(Podgorica, 24 June 2011) – MANS today submitted its comments to the Ministry of Sustainable Development and Tourism on the draft Detailed Spatial Plan (DPP) for the transmission line stretching from the Montenegrin coast to Plevlja and the undersea cable to Italy. Comments prepared by MANS during the course of the public hearings contain a review of several aspects of the projected cable and transmission lines in their energy, economic, legal and spatial dimensions.
Despite the fact that the document contains no economic analysis demonstrating the social benefits of this project, or its cost for Montenegro, including the questionable justifications for the cable, the draft DPP is in direct conflict with several existing planning documents of higher order.
This includes the devastating fact that the authors of the DPP suggest that the transmission lines should cross at least two national parks, Lovćen and Durmitor, and that the plan directly contradicts the spatial plans for both these regions (i.e. they do not foresee transmission lines). If the government stands by its decision on the proposed route, it would mean that prior to adopting the DPP it would have to alter the individual spatial plans for both national parks.
An identical situation exists with the Spatial Plan for the Coastal Zone, which also doesn’t foresee an undersea cable, so it would be necessary to also alter this plan before adopting the proposed DPP.
Similarly, if we consider the Spatial Plan of Montenegro as the most significant planning document in the country, it is worth noting that the route for the planned 400 kW transmission line from the coast to Plevlja is not mentioned in this document. It only partially coincides with the route of a 220 kW line from the Spatial Plan. For the most part, however, the route of the proposed transmission line was freely formed and barely rooted in this higher order plan.
Furthermore, the location of the conversion plant in Lastva Grbaljska was not mentioned in the Spatial Plan, even though this document mentions the integration of Montenegrin and Italian energy systems and the construction of a 400 kW facility on the coast, without specifying a precise location. This indicates that Montenegro did not have a strong strategy in relation to this project, but has yielded to the demands of the Italian energy company.
According to the Law on Spatial Planning and Construction, the DPP for the Undersea Cable and Transmission Line will not be considered by the Montenegrin Parliament but only by the Government of Montenegro. This differs from the Spatial Plan of Montenegro, the Spatial Plan for the Coastal Zone, and both national park plans which were all adopted by the Parliament. If the government decides to adopt the DPP in its current format it will be directly violating Parliamentary decisions and the contents of these higher order documents.
Since the DPP is not in compliance with the aforementioned regulations, the Constitutional Court should not have significant difficulties in challenging its legality; a question that MANS will initiate if this DPP is adopted in its current format.
As far as the public hearings are concerned, they unfolded under the shadow of the government’s well established track record of hiding key information concerning the essence of these projects, their benefits and costs, etc. In fact, in spite of the alleged willingness to disclose information about the cable, the Government continues to hide the contract with Terna – probably waiting for the public hearings to finish and for the plan to be adopted.
Maybe then we’ll finally be able to learn what to expect from the Terna deal, including the penalties that the government will have to pay its Italian partner if it fails to meet its obligations.
Unfortunately, considering the way this project has been carried out to date, it is fair to believe that the government and Terna have already agreed to release as little information as possible about their mutual agreements. While understandable for a company concerned about its profits, it is not understandable nor is it acceptable for the Government of Montenegro to adopt such a model of behavior, which would – at least on paper – take care for the interests of its citizens.
MANS therefore appeals to the competent Ministry to withdraw the current plan without further delay, that it make public all available information about the project and related agreements with its Italian partner and seriously approach the preparation of studies that will show whether or not it is worth proceeding with such a project (and what form it should take).
The final comments can be viewed at the following address: http://www.mans.co.me/en/wp-content/uploads/2011/06/Comments-on-Draft-Spatial-Plan-for-Submarine-Cable.pdf
