The Action for Social Justice (ASP) submitted comments to the Ministry of Energy and Mining on the National Energy and Climate Plan, in which it, among other things, proposed defining the year of cessation of operation of the Pljevlja Thermal Power Plant (TPP).
"ASP proposed defining the year of cessation of operation of the Pljevlja thermal power plant and the period of placing the plant in cold reserve, while implementing a just transition for the city, and due to the certainty of future energy processes in the country," the statement said.
ASP pointed out that it is unacceptable that this strategic document does not precisely project the year of the cessation of operation of the Pljevlja thermal power plant, but instead mentions different years of 2035, 2037 or 2041 in different places.
"In order to avoid potential uncertainties, and bearing in mind that the TPP currently represents a significant source of energy production in the country on the one hand, while on the other it operates without a permit, and at the same time Montenegro must fulfill its international obligations for the operation of this type of plant, it is necessary to project the reduction in the number of operating hours of the TPP by year, as well as the year of its cessation of operation, including the period when it can be a cold reserve plant," the comments explained.
It is also necessary, according to ASP, to foresee the period of implementation of a just transition for Pljevlja and the method of implementation and cost estimation, because the issue of transition is of essential importance for the city's population, which is associated with around three thousand direct and indirect existing jobs.
ASP also pointed out that the strategic document projects a huge number of future facilities for the production of electricity from renewable energy sources, with an estimated investment of 2,5 billion over ten years.
Even if it is assumed that the projection is realistic, the section on the impact on the annual budget does not present a projection of that impact, but rather states in a blanket manner that it depends on the prices achieved and purchase contracts after the auctions, so it is proposed to include a projection of the financial impact.
"It is also necessary to specify the annual impact on the state budget through the costs of companies in majority state ownership, such as Elektroprivreda (EPCG), Montenegrin Electricity Transmission System (CGES), and the Eco-Fund," the comments add.
It is also stated that the impact of future projects on the development of the transmission and distribution network, whose investments consumers pay for through electricity bills, must be determined.
ASP assessed that it is necessary to consider the exclusion of environmentally and economically unviable projects for the development of large hydroelectric power plants, such as the Komarnica hydroelectric power plant project, whose planned construction, as they claim, not only seriously violates the provisions of the Bern Convention and the EU Directive on Nature Protection, but is also energetically and economically unviable, with costs of over 300 million euros for a project that would provide less than two percent of national electricity production.
ASP also states that it is necessary to consider excluding the development of the use of new fossil fuels, including the development of gas-fired combined heat and power plants, gas transport infrastructure, new storage facilities, including reliance on the 2017 Gasification Master Plan, as an outdated and unfeasible document.
"It is worth emphasizing that gas-fired power plants are not meeting energy efficiency measures, but are instead suffering from a long-term dependence on imported gas, which we currently do not have, and additional credit indebtedness and "stranded" investments," ASP added.
They believe that it is necessary to supplement and revise building measures in the area of energy efficiency, especially by introducing a mandatory annual target for renovating at least three percent of the surface area of public buildings and by including specific measures to reduce energy consumption in the heating sector through the replacement of fossil fuels with sustainable sources and efficient technologies.
Among other things, the ASP also indicates that it is necessary to revise the ambitious projected reduction in emissions from the transport sector by 2030 and 2050, while the National Energy and Climate Plan needs to be supplemented with targets and real measures to reduce energy poverty.
"The public debate on this strategic document for energy and climate, which was not marked by great transparency, ended on Friday," concluded the ASP.
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