Šula residents raise objections to the Draft for granting a concession for the exploration and exploitation of lead and zinc

The residents of Šul have made a number of objections to the Draft Concession Act for the grant of a concession for the exploration and exploitation of lead and zinc at the deposits of "Šuplja stijena", "Đurđeve vode", "Paljevine" and "Ribnik" near Pljevlja, pointing primarily to long-standing problems with pollution, tailings management, water and air quality, and the safety of life in this mining settlement.

The comments, submitted by email, almost entirely related to what the locals claim, that they have been suffering the consequences of previous mining activities for years and, as they state, the lack of clear and publicly available data on the state of the environment.

Olivera Djukovic, an architecture student whose family hails from Šul, questions the fact that new exploration and exploitation activities are being planned without the public ever being presented with the results of systematic air, water and soil monitoring following previous incidents with the tailings pond. She states that for years, locals have witnessed the tailings pond embankments bursting, polluted water spilling into streams that flow into the Ćehotin basin, and the deposition of dust that they suspect contains heavy metals.

He particularly emphasizes that the Draft mentions the formation of new tailings dumps, while, as he claims, the existing ones have not been fully rehabilitated or recultivated. He questions how it is possible to plan the expansion of mining activities without prior, publicly documented insight into the consequences of previous work.

Similar concerns are expressed by Vladimir Djukovic, a doctor and resident of Šul, who directly links the issue of the concession to human health. He is requesting data on air and water quality measurements, information on possible analyses of the presence of heavy metals in the soil and households, as well as data on the health status of miners and locals. He particularly raises the issue of the risk of contamination entering homes through the work clothes and shoes of mine employees, as well as the issue of systematic examinations and long-term monitoring of health consequences.

Environmental activist and local resident of Šula Novak Kusljevic In the comment, he states that obligations from previous tailings management plans, such as dry pressing of waste, installation of protective foils and reclamation, have remained only on paper. He claims that in practice, polluted water has been discharged into surface and underground streams, that certain sources have been diverted for the needs of the mine, and that intensive mining is endangering facilities and sources of drinking water in the settlement.

Radomir Starcevic points to the part of the Draft that states that there are no residential or other facilities in the concession area that could be endangered by exploitation, except for mining facilities. He assesses this claim as extremely irresponsible, because, as he states, it is the residents of Šul who live in the immediate vicinity of mining activities and, in his opinion, have been suffering their consequences for years. He also recalls an earlier environmental incident, which some experts have called one of the largest environmental disasters in the country, when wastewater and tailings reached the source and course of the Ćehotina, with, as he claims, a lack of timely and transparent public information.

Unlike the locals who prioritize the environment and health, the representative of the Union of Free Trade Unions from the mine focuses on the position of the employees. He requests that the Concession Act include an obligation for the future concessionaire to take over the existing workers, as well as a more precise definition of the systematization of jobs. These comments were partially accepted.

Particularly extensive comments were submitted by Krystian Krawiec financial director and president of the Board of Directors of “Gradir Montenegro”, which has used the concession so far. They dispute key data on which the Draft is based.

The company claims that the data on remaining ore reserves is outdated and that the actual quantities of ore at the time of possible takeover will be many times less than shown. They also state that the quality of the ore has been below the projected values ​​from the study for years, which significantly complicates processing and reduces the market value of the concentrate.

They also point out that during the concession period they operated with a loss of around 15 million euros, which, according to them, shows that exploitation under the current conditions is economically extremely difficult and on the verge of profitability. They question the economic viability of certain deposits envisaged in the Draft, claiming that some of them are practically unprofitable for exploitation.

They particularly emphasize that the entire ore processing infrastructure is privately owned by the company, and that this must be clearly defined before a new concession is awarded. They also demand a change in the model for calculating the concession fee, arguing that the current model is unsustainable in real production conditions.

Most of these objections were not accepted, with the explanation that the Draft uses official data and that the method of calculating the concession fee is prescribed by law.

In its responses to citizens' comments, the drafter mainly refers to laws in the field of environmental protection, water and environmental impact assessment, stating that the future concessionaire will be obliged to establish a monitoring system in the entire exploitation area, including Šula. It is also emphasized that part of the concession fee belongs to the municipality of Pljevlja, which can direct these funds according to the needs of the local community.

There was also no specific data on the current state of water, air and soil, as well as no direct reference to allegations of previous incidents that locals cite as a reason for distrust.

The government has launched a new concession procedure for the exploitation of zinc and lead in Šuli near Pljevlja, given that the concession of the Polish-owned company Gradir Montenegro expires this year. The planned concession period is 20 years, of which six months are planned for research, six months for preparation of documentation, and 19 years for exploitation.

The projected annual production is 500.000 tons of ore, which could reach a total of 9,5 million tons during the exploitation period. The estimated total value of production is around 275,5 million euros, or around 14,5 million euros per year.

The minimum concession fee for the state is estimated at more than 11 million euros for the entire period, or around 580.000 euros per year, with the possibility of growth through a variable part that depends on market conditions and production volume.