Although there is some progress, the nature of Montenegro is threatened and it is necessary to devote oneself to solving numerous problems in the field of environmental protection, it was said at the conference of the Coalition on the 27th.
In anticipation of the European Green Week, Coalition 27 presented the Shadow Report for Chapter 27: "Progress on Pause", which aims to present an overall picture of Montenegro's progress in the EU accession process for the period from January 2022 to May 2023, in terms of improvement of the situation in the field of environmental protection and climate change.
The report, as announced, deals with ten thematic areas from Chapter 27, and refers to the implementation of the remaining obligations from the National Strategy, which are now an integral part of the Action Plan for meeting the final benchmarks in Chapter 27 - Environment and Climate Change.
"The assessment of the implemented activities in this area can be sensed already in the very title of the report 'Progress on pause' (draft), and in addition to the analysis of essential problems, the readers of the report also have a set of recommendations for strengthening the process of transposition and implementation of EU legislation included in Chapter 27," he states. was announced by the Center for the Protection and Study of Birds (CZIP).
The report was presented by Ksenija Medenica in front of CZIP, Azra Vuković from Green Home, consultant Milica Kandič and Miodrag Karadžić from the Association of Young Ecologists and Northern Land.
The preparation of the report was coordinated by Milica Kandić, as an external expert, who presented the methodology and a comprehensive overview of the report.
When it comes to the subfield of Nature Protection, as stated, the Report showed that certain progress has been made in that area, said Medenica.
"It is primarily reflected in the initiation of the process of amendments to the Law on Nature Protection and the Law on Forests, which should be adopted as soon as possible. Also, revisions of the protection studies for the National Parks: Durmitor, Lovćen and Lake Skadar have been initiated, while the revision process for the NP Biogradska Gora has been completed, and the final step remains for the study to be adopted. It is also positive that the creation of protection studies for new areas has been initiated: the river Mrtvica and its surroundings, the Draft Protection Study for the Great City Park in Pljevlje and the preventive protection procedure for Valdanos and Maslinada in Ulcinj. The work on the establishment of Natura 2000 continues and the preparation of the Red List of endangered species is underway," said Medenica.
However, although there is some progress, the nature of Montenegro is threatened and it is necessary to devote oneself to solving numerous problems in that area, it is noted in the announcement.
"First of all, the management of protected areas stands out as a problem. The national parks of Montenegro have been without management plans since 2020. They are currently being prepared, but it is a paradox that they will be adopted in the second half of the current year, but for the period from 2020-2025. It is encouraging that the preparation of the Plans was finally approached thoroughly, so we hope for quality documents and their implementation in the near future," said Medenica.
Then she emphasized that protected areas, apart from bad management, are also threatened by unplanned construction.
"Examples that show this are the permits issued for construction in Prokletije National Park in the heart of the park, in the Grebaja valley. Then, the consequences of the construction of the highway on the river Tara, but also some future plans, such as the announced construction of the bridge on Bojana, which has been announced several times in the media and has no basis in plain planning documentation. Poor spatial planning in valuable areas has long been a topic in the international community, so the case of the construction of Porto Skadar Lake and HPP Komarnica has the attention of the Berne Convention, which sent recommendations to the Government of Montenegro for both cases," said Medenica.
As in previous years, the problems of the Ulcinj Saltworks have a special place in the Report. The unresolved issue of the management structure, four years after the declaration of the protected area, is the biggest obstacle to the implementation of measures to protect this area, according to the announcement.
"The ignorant attitude of the local government towards the obligation that they should have fulfilled a long time ago is particularly worrying," said Medenica.
One of the particularly important issues in the field of nature protection, which has never been included in the Progress Report of Montenegro, is the issue of poaching. As Medenica says, despite numerous initiatives to change the legislative framework, references to the need for reform of hunting in Montenegro as well as requests for better intersectoral cooperation, in the past year the responsible Ministry of Agriculture has done "absolutely nothing to solve the problem of poaching".
"Finally, in the field of nature protection, cases of the construction of a military training ground in Sinaia are also described, which is apparently still being planned despite the importance of this area from the point of view of the wealth of biodiversity and despite the petition of the citizens' initiative, which has over 22 thousand signatures of dissatisfied citizens of Montenegro," she concluded. Pelvis.
Azra Vuković from Green Home referred to the sub-area on waste management and said that the adoption of the new Law on Waste Management is five years late.
"Also, the State Plan for Waste Management in Montenegro, 2023-2028, has not been adopted. Implementation of local waste management plans is at a very low level or non-existent. It has been estimated that 25.000 tons are disposed of annually at the unregulated Mislov landfill.
In her presentation, Vuković emphasized that the Report on the implementation of the State Waste Management Plan in 2021 indicates insufficient infrastructure for primary selection, that citizens' awareness of primary selection is insufficiently developed and there are no incentive measures for citizens to selectively separate waste.
In addition to the obvious problems, there are recycling centers in Podgorica, Herceg Novi, Kotor and Žabljak. Also, recycling yards.
"There are also regional landfills for non-hazardous waste in Podgorica and Bar (Livade and Možura), waste vehicle processing plants in Podgorica (1) and Nikšić (3). We also have recycling yards in Podgorica, Budva, Mojkovac, Plav," reminded Vuković.
However, as stated, the situation in some municipalities is not good.
"The municipality of Plav, although it has a recycling yard with a sorting plant, does not have data on the amount of separately collected waste. Even though the municipality of Žabljak has a recycling center, it does not serve its purpose and the decision on selective waste disposal is not applied. In the municipality of Kotor there is the first composting plant in Montenegro to solve the issue of green waste management in the municipalities of Kotor, Tivat, Budva and Herceg Novi, however, the installed capacities are not sufficient. Most municipalities dispose of waste at temporary landfills," said Vuković.
Also, only nine municipalities submitted data on the amount of collected non-hazardous construction waste, and only three municipalities have a defined temporary location for non-hazardous construction waste.
"Regarding the issue of the treatment of hazardous and non-hazardous waste, a register of polluters was prepared and put into operation, however, it is not in use due to cyber attacks and the problem has not yet been resolved," Vuković pointed out.
Some of the key recommendations, as she said, in order to solve the problem of waste management, would be a new Law on Waste Management, create and adopt the National Waste Management Plan in Montenegro, adopt Local Waste Management Plans, provide incentive measures for citizens in order to implement primary selection, strengthen administrative and operational capacities at the state level, strengthen cooperation between state and local authorities, ensure the functioning of the register of hazardous waste polluters and many others...
Miodrag Karadžić from the Society of Young Environmentalists and the North Country presented the sub-area of air and water quality.
A general overview of the situation in the subfield of water quality shows that the legislation is fully aligned with the EU acquis (the law was adopted in 2007, amended in 2015, as well as in 2018).
"However, the registry of waters of importance for Montenegro and for waters of local importance has not yet been created, a water information system, state and local operational plans for the protection of waters from accidental pollution for waters of importance have not been established. Inadequate sewage networks for the collection and removal of fecal water are significant problems in the functioning of existing treatment plants, which call into question the efficiency of the management of the waste water system and, therefore, the quality of surface and underground water. It can be said that the choice of contractor was questionable for some plants," said Karadžić.
As he says, according to the findings of the State Audit Institution, sewage sludge is mostly stored within the plant, although its application is defined by the Law on Waste Management and the Rulebook on the specific conditions that municipal sewage sludge should meet. At the level of the State and local self-governments, it is pointed out, there are no sewage sludge management plans, which would define the method of treatment and handling of it.
In the Report itself, several key recommendations are listed, when it comes to the sub-area of water quality.
"It is important to establish Registers of waters of importance for Montenegro and waters of local importance, Establish a Water Information System, which, among other things, contains a water pollutant cadastre; amount of waste water; Enact a Sewage Sludge Management Plan that would define the manner of handling and treatment of the resulting sewage sludge both at the state level and at the level of local self-governments, and many others," said Karadžić.
When it comes to the air quality sub-area, a general overview of the situation shows that the National Air Quality Strategy for the period 2021-2029 has not been adopted as planned. with the Program of Measures to Reduce Emissions Covered by the NEC Directive.
"The cadastre of pollutants has not been established, so adequate data on air pollutants have not been provided. Polluters do not monitor and do not submit reports on monitoring to local governments and the Agency. There is no monitoring of indoor air quality or assessment of the cumulative effects of pollution on public health," he said. Karadzic.
It is recalled that in March 2021, Montenegro submitted to the European Commission an analysis of economically viable emission control strategies for 2020 and 2030, which serves as the basis for the final agreement between the EU and Montenegro on its obligations to reduce emissions under the NEC Directive. In January 2022, the European Commission gave the green light to that document, with the recommendation that Montenegro must define obligations to reduce emissions in accordance with the National Energy and Climate Plan, "which to date, i.e. almost two years later, has still not been adopted".
Karadžić sees achieving the prescribed air quality in all zones as the biggest challenge in the area of air quality.
"The increased concentration of suspended PM particles, especially in the municipalities of Pljevlja, Bijelo Polje, Podgorica and Nikšić during the heating season, is worrying both because of the frequency and the amount of concentrations, despite the fact that these municipalities, with the exception of Bijelo Polje, have adopted action plans to improve the quality air," he said.
Some of the key recommendations for that area, as announced, would be: to update the draft of the Air Quality Strategy with new data from the emission inventory as well as with established emission reduction targets; adopt air quality plans for zones where pollutant concentrations exceed any established limit or target value, with Action Plans for its implementation; initiate amendments to the Law on Air Protection in order to more precisely determine the obligations of local self-governments with regard to the adoption, implementation and reporting of measures provided for in local action plans; ensure adequate functionality of air quality monitoring stations in the State Air Quality Monitoring Network; establish a functional cadastre of pollutants...
The report was prepared within the framework of the project "Strengthening the participation of civil society in the field of environment in the EU accession process (4E)", which is financially supported by the European Union, through the program "Civil Society Facility 2021 and Thematic Program on Human Rights and Democracy 2021".
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