, and borrowing, emphasizes that he nevertheless welcomes the fact that EPCG announced the implementation of the project to connect Krupačko and Slano Lakes, which could significantly increase the capacity of the Perućica HPP. Work should also be done to strengthen existing capacities, he says, because there are great opportunities for improving the energy situation in the country.
Despite numerous alternative solutions and possibilities provided by existing plants, the Government and EPCG, despite all the controversies, are not giving up on Komarnica.
EPCG emphasizes that the final decision on the next steps in the implementation of the Komarnica HPP will be known during this year.
The Government and the Agency ignored two negative expert opinions on the Study
The Environmental Impact Assessment Study for the Komarnica HPP was published in February 2022. At that time, an expert commission of 19 experts was formed, which assessed the study as unacceptable and returned it to EPCG for further development.
The first time it was assessed as unacceptable due to the methodology and description of biological characteristics, explains Andrijana Mićanović from CDE, who had insight into the entire process of assessing this document.
"EPCG had two and a half years to conduct additional research and amend the Elaborate. This was done in a very unprofessional manner; EPCG only made minor changes, without any new research," says Mićanović.
Therefore, at the beginning of 2025, the Commission gave a negative opinion on the Study for the second time, after which EPCG requested a one-year extension of the deadline.
According to Mićanović, this was a great opportunity for the Environmental Protection Agency (Agency), which has the final say on this document, to say that the Elaboration does not justify the construction of the Komarnica HPP, which would have made its removal from the strategic documents much easier. However, this did not happen, and the Komarnica HPP was included in the recently adopted PPCG.
"The agency was required by law to state its position on the Commission's position - the most logical thing would have been for it to have given a negative opinion itself, in accordance with the Commission's decision. However, director Milan Gazdić did not state his position at all and on his own initiative gave EPCG a new deadline of 30 days. EPCG simply decided to withdraw from the procedure - which means that the procedure can be restarted whenever they want," explains Mićanović.
This means that a unique opportunity was lost, preventing the project from passing one of the most important steps on the path to implementation.
The Agency, on the other hand, claims to CIN-CG that they did everything according to the law:
"It cannot be said that the Agency extended the aforementioned deadline on its own initiative, but rather acted in accordance with its competencies and obligations as provided for by the Law. In connection with the aforementioned extension of the deadline, we inform you that the project owner requested an extension of the deadline for an additional 365 days, and that the Agency, after considering the request in question, decided to extend the deadline in question by 30 days, appreciating finding the best possible solution when it comes to the implementation of the projects and their impact on the environment."
“We have had access to all the documentation for and against Komarnica from the beginning of the process: biodiversity, energy and economic research,” explains Mićanović.
"Biodiversity is very poorly researched in the Elaborate. That's why we organized three scientific expeditions, the fourth is currently underway. We have attracted scientists from all over Western Europe who are helping us research the biodiversity of this area," explains Mićanović.
Despite numerous procedural problems and violations, EPCG says that "the continuation of this procedure, as well as a decision on the next steps, is expected during the current year."
In order to fully comply with the highest environmental protection standards, EPCG plans to, in addition to supplementing the existing Study, also prepare an Impact Study on the UNESCO site of the Durmitor National Park, in accordance with UNESCO methodology. It is also planned to prepare an appropriate environmental study in the form of an ESIA (Environmental Social Impact Assessment), according to the rules of international financial institutions.
"If the impact assessment conducted by the Environmental Protection Agency lasted three years, the question arises how long this procedure with UNESCO will take? Especially considering that the process conducted by the Agency was delayed due to the lax work of the management of Elektroprivreda," Vuk Iković asked in an interview with CIN-CG.
Contract with Elektroprivreda Srbije
EPCG claims that the Komarnica HPP construction project should be implemented in accordance with the Agreement on Long-Term Business and Technical Cooperation between EPCG and Electric Power Industry of Serbia (EPS), which provides for joint financing and preparation of technical documentation. Otherwise, they claim, if they find other partners for this project, they would have to pay penalties to EPS.
The contract referred to by EPCG was signed back in 1991 between the electric power companies of Montenegro and Serbia, and its operational implementation was concretized through the Agreement on Joint Financing of the Implementation of Previous Works on the Komarnica HPP, which has since been annexed four times.
"The contract clearly specifies that, if EPCG decides to enter the construction of the Komarnica HPP independently or with another partner, it is obliged to refund EPS their proportional stake - the valorized value of 49 percent - within 12 months of making the decision on such a construction model," EPCG states.
An expert who is well-versed in this contract claims that this only applies to the investments made so far in preparing the project and that it is not a large sum, and that the damages from the construction of the Komarnica HPP would be much greater than any possible penalty payments to Serbia for participating in the preparation of the documentation for this project so far. And if the construction of the Komarnica HPP does not proceed, then there are no penalties.
See more:
Download the app and follow the news
FOLLOW US ON
