Case Study: Komarnica Dam

Unveiling Komarnica Hydropower Plant:

Positioned 45 kilometers upstream from the existing 342 MW Piva power plant, the Komarnica hydropower plant envisions a 171-meter-high concrete arch dam and a 17.6-kilometer-long reservoir. Operating as a peaking plant, it anticipates an annual electricity generation of 213 GWh, a stark contrast to the Piva plant's average of 860 GWh, also in peaking mode.

Questionable Need and Environmental Vulnerability:

The necessity for another hydropower plant in Montenegro, already generating 40 to 60 per cent of its electricity from hydropower, remains unclear. This high dependence on hydropower makes Montenegro exceptionally vulnerable to climate change, evident in its considerable annual fluctuation in generation (refer to Annex 2). The lack of economic viability evidence for Komarnica further raises concerns, emphasizing the urgent need for diversification in renewable sources.

Environmental Impact on Protected Areas:

The Komarnica project threatens to flood the Komarnica candidate Emerald Site (ME000000P), the Dragišnica and Komarnica Regional Park, and potentially impacts three Natura 2000 sites: Bukovica Valley and Vojnik Mountain under the Birds Directive, and the Komarnica and Pridvorica sites under the Habitats Directive. Despite being identified as an area for the expansion of the Durmitor National Park and UNESCO site, Komarnica holds only a 'Regional Park' status.

Biodiversity at Stake:

Home to numerous protected species such as wolves, bears, Balkan chamois, otters, stone crayfish, golden eagles, rock partridges, and corncrakes, the area's biodiversity faces imminent threat. The partial fieldwork conducted so far leaves the full extent of potential damage unknown. Unique caves and cliffs, integral to the region's biodiversity, would be submerged without comprehensive research.

The environmental assessment, released in February 2022, appears more as a promotional brochure than a scientifically rigorous study, leaving it susceptible to legal challenges. Organizations, including the Montenegrin Ecological Society, KOD, and the Nikšić Young Ecologists’ Association, filed a complaint with the Bern Convention in April 2022, asserting Montenegro's failure to safeguard the Komarnica Emerald Site and assess the project's impacts adequately.

Regulatory Gaps and Public Opposition:

Montenegro, under the Bern Convention and the EU Water Framework Directive, holds responsibilities to protect candidate Emerald sites and assess projects impacting Natura 2000 sites. The Komarnica environmental impact assessment lacks an 'appropriate assessment,' and projects affecting the river’s status require a detailed assessment under the EU Water Framework Directive. The current substandard environmental assessment positions the project for potential legal challenges, intensifying the growing public opposition to Komarnica.

Funding Uncertainty:

While the Montenegrin government sought funds for the project as a Flagship under the EU Economic and Investment Plan, the European Commission has clarified that none of the proposed greenfield hydropower projects, including Komarnica, has received endorsement for funding within the Western Balkans Investment Framework (WBIF). The funding source for the project remains entirely uncertain.