Professor Branko Radulović believes that the Draft Spatial Plan of Montenegro until 2040, which is still under public debate, is a worthless document and should be rejected, and its preparation should be entrusted to the Montenegrin Academy of Sciences (CANU), the University of Montenegro or the Institute for Development.
Radulović submitted the analysis of the Draft Spatial Plan of Montenegro (PPCG) to Prime Minister Milojko Spajić, Minister of Spatial Planning, Urbanism and State Property, Janko Odović to the Council for Review of the Spatial Plan of Montenegro until 2040. He announced that he would also submit the analysis to the leadership and parliamentary groups of the Assembly .
"The PPCG draft does not meet even the minimum standards, it is not prepared in a legal, methodical and systematic way, it is not analytical and credible, it is not in line with new policies and decisions of the EU and global trends, it does not offer a harmonized and sustainable vision of the development of Montenegro and optimal sectoral solutions, it does not assess the strategic impact on the environment, and it cannot be improved with proposals and suggestions in order to become a valid strategic document. That is why it should be rejected and drafted in a completely different way, above all in a legal and institutional way, with authoritative and eminent managers and processors." stated Radulović in the analysis.
According to earlier announcements, the Government should adopt the Spatial Plan in the third quarter of this year, after which it will be sent to the Assembly for consideration and adoption.
Radulović points out that the PPCG is an extremely complex document characterized by an interdisciplinary scientific approach, based on the concept of sustainable development, integrating nature, society and the economy, and determines the development of the entire country.
He reminds that it is a leading planning document that determines lower order documents and sectoral strategies, creates leading scientific and development institutions and should predict the long-term future of Montenegro.
In his analysis, he points out that emphasizing the urgency of adopting PPCG of this quality, bearing in mind its formal importance and the obligation of implementation, would produce even greater disorientation of Montenegro in the future, loss of important resources, wrong investments and huge financial losses.
"Even due to the condition of some important segments, biological survival in this area would be called into question. Some priority sector projections, such as those in transport and energy, should be partially prepared, starting from a quality project assignment and feasibility study to the main project of the most favorable variant, but improved and legislation in accordance with new EU policies," he said.
He believes that the Draft PPCG is a speculative document that is based on unreliable data, omits important segments, has no more variant approaches and does not offer optimal solutions.
"The PPCG draft was not drawn up in accordance with the provisions of the Law on Spatial Planning and Construction of Buildings, the Law on Environmental Impact Assessment, the Rulebook on the Methodology of Drafting a Planning Document or the Program Task for Drafting the Spatial Plan of Montenegro until 2040," he stated.
In this way, as he added, 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.
"The PPCG concept, a document of the previous phase, was negatively evaluated by the PPCG Review Council, the academic community and the civil sector. The developers then, illegally, unsuccessfully tried to improve it with small corrections and leave an impression of seriousness with several new processors. The government for reasons known to them, determined such a low-quality text," said Radulović.
According to him, the first part of the document - Analysis of the existing state of organization, arrangement and use of space, on 311 pages, is a de facto repository of chronological data on the creation of the document, legislative regulations, copy-paste from already published and outdated, often inaccurate, quotes, works, reports and studies dealing with historiographical and general peculiarities, individual segments and characteristics of Montenegro.
"None or very little of the proclaimed principles and legislative regulations, especially in relation to the Rulebook on the Methodology of Creating a Planning Document".
The second part of the offered document, called the Draft PPCG until 2040, given on 279 pages, was supposed, as he says, to offer goals and planning solutions and their implementation.
"On the basis of legal guidelines and the methodology of document preparation, 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, based on new detailed data, analysis of the opinions and proposals of the interested public, cost-benefit analysis, should have determined the optimal variant for a certain topic. The document did not use such a scientific and research methodology in any segment".
Radulović states that the editors of the Strategic Environmental Impact Assessment Report (third part), made up of 420 pages, themselves point out, especially in chapter 11 - Conclusions, the lack of data, that they expect the Analysis and Draft PPCG to undergo significant changes, that used data obtained through the GEF project, that valuable data can only be expected through spatial planning documentation of a lower hierarchical level.
He believes that the major shortcoming of the Report is that it does not offer the identification and solutions of numerous environmental problems, from wild landfills to "black spots", as well as the conditions, dynamics and time of fulfillment of the criteria from Chapter 27 - Environment.
Projections in the sphere of fantasy
In his analysis, Radulović states that there are numerous contradictions, conflicts, contradictions and superficialities in the document.
He believes that the author's projection that the population in Montenegro will increase from 622.271 in 2020 to 7,4 in 668.781 by 2040% is in the realm of fantasy.
"The authors also recommended indicators that GDP per inhabitant according to purchasing power will grow intensively to the level of the European average, which is extremely irresponsible if one considers the current ambiguities, wrong strategic decisions, global challenges, concrete sectoral reforms and solutions are not offered, their effects, the new economic policy is in line with the new EU policies. According to them, what would be the growth in Montenegro. Fantastic," he said.
He adds that sectoral projections - economic projections are full of contradictions and absurdities - do not even offer exploitation and conditional-balance geological reserves of mineral raw materials, which are non-renewable and which remained after illegal exploitation, and for whose condition individual processors are also responsible.
"There is not a single projection of how we will carry out the sustainable valorization of the remaining resources and create conditions for reindustrialization with competitive products and with medium and high technological content. They had to emphasize the aluminum, steel, wood, cement and agricultural industries in particular. They did not connect the remaining reserves of red bauxite with the production and processing of alumina and aluminum and the achieved effects respecting the context," he said.
He states that for the sector of exploration and production of hydrocarbons and gas supply and gas infrastructure, the only correct conclusion, which was missing, is that any further activity in this sector is a failure, bearing in mind the research results so far and the fact that these energy sources will soon be banned for use. or heavy fees will be imposed.
"Not a word about how to specifically revive the villages, how to preserve agricultural land, how much support should be in order for producers to be competitive with the environment and beyond. Even the field of tourism, which has been treated with better quality, does not offer concrete solutions on how to move from seasonal and extensive to sustainable and year-round".
Framework, oversized and outdated solutions in traffic
The draft PPCG, as it says in the field of transport, offers tentative, oversized and outdated solutions, destruction of space, "concreting" of Montenegro, failed and "shallow" investments, the damages that would result in the bankruptcy of Montenegro and the halting or prolongation of development.
"They base their decisions on the retrograde Traffic Development Strategy of Montenegro, the valid Spatial Plan of Montenegro and other documents. They had to know that the process of a major energy transition is already scheduled, that major means of transport in the EU must reduce CO2040 emissions by almost 2 percent by 100 , that it will produce a revolution in transport, that the new EU policy is based on new sectoral objectives. traffic".
He believes that the Adriatic-Ionian highway, the continental variant, as a transit road, can achieve a maximum average of about 4.000 vehicles per day, which is less than 20 percent of economic justification and much less than the projected possibility.
"When it comes to the Bar-Boljara highway, the justification for construction is with a volume significantly higher than 20.000 vehicles per day, i.e. more than 7,3 million vehicles per year, while the volume of vehicles in 2023 was only 2,29 million or 6.274 vehicles, which is about 30 percent self-sustainability".
He reminds that the total revenue from tolls during the last year was about 9,4 million euros, and the maintenance costs were about 8,1 million euros, so it will take more than 800 years to pay off the debt for the construction of the Smokovac-Mateševo section.
"According to many experts, the Bar-Boljara highway should continue to be built as a high-speed road from Mateševo to Boljara, as well as the Andijevica-border with Kosovo section. Also, the full bypass around Podgorica, the Podgorica-Budva and Podgorica-Bar sections, should be built as high-speed highways using the existing highways. The Adriatic-Ionian highway through Montenegro should be built as a fast road that would connect the bypass around Trebinje with Nikšić, Danilovgrad, Podgorica, Tuzi and Božaj".
As he added, when choosing the best variant of the high-speed road from Široki Brijeg to Sukobin, the construction of an underwater tunnel through the Bay of Kotor should have been considered.
"The priorities for the construction of the main roads should be fast traffic as a continuation of the construction of the corridor from Bar to Boljar and fast traffic from Široki Brijeg to Sukobin".
He believes that the development of railway transport should be one of the priority activities due to its increasingly significant role in freight and passenger transport, which the EU has decided to do.
"To this end, the developers had to offer a long-term development scenario of the primary and secondary network, which is characterized by an average operating speed of 160 km/h and connection with the TNT-T network and corridors and the valorization of the Port of Bar. Also, in the case of air traffic, they had to offer a scenario and a model urgent modernization of Podgorica and Tivat airports".
Radulović says that when it comes to maritime traffic, the authors rightly emphasize the establishment of a maritime line with Italy and along the eastern side of the Adriatic coast, maritime services based on EEQI principles, the "Blue Roads" network, connection with the TNT-T network and corridors, but apart from "dry" enumeration, no analysis is offered.
"They are not even deciding on the future of Bar Port and the construction of an LNG terminal. It is clear that it should not be built because, apart from environmental, geopolitical, spatial, explosively risky, visually degrading reasons, gas is a transit energy that will be prohibited for use".
According to Radulović, the announced model for the construction of hydroelectric power plants is wrong, and the ecological reconstruction of the Thermal Power Plant carries a great technological, ecological and economic risk.
"In terms of guidelines and development directions in energy, they had to offer a sustainable option - adoption of the National Energy and Climate Plan and the Law on Renewable Energy Sources, preparation of technical documentation for the construction of reversible and hybrid hydroelectric power plants on the Piva and Morača streams, valorization of Lake Bileć, mapping of the area for valorization of the potential of wind and sun, review of the granting of urban-technical conditions and concessions for the construction of solar and wind power plants, expertise and improvement of the ecological reconstruction of the thermal power plant, selection of the best model for the construction of new energy entities in the best public interest," he stated.
Waste management, as he says, should have been a segment of the document of special importance in order to solve the difficult situation as efficiently and rationally as possible and to fulfill the complex and extensive requirements from Chapter 27 - Environment.
"The quality of this part of the document is indicated by the fact that the authors do not distinguish between regional centers and regional landfills, where they are built and where not, they use data from the State Plan made in 2014 and not from the State Plan made in 2022, and are, for example, for organic waste, the differences are 35,1 percent and 40,7 percent respectively".
"A certain number of processors do not meet the criteria"
Radulović states that contradictions and absurdities have been a feature of the creation of the PPCG since the very beginning.
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 Aco Đukanović.
"Due to the poor quality of work and missing deadlines, Jovanović was dismissed and re-elected by several governments. The negative evaluations of all relevant and competent institutions and the public on Concept PPCG indicate such work. In this way, instead of completing the drafting of the new PPCG, as defined by the first contract in 24 months, today, after more than five years, we have a worthless Draft".
He points 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 linked to various "corrupt actions" that have devastated the space, resources and ecological potential of Montenegro.
"The selection criterion of many processors is the cooperation on numerous projects that RZUP prepared for the institutions of Montenegro in the interest of tycoons".
He says that the preparation of the PPCG should be left to CANA or UCG or the "Institute for the Development of Montenegro", which should be formed, and reputable institutes from the environment and the EU can also be collaborators.
"At the same time, we must work in concert on the creation of sectoral studies and 'mature' projects. At the same time, prepare the environment and establish the best cooperation with the EU and international institutions for a large, green and sustainable 'Marshall Plan', he said.
According to him, the attitude of the Government and the Assembly towards the proposed PPCG Draft will be a product of their competence and public interest.
"Until now, the government has not shown even minimal reform capacities, not to mention the expert knowledge that is needed for quality analysis. I am afraid that such a bad document will be adopted," said Radulović.
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