The agreements that Montenegro recently signed with the United Arab Emirates (UAE), if their implementation begins, could have serious consequences for the nature and the space of Montenegro in general, experts warn.
The path towards concreting protected areas was opened with the recent adoption of the Spatial Plan of Montenegro (SPMG). Despite numerous controversies and criticisms, the SPMG was adopted by the Parliament of Montenegro at the end of June.
"If the Agreement on Cooperation in the Field of Tourism and Real Estate Development with the UAE is implemented, serious and permanent environmental consequences are possible, which are currently unforeseeable," he tells Center for Investigative Journalism of Montenegro (CIN-CG) Ksenija Medenica, a biologist from the Center for Bird Protection and Research (CZIP).
Although the Agreement on Cooperation in the Field of Tourism and Real Estate Development does not specify any specific location, this very vagueness is additionally worrying, warns Medenica.
"This leaves the possibility for the investor to independently select any area of strategic and ecological importance. So far, Velika plaza, Buljarica, Jaz, Hajla, Bjelasica and Sinjajevina have been mentioned in public as potential locations - all sites of exceptional value for nature, some of which are protected at the national level, and all of which have international significance and are recognized as potential Natura 2000 habitats," says Medenica.
PPCG is also planning a hydropower facility in the Komarnica canyon, although the second part of that document states that it is an area under protection.
Unlike the usual bilateral agreements between the two countries, the Agreement on Cooperation in the Field of Tourism and Real Estate Development with the UAE does not contain clauses that allow Montenegro autonomy over the works and projects that the UAE will carry out, he explains to CIN-CG. Časlav Pejović, Professor Emeritus, Kyushu University Faculty of Law, expert in international law.
This important clause, which is included in bilateral agreements by countries that are concerned about their own interests, is called the “right to regulate.” This clause provides countries with protection if a foreign investor with whose country a bilateral agreement has been signed builds against the interests and regulations of the country in which it is investing, explains Pejović.
"In this way, the environment is protected, among other things. According to the Agreement between Montenegro and the UAE, such protection does not exist," says Pejović.
However, since this clause was not previously included, Montenegro gave priority to the interests of investors, explains Pejović.
"Under the current Agreement, Montenegro would be liable to investors from the UAE if it enacted regulations that would jeopardize the interests of investors," says Pejović.
Pejović gives the example of an agreement signed between the UAE and India, in which both countries protect the public good, if one of the countries intervenes against the interests of investors, to prevent a negative impact - this is not considered a violation of the Agreement.
Medenica also points out that Montenegro cannot protect itself from the destructive effects on nature based on an agreement with the UAE. This, she says, is best seen in the example of Velika Plaza, where there was insight into the conceptual design of the project by an Arab investor. The implementation of the presented mega investment of apartments and resorts from the UAE, which has so far been prevented by the resistance of local authorities and activists, would have catastrophic consequences for biodiversity, she warns.
"It would destroy the habitats of rare and endangered plant and animal species, including as many as 35 of the 48 endangered birds in Montenegro. It would also lead to the degradation of the only known location in Montenegro for the hatching of the loggerhead turtle. It would also damage the coastal dunes, which are priority EU habitats, protecting the beach from erosion and protecting Ulcinj from flooding," says Medenica.
Velika Plaza is an ecologically key area, with exceptional biodiversity and the status of a protected natural area, claims the biologist.
"An infrastructure project of this scale would lead to irreparable loss, and is in direct contradiction with domestic laws, international obligations and strategic documents on nature protection," said Medenica.
Buljarica one of the most endangered areas
The adopted PPCG seems to have been created to make concessions to investors' mega projects, rather than to protect the area and enable sustainable development of the country. The PPCG envisages significantly more construction in almost all municipalities, compared to the version of the plan that was at the public hearing.
The PPCG is particularly worrisome when it comes to Buljarica, which CIN-CG has already written about. While the textual part of the Plan states that Buljarica is an area of exceptional importance for nature conservation, the graphic presentation of the PPCG turns the entire location into an urban-construction area, which opens the door to mass urbanization and destruction of natural habitats.
In a statement to CIN-CG, CZIP previously expressed suspicion that this land rezoning was done overnight, given the Prime Minister's statements. Milojko Spajić and investors from the UAE Mohamed Alabara who also expressed interest in Buljarica. Alabar emphasized that he is interested in construction in Buljarica, and part of the local population who owns land in this location has also expressed a desire to negotiate with the Arab investor.
According to the PPCG, not only in Buljarica, but in the entire municipality of Budva, a significantly larger construction area is planned than in the version of the Plan that was at the public hearing. And although the city center itself has long been devastated, it seems that the next in line are the hinterland, which in the version of the plan at the public hearing was a protected zone, and the hinterland of Jaz, a beach for which Alabr also expressed interest.
Buljarica has long been threatened with concreting. Back during the rule of the Democratic Party of Socialists (DPS), the Government of Montenegro, through the Privatization Council, announced a tender in 2016 for the sale of Buljarica, without the consent of the Municipality of Budva and private land owners. At that time, the construction of 40 thousand apartments, or 11,5 million square meters of residential and commercial space, of which as much as 9,3 million would be apartments, villas and apartments for further sale, or the market. The project did not go through due to resistance from the local population.
Buljarica Bay is one of the few remaining fresh-salt marsh areas on the Adriatic coast, surrounded on the sea side by meadows of Posidonia oceanica seagrass, which is protected by international and domestic legislation, according to the research Buljarica: Paštrović's Treasure on the Tycoon's Table, by the Network for the Affirmation of the Non-Governmental Sector (MANS) and the Montenegrin Society of Ecologists (CDE).
Many other plant and animal species living in the Buljarica area are protected at the national and international level, and there are high-value ecosystems, especially from the perspective of the Natura 2000 ecological network and marine protected areas, this publication states. The ecosystems of the Buljarica wetland area are home to a very rich flora and fauna, and Buljarica is one of the areas richest in resources on the entire Montenegrin coast, this publication states.
"In the hinterland of Buljarica beach, there is a dense belt of reeds that gradually turns into meadows, and later into a forest of oak, ash, elm and olive groves. The hills surrounding the valley are covered with macchia and cultivated olive groves. The pronounced biodiversity in such a small area on the Adriatic coast illustrates the ecological complexity of Buljarica, but also its vulnerability," the study states.
Buljarica is home to 41 species of dragonflies, 11 species of amphibians, 93 species of birds, and this location is home to as many as 36 types of habitats, including endemic and relict species of plants and animals.
Although the Environmental Protection Agency (EPA) and the Ministry of Ecology in the Government Dritan Abazović In 2022, they announced the protection of this area as unique in the Adriatic, but this did not happen. Back in 1968, in the former Yugoslavia, the value of the coastal part of Buljarica was recognized, which was then protected as a Natural Monument. Buljarica was also nominated for the Emerald Network of Protected Areas, but this protection system has not yet come to life in Montenegro. Today, the entire area is almost completely unprotected, especially the wetland part.
Neither the PPCG nor the strategic impact assessment for Velika Plaža protects this area.
The adopted PPCG also provides for significantly larger construction land compared to the version that was at the public hearing and when it comes to the municipality of Ulcinj, including Donji Štoj, the central part of the municipality, and the part planned for construction on Velika Plaza.
The Strategic Impact Assessment (SIA) for the State Study of the Velika Plaza location was formally prepared and was subject to public consultation at the end of 2023. However, this document has serious limitations both methodologically and substantively, leaving the beach deprived of the protection from investments announced in the agreement with the UAE, warns Zenepa Lika, architect and president of the Dr. Martin Schneider-Jacoby Association (MSJA).
"The text of the SEA clearly speaks about the sensitivity of the terrain, while at the same time the planning document allows for high storeys (from five to 10 floors), occupancy of up to 50 percent and interventions in areas that should have limited use. This discrepancy sends a bad message - that the assessment is being used as a formality, and not as a real tool for nature protection. Unfortunately, in this case, the SEA conceals more than it resolves key issues, thus calling into question the sustainability of the overall planning," warns Lika.
Construction works and infrastructure in this area entail: loss of habitat due to backfilling, leveling and concreting of the soil, disruption of the hydrological regime, including changes in the inflow and quality of water in wetland systems, pollution during and after construction (wastewater, light and sound pollution), fragmentation of space, which permanently disrupts the natural connection between Solana, Velika Plaza and Ada Bojana, states Lika.
But the loss is not just ecological, the architect explains.
“The landscape of Velika Plaza is one of the last untouched in the Mediterranean - a wide, free, sandy plain that provides a rare sense of spatial width, peace and natural silence. It is a place where nature and man still share space without conflict. Velika Plaza is not only the longest sandy beach in Montenegro, but also the largest untouched beach in the former Yugoslavia. Its value lies not in luxurious construction, but in the natural dignity it carries.”
Velika Plaza and its hinterland represent one of the richest habitats of plant and animal species on the Montenegrin coast, especially those protected by national and European legislation. It is a Key Biodiversity Area, which places it on the global map as very significant. In the Velika Plaza zone, 22 plant species with protection status have been identified - endemic, relict and priority species for protection. Among them is the sea daffodil (Pancratium maritimum), which grows exclusively on dunes and is one of the most sensitive plant species in the Mediterranean. As many as 18 habitat types from the EU Habitats Directive have been recognized in the area of the Ulcinj municipality, including: gray and white dunes with vegetation (priority types), Mediterranean salt steppes, estuarine and lagoon systems, wet depressions between dunes, which are extremely rare in Montenegro, and as many as 240 bird species have been recorded in this area.
He is also a recent member of the European Parliament. Thomas Weiss claimed that the closure of Chapter 27 in negotiations with the European Union (EU) would depend on the protection of Komarnica, Ulcinj's Saltworks and the dunes on Velika Plaza.
The identity of Montenegro is being lost.
By destroying protected areas through mass construction, not only is the landscape lost - the recognizable character and biodiversity of Montenegro are erased, which means the loss of local, national and Mediterranean natural heritage, says Lika. If such interventions are carried out, for example on Velika Plaza or Buljarica, the consequences will be irreversible - some of the last untouched landscapes of the Mediterranean would be permanently lost.
In Montenegro, spatial planning and architectural design have been under pressure for decades from generic, investor-led, uninventive construction, which diminishes local spatial qualities and undermines the existing values of architectural heritage, he explains to CIN-CG. Sonja Dragovic, researcher in the field of urban planning and space.
"However, the destruction of the characteristic ambience along the coast through excessive construction, which in recent years has spread to the tourist centers of the north, such as Kolašin and Žabljak, is not the result of the bad taste of individual investors, but of the systemic responsibility of the competent institutions: the authorities that adopted and implemented 'development' policies that amounted to privatization, the ministries that led spatial planning, local governments, and the main state and city architects," explains Dragović.
In this context, the question of whether investments in real estate construction come from the UAE, Canada, or the European Union becomes secondary, explains Dragović.
"The key is how the legal and planning framework is designed. If the Spatial Plan envisages maximum exploitation of space through intensive construction, this automatically generates interest from investors who see this as an opportunity for good profits: more square meters, more money from sales! In this process, not only the quality of architecture, but also long-term sustainability and public interest are regularly sacrificed," says Dragović.
The current PPCG until 2040 creates the basis for further growth in interest in real estate investments. Given the recently concluded agreement favoring economic relations with the UAE, it is realistic to expect that part of these investments will come from there.
"The plan, in general, opens up space for investments of this type, through structurally adjusted mechanisms that stimulate further intensification of commercial construction. Therefore, it is illusory to expect that this construction would be significantly improved by the arrival of some 'better' or 'greener' investors, as long as the regulatory framework persistently forces quantity over quality. Even the most sensitive architects cannot create a sustainable and context-adapted solution if the task is to extract the maximum square footage from each plot. We can clearly see the results of such an approach in Budva, in the neighborhood below Ljubović, in Kolašin...", explains Dragović.
"The problem is, therefore, systemic. In Montenegro, there are small, dedicated initiatives that are trying to advocate for different approaches, such as KANA, Expeditio and other responsible individuals. However, their influence on changing public policies in this area remains at the level of incidents," Dragović emphasizes.
According to her, there is a lack of strong institutional support for a vision of spatial development that would be focused on long-term sustainability, equitable spatial development, and careful treatment of the landscape and existing cultural and spatial values, instead of short-term profit.
"Unfortunately, at this moment I don't see any option from the existing political scene that could seriously - with arguments, confidently, energetically - stand behind such a vision," says Dragović.
UAE Agreement - a basis for investors to "invest" in protected areas
Despite the numerous criticisms of the agreement - and the resistance that has so far proven strong in Ulcinj, smaller Montenegrin municipalities in the north say they believe that investments from the UAE will contribute to the country's development. Several mayors have had the opportunity to meet with Alabaro, to whom they have proposed projects in valuable protected areas.
The signing of an agreement with the UAE, which is used as a basis for inviting investors to invest in exceptional natural areas, such as Bjelasica, Bogićevica, Prokletije, Sinjajevina and others, raises serious questions about the vision of the country's development, warns Medenica.
"These areas, which according to all expert criteria should be protected as Natura 2000 zones, are today being offered to investors as if they were nobody's property, without a clear strategy, expert assessment and public consensus," says Medenica.
"The agreement with the UAE represents a significant step forward in the international promotion of the potential of the Municipality of Berane and represents a path to new investments, which will lead to new jobs, the development of tourism infrastructure and the improvement of the local economy, as well as the promotion of the natural resources of this region," the Municipality of Berane told CIN-CG.
This municipality was among the first to submit proposals for investment projects after learning about the arrival of UAE investors. They particularly highlight the development of the luxury tourist complex Jelovica Luxury Retreat, located on the Jelovica site, on the Berane side of the Bjelasica mountain, which is among the most important potential Natura 2000 habitats. This means that investors should be especially careful when it comes to such areas.
In Berane, as the Municipality says, they are hoping for investments that could be considered "sustainable".
"The goal is to valorize the municipality's natural resources in a way that is sustainable, environmentally responsible and in line with the strategic development plans of Berane," say the Municipality of Berane.
The Municipality of Gusinje highlights the beauty of the Prokletije Mountains as its most important resource. They have proposed projects related to Mount Bor, which is part of the Prokletije Mountains, the Grlja River Canyon in the village of Vusanje, and Ali-paša Izvore to investors from the UAE, Gusinje Municipality Mayor Sanel Balić told CIN-CG.
The Mayor of Plav Municipality, Nihad Canović, said earlier that the municipality had submitted detailed projects to Alabro, presented him with the Bogićevica location, and expressed satisfaction with the reactions of investors from the UAE to the proposed projects. He also expressed hope that the local economy would experience a boom thanks to investors from the UAE.
Similar enthusiasm was expressed by the mayor of Kolašin, Petko Bakić, who proposed to Alabaru construction on Sinjajevina and Bjelasica.
"The competition between local governments in who will offer the investor a better piece of land is only a reflection of the complete inability of state and local structures to plan, use and protect what is most valuable in the long term. Instead of valorizing these natural resources through sustainable development models - such as eco-tourism, scientific research and entrepreneurship, local governments are indiscriminately offering them through this agreement, the constitutionality of which is questionable, and whose implementation in other countries (the example of Belgrade on the water) has already caused numerous controversies and harm to the public interest," warns Medenica.
According to her, giving these spaces to investors means permanent loss - loss of citizens' rights to access nature, loss of ecological and landscape values, and loss of future development opportunities. Local communities are in turn offered the role of cheap labor, while profits and control are shifted out of their hands, all to the detriment of nature.
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