The document, the updated Nationally Determined Contribution (NDC) of Montenegro for 2030 and 2035, which the Government of Montenegro adopted earlier this year, although of key importance for Chapter 27, will be difficult to implement because it is based on imprecise data and an insufficiently clear plan, experts claim.
This document should be a platform for reducing greenhouse gas emissions, improving energy efficiency, encouraging renewable energy sources, improving air quality and protecting the environment. All this is necessary for Montenegro to respond to the demanding tasks of the European Union for closing the negotiating Chapter 27, but also to the obligations arising from the Paris Agreement, to which our country is a signatory.
The NDC aims to reduce greenhouse gas (GHG) emissions by 55 percent by 2030, and 60 percent by 2035. GHG gases contribute to global warming by trapping heat in the atmosphere, such as carbon dioxide, methane, and nitrous oxide. The Paris Agreement commits countries to reduce emissions as part of a joint fight against the negative impact of climate change.
The documentation he obtained Center for Investigative Journalism (CIN-CG) shows that this is another plan that the Government adopted without explaining in detail how it will be implemented.
Unclear plans and inaccurate data
Director of the Center for Climate Change UDG Ivana Vojinović says that the new document lacks data on the quantitative effects of each individual activity or at least sector to achieve the goal of reducing emissions by 55 percent.
"The NDC cites as references for its development some strategies that have not yet been adopted, such as the National Biodiversity Strategy, the National Energy and Climate Plan, the National Adaptation Plan, the National Waste Management Plan, etc."
International experts also question some aspects of the document. One of the many objections of the Energy Community Secretariat (ECS) is that it is not clear how the target of reducing GHG emissions by 2030 will be achieved. They state that the policies and measures do not seem realistic given that the key measures relate to reducing emissions at the Pljevlja Thermal Power Plant (TPP), improvements in the waste sector and the rapid adoption of electric vehicles.
"Although it seems ambitious that Montenegro can achieve a plan to reduce GHG emissions, it is clear that this would most likely mean closing the Pljevlja thermal power plant, or putting the plant into the role of a cold reserve, most likely as early as 2030," he tells CIN-CG. Natasa Kovacevic from the CEE Bankwatch Network, a global network operating in Central and Eastern Europe.
The new draft of the National Energy and Climate Plan of Montenegro (NECP) for the period until 2030 was prepared with the technical support of a consulting team engaged by the German Society for International Cooperation (GIZ), the Ministry of Energy and Mining told CIN-CG. In parallel, a Strategic Environmental Impact Assessment for the NECP was also prepared.
The Ministry said that the key policies and measures envisaged by the NECP are: accelerated development of new electricity capacities based on hydropower and solar and wind energy, further development of the buyer-producer concept and establishment of energy communities, development of transmission and distribution network capacities and application of energy storage with the aim of efficient integration of new energy sources, the importance of investing in energy efficiency, especially in improving the existing building stock, reducing emissions in the transport sector through the accelerated introduction of electric vehicles, modernization of public transport and removal of old cars, implementation of a just transition in the coal region and decommissioning of the Pljevlja thermal power plant in 2041.
THERMAL POWER PLANT HAS BEEN OPERATING ILLEGALLY FOR YEARS
The Pljevlja Thermal Power Plant has been operating illegally since the end of 2020, after spending 20 thousand operating hours allocated in accordance with the Large Combustion Plants Directive, while the Energy Community opened a case against Montenegro in April 2021 due to this violation.
To continue operating the TPP, they launched a modernization project to bring the power plant into compliance with EU pollution standards, and the Chinese company Dongfang Electric International Corporation was selected as the contractor in 2019.
The main works have been postponed several times and are scheduled to start in 2025. In a move considered illegal, Montenegro amended national laws to allow the plant to continue operating, which is now expected to shut down between 2030 and 2035. In December 2024, Montenegro submitted a draft National Energy and Climate Plan (NECP) to the SEZ, announcing further delays and the planned closure of the plant in 2041.
The planned coal phase-out by 2035 is questionable, given that the Pljevlja TPP is planned to be used until 2040 and beyond as a cold reserve. The draft NECP does not offer clear steps or a framework for a just transition, and the SEZ is seeking clarification on how the coal phase-out by 2035 fits into these plans, as well as more information on measures to ensure a just transition.
Former Chairman of the Board of Directors of the Coal Mine Dusan Janjušević says that an alternative to coal currently does not exist and new technologies such as hydrogen are still being developed.
"There is no need to play with energy stability, because a country that lacks energy and food is moving into modern slavery."
"The decarbonization process is slow due to dependence on the Pljevlja Thermal Power Plant, which provides a significant portion of electricity, from 40 to 50 percent, and the transition to renewable energy sources requires significant investments and a long-term strategy that is not sufficiently developed in Montenegro. What has been positive in the energy sector recently is the start of construction of the 55 MW Gvozd wind farm, as well as a greater focus on valorization of solar potential," says Vojinović.
FALSE EXCUSES JOB FOR THE PROSECUTOR'S OFFICE
The thermal power plant does not have an integrated permit for the prevention and control of environmental pollution, which it was obliged to obtain under international treaties, which have primacy over national legislation. The government has not taken any concrete measures to address this problem. Instead, illegal operations are justified, while emissions of harmful gases persist at worrying levels.
At the end of 2023, the SEZ did not accept the arguments of the Government and EPCG that the late ecological reconstruction, which is not carried out according to the standards for the construction of new thermal power plants, would bring the future operation of the Pljevlja thermal power plant into line with EU and EC regulations.
They concluded that Montenegro had violated EU Directives and the Treaty Establishing the EU, which means that the Pljevlja TPP cannot meet the requirements for obtaining an operating permit and thus extend its lifespan with such ecological reconstruction.
"It is understandable that EPCG and the government are still trying to delay the entry into force of the EU and SEZ decisions and the accompanying financial sanctions through subsequent legal actions that would seriously jeopardize or completely prevent the further operations of TE Pljevlja due to violations of regulations. On the other hand, it is completely unreasonable and incomprehensible that, despite the clear position of SEZ and the EU, they continue to finance the implementation of the controversial environmental reconstruction, which will cost between 150 and 200 million euros, according to official estimates," he told CIN-CG. Dejan Mijović economic analyst.
The only novelty is that now the leaders of EPCG and the Government are violating the public interest, aware that their decisions are in conflict with SEZ and EU regulations, and even domestic legislation. All this raises suspicions that these individuals are not motivated by public but rather by particular interests, explains Mijović.
"Two directors of the TPP have resigned in the last few months, the executive and technical directors, due to dissatisfaction with the implementation of the reconstruction works, while now there is talk in expert circles that the backup boiler could run on fuel oil," explains Kovačević.
Plans for the construction of the secondary network of the Pljevlja Thermal Power Plant are not progressing, which puts the project at serious risk, which is why the Ministry of Energy and the Prosecutor's Office must urgently conduct an investigation and determine irregularities, in order to ensure accountability and prevent further consequences for the project and the environment, says Kovačević.
PLJEVLJA STILL WITHOUT A JUST TRANSITION
Pollution that threatens the health of Pljevlja residents is increasing, bringing new premature deaths. According to the CEE Bankwatch Network report "Comply or Close", in 2023 alone, sulfur dioxide emissions from the thermal power plant amounted to 44.017 tons, nitrogen oxides 3.982 tons, while dust particle emissions increased from 560 tons in 2022 to as much as 1.130 tons in 2023.
Given that the Government has not provided a detailed explanation of the planned activities, the achievement of the target of 55 percent reduction in greenhouse gas emissions is uncertain, and there is a risk that it will not be met in the next five years. As a general rule, nature is the strongest ally in the fight against climate change, the preservation and protection of forests, rainforests and wetlands can provide effective emission reduction, adaptation and mitigation of climate change, says Vojinović.
"Unfortunately, there is no serious and adopted just transition plan for Pljevlja, although the path is clearly marked. Pljevlja is the only city where a just transition can truly be just. Every mining city, and especially a country that depends on mining, must be prepared to exhaust these resources at some point and move on to new types of activities. The mineral resources it has, as well as the geographical position of Pljevlja, clearly outline the direction of future development," explains Janjušević.
THE MOST IMPORTANT GHG GAS IN MONTENEGRO IS CO2
The fourth national report and the first biennial transparency report of Montenegro to the United Nations on Climate Change 2024 (the Report) states that the overall trend in GHG emissions from the energy sector shows growth, with an increase of 13,6 percent in the period from 1990 to 2022, 33,62 percent.
In 2022, the most important greenhouse gas in Montenegro is CO2, with a share of 77 percent. CO2 emissions mainly come from combustion activities, primarily in coal-fired power plants, but also from road traffic, the Report states.
In order to respond to EU requirements and obligations under the Paris Agreement, Montenegro should make realistic plans, which will primarily relate to the Pljevlja TPP due to greenhouse gas emissions.
Remarks of the Energy Community Secretariat
The NECP represents the umbrella strategic document of Montenegro in the field of climate and energy policy. As such, it sets out the main objectives and priorities related to the reduction of greenhouse gas emissions, the improvement of energy efficiency and the development of renewable energy sources.
In December 2024, the Ministry of Energy sent the draft NECP to the Energy Community Secretariat for comment. CIN-CG has reviewed the comments of the Energy Community Secretariat, which contain a number of detailed objections.
Based on these comments, the Ministry has updated the NECP and the Strategic Impact Assessment. The final draft should be sent to the SEZ in mid-June 2025, followed by adoption of the document by the Government after a positive opinion.
"The NECP has numerous shortcomings, in addition to the inconsistent years of coal phase-out and the year of closure of the Pljevlja TPP, it is completely unbelievable that the document was sent to the Energy Community without first being sent for comments to interested parties. The document does not address the socio-economic status of Pljevlja as the municipality most affected by the transition," says Janjušević.
And SEZ points out that a public debate should be held on the draft NECP, as well as a thorough and comprehensive assessment of the cumulative environmental impacts of continuing the operation of the Pljevlja TPP until 2040.
The SEZ comments also emphasize that Montenegro must clearly define a target year for achieving climate neutrality. Policies and measures should also be reformulated to be more specific, improved to provide more precise information on their impact on the 2030 targets for renewable energy sources and GHG emission reductions.
"The draft NECP contains elements that appear to have been written several years ago but were not updated before submission. The combination of outdated and recently added information makes it difficult to understand Montenegro's real plans," the SEZ comments read.
Although the preservation and enhancement of natural carbon sinks is extremely important, it should be borne in mind that the goal of the Paris Agreement and the NDC stemming from it, as well as the EU Energy and Climate Framework by 2030, is the decarbonization of national economies, i.e. the gradual elimination of fossil fuels and the transition to renewable energy sources. When we look at the updated NDC of Montenegro in this context, it is clear that it lacks key information precisely on the decarbonization of the energy sector, which, without LULUCF (land use, land use change and forestry), accounts for 75 percent of GHG emissions in Montenegro, Vojinović tells CIN-CG.
"Since we still do not have a National Energy and Climate Plan, the question arises as to how this assessment was arrived at, because we lack precise and quantified data on the gradual shutdown of the Pljevlja TPP with a just transition of Pljevlja and the switch to renewable energy sources, which had to be the basis for the calculation of the NDC," explains Vojinović.
“The draft NECP contains significantly outdated information, with paragraphs reflecting the situation from the last quarter of 2021. Consequently, the data and information included in the document are not relevant, and this section needs to be thoroughly updated to reflect the latest available data and developments. Also, references to legal acts, such as the Energy Law and Market Rules, in the section Current energy and climate policies and measures related to the five dimensions of the Energy Union are outdated and need to be revised to be aligned with current legislation. National targets and specific deadlines must be clearly defined in accordance with the provisions of the Electricity System Integration Package,” the SEZ commented.
Global impact of TPP
A new report by the US-based Global Energy Monitor (GEM) has recorded an important turnaround in coal-fired electricity generation in 2024: the smallest amount of new coal-fired capacity opened in the last twenty years.
The closure of thermal power plants in the European Union (EU27) has increased fourfold, while the United Kingdom (UK) has closed its last coal-fired power plant - becoming the sixth country to completely phase out the use of coal for electricity generation since the adoption of the Paris Climate Agreement in 2015.
In member countries of the Organization for Economic Cooperation and Development (OECD), the shift away from coal to other energy sources has been particularly pronounced - the number of proposed new power plants has fallen from 142 in 2015 to just five currently.
Japan and South Korea remain exceptions among OECD countries, as they continue to build and plan new coal-fired power plants.
In Southeast Asia, the number of new coal-fired power plants is decreasing, and countries such as Indonesia and Malaysia are announcing a gradual exit. A similar trend is visible in South America, where most countries are giving up coal - the exceptions are Brazil and Honduras, while Panama announced a complete shutdown by 2026.
In Africa, although renewables and gas dominate, new projects in Zimbabwe and Zambia - backed by Chinese investors - run counter to Beijing's 2021 pledge not to build any more coal-fired power plants outside China.
Bonus video:
