A handbook for avoiding participation: the case of EXPO

Author: Jovana Timotijević, Ministry of Space collective

[...]

Step 8_Schedule a public session within the scope of public inspection for a specific date (to meet the norm prescribed by law)

Step 9_If the public stirs up against the plan, give yourself more time to devise tactics to defend against the citizens and cancel the session

Step 10_Determine the next date of the meeting, but by no means announce it until the day before the meeting (this way you will prevent the limited public from coming to the meeting in full numbers)

Step 11_Be sure to schedule a session during working hours, but as early as possible in the morning (you kill two birds with one stone - working people and night birds)

Step 12_If you haven't thwarted the confused public, go back to Step 2 and give yourself more time for a new defense tactic

[...]

(Manual "How to avoid public participation in spatial and urban planning", probably)

This is how the attempt of the Agency for Spatial Planning and Urbanism of the Republic of Serbia to hold a public meeting on the topic of the IV phase of the Spatial Plan of the Special Purpose Area of ​​the National Stadium looked like. After the originally scheduled session was canceled the day before it took place, the same thing happened with the second attempt - on March 21, 2025. The session was announced and canceled the previous day...we'll see what awaits us next. However, the fiasco with the public session is only a logical continuation of the systemic avoidance of involvement the public in a plan that claims to be from national significance! Everything that preceded it also had the same goal.

It's one and the same plan, why not discuss it a hundred times

The treatment of the Spatial Plan of the special purpose area of ​​the National Stadium as a phased planning document made it possible to avoid the obligation to present planning solutions at an early public inspection, as one of the two public inspections prescribed by Articles 45a and 50 of the Law on Planning and Construction. Namely, the early public inspection was held only for the I phase of the subject plan, although it contained only a small part of the coverage that was presented in the IV phase. That early public inspection was held in April 2019, presenting to the public a proposal for a plan that included the national football stadium and accompanying sports facilities, along with roads, infrastructural areas and green areas, all on the territory of about 114 ha. In the following phases, including this (for now) last phase IV, infrastructural and traffic areas, the EXPO 2027 exhibition complex (exhibition space, accompanying accommodation facilities and accompanying commercial facilities), as well as a theme park, were additionally planned, so that the scope of the plan grew from those 114 to the entire 813 ha. However, none of these phases passed the early public inspection, and the public only had 15 days to familiarize themselves with the new planning solutions.

Let us not be in debt, we promised the International Bureau of Exhibitions

Despite the rule determined by Article 50 of the Law on Planning and Construction, which states that public inspection lasts 30 days, the Law on Special Procedures for the Implementation of the International Specialized Exhibition EXPO BELGRADE 2027, especially Article 4, shortens public inspection to 15 days. For plans that are of national importance (Conclusion of the Government of the Republic of Serbia No. 351-5082/2022 of June 30, 2022), which means that it is recognized that its effects will significantly affect the entire society, it is necessary to ensure sufficient time to svi citizens become familiar with the complex content of the plan and that they can react to it. However, in the name of efficiency, the principle of participation is absolutely compromised here.

Also, during the public inspection, a public presentation is prescribed by law for Spatial Plans of Special Purpose Areas. It was also scheduled for February 14, 2025, starting at 11 a.m., in the City Administration building, but was not held, due to the fact that it was interrupted shortly after the start by the representative of the plan's client (Agency for Spatial Planning and Urbanism). This violated the legal obligation to present the Draft in question to the public, so it is difficult to consider that the entire public review was held within the framework prescribed by law. 

How should we react, if we don't know what to do sve do we react?

The documentation related to this plan that was highlighted during public inspection was neither complete nor accessible to the general public. First of all, only the textual and graphic parts of the plan were published, while the supporting documentation of the plan was completely omitted, and thus the public was prevented from gaining a full insight and understanding of the proposed planning solution. Also, in the graphic part of the documentation, the territory of the plan is quite unnecessarily divided into 13 parts (different files that are not uniformly formatted), and without expert knowledge, it was completely impossible to see the scope of the plan as a whole. 

Also, considering that a public inspection of one in a series is being organized PHASE of the plan in question, complete insight into the planning documentation and the possibility of understanding the planning solutions proposed in the last phase also require insight into the overall documentation of all the already adopted previous phases, which again it is not available to the public. The textual parts of the previous three phases of the plan were published in the Official Gazette of the RS after its adoption, which if you want to read, you have to pay between 30.000 and 50.000 dinars per year. And the graphic parts cannot be seen, because the Central Register of Planning Documents (which is defined by law as the place where all adopted plans in the country are publicly published in electronic format) has not existed for 3 years already. It directly reflects the motivation (or lack thereof) to provide the public with all the necessary information in an accessible way in order to react to the plan - we remind you, the one that is from national importance!

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Instead of applying nthe principles of public participation from Article 3 of the Law on Planning and Construction, as well as the principles of public participation and partnership from Article 3 of the Law on the Planning System ("Official Gazette of RS", No. 30/2018), which implies that when determining public policies, care must be taken "to enable the realization of individual legal and other interests of all interested parties and target groups", for this plan it seems that the determination is quite the opposite - to avoid these principles as much as possible.