The Association of Architects of Serbia (UAS) sent two public letters on Tuesday.
In a letter sent to all competent institutions, they demand "to withdraw from the procedure Draft amendments to the Spatial Plan areas of special purpose for the development of the part of the waterfront of the city of Belgrade - the area along the Sava river for the project "Belgrade on the water" due to the permanent disastrous consequences on the legal and planning system of the Republic of Serbia and the development of Belgrade, which will occur with its adoption".
They ask all fellow responsible urban planners and planners to take responsibility and stand up to power actors, believing that "there is still room for change".
Electronic public meetings are illegal
The second letter was sent to the Ministry of Construction, Transport and Infrastructure, and it concerns illegalities related to electronic public sessions.
The letter was sent immediately before the electronic public meeting scheduled for July 30 at 9 a.m., about the plan that foresees the expansion of Belgrade on the water, or, officially, the Amendments and Supplements to the PPPPN for the arrangement of the waterfront part of the city of Belgrade - the area along the banks of the Sava River for the Belgrade on the Water project.
Here's what it's all about: "the digitization of the spatial and urban planning process was presented for the first time through the Proposal for the Policy Concept of eSpace reform, which was held for public discussion in February 2022," reminds UAS.
Then, that "public discussion, contrary to legal procedures, was terminated before the scheduled deadline, the documents were withdrawn from the website of the competent ministry, and the public was never informed about the next steps. During that discussion, the expert public and civil society organizations sent numerous serious criticisms and comments on the proposed concept. The policy concept was never formally adopted, nor did the Government of the Republic of Serbia establish a plan for its further development".
Nevertheless, the latest "amendments to the Law on Planning and Construction (2023) introduced certain concepts and elements from the mentioned concept, without relying on the previously established legal framework. These facts clearly indicate that the current reform of eSpace is being carried out without public discussion and without the appropriate legislative and institutional basis."
Timing
The Ministry makes this change "at the moment when the public clearly shows an extreme interest in directly participating in public discussions on urban planning documents and when two large spatial plans of special purpose areas are adopted - PPPPN for the National Football Stadium Phase 4 (EXPO) and Amendments to the PPPPN for the arrangement of the waterfront part of the city of Belgrade - the area along the banks of the Sava River for the Belgrade on Water project".
And this happens when the profession has almost no influence on urban planning. UAS points to two dangers in spatial planning.
Abolition of the profession
First, the spatial plan of the special purpose area (PPPPN) has become an instrument for planning the urban fabric, which is completely contrary to the basic principles of urban planning and current practice.
Second, the enactment of special laws (lex specialis) is increasingly resorted to in order to bypass the usual legal procedures and exclude public participation.
"Using the PPPPN for city development planning effectively abolishes urban planning as a professional and institutional practice," they say, emphasizing that "the entire planning process is transferred to a centralized, republican level, thus rendering meaningless the constitutionally and legally guaranteed right of local self-government units to independently plan their own territory."
"These plans implement what the Government of the RS, according to unclear criteria, declares to be projects of importance for the RS and public interest, without room for a critical review of what that interest and special importance really are. Different perspectives, conflicts of interest, and even social dialogue itself are excluded."
Urgent explanation
In such circumstances, electronic public meetings "as prescribed by this amendment to the Rulebook and introduced into our practice, are not and cannot be an adequate mechanism for public participation in decision-making on matters of national and public importance - and especially not when special-purpose spatial plans are misused for city development planning, which brutally nullifies the purpose of urban planning and the right of citizens to decide on the space in which they live."
That is why they are asking "the Government of the Republic of Serbia, the Ministry of Construction, Transport and Infrastructure, as well as the Agency for Spatial Planning and Urbanism, to urgently and publicly explain on the basis of which document and within the framework of which legal act this reform is being carried out", the UAS statement reads.
Both of these public letters of the Association of Architects of Serbia were signed by the associations of architects in Belgrade, Novi Sad, Niš, Zrenjanin, Valjevo, Vranje and a dozen professional organizations.