Natural and Culturo-Historical Region of Kotor

• Earthquake damage (issue resolved)
• Lack of Management System/Management Plan
• Inadequate legal framework
• Building and development (accelerated urban development and urban pressure)
• Ground transportation infrastructure (proposed major bridge at Verige and other proposed development projects)
• Lack of buffer zone (issue resolved)
• Major visitor accommodation and associated infrastructure
• Land conversion
• Society’s valuing of heritage
• Changes in traditional ways of life and knowledge system
• Impacts of tourism/visitor/recreation

N/A

On 8 December 2022, the State Party submitted a state of conservation report, which is available at https://whc.unesco.org/en/list/125/documents/ and presents the following progress:

• A study was prepared by the Administration for the Protection of Cultural Properties of Montenegro on the protection of cultural properties to inform amendments to the Municipality of Tivat’s Detailed Urban Plan (DUP) for Lepetani village and the Urban Plan (UP) for the Lepetani Tourist Zone;
• The Municipalities of Kotor and Tivat are taking forward plans to designate the Vrmac hill as a protected nature park. A public consultation on a draft protection study, prepared by the Environmental Protection Agency, has taken place and is informing a revised proposal that will be sent to the Government for adoption;
• The State Party has ensured that Heritage Impact Assessments (HIA) were prepared for a number of proposed projects located in the World Heritage property and its buffer zone, of which they submitted for technical review those for tourist facilities in Muo, Orahovac, Risan and Herceg Novi; a business centre in Škaljari; and residential projects at Prčanj, Dobrota and Tivat;
• HIAs have been requested for numerous other proposed construction projects located in the World Heritage property and its buffer zone, namely at Risan, Morinj, Dobrota, Stoliv, Kotor, Orahovac, Prčanj, Škaljari, Muo, Strp, as well as for the Verige Bridge project and the tourist complex proposed for the Luštica-Montrose peninsula;
• The State Party has sent a number of notifications in line with Paragraph 172 of the Operational Guidelines, regarding actions proposed for the World Heritage property and its buffer zone, including visual analysis of the Dub-Kuk section of the proposed cableway from Kotor to Cetinje and numerous projects planned for Sveti Marko Island;
• Consent was given for the reconstruction and expansion of the Hotel Teuta on the basis of revised plans that took into consideration ICOMOS’ recommendations to reduce the negative impact of the existing hotel on the property’s Outstanding Universal Value (OUV).

Progress has been made on some of the Committee’s recommendations, but it remains a concern that a series of documents requested from the State Party have not been submitted, making it difficult to accurately assess progress in improving the property’s management system. While acknowledging the delay caused by the pandemic and political changes at both national and local levels, it is of particular concern that the revision of the Management Plan has not been completed since the 2018 joint UNESCO World Heritage Centre/ICOMOS Reactive Monitoring mission and it is recommended that this is prioritised. In addition, the Management Plan should be integrated into the evolving legal framework, particularly in anticipation of the challenges of tourism management and the potential impacts of major tourism infrastructure projects.

Moreover, a robust planning framework, based on World Heritage commitments, needs to be put in place to effectively address the increasing development pressure in and near the property. Although the updated HIA for Natural and Culturo-Historical Region of Kotor for Harmonizing Policy/Planning Framework and Instruments seems to have been completed and is currently under institutional review, it has not been shared with the World Heritage Centre, nor made publicly available. Information from third parties, which has been provided to the State Party for comment, indicates that the 2017 Law on Spatial Planning and Construction of Structures no longer envisages the preparation of spatial plans by municipalities. In addition, information was provided that the moratorium on new construction ended in 2020. Clarifications from the State Party on these issues is awaited.

The State Party has listed a large number of projects proposed within the World Heritage property and its buffer zone. Several of these have been subject to technical review by the Advisory Bodies, together with relevant HIAs. The construction of the Muo Hotel has been assessed as having a negligible potential impact on the OUV, as has the residential complex proposed for Dobrota – although in the latter case the accommodation seems to cater more to the needs of tourists than local residents. The ‘Anchor Centre’ at Škaljari and the four villas at Prčanj, while not problematic in principle, would require design improvements before approval. Two different hotels proposed for Orahovac were assessed as having minor/moderate negative impacts on the OUV. This latter case emphasises the urgent need for the planning framework to be completed, given the large number of projects proposed and their cumulative impacts which can be highly significant. In addition, indirect impacts of construction projects, such as those potentially favouring increased tourism (e.g., the Luštica peninsula road), need to be given greater consideration in both individual HIAs and strategic planning decisions. For example, the Committee already requested information on developments associated with the new Luštica peninsula road and the multiple projects being proposed in that area need to be assessed both individually and in terms of their cumulative impacts.

Meanwhile, it is also noted that some more sensitive projects have been approved without any information being provided in advance to the World Heritage Centre, as requested, such as the three stone quarries in the buffer zone that were authorised following HIAs. More recently, in the light of additional information received on this issue, the World Heritage Centre invited the State Party to comment on the existence of three quarries and plans to open three more, and to provide the corresponding HIAs. In view of the serious potential negative impact that quarries can have on OUV, the exact location of all quarries and their potential impacts need to be better understood. It also seems important to review the relevant sections of the Spatial Urban Plan adopted by the Municipality of Kotor and other planning documents to ensure that the proposed quarry locations are adequately considered in future with regard to World Heritage protection.

In light of all of the above, the State Party is requested to continue to ensure that information on all proposed projects is provided in advance to the World Heritage Centre, including any relevant HIAs. This relates to information on projects already requested in previous Committee decisions and the 2018 mission report, as well as on any new proposals that have the potential to affect the OUV. It would be beneficial for impact assessment teams to refer to the Guidance and Toolkit for Impact Assessments in a World Heritage Context to better integrate World Heritage considerations into future impact assessments and subsequent planning decisions.