Dragana Šćepanović
In the Komovi Nature Park, which territorially covers the municipalities of Podgorica, Kolašin, and Andrijevica, no first steps have been taken towards establishing effective protection and management.
The Komovi Nature Park (NP), recognised as an area of international importance and nominated as an Emerald site, has two permanent and one temporary managers whose work so far has lacked cooperation and coordinated activities. The State Administration for Forest and Hunting Management, on the other hand, decides on the use of the park’s forests, signing contracts for exploitation with numerous private companies.
In the Podgorica area, three private companies are using the park’s forests this year, and in the Kolašin area, even five private companies. According to ten-year management plans, from two forestry units in the Kolašin municipality within the park, by 2027 and 2029 respectively, a total of 144,000 cubic meters of gross wood mass is planned to be cut. On two forestry units in the protected area belonging to the Capital City, six contracts for the use of state-owned forests have been concluded this year, amounting to 12,247 m³. There is also illegal logging.
So far, the nature park has not served as an opportunity for the development of local communities nor as a chance to start local food production based on preserved nature, claim the Montenegrin Society of Ecologists (MES). On the other hand, they explain, when one company manages the park, it should also manage the forests and waters of that park because, they remind, “that area received the status of Park precisely because of the natural originality of its waters, forests, animal and plant life.”
“We witness that disrespect for the law and disregard for scientific facts is the main reason for the existence of park companies that do not know how to create a model of self-sustainability but only wait for money from the state and remain dependent. Such companies reduce their main task—nature and local community conservation within the park—to installing gates and charging entrance fees, while nature is left to fend for itself. No company can manage nature if it does not understand it,” say MES.
They add that nature parks in Montenegro are not companies that study nature and, based on research data, create management models but have turned into municipal companies that serve to employ people through party lines. MES assesses that “companies managing parks can become profitable after five to ten years of work, and if they do not work on their financial stability and sustainability, both locals and nature dependent on them will suffer.” Protection of nature has been presented to locals as a ban on forest cutting and hunting instead of a brand for a village. Local communities, they claim, can prosper if they establish a quality resource-use model that does not impoverish either them or their environment.
Companies responsible for Komovi NP currently only care for furniture, ticket sales, and signposts. More extensive activities are hindered by lack of money, scarce equipment, few rangers, lack of experts, and often overlapping jurisdiction with the Forest and Hunting Management Administration.
In the Podgorica area, the Agency for Protected Area Management (AUZP) Podgorica takes care of the NP. Jasna Gajević, acting director of the Agency, explains that the greatest pressure on the area comes from forest exploiters, whether owners or contractual users. “We tried to establish closer cooperation with the relevant people from the Forest Management Regional Unit, to organize joint visits and inspections, but we did not receive goodwill from their side. Illegal construction has been reported to the building inspection several times. We have not received any feedback from them either,” Gajević explains.
Currently, AUZP has only three rangers, which Gajević says is insufficient to properly monitor the protected areas under their management. Monitoring in Komovi NP is especially challenging due to its size, poorly accessible roads, and poor internet communication. To manage this area adequately, “the Agency needs significant staff and technical reinforcement.”
On the Andrijevica territory, the NP is managed by the homonymous company (AUZP), whose director Ivana Jukić identifies illegal logging and unplanned construction as the main problems. She says guidelines for the construction of mountain huts (katun houses) need to be developed soon to adequately address these issues.
“If the forests of Komovi were preserved, today they would be a unique feature and curiosity of Europe,” says Jukić.
In the Kolašin part of the Komovi Protected Area (PA), there is still no permanent manager, and thus no protection service. The temporary manager is the Secretariat for Environmental Protection, and care for Komovi so far has been mainly “on paper” and through educational activities. The rest has been left to the government’s Forest Administration.
“In terms of physical protection, the Secretariat could not do much,” says Secretary Mile Glavičanin. He reminds that the responsibilities of the temporary manager overlap with those of the Forest Administration. Still, Glavičanin claims that “despite everything, the situation in the protected area can now be considered satisfactory.” He supports this by saying the PA “has not yet been exposed to the pressure of mass tourism and uncontrolled construction.”
According to the Law on Nature Protection, the manager of a protected area is obliged, among other things, to adopt an annual management program and an internal rules act, establish a protection service, adopt a financial plan for protection and development of the area, as well as an annual plan for staff development and training… Some managers have, for years, without any consequences, failed to meet even the minimum of these obligations.
Tourism valorisation of Komovi PA in Andrijevica is still in the planning phase. The company managing the PA confirms it is not self-sustainable and depends “on the modest budget of the Municipality of Andrijevica.” The municipality has not fulfilled the legal obligation to adopt a Management Plan, even though the manager has existed for five years.
The Podgorica Agency for Protected Area Management (AUZP) adopted a five-year Management Plan for Komovi PA last year and, according to it, has proposed a second annual management program. It is currently under review by the competent Secretariat in the Capital City. According to the annual plan, says Gajević, they will work on activities and measures for the conservation, maintenance, improvement, and sustainable use of the protected area. Special attention, she announces, will be paid to forest protection and improving cooperation with the Forest and Hunting Management Administration.
In Kolašin, they have a plan, which so far is only a dead letter on paper, but for years they have been in the phase of “finding the most optimal management model with the least burden on the budget.”
Few of the increasingly fewer residents living within the Komovi PA are satisfied with the care of the area so far. They mostly claim that uncontrolled logging, illegal construction, destruction of roads and waterways continue… The NGO UZKOM has repeatedly addressed the Forest and Hunting Management Administration, providing evidence that forest exploitation is still being carried out without any order. Executive director Novica Dragojević reminds that it was only thanks to the efforts of local residents that the waterways of the area were prevented from being put into pipes for small hydroelectric plants (SHP).
According to him, the Kraljske Bare Local Community has never benefited from the vast forest wealth that private owners have exploited in the PA. Behind the forest concessionaires, he claims, lies destroyed road infrastructure and cleared forests, while the wealth flowed “into private pockets.”
“Komovi PA exists only on paper,” claims Dragoslav Babović from the Andrijevica village of Konjuhe. Forest devastation continues, and the consequences of SHP construction are felt everywhere. Babović explains that infrastructure enabling even minimum conditions for a quality life for the sparse population is missing.
In the Podgorica area, the Forest Administration says that three concessionaires use state-owned forests: Bekom C from Podgorica, Pelengić Trade from Bijelo Polje, and Eko Vladoš from Kolašin. In the Kolašin area, in addition to these three, forests are cut by Keker LLC and Nikola LLC. In the Komovi PA area within Andrijevica’s territory, no logging has been carried out on that basis.
The Administration did not provide a concrete answer to how much the forest management plan in this area aligns with prescribed protection measures for the PA. “The forest management program, adopted for the management unit, is a 10-year plan, and when adopted, the consent of the relevant Ministry and the opinion of the state administration body responsible for environmental protection, private forest owners, and local self-government must be obtained, and before that, it is harmonised with higher forestry plans adopted by the Parliament and Government. All work in state forests is planned and carried out exclusively in accordance with these planning documents,” the Administration explains.
However, MES states that “the Ministry of Agriculture has never done a report on the strategic impact assessment of the Forest Management Program.” Without that document, they explain, neither logging could be officially authorised nor tenders announced for concessions.
After all this, it is impossible to avoid the conclusion that Komovi’s protection so far has been merely declarative and did not mean improvement for either residents or the environment. The natural wealth of that area has been continuously devastated even during years of formal protection. Managers have not found ways to valorise that space, and inspections, even when reports existed, were slow to visit locations where nature destruction was obvious. Komovi has thus become yet another area that paid the price of shifting responsibility, overlapping jurisdictions, inconsistent legal regulations, and neglect. The question remains: what is the use of officially protected areas without real protection?
This article was created as part of the project “Ecological Networks – a Key to Development on the Foundations of Preserved Nature,” implemented by the NGO Montenegrin Society of Ecologists. The project is supported by the Center for Civic Education (CGE), within the program “NGOs in Montenegro – from Basic Services to Policy Shaping – M’BASE,” funded by the European Union and co-financed by the Ministry of Public Administration. The content is the sole responsibility of the NGO Montenegrin Society of Ecologists and does not necessarily reflect the views of CGE, the European Union, or the Ministry of Public Administration.
