SUBJECT: Request to Revoke the Decision on the Establishment of a Military Firing Range on Sinjajevina from September 2019

Dear Sir/Madam,

On behalf of the Civil Initiative “Save Sinjajevina,” we hereby submit this initiative requesting the formal revocation of the decision from September 2019, which envisioned the establishment of a military firing range on Sinjajevina. This decision was made without prior public consultation and ignored numerous civic protests, petitions, and appeals, thereby violating the fundamental rights of local communities to decide on matters that directly affect their lives and the environment.

Although herders have been preparing to return to Sinjajevina, which is under UNESCO protection, this harmful decision has yet to be revoked, despite numerous promises from various governments in the past years. We remind you that Prime Minister Milojko Spajić, during a meeting with representatives of the initiative in January 2023, clearly stated: "There will be no military ranges on Sinjajevina." We believe it is high time for this promise to be officially confirmed through a formal decision by the Government of Montenegro.

The Civil Initiative “Save Sinjajevina” began its activities in 2018, immediately after the first news surfaced about the planned use of Sinjajevina as a military firing range. The initiative was officially registered in 2019, and its formation resulted from spontaneous protests by herding communities from Sinjajevina and other citizens who have expressed their opposition to this decision for the past seven years.

During the decision-making process regarding the military firing range, relevant state bodies were involved, including the Ministry of Sustainable Development and Tourism, as well as the Agency for the Protection of Nature and the Environment. According to the opinions of these bodies, this matter is of special importance for the preservation of natural resources and environmental protection.

In 2016, the Agency for the Protection of Nature and the Environment conducted a study that clearly demonstrated that Sinjajevina meets all the criteria to be designated as a regional nature park. This document was financed by the European Union and represents a key foundation for future protection of this area.

Furthermore, the Civil Initiative “Save Sinjajevina” posed several critical questions to the Ministry of Defense of Montenegro back in 2020:

1. Legislative Framework for the Protection of Sinjajevina: Sinjajevina is located in the transitional zone of the Tara River Canyon Biosphere Reserve, meaning all economic and human activities in this area must comply with the norms prescribed by UNESCO.

2. Protection as a Natural Asset: At the time the decision was made regarding the military firing range, Sinjajevina was in the process of being protected as a natural asset, which should have been completed by 2020.

3. Compliance with EU Bird and Habitat Directives: Sinjajevina has been identified as a potential Special Protection Area (SPA) for birds, covering an area of 39,240 ha, in accordance with EU nature protection standards.

4. Implementation of the Bern Convention and the EU Habitat Directive: Sinjajevina is also part of the Emerald Network and recognized as an area of international importance for the protection of natural habitats and species.

It is crucial to ask whether the Ministry of Defense and other competent authorities were fully informed about these international obligations that Montenegro must fulfill under EU legislation and international conventions.