Letter of Concern for Skadar Lake National Park, Montenegro June 2016

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We are writing to share our concerns about proposed commercial development in the Skadar Lake National Park, in Montenegro, which we feel will have severe environmental impact. We are requesting assistance to lobby for careful debate and protection of the environment in any future developments. This is a two page summary of the main issues and concerns, supported by 3 pages of maps of the areas affected. General Problem 1. CURRENT AND URGENT ENVIRONMENTAL THREAT: Two planned and already approved (building permits issued) private and commercial mega resorts in the Mihaliovici area in Skadar National Park. 2. FUTURE THREAT: Spatial and Zoning development plan for the National Park currently in progress that favours increasing tourist facilities and investment up to 2025. 3. ONGOING THREAT: Non-existent monitoring and control of illegal activities in the Skadar Lake National Park area. Specific Threats Proposed and approved building of villas, hotels and a 30 boat berth marina in the Mihailovici area, which covers over 59000 square metres, and is within Zone 3 of the Skadar Lake National Park. Building of supporting infrastructure (roads, electricity, water supply, lighting, sewerage etc) from Virpazar to Rijeka Crnojevica. (Map of proposed route included.) Mass tourism development in an area with no current regulations to protect the environment from such tourism volume. Impact of these threats Visually degrade part of the park that is currently pristine and unaffected by human activity. Destruction and discontinuation of the park as a protected area in practice. Destruction of local (not yet explored nor catalogued) biodiversity, especially in the coastal area of the park. Impact of mass tourism (air, ground and waste water) and pollution from planned boat and water sport activity on the habitats of lake as a whole, especially spill effects on zones I and II. This is covered in option 3 in the new Spatial Plan for Skadar Lake National Park. Impact of planned road infrastructure in support of the projects will extend from Virpazar to Rijeka Crnojevica (25km in total). Elevating local roads to regional roads will remove the relative protection from illegal building activity that this part of the park has been able to avoid. 1

We claim the following A non-transparent, secret planning process: State project Mihailovici has been approved behind closed doors, and deliberately kept secret from the people of the local community. Construction licences have been issued to companies and approved behind closed doors. These companies include: o 1) MJ Property doo, Podgorica and o 2) Montenegro Resort property doo Podgorica Porto Skadar Lake project The public has only been informed through the media (as the story has recently broken in Montenegro) and no expert opinion has been sought after. No effort has been made to explore biodiversity and habitats in the area and how they will be impacted by the construction projects Companies involved in the investment are inexperienced in similar projects and are interested in creating a profit on the backdrop of the National Park. Future planned infrastructure to support this project will create a surge of land sale and illegal activity that has not been monitored or suppressed so far due to lack of political will and capacity. Planned Spatial Plan for the NP Skadar Lake currently in making by development company CAU has also been conducted away from scrutiny of the general public, environmental experts and the media. From our current knowledge it is in its final stages, and heavily supportive of larger scale private tourist developments. Our position and beliefs Skadar Lake National Park is of national and international importance, and for this reason its PROTECTION and PRESERVATION should be to the forefront That all currently approved projects in the Mihailovici zoning area (including Porto Skadar Lake) in particular are frozen and abandoned. Any future development planning should include close collaboration with national and international experts in the area of sustainable development and not be rushed in favour of private inexperienced investment and profit. That without HELP and involvement from relevant international organisations like Ramsar, Euronatur, IUCN, EU and others, Skadar Lake National Park will be lost in the form as it is, to this and future generations. The remaining pages include maps and pictures of the places impacted by the development plans, and excerpts from the developers website. 2

Skadar Lake National Park Area Affected, with Mihailovici detailled Google Maps location: https://www.google.co.uk/maps/place/velja+gora/@42.3180439,19.0906187,13z/data=!4m15!1m9!4m8!1m0!1m6!1m2!1s0x134ddb4463c7f405:0x90f379897e2cabeb!2svelja+gora,+montenegro!2m 2!1d19.0777778!2d42.3155556!3m4!1s0x134ddb4463c7f405:0x90f379897e2cabeb!8m2!3d42.3 3

Letter of Concern for Skadar Lake National Park, Montenegro June 2016 www.skadarlake.org Road between the towns Virpazar and Rijeka Crnojevica Map of the Mihailovici Area in various detail, showing land usage plans (Mihailovici outlined in red toward bottom left of map) 4

Detailled view of Mihailovici, showing land affected by project 5

Letter of Concern for Skadar Lake National Park, Montenegro June 2016 www.skadarlake.org Porto Skadar Lake Development Website excepts below http://www.portoskadarlake.com 6