Businessman's company "Carine" Ceda Popovic began works to fill and concretize the beach beneath their future hotel in Baošići, without obtaining conservation conditions and consent from the Administration for the Protection of Cultural Heritage - which is why that institution ordered an immediate halt to the works. The Administration states that the project is being carried out in the UNESCO protected area of the Kotor area and in violation of prescribed procedures.
Popović told "Vijesti" that they had not received a decision on the ban, that they had all the necessary documentation, including a building permit issued by the Secretariat for Urban Planning and Construction Inspection of the Municipality of Herceg Novi and the consent of the Coastal Zone Authority. He emphasized that the beach was already located at that location and that it was a matter of arranging a bathing area, and that according to their information, the area was not under the protection of cultural heritage.
A private owner in Herceg Novi is building a higher category resort across from the local sports field in Baošići, and they have also leased a beach below the hotel with an area of about 1.500 square meters. After its development and filling, its area will be 12.500 square meters.
"The company "Carine" is ordered to suspend the execution of works until the legal and professional basis for their implementation is obtained. It is necessary to obtain conservation conditions, develop a conservation project and register the works, all in accordance with the Law on the Protection of Cultural Property and regulations on the construction of buildings. Construction works were found on the site in the form of embankment filling, reinforcement, concreting, as well as construction materials for future works, which are not in accordance with the aforementioned decision on conservation conditions. Considering the above, it is proposed to suspend construction works and refer the party to the legal procedure for developing and submitting a request for approval for a conservation project that must be in line with the issued decision on conservation conditions," reads the decision, which "Vijesti" had access to, noting that this decision can be made without the party's statement in case of urgency to protect the public interest.
The administration issued a decision to suspend the works on February 11, and “Carine” has the right to appeal to the Ministry of Culture and Media within 15 days. The appeal will not affect the postponement of this decision.
The administration did not give consent.
The administration stated in its decision that this area is part of the protected environment of the Natural and Cultural-Historical Area of Kotor, which is listed on the UNESCO World Heritage List, and that in August 2023 they issued a decision on conservation conditions for the purposes of developing urban and technical conditions for the beach. “Carine” appealed this decision to the Ministry of Culture and Media, which in January 2024 rejected the appeal as unfounded.
On February 10th of this year, the Administration's experts went out into the field and checked the works on this beach and determined that they had not received a request for approval for the conservation project, because according to the Law on the Protection of Cultural Property and Construction of Facilities, approval is a condition for obtaining a building permit.
Video: Siniša Luković
The Administration explained to "Vijesti" that the decision on the conservation conditions was also submitted to the Ministry of Spatial Planning in March last year, due to the Coastal Zone Authority's decision to announce a tender for this beach. They point out that the conservation conditions stipulate that the value and characteristics of the coast with piers, mandrači and bathing areas must be preserved, without changing its line, but that they were never submitted with the project documentation for approval.
The Administration also referred to the hotel being built above the beach itself and stated that since 2019, they have not responded to the request for the issuance of conservation conditions for the needs of urban planning and technical conditions, so in 2023, the Chief State Architect approached them and asked for an opinion in the phase of revising the conceptual design, because this project required a Visual Impact Study.
"The Administration has adopted an act that prescribes the obligation to prepare an HIA study (heritage impact assessment). At the request of the investor, a commission was formed to prepare an HIA study. The expert development team submitted to the investor a set of measures that need to be implemented in order to adjust the conceptual design, so that the end result would be a design of a facility that would not negatively affect the values of the area. The measures were not taken into account, so the HIA study, which was adopted by the Administration, assessed that the implementation of the design solution would have a negative impact on the universal value of the area. The HIA study was submitted to the chief state architect and the investor, in which context the former stated that it was not relevant for granting approval for the conceptual design. After this, the project receives a construction application from the Ministry, without considering the Administration, that is, without preparing project documentation that would be submitted to this body for approval, and its construction begins," they pointed out.
They also claim that the inspection determined that the hotel had been upgraded with two more floors compared to the construction application, which was subsequently included in the Spatial and Urban Plan (PUP) for Herceg Novi. They state that they also gave a negative opinion on this, but that it was not taken into account, while during the construction, the potential cultural asset Smekja-Rašković Palace was demolished, where the cultural asset Memorial Plaque commemorating the stay of the French writer Pierre Loti is located., what they wrote to the inspectorate about.
"The administration did not give consent for the implementation of the aforementioned projects at any stage, but rather sought to ensure the implementation of enhanced control mechanisms, in accordance with Montenegro's national and international obligations. The administration acts in accordance with and according to the letter of the law, but the question arises whether other state and local self-government bodies do the same," they said.
They won the tender, they have the permit.
The owner and CEO of the company "Carine" Popović said that the project is worth a total of around 80 million euros, but that they have not yet received the decision to ban construction on the beach and that they received the paperwork for the project from the Secretariat of the Municipality of Herceg Novi. He emphasized that everything was taken care of in order to obtain the building permit, and that he was not familiar with the role of the Administration in the entire process.
Video: Siniša Luković
"This is an investment beach, not just one, there were several that went to the Government. There was a tender, we won it, we did a conceptual design and got approval from the Coastal State, did the main design, got approval and submitted it to the Secretariat, which issued the building permit. There are no cultural assets at this location and it is not under protection, otherwise it would not even be included in the investment beach plan. The beach already existed, so nothing new is happening here," he said, emphasizing that the beach will be put in order in this way.
Popović emphasized that they are taking care of the protection of the existing condition and appearance of the coast and are using natural stone for filling. He claims that everything has been preserved and that they have also received approval for the dilapidated mandrać, and that the local community has also requested that it be fixed, because it is about to be demolished. He emphasized that they have a building permit to work and that they have received urban planning and technical conditions....
When asked whether "Carine" had conducted an HIA study for the hotel project, Popović stressed that they received the urban-technical conditions in 2019, while they registered the construction in 2024 - and that they did everything according to the documentation. He pointed out that the study is not mentioned anywhere, so they did not prepare one. Regarding the two floors that were allegedly built on this hotel without a construction registration, Popović stressed that their project fully fits into the valid PUP of Herceg Novi.
The Environmental Protection Agency decided in mid-January this year that "Carine" for beach development does not have to prepare an Environmental Impact Assessment for this project.
The documentation that "Carine" submitted to the Agency states that they plan to install 428 sets of deck chairs, that the surface area of the beach is 1.460 square meters, while after the renovation it will be 12.476 square meters, of which 10,84 thousand is the beach, 337,5 sports fields, 64,3 changing rooms and toilets, 128,4 beach bar and two piers 1,1 thousand square meters.
They signed a lease agreement with Morski dobro at the end of November 2025, and it was concluded for a maximum of 30 years, while they received their green light for the conceptual design in December 2025.
Management not to threaten
Democratic Party MP Zdenka Popović made a public appeal to the Administration for the Protection of Cultural Heritage not to visit buildings with a building permit in the final phase of construction and not to threaten them with stopping the project.
She said this three days ago during a parliamentary debate on amendments to the Law on the Protection of the Natural and Cultural-Historical Area of Kotor.
PES MP Vasilije Čarapić said that previously illegal construction in the Kotor area could not be legalized, and that the new Law on Legalization made this possible, but with the permission of the Administration.
Popović pointed out that they were approached by investors in the protected zone, whose projects are in the final stages.
"It so happened that the Administration's inspection started this morning and is already writing a decision to stop construction. I don't understand what it's about. Let's see how we can solve the problems, I'm not talking about legalization, I'm talking about buildings and owners who have permits with buildings in the final phase. I ask the Administration's inspection not to visit buildings that are in the final phase of construction and that have a building permit and not to threaten the owners that they will bring them a decision to stop construction," said Popović.
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