Comment on the expansion plan of Belgrade on the water

This letter does not seek to improve the plan in question in a technical sense, but points to its political, social and institutional illegitimacy from the standpoint of the protection of public goods and spatial justice. 

Planning documents represent an instrument for translating public, that is, spatial policies into spatial solutions. But what these spatial solutions are and how planning documents are prepared and adopted depends on what spatial policies are implemented. The spatial policy that you implement is devoid of any form of long-term reflection and planning that focuses on protecting and improving living conditions in our cities for all beings who live or will live in them. The subject of the spatial policy that you implement is not the people who live in our cities, but the political elites who, in conjunction with big capital, operate through the state. The central issue of the spatial policy that you implement is not the issue of the equal realization of the right to a roof over the head, which all people in the city have, nor the issue of the equal distribution of all public services and services that should be available and accessible to everyone. Climate changes and their consequences in cities, as well as the question of their mitigation and adaptation of the city to them, are not seen in the spatial policies that you implement as one of the basic preconditions of planning. What's worse, they don't look at each other at all. Public goods and public resources (cultural goods, natural goods, forest, agricultural, water land, public building land, water sources, air, public green areas) are not treated in the spatial resource management policy that you implement as resources that must be preserved, improved, shared equally and to which all beings have an equal right, but as a chance for unlimited exploitation, privatization and turning into a commodity on which the privileged will profit. 

This plan is exactly one such instrument that reflects the centralized, authoritarian, market-oriented, ecologically unsustainable and socially exclusionary spatial policies that you implement. In the following, it will be shown more specifically how they are implemented with this plan, and why they are unacceptable and why we fundamentally oppose the plan and demand the immediate suspension of the development and rejection of this plan. 

1. Spatial plan of special purpose areas (PPPPN) as a means of centralizing decision-making power and political control over space

There is not a single explanation that would be in line with several decades of planning practice and logic, on the basis of which the application of PPPPN as a planning instrument for area planning in the innermost center of a city could be justified. The City of Belgrade, according to the existing administrative arrangement (Law on Local Self-Government, Law on the Capital and the Statute of the City of Belgrade), has complete autonomy in planning its territory. Abuse of the mechanism conclusion of the Government of the RS on determining the project of special importance for the RS, it was possible to adopt the initial PPPPN for Belgrade on the water, which at that time represented a planning precedent. This not only suspended the existing order of urban plans, but also the legal framework of spatial planning. 

With the numerous amendments to the Law on Planning and Construction that followed, and ending with the last amendment from 2023, this mechanism of centralized planning was institutionalized. The amendment of the law actually made it possible to legalize this harmful and centralized planning practice. By applying PPPPN for the planning of the national stadium, EXPO complex, luxury housing, new fair space, theme park, shopping centers, creative industries, hotels, scientific and educational campuses, business premises, etc. urban planning was abolished. Belgrade's planning takes place at the republic level, which is completely unacceptable.

PPPPN is used here as a way to implement projects, which would not be possible to implement through urban plans, due to the little remaining regulation, restrictions and urban hierarchy of plans. Because according to the current Plan of General Regulation of the Building Area of ​​the City of Belgrade for the Belgrade Fair complex, for example, it is prescribed that a detailed regulation plan be drawn up, which would not be so easy to change its purpose from public to residential. Here it is clear that the centralization of planning actually enables the speedy and effective realization of the interests of capital close to the ruling structures, because the Government has at its disposal a mechanism to declare anything it wants as a project of special importance for the RS, and then to pass a PPPPN according to a shortened procedure, excluding the public, which can bypass all other plans and laws and which will make the interests of capital legitimate and disguise them as "public interest". 

The use of PPPPN in the planning of Belgrade, and specifically in the case of the "Belgrade on the Water" project, represents a systemic, institutional practice through which planning becomes a political-administrative tool that serves to centralize power and redistribute spatial resources in favor of political-investor interests. It is more than obvious that there is no more space to discuss spatial and urban standards and norms, parameters and rules of arrangement and construction - this is not planning, but a form of political control over space, with the tendency of unlimited expansion. 

2. Simulation of participation in an authoritarian plan

Already during the public presentation of the plan, the procedure was designed to limit the space for open discussion and exchange of arguments. The participants were divided into several separate groups, which prevented a broader public debate, and the members of the Commission for Public Insight — as per established practice — during the participants' presentation spent almost the entire time looking at their mobile phones, ignoring the comments made and demonstrating open contempt for the meaning of the public presentation procedure itself.

Considering the current practice in conducting public reviews, and especially for plans for which there is great public interest, it is reasonable to expect that the upcoming public hearing for this plan will be conducted in a new regime, made possible by the most recent amendments to the Rulebook on the Content, Method and Procedure of Drafting Spatial and Urban Planning Documents ("Official Gazette of the RS", No. 47/2025), which introduced the possibility of conducting electronic public sessions. The first public session held in this format was accompanied by serious technical and procedural problems, while everyone who does not have access to the Internet or an appropriate level of digital literacy is initially excluded from this process.

It is particularly worrisome that clearly articulated and well-grounded views of experts and the general public, expressed through joint initiatives, formal letters and public calls from numerous professional associations, academic institutions, professional organizations and civil initiatives, were ignored this time. On the occasion of the announced demolition and radical change of purpose of the Belgrade Fair complex and the ensemble of the General Staff and the Ministry of Defense, a large forum was organized in April 2024, where more than 350 experts unanimously expressed their opposition to such planning solutions.

The working group formed after the Forum analyzed in detail the existing documentation and received comments, and adopted it Declaration on the fate of the Belgrade Fair and the General Staff, which expressly demanded a return to the earlier decision on the protection of the Belgrade Fair from 2009, as well as the development of an urban plan of detailed regulation (PDR) for this location, with the full involvement of experts and the general public through a democratic and competitive planning process.

Despite these demands, and the broader social consensus regarding this plan, the procedure of developing and adopting the plan continued without any consideration of the views expressed, which once again confirmed that participation in these processes is completely meaningless.

3. The plan as a legal mechanism for turning public goods into commercialized and exclusive spaces

The amendments and additions to the plan envisage further privatization of the banks of the Sava River and the seizure of public green areas, which drastically undermines the public interest, the rights of citizens to access the river, as well as the quality of protected natural entities.

Another marina is planned to be built in the area of ​​the Čukarica backwater, within Ada Ciganlija, on land that is currently defined as a public green area. Although it is an area that belongs to a protected natural asset - the Area of ​​exceptional features of Ada Ciganli, it is evident from the plan that part of this green and recreational zone is being repurposed for infrastructure related to nautical and potentially commercial contents. Directly next to the planned marina is the location of Ada Safari, for which a tender for the construction of a zoo and entertainment center was held this year. This creates new pressure on the ecosystem and the character of Ada as a public and natural space. Instead of strengthening its role as a public recreational and natural asset, the proposed interventions lead in the direction of commercialization of this space.

On the other side of the Sava, within the New Belgrade waterfront between the Ada Bridge and the Gazela, the expansion of the "Belgrade on the Water" complex is planned to the left bank of the river, in an area that currently represents a typical brownfield location with high potential for revitalization and conversion into green public areas. Despite this, the entire area is planned to be repurposed into another gated residential-business block, further reducing public access to the river and green areas along the coast.

Of particular concern is the fact that this part is also located in zone II of sanitary protection of the water source, which means that according to current regulations, any new residential construction is inadmissible, precisely because of the protection of citizens' health and water quality.

Furthermore, the plan confirms that the Belgrade Fair complex no longer has its original purpose and function, and that all halls of the Belgrade Fair, except for Hall 1, are expected to be demolished. The Belgrade Fair represents one of the most significant achievements of Yugoslav post-war architecture, due to the exceptional architectural and constructive value of the buildings - primarily Hall 1, but also other halls that were designed as part of this complex. Additionally, Hall 1 is slated for conversion, that is, it is planned as a "multifunctional facility" of unspecified content, which opens up space for its further commercialization and degradation of the status of a cultural monument it currently enjoys.

4. Apartment 

In this special purpose plan, luxury residential development is treated as if it is of strategic importance to the state - which is conceptually and socially meaningless. Planning documents of this type are intended to respond to infrastructural, environmental, security or other systemic needs of public importance. Luxury apartments are not. Housing is a right, but luxury construction is a market product, and it is usually an investor venture without any social function. Its declaration as a project of special importance is not only morally and politically unacceptable, but also legally problematic because it distorts the very purpose of this mechanism.

At the moment when this plan is being drawn up, there is already a serious surplus of apartments in Belgrade compared to the real needs of the population. Between the two censuses, the number of apartments in Belgrade increased by 134.000, while the number of unoccupied apartments increased by 24.000. According to the demographic projections from the study prepared for the needs of the new General Urban Plan, a decrease in the number of inhabitants is expected in all considered scenarios. Official statistics indicate the existence of around 10.000 abandoned apartments, 35.000 occasionally used and another 108.000 temporarily uninhabited apartments. In this context, the continuation and institutional support of excessive housing construction - especially luxury apartments - cannot be explained by any rational analysis of needs.

If housing construction could be a project of special importance for the state, it could only be the construction of housing for those who cannot solve their housing problem on the market. This plan does not offer that. On the contrary - the most expensive square meters in Serbia have been located within the Belgrade complex on the water for years, reaching prices of up to 11.800 euros per square meter, while the average price is 4.800 euros per square meter. On the other hand, the average salary in Serbia is not even 1.000 euros. This means that a citizen with an average income would need to set aside all his income over the next 22 years to be able to afford an apartment of average size of 55 square meters. In the analysis that preceded the adoption of the current Law on Housing and Building Maintenance, it is clearly stated that if the price of an apartment exceeds four annual salaries, the state should intervene and provide instruments to increase the availability of housing.

However, instead of responding to this obvious and deepening housing crisis, the state actively invests public resources – through land, infrastructure, planning privileges and tax breaks – in luxury housing projects that do not meet any public needs. Moreover, these projects are implemented without any control of the origin of the capital and without any public discussion about who are the users of those areas and on the basis of which criteria the state decides to invest in exactly that type of construction. An apartment as a human right is replaced by an apartment as a means of accumulation and speculation, while the majority of the population remains exposed to uncertainty, an overvalued market and deepening housing insecurity.

5. Ignoring climate and environmental imperatives

The planned construction on the site in question is directly against the current protection regime for Belgrade's water supply sources. According to the Decision on the determination of zones of sanitary protection for sources of underground and surface water for the water supply of the city of Belgrade (Ministry of Health of the RS, no. 530-01-48/2014-10 of 01.08.2014), the site in question is located in zone II (narrower zone) of the sanitary protection of the Belgrade water source. According to the provisions of the Rulebook on the method of determining and maintaining sanitary protection zones of water supply sources (Official Gazette of the RS No. 92/08), as well as according to the Elaboration on sanitary protection zones of underground and surface water sources of water supply in the city of Belgrade (Institute "Jaroslav Černi", 2013), the construction of new residential areas is unequivocally prohibited in this zone.

This prohibition is clearly confirmed in the textual part of the valid General Regulation Plan (GRP) of Belgrade, which foresees exclusively permitted uses such as green areas, sports and recreational facilities (zone S10). Nevertheless, the graphic part of the plan remained inconsistent and incorrectly shows the location as a residential zone, despite the fact that in 2014 the location was moved from III to II protection zone, which further tightens the permitted regime. Such a deviation indicates a serious failure in harmonizing spatial planning documentation with valid regulations and a risk to the quality of water supply to the population.

The Sava Amphitheater area is already showing extreme indicators of heat stress. According to data on the frequency of tropical nights, this part of the city records more than 50 tropical nights per year, which is significantly more than the inner city center. Although the textual part of the plan states that the area in question is located in the heat island zone, it is avoided to state that the intensity of construction actually represents an extremely important factor and the cause of such a large number of tropical nights. Also, there was no explanation of the consequences of this situation - which is highly risky for public health and the health of the residents of this part of the city. Nevertheless, regardless of the conducted research and the alarming results of the same, the changes and additions to the plan do not approach spatial planning in a way to mitigate the effects of the heat island, increase the representation of natural soil and vegetation, nor introduce mandatory measures related to the ecological index of the location. On the contrary, the plan additionally stimulates high-intensity construction, which strengthens the negative microclimatic trend in the long term and ignores the public interest.

Although the plan documentation states that about 12% of the area is designated for public green areas, this percentage is highly debatable - as it includes mostly paved squares and promenades, such as Sava Square and Sava Promenade. These surfaces, although formally labeled as "green", do not contribute to the reduction of the heat island, nor do they perform ecological functions that would have continuously connected green surfaces in direct contact with the ground.