Text prepared in cooperation with the Center for Investigative Journalism of Montenegro (CIN-CG)
About one-third of the total number of areas proposed for the Emerald Network have not received either national or local protection, even though they should have according to the Action Plan.
In October, representatives of the Center for Protection and Study of Birds (CZIP) found felled trees of great value and age in the primeval forests of Zeletin and Visitor during a field visit. They concluded that the primeval forest has been damaged and that its survival is threatened.
The Center for Investigative Journalism of Montenegro (CIN-CG) contacted the Forestry Administration (UZŠ) to clarify whether the logging was illegal or authorised, but they did not receive an answer. These areas fall under the UZŠ regional unit “Kutska river,” meaning that this valuable natural area is effectively assigned to the forestry industry.
For years, CZIP has demanded that Zeletin and Visitor mountains be recognised as protected natural areas, as they represent unique primeval forest reserves — of which only about three percent remain in Europe. However, there has been no response from the authorities.
The Zeletin and Visitor forests are among the areas proposed as sites of exceptional natural significance as part of the Emerald ecological network, yet they have never received any form of national or local protection.
In 2011, Montenegro declared 32 natural areas as candidates for the Emerald Network. This network represents a form of protection for natural habitats and wild species and applies even to countries that are not EU members. The establishment of the Emerald Network is especially important for candidate countries for EU accession, like Montenegro. It is based on the Convention on the Conservation of European Wildlife and Natural Habitats — the Bern Convention.
However, significant damage has already been done to some candidate sites, especially those without any other protection status, such as Zeletin and Visitor.
“Although Zeletin and Visitor are candidates for Emerald and internationally important biodiversity sites, logging over the last few years has seriously damaged this treasure. Road construction, fires, illegal and legal logging have degraded what we had in this area ten years ago,” says Bojan Zeković, an ornithologist from CZIP, speaking to CIN-CG.
He emphasises that it is unacceptable that the Forestry Administration does not recognise the importance of this area and allows the destruction of some of the best-preserved forests in Montenegro, which most citizens don’t even know about.
“Zeletin and Visitor are not well-known as some of our more popular mountains, but from a biodiversity perspective, they are priceless. They feature monumental, old primeval trees, important plant and animal species, valuable geological features, and waters… A rare place where Macedonian pine and Bosnian pine, two endemic and rare pines of Montenegro, grow together,” explains Zeković.
Other significant Emerald candidates include the Komarnica canyon (Nevidio), Sinjajevina, Lake Skadar, Buljarica, Velika Plaža… These areas have been linked for years with ambitious infrastructure, tourism, and industrial projects that could permanently destroy their natural value, which is the primary reason for their nomination to the network.
Even One Third of Emerald Candidates Have No Protection
About one third of the proposed Emerald Network areas have so far received neither national nor local protection, putting them at risk from possible investments and projects. Besides Zeletin and Visitor, this is also the case for Sinjajevina, the largest pasture in the Balkans, which the state has planned for years to convert into a military training ground.
Ćemovsko Polje, one of the most important remaining pseudosteppe habitats in Europe, significant for numerous bird species, is also unprotected. On the contrary, it is known as a waste dump.
The mountains Golija and Ljubišnja, the Mrtvica Canyon, and the valleys of Ćehotina and Lim are also areas with valuable and incompletely studied ecosystems, left at the (dis)grace of the state and investors.
According to the “Action Plan for Meeting the Final Benchmarks in Chapter 27 – Environment and Climate Change”, all Emerald candidates must have “prescribed and integrated adequate habitat protection measures in planning documentation and related Strategic Environmental Impact Assessments.” However, the Strategic Environmental Assessment published in 2014 does not mention any network of protected areas.
The Environmental Protection Agency explains that since 2016 work has been ongoing to map species and habitats important at the European level within another network — Natura 2000. However, Natura 2000 is exclusively for EU member states, so Montenegro cannot yet be a formal part of it.
The European Commission has also stated that they cannot evaluate Montenegro’s data and mapping done for Natura 2000 since the country is not yet in the EU, but can only assess the Emerald process. They even offered assistance in converting data collected for Natura 2000 into Emerald data, in accordance with the Bern Convention. This is noted in internal documents of the Environmental Protection Agency from last year, which CIN-CG has reviewed.
Within the project to research habitats and species for Natura 2000, so far 27 Emerald candidates have been fully researched, investigations for two areas are ongoing this year, two are partially researched and planned for next year, and two have not been researched and are planned for the future, the Agency stated. By the end of this year, about 60 percent of the entire Montenegrin territory will be mapped.
On Ljubišnja, mining expands — because no protection came
Ljubišnja Mountain, like Visitor and Zeletin, is an Emerald candidate without any kind of protection. Thanks to this, the company Gradir – Montenegro managed to obtain permits for detailed geological exploration of zinc and lead deposits, right next to valuable forests, and has already begun excavation.
During a recent field visit, CZIP encountered new exploratory mines located near the potential nature park, whose declaration could finally protect this area.
“The mines have completely destroyed the forest and devastated part of the mountain, besides the already existing Šuplja Stijena mine,” explains Zeković. The exploitation of lead and zinc ores has already massively damaged the Ljubišnja area, he adds.
After the field visit this year, CZIP contacted the environmental inspection, explaining that these deposits are located near a forest that would belong to the nature park.
However, in a reply from the environmental inspection, which CIN-CG reviewed, it was stated that Gradir – Montenegro has all necessary permits.
“In response to your statement that this is a potential nature park, we inform you that no procedure has been initiated to place Ljubišnja under protection, and no decision has been made for preventive protection,” the environmental inspection states. Therefore, they continue, “the environmental inspection has no jurisdiction to conduct inspection supervision in this administrative matter, since this is not a protected area.”
What is a problem for Ljubišnja is also a problem for other mountains, related to complete neglect of biodiversity, which is not taken into account in planning, says Zeković.
“Rare are the mountains where you can find footprints of wolves, bears, roe deer, wild boars, black grouse, hazel grouse — a small living world. This is the case with Ljubišnja. Unfortunately, Ljubišnja has been exploited for timber for decades, which was sustainable up to a point as evidenced by the presence of these species, but what we see on the ground in recent years does not support this,” Zeković notes.
Ljubišnja is a mountain that is mostly, about 70%, covered with forests, especially coniferous forests of exceptional importance for numerous bird species, but also for the entire living world in this area, Zeković explains.
“Ljubišnja is the most important mountain in Montenegro for the Ural owl, and also extremely important for the little owl, boreal owl, black grouse, hazel grouse, three-toed woodpecker, and many other endangered and protected species, precisely because of which this area is recognised as an Emerald site, i.e., a future Natura 2000 site.”
Plans for the future — uncertain
The Draft Spatial Plan of Montenegro until 2040 (NPPCG) states that Emerald is already an established network, covering 15 percent of our country’s land territory.
“The Spatial Plan of Montenegro must adequately address these areas in terms of protection guidelines and avoiding planning conflicts with their conservation needs,” the Draft Plan states.
However, in the section of the plan where protected areas in Montenegro are mapped in detail, precisely to avoid conflicts, Emerald sites are not marked in green like other protected natural areas but are outlined with yellow lines. It is indicated that these are “potential” protected areas. Because of this, the Plan’s Review Council suggested revisions in the “Review of the Draft Spatial Plan until 2040” released this month.
“It is unclear whether the Emerald network already exists or is yet to be established,” the Council notes.
The Council also suggested removing the term “potential protected areas” from the Draft and emphasising that these are candidates for protection to reduce the risk of projects and activities that could endanger them.
The Draft Plan does not clarify the fate of the candidates for Emerald sites. One such area is the Komarnica Canyon, which is threatened with permanent flooding due to a planned hydroelectric power plant.
The construction of the Komarnica hydropower plant is still of interest to investors but is also met with strong protests from biologists and ecologists at both national and international levels – including warnings from UNESCO and the European Commission.
“Recognising the undisputed importance of the Komarnica hydropower plant in Montenegro’s energy system, and on the other hand ecological demands and spatial protection requirements, it is important that the final decision on the construction of the Komarnica HPP is based on conclusions from competent Montenegrin institutions within the project documentation and environmental impact assessments,” the Draft states.
The NGO Montenegrin Ecologists Society (MES), together with KOD and the Society of Young Ecologists, submitted a complaint to the Bern Convention Secretariat in 2022 regarding the Komarnica HPP construction plan. They noted that building a hydropower plant on Komarnica would violate the Bern Convention, which obliges signatory countries to improve national policies for the conservation of wild flora and fauna, with special attention to endangered species, as well as the preservation of wild animals and natural habitats. The Secretariat will give its final opinion on the project after the Environmental Protection Agency prepares an Environmental Impact Assessment Report. CDE believes in a positive outcome following the preparation of the report.
The Sinjajevina area, another Emerald candidate that remains without any form of institutional protection, is still under threat of being turned into a military training ground. The Draft Plan states that “the Ministry of Defence and the Government of Montenegro will make decisions on the temporary use of the Sinjajevina military polygon and all conditions related to environmental protection and the use of the Sinjajevina area for agricultural purposes.”
Protected areas – they are not.
Some of the Emerald candidates have the highest level of state protection, such as parts of national parks. However, even a high level of national protection does not guarantee the safety of these sites from the greedy hands of investors.
For example, Skadar Lake National Park almost became the site of Porto Skadar Lake, a luxury resort and yachting marina. Almost all other Emerald candidates have been the subject of controversial projects. However, the Bern Convention reacted.
“Although the Emerald network has not been officially established in Montenegro, the Bern Convention does react when candidates for the network are threatened,” says Milena Bataković from the Environmental Protection Agency in an interview with CIN-CG.
When NGOs protested the construction of the luxury resort on Skadar Lake and submitted a complaint to the Bern Convention, independent experts were sent to assess the situation.
“When the mission arrived, it did not want to listen to either the state supporting the investor or the NGOs, but independent experts conducted the assessment. The conclusion was that the project was harmful,” Bataković points out.
At that time, the Bern Convention called for amendments to the spatial plan, and Montenegro should regularly report on this to the Bern Convention.
The Draft Plan until 2040 recognises that most protected areas lack a high level of protection.
“Although Montenegro has 78 nationally protected areas, only nine have management plans, and out of those, 32 do not even have an appointed manager such as municipalities or the National Parks of Montenegro,” the document states.
“As with anything else, if you don’t have a plan, then you don’t have a goal and you don’t know where to spend the money,” says biologist Vuk Iković in an interview with CIN-CG.
There are also nature parks that have management plans and protection services, such as Komovi, but even then the situation is poor because there is conflict between nature and society.
“That will last as long as politicians impose the view that nature conservation is a cost and as long as enterprises managing protected areas are seen as political spoils,” Iković concludes.
Montenegro Does Not Comply with the Nature Protection Law
According to Montenegro’s Nature Protection Law, the priority is the establishment of a network of protected natural areas, i.e., wild flora and fauna. However, even 15 years after adopting this law, Montenegro has not yet established such a network. The network of protected areas implies that individual protected locations of flora and fauna are interconnected, because only this way can the sustainability of protection be ensured.
Iković believes that Montenegro could have declared the Emerald candidates as a network long ago and then worked on further improvements and research.
“The network should have been declared, which would have helped avoid many harmful projects over the past decade and in the future,” he explains.
“Although Emerald sites have never been formally declared, the nature protection sector is aware that Montenegro must ensure a protection mechanism. Spatial planning should not overlook them,” says Bataković.
Iković points out that one of the key tools that would help preserve natural areas is GIS software.
“GIS serves to overlay areas with different uses and accurately determine conflicts of interest. That way, it would be clear where what is allowed and where strictly protected areas are,” he says.
“The Directorate does not have an employed GIS specialist, but a number of employees possess knowledge in this field,” state the Ministry of Ecology, Spatial Planning and Urbanism.
The establishment of the ecological network, currently as Emerald, and after EU accession as Natura 2000, is not significant “only” from the nature protection aspect, say MES representatives to CIN-CG.
“Ecological networks do not exist solely to protect plant habitats or animal species, but it is equally important to improve the quality of life of the local population living in these areas. Therefore, their maximum involvement in monitoring and maintaining these protected areas, as well as developing the local community economy based on preserved nature, is of key importance,” explain the MES team.
“Today, we witness not only that nature is best preserved in ecological networks but also that local economies and rural tourism are most developed in villages that have become part of the ecological network. Therefore, this process not only protects nature but creates a new economic environment beneficial to both humans and nature,” the organization stated.
Đurđa Radulović
This text was created within the project “Ecological Networks – The Key to Development Based on Preserved Nature” implemented by the NGO Montenegrin Ecologists Society (CDE). The project is supported by the Center for Civic Education (CPC) 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 of this text is the sole responsibility of the NGO Montenegrin Ecologists Society and does not necessarily reflect the views of CPC, the European Union, or the Ministry of Public Administration.
