Infrastructure Projects Facility Technical Assistance Window (IPF TA ...

Infrastructure Projects Facility 

Technical Assistance Window (IPF TA) 

EuropeAid/128073/C/SER/MULTI 

Sub project: 

WB4-MNE-ENV-12B: Management models and options 

for cost recovery for the future construction and operation 

of regional landfills in Montenegro (Case Study 

for Nikšić) 

Institutional Review Report (Activity 2) 

May 2012

Project Office 

Deĉanska 5, 1st floor 

11000 Belgrade 

Serbia 

Tlf. 45 97 22 11 

E-mail xxxx 

web COWI-ipf.com 

COWI A/S 

Parallelvej 2 

DK-2800 Kongens Lyngby 

Denmark 

Tlf. +45 45 97 22 11 

Web www.cowi.com 

The European Union's 2008 IPA Programme for Albania, 

Bosnia and Herzegovina, Croatia, the former Yugoslav 

Republic of Macedonia, Montenegro, Serbia, Kosovo (under 

UNSCR1244/1999), Turkey and Iceland 


Technical Assistance Window 

(IPF TA) Western Balkans 

EuropeAid/128073/C/SER/MULTI 

Sub project: 

WB4-MNE-ENV-12B 

Management models and options for cost 

recovery for the future construction and 

operation of regional landfills in Montenegro 

(Case Study for Nikšić) 

Institutional Review Report (Activity 2) 

FINAL 

May 2012 

Document no. WB4-MNE-ENV12B_TECH_Activity 2 Report 

Version 2 

Date of issue 31 May 2012 

Prepared Srna Sudar, Zdenka Ivanovic, David Toft 

Checked Dr Merih Kerestecioğlu, Ayşe Çiğdem Arslancan, David Toft 

Approved Dr Merih Kerestecioğlu

Infrastructure Projects Facility – Technical Assistance Window 

Sub project: WB4-MNE-ENV-12B: Management Models and Options for Cost Recovery for the Future Construction and 

Operation of Regional Landfills in Montenegro 

i 

Table of Contents 

1 Executive Summary 6 

2 Report Overview 10 

3 Introduction 12 

4 Institutional and Legal Review 14 

4.1 Institutional set-up at national level 14 

4.2 PROCON 16 

4.3 National policy framework 18 

4.4 Relevant national legislation 26 

4.5 Institutional set-up at local level 36 

4.6 Development needs 39 

5 Waste Generation in Nikšić Area 41 

5.1 Review of national economic development 

parameters 41 

5.2 Review of forecasts for waste generation 42 

6 Case Study Nikšić 49 

6.1 Nikšić 49 

6.2 Plužine 52 

6.3 Šavnik 54 

6.4 Regional landfill for Nikšić, Šavnik and Plužine 56 

6.5 Sources of financing 57 

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ii 

List of Tables 

Table 1 Other institutions in solid waste management in 

Montenegro ................................................................................. 16 

Table 2 Economic indicators of Montenegro, 2012 ................................. 41 

Table 3 Population and waste generation of the Nikšić catchment 

area, 2004 .................................................................................... 43 

Table 4 Generated amounts (t/year) of municipal waste for Nikšić, 

Pluţine and Šavnik, from 2004 to 2009 ...................................... 44 

Table 5 Total amount of waste in Nikšić, Pluţine and Šavnik, in 

tons, 2010-2029 .......................................................................... 44 

Table 6 Total amount of waste generated, in tons, 2010-2029 ................ 45 

Table 7 

Total amount of waste generated, disposed and recycled 

from 2010 to 2029....................................................................... 45 

Table 8 Population of Nikšić, Pluţine and Šavnik, 2007-2029 ............... 46 

Table 9 Population by municipality and settlement type ......................... 46 

Table 10 Waste generation forecast, 2013-2030 ........................................ 47 

Table 11 Key data on Nikšić ...................................................................... 49 

Table 12 Basic data on Nikšić PUC ........................................................... 51 

Table 13 Key data on Pluţine .................................................................... 52 

Table 14 Basic data on Pluţine PHUC ...................................................... 53 

Table 15 Key data on Šavnik ..................................................................... 54 

Table 16 Data on Šavnik PUC ................................................................... 55 

Table 17 

Table 18 

Table 19 

Table 20 

SWOT Analysis for the North Region (Pluţine, Šavnik), 

strengths and weaknesses ............................................................ 69 

SWOT Analysis for the North Region (Pluţine, Šavnik), 

opportunities and Threats ............................................................ 70 

SWOT Analysis for the Central Region (Nikšić), strengths 

and weaknesses ........................................................................... 71 

SWOT Analysis for Central Region (Nikšić), opportunities 

and threats ................................................................................... 72 

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iii 

List of Figures 

Figure 1 Organisational chart of PROCON .............................................. 18 

Figure 2 Organisational chart of the Municipality of Nikšić .................... 50 

Figure 3 Organisational chart of the Municipality of Pluţine ................... 53 

Figure 4 Organisational chart of the Municipality of Šavnik .................... 55 

List of Annexes 

Annex 1 

Annex 2 

Annex 3 

Annex 4 

Main Legal Acts of PROCON 

Legal Acts Reviewed for Legislative Framework 

Secondary Legislation 

SWOT Analysis on the Regions in Montenegro 

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iv 

List of Abbreviations 

EC 

EIB 

IPF 

MNE 

MoSDT 

PROCON 

PUC 

TA 

ToR 

EPA 

IPPC 

EU 

EIA 

GoM 

IFI 

EUR 

NSSD 

MSSD 

NPI 

WI 

WEEE 

RoHS 

PCB 

PCT 

BoT 

PPP 

CRPS 

European Commission 

European Investment Bank 


Montenegro 

Ministry of Sustainable Development and Tourism 

National Project Implementation Unit in the Field of Communal 

Services and Environment 

Public Utility Company 

Technical assistance 

Terms of reference 

Environmental Protection Agency 

Integrated pollution prevention and control 

European Union 

Environmental impact assessment 

Government of Montenegro 

International finance institute 

European currency 

National Strategy for Sustainable Development 

Mediterranean Strategy of Sustainable Development 

National Program for Integration 

Waste Incineration (Directive) 

Waste Electrical and Electronic Equipment (Directive) 

Restriction of Hazardous Substances (Directive) 

Polychlorinated biphenyls 

Polychlorinated terphenyls 

Build, operate, transfer 

Public private partnership 

Central Register of business organizations 

.




v 

MONSTAT 

PHUC 

RM 

WTN 

SME 

MoF 

WBIF 

Statistical Office of Montenegro 

Public Housing and Utility Company 

Republic of Montenegro 

Waste Transfer Note 

Small and medium size enterprises 

Ministry of Finance 

Western Balkans Investment Framework 

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6 

1 Executive Summary 

1.1 English version 

The current document constitutes the Institutional Review Report (Activity 2) 

of the project “Management models and options for cost recovery for the future 

construction and operation of regional landfills in Montenegro (Case Study for 

Nikšić).” The report is divided into the following sections: 

 

 

 

 

 

Overview of the Report (Chapter 2) – lists the issues to be addressed in 

the report, as well as the presents the objective of the report, which is to 

examine what future solutions for procurement and operations are 

available under the current legal and institutional framework, as well as 

provides some initial indications of the condition of the municipalities 

and PUCs that will be involved in the regional landfill scheme. In this 

sense, it provides some basic inputs into the Activity 3 Report. Otherwise, 

however, the current report does not affect the outputs of the Activity 

3 and 4 Reports. 

Introduction (Chapter 3) – provides an introduction to the report, including 

the main principles of solid waste management in the Montenegro. 

Institutional and Legal Review (Chapter 4) – covers the institutional 

set-up at the national level, as well as the national policy framework 

and relevant national legislation with respect to solid waste management, 

the institutional set-up at the local level, and development needs 

in the sector. 

Waste Generation in Nikšić Area (Chapter 5) – reviews the forecast for 

waste generation in the Nikšić Service Area for solid waste management. 

Case Study on the Nikšić Service Area (Chapter 6) – presents the basic 

information on solid waste management in the Nikšić Service Area, the 

proposed regional landfill, and financing of the solid waste management 

sector, in particular with respect to landfill operation, closure, and 

post-closure aftercare. 

The institutional set-up for solid waste management is fairly typical: the national 

government sets the policy objectives for the development of the sector, 

while the local governments function as the regulators of the services at the local 

level, including with respect to tariff-setting and establishing minimum service 

levels. The typical service provider of solid waste management is a multipurpose 

public utility company (PUC). The relationship between the local government 

and the PUC is governed by a PUC statute and local decision accord- 

.




7 

ing to which solid waste collection and disposal is assigned to the PUC. Performance-based 

contracts, by which a commercial relationship is established 

between the local government and PUC, are not used. 

According to the legal set-up for solid waste management in Montenegro, an 

inter-municipal company can be established for solid waste management and 

landfill operations. This is the case in the Nikšić Service Area, although the 

company Budoš essentially exists only on paper until such time as the regional 

landfill is constructed. In addition, all forms of public sector participation are 

permitted under the law. This means that the report for Activity 3 (Procurement 

Options Report) should consider all public-private partnership type options for 

the landfill construction and operation. 

There are several areas of development needs for the solid waste management 

sector, as listed below: 

• Continued harmonisation of laws – in particular the “Law on waste management” 

with the Directive on Waste 2008/98/EC is needed, in particular 

with respect to the hierarchy of waste, extended producer responsibility, 

preparation for reuse, recycling, biodegradable waste, content of local 

waste management plans, prevention of waste generation, etc. 

• Local capacity for planning and management of waste collection and landfills 

– there remains one regional landfill in the country and experience in 

landfill management is limited. Capacity development programmes for local 

governments, PUCs, regional landfill companies, etc. are needed. 

• Support to local governments and PUCs in the calculation of tariffs for 

solid waste collection and disposal. 

• Financial support to municipalities in the construction of regional landfills, 

as well as support in implementing cost covering tariffs for solid waste collection 

and treatment services. Financial support for care of landfills after 

their closure should also considered since according to the Law on waste 

management, this is the responsibility of the local government (and not the 

landfill operator, as in the Landfill Directive). 

1.2 Sažetak 

Ovaj dokument predstavlja Izvještaj o institucionaloj organizaciji u okviru projekta 

“Modeli i opcije upravljanja za povraćaj troškova buduće izgradnje i rada 

regionalne deponije u Crnoj Gori (Studija sluĉaja za Niksic)”. Izvještaj je podijeljen 

u sledeća poglavlja: 

• Kratak pregled Izvještaja (Poglavlje 2) – navode se sva pitanja koja su 

ovim Izvještajem obuhvaćena, kao i sam cilj Izvještaja, a to je da se uvidi 

koje opcije nabavke i rada su moguće u okviru postojećeg institucionalnog 

sistema i zakonodavstva u zemlji, kao i da da inicijalne naznake o uslovima 

u Opštinama i njihovim komunalnim preduzećima koja će biti 

.




8 

ukljuĉena u rad buduće regionalne deponije. Uzimajući ovo u obzir, ovaj 

Izvještaj daje uvod u Izvještaje koji će pokriti aktivnosti 3 i 4 projekta. 

• Uvod (Poglavlje 3) – daje uvod u Izvještaj, ukljuĉujući glavne principe 

upravljanja ĉvrstim otpadom u Crnoj Gori. 

• Institucionalni i pregled zakonodavstva (Poglavlje 4) – daje pregled insitucionalne 

organizacije na nacionalnom nivou, kao i nacionalni zakonodavni 

okvir, s osvrtom na relevantnost za oblast upravljanja otpadom, zatim 

institucionalnu organizovanost na lokalnom nivou i razvojne potrebe 

sektora. 

• Generisanje otpada na podrucju Nikšića (Poglavlje 5) – daje pregled oĉekivanog 

generisanja /koliĉine otpada u servisnom podruĉju Nikšića. 

• Studija sluĉaja za servisno podruĉje Nikšića (Poglavlje 6) – daje pregled 

osnovnih informacija o upravljanju ĉvrstim otpadom u servisnom podruĉju 

Nikšića, o regionalnoj depoiniji i finansiranju sektora upravljanja otpadom, 

s posebnim osvrtom na rad deponije, njeno zatvaranje, i odrţavanje nakon 

zatvaranja. 

Institucionalna organizacija sistema za upravljanje ĉvrstim otpadom je manjeviše 

tipiĉna: Vlada donosi politike i ciljeve za razvoj sektora, dok lokalne 

samouprave imaju funkciju organizacije i sprovoĊenja tog servisa na lokalnom 

nivou, ukljuĉujući uspostavljanje tarifa i ustanovljanja minimuma usluge. Ovu 

vrstu usluge na lokalnom nivou, tipiĉno izvršava Javno-komunalno preduzeće 

(JKP), koje ima više uloga. Odnos izmeĊu lokalne samouprave i JKP je 

ustanovljen u Statutu JKP i Odluci o osnivanju JKP, kojom su poslovi 

sakupljanja i odlaganja ĉvrstog komunalnog otpada dodijeljeni JKPu. Ugovori 

na bazi rada i dostignuća preduzeća, izmeĊu lokalne samouprave i JKP se ne 

koriste. 

U skladu sa pravnim okvirim za upravljanje ĉvrstim otpadom u Crnoj Gori, 

moguće je osnovati meĊu-opštinsko preduzeće za upravljanje ĉvrstim otpadom 

i deponijom. Ovo je sluĉaj i u servisnom podruĉju Nikšića, iako kompanija Budoš 

u stvari postoji samo na papiru sve dok se regionalna deponija ne izgradi. 

Dodatno, svi vidovi uĉešća javnog sektora su dozvoljeni u okviru postojećeg 

pravnog okvira. U skladu sa tim, Izvještaj za aktivnost br. 3 projekta (Opcije 

nabavke) treba da uzme u obzir sve vidove javno-privatnog partnerstva za 

izgradnju i upravljanje deponijom. 

Postoji potreba za razvojem u nekoliko oblasti u sektoru upravljanja ĉvrstim 

komunalnim otpadom.Oblasti, tj. potrebe su navedene u nastavku: 

• Kontinuirana harmonizacija zakonodavstva– posebno je potrebno dalje 

usklaĊivanje “Zakona o otpadu” sa Direktivom o otpadu 2008/98/EC, s 

osvrtom na hijerarhiju u upravljanju otpadom, produţena odgovornost proizvoĊaĉa, 

priprema za ponovnu upotrebu, recikliranje, biorazgradivi otpad, 

.




9 

sadrţaj lokalnih planova upravljanja otpadom, prevencija generisanja otpada, 

itd. 

• Kapacitet na lokalnom nivou za planiranje i upravljanje sakupljanja otpada 

i upravljanja deponijom – postoji jedna regionalna deponija u zemlji, i 

iskustvo u oblasti upravljanja je ograniĉeno. Programi izgradnje kapaciteta 

lokalnih samouprava, JKPa, kompanija koje bi upravljale regionalnom deponijom, 

itd. je nadasve potrebno. 

• Podrška lokalnim samo-upravama i JKPima u kalkulaciji i uspostavljanju 

tarifa za sakupljanje i odlaganje ĉvrstog otpada je neophodno. 

• Neophodna je finansijska podrška opštinama za izgradnju regionalne deponije, 

kao i u sprovoĊenju tarifa koje pokrivaju troškove za sakupljanje i 

odlaganje ĉvrstog komunalnog otpada, i za njegovu obradu/preradu. Finansijska 

podrška za odrţavanje deponije nakon njenog zatvaranja se treba 

uzeti u obzir, jer Zakon o otpadu nalaţe da je ovo odgovornost lokalnih 

samouprava (ne onoga ko upravlja deponijom, kao što nalaţe Direktiva o 

deponijama). 

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10 

Scope 

2 Report Overview 

This report constitutes the output of Activity 2 – Review of the current 

institutional set-up for waste management and review of case study of Nikšić 

landfill. According to the Terms of Reference (ToR), this report should cover 

the following issues: 

• Review the existing institutional set up in Montenegro at State and Local 

Government level concerning solid waste management. The relevant policies, 

functions, capacities and development needs will be evaluated. 

• Review institutional set-up of municipal utility companies (PUCs). 

• Review current plans for the formation of inter-municipal operational institutions, 

if any. 

• Review national and regional economic development parameters; 

• Based on existing studies, review forecasts of waste generation in the area 

for the lifetime of the landfill. 

• Review current and forecast legislation with respect to waste generation – 

the relevant Montenegrin laws and regulations, as well as EU Directives 

that might impact the total volume, such as the required reduction of landfill 

of biodegradable waste and packaging waste. 

• Discuss available external sources of financing and financial costs, as well 

as financial security or any other equivalent to be provided by the operator 

as described in the requirements of Council Directive 1999/31/EC. 

• Prepare case study on Nikšić, including: 

- review and evaluation of functions of company (-ies) in charge of 

waste management in Nikšić, including: planning, operations, financial, 

commercial, administration and monitoring. The analysis shall 

assess the current status of the organization, and suggest needs for development 

and strengthening, taking into consideration the future role 

of the organization as the owner of the regional facility. 

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11 

- review and evaluation of companies in charge of waste management 

in Pluţine and Šavnik. 

Objective 

This report basically stands alone from the other reports on the procurement 

and operations options (Activity 3 Report) and the tariff models report (Activity 

4 Report). It serves, however, to examine what future solutions for procurement 

and operations are available under the current legal and institutional framework, 

as well as provides some initial indications of the condition of the municipalities 

and PUCs that will be involved in the regional landfill scheme. In 

this sense, it provides some basic inputs into the Activity 3 Report. Otherwise, 

however, the current report does not affect the outputs of the Activity 3 and 4 

Reports. 

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12 

Waste management 

framework in MNE 

National Waste 

Management Plan 

Law on Waste 

Management 

Key principles 

3 Introduction 

Over the past decade, Montenegro has made efforts to establish a waste management 

framework in the country. Based on past experience, current policy is 

that solid waste management must be an integral part of environmental protection 

policy and actions. In this respect Montenegro, is still in the process of establishing 

a legislative and institutional framework that will ensure full compliance 

(for example, with European Union directives) in solid waste management. 

According to the National Waste Management Plan 2008-2012 (2008), the 

communal waste management system in the country is based on the existing 

system of collecting and transporting waste. The plan gives guidelines for establish 

a system that presumes waste disposal in sanitary landfills in combination 

with transfer stations and recycling centres. In addition, the National 

Waste Management Plan 2008-2012 provides a framework for the regional 

concept of waste management which would be based on the interests of local 

self-governments jointly to organize some activities related to waste management 

with the following reasoning behind the concept: rational use of space, 

limited resources, and reducing the overall costs of waste treatment. The region, 

that would have a regional landfill to serve its purposes, would need to 

have a landfill contracted and managed in accordance with regulations, standards 

and EU directive. 

The Law on Waste Management, adopted in 2005 (Official Gazette 80/05; implementation 

postponed until 1 January 2008), sets out that Montenegro is 

committed to organizing work on collection, temporary storage, transport, 

processing and disposal of waste by respecting principles of sustainable development, 

proximity, and regional waste management system, as well as enforcing 

preventive action, "polluter pays" and at utmost the respect to the sequence 

of waste management practices. Furthermore, the Law prescribes that waste 

management is implemented and organized in accordance with national and 

local waste management plans. 

The key guiding principles of Montenegro‟s waste management system are set 

to be: 

• Sustainable development - respecting this principle creates the preconditions 

for sustainable waste management, which means more efficient use 

of resources and reduction of waste produced. Further, it means that when 

.




13 

waste has been already produced, it should be dealt with it in a way that 

will contribute to the overall objectives of sustainable development. 

• The proximity principle - waste should be treated or disposed as close to 

the place of his occurrence as possible. The principle aims to avoid adverse 

impacts of waste transport on the environment. However, this principle depends 

on local conditions and should be balanced against the principle of 

economic feasibility, which usually implies regional organization of waste 

management operations. 

• The precautionary principle means that if there is a possibility of 

serious or irreversible damage, lack of full scientific reliability cannot be a 

reason for not taking measures to prevent environmental degradation. 

• The polluter pays principle that stipulates that polluters must bear the full 

cost of the consequences of their actions. In the case of waste, producers 

and consumers of waste should bear the costs of production, treatment and 

disposal by including these in the price of services. 

• The waste hierarchy principle, which refers to the order of priority in waste 

management system: prevention of waste generation, preparation for reuse; 

recycling; treatment of waste in a different manner, such as composting, 

energy production, etc.; and finally disposal. 

These guiding principles of waste management in Montenegro have been accepted 

and promoted in country's policies, plans and legislation framework, 

starting with the National Waste Management Policy adopted in February 2004, 

the Strategic Master Plan for Solid Waste Management (end of 2004/beginning 

of 2005), Law on Waste Management (2005), and the National Waste Management 

Plan 2008-2012 (2008). As indicated in Section 4.6, however, continued 

harmonisation of this law with the EU Waste Directive is needed. 

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14 

4 Institutional and Legal Review 

This chapter covers a review of the existing institutional and legal set-up concerning 

solid waste management in Montenegro at the national and local government 

levels. 

4.1 Institutional set-up at national level 

There are several institutions with influence on national policies related to solid 

waste management in Montenegro. Therefore, the following section provides 

an overview of the relevant actors at the national level as part of the waste 

management system in Montenegro. 

4.1.1 Ministry of Sustainable Development and Tourism (MoSDT) 

The MoSDT, (previously the Ministry of Spatial Planning and Environmental 

Protection), is the line ministry responsible for the environment and solid waste 

management, in particular: 

• Protection and improvement of the environment 

• Preparation and implementation of policies and strategies and the legislative 

framework in the field waste management, as well as preparation of a 

National Waste Management Plan and other programmes and plans 

• Urban and spatial planning 

• Establishing standards for waste treatment, permitting, and technical standards 

for waste treatment facilities 

• Coordination of waste management with other ministries and institutions 

• Management and coordination of waste projects funded from national and 

international resources 

• Issuing licenses to facilities for waste treatment, including recycling 

• Inspection and control of ecological parameters. 

Within the MoSDT, the Sector for Waste Management and Communal Development 

has nine permanent employees and two employees on defined-term 

contracts 1 . The sector comprises the following departments 2 : 

1 According to the official government systematization, the sector is to have 16 employees. Extract 

from the Regulations on internal organization and the Ministry of Sustainable Development and 

Tourism, 2011. 

2 Report on the work and situation in the administrative areas in 2011 of the Ministry of Sustainable 

Development and Tourism, May 2012. http://www.gov.me/sjednice_vlade/66 

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15 

• Department of Waste Management: three permanent and one limited-term 

employee (5 positions total may be assigned according to the government 

systematization) 

• Department of Communal Development: 2 permanent employees (3 positions 

total may be assigned) 

• Department for Programming and Implementation of EU funds: four permanent 

and one limited-term employee (7 positions total may be assigned 

according to the government systematization). 

The Sector carries out tasks related, among others, to: 

• preparing policy proposals, recommendations and measures for implementation 

of policy related to communal issues 

• developing strategies and other developmental plans, programs and projects 

in the area of waste management 

• monitoring of the implementation of adopted long-term development planning 

documents and action plans 

• drafting laws and by-laws within the scope of this department, as well as 

providing opinions, interpretations and suggestions for the process of their 

implementation 

• monitoring the process of harmonization of legislation in its area of competence 

with the legislation of the European Union 

• monitoring and improvement of operation of business entities involved in 

communal activities 

• monitoring and improving human resource potential in its area of concern 

• adopting best international practices in the sector in accordance with the 

proposed measures 

• cooperating with educational institutions and professional associations in 

order to improve operations in its fields of concern 

• developing the institutional framework to improve relations in the field of 

waste management other utility services 

• cooperating with local governments in communal services, as well as cooperation 

with state and communal public companies or private companies 

and entrepreneurs who perform certain services 

• defining guidelines for the provision of communal services and analysing 

and assessing the situation in communal services, including solid waste 

management, to ensure compliance with international standards 

• implementing activities in the process of joining the European Union, as 

well as cooperating with international financial institutions and funds for 

the EU pre-accession assistance 

• participating in preparation of tender documents for procurement within 

the jurisdiction of the Sector 

• providing opinions, professional instructions, and technical assistance. 

4.1.2 Environmental Protection Agency (EPA) 

The Environmental Protection Agency is an independent body that deals with 

the implementation of laws related to environmental protection. It is responsible 

for environmental inspection and monitoring, issues permits, and implements 

strategic environmental assessment (SEA) and environmental impact 

.




16 

assessment (EIA) procedures, as well as is responsible for integrated pollution 

prevention and control (IPPC) permitting, with which all landfills in Montenegro 

must comply. The Agency‟s role also includes collecting data and preparing 

reports on conditions in the field of waste management in Montenegro for 

the relevant international organizations and institutions, such as the European 

Union. 

4.1.3 Other institutions 

Apart from the key institutions mentioned above, other institutions have an influence 

on solid waste policies, as shown in the following table. 

Table 1 

Other institutions in solid waste management in Montenegro 

Name of institution 

Directorate for Public 

Works 

Ministry of Agriculture 

and Rural Development 

Ministry of Economy 

Ministry of Finance 

Ministry of Health 

Ministry of Interior 

Ministry of Labour and 

Social Welfare 

Ministry of Transport 

and Maritime Affairs 

Description 

Divided into three sections (for investment implementation, investment 

monitoring, and general services), the Directorate is involved 

in the preparation, implementation and monitoring of public works 

projects. 

Previously Ministry of Agriculture, Forestry and Water Management. 

Responsible for the protection and use of agricultural land, control 

of animal waste, water management, and water protection. 

Responsible for energy, energy efficiency, mining, and geological 

survey, as well as regional development. 

Responsible for adopting the budget system and tax policy, as well 

as for foreign investments, donations and assistance from abroad. 

Responsible for health care, including management of medical 

waste, establishment of sanitary standards, as well as sanitary 

control and inspection. 

Responsible for local government. The Law on Local Self- 

Government falls under the jurisdiction of the Ministry of Interior 

Responsible for social security, employment policy, etc. The main 

laws governing employment condition and procedures on all levels 

are the Labour Law of Montenegro (Official Gazette of GoM 

No. 49/08) and Law on Civil Servants and State Employees (Official 

Gazette of GoM No. 50/08) for employment and work in public 

administration. Taxes on wages go indirectly into the municipal 

budgets, which then, among others, goes toward financing the 

activities of the PUC. 

Responsible for all transport. 

4.2 National Project Implementation Unit for 

Communal Services and Environment (PROCON) 

At the national level, the National Project Implementation Unit in the Field of 

Communal Services and Environment (PROCON) is the national project implementation 

unit established by the Government of Montenegro at the end of 

2008 to manage and coordinate projects in the area of communal services and 

environmental protection. 

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17 

Mission 

Priority projects in 

SWM 

According to its mission and operations, PROCON strives to prevent 

environmental pollution, through expert support in improving the environmental 

protection system and developing/strengthening communal infrastructure 

in Montenegro. PROCON‟s main activities are consulting and management 

for the needs of the national and local governments. The services of 

PROCON are based on contractual relations between the Government of Montenegro 

and international financial institutions (i.e., the European Investment 

Bank (EIB) and various IFIs) and they encompass: project financing; project 

analyses to assess feasibility, sustainability and harmonization with strategic 

planning documents; preparation of ToRs for feasibility studies, studies on the 

estimate of environmental influence (EIA) and accompanying project documentation; 

organisation and implementation of tender procedures, as well as tender 

evaluation; and performing of other activities as stipulated by the contracts on 

utility-sector and environmental protection project financing. The main activity 

of the company is consulting and management. 

The company‟s priority projects in 2012 include the following in the field of 

solid waste management 3 : 

1 Construction of Leachate Water Treatment Plant for the landfill “Livade” 

landfill in Podgorica 

2 Sanitation and remediation of dumpsite “Vrtjeljka” in Old Royal Capital 

Cetinje (documentation and studies) 

3 Sanitation and rehabilitation of "Ćafe" dumpsite in the municipality of Bar 

4 Construction of regional landfill in Nikšić Municipality for the municipalities 

of Nikšić, Šavnik and Pluţine 

5 Construction of regional centre for waste management in Pljevlja Municipality 

for the municipalities of Pljevlja and Ţabljak (documentation and 

studies) 

6 Construction of the regional centre for waste management in Berane, for 

the municipalities of Berane, Andrijevica, Plav and Roţaje (intended for 

implementation through a public private partnership – PPP) 

7 Construction of Regional centre for waste management in Kotor Municipality, 

for the Municipalities of Kotor, Tivat and Budva (Herceg Novi) 

8 Construction of a Regional Landfill in the Municipality of Bar, for the municipalities 

of Bar and Ulcinj. 

Organization 

The company‟s main legal acts are listed in Annex 1. The company‟s 

organisational structure is presented in the following figure. 

3 http://www.procon.me/eng/projects.phpak=t&p=3 

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18 

Figure 1 

Organisational chart of PROCON 

Source: website of PROCON (http://www.procon.me/eng/page.phppid=3) 

4.3 National policy framework 

The national policy framework can be viewed through the following national 

policy documents, which are discussed further in this sub-section. 

• National Policy for Waste Management (February 2004) 

• Republic-Level Solid Waste Strategic Master Plan (January 2005) 

• National Strategy for Sustainable Development (2007) 

• Montenegro Spatial Plan until 2020 (March 2008) 

• Policy Development Plan (December 2008) 

• Waste Management Plan in Montenegro for 2008 – 2012 (February 2008) 

• Regional Development Strategy 2010-2014 (February 2011). 

4.3.1 National policy for waste management (2004) 

On 26 February 2004, Montenegro adopted a National Waste Management Policy, 

which encompasses a vision, principles and objectives prescribed by the 

National Environmental Programme, as well as supports the targeted objectives 

of other existing national regulations and standards. This policy of integrated 

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19 

and sustainable waste management constitutes a vision for future waste management 

methods and defines goals and strategies that will facilitate its implementation. 

In summary, the Policy aims at: 

• Promotion of the prevention and reduction of waste generation and thereby 

pollution 

• Promotion of the management and reduction of waste impacts that cannot 

be avoided, from generation to final disposal 

• Provision of integrated and sustainable capacities and conditions for use of 

water, air and soil 

• Ensuring remediation of any contamination of the environment by making 

the person responsible for the contamination liable for this remediation. 

4.3.2 Republic-Level Solid Waste Strategic Master Plan (2005) 

The Republic-Level Solid Waste Strategic Master Plan, which was adopted in 

January 2005, provides conditions for the rational and sustainable management 

of solid waste at the national level. The Master Plan is aimed at the reduction of 

the impact of waste on the environment, increasing efficiency in the use of resources, 

and waste management gaps in the past. The Master Plan establishes 

the major objectives that are to lead to satisfactory progress in waste management 

at the national level, while in the mid-term the goal is to reduce waste, in 

line with relevant European Union directives on waste. In addition, the Master 

Plan establishes internal national targets, focusing on the management of municipal, 

hazardous, medical and other types of waste. In the medium-term, the 

results should aim to: 

• Increase the amount of waste collected 

• Reduce the amount of waste deposited in landfills/dumps 

• Introduce recycling activities. 

Apart from its vision and goals, the Master Plan gives an overview of the major 

types of waste generated in the country, as well as examines the then current 

waste management process, providing relevant management plans for strengthening 

the system through legislation and institutional restructuring. In this respect, 

the Master Plan envisions the construction of seven regional landfills for 

municipal waste, to serve all 21 municipalities in Montenegro. In addition, the 

Master Plan prescribes rehabilitation of the existing waste disposal sites, improvements 

in waste collection and recycling systems, as well as improvements 

in management and disposal of specific types of waste: hazardous, wastewater 

sludge, and medical waste. The financial implication of the implementation of 

the activities envisioned in the Master Plan was estimated at EUR 120 million 

up to 2014. 

Significant achievements have been made in the areas of policy reform and 

harmonization, while from the infrastructure side the projects seeking for heavy 

investment are in the preparation phases and need further financing or are under 

implementation. At the moment, Montenegro has only one sanitary landfill that 

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20 

acts as a regional: the landfill “Livade" in Podgorica, servicing also Danilovgrad 

and Cetinje. 

4.3.3 National Strategy for Sustainable Development – NSSD 

(2007) 

The commitment to Montenegro as an Ecological State (see section 4.4.1 on the 

Constitution) has led to the preparation of the framework strategic document 

Directions for the Development of Montenegro as an Ecological State in 2000. 

The NSSD represents a further step based on previous actions to incorporate 

elements of modern strategic planning and to establish a stronger connection 

with the international processes, strongly relying on the Development and Poverty 

Reduction Strategy and other sectoral strategies developed in the country. 

Additionally, the NSSD is one of the elements of the implementation of the 

Mediterranean Strategy of Sustainable Development (MSSD) at the national 

level, aimed at implementing sustainable development principles for the betterment 

of the environment and people. 

Principles 

In Montenegro, the principles of sustainable development are understood as 

the: 

• Integration of environmental issues in sectoral policies 

• Internalization of environmental costs (i.e., conversion of external costs of 

environmental degradation into internal costs of polluters/users) through 

the implementation of the polluter/user pays principles 

• Participation of all stakeholders in decision-making, consultations, dialogue, 

and partnerships 

• Access to information and justice 

• Inter and intra-generational equity, as well as gender equality 

• Precautionary principle, or the requirement to safeguard natural equilibrium 

in the absence of certainty 

• Principle of subsidiary and interdependency between local and global levels 

• Access to services and financial resources to meet basic needs. 

Main problems 

The NSSD reflects on the issues of different sectors, among others waste. The 

Strategy recognizes the main problems in the waste sector that need significant 

improvement in order to meet the objective of sustainable development, such 

as: 

• poor database on different sources, quantities and sites where waste is disposed 

• provisional data on communal waste, no data on construction and animal 

waste 

• small scale of recycling, and almost non-existent energy recovery programmes 

and recovery of raw materials from waste 

• low awareness of the need to reduce waste generation and provide for its 

appropriate treatment/disposal 

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21 

• lack of sufficient capacities of public utility companies as the main providers 

of municipal waste collection and disposal services 

• selection of sites for future regional landfills that are acceptable to the local 

population from the point of view of environmental protection and which 

incur the lowest costs 

• implementation of new regulations and necessary improvements in managing 

hazardous and industrial waste. 

The Republic-Level Solid Waste Strategic Master Plan, the National Waste 

Management Policy and the Law on Waste Management are aimed at addressing 

above mentioned issues, leading to the conclusion that successful implementation 

of these polices will improve the state of the waste sector in the 

country. In these respects, the main goals of the NSSD in waste management 

are the further harmonization of national legislation with EU legislation, 

strengthening capacities for waste management, construction of sanitary landfills, 

raising awareness on waste separation and recycling, and enhancing the 

waste database. 

4.3.4 Spatial Plan of Montenegro until 2020 

The Spatial Plan of Montenegro until 2020 sets the national objectives and 

measures for spatial development, in line with economic, ecological, socioeconomic 

and cultural-historic development. Furthermore, the Spatial Plan defines 

general and specific principles of spatial development, in accordance with 

sustainable development principles, and provides guidelines for the development 

of sectoral policies and detailed spatial planning documents at the state 

and local levels. 

Scope 

The Spatial Plan of Montenegro envisions the spatial development of the 

country in response to the actual needs of the population as well as to recent 

changes and future trends. Two main pillars constitute the spatial development 

of the country, reflecting different requirements of the same process: 

• regionalization of the development perspective 

• further integration of the Montenegrin space. 

Classification 

The Spatial Plan specifies three regions of Montenegro: 

• Coastal Region – development zones of Boka Kotorska Bay, Central Coast 

and Southern Coast. 

• Central Region – development zones of Zeta and Bjelopavlići Plain, Nikšić 

and Cetinje area constituting lowlands surrounded by karst areas. The largest 

part of industry, the best agricultural land and the main centres of services, 

cultural and other tertiary activities, excluding tourism, are concentrated 

in this region. The present spatial structures and conditions in the 

Central Region require an appropriate organization of the space in the light 

of the industrial restructuring processes and pressure on agricultural land. 

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22 



• Northern Region – development zones formed in the river valleys of the 

Lim, Tara and Ćehotina, Piva and Ibar, with adjacent mountain areas. 

Objectives 

As mentioned previously, the Spatial Plan of Montenegro states general and 

specific guidelines for development of sectoral policies. Concerning waste, the 

Spatial Plan sets out the following objectives to: 

• mitigate the negative environmental impacts of waste. To this end, the municipalities, 

as the responsible authority for waste disposal, are to elaborate 

waste management strategies. These strategies must include approaches for 

waste collection and disposal in accordance with established intermunicipal 

cooperation. 

• reduce the volume of waste by introducing systems of waste separation to 

exclude those components of waste that can be reused or recycled from 

those that have to be landfilled. Accordingly, municipalities have to elaborate 

concepts for waste separation systems in accordance with their general 

waste management strategies. 

• define special areas for collection, i.e. primary disposal of solid municipal 

waste, so that complete functional areas are established, with waste management 

centres as integral parts. The areas are determined on the basis of 

the corresponding number of potential users, homogenous internal transportation 

links at as short as possible distance, and the existing disposal 

system. 

• close or rehabilitate, if possible, existing, mostly inappropriately organized 

dumps, which represent the greatest danger as potential pollution sources. 

The locations have to be secured from further potential pollution of natural 

resources by conducting appropriate ecological-technical measures. 

• dispose and treat low and medium radioactive waste in accordance with the 

regulations on the protection from ionizing radiation and international conventions 

and treaties, of which Montenegro is a signatory. In accordance 

with international guidelines, sites are defined by analysing variants, with 

careful evaluation of options from the point of view of environmental impact 

and urban development, economic effects and general social acceptability. 

The selection of sites should be defined on the basis of detailed and 

comprehensive studies including environmental impacts assessment (also 

considering transport requirements) and potential seismic risks. 

Objective 

4.3.5 Policy Development Plan (2008) 

The Policy Development Plan was developed in 2008 by the Ministry in charge 

of environmental and sustainable development issues (at the time, the Ministry 

of Tourism and Environment) to provide a technical guidance tool for the development 

of environmental policy in line with the EU standards and good 

practices over the course of the next two to three years. The Plan intends to address 

organizational changes and capacity development of the Ministry and to 

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23 

contribute to the institutional strengthening necessary as part of the accession 

process in the area of environment. The Plan: 

• reviews and analysed existing information 

• identifies priority areas for environmental policy-making 

• outlines what actions and resources are needed to develop a comprehensive 

set of environmental policies over time. 

The Plan reflects to a large degree the priorities and activities outlined in the 

National Program for Integration (NPI) of Montenegro into the European Union 

for 2008 – 2012. In addition, it draws significantly on other available policies 

and strategies relevant to the environment sector in Montenegro, especially 

on the National Strategy for Sustainable Development. 

Content 

Requirements 

The document comprises two parts. Part one outlines general topics such as the 

purpose and content of environmental policies, discusses setting of policy objectives 

and policy integration, and presents the purpose and objectives of the 

Plan, as well as methodology applied. Part two provides detailed information 

on 14 policy areas (among others, waste) and a number of sub-areas for which 

specific policies are to be developed. At the end of the Plan, one-page factsheets 

are provided which contain summarized information on each policy area 

and sub-area covered in the Plan. 

Concerning waste, the Plan prescribed actions to be taken that were relevant at 

the time of the Plan development, such as: 

• Further transposition of the Hazardous Waste Directive 91/689/EEC, 

Waste List Decision 2000/532/EC, and Regulation (EC) 1013/2006 is 

planned through the following secondary legislation: 

- Rulebook on Types and Waste Test Methods (containing catalogue of 

waste) 

- Rulebook on Mandatory Requirements for Assets and Equipment 

Used for Collection or Transport of Hazardous Waste 

- Rulebook on Content of Labels for Products Containing Hazardous 

Substances 

- Rulebook on Content, Form and Manner of Preparing Waste Records, 

etc. 

• Further harmonization with the Waste Framework Directive, Landfill Directive, 

Regulation on Shipments of Waste and Waste List Decisions is 

planned through the following secondary legislation: 

- Rulebook on landfills 

- Rulebook on Types and Waste Test Methods (containing catalogue of 

waste) 

- Rulebooks on requirements for provision of waste treatment and disposal 

services, on different types of waste to be accepted on landfills, 

on reuse and recycling, waste reporting etc. 

.


24 



• Transposition of the Waste Incineration (WI) Directive is planned for 2010 

– 2012. Transposition of the Landfill Directive through harmonization of 

secondary legislation with the Urban Wastewater Treatment Directive and 

Sewage Sludge Directive was planned in 2009. From 2010 – 2012, harmonization 

with the following directives is planned: 

- Batteries and accumulators Directive 

- Waste Electrical and Electronic Equipment Directive (WEEE Directive) 

and Restriction of Hazardous Substances Directive (RoHS Directive) 

- End-of-life vehicles Directive 

- Packaging and packaging waste Directive 

- Waste oils Directive 

- PCBs and PCTs disposal Directive. 

From 2008 to 2012, most of the above prescribed activities have been realized. 

Scope 

4.3.6 National Waste Management Plan for 2008-2012 

The Waste Management Plan in Montenegro for 2008-2012 was adopted in 

February 2008. The Plan includes: 

• Assessment of waste management 

• Objectives of waste management 

• Long and short-term measures for waste management in the planning period, 

with the implementation dynamics 

• Funding framework for the realization of the plan 

• Plan realization paths and the responsible institutions 

• Raising public awareness on waste management. 

Objective 

The main task of the Waste Management Plan in Montenegro for 2008-2012 is 

the implementation of the strategic directions for waste management in the 

country. These directions are as follows: 

• Establishing an integrated waste management system, based on increasing 

the amount of waste that is collected, reducing the amount of waste that is 

disposed, and introducing recycling 

• Remediation and closure of existing landfills 

• Remediation of "hot spots" or locations highly affected by waste load. 

• Development and establishment of inter-municipal (regional) sanitary 

landfill with waste treatment before final disposal. 

Furthermore, this Plan assigns to local self-governments the responsibility to 

develop and implement waste management policy at the local level, through: 

• Adopting programmes and plans for waste management in their territory 

• Pursuing joint programs between two or more municipalities 

• Estimating waste production 

• Developing a plan for collecting and transporting 

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25 

• Developing a Treatment Plan 

• Preparing a Disposal Plan 

• Reducing waste production 

• Improving the capacity of utilities 

• Regulating the work of the private sector regarding the collection, transportation 

and disposal of waste 

• Improving the permitting system. 

4.3.7 Regional Development Strategy 2010-2014 (2011) 

In order to achieve a more equal socio-economic development of Montenegro, 

in accordance with the principles of sustainable development, regional development 

in the EU, and as an important element of the EU accession process, in 

February 2011 the Government of Montenegro developed and adopted the Regional 

Development Strategy for 2010-2014. 

Objective 

The main aim of this Strategy is to define socio-economic development goals 

and reduce regional disparities, by strengthening the potential for the development 

of those parts of the country that are lagging behind more developed ones. 

The document represents a governing instrument of economic policy. The strategy 

is defined by the "bottom up" principle, linking local and regional development 

needs with the development priorities at the national level, support to 

less developed areas, and support for sustainable natural resource management, 

application of low carbon technologies and the development of municipal infrastructure. 

The Strategy defines three regions: 

• North region: comprising the Municipalities of Andrijevica, Berane, Bijelo 

Polje, Mojkovac, Kolašin, Plav, Pljevlja, Pluţine, Roţaje, Šavnik and 

Ţabljak. 

• Central region: comprising the Capital town - Podgorica, Historic capital 

town - Cetinje, and the Municipalities of Danilovgrad and Nikšić. 

• Coastal region: comprising the Municipalities of Bar, Budva, Herceg- 

Novi, Tivat, Kotor, Ulcinj. 

Three strategic objectives are defined in the Strategy: balanced development of 

all local governments and regions, rapid development of less developed municipalities 

and regions, and regional development and environmental protection. 

Content 

The Regional Development Strategy for 2010-2014 contains a SWOT analysis 

of a cross-section of all the factors that influence the development of state and 

local government, the details of which are presented in the Annex to this Report. 

Among others, the Regional Development Strategy foresees development 

of solid waste management as a priority. 

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26 

4.4 Relevant national legislation 

This section contains an overview of relevant national laws that affect the solid 

waste management sector, beginning with the Constitution of the Republic of 

Montenegro. 

4.4.1 Constitution of the Republic of Montenegro 

The country‟s significant natural potential and stated duty to preserve it have 

led to the proclamation of Montenegro as an Ecological State, by the adoption 

of the Parliament of Montenegro of the Declaration on Montenegro as an Ecological 

State in 1991. This Declaration was in accordance with the principles 

and requirements of sustainability. This commitment to a healthy environment 

was confirmed in Montenegro‟s Constitution in 1992, which states that Montenegro 

is a “democratic, social and ecological state” and established the right to 

a healthy environment and the duty to protect and improve it as constitutional 

principles. 

4.4.2 Law on Environment 

The Law on Environment 4 defines the basic principles and instruments to be 

used to protect environment. This law prescribes: principles of environmental 

protection and sustainable development, actors and instruments of environmental 

protection, public participation on environmental matters and other issues 

of importance to the environment. Environmental protection ensures the 

general preservation of the quality of environment, biological and landscape 

diversity, rational utilization of natural resources and energy in the most convenient 

manner for the environment, as a basic condition for a healthy and sustainable 

development. Integrated environmental management is conducted in a 

manner to ensure sustainable development in accordance with this Law and 

other regulations. 

4.4.3 Law on Nature Protection 

The Law on Nature Protection5 defines measures for the protection of nature 

and particularly the protection of certain natural resources which are specific by 

biological, geological, and ecosystem biodiversity. The Law establishes the 

procedure for putting under protection natural resources, determines ways to 

control and use protected natural resources, provides for special protection 

measures, and prescribes the measures to protect during the performance of 

work/activities and in the process of development of spatial and other plans. By 

this Law, national categories of protected natural objects are established such 

as: parks and natural areas, nature reserves, natural monuments, memorials and 

monuments, and some flora and fauna species. 

4 Official Gazette of GoM, No. 48/08 

5 Official Gazette of GoM, No. 51/08, 21/09 

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27 

4.4.4 Law on Environmental Impact Assessment 

The Law on Environmental Impact Assessment6 regulates the process of environmental 

impact assessment for projects that can have a significant impact on 

the environment, the contents of the study on impact assessments, the participation 

of interested institutions, organizations and the public, the process of assessment 

and issuing of approvals, information on projects that can have a significant 

impaction the environment of another state, control and other issues of 

importance to assess the impaction the environment. Regional landfills in Montenegro 

require an environmental impact assessment. 

Several bylaws were passed prior to the date on which the Law came into effect 

(1 January 2008), including the Decree on projects subject to EIA7; Rulebook 

on content of documentation to be submitted together with request for determination 

on the need for EIA8; Rulebook on content of documentation to be submitted 

together with request for determining the EIA scope and contents of the 

EIA study9; Rulebook on content, form and a way of keeping the public record 

on actions and decisions on EIA10; and Rulebook on contents of the EIA 

study11. The EIA law and related secondary legislation are harmonized with 

the EU Directive 85/337/EEC on the assessment of the effects of certain public 

and private projects on the environment, as amended by 97/11/EEC and 

2003/35/EC. The requirements of EU Directive 2003/4/EC and Directive 

2003/35/EC on public access to environmental information, public participation 

in decision-making and access to justice, were transposed into this Law. 

In terms of projects that are subject to EIA, the Decree on projects subject to 

EIA divides activities into two lists; for projects on the first list, the EIA is 

mandatory, while for projects on the second list, an EIA may be required. 

Essentially any major investment in the solid waste sector requires an EIA. The 

types of solid waste projects that fall under List 1 are contained in the annex to 

the law, under point 11 (“other projects“) and include: 

• Installations for the treatment of hazardous waste by incineration, chemical 

or biological treatments as well as landfills for temporary and permanent 

storage of hazardous and radioactive waste. 

• Waste disposal installations for the incineration or chemical and biological 

treatments, temporary storage and permanent disposal of non-hazardous 

waste, including municipal and inert waste, with a capacity exceeding 100 

tonnes per day. 


7 Official Gazette of Montenegro No 20/07 

8 Ibid. 

9 Ibid. 

10 Ibid. 

11 Ibid. 

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28 

All other typical solid waste projects fall under List 2 (annex 2 to the Law, under 

point 13 “Other projects“), including: 

• Waste disposal installations for the incineration or chemical and biological 

treatments, temporary storage and permanent disposal of non-hazardous 

waste, including municipal and inert waste, with a capacity not exceeding 

100 tonnes per day 

• Recycling facilities and centres for waste recycling 

• Plants for treatment and disposal of sludge from waste water 

• Installations for processing, storage and permanent disposal of radioactive 

waste 

• Installations for the disposal of animal carcasses and animal waste 

• Biogas plants 

The Law on EIA sets the responsibility of conducting the EIA on the project 

developer and the obligation for authorisation for the impact assessment is governed 

under Article 6: “Project developer cannot commence with project implementation 

without previously conducted impact assessment procedure and 

obtaining of authorisation of the competent authority for the impact assessment 

Study.” The Environmental Protection Agency acts as the state administration 

body for projects for which other consents, approvals and permits are issued by 

other state administration). At the local level, however, the competent authority 

is part of a local self-government unit responsible for environmental protection. 

4.4.5 Law on Integrated Pollution Control and Prevention 

The Law 12 on Integrated Pollution Control and Prevention regulates the conditions 

and procedures for issuing integrated permits for installations and activities 

that can have negative impacts on human health, environment or material 

assets, the types of activities and facilities, surveillance and other issues of importance 

to prevent and control environmental pollution. The Law complies 

with the Council Directive 96/61/EC concerning integrated pollution prevention 

and control and its later amendments. 

All envisioned landfills in Montenegro fall under this Law, meaning that they 

require an IPPC permit, due to their capacities according to existing project 

documentation for their construction and operation 13 . 

4.4.6 Law on Strategic Environmental Impact Assessment 

The Strategic Environmental Impact Assessment Law defines the conditions, 

manner and procedure for carrying out strategic impact assessment on environment 

of certain plans and programmes, through the integration of environmental 

principles in the process of preparation, adoption and implementation of 

plans or programs which have a significant impact on the environment. 

12 Official Gazette of GoM 80/05 

13 10 tonnes daily or 25000 tonnes in total 

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29 

The national legislation on strategic environmental impact assessment has been 

harmonised with relevant Directive 2001/42/EC of the European Parliament 

and of the Council of 27 June 2001 on the Assessment of the Effects of Certain 

Plans and Programmes on the Environment, with the Protocol on Strategic, and 

was drafted in accordance with the EU Guidance on SEA directive implementation. 

4.4.7 Law on Spatial Planning and Construction of Buildings 

The Law on Spatial Planning and Construction of Buildings 14 defines the system 

of spatial planning of Montenegro, the manner and conditions of building 

structures and other issues relevant to spatial planning in order to create conditions 

for the spatial development and for the legal construction of facilities in 

accordance with the standards of quality and technical standards in the field of 

construction. 

Spatial planning is based, in accordance with the Law, on the following principles: 

harmonized economic, ecological, social, energy, and cultural development 

of the State; sustainable development; encouraging balanced economic 

development, rational use and protection of space and natural resources, compliance 

with European regulations, protection of integrated values of the space, 

decentralization, polycentric cohesion and competitiveness, protection and improvement 

of the environment, cultural heritage, public interest, public participation 

in planning, seismic planning. 

Construction of facilities is to be based on the following principles: protection 

of public interest, real estate property, harmonization with European norms and 

standards, stability and durability of the building, a seismic design and construction, 

health, environmental and space, protection from natural and technological 

disasters, fire, industrial accidents, thermal protection, protection from 

noise, reducing the irrational use of energy and energy efficiency. 

4.4.8 Law on Local Self-Government 15 

With the adoption of the Law on Local Self-government in 2003, and following 

its amendment, significant decentralization of activities from the national to the 

local level was pursued by increasing the competence and jurisdiction of local 

governments. The Law on Local Self-government established activities and 

services to be provided by the local self-governments. The Law prescribes legal 

status of the municipality, services of the local government, property, local 

government financing 16 , local government public bodies, local communities, 

14 Official Gazette of Montenegro No. 51/08 

15 Law on Local Self-Government (Official Gazette of Go M No. 42/03, 28/2004, 75/2005, 13/2006, 

88/2009, 3/2010)/ Law on financing of local self-governments Official Gazette No. 42/2003, 44/2003, 

No/2008. Note to the Art. cl. 174. Of the Law - 51/2008-1) and Law on Financing Local Self- 

Government (Official Gazette No. 42/2003, 44/2003, No/2008. Note to the Art. cl. 174. Of the Law - 

51/2008-1). 

16 Prescribed in detailed by the Law on Financing of Local Self-governments (Official Gazette No. 

42/2003, 44/2003, No/2008. Note to the Art. cl. 174. Of the Law - 51/2008-1). 

.




30 

citizen participation in the provision of local self-government services, relations 

and cooperation between local governments and citizens, relations of local governments 

and nongovernmental organizations, association and cooperation of 

local communities, transparency of local-government services, etc. 

The most important policy regulating the operation of the local governments is 

the Law on Financing Self-governments together with the Law on Property 

Tax, which regulates mostly the introduction, collection and control of major 

local revenues, with their latest amendments, both Laws entered into force on 1 

January 2011. 

Financial aspects 

The Law on Financing Self-governments aims at providing more financial 

sustainability and fiscal autonomy of local-governments. The sources of financing 

for local-governments include: 

• own revenues (local communal tax, local administrative tax, compensations 

for the use of communal property of general interest, compensations 

for the use of land, revenues collected by the administrative bodies, fees, 

etc.) 

• renounced revenues within the municipality, collected out of different 

kinds of taxes 

• additional resources (municipalities that cannot provide the resources necessary 

for their activities receive extra resources from the State budget (or 

“governmental support”) 17 . 

The national government provides direct capital funding for some municipal 

services such as roads construction, lighting, water and sanitation, culture and 

sports. Investment grants are also available to municipal budgets, although they 

require a high percentage (50 to 70%) of matching funds. Since municipalities 

cannot provide this with their own funds, or based on their own creditworthiness, 

they are effectively dependent on State guarantees. 

The allocation of taxes on property, property use and beverage consumption to 

municipalities, and shares of 10% in personal income tax (PIT) by residence 

and 50% in property transfer tax, together with fees, charges and the right to 

impose a surcharge of up to 13% on personal income tax, (15% in the two cities) 

were introduced. Certain administrative difficulties, as well as adoption of 

a number of other laws, such as the Laws of the Local Communal Taxes, the 

Law on Registry, the Law on Spatial Planning and Construction of Objects, 

Person Income Tax Law and others), however, have decreased the revenue 

sources of local-governments 18 . In addition, collection of certain fees has been 

difficult for local governments due, among others to a lack of reliable taxpayer 

databases. 

Another problem local-governments face resulted from State‟s efforts to support 

the construction sector during crises by adopting the Law on Spatial Plan- 

17 Local Government Initiative, http://lgi.osi.hu/country_datasheet.phpid=202 

18 Ibid. 

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31 

ning and Construction of Objects. This law cancelled significant local government 

revenue – fees for use of construction land – which has jeopardized the 

implementation of another significant local revenue: fees for land development 

(compensation for setting communal infrastructure on the land), which was established 

in the Law on Financing Local Self-governments. 

4.4.9 Law on Participation of Private Companies in Public 

Services 

The Law on Participation of Private Companies in Public Services 19 , which applies 

to all public institutions, provides a framework for intensification of participation 

of the private sector in the areas of general significance for the society, 

and application of public services in relation to leasing and management 

contracts, including build-operate-transfer (BOT) arrangements. This Law, together 

with the Law on Concessions, provides general arrangements for several 

instruments that could be used for planned action and private capital to revitalise 

the infrastructure of the state/local governments despite the lack of funds 

from the budget for participation of the private sector in public services, for the 

betterment of government/local governments. These areas are: 

Public-private-Partnership (PPP) 20 : a private investor can undertake construction 

on a given site and use it for pre-defined number of years, but it needs to 

transfer the ownership after the completion of the pre-defined timeframe by 

which the public interest is protected. With such arrangements, private companies 

bring profit to the local governments, which resource was previously exploited. 

The Law envisioned that PPPs can be concluded only on the grounds of 

a public call made by a public institution (Article 15 of the Law). 

From 2002 to 2009, the Law on participation of the private sector in the procurement 

of public services regulated the area of concessions. With the adoption 

of the Law on Concessions in 2009, certain provisions of the Law on participation 

of the private sector in the procurement of public services ceased to 

be applicable (Provisions of chapters IV, VII, VIII, IX and articles 141, 142 and 

143 Law on participation of private sector in the procurement of public services, 

as well as the provisions of other chapters related to concessions and 

BOT arrangements ceased to be applicable. Provisions of other laws regulating 

the allocation of concessions will not be applied if contrary to this law). 

Procurement of public services leasing (articles 55-63) can be used for: existing 

public infrastructure that requires repair, existing public enterprises not requiring 

repair, or for infrastructure that will be of public use. The private investor 

bears the costs of insurance and maintenance, while the insurance agreement 

is integrated in the lease agreement. The investor or the operator cannot benefit 

from subsidies, or use the public funds for repair for personal gain. (“activities 

19 Official Gazette GoM No. 30/02 from 26.06.2002 and No. 08/09 from 04.02.2009 

20 Institut Alternativ, with support from Open Society Institute, Public-Private Partnerships in Montenegro: 

Accountability, transparency and efficiency 

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32 

undertaken in terms of procurement are conducted in line with the best and 

generally accepted private sector procurement practice”-articles 63-69). 

Management Agreements (articles 64-69) can be established between a public 

institution and consulting agencies or private consultancy based on the contract 

to offer different type of services, such as: management, supervision, financial, 

legal, or technical services. Commission (3 member) that needs to be approved 

by the government/parliament, municipality/line ministry (depending who concludes 

the Agreement) is established to monitor the implementation of the contract. 

The commission approves the reports of the consultants or consulting 

agencies, and the copies are passed on to the Privatization Council. 

4.4.10 Law on Concessions 

In Montenegro, according to the Law 21 , concessions are awarded for several 

reasons (art. 2): 

• in the public interest, to increase employment, introduce a new technology 

and secure enhanced economic growth, or secure profit for the grantor 

• rational, cost-effective, proper and efficient use of natural resources, goods 

in general use, and other goods from general interest 

• Technical-technological advancement and improve security and unity of 

the system, infrastructure improvement activities subject to the concessions; 

• construction, reconstruction and modernization of objects that are significant 

for the provision of public services 

• Competition in the area which provides concessions, protection and improvement 

of the environment. 

The Law provides grounds for the process of allocating concessions, guaranteeing 

to the bidder complete and correct information on the procedures, standards 

and criteria for the selection of the concessionaire; defines categories subject 

for concessions (Article 6). 

The Law on Concessions prescribes the maximum concession period of 30 

years, when the concession has been allocated by the government or the parliament, 

and the maximum concession period of 60 years when the decision on 

the allocation of the concession has been adopted by the Parliament (Article 8, 

paragraph 2). The possibility to extend a concession for a period not exceeding 

half of the period defined in the original concession contract is given by the 

Law. 

An eight-member Concessions Commission must be established (plus the 

President of the Commission), whereas the Government elects the president of 

the Commission. Membership is for a five-year period with the possibility of a 

single re-election (Article 10, paragraph 8). 

21 Official Gazette of GoM No. 08/2009 

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33 

The plan for awarding concessions is determined and published on the Government 

website annually and adopted by the Government or the municipality, 

depending on whether the plan is adopted at the state or local level. Before 

adopting the plan, the competent authority is obliged to organize a public debate. 

The concession is allocated on the grounds of a public call for bids and a 

public competition either in an open, two-phase, or a shortened procurement 

process. 

For a concession lasting for up to three tears, a shortened process with no public 

debate is prescribed. The possibility for not having the legal obligation to 

have a public debate in the shortened process is a novelty in Montenegrin legislation. 

In Montenegro, compulsory public debate existed until 2009 (Law on 

participation of private sector in the procurement of public services required 

that public debates are organised for all concessions regardless of their duration. 

This is visible from article 74 of this Law, stipulating that each concession 

contract concluded on grounds of article 73, which is concluded without the 

consent of the bearer of the concession, and publication in the “Official Gazette 

of the Montenegro” and without public debate will be considered null and 

void) 22 . 

4.4.11 Law on Foreign Investment 

Another Law important for PPP is the Law on Foreign Investment 23 . The Law 

regulates in which way a foreign natural or legal person may establish an enterprise 

or invest in one (i.e. buy a company or a part of it by purchasing that 

company‟s shares) under the same conditions as a domestic person. The foreign 

investor may invest through lease agreement, franchise, management and sale 

of real estate, and may also construct on grounds of BOT arrangement or a concession 

(Articles 12 and 13). As by the Law, when the Government of Montenegro 

is one of the contracting parties, it does not have rights exceeding the 

ones of the other contracting party (Article 28). 

4.4.12 Law on Waste Management/Waste Management Act 

The Law on Waste Management was adopted by the Parliament of Montenegro 

24 in 2005 and was planned to enter into force as of November 2008. Its full 

enforcement, however, began on 1 January 2010. This Law regulates types and 

classification of waste, waste management planning, provision of conditions for 

waste collection and treatment, rights, obligations and responsibilities of legal 

and physical entities in waste management, conditions and procedure for permits, 

defines principles for managing specific waste streams, sets a legal basis 

for regulation of waste incineration, supervision and other issues of importance 

to waste management. 

22 Institut Alternativ, op. cit. 


24 "Official Gazette of RM" No. 80/05 and "Official Gazette of Montenegro", No. 73/08 and No. 

40/2011-1 

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34 

For the local self-government this Laws is important from the aspect that its 

provides guidelines for the development of Local Waste Management Plans, in 

accordance with Waste Management Plan in Montenegro for 2008-2012, the 

Strategic Master Plan for Waste Management and Waste Management Plan in 

Montenegro for 2008-2012. In this aspect, several articles of the Law will be 

pointed out: 

• Article 17 – prescribes development and adoption of local plans, and provides 

basic content concept of the Local Plan 

• Article 20 – defines the implementation of waste management plan 

• Article 21 – determines the joint management of waste between several 

municipalities 

• Article 22 – states that: “The waste producer is obliged to prepare a waste 

management plan, if it produces annually more than 200 kg of hazardous 

waste or more than 40 tons of non-hazardous waste. Local selfgovernments 

may oblige the waste producer to provide information about 

the waste produced and its waste management methods, if it produces annually 

more than 10 tons of non-hazardous waste.” 

• Article 65 – governs the obligations of the landfill operator, which include: 

- identify waste quantity before acceptance to the landfill site 

- check waste being accepted against the information contained in the 

presented waste transfer note for match 

- deny acceptance of the waste in case of identified discrepancy between 

the waste being accepted and the information contained in the 

presented waste transfer note and immediately inform the competent 

authority of the state administration (environmental inspectorate) 

- provide selective waste disposal in order to prevent reaction of chemical 

elements of different types of waste and adverse effect on the environment 

and provide conditions for its further use and re-cultivation 

and rehabilitation of the landfill site area 

- provide proper functioning of the technical equipment operated at the 

landfill site and apply sanitary, hygienic, fire protection and health 

and safety at work regulations, in conformity with the law 

- inform the permit issuing authority (Ministry of Sustainable Development 

and Tourism) on the landfill closure and top cover 

- supervise the landfill site before and after the cessation of operations 

and provide a competent authority with the report on operating results 

for the calendar year by the end of first quarter of the next year 

- immediately inform the competent authority of the state administration 

(environmental inspectorate) on identified changes, indicating 

possible occurrences or presence of environmental risk. 

• Article 66a – addresses the issue of funds for landfill closure, as follows: 

- A waste producer shall pay all costs incurred by the disposal of waste 

at the landfill. 

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35 

- The charge rate referred to in paragraph 1 of this Article shall be defined 

by the Government. 

- Funds for the costs related to maintenance and control after the landfill 

closure shall be defined in the permit for waste disposal issued for 

the period which cannot be shorter than 30 years. 

- Fund sources and amount for the costs referred to in paragraph 3 of 

this Article shall be provided by the local self-government units that 

use the landfill. 

This Law does not apply to the following wastes: radioactive waste; military 

waste; waste water discharged into surface water and sewage systems, except 

liquid waste; waste from slaughter houses, animal faeces, solid and liquid fertilizer 

and animal urine and other harmful substances of animal origin, substances 

that are used for cooling (liquid), soil and rock materials that are displaced in 

on-going investment projects, research or exploitation, processing and utilization 

of mineral resources, land clearing caused by cleaning of the seabed in 

order to maintain access to ports, cleaning the water reservoir of fish ponds, 

natural waterways or ditches with the aim of maintaining and regulating water. 

Several bylaws to the Law on Waste Management have also been promulgated. 

These are presented in the Annex. 

4.4.13 Law on Communal Services 

The new Draft Law on Communal Services 25 defines communal services, principles, 

conditions and methods of communal services, communal equipping of 

the construction land and other issues important for communal activities. 

Communal services within the Draft Law on Communal Services are the activities 

of public interest. 

Communal service, under this Law, is the provision of services and delivery of 

products, which are an indispensable condition for life and work of citizens, 

companies and other entities in the area of local government and maintenance 

of communal infrastructure, equipment and resources to perform these activities. 

Communal services, under this law are, including those related to solid waste 

management, such as municipal waste management and planning and maintenance 

of public areas. 

25 Official Gazette of GoM, no. 48/08 – draft amendments to the law are prepared and are in the Parliament 

for adoption 

.


36 



4.4.14 Law on Business Organization and its amendments 

The last amendment of the Law on Business Organization, 26 which came into 

force in early August 2011, introduced several organizational novelties: 

• Within six months, the Central Register of business organizations shall be 

established in Podgorica ("CRPS") and be managed by the Tax Authority. 

This Central Register will replace the existing one in the Commercial 

Court in Podgorica. A Registration application can be also submitted in 

branch offices of the Central Register. 

• By registering the company with CRPS, a tax identification number is assigned 

and at the request of the applicant a VAT registration number can 

be granted, as well as excise tax number. 

• Establishment of a company is now fully linked only with one Government 

body. 

• Government body in charge of registration of business needs to decide on 

refusal of application within four working days, whereas if this type of decision 

is not made, it is considered that a company is registered. 

• The new Law encompasses the provision withdrawing the mandatory use 

of stamps for the companies for their daily business operation. 

• So far, the obligation of companies to submit annual financial reports to 

CRPS is abolished. 

• The level of transparency on business restructuring is increased, as well as 

of and information provision to shareholders. The business is now required 

to publish in their website a notice convening the shareholders' assembly 

meeting. Upon a request of shareholders, business must sent notifications 

and materials via e-mail to shareholder, and the participation on the shareholder 

assembly meeting via e-mail is granted. 

• It is more precisely defined the provision of regulating acquisition of individual 

shares. 

4.5 Institutional set-up at local level 

The following section presents the institutional set-up at the local level with 

respect to solid waste management. 

Responsibilities 

4.5.1 Role of local self-government in solid waste management 

Montenegro has 21 local self-governments (divided into the capital city of 

Podgorica, the historic capital city of Cetinje, and 19 municipalities). Local 

self-governments have the responsibility to: 

• enforce legislation and regulations adopted by the State 

• ensure financial resources for their work and activities 

• adopt short-term and long-term programmes of activities and provide funding 

for their implementation 

26 Latest amendment: Official Gazette of Montenegro, no. 36/11. Previous amendments: Official Gazette 

No. 06/02 from 08.02.2002, 17/07 from 31.12.2007, 80/08 from 26.12.2008, 40/10 from 22 July 

2010, 36/11 from 27 July 2011. 

.




37 

• determine prices of communal services 

• perform inspection tasks 

• collect taxes and impose fines 

• issue permits for the collection and treatment of waste at the local level. 

Solid waste 

management 

In the area of solid waste management, local self-governments have the responsibility 

to develop and implement solid waste management policy at the local 

level for each municipality individually or as joint waste management between 

system two or more municipalities. Their activities are reflected in: 

• Preparation and adoption of waste management programmes and plans for 

waste management in their territory (local waste management plans) 

• Joint programmes between two or more municipalities 

• Assessment of waste generation and plan for collection and transport 

• Preparation and implementation of waste treatment plan 

• Preparation of waste disposal plan 

• Waste generation reduction plan 

• Strengthening the capacity of public utility companies 

• Regulating the PUC‟s and private companies‟ work in the field of collection, 

transport and waste disposal 

• Advancing the permit system. 

According to the Republic-Level Solid Waste Strategic Master Plan, waste 

management requires a complete specialization, high level of knowledge and 

awareness in this area. It involves a high cost of facilities and equipment maintenance, 

major investments in modern technological solutions and high operating 

costs. Taking into account the unfavourable economic situation in the past 

two decades in the country, the optimal solution for Montenegrin municipalities 

in the area of solid waste management in accordance with European Union directives 

has been seen in building inter-municipal landfills with recycling centres 

and in establishing inter-municipal companies to manage such landfills and 

consider the interests of citizens. 


4.5.2 Role of Public Utility Companies 

At the local level in municipalities, the collection, transport, and disposal of 

solid waste are organized within Public Utility Companies (PUC), which are 

fully owned by municipalities. Pursuant to the Law on Communal Services 

(Official Gazette of GoM, no. 48/08 27 ), the organization of communal services 

on the local level is the responsibility of the local self-government. These 

services are usually just one aspect of the scope of communal services the PUC 

public utility provides. The local self-government may also assign these tasks 

to another company. 

As defined under the Law on Communal Services, communal services include: 

27 At the time of writing this report, the draft amendments to the law have been prepared and are in 

Parliament for adoption. 

.




38 

• maintenance of sanitation (cleaning public spaces, solid waste collection, 

stormwater sewer systems, etc.) in towns and other settlements 

• construction, maintenance and use of landfill 

• maintenance of parks, public green space and recreational areas 

• water supply 

• collection, treatment and disposal of wastewater 

• supply of heat 

• public transport in towns and other settlements 

• maintenance of streets, roads and other public spaces in towns and other 

settlements and public lighting, as well as construction, maintenance and 

use of local roads 

• construction, maintenance and use of bridges, public buildings and the 

maintenance and regulation of riverbeds 

• maintenance of cemeteries and burials 

• chimney services, maintenance of public toilets, maintenance of public 

bathrooms, dog pound, public parking space, maintenance of market and 

their services. 

Typically, a PUC provides several of these services. 

4.5.3 Inter-municipal waste management companies 

There are recent examples of establishment of inter-municipal waste management 

companies in Montenegro: 

• Municipality of Podgorica has established the company “Deponija” d.o.o. 

(Ltd.) to manage the newly constructed sanitary landfill in Podgorica for 

use by the Municipalities of Danilovgrad and Cetinje (through their PUCs) 

under the same conditions as the PUC “Ĉistoća” from Podgorica. 

• The Municipalities of Bar and Ulcinj established the company "Mozura" 

d.o.o on 4 November 2008 to manage their regional landfill. 

• The Municipalities of Nikšić, Pluţine and Šavnik established the company 

"Budoš" d.o.o on 5 March 2009 to manage their regional landfill. 

Another earlier example of an inter-municipal waste management company is 

"Lovanja" d.o.o., which was established to manage the landfill constructed in 

2004 for the disposal of waste collected from the Municipalities of Budva, Kotor 

and Tivat. This landfill was open for use until 2007, when those three municipalities 

were obliged to find and make an agreement on the permanent location 

for their regional sanitary landfill. After the unsuccessful process of determining 

a location for the permanent regional landfill for these municipalities, 

on 27 December 2007, the Government of Montenegro passed a Decision for 

concluding the issue of construction, maintenance and utilization of the regional 

sanitary landfill for the Municipalities of Budva, Kotor and Tivat as matter 

of public interest and effectively taking over the process. This Decision instructed 

the company "Lovanja" d.o.o to coordinate the construction, management 

and maintenance of a new joint landfill for these three municipalities. 

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39 

4.5.4 Private sector participation in waste management 

According to the Law on Communal 28 the collection, transport and disposal of 

municipal solid waste, may be performed by private companies as well as public 

companies. According to the Law, the involvement of the private sector in 

carrying out these tasks should be based on: 

• transparency of the process of delegating these tasks 

• relevant technical and organizational capacities of companies or entrepreneurs 

• regulating effective partnership arrangements 

• signing appropriate agreements with the private partner on the basis of 

clearly defined relations, monitoring and control. 

The legal conditions for private sector participation in solid waste management 

are aimed at introducing market principles in performing the tasks of collection, 

transport and disposal of municipal solid waste, allowing the promotion of 

competition between public and private sectors. The intent is to foster effective 

and efficient waste management systems at the local level. 

4.5.5 Regulator of communal services 

Each municipality has a PUC that deals, among others, with solid waste management. 

The regulator of communal services at the local level is the municipality 

(local self-government) in accordance higher level legislation 29 . This includes 

the definition of the service area, the definition of service standards, and 

the approval of tariffs (fees) for services provided. On the other hand, the relationship 

between the local self-government and the PUC is governed under the 

Decision of the local assembly on the establishment and organisation of the 

work of the PUC. This decision is based on the Law on Communal Services 

and Law on Companies 30 and in turn forms the basis of the statute of the PUC. 

Performance-based contracts (or public service agreements, service level 

agreements, etc.) are not applied in the field of solid waste management in 

Montenegro. 

4.6 Development needs 

There are several areas of development needs for the solid waste management 

sector, as listed below: 

• Continued harmonisation of laws – in particular the “Law on waste” with 

the Directive on Waste 2008/98/EC is needed, in particular with respect to 

the hierarchy of waste, extended producer responsibility, preparation for 

28 Official Gazette of GoM, no. 48/08 

29 For example, the municipality cannot approve a location for a local or regional landfill; this falls 

under the competence of the national government. The Spatial Plan of Montenegro applies in the case 

of the landfill location. 

30 For example, the Decision on the establishment of the Niksic PUC refers to the Law on Companies, 

Official Gazette of the Social Republic of Montenegro no. 40/89 and the Law on Communal Services, 

Official Gazette of the Social Republic of Montenegro no. 7/90. 

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40 

reuse, recycling, biodegradable waste, content of local waste management 

plans, prevention of waste generation, etc. 

• Local capacity for planning and management of waste collection and landfills 

– there remains one regional landfill in the country and experience in 

landfill management is limited. Capacity development programmes for local 

governments, PUCs, regional landfill companies, etc. are needed. 

• Support to local governments and PUCs in the calculation of tariffs for 

solid waste collection and disposal. 

• Financial support to municipalities in the construction of regional landfills, 

as well as support in implementing cost covering tariffs for solid waste collection 

and treatment services. Financial support for care of landfills after 

their closure should also considered since according to the Law on waste 

management, this is the responsibility of the local government (and not the 

landfill operator, as in the Landfill Directive). 

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41 

5 Waste Generation in Nikšić Area 

This chapter discusses factors affecting the amount of solid waste generated in 

the area to be covered by the regional landfill in Nikšić since the Feasibility 

Study. Further, based on existing studies, it provides a review of forecasts of 

waste generation in the area for the lifetime of the landfill. 

Macroeconomic 

indicators 

5.1 Review of national economic development 

parameters 

The basic macroeconomic indicators for 2011 for Montenegro are presented in 

the following table 31 . 

Table 2 Economic indicators of Montenegro, 2012 

Feb 2012 

GDP in current prices, in million EUR 3,394 

GDP real growth rate, in % (2011) 2.5 

Inflation, in % 2.7 

Employment growth, in % 1.9 

Unemployment rate, in % 11.9 32 

Current account balance of payments, in GDP% -19.3 

Total government debt, in million EUR 1,473.2 33 

Total government debt, as % GDP 43.4 

Net foreign direct investments, as % GDP 17.3 

Public spending, as % of GDP 20.8 

Growth in household consumption, % 2.1 

Source: Ministry of Finance of the Republic of Montenegro 

31 Economic and Fiscal Program of Montenegro 2010-2013 from January 2011; Feb 2012 (Monthly 

Macroeconomic Indicators, Ministry of Finance (MoF) of Montenegro 

32 Data from Feb 2012 (Monthly Macroeconomic Indicators, MoF); According to IMF Labour force 

definition, the unemployment rate was 20% (Preliminary conclusions of the Mission of the International 

Monetary Fund, March 5, 2012). 

33 Ministry of Finance, Statement: Data on Government Debt and Issued Guarantees, as of 31 January 

2012. As of 31 January 2012, the government debt of Montenegro was 1,473.2 million euro or 43.4% 

of GDP. Internal debt was 419 million euro or 12.3% of GDP, while the foreign debt was 1,054.2 

million euro or 31.0% of GDP. 

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42 

The basic economic indicators cited in the foregoing table point to a fairly 

healthy economy, with a positive GDP growth rate, continued declines in unemployment, 

but which increasing debt as a percentage of GDP. Consumer 

spending continues to increase. 

In summary, the main development problems that Montenegrin municipalities 

currently face are: high levels of unemployment, underdeveloped infrastructure, 

low household income, low local government revenues, ageing population, low 

population density, and lack of capacity of local governments for strategic 

planning. 

5.2 Review of forecasts for waste generation 

One of the most important planning instruments for the sustainable and longterm 

implementation of waste management system is a sound database regarding 

current waste generation and qualities. 

The data and information compiled were mainly from information holders out 

of the 21 Montenegrin municipalities in the period November 2003 - February 

2004 on waste related issues supported by available statistical data and own 

assumptions of the corresponding consultants. 

Planning perspective 

On the basis of the Strategic Master Plan (2004) the perspective is based on the 

following assumptions: 

• The estimated demographic growths for the municipalities based on the 

relevant regions are given below: 

- Central Region – projected population growth is +0.81% for Nikšić 

- Mountain Region – projected population growth is -0.68% for Pluţine 

and Šavnik 

• Waste generation, as was divided into regions, is as follows: 

- Central Region - 0.80 kg/cap/day for Nikšić 

- Mountain Region - 0.60 kg/cap/day for Pluţine and Šavnik 

- Tourists - 1.5 kg/cap/day per overnight stay 

- Refugees - 0.25 kg/cap/day 

• Extension of the service area for collections in the short-term (from 2005 

to 2009): 

- in urban areas, stepwise increase in the service area from 85% to 92% 

of total area 

- in rural areas (population over 190 inhabitants), stepwise increase 

from 15% to 27%. 

• Extension of the service area for collections for the medium-term (from 

2010 to 2014): 

- in urban areas, stepwise increase of the service area from 93.3% to 

100% of the total area 

.




43 

- in rural areas (population over 190 inhabitants) stepwise increase in 

the service area from 48.3 % to 75%. 

• Increase in source separation of several recyclable fractions in accordance 

with the Master Plan. 

The Feasibility Study for Nikšić Regional Solid Waste Landfill was prepared in 

2008 according to the Republic-Level Solid Waste Strategic Master Plan in 

Montenegro and used same the criteria. 

Baseline data 

The baseline data for preparation of the Feasibility Study were the amount of 

solid waste produced in the municipalities of Nikšić, Pluţine and Šavnik since 

2004. Accordingly, the calculated amount of solid waste is about 15,800 tons 

per year, distributed as follows: 

Table 3 Population and waste generation of the Nikšić catchment area, 2004 

Municipalities 

Census 

2003 

Municipal Solid Waste 

Generated Recycled 

Disposed 

Share recycled 

and disposed 

person [t/a] [t/a] [t/a] [%] 

Nikšić 75,274 22,334 0 15,251 68 

Plužine 4,270 951 0 349 37 

Šavnik 2,938 645 0 161 25 

Total 82,482 23,930 0 15,761 66 

Source: Republic-Level Solid Waste Strategic Master Plan of Montenegro, 2005 

Given the time that had passed between the preparation of the Master Plan and 

the Feasibility Study, the latter undertook a verification of data on the quantity 

of waste set out in the Master Plan, as follows: 

• In the years since the approval of the Strategic Master Plan, the total 

amount of municipal waste in the Municipality of Nikšić increased from 

about 22,334 tons in 2004 to a projected 23,893 tons in 2009. This is 

caused by population growth of 0.81% (increase in waste producers) and 

gross domestic product (GDP) increase of 2.5%. According to the Feasibility 

Study, these factors resulted in an overall increase in waste generation 

over the period 2004-2009 by about 5%. 

• According to the Feasibility Study, for Pluţine the total amount of waste 

generated changed slightly from about 951 tons in 2004 to a projected 

944 tons in 2009. This was due to a population decline of -0.68% (fewer 

waste producers) that was not compensated by the GDP growth of 2.5%. 

These factors caused a slight decrease in waste generation during the period 

2004-2009. 

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44 

• According to the Feasibility Study, Šavnik was in the same situation as 

Pluţine, with the generated waste changing slightly from about 645 tons 

in 2004 to about 642 tons in 2009. 

Table 4 

Generated amounts (t/year) of municipal waste for Nikšić, Plužine and 

Šavnik, from 2004 to 2009 

2004 2005 2006 2007 2008 2009 Total 

Nikšić 22,334 22,636 22,942 23,254 23,571 23,893 138,630 

Plužine 951 950 949 947 946 944 5687 

Šavnik 645 644 644 643 642 642 3860 

Total 23,930 24,230 24,535 24,844 25,159 25,479 148,177 

Source: Feasibility Study for Nikšić Solid Waste Landfill, 2008 

Waste generation 

As evident from the preceding data, the overall increase in waste generated in 

the Nikšić for the period 2004-2009 was expected to be 1,559 tons, equivalent 

to 260 t/year. In Pluţine, as well as in Šavnik, less waste was generated in 2009 

than in 2004. This is in accordance with the data on decreased population. 

Next, the Feasibility Study included waste generation forecasts for the period of 

2010-2029. The overall summary of waste generation, as well as disposal and 

recycling forecasts over the twenty year design period of 2010-2029 is presented 

in the following tables. 

Table 5 Total amount of waste in Nikšić, Plužine and Šavnik, in tons, 2010-2029 

Nikšić Plužine Šavnik Total 

2010–2014 

Disposed 89,168 2,388 1,379 92,935 

Recycled 16,389 540 343 17,272 

Uncollected 18,926 1,780 1,472 22,178 

Generated 124,483 4,708 3,194 132,385 

2015–2019 

Disposed 90,122 2,321 1,408 93,852 

Recycled 31,301 1,054 681 33,036 

Uncollected 11,584 1,229 1,036 13,849 

Generated 133,007 4,605 3,125 140,737 

2020–2029 

Disposed 163,124 3,692 2,269 169,086 

Recycled 114,212 3,415 2,277 119,905 

Uncollected 15,899 1,687 1,422 19,008 

Generated 293,235 8,795 5,968 307,998 


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45 

Table 6 Total amount of waste generated, in tons, 2010-2029 

Disposed Recycled Uncollected Generated 

2010-2014 92,935 17,272 22,178 132,385 

2015-2019 93,852 33,036 13,849 140,737 

2020-2029 169,086 119,905 19,008 307,998 

2010-2029 355,873 170,213 55,034 581,120 


Table 7 Total amount of waste generated, disposed and recycled from 2010 to 2029 

Disposed Recycled Uncollected Generated 

Nikšić 342,415 161,902 46,408 550,725 

Plužine 8,402 5,010 4,696 18,108 

Šavnik 5,056 3,301 3,930 12,287 

Total 355,873 170,213 55,034 581,120 


Feasibility Study 

As can be seen in the foregoing tables, to forecast the amount of waste, the 

Master Plan and Feasibility Study were based on the 2003 census and the estimated 

demographic growth for each of the three municipalities. 

According to the Feasibility Study the proposed landfill will have area of about 

23,000 m², or 2.3 hectares. As calculated, the waste generated in the period of 

2009-2029 is expected to be 355,873 tons. With an anticipated volume of 

290,653 m³ of waste and a calculated maximum landfill capacity of 30.000 m³, 

the lifetime of the landfill was estimated to be approximately 15 years. On the 

other hand, the updated main design, which is currently under a review/approval 

process, anticipates a landfill lifetime of 20 years. This is now the assumption 

under which the Municipality of Nikšić should operate. 

Demography The Feasibility Study presents estimates on population growth for the 2008- 

2029 period in accordance with the requirements of the project and using the 

assumptions outlined in the Master Plan. This is summarized in Table 8. 

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46 

Table 8 Population of Nikšić, Plužine and Šavnik, 2007-2029 

2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 

Nikšić 75,274 75,884 76,498 77,118 77,743 78,372 79,007 79,647 80,292 80,943 81,598 82,259 

Plužine 4,272 4,243 4,214 4,185 4,157 4,129 4,101 4,073 4,045 4,018 3,990 3,963 

Šavnik 2,972 2,952 2,932 2,912 2,892 2,872 2,853 2,833 2,814 2,795 2,776 2,757 

Total Population 82,518 83,078 83,644 84,215 84,792 85,373 85,961 86,553 87,151 87,755 88,365 88,979 

2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 

Nikšić 82,926 83,597 84,274 84,957 85,645 86,339 87,038 87,743 88,454 89,170 89,893 

Plužine 3,936 3,909 3,883 3,856 3,830 3,804 3,778 3,753 3,727 3,702 3,677 

Šavnik 2,738 2,720 2,701 2,683 2,665 2,647 2,629 2,611 2,593 2,575 2,558 

Total Population 89,600 90,226 90,858 91,496 92,140 92,790 93,445 94,106 94,774 95,447 96,127 


The 2011 Census, however, reveals different a population growth trend, as 

shown in the following table. 

Table 9 

Municipality 

Population by municipality and settlement type 

Population of 

Municipality 

Census 2003 Census 2011 

Urban 

area 

Rural 

area 

Population of 

Municipality 

Urban 

area 

Rural 

area 

Montenegro 620,145 620,029 

Nikšić 75,274 58,358 16,916 72,443 59,670 12,773 

Plužine 4,270 1,494 2,776 3,246 1,341 1,905 

Šavnik 2,938 568 2,370 2,070 472 1,598 

Total 82,482 60,420 22,062 77,759 61,483 16,276 

Source: Republic Level Solid Waste Strategic Master Plan of Montenegro, 2005 and Census 

of the Republic of Montenegro, 2011 

Clearly, the population in the Nikšić Service Area has decreased by 4,723 between 

the two censuses. A migration of the population from rural to urban areas 

is also evident; while the population data reveal a decrease in the population of 

the Municipality of Nikšić by 2,831, the population of the urban area of Nikšić 

increased by 1,312. The population of the Municipality of Pluţine fell by 1,024 

and in its urban area by 153. In the Municipality of Šavnik, these figures fell by 

868 and 96, respectively. Compared to the estimates from the Feasibility Study 

(84,972 for 2011), on the other hand, the population from the 2011 Census was 

less 7,213. 

Assumptions 

A new, rough calculation of waste generation in accordance with the new 

statistical data and based on the following assumptions can be made: 

• Total population in 2011 is 77,759 (2011 Census) 

• Waste generation in 2011 is 22,000 t/year 

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47 

• In accordance with "The demographic trends in Montenegro since the 

mid-20th century and prospects to 2050" (MONSTAT 2008), the population 

in Montenegro in 2050 would be higher than for the starting year 

2005. The results of the projection confirm that the process of depopulation, 

which in the northern region will probably continue at least until 

2015. For this reason, waste generation of 22,000 t/year over the period 

2013-2017 may be expected. 

• Percentage of recycled and uncollected waste will be 30% over the period 

2013-2017 (recycled 13%, uncollected 17%). 

• Increase in waste generation for the region over the period 2018-2022 

will be about 6% due to the estimated demographic growth of +0.81% 

(increase in waste producers) and GDP of +2.5%. 



• Increase in waste generation for the region over the period 2018-2022 

will be about 8%. 



Table 10 Waste generation forecast, 2013-2030 

Period Generated Recycled Uncollected Disposed 

2013-2017 113,525 14,758 19,300 79,467 

2018-2022 120,336 27,677 12,034 80,625 

2023-2030 207,936 79,015 14,557 114,364 

2013-2030 441,797 121,450 45,891 274,456 

Source: Consultant's assessment based on changing population growth data 

Landfill volume 

According to the foregoing table, solid waste in the amount of 274,456 tons 

will be disposed at the landfill over the period 2013-2030. Since the assumed 

density of compacted waste is 950 kg/m³, a landfill volume of 288,179 m³ net is 

needed for the waste. 

Assuming that 16% of inert material is necessary for covering, the value of total 

volume is 334.287 m³. 

Taking into account the value of available landfill volume of 330.000 m³ and 

the expected amount of generated waste for the following period, it can be concluded 

that based on current parameters that the landfill can be designed for the 

period of 18 years. 

The Nikšić PUC, in its services for the collection and disposal of waste, submitted 

information about collection of more than 40,000 tons waste per year. This 

assumption is based on the volume of solid waste transport trucks and the number 

of trips to the current dump; it is not based on measurements from a waste 

scale. The PUC also confirms that this amount includes waste from illegal 

dumps, construction and demolition waste, green waste and communal waste 

without any selection and recycling. The PUC concurs with the Consultant‟s 

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48 

rough calculation on the condition that the future landfill dispose only communal 

solid waste and not that intended for recycling, composting, etc. 

From the foregoing discussion, it is evident that the waste stream generated in 

the Nikšić Service Area is likely to decline mainly due to a decline in population. 

Legislative changes, in particular affecting packing waste, waste to be 

composted, and demolition waste, will serve to reduce the amount of waste deposited 

at the future regional landfill, thereby extending its assumed useful lifetime. 

This conclusion should be checked with the main design of the landfill, 

when it becomes available, and is addressed in the report for Activity 3. 

Overall, harmonisation with the Directive on Waste (2008/98/EC) will require 

that priority is given to the prevention of waste generation, preparation for reuse 

of waste and recycling of waste. The last option is to be disposal of waste. 

Recycling should also be gradually increased – up to 60% of dry fractions of 

municipal waste (paper, glass, metal and plastic) and 50 % of bio-waste (biodegradable 

kitchen waste and plant waste). Meeting these objectives would 

likely enable the Nikšić regional landfill to have a useful lifetime of a period of 

20 years or more. 

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49 

6 Case Study Nikšić 

The following case study provides an overview of the institutional setting in the 

area that will be serviced by the Nikšić regional landfill. The case study will be 

expanded in the report for Activity 3 (Procurement Options Report). 

6.1 Nikšić 

6.1.1 Basic information - Nikšić 

Nikšić is located in the karst area of north-west of Montenegro. It is the second 

largest city in Montenegro, representing a major link point between the coast 

and north of the country. It is one of largest industrial centres of Montenegro, 

with a steel mill (Nikšićka Ţeljezara), bauxite mine, Trebjesa brewery 

(Nikšićka Pivara), and other businesses, such as MONTAVAR Metalac, Meat 

Industry Goranović, Nika and Srna dairy, MIRAI Javorak, hydropower complex 

of Upper Zeta, and HTPO nogošt, etc. 

Demography 

By the last Census of the Population, Households and Dwellings of 

Montenegro in 2011 34 , the Municipality Nikšić, together with its suburbs has 

population of 72,443 (11.68 % of the entire population of Montenegro). 

Table 11 

Key data on Nikšić 

Category Year Value Source 

Population 2011 72,443 Census 

Change in population 2003 – 2011 75,282 (2003) -4% Census 

Municipal budget expenditures 2010 EUR 15.8 m Financial report 

Municipal budget expenditures per capita 2010 EUR 219 Financial report / Census 2011 

No of local government employees 2010 /2011 574/435 

Recently employed 2011 13 (trial employees) - 

Leaving employees/retiring 2011 

32 (retiring) + 107 (end of contract by mutual 

understanding) (municipality only 35 ) 

Ministry of Internal Affairs Report / 

Office of Municipality Manager 

Office of Municipality Manager 

Training budget 2010 EUR 2,333 Financial report 

34 MONSTAT 

35 That is, does not include total employment at the local self-government, such as at PUC. 

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50 

6.1.2 Local government 

In accordance with the Law on Local Self-Government 36 , the functional structure 

of local government of Nikšić is established. The internal organization of 

the Nikšić local government is based on the principles of: lawful and timely 

performance of tasks; application of IT in work methods; grouping of related 

and interconnected operations; and providing full control and responsibility in 

performing the work. In the process of government rationalization, required in 

the accession process to the EU, the number of employees in the Municipality 

Nikšić has decreased from 574 in March 2010 to 435 in 2011 37 . 

Organization 

For the efficient operation of the Nikšić local government, in accordance with 

the Law, the statute of the municipality and other regulations, bodies and local 

government services have been established. The secretariat, directorates, agencies 

and bureaus have been established as bodies of the Municipality. 

ORGANISATION OF THE LOCAL SELF-GOVERNMENT 

PRESIDENT OF THE MUNICIPALITY 

MAIN ADMINISTRATOR 

BODIES OF LOCAL SELF-GOVERNMENT 

SPEICIAL ORGANS 

Communal police 

SERVICE ORGANS 

President Office 

SECRETARIATS Bureau DIRECTORATES 

Protection and rescue service 

Center for information systems 

Main Administrator Office 

Main Manager Office 

Secretariat for local selfgovernment 

Bureau for local 

public revenues 

Directorate for 

property 

Service for internal audit 

Office for common tasks 

Secretariat for finances, 

development and business 

Secretariat for urban planning 

and environmental protection 

Secretariat for communal 

services and transport 

Secretariat for culture, sport, 

young people and social affairs 

Figure 2 

Source: Municipality of Nikšić 

Organisational chart of the Municipality of Nikšić 

6.1.3 Nikšić Public Utility Company 

Nikšić PUC was established on 9 May 1990 38 . The obligation and activities of 

the PUC are: collection, removal and disposal of communal waste, cleaning 

36 Official Gazette of GoM No. 42/03, 28/04, 75/05, 13/06 (88/2009, 3/2010). 

37 The Strategy of Public Administration Reform for 2010-2015, aimed at functional and fiscal decentralization, 

as well as at providing direct financial and material resources to local governments for 

their operation, foresees more cost-effective and optimal functioning of local government, in particular 

in terms of personnel. 

38 Previously, it operated as part of the Work organization for communal services of Nikšić. 

.




51 

streets, sidewalks, squares, green and other public areas, landscaping of public 

areas, cleaning of urban, suburban and local roads of snow and ice of the market 

services and market activity, funeral services and burial activity. 

Nikšić PUC calculates and recommends to the local government for adoption 

fees for collection of solid waste. 

Table 12 

Basic data on Nikšić PUC 


No of employees 2012 

Employees dealing with waste 2012 

191 in total 

165 permanent 

26 contracted for specific period 

49 in total 

31 permanent 

18 contracted for specific period 

PUC Nikšić 

PUC Nikšić 

Share of PUC revenues from 

waste management services 

2012 61.81% PUC Nikšić 

Amount of waste collection/annual 

2011 

42,000 tonnes annually 

3,500 tonnes/month 

PUC Nikšić 

Fee for waste collection 2012 

Number of invoices issued 2012 

0.071 EUR/ m 2 (with VAT) city households 

0.060 EUR/ m 2 (with VAT) suburb households 

0.004 – 0.321 EUR/ m 2 (with VAT) legal entities (public 

and private) 

59,815 EUR/monthly – households 

34,807 EUR/monthly – legal entities 

PUC Nikšić 

PUC Nikšić 

Capacity Capacity of the PUC Nikšić is as follows 39 : 

• Numbers of users of municipal services are 1,014 corporate and 14,393 

households. The daily amount of waste disposed: 350 - 400 m 3 , or approximately 

120 tons. 

• Number of containers: 

- 400 pieces of 1.1 m 3 and 

- 70 pieces of 5 m 3 . 

• Number of available vehicles for the transport of waste: 

- 5 loaders for the removal of 5 m 3 containers (year of production: 1984, 

1986, 1987, 1990 and 1993) 

- 6 trucks for emptying 1.1 m 3 containers (two-1985, two-1990 and two 

2004) 

- One cleaner (year of production: 1985) 

39 According to the information received from PUC Niksic. 

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52 

• Organizational structure: technical sector, economic-financial sector, and 

legal, human resources and general affairs sector. 


plan 

The Municipality of Nikšić developed and adopted a local waste management 

plan for 2009-2014 in 2009, in accordance with National Waste Management 

Policy and the Strategic Master Plan for Waste Management and defining medium-term 

objectives and conditions for the rational and sustainable management 

of waste in the municipality of Nikšić. 

6.2 Plužine 

6.2.1 Basic information - Plužine 

The Municipality of Pluţine is one of the youngest towns in Balkans, due to the 

fact that today‟s town of Pluţine was built in late 1970s at the banks of Piva 

Lake, since the previous location at a much lower altitude was flooded after 

building of the Hydropower plant Piva. The main economic actors in the Municipality 

are: Hydropower Plant Piva, Plant for production of Electrodes, 

Wood processing in Brezna, Montenegro Forestry-organizational unit Pluţine, 

agriculture and trade. 

Table 13 

Key data on Plužine 


Population 2011 3.246 MONSTAT 

Change in population 2003 – 2011 -24% MONSTAT 

Municipality expenditures 2010. EUR 3.2 m Financial report 

Municipality expenditures by per person 2010 EUR 997 (2/21) Financial report / Census 2011. 

No of employees /local government 2010 34 Ministry of Internal Affairs report 

Surplus/Deficit Ministry of Internal Affairs report ) 2010 10 Ministry of Internal Affairs report 

Recently employed (last year) 2011 0 - 

Leaving employees/retiring 2011 9-15 - 

No of employees 2011 31 Employee register 

Training budget 2010 None - 


The following chart shows the organisational scheme of the Municipality of 

Pluţine. 

.




53 

Local 

Parliament 

President of the 

Municipality 

Main 

Administrator 

State Secretary of 

Local Parliament 

Cabinet 

Manager (1) Secretariat (1) 

Public Revenue 

Bureau (3) 

Communal 

Police (1) 

Dep. for 

Protection (1) 

Information 

centre (1) 

Public property right 

Ombudsman (2) 

Independent 

referents (6) 

Dep. For budget 

(2) 

Joint Admin. 

Bureau (6) 

Figure 3 

Organisational chart of the Municipality of Plužine 

Source: Municipality of Plužine 

6.2.3 Plužine Public Housing and Utility Company 

The Pluţine PHUC (which also deals with housing as well) has the following 

obligations and undertakes the following activities: collection, removal and 

disposal of communal waste, maintaining water and communal infrastructure, 

cleaning streets, sidewalks, squares, green and other public areas, landscaping 

of public areas, cleaning of urban, suburban and local roads of snow and ice of 

the market services and market activity, road maintenance, funeral services and 

burial activity. 

Table 14 

Basic data on Plužine PHUC 


No of employees 2012 27 in total / 22 permanent / 5 seasonal PHUC Plužine 

Employees dealing with waste 2012 5 in total PHUC Plužine 

Waste management income share activities 

compared to other PUC responsibilities 

2012 20 % PHUC Plužine 

Amount of waste collection/annual 2011 727 tons annually PHUC Plužine 


Invoices issued 2012 

0.072 EUR/ m 2 (with VAT) households 

0.022 – 0.40 EUR/ m 2 (with VAT) legal entities 

(public and private) 

6,595 EUR/month – households 

73,222.20 EUR/month – legal entities 

PHUC Plužine 

PHUC Plužine 

Capacity Capacity of the PHUC Pluţine is as follows 40 : 

• Number of users of municipal services is 415 corporate and 46 households. 

The daily amount of waste disposed: on average 80 m 3 of waste per month 

(in summer season more, in winter season less). 

40 (by the information received from PHUC Pluţine): 

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54 

• Number of containers 41 : 

- 12 pieces of containers for selective waste collection 

- Waste disposal bins of 50 litres on 10 locations 

- 60 pieces of containers of 1.1. m 3 . 

• Number of available vehicles for the transport of waste: 

- 1 compactor truck (up to 15 m 3 ) – 4 years old 

- 1 truck for carrying open containers – 3 m 3 containers (35 years old) 

- Zastava truck 50.8/ 3 tons/ - extended cabin (30 years old) 

- One cleaner (year of production: 1985). 

• Organizational structure: technical sector, economic-financial sector, and 

legal, human resources and general affairs sector. 


plan 

The Municipality of Pluţine has developed and adopted a local waste management 

plan for 2010-2014 by the end of 2008. After the implementation of several 

amendments and changes, the Ministry of Spatial Planning and Environment 

(the line ministry at that time) approved the plan in November 2010. 

6.3 Šavnik 

6.3.1 Basic information - Šavnik 

The Municipality Šavnik is one of the least developed municipalities in Montenegro. 

According to the 2011 Census of Montenegro, the Municipality of Šavnik 

had 2,070 inhabitants, representing a drastic decrease compared to 1991 

when the number of inhabitants in the municipality was 3,690. However, Šavnik 

has great natural resources and landscapes rich in biodiversity. The city has 

a good strategic position due to the proximity of regional tourism destinations 

in the north of Montenegro (Durmitor National Park, ski resorts at Savin Kuk 

and Ţabljak). The municipality also has excellent wind and hydro potential for 

power generation from hydro and wind power generation that would be used to 

service the future needs of the Municipality of energy, while the surplus could 

be sold to other municipalities and countries in the region. Good transport links 

with Šavnik, Nikšić, Kolašin, Ţabljak and Pluţine, allows easier access to citybased 

resources. 

Table 15 

Key data on Šavnik 


41 (source Pluţine Local waste management plan for 2010-2014) 

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55 

Population 2011 2.070 MONSTAT 

Change in population 2003 – 2011 -30% MONSTAT 

Municipality expenditures 2010. EUR 959.000 Financial report 

Municipality expenditures per capita 2010 EUR 219 (14/21) Financial report / Census 2011. 

No of employees /local government 2010 37 Ministry of Internal Affairs report 

Surplus/Deficit Ministry of Internal Affairs report 2010 13 Ministry of Internal Affairs report 

Recently employed (last year) 2011 - - 

Leaving employees/retiring 2011 - - 

No of employees 2011 51 Employee register 

Training budget 2010 EUR 200 - 


The organizational structure of Šavnik local government as is in the following 

table. 


President of the 

Municipality 

Main 

Administrator 

State Secretary of 


Bureau for specific administrative and 

technical tasks 

Secretariat 

Bureau for 

Protection 

Communal Police 

Figure 4 

Source: Municipality of Šavnik 

Organisational chart of the Municipality of Šavnik 

Within the new organization in the Municipality of Šavnik, the waste management 

activities are located in the newly established (in process of establishing) 

Secretariat for urban planning and communal affairs 42 . 

6.3.3 Šavnik Public Utility Company (PUC) 

The Šavnik PUC was established on 8 May 2007. The obligation and activities 

of the PUC are: collection, removal and disposal of communal waste, wastewater 

collection and treatment, maintaining water and communal infrastructure, 

cleaning streets, sidewalks, squares, green and other public areas, landscaping 

of public areas, cleaning of urban, suburban and local roads of snow and ice of 

the market services and market activity, funeral services and burial activity, and 

road maintenance. 

Table 16 

Data on Šavnik PUC 

42 (Source: information received from the Municipality Šavnik) 

.




56 


No of employees 2012 

Employees dealing with waste 2012 

Secretariat for urban planning and communal 

affairs is in process of establishment 

- 

PUC Šavnik 

PUC Šavnik 

Waste management income share activities 

compared to other PUC responsibilities 

2012 - PUC Šavnik 

Amount of annual waste collection 2011 


Invoices 2012 

- 

0.03 EUR/ m 2 (with VAT) households 

0.03 – 0.30 EUR/ m 2 (with VAT) legal entities 

(public and private) 

6,595 EUR/month – households 

73,222.20 EUR/month – legal entities 

PUC Šavnik 

PUC Šavnik 

PUC Šavnik 

The Municipality Šavnik has not developed a local waste management plan. 

6.4 Regional landfill for Nikšić, Šavnik and Plužine 

6.4.1 Current status 

The regional landfill for the municipalities of Nikšić, Šavnik and Pluţine is 

planned to be located in the municipality of Nikšić, at the locality of Budoš. 

After the Decision of the three Municipalities – Nikšić, Šavnik and Pluţine – 

jointly to manage the communal waste disposal activities, the limited liability 

Company “Budoš” was established in March 2009. In addition, amendments to 

the Spatial Plan of the Municipality of Nikšić related to landfill construction 

were approved in November 2009. Taking into account that the land at the envisaged 

construction site for sanitary landfill was private property, the instrument 

of determining the land of the public interest for the expropriation process 

was used when the local parliament of Nikšić municipality made such decision. 

The municipality of Nikšić submitted the request to Cadastral Unit for land expropriation 

in December 2009, and this request was processed. 

Feasibility Study 

A Feasibility Study for the Regional Landfill Construction project in Nikšić (to 

the level of Preliminary Design) was prepared at the end of 2008 43 . In 2009, a 

company was hired to prepare a Main Design 44 , the preparation and revision of 

which is in progress. As stipulated by the national legislation, the EIA is in the 

process of preparation through a technical assistance project 45 . Relevant data 

for completion of the EIA will be provided after finalization of the main design. 

According to the Draft Main Design, the total amount of funds required for the 

works on landfill construction is EUR 16,573,000, with expected object life- 

43 Spanish Company EPTISA, Spain 

44 IK Consulting, Belgrade 

45 The EIA is financed by the WBIF IPF and implemented by the COWI IPF Consortium 

.




57 

time of 20 years. The approximate amount, required for the construction of the 

Phase I, is EUR 9,200,000. 

6.4.2 BUDOŠ, Ltd 

For the purpose of the operation and management of the regional landfill for the 

municipalities of Nikšić, Šavnik and Pluţine, the limited liability company Budoš 

was established on 5 March 2009. Together with the Decision to establish 

joint company to service the landfill, the Statute of the Company was adopted, 

which prescribed the business of the Company in accordance with the Law on 

Business Organization 46 . Currently, the Company has one employee – the Executive 

Director – and is waiting for the construction of the landfill in order to 

expand and strengthen its capacities. 


The Company business activities are envisioned as: 

• removal of debris and waste, including the management and operation of 

sanitary landfill 

• recycling of metal waste and residue 

• recycling of non-metal waste and residue(including collecting, sorting, 

conditioning and sale) 

• technical testing and analysis of potential pollution from waste and 

measuring quality of air, water, etc. 

Capital 

The founding capital of the Company is 100,000 EUR, set as follows: 

• Municipality Nikšić: 97,000 EUR (97%) 

• Municipality Pluţine: 2,000 EUR (2%) 

• Municipality Šavnik: 1,000 EUR (1%) 

The management bodies of the Company are: the Board of Directors and the 

Executive Director. 

6.5 Sources of financing 

In terms of financing sources for the construction and operation of a regional 

landfill in Nikšić, the Government of Montenegro has made explicit in its policies 

and statements that the collection, treatment, and disposal of solid waste 

should be a self-financing service. This means that the tariffs for solid waste – 

including all the costs of collection and final destination of the solid waste 

(whether composting, landfilling, etc.) – should cover the costs of providing the 

service. In addition, solid waste tariffs are supposed to cover the costs of investments, 

for example, by including depreciation of facilities and debt service 

in the calculation of tariffs. The Government of Montenegro, however, will 

support the development of solid waste management projects by financing studies 

and capacity development, as well as by incurring loans to finance invest- 

46 Official Gazette No. 60/02 and 17/07 

.




58 

ments. The costs of debt service, however, are to be included in the calculation 

of the cost recovery tariffs. 

Landfill Directive Under Article 10 (cost of the landfill of waste) of the Landfill Directive, 47 

“Member States shall take measures to ensure that all of the costs involved in 

the setting up and operation of a landfill site, including as far as possible the 

cost of the financial security or its equivalent referred to in Article 8(a)(iv), and 

the estimated costs of the closure and after-care of the site for a period of at 

least 30 years shall be covered by the price to be charged by the operator for 

the disposal of any type of waste in that site.” 

Thus, closure and after-care costs are also part of proper cost-recovery tariffs. 

This portion of the tariff must be set aside to provide the financial security required 

under Article 8 of the Landfill Directive 48 on the conditions of the permit, 

according to which the competent authority (in Montenegro, this is the 

Ministry of Sustainable Development and Tourism) must not issue a landfill 

permit unless it has been demonstrated, among others, that: 

“adequate provisions, by way of a financial security or any other equivalent, 

on the basis of modalities to be decided by Member States, has been or will be 

made by the applicant prior to the commencement of disposal operations to 

ensure that the obligations (including after-care provisions) arising under the 

permit issued under the provisions of this Directive are discharged and that the 

closure procedures required by Article 13 are followed. This security or its 

equivalent shall be kept as long as required by maintenance and after-care operation 

of the site in accordance with Article 13(d). Member States may declare, 

at their own option, that this point does not apply to landfills for inert 

waste” Landfill Directive (1999/31/EC), Article 8(a)(iv) 

Therefore, financial security must be ensured and the cost of this included in 

the cost recovery tariffs. The financial security can be any kind of instrument, 

such as: renewable bonds, escrow accounts, cash deposits on a special fund 

designated for this purpose, etc. 

In the case of Montenegro, article 66a of the Law on Waste governs the issue of 

funds for landfill closure, as follows: 

A waste producer shall pay all costs incurred by the disposal of waste at the landfill. 

The charge rate referred to in paragraph 1 of this Article shall be defined by the 

Government. 

Funds for the costs related to maintenance and control after the landfill closure 

shall be defined in the permit for waste disposal issued for the period which cannot 

be shorter than 30 years. 

Fund sources and amount for the costs referred to in paragraph 3 of this Article 

shall be provided by the local self-government units that use the landfill. 

47 Council Directive 1999/31/EC 

48 Council Directive 1999/31/EC 

.




59 

This is not fully compliant with the Landfill Directive, according to which the 

landfill operator should secure financing for landfill after-care. 

.

Annex 1 

Main Legal Acts of PROCON 

The main legal acts of the Company PROCON are: 

• DECISION ON ESTABLISHMENT OF THE LIMITED COMPANY 

"PROJECT - CONSULTING" – PODGORICA("Official Gazette of Montenegro", 

No. 07/08 of 01.02.2008) 

• DECISION on amendments to the Decision on establishment of the Limited 

Liability Company “Project – Consulting” – Podgorica (Based on article 

71 item 1 of the Company Law (“Official Gazette of Montenegro”, No. 

06/02 and “Official Gazette of Montenegro”, No. 17/07, 80/08), from December 

2009 – the act that recognises the Company's founding capital: 

“The founding capital of the Company represents the cash contribution in 

the Company amounting EUR 80,000 (written form: eighty-thousand Euros), 

which has been deposited into the bank account of the Company.“ 

• ARTICLES OF ASSOCIATION OF THE LIMITED LIABILITY COMPANY 

“PROJECT-CONSULTING” – PODGORICA - Pursuant to Article 11(2) 

of the Company Foundation Resolution for the limited liability company 

DOO “Project - Consulting” Podgorica (“Official Gazette of the Republic 

of Montenegro”, No. 07/08 of February 1, 2008), the Board of Directors of 

the Limited Liability Company “Project-Consulting”, with the consent of 

the Government of Montenegro, from August, 2008, adopted documents 

stating that Company is “ is founded as a single-member limited liability 

company for the purpose of conducting activities of significance for Montenegro 

and local self-government“ (Article 1). 

• RULE BOOK ON ORGANISATION AND SYSTEMATISATION OF 

WORKPLACES OF THE LIMITED LIABILITY COMPANY "PROJECT 

- CONSULTING", from July 2008. This Act has been approved by the 

Government.' 

• DECISION on adoption of the Rules of Procedure for the Board of Directors 

of the Limited Liability Company “Project-Consulting” Podgorica, 

adopted by the Company Board of Directors in December, 2008. 

.

Annex 2 

Legal Acts Reviewed for Legislative 

Framework 

• Law on Environment (Official Gazette of the Republic of Montenegro No. 

80/05 and 48/08) 

• Law on Nature Protection (Official Gazette of GoM, No. 51/08, 21/09) 

• Law on IPPC (Official Gazette of GoM No. 80/05) 

• Law on EIA (Official Gazette of GoM No. 80/05) 

• Law on SEA (Official Gazette of GoM No. 80/05) 

• Law on Spatial Planning and Construction of buildings (Official Gazette of 

Montenegro No. 51/08) 

• Law on Self-Government (Official Gazette of GoM No. 42/03, 28/2004, 

75/2005, 13/2006, 88/2009, 3/2010) 

• Law on Participation of Private Companies in Public Services (Official 

Gazette GoM No. 30/02 from 26.06.2002 and No. 08/09 from 04.02.2009) 

• Law on Concession (Official Gazette of GoM No. 08/2009) 

• Law on Foreign Investment (Official Gazette of GoM, No. 52/00) 

• Law on Waste Management (Official Gazette of the Republic of Montenegro 

No. 80/05 and Official Gazette of Montenegro, No. 73/08 and No. 

40/2011-1) 

• Regulation on the Waste Classification, Processing procedures, Treatment 

and Removal (Official Gazette, GoM, No. 68/09 from 13.10.2009, 86/09 

from 25.12.2009) 

• Regulation on notification of placing packaging and packed products on 

the market, establishing take-over, collection and processing system waste 

paper and packaging, the operation of that system (Official Gazette GoM, 

09/10) 

• Decree on the method and process of registering placement on the market 

of the electrical and electronic equipment; establishment of the system for 

take-over, collection and treatment of waste electrical and electronic 

equipment and system operations (Official Gazette GoM, No. 09/10) 

• Rulebook on detailed characteristics on landfill site, construction conditions, 

sanitary-technical conditions, operating mode and closure of landfills; 

education degree and qualifications for landfill operator; and types of 

waste acceptance criteria (Official Gazette GoM, No 84/09 and 46/11 from 

16.09.2011) 

.

• Regulation on the Waste Recovery and Disposal Facilities (Official Gazette, 

GoM, No. 75/10) 

• Regulation on WTN waste records consolidated reports (Official Gazette 

GoM, No. 46/10) 

• Regulation on Handling the Construction Waste (Official Gazette GoM, 

No. 60/10) 

• Law on Communal Services (Official Gazette of GoM, br. 48/08) (draft 

amendments to the law are prepared and are in the Parliament for adoption) 

• Law on Business Organization and amendments of the Law (Official Gazette 

No. 06/02 from 08.02.2002, 17/07 from 31.12.2007, 80/08 from 

26.12.2008, 40/10 from 22 July 2010, 36/11 from 27 July 2011) 

.

Annex 3 

Secondary Legislation 

Based on the Law on Waste Management of the Government of Montenegro 

(Official Gazette of RM No. 80/05 and Official Gazette of Montenegro, No. 

73/08, 64/11), the following by-laws relevant for the current review (Activity 

2) have been adopted in the period 2008-2011: 

1 Regulation on the Waste Classification, Processing procedures, 

Treatment and Removal (Official Gazette, GoM, No. 68/09 from 

13.10.2009, 86/09 from 25.12.2009) 

This Regulation provides a waste categorization catalogue, as Annex 1 to 

the Regulation in which different types of waste are categorized and classified 

into 20 groups, depending on the type of origin. According to the 

process through which the waste originated, each group has one or more 

subgroups where the waste is classified. The Regulation, furthermore, 

clearly indicates what is defined as hazardous waste (Art 3. of the Regulation 

and Regulation Annexes). 

2 Regulation on notification of placing packaging and packed products 

on the market, establishing take-over, collection and processing system 

waste paper and packaging, the operation of that system(Official Gazette 

GoM, 09/10) 

This regulation applies to packaging which is placed on the market and 

packaging waste generated in industry, handicrafts, trade, service industries, 

households and other sectors, according to which the end user is required 

to deliver municipal waste packaging to a utility company as a separate 

fraction of municipal waste, while commercial waste packaging needs 

to be delivered to a processor of packaging waste. Separately collected 

packaging waste generated in the trade, tourism or other services sectors 

may be submitted to utility companies, provided that the legal entities and 

entrepreneurs who carry out these activities provide containers for separate 

collection of packaging. 

3 Decree on the method and process of registering placement on the 

market of the electrical and electronic equipment; establishment of the 

system for take-over, collection and treatment of waste electrical and 

electronic equipment and system operations (Official Gazette GoM, 

No. 09/10) 

This Decree applies to equipment that is not part of machinery and vehicles, 

and is not in corporate into the facilities, namely buildings, as their integral 

part. Waste equipment can be collected by a distributor, utility company 

and someone who will treat/process waste equipment. Waste equipment 

cannot be delivered to the utility companies as mixed municipal 

waste. 

4 Rulebook on detailed characteristics on landfill site, construction conditions, 

sanitary-technical conditions, operating mode and closure of 

.

landfills; education degree and qualifications for landfill operator; and 

types of waste acceptance criteria (Official Gazette GoM, No 84/09 and 

46/11 from 16.09.2011) 

This Rulebook defines in detail the characteristics of site: geological, hydrological, 

morphological, meteorological, seismological etc., construction 

conditions, sanitary-technical conditions, operating mode and closure of 

landfills, education degree and qualifications for landfill operator, as well 

as types of waste and waste acceptance criteria. Some of the Rulebook 

provisions defines: 

- Waste disposal sites shall be determined based on location and distance 

of the site from the structures, visibility of site and environmental 

integration, transport lines, transport distances and level of 

site-related infrastructure; the possibility of provision of material for 

construction of an impermeable layer, drainage and covering; and previous 

use of site area. 

- Landfill shall be constructed with a minimum distance of 300 m from 

inhabited areas and recreation areas, public parks, rehabilitation centres 

and resorts and agricultural areas intended for growing fruits and 

vegetables; With a minimum distance of 500 m from permanent rivers 

and lakes; Is above aquifers or in which water flows from cracks in 

rock mass do not fill the landfill area; Is not within Category I, Category 

II and Category III of the sanitary protection zone. 

- Landfill can be constructed at a site that is provided with a leachate 

and gas collection system, and technical solutions for treatment of 

leachate and gas to prevent pollution. 

- A landfill comprises: landfill body, landfill gas treatment system, 

leachate collection basin, leachate treatment and drainage system, external 

drainage system for collection of storm water and water resulting 

from waste truck-cleaning, waste weighing equipment, waste control 

and analysis area and temporary waste storage area. 

- Bottom and sides of landfill body shall be lined with a mineral layer 

(clay) combined with synthetic materials. 

- Surface sealing of landfill body involves placing layers in the following 

sequence: highly impermeable mineral layer (clay), impermeable 

synthetic material with a protective geo-textile layer drainage layer, 1 

m thick top soil cover (re-cultivation layer), and 0.3 m thick humus 

layer. 

- Other specific Rulebook provision and conditions for Leachate treatment, 

landfill gas, protective measures, etc. 

5 Regulation on the Waste Recovery and Disposal Facilities (Official 

Gazette, GoM, No. 75/10) 

.

In regard to equipment and staffing, the waste recovery or disposal facility 

needs to fulfil some of following conditions set out by this Regulation: 

- if the waste is not collected in the enclosed containers, canisters or 

tanks, the facility shall be equipped with a wheel-washing system for 

vehicles, and the wastewaters from wheel washing shall undergo 

treatment in accordance with relevant national regulations. 

- area for acceptance of the waste in the facility shall be equipped with 

an electronic scale to weigh the vehicle and computer equipment for 

issuing electronic receipt for the quantity (not mandatory for sites with 

capacity below 10 tons a day or below 2000 tons a year). 

- log file maintained; 

- The facility shall comprise: the area for receiving and collection of the 

accepted waste, the area for storage of the accepted waste, the area for 

pre-treatment of the waste pending recovery or disposal, the area for 

recovery or disposal, the area for storage and dispatching of residual 

waste or disposable waste, the area for storage and dispatching of the 

recovered waste, special premises for the facility operator. 

- Description of operating process of the facility contains: description of 

location and identification of risk source; Description of level of 

equipment in the facility and location with a view to pollution prevention 

and control; Description of technological process and level of 

equipment for carrying out the operating process; Description of the 

pollution prevention procedure and reporting and location-related 

documents. 

6 Regulation on WTN waste records consolidated reports (Official Gazette 

GoM, No. 46/10) 

This Regulation prescribes the format, content and manner of completion 

of the waste transfer note; format, content and manner of maintaining the 

record of quantity and types of waste - to be maintained by a waste producer, 

legal or natural person which disposes of waste due to the performing 

of operations of the waste recovery, collection and transport and by the 

local government authority responsible for municipal waste management; 

format and content of the annual report to be submitted to the local government 

authority by a waste producer, legal or natural person which disposes 

of waste due to the performing of operations of waste recovery, collection 

and transport; content and manner of maintaining the register of 

data on the waste production, waste management and issued permits; and 

format and content of the consolidated report on the waste production, 

waste management and issued permits to be submitted to the Environmental 

Protection Agency. 

In addition, the Regulation provides clear guidance on the format of the 

Waste Transfer Note (WTN) and the manner of its completion. The WTN 

.

shall contain data on consignor place of production and origin of waste 

when the consignor is the producer of waste; temporary waste storage depot 

if the consignor as a collector disposes of the temporary stored waste; 

carrier and means of transport; consignee; temporary waste storage depot if 

the consignee as a collector carries out temporary storage of waste; place 

of treatment and waste recovery procedure, when the consignee carries out 

waste recovery; type and quantity of waste in the consignment; physical 

properties and type of the packaging; place of delivery, i.e. acceptance of 

the consignment. 

The records of quantity and types of waste shall be maintained on the gridlines 

set by the Regulation, as well as the local government data register of 

waste production, waste management, etc. 

7 Regulation on Handling the Construction Waste (Official Gazette 

GoM, No. 60/10) 

This Rulebook applies to the construction waste classified under the waste 

identification code 17 in the waste catalogue (waste concrete, bricks, ceramics 

and gypsum-based construction material or mixture of construction 

material with the soil excavation). 

The Rulebook prescribes methods for storing construction waste (construction 

waste on the construction site shall be stored separately by types of 

construction waste, in accordance with the waste catalogue and separately 

from other waste, in an environmentally safe manner); disposal of the construction 

waste (disposal can be executed in containers located on the site); 

the need for construction waste management plan and its content (for a 

building, the volume of which together with the soil excavation exceeds 

2000 m 3 ); maintaining records by the investor of the type and quantity of 

the construction waste in conformity with the law; re-use of construction 

waste (can be re-used for construction works on the construction site on 

which the waste was produced if the volume of waste does not exceed 50 

m 3 ); handling the asbestos-cement waste (shall be packed in sealed bags or 

foil in order to prevent discharge of the asbestos fibres in the environment 

during loading, transport and unloading on the landfill. Asbestos-cement 

waste can be packed in textile bags, artificial substances or polyethylene 

foil being at least 0.4 mm thick, or layers of stretchable foil of total thickness 

of at least 0.6 mm). 

8 Other by-laws in the field of waste management: 

• Regulations on quality and sanitary-technical conditions for the release of 

wastewater to the public sewerage system, method and procedure of examination 

of the wastewater quality, the minimum number of tests and de- 

.

termined the contents of the report on the quality of wastewater ('Official 

Gazette of Montenegro, No. 45/08, 09/10) 49 , 

• Rules on detailed conditions to be met by municipal sludge, the amount, 

scope, frequency and methods of analysis of municipal sewage sludge to 

the permitted uses and conditions to be met by land planned for its implementation 

('Official Gazette', No. 89 / 09) 50 

• Decree on the criteria, amount and manner of special charges for waste 

management (Official Gazette, No. 11/09, 46/09 and 15/11) 51 

• Regulation on the procedure for placing packaging and packaged products 

on the market, the establishment of systems acquisitions, collection and 

processing of waste packaging and operation of the system (Official Gazette, 

No. 09/10 19/11) 52 

• Regulation on the procedure for registration of putting tires on the market, 

the establishment of systems acquisitions, collection and processing of 

waste tires and working of the system (Official Gazette, No. 09/10) 53 

• Regulation on the procedure for registration of vehicles put on the market, 

establishment of system acquisitions, and waste collection vehicles and 

operation of the system ("Official Gazette" No. 09/10) 54 

• Regulation on the procedure for registration of placing batteries and accumulators 

on the market, the establishment of systems acquisitions, collection 

and processing of used batteries and accumulators and the system (Official 

Gazette, No. 15/10) 55 

• Rules for the treatment of waste oil (Official Gazette, No. 21/10) 10) 56 

• Rules on the form, content and manner of completing the form on the 

transport of waste and registering waste, the annual report on waste, main- 

49 Pravilnik o kvalitetu i sanitarno-tehniĉkim uslovima za ispuštanje otpadnih voda u recipijent i javnu 

kanalizaciju, naĉinu i postupku ispitivanja kvaliteta otpadnih voda, minimalnom broju ispitivanja i 

sadrţaju izvještaja o utvrĊenom kvalitetu otpadnih voda (‟‟Sluţbeni list CG“, broj 45/08, 09/10) 

50 Pravilnik o bliţim uslovima koje treba da ispunjava komunalni kanalizacioni mulj, koliĉine, obim, 

uĉestalost i metode analize komunalnog kanalizacionog mulja za dozvoljene namjene i uslovima koje 

treba da ispunjava zemljište planirano za njegovu primjenu (‟‟Sluţbeni list CG‟‟, broj 89/09) 

51 Uredba o kriterijumima, visini i naĉinu plaćanja posebne naknade za upravljanje otpadom 

(‟‟Sluţbeni list CG‟‟, broj 11/09, 46/09 i 15/11) 

52 Uredba o naĉinu i postupku prijave stavljanja ambalaţe i upakovanih proizvoda na trţište, 

osnivanja sistema preuzimanja, sakupljanja i obrade otpadne ambalaţe i rada tog sistema („‟Sluţbeni 

list‟‟, broj 09/10, 19/11) 

53 Uredba o naĉinu i postupku prijave stavljanja guma na trţište, osnivanja sistema preuzimanja, sakupljanja 

i obrade otpadnih guma i rada tog sistema (‟‟Sluţbeni list CG‟‟, broj 09/10) 

54 Uredba o naĉinu i postupku prijave stavljanja vozila na trţište, osnivanja sistema preuzimanja, sakupljanja 

i obrade otpadnih vozila i rada tog sistema (“Sluţbeni list CG”, broj 09/10) 

55 Uredba o naĉinu i postupku prijave stavljanja baterija i akumulatora na trţište, osnivanja sistema 

preuzimanja, sakupljanja i obrade istrošenih baterija i akumulatora i rada tog sistema (“Sluţbeni list 

CG“, broj 15/10) 

56 Pravilnik o postupanju sa otpadnim uljima (“Sluţbeni list CG”, broj 21/ 

.

tenance of the register data and the content of the summary report form 

(Official Gazette, No. 46/10) 57 

• Regulation on detailed contents of the documentation for the issuance of 

permits for import, export and transit of waste and waste classification list 

(Official Gazette, No. 75/10) 58 

• Ordinance on the content, form and manner of keeping the register of licenses 

issued for the transboundary movement of waste (Official Gazette, 

No. 71/10) 59 

• Regulation on detailed contents of a detailed description of the work process 

and conditions of the equipment and personnel with which the treatment 

plant and disposal facilities need to comply (Official Gazette, No. 

75/10) 60 

• Ordinance on the incineration of waste (Official Gazette, No. 14/11) 61 

• Regulations on the procedure of processing equipment and waste containing 

PCBs (Official Gazette, No. 34/11) 62 . 

57 Pravilnik o obliku, sadrţaju i naĉinu popunjavanja formulara o transportu otpada i evidencije o 

otpadu, godišnjem izvještaju o otpadu, sadrţini i naĉinu voĊenja registra podataka i sadrţaju i formi 

zbirnog izvještaja ("Sluţbeni list CG ", broj 46/10) 

58 Pravilnik o bliţem sadrţaju dokumentacije za izdavanje dozvole za uvoz, izvoz i tranzit otpada, kao 

i listi klasifikaciji otpada ("Sluţbeni list CG", broj 75/10) 

59 Pravilnik o sadrţaju, obliku i naĉinu voĊenja registra izdatih dozvola za prekograniĉno kretanje 

otpada ("Sluţbeni list CG", broj 71/10) 

60 Pravilnik o bliţem sadrţaju detaljnog opisa radnog procesa i uslovima koje u pogledu opreme i 

kadra ispunjava postrojenje za preradu i odstranjivanje otpada ("Sluţbeni list CG", broj 75/10) 

61 Pravilnik o spaljivanju otpada ("Sluţbeni list CG", broj 14/11) 

62 Pravilnik o naĉinu i postupku obrade opreme i otpada koji sadrţi PCB ("Sluţbeni list CG", broj 

34/11) 

.

Annex 4 

SWOT Analysis on the Regions in 

Montenegro 

The following SWOT analysis was prepared within the Regional Development 

Strategy for Montenegro. These include the North Region (including Pluţine 

and Šavnik) and the Central Region (Nikšić). The Coastal Region is not shown 

below. 

Table 17 

SWOT Analysis for the North Region (Plužine, Šavnik), strengths and 

weaknesses 

Human 

resources 

Environment 

Economic 

activities 

Traffic and 

public 

infrastructure 

Strategic 

and 

development 

plans and 

programs, 

policy 

Strengths 

Available human resources; 

Relatively good opportunities for 

education; 

Educated population; 

Biological diversity, existing and 

potential protected areas 

water and forest resources, 

agricultural land; 

The interest of local 

government and population in 

solving environmental problems; 

Cooperation with the civil sector. 

The potential for rural tourism; 

Strategic Tourism Development; 

Development of entrepreneurship 

and business centres; The potential 

for forestry development; Industries 

based on agriculture; 

Developmental communication 

network; 

There is awareness of the need to 

pass Local government development 

strategies; 

Urban plans of local governments 

are in the process of development. 

Weaknesses 

Unemployment; 

Non-harmonized supply and demand 

in the labour market; 

Depopulation; 

High outflow of educated people; 

Inadequate waste management and 

Wastewater - undeveloped utilities; 

The absence of effective mechanisms 

for sustainable management of 

natural resources 

Insufficient capacity (in general, and 

for development projects for the EU 

funds); 

Low energy efficiency; 

Under developed economic infrastructure; 

Complicated administrative procedures; 

Unorganized purchase of agricultural 

product; 

Underdeveloped Sector of Information 

technology; 

Travel and rail infrastructure; 

Access to basic services in rural areas 

The lack of spatial planning documents; 

The lack of sectoral strategies; 

The absence of plans for development 

of utility services 

Lack of local environmental plans 

The absence of a database of local 

government; 

Lack of funds. 

.

Table 18 

SWOT Analysis for the North Region (Plužine, Šavnik), opportunities 

and Threats 

Human 

resources 

Environment 

Economic 

activities 

Traffic and 

public 


Strategic and 

development 

plans and 

programs, 

policy 

Opportunities 

Investing in lifelong education; 

Opening of new educational 

institutions; 

Training on EU programs; 

The rich natural heritage; 

Development potential of rural areas; 

EU funds and other potential sources 

funding; 

Renewable energy sources(wind, biomass, 

water); 

Improving forest management, 

with a greater degree of involvement of 

local 

self-government. 

New trends in tourism (bicycling, 

hunting, rafting...); 

Growing International Demand for rural 

tourism; 

Funds and activities of the Government 

of Montenegro and the EU for economic 

development and improvement 

business environment; 

New trends in development of organic 

food; 

The development of information technology; 

Transfer of knowledge and technology; 

Development of SMEs. 

Construction of the highway Bar- 

Boljare; 

Private-public partnership; 

The possibility of cross-border cooperation 

(IPA); 

Decentralization of development management; 

Threats 

The low natural population 

growth; 

Further population; 

Weak capacity to prepare the 

EU projects. 

Outdated technologies (GP); 

High CO2 emissions; 

Illegal construction, which 

threatens natural and other 

values; 

Unplanned deforestation 

Lack of funds 

Natural disasters; 

The development of mass tourism 

projects in neighbouring 

countries; 

Global and EU competition; 

Inability to attract funds for 

development of renewable energy 

sources; 

No investors for investment in 

infrastructure; 

No harmonized local governments 

and state development 

policies; 

Adverse external sources of 

funding; 

The slow process of decentralization; 

Lack of implementation of 

adopted strategic plans; 

.

Table 19 

SWOT Analysis for the Central Region (Nikšić), strengths and weaknesses 

Strengths 

Weaknesses 

Human resources 

Environment 

Economic 

activities 

Traffic and 

public infrastructure 

Strategic and 

development 

plans and 

programs, 

policy 

Educational institutions; 

Educational Structure; 

Positive demographic trends of 

employment opportunities. 

Rich in biodiversity; 

Partially developed utility 

infrastructure; 

Progress in the preparation of 

project documentation; 

Relatively well-developed capacities. 

Business centres; 

Development of economic infrastructure 

entrepreneurship; 

A large number of SMEs; 

Excellent conditions for the development 

of small and 

medium business; 

Defining the agro industrial zone 

Tourism Resources; 

Investments inroad infrastructure; 

Airport; 

Good transport links; 

Developed telecommunication 

network. 

Multi-year investment plan; 

Detailed master plans. 

Lack of social inclusion; 

Under developed system of lifelong 

education; 

Low energy efficiency; 

The low-level of awareness about the 

environment, particularly on climate 

change; 

Improper dispose a of special 

waste streams; 

Inadequate control of pressures and 

inefficient enforcement of laws. 

Lack of evaluation culture-natural gases; 

The low-level of investment in research 

and development; 

Protecting intellectual property; 

A significant level of unused resources 

and agricultural land; 

Reduced liquidity of companies; 

Quality of transport services; 

Out dated rail infrastructure. 

Requires new Strategic development 

plan of Local Government; 

The required geographic information system; 

There is no reliable statistical base data; 

Lack of harmonization between the 

dynamics of development 

Capital town with other parts of State; 

.

Table 20 

Human resources 

Environment 

Economic 

activities 

Traffic and 

public 


Strategic and 

development 

plans and 

programs, 

policy 

SWOT Analysis for Central Region (Nikšić), opportunities and threats 

Opportunities 

EU training program; 

Investing in life long education; 

Education of persons with special 

needs; 

The increase in labour supply of 

different professional profiles. 

Improving energy efficiency 

the industry standard for energy 

efficient Building; 

Renewable energy sources(sun, 

wind); 

The application of new knowledge 

and technology; 

Improving the system of selective 

waste collection. 

Investment in research and development; 

The application of new knowledge 

and technology; 

E-commerce; 

Further improvement of economic 

Skadar Lake as infrastructure 

tourist destinations; 

New Trends in Tourism(Rural 

tourism, bicycling, villas); 

Water potential; The potential for 

agricultural development; 

IT business incubator. 

The geographical location; 

The potential for combined traffic 

methods; 

Construction of the highway Bar- 

Boljare; 

Adriatic-Ionian corridor; 

Digitization means of mass 

communication; 

The high frequency of traffic 

during summer season. 

Cross-border cooperation; 

EFunds. 

Threats 

Lack of awareness of the need for 

education and training skills; 

Outflow of young and highly qualified 

labour forces to other countries. 

The pressures on agricultural land; 

All forms of pollution of the environment, 

especially industrial pollution; 

Multiple pressures on protected areas. 

Lack of funds; 

Global and EU competition; 

Decrease in investment activity; 

Decrease in demand for real estate; 

Lack of finding investors for investment 

in infrastructure. 

Lack of enforcement of adopted strategic 

plans. 

.

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