The Action for Social Justice (ASP) submitted comments to Montenegro’s Ministry of Energy and Mining on the National Energy and Climate Plan, emphasizing the need to define a clear closure date for the Pljevlja Thermal Power Plant (TPP) and plan its transition.
ASP highlighted that the current plan lists multiple potential closure years—2035, 2037, or 2041—creating uncertainty for the region. They recommended specifying the year TPP Pljevlja will cease operations, the period for placing it in cold reserve, and a framework for a “just transition” for the city, which is critical for the roughly 3,000 direct and indirect jobs linked to the plant.
The organization also called for clearer projections of the financial impact of planned renewable energy investments, estimated at €2.5 billion over ten years, including effects on the state budget and major state-owned companies such as EPCG, CGES, and the Eco Fund.
ASP urged the exclusion of ecologically and economically unviable projects, such as the Komarnica hydroelectric plant, which they claim violates EU and Bern Convention nature protection standards while contributing less than 2% to national electricity production at a cost of over €300 million. They also recommended reevaluating new fossil fuel projects, including gas plants and infrastructure, citing risks of import dependency and stranded investments.
Additional proposals included mandatory annual renovation targets for at least 3% of public building surfaces, measures to reduce heating energy consumption by replacing fossil fuels with sustainable sources, and realistic targets for reducing transport sector emissions by 2030 and 2050. ASP stressed the need for concrete measures to address energy poverty and called for improved transparency in the public consultation process.
