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Conclusions of the coordination team for the protection of the River Lim

Podgorica, 05 february 2013 - Meeting of the NGO representatives for the protection of the River Lim, which was held on Wednesday, 12.30.2013 in Bijelo Polje brought together the significant number of representatives of civil society from Serbia, Bosnia and Herzegovina and Montenegro, representatives of the local communities, fishing clubs, local self government, informal local networks and associations, as well as the media.


The meeting resulted in the formation of coordinating team of NGO from Serbia, Montenegro, and BIH for the protection of the River Lim. Board was established with the aim of organized monitoring, planning activities and common interventions in the procedures, legal and planning course of the hydro power plants Brodarevo 1 and 2 on the River Lim. The coordination team have 8 representatives, led by the team leader Almer Mekić NGO Euro Most, Bijelo Polje, and the rest of the members: Milorad Mitrović NGO Mreža Sjevera, Pljevlja, Amel Kurbegović NGO Koordinacioni tim za zaštitu rijeke Lim Prijepolje, Nataša Kovačević NGO Green Home, Podgorica, Jasna Hasanagić NGO Ekološki pokret, Priboj, Dragoljub Simović NGO Rafting klub Prijepolje, Radoje Mišković from local community Baranselo Berane.


After several hours of discussion, information exchange and detailed analysis of studies on the environmental impact assesment of hydro power plants Brodarevo 1 and Brodarevo 2, submitted in mid January 2013 by Serbia to Montenegro, coordinating team concluded:


- From the published environmental impact assessment study is clear that it is planned to build hydropower plants Brodarevo 1 and 2 at the border with Montenegro, which requires a environmental impact assesment study in transboundary context, what in this case is missing.

- Documents on Spatial plan of the special purpose for building these plants – which is not presented to the Montenegrin public – consists high level of possibility that accumulation Brodarevo 1 encroaches on the territory of Montenegro, territory of the municipality of Bijelo Polje.

- That Republic of Serbia, through its Ministry in charge of environmental protection, broke the law and international obligation of including the state Montenegro and its public in the environmental impact assessment for the hydropower facilities Brodarevo 1 and Brodarevo 2 on the River Lim.

- That in the process of the environmental impact assessment study for hydropower plants Brodarevo 1 and Brodarevo 2, which is pending in the Serbian Ministry that is in charge of environmental protection, there was a serious violation of the law on Environmental impact assessment of Montenegro and the Republic of Serbia (article 23) and the relevant provisions of the ESPOO Convention (article 3) on cross – border cooperation and public participation of Montenegro in the process of writing, by which interested public of Montenegro was completely prohibited in participating in this process, from the moment of deciding on the scope and content of the above impact studies, three years ago.

- The study on the environmental impact of the hydro power plants Brodarevo 1 and Brodarevo 2, submitted to Montenegro from Serbia, does not process Montenegrin territory at all, neither negative or other impacts of these energy facilities on Montenegro, and as such is not eligible to give any opinion on it by the Montenegrin stockholders and experts.

- From the standing point of the interested Montenegrin public it is completely necessary to provide legal conditions for participation of Montenegrin public in this process, and that it is possible to provide only by CANCELING THE PROCESS, which is run ilegaly by Serbian Ministry without the involvement of the Montenegrin government and the public, and returning procedure in the phaze of decision about giving solutions on the scope and content of the impact study – when Montenegrin public for the first time in accordance with the law, had to be included in the process.

- That interested and professional community of Montenegro may comment on environmental impacts of these large hydro power plants only when new study is constructed in the legal procedure, which will contain chapters about the impact of these hydro power plants on territory, natural and other values of Montenegro.


From the mentioned reasons, it is required from the Government of Montenegro, the ministry responsible for the environment and the ad hoc expert committee for evaluation of the cross–border impacts of the HPP Brodarevo 1 and Brodarevo 2 to Montenegro, to draw a conclusion stating:


1. That the present proceedings to the front of Serbian Ministry are illegal and contrary to international standards and commitments by ratifying Espoo and Aarhus Convention, because the Republic of Serbia had not respected the legal deadline for informing Montenegro on the procedure of estimating the environmental impact assessment of hydro power plants Brodarevo 1 and 2, which prevented Montenegro to conduct timely and effective procedure of informing and participation of Montenegro in the process of cross–border EI assessment on Montenegro by the hydro power facilities Brodarevo 1 and Brodarevo 2 in accordance with their national legislation and standards.

2. Provided study on EIA for HPP Brodarevo 1 and 2 is not suitable for comments of the experts on the impact of these objects on the territory of Montenegro, because it does not contain a chapter on the impact on Montenegro.

3. Because of these reasons it is required from the public of Serbia to RESET procedure and return it in the initial stage, so that state of Montegro and its public can be able to participate in the beginning of the environmental impact assessment, so this process would be an effective remedy, in terms of standards of the International Convention on Human rights.


The coordination team will discuss these and other illegal, malicious and rough violations of the rights and interests of citizens, and we will also inform commitees for complaints of Aarhus and ESPOO Convention, as well as  national judiciary and anti–coruption bodies of Serbia and Montenegro, in order to prepare criminal and other proceedings against legal and private individuals when there is a suspicion in issuing of administrative acts to REV Company Ltd, which intends to build dams on the River Lim, commiting criminal acts of misconduct, falsification of official documents, money laundering and so on.


Coordinating team expresses doubt and fear in the process of issuing building permits for the hydro power plants Brodarevo 1 and Brodarevo 2 to REV Company Ltd, as a legal entity with no credit rating and references in the field of construction at power facilities. We also express doubt that those are elements of massive corruption, and that in making of these EIA studies are involved companies with questionable business ethics, whose related legal entities are on the black list of the World Bank. Coordinating team informs the public, that it is in preparation of a protest meeting that would be held on March 15, 2013. For the International Day of Action for Rivers and Against Dams, in the place Kumanica on the border between Serbia and Montenegro, on which will be gathered representatives of the NGOs, representatives of municipalities from Montenegro and Serbia which are affected by the plan of building hydropower plants on the River Lim.


More information at: natasa.kovacevic@greenhome.co.me