Komarnica hydropower plant, Montenegro

The 172 MW Komarnica hydropower project is planned to be built on the river Komarnica, 45 km upstream of the existing 342 MW Piva power plant in Montenegro. The project would feature a 171 m high concrete arch dam that would impound a 17.6 km long reservoir. As a peaking plant, it is expected to generate only 213 GWh of electricity annually (compared to an average of 860 GWh generated by the Piva plant).

Plans to build a hydropower plant on the Komarnica have been around since the 1970s, but have been vigorously revived in recent years after EPCG’s other flagship projects – the Pljevlja II coal plant and the Morača hydropower plants – proved uneconomic and were shelved.

However, it is unclear why Montenegro, which already generates 40-60 per cent of its electricity from hydropower, depending on rain and snowfall, needs yet another hydropower plant, and no evidence of Komarnica’s economic viability is available to the public. A system with such a high percentage of hydropower is already highly vulnerable to climate change, as can be seen from its wide annual fluctuation in generation. This is all the more so because the Piva plant already works as a peaking plant. Surely Montenegro needs diversification of its renewable energy sources much more than it needs another hydropower plant, especially as plans for its first large-scale solar plant at Briska Gora have stagnated.

The project would flood part of the Komarnica candidate Emerald Site (ME000000P) and the Dragišnica and Komarnica Regional Park. The area is also part of three potential Natura 2000 sites: Bukovica Valley and Vojnik Mountain under the Birds Directive and the Komarnica and Pridvorica sites under the Habitats Directive.

Moreover, the Komarnica river has been identified as a potential area for the expansion of the Durmitor National Park and UNESCO site, but so far has only been awarded a weaker ‘Regional Park’ status.

The area is home to numerous protected species, including wolves, bears, Balkan chamois, otters, stone crayfish, golden eagles, rock partridges and corncrakes. Yet the full extent of the likely damage by the project is not yet known due to only partial fieldwork having been done.

Unique caves and cliffs would be flooded before their biodiversity is even properly researched.

The project’s environmental assessment, published in February 2022, reads more like an advertisement brochure than a scientifically grounded study. It promises the people of Šavnik a golden future based on an influx of tourists who will allegedly visit because of the hydropower plant, but offers no evidence on why or how exactly this will happen. Experience from the town of Plužina, near the existing Piva hydropower plant, rather suggests that the hydropower plant will hinder tourism.

Moreover, although the environmental assessment admits that the hydropower plant will damage biodiversity, it claims that the harm done by the project would supposedly be outweighed by its economic and social benefits.

As an EU candidate country, Montenegro has to a certain extent transposed the EU’s nature protection laws, though it has not made a final selection of Natura 2000 protected areas yet. In any case, it has a duty to protect its candidate Emerald sites under the Bern Convention and must carry out an ‘appropriate assessment’ for any project which may significantly impact an Emerald site or Natura 2000 site. If it is found that the impact will be significant, the project may not go ahead unless a specific assessment finds it to be a project of ‘overriding public interest’. But the Komarnica environmental impact assessment does not include any ‘appropriate assessment’ at all.

Similarly, projects that would degrade the river’s status are not allowed under the EU Water Framework Directive unless they obtain the right to a derogation under Article 4(7) of the Directive. Again, a detailed assessment is needed, which has not been carried out in the case of Komarnica.