The Government of Montenegro has adopted a concession act for the "Skrbuša" deposit near Kolašin, paving the way for a public announcement for the award of a concession for geological research and exploitation of architectural-construction and technical-construction stone in an area with estimated reserves of around two million cubic meters.
The plan, prepared by the Ministry of Energy and Mining, envisages exploitation for up to 30 years, despite the opposition of the Municipality of Kolašin, which warned of possible consequences for water resources, tourism and local infrastructure, as well as the objections of the Directorate for Forests and Hunting Management that the site is located in a protective forest and should be excluded from the concession plan.
"It should be particularly noted that the local population is already expressing opposition to the road widening and the construction of the quarry, which further indicates a serious conflict between the planned project and the interests of the community," emphasized the Mayor of Kolašin. Petko Bakić in the report from the public hearing, which is an integral part of the Government's documentation.
The Office of the Protector of Property and Legal Interests of Montenegro pointed out during the public hearing that the plots in question are located in the UNESCO Biosphere Reserve “Tara River Basin” and suggested that the Ministry of Energy and Mining consider addressing UNESCO, which the Ministry accepted. The documentation does not state what UNESCO responded.
"The Environmental Protection Agency stated that all of the aforementioned cadastral plots are located outside the boundaries of existing protected nature areas, but in relation to the identified ecologically significant areas, all of the aforementioned cadastral plots are located in the Tara River Basin World Biosphere Reserve (UNESCO, M&B). In this regard, we believe that it would be necessary for you to assess whether it is appropriate to contact the UNESCO office in this regard," the Protector stated.
The concession act was prepared based on the annual Concession Granting Plan for Detailed Geological Exploration and Exploitation of Mineral Raw Materials for 2026, which was adopted by the Government in February this year.
Reserves estimated at two million cubic meters
The documentation states that the wider area also includes the Bar - Boljare highway route (the Mateševo - Andrijevica section is planned), which further increases the importance of the site in the context of future exploitation of mineral resources.
"The continued development of the construction sector in the northern and central parts of Montenegro, as well as the modernization of the existing and the construction of new transport infrastructure, especially the planned section of the Bar - Boljare (Mateševo - Andrijevica) highway, have led to an increased demand for stone aggregates. Given that the site in question is located relatively close to the planned highway route, its importance is further increased from the aspect of providing quality mineral raw materials for the construction of this strategic road," the documentation states.
Based on the assessment of the site, taking into account the area and morphological characteristics of the terrain, the potential geological reserves of architectural and construction stone and technical construction stone are estimated at two million cubic meters of solid rock mass. The planned annual exploitation capacity is 20.000 cubic meters, which, as they state, would yield 2.000 cubic meters of commercial blocks and tombolos of architectural and construction stone and 30.000 cubic meters of finished stone aggregate of various fractions.
"Taking into account the estimated reserves and planned annual capacity, it is possible to foresee a concession duration of up to 30 years, which is in accordance with the applicable legal framework. More reliable data on geological characteristics, raw material quality and other key parameters for further exploitation can be obtained exclusively by conducting detailed geological surveys at the site itself, in accordance with applicable technical and legal requirements. Special attention must be paid to environmental protection, given that the planned type of exploration and exploitation requires the use of modern technical means and mechanization, the adverse impact of which on the environment is relatively small," the documentation states.
It was pointed out that a detailed geological survey has not been conducted at this location to determine the quantity and quality of the mineral raw material, nor has its specific application in the construction industry been analyzed.
"However, based on an analogy with deposits of similar geological structure, where such research has already been conducted, and in which comparable types of limestone are involved, it can be assumed with a high degree of reliability that this is a technically high-quality stone, suitable for use in construction. Given the established reserves, terrain configuration, possible development of the mine and other advantages, the annual capacity can be increased compared to the initial minimum annual capacity. This represents a significant advantage for bidders," the documentation states.
Bakić: Unacceptable without hydrological studies
The Municipality of Kolašin had the most objections, and Bakić stated that he was filing the objection due to serious concerns about the long-term consequences that the implementation of the project could have on the environment, water resources, local infrastructure and development potential of this area.
"I believe that the Concession Act does not take into account in a sufficiently serious and professional manner the specifics of the area where stone exploitation is planned, especially considering the fact that project documentation is being prepared in the immediate vicinity for a future water source with a capacity of approximately 20 to 30 liters per second. This is precisely why it is necessary to carefully assess all possible impacts of mining activities on groundwater and surface water," Bakić assessed.
The concession act, according to him, confirms that the area in question belongs to the Tara River basin and is characterized by a developed hydrological network, with the watercourses Skrbuša, Mujički potok and Izlazačka River.
"It is also stated that the terrain has pronounced fissure-cavernous porosity, which allows for the infiltration of surface water and its movement through underground streams towards the Tara River. These characteristics indicate that this is a hydrologically very sensitive area in which mining, stone exploitation, the operation of crushing plants and the use of heavy machinery could have lasting consequences for the quality and stability of water resources. Of particular concern is the fact that the act itself states that detailed geological research has not been conducted on the site in question so far, and that the assessments are based on assumptions and analogies with other sites. I believe that it is unacceptable to initiate the concession granting procedure before serious and independent hydrogeological studies have been carried out that would unequivocally prove that the exploitation will not endanger existing and future water sources," Bakić stated.
He pointed out that the issue of traffic infrastructure is also of additional concern, because access to the site is provided by a narrow municipal road, with "limited technical capabilities" and categorized as "a load of seven tons per axle, which is why it is not intended for intensive freight transport of large quantities of stone material."
"The Concession Act also states that due to the existing technical characteristics of the road, it will be necessary to adapt it for the needs of transporting materials and machinery. At the same time, the act foresees intensive truck transport, the use of heavy machinery, crushing plants and continuous transport of stone aggregate. However, the act does not clearly define how the reconstruction or expansion of the road would be carried out, what consequences this would have for the surrounding plots, nor who would bear the costs of repairing the road infrastructure that would be exposed to the constant load of heavy trucks. It should be particularly noted that the local population is already expressing opposition to the expansion of the road and the construction of a quarry, which further indicates a serious conflict between the planned project and the interests of the community," Bakić stated.
PUP Kolašin mentions decorative stone
The local administration specifically pointed out the fact that the Concession Act is defined as an act for the exploitation of "architectural-construction and technical-construction stone", although the Spatial and Urban Plan of the Municipality of Kolašin for the "Skrbuša" site recognizes exclusively architectural-construction stone, or decorative stone (AGK), while technical-construction stone is not at all envisaged or planned as a mineral raw material for exploitation in this area.
"The Spatial and Urban Plan of the Municipality of Kolašin clearly states that mineral deposits have been identified in the municipality that can be used through a concession, with the 'Skrbuša' site designated exclusively as a deposit of 'architectural and construction stone (AGK)', i.e. ornamental stone. The SPA describes the geological characteristics of the site in detail, stating that it is a colorful breccia and marbled limestone known as the 'Skrbuša' marble breccia, which represents a valued and sought-after decorative material of various shades. Therefore, the planning document of the Municipality of Kolašin treats the 'Skrbuša' site as a site of ornamental, i.e. architectural and construction stone, and not as a deposit of technical and construction stone and stone aggregate for mass exploitation, crushing and production of technical construction material," the local administration said, adding that, on the contrary, the concession act in question introduces a completely new category of exploitation of technical and construction stone and provides for the crushing of rock mass, the production of various fractions, the operation of crushing plants, intensive truck transport and large-scale surface mining.
Bakić stated that the concession act explicitly states the production of tens of thousands of cubic meters of stone aggregate per year, as well as the use of crushing plants with a capacity of 30-60 m3/h.
"I also note that the mechanization required in the concession act is not appropriate for the exploitation of architectural and construction stone, so the question of implementing all the listed procedures arises. We believe that in this way the purpose of the site is being substantially expanded beyond the planning commitments defined by the PUP, which completely changes the character of the planned exploitation and significantly increases the scope of negative impacts on the area. Taking into account all of the above, I believe that the Concession Act in question does not contain sufficiently high-quality and reliable expert evidence that would justify initiating the concession award procedure at this site, and also considering the expansion of existing quarries on the territory of the Municipality of Kolašin. Therefore, I propose that the procedure for adopting the Concession Act be suspended until detailed hydrogeological, ecological and infrastructure analyses are prepared, as well as that an additional public debate be organized with the full involvement of the local population and the professional public, in order to protect the natural resources and development potential of this area," Bakić emphasized.
State-owned location
He added that they drew attention to the fact that the "Skrbuša" site was not suitable for exploitation during the public debate on the concession plan for 2026.
The Report from the public hearing stated that the objections of the Municipality of Kolašin were partially accepted.
"The deposit location in question is owned by the state of Montenegro to the extent of the right of disposal (1/1), without encumbrances and restrictions, and all conditions prescribed by the Law on Concessions have been met. The concessionaire is obliged to comply with environmental protection regulations and maintain road infrastructure. When exploiting architectural and construction stone, only 10-15% is used for architectural and construction stone, and the remaining 85-90% is mining waste, and therefore, for the rational and economical use of the deposit, it is planned to use the rest as technical and construction stone for which a separate concession fee is paid," the Ministry of Energy replied to Bakić.
The Ministry of Spatial Planning had no objections during the public hearing, while the Environmental Protection Agency stated that the investor must contact them regarding the assessment of whether he needs an Environmental Impact Assessment Study. The Ministry accepted the Agency's objection.
Threatened law and protective forest
The Forest and Hunting Management Administration (PJ Kolašin) stated during the public hearing that the site in question is located in forest section 51b, within the "Rečinska rijeka - Vranještica" Management Unit, for which the Forest Management Program for the period 2019-2028 applies.
"The area of department 51b is 38,79 ha, and the management and administration of this forest is carried out by the Forest and Hunting Management Department of the Kolašin Unit. According to the current Forest Management Program, the aforementioned department is defined as a protective forest by purpose. In accordance with Article 33 of the Law on Forests of Montenegro, protective forests are special-purpose forests whose main function is the protection of soil, water, terrain stability and ecosystems. Activities that may jeopardize their main function are prohibited in such forests," says the head of this Unit. Radovan Dabetic.
He explained that Article 45, paragraph 1 of the law provides that changing the purpose of forests by clearing them for construction or other land can be carried out if this is planned in a state planning document or a spatial and urban plan of a local self-government unit, or a forest development plan in accordance with the law, and paragraph 8 clearly specifies that changing the purpose by clearing them cannot be carried out in protective forests.
"The Law on Mining and Geological Exploration stipulates that the exploitation of mineral raw materials can only be carried out in compliance with regulations in the field of forest and environmental protection, as well as in accordance with applicable planning documents. Given that the 'Skrbuša' site is a protective forest, I believe that its inclusion in the Concession Granting Plan for 2026 is not in accordance with applicable laws. Based on all of the above, we propose that the 'Skrbuša' site be excluded from the concession granting plan," said Dabetić.
Quarry in the tourist zone
Bakić considers it very problematic that stone exploitation is planned in an area that is also recognized as an area of tourist development, and that the concession act clearly states that it is within the planned tourist zones.
"In the immediate vicinity, the construction of tourist facilities, tourist trails and valorization of natural sites are planned, including the planned tourist trail to the waterfall in Izlazački potok, as well as the area of LSL 'Smrčje' and LSL 'Trunića Do'. This raises a serious question as to how it is possible to simultaneously plan the development of tourism and the implementation of an industrial quarry, which involves blasting, noise, vibrations, a large amount of dust, increased truck transport and permanent devastation of the landscape. Such activities are in direct contradiction with the concept of development and tourist valorization of the natural potential of the Kolašin area," said Bakić.
He added that the fact that the site in question is located within the Tara River Basin World Reserve under the protection of the UNESCO MAB program is of particular concern.
"Although the area is not formally within the boundaries of a national park, it is undeniable that it belongs to an area of international ecological importance, which is why a far more cautious approach to activities that may have lasting consequences for the natural values, biodiversity and water resources of this area is necessary," Bakić said.
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