REALESTATE ADMINISTRATION DEPARTMENT Oktobarske revolucije 1/V, PC Čelebić Podgorica

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MONTENEGRO GOVERNMENT OF MONTENEGRO AGENCY FOR ENVIRONMENTAL PROTECTION 02 No: UPI 1907/6 Podgorica, April 6, 2010 REALESTATE ADMINISTRATION DEPARTMENT Oktobarske revolucije 1/V, PC Čelebić Podgorica Attached to this memo, as to a holder of the project, we submit the decision by which is determined that no assessment of the environmental impact is necessary for construction of business premises building of the Real Estate Administration Department of Montenegro, which will be, according to the plans built on the urban plot number 2, cadastral plot No. 4534 / 7 KO Podgorica III, Block 1, covered by a detailed urban plan, "Storage service zone" the amendments and additional changes. DIREKTOR Daliborka Pejović Delivered to: Real Estate Administration Department, Oktobarske revolucije1 / V, PC Čelebić, Podgorica Public record on conducted environmental assessments Ecological Inspection

MONTENEGRO GOVERNMENT OF MONTENEGRO AGENCY FOR ENVIRONMENTAL PROTECTION 02 No: UPI 1907/6 Podgorica, April 6, 2010 Agency for Environmental Protection, according to the Article 13 of the Environmental Impact Assessment Law (Official Gazette of MNE No: 80/05) and Article 196 of the Administrative Procedure Act (Official Gazette of MNE No: 60/03), in the procedure of considering the necessity for environmental impact assessment of the construction of the office building for Real Estate Administration Department of Montenegro, whose completion is planned on urban plot No. 2, cadastral plot No. 4534/7 KO Podgorica III, Block 1, and it is covered by detailed urban plan Storage Service Zone in the amendment, conducted based on the request of the project holder, the Real Estate Administration Department of Montenegro, from 16.03.2010, has adopted the following: DECISION I It is established that no environmental impact assessment is needed for the building of the new offices for Real Estate Administration Department of Montenegro, whose completion is planned on urban plot No. 2 cadastral plot No. 4534 / 7 KO Podgorica III, Block 1, covered by Detailed Urban Plan Storage service zone the amendment. II Project holder, the Real Estate Administration Department of Montenegro, can begin with the project implementation, in accordance with mentioned technical norms and standards prescribed for this type of structures, with a requirement that when conducting construction and usage of facilities, following protective measures need to be provided: During the works, prevention of spreading the building materials and waste i.e. properly collected and disposing of generated waste on the approved location; In the case of spill oil and fuel into the soil during operation of construction machinery, it is necessary to make restoration or remediation of contaminated areas; During the construction and project implementation, it is necessary to comply with the measures of temporary restrictions established by the Law on Protection against noise (Official Gazette of MNE No. 45/06); Collection of waste materials and providing space for special containers for their temporary storage in accordance with the law.

III The Project holder is obliged to show this solution to the processor of technical documentation in order to comply with measures mentioned above when preparing technical documentation and verify the same in the process of technical review of the project and inspection of the facility. IV it is obligation of the project holder, the Real Estate Administration Department of Montenegro, in the case of reconstruction of facility in order to expand capacities or change the purpose of the object, submit a request to the competent authority to decide on the need for assessment of environmental impact. EXPLANATION Project holder, the Real Estate Administration Department of Montenegro, on the day March 16, 2010 addressed the Agency for Environmental Protection, as a relevant authority with a request No: 02 UPI 1907 / 1, to decide upon the need of conducting environmental impact assessment for construction of the office building for the purposes of Real Estate Administration Department of Montenegro, whose completion is planned on the urban plot No 2, cadastral plot No. 4534 / 7 KO Podgorica III, Block 1, covered by a detailed urban plan Storage service zone in the amendment. Enclosed to the application is a documentation which is prescribed by the Regulations on the content of documents which is to be submitted together with an application for the assessment of environmental impact (Official Gazette of MNE No. 14/07). After examining the list of projects which is a part of the Regulation on projects for which environment impact assessment is done (Official Gazette of MNE No. 20/07), it was determined that the planned project is in the List II number 12 (b), for which the assessment process is conducted by the decision of the competent authority. After considering the application, the Agency for Environmental Protection, noted that the present application contains information relevant for decision making. Acting at the request of the project holder, according to the provisions of Article 12 of the Environmental Impact Assessment Law (Official Gazette of MNE No. 80/05), Agency notified interested parties, organizations and the public that it has organized public insight and provided availability of data and documentation of the project holder. During the deadline which was set for this purpose, insight into the relevant documentation is done by the representatives of the Secretariat of Planning and Spatial Development and Environmental Protection of the Capital city of Podgorica, followed by an opinion of the same institution delivered by No. 08 353/10 36 / 1 of March 31, 2010 in which it was stated that the project it may not be required elaborate on environmental assessment. Considering the requirement of the project holder and data on the location, characteristics and possible impacts resulted by the project implementation on environment, Agency has determined following: This project envisages construction of office building of the Real Estate Administration Department of Montenegro, whose realization is planned on urban plot No 2, cadastral parcel No 4534/7 KO Podgorica III, Block 1, covered by Detailed Plan urban plan Storage Service Zone in the amendment. Land surface area is 2449.58 m2. Terrain is suitable for building, it is stable, filtered with a low level of ground water

and flat or slightly tilted (from 0.5 to 0.8%) from northeast to southwest. In the vicinity of the planned building there are a larger number of storage objects, mega market Mercator and Belgrade Bar railway. In surrounding there are objects of housing and commercial purpose, buildings, fire station, car market, "Impek" and "Plantaže". When considering micro location, plot is accessible from the road to Tuzi under the underpass. On the location there are no wetlands. This site does not belong to protected area in any way. Office building of the Real Estate Administration Department of Montenegro has been designed for 2S + P + 5 levels (2 underground floors, ground and five above ground floors for commercial purposes). The basic purpose of this building is the administration business. Ground floor of the building is 2967.87 m2, floor BGP is 5678.63 m2, i.e. total of 8646.50 m2 approx. The ground floor has rooms designed for public service, working with clients and visitors, and it is suitable for persons with special needs. Functionally, it is separated from the Real Estate Branch Office, Podgorica, with separate entrances, rooms and desks for providing services, as well as related supportive departments and offices. Floors are organized and designed as a modern flexible office working space, suitable for the demands of much different content, with the possibility of diverse, changeable and flexible functional organization. Garage for Department employees is resolved and projected in the garage at the Basement 2. The capacity of the garage is 40 places, of which two for disabled persons. Access to the building premises and departments is provided for the persons with special needs, equipped with vertical and horizontal communication, as well as with access to sanitary block (on the ground floor) with an appropriate equipment for its use. The facility will be provided with plumbing and sewage systems, high and low voltage, fire alarm installations and mechanical installation of air conditioning and ventilation. It is planned that building will be connected to the city traffic, electricity, and water and sewer system. Building connections on the existing infrastructure network (water supply and sewerage, electrical installation and telecommunication) were performed in accordance with the terms of relevant companies. Possible washing floors will be performed in garage with wet rotary brush for cleaning and dry wash of the floors. Taking into account the available documentation and data on the characteristics of the planned project and the location, valid technical norms and standards prescribed for the construction, usage and maintenance of these types of facilities, and suitable protective measures set under II of the this solution; no significant negative impact on environment is expected during the construction. Bearing in mind the previously mentioned, the Agency for Environmental Protection, on the basis of considering request of the Project holder, review of the documentation submitted and with the application of the provisions of Article 13 and Article 5, paragraph 1, item 2 of the Environmental Impact Assessment Law (Official Gazette No. 80/05) and paragraph 196 of the Administrative Procedure Act (Official Gazette No. 60/03) has decided following: This decision prescribe measures to prevent possible harmful environmental effects during construction and utilization of business premises building and order to the Project holder/applicant to forward this decision to the processor of the technical documentation, so these measures may comply with technical documentation prepared and verified in the process of technical control of the project and inspection.

Also, by this decision, obligations of the project holder is determined that in the case of changing the purpose of the building or expansion of capacities, is to submit a request to a relevant body to decide on the need for assessment of environmental impacts. Legal Notes: This decision is final in administrative procedure and filling a complaint is not possible, but it can resort to the dispute before the Administrative Court of Montenegro within 30 days of receipt of the decision. DIRECTOR Daliborka Pejovic Delivered to: Real Estate Administration Department, Oktobarske revolucije1 / V, PC Čelebić, Podgorica Public record on conducted environmental assessments Ecological Inspection