Draft Spatial Plan full of controversies: The remaining dam on Komarnica and the military training ground on Sinjajevina

The strategic impact assessment strongly criticizes some proposals from the Draft PPCG because not enough attention was paid to protected areas, sustainable development and the real needs of society. All problematic solutions remain, from the dam on Komarnica to the military training ground on Sinjajevina

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Will there be a military training ground: Sinajevina, Photo: Jelena Jovanović
Will there be a military training ground: Sinajevina, Photo: Jelena Jovanović

The rivers Komarnica and Piva, with the construction of hydropower plants, would suffer incalculable negative impacts on biodiversity, habitats, landscape, warns, among other things, in the Strategic Impact Assessment (SIA) of the Draft Spatial Plan of Montenegro until 2040 (NPPCG), which leaves the possibility of construction of these hydropower plants, despite the warnings of the non-governmental sector and part of the professional public.

The draft PPCG was adopted by the Government Dritan Abazović, in the last weeks of the mandate. According to the first reactions, there are a lot of controversial solutions in the draft, which could further fuel disputes about how to treat space and which way Montenegro should develop.

From the new Ministry of Spatial Planning, Urbanism and State Property, headed by Janko Odović, did not answer numerous questions from the Center for Investigative Journalism of Montenegro (CIN-CG) related to NPPCG.

No answer: Odović
No answer: Odovićphoto: Dušan Cicmil

Hydropower plants: Komarnica, Kruševo, Boka

In addition to Komarnica, the Draft also plans the construction of the Kruševo hydropower plant, as well as the Boka HPP on the coast. These are Emerald sites, potential UNESCO extended area and regional park zones.

That is why these projects should be deleted from the Plan, according to several experts contacted by CIN-CG.

"The Komarnica HPP project is technically the most ready for implementation, however, from the aspect of space protection and environmental impact, it does not have the support of the institutions responsible for environmental protection," it says in the draft plan, without any indication of a solution to this conflict.

In that document, it is written that currently the largest part of annual electricity consumption can be met from domestic power plants, while the need to import electricity is gradually decreasing and is currently below 10 percent of the total needs of consumers. The situation has changed, because there is no longer the largest energy consumer, Kombinata aluminumijuma Podgorica (KAP).

Natasa Kovacevic from the international organization CEE Bankwatch recalls the adopted decision from the UNESCO session, by which Montenegro is obliged to specifically consider the impacts of HPP Komarnica on the Dragišnica and Komarnica nature park and not to approve the project if it would result in negative impacts.

Montenegro is obliged to consider the impacts of HPP Komarnica: Nataša Kovačević
Montenegro is obliged to consider the impacts of HPP Komarnica: Nataša Kovačevićphoto: Luka Zeković

"In international practice, spatial plans have clear decisions on whether an area should be excluded from a certain type of project or not, whether it is protected areas or other sensitive areas," says Kovačević.

In the Strategic Impact Assessment on the Draft Plan, it is pointed out that the planned hydropower plants are recognized as clear conflicts in space, contrary to the objectives of nature protection. Despite this, the construction of the Komarnica hydropower plant is still open without a clear determination by the state, the document says.

In the case of the Kruševo hydroelectric power station, it is emphasized, it is an area that is part of the Dragišnica Komarnica Nature Park, which represents a direct conflict with the need to preserve the value of the protected area and the Law on Nature Protection. They point out that PPCG should consider alternative solutions in relation to the choice of location.

In that document, the Boka HPP is said to be "completely unacceptable", given that it implies the release of huge amounts of fresh water into the Risan Bay, where the preventively protected areas of Sopot and Dražin vrt are nearby (which until the end of the strategic assessments to be declared permanently protected areas):,,In addition, such a large amount of fresh water transferred from Bileć Lake would contribute to a serious disruption of the natural balance of the marine ecosystem of this part of the bay".

The pushing of outdated ideas and projects from the last century, such as these hydroelectric plants, unfortunately indicate that we have not moved far from the state of consciousness we were in when the last Plan was being developed, he assesses Andrijana Mićanović from the Montenegrin Society of Ecologists (CDE).

He explains that projects that have long been overcome in developed countries are being forced, and we are ignoring the recommendations of the European Union (EU), UNESCO, the Berne Convention and many other agreements signed by Montenegro:,,If in one area such as the canyon of the Komarnica river, recognized and protected at the national and international level, we are planning complete devastation, then it clearly shows us that as a country we do not have a clear vision of development".

The Strategic Impact Assessment concludes that a significant number of locations intended for the development of the energy sector are in direct conflict with the protection of nature and valuable areas of biodiversity.

"Insufficiently clear guidelines for the use of certain areas leave room for concession contracts to be signed first, and only then to recognize conflicts related to nature and environmental protection. This is a problem that Montenegro has been facing for years, which must be changed", the document emphasizes.

Thermal power plant Pljevlja

The European Commission (EC), in this year's Report for Montenegro, points out that there is insufficient focus on environmental standards in energy infrastructure projects, and that there is no progress in finding an alternative solution for energy.

"Montenegro needs to make a strategic decision on how to replace the thermal power plant in Pljevlje, which currently produces about 50 percent of Montenegrin electricity, but remains the main polluter," the Report notes.

The EC assesses that the ecological reconstruction of the Pljevlja Thermal Power Plant (TE Pljevlja) does not solve the essential problems, and that Montenegro should intensify its efforts to permanently close this plant:,,Montenegro should plan a just transition, by providing economic alternatives to the communities that will be most affected by the expulsion coal".

The expensive reconstruction of the Pljevlja Thermal Power Plant has progressed, the report points out, despite numerous controversies concerning the environment and Montenegro's international obligations regarding greenhouse gas emissions.

Kovačević, who is the coordinator for the decarbonization of the district heating sector in the Western Balkans, points out that the draft plan requires ensuring the uninterrupted operation of the Pljevlja Thermal Power Plant, and that there are no indications of plans to abandon the use of coal, which, according to Montenegro's international obligations, should happen after 2035 , and probably earlier, given the financial burdens due to burning coal that are coming our way in a few years.

She adds that renewable energy sources and energy efficiency should be a priority for Montenegro, but that none of these projects should be implemented without applying the principle of "do no significant harm".

Kovačević for CIN-CG states that, from the priorities of the Plan, it is evident that the developers did not think that we will be part of the EU by 2040, and that the regulations on decarbonization of the energy and other sectors will be binding.

He adds, the short-term opening of export-oriented new coal mines in Pljevlja (Mataruge, Glisnica) is planned, the first of which will threaten the only water source in Pljevljak.

There are no clear guidelines for the decarbonization of the heating sector in the draft plan, emphasizes Kovačević, although it is stated that the air in cities like Podgorica, Nikšić and Pljevlja is critically bad, which is mostly a product of combustion during the heating season.

Kovačević says that it is necessary to have clear demographic data from the new census, a detailed national and energy climate plan, clear years of abandoning the use of fossil fuels in order to reach net zero emissions by 2050, compliance with the road map for a just transition...

She assesses that the Draft must be seriously refined, in order to be included in the public debate, and that it is not possible to do it well by the end of this year.


The draft document still did not resolve some of the most important conflicts in the area, which arose during the discussion of the PPCG concept: the military training ground on Sinjajevina, the construction of the wind power plant (VE) on Brajići, but not the high-speed road corridor in the Primorje region.

The Draft Plan states that the area of ​​Sinjajevina can be used as a temporary military training ground, but also for agriculture.

The strategic impact assessment as a solution, however, proposes the realization of exercises outside of Montenegro:,,Montenegro is a mosaic of areas with exceptional natural features and is too small to allow itself the 'luxury' of sacrificing any part for military exercises, which would represent a major negative the impact on biodiversity and habitats, but also the impact on the lives of people who traditionally go to the katuns in the summer".

However, the Draft Plan states that the Report of the Interdepartmental Working Group (IRG) states that artillery firing would be carried out two to three times a year, lasting up to 10 days, during the period when the local population is not engaged in agriculture in that area. From October to the end of May, the Army would use the space for training that does not require artillery fire.

"The army will not build facilities in Sinjajevina, but would establish temporary facilities, such as tents and containers. At the end of the activity, the area would be rehabilitated," the IRG report states.

They explain that from the area of ​​74,5 square kilometers of the Military Shooting Range in Sinjajevina, the effect of artillery shells would be aimed at about nine square kilometers.

"The space on Sinjajevina was given to the Ministry of Defense for temporary use by the Government's decision, and it could be canceled if expert agencies establish that there is a risk to the environment," the IRG report says.

In the Municipality of Žabljak, in the revision of the Draft PPCG, they propose that the area of ​​Sinjajevina be declared a regional nature park, in order to protect and valorize the area exclusively for agricultural and tourist purposes.

"In this way, the possibility of building any military training grounds and other military facilities, as well as carrying out military activities, which threatens the complete devastation of this mountain," is the opinion of the representative of the Municipality of Žabljak.

Nataša Kovačević points out that it is not compatible to have a military training ground and traditional agricultural practices in Sinjajevina.

"The plan mentions Sinjajevina as a potential nature park, and this is also an Emerald area and an important bird habitat (IBA)," she says.

If the decision is left to the defense sector, it is clear that there will be a military training ground, Kovačević points out: "If there are military activities, it would mean that shepherds and tourists will be expelled from a large part of the mountain."


In the PPCG draft, it is written that the construction of the Brajići wind farm, which should include the municipalities of Budva and Bar, is also being considered.

From the municipality of Bar, in the revision of the draft Plan, they point out that in the draft of the Detailed Spatial Plan for that wind farm it is written that it is not a windy area!

And the Municipality of Budva is particularly opposed to the planning of the wind farm in Brajići.

They claim that the construction of a wind power plant on Brajići would permanently devastate an area rich in natural springs, cultural-monumental values ​​and rural, residential structures.

Ornithologist Bojan Zekovic from the Bird Protection Center (CZIP) points out that the wind farm on Brajići would be a great danger to birds.

He explains that for now two main corridors for bird migration have been recognized in Montenegro - one through the Bojana delta, Lake Skadar with a special concentration of raptors through Bjelopavliće to Nikšić polje, and the other on the coastal mountains of Orjen - Lovćen - Rumija.

"Of the 19 griffon vultures, four were in the immediate vicinity of the planned wind park, while another species of vulture - the white vulture, which was re-registered in Montenegro after almost three decades, just passed through the location of the planned wind park in Brajići," he says. Zeković.

He points out that other species of raptors that are endangered and sensitive have their own routes on Brajići, such as the striped eagle, a rare and endangered species that no longer nests here.


The Draft PPCG no longer mentions the construction of the Virpazar port. However, the possibility of opening a waterway on the Bojana River, which would connect Lake Skadar and the Adriatic Sea, remains open.

"Lake Skadar is a RAMSAR area under international protection and a National Park, and it is completely unacceptable to plan the development of nautical traffic, especially without clear guidelines for the size of vessels and the number of vessels," the Strategic Impact Assessment points out.

The Draft Spatial Plan mentions the possibility of developing new airports in Ulcinj, Bar, Berane, Nikšić, Pljevlja and Žabljak.

SPU warns that it is necessary to review these locations, and they especially point out that the airport in Ulcinj would be in the immediate vicinity of the Ulcinj salt pan, which is protected and is also an internationally important area for birds.

"Here, it should be borne in mind that for the closing of negotiation chapter 27, in the final benchmarks, the Ulcinj Saltworks is represented with over 30 percent", the SPU emphasizes.

The construction of the airport in Ulcinj is planned in the hinterland of Velika plaža, which is an area with unique species and habitats.

"With the construction of the planned roads (Bar-Boljare highway, Adriatic-Ionian highway), the arrival to the Ulcinj Riviera will be easier and faster, so the idea of ​​building an airport should be rejected", concludes the SPU.

CZIP previously warned that Gornji Štoj is the most important nesting area for the legally protected species of bee-eaters in our country, and the construction of the airport infrastructure would mean the absolute destruction of an important habitat for this species.

The executive director of that organization Jovana Janjušević for CIN-CG assesses that the Draft PPCG until 2040 offered a lot of dangerous and problematic contents, which condemn ecological Montenegro to absolute urban defeat and collapse.

She also points out that it is a completely incomprehensible idea to place the airport in the immediate vicinity of the Ulcinj salt pan, on whose favorable ecological status our entry into the European Union depends.

"If airplanes, as the biggest polluters, contribute to the goal of reducing CO2 emissions (and other emissions that contribute to climate change), then we believe that it is completely justified that Gornji Štoj be completely concreted, and that instead of brightly colored birds, a virtuous airport is positioned there," she said ironically. Janjušević.

The draft plan also proposes a controversial solution for a "high-speed road" on the Primorje, i.e. the crossing of the corridor by a bridge, but with the mandatory consultation of the competent Ministries and the Administration for the Protection of Cultural Property with representatives of UNESCO. The UNESCO report from 2018 pointed out that the bridge on Veriga should be abandoned.

The municipality of Tivat, in the revision of the Draft PPCG, warns that the position of the expressway in the Bay of Kotor must be precisely defined. And the Municipality of Kotor strongly opposes the construction of a bridge on Veriga.

The SPU points out that it is necessary, in the further stages of the development of the PPCG, for the relevant ministries to intensify communication with UNESCO and to consider the additional preparation of the Heritage Impact Assessment (HIA) of crossing the Boka Kotor Bay.

Many goals without clear solutions

Mićanović concludes that the focus is still on the idea of ​​rapid economic progress, which cannot be sustainable, and that nature protection is still described as something that is restrictive and limits development.

The Strategic Impact Assessment emphasizes that the Draft Spatial Plan lists many goals, without clear solutions for achieving them.

It is also emphasized that it remains unclear why the intensive protection scenario (ecological scenario) is unacceptable.

"The argument that Montenegro is not yet prepared for such a scenario without clearly set and assessed criteria points to a lack of will, knowledge and ambition towards a direct transition to a sustainable type of development, which brings us into conflict with the goals and obligations from international documents".

In that document, it is pointed out that by mapping first Emerald, then Natura 2000 habitats, habitat types of special interest for nature protection were identified, which currently do not enjoy protection and which therefore suffer from various anthropogenic pressures:,,The Spatial Plan of Montenegro must adequately treat them in in terms of protection guidelines and avoiding planning conflicts with their protection needs", concludes the Strategic Impact Assessment.

Kovačević: Remove gas power plants from the Plan

Kovačević believes that the group of most problematic projects in the Draft Spatial Plan is the construction of gas power plants in Bar, Podgorica and Pljevlja and related gas infrastructures. She emphasizes that these projects must be removed from the Draft Plan.

"Given that we are talking about investments in fossil gas, the construction of an LNG terminal would block Montenegro from fulfilling the goals of the Green Agenda - phasing out fossil fuels by 2050 and the obligations from the Sofia Declaration on a carbon-neutral continent and achieving climate neutrality." says Kovačević.

Instead of switching to renewable energy sources, Kovačević points out, our government is planning an infrastructure that will make us dependent on gas imports.

"Montenegro uses almost no gas, is not connected to international gas networks, does not have a gas distribution network, while the construction of the terminal takes five to ten years, which means that it would start operating after 2030," she points out.

This means, she explains, that the terminal will operate for 20 years, until the 2050s, when Montenegro should be climate neutral.

"So, we will have an investment that in 2050 will be a 'stranded' asset of over one billion euros," says Kovačević.

Montenegro to be an oil and gas producer

The PPPCG Draft states that the era of diesel and gasoline consumption appears to be coming to an end:

"Even if all the passenger cars that exist in the world today were to be replaced by electric ones, it would ultimately reduce the total consumption of oil and gas by only 20 percent."

The other 80, they state in the Draft, remain for truck and ship transport, air traffic and the enormous consumption that petrochemicals have today:

"Oil and gas will continue to play the role of the primary source of energy in the world for a long time to come. Bearing this in mind, Montenegro must continue with the development of the oil and gas exploration sector with the goal of becoming an oil and gas producing country," the Draft PPCG reads.

So far, the presence of these substances in Montenegro has not been established.

CIN CG disclaimer
photo: CIN-CG

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