Dragana Čenić: Special Purpose Spatial Plan for the Coastal Zone is a planning document and it cannot determine the right of ownership

Dragana Čenić: Special Purpose Spatial Plan for the Coastal Zone is a planning document and it cannot determine the right of ownership

Given the statement that the NGO MANS made today about the Draft of the Special Purpose Spatial Plan for the Coastal Zone, in terms of protecting the Ulcinj Saltworks locality, and taking into account similar allegations which have been delivered to the public over the past period, Dragana Čenić, the director of the Directorate for Spatial Planning, which operates within the Ministry, provided the following response:

Although we are very thankful for all the constructive suggestions and remarks on the account of this important planning document, we must draw attention to the fact that some more or less similar messages, referring to this topic, have been delivered to the public, and it is our utmost belief that we have already provided reasoned responses to the mentioned statements.

The court decision to declare the Decision on Amendments to the Spatial Plan of Montenegro by 2020 unconstitutional, in terms of protecting the Ulcinj Saltworks, shall not affect the process of its protection in planning documents of the lower order. This is precisely why this locality has been distinctively marked as a protected area in the Draft of the Plan, and anyone who may have acquired some more detailed information about the document can be assured of that.

We reiterate that there are plans to build a construction site, with the surface of about 6 ha, at the location of the Ulcinj Saltworks (which encompasses the area of 1492ha) and there is a suggestion to set up complementary tourist facilities – flora and fauna observation and an eco-resort. Please note that there already exists a construction site at this location, intended for industrial purposes, which is confirmed by the local planning document, and thus the Draft of the Spatial Plan for the Coastal Zone does not envisage expansion of the construction area. Besides the mentioned 6 ha, the Development Reserve Zone, covering 70 ha, also relates to the area in the hinterland, outside the borders of the Ulcinj Saltworks (appendix 1).

Also, this planning document was not based on anyone’s uncontrolled desires. Rather, it was created according to the clearly prescribed rules and procedures: The decision on its creation was made, and was adopted by the Government. The companies that made this planning document were chosen through a regular, transparent tender procedure, and there were no complaints against the decision. After the Draft was made, and analysed by the Government one more time, it was made available to the public. An entire team of planners, architects and other experts is going to analyse all the filed remarks, with the aim of reaching the best solution.

Considering the fact that the Ministry has, so far, explicitly stated many times that any kind of construction that is being discussed in the public is not planned at this locality, and the fact that this institution has clearly stated its resolution to support the protection and sustainable development of Ulcinj Saltworks, both in front of the domestic and international community, we indeed believe that delivering the type of messages that we are reacting to today, is counterproductive and confusing.

When it comes to the statement that the Ulcinj Saltworks was marked as private land, we emphasise that the planning document does not determine the structure of ownership. Therefore, even if the plan does contain inaccurate information, it is clear that the aforementioned information can in no way influence the real ownership rights. The purpose of the public hearing stage is to define if anything was not adequately stated in the Plan in order to eliminate and revise any potentially misleading points.

We also believe that the continuous linking of the decision of the Constitutional Court and the statement made by the Council for Privatisation on this topic with the activities conducted by the Ministry of Sustainable Development and Tourism in a part of the Ulcinj Saltworks area is rather unfair. The issues in question are absolutely out of our jurisdiction. We honestly hope that these two issues which are being forced on the Ministry, through insinuations about the alleged conspiracy between state structures, which aim to degrade Ulcinj Saltworks, is not going to overpower the truth.

The truth is that the Ministry of Sustainable Development is determined to support the protection of Ulcinj Saltworks and it will invest as much time as it is necessary in this process, without hastily involving itself in the story, provoked by a sally of public accusations. Namely, due to the fact that the Ulcinj Saltworks system cannot exist on its own, i.e. it is maintained through human assistance, the entire process of proclaiming it a protected area requires additional analyses from the aspect of its management, including the management resources, and those analyses are currently being conducted. This is the only way in which we can avoid to burden the process of protection by potential damage claims (as was the case with Tivat’s salt plant), which was the exact reason why the procedure of putting that locality under protection took more time.

Of course, I would like to invite the members of the NGO MANS and all interested parties to deliver actual proposals for the Draft of the Special Purpose Spatial Plan for the Coastal Zone, both in terms of the Ulcinj Saltworks and beyond, before the end of the public hearing phase. The proposals will be thoroughly analysed, with a single goal: to provide a document which will not only make proud the individuals who created it, but the entire country as well.



Appendix: REVIEW OF CONSTRUCTION AREAS WITHIN THE DRAFT of SPSPCZ
Grey colour on the graphic marks the construction areas (building area)