The Council of the Local Community "Kavač" sent an urgent letter to the Minister of Spatial Planning, Urbanism and State Property Slaven Radunović, the competent urban planning and construction inspection, the Municipality of Kotor and other competent institutions to review the construction of a complex of nine buildings above the Vrmac tunnel.
"Kotor is being attacked by construction from all sides, and currently Kavač is the largest construction site where much is being done outside the regulations and which endangers the local population. We ask you to protect us," the letter, which Vijesti has had access to, states.
Locals warn Radunović that the project is controversial in several aspects, is not in line with urban planning and technical conditions, and its construction could very likely have lasting consequences for the citizens of Kotor.
As they claim, the traffic project is not in line with the urban and technical conditions (UTU) from the Kotor Spatial Urban Plan (PUP).
"According to the UTU issued on November 23, 2023 by the Ministry, under point 17.3, the conditions for connection to the traffic network are prescribed, which is in accordance with the PUP of the Municipality of Kotor, where it is necessary that newly built units are accessed from lower-level roads. The UTU lists plots that have already been recorded as a route with the official status of passage and continue onto a road owned by the Municipality of Kotor, all in accordance with the act issued by the Secretariat for Entrepreneurship Development, Utilities and Traffic. The documentation includes the subsequently requested conditions of the Traffic Administration dated October 12, 2023, where special conditions for connection to the main road are required, which state that a four-way intersection is planned or should be planned at the very exit from the tunnel, which remains unclear.
The only authoritative document on the basis of which conditions can be issued is the Kotor Municipality's Urban Development Plan, which does not have an intersection marked at that location. The creation of such an intersection at the immediate exit from the Vrmac tunnel on the M1 highway represents a precedent that will represent a black spot on that section, because the existing intersection, which is located a few hundred meters lower, is a place where accidents constantly occur and which has claimed several lives," warn the Kavač Local Community Council.
Examine a whole range of failures
The forced construction of a connection to the main road, as they point out, on its most frequented section for the entire newly planned settlement is absolutely inconsistent with the conditions, plan and expertise.
"On whose orders and why were additional conditions requested from the Traffic Administration, ignoring the existing ones in the plan? We want accountability for the person who signs the conditions that are not based on the plan and ignore the existing conditions from the UTU," the local community points out, demanding an investigation into why the official conditions from the PUP were ignored and why new conditions were written and on whose orders, which are not in line with the planning document.
The question, they add, is whether the project has received approval for connection.
"It should also be noted that for the existing complex, within the framework of the project for the construction and protection of the foundation pit, it is planned to provide it by driving piles, and all of this is planned in the zone above the tunnel route (immediate vicinity). During the reconstruction of the tunnel about 15 years ago, the ground collapsed in that very zone above the tunnel route and this is still visible on the ground today. The Roads Administration and the Ministry, as the competent authorities, should also know that the tunnel is endangered by construction in the zone above the route, especially where the construction of underground floors and driving piles is planned. The Vrmac Hill is not karst rock, but is composed of layers of gravel, and therefore the possibility of soil collapse is greater, as is the threat to traffic safety of the tunnel itself. The tunnel is already in poor condition, as you yourself are aware, and such an attack on the zone above the route can have major consequences. It is obvious that the project is not in accordance with the conditions, so we expect that a whole series of failures that were made will be examined and that they will be canceled," the locals demand.
Wastewater and environmental threats
According to the UTU, at that location, as stated by the MZ "Kavač", there is no sewage network built and the conditions stipulate that wastewater is treated individually with bioseptics.
"It should be recalled that when issuing the conditions, it is not known what the investor's plan is for a particular location, and the aforementioned location is not planned to have a single facility, but a complex of nine buildings and a large swimming pool. Underground garages are also planned. The location is located in the area above the Vrmac tunnel, where one of the three main springs that the Waterworks uses to supply Kotor with drinking water is located. Vrmac Hill, in whose bowels the tunnel contains a catchment, has already suffered the loss of a large amount of water, when during a reconstruction of the tunnel, about 15 years ago, construction work was carried out, which affected the loss of a water branch, which then reduced the yield of the spring. The potential construction of this complex, where construction work is planned above the network of drinking water basins in the Vrmac tunnel catchment, in the form of pile driving, as well as the construction of underground floors and, ultimately, the construction of bioseptic tanks with overflows at elevations above the catchment, is a threat to the environment and the source of drinking water that supplies Kotor. "There is no doubt at all that by allowing this construction, this will happen sooner or later," the locals emphasize.
The state should protect us, this is a violation of constitutional rights
As stated by the Local Community "Kavač", the Environmental Impact Assessment Study has not yet been completed.
"We submitted comments and suggestions to the Environmental Protection Agency and the Secretariat for the Protection of Cultural and Natural Heritage within the legal deadline and are awaiting the outcome. Despite this, the project was revised and the Application for Works was posted on the ministry's website, although this was impossible after that date in December, when the public discussion of the Study lasted until February 5 of this year.
There is a lot that is not in accordance with the law regarding this issue, so we want the procedures for the aforementioned project to be examined, everything that was done in a row outside the rules of the profession and the law, and to inform us of the outcome. Anyone who signs this is responsible for the very certain disaster that the construction can cause for the general good and for the city of Kotor. It is true that the Kotor Urban Development Plan, which initially envisaged construction in a given area, is the main problem, but by allowing the unification of the location and the possibility of building large facilities on such a specific location, infrastructural matters of general interest are called into question.
"This is only about the investor's profit, not about any valorization of space or a facility of general interest, therefore it is necessary for the state to protect us, because this is a violation of constitutional rights," the local community said.
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