GI “Spasimo Brezna”: Agency Again Grants “Green Permit” for the Alcazar Energy Wind Farm – Appeals Filed, Criminal Complaints to Follow

The Environmental Protection Agency has once again granted consent for the “Bijela” Wind Farm with its 110 kV connection transmission line, even though, in the repeated proceedings, precisely those illegalities and deficiencies for which the Ministry of Ecology, Sustainable Development and Northern Development annulled the previous consent and returned the case to the Agency for reconsideration have not been remedied, the Citizens’ Initiative “Spasimo Brezna” and the affected owners of private properties in Duži stated.

As they point out, this decision, No. 03-UPI-2482/122 dated 08 September 2026, was adopted following proceedings that were non-transparent and marked by serious violations of procedural rights. For this reason, the affected residents and GI “Spasimo Brezna” filed appeals with the Ministry, and they are also announcing criminal complaints against the responsible officials on suspicion that the proceedings were conducted in a manner aimed at favouring the investor.

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The competent Ministry had previously identified serious deficiencies concerning changes to the route and cadastral parcels, impacts on the “Dragišnica and Komarnica” Nature Park, the buffer zone of Durmitor National Park, the Emerald site and potential Natura 2000 area of the Komarnica Canyon, as well as the assessment of significant and cumulative impacts. However, the new consent still fails to provide a clear answer to the key questions: what exactly was changed, which parcels were added or removed, why the route was changed, and what consequences those changes have.

A particular problem is the fact that the affected residents, whose rights as parties to the proceedings are guaranteed by law, were denied full and verifiable access to the documentation on which the decision was based. Key documentation was delivered via temporary WeTransfer links, and when the Agency was informed that the link had expired and that the documentation was no longer accessible, the new decision was nevertheless issued just two days later.

At the same time, the decision was issued before a final decision had been made on all requests for recognition of party status. In the reasoning of the new consent, the EPA states that one such request was rejected because, allegedly, the Revised EIA Study did not contain parcels owned by the applicant. After the Revised EIA Study was publicly disclosed, only on the day the new decision was published, it turned out that those parcels were in fact included in the project documentation.

This raises the very serious question of the facts on the basis of which the Agency previously denied party status and whether the decision was based on a deliberately false statement of a decisive fact.

In addition, the public hearing on the original EIA Study was held back in May 2025, while consent was granted on the basis of a later Revised EIA Study, following changes to the route and cadastral scope. The route change was neither cosmetic nor merely technical. The spatial scope, cadastral parcels and the technical solution itself were changed, meaning that the new route practically constitutes a new project compared with the one on which the public was consulted. Nevertheless, no new public hearing was held.

The most contentious part of the new consent concerns birds and bats. The EPA granted consent to the project, while in the same decision ordering that a one-year study of birds and bats be carried out only afterwards, by 01 October 2027, after which the Agency retains the possibility of prescribing additional measures.

This is contrary to the basic logic of environmental impact assessment.

The studies must first be carried out and the actual impacts of the project established, and only then can a decision be made on whether the project is acceptable and under what conditions. Consent cannot first be issued and then a year spent investigating whether the project poses a risk requiring additional protection measures. Particularly because the documentation itself identifies a significant risk to birds and a high risk to large birds of prey.

The new consent also contains serious contradictions in its own chronology. The EPA refers to documents concerning the route change from September 2025, and then states that those documents were considered in a Commission report from June 2025. A document from September could not have been considered three months earlier.

GI “Spasimo Brezna” considers that the totality of these facts demonstrates a pattern of conduct that requires much more serious scrutiny than ordinary second-instance review of the decision.

When an authority denies party status by relying on a fact that later proves to be false, when it fails to provide affected residents with proper access to documentation, when the route and parcels are substantially changed without a new public hearing, when previously identified deficiencies remain unresolved, and when environmental consent is issued before the completion of key biodiversity studies, there are grounds to examine whether the proceedings were conducted in a manner that favoured the investor. Therefore, in addition to the appeals already filed with the Ministry, criminal complaints against the responsible officials will also be prepared, with a request to the competent Prosecutor’s Office to examine whether false facts were stated in official acts, whether certain documents and data were selectively presented or omitted, and whether the specific conduct contains elements of criminal offences against official duty and the authenticity of official documentation.

GI “Spasimo Brezna” does not prejudge anyone’s criminal liability, but considers that there are sufficiently serious and documented facts that the competent Prosecutor’s Office must examine. Because this is no longer only about a single wind farm. It is about whether, in Montenegro, environmental consent can be issued before key studies have been completed, with a changed route, disputed parcels, restricted access to documentation and unresolved rights of citizens living in the area directly affected by the project.

They recall the numerous illegalities they have been pointing out and fighting against for more than a year, as well as what they describe as the illegal expropriation of citizens’ private property for the benefit of a private investor, the Dubai-based company Alcazar Energy Partners, namely its subsidiary in Montenegro, Vjetro park Bijela. They have filed a lawsuit with the Administrative Court against the Government’s decision declaring public interest.

“The Government of Montenegro adopted, at the end of December last year, during a WhatsApp session, an illegal decision by which it unlawfully declared an alleged public interest over hundreds of privately owned parcels in the municipalities of Nikšić and Šavnik, without any explanation and without identifying specific projects. The state is now, in practice, taking private property away from its own citizens in order to hand it over to the private company Alcazar Energy Partners. For months, pressure has been exerted on residents and on GI ‘Spasimo Brezna’, attempts have been made to intimidate and discourage them from resisting so that they would surrender their property, while the most visible members of the community are being subjected to attempts to discredit them,” GI Spasimo Brezna stated.

They add that they will not give up the fight or their guaranteed human, civil and constitutional rights.

“We have received signals from international stakeholders that, in the EU accession process, they will insist that these rights and procedures must be respected. On the other hand, we expect that those who violate laws, the Constitution and international conventions and abuse their positions will end up where they belong,” GI “Spasimo Brezna” and the affected residents of Duži concluded in their joint statement.