Shadow Report Presentation for Chapter 27: "Progress on Pause"

In anticipation of the European Green Week, Coalition 27 presented the Shadow Report for Chapter
27: “Progress on Pause”, which aims to present an overall picture of Montenegro’s progress in the
EU accession process for the period from January 2022 to May 2023, in terms of improving the
situation in the field of environmental protection and climate change.
The report deals with ten thematic areas from Chapter 27, and refers to the implementation of the
remaining obligations from the National Strategy, which are now an integral part of the Action Plan
for meeting the final benchmarks in Chapter 27 – Environment and Climate Change.
The evaluation of the implemented activities in this area, can be sensed already in the very title of
the report “Progress on pause” (draft), and in addition to the analysis of essential problems, the
readers of the report also have a set of recommendations for strengthening the process of
transposition and implementation of EU legislation included in Chapter 27.
The report was presented by Ksenija Medenica in front of the Center for the Protection and Study
of Birds, Azra Vuković from the NGO Green Home, Milica Kandić, a consultant, and Miodrag
Karadžić from the Society of Young Ecologists and Northland.

The preparation of the report was coordinated by Milica Kandić, as an external expert, who
presented the methodology and a comprehensive overview of the report.
When it comes to the sub-field of Nature Protection, the report showed that certain progress has
been made in this area, said Ksenija Medenica in front of the Center for the Protection and Study
of Birds.
“It is primarily reflected in the initiation of the process of amendments to the Law on Nature
Protection and the Law on Forests, which should be adopted as soon as possible.” Also, revisions of
the protection studies for the National Parks: Durmitor, Lovćen and Skadar Lake have been
initiated, while the revision process for the NP Biogradska Gora has been completed, and the final
step remains for the study to be adopted. It is also positive that the creation of protection studies
for new areas has been initiated: the river Mrtvica and its surroundings, the Draft Protection Study
for the Great City Park in Pljevlja and the procedure for the preventive protection of Valdanos and
Maslinada in Ulcinj. Work on the establishment of Natura 2000 continues, and the preparation of
Red Lists for amphibians and reptiles, plants and fish is underway,”- Medenica said.
However, even though there is some progress, the nature of Montenegro is threatened and it is
necessary to devote oneself to solving numerous problems in this area.
“First of all, the management of protected areas stands out as a problem. The national parks of
Montenegro have been without management plans since 2020. They are currently being prepared,
but it is a paradox that they will be adopted in the second half of the current year, but for the period
from 2020. to 2025. It is encouraging that the preparation of the Plans was finally approached
thoroughly, so we hope for quality documents and their implementation in the near future.” –
Medenica said.

Then she emphasized that protected areas, apart from bad management, are also threatened by
unplanned construction.
“Examples that show this are the building permits issued in Prokletije National Park in the heart of
the park, in the Grebaje valley. Then, the consequences of the construction of the highway on the
river Tara, but also some future plans, such as the announced construction of the bridge on Bojana,
which has been announced several times in the media and has no basis in plain planning
documentation. Poor spatial planning in valuable areas has long been a topic in the international
community, so the case of the construction of Porto Skadar Lake and HPP Komarnica, has the
attention of the Berne Convention, which has sent recommendations to the Government of
Montenegro for both cases. „- Medenica drew attention.
As in previous years, the problems of the Ulcinj Saltworks have a special place in the Report. The
unresolved issue of the management structure, four years after the declaration of the protected
area, is the biggest obstacle to the implementation of measures to protect this area.
“The ignorant attitude of the local government towards the obligation that they should have
fulfilled a long time ago is particularly worrying.„ – Medenica said.
One of the particularly significant issues in the field of nature protection, which has never been
included in the Progress Report of Montenegro, is the issue of poaching. As Medenica says, despite
numerous initiatives to change the legislative framework, references to the need for reform of
hunting in Montenegro, as well as requests for better intersectoral cooperation, in the past year the
competent Ministry of Agriculture has done absolutely nothing to solve the problem of poaching.
“Finally, in the field of nature protection, cases of the construction of a military training ground in
Sinaia are also described, which is apparently still being planned despite the importance of this area
from the point of view of the richness of biodiversity and despite the petition of the citizens’
initiative, which has over 22 thousand signatures of dissatisfied citizens of Montenegro.“ –
Medenica concluded.

Azra Vuković from the NGO Green Home referred to the sub-area on waste management and said
that the adoption of the new Law on waste management is 5 years late.
“Also, the State Plan for Waste Management in Montenegro, 2023-2028, has not been adopted.
Implementation of local waste management plans is at a very low level or non-existent. It has been
estimated that 25,000 t are disposed of annually at the unorganized landfill in Mislov do.“
In her presentation, Vuković emphasized that the Report on the Implementation of the State Waste
Management Plan in 2021 indicates insufficient infrastructure for primary selection, that citizens’
awareness of primary selection is insufficiently developed and there are no incentive measures for
citizens to selectively separate waste.
In addition to the obvious problems, there are recycling centers in Podgorica, Herceg Novi, Kotor
and Žabljak. Also, recycling yards.
“There are also regional landfills for non-hazardous waste in Podgorica and Bar (Livade and
Možura), waste vehicle processing facilities in Podgorica (1) and Nikšić (3). We also have recycling
yards in Podgorica, Budva, Mojkovac, Plav…” – Vuković reminded.
However, the situation in some municipalities is not good.

“The municipality of Plav, although it has a recycling yard with a sorting plant, does not have data
on the amount of separately collected waste. Even though the municipality of Žabljak has a
recycling center, it does not serve its purpose and the decision on selective waste disposal is not
applied. In the municipality of Kotor, there is the first composting plant in Montenegro to solve the
issue of green waste management in the municipalities of Kotor, Tivat, Budva and Herceg Novi,
however, the installed capacities are not sufficient. Most municipalities dispose of waste at
temporary landfills.”- Azra said.
Also, only 9 municipalities submitted data on the amount of collected non-hazardous construction
waste. Only 3 municipalities have a defined temporary location for non-hazardous construction
waste.
“Regarding the question of the treatment of hazardous and non-hazardous waste, the register of
polluters was prepared and put into operation, however, it is not in use due to cyber attacks and the
problem has not yet been resolved,” – Vuković pointed out.
Some of the key recommendations, as Vuković says, in order to solve the problem of waste
management, would be the new Law on Waste Management, the drafting and adoption of the
National Waste Management Plan in Montenegro, the adoption of Local Waste Management Plans,
and the provision of incentive measures for citizens in order to implement primary selection,
strengthen administrative and operational capacities at the state level, strengthen cooperation
between state and local authorities, ensure the functioning of the register of hazardous waste
polluters and many others…
Miodrag Karadžić from the Association of Young Ecologists presented the sub-area of air and
water quality.
A general overview of the situation in the sub-field of water quality shows that the legislation is
fully aligned with the EU acquis (the law was adopted in 2007, amended and supplemented in 2015,
as well as in 2018).
“However, the register of waters of importance for Montenegro and for waters of local importance
has not yet been created, a water information system, national and local operational plans for the
protection of waters from accidental pollution for waters of importance have not been established.
Inadequate sewage networks for the collection and removal of fecal water are significant problems
in the functioning of existing treatment plants, which call into question the efficiency of the
management of the waste water system and, therefore, the quality of surface and underground
water. It can be said for certain plants that the choice of contractor was also questionable.” –
Karadžić said.
According to Karadžić, according to the findings of the State Audit Institution, sewage sludge is
mostly stored within the plant, although its application is defined by the Law on Waste
Management and the Rulebook on the specific conditions that municipal sewage sludge should
meet. At the level of the State and local self-governments, there are no sewage sludge management
plans, which would define the method of treatment and handling of it.
In the Report itself, several key recommendations are listed, when it comes to the sub-area of
water quality.

It is important to establish Registers of waters of importance for Montenegro and waters of local
importance, Establish a Water Information System, which, among other things, contains the
cadastre of water polluters; It is necessary for commercial, water supply and sewerage companies
that manage waste water treatment plants to establish reliable measurement of the amount of
waste water; Adopt a Sewage Sludge Management Plan that would define the manner of handling
and treatment of the resulting sewage sludge both at the state level and at the level of local self-
governments, and many others. – Karadžić said.

The cadastre of pollutants has not been established, so adequate data on air pollutants have not
been provided. Polluters do not monitor and do not submit reports on the conducted monitoring to
local governments and the Agency. There is no monitoring of indoor air quality or assessment of the
cumulative effects of pollution on public health.- Karadžić said.
In March 2021, Montenegro submitted to the European Commission an analysis of economically
viable emission control strategies for 2020 and 2030, which serves as the basis for the final
agreement between the EU and Montenegro on its obligations to reduce emissions under the NEC
Directive. In January 2022, the European Commission gave the green light to this document with
the recommendation that Montenegro must define obligations to reduce emissions in accordance
with the National Energy and Climate Plan, which has not yet been adopted to date, i.e. almost two
years later.
Karadžić sees achieving the prescribed air quality in all zones as the biggest challenge in the area of
air quality.

The increased concentration of suspended PM particles, especially in the municipalities of Pljevlja,
Bijelo Polje, Podgorica and Nikšić during the heating season, is worrying both because of the
frequency and the amount of concentrations, despite the fact that these municipalities, with the
exception of Bijelo Polje, have adopted action plans to improve quality air – he said.
Some of the key recommendations for this area would be: to update the draft of the Air Quality
Strategy with new data from the emissions inventory as well as with established emission
reduction targets; Adopt air quality plans for zones where pollutant concentrations exceed any
established limit or target value, with Action Plans for its implementation; Initiate amendments to
the Law on Air Protection in order to more precisely determine the obligations of local self-
governments regarding the adoption, implementation and reporting of measures provided for in
local action plans; Ensure adequate functionality of air quality monitoring stations in the State Air
Quality Monitoring Network; Establish a functional cadastre of pollutants and many others..

The report was prepared within the framework of the project “Strengthening the participation of
civil society in the area of the environment in the EU accession process (4E)”, which is financially
supported by the European Union, through the program “Civil Society Facility 2021 and Thematic
Program on Human Rights and Democracy 2021″.

Shadow Report Presentation for Chapter 27: “Progress on Pause”

Shadow Report Presentation for Chapter 27: “Progress on Pause”

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