Professor Branko Radulović believes that the Draft Spatial Plan of Montenegro (PPCG) until 2040 should be rejected as low-quality and unusable, and one should not wait for the census to do so.
"Environmentalists have already expressed their negative opinion. Scientific institutions must have their own position. This is their obligation," Radulović stated in the announcement. He believes that the draft PPCG until 2040 was not prepared in accordance with the provisions of the Law on Spatial Planning and Building Construction, the Law on Environmental Impact Assessment, the Rulebook on the Methodology of Planning Document Preparation or the Program Task for the preparation of PPCG until 2040.
"It is even a speculative document. The draft PPCG did not fulfill the basic requirement of being a strategic document that determines state goals and measures of spatial development in accordance with the overall economic, social, ecological and cultural-historical development of Montenegro", said Radulović, who would be a member of the PPCG Audit Council.
He adds that the PPCG was not created respecting a multidisciplinary and highly professional procedure, and does not ensure a high degree of reliability.
As the PPCG determines development policies, arrangement and use of space, defines individual strategies and plans, the way of using resources and potential, development priorities and much more, the obligation to implement and implement its vision, goals and solutions would produce setbacks and retrograde processes and enormous material losses.
"Even if we become a member of the EU, with the application, vision and solutions offered by this document, we would forever be the most underdeveloped country in the EU. Contrary to the author's claim that we will become a developed member of the EU".
Radulović reminds that, as a member of the PPCG Audit Council until 2040, on June 15.6.2022, XNUMX. year, publicly expressed his opinion, stating that the PPCG Concept that they received for evaluation is worthless material, that it should be discarded and a credible and institutional processor should be formed.
As he said, the Council, the academic community, and the civil sector also communicated a negative opinion, with very negative views.
"During 2021, several of us distinguished academics, regular professors and scientists were asked by the then minister, Prof. Dr. Ratko Mitrović to be members of the PPCG Audit Council, which we accepted, however, after an insight into the Concept and the credibility of the manager and some processors, we submitted our resignations.
The emergence of contradictions is worrying
According to him, what is worrying is that the contradictions surrounding the creation of the PPCG continue.
He reminds that in December 2018, before the expiration of the valid PPCG until 2020, the 41st Government of Duško Marković made a decision on the preparation of the PPCG until 2040 and then elected Svetlana Jovanović, executive director of the Republic Institute for Urban Planning and Design ( RZUP) whose owner is the controversial businessman Aco Đukanović.
"Due to the poor quality of work and missing deadlines, Jovanović was dismissed and re-elected. Thus, instead of completing the drafting of the new PPCG, as was defined by the first 24-month contract, today, after 5 years, we have a bad Draft. It should also be pointed out that a certain number of processors do not meet the criteria nor are they competent to produce such an important document, while a large number of them are connected to various corrupt practices that have devastated the space, resources and ecological potential of Montenegro. Unfortunately, one must also note the political uniformity of the processors and their affiliation with the previous retrograde regime".
He believes that the Draft PPCG is a speculative document that did not respect the legal procedure of drafting and adoption.
"In fact, as a member of the Council, in May 2022, I received for evaluation the proposal for the PPCG concept until 2040, contained in four books and as many as 1.002 pages, without cartographic attachments. After the unique and extremely negative evaluations of all elements of society on the PPCG Concept, the processor proposed a completely new document to the Government in the form of the PPCG Draft Proposal until 2040 for adoption in a completely new text".
The draft PPCG, he adds, is given in two parts - Analysis of the current state of the organization, arrangement and use of space and the Draft Plan, on as many as 593 pages.
According to him, the document should have been prepared on the basis of legal regulations and program tasks, in a scientifically and methodologically uniform, current and valid way, on about 250 pages.
He says that the first part of the document - Analysis of the existing state of organization, arrangement and use of space, should contain the starting points on the characteristics of the territory, assessments of the state by area, global context, syntheses of assessments of the existing state, an overview of problems, limitations and potentials of the planning area. The analysis, he adds, should have been done in a methodological way, with a uniform level of processing of all segments, concisely, based on current and valid data.
"The offered text, on the contrary, on 311 pages, is a de facto repository of chronological data on the creation of documents, legislative regulations, copy-paste quotes, papers, reports and studies dealing with historiographical and general peculiarities, individual segments and characteristics of Montenegro. Nothing or very little of the proclaimed principles and legislative regulations, especially in relation to the Rulebook on the Methodology of Creating a Planning Document".
According to Radulović, the second part of the offered document, called the Draft PPCG until 2040, given on 279 pages, was supposed to offer goals and planning solutions and the implementation of solutions.
"On the basis of the legal guidelines and methodology of the document, it was necessary to provide several variants of solutions, which respect the policy of rational use of space and environmental protection, the principles of sustainable development, as well as the achievement of balanced socio-economic development. Then, on the basis of new detailed data, analysis and opinions and proposals of the interested public, cost-benefit analysis, it was necessary to determine the optimal variant for a certain topic. The document does not contain such a scientific and research methodology in any segment".
Numerous conflicts, contradictions, superficialities
According to Radulović, there are many contradictions, conflicts, inconsistencies, superficialities contained in the offered document.
"Demographic analysis and projections are of crucial importance for the future of Montenegro. The author's projection that the number of inhabitants in Montenegro will increase from 622.271 in 2020 to 7,4 in 668.781 by 2040% is in the realm of fantasy. At the same time, the UN and the CIA claim that there will be depopulation in Montenegro, that by 2050 the number of inhabitants will decrease by 7,9%, by about 50.000, that it will amount to about 570.000".
He says that forecasts that Montenegro will have 2100 inhabitants at the end of the century, in 449.000, are extremely worrying. Less by about 180.000 inhabitants or 38,6%.
"What is certain is that the depopulation will be more intense, not only because of the decline in natural growth, but also because of increased migration to the EU. All the youth will leave us, the old point of view will be more numerous for a while and then it will also decline and emigrants will live here".
He reminds that the authors recommended indicators that GDP per inhabitant according to purchasing power will grow intensively to the level of the European average, which, as he assesses, is extremely irresponsible if current doubts, global challenges are recognized, they do not offer concrete sectoral reforms and solutions, their effects, new economic policy in line with new EU policies.
"One gets the impression that the authors are not familiar with the state of social activities, whether it is education, science, culture, social protection, pension and disability insurance, physical culture and sports. In order for these activities to function as a dignified life, in addition to eliminating numerous deviations, reforms and huge financial resources are necessary for our circumstances".
A budget that would be 300% larger than the current one is needed, he adds. Only for a modern and sustainable health system, instead of the current modest 389 million euros, it is necessary to allocate around 1,8 billion euros, if the criteria that the average allocation for health in the EU is 3.000 euros per inhabitant would be respected.
The Adriatic-Ionian highway is the biggest investment failure
The authors of the PPCG, he says, advocate intensive traffic development.
"Nice, but which one and how. They must know that a major energy transition is underway, that it has already been defined that green hydrogen will be used in air, sea and freight-road transport, and electricity in rail and passenger-road transport. One gets the impression that the authors are not familiar with traffic frequency analyses, investments and effects".
Radulović believes that the Adriatic-Ionian highway, the continental variant, would be the biggest investment failure, with its implementation, Montenegro would go bankrupt and not gain anything.
He explains that it is a transit road, does not valorize the potential of Montenegro, destroys its relief and ecology.
According to the "Feasibility Study for Two Highways in Montenegro", which was prepared by the respected development consultant Louis Berger, the frequency on this road would be very low, with a maximum of about 4.000 vehicles per day, Radulović states.
"The construction of 1.550 km, which is the length of the section of this highway through Montenegro, would cost up to 3 billion euros. For that amount, several times more expressways and tens of times more highways could be built. The authors should have created variant II: continuation of the construction of the Mateševo-Andrijevica highway, the Andrijevica-Boljare expressway, a full bypass around Podgorica, the Podgorica-Budva expressway, the Podgorica-Bar expressway, using the existing highways.
He says that the Adriatic-Ionian highway should be built as a fast road that would connect the border of BiH, Viluse, Nikšić, Danilovgrad, Podgorica, Tuzi, the border with Albania.
"The high-speed road to the coast must be a priority. The other planned roads in Montenegro are not disputed. This variant is a winner, it would satisfy the needs of Montenegro in this century and it would cost much less". He says that the modernization of railway infrastructure and airports in Podgorica and Tivat is also a priority.
What is new negativity, as he states, is that the processor did not analyze Montenegro's membership in the EU and the benefits they would receive, as well as the valorization of domestic resources and investments "in depth".
"The cement plant needs to be built now or never".
RES and green hydrogen are the only energy sources of the future
According to Radulović, the processors rightly stated that the energy sector is our greatest potential. However, they had to have adequate responsibility.
"They need to know that according to research by the Energy Institute, for the needs of the G20, electricity from renewable sources and green hydrogen are the only energy sources of the future. In particular, it must be known that climate change will cause a lack of water for the needs of biodiversity, so many experts predict that the flow of water in Montenegro will decrease by around 2050% by 30".
He believes that they should have made an analysis of the effects and losses of three variants of the valorization of the Piva watercourse - the construction of reversible or flow-through HPP "Komarnica", HPP "PivaII", HPP "Kruševo" and the reconstruction of HPP "PivaI" or none of them.
Reversible hydropower plants, he adds, have numerous advantages.
"Analyze the use of our waters of Bileć Lake differently - the construction of HPP "Risan" or the transfer of waters. The waters of Morače will one day be used for multiple purposes. Nothing in the document about solar and wind resource hoarding and tycoon deals. We have lost about 1.000 KW of installed power and about €2 billion in revenue per year. We should finally forget about oil and gas reserves and the construction of gas pipelines. The adoption of the National Energy and Climate Plan, the Law on Renewable Sources and the amendment of the Law on Energy is of particular importance for the sake of the EU".
The authors do not distinguish between regional centers and regional landfills
A rational and efficient solution to the difficult situation and waste management should have been one of the most important segments of the document, according to Radulović.
"The manner in which this chapter was processed is indicated by the fact that the authors do not distinguish between what are regional centers and what are regional landfills, where they are built and where not, data from the State Plan made in 2014 and not from the State Plan made in 2022 are used. and, for example, for organic waste, the differences are 35,11% and 40,7%, respectively. Also, some data from 2013 are presented in 2023 for the purposes of the plan until 2040. Unbelievably, numerous tables and projections were made that way".
Such data, he added, also apply to sewage sludge, non-hazardous construction waste and other types.
In this way, based on the data provided in the State Plan 2015-2020. year, which was done in 2014, the estimate of the total amount of municipal waste generated in 2040 will amount to 332.290 t, and according to estimates in the Draft State Plan 2023-2028. will amount to 376.328 tons, he said. "Furthermore, the processor projects without any analysis, with wrong data, the construction of four plants for the thermal treatment of sewage sludge, permanent instead of temporary local landfills for non-hazardous construction waste, four plants for the treatment of waste tires, five plants for the treatment of waste vehicles".
A similar situation, he adds, is with the chapter "Management of waste from electrical and electronic products" where four locations of facilities for processing waste from electrical and electronic products are proposed in such a way that they are "attached" to the proposed locations of the Regional Centers for Waste Management.
It is similar, more or less, with the treatment of other chapters, whether they are agriculture, reindustrialization, mineral resources or other areas, Radulović states.
"It is clear that we are in big trouble. We have no development vision, PPCG, lower-order plans, development strategies, sectoral reforms, optimal solutions. We don't even have time to wait anymore, we are losing huge funds, resources are being destroyed, it is necessary to launch a large and sustainable investment plan. We must not make a single mistake. All solutions must be optimal for us".
He believes that it is rational to entrust the creation of the PPCG to CAN or UCG or the "Institute for the Development of Montenegro", which must be formed. Collaborators can also be reputable institutes from the environment and the EU.
"This is a practice in all advanced countries. At the same time, it must be done in accordance with the preparation of sectoral studies and "mature" projects. Everything should be foreseen in the budget for 2024. If we want to join the EU, to start looking like a normal country, the year 2024 must be the year of reforms and the initiation of a large and sustainable cycle. The condition of all conditions is a visionary, well-known and determined government", said Radulović.
Bonus video:
