The Environmental Protection Agency (EPA) has given the Capital City of Podgorica approval for the Environmental Impact Assessment Study for the project to build a wastewater treatment system, the construction of which is planned in the industrial zone of the Aluminum Plant (KAP), on urban plots located in the cadastral municipality of Dajbabe.
The residents of Botun, who have been opposing the construction of the plant for years, say they are not surprised by such a decision, but that they will "defend their village with the only thing they have - their lives."
"The conducted environmental impact assessment procedure determined that the Study was prepared in accordance with the Law on Environmental Impact Assessment and that it contains defined measures to prevent, reduce or eliminate harmful impacts on the environment," the Agency's statement states, among other things.
The decision on granting consent, as it is added, establishes the obligation of the Project Owner to implement the work related to the project for the construction of the wastewater treatment system "in accordance with environmental protection measures", which are determined in the Study and relate to measures for the prevention, reduction or elimination of harmful impacts during the project implementation, exploitation and in the event of an accident, and the Project Environmental Impact Monitoring Program.
It is planned to build a wastewater treatment plant in the KAP industrial zone, on urban plots: UP2F, UP3F, UP4F and UP9F, i.e. cadastral plots/parts of cadastral plots: 1/3, 2/3, 15/3, 23/2, 23/4, 23/6, 27/8, 27/14, 1078/4 1078/8 KO Botun and 1111/45, 2914, 2915, 2916/1, 2917/1, 2918, 2919/1, 2920 KO Dajbabe, Capital City of Podgorica.
The existing wastewater treatment plant for Podgorica was built in 1978 and designed for 55.000 residents.
As stated in the Study, Podgorica, according to the 2023 census, has 179.505 inhabitants, while the wider area encompasses 10,4 percent of the territory of Montenegro and around 28,78 percent of its population.
There can be no pollution of air, water, or soil.
The Study emphasizes that, with the latest systems for purifying gases before release into the atmosphere, "it is guaranteed that the quality of the gases will meet the requirements prescribed by the Regulation on Limit Values for Emissions of Pollutants into the Air from Stationary Sources."
"Two stages of flue gas filters, an electrostatic separator and a fabric filter are sufficient to significantly reduce the dust content, i.e. particles. Should there be an increase in NOx emissions in the Sewage Sludge Incineration Plant, there is a possibility of installing an SNCR system (selective non-catalytic reduction system), since spare nozzles for this purpose are already provided within the fluidized bed combustion technology," the document states.
It was also emphasized that "there is no danger to surrounding water sources and groundwater."
"The newly designed plant would probably be sufficient to approximately reach class A2 of the watercourse even without UV lamps. However, the plant will have germicidal lamps installed, which will almost eliminate microbiological pollution in addition to physical and chemical pollution."
Regarding sludge treatment, the Study specifies that "the flow from reception to incineration in a fluidized bed is designed in such a way that there is no possibility of soil contamination."
"Also, the collected ash from the incineration of sludge will be disposed of so that it is not spread over the surrounding land. The land use at the location in question is industrial, meaning that the implementation of the project in question will not result in the loss of agricultural land."
Flora and fauna are not endangered
The location where the new system is planned to be built is located in the southern part of the capital, in the immediate vicinity of the Aluminum Plant and belongs to the planning document DUP "KAP Industrial Zone". According to this planning document, which covers an area of 483,68 hectares and was adopted in 2019, the new POV is located next to KAP's facilities, and borders its processing plants, water supply wells, a wastewater canal, as well as the road to the settlements of Dajbabe, Zelenika and Botun.
The selected location for the new POV system is 12,7 hectares in size, on the left bank of the Morača River.
The planned gross area of the facility is 6.500 square meters.
As stated in the Study, the project location is not in a zone that encompasses wetlands and coastal areas, and there are no river mouths nearby.
"There is no agricultural land in the location zone, and the location in question is not used as agricultural land. When talking about the regenerative capacity of natural resources, due to the very purpose of the project, one cannot talk about the possibility of regenerative capacity," the document states.
It is also added that "the absorption capacities of the location in question are not large", and therefore "they should be used rationally".
"There is no agricultural land in the project location zone, and the subject site is not used as agricultural land. The project zone does not encompass areas of historical, cultural or archaeological importance," it said.
It also states that, upon visiting the site, "no presence of endangered, rare, endemic and protected plant species was determined" - in accordance with the 2006 list.
"But potentially, in such habitats, the presence of orchids that are protected by law in Montenegro can be expected. First of all, we are referring to Orchis papilionacea, Orchis morio, Spiranthes spiralis and Serapis vomeracea, which have stable and numerous populations in the territory of the Capital City (and beyond), so the impact of this project, in a negative context, does not have to be considered significant," the Study states.
As it is added, "it has been determined that there are elements that the areas in question can potentially be recognized as NATURA 2000 habitats, type 6220 Eumediterranean xerophilous grasslands (Thero-Brachypodietea) and/or 62A0 Eastern sub-Mediterranean dry grasslands that are widely distributed in Montenegro."
"However, the composition of the communities and the current appearance of the site are such that their representativeness is assessed with the lowest grade or is even closer to the status of 'non NATURA'. In this regard, the implementation of the project in question does not have to be viewed through the prism of impact on important habitats protected by the Habitats Directive."
In the part describing the fauna, it is stated that, after reviewing the available professional and scientific literature, it was determined that in the area of the Capital City of Podgorica, "and especially in the part to which the location in question belongs, no systematic faunal research has been conducted", and that "due to unfavorable habitat conditions, it is not realistic to expect the presence of stable populations of small mammals".
"However, due to the presence of favorable microhabitat conditions, it is possible to temporarily retain certain species of birds, reptiles (including snakes), amphibians (near the river), as well as various groups of invertebrates that should have more stable populations in the immediate and/or wider environment."
State-of-the-art technology
The document also states that the planned system is based "on the application of the most modern technologies."
"Which represent the most advanced, technically efficient and practically proven solutions available globally. These technologies include modern engineering approaches, scientific innovations and a high degree of automation, with the aim of achieving maximum purification efficiency, reducing negative environmental impact, as well as full compliance with applicable legislation and European standards," it states.
As it is added, the most modern technology involves the optimization of all phases of the purification process - from the reception and pre-treatment of wastewater, through biological and chemical purification, to advanced sludge processing and controlled discharge of purified water into the recipient.
The facility is expected to have a capacity of around 230.000 residents.
"When designing the SPOV... different load scenarios were taken into account for two design periods, 2035 and 2045, as well as the loads for the expected start of the plant. As the start of construction was postponed, new deadlines were defined," the document states, with the construction start date set for December 29, 12, while completion is planned for May 2024, 1.
It is also planned that sewage sludge produced by wastewater treatment and extracted from primary and final sedimentation tanks will be treated "in anaerobic digesters to decompose organic matter and produce biogas."
“Biogas will be used in the plant to produce heat and electricity using combined heat and power equipment. The remaining digested sludge will be dried and further incinerated in the sludge incineration plant.”
According to the Study, the wastewater treatment plant consists of a pre-treatment unit, which consists of a receiving and protective chamber with a stone catcher, a receiving station for sludge from septic tanks, manual and automatic coarse screens, an inlet pumping station, fine screens, a sand, grease and oil removal plant, a compressor station for the sand, grease and oil removal unit, primary sedimentation tanks, a primary sludge pumping station...
The biological and chemical wastewater treatment plant consists of a tank for anaerobic phosphorus removal, activated sludge tanks (with anoxic, anoxic/oxic, oxic zones), a compressor station for the activated sludge tank, final sedimentation tanks, a return sludge and excess sludge pumping station, and chemical phosphorus precipitation units. Tertiary wastewater treatment and wastewater monitoring consist of a disc filter unit and UV disinfection, while auxiliary units for effluent monitoring, odor control, and bypass lines…
Collector from Mugoša to Mujovići
The project for a new wastewater treatment plant in Podgorica has been discussed for more than a decade, ever since the time when Miomir Mugoša was at the head of the city.
During the mandate of Slavoljub Stijepović, i.e. in 2017, a loan agreement was signed with the German Bank for Reconstruction and Development and a donation of 10 million from the European Union was received.
All this time, the locals of Botun opposed the project.
In early 2020, the then director of Waterworks and Sewerage Filip Makrid and the director of Bemax Veselin Kovačević signed a contract for the construction of a primary collector within the wastewater treatment system. After signing the contract, Mayor Ivan Vuković recalled that this was the project of the century for the Capital, the project to build a wastewater treatment system, with an estimated value of over 50 million euros.
After two years, in June 2022, Vuković re-signed the Contract for the construction of the wastewater treatment plant system. In addition to Vuković, the 3.500-page document was initialed by the then executive director of the Water and Sewerage Company Filip Makrid, and the contractors, the director of the Turkish company Kuzu Group Mehmet Emre Bastopku and a member of the board of directors of the Turkish company Alkatraš, Bauram Albauark. The two Turkish companies, which won the job of building the plant in the 2022 tender, submitted the final draft of the main project, the construction of which should last three years.
After signing, the contractor was required to prepare the main design. The revised version was completed in the third quarter of 2024, thus creating the conditions for the start of work.
Mayor Saša Mujović recently reiterated that construction of the collector in Botun must begin by the end of the year, as this is the only way for Podgorica to get a wastewater treatment system without having to pay tens of millions of euros in damages if the work does not begin...
Botunjani: No construction
Bojan Bašanović, a resident of Botuni and long-time environmental activist, told "Vijesti" that the people of Botuni were "not particularly surprised by this decision of the Agency, which was made after working hours."
"We stand by our previous positions - the Constitution was not respected, but neither were the positions of numerous domestic and international regulations, the profession, professors from England and Germany, and most importantly, the voice of the locals who have been expressing opposition for 21 years. We will defend ourselves and Botun with the only thing we have - our lives, because we owe it to our ancestors and descendants," he stressed.
Jagoš Bećirović, who lives in Botun, said that the construction of the collector is a "fake thing," and that the locals will not allow its construction.
"We will make a statement immediately after Sunday. The story about the construction of the collector is fake," he claims.
He also pointed out that the locals will soon agree on a set of warnings:
"We are fighting for the survival and healthy lives of our children."
Responding to a question from "Vijesti" whether he would sit down at the table and talk again with Mayor Saša Mujović about the collector, Bećirović said that a conversation is possible "only about changing the location."
"We can't talk about construction in Botun. We won't allow the construction of the collector at the cost of our lives."
Another local resident, Boris Ćetković, said that building a wastewater treatment system in Botun is not an option.
According to him, the Environmental Protection Agency's decision is "catastrophic".
"In 20 years, they have not been able to agree on changing the location for the construction of the collector. No mayor can solve this problem. We suspect fraud."
He emphasized that "there is no agreement with the Capital City regarding the construction of a collector in Botun."
"They won't move it. Many bad things will happen if it's built here. While it's in Botunjanina, and also in Zećana, the collector won't be built here," he said.
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