Experts and civil society organizations demand that the regulation of the Avala Film complex ensure the protection of the public good and the right of the citizens of Belgrade to a healthy and preserved environment, while respecting the legal procedures.

The documents presented by the Secretariat for Urbanism and Construction Affairs of the City of Belgrade for early public inspection on the occasion of drafting a detailed regulation plan for the "Avala Film" complex indicate with their content, but also a series of omissions and illogicalities, that the city authorities intend to turn Kosutnjak into a residential and business area, with the devastation of a large stretch of Kosutnjak forest for new sports centers and intensive construction. The analysis of the document indicates that the development of the film industry in the area of ​​the former film giant "Avala Film" is not its goal, but that it serves as a screen for the construction of thousands of square meters of residential and commercial space.

The analysis of the documentation on the early public insight indicates that the intentions of the city authorities are directly contrary to the public interest and the interests of the citizens of Belgrade. In its essence, the realization of the plan would harm the public good and contribute to the damage to the environment, and thus to the citizens of Belgrade. In a city where the air is assessed as excessively polluted, and the indisputable climate change that has already brought us torrential floods, cutting down over 25 hectares of forest is unreasonable and extremely risky. The concern and rebellion of the nearby population, but also of all recreational users and nature lovers, is justified and understandable.

Data from the plan presented at an early public inspection indicate the construction of almost 420,000 m2 of new residential space and 150,000 m2 of commercial space. Forests and public green spaces are disappearing under these changes, and from the existing 34.7 hectares they are being reduced to ten times smaller area of ​​only 3.4 hectares. Greenery and culture are being taken away and a space of 9.6 hectares of built-up squares of commercial content is being created, which is currently not on the site at all, and another 7.9 hectares of mixed city centers are being added to that. Paradoxically, the goal of drafting this plan is to reduce the areas for public service facilities and complexes (health center, kindergarten, fire service and cultural content) by almost a third, by a total of 9.7 hectares.

If we look at the planned increase in population (from the current 854, an increase in population to 7980 is predicted) and ten times higher housing density, it is pointed out that the primary goal of the plan is to build an elite housing complex. In order to achieve that, 26.8 hectares of forests and 7.9 hectares of green areas will be sacrificed in one of the most valuable locations in Belgrade, invaluable in their contribution to natural resources.

In addition to a number of omissions in the preparation of documentation, such as that the preparation of the planning document is signed by "responsible urban planners" whose licenses have expired and that the "Avala Film complex" is not precisely defined, its content is problematic and contrary to laws and plans and indicates that the purpose of the plan is to legally support the illegitimate practice of ceding the most valuable urban spaces to the private interest and to the detriment of the public interest and the future of the city.

The realization of the plan is based on a series of questionable actions of the competent institutions, deputies and public companies to which the public interest is subordinated to the private one. Thus, "Srbijasume" is giving up parts of the forest in this area, and the Ministry of Culture and Information is being asked to give its consent for the areas of public purpose to be renamed into areas of other purposes. At the same time, higher-level urban plans are taken as "orientation" and thus invalid. The question arises - if the plans of a higher order are taken as invalid, then what are the plans for in general and on the basis of what information was the material for early public insight made and the future of this part of Belgrade determined?

Experts and civil society organizations demand that the development of a detailed regulation plan for the Avala Film complex be stopped immediately on the proposed basis and that the basic concept be changed by respecting higher-order procedures, laws and plans, ensuring the preservation of forests and green areas without changing the purpose of land because there is no basis for that, and to leave the investor the opportunity to use and invest in real estate owned by him, without changing the ownership structure over the land.

It is necessary that the detailed regulation plan be developed in accordance with the objectives, purpose of space and restrictions set by the Environmental Protection Program of the City of Belgrade (2015), the Afforestation Strategy of the City of Belgrade (2009), the Climate Change Adaptation Action Plan with vulnerability assessment for the City of Belgrade (2015), the Plan of General Regulation of the Green Area System of Belgrade (2019) and other strategic and planning documents in the field of environmental protection and planning and construction. The report on the strategic environmental assessment of the detailed regulation plan must be prepared in accordance with the law and that report must contain up-to-date and accurate data on the state of the environment, protected species and their habitats, biotope value assessment and non-implementation of the plan. Based on these data and analyzes, it is necessary to determine the solutions that are most favorable for achieving the goals of environmental protection and sustainable development of Belgrade, and thus this part of Kosutnjak.

In the procedure of early public insight, citizens were not enabled to submit their remarks and comments in the manner prescribed by law. Experts and civil society organizations demand that the early public inspection procedure be suspended in a situation when due to the COVID-19 virus epidemic there are no basic conditions for public participation in the decision-making process, and that the procedure be repeated when all irregularities and omissions are eliminated.

The signatories of this initiative are experts and civil society organizations: Belgrade Open School, Center for Cultural Decontamination, Evropa Nostra Serbia, Ministry of Spatial Planning, Ne davimo Beograd, Polekol, Pedestrians Are Not Marathoners, RERI, WWF, ZaNašKej, Ksenija Radovanović, Slavica Čepić - Landscape Architect / Researcher at the Faculty of Forestry.

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