Dear Mr. Radunović,
Center for the Protection and Study of Birds, Kana/who if not an architect?, Biciklo.me, CEGAS, Montenegrin Society of Ecologists, Green Home, Program for the Environment, The Parks Dinarides instruct the Initiative to suspend the public debate on the innovative draft of changes and additions to the Spatial Urban Plan of the Capital City of Podgorica and the Report on the Strategic Environmental Impact Assessment and we invite you to act urgently in order to prevent such an important document from being adopted in an extremely inappropriate manner.
First of all, the current PUP of Podgorica was adopted for the period until 2025, so the question arises as to why the Ministry is dealing with changes and additions in December 2024, instead of drafting and adopting a new plan. Also, this process of point-by-point changes to the SUP of Podgorica towards the very end of its validity takes place directly after the adoption of the Spatial Plan of Montenegro until 2040, which as a basic strategic document should define the key goals and guidelines for spatial development and with which the SUP of Podgorica had to be harmonized. One gets the impression that the amendments to this plan are being adopted “by force” in the short term, absolutely unjustifiably before the higher order plan and before the adoption of the new Law on Spatial Planning and Building Construction, which could radically change the way local governments decide on planning its territory.
By reading the available documents, it is clear that these changes and additions to the SUP give space to the visionary ideas of the Government of Montenegro, but in such a way that in an extremely short period of time, in a non-transparent procedure and in complete contradiction to the statements of the Strategic Environmental Impact Assessment, changes are adopted that they prioritize the private over the public interest and which are disastrous for the most valuable areas of the Capital City. Here we specifically mean the areas within the Zeta Nature Park (Velje brdo, Mareza) and Ćemovsko polje, the importance of which is beautifully described in the Strategic Impact Assessment. In addition, a number of minor, point-by-point changes in the area of the entire Capital City, the purpose of which is not clear or explained in this document, and which may have an extremely bad impact on the quality of life in Podgorica, are also worrisome.
The text of the Draft Amendments to the SUP of Podgorica itself contains serious spelling and grammatical errors that make the document difficult to read, which supports our overall impression that the process of developing this important plan was approached in an extremely frivolous and unprofessional manner. The graphic part is presented through 53 pdf documents for which the interested public is expected to submit comments within only 18 days. At the same time, a large number of documents cannot be opened at all.
On behalf of the above-mentioned group of NGOs, we invite you to stop the ongoing process of drafting and adopting amendments to the PUP and to harmonize this process with the dynamics of the adoption of the new Spatial Plan of Montenegro and the new Law on Spatial Planning and Building Construction. This would give Podgorica a chance to develop and bring a really high-quality SUP that our city needs, but also show your will to make the area better, and not to open the door to corruption and processes that can threaten the environment and the quality of life of citizens, which is immediate impression.
Center for the Protection and Study of Birds
Bike.me
KANA/who if not an architect?
CEGAS
Montenegrin Society of Ecologists
Green Home
Program for the environment
Parks of the Dinarides
