Civil engineer Nenad Rubežić and independent councilor in the Pljevlja Municipal Assembly Saša Ječmenica filed a criminal complaint with the Basic State Prosecutor's Office in Pljevlja, as citizens, against several officials at the Electric Power Company of Montenegro (EPCG), claiming that the Pljevlja Thermal Power Plant was illegally put into so-called trial operation, without fulfilling legal requirements, which led to extreme air pollution and a serious threat to the health of citizens in recent days.
The report states that it was filed without any political or other illicit goal, based solely on the basic human rights of the citizens of Pljevlja and the right to a healthy environment.
Criminal charges have been filed against the manager of the ecological reconstruction project of the Pljevlja Thermal Power Plant, Ljubiša Janković, the manager of the boiler adaptation project, Slavenko Drobnjak, the manager of the chimney adaptation project, Olga Radulović, the executive manager of the EPCG Production Unit, Miro Vračar, the technical director of EPCG, Ljubiša Đurković, the acting executive director of EPCG, Bojan Đordan, as well as other responsible persons in that state-owned company, for co-perpetration.
The complainants suspect that the reported persons committed the criminal offenses of forging official documents, illegal construction, commissioning and operation of facilities and plants that pollute the environment, as well as abuse of position in business operations.
The application cites as key evidence EPCG document number 10-00-52656 dated November 28, 2025, entitled Consent to put part of the Pljevlja TPP plant into trial operation, which, according to citizens, has been certified as true even though it contains a number of untrue allegations.
The document, as they state, claims that the facility has installed installations, equipment and facilities in accordance with the revised main reconstruction project, that the complete delivery and installation of the equipment envisaged by the project was carried out within the framework of the ecological reconstruction project, that the expert supervision issued a statement that the conditions for putting the facility into trial operation have been met, and that all conditions have been met in accordance with the relevant provisions of the Law on Construction of Facilities.
The applicants claim that the signatories of this document knew that these allegations were false at the time of its signing.
Particular attention is paid to the minutes of the thermal energy inspector of the Ministry of Energy and Mining, Miloš Kovačević, number UP IN-01-724/25-19/3 of December 11, 2025, from which, as stated, it follows that the inspection began on November 28, 2025, the same day when the disputed consent of EPCG was issued.
The minutes state that the inspector contacted the technical director of EPCG, Ljubiša Đurković, that day, and that they agreed on the method and dynamics of conducting inspections, and that he clearly warned that before issuing a decision on trial operation, it was necessary to obtain the consent of the electricity, construction, environmental and water inspections. In the same minutes, the inspector states that he learned from the media that the Pljevlja Thermal Power Plant was put into operation and that it was soon out of operation due to problems with the waste transport system, about which he received additional information from Ljubiša Janković. At the end of the minutes, the inspector explicitly announces that he will issue a decision rejecting the request for trial operation, because the legally prescribed conditions were not met.
Despite this, as stated in the criminal complaint, the responsible persons at EPCG, aware of the remarks and warnings of the thermal energy inspector, issued an act on the same day granting consent for the trial operation, which, contrary to the content of the minutes, claims that all legal requirements have been met and that the inspector has given a positive statement. The complainants state that it is particularly significant that the inspector had direct communication with the technical director of EPCG on that day and that he realistically expected that the facility would not be put into operation until the inspection supervision was completed and a decision was made approving the trial operation.
The application further raises the issue of the fact that it is not clear who carried out the expert supervision of the commissioning of the Pljevlja Thermal Power Plant after the environmental reconstruction, since EPCG canceled the public procurement procedure for these services on October 15, 2025, and a new public call was not issued.
It is also questioned whether EPCG formed an internal commission of registered persons in order to avoid the application of regulations on technical inspection, and whether the expert supervision and technical inspection were carried out in accordance with the Law on Construction of Structures.
In their complaint, the citizens of Pljevlja state that the trial operation of a facility under construction, without obtaining legally required permits, with non-functional parts of the plant and without connected desulfurization and denitrification systems, has resulted in serious environmental pollution.
According to their allegations, in the period from November 28, 2025 onwards, there was an uncontrolled emission of large amounts of sulfur dioxide and other pollutants into the air, as well as soil pollution with ash and slag during their transportation and disposal contrary to the project documentation. Of particular note is the period from December 10 to 15, 2025, when, according to them, the pollution was extreme, especially during the night hours of December 13, when the SO₂ concentration reached a level of 805 micrograms per cubic meter of air.
The applicants believe that EPCG has in this way abused the institute of trial operation from the Law on Construction of Facilities, using it as a cover for the operation of a facility that was not completed in accordance with the revised main ecological reconstruction project and without a time limit, with the aim of achieving unlawful material gain through the production and sale of electricity. The application states that the responsible persons, aware of the consequences for human health, continued to operate the facility even in conditions of poor meteorological conditions, thereby further contributing to the endangerment of the lives and health of the inhabitants of Pljevlja.
Finally, Rubežić and Ječmenica state that the described actions have fulfilled all the elements of criminal offenses from the Criminal Code, that the acts were committed in conjunction and that their execution is still ongoing, which is why they expect urgent action from the Basic State Prosecutor's Office in Pljevlja, the Police Directorate and the competent inspection bodies, in order to prevent further environmental pollution and endangering the health of citizens.
The criminal complaint, as they point out, was filed in the interest of the citizens of Pljevlja who, despite the fact that the Thermal Power Plant entered the process of ecological reconstruction to reduce emissions, were put in a situation of being exposed to long-term and increased air pollution precisely due to the commissioning of the plant without key ecological systems.
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