COMMENT ON THE DRAFT AMENDMENT AND SUPPLEMENT TO THE GENERAL REGULATION PLAN (PGR) OF THE CITY OF BELGRADE

Secretariat for Urban Planning and Construction Affairs
Queen Mary 1,
Beograd

Complainant:
xxxxxxxx

Case: Early public inspection of the draft amendments to the general regulation plan for the construction area of ​​the city of Belgrade

1. Subject of the complaint

With this remark, we point out the deeply problematic and systemically harmful provision proposed as part of the amendment of the table "Compatibility of Purposes", which foresees the possibility to public areas (educational, health, social, communal, traffic areas, public green areas, forests, sports complexes and other public facilities) conversion to any other purpose by creating a detailed regulation plan (PDR), with the consent of the competent institutions.

This provision represents a fundamental change in the planning regime and opens the possibility for broad and unlimited privatization of public land in the city of Belgrade.

2. Reasons for submitting an objection

2.1. The protection of public purposes in the planning system was abolished

The proposed provision allows any public use — including schools, kindergartens, health centers, hospitals, universities, parks, public green spaces and forests — to be converted to residential, mixed-use or commercial use. This abolishes one of the key roles of PGR - to protect public spatial assets and ensure the stable presence of public areas in the city, as well as their equal representation and spatial distribution throughout the city. Instead of the PGR ensuring a sufficient number of public services, the necessary area of ​​land for public needs of all kinds, this plan would become completely flexible against particular interests, and completely abolish the protection of public spaces, which is the duty of the public sector and institutions.

2.2. Decisions are moved from the higher planning level (PGR) to PDR level

The decision on the use of space and/or on the change of purpose is moved from the higher-order plan, which takes into account the needs of the entire city, and which is required to plan public and social infrastructure networks in the entire territory of the city, to the lower-order plan which takes into account the individual location (which is usually in private property). This approach opens up space for partial, short-term and investor-motivated decisions, which are not based on an analysis of the capacity of public systems (educational, health, infrastructure), nor on a strategic approach to city planning. It is not enough to transfer the responsibility of deciding on a change of purpose to "competent institutions", when in practice these decisions are made at the level of the Commission for Plans of the Belgrade Guard, which cannot possibly be the appropriate body that will decide on a change of purpose at the level of the PDR. Additionally, this opens up space and an additional risk of corruption in planning and construction. 

2.3. A legal framework is being created for mass privatization of public land

As long as the land is planned as a public purpose, it cannot be sold. By changing the purpose through the PDR, this protection is removed, which opens the way for the alienation of public land. This applies both to existing public service facilities and to land reserved for future public facilities.

This approach threatens the long-term capacity of the city to provide new schools, kindergartens, health facilities and public green areas, and directly affects the (in)availability and (un)equal distribution of public services in the city.

2.4. All categories of public areas are at risk

The amendment applies to practically all public purposes that are of key importance for the functioning of the city. This makes it unclear which part of the public space remains de facto protected, since any parcel of public property can become the subject of conversion and subsequent privatization.

2.5. The plan loses its regulatory function

The PGR is a high-level document whose main purpose is to ensure stability, development guidelines and protection of public interest. The proposed provision turns it into a document that does not limit investor pressure, but rather institutionalizes it. In this way, the plan becomes an instrument of deregulation, not a regulatory mechanism. 

2.6. Consequences for public health, urban climate and quality of life

Belgrade already has only 9% of public green areas. Allowing conversion and loss of remaining green areas and forests endangers public health, increases thermal risks and undermines the ecological resilience of the city. This provision would completely prevent the implementation of the entire set of public policies that prescribe "greening of the city" as a primary measure in the fight against the consequences of climate change and as a basic prerequisite for improving public health in the city. The role of the plan is to be an instrument to spatially implement public policies. This plan, with the proposed changes, would not only not enable the realization of the goals and measures of public urban policies, but would contribute to completely opposite effects. 

 3. A request

Based on all of the above, the complainant considers that the proposed change to the plan is completely unacceptable and that it stems from a planning concept that is contrary to the public interest, professional practice and the basic principles of spatial planning.

We demand:

1. That the proposed provision on the conversion of public purposes be completely deleted from the draft amendments to the PGR.

2. To establish a planning system in which public purposes are permanently protected, and changes of purpose are considered only exceptionally, with strictly prescribed criteria, analysis and mandatory explanation.

3. That decisions about the use of space are based on analytical criteria, including:

• • capacities of educational, health and social institutions,
  • needs of the population,
  • protection of public green areas and urban climate.

4. To develop a plan that is rigorous for investors and flexible for the needs of citizens, and not vice versa.

The current proposal for changes to the PGR does not provide these standards, so it is necessary to reject it and create a solution that will serve the long-term, fair and sustainable development of the city of Belgrade.