GI Let's Save Sinjajevina: Finally overturn the decision to establish a military training ground

The civic initiative "Let's Save Sinjajevina" requested today that the decision from September 2019 on the establishment of a military firing range in Sinjajevina be finally repealed.

As they remind, this decision was made without prior democratic debate, ignoring multiple civil protests, petitions and public appeals, which, they claim, grossly violated the basic rights of local communities to participate in decision-making on issues that directly affect their existence and environment.

"Today, as herders prepare for a new climb to Mount Sinjajevina, which is under UNESCO protection, despite numerous promises from several governments in the past five years, this harmful and illegitimate decision has still not been repealed. We recall that Prime Minister Milojko Spajić, during a meeting with representatives of the initiative in January 2023, clearly stated: 'There will be no construction of military training grounds on Sinjajevina'. We believe that it is high time that this promise is finally materialized and made official through a formal decision by the Government of Montenegro," states the text of the initiative submitted to the Government by "Let's Save Sinjajevina".

They pointed out that the Agency for Nature and Environmental Protection conducted a study in 2016, which was also financed by the European Union, and which unequivocally showed that Sinjajevina meets all the criteria to be a regional nature park.

"We would like to remind you that the Citizens' Initiative Save Sinjajevina asked the Ministry of Defense back in October 2020 whether they were aware of a number of facts, namely:

1. That the planned military training ground is located within the transitional area (zone) of the Tara River Canyon Biosphere Reserve, and that there are important facts and norms that must be respected regarding this internationally protected UNESCO area? Let us note that the transitional area - the Biosphere Reserve area, is defined as an area in which communities foster socio-culturally and ecologically sustainable economic and human activities.

2. That at the time of the decision on the location of the military training ground, the legal procedure for establishing a protected natural asset in the Sinjajevina area was underway, and that this area should have been placed under protection in accordance with the Spatial Plan of Montenegro until 2020. The "Study on the Protection and Establishment of a Protected Natural Asset in the Sinjajevina Area" was carried out in July 2016 as part of the project: "Sinjajevina", for the implementation of which the municipalities of Mojkovac, Kolašin, Žabljak, Šavnik and Danilovgrad received funds from the Delegation of the European Union to Montenegro through the Inter-municipal Development Grant Programme. The "Sinjajevina" project was implemented by the Municipality of Mojkovac in partnership with the municipalities of Kolašin, Žabljak, Šavnik and Danilovgrad. In accordance with the activities and objectives within this project, the Sinjajevina area should have been placed under protection already in this project 2016/2017.

3. It must be determined how the provisions of the EU Directive on the Conservation of Wild Birds (Directive 2009/147/EC of the European Parliament and of the Council of 30 November 2009 on the conservation of wild birds) will be implemented in the Sinjajevina area, given that a potential area of ​​special interest for birds - SPA has been identified in this area with an area of ​​39.240 ha. Namely, within the IPA project "Establishment of Natura 2000 in Montenegro", which was financed by the European Union with three million euros, the Sinjajevina area was identified as a potential area of ​​special interest for birds - SPA with an area of ​​2009 ha, based on EU standards in the field of nature protection (EU Directive on the Conservation of Wild Birds - Directive 147/30/EC of the European Parliament and of the Council of 2009 November 39.240 on the conservation of wild birds) (source: Rubinić, B., Sackl, P. & Gramatikov, M., 2019: Conservation of wild birds in Montenegro. The first inventory of potential Special Protection Areas in Montenegro. AAM Consulting. Budapest xiii +328 pp.).

4. That the manner in which the obligations under the Bern Convention will be implemented must be determined, given that the Sinjajevina area, more precisely Babji zub (Torna) and Gradište, has been identified as one of the areas within the Emerald network in our country.

5. That it is necessary to determine the manner in which the obligations of the EU Habitats Directive will be implemented in the Sinjajevina area. Namely, during the preparation of the "Study on the Protection and Establishment of a Protected Natural Area in the Sinjajevina Area", in 2015 and 2016, habitats and species from the annexes of the EU Habitats Directive (Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora) were identified in the Sinjajevina area, a total of 10 habitat types and 32 species", the text of the initiative states.

It is added that the question is whether the Ministry of Defense, in the process of making a decision on the location of the military training ground, was informed by the Ministry of Sustainable Development and Tourism and the Agency for Nature and Environmental Protection about Montenegro's obligations under the above-mentioned international conventions and EU directives.

"The two aforementioned EU directives are the legal implementation of the Berne Convention, binding on all EU members, but also on candidates for EU membership. According to Article 9 of the Constitution of Montenegro, 'ratified and published international treaties and generally accepted rules of international law are an integral part of the internal legal order, have primacy over domestic legislation and are directly applicable when they regulate relations differently from domestic legislation'," the initiative concludes.