The draft of the Spatial Urban Plan (SUP) of the Municipality of Kotor does not provide for protection, does not follow the recommendations of the UNESCO mission and "is just a continuation of bad planning solutions for this area": it repeatedly refers to non-existent documents, is not harmonized with some of the valid regulations, and is full of contradictions , mistakes and omissions, and the responsible planner Mladen Krekić has no experience for the work entrusted to him.
These are just some of the comments on the Kotor PUP Draft and the Draft Report on Strategic Environmental Impact Assessment that, after a public discussion and presentation at the beginning of June, were recently sent to the Ministry of Sustainable Development and Tourism (MORT) by the non-governmental organization "Expeditio".
Recalling the importance of the draft plan, the NGO assessed that its preparation was started "in a period when the area of Kotor is threatened with a review of its status on the UNESCO World Heritage list precisely because of the constant neglect of expert opinion in the field of spatial planning in the last 15 years".
"The detailed plans that were adopted, in the process of which the private interest was put before the public one, produced a series of catastrophic mistakes", it is stated, among other things, in the comments of the Kotor organization, and they add that the essential recommendations of the UNESCO/ICOMOS monitoring mission from November last year, among which the rejection of the bridge over the Veriga passage and the long bypass project for Kotor and Dobrota.
One of the key remarks addressed to Pavel Radulović's department is that the draft is not entirely based on the Study of the Protection of Cultural Properties for the Kotor Municipality area, which, according to the authors, was done precisely for the purposes of that document.
"This study is only formally mentioned, but its essential guidelines and way of treating the World Heritage area were not taken into account, which is incomprehensible, because for a municipality in which more than a third of the territory is on the World Heritage List, it would have to be the basic starting point for making a plan".
They consider it incomprehensible to reject a scenario in which the focus is on protection, and claim that precisely such an approach offers adequate solutions for the future of the city.
"Protection is presented as an obstacle to development, which is absolutely unacceptable and contrary to the status of the Kotor area on the world heritage list, as well as the general commitment of the state to sustainable development", according to the comments of the NGO "Expeditio".
The fact that the draft plan focuses exclusively on tourism is considered by the Kotor NGO to be a fundamental omission and they assess that it can have "long-term negative consequences for life in the municipality".
"The current construction of exclusively tourist facilities, as well as the conversion of existing residential buildings into apartments for rent and hotels, are already leading to a serious degradation of everyday life, especially in the urban cores of Kotor, Perast and settlements along the coast. The planned solutions would deepen it even more to the detriment of the quality of life of the residents", said the NGO from Kotor, adding that the planned solutions, through restricting access, are taking more and more of the coast away from the citizens.
They remind that, especially in the coastal settlements of Dobrota, Prčanj, Kostanjica, Morinj, Dražin vrt... there has been excessive construction for years, which is not accompanied by adequate infrastructure.
"Especially traffic. The city is in a traffic collapse every day". In that part, as stated by the Kotor NGO, numerous omissions, wrongly drawn road routes and bad solutions are evident in the draft plan.
They also remind that there is no local strategic framework, which should represent a project task for the planners of the plan and which, as they said, would ensure that the wishes, visions, plans and needs of the city and the local population are taken into account.
In a couple of places, the PUP mentions the preparation of detailed development plans, including the Detailed Urban Plan and the Local Site Study, which is not provided for by law.
"PUP had to offer solutions... that would bring the city back from the edge of the abyss into which it was pushed. Instead, we received a document that does not meet even the minimum professional standards and does not represent a development document that would offer a solution to existing conflicts and present a new vision of city development for the 21st century", according to the comments of the NGO "Expeditio".
They also assessed that the document is methodologically "at an inappropriately low level, full of contradictions, copied parts from different documents...", which is why they believe that even if it were to be adopted, it would not be possible to implement it.
The NGO from Kotor said that planning should be returned to "experienced teams of experts in the field of spatial planning, with the mandatory inclusion of experts from the field of World Heritage protection".
"Who, without the influence of politics and personal interests, would make a document that would represent a step forward from the previous negative planning practice", according to the NGO "Expeditio".
In order for this to be possible, as they said, it is necessary to completely change the spatial planning system.
"Including the legislative framework, and prioritizing the preservation of the exceptional universal value of the Kotor area, which is clearly indicated by the recommendations of the UNESCO/ICOMOS Reactive Monitoring Mission from November 2018," said the Kotor NGO.
In addition to architects, conservators, ethnologists-anthropologists, mathematicians from the "Expeditio" organization, citizens and colleagues from other NGOs participated in the ten-page document, including the Network for the Affirmation of the Non-Governmental Sector...
Expeditio: Krekić lacks experience
From the NGO "Expeditio" they believe that the manager of the Draft PUP of the Municipality of Kotor, Mladen Krekić, was inadequately chosen for that position and that he does not have the necessary experience for that position.
Referring to the Law on Spatial Planning and Building Construction, they remind that the manager can be a graduated spatial planner with, among other things, at least 15 years of work experience in spatial and urban planning.
"The head of the development of the PUP of the Municipality of Kotor has no experience in the development of spatial plans at the municipal level", according to the NGO "Expeditio" in comments addressed to MORT. According to data from the website of the Chamber of Engineers, Krekić first received a license as a responsible planner 10 years ago.
They don't even care about cultural assets
In the part of the comments on the Draft Report on Strategic Environmental Impact Assessment, from the NGO "Expeditio", among other things, they state that the conservator should be part of the team for the preparation of that document, but that this is not the case.
The report, as they state, does not even indicate the essence of the interventions on the condition of the cultural heritage foreseen by the PUP.
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