The Local Community Council of “Kavač” has urgently reached out to Minister of Spatial Planning, Urbanism, and State Property Slaven Radunović, along with the relevant urban planning and construction inspection authorities, the Municipality of Kotor, and other responsible institutions to evaluate the ongoing construction of a complex consisting of nine buildings above the Vrmac tunnel.

“Kotor is facing a construction invasion from multiple fronts, and presently, Kavač represents the largest construction site where numerous projects are not adhering to regulations, posing a threat to local residents. We urge you to ensure our protection,” states the letter accessed by Vijesti.

Residents are cautioning Radunović about the project’s controversial nature on various levels, arguing it does not align with urban planning and technical specifications, and its development could result in lasting repercussions for the citizens of Kotor.

They assert that the traffic project fails to meet the urban and technical conditions (UTU) outlined in the Kotor Spatial Urban Plan (PUP).

“According to the UTU issued on November 23, 2023, by the Ministry, under point 17.3, the criteria for connecting to the traffic network are defined, which aligns with the PUP of the Municipality of Kotor, stipulating that newly constructed units must be accessible from lower-level roads. The UTU identifies plots formally designated as a passageway and linking to roads owned by the Municipality of Kotor, all as per the documentation provided by the Secretariat for Entrepreneurship Development, Utilities, and Traffic. The documentation also includes conditions requested subsequently by the Traffic Administration dated October 12, 2023, indicating the necessity for a four-way intersection at the tunnel’s exit, a point of contention that remains vague.

The only authoritative document for conditioning issuance is the Kotor Municipality’s Urban Development Plan, which lacks designation for any intersections at this site. Establishing such an intersection right at the exit of the Vrmac tunnel on the M1 highway sets a dangerous precedent, being a known accident hotspot just a few hundred meters away, where incidents have tragically resulted in fatalities,” warns the Kavač Local Community Council.

Investigate Numerous Failures

The community asserts that constructing a connection to the main road on its busiest stretch for the entire newly planned settlement starkly contradicts the established conditions, plans, and expert assessments.

“Who has directed the alteration of conditions from the Traffic Administration, disregarding the existing ones in the plan? We demand accountability from the individual responsible for signing conditions not grounded in the plan, which overlook the current conditions from the UTU,” the local community emphasizes, insisting on an investigation into the reasons behind the dismissal of official conditions from the PUP and the introduction of new ones that are inconsistent with the planning document.

They voice concern over whether the project has obtained the necessary approval for connection.

“Furthermore, it’s essential to highlight that for the current complex, the plan for constructing and safeguarding the foundation pit includes driving piles, with provisions set within the immediate vicinity above the tunnel route. Approximately 15 years ago, during the tunnel’s reconstruction, the area above the tunnel route experienced ground collapse, traces of which are still evident today. The Roads Administration and the Ministry, being the governing bodies, must recognize that construction in the area above the tunnel poses risks, especially where underground levels and pile driving are concerned. The Vrmac Hill is not solely karst rock; it comprises layers of gravel, increasing the likelihood of soil failures and jeopardizing the tunnel’s traffic safety. The current condition of the tunnel is already precarious, and encroaching on the area above it could have severe consequences. We expect a thorough investigation and annulment of the numerous discrepancies that have occurred,” the locals demand.

Wastewater and Environmental Risks

The UTU indicates, as highlighted by MZ “Kavač,” that there is no sewage system in place for that area, stipulating individual waste treatment via bio-septic systems.

“It must be underscored that the issuance of these conditions did not consider the investor’s plan for the specific location, which is not intended for a single structure but rather for a complex of nine buildings and a substantial swimming pool. The blueprint also includes underground garages. This site is situated above the Vrmac tunnel, which houses one of the three primary springs that provides Kotor with potable water. Vrmac Hill, where the tunnel’s catchment exists, has already encountered significant water loss due to past construction activities during the tunnel’s renovation some 15 years ago, which adversely affected a water branch and subsequently diminished the spring’s yield. The anticipated construction of this complex, with planned work above the drinking water reservoir network in the Vrmac tunnel catchment, including pile driving, along with underground floors and ultimately, bio-septic tanks with potential overflows above the catchment area, poses a dire environmental threat and jeopardizes the drinking water source for Kotor. “There is no doubt that permitting this construction would inevitably lead to adverse outcomes,” locals stress.

The State’s Duty to Protect Us: A Breach of Constitutional Rights

The Local Community “Kavač” states that the Environmental Impact Assessment Study has yet to be finalized.

“We have submitted our comments and recommendations to the Environmental Protection Agency and the Secretariat for the Protection of Cultural and Natural Heritage within the legal timeframe and await their response. Nevertheless, the project underwent revisions, and the Application for Works was posted on the ministry’s website despite being unlikely after the December deadline, when the public discussion of the Study continued until February 5 of this year.

Numerous legal inconsistencies surround this matter, prompting us to seek a review of the procedures for the aforementioned project, to scrutinize all actions taken outside professional and legal standards, and to be informed of the outcomes. Anyone endorsing this bears responsibility for the likely disaster that construction may inflict on the public good and the city of Kotor. While the Kotor Urban Development Plan originally contemplated development in the area, the unification of this location and the prospect of erecting large structures in such a sensitive area puts infrastructure matters of general concern at risk.

“This solely concerns the investor’s profit, rather than any consideration for the valorization of space or facilities of general interest, highlighting the necessity for state intervention to safeguard our rights, as this constitutes a breach of constitutional rights,” concluded the local community.

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