Unsound SEA in Montenegro

The unsound report on the strategic environmetnal assessment (SEA) of the local study of the location (LSL) for SHP Bukovica 1 and SHP 2 Bukovica is the subject of this press release.

Based on an assessment of the LSL and SEA for this project, we believe that the principle of maximum environmental protection cannot be met based on the given guidelines. The infrastructure works will severely damage the natural environment and the water regime of the Bukovica River.

The LSL does not possess precise environmental data for the mentioned area, and the construction process will result in permanent changes to the terrain. This will result in permanent changes to the river’s ecosystem.

In the SEA itself, it is wrongly estimated that the small hydro facility will have an acceptable impact on the natural balance of the ecosystem of this river.

The biological minimum is determined based on 10 percent of the mean annual flow at a given site. At the small hydro location Bukovica 1 it is 224 l/s, and 122 l/s for Bukovica 2 in all conditions during the period of hydropower facility operations. This leads us to the conclusion that this river, which in certain sections has a wide flow, spillways, and whirlpools, will be turned into a small stream without living systems.

 

 

The negative impact of this on species is said to be insignificant in the SEA. We disagree and believe that the construction of planned infrastructure facilities will seriously impair the trout population, which, as per research, is abundant in Bukovica.

The construction of the small hydro facilities includes the construction of artificial fish pathways, which cannot in any way replace the natural environment. Also, there is no guarantee that the fish will be able to migrate upstream due to low flow.

If damage to the fishery occurs, it is stated that the investor is required to make a fishery compensation, and the future concessionaire will participate in fish stocking activities. It is not specified in the SEA which fish species would be stocked. The investors and the concessionaire must know that trout is not artificially stocked anywhere in Montenegro, and the introduction of another type of fish in Bukovica would be unacceptable.

When it comes to waste creation, it is stated that the production of all types of waste (industrial and communal) is extremely small and the negative impact is assessed as insignificant. However, it is not stated that even small quantities of industrial waste can create a major problem for water resources. In this case, 1 liter of machine oil can contaminate one million liters of water.

As in many similar instances to date, there has not been adequate public involvement when it comes to this matter. Although there was a need for the interested public to engage in consultations from the early planning stage, this did not happen. Public debates were conducted to meet the legal minimum, but without properly informing the local population and conducting inclusive discussions.

Finally, it is the proposal of the NGO "Association of Young Ecologists" to abandon the project of building a hydropower facility on the Bukovica river and to puruse instead its eco-tourism values and put the river under formal legal protection. This would make the river and its environment a jewel of nature that would be used by people today in a sustainable manner, so that it can be handed over to future generations.

This press release was prepared by the NGO "Association of Young Ecologists", which is implementing the project " Environmental Networking towards Sustainable Development " with the NGO "North Land" and the NGO "Center for Bird Protection and Study of Montenegro", which is supported by the CO SEED project which is funded by the European Union through the Instrument for civil society and the media.