GI "Save Brezna": National MEGA study must not become the basis of Montenegro's energy policy

The national study Montenegro Energy Growth and Acceleration (MEGA), prepared by The Nature Conservancy (TNC) and the NGO Eko-tim, in partnership with the Ministry of Energy and Mining and the Investment Agency, with the active participation of the Montenegrin Electricity Transmission System (CGES), which was presented to the public in Podgorica yesterday, is a dangerous attempt to legitimize previously agreed energy projects as "low-conflict", scientifically based and in the public interest - even though they are not, the Civic Initiative "Save Brezna" announced.

This document, they remind, was announced at the end of 2024 as a "national study" for identifying locations with high development potential and low environmental and social conflict for the development of solar and wind power plants - Montenegro Energy Growth and Acceleration (MEGA). The MEGA document itself, they add from GI "Spasimo Brezna", does not contain "elementary data required by any serious 'study' - who the authors/co-authors are and their references, there are no names of the members of the Advisory Board or the names of the consultants, it is not known who the auditor is..."

During yesterday's presentation, as they said, at the insistence of journalists, it was announced that the lead author of the MEGA study is Zoran Miljanić.

"Miljanić is a former member of the board of directors of CGES and EPCG, and until recently was actively engaged in energy companies. The fact that CGES was the source of data and information used in the 'study' raises reasonable suspicions of a conflict of interest, and thus the questioning of the results of the study. Based on a detailed analysis of this document, available documentation and statements made at the public presentation, we believe that this study, in its current form, has serious methodological, factual and procedural shortcomings, and must not be used as a basis for creating energy policy, spatial planning or identifying the so-called Renewable Acceleration Areas RAA (locations for renewable energy sources) in Montenegro," the statement reads.

This document, they believe, is not a neutral analysis, much less a "credible and relevant study", but another attempt to normalize and present as "benign" private conflicting energy projects, led by the "high-risk project to build an international energy hub in Brezne".

"The European Bank for Reconstruction and Development - EBRD (European Bank for Reconstruction and Development) has activated the independent control mechanisms IPAM and OCCO regarding the approved credit support for this project, which, as we have documented, is based on falsified data and concealment of facts by CGES. The MEGA study, as we reasonably suspect, is only a tool for pushing and justifying the project of the international energy hub Brezna (400 kV), in the very center of the settlement, through the form of alleged 'smart planning', while real people, rights, law and security risks are completely ignored and erased," say the GI "Save Brezna".

They add that, despite "the fact that the location in Brezne is highly conflictive on multiple levels for the construction of an internationally significant energy facility," the authors of the MEGA document do not even state this in a footnote.

"According to the data from the MEGA document, which was derived based on data obtained from CGES, as much as 65% of new RES capacities are planned to be connected to the Brezna substation. In the Municipality of Plužine alone, at least 22 RES facilities are planned, additional projects are planned in Šavnik and Nikšić; the Komarnica hydroelectric power plant is still in circulation, which would also be connected to the Brezna 400kV substation. This would mean dozens of transmission lines above private houses, properties and tourist facilities, and would certainly mean new additional expansions of the substation, additional 400 kV transmission lines, violation of the N-1 and N-2 energy security criteria," writes GI "Save Brezna".

They claim that building such an energy hub at that location would mean creating an "extremely risky energy point for the region, the EU and NATO energy corridors."

"This would not just be a silent genocide in Brezne, but a real systemic threat to the energy stability and security of Montenegro, the region and the EU."

They remind that the residents of the village of Brezna, gathered in the GI "Save Brezna", have been "fighting to prevent the construction of an international energy hub in the center of the village" since April last year, when they learned about this plan.

During that process, they recalled, they announced that they "discovered that CGES falsified the project documentation" by claiming that there were no residential or commercial buildings within a two-kilometer radius, even though "there are more than 150 of them," and pointed to "numerous essential shortcomings, violations of procedures and standards, EU practices, laws and international conventions."

"All internationally relevant mechanisms and bodies have been informed and if this insane project in Brezne continues to persist, when certain consequences occur, no one can say they did not know, thereby assuming serious responsibility. It is also clear to the layman that the scenario that the alleged national MEGA study presents as a 'done deal' and tries to normalize means: planned forced displacement of the entire Brezne area, complete destruction of all economic activity, rural tourism and agriculture, total devaluation of the private property of locals and a systemic security risk for the energy system of Montenegro, the region and the EU. We emphasize that we are not against development, not even energy development, but we do not agree to the alleged development that: violates laws, ignores citizens, destroys the economy, tourism and agriculture, and turns living villages into energy scorched zones, for the sake of the interests of privileged companies and individuals," they add.

GI "Save Brezna" will, they say, use all domestic and international legal means guaranteed by law, contact relevant domestic and international institutions and supervisory bodies, including donors to The Nature Conservancy and Eko-tim, as well as inform the public through the media, and demand "establishing responsibility" for those who participated in the development, financing and promotion of this document, if its application in decision-making of public importance is carried out without adequate transparency, expert review and legal basis.