Local experts in spatial planning, sustainable development, and protection of the cultural heritage of Kotor believe that the Draft Spatial Plan of Kotor represents only the continuity of inadequate planning documents for this area and leads to further devastation of space.
Within the public hearing on the Draft of the Spatial Plan of the Municipality of Kotor and the accompanying Draft of the Report on Strategic Environmental Impact Assessment, the local expert group submitted their remarks to these documents to the Ministry of Sustainable Development and Tourism. Experts are supported by part of the participants on the round table on this topic, Center for Sustainable Spatial Development Expeditio from Kotor organized on 5 June.
"Considering the current situation in Kotor, risking to lose the World Heritage status due to over-urbanization, the general importance of adopting a Spatial Urban Plan for the development of municipalities, and the problematic procedure and the quality of the document itself, local experts claim that the Draft Spatial Plan is only a continuation of inadequate planning arrangements for this area," Expeditio said on their official FB page.
"Even though the plan suggests, with the pressures of the outside, before all UNESCO, that it will partly limit the construction of facilities, we consider it still doesn't help the city to start from the deadlocks that it found by the lack of responsibility of local and state institutions."
Apart of the local experts, comments have been signed by some of the participants of the round table under the project "Active Citizens for Better Montenegro - The Rule of Law and Sustainable Development of Montenegro." At the roundtable, representatives of the profession, competent institutions, as well as all political parties operating in Kotor, were invited.
Experts recall that the neglect of expert opinion in the field of spatial planning in the last 15 years has caused Kotor today threatening to review status on the World Heritage List of UNESCO.
In their view, the Draft Spatial Plan does not represent the sustainable development strategy with the idea but allows for further alteration of the ambiance, thus destabilizing the values for which the Natural and Cultural Historic Area of Kotor is enrolled on the World Heritage List.
The presented document experts commented in the remarks as unworthy of the profession, without the minimum of professional standards.
"Methodologically, the document is at an inappropriately low level, full of contradictions, copied pieces from different materials, which, in a large extent, represent the content of the document itself, which is unacceptable. Such a plan will be impossible to implement," states the letter addressed to the Ministry of Sustainable Development and Tourism, which has signed 13 of the most subordinated space planning and protection experts from Boka Bay.
They point out that a significant role for this plan plays the legislative framework - the Space Planning and Construction Facility Act of 2018, which instead of introducing the order and upgrading the space planning system has led to complete chaos. The established, previously confirmed planning practices were abolished, creating a prerequisite for accelerating the devastation of space, ignoring the already dramatic condition in Montenegro.
One of the critical remarks of experts from Kotor is that the Draft Spatial Plan does not entirely rely on the Cultural Heritage Protection Study for the area of the Kotor Municipality, which was done precisely for this document. This Study is only formally cited, but its core guidelines and the way of treating the Invertebrate Areas are not taken into account, which is incomprehensible, because, for a municipality where more than one third of the territory is on the Heritage List, it must have been the primary starting point for making the plan, experts conclude.
The only solution to the current situation is that the planning is brought back to experienced teams of planning experts, with the involvement of experts in the area of protection of the World Heritage, who would, without resorting to politics and personal interests make a document that would represent a breakthrough from the previous harmful planning practices.
"Of course, the prerequisite is a complete change of the space planning system (because its improvement is unfortunately impossible), including the legislative framework. The priority should be given to preserving the extraordinary universal value of the Kotor Area, as clearly indicated by the UNESCO / ICOMOS Reactive Monitoring Mission Report of November 2018, "states the remarks, experts from Boka Bay submitted yesterday to the Ministry of Sustainable Development and Tourism of Montenegro.