The Montenegrin Society of Ecologists (CDE) issued a statement regarding the article "Green instead of coal-fired electricity: The new Spatial Plan envisages Montenegro being energy independent", which was published yesterday on the Vijesti portal.
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Their statement, signed by Jelena Popović, is reproduced in full:
"The Spatial Plan of Montenegro, in the part relating to the Komarnica HPP, ignores expert opinions, violates environmental standards, neglects economic indicators and bypasses democratic procedures.
Although the project is based on data that is several decades old, although it has not received an environmental permit and approval from the Environmental Protection Agency, and its cost-effectiveness analysis has not been conducted, the Komarnica HPP is still being promoted as a key energy solution.
This approach not only endangers one of the most valuable natural areas in Montenegro and Europe, but also distracts attention from real solutions and alternatives in the energy sector.
Representatives of EPCG and decision-makers, including all previous energy ministers, have publicly and unequivocally stated on several occasions that if the Komarnica HPP project does not receive approval from the Environmental Protection Agency, the project will be abandoned. Today, when that approval has not been obtained and the project has not received an environmental permit, the Plan foresees its construction.
Instead of insisting in the Spatial Plan on projects that will cause immeasurable damage to Montenegro, destroy nature and spend hundreds of millions of euros on a hydroelectric power plant that will produce only a few percent of our total energy needs, Montenegro should focus on improving existing capacities, developing green technologies and a just transition, in accordance with environmental, economic and social standards.
The title of the article published in Vijesti suggests that the Spatial Plan envisages green energy instead of coal. But this is a misinterpretation. In energy terms, "green" denotes technologies that not only use renewable energy sources, but are also designed to have minimal negative impact on the environment and biodiversity. Numerous projects proposed by the Spatial Plan, such as the Komarnica HPP, cannot be considered green in any way. The Environmental Protection Agency did not give its consent to the Environmental Impact Assessment Study for the Komarnica HPP, although EPCG worked for three years on the alleged improvement of the initial very poor document. In addition, an independent economic and energy analysis showed that the Komarnica HPP project is unprofitable and highly risky for Montenegro.
The Spatial Plan presents numerous facts taken out of context, and there is also information that is incorrect and may mislead citizens. It states that energy development cannot be based solely on solar and wind power plants, because they depend on weather conditions, and should be linked to reversible hydroelectric power plants that would be turned on when there is not enough wind and sun, in order to preserve the stability of the system. Although the claim is basically correct, it is completely out of context when applied to Montenegro.
Namely, Montenegro already produces half of its energy from hydroelectric power plants. Instead of focusing on improving existing hydroelectric power plants and developing new technologies that would be connected to the existing infrastructure, the Spatial Plan pushes for the construction of the Komarnica HPP, while EPCG and decision-makers have never conducted a cost-benefit analysis of the project. Here is the first, but not the only "rabbit in the bush". The claim made in the Plan that the Komarnica HPP could produce 670 GWh annually - which represents 40 percent of the average annual production of the Pljevlja Thermal Power Plant - is completely new and previously unknown information, and experts assess it as inaccurate and technically unattainable.
The official EPCG project documentation for the Komarnica HPP states that it would produce only 213 GWh per year, which is only a seventh of the energy provided by the Pljevlja TPP. In addition, this projection is questionable, because the data is based on hydrological values that are several decades old, and today's water availability in this part of Montenegro is declining under the influence of the climate crisis. The claim that Komarnica is "acceptable for the EU" can only refer to the fact that the Komarnica area has been proposed for protection as a natural area of exceptional value at the EU level. However, it is not correct in the context of the construction of the hydropower plant, as implied in the text and the Spatial Plan. The truth is this: the creators of the Spatial Plan refer to the study "Regional Strategy for Sustainable Hydropower in the Western Balkans" (WBIF), claiming that the Komarnica HPP is classified as environmentally acceptable projects, and that the European Commission has identified four projects for support - among them the Komarnica HPP.
This is a narrative that has been circulating in public space for years and has been repeatedly denied.
The European Commission did not give the green light for the Komarnica HPP, but only financed the preparation of the above-mentioned study, the summary of which clearly states that the content of the study does not necessarily reflect the views of the EU, and that the list of 45 projects is not an EU evaluation of which projects should be built. The European Commission has clearly stated that the Komarnica HPP and the Kruševo HPP will not be financed from the Economic and Investment Plan for the Western Balkans.
Although proposed by the regional governments, these projects were not selected because they are not aligned with the Green Agenda for the Western Balkans. Instead, the Commission recommends that Montenegro support projects for the reconstruction and improvement of existing hydropower plants, which is also in line with the WBIF analysis. If the construction of the Komarnica HPP is opposed by citizens, independent domestic and international experts in the fields of energy, economics, domestic and international law, ecology, spatial planning, tourism – if they are against the EU and UNESCO, and the consent of the Environmental Protection Agency is also missing – then why is this project, planned in a multiple protected area, still in the Spatial Plan?
The Montenegrin Society of Ecologists, within the framework of the Save Komarnica initiative, has prepared the document "Case Study: Komarnica Canyon", which presents the conclusions of the legal and energy-economic analysis, conducted in cooperation with domestic and foreign experts. The study clearly explains why the Komarnica HPP is not only economically and energetically unprofitable, but also highly risky for Montenegro. The study also offers solutions - an overview of alternative energy projects that the state should focus on.
According to experts, the Komarnica HPP is an extremely expensive, technically demanding and long-term construction project, which, once built, would contribute only slightly more than one percent of the country's annual electricity production. Estimated construction costs range from 480 million euros, while figures between 183 and 343 million are circulating in the public domain. In addition, the study offers a number of alternative solutions that would ensure Montenegro's long-term energy independence, enable the closure of the Pljevlja TPP and the implementation of a just energy transition.
This response deals exclusively with the part of the Spatial Plan that relates to the Komarnica HPP. However, the Plan itself contains numerous other contradictory and controversial information that call into question the sustainable development of a significant part of the territory of Montenegro. The Spatial Plan is not harmonised with environmental regulations, in fact the plan cannot be adopted without the consent of the Environmental Protection Agency on the strategic environmental impact assessment of the plan.
"Given that the final version of the Plan has been significantly changed compared to the one that was available during the public debate, such a document cannot and must not be adopted. It is urgently necessary to return the Spatial Plan to the public debate. Otherwise, CDE, together with other organizations and all interested parties, will launch a campaign, as well as legal actions, in order to prevent the damage that the adoption of the PPCG would bring to Montenegro," the CDE said.
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