Will there be a dam on Komarnica (animation), Photo: EPCG

Chaos in the spatial planning of Montenegro: The concept is unclear and contradictory

CIN-CG: Experts also question outdated data on the basis of which it is impossible to plan the country's development in the coming decades.

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Will there be a dam on Komarnica (animation), Photo: EPCG
Will there be a dam on Komarnica (animation), Photo: EPCG
Disclaimer: The translations are mostly done through AI translator and might not be 100% accurate.

The Komarnica hydroelectric power plant, the military training ground on Sinjajevina, the port of Virpazar, the gas pipeline, the Adriatic-Ionian highway, the high-speed road from Ulcinj to Herceg Novi... These controversial projects were included in the concept of the spatial plan of Montenegro (PPCG), which was completed at the end of last year. .

Based on the concept, the Draft PPCG is being prepared, a fundamental document that should define the valorization of the territory of Montenegro until 2040, and also the path its development will take.

The concept is too cumbersome, full of contradictions, with unclear messages for the development of the country, say several experts in the field of spatial planning for Center for Investigative Journalism of Montenegro (CIN-CG).

The PPCG concept proposed three possible development scenarios - ecological, sustainable and intensive development, of which the Ministry of Ecology, Spatial Planning and Urbanism (MEPPU) will propose a sustainable development scenario in the draft for all areas.

Experts warn that this is not a good solution, because the ecological scenario had to be considered for some areas, especially for those related to nature protection.

Outdated data on the basis of which the development of the country in the coming decades cannot be planned is also problematic.

The deadline for creating the Spatial Plan is October this year.

Although 73 comments and suggestions were received on the PPCG concept, the Ministry for CIN-CG stated that they did not receive a large number of constructive remarks that would refer to the improvement of the content of the document. They claim that these were mostly initiatives of interested users that related to the conversion of space.

However, CIN-CG interlocutors warn that this is not true, and that this situation is only a logical continuation of the chaos in spatial planning that has been going on in Montenegro for years. The culmination, they said, happened after the Law on Spatial Planning and Building Construction was passed in 2017. That law provided for the centralization of space management. It would include a spatial plan and a general regulation plan (GRP), which was supposed to replace local plans.

However, the state has failed to implement that law for the seventh year. All deadlines have been breached. The initial deadline for the creation of the PPCG expired in 2020, and the PGR will still be abandoned, after its creation has also been postponed several times.

"The pressure of decision-makers, who see development in activating all possible capacities at the same time, is the main problem - both for planners and for all of us," the architect told CIN-CG Biljana Gligorić, director of the Center for Sustainable Spatial Development Expeditio, a non-governmental organization that has been engaged in stopping the devastation of space in Montenegro for years.

She expects that the Draft PPCG will be very similar to the Concept of that document, which she said lacks uniformity, and quantitative and fresher data as well as better analysis of causes.

"Just recognizing the consequences is not enough," she warned.

Biljana Gligorić
Biljana Gligorićphoto: Private archive

That the concept of PPCG does not bring much new, as well as that there are no significant messages, was also assessed by the spatial planner Ksenija Vukmanović.

"We do not have a clear development strategy outlined. The documents that form the basis for the development of the plan have not been updated and fully harmonized, and include conflicting positions," Vukmanović said.

She added that the guidelines concerning Komarnica, Sinjajevina, gas pipelines, and primary traffic routes - have not been finalized.

"Given that it is a concept of a planning solution, it is to be expected that the Draft Spatial Plan will express clearer positions on these and all other controversial issues concerning further spatial development".

What should be fixed?

However, even the critics of the proposed PPCG concept do not fully agree on how the poor proposed solutions should be fixed.

Sinjajevina, she told CIN-CG Vukmanović, according to previous analyzes by experts, is the most favorable location for a military training ground in Montenegro. However, she asserted that no analysis was presented of the impact this training ground would have on the environment.

She said the same about the Komarnica hydroelectric plant:

"We must be open and have clear analyzes with concrete conclusions, so that citizens know what we are talking about, and we don't have that".

In the comments on the concept of the Plan submitted to the MEPPU by members of Expeditia, they recommend that in the network of protected natural assets, the protection of Sinjajevina as a regional nature park should be foreseen, but also that the possibility of building a hydroelectric power plant on Komarnica should be ruled out.

Military training ground or not: Sinjajevina
Military training ground or not: Sinjajevinaphoto: Jelena Jovanović

According to Expeditio, it is necessary to completely cancel the road for high-speed motor traffic along the coast, due to the planned construction of the Adriatic-Ionian highway, which passes through the hinterland of the Primorsky region and in the area of ​​Montenegro, which is a connection between Croatia and Albania.

"This high-speed road would irreversibly devastate the already rebuilt and devastated cultural landscape of the coast," said Expeditio.

Vukmanović, however, believes that a high-speed road should be built because, as he says, the construction of the Adriatic-Ionian highway is more demanding and therefore more expensive. She also clarifies that the construction of the Adriatic-Ionian highway is definitely on a long wait, because it is not a priority for Albania and Croatia, with whose highways the route needs to be connected, for a period of 10 to 20 years.

From the Center for the Protection and Study of Birds (CZIP), in the comments on the concept plan that they submitted to the Ministry, they noted that the risks of pollution in the Skadar Lake National Park should be mitigated, not increased by the intensification of traffic.

They warned that the cumulative effect of pollution that would result from the construction of the Virpazar port has not been analyzed.

They also pointed out that the proposal for the construction of HPP Komarnica is contradictory because this area is mentioned later in the concept as an area of ​​importance for protection.

"This is a future Natura 2000 habitat, an EMERALD area of ​​international importance. The Komarnica HPP would definitely be the last straw when it comes to the problems faced by birds," said CZIP.

Brajići also see the wind power plant as particularly critical, because birds use that route for migration, but also because of the impact on the landscape and the development of tourism and the needs of the local community, which strongly opposes the construction of the power plant.

"The document does not mention solving the problem of managing and disposing of waste after the end of the working life of wind turbines/turbines and solar panels. The construction of such a large number of wind power plants creates a serious waste problem that will escalate in the next 30 years, which is the lifetime of the turbine," warned the CZIP.

In response to all the aforementioned remarks, the Ministry for CIN-CG claims that it does not mean that everything that was found in the concept will also be in the Plan, and that there are certain conflicts in the space that need to be resolved.

"During the discussion on the concept, the civil sector had objections to Komarnica, the Brajić wind farm and the Sinjajevina military training ground. These are the conflicts that need to be resolved - whether they will be included in the draft or not. A strategic assessment will provide an answer to that dilemma." explains the director of the Directorate for Spatial Planning in the Ministry Marina Izgarevic Pavicevic.

Will HPP Komarnica be built?

Officials increasingly support the construction of the Komarnica hydroelectric plant, stating that it will bring development to the northern region of the country. The Ministry claims that the plan for the construction of that HPP has already been adopted. But the Minister of Ecology, Spatial Planning and Urbanism Ana Novaković Đurović she recently repeated in the media that HPP "Komarnica" will not be built.

Be that as it may, in the end, according to the unofficial information of CIN-CG, in the study that was done for Komarnica, although the reservoir enters a protected area, there is no information at all about the impact on that area, the size of the area of ​​lost habitats and which ones.

Ana Novaković Đurović
Ana Novaković Đurovićphoto: Boris Pejović

In its comments on the concept, Expeditio also questions the volume of that document, pointing out that the previous PPCG had less than 200 pages, while the new concept has over 600 pages:

"This is too extensive a document that is difficult to follow and analyze, even for us who are part of the professional public. It should be more integral, to recognize all possible conflicts and resolve them, to give clear guidelines," remarks the Center for Sustainable Spatial Development.

It is unclear, they pointed out from Expeditio, in what way this PP is different from the previous one and what guarantees that devastation will not happen as before. Although she told CIN-CG that the sustainable development scenario, through which every area in the Plan is planned to be treated, is not problematic, the director of Expeditia Biljana Gligorić she warned that the problem is that the environmental scenario is treated as extreme.

"This is not a good message in an ecological state. This plan concept makes no sense in the ecological scenario, and it would be the most logical choice after a terrible adventure of spatial development that led us to a dead end and to the permanent devastation of space."

Precisely because of all the devastation that happened in the territory of Montenegro, Biljana Gligorić from Expeditio believes that the only correct way was the complete opposite of the previous scenario - the ecological one.

This means, she says, the PPCG, which will be far more rehabilitative than investment.

He claims that in this way the state has officially admitted that it has completely lost control of the space and suffered a defeat, and warns that "the continuation of such a trend is disastrous for Montenegro".

Ksenija Vukmanović also assessed that the ecological scenario was insufficiently analyzed.

"It does not mean that in that scenario new facilities and infrastructure systems could not be built, but the standards and rules for development are more rigorous, they would require significantly greater investments and state control".

CZIP also warned in their comments on the concept that the ecological scenario was unjustifiably described as unacceptable in most cases without a clear argumentation:

"The question arises whether the methodology for choosing one scenario is correct, because the analysis of spatial development possibilities in variants for different areas shows that, for example, a restrictive (ecological) scenario is the best solution for the area of ​​nature protection".

Ministry: Not all conflicts can be reconciled

The non-governmental organization Eko-team, in its comments on the concept of PP, pointed out, among other things, that research and possible production of hydrocarbons in the Montenegrin seabed are in collision with the development of tourism. Although state officials announce the reduction of harmful gas emissions by 2030, the Eco-team adds, this goal is not grounded in current plans and processes.

"The state allocates more and more money to justify the further burning of coal at the Pljevlja Thermal Power Plant, opens new coal mines and promotes gas and fossil infrastructures that carry great economic and environmental risks," warns the Eco-team.

CZIP also claims that in the concept of the Plan, oil exploitation is stated only as a possibility, and not as a threat, even though it can have serious effects on the environment. They also pointed out that the concept was written in a superficial and general way.

"Quantitative criteria are generally absent, flat estimates are given and terms are used that describe the development of certain areas imprecisely and vaguely," they claim.

They complain that there are a large number of spelling and grammatical errors in that document, and even that part of the text is in the Croatian language.

Biljana Gligorić emphasized that it is clear to everyone, especially after the last large influx of refugees from Ukraine and Russia, that the census data from 2011, which were used in the development of the PPCG concept, are absolutely not valid.

"The problem is that Montenegrin society is small and such large demographic influxes dramatically affect it. And if the wrong data is taken, we can easily make a mistake in adopting spatial and development policies," warned Gligorić.

For CIN-CG, the Ministry replied that it would be good to have a new census, but that it is not an obstacle, because there are projections made by MONSTAT. They say: "A demographic study has been done. Based on all the analyses, it is evident that the outflow of residents in the north will be even worse than it was in the 2011 census".

On behalf of the Ministry, Marina Izgarević Pavićević stated that a strategic assessment of the impact on the environment had been made. According to her claims, the PP will definitely try to activate the northern region so that some projects are foreseen that will contribute to the return of the people:

"All areas will be treated through the prism of sustainable development, and the emphasis will be on agriculture, tourism and energy."

Marina Izgarevic Pavicevic
Marina Izgarevic Pavicevicphoto: Maja Boričić

Ekspeditia Director Biljana Gligorić reminded that civil society has been warning for years that it is not a good practice to hold public hearings in the middle of summer, especially not on such an important document that deals with the development of Montenegro until 2040. She added that her 25-year experience of participating in public hearings shows that public discussion almost never results in major changes such as, for example, throwing out problematic projects.

"Conceiving of participation only as a mandatory step, but not as a truly useful process that improves the final document, can again, who knows how many times, cost us dearly," she warns.

"It is not always easy to reconcile all conflicts. We certainly have a strategic assessment and aim to reduce these impacts to a minimum or to have no impact at all," Marina Izgarevic Pavićević responded to those remarks on behalf of the Ministry.

She announces that in the middle of May they should finish the Draft, which will be sent to the institutions for their opinions. The deadline for an answer will be two months.

"Only after obtaining positive opinions, the material will be sent to the Government to determine the Draft PP, which will then be on public discussion".

At the same time, legal changes in this area are also expected. The Ministry wants three laws to emerge from the current Law on Spatial Planning and Building Construction - on spatial planning, on construction of buildings and on legalization. The drafts of those laws have been completed and are currently under public discussion.

According to the current Spatial Planning Law, the creation of a General Regulation Plan (PGR) was foreseen, for which, according to information from CIN-CG, almost half a million euros have already been spent. By passing new laws, which do not provide for such a document, the PGR will also be annulled.

The Ministry explained to CIN-CG that they had to work on the PGR because it is provided for by the current law.

"We cannot stop it until a new law is passed. No money was wasted, because that material will be used to create local plans," the Ministry claims.

After the adoption of new laws and PPCG, local plans will have to be changed, which will be harmonized with the new spatial planning policy.

They give millions, then cancel the plans

Vukmanović, who was the coordinator of the drafting of the current General Regulation Plan, explained to CIN-CG that the intention of the law from 2017 was to put out of force more than 500 valid planning documents, many of which were inconsistent with higher-order plans, as well as with low-quality and outdated planning solutions from the aspect of urban planning indicators.

"2020 euros were paid for the first phase of the PGR, which the work team completed and handed over to the Ministry in December 400.000, 60 experts, signatories of the contract on the preparation of the PGR, and more than 40 associates worked on it", she said, giving specific figures.

She estimated that what was done could be used to some extent for local plans, but with updating the data.

According to the new legal solutions, said Izgarević Pavićević, it is planned to establish state and local agencies that will prepare planning documents. This means that this job will no longer be given to individuals as before.

"It will be like in the past when the Republic Institute made spatial plans. We realized that this way there was the least possibility of corruption, and the plans were of better quality and enforceable," explained the director of the Directorate for Spatial Planning in the Ministry of Ecology, Spatial Planning and Urbanism.

She added that it is planned to return to the law the issuing of construction permits and licenses and inspection supervision.

Vukmanović hopes that the set of new laws will help to bring order to the area, that the hierarchy of plans will be clearly established and that local plans will have more concrete and clear principles. She cites the introduction of state and local agencies that will make these plans as a good idea. However, he warns that there is a large deficit of urban planners in the country.

There is not enough understanding of how demanding, slow and complex the space planning process is, added architect Gligorić. She assesses that all the anomalies we are now encountering in the system are a direct consequence of the aforementioned catastrophic planning law from 2017.

"According to that law, only one spatial plan (PUP of Kotor) was adopted. And the planning system was destroyed, the hierarchy of plans was disrupted, the process of legalization was not completed. Due to the force of circumstances, the old bad plans remained in force, which all means that we are witnessing a complete chaos, which not only costs us dearly financially, but also leads to a complete blockage of the system," Gligorić said harshly.

She hopes that a set of new legal solutions will begin to correct this chaos, but she also warns that we must not forget that this is only the first step and concludes that we will have to wait many years to come up with quality spatial plans that will guarantee fewer conflicts and devastation in space.

In the past, the needs of society were listened to

Biologist Vasilije Bušković points out that the problem is that in the last 20 years in the area we have a phenomenon where conflicting uses are foreseen in the same locality - agriculture, tourism, wind power plants, infrastructure.

"Spatial planning is of interest to a large number of people, unfortunately it works when someone from politics says what to draw, you only have to ask the profession in order for it to work properly".

He recalls how things worked before, explaining that before the creation of the PP, a social plan was worked out, that is, the needs of society were listened to and a plan was made based on them.

And Vukmanović points out that under socialism work was more systematic and that the hierarchy of plans was clear:

"Disorder in the spatial planning process brought an investment boom, when the plans became a market product. Interests still rule in planning. Spatial plans should be done professionally, and clear and strict rehabilitation measures should be defined for the devastation that occurred in the area, including areas of illegal construction."

Fales and digital maps of protected areas

The Ministry explains that the Environmental Protection Agency should make digital maps of protected areas:

"We get that data from them, and as soon as we get it, we transfer it into space. There are spatial plans for national parks, we have our NP borders, it is necessary for the Agency to mark them on the ground".

They explain that everything depends on the data they receive from the relevant institutions, and that it is necessary for all institutions to be actively involved.

"The previous PP was also good, implementation is the key, that's something that was missing, that's why this happened to us in the area, not because we had a bad plan", the Ministry concludes.

The Ministry "forgot" two of the four areas on the UNESCO World Heritage List

Limitations due to climate change in two UNESCO world heritage areas (the historical area of ​​Kotor and the Bay of Kotor and the natural area of ​​Durmitor) have been insufficiently addressed, it is emphasized in the comments on the concept submitted by Expeditio. They also add that imprecise and inadmissible formulations are used for protected areas:

"Montenegro has four registered properties on the UNESCO World Heritage List; It is a shame and unacceptable that a document of this level has such vague and imprecise wording and errors".

In the document, the Ministry does not mention the three stećak necropolises and the Kotor fortress, which are also inscribed on the UNESCO World Heritage List. The assessment of the situation in the chapter of cultural heritage protection is not based on expert analyzes and does not correspond to reality, according to Ekspediti.

"This area is characterized by a completely collapsed institutional system of protection, problematic and inconsistent legal solutions, the absence of basic documentation, including the register of cultural assets, drastic devastation of the cultural landscape..."

China
photo: CIN-CG

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