In October, representatives of the Center for the Protection and Study of Birds (CZIP) found felled trees of great value and age in the Zeletin and Visitora rainforests. They concluded that the rainforest has collapsed and that its survival is threatened.
Center for Investigative Journalism of Montenegro (CIN-CG) he turned to the Forestry Administration (UZŠ) to clarify whether it was illegal or authorized logging, but they did not know how to answer. Certainly, it is a place that belongs to the regional unit of the UZŠ "Kutska Rijeka", which means that this valuable natural area is actually intended for the forestry industry.
For years, CZIP has been demanding that the areas of Zeletin and Visitor, mountains in the east of Montenegro, be recognized as natural areas for protection, because they represent unique rainforest reserves, of which only three percent remain in Europe. However, there was no reaction from the authorities.
The forests of Zeletin and Visitora are one of the areas that have been proposed as areas of exceptional natural importance as part of the Emerald ecological network, and have never received any kind of national or local protection.
In 2006, Montenegro declared 32 natural areas candidates for the Emerald network. This network is a form of protection of natural habitats and wild species and is also valid for countries that are not members of the European Union (EU). The establishment of Emerald is particularly important for countries that are candidates for the EU, such as Montenegro. The basis for the establishment of this network is the Convention on the Conservation of European Wild Flora and Fauna and Natural Habitats - the Berne Convention.
However, significant damage has already been done in some candidate areas, especially those that do not enjoy any other level of protection, such as Zeletin and Visitor.
"Although Zeletin and Visitor are candidates for Emerald and an internationally important area for biodiversity, logging has significantly damaged this pearl in the last few years. Breaking roads, fires, illegal and legal logging have degraded what we had in this area 10 years ago," he told CIN-CG. Bojan Zekovic, ornithologist from CZIP.
He says that it is unacceptable that the Forestry Administration does not recognize the importance of this area and allows the destruction of the most preserved forests in Montenegro, which most residents do not even know about.
"Zeletin and Visitor are not as well known as some of our more popular mountains, but they are priceless from the point of view of biodiversity. These are monumental, old, rainforest trees, important species of plants and animals, valuable geological features, water... A rare place where molika and munika grow together, two endemic, rare pines of Montenegro", explains Zeković.
Some of the other important candidates for Emerald are the Komarnica canyon (Nevidio), Sinjajevina, Skadar lake, Buljarica, Velika Plaža... Ambitious infrastructure, tourism and industrial projects have been linked to these areas for years, which could forever destroy their natural value, which is the primary the reason they were nominated for the network.
As many as a third of Emerald applicants do not have any form of protection
About a third of the areas proposed for Emerald have not received either national or local protection to date, so they are at risk due to possible investments and projects. Apart from Zeletin and Visitor, this is the case with Sinjajevina, which is the largest pasture in the Balkans, and which the state has planned for years to turn into a training ground for military exercises.
Even Ćemovsko polje, one of the most important remaining pseudosteppes in Europe, important for numerous species of birds, is not protected. On the contrary, it is known as a waste dump.
Golija and Ljubišnja mountains, Mrtvice Canyon, Ćehotina and Lima valleys are also areas with valuable and incompletely explored ecosystems, left at the mercy of the state and investors.
According to the "Action plan for meeting the final benchmarks in chapter 27 - environment and climate change", all candidates for Emerald must have "prescribed and integrated measures of adequate habitat protection in the planning documentation and the related Strategic Environmental Impact Assessment". However, the Strategic Assessment published in 2014 does not mention any network of protected areas.
The Environmental Protection Agency explains that since 2016 they have been working on the mapping of species and habitats significant at the European level within the framework of another network - Natura 2000. However, Natura 2000 is a network exclusively for EU member states, so Montenegro cannot yet be and the formal part of it.
And the European Commission stated that they cannot evaluate the data and mapping of Montenegro made for Natura 2000, since the country is not yet in the EU, but that they can only evaluate the Emerald process. They even offered to help translate data collected for Natura 2000 into Emerald data, in accordance with the Berne Convention. This is stated in the internal documents of the Environmental Protection Agency from last year, which CIN-CG had access to.
As part of the habitat and species research project for Natura 2000, 27 candidates for Emerald have been fully researched so far, research is ongoing this year for two areas, two have been partially researched and are planned for next year, and two have not been researched and are planned for the next period, the Agency said. By the end of this year, about 60 percent of the entire Montenegrin territory will be mapped.
Mines are spreading on Ljubisnja - because there was no protection
Like Visitor and Zeletin, the Ljubišnja mountain is also an Emerald candidate, you can sew it up without any vision. Precisely thanks to this, the company Gradir - Montenegro managed to obtain permits for detailed geological research of zinc and lead deposits, in the immediate vicinity of valuable forests, and has already started with excavation.
CZIP recently, during a tour of the field, came across new exploratory mines, which are located near a potential nature park, the declaration of which could finally protect this area.
"The miners completely destroyed the forest and demolished part of the mountain, next to the existing Suplja stijena mine," explains Zeković. The exploitation of lead and zinc ores has already greatly damaged the area of Ljubišnja, he says.
After the field visit this year, CZIP turned to the environmental inspection, explaining that these deposits are located in the immediate vicinity of the forest that would belong to the nature park.
However, in the response of the environmental inspection, which CIN-CG had access to, it was stated that the company Gradir - Montenegro has all the necessary permits.
"In relation to your statement that it is a potential nature park, we inform you that the procedure for placing Ljubišnja under protection has not been initiated and that no decision on preventive protection has been adopted," the ecological inspection's response states. Therefore, they further state, "the environmental inspection has no competence to carry out inspection supervision in this administrative matter, because it is not a protected area".
The problem on Ljubišnja is also a problem on other mountains, and it concerns the complete neglect of biodiversity, which is not taken into account during planning, says Zeković.
"There are rare mountains where you can come across prints of a wolf, bear, roe deer, wild boar, grouse, hazel grouse, the living world in miniature. This is the case in Ljubisnja. "Unfortunately, Ljubišnja has been the subject of forest exploitation for decades, which was sustainable up to a certain point, which reflects the presence of these species, however, what we see on the ground in recent years is not in favor of that," says Zeković.
Ljubišnja is a mountain that for the most part, about 70 percent, is covered with forests, especially coniferous forests, which are extremely important for numerous species of birds, but certainly also for the entire living world in that area, explains Zeković.
"Ljubišnja is the most important mountain in Montenegro for the Ural owl, while it is also extremely important for the little owl and the mountain cuckoo owl, the deaf grouse, the woodpecker, the three-toed woodpecker, and many other endangered and protected species, thanks to which this area is recognized as Emerald area, i.e. the future Natura 2000 area".
Future plans - uncertain
In the Draft Spatial Plan of Montenegro until 2040 (NPPCG), it is stated that Emerald is an already established network, and that these areas cover 15 percent of the land territory of our country.
"The Spatial Plan of Montenegro must adequately treat them in terms of protection guidelines and avoiding planning conflicts with the needs of their protection", it is stated in this Draft Plan.
However, in the part of the plan in which the protected areas in Montenegro are mapped in detail, precisely in order to avoid conflict, the Emerald areas are not marked in green like other natural areas under protection, but with yellow lines. It is indicated that these are "potential" protected areas. For this reason, the Council for the revision of the Plan in the "Revision of the Draft Spatial Plan until 2040", as of this month, proposed a revision.
"It is not clear whether the Emerald network already exists or has yet to be established," the Council states.
The Council also suggested that the term "potential protected areas" should be deleted from the Draft, but that it should be emphasized that these are candidates for protection in order to reduce the risk of projects and activities that may endanger them.
It is not clear from the Draft Plan what will be the fate of the applicants for the Emerald areas. One such area is the Komarnica canyon, which the construction of a hydroelectric power plant threatens to submerge forever.
The construction of HPP Komarnica is still the subject of investor interest, but also of great protest by biologists and ecologists both at the national and international level - warnings from UNESCO and the European Commission.
"Recognizing the indisputable great importance of HPP Komarnica in the energy system of Montenegro, and on the other hand environmental requirements and space protection requirements, for the final decision on the construction of HPP Komarnica, it is important to draw conclusions within the project documentation and accompanying environmental impact assessment from the competent institutions of Montenegro", it is stated in the Draft.
In 2022, the NGO Montenegrin Society of Ecologists (CDE), together with the KOD organization and the Society of Young Ecologists, submitted a complaint to the Secretariat of the Berne Concession regarding the Komarnica HPP construction plan. At that time, they stated that by building the HPP at Komarnica, Montenegro would violate the Berne Convention, which obliges the signatory countries to improve their national policy in the preservation of wild flora and fauna, with special attention to endangered species, as well as the preservation of wild animals and natural habitats. This secretariat will give its final opinion on the project when the Environmental Protection Agency prepares the Environmental Impact Assessment Report. From CDE, they believe in a positive outcome after the preparation of the Elaboration.
The Sinjajevina area, another Emerald candidate that has been left without any form of institutional protection, is still under threat of being turned into a training ground for military exercises. The Draft states that "the Ministry of Defense and the Government of Montenegro will draw conclusions on the temporary use of the military training ground in Sinjajevina and all conditions related to environmental protection and the use of the area of Sinjajevina for agricultural purposes".
They are not protected areas either
Some of the Emerald candidates have the highest level of state protection, such as being part of national parks. However, even a high level of national protection does not guarantee the safety of these projects from the greedy hands of investors.
Thus, NP Skadar Lake almost became the location for Porto Skadar Lake, a luxury resort and yachting port. Almost all of the other Emerald contenders have been subject to contentious projects. Nevertheless, the Berne Convention reacted then.
"Although the Emerald network has not been officially established in Montenegro, the Berne Convention is very responsive when it comes to endangering candidates for the network," he told CIN-CG Milena Bataković from the Environmental Protection Agency.
When the NGO sector protested the construction of a luxury resort on Lake Skadar and appealed to the Berne Convention, they sent independent assessors of the situation.
"When the mission came, it didn't want to listen to either the state on the side of the investor or the NGO, but independent experts made an assessment. The conclusion was that the project is harmful", Bataković points out.
At that time, the Berne Convention called for changes to the spatial plan, and Montenegro should regularly report on this to the Berne Convention.
In the Draft Plan until 2040, it was recognized that most of the recognized protected areas do not have a high level of protection.
"Although there are 78 nationally protected areas in Montenegro, only nine have a management plan, and even 32 of them do not even have a named manager, such as municipalities or National Park of Montenegro", this document states.
"Like any other thing, if you don't have a plan, then you don't have a goal and you don't know what you will spend your money on," the biologist told CIN-CG. Vuk Iković.
Also, we have nature parks that have both a management plan and a protection service, such as the case of Komovo, but again the situation is bad, because there is a conflict between nature and society.
"This will last as long as politicians impose the attitude that nature conservation is an expense and as long as companies that manage protected areas are viewed as political prey," says Iković.
Montenegro does not respect the Law on Nature
According to the Montenegrin Law on Nature Protection, the priority is to establish a network of protected nature areas, i.e. wild flora and fauna. However, Montenegro has not established a network even after 15 years since the adoption of this Law. The network of protected areas implies that certain protected locations of flora and fauna are interconnected, because this is the only way to ensure the sustainability of protection.
Iković believes that Montenegro could have declared Emerald candidates as a network a long time ago, and only then work on further improvement and research.
"The network should have been announced, and this would have contributed to avoiding many harmful projects during the previous decade, and in the future," he explains.
"Although Emerald areas have never been formally declared, the nature protection sector is aware that Montenegro must provide a protection mechanism. Spatial planning should not ignore them", says Bataković.
Iković points out that one of the key tools that would help preserve natural areas is GIS software.
"GIS serves to overlay areas of different uses and to accurately determine conflicts of interest. That way, it would be known where what is allowed, and where the strictly protected areas are," he says.
"The directorate does not have an employed GIS expert, but a certain number of employees possess knowledge in the mentioned field," the Ministry of Ecology, Spatial Planning and Urbanism states.
The establishment of an ecological network, currently as Emerald, and after joining the EU as Natura 2000, is not significant "only" from the aspect of nature protection, CDE told CIN-CG.
"Ecological networks do not exist only to protect species of plant habitats or animals, but it is equally important to improve the quality of life of the local population, who live in these areas. That's why their maximum involvement in the process of monitoring and maintaining these protected areas, as well as the development of the economy of the local community on the foundations of preserved nature, is of key importance," explained the CDE.
"Today we witness not only that nature is best preserved in ecological networks, but also that the local economy and rural tourism are the most developed in the villages that have become part of the ecological network. That is why this is not only the protection of nature, but also the creation of a new economic environment that benefits both man and nature,'' said the organization.
This text was created as part of the project, "Ecological networks - the key to development on the foundations of preserved nature" implemented by the NGO Montenegrin Society of Ecologists. The project is supported by the Center for Civic Education (CGO), within the program "CSOs in Montenegro - from basic services to policy formulation - M'BASE" financed by the European Union and co-financed by the Ministry of Public Administration. The content of this text is the sole responsibility of the NGO Montenegrin Society of Ecologists and does not necessarily reflect the views of CGE, the European Union or the Ministry of Public Administration.
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