Environmental Organisations Launch International Procedure:
Construction of “Komarnica” Hydropower Plant Violates the Bern Convention
Montenegrin Ecologists Society, in collaboration with the NGO Young Ecologists of Nikšić and the Organization “KOD”, has submitted a complaint to the Secretariat of the Bern Convention regarding the Government of Montenegro’s decision to grant a concession to the Electric Power Company of Montenegro for the construction, use, and maintenance of the Komarnica hydropower plant.
By approving the concession for the exploitation of the Komarnica area for hydropower development, Montenegro has violated Articles 3 and 4 of the Bern Convention. These provisions obligate signatory states to promote national policies for the conservation of wild flora and fauna, with special attention to endangered species, as well as Recommendation No. 157 (2011) of the Standing Committee concerning the conservation of wild animals and natural habitats.
The organizations argue that building this hydropower plant would breach both European and national environmental laws, including the legally binding Bern Convention – an important legal instrument for nature protection across the European continent and parts of Africa. Montenegro became a party to this convention in 2011 and nominated 32 EMERALD sites as areas of high biodiversity value, including Komarnica.
GigoThe goal of the Bern Convention is the preservation of wild species and their natural habitats and the promotion of European cooperation in environmental protection, with a particular emphasis on threatened habitats and sensitive species, including migratory ones. Signatory states are obliged to cooperate to strengthen the Convention’s effectiveness through coordination, information sharing, and best practices. The Komarnica Canyon is recognized under this convention as an important habitat, rich in wild flora and fauna—natural heritage of great value that must be preserved for future generations.
The Environmental Impact Assessment report for the project itself acknowledges that the area is of high biodiversity value and concludes that, in this case, economic development is incompatible with nature conservation. However, other legally required assessments were either omitted or not conducted in accordance with Montenegrin legislation.
Andrijana Mićanović (Montenegrin Ecologists Society): “Two days ago, we received confirmation that our complaint has been accepted as valid by the Bern Convention Secretariat, which will now forward it to the relevant institutions in Montenegro. These institutions have until September 15 to respond to our claims that the construction of the Komarnica hydropower plant would completely destroy local flora and fauna and their habitats, permanently degrading the area’s ecological value and violating this legally binding Convention.”
Bojana Živković (KOD Organization):
“This is a crucial step toward the preservation and sustainable use of the Komarnica River. For decades, Montenegro has missed opportunities for sustainable economic growth—something that directly impacts the quality of life of its citizens. Protecting Komarnica is both a step toward responsible development and an investment in better living conditions.”
Miodrag Karadžić (Young Ecologists of Nikšić):
“There are far more reasons to protect one of the most beautiful and last surviving canyons in Europe than to flood it for minimal economic gain. The loss and degradation of biodiversity would be permanent and irreversible. Habitats would disappear, and in return, Montenegro and the local community would gain very little.
All current plans and narratives surrounding the Komarnica hydropower project remain vague. Frankly, it seems like the strategy is: ‘Let’s build the power plant first, and then we’ll figure out how much electricity it will actually produce.’”
CONCLUSION
Komarnica, home to dozens of species of European importance and a nominated Emerald site (ME000000P), faces the threat of destruction by a planned 172 MW hydropower plant, with a 171-meter-high dam and a 17.6 km-long reservoir. This project would have numerous harmful impacts on protected habitats and populations, resulting in irreversible biodiversity loss.
The step taken toward the Bern Convention Secretariat is a response to the lack of seriousness and persistence in Montenegro’s EU integration process, the poor treatment of the environment, and the dangerous prioritization of short-term economic goals over long-term societal well-being and intergenerational justice.
