PODGORICA 09 February 2011. – MANS is requesting that the Ministry of Sustainable Development and Tourism halt the current procedure for adopting the Draft Locational Study for the “Trešanjski mlin” landfill. The proposed site is meant to service the waste disposal needs of the municipalities of Kotor, Budva and Tivat. The document, in its present form, already violates the law and should not proceed.
MANS today submitted to the Ministry its feedback on the document and pointed out that there is a discrepancy between it and higher order documents, thereby placing it in violation of a key provision of the Law on Spatial Planning and Construction.
Specifically, the proposed landfill does not exist in the graphics of the Urban Spatial Plan of the Municipality of Kotor (though it is mentioned in its text as a possible location). The Regional Plan of Montenegro, as the highest order planning document in the country, also makes no mention of this location.
The contracting party also references the Strategic Master Plan for Solid Waste, which is not to be found in the system of planning documents conforming to the Law on Spatial Planning and Construction and thus cannot constitute a plan of higher order.
Given that the landfill is a site of regional importance, which the old city plan of Kotor did not foresee, handling this type of infrastructural project through simple planning documentation is insufficient and inadequate.
Particularly worrying is the fact that the planned location covers a surface area of 14 hectares, while the planned buffer zone is only 25 meters long, which is insufficient to protect against the site’s negative effects.
Furthermore, the green-space and buffer zone around the landfill need to be placed within the system of protected areas fitting for this object’s rank and capacity.
For all of the above reasons, it is important to halt the current process of adopting this planning document until the adequate changes are made to Kotor’s Urban Plan. The aim of such a freezing of the procedure would be to offer a proper overview of all the problems with the project, to help find sustainable solutions and to define not only the location of the landfill but also its related protective areas.
Even though this planning document must follow the stipulations of the Strategic Environmental Impact Assessment, which the Municipality of Kotor is obliged to undertake, the document still has not been made available to the public for feedback.
MANS is also asking that Kotor’s authorities release the SEA, which would allow citizens of the region to obtain all the details concerning the potentially hazardous consequences of waste-disposal in the region that would be coming from several municipalities in Montenegro.
