Podgorica, 22 April 2012 - We can not agree with the statement of the Minister of Sustainable Development and Tourism, Mr. Predrag Sekulic that a potential “building of HPP on Komarnica River shall not affect the natural beauty and cultural heritage" of the area. We consider this statement very irresponsible, since it is commonly known that each dam carries more or less negative impact on the environment and that Detail Spatial plan for multipurpose reservoirs on the River Komarnica (DPP) besides constructing of dam for HPP on Komarnica River includes the construction of 17 more dams on this river basin. We remind the Minister that it is precisely a goal of the Strategic Environmental Assessment (SEA), besides looking at all the positive and negative aspects of this project, to define the measures to mitigate the negative impacts that should definitely happen. The statements with the aim to manipulate the public and focused at creating one-sided opinions can not provide a good atmosphere and contribute to deepening the dialogue necessary for making the best solutions. For this reason, we hope that the professional and the interested public will take active participation in upcoming public discussions in order to get more realistic insight when it comes to justifying the negative impacts and risks that HPP on Komarnica River would cause.
When it comes to the content of the DPP and SEA, it is disappointing to see that the drafts of these documents repeat the same mistakes as in the case of development the SEA for HPP on Moraca River. Just as with SEA for Moraca River, there are no alternative solutions in SEA for Komarnica River developed and described in detail in the technological, environmental, economic and other terms, but it provides an alternative "not build anything" which has no legal standing in Law on Strategic Environmental Assessment or by any international standard in this area. This indicates a misunderstanding of the term "alternative solutions", given that consideration of alternative solutions should be one of the crucial tools of impact assessment, whose ultimate aim is to analyze the different possibilities to accomplish a goal, and that is the case in Montenegro to reduce the energy deficit or to create new energy sources that are least harmful to the environment. In any case this cannot be achieved by the do nothing option and it cannot represent an alternative solution.
The project of building such dams are talking about the flooding of vast areas, which means permanent loss of nationally and internationally important species and habitats, but also a unique landscape and canyon complexes of special value. Having this in mind it is essential to carefully, in detail and objectively look at all the risks and negative impacts in order to define extent of mitigation that would be primarily in the interest of preserving the natural values of this area.
Given the money and time spent on making these documents, having in mind that the decision for making DPP was adopted in June 2010 the statement that the extent of negative impact on rare flora and fauna in the region "is not possible to fully assess due to poor availability of data" is unacceptable. However, statement about the lack of biodiversity data brings the need for additional research before making a final decision on construction because without such data strategic assessment of environmental impact cannot give an positive opinion.
Particular attention will require the issue of building an additional 17 dams in the catchment area, whose impact on the environment is not thoroughly considered. It is also questionable, and their compliance with the Spatial Plan of Montenegro and the current Strategy for Energy.
We remind the competent authorities and the public that it is about a canyon of the river which belongs to the EMERALD international ecological network of protected areas, and that it is currently being worked on drafting the Law on National Parks, which provides for the expansion of NP Durmitor area on Komarnica River Canyon, which requires special consideration with real insight on negative impacts in accordance with the requirements of relevant EU and national legislation in this area. Particularly questionable is the sensitive part of the canyon Komarnica, known as Nevidio located in the planned scope and the exceptional natural and tourist value since it is protected as natural monument. The plan provides for direct contact of the future lake water and canyon Nevidio which can be very conflicted in terms of conservation and tourism development of this canyon.
We are talking about an area that belongs to the Black Sea basin, which is of international value and in this case there are possible cross-border consequences. In this regard, and according to the ESPOO Convention which Montenegro is a signatory, we need to make an accurate analysis of cross-border impact and reach an agreement and cooperation with neighboring countries that belong to this basin.
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