Kotor is under scrutiny of UNESCO due to the consequences of excessive urbanization of this protected area
The Faculty of Architecture did not have the appropriate permission for making of the Study of the Heritage Impact Assessment (HIA) and the Natural and Culturo-Historical Region of Kotor, by which the Government is trying to prevent the United Nations Educational, Scientific and Cultural Organization (UNESCO) from removing this town from the list of world cultural and natural heritage.
This is evidenced by documents obtained by the Network for Affirmation of NGO Sector (MANS).
Kotor is under scrutiny of UNESCO due to the consequences of excessive urbanization of this protected area.
According to the documents obtained by MANS, the Faculty of Architecture from Podgorica, at the time when the Ministry of Culture signed a contract for making of this HIA, did not have the necessary conservation license, but received it three months later.
The Ministry of Culture told “Vijesti” that “it was not necessary back then as it is not now to have a conservation license for making of the Heritage Impact Assessment”, and that therefore HIA, drafted by the Faculty of Architecture in September 2017, is a valid document.
The contract on financing of this project, worth € 50,000, was signed in December 2016 by the then Minister of Culture Janko Ljumović and the Dean of the Faculty of Architecture, Svetislav Popović.
According to the contract, the Faculty of Architecture was obliged to make by September 1, 2017 a comprehensive Heritage Impact Assessment (HIA), based on the ICOMOS guidelines, “in relation to the Heritage Impact Assessment on cultural heritage from the World Heritage List in order to establish a clear framework for the protection of the exceptional universal value of the cultural heritage and its characteristics, as well as to promote sustainable and compatible forms of development.”
On its session in July 2016, UNESCO requested drafting of this document from the Government.
In February 2017, the Government adopted an Action Plan for the implementation of decisions pertaining to the Kotor region. According to the Action Plan, the Faculty of Architecture “is designated as the bearer of the development of the assessment”, while the partners on drafting of the HIA are the Directorate for Protection of Cultural Heritage and the National Commission for UNESCO of Montenegro.
At the moment of the contract signing, according to the documents obtained by MANS, the Faculty of Architecture did not possess a conservation license.
It was issued to it only three months later – on March 6, 2017, based on the application submitted to the Commission for issuing of a conservation license in December 2016 and supplemented documentation from February 2017.
This means that the Faculty of Architecture did not have a conservation license even at the time when, while adopting the Action Plan for keeping of Kotor on the UNESCO list on February 2, 2017, the Government of Montenegro “designated it as the bearer of drafting of the key document – HIA study”.
“Bearing in mind that the Heritage Impact Assessment was not recognized in national legislation at the time, it was not necessary for the bearer of drafting to have a conservation license, since the license is issued for development of a study on the protection of cultural heritage, for the preparation of conservation projects and for implementation of conservation measures on cultural heritage, in accordance with the Law on Protection of Cultural Heritage.
The line ministry, headed by Aleksandar Bogdanović, claims that “a conservation license is not a precondition for making the assessment adopted by the Government”.
Kapetanović: It is logical that such study is done by someone who has experience with cultural heritage
Experts who constantly warn about the destruction of Kotor believe that there are many undefined things “which enable for the high-level works on HIA drafting to be done also by those for whom this is not the primary activity, such as the Faculty of Architecture”.
“When its drafting began, HIA was not legally defined in our country. Even with the latest amendments to the Law on Protection of the Natural and Culturo-Historical Region of Kotor of this year, it is not clear who can draft the HIA and whether they need conservation licenses for it. In any case, it would be logical for someone who has experience with cultural heritage to do it”, according to the architect-conservator Aleksandra Kapetanović from NGO “Expeditio” from Kotor, a member of the Council for Management of the Natural and Cultural-Historical Region of Kotor.
