Both the lay and professional public are opposed to the resumption of production in the Brskovo mine in Mojkovac, as planned by concessionaire Tara Resources AG. The former are gathered in the civic initiative “Healthy Mojkovac”, and the latter form a team of planners preparing a detailed spatial plan for the concession area. From those addresses, a request to terminate the contract was sent to the Government (Ministry of Ecology, Spatial Planning and Urbanism, Ministry of Capital Investments) on May 30th, that is, on June 7th, a proposal to suspend planning activities was sent.
In 2010, when Igor Lukšić was the prime minister, the government signed a 30-year contract with the Podgorica company North Mining on a concession for detailed geological research and exploitation of sulfide polymetallic ore (Pb, Zn, Cu, FeS2 and other accompanying metal sulfides) in the research area of the former Brskovo mine. Eight years later, the Swiss company Tara Resources takes over the concession and establishes Brskovo Mine as the mine’s business operator.
In the meantime, five contract annexes were verified. The last sixth was signed on July 30th, 2021 by the Government of Zdravko Krivokapić, and according to it, Tara Resources should prepare mining technical documentation and obtain approvals, permits and consents for exploitation and performance of works by July 25th. Pobjeda asked Ervin Ibrahimović’s department whether this has been done, that is, whether the Government will terminate the contract or set a new deadline for the concessionaire by signing the 7th annex, but the answer did not arrive.
The public hearing on the Draft Detailed Spatial Plan (DPP) for the Brskovo concession area ends on July 3rd.
Criticism of the DPP
In the proposal sent to Ana Novaković Đurović’s department to suspend planning activities, which is signed by the head of the sixteen-member work team that worked on the draft DPP Brskovo, Sonja Radović Jelovac states that “the state’s position on the issue of supporting the project is unclear” and that “the creation of that extremely complex planning document does not there may be procedural errors”.
– DPP is not an instrument for making decisions on the strategic development of the state, although it has a mandate to point out all negative impacts and potential protection measures with the Strategic Environmental Impact Assessment procedure, and based on that input to the state to evaluate the justification of the implementation of the plan – they state in the explanation.
The Ministry of Economic Development and Tourism did not participate in the central public debate, even though it is the successor to the signed contract. The Ministry of Capital Investments, which includes the Directorate for Geology and Mining, did not participate either.
The authors emphasize that the Ministry of Sustainable Development and Tourism did not obtain UNESCO’s opinion before starting the drafting of the document, considering the potential impact on the Tara River, but the Ministry of Capital Investments and the Ministry of Economic Development and Tourism gave a positive opinion on the first submitted draft. Also, the Ministry of Economic Development and Tourism did not participate in the central public debate, even though it is the successor to the signed contract.
The Ministry of Capital Investments, which manages the processes and procedures related to the concession, and which includes the Directorate for Geology and Mining, did not participate either.
There is a lack of a verified study of the feasibility of exploitation of lead, zinc and accompanying useful components in the deposits of the Brskovo ore field, which must be in accordance with the current laws and regulations of Montenegro and all international conventions ratified by the state of Montenegro.
The documentation that had to be prepared by the Institute for Geological Research of Montenegro is also missing, and according to the State Plan for the Exploitation of Mineral Resources 2019-2028. as well as relevant opinions for issues of space protection at the international and local level (UNESCO) and environmental and ecological protection (Ministry of Ecology and Spatial Planning).
– Not wanting to potentially enter the zone of violation of legal regulations and provisions, and in order to protect the professional integrity of the planning team, we propose to suspend planning activities – they state in a letter to the Ministry of Ecology, Spatial Planning and Urbanism.
Healthy Mojkovac
Healthy Mojkovac in the Civic Initiative claims that there are enough reasons for the state to terminate the contract with Tara Resources.
– The opening of surface mines is prohibited in the EU, and this project, if implemented, would permanently, completely and irreversibly destroy 7,000,000 m2 of natural beauty, which includes 17 habitats from the NATURA 2000 list, over 100 protected species… on a distance of only 1.8 km from Biogradska gora National Park, in the catchment area of the UNESCO-protected Tara, which gravitates towards Durmitor National Park and exposed the inhabitants of Mojkovac and its surroundings to the direct influence of carcinogenic substances (organic compounds, cyanide and heavy metals), putting this town in a discriminated position in relation to other cities of Montenegro, stopping the further growth and development of tourism and agriculture. But, not only Mojkovac, Kolašin is not far from exploitation fields… Did you know that silver and gold are actually hidden behind the name “and other accompanying metal sulfides” as stated in the title of the contract? How will you protect the citizens of Mojkovac from an environmental disaster caused by hazards, do you have any contractual guarantee? How did you protect the state from the declaration of bankruptcy of the concessionaire after it carried out the complete devastation of the area and exported all the found mineral wealth – they ask the Ministry of Capital Investments and the Government, and state that the contract indicates only the private interest of the concessionaire, and that “Montenegro is losing its mineral resources, nature, people … for only 3.5 percent of one’s profit”.
They emphasize that the Strategic Environmental Impact Assessment is completely inconsistent with the legislation of Montenegro and the basic standards and principles of human health and environmental protection.
– In the program task, it is written that for “the reactivation of ore exploitation, it is mandatory to develop suitable projects that will ensure the application of environmentally friendly technology and environmental protection measures, which will be verified by environmental impact assessment studies. Considering the fact that the area is part of the world network protected areas, man and the biosphere, special attention should be paid to the restrictions arising from international obligations, especially when it comes to protection regimes”. This means that it is necessary to have UNESCO’s opinion before drafting the document. Bearing in mind the technological processes that take place during the flotation procedure, the use of heavy carcinogenic organic additives, cyanide and other dangerous substances and the possibility of their reaching underground and surface waters, as well as the potential contamination of the Tara River, non-compliance with the provisions of the protection of this area is directly called into question the further status of “tears of Europe” – according to GI.
They further explain that the Feasibility Study for the exploitation of lead, zinc and accompanying useful components, submitted by the concessionaire, is based on invalid regulations, and that it is the only document based on which the processors prepared the DPP and SPU, which are under public discussion.
– The study, commissioned by the concessionaire, was prepared by the Institute of Mining and Metallurgy in Bor. The authors stated that it complies with our laws and regulations, which is not true, four out of five regulations are not valid! Not a single state institution gave a positive opinion on that study – say the GI.
They especially emphasize that the technology that the concessionaire will use is not in compliance with laws and regulations.
– The concessionaire deliberately avoided mentioning the presence of mercury in the ore body, because the Industrial Emissions Act (2019) prohibits the use of mercury and mercury compounds and mixtures of mercury in plants, i.e. in corresponding production processes. Therefore, the flotation procedure, which is contrary to the law, is directly questioned! This fact also leads to the termination of the contract, because the technological procedure is contrary to the legal regulations of Montenegro. The presence of mercury in the amount that defines the subject area as a “mercury mine” is described in the State Plan for the exploitation of mineral resources for the period 2019-2028. years. The State Plan, as well as the accompanying Strategic Environmental Impact Assessment, do not envisage the exploitation of ore in the Brskovo area, so in order for it to begin, it is necessary to adopt a new state plan with accompanying documentation, which would only then be the basis for initiating the procedure for adopting a DPP for the area of the former Brskovo mine, which it was not done – according to GI.
GI Healthy Mojkovac reminds that Montenegro has ratified the Minamata Convention, which obliges “to take appropriate measures” to “not allow” the production, import or export of new products containing mercury.
– Among other things, the Minamata Convention describes that “mercury and most of its compounds are very toxic to humans and the environment, even relatively small concentrations can have a serious harmful effect on neurological development. Elemental mercury that is released into the atmosphere is deposited in water over time the environment where it can be converted by bacteria into methylmercury, its most toxic form. Depending on the form, it can remain in the air for up to a year and can be transported across the hemisphere before being deposited; therefore, mercury is a global problem and it cannot be solved at the national level. In water systems, inorganic mercury is transformed into a much more toxic form – methylmercury, which accumulates in fish and marine mammals, and which is further consumed by humans.” Due to these and numerous other reasons, “the use of mercury and mercury compounds and mixtures of mercury in plants, i.e. in appropriate production processes” is prohibited in Montenegro, which calls into question any chemical processing of ore, methods and technologies that would be carried out by the concessionaire – they say in GI.
They say that they will not give up the fight for a Healthy Mojkovac and announce that they will turn to the Agency for the Prevention of Corruption “due to justified doubts regarding the engagement of the author of the Strategic Impact Assessment by the concessionaire”.
DPP auditors
That there are numerous dilemmas when it comes to the opening of the Brskovo mine is indicated by the Council for revision of the detailed spatial plan for the concession area (president Prof. Dr. Veljko Radulović), although he gave the green light for the corrected version to go to public discussion. They expect that the involvement of competent domestic and international experts will help to determine “whether mining activities are destructive, that is, whether they are sustainable – both from the economic aspect and from the aspect of protection”.
Radulović draws attention to the contradictory treatment of the Brskovo area through planning documentation.
– Detailed spatial plan for the concession area for the exploitation of mineral resources Brskovo in Mojkovac occupies part of the transition zone of the biosphere reserve of the Tara river canyon, protected by UNESCO, which has an emphasized development role in accordance with the principles of sustainability. Also, that area partly falls under the III regime of protection of the Biogradska gora National Park. It is a very vulnerable area where all activities must be carried out with planned protection measures. So, the DPP should unambiguously and clearly prescribe what is its competence, namely the guidelines for construction and protection, based on the adopted development scenario – he stated.
Radulović points out that the strategic determination of whether there is a place for mining activities at that location should be a topic for a higher order plan – the Spatial Plan of Montenegro.
He emphasizes that different types of activities can take place in that zone, including industrial ones, but destructive mining is difficult to accept due to their unsustainability and significant impact on the natural characteristics of the area, especially on biodiversity and the habitats of important plant and animal species.
Therefore, he suggests that before the adoption of the DPP, the coverage of the protected zones of the UNESCO program “Man and the Biosphere” should be checked and UNESCO’s expert bodies should be informed for the purpose of expert consultations.
Mr. Dragoljub Marković draws attention to the fact that, according to the Spatial Plan of Montenegro, the exploitation field is included in the “zone protected by international agreements”.
– This is a very significant statement because the seriousness and importance of official decisions can be called into question by repurposing! Formally, and in this case emphatically and essentially, it is not acceptable to change the provisions of the Spatial Plan of Montenegro (constitution on space) with a lower order plan. The strategic determination of PP of Montenegro is that the area in question is a protected area, so it cannot be changed by making the best mine organization plan, but by choosing between the determination of PP and the State Plan for the exploitation of mineral resources for the period 2019-2028. The preparation of the new PP, which is in progress, should be used to first check the strategic decisions related to this area, i.e. the protection of the area (established PP of Montenegro until 2020) versus the reactivation of mines (State plan for the exploitation of mineral resources for the period 2019-2028. year) – says Marković.
Dr. Miroslav Čizmović is concerned that even in the innovative plan of DPP Brskovo, the catchment area of the new mine is not fully defined and it enters the protection zone of NP Biogradska gora.
– Official reports show higher levels of heavy metals in some of the investigated watercourses as a consequence of the operation of the old mine. According to CETI data, surface waters do not have a good status due to elevated concentrations of lead, mercury, cadmium and nickel depending on the measurement location, due to groundwater seepage from old mining tunnels and through uncontrolled disposal of solid waste/tailings. According to the analysis results, at all locations, all parameters are out of the permissible limit values. The future area occupies a large area and a large part of the land that is under forest or used for agriculture will be permanently lost. At the same time, we should also add the areas where the fertile soil will be deposited, which should be returned to the tailings during recultivation – states Čizmović.
Three scenarios
The total area of the Brskovo concession area is 4.6 km. The draft DPP deals with three scenarios of ore exploitation. The first does not include the opening of mines and considers the development of the area through tourism, agriculture and preservation of biodiversity, archaeological sites and cultural monuments.
However, the developers notice that in the planned area there are unrenovated areas that represent an ecological problem, originating from former mining operations, which represents a problem in the further use of the space for purposes other than mining activity.
The second scenario involves the opening of mines in the locations of Žuta prla and Brskovo, with the application of conventional technology for the processing, disposal and flotation of tailings. In the DPP, it is assessed that this variant would have positive effects (investment in the local community, concession fees, employment of the population), but it is not acceptable due to the application of conventional technologies.
The third, accepted scenario, considers the development of the area with the opening of the mine. It implies the activation of the Žuta prla and Brskovo sites, the relocation of the Rudnica river in the part that is susceptible to contamination. Without denying that it has economic benefits, the DPP emphasizes that it will leave numerous consequences on the environment, but that “a smaller area will be degraded”.
– The negative aspects are reflected in the reduction and degradation of the forest cover, changing the image of the area, changes in water courses, the relocation of part of the population from the locality, the relocation of archaeological sites and cemeteries, air pollution, watercourses, occupation of land… What will permanently leave a negative impact on the area, its character and image is a tailings dump and a zone of soil subsidence, with the fact that the application of new technology degrades a smaller area compared to the conventional one. It implies a closed system of depositing reactive material and tailings, and thus represents a significantly better solution from the aspect of environmental protection – it is stated in the draft DPP Brskovo.
It is planned to purchase around 512 ha of land – 150 ha of private land and 362 ha of state land. About 70 percent of the territory is owned by the state/municipality, while 30 percent is privately owned. More than 70 percent of the private land that the concessionaire plans to acquire is registered as field or meadow/pasture/courtyard, and about 27 percent is forest. There are also pastures, fields, orchards… A total of 28 households are expected to be displaced.
Investment
The old Brskovo mine operated from 1966 to 1991, exploiting zinc and lead. The new one, investor Tara Resources announced, will be among the largest in Europe, it will have two surface mines, a processing plant and a waste management facility.
Production of about 45,000 tons of zinc, 13,000 tons of lead, 3,000 tons of copper and about one million ounces of silver is planned. The expected duration of the mine is 13 years and more, and the expected start of production is two years after the start of construction, which is planned for 2023/2024. a year.
Annually, it will earn about 100 million euros from exports, and it will allocate 10 million euros for concession fees and taxes, of which the Municipality of Mojkovac would receive almost three. During construction, around 700 workers will be employed, while around 450 direct and 200 indirect jobs will be created for ore mining.
In February, after Dritan Abazović, the prime minister in his technical mandate, visited Brskovo, the Government announced that 25 million had been invested in the mine so far, and the total investment was 150 million.
