Hello Mojkovac: The concessionaire misled the team for creating the spatial plan for Brskovo

The Citizens' Initiative (GI) "Zdravi Mojkovac", as part of the public debate on the Draft Detailed Spatial Plan (DPP) for the area of ​​the concession area for the exploitation of mineral raw materials - Brskovo and the Draft Report on the strategic assessment of the impact on the environment, submitted to the Ministry of Ecology, Spatial Planning and urbanism comments, proposals, suggestions on more than 50 pages.

The Environmental Movement "Ozone" supported the argumentation which, as they stated in a joint statement, "showed all the controversies, contradictions, shortcomings and illogicalities in the Draft DPP and the Report, and that they should be withdrawn."

"The DPP draft was not made in accordance with valid domestic legal regulations, international conventions, which Montenegro ratified, but also with higher-order plans and has essential legal, technical-technological, methodological, legal and ethical-sociological deficiencies. Also, the shortcomings of economic analysis. The adoption of such a document is contrary to the principles of sustainable development and the green agenda. The document proposes activities that result in permanent and irreversible devastation of the area, in the area between the two national parks and the Tara river, which is under UNESCO protection," stated the GI.

The adoption of the DPP, as they claim, would result in "potential dangers of pollution of the wider area and water sources for neighboring cities, pollution of surface and underground water, soil, air, destruction of flora and fauna...". The implementation of mine projects, they explain, takes away every chance of Mojkovac to valorize its tourist potential, and endangers the citizens of Mojkovica with a number of constitutional rights, first of all, the right to a healthy environment.

GI "Zdravi Mojkovac" raises the issue of conflict of interest in the preparation of documents and explains that "the study, on the basis of which the Plan and the Strategic Environmental Impact Assessment were made, were not verified by the state authorities, but the contracting authority is the concessionaire whose direct interests are involved". They demand that the opinion of the Agency for the Prevention of Corruption be requested in connection with these allegations. They also remind that the exploitation of lead and zinc ore in the Brskovo mine is not planned by the State plan for the exploitation of mineral raw materials.

"In order to plan any activities in that area, during which polluting substances are emitted or are by-products of the production process, it is mandatory to make a hydrological study to determine the dispersion of polluting substances in underground water courses, because this is the only way to identify dangers and propose adequate protection measures. Everything else leads to a direct threat to people's health and life and is unacceptable for further planning of any activities on the planned scope", remind the relevant ministry of GI.

The main shortcoming of the DPP, they claim, is "the lack of basic information about the procedures that will be carried out in the investigative exploitation area and the absence of mention of the necessary treatment procedures and prevention and protection measures in relation to the presence of heavy metals (mercury, lead, arsenic, cadmium...)" . As explained by GI, due to these deficiencies, decision-makers were misled regarding the dangers to human health and life, as well as to all segments of the environment.

"The concessionaire misled both the Plan drafting team and the decision-makers, because by avoiding the mention of the term hazardous waste, and especially avoiding the mention of the presence of mercury, for which restrictions are prescribed in the Montenegrin legislation, he tried to present the proposed so-called "innovative technology" as acceptable. concealed the real situation and danger, which could have resulted in catastrophic consequences for the health and life of people and the environment", they explain.

Among the many objections to the DPP is the method of compensation for private property, the occupation of which is planned for the implementation of the mine project. Compensation areas can be areas in state or private ownership. They claim that, given that there is no Decision on declaration of public interest, conversion is carried out, so meadows, pastures, orchards, fields are turned into forest land "in order to make up for the forest areas that will be cut down by the concessionaire of the mine". This, they claim, "degrades the economic base of the local community through the reduction of arable land and thus income, which ultimately forces the population to emigrate."

The second document, that is, the Strategic Impact Assessment, as stated by the GI, "did not recognize the impacts of the opening of the mine on the environment and human health." Also, they explain, that document did not provide recommendations and solutions for preserving the value of natural resources and goods, landscapes, biological diversity, wild plant and animal species, and autochthonous ecosystems.

They see the skipping of the early consultation phase as the biggest lack of procedures related to the planned mine project. They, they explain, had to be carried out before the public hearing, "with the participation of experts and interested public, transparent and responsible communication with citizens". They say that "if the executive authorities want to protect the public interest and show a real desire for the process of European integration, they should, after the concession contract expires, abandon the plan to exploit mineral resources in Brskov".