The Spatial Plan of Montenegro (PPCG) until 2040, which the Government approved at its session on June 12, opens the door to mass urbanization of areas where construction has not been allowed until now, and is particularly critical of the Buljarica area, which investors have long had their eye on.
Experts claim that several laws were violated when the PPCG was adopted, and that this most important document after the Constitution is too extensive and lacks a vision of sustainable development.
The plan is also full of contradictions. For example, the textual part of the Plan states that Buljarica is an area of exceptional importance for nature conservation, but the graphic presentation of the PPCG says that the entire location will be converted into an urban-construction area, which opens the door to mass urbanization and destruction of natural habitats. Center for Investigative Journalism (CIN-CG) Ksenija Medenica, from the Center for Bird Protection and Research (CZIP).
This was not the case in the Draft PPCG until 2040, which was prepared by the previous Government, nor in previous plans, where this area was always presented as a natural zone, with a very limited scope of permitted construction.
The Ministry of Spatial Planning, Urbanism and State Property (MDUP), headed by Slaven Radunović, did not deny to CIN-CG that the Buljarica area was left without protection in the Plan, but emphasized that the Municipality of Budva will decide on the level of urbanization of this valuable area:
"The PPCG shows the boundaries of the General Urban Developments, but does not define construction areas in detail. At a more detailed/lower planning level (municipal PUP), construction areas will be defined, including in the Buljarica area, taking into account all restrictions from the aspect of spatial protection."
CZIP suspects that, given the statements of Prime Minister Milojko Spajić and Arab investor Muhamed Alabar, this land rezoning, which was done overnight, is precisely the basis for the implementation of an investment from the United Arab Emirates (UAE), based on the recently signed agreement with this country. Alabar emphasized that he is interested in construction in Buljarica.
The plan was established without a Strategic Environmental Impact Assessment report, which was supposed to be prepared by the Environmental Protection Agency (Agency). The Agency, headed by Milan Gazdić, told CIN-CG that they did not prepare a Strategic Environmental Impact Assessment report because the PPCG “was adopted before the deadline for submitting the report.”
The Ministry told CIN-CG that the Agency, on its own initiative, suspended the procedure for granting approval for the report on June 16, which, according to them, means that the Agency did not decide upon the Ministry's request.
In any case, the Law on Strategic Environmental Assessment has been violated, according to which the PPCG cannot be adopted without this report.
According to unofficial information from CIN-CG, a compromise was made between the Ministry of Spatial Planning and Urbanism and the Agency in order for the plan to be adopted.
On the same day that the Plan was approved by the Government, the Agency issued an opinion that did not mention Buljarica, nor did it mention numerous other protected areas that the Plan put at risk of excessive construction and devastation of the environment and biodiversity.
When CIN-CG asked the Agency why they did not raise the issue of Buljarica, they said that they had "sent comments on the draft versions of this document on several occasions, and each one included Buljarica as a protected area and an area recognized by international treaties as particularly valuable from the aspect of nature protection."
"As far as the Agency is concerned, the value of Buljarica as a habitat goes beyond national boundaries," the Agency stated.
One in the text, the other in the picture
The Agency's opinion on the Montenegro Nature Conservation Plan, worded in just a few sentences, only addresses the issue of Komarnica and Velika Plaza by name. The Agency states that in one part of the Plan, Komarnica is treated as a protected natural object, while in the energy part, it is planned as a hydropower facility.
"Most protected areas are presented in the same way," the opinion reads.
They also raise the issue of Velika Plaza, which, they say, is presented in one part of the Plan as an extremely valuable area from a protection perspective, while in another part it is written that it has "the greatest potential for the development of an exclusive tourist complex, at the state level."
"If the Agency had acted in accordance with applicable laws and its own powers, a realistic and timely opportunity would have opened up to remove the 'Komarnica' HPP from the draft Spatial Plan," the Montenegrin Society of Ecologists (CDE) stated, accusing the Agency of evading the application of the law.
The PPCG states that "the 'Komarnica' HPP project is the most technically ready for implementation, however, from the aspect of spatial protection and environmental impact, it does not have support from the institutions responsible for environmental protection."
The Plan states that the study "Regional Strategy for Sustainable Hydropower in the Western Balkans", WBIF, which was prepared for the needs of the Western Balkans Investment Fund, classifies the "Komarnica" HPP as an environmentally friendly project, and that the European Commission has identified four specific projects that will be supported, including the project to build the "Komarnica" HPP.
However, the Komarnica Case Study, prepared by the organization Sačuvajmo Komarnica, states that this plan is economically and energetically unviable, that the plans for this HPP used data that is several decades old, and that it could cost close to 480 million euros. Contrary to the claims in the Spatial Plan, they point out that the construction of the HPP would violate numerous EU directives, including the EU Water Framework Directive, as well as the Bern Convention, and the UNESCO World Heritage Center (WHC) has also expressed concern about this natural area.
Recently, European Parliament member Thomas Weiss claimed that the closure of Chapter 27 in negotiations with the European Union (EU) will depend on the protection of Komarnica, the Ulcinj Saltworks, and the dunes on Velika Plaza.
According to projections in the PPCG, the Komarnica HPP would produce about 670 GWh annually, which is, as stated, about 40 percent of the average annual production of the Pljevlja TPP. In contrast to this estimate, the experts who prepared the Komarnica Case Study calculated that under ideal conditions it would produce three times less electricity - 213 GWh, which is only a few percent of Montenegro's total energy needs.
Despite all these findings, the department headed by Radunović claims that "Montenegro needs the 'Komarnica' HPP", reminding that the construction of this HPP is foreseen by the valid planning documentation, and that the decision will be made after the final position on the environmental impact assessment.
The law was also violated regarding public debate.
Experts warn that the plan was also adopted illegally because there were no public discussions regarding key changes.
The public debate on the Draft PPCG lasted from January 29 to April 29 last year, and during its duration 449 proposals, comments and suggestions were received. The plan has since undergone significant changes, around Buljarica, Velje brdo and the drawing of a large number of new roads, so by not organizing a new public debate in this way, the law was also violated. The Law on Spatial Planning states that if there are significant changes to the planning document, a new public debate must be conducted.
The Ministry told CIN-CG that it disputes the claims that the law was violated. They state that the entire process of drafting the PPCG was transparent. They say that these are minor changes to the Plan.
"There were no legal reasons for holding a new public hearing," the Ministry claims.
"I agree that the PPCG proposal was passed in a non-transparent manner, considering that the public debate was a long time ago, and that there were a number of objections from both the public and civil sectors. Another public debate should have been organized at which the Plan with the changes and new solutions would have been presented to the public, especially in the traffic section, where citizens are very interested," a spatial planner, who asked to remain anonymous, told CIN-CG.
Experts CIN-CG spoke with claim that the Plan still states sustainable development as the main development goal, although guidelines on how to achieve such development have not yet been clearly defined, along with practices that implement unsustainable development.
The plan envisages the construction of over 200 kilometers of highways, more than 300 kilometers of expressways, wind farms, in addition to "Komarnica" and the "Kruševo" hydroelectric power plant, a railway from Podgorica to the airport in Golubovci...
Velje brdo is also in the Plan. However, it is marked as a natural area, while the textual part mentions a megalomaniacal construction project at that location.
"The Spatial Plan of Montenegro, which the Government adopted a few days ago, raises deep concerns from the aspect of nature protection and respect for legal procedures. There are numerous reasons for such concern, and the first and main one relates to the process of drafting and adopting the document itself, which was non-transparent, chaotic and in many aspects illegal," Medenica points out.
Energy independence
According to the PPCG, Montenegro should become an energy independent state by 2040. The plan optimistically predicts that the Pljevlja TPP, which produces almost half of Montenegro's electricity needs, will continue to operate until at least 2035 and at most until 2040. In order to replace the electricity from the Pljevlja TPP, in addition to the Komarnica and Kruševo hydroelectric power plants, the construction of new energy plants is planned, five wind farms (WPPs), Brajići, Gvozd, Korita, Bijela and Golija-Smriječno-Goransko Rudnice, as well as 24 solar power plants (SPs).
The spatial plan also foresees the possibility of reaching an interstate agreement on the use of the waters of Lake Bileća.
The Plan also states that the implementation of wind farms will depend on an assessment of possible negative impacts on the population, settlements and the environment.
The PPCG states that there are 38 small HPPs operating in Montenegro, seven owned by EPCG, and 31 privately owned (privileged producers). An interesting calculation in the plan shows that thirty-one private small HPPs produce 152,1 GWh annually, which is symbolic and significantly less than, for example, the Krnovo wind farm, which produces 201 GWh annually. The Ministry for CIN-CG also points out that the construction of the Brajići wind farm is “a very favorable project in terms of electricity, but it requires additional impact on the space and natural and cultural heritage”. In addition to the civil sector, the authorities in the Municipality of Budva are also opposed to the construction of this wind farm.
A novelty in the plan is also the prediction of the use of hydrogen, for which it is stated that the potential for use exists in the areas of: transport, energy-intensive industry (thermal energy), heating...
Expansion of the transport network
The PPCG predicts that the total length of planned highways in Montenegro, with the already constructed priority section, will be around 270 km, while the total length of planned expressways will be around 353 km.
"The planned road network is overambitious, expensive, and not realistic to implement given the financial conditions and situation in Montenegro," says a CIN-CG source, who wished to remain anonymous.
The biggest changes to the planning solution occurred in the traffic section where several new expressways were planned: the Andrijevica-Montenegro-Peć border expressway; the northern expressway, Pljevlja-Bijelo Polje-Berane-connection to the highway; the Pljevlja-Žabljak-Nikšći-Danilovgrad-Podgorica-connection to the highway; the Podgorica-Tuzi-Božaj expressway; an extension of the road from Bar to Ulcinj is planned.
The Ministry says that the planned network of roads is ambitious, but that the planned development requires serious investment in traffic infrastructure: "The Plan explains all roads, provides optional solutions, and defines priorities for implementation in road and all other forms of traffic."
Our source says that the route of the highway from Podgorica to Bar is planned around Lake Skadar through Crmnica, a problematic route from the aspect of morphology and topography (settlements, landslides, springs, destruction of the ambient values of the area). He also points out that the position of the planners was to expand the existing road from PG to Bar across the lake to the level of a high-speed road (bearing in mind that the reconstruction of the railway across the lake is underway), and not to build a highway on this stretch. However, this was not accepted by the Government and “Monteput”.
The highway route from Podgorica to Bar is planned to bypass Lake Skadar, because according to the Law, a highway cannot be planned through the National Park, the Ministry told us, explaining that the option of expanding and reconstructing the existing road and railway across Lake Skadar has been left open.
The CIN-CG source also points out that the route of the expressway over Luštica is also very problematic, from the aspect of the impact on the ambient values of the protected area: "The route is called coastal and bypasses Tivat and Kotor, where traffic problems are most pronounced. The planners' position was to try once again to get UNESCO approval for the crossing over the bay, the Sv. Neđelja-Opatovo bridge, and if that was not achieved, to abandon the expressway, however, the Government and 'Monteput' insisted on the crossing over Luštica via the expressway," says our source.
The Ministry says that the route via Luštica was considered through the Preliminary Design, as an alternative to the previously planned crossing in the Sveta Neđelja-Opatovo zone, with the proviso that part of the corridor must be verified through the development of a cultural heritage impact assessment study and an environmental impact assessment.
The Plan states that the airports in Podgorica and Tivat will be further developed and modernized, and it is also proposed that Berane Airport be developed as an international airport.
During the public hearing, the Municipality of Berane insisted on building an airport in this city. It remains for state and local institutions to resolve the problem of illegal construction in the vicinity of the existing runway and the airport zone, the Ministry told us.
Other airports Nikšić - Kapino Polje, Podgorica - Ćemovsko Polje, Žabljak, Pljevlja, Bar and Ulcinj will be developed primarily as airports for special needs, recreational flying, sports flying, seasonal tourist traffic, business and tourist needs. The construction of heliports in all municipalities has also been announced.
It has also been proposed to relocate the Nikšić-Podgorica railway route in part of the valuable archaeological site of Duklja.
It is also positive that the military training ground in Sinjajevina was abandoned, as well as the LNG terminal in the Port of Bar.
An apartment for everyone
"The vision of housing policy for the planning period is to build a society in which there are no homeless people and where all residents are protected from homelessness and poverty, where apartments are available, affordable and energy efficient, with a low carbon footprint, where special attention is paid to the needs of vulnerable population groups and their integration," it is written in the Spatial Plan on future care and total change in the field of housing.
The data from the 2023 Population Census shows that there are around 170.000 empty apartments in the territory of Montenegro, and that due to the lack of affordable apartments on the rental market, it is necessary to put all available vacant apartments into operation, which, as stated in the Plan, is the domain of housing policy.
Options also mentioned include the construction of apartments for sale at more favorable terms, the construction of apartments for the free market, the construction of social housing apartments for rent to vulnerable and other low-income groups of the population, and the construction of apartments for rent according to market principles.
"During the preparation of PPCG-2040, the Government of Montenegro launched an initiative and made a decision to build a residential settlement in the Velje Brdo area, with the aim of providing a certain stock of apartments under affordable conditions and with control from the state level. At a more detailed/lower planning level, spatial capacity, infrastructure equipment and protection of the space will be defined, with the aim of implementing the project, which is defined as a project of public interest. The construction of apartments should not be left to the exclusive regulation of the market," the plan states.
CZIP also points out in this example that for Velje brdo, the textual part states planned urbanization under the auspices of "public interest", while in the graphic part the same area is marked as "other natural areas", which is in direct contradiction to the planned content.
"A particular concern is the appearance of a new paragraph in the textual part of the plan that refers to the Velje Brdo project, a megalomaniacal urban development project that envisages the construction of a settlement for around 40.000 residents. The Government of Montenegro previously tried to push this project through the Spatial and Urban Plan of the Capital City, but due to the stormy reaction of the professional public and citizens, the process was suspended and now inserted into the state plan, with the intention of subsequently re-proposing it through local plans on that basis. This is a change that is significant enough that, according to the current legislation, it should have caused a reopening of the public debate. However, this did not happen, which violated the legal procedure and rendered public participation meaningless for the umpteenth time," says Medenica.
In addition to Podgorica, mass urbanization, which was not foreseen in the Draft, is also taking place in other municipalities, such as Kolašin, Nikšić, Bar, Ulcinj, Herceg Novi...
Demographic projection
By creating better economic and infrastructure conditions in all regions, it is expected that in the first phase of the planning period, internal migration will begin to decrease, and after 2030, migration from the Northern region and depopulated municipalities of the Central region will be stopped, which would also stop the decline in the population in the Northern region, the Plan states. It also envisages a return to municipalities from which there has been mass emigration in previous decades, if the development of the Northern region envisaged by the Plan is achieved. But this is also in conflict, because on the one hand, the construction of entire settlements in Podgorica and the Coast is planned, while there is talk of revitalization and a return to the North, experts warn.
Optimism does not only apply to the north, but also to the entire country, so the Spatial Plan states that Montenegro, which according to the 2023 census had 633.090 inhabitants, will have 2040 in 684.045. Reputable international institutions, including the United Nations, have warned that Montenegro could have significantly fewer inhabitants in a few decades.
The data presented in the Plan do not support this optimism either. Statistics on students in primary schools in Montenegro show that this number is constantly declining, as in the 2005/06 school year there were 74.872 students, and in 2022/23 there were 69.922.
"In the 21st century, the number of pensioners in Montenegro is constantly increasing. The fact that pensioners make up almost a fifth of the Montenegrin population represents a great burden for the state in terms of financing its obligations," the Plan states.
One of the main goals of the plan is to reach the EU average in terms of wages and purchasing power of citizens, as well as quality of life, by 2040. However, it is not clear on what basis this assessment was made, especially considering the worrying demographic trends, but also the insufficient concern for sustainable development.
Five years lost, regulations under which the Plan was developed changed
The original deadline for the development of the PPCG expired in 2020, so the adoption of this strategic document, the most important after the Constitution of Montenegro, is five years late, so instead of the legally prescribed 20 years, it will be valid for 15 years until 2040.
Architect Borislav Vukićević reminds CIN-CG that the decision to develop the Plan was made by the Government of Duško Marković in 2018 and that the deadline for development was supposed to be two years from the appointment of the head of the PPCG development, which happened in 2019.
He also raises the issue that the legal regulations regulating this area have been changed in the meantime, and that the Spatial Planning Agency has been established, so we can expect that this Plan, prepared under the old law, will have to be prepared again.
"Neither this government, nor the previous one, is willing to acknowledge that the situation in the areas of planning and urbanism has gotten out of control, which would then indicate the need for a thorough reform of the planning system," Vukićević points out.
Bonus video:
