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

On 31 January 2020, the State Party submitted a state of conservation report, which is available at https://whc.unesco.org/en/list/125/documents/. The State Party provided additional information and updates throughout 2020 and in early 2021. These documents report progress in a number of areas addressed by the Committee at its previous sessions, as follows:

• The draft Spatial Urban Plan for Kotor Municipality has been revised on the basis of the recommendations of the 2018 joint World Heritage Centre/ICOMOS Reactive Monitoring mission and the December 2019 ICOMOS Technical review, and also incorporated the results of public consultation. The proposed Spatial Urban Plan was transferred to the World Heritage Centre in May 2020 for final comments and ICOMOS provided a Technical review in June 2020. The Spatial Urban Plan was adopted in summer 2020;
• The Heritage Impact Assessment (HIA) for Natural and Culturo-Historical Region of Kotor for Harmonizing Policy/Planning Framework and Instruments was completed and is now undergoing institutional review before final revisions and submission to the World Heritage Centre;
• The new Amendments of the Law on Protection of Natural and Culturo-historic Region of Kotor were passed in December 2019;
• The Management Plan is being updated to give consideration to the recommendations of the 2018 mission, and will be integrated with the Spatial Urban Plan and influence future legislation;
• HIAs for the proposed Morinj accommodation complex, the reconstruction of the Hotel Teuta in Risan, the preliminary design of the planned Mariott Hotel in Kotor, and the Port of Kotor Business Plan were carried out and submitted to the World Heritage Centre;
• The Ministry of Transport has begun preparations for an HIA of the proposed Verige Bridge;
• Concerns raised about the Silence of Administration administrative rule were addressed during the drafting of the forthcoming Law on Spatial Planning and Construction of Structures;
• A buffer zone study will be implemented to define in which areas in and around the property an HIA should be required for potential projects, as foreseen in the Amendments to the Law on Protection of the Natural and Culturo-historic Region of Kotor;
• A Detailed Urban Plan for Lepetani is underway by the Ministry of Sustainable Development and Tourism and on completion it will be submitted to the World Heritage Centre for review;
• Information has been provided regarding two proposed projects in the buffer zone: a local road across the Luštica peninsula and a Kotor-Lovćen cable car;
• Information has been provided regarding the upgrading of the sewage system around Kotor Bay and the reconstruction and the expansion of a hotel development within the boundaries of the property; a project for an underpass near the old town of Kotor is being translated into one of the working languages of the World Heritage Convention, after which it will be submitted to the World Heritage Centre.

On 23 April 2021, the World Heritage Centre requested information from the State Party in line with Paragraph 174 of the Operational Guidelines on the planned contruction of an apartment complex in Risan.

Progress in implementing the Committee’s decisions continues to be made and the recommendations of the 2018 mission are being integrated into a number of strategic documents and long-term planning tools.

The Amendments of the Law on Protection of Natural and Culturo-historic Region of Kotor were passed in order to offer increased clarity on the application of HIAs while awaiting the adoption of the revised Management Plan. It is reported that the revised Management Plan in turn will prompt further legislation for improving the management system. This process has shown the need for a more nuanced approach to the buffer zone and therefore a study is foreseen to define those areas in which projects will require an obligatory HIA.

The Spatial Urban Plan for Kotor Municipality has been adopted, while the HIA for Harmonizing Policy/Planning Framework and Instruments should soon be sent to the World Heritage Centre for review. In addition, work is underway for a Detailed Urban Plan for Lepetani, which will be submitted to the World Heritage Centre for review prior to its adoption. These efforts show the commitment of the State Party to translating its World Heritage obligations into the management of the property.

However, further improvements are needed to make sure that this strategic planning is reflected in decision-making for individual projects. Although the State Party regularly communicates with the World Heritage Centre regarding project proposals and HIAs are carried out, there continues to be a divergence between some of the HIAs’ conclusions and the recommendations of the 2018 mission and the ICOMOS Technical reviews. It is suggested that HIAs need to be carried out with full reference to the emerging strategic documents, that clear connections need to be made in HIAs between analysis of potential impacts on OUV and the report conclusions, and that (as recognized in Art. 2 of the Amended Law), the HIA process should inform all stages of design development, rather than being a retrospective assessment of a fully-developed project. This should be adopted for the forthcoming HIA for the Verige Bridge and any other future assessments. The State Party’s plan to harmonize the Management Plan, the Spatial Urban Plan and HIA is therefore much welcomed.

Following a high-level meeting, held at UNESCO Headquarters on 5 February 2020, between the UNESCO Assistant Director-General for Culture, the Director of the World Heritage Centre and the Minister of Culture of Montenegro, a constructive dialogue was established between the World Heritage Centre, ICOMOS and national authorities in order to provide advisory assistance to the state institutions to improve HIA for the reconstruction of Hotel Teuta in Risan in the best possible way. On 25 September 2020, the State Party presented the revised plans for the reconstruction of the Hotel Teuta in Risan in an online meeting to the World Heritage Centre and ICOMOS and subsequently submitted a revised HIA in November 2020. The new design proposal will reduce the negative impacts of the existing structure in close and more distant views (including from the archaeological site, Carine), improve the urban structure of Risan, and eliminate risk to any archaeological deposits below the made ground on which the hotel stands, which should be commended.

The proposals for a Kotor-Lovćen cable car and a local road for the Luštica peninsula seem to pose no problems at this stage, nor does the Business Plan for Kotor Port. However, it is recommended that the Committee request the State Party, in addition to maintaining communication with the World Heritage Centre as plans are developed (for example, by providing Accurate Visual Representations for the cableway), to consider indirect and cumulative impacts of such projects on the property. The purpose of the Luštica road is to facilitate the construction of tourist resorts and, while improvements to Kotor Port are welcomed, one of its primary purposes remains that of hosting cruise ships. These cases point towards much bigger challenges in managing tourism and the impact it has on World Heritage, which goes beyond consideration of individual building or infrastructure projects.