The Amendments to the Spatial and Urban Plan (SUP) of Podgorica, adopted in August 2025 without serious demographic, economic and infrastructure projections, also include projects that have been causing strong resistance from experts and the general public for decades - hydroelectric power plants (HPPs) on the Morača River (Zlatica, Milunovići and Raslovići).
Plans to build these hydroelectric power plants were previously suspended precisely because of the high environmental and financial risks, and they first appeared in the second half of the 20th century and were conceived as a system of four dams. The Government of Montenegro under the leadership Milo Đukanović reactivated the project in 2008 and made a decision to develop a Detailed Spatial Plan for Multipurpose Reservoirs on the Morača River, and in 2010, during the term of Prime Minister Igor Lukšić, a Draft Plan with an accompanying strategic environmental impact assessment was also established.
The plan included the Andrijevo, Raslovići, Milunovići and Zlatica hydroelectric power plants, and the estimated value of the investment was around half a billion euros. The tender for their construction, which was announced in 2011, failed, because no bids were received, which was understood as a sign that the project was not economically viable. Experts from the World Bank, namely its International Finance Corporation (IFC), also worked on the assessment of the project and its feasibility, and they assessed that it was a bad and risky solution. Various environmental organizations have also warned for years that building dams would have serious consequences for the environment, endangering Lake Skadar, changing the course of the Morača River, increasing the risk of landslides and flooding settlements, jeopardizing the water supply and destroying the natural ecosystem in the canyon. It was particularly emphasized that a project in an earthquake-prone area such as this one carries additional risks for Podgorica.
Hydropower plants on the Morača River are not only mentioned in the amendments to the Podgorica Regional Development Plan, but are also, albeit discreetly, included in the controversial, recently adopted Spatial Plan of Montenegro (PPCG):
"The Electric Power Company of Montenegro (EPCG) is also developing other potential hydroelectric power plant projects, exploring the optimal way to realize the recognized hydrological potential on the Ćehotina and Morača rivers, taking into account all relevant aspects, especially energy, environmental and economic."
From the Ministry of Spatial Planning, Urbanism and State Property (MPPUDI) for Center for Investigative Journalism of Montenegro (CIN-CG) They say that the amendments to the Regional Development Plan do not plan the specific construction of hydroelectric power plants on the Morača River, but that "it is listed as one of the potential development directions, which is in line with the PPCG."
“The re-introduction of hydropower plants on the Morača River in the amendments to the Podgorica Urban Development Plan is an attempt to revive a project through lower-level planning acts that is not recognized in either the Spatial Plan of Montenegro or the Draft National Energy and Climate Plan, which was submitted for comments to the Energy Community. Citizens and experts have already proven that this is an economically unprofitable and pointless project that would destroy areas of international importance (EMERALD and potential Natura 2000 habitats),” the environmental activist and energy coordinator at the CEE Bankwatch Network told CIN-CG. Natasa Kovacevic.
She also points out that, without the transfer of the Tara River into the Morača, the water potential would be insufficient, which would mean a violation of the international Convention on the Protection and Use of Transboundary Watercourses and International Lakes (Water Convention).
"Montenegro already has 63,55 percent of renewable sources in its energy mix, but as much as 90 percent of that energy comes from hydropower plants, which led to shortages and high import costs during the droughts from 2019 to 2022. Instead of returning to outdated and high-risk hydropower projects, the country needs urgent diversification, i.e. investment in solar and energy efficiency, whose share today is only less than one and a half percent."
Hydropower plants depend on stable watercourses, and extreme droughts, heat waves and changes in precipitation, all consequences of climate change, lead to reduced water inflows and increasingly frequent production outages. In addition, dams change the natural course of rivers and destroy habitats, and building them today means investing in a system that is becoming unsustainable precisely because of climate change. Instead, experts recommend a shift towards solar and wind, which are more resilient to climate extremes and do not destroy aquatic ecosystems. This is why the construction of HPPs is increasingly risky and harmful, and many countries are opting for other ways of generating electricity.
The Morača Canyon is a habitat for more than 115 bird species, and, as stated in the Environmental Impact Assessment of Dams on the Morača River on Birds of the Morača Canyon and Skadar Lake (Assessment) from 2009, the construction of dams on the Morača River would drastically affect the state of the flora and fauna of the canyon, and would also have incalculable consequences on the state of the environment downstream.
"Submerging the canyon upstream would permanently destroy habitats for birds to live, breed, and feed, and would drastically change the qualitative and quantitative state of the canyon's ornithofauna. Species that nest on high cliffs and hunt in the more open part of the canyon would disappear, such as eagles, falcons, and owls, for example, as would numerous songbirds that nest in the riverbed itself and in low vegetation or on trees above the water."
It is questionable, the Assessment states, how the change in microclimate and geomorphology due to the submergence of the Morača Canyon will affect two surrounding and already established Emerald habitats in Montenegro - the Mrtvica River Canyon and the Mala Rijeka Canyon.
"Available maps indicate a drastic deterioration of the situation in these canyons as well, with the accumulations from the Morača River expanding and submerging parts of the Mala Rijeka and Mrtvica Rivers, which already have international recognition as Emerald habitats," the document states.
Kovačević points out that Montenegro should look to regional examples of cooperation, where existing hydroelectric power plants serve only to balance solar and wind energy.
Institutions pointed out numerous shortcomings
This kind of planning of large and controversial energy facilities, but also of entire new, bulky settlements, shows that the vision of the amendments to the Urban Development Plan is not based on sustainable planning, but rather on designing projects based on different interests, less often those of citizens, and more often those of well-connected investors.
This is also indicated by the opinions of numerous institutions that were required to give their consent to amendments to the Podgorica Urban Development Plan, which CIN-CG had access to.
The Environmental Protection Agency (EPA) gave its approval, but with the warning that the implementation of the plan must not begin without conducting additional studies and assessments, especially for the Velje Brdo area, which has been designated as sensitive and valuable from a nature protection perspective.
"The planned Velje Brdo project requires the development of a strategic environmental impact assessment, with a focus on hydrology, seismicity, geomorphology, biodiversity, sociological study, impact on demography, biodiversity study, as well as the implementation of the environmental impact assessment procedure," the institution states.
The Montenegrin Transmission System (CGES) formally gave its consent, but with the condition that the planning document be supplemented with guidelines for the reconstruction of the key substation TS 400/110kV Podgorica 2. The station, which is about fifty years old, no longer meets the needs of reliable supply and CGES says that its complete reconstruction is necessary. Therefore, Podgorica does not have a sufficiently secure electricity infrastructure even today, let alone after the construction of new settlements and the planned expansion of housing construction and urbanization that foresee amendments to the PUP.
The problem is also the transport infrastructure. The Secretariat for Transport of the Capital City believes that such a spatial solution is not precise enough when it comes to this. They propose that the amendments to the Urban Development Plan incorporate the current regulations and the Transport Development Strategy of Montenegro for the period from 2019 to 2035 and that the obligations regarding parking in settlements be specified.
Amendments to the PUP are both illegal and illegitimate
Amendments to the Podgorica Urban Development Plan also foresee the construction of golf courses and tourist resorts, opera houses, sports halls, and religious buildings. Podgorica is expected to receive another 20 new apartments in the coming years, although it already has more apartments than households.
“Water Supply and Sewerage LLC Podgorica” only gave conditional approval to the amendments to the Urban Development Plan, because the planned housing development in the Velje Brdo settlement is not in line with the existing capacities of the capital's water supply system.
"In technical terms, if the Velje Brdo settlement and future reservoirs were connected to the existing pressure pipelines from the Mareza spring without a detailed analysis, there is a risk of endangering the entire water supply system in the territory of Podgorica," the company states, insisting that detailed hydrogeological research is necessary to connect new settlements. In addition, they point to other technical shortcomings - imprecisely mapped reservoirs, the absence of certain springs, and the lack of complete documentation on hydro-technical installations.
The Law on Spatial Planning and Construction of Facilities (the Law) does not recognize the category of "conditional consent", consent is either there or there is no consent.
"Water Supply and Sewerage Tuzi" did not give its consent to the new amendments to the PUP.
Without the opinion and consent of the institutions that manage water and sewage, no urban plan should be adopted, because this is basic infrastructure without which settlements cannot expand.
"One gets the impression that spatial changes are being made without applying the principles set out in strategic documents, without any prior analysis, projections or positive planning practices, nor are they accompanied by infrastructure needs, but rather that they are about fulfilling investment requirements," a demographer tells CIN-CG. Miroslav Doderović.
He points out that it is a completely unplanned decision to build more apartments.
"The amendments to the Urban Development Plan do not take into account either the demographic or economic reality of Podgorica," warns Doderović, adding that Podgorica already has around 10.000 empty apartments.
He also points out that the local government has not even adopted a decision to establish an Agency for the Development of Local Planning Documents.
When asked why mass housing construction is planned even though the population in Podgorica has almost stagnated, the department Slaven Radunović They respond that the amendments to the PAP “are not based solely on census data, but also on internal migration, changes in household structure and increased demand”.
Adoption of Amendments to the Spatial and Urban Plan (SUP) of Podgorica were accompanied by numerous illegalities, the first of which relates to the fact that a public debate, which is a legal obligation, practically did not take place, it was only simulated.
The second illegality relates to the responses to the objections, which, contrary to the Law, were published only eight months after the simulated public debate, although the legal deadline is 30 days.
The report from the public hearing was not signed by all members of the Review Council, but by the only spatial planner on the Council. Dragoljub Markovic publicly distanced himself from the document and refused to sign it.
"I did not sign the document, because in essence we do not have planning here, but rather mapping. Instead of a vision for the development of the city, it was just mapping - who needs what and who wants what. The amendments to the Podgorica Urban Development Plan confirm that there is no question of spatial planning here," Marković told CIN-CG.
He states that, if at least part of the space is to be preserved, other plans must be made instead of these.
"They must have a clear vision and rules, not partially amended and supplemented documents created during the real estate boom, when they were created based on the ambitions of everyone selling their field and building a multi-story building on it, where they would sell the apartments to rich foreigners," Marković points out.
The final version of the plan was only published more than a month after its adoption in the Central Registry of Planning Documents, although the deadline is seven days.
The Ministry of Interior Affairs and Public Works told CIN-CG that "the amendments to the Urban Planning Act were drafted in accordance with the law, through all prescribed phases and with the participation of experts and the interested public."
"They were done in compliance with the Law on Spatial Planning and the Law on Spatial Planning and Construction of Facilities, and four public presentations were organized in the process, in Zeta, Tuzi and twice in Podgorica," they state.
"This spatial solution has no social legitimacy. The entire process was conducted in an atmosphere that prevented quality participation in the discussion, and the responses to the comments that citizens managed to send were formal and general. The Review Council dealt with form, not substance, and the only spatial planner on the Council withdrew his opinion and consistently disputed the quality of the document," the researcher at the University Institute of Lisbon (ISCTE-IUL) and member of the organization Who If Not an Architect (KANA) told CIN-CG. Sonja Dragovic.
"In short: there was no public debate, but there will be criminal charges and protests," says Dragović.
She, like Marković, believes that the creation of a new Podgorica Urban Development Plan is the only solution.
"The existing document, in terms of scope and consequences, is actually a new plan, disguised as amendments to avoid the analysis that should be the basis of strategic planning for the next decade."
Dragović also states that in the coming years, Podgorica will most likely slowly become an increasingly worse, hotter, and more uncomfortable place to live.
"With even greater traffic jams, water and electricity restrictions, suffocated in the summer by smoke from nearby fires, and in the winter by smog from home fireplaces, while layers of poorly constructed facades fall onto parking lots (because we no longer have sidewalks, everything is parking lots) under gusts of wind from the north? Podgorica has been heading towards this scenario for decades; I would even say that it is largely living that scenario," she believes.
Despite the long wait, CIN-CG has not received answers from the Capital City to numerous questions regarding the adoption of amendments to the Podgorica Urban Development Plan.
Botun - political manipulation of borders
The wastewater treatment plant (WWTP) in Botun, the construction of which is one of the most important conditions for fulfilling the obligations under the negotiating chapter 27 (Environment and Climate Change) on Montenegro's path to the European Union (EU), is envisaged not only by the Amendments to the Podgorica Urban Development Plan, but also by the Spatial Plan of Montenegro (PPCG) until 2040, which was adopted by the Government. However, both the Municipality of Zeta and the local government, which is dominated by the Democratic People's Party (DNP), the party that voted for PPCG, oppose the construction of the collector, claiming that the project is being implemented to the detriment of Zeta, although available official documents indicate uncertainty as to which municipality the location of the plant belongs to.
At the end of 2017, the Assembly of the City Municipality of Golubovci made a decision unilaterally drawing new borders for its municipality, without the consent of the Capital City and without a separate decision on the borders of Podgorica being made by the Capital City Assembly. At that time, borders were drawn that gave Golubovci a large territory, which, as can be seen, resulted in an irregular border shape (in the form of “teeth”), and the location planned for the WWTP was left outside of that area.
Although the then authorities of Golubovci claimed that Botun was under their jurisdiction, the decision shows that they formally included it in their composition, but in such a way that they avoided including the location for the WWTP. This decision, made during the government of the Democratic Party of Socialists (DPS), was never annulled, nor was it changed by the new government in Zeta. Therefore, the status of the location of the future WWTP remains unresolved, and the process of demarcation between the Capital and the newly formed Municipality of Zeta has not yet been implemented.
The very form of the "teeth" drawn into the borders further fuels suspicions that the territory was manipulated for political reasons back in 2017, which further complicates the interpretation of jurisdiction and the legal framework within which the WWTP project is being attempted to be implemented.
The uncertainties about which territory the location of the future WWTP belongs to leave room for further political manipulation and deepen the controversy surrounding the project itself.
An additional dilemma is introduced by the recent announcement by the Municipality of Zeta that it will hold a local referendum in which citizens would decide on the construction of a WWTP.
Such an initiative would be controversial for several reasons. First of all, the Law on Local Self-Government clearly stipulates that a referendum can only decide on issues within the jurisdiction of that municipality. If the location of the WWTP, according to the current decisions, is not part of the territory of Zeta, the question arises as to how the referendum could relate to it. In addition, the demarcation process has not moved from the deadlock, despite earlier announcements that the issue would be resolved quickly. Such a situation further complicates the issue of jurisdiction, while the current situation indicates that all key powers are in the hands of the Capital City and the Water Supply and Sewerage Company, which is also formally the project investor.
The capital city did not respond to CIN-CG's questions regarding this situation.
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