The Public Company for the Management of the Maritime Assets of Montenegro (JPMD) in the project of arranging a temporary facility, the so-called of the Tivat Airport's water terminal started on the basis of an agreement with the Ministry of Ecology, Spatial Planning and Urbanism, and not on the basis of valid spatial planning documentation and regulations that regulate that area.
This results from the answers that "Vijesti" received to a set of questions posed to JPMD in connection with an investment worth about thirty thousand euros that this state-owned company, outside of its official Program for the use of funds for 2022, is currently building at the Blato (Kukoljina) location in Tivat, right next to the threshold runway 14 of Tivat Airport.
JPMD told "Vijesta" that "in order to increase the level of access service, i.e., arrivals and departures from the airport in Tivat, relief from road traffic and faster transportation of passengers staying on the Montenegrin coast, in the northern zone the State studies of the location "Tivat Airport "- Sector 24, near the mouth of the Gradiošnica river, planned water terminal".
"Since the construction of the water terminal has not yet been started on the stretch where the water terminal is planned, the JPMD, and previously in agreement with the relevant Ministry of Ecology, Spatial Planning and Urbanism and the Government of Montenegro, initiated the procedure for putting the temporary location into operation, which is located in the immediate vicinity of the planned water terminal, where the operation of seasonal docking and mooring of vessels for the needs of Tivat Airport will be carried out, all with the aim of relieving road traffic, which is also known on the Montenegrin coast during the summer tourist season and in order to the atmosphere of tourists coming to Montenegro was as pleasant as possible", answered the JPMD to the question on the basis of the specific documentation that the company embarked on this project.
The location for the permanent facility of the water terminal, according to the valid DSL "Tivat Airport", is planned about 300 meters north of the place where JPMD, in cooperation with the Airports of Montenegro, has been arranging the "temporary" facility of that terminal for several days - approximately at the place where they are now facilities of the abandoned and collapsed former slaughterhouse, near the aviation fuel tank of Jugopetrol. Despite this, the temporary water terminal JPMD and ACG, with the approval of the Government, without any basis in the planning documentation, began to be arranged on the coast in the town of Blato, in the immediate vicinity of the threshold of runway 14, in a zone that is under a special regime due to the safety of air traffic at the airport .
"The mentioned temporary location is recognized and marked with number 10 (firmly constructed pier) in the Program of Coastal Infrastructure Facilities brought by JPMD, on which floating temporary facilities (pontoon and/or breakwater) forming a pier and mooring are mounted, marked with number 8.1 in the Program of Temporary facilities in the maritime domain for the period 2019-2023. year, in the municipality of Tivat, issued by the Ministry of Ecology, Spatial Planning and Urbanism. The location is on the floor. plot 1262/1 KO Mrčevac, municipality of Tivat, in front of which a platform for landing and mooring of vessels, dimensions up to 50 m x 2.5 m, which amounts to P = 125 m2 and P of the water area = 150 m2, is being placed", stated the JPMD.
They stated that, in addition to the work they had already undertaken at that location where they concreted the access plateau to the existing wall, erected a small sanitary facility, asphalted a large parking lot and horticulturally landscaped the surroundings, they sent "a request for the issuance of urban and technical conditions for the construction of a water terminal in accordance with the DSL Secretariat for Spatial Planning in the Municipality of Tivat, in order to determine, i.e. predict the funds for the Conceptual Solution, and therefore for the Main Project for the construction of the official water terminal, through the Plan for the use of funds for the year 2023".
"Therefore, the Public Company for the Management of the Maritime Assets of Montenegro is preparing a location as a temporary seasonal solution, which is located near the planned water terminal for the needs of seasonal docking and mooring of vessels for the needs of Tivat Airport," said the company headed by Blazo Radjenovic (URA) and Mladen Mikijelj (DF).
When asked what official position they received from the Civil Aviation Agency (ACV) as the supreme aviation authority in the country regarding the intention to establish a temporary water terminal at that location, JPMD said that the company "has permission from the Civil Aviation Agency for docking and mooring of vessels up to three meters in height".
However, some objects, especially the new tree seedlings that JPMD has placed, are already more than three meters above sea level, although they are located in a zone much closer to the threshold of runway 14 than is the case with the mooring pontoon which, according to to the earlier position of the ACG, only vessels lower than three meters above the sea are allowed to approach, because more and more "break through" the so-called horizontal transition planes in the protected zone of the airport.
Last Sunday, in response to questions from "Vijesti" regarding the "temporary water terminal" project in Blato, ACV expressed great reservations about what JPMD and ACG are doing.
"In accordance with our powers, and based on a detailed expert analysis, we are of the opinion that any construction or activities in the immediate vicinity of operational areas, of any airport, must be reduced to a minimum, in order to give priority to the safe performance of aircraft operations, especially in conditions of emergency procedures, so as not to endanger the safety of passengers, aircraft and equipment. Given that parts of the infrastructure of the water terminal are planned to be built in the zone of the protective surfaces of Tivat Airport (which will increase the presence of passengers, vehicles and accompanying equipment), we believe that the above may have a negative impact on air traffic, as well as on the users of the water terminal at Tivat Airport and in this context, it is necessary to implement protective measures so that the new infrastructure does not affect the safety of air operations and the safety of passengers using the water terminal", ACV told "Vijesta".
The Agency pointed out that on June 22, their inspector "at the request of JP Morsko thoroughly inspected the location and inspected the condition of the port dock" and confirmed that JPMD and ACG on Blato operate a temporary terminal without any documentation.
"Since there is no adequate documentation for the mentioned facility, the ACV inspector verbally gave instructions to the representatives of the Maritime Dobr in which way and under what conditions it is possible to arrange the surface of the dock. The surface of the dock is located in the zone of the approach surface for runway threshold 14, i.e. the departure surface from runway threshold 32 of Tivat Airport, and accordingly the height criteria for the construction/installation of physical objects must be met, so that they do not represent an air obstacle", they told us from ACV.
Everything is beyond ICAO standards, it cannot be done without ACV's permission
The topic of whether the temporary water terminal insisted on by JPMD, ACG and the Government of Prime Minister Dritan Abazović, as it is now, violates the standards and provisions of the International Civil Aviation Authority (ICAO) and the provisions of the Law on Air Transport of Montenegro, was also dealt with by avioportal.me. . ACV confirmed to that media what they had previously told "Vijesta" and added that "what we can state, on the basis of independently initiated, internal expert analyzes and on the basis of the information at our disposal, is that a part of the infrastructure of the water terminal ( parking, access roads and planted greenery), are located in the zone of the basic runway and the safety area of the end of the runway, which is contrary to the current regulatory requirements for these areas, while the main port part of the infrastructure does not threaten the safety of air traffic ".
As a result, the state and its two companies that build the "temporary water terminal" of Tivat Airport in this way do not solve any existing problem, but create a completely new problem on a long list of deficiencies that have been preventing the official certification of Tivat Airport according to ICAO standards for a long time.
The ACV confirmed that the construction and functioning of the temporary water terminal facility at this location included in the protective areas of the Tivat airport "requires the consent of the technical authorities, as provided for by law."
"In this particular case, the Civil Aviation Agency was not submitted a request for consideration of technical documentation. This facility, if we consider the safe and smooth operation of air traffic at Tivat Airport as a priority, can be built only if there is no negative impact on the safety of aircraft operations, and since there is no adequate technical documentation for the said facility, it is not even possible to assess the level of negative impact on the safety of aircraft take-off/landing operations from Tivat Airport to Tivat Airport", ACV confirmed to avioportal.me.
Jet blast can “blow away” the passengers of the water terminal
ACV confirmed to aviaportal that part of the facilities of the temporary water terminal is in a dangerous, so-called the jet blast zone (the zone in which the exhaust of the jet engines of the aircraft acts during take-off).
"Part of the infrastructure of the water terminal (specifically, the part of the parking space closer to the fence of Tivat Airport around the threshold of runway 14 and the "preliminary" corridor for the movement of passengers and vehicles to the location of the water terminal) is located in the "jet blast" zone during the aircraft take-off procedure from the threshold 14 runways of Tivat Airport. Based on the simulations of the air flow speed from the engines of larger planes, there would be the appearance of air currents at the location of the parking lot and "preliminary" passenger movement corridors with air flow speeds in the range of 50-80 km/h, depending on the place where the air flow is measured during airplane take off. In this regard, it is evident that such air currents can cause the rejection of lighter objects and things, which can result in injuries to passengers or damage to equipment. What we can state with certainty, for prominent locations, is that there would be a feeling of least discomfort among people who are in the "jet blast" zone, explained the ACV.
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