The company “Novi Boksiti” Nikšić has been granted a concession for detailed geological exploration and exploitation of potential red bauxite deposits in concession block four, in the territory of the municipality of Nikšić. The said concession block is located in the Kuta II area, which belongs to the domain of the Prekornica mountain, which is also home to the largest communities of munica in the Balkans, a special type of pine that is protected by law.
The Forest and Hunting Management Administration (Forest Administration) stated that within the concession area where the exploitation of ore is planned, as many as 656 hectares are forests and forest land. The Forest Administration has the right to manage these 656 hectares.
There is a great deal of forest wealth in that area, over 90 thousand cubic meters of valuable species, of which as much as 23 thousand cubic meters is pine.
"Half of the area belongs to protective forests, which, according to the current Forest Law, cannot be changed in purpose, which would have to happen during the implementation of the contract in question," the Forestry Administration told the Center for Investigative Reporting of Montenegro (CIN-CG).
The concession agreement was signed on October 17, 2024 by the Minister of Mining, Oil and Gas. Admir Šahmanović, after receiving authorization from the Government of Montenegro at its session on September 12, 2024.
"The concession agreement does not recognize the presence of the munica, which is a protected species under the Nature Protection Act, even though it makes up 26 percent of the total timber stock in the concession area. The planned logging would further threaten not only the munica but also the sustainability of the entire ecosystem of this area," he comments on this concession. Andrijana Mićanović from the Montenegrin Society of Ecologists (CDE) for CIN-CG.
Red bauxite is a key raw material for the production of aluminum. Its economic and strategic importance is reflected in its wide application and high demand on the global market. According to the Chamber of Commerce of Montenegro, proven reserves of red and white bauxite in our country exceed 40 million tons, which is about one percent of total world reserves.
On the other hand, the munika (pinus heldreichii) is a species of pine that grows exclusively in the mountains of the Balkans, with isolated locations in the Apennines.
"The munika is a relict species, which means it survived the ice age. Its habitats are of exceptional ecological importance and have been protected in Montenegro since 1976," says Mićanović.
The CDE explains that the munika forests have been under extremely high pressure for decades due to massive forest fires and logging, and that additional losses would endanger not only this species, but also the entire forest ecosystem and the survival of species that depend on these forests.
"The forests of the munika require restoration, not the brutal devastation of forest areas," warns Mićanović.
Forestry Administration and Ministry of Agriculture excluded from concession award process
The Forestry Administration, which is responsible for the area, was excluded from the process of adopting concession documents and decisions on granting concessions. They were only left to warn of possible damage after the contract was signed.
In addition to the Administration, the Ministry of Agriculture, Forestry and Water Management (MAWM) has also criticized this concession.
"Given that the munika, as an endemic species of the Balkan Peninsula, is on the Red List of Threatened Plant Species of the International Union for Conservation of Nature (IUCN), we note that the bans on its logging were established in the process of harmonizing our legislation with the legislation of the European Union in the pre-accession phase and that we are already obliged to implement them," they pointed out in a letter sent by the Minister Vladimir Jokovic, on behalf of the Ministry of Mining, Oil and Gas (MNOG), forwarded it to the Ministry of Mining, Oil and Gas (MOM) on January 31, 2025, three and a half months after the concession was signed.
The letter sent by the Ministry of Forestry and Forestry to the MRNG points out that the Forestry Administration and this Ministry were not consulted in the process of adopting concession acts and decisions on granting the concession.
"Since the Forest Administration, as the manager of the area in question, did not participate in the adoption of the concession act, nor was it informed at all by the competent authority about the intention to conclude a concession agreement for the area it manages, the question of the legitimacy of the agreement in question arises," Joković's department stated.
On the other hand, Minister Šahmanović's department claims that the public debate on the Draft Concession Act was held from January 22 to February 15, 2024 and that all competent institutions, including the Ministry of Labour and Social Affairs, were duly notified.
The entire project was initiated by the Ministry of Energy and Mining, headed by the current mayor of Podgorica. Saša Mujović, which informed the competent institutions about the public hearing via a public call. The call was, among other things, also sent by e-mail to the cabinet address of the Ministry of Social Affairs and Health.
"The Ministry of Labour and Social Affairs did not submit any comments or suggestions to the aforementioned letter," MRNG stated.
The Ministry of Forestry and Forestry did not respond to CIN-CG's inquiry about whether they had received an invitation and, if so, why they did not participate in the public hearing. The Forestry Administration, however, confirmed to CIN-CG that they were only informed about the concession contract 14 days after the deal was concluded.
Ministries disagree on the legality of the work
The Ministry of Environment and Water and the Administration, together with eight environmental NGOs, are questioning the legitimacy of the concession agreement, pointing to a number of procedural shortcomings.
Joković's ministry, in its letter to Šahmanović's department, states that the observed shortcomings in the development of the concession granting plan, concession act and decision on granting the concession limit the full realization of the concession right.
On the other hand, MRNG claims that the entire process was carried out in accordance with the law.
"As the chronology of the procedures carried out shows, the then Ministry of Energy and Mining conducted the concession award procedure in accordance with the law, taking into account the protection of the public interest."
The CDE warns that inadequate protection and lack of transparency in the concession approval process have led to uncontrolled exploitation of natural resources without any sustainability strategy:
"Institutions must take appropriate measures and act in accordance with the Law on Nature Protection and the Law on Forests."
In addition to warning the authorities that the law must be respected, the CDE sent an urgent message to all competent institutions.
"If they do not act in accordance with the law, we will contact the competent inspectorates. If the inspectorates do not react, we will hold the authorities responsible for their work accountable," they say.
Non-transparent change to the PUP
In July 2024, four months before Minister Šahmanović signed the concession agreement, the Government's decision on amendments to the Spatial and Urban Plan (SUP) of the Municipality of Nikšić entered into force. In the graphic part of that decision, the subject site (KO Kuta II) was defined as a mineral deposit and an exploitation field.
The Forestry Administration claims that it only received information about the change in the purpose of the plot it manages, which is included in the concession area for the exploitation of mineral raw materials, after the concession agreement was concluded.
"Until the date of submission of the concession contract, the Forest Management Department of the Administration did not have information about the change in the purpose of the plots managed by the Administration as forest and forest land, which are part of the concession area for the use of mineral raw materials," states the request for instructions on how to proceed that the Forest Management Administration sent to the Ministry of Agriculture on January 21, 2025, half a year after the amendment to the PUP.
The CDE expresses concern about the changes to the Nikšić Municipality's PUP, emphasizing that changing the purpose of protective forests through clearing is prohibited by Article 45 of the Forest Law.
"A worrying fact regarding the changes to the Nikšić Municipality's PUP is that the concession decision was preceded by a change to this plan. According to the new changes, the site in question (KO Kuta II) is defined as a mineral deposit and an exploitation field, while it was previously recognized as a forest area within the Župa-Štitovo management unit, managed by the Forest and Hunting Management Administration," says Mićanović from the CDE.
DOO "Novi Bauxiti" emphasized that red bauxite ore has been exploited in the immediate vicinity of the site in question for decades and that there are four active mines there.
"The location in question, where we were given the contract with the Government of Montenegro to conduct geological research and exploit red bauxite deposits, has been the subject of a concession call three times in the last twenty years," the company told CIN-CG.
A map of the Kuta II site, prepared by CIN-CG based on a technical study by the company “GeoFriends”, confirms that bauxite is being exploited in a small part of the site. However, the new concession agreement, legitimized by the PUP, envisages the expansion of the mine area and large-scale logging of mostly protected forests.
The CDE points out that the exclusion of the Forestry Administration from the process of amending the RAP further indicates the lack of transparency and lack of coordination in making such important decisions.
"Therefore, we demand an urgent review of the adopted decision and the suspension of all further activities in order to prevent the brutal devastation of protected forests."
Instead of the ecological aspect, they valued the archaeological aspect
According to information from the Forestry Administration, the concession act states that the then Ministry of Energy and Mining requested the opinion of the Administration for the Protection of Cultural Heritage, which determined that there are no legally protected archaeological sites at that location.
"A review of the documentation concluded that the cultural property 'Stari rudnik, Župa' is located near the concession area, however, it does not include the concession area and is located more than 500 meters away," the Directorate for the Protection of Cultural Heritage told CIN-CG.
The Law on the Protection of Cultural Property stipulates that geological research and exploitation of mineral resources cannot be carried out in areas where cultural property is located, nor in their immediate vicinity, without prior consent from the Administration.
However, additional controversy is caused by the absence of an environmental aspect in the concession decision-making process. Namely, the Directorate for the Protection of Cultural Heritage states that they are not competent for the issue of nature protection, and refers to the Environmental Protection Agency.
The Environmental Protection Agency (EPA) confirmed to CIN-CG that an impact assessment has not been conducted. However, in accordance with the Law on Environmental Impact Assessment, the project developer is required to submit a request to the EPA for a decision on the need for a study.
"The concessionaire is obliged to conduct a preliminary environmental impact assessment procedure in the exploration and exploitation area of 'Block No. 4', when planning and implementing the investment project, in accordance with the law," reads the draft Concession Act prepared by the then Ministry of Energy and Mining at the end of 2023.
On the other hand, "Novi Bauxiti" told CIN-CG that, according to the information they have, the aforementioned study is not necessary for the research work they are currently doing in accordance with the project.
The Forestry Administration believes that it was necessary to prepare an environmental impact assessment before concluding the contract in question.
"Novi Bauxites" under investigation for marking concession area
The suspicion that the deal was finalized even before the official signing of the contract is fueled by a criminal complaint filed by the Forestry Administration. Namely, a month before the signing of the contract, the Nikšić branch of the Forestry Administration filed a criminal complaint against unidentified persons, who were also suspected of being employed by the company "Novi Boksiti".
"The report was filed because unidentified persons marked the area under forest and forest land (sections 81a and 125a, management unit 'Župa-Štitovo') under the jurisdiction of the Forestry Administration without its knowledge and participation."
The Basic State Prosecutor's Office (ODT) in Nikšić responded to CIN-CG that a case has been opened regarding this report and that all legally prescribed measures and actions are being taken to collect relevant facts for making a decision in this case.
"After receiving verbal information that a criminal complaint had been filed against us, we requested and received official information from the ODT in Nikšić that no complaint had been filed against us. We do not even understand why a complaint would have been filed. We signed a concession agreement with the Government of Montenegro, i.e. the Ministry of Mining, Oil and Gas," the company "Novi Boksiti" told CIN-CG.
The Nikšić-based company "Novi Bauxiti" is majority-owned Nenad Bajović (80 percent), and the co-owner with a 20 percent share is Ivan IvanovicBajović is the owner of “Autoprevoz Bajović”, and Ivanović is the owner of the company “Rapax”.
Termination of the contract does not cause harm to the state.
Two months after the contract was signed, "Novi Bauxiti" requested a meeting with the Forestry Administration to implement procedures for logging the area over which they have concession rights. "Novi Bauxiti" claims that the Administration did not respond to their persistent calls.
This company states that they only learned about the existence of the mine in the concession area at the beginning of this year.
"After learning about the alleged existence of the mine, our engineers determined that the area where the mine is allegedly located on the maps, which does not mean that it is actually there on the ground, only partially overlaps with the concession area where research is currently being conducted, due to fires and other factors," they emphasize.
They add that, if ore of appropriate quality is found that is profitable for exploitation in an area where it is determined that there are munika, underground exploitation could possibly be carried out, which, they believe, would not endanger the munika.
Due to the numerous unknowns surrounding this case, Šahmanović's department states that Article 18 of the Concession Agreement stipulates under what conditions the grantor, or rather the state, has the right to terminate the agreement:
"We emphasize that paragraph five of the same article stipulates that in the event of termination of contracts defined in this article, the concessionaire is not entitled to compensation for damages," Šahmanović's ministry told CIN-CG.
Symbol of resistance
The Munika is a species that grows at high altitudes, between 1.200 and 2.000 meters above sea level. This tree can reach a height of 20 to 30 meters and is distinguished by its thin and green needles, arranged in pairs, as well as by its cylindrical cones, about 7-12 cm long. The bark is gray-brown and rough, especially on older specimens.
The munika is not only a plant that survives in extreme conditions, but also represents an extraordinary example of adaptation to nature. Its ability to grow in high mountains, on rocky terrain and in harsh climatic conditions makes it a symbol of resilience.
The Forestry Administration says that the munika forest is spread over an area of 10.541 hectares in Montenegro, which is two percent of the total forest wealth. It is most abundant in the municipality of Nikšić (803.474 cubic meters), followed by the areas of Danilovgrad, Kolašin, Podgorica and Andrijevica.
The munika is a long-lived species, which can live for hundreds of years. In 2019, experts estimated that there is a munika tree in the Andrijevica area that is over 1500 years old, they named it Radmilo.
This longevity makes the mountain a valuable biological resource, as its forests, which are among the oldest and most natural in Europe, provide a haven for unique mountain fauna and support biodiversity that could otherwise be threatened by deforestation or climate change.
Its presence is an indicator of the health of the mountain environment in which it grows. Due to its sensitivity to climate change, its distribution and growth can provide precise signals about the impact of environmental changes, making it a reference point for ecological and conservation studies. For these reasons, the munica is not only a plant to be admired for its beauty and strength, but also an important element for the conservation of the natural environment.
The munika tree, as an endangered tree species, is protected in Montenegro by the Law on Nature Protection, and at the international level by the European Habitats Directive, the European Biodiversity Strategy, the International Union for Conservation of Nature (IUCN), the Convention on Biological Diversity (CBD) and the Bern Convention.
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