MERS: What knowledge does Saveljić have about the state body in which he works and in which he represents the "gray eminence"?

The Ministry of Ecology, Sustainable Development and Northern Development (MERS) reacted to the article "With this law, there is no nature protection: ASK gave a number of recommendations on the draft regulation of the Ministry of Ecology" published on June 5 on the Vijesti portal.

We transmit the response in full:

"First of all, it is important to emphasize that the Draft Law on Nature Protection has not yet been adopted at the session of the Government of Montenegro, that is, it is in the phase of harmonization with the institutions of the European Commission, which is a regular procedure before the adoption of any law, or by-law and strategic act, in the process of our European integration. Despite this, in some media and on social networks, the impression has been created that the law has already been adopted and entered into force, which is therefore not true.

Bearing in mind the numerous comments (here, we are primarily referring to the reactions of individual users of social networks, to which some Montenegrin media, for reasons and motives known to them and which we do not intend to go into, give space and importance), on the text that has not yet gone through the complete adoption procedure, the Ministry of Ecology, Sustainable Development and Northern Development considers it important to present the facts to citizens and further clarify certain solutions contained in the draft legal text.

In the spirit of transparency and openness, which represent one of the basic principles of MERS' work, we provide detailed explanations below so that the public is timely and accurately informed about the content and objectives of this legal solution.

We would like to point out that the draft Law on Nature Protection was subject to public debate from 8 June to 18 July 2023. Regarding the allegations that the version of the law from the public debate differs from the current text of the draft law, we would like to point out that certain comments and suggestions received from interested parties were accepted during the public debate. Also, since the end of the public debate, the text has gone through several iterations of harmonization within the working group formed for its development, with the participation of professional institutions, as well as an expert from the European Commission engaged through the EU4Green project.

We also note that at the end of last year, the text of the law was submitted to the European Commission for consideration, after which it was further harmonized in accordance with the submitted comments, all with the aim of fully transposing the relevant acquis communautaire in the field of nature protection. We particularly emphasize that no objections were submitted to the provision that has been presented as controversial in recent days.

Regarding the submission of the text to the competent institutions, we would like to point out that the text of the draft law, which contained a provision relating to the construction of facilities in the second protection zone, was submitted to the Environmental Protection Agency on October 15, 2025 for information and additional harmonization. From that moment to today, no objections or initiatives to amend the provision in question have been submitted.

It follows from the above that there was no need to obtain the draft law through informal or 'unofficial' means (and we despise such 'feats', because the transparency of MERS's work is at the highest level, and, after all, we respond very meticulously to every inquiry from anyone), and therefore there is no basis for the claim that employees of the Environmental Protection Agency were not familiar with the content of the regulation in question.

When it comes to the allegations relating to the opinion of the Agency for the Prevention of Corruption (ASK), we would like to point out that this is not an extraordinary procedure or a case that was in the special focus of this institution, as presented in the title and on the front page of 'Vijesti'. This is a regular procedure for obtaining opinions on draft regulations, in accordance with Article 40 of the Rules of Procedure of the Government of Montenegro. Therefore, for the sake of the Montenegrin public, MERS regularly consults ASK in its work, especially in the procedures for drafting legal regulations, precisely with the aim of eliminating the risk of the subsequent development of corruption.

Given that most of the ASK's comments relate to insufficiently precise definitions of terms, such as 'permanent impairment of biological diversity', 'negative impact of traffic on nature' or the formulation 'to the extent that the basic values ​​of the area are not impaired', we point out that similar general formulations are used in other regulations in the field of environmental protection. Their specific application and interpretation are carried out through environmental impact assessment procedures, which are regulated by a special law and which contain clearly defined criteria, methodologies and procedures for determining and assessing impacts.

Based on the comments of the ASK, as well as on the written proposal of Mr. Saveljić that, although the norm has a control mechanism - the issuance of a permit by the competent administrative body, namely the Environmental Protection Agency (where he is employed), - this does not represent a sufficiently adequate and sustainable instrument of control in practice, we point out that, wishing to increase the level of nature protection, we have decided to remove the provision in question from the text of the draft law. Mr. Saveljić was also informed of the aforementioned decision in a timely manner.

However, we wonder: what kind of knowledge does Mr. Saveljić have about the state body in which he works and in which he represents the 'gray eminence'? Why doesn't he share this knowledge with the competent prosecutor? What opinion does he have about his colleagues and his superiors in the Environmental Protection Agency? If the media are already giving space to public accusations (which we, especially with the word spoken publicly, have absolutely no problem with), then it would probably be natural for the accusations to be brought to an end and the knowledge that anyone is talking about publicly to be examined. If they are justified and provable – we will have another result in the fight against illegality. If, however, they are not, we will have a public assessment of the credibility of the blanket accusations. Both will be in the public interest of Montenegro, and therefore we support it.

Finally, we would like to note that the development of this regulation took a long time precisely because of the commitment to a transparent and inclusive process, which included multiple rounds of consultations and coordination with the competent institutions, the professional community and the European Commission. In addition, the process required ensuring full compliance with European legislation, implementing the obligations of transposition of relevant directives and applying the best European standards and practices in the field of nature protection.

We also take this opportunity to appeal to your media outlet that when requesting statements on topics of public importance, your journalists leave appropriate deadlines for submitting responses, so that we are able to provide complete, precise and reasoned answers. This is especially important when it comes to complex and significant issues, such as legal solutions that are still in the phase of harmonization and consideration. MERS has, and we believe that it will continue to have, very fruitful cooperation with all media outlets, including yours, and based on this, we believe that more correct deadlines for submitting responses should be given (because the activity of this department is extremely dynamic, considering that we are closing the most difficult chapter – Chapter 27 – and that all the capacities at its disposal are allocated to completing this work as a primary task), and sometimes it is necessary to count on a longer period for responding to the media," reads the MERS response.