The strategic environmental impact assessment report concerning the Spatial Plan up to 2040 addresses various criticisms and proposals for changes, including calls to eliminate certain projects. However, due to its status as an administrative action overseen by the Environmental Protection Agency—subject to appeal by the Ministry of Spatial Planning—it cannot be publicly released while the appeals process is ongoing, as explained unofficially to “Vijesti” by the agency.

This report was approved on June 23, with a 15-day appeal window. The government adopted the draft of the Plan on June 12, prior to the Report’s availability. Two parliamentary committees endorsed the Plan without considering the Report, and the Parliament’s debate was initiated and concluded yesterday, despite deputies lacking access to this critical document. The vote is anticipated in the coming days, potentially before the appeal deadline and the Report’s release, raising concerns about the adoption of such a vital document, termed by the Ministry of Spatial Planning as second only to the Constitution, without legislators being fully informed.

The law mandates public awareness

The Agency evaluates the Spatial Plan solely through its Strategic Environmental Impact Assessment, prepared by a different drafting group representing “Entasis,” which secured the contract through a prior tender. Although the Strategy is meant to integrate with the Spatial Plan, this has not occurred, and the Assessment remains unpublished during Parliament’s deliberation, which contradicts the Law on Strategic Impact Assessment mandating public access to such documents before decisions are made. The Report and the Agency’s approval of the Strategic Assessment are pending the expiration of the appeal period.

The recently adopted Report is a revised version, replacing the initial report released in January regarding an earlier draft of the Spatial Plan that underwent public discussion. Since then, amendments have been made to the Plan, including the incorporation of the Velje Brdo residential area and adjustments to the Adriatic-Ionian Highway and coastal expressway routes, making the new version essential in light of these changes.

According to information from “Vijesti,” notable objections target ongoing projects that the Government is attempting to advance, including Velje Brdo, Velika Plaza, Buljarica, and the hydroelectric plants “Komarnica” and “Gornje Kruševo,” along with sections of highways and expressways, plans for new beaches, and education and health facility developments. Some objections were noted in the January report, yet none were incorporated into the final version of the Spatial Plan presented to MPs.

Throwing away the hill is better

The “Velje Brdo” project, which envisions a new residential settlement for 40,000 inhabitants, is briefly referenced in the Spatial Plan, noting that it will be elaborated through municipal urban planning.

“While preparing the PPCG-2040, the Government of Montenegro initiated and decided to construct a residential area in Velje Brdo, intending to provide a stock of apartments at reasonable prices with state oversight. More detailed planning will define spatial capacity, infrastructure, and area protection to implement this public interest project,” the Plan states.

According to “Vijesti,” the report entirely dismisses the proposed residential settlement on this hill as it lacks the requisite preliminary studies and analyses of the natural features and suitability for construction. Additionally, the need for such a significant number of new apartments remains unproven, considering the existing surplus in Podgorica.

It argues that housing accessibility for specific population segments should be addressed through tax policy rather than by constructing a massive new settlement. Furthermore, Velje Brdo is identified as a critical green corridor crucial for mitigating air pollution and climate change, warranting its preservation, and part of this area is already designated within the protected Zeta River Nature Park, which poses further constraints on the proposed planning.

What’s unacceptable for the airport?

The Report indicates that Montenegro, in its EU accession process, must establish the international Natura 2000 network of protected areas by closing the 2000 negotiation chapter related to environmental protection. This network includes regions like Velika Plaža, Ada Bojana, Solana, Buljarica, Piva, Komarnica, and more—many of which are earmarked for various tourism, energy, and transport projects.

The report entirely opposes the construction of an airport in Štoj, citing its location within a protected zone. It also notes that the updated Ulcinj Plan connects the existing travel routes to airports in Podgorica and Tivat, allowing for quick access. Building an airport there would devastate large habitats deserving the highest protection, which Montenegro, in its EU integration efforts, is obligated to preserve.

Preserve Solana, Velika Plaža, and Bojana

The Salt Pans area is deemed a unique ecosystem requiring preservation without future infrastructural interventions while encouraging controlled salt production and ecotourism in the vicinity.

Velika Plaža, where the government and a UAE investor plan a new city valued at €35 billion, is labeled as a biodiversity center due to its rich species diversity and the number of threatened species and habitats protected by national and international legislation. According to EU directives, construction is prohibited in parts of Velika Plaža occupied by dunes and ponds, along with the remaining 50% of this NATURA 2000 habitat. Natural vegetation preservation is emphasized, permitting only the development of limited accommodation facilities in designated areas.

For Ada and the Bojana Delta, no substantial infrastructure projects are proposed in energy, tourism, or transport sectors, ensuring the coastal zone, wetlands, the Bojana River, and aligning streams are safeguarded against pollution and over-urbanization. The Spatial Plan’s proposal to facilitate navigation along the Bojana River and Lake Skadar is rejected, being an international RAMSAR area where nautical activity is deemed unacceptable.

Restricted construction at Buljarica

In the Buljarica area, where the Plan permits development of extensive tourist facilities, at least 170 major protected species have been recorded. The saline lagoon and Mediterranean salt meadows must be kept entirely free from construction, along with a minimum of another 50% of representative NATURA 2000 habitats, to be determined via a more thorough area survey.

Full protection of the Tivat Salt Flats from construction is necessary, preserving its current integrity.

In Luštica, already affected by urbanization, portions should be safeguarded from urban development projects, incorporating the establishment of green corridors.

In the protected Zeta River area, it is advised that no industrial development, even on a small scale, occur. Recommendations include promoting ecotourism, alongside constructing small rustic facilities, cycling, boating, and organic farming with strict limitations against urban expansion.

Sinjajevina reserved for pasture

The spatial plan for Sinjajevina continues to allow military usage, along with development in tourism and agriculture. The report emphasizes that Sinjajevina encompasses 16 types of NATURA 2000 habitats, necessitating its preservation as one of Europe’s largest grasslands.

Regarding the expressway from Budva to Herceg Novi, its route over the bay remains undecided. It is deemed unacceptable to finalize the Spatial Plan without clearly designated primary transport corridors, noting that the route through Luštica and Kumbor bridges proximity to protected areas.

The highway segment from Andrijevica to Serbia is noted for its impact on habitats, water systems, and the migratory paths of large mammals, urging alignment with existing roads wherever feasible.

Unclear educational and health service needs

The Report stresses the necessity of a thorough demographic overview of Montenegro, accounting for the number of children per municipality and the existing primary, secondary, and preschool institutions, which are critical for establishing realistic educational development goals.

It highlights a lack of clear indicators regarding the current educational situation that could guide further development and goal achievement, with the same principle applying to health, social, and child protection sectors.

Concerns are raised regarding the absence of defined data on the number of missing institutions per municipality and the required health facilities needed for adequate treatment.

Hydropower plants deemed necessary; alternatives should have been considered

The Report offers guidance for designing energy facilities outside protected areas, particularly for the “Kruševo” and “Komarnica” hydroelectric power plants.

It emphasizes the need to consider the anticipated decommissioning of the Thermal Power Plant, indicating that developing numerous uncontrollable energy sources (solar and wind) necessitates additional controllable hydroelectric capacity.

It acknowledges the need to incorporate hydroelectric power plants post-TPP shutdown for stabilizing production, as solar and wind rely on weather conditions for generation.

However, the proposed hydroelectric power plants conflict with protected areas, highlighting the absence of a clear development vision hindering project execution.

The “Kruševo” hydroelectric plant is positioned in a segment of the “Dragišnica-Komarnica” Nature Park, thus violating the Nature Protection Law’s provisions.

Komarnica Canyon is one of 32 areas in Montenegro nominated for EMERALD protection.

The report advises reconsidering alternative sites for proposed developments in the Spatial Plan.

It also rejects the proposed Boka hydroelectric power plant, which involves diverting water from Montenegro’s section of Lake Bileća to a hydroelectric facility near Risan, calling it unacceptable as it would significantly affect freshwater availability in the bay.

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