First Draft - Capacity Assessment Report MNE Institut - M.Marković

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Enhancing Montenegro’s Capacity to Integrate Climate Change Risks into Planning

Capacity Gap Assessment Report


Public Sector Institutions

Draft, March 2022

Table of Contents
1 Capacity assessment process .......................................................................................................... 3
2 The main findings ............................................................................................................................ 4
2.1 Institute for Hydro-meteorology and Seismology .................................................................. 4
2.2 Public Health Institute............................................................................................................. 6
2.3 Ministry of Health – Public Health Directorate ....................................................................... 8
2.4 Biotechnical Faculty ................................................................................................................ 9
2.5 Ministry of Agriculture, Forestry and Water Resources – Directorate for Agriculture ........ 12
2.6 Ministry of Agriculture, Forestry and Water Resources – Directorate for Water Resources,
and Water Administration ................................................................................................................ 13
2.7 Ministry of Ecology, Spatial Planning and Urbanism – Climate Change Department .......... 15
2.8 Ministry of Internal Affairs – Directorate for Protection and Rescue ................................... 17
2.9 Ministry of Ecology, Spatial Planning and Urbanism – Department for Integrated
Management of Marine and Terrestrial Ecosystem and Sustainable Development Unit ................ 19
2.10 Environmental Protection Agency ........................................................................................ 21
2.11 Podgorica Municipality ......................................................................................................... 22
2.12 Environmental Protection Fund ............................................................................................ 24
2.13 Investment Development Fund ............................................................................................ 26
2.14 Foreign Investment Agency .................................................................................................. 27
2.15 Statistics Administration Monstat ........................................................................................ 28
2.16 Regional Park Piva ................................................................................................................. 30
2.17 Marine Biology Institute ....................................................................................................... 31
2.18 Association on Municipalities ............................................................................................... 33

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2.19 Ministry of Agriculture, Forestry and Water Resources – Payments Directorate ................ 34
2.20 Pluzine Municipality .............................................................................................................. 36
2.21 Ministry of Economic Development and Ministry of Health – Directorate for Tourism
Development Policies and Health Tourism Department .................................................................. 37
2.22 Ministry of Agriculture, Forestry and Water Resources – Forestry Directorate ................... 38
2.23 Public Enterprise Morsko dobro............................................................................................ 40
2.24 Ulcinj Municipality ................................................................................................................ 42
3 Conclusions and recommendations .............................................................................................. 43
Annex 1: Overview of the assessment meetings .................................................................................. 48
Annex 2: Questionnaire used for the capacity gap assessment ........................................................... 49

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1 Capacity assessment process
The capacity assessment process presented in this report was carried out in the framework of the
project Enhancing Montenegro’s capacity to integrate climate change risks into planning – Outcome
1: Adaptation planning governance, institutional coordination, and technical capacity strengthened. It
encompasses a total of 25 public sector institutions/ their organisational units with various roles and
responsibilities, including scientific and technical ones (such as the Biotechnical Faculty, Marine
Biology Institute, Institute for Hydro-meteorology and Seismology), as well as institutions providing
financial support (such as investment and environmental funds) and public administrations bodies at
national and local levels. Moreover, the assessment included one protected area manager and an
association of local self-government units (municipalities). Only two out of 27 approached institutions
did not express interest1 for taking part in the assessment.

The assessment process and identification of gaps was conducted based on a predefined set of
questions, aimed at rating respective capacities as low (grade 1), basic (grade 2) or strong (grade 3). A
set of criteria describing each of these capacity levels were developed for all of the seven capacity
elements2 assessed. For majority of the questions, three statements (corresponding with grades 1 to
3) were articulated and offered for discussion, whereas appropriate scores were assigned for provided
answers (1 denoting low capacity). Moreover, a number of questions requiring descriptive answers
was included to collect more detailed information. The applicable questions were discussed and
appropriate answers agreed upon between the representatives of the assessed institutions and the
local consultant conducting the interviews; additional information was provided whenever relevant.
The questionnaire used for the assessment (as developed by the Project’s international consultants)
is presented in Annex 2.

In total, 63 individuals took part in the assessment interviews held in the period December 2021 –
February 2022. Two interviews were held online, the remaining 23 through direct communication. An
overview of the interviews held is presented in Annex 1. Organisation of the meetings in the first
couple of months of 2022 coincided with the period of peak incidence of covid-19 infections in
Montenegro, which had an impact on the time span and frequency of the meetings, contributing to
certain deferrals in the process.

In addition to the interviews and structured questions used to assess institutional and individual
capacities for climate change adaptation (CCA), the overall assessment of capacity gaps included a
review of the key legislation, plans and strategies guiding the work of the 25 surveyed institutions.
Results of this part of the analysis are presented in a separate report,

The main findings of the capacity gap assessment are presented in Chapter 2 of the present report,
addressing (for each of the 25 examined institutions):

a) Mandates, organisational structure and the key relevant legislation/ strategic documents;
b) Results of the capacity assessment;
c) The main capacity gaps and needs.

Conclusions and recommendations are presented in Chapter 3.

1
These were Ministry of Finance and Social Support, and Public Enterprise National Parks of Montenegro.
2
1) Governance and policy capacity; 2) Leadership and organisational capacity; 3) Strategic planning capacity; 4)
Data, information and analysis capacity; 5) Human resources capacity; 6) Financial resources capacities; and 7)
Implementation, monitoring and evaluation, and knowledge management capacity.

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2 The main findings

2.1 Institute for Hydro-meteorology and Seismology


Two interviews were held – on 10 and 17 December 2021 – bringing together staff from several
sectors/ departments of the Institute for Hydro-meteorology and Seismology (IHMS). The discussions
showed that capacities for CCA in the Department for applied meteorology and climate change were
deemed somewhat higher compared to other departments. Consequently, two questionnaires were
completed and the results are presented in the subsequent paragraphs separately for the Department
for applied meteorology and for the rest of the IHMS.

Description of the institution

IHMS is a public administration body operating in line with the Law on hydro-meteorological activities
(OMG 026/10, 040/11, 030/12), providing scientifically based warnings, forecasts and weather and
climate data, information on the state of atmosphere and water – all in order to protect natural and
man-made assets and contribute to sustainable development. The Law on the protection from
harmful effects of climate change (OGM 073/19) is also relevant for the IHMS work, in particular for
CCA activities. The Law on hydrographic activities (OGM 026/10, 040/11, 030/12) refers to the relevant
activities/ parts of the Institute too. The functional roles and responsibilities of individual departments
are regulated under an internal act on the institution’s organisational structure.

The Institute comprises four organisational units/ sectors dealing with: 1) meteorology and air quality;
2) hydrology and water quality; 3) hydrography and oceanography; and 4) seismology. The capacity
assessment was conducted for all but the seismology sector of the IHMS. With the exception of the
Department for applied meteorology and climate change, engagement of the IHMS in CCA activities
in the so far period was rather limited. Nevertheless, the Institute is seen as an indispensable link and
source of data for planning and implementing adaptation measures and activities. At the same time,
it is recognised that the existing activities need to be re-shaped and adjusted to ensure its data,
products and analyses provide an adequate basis for modern and targeted adaptation planning.

In 2021, a total of 125 work positions were envisaged3 for the entire IHMS (including, for example,
staff of the local meteorological stations). Around one fifth of this number was employed in the
departments involved in the assessment (departments for applied meteorology and climate change,
air quality, water quality, hydrological monitoring, and hydrography).

Capacity assessment

The overall capacity of the IHMS was assessed as low to basic, with the average score of 1.75 for the
Department for applied meteorology and climate change and 1.54 for the Institute as a whole. The
lowest scores (indicating substantial capacity gaps) were recorded as regards financial resource and
capacities for the design and implementation (the latter looking in particular at whether planned
climate change adaptation actions are implemented, climate services/ goods provided and targeted
stakeholders/ constituents are benefitting from such actions). The overall IHMS capacity to design and
implement effective CCA services and programmes received the score of 1.07, whereas the score of
the Department for applied meteorology was somewhat higher but still weak – 1.14. Financial
capacities for both the institution as a whole and the assessed Department had a low score (1.2) too.
The score lower than 1.5 was also recorded for the entire IHMS in respect to the governance and
policy capacity, assessing, for example, whether there is a clear mandate for CCA/ is adaptation

3
The figure includes vacant positions so the number of staff is somewhat lower.

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explicitly incorporated in the organizational structure and polices, what are links with relevant
international and European policies, and similar. The Department for applied meteorology and climate
change is the only organisational unit of the IHMS that has climate change adaptation and vulnerability
assessments specified as the core of its work, in addition to climate change projections, monitoring of
extreme weather events, and application of meteorological data for agriculture.

The highest capacity scores were recorded for leadership and organisational capacity: the Department
for applied meteorology had the score of 2.25 (indicating higher than basic capacity) and the entire
Institute had the score of 1.88 (approaching the basic capacity). The relatively high average score for
leadership and organisational capacity can be mainly attributed to the fact that there are individuals
and organisational units in the IHMS that have been taking part in CCA activities for the past two
decades, which led to the Institute’s involvement in a range of projects and initiatives. This in turn
contributed to the institution’s recognition as an important factor in CCA processes at national and
international levels, and has had a positive impact on capacity development. The Department for
applied meteorology also scored well in relation to the data, information and analysis, as well as the
monitoring and evaluation capacity (with respective scores of 1.93 and 1.83), once again as a result of
long-lasting intertest and involvement in adaptation-related projects and activities.

Part of the questionnaire related to strategic planning capacity was not completed as the IHMS does
not have a strategic plan on CCA. Adaptation was never planned as a primary/ priority activity, while
some elements relevant for adaptation were addressed through the annual work plans. The Institute
however participated in numerous planning processes at national level (such as preparation of the
National Communications to UNFCCC) as well as in various projects addressing adaptation.

Overall, it can be concluded that under the current state of the affairs and despite certain
achievements, the Institute does not have a capacity to deliver necessary data and support the
adaptation planning processes. Opportunities to change this situation exist, inter alia through the
National Adaptation Plan process and the current activities on designing and delivering a training
programme (the latter providing initial possibilities to start overcoming the identified capacity gaps).
The IHMS’s mandate for CCA has been assessed as weak, and its visibility in the relevant processes as
low, despite certain continuity and achievements on the part of individual departments and/ or staff.
Moreover, it was concluded that its regular (data collection and monitoring) activities need to be
better defined in line with contemporary trends in CCA planning, and that better interconnecting (of
the organisation, infrastructure and data) is needed.

Capacity gaps and needs

The main capacity gaps were identified as regards the mandate and prioritisation of CCA in the
operation of the IHMS, human resources (inadequate number of staff or insufficient knowledge/
skills), financial resources (lack of adequate budgetary provisions for adaptation, limited experience
with attracting/ utilising available external funding sources), and capacities to implement CCA
programmes/ services, to monitor and evaluate them and to manage/ disseminate CCA knowledge in
an effective manner.

As regards capacities to implement CCA programmes and services, significant gaps were identified in
relation to integration of socio-economic, gender and cultural issues into planning (i.e. no efforts were
identified to address these aspects in any of the so far adaptation-related activities). Similarly, debate
on Just Transition did not play an important role in the work of the IHMS and its cooperation with
various stakeholder so far. For both the Institute as a whole and for the Department for applied
meteorology and climate change, low capacities i.e. significant gaps were identified in relation to the

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need to assign clear timelines, responsibilities, and resources for implementation of adaptation
services and programmes.

Amendments of the relevant legislation (to define the IHMS mandate for CCA more precisely) and
strengthening of human resources are necessary to improve the organisational and individual
capacities of the Institute. This especially as IHMS is a multidisciplinary organisation that generates a
lot of data but needs to use it in a better way to strengthen its position in the processes related to
adaptation. Lack of general definitions or specifications of data which are important for adaptation
planning is also seen as a gap that affects capacity development in a negative way. It is expected that
improvements in this area will be made as the list of CCA indicators is agreed upon and developed,
which will in turn enable the IHMS to organise and/ or adjust the data it produces to better suit the
adaptation planning needs.

Trainings are first of all needed to increase general knowledge on CCA and adaptation plans.
Moreover, capacity building on the types of measurements and observations needed for adaptation
planning (in the areas of responsibility of the IHMS, such as meteorological and hydrological data),
including on how the data generated through the Institute’s regular activities could be used in the
adaptation context, would be also very useful. Moreover, there is a need for training and information
sharing on the potential CCA indicators (including relevant EEA and SDGs indicators). As regards the
more specific capacity development needs and topics, communication and advocacy for adaptation
was also mentioned through the assessment process. Other topics that emerged from the assessment
interviews include adaptation programmes and services for agriculture, green infrastructure and
others. The need for a strategic planning and delivery of trainings was emphasised, taking into account
to the institution’s tasks and resources. Trainings should include practical examples whenever
possible.

2.2 Public Health Institute


The assessment interview was held on 16 December 2021.

Description of the institution

The key piece of legislation regulating the work of the Public Health Institute (PHI) is the Law on the
protection of health (OGM 003/16, 039/16, 002/17, 044/18, 024/19, 008/21); responsibilities are
further detailed through the Statute and the Rulebook on internal organisation of the PHI. These acts,
however, do not define the PHI mandate for climate change adaptation and do not include any
references to adaptation. Nevertheless, the PHI has been consistently involved in the preparation of
National Communications on Climate Change and is recognised as an important national actor for
provision of relevant data and analyses of potential impacts of climate change on health. Involvement
in CCA activities was further strengthened through cooperation with the World Health Organisation
(WHO) and its Working Group on Health in Climate Change (HIC) of the Environment and Health
Process (EHP) in Europe, in which the Institute is represented.

The climate change-related topics and activities are covered through the engagement of the PHI
Centre for health ecology (with a staff of around 40); the Centre for prevention of diseases also
contributes/ takes part in some activities. Staff members of the Centre for health ecology have been
coordinating and leading the adaptation work of the PHI (nationally and internationally) and have
taken part in the present assessment.

On behalf of the PHI, staff of the Centre for health ecology has been contributing to the National
Communication processes, taking part in a range of CCA-related projects and initiatives, including

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international ones, and cooperating (together with other relevant institutions) on the development of
analyses, tools (such as bio-meteorological forecasts4 and warnings), programmes and awareness
raising activities to address health effects of climate change. With the assistance of the WHO, the
Centre played a lead role in the preparation of the Programme of health system adaptation to climate
change 2020 – 2022 with Action Plan for the period 2020 – 2021. A range of health system actors took
part in developing the Programme and its Action Plan, including the Ministry of Health, Health Centres,
Emergency Units and others. As a part of the Action Plan, capacity assessment was envisaged. The
implementation of the Programme was unfortunately halted due to the outbreak of covid-19.

For the future CCA activities in the health sector, capacity development is deemed necessary, in
addition to improved cooperation with the environmental institutions and better overall coordination,
possibly through the National Council on Sustainable Development (where health sector needs to be
represented). It would be also useful to link the health CCA activities to the process of harmonisation
with the relevant EU policies (to step up the implementation and facilitate capacity development).

Capacity assessment

With the overall score of 1.4, capacity of the Public Health Institute (Centre for health ecology) for CCA
can be evaluated as low. Exceptionally, results of the assessment indicated the Institute achieved or
approached basic capacity as regards its ability for strategic planning and knowledge management
(with respective scores of 2.0 and 1.8). Conversely, the scores for leadership and organisational
structure (1.38), data, information and analysis (1.36), human (1.29) and financial resources (1.17) all
indicated low capacities. Similar to the situation with the Institute for Hydro-meteorological and
Seismology, the lowest score was assessed for the organization’s budget and access to finance for
addressing CCA issues. As regards human resources, the score of 1.29 means that the organisation
lacks people tasked with CCA and/ or relevant individual skills, whereas availability of adequate
training programmes is low. The interviewed staff (who lead all the CCA-related activities in the
Institute and act as informal focal points) assessed they used 5 – 10% of their time on adaptation tasks
and responsibilities. The situation is partly due to the fact that adaptation to climate change has long
been considered as an area of work where the environmental institutions played a key role.

Despite the fact that strategic planning capacity has been advanced through the process of
preparation of the Programme of health system adaptation to climate change 2020 – 2022, the plan
is not implemented, i.e. it does not guide management decisions and operational planning. As
mentioned before, covid-19 pandemic brought new priorities for the health sector and has had a
negative impact on the status of the Programme’s implementation.

Other areas where the PHI scores indicated stronger capacities (approaching basic levels) were
primarily for implementation, monitoring and evaluation, and knowledge management. This came as
a result of activities (implemented through various projects, for example GiZ and UNDP projects)
aimed at awareness raising and/ or provision of different CCA services, such as warnings,
recommendations on how to behave during heat waves, and similar.

Capacity gaps and needs

The Institute lacks a formal mandate for CCA. Despite some achievements in CCA planning and good
practices in delivering adaptation services5, there is a strong need for capacity development,

4
Efforts were made in the previous period to develop such forecasts, but were not finalised. Meanwhile, the
attention shifted to other tools and the work on the bio-meteorological forecasts was dropped.
5
For example, through cooperation with the IHMS on the warning system for extreme weather events with
information on potential health impacts and appropriate advices.

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integration of environment, climate and health data and improved coordination. Support for more
attention being paid to adaptation activities in the health sector (which is a starting point for capacity
development) could be inter alia provided through the work of the National Council on Sustainable
Development and engagement of health sector decision-makers in the relevant process. Development
of the National Adaptation Plan is also seen as an opportunity to improve coordination and strengthen
capacities.

Trainings would be in particular useful for processing of health data and improvements in
methodologies to analyse health statics (data on illnesses and deaths) for climate-related infectious
diseases, and methodologies to assess the impacts of climate change and health vulnerabilities. In the
previous period efforts have been made to address some of the gaps of relevance for CCA. For
example, there were attempts to analyse death statistics in relation to meteorological data/ heath
waves, but there were no significant moves forward due to weaknesses in the ways causes of death
are recorded, whereas Emergency Units protocols proved to be insufficient for extraction of necessary
data and analysis.

Efforts to implement a new information system for the Emergency Units and Emergency Room Centre
are underway, and this represents an opportunity for improving the use of health statistics for
adaptation purposes. Trainings for the leading people of the Institute, Ministry of Health and directors
of all the hospital on these topics would be very useful. Bilateral cooperation and transfer of good
practices is important and needed. Trainings for media would be also useful, to ensure information on
health and CCA is better communicated to population.

2.3 Ministry of Health – Public Health Directorate


The assessment interview was held on 17 December 2021. Due to other pressing priorities and earlier
involvement of the Public Health Institute in the CCA activities6, representatives of the Directorate
recommended that the views of the PHI are taken as representative for the assessment of capacities,
gaps and needs in the health sector in general. Moreover, it was recommended that the Department
for the development of health tourism (of the Ministry of Health) should be involved in the assessment
for the tourism sector, together with the Tourism Directorate of the Ministry of Economic
Development. Finally, answers were provided for a limited number of questions from the assessment
questionnaire, mainly referring to the governance and policy (given the fact the Ministry has an overall
responsibility for public health policies and coordination in the health sector).

Description of the institution, capacity assessment, gaps and needs

Public health Directorate7 of the Ministry of Health (MH) covers a wide range of public health issues
with limited human resources. Department for public health (as one of the Directorate’s
organisational units), for example, has a staff of four. Responsibilities of the Directorate are primarily
defined through the Law on the protection of health (OGM 003/16, 039/16, 002/17, 044/18, 024/19,
008/21). Other relevant legislation includes the Law on mandatory health insurance and public
administration laws and regulations. Mandate for CCA is not explicitly defined but can be derived from
the mandate to protect public health in general; some responsibilities are outlined in the relevant
plans and programmes.

6
Including preparation of the Programme of health system adaptation to climate change 2020 – 2022.
7
Full name is Directorate for public health, prevention of misuse of drugs and other psychoactive substances,
precursors and cosmetic products.

8
During the past few years, attention of the MH – Public health Directorate – has been fully dedicated
to the preparation of a range of action plans (ten in total) for different policy areas under its
competence and their implementation and monitoring. Examples include rare diseases, mental
health, HIV/ AIDS and other action plans. Preparation of an action plan for vector-borne diseases is
foreseen. Programme of health system adaptation to climate change 2020 – 2022 has been prepared
under the leadership of the Public Health Institute, but its implementation has not stared due to other
pressing priorities and insufficient capacities.

The Programme has defined the health sector mission in relation to CCA and has set the following
overall and operational goals:

Mission: Creation of a national framework for the development of capacities for adaptation
and resilience to climate change related risks
Overall goal: Reduce vulnerability and advance adaptation measures to decrease negative
effects of climate change on human health and increase readiness of the entire
health system to respond to challenges
- Protection of human health from undesired effects of climate change
through multi-sectoral response, mainstreaming of health into all policies
- Management of risks from extreme climate events
- Reducing morbidity and mortality from infectious diseases attributed to
Operational climate change
goals: - Generation of evidence on health impacts of climate change at national and
sub-national levels through research and studies
- Raising public awareness on climate change and its impact on health
- Planning, assessment of risks, preparation and maintenance of health
system readiness for potential natural disasters caused by climate change

Based on the provided answers, the MH’s capacity for CCA has been assessed only for the governance
and policy segment of the overall capacities. The score of 1.39 indicates a low capacity as the
organisation (Public health Directorate of the MH) does not have a legal requirement to address
climate change adaptation, potential responsibilities for CCA are not well-known to staff members
and relevant stakeholders, and CCA is not prioritised in the decision-making and operational work.

The main gaps refer to the fact that the mandate for CCA is not defined through the regulatory
framework, and to insufficient capacities. Responsibilities are nevertheless deriving from the
Directorate’s lead role in protecting public health and from the Programme of health system
adaptation to climate change 2020 – 2022. It is therefore necessary to capacitate this institution to
assume a lead role in creating and implementing CCA measures and activities in the health sector,
supported (on a technical level) by the PHI that has already developed certain capacities in this area.

2.4 Biotechnical Faculty


The assessment interview was held on 20 December 2021. Biotechnical Faculty (BTF) staff
participating in the interview (teaching/ scientific staff) was only able to provide answers for half the
questions of part 6 of the questionnaire (on financial resources). For part 7 (on implementation,
monitoring and knowledge management), interviewees were able to provide answers to just a few
questions, which made the scoring redundant; some qualitative analysis is provided instead, in
particular for the knowledge management questions. Part 3 was not completed due to the fact that
BTF does not have a written plan or strategy on CCA.

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Description of the institution

Biotechnical Faculty (BTF) is a part of the University of Montenegro and its operation is regulated
under the Law on high education (OGM 044/14, 052/14, 047/15, 040/16, 042/, 071/17, 055/18,
003/19, 017/19, 047/19, 072/19, 074/20, 104/21); University Statute also applies. Development
strategy from 2020 defines the BTF mission, referring to the three main functions of the Faculty:
educational, research and advisory. Impacts of climate change on agriculture are referred to, but not
addressed in the BTF Strategy. In addition to the study programmes8 and laboratories, the institution
comprises several research units, including the Centre for agro-economy, Centre for forestry, Centre
for soil and amelioration, and others. Total number of staff is around 95.

Capacity assessment

The overall score of 1.36 (for the completed sections of the questionnaire) shows the Biotechnical
Faculty has low institutional capacities for CCA. Individual capacities appear to be more developed due
to personal interests and recognition of the importance of adaptation for agriculture. As a result,
efforts have been made to keep abreast with relevant knowledge and trends, to integrate some
adaptation topics into study and research programmes, and to pass adaptation knowledge to students
and beneficiaries. However, all these are taking place in an ad hoc manner, as CCA is not systematically
integrated in the BTF’s work. The institution has taken active part in all the national processes
implemented under the UNCCD, and is involved in the development of projects related to land
degradation. Moreover, the BTF has regularly contributed to policy making and planning processes
(related to soil, agriculture, forestry) in the country. Some staff/ researches have also participated in
projects, research campaigns and data collection efforts on, for example, soil and crop characteristics
of relevance for adaptation.

The highest capacity scores were recorded for governance and policy (1.5), leadership and
organisation (1.43), and data, information and analysis (1.43), where some progress towards basic
capacities has been identified. For governance and policy, this can be mainly attributed to the
involvement (of BTF staff) in the relevant international policy processes, good cooperation with a
range of stakeholders and continuous efforts (which occasionally focus on adaptation) to pass the
knowledge gained through scientific and research work to those who can apply it in practice. The
management capacity and knowledge for CCA exist in the BTF, but further development is needed to
reach basic (and eventually strong) levels. Impetus for the development of data and analytical
capacities has been provided through participation in a range of projects (e.g. LUCAS9 project
implemented by the European Joint Research Centre for soil), as well as through preparation of
sectoral studies and national reports on agriculture (supported by FAO, GiZ and other organisations).

For human and financial resources, the assessment showed low level capacities with scores of 1.3 or
lower. This means that the number of staff with relevant knowledge and skills – at leadership,
management, and technical levels – is inadequate and that they are not addressing climate change
adaptation issues in an effective manner. Being a part of a public University, BTF’s budgets are created
in line with standard procedures where the bulk of resources comes from the state budget. Project-
related funds and earnings (from commercial services of the BTF) also contribute to the overall budget.
Like in case of other assessed institutions, there are no budget lines specifically dedicated to
adaptation activities in the BTF’s budgets.

8
Including, for example, plant production, animal husbandry, applied agriculture, food safety, agro-business and
rural development, etc.
9
Land Use/Cover Area frame statistical Survey.

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Biotechnical Faculty did not have direct experience with creation and implementation of adaptation
programmes or services, despite the fact its activities are in various ways touching upon CCA topics.
The institution/ its staff collect data of relevance for adaptation planning (e.g. data on the content of
organic carbon in soil); however, this data is not systematically organised and is mainly shared through
direct, personal contacts. As regards awareness raising activities, the BTF engages in them through,
for example, provision of presentations or lectures on the impacts of climate change on agriculture,
and extension of advices to agricultural producers.

Capacity gaps and needs

Significant gaps have been identified through the assessment process and there is a strong need to
build upon the existing achievements and improve significantly BTF’s capacity to assume a more
prominent and more effective role in the development and implementation of CCA measures in
agriculture. With the BTF’s main function being education, primary interest is for the development of
educational tools that could be used to pass the adaptation knowledge to students. Sharing of
experiences with other universities and training on how to integrate adaptation topics into the BTF’s
curricula would be welcome.

Another important gap (within the institution as well as for the country as a whole) is related to the
lack of information system comprising detailed data needed for the assessment of vulnerabilities and
for planning of agriculture adaptation measures. Trainings are necessary to better understand
different possibilities offered through the information systems as well as on data collection needs (e.g.
whether it would be necessary to develop a network of agrometeorological stations). Trainings on the
use of different models (projecting, for example, how different crops behave under various climate
scenarios) would be also beneficial for the development of BTF’s capacities.

Moreover, strengthening of organisational and leadership, as well as of skills and capacities to attract
additional financial resources are needed. At the same time, it is necessary to expand the pool of
teaching and research staff interested/ involved in CCA activities. This can be achieved through
knowledge sharing and training programmes, through exchanges and study visits including
possibilities for the BTF PhD students to spend time at universities and research institutes that have
advanced adaptation programmes and services.

As regards planning and implementation of adaptation measures, it would be important to strengthen


cooperation with the Ministry of Agriculture, Forestry and Water Resources and other relevant
stakeholders on the development of Green Climate Fund projects10 and formulation of specific
adaptation measures to be supported through agro-budgets and/ or projects providing direct
assistance to agricultural producers.

The format of the trainings should allow for flexibility as the time/ availability of potential BTF
attendees may be limited. To this end, preparation of online courses (that could be attended at the
time suitable for participants) should be considered. For scientific and research work – visits to other
universities, knowledge and research centres would be a useful and effective form of capacity building.

Preparation of the National Adaptation Plan is seen as an important opportunity to reinforce strategic
priorities identified in the Land Degradation Neutrality (LDN) report and to provide for structured,
longer-term capacity building work for the BTF and other agricultural stakeholders for CCA.

10
Project concept note that is currently being prepared, refers, among other things, to the need for the
information system development.

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2.5 Ministry of Agriculture, Forestry and Water Resources – Directorate for
Agriculture
Interview with representatives of the MAFWR’s Directorate for Agriculture was held on 17 December
2021. Despite the fact that that some aspects of climate change adaption have been addressed in the
key strategic documents for agricultural sector (Strategy for Agriculture and Rural Development and
IPARD11 Programme), section 3 (on strategic planning) of the questionnaire was not completed as for
majority of questions, the interviewees were not able to provide relatable information. Part 7 of the
questionnaire was not completed for similar reasons: interviewees did not have enough applicable
information to answer, or found several questions were not relevant for the Directorate.

Description of the institution

The main tasks of the Directorate encompass preparation and implementation of agricultural and rural
development policies, overseeing implementation of relevant regulations, monitoring of the state of
agriculture and agro-industry, preparation of agricultural and agro-industry development
programmes, preparation of production and consumption balances for agricultural products,
cooperation with other state administration bodies and scientific institutions towards implementation
of adopted policies, and similar. The Directorate has a staff of 10.

The key legislation is the Law on agriculture and rural development (OGM 056/09) and the Law on
organic production (OGM 056/13). Decree on the organisation and the manner of work of state
administration (OGM 118/2020, 121/2020, 001/2021 i 0022/2021) and rulebooks on the internal
organisation of the Ministry also apply. The Law on agriculture and rural development does not specify
any competences of agricultural institutions for CCA, nor does it refer to climate change in general.
Effects of climate specificities are recognised in the Law on organic production but not in the context
of climate change and the need to adapt.

On the other hand, Strategy for Agriculture and Rural Development 2015 – 2020 recognizes climate
change (both mitigation and adaptation aspects) and its relevance for agriculture, considering (on a
general level) its possible impacts and setting up a strategic goal linked to climate change, primarily
mitigation. In doing so, the Strategy sets a broad mandate for the Directorate to address CC issues.
Programme for the development of agriculture and rural areas in the framework of IPARD II – 2014 –
2020 refers to adaptation by integrating one of the EU priorities in this area (transition to climate
resilient agriculture); however, it falls short of including specific adaptation measures.

Changes of legal and strategic framework are underway, with both a new law and agricultural strategy
for the period 2022 – 2027 being expected in 2022. At the time of carrying out this assessment the
draft documents (law, strategy) were not available for review, therefore it was not possible to assess
whether or to what extent will CC impacts and the need for adaptation in agriculture be integrated.
Through the accession process forums, the EU institutions recommended that all the applicable EU
documents, including the 2021 EU Strategy on Adaptation to Climate Change, are taken into account
in revising the national frameworks for agriculture.

Capacity assessment

The overall capacity score for the Directorate was 1.33 – an average of the scores for individual parts
of the questionnaire ranging from 1.19 for human resources capacity to 1.50 for financial resources
(the assessment was completed for five areas all together). Relatively high score for financial resources

11
The EU Instrument for Pre-accession Assistance for Rural Development

12
capacity can be attributed to the fact that the Directorate/ Ministry has experiences in managing
external (mainly EU) funds and that it works with an extensive network of beneficiaries/ agricultural
producers. Nevertheless, dedicated budgets for CCA activities have not been applied so far. On the
other hand, the annual agro-budgets contain financial resources for provision of support to
agricultural producers to compensate for losses borne due to extreme weather conditions.

The score of 1.39 for governance and policy part of the questionnaire is mainly due to the fact that
agriculture development Strategy and IPARD programme incorporated provisions on climate change
vulnerability and adaptation. However, further operationalisation of such general guidelines as well
as implementation are missing, hence low capacities were identified in most of the other areas (except
for financial resources where somewhat higher capacity was detected).

As regards capacity for strategic planning (part 3 of the questionnaire), the score was not derived since
specific plan on CCA does not exist, while a new agricultural strategy is being developed. The planning
processes so far were typically carried out with external expert support.

Answers were provided for just a few questions on implementation, monitoring/ evaluation and
knowledge management, which made it impracticable to come up with a quantitative assessment of
these capacities. It is worth noting, however, that gender issues have been taken into account for a
number of programmes of the Directorate (for example, diversification programme, IPARD, support
for food processing) where female producers are prioritised for support. Adaptation services were
only provided sporadically so far, through some measures that could be indirectly labelled as
adaptation ones and mainly through the work of Extension Services (which are part of the Ministry).
Extension services have a good cooperation with local level as they oversee implementation of
measures and provide advices to producers. The EU documents were identified as the most important
learning sources.

Capacity gaps and needs

The Directorate for Agriculture does not have a mandate for CCA set out in the applicable legislation,
and the tasks related to adaptation are not specified in the job descriptions for any of the positions in
the Directorate. It is necessary to adjust this to ensure adaptation tasks and responsibilities are taken
into account in the future. The ongoing revision of the Law on agriculture and rural development
represents an opportunity to that end. As the next step in capacity development, provision of trainings
would be necessary.

Availability of data is another important gap. Lack of data is a major issue in general, and for adaptation
planning as well. Better coordination and networking among relevant institutions, including
harmonisation of methodologies, is necessary in order to overcome this gap. Capacity development
activities focusing on the type of data needed for CCA planning would be welcome, and the same
applies to transfer of experiences for the development and implementation of adaptation measures
in agriculture.

2.6 Ministry of Agriculture, Forestry and Water Resources – Directorate for


Water Resources, and Water Administration
The assessment interview was held on 21 December 2021 jointly for the Directorate for Water
Resources of the Ministry of Agriculture, Forestry and Water Resources (MAFWR) and for Water
Administration (WA). The two institutions have a shared mandate (defined under the Law on waters)
and the key role in formulation and implementation of water policies, therefore harmonised answers
were provided and the assessment results presented herewith refer to both institutions.

13
Even though there is no specific plan for adaptation for water resources, part 3 of the questionnaire
(on strategic planning) was completed having in mind Water Management Strategy and draft River
Basin Management Plans, which address climate change to a limited extent. For parts 6 of the
questionnaire (on financial resources) and in particular for sections 7.1 (on the design and
implementation of CCA programmes and services) and 7.2 (on monitoring and evaluation),
interviewees were only able to provide few answers; section 7.3 on knowledge management was
completed but the overall score for part 7 was not derived (due to a low number of answers for
sections 7.1 and 7.2) and was consequently not taken into account for the overall score.

Description of water management institutions

The Law on waters (OGRM 027/07, OGM 073/10, 032/11, 047/11, 048/15, 052/16, 055/16, 002/17,
080/17, 084/18) and the Law on financing of water management (OGM 065/08, 074/10 i 040/11) are
the key legislation guiding the work of the Water Directorate of the MAFWR and Water
Administration. Other regulations pertinent for the work of the two assessed institutions include the
Decree on the organisation and the manner of work of state administration (OGM 118/2020,
121/2020, 001/2021 i 0022/2021) and rulebooks on their internal organisation.

The MAFWR Water Directorate has the overall responsibility for water management policy. It
proposes systemic solutions to provide for the use, protection of waters, and protection from harmful
impacts of waters, as well as relevant regulations, plans and programmes. The Directorate is also
responsible for monitoring the state of water resources and for adoption of necessary water
management measures. A total of eight positions are envisaged within this organisational unit of the
MAFWR, whereas current number of staff is four.

Water Administration is tasked with implementation of water management policies, including water
and watercourses management works and measures, measures to protect waters and measures to
protect from harmful impacts of waters. The WA issues water permits and oversees the use of water/
materials from watercourses. Establishment and keeping of water information system is another
responsibility of the WA, alongside with monitoring, international cooperation and staff capacity
development. At the moment, seven out of 18 envisaged positions in the WA are filled; moreover, the
WA work is currently aided by an expert seconded to the institution through international
cooperation.

In addition to the applicable laws and regulations, scope of work of the public administration
institutions tasked with water management is further elaborated through the Water Management
Strategy. Climate change is only touched upon in the Law on waters, which requires that CC impacts
on flooding are taken into account and addressed in the flood management assessments and plans.
The goals set under the Water Management Strategy (general and operational ones) do not refer
directly to CCA but some of them incorporate topics of relevance for adaptation (for example flood
protection goals, goals relevant for irrigation, and others). The Strategy defines certain adaptation
activities for groundwater and protection from floods.

Capacity assessment

The overall score of 1.30 indicates low capacity of the water management institutions and it comes as
a result of limited human resources and limited experiences with CCA in the so far period. Low
capacities have been identified across all the assessed capacity elements – governance and policy,
strategic planning, data and analysis, human resources (where the lowest score of 1.14 was recorded)
and knowledge management. The assessment results showed situation was slightly better for financial

14
resources. Even though water management institutions did not report having dedicated budgets for
CCA activities, access to finance for addressing adaptation issues (through various projects and
cooperation initiatives12) has been assessed as reasonably favourable, which has had a positive impact
on the overall score.

Capacity gaps and needs

The assessment showed the so far priorities in the water management sector were linked to complex
tasks of implementing the Law on waters (i.e. the main requirements set under the EU Water
Framework Directive), therefore weak mandate and weak capacities for CCA have been identified.

The main gaps of relevance for CCA are related to the lack of water information system and the fact
that adaptation measures have not been developed/ integrated in the first River Basin Management
Plans (RBMPs)13. Some adaptation issues have, however, been addressed in the RBMPs, mainly in
relation to risk management. There is a need to improve the situation and update the Plans - in six
years-time (for the next cycle of river basin management planning) or even earlier, if opportunities
arise.

The causes of the current state include insufficient recognition of importance of CCA in water
resources management, lack of experience, knowledge gaps, lack of data, and similar. Climate change
adaptation is not explicitly mentioned in the description of work for any position in the two water
management institutions subject to this assessment. Generally speaking, necessary knowledge and
skills needed for adaptation planning and implementation are not found at either technical or
management positions in the Directorate and WA.

Staff, trainings and transfer of experiences on all aspects of CCA in water management are necessary.
Bilateral exchanges and twinning projects are useful and could be an important channel for delivering
capacity development activities. An example where such exchanges would be welcome is the
development of water information system. Whenever possible, it would be good to link the trainings
to specific problems encountered in Montenegro (for example, erosion at Ada Bojana) and/ or to
illustrate with cases of good practices (from the region or wider), possibly also through pilot projects.
In the previous period, the water management institutions have not been active in carrying out
awareness raising activities on CCA. For the future, it would be good to work on the development of
capacities to implement such activities, based on, for example, results of the available analyses (e.g.
analyses of the Regional Water Supply Utility on the abundance of water at Bolje sestre spring used
for water supply of the coastal area).

2.7 Ministry of Ecology, Spatial Planning and Urbanism – Climate Change


Department
The interview was held on 22 December 2021. For part 3 of the questionnaire, answers were provided
having in mind the National Climate Change Strategy by 2030 and the fact that preparation of the
National Adaptation Plan (NAP) is underway. Partial answers were provided for part 6 of the
questionnaire on financial resources, reflecting the institutional competences and type of work
performed by the Department,

12
Worth noting is the fact that the water management sector has been a beneficiary of significant EU assistance.
13
The (draft) management plans for Adriatic and Danube basins, for example, do not include any measures from
the KTM 24 category (Key Types of Measures, as defined in the Water Framework Directive Implementation
process) which refers to CCA measures for water resources.

15
Description of the institution

Climate change department operates within the Ministry of Ecology, Spatial Planning and Urbanism
(MESPU) Directorate for the EU integration, international cooperation and climate change. It is a small
organisational unit with a staff of two (with four envisaged positions). The Directorate is responsible
for the adoption of climate policy, overall organisation, coordination, implementation and overseeing
of activities related to the EU accession process (for chapter 27 on environment and climate change)
for the areas of Ministry’s responsibilities, reporting to the relevant national and international
organisations, and similar. The Directorate also has the overall responsibility for the development of
climate change mitigation and adaptation measures, cooperation with the Green Climate and
Adaptation Funds, following up on the best international practices for climate change with subsequent
proposal and implementation of measures.

In this framework, Climate change department is tasked with: preparation, monitoring and guiding
the climate policy; preparation of climate change strategies, programmes, action plans and projects;
reporting on the implementation of the national climate and adaptation strategies and other relevant
documents; preparation of climate change laws and other regulations; preparation of GHG
inventories; provision of support towards the development of low carbon and resilient economy;
implementation of the UNFCCC and Kyoto Protocol, with preparation of the National Communications
on climate change; establishment of the EU Emissions Trading System (ETS); editing and updating of
specialised portals for climate change including the MRV (monitoring, reporting and valuation) portal,
etc.

Mandate of the Department (and of the Ministry in a wider sense) for CCA is set under the Law on the
protection from harmful effects of climate change (OGM 073/19). Moreover, a range of strategic
documents and plans also apply, including National Climate Change Strategy by 2030, Third National
Communication (2020), Second Biennial Update Report on Climate Change (2019), Updated Nationally
Determined Contribution with the Report for its preparation (2021), Programme for cooperation with
Green Climate Fund 2021 – 2023, and Disaster Risk Reduction Strategy with Dynamic Plan for the
Implementation of Activities 2018–2023. These documents predominantly refer to climate change
mitigation, whereas preparation of the National Adaptation Plan is underway. Another relevant
strategic document (prepared under the lead of the Ministry of Internal Affairs) is Disaster Risk
Reduction Strategy with Dynamic Plan for the Implementation of Activities 2018–2023.

Capacity assessment

The assessment showed capacities of the Department were approaching and/ or exceeding basic
levels for a number of elements including governance and policy (with the score of 1.78); leadership
and organisation (2.19); strategic planning (1.77); and data, information and analysis (1.92). These
capacities were mainly developed through comprehensive processes of strategic documents
development and implementation monitoring, as well as through a range of projects supported by
international actors. The EU integration process and implementation of the UNFCCC requirements
often act as a driving force for the capacity development.

In the development of the CC Strategy, gender, vulnerable groups and/ or cultural specificities were
not taken into account, but some progress in this area was made through the Report for the
preparation of updated nationally determined contribution from 2021; it is expected that the NAP will
further elaborate and use data disaggregated on gender, socio-economic or cultural grounds to
address CCA needs.

16
As regards data collection and analysis, expected establishment of the MRV portal will be a significant
step forward for addressing climate change issues in general. The so far progress has been, for
example, achieved with reporting on the implementation of the CC Strategy (with two implementation
reports covering three-years periods being produced – for 2015 – 2018 and 2019 – 2021) and project-
based collection of data (e.g. the IUCN Adapt project with a regional vulnerability assessment and
work on adaptation indicators, bilateral support for the development of GIS for monitoring of
vulnerable areas, and others).

For the remaining areas for which the capacity assessment was conducted, somewhat lower scores
(ranging around 1.5) were derived indicating less progress with human and financial resources
capacities was achieved; the same applies for the capacity to design and implement CCA programmes
and services, to monitor and evaluate them, and to manage/ use gained knowledge effectively. The
staff of the Department is only able to dedicate minimal share of their time to adaptation issues,
whereas the bulk of recent work was dedicated to the establishment of the ETS scheme. Options to
open new positions and establish a separate unit for adaptation are being considered. The CC
Department provides for dissemination of climate policy-related information, reports and analyses,
for example through the website www.klimatskepromjene.me. For monitoring and evaluation tasks,
the focus is on reporting, capacities for evaluation of undertaken CC activities are still limited.

Capacity gaps and needs

Mandate of the Climate change Department of the MESPU for CCA is available, but not specified
clearly enough; the mandate is set under the Law on the protection from harmful effects of the climate
change and through the relevant strategic framework. Insufficient human (more so in terms of the
number of staff than their knowledge) and financial resources have been identified as further
significant gaps for addressing the CCA issues in the manner required under the relevant EU and
international processes.

The existing plans, programmes and adaptation services are generally not based on suitable data,
information and analysis (baseline information are often missing). Significant gaps were also identified
as regards monitoring and evaluation. Trainings were so far mainly available on an ad hoc basis, linked
to various projects and initiatives. Awareness raising activities on CCA have not been conducted so far
in an organised manner but occasionally (usually through the statements for media).

In conclusion, the most important gaps identified for the Climate change department refer to data
and knowledge on how to plan adequate adaptation policies and measures. Trainings to address these
gaps are needed, together with examples of good practices in applying the adaptation measures.

2.8 Ministry of Internal Affairs – Directorate for Protection and Rescue


The assessment interview was held on 23 December 2021. Majority of the answers (in particular for
parts 2 and 3 of the questionnaire) were provided having in mind the immediate mandate of the
Directorate i.e. disaster risk reduction where adaptation to climate change is addressed indirectly; due
to such a perspective, the derived scores predominantly reflect the institution’s disaster risk reduction
capacity and should be interpreted accordingly. The interviewee was able to provide answers to just
a few questions on availability of and access to financial resources for adaptation, therefore the score
was not derived for part 6 of the questionnaire. Parts 7.1 and 7.2 were not completed either, due to
low relevance of these sections (on the design, implementation and monitoring of CCA programmes
and services) for the Directorate’s work.

17
Description of the institution

Directorate for Protection and Rescue is a large organisational unit of the Ministry of Internal Affairs
with a staff of 170 – 180. As one of the Directorate’s organisational units, Department for Civil
Protection and Disaster Risk Reduction is inter alia responsible for preparation of national plans for
protection and rescue for different types of hazards, and international cooperation. The Department’s
staff is planned at 11.

Mandate for the Directorate’s work is set out in the Law on protection and rescue (OGM 13/07, 5/08
and 32/11), which does not refer to climate change. Consequently, climate change and/ or adaptation
planning are not integrated in the job descriptions for the Directorate’s staff. This part of the Ministry
of Internal Affairs however deals with climate change and adaptation issues indirectly – through its
responsibilities for disaster risk reduction, primarily for the risks linked to extreme weather events
(such as fires and floods).

Strategic framework for the Directorate’s work is set out in the Disaster Risk Reduction Strategy with
Dynamic Plan for the Implementation of Activities 2017 – 2023. In 2021, comprehensive Disaster Risk
Assessment was published (preparation coordinated by the Directorate, whereas the Department had
a lead role in preparing the climate change chapter included in the document). Cooperation with the
Sendai Framework for Disaster Risk Reduction14 is another responsibility of the Directorate.

Capacity assessment

Even though CCA is not explicitly mentioned in the Directorate's strategic documents, it is taken into
account in all the relevant activities, with full integration of pertinent international processes (e.g
Sendai Framework, Paris Agreement). For example, efforts have been made to develop nature-based
solutions for disaster risk reduction (DRR); such initiatives are integrated in the programme for
cooperation with the Green Climate Fund. Afforestation programme in Ulcinj (a part of the project
supported by JICA - Japan International Cooperation Agency) is another good example of combing risk
reduction and adaptation measures. Generally speaking, many measures aimed at reducing certain
risks to an acceptable level can be also labelled as CCA measures. The DRR work is contingent on
intensive cooperation and involvement of a range of stakeholders, and the Directorate has developed
quite strong capacities in this area. As regards the awareness raising activities, the ones most pertinent
to adaptation include campaigns prior to fire flooding and fire seasons as well as efforts to develop (in
cooperation with the Educational Institute) an educational programme (on floods, fires) targeting
school teachers and managers.

The capacity assessment showed that the Directorate for Protection and Rescue has reached or
approached basic capacity for all the completed parts of the questionnaire, in particular for leadership
and organisational (with the score of 2.44), and for strategic planning (2.00) capacities. Scores for
governance/ policy and for data and analytical capacities were 1.89 and 1.79 respectively. It should
be noted however that the answers leading to such scores have been provided by having in mind the
primary mandate of the institution, where the assessment refers to the Directorate's capacity to
execute its competences and address climate change from disaster risk management perspective;
answers from adaptation perspective could not be provided. At 1.97, the overall capacity score for the

14
The Sendai Framework for Disaster Risk Reduction 2015 - 2030 is the first major agreement of the post-2015
development agenda providing states with concrete actions to protect development gains from the risk of
disaster. The Sendai Framework works hand in hand with the other 2030 Agenda agreements, including the Paris
Agreement on Climate Change. DesInventar Sendai is the Sendai Framework information system that contains
disaster loss data for various countries.

18
Directorate was also rather high (at least in comparison with other assessed institutions) but it
primarily reflects the level of institutional and individual capacities for DRR.

Somewhat lower scores (around 1.7) were obtained for human resource and knowledge management
capacities, where the answers were more directly related to CCA. The Directorate was one of the few
institutions where instances of a significant share of work time being dedicated to CCA were reported;
the answer, however, referred to a limited period of time and to specific tasks (preparation of the
relevant chapter of the Disaster Risk Assessment) which were focused on adaptation issues.

Capacity gaps and needs

Lack of data represents a significant gap for planning and implementation of DRR and CCA measures
alike – a good example are insufficient data on damages collected at local level. The data that is
collected – such as data on the number of fires, floods – is not systematic and well-organised, which
diminishes its usefulness. Linking of different types of data is very important for analytical purposes
and for the development of targeted actions. National and local budget allocations are insufficient to
attain DRR and related CCA goals, and project-based funding is often used to bridge the gaps.
Cooperation with local level on CCA issues is impeded by weak capacities in most municipalities. For
this reason, it is very important that capacity building activities target local level too.

The staff of the Directorate has gained certain knowledge on CCA through international exchanges
and work on different projects but has not had the chance to attend any trainings on adaptation so
far. Further education is needed to ensure better understanding of CCA, in particular on how to
integrate adaptation in the protection and rescue plans and how to link it with DRR. The most effective
way for capacity building are direct exchanges with international partners and by learning from best
practice cases. An option of the Directorate becoming an independent institution (operating outside
the organisational structure of the Ministry of Internal Affairs) is considered, which could potentially
bring side benefits for the development of CCA capacities.

2.9 Ministry of Ecology, Spatial Planning and Urbanism – Department for


Integrated Management of Marine and Terrestrial Ecosystem and
Sustainable Development Unit
The assessment interview was held on 23 December 2021 for the two organisational units of the
MESPU responsible, among other, for sustainable development, marine and nature protection
policies. Part 3 of the questionnaire (on strategic planning capacity) was completed having in mind
various plans and strategies that guide the work of the Department for integrated management of
marine and terrestrial ecosystems and Sustainable development unit. Given the fact that mandate of
the two units is not directly related to climate change and adaptation, parts 7.1 and 7.2 of the
questionnaire (on the design and implementation of CCA programmes and services, and their
monitoring/ evaluation) were not completed.

Description of the institution

Department for integrated management of marine and terrestrial ecosystems (DIMMTE) operates
within Nature Directorate of the MESPU and is tasked with preparation, implementation and
monitoring of policies providing for integrated management of marine and coastal ecosystems in line
with the National Strategy for Sustainable Development (NSSD) and National Strategy for Intgerated
Coastal Zone Management (NS ICZM). Moreover, the Department is responsible for the development
and mainstreaming of methodology for valuation of natural resources and ecosystem services,

19
monitoring the ecosystems state, contributing to the development of pollution prevention measures
etc.

Sustainable development unit (SDU) operates as a self-standing organisational part of the Ministry15
responsible, primarily, for the implementation of sustainable development policies in line with the
NSSD and the UN Agenda 2030. International cooperation is another important prerogative of the
Unit. Moreover, the Unit supports the work of the National Council on Sustainable Development,
including for climate change policy.

Both organisational units were not fully staffed at the time of the assessment, while the numbers of
planned positions were four (SDU) and nine (DIMMTE).

In addition to the set of laws and strategic documents/ programmes relevant for the MESPU Climate
change department, the DIMMTE and SDU work is regulated through the laws on environment, nature
and marine environment protection; strategic framework also comprises NSSD, NS ICZM, National
Biodiversity Strategy with Action Plan and the forthcoming Marine Strategy.

Capacity assessment

Similar to the situation with the Climate change department, the organisational units of the MESPU
working on the protection of marine and terrestrial ecosystems (DIMMTE) and sustainable
development (SDU) have achieved certain accomplishments with the development of CCA capacities,
reaching the overall score of 1.69. The strongest capacities were identified in respect to strategic
planning (2.08) and governance and policy (1.83), followed by leadership and organisational (1.63),
knowledge management (1.6) and capacities to access and use/ produce good quality adaptation data
and analyses (1.58). As regards the last capacity element, DIMMTE and SDU are not acting as data
producers but are involved in the preparation of analyses and reporting. The score indicates that some
systems and procedures for monitoring, generating and using climate information, data and analysis
are in place in the Ministry, but they are not of sufficient quality. For both organisational units it was
assessed that cooperation with international and European efforts to collect statistical data and
analyses was continuous but insufficient.

Not surprisingly, the lowest capacity scores were obtained for human and financial resources due to
the lack of adequate numbers of trained staff at various positions in the institution, low availability of
training programmes and insufficient budgets for the implementation of CCA activities.

Capacity gaps and needs

Education, awareness raising and improvements of organisational matters have been identified as the
main needs for the development of CCA capacities in the parts (DIMMTE, SDU) of the MESPU assessed
herewith. Workshops, seminars and/ or other types of exchanges are always useful, especially when
examples of good practices are presented.

As regards the training topics, it would be important to organise a CCA training of a more general
nature for the decision-making level and/ or members of the relevant Working Groups of the National
Council on Sustainable Development. A more focused training – for example on the data needed for
adaptation planning, development of adaptation programmes and similar – would be needed for the
technical level.

15
The Unit is expected to be moved to the Government’s General Secretariat.

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2.10 Environmental Protection Agency
The assessment interview was held on 22 December 2021. Due to the fact that the Environmental
Protection Agency (EPA) was not directly involved in climate change adaptation activities so far,
interviewees only provided answers for parts 1 (on governance and policy capacity), 2 (leadership and
organisation), 4 (data, information and analysis) and 7.3 (knowledge management) of the
questionnaire. The answers were provided having in mind the Agency’s capacities that could be used
in the future for CCA planning and implementation. The assessment was not undertaken for strategic
planning capacity as the Agency does not have an adaptation plan nor does it have responsibilities for
implementation of such plans developed/ adopted by other institutions. For the same reasons (Agency
not being involved in the design/ implementation of CCA activities), it was not possible to assess the
institution’s human and financial capacities in the context of CCA, and parts 7.1 and 7.2 of the
questionnaire (on the design, implementation and monitoring of CCA programmes and services) were
not completed.

Description of the institution

The EPA was established in 2008, in line with provision of the then-applicable Law on environment. In
addition to the environmental law, climate and nature protection legislation also regulate the EPA’s
competences, which are further specified in the decrees on the organisation and the manner of work
of state administration, as well as in the rulebooks on internal organisation of the institution. Strategic
framework comprises a set of national documents (e.g. climate change, air protection, biodiversity
and other strategies and plans); on the operational level, the EPA’s work is guided by its annual work
programmes and reports on their implementation.

The main functions of the EPA are:

• Environmental monitoring;
• Preparation of analyses and reports;
• Permitting;
• Communication (on the national and international levels, the latter including communication
with other EPAs and the European Environment Agency, participation in the work of
professional networks, and similar); and
• Performing of other tasks in line with relevant environmental legislation.

The main goals of the Agency are:

• Protection and improvements of the natural environment;


• Transparent and responsible implementation of environmental laws, regulations and
policies; and
• Provision of timely and reliable information on the state of the environment to the national
and international organisations and to the general public.

Responsibilities in the area of climate policy are related to the preparation of GHG inventories, with
four persons working on them (within the Agency’s Monitoring department). Competences for CCA
are not clearly established; some indirect responsibilities can be derived from the Agency’s tasks
related to monitoring, provisions of information and reporting, and implementation of nature
protection and protected areas regulations and plans.

21
Capacity assessment

The Agency’s so far responsibilities related to climate change have been linked to preparation of
greenhouse gas inventories; number of staff available to complete related tasks has increased and is
now on a more or less satisfactory level. The EPA benefited from significant capacity building activities
for GHG inventories, nevertheless there is room for further improvements. The main sources of
learning included relevant IPCC guidelines, workshops (often organised by the UNFCCC) and twinning
programmes. Adaptation training on the other hand has been scarce, mainly delivered as a side topic
in the climate change capacity development activities (as, for example, through ECRAN - Environment
and Climate Regional Accession Network).

The EPA takes part in various working groups organised in the policy development processes. It is also
designing the environmental monitoring programme and compiling monitoring data to prepare
annual state of the environment reports and indicator-based assessment (the latter prepared once in
four years). It also participates in some educational activities by delivering, for example, presentations
on climate change and other environmental topics for schools and kindergartens.

The overall score of 1.61 indicates that the EPA has made progress in developing capacities for CCA
even though it does not have direct responsibilities for adaptation. These achievements are likely to
be due to the capacity development efforts related to the Agency’s primary mandate. The highest
score (1.8) was, for example, recorded for knowledge management, which is a constituent part of the
reporting and communication work the Agency is performing. Relatively high scores were also
recorded for data, information and analysis (1.57) and for governance and policy (1.6) capacities. The
score for organisational and leadership capacities was somewhat lower (1.44), indicating low overall
management capacity and a lack of formally assigned responsibilities to address climate change
adaptation related issues.

Capacity gaps and needs

The EPA potential to assume a more active role and to contribute to adaptation planning and
implementation needs to be considered, possibly through the NAP preparation process. Meanwhile,
it would be useful to evaluate options and needs for integration of adaptation aspects into
environmental monitoring programmes, and to work on mainstreaming adaptation into the relevant
areas of the Agency's work (e.g. nature protection). Provision of training on general adaptation topics
would be also useful, especially for younger/ less experienced staff.

2.11 Podgorica Municipality


The assessment interview was held on 27 December 2021. A comprehensive set of information was
provided for all the parts of the questionnaire based on the preparation and implementation of the
2015 Vulnerability Assessment and Adaptation Action Plan and related experiences.

Description of the institution

Podgorica is the capital and largest city in Montenegro. The municipality spreads over an area of 1,143
km2; according to the last census, population was 185,937 – close to 30% of the country’s population.

Local self-government is organised through a number of Secretariats. Climate change responsibilities


are assigned to the Secretariat for spatial planning and sustainable development and its
environmental department that currently has a staff of five. Mandate for CCA is explicitly defined
under the Decision on internal organisation and the manner of work of the capital town of Podgorica

22
(OGM, Municipal regulations, 038/18 and 043/18), which specifies that the Secretariat is inter alia
tasked with preparation and implementation of climate change adaptation strategy. Responsibilities
for climate change policies at local level are integrated in the relevant job descriptions of the
environmental department staff.

Vulnerability Assessment and Adaptation Action Plan from 2015 is the main strategic document
guiding the work of the Secretariat as regards climate change and adaptation in particular. Other
relevant documents include Local energy and climate plan 2015 – 2025, energy efficiency plan, Spatial
Urban Plan of Podgorica, and local environmental and biodiversity action plans.

Capacity assessment

Podgorica Municipality adopted its adaptation strategy/ action plan in 2015 in the GiZ supported
process that involved a range of stakeholders. In addition to the planning, the process had an
educational function too, integrating the adaptation topics into local planning agenda. The strategy
had an important impact on the development of capacities to address adaptation issues and has
affected practical work and priority setting during the past years. Following its adoption, for example,
several projects and initiatives have been designed and implemented in line with the set objectives,
including renovation of facades by using adequate colours and anti-reflection coatings16, provision of
subsidies for bicycles, expansion of green areas and afforestation, and others.

Overall capacities of Podgorica Municipality to address CCA issues were assessed as basic, with the
score of nearly 2 (1.99). Basic or higher capacity scores were recorded for governance and policy
(2.17), leadership and organisation (2.44) and strategic planning (2.08), suggesting that in some areas,
organisational units responsible for CCA planning have made progress towards strong capacities.
Human and financial resources, as well as capacities to implement and monitor/ evaluate CCA
programmes and services, and manage CCA knowledge, were assessed as somewhat lower but still
significant (in comparison to majority of other assessed institutions), with scores in the area of 1.8 –
1.9. The lowest capacity score (1.64) was recorded for the abilities to generate and/ or use CCA data,
information and analyses.

Examples of data produced by Podgorica municipality include results of local air and noise monitoring
programmes, cadastre of green areas and information collected through monitoring the
implementation of measures included in the environmental impact assessment studies. As regards
the financial capacities and access to funds, the interviewees did not have information on any
sustainable finance initiatives in Montenegro or issuance of green bonds, nor were they familiar with
the ESG (Environment, Social, Governance) criteria; they also did not know whether banks in
Montenegro were taking into account CCA and/ or sustainability criteria in their investment decisions.
Podgorica is a part of the City Climate Finance Gap Fund initiative and is currently undertaking a pre-
feasibility study for provision of assistance for turning the flat roofs into green ones. Grants/ subsidies
for climate-friendly activities are provided on an annual basis.

In cooperation with the Association of Municipalities and international partners, Podgorica will
prepare Sustainable Energy and Climate Action Plan (SECAP) which is expected to provide for a
comprehensive review of the so far adaptation activities and outline the next steps. Participation in
various projects and initiatives has been identified as one of the main sources of learning on CCA,
alongside with consultations with colleagues, exchanges of experiences and occasional trainings.

16
The project titled “For a prettier face of Podgorica” is implemented jointly by the local self-government and
assembles of apartment owners that each contribute 50% of the budget for renovation.

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Capacity gaps and needs

Even though it is difficult to assess, individual staff of the Secretariat are spending a small share (less
than 20%) of their time on CCA related tasks at the moment. As the international and EU policies on
adaptation are evolving and more competences are added to local governments, there is a need for
more staff and for further training and capacity development. This especially as the so far trainings
were not directly linked to CCA.

It is very important to ensure that the available staff is exposed to continuous and successive capacity
building efforts, to develop the overall as well as technical knowledge and skills. Workshops and
exchange of experiences are needed, preferably through presentation of successful practices from the
cities that have similar conditions as Podgorica. Practical approaches should be applied to the greatest
possible extents (focusing, for example, on solutions that could be applied to improve adaptation
potential of certain city areas, such as Podgorica main square or City quarter). It is also important to
ensure presence of different institutions/ stakeholders at the trainings.

2.12 Environmental Protection Fund


The assessment interview was held on 28 December 2021. Part 3 of the questionnaire was not
completed as the Environmental Protection Fund does not have a strategic plan on adaptation;
similarly, adaptation has not been integrated in the documents regulating the Fund’s operation
(Statute, for example). Part 7.1 was also found inapplicable, while answers for monitoring and
evaluation (part 7.2) were only provided for a limited number of questions and with a view to the
Fund’s regular monitoring and evaluation procedures (which are not focused on adaptation aspects).

Description of the institution

Mandate of the Environmental Protection Fund (Eco-fund) is set under the Law on Environment (OGM
52/16) as well as through its founding Decision (from 2018) and Statute. Even though adaptation is
not explicitly mentioned, the Decision on the Fund’s establishment stipulates that protection from
harmful effects of climate change is one of the areas to be supported through the Eco-fund’s work.
Mission of the Fund is defined as collection and disbursement of funds to support development of a
sustainable society in Montenegro based on efficient use of natural resources and low-carbon
development. The Decree on emission trading credits is expected to be adopted soon, thus expanding
the revenue base of the Fund (which inter alia includes receipts from environmental taxes and
charges). Operational matters are planned through the annual work programmes.

The Eco-fund extends financial support17 for preparation, development and implementation of
programmes, projects and activities providing for protection and sustainable use of resources,
protection and improvement of the state of the environment, energy efficiency and the use of
renewable energy sources at national and local levels. Its work is guided by all the strategic documents
related to the implementation of the Law on environment as well as by the climate change strategies
and plans. The Eco-fund has a staff of 12. It is in the process of accreditation for the Green Climate
Fund.

17
As regards climate change, the financial support provided so far referred to mitigation measures, such as
procurement of photovoltaic panels and electrical/ hybrid vehicles.

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Capacity assessment

Close to strong capacity (with the score of 2.67) was identified for monitoring and evaluation18 due to
well elaborated internal procedures and capacities to monitor implementation of approved projects;
however, the Fund did not have any projects on CCA as yet. Basic capacity (score of 2) was detected
for knowledge management for similar reasons. Governance and policy, and human resources
capacities have also been assessed as approaching basic levels (with scores ranging around 1.8). This
means that the Eco-fund has an informally articulated mandate to address CCA issues in the
framework of their work and staff capable of carrying it out, but necessitating further capacity
development.

The overall capacity of 1.6219 suggest reasonable level of knowledge and skills is available to address
CCA in executing the Eco-funds primary mandate – disbursement of funds to support selected projects
and initiatives. Somewhat lower score of 1.5 was derived for financial resources capacity as the Fund
did not have budget lines dedicated to CCA, and was not familiar with/ applying the ESG (Environment,
Social, Governance) criteria; moreover, the staff did not have much information on how other
financing sources for addressing climate change adaptation issues could be accessed. The lowest
capacity score (1.42) was recorded for the Eco-fund capacity to access and use quality CCA
information, data and analysis.

These capacity assessments refer to a situation where the Fund is recognised as a financing
mechanism and an institution that implements policies created by the Ministry of Ecology, Spatial
Planning and Urbanism. The Fund also contributes to policy making through its involvement in various
working groups on the national level. International policies and processes are followed to the extent
required by their mandate.

Procedures for conduct and follow up are in place for the entire project cycle – from application stage
to ex post evaluations. Project approval is based on the criteria set out in the public calls, and is
handled by appointed commissions, in line with internal regulations. The Board of Directors gets
involved in the approval of projects with budgets above 200,000 euros.

The Fund’s programme of work includes education on climate change whereas environmental NGOs
can apply for financial support to deliver such activities. The most important learning sources so far
included the trainings organised by UNDP and exchanges with other environmental funds.

Capacity gaps and needs

The internal acts of the Fund, including the rulebook on the organisational arrangements and job
descriptions, recognise climate change but not adaptation. The number of staff is limited for the time
being, but new positions are considered and a change in the internal organisation is planned.
Outsourcing is also envisaged to obtain expertise that might be lacking from within the institution. To
strengthen the existing capacities, additional trainings, exchange of experiences20, participation in
different forums and working groups are all needed.

18
Based on a limited number of provided answers.
19
Scores for parts 7 of the questionnaire were not taken into account in deriving the average as they are based
on a low number of questions (eight out of 18 non-descriptive questions for part 7 in total)
20
The Eco-fund is cooperating with the Slovenian Environmental Fund and Ministry, and a visit to Croatian Fund
is planned.

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The Fund does not have its own strategy or a plan on how to address CCA in its work. The main
knowledge gaps include information on financing instruments and attraction of available international
funds.

An important gap is the lack of environmental data – with weaknesses detected as regards collection,
systematisation and keeping of data (lack of information system), which may represent a significant
obstacle for adaptation. The national list of environmental indicators does not include adaptation.
Improvements in this are expected following the NAP preparation.

Further trainings aiming to increase the Fund's capacity to address CCA issues should be linked to its
basic activities, possibly looking into integration of adaptation criteria into the Fund's financing
programmes as well as into the ways to attract more funds for adaptation.

2.13 Investment Development Fund


The interview was held on 29 December 2021. The Investment Development Fund (IDF) intends to
prepare a written plan (which is not in place now) on integration of CCA into its activities, therefore
part 3 of the questionnaire was not completed. For part 4 (on data, information and analyses), a
limited number of questions was answered and the score was not derived. Another part that was not
completed was 7.2 on monitoring and evaluation.

Description of the institution

The IDF was established in 2010 in order to provide favourable loans for different development
programmes. Its mandate is set under the Law on investment-development fund of Montenegro
(OGM 88/09), whereas other applicable regulations on the control of financial institutions also apply.
The mission statement of the Fund as a development institution is to “... support creation of new
values based on knowledge, cultural heritage and natural assets in order to incentivise systemic,
sustainable and even economic and social development in line with general strategic goals of
Montenegro”. Priority areas of the IDF work include financing of environmental and infrastructural
improvements. The Fund has a staff of around 80.

In recent years, through cooperation with UNDP, international financial institutions and bilateral
donors, the Fund is progressively taking up the green economy development agenda, with a growing
share of climate finance in its overall disbursements. Climate finance (mainly support for energy
efficiency improvements and renewable energy sources) is already making an estimated 20% of the
total portfolio.

The legal framework and the Statute of the Fund do not set grounds for climate change adaptation
work, but as the availability of climate finance is growing, there are ongoing efforts to (with the
technical assistance of international partners) review mandate and the organisational structure to
make the institution more apt for addressing CCA priorities. The ongoing cooperation with the EIB and
French Development Agency (AFD) are especially important to this end.

In addition to its own annual work plans, the IDF's work is guided by the main national development
policies.

Capacity assessment

The IDF is actively involved in the development of financing instruments for climate change, including
adaptation. The Fund’s management is aware how important it is to develop climate finance in a

26
situation where international partners are increasingly asking that at least a part of finance is targeting
climate priorities. There is a strong support from the institution’s leadership to move in this direction.
Consequently, the highest score (1.94) in the capacity assessment was recorded for leadership and
organisation, indicating that the IDF has a basic capacity in this area. Similar result (1.9) was derived
for governance and policy capacity: even though there is no formal mandate to address CCA at the
moment, adaptation is being incorporated in the procedures and operations, staff is familiar with CCA
and there are efforts to integrate it more formally in the organisational structure.

The overall score of 1.78 suggests significant progress has been achieved towards basic capacities for
addressing the CCA issues. In addition to policy/ governance and organisation and leadership,
relatively high capacity scores were recorded for financial resources (1.83) and knowledge
management (1.7). Somewhat lower capacities were assessed for human resources and for the design
and implementation of CCA services. For part 4 of the questionnaire on the access to and/ or use of
CCA data, information and analysis, only 4 out of 12 questions were answered, therefore the score for
this capacity element was not derived. The availability of adaptation-related data was assessed as
poor. As regards the use of CCA data within the IDF and understanding of such data and analyses by
its staff, it was assessed that capacities were on the basic level; the same was the case for the question
on organisation of trainings to improve understanding, where progress has been through cooperation
with AFD.

Capacity gaps and needs

Improvements are needed as regards availability and use of CCA data, information and analyses, as
well as for strategic planning and the ability to design, implement and monitor/ evaluate adaptation
programmes or services. In relation to knowledge management, improving accessibility for external
stakeholders and better communication would be useful. The ongoing cooperation with international
partners is providing sufficient capacity development opportunities to address the identified gaps.

2.14 Foreign Investment Agency


The assessment interview was held on 30 December 2021. Due to low applicability of respective
questions for the Foreign Investment Agency’s work, parts 3, 4, 7.1 and 7.2 of the questionnaire
were not completed.

Description of the institution

The Foreign Investment Agency (FIA) is tasked with promotion of Montenegro’s investment
opportunities, and with providing potential foreign investors with contacts and information needed
to make investment decisions. The Agency also participates in the implementation of economic
citizenship programme. In total, around 30 staff is employed; organisational set up encompasses
departments on public-private partnership, promotion of investments and international cooperation,
and others.

FIA operates in line with the Law on public-private partnership (OGM 73/2019) and the Law on foreign
investments (OGM 18/11). Its work is further guided by the institution’s Statute and work plans. None
of these documents set a specific mandate for climate change adaptation activities, but FIA is
developing a new concept of work where more attention is paid to green investments. In such a
context, interest for CCA was developed. Even though the Agency lacks formal mandate, it has an
indirect role in the implementation of CCA (through its contacts with international funds) and has
already had practical experience in bringing together providers of adaptation funding with interested
entities in Montenegro (for example AFD and Investment Development Fund). Plans for the future

27
include preparation of overviews of all the national sectoral strategies (covering NAP and adaptation
measures, once they are developed) for investors, and application of UNEP’s approach to green
foreign direct investment (FDI).

Capacity assessment

The assessment showed the overall CCA capacities (with the score of 1.29) of the FIA were rather low.
They were more advance for governance and policy (1.56), and leadership and organisation (1.42)
areas, but quite low as regards human and financial resources and knowledge management (with
scores ranging from 1 to 1.2). This shows that the organisation does not have adequate number of
trained staff to address CCA issues, that adaptation is not taken into account in its budgets while other
funding sources for CCA are unstable/ unreliable, and that a system for learning and 28disseminating
information on CCA are not in place. Conversely, some progress in capacity development was reported
for the commitment to address CCA and organisational arrangements, and alignment with relevant
international processes, which resulted in the scores that are midway between low and basic
capacities.

For part 4 of the assessment (on capacities to generate and/ or use quality CCA data, information and
analysis), the Agency is perceived as an intermediary that can direct foreign investors towards relevant
data sources, therefore a limited number of questions was found applicable. For all the questions that
were answered (on, for example, the use of CCA data, understanding of such data by the staff,
organisation of trainings), low capacities were identified. For parts 7.1 and 7.2 of the questionnaire,
few responses were provided and were not sufficient to derive capacity scores.

Capacity gaps and needs

The main identified gaps relevant for the FIA’s work are linked to a lack of knowledge and low
understanding of CCA among its staff. To address this gap, general trainings on vulnerability to climate
change, on the approaches and tools used to mainstream climate considerations in future investments
(climate-proofing), on the sources of data for CC and adaptation, etc. would be useful. Training on the
UNEP’s concept of green FDI would be welcome too.

2.15 Statistics Administration Monstat


The assessment interview was held on 17 January 2022. Parts 3 and 6 of the questionnaire were not
completed as interviewees could not report on procedures and tools to integrate CCA into planning
and thought that most of the questions on financial resources capacity were not applicable for the
Statistics Administration. Similarly, answers were not provided for parts 7.1 and 7.2 as Monstat was
not involved in the provision of CCA programmes and services.

Description of the institution

Monstat is the competent body for the production of official statistics; its work is increasingly being
aligned with Eurostat’s work. The institution’s mission is production of statistics that will be used by
citizens, government and scientific research institutions, media and other users allowing them easy
and quick access to statistical data. The main tasks include but are not limited to: organisation and
conducting of statistical surveys; collection, processing, statistical analysis and publishing of statistical
data; development, updating and usage of state level registers determined by law in cooperation with
relevant public administration bodies; preparation of methodologies for conducting of statistical
surveys; preparation of programs of statistical surveys; development of statistical information system;

28
and control of accuracy of responding units data. Monstat’s mandate is set under the Law on official
statistics and official statistical system (OGM 082/12, 047/19).

Strategic framework is provided through the Strategy for the development of official statistics 2019 -
2023 and work plans. The Strategy only makes a reference to climate change in the context of
cooperation (with UNDP) on preparation of the Biennial Update Report on Climate Change.

Monstat comprises several sectors, including Agricultural Statistics, Fisheries, Business Statistics and
Environment and Forestry Sector, with a department responsible for environmental and forestry
statistics. Description of the Department’s responsibilities bears no references to climate change21.
Five positions are envisaged for the Monstat’s Environment and forestry department, but only one is
filled at the moment.

Capacity assessment

Examples of integration of climate change issues into Monstat’s work include recent amendments to
the plant production survey in order to compile data on variables relevant for the GHG inventory,
improvements in the forestry statistics (with trainings for the forestry reporting units), and similar.
Temporary cooperation with local level was established in an attempt to collect data on damages from
forest fires through local Protection and Rescue Services; permanent reporting of data on forest fires
is a responsibility if the Forestry Administration.

Climate-related data generated by Monstat is linked to GHG emissions/ sinks, and it includes data on
forest fires, forest cutting, wood products, burning of fodder, municipal waste and its composition,
landfills, wastewater and similar. Data on adaptation is not collected or at least it is not labelled and
defined as such. As regards adaptation indicators, Monstat was not directly involved in the initial
processes on their development but has cooperated with IHMS by providing required agricultural
data.

The assessment showed that Monstat’s overall capacities for addressing CCA issues were midway
between low and basic, with an average score of 1.57. Human resources as well as governance/ policy,
and leadership and organisational capacities were around this level i.e. in the range of 1.56 to 1.7.
Somewhat lower score (1.42) was recorded for generation/ use of climate data, information and
analysis, meaning that limited data is available and that there is a lack of staff knowledgeable about
the appropriate use of climate information. The assessment also showed there was a significant room
for improvements as regards knowledge management capacity of the Statistics Administration,
despite certain achievements in this area (with capacity score of 1.7).

Capacity gaps and needs

Capacity gaps and needs for the Statistics Administration are primarily related to the number of staff
in the Environment and forestry department and appropriate capacity development activities. Overall,

21
Forestry statistics unit takes part in the development of methodologies for forestry sector and prepares
indicators on cutting of different types of trees and manufacturing of wood products, as well as indicators on
growing and protection of forests, wildlife and hunting.

Environmental statistics unit takes part in methodological and organisational preparations for conducting
statistical surveys on the use and protection of water from industrial pollution, irrigation systems, public water
supply and sewage systems, municipal and industrial waste; it also develops and applies internationally
harmonised statistical standards for environment.

29
Monstat staff has a good knowledge for traditional statistical areas, but trainings are necessary for the
new ones (such as climate change and CCA) where requirements are evolving and becoming ever more
comprehensive. Procedures for data reporting and collection are quite well defined, but the situation
changes and there is a need for national policy creators to define data needs so Monstat could take
necessary steps towards their generation. Infrastructure and resources to support data collection
needs are insufficient.

Specific topics for which organisation of trainings would be welcome include generation of data on
fires (in cooperation with the Ministry of Internal Affairs), following up on the effects of weather-
related disasters, needs for GHG inventories preparation, meeting the Green Deal obligations, possibly
also for generation of data related to wastewater treatment plants. As regards knowledge
management, sharing of good practices from other countries would be beneficial (design and
maintenance for the Slovenian database on waste, for example). National inter-institutional
cooperation is very important and possibilities should be used to provide guidance on its improvement
through the trainings.

2.16 Regional Park Piva


The assessment interview was held on 27 January 2022. For part 3 of the questionnaire, most answers
were provided based on preparation of protected areas management plans which did not address
CCA. For this reason, the organisation’s ability to integrate adaptation into strategic planning was not
assessed. Few answers were provided for part 6 on financial resources; these were deemed
insufficient to derive conclusions on the capacity level. Part 7 of the questionnaire was not completed
as the protected area manager – Regional Park Piva – was not involved in the design and delivery of
CCA programmes or services, nor did it have opportunities to apply or disseminate CCA knowledge.

Description of the institution

Regional Nature Park Piva is a protected area (declared in 2015) located in the northwest of
Montenegro, Pluzine Municipality, on the border with Bosnia and Herzegovina. Surface of the
protected area (PA) is around 32,500 ha. It is managed by a public company Regional Park Piva (RPP)
with eight staff members. The PA manager acts in line with the Law on nature protection (OGM 54/16),
internal acts and management plans of the Piva Park. Mandate or mission for climate change
adaptation is not in place, and the experiences with addressing CCA issues are quite limited. Despite
this, there is a general awareness on the potential impacts of climate change on protected area
resources and an interest to develop capacities for adaptation activities in the future.

Capacity assessment

As regards climate change related activities, the RPP has mainly dealt with promotion and use of
renewable energy sources and energy efficiency improvements (solar panels, LED lighting, etc.).
Adaptation was only addressed indirectly so far, through some projects, information sharing, learning
and similar activities.

The RPP and Pluzine Municipality are involved in a cross-border project (implemented together with
Foca Municipality from Bosnia and Herzegovina) on prevention of fires. Trainings and fire-fighting
equipment were provided, including rescue drills aimed at improving cooperation and coordination of
protection and rescue services from the two municipalities.

The main documents guiding the RPP work are management plans prepared in line with national
standards/ requirements, often with external assistance (e.g. UNDP). They do not touch explicitly on

30
CCA but contain some information that could aid adaptation planning. A regular function of the RPP
that could be used for identification of CC impacts and adaptation needs is monitoring of the state of
habitats and species within the PA. Monitoring reports are used for planning purposes and are shared
with the Environmental Protection Agency. Even though CCA is not a priority for the PA manager at
the moment, preparation of an adaptation plan is something that will be considered in the coming
period. The RPP did not have access to adaptation funding so far, but is regularly applying for or taking
part in projects that help increase its technical, human and financial capacities (some 5 – 15% of the
annual budgets usually come from projects).

Modest experiences and low level of priority assigned to CCA in the so far operation are reflected in
the capacity assessment. Low capacities were identified for human and data/ analytical capacities
(with respective scores of 1.36 and 1.33), somewhat higher for policy and governance (1.56) and
leadership and organisational (1.5) capacities. The overall score of 1.44 indicates the RPP has a solid
basis but also a need for further capacity development to be able take on CCA issues effectively.

Capacity gaps and needs

The RPP benefited from a large number of trainings but none of them were (fully or predominantly)
dedicated to adaptation. In order to improve the overall capacity for planning and implementation of
CCA activities, elaboration of an adequate mandate or mission, education and trainings are needed.
Training/ education should start from explanation of basic terms and expand to identification of
adaptation-related problems and solutions to address them. It should be also focused on the data use/
generation and analytical capacities of the PA manager. Moreover, all exchanges and knowledge
sharing on how to integrate adaptation in protected area management planning would be useful.

2.17 Marine Biology Institute


An online meeting was organised with representatives of Marine Biology Institute (MBI) on 28 January
2022 to carry out capacity assessment. By being a scientific and research institution, the Institute does
not have a strategy for integration of CCA into planning. Consequently, part 3 of the questionnaire on
strategic planning was not completed. Parts 7.1 and 7.2 were also found inapplicable given the fact
that MBI does not design or implement specific CCA services or programmes. A few answers provided
for part 6 were deemed insufficient to derive conclusions on the financial resources capacity of the
Institute.

Description of the institution

Marine Biology Institute is a part of the University of Montenegro. The key pieces of legislation
regulating its work are the Law on scientific research (OGM 80/10, 40/11, 57/14 and 82/20) and the
Law on marine fishery and aquaculture (OGM 56/09, 40/11). University of Montenegro’s Statute,
Development Strategy and the Annual plans of scientific research also apply. The Institute currently
has 38 staff (including permanent and project-based positions) working within five organisational
units/ laboratories for:

- Marine chemistry and oceanography;


- Ichthyology and marine fishery;
- Plankton and sea water quality;
- Benthos and protections of the sea;
- Development research and aquaculture.

31
Mandate for climate change/ CCA is not defined, nevertheless the Institute has a unique capacity and
data needed to assess impacts of climate change on marine ecosystems in Montenegrin marine area.
Climate change and/ or adaptation are topics addressed through various projects. A recent example
is the GEF project where MBI, together with IHMS and Oceanography Institute from Croatia,
monitored marine water temperature and salinity changes. MBI was also involved in the definition of
Good Environmental Status for marine waters and has an important role in the preparation of
Montenegro’s marine strategy; it is expected the Institute will be also an important player in
monitoring its implementation and reporting. The Institute is regularly consulted in the preparation
of relevant plans and policies, and has contributed to the preparation of the National Communications
to the UNFCCC (including through preparation of a report on invasive species for the Second National
Communication).

Capacity assessment

The Institute takes part in the preparation and/ or is involved in the implementation of various projects
designed by other institutions as an actor that has significant resources for marine ecosystems
research and monitoring. It is an important ‘producer’ of data on physical-chemical characteristic of
sea water, microbiology, habitats and other areas. The main services provided by the MBI are data
and scientific articles and publications.

Even though it’s mandate for CCA is not established and adaptation is not reflected in the
organisational structure, job descriptions and annual plans, it is a cross-cutting theme of the MBI work
addressed through many activities and projects. That is why the Institute has reached certain level of
capacities for addressing CCA issues in its role of a scientific and research institution. The overall
capacity score of 1.5 shows the institution is half way between low and basic capacity, with best results
for knowledge management (1.9), data, information and analysis (1.64), and leadership and
organisational capacity (1,63). Low capacity score for human resources (1.21) was recorded due to a
lack of staff and low availability of CCA training programmes in the country (with literature and
exchanges with regional experts being the main learning sources). On the other hand, high scores for
knowledge management and data can be attributed to the fact that the MBI has a long tradition in
collecting data and analysing marine processes, and has developed a sound system for documenting,
storing, and disseminating information, including (for example) through ISO 17025 certification for
biological and microbiological data.

Capacity gaps and needs

The main gaps were identified in relation to the lack of staff who could take on the CCA work more
extensively, as well as to low availability of capacity development programmes and forums.
Continuous development of knowledge and skills is needed, as climate change impacts on marine
ecosystems are a complex research area with new developments taking place practically on a daily
basis. It is also necessary to work on updating the existing data, to improve the use of information and
communications technologies and the ways of presenting results of scientific research to the public
and decision-makers. Specific trainings and knowledge exchanges on new methods and programmes
(for example for vulnerability assessments) and on the ways other experts are interpreting data would
be welcome. Learning through practical examples and study visits are particularly effective forms of
capacity building (and are needed for all the areas). The Institute could also benefit from the
development of skills on how to attract additional project-based funding for CCA activities.

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2.18 Association on Municipalities
The assessment interview was held on 7 February 2022. Part 3 of the questionnaire was not completed
as the questions were found inapplicable for the Association’s work. Interviewees were not able to
answer most of the questions on financial resources, therefore the capacity score was not derived for
part 6 of the questionnaire. Similar situation was encountered for part 7 on the design,
implementation, monitoring and evaluation of CCA programmes and services, and knowledge
management.

Description of the institution

Mandate of the Association of Municipalities (AoM) is defined under the Law on local self-government
(OGM 002/18, 034/19 and 038/20) and the organisation’s Statute; strategic development plan also
guides its work. The AoM responsibilities include: development and improvement of the legal
framework and of the local self-governments’ position; improvements in the areas of housing and
communal affairs, spatial planning, construction, transport and roads maintenance, economic and
non-economic activities as well as in the other areas of the local self-government competences;
cooperation of local communities; advocacy for the common interests of local communities at national
and international levels; taking part in policy making processes; cooperation with international local
government organisations; education and capacity building for citizens and local self-governments
staff; and others.

The Association performs its mandate through a number of permanent working bodies – committees
for local self-government development; spatial planning; local self-government financing; social
affairs; communal affairs and environmental protection; and European integration and international
cooperation. Each committee has seven members – representatives of various local self-government
units – who are considered an internal capacity of the Association. Moreover, the organisation has 11
employees.

Capacity assessment

The Association of Municipalities has an extensive experience in cooperating with and providing
technical support to local self-government units in Montenegro. It is a member of the Network of
Associations of Local Authorities of South East Europe (NALAS)22 and was involved in the project of
localisation of the Agenda 2030, disseminating information to municipalities. The AoM was also
involved in the dissemination of information on the possibilities to prepare Sustainable Energy and
Climate Plans which has led to support being approved for two Montenegrin municipalities –
Podgorica and Tivat – to prepare these plans. Support for two more municipalities (Kolasin and
Pljevlja) is considered, and educational workshops will be delivered benefiting all the municipalities.
Another relevant project - EU4 Energy Transition: Covenant of Mayors in the Western Balkans and
Turkey – is targeting 6 municipalities from Montenegro. The Association is often recognised by other
entities as a project partner but does not play an active role in project preparation and fundraising.

The AoM has frequently organised trainings and/ or was involved in the training processes for local
authorities23. However, climate change adaptation was not covered under such initiatives. Climate
change related activities in which the AoM took part so far were linked to mitigation measures. The
organisation is not generating data (CCA related or other); it does take part in preparation of different

22
NALAS gathers 15 associations representing around 9,000 local governments elected by more than 80 million
of citizens of South East Europe.
23
In the AoM view, online trainings for local governments staff should not be a preferred form of training.

33
reports and publications, and drafts ad hoc analyses needed for the negotiation process between local
and national authorities. Internet and projects in which it participates have been identified as the main
learning sources for CCA.

Through its past activities, the AoM has developed some capacities to address CCA issues, primarily
for governance/ policy and leadership and organisation where the capacity scores of 1.28 and 1.5 were
recorded. Organisational structure of the AoM, roles and responsibilities of its organisational units
and its overall management capacity are favourable and represent a good starting point for further
development of capacities for CCA. On the other hand, capacities for data generation/ use and human
resources (in the context of CCA planning and implementation) have been assessed as rathe low (with
respective scores of 1.1 and 1.2).

Capacity gaps and needs

Trainings and pilot projects allowing for practical application of knowledge (learning by doing
approach) are needed to raise the AoM and local authorities’ capacities to contribute to effective
design and implementation of adaptation measures. In the Association’s view, seminars and similar
type of trainings are also useful but only for committed participants/ civil servants. Generally, all the
new information and knowledge on CCA would be welcome. For the Association itself, there is no
need for specialised or technical trainings. For the trainings for the local authorities, it would be useful
to focus on integration of CCA in the spatial planning processes.

2.19 Ministry of Agriculture, Forestry and Water Resources – Payments


Directorate
The assessment interview was held on 7 February 2022. A limited number of answers was provided
for parts 3 and 6 (on strategic planning and financial resources) of the questionnaire hence the scores
were not derived; part 7 (on implementation, monitoring and evaluation and knowledge
management) was not complected.

Description of the institution

Payments Directorate is a large organisational unit (with a planned staff of cca 110) of the MAFWR
responsible for management and payments performed through IPARD Programme, Agro-budget and
other agriculture support programmes. The Directorate receives, evaluates and approves project
applications, executes payments for approved projects, prepares and implements supervision plans,
and monitors disbursements from different budget lines. It is also responsible for establishment and
maintaining of agricultural registers and for implementation of an integrated administrative and
control system.

The structure and functional units of the Directorate are defined through the Rulebook on internal
organisation of the Ministry. Current job descriptions do not have any references to CCA and it is likely
this will remain so for the foreseeable future. The extent to which the Directorate is/ will be paying
attention to climate change and adaptation issues is determined through the programmes the
implementation of which it manages. The main so far programme – IPARD II for the period 2014 –
2020 – discusses vulnerabilities of agriculture to climate change24 and is designed to support, in
general terms, implementation of the Strategy for Agriculture and Rural Development 2015 – 2020,

24
Due to potential negative impacts of climate change on soil fertility, higher incidence of extreme droughts,
higher precipitation intensity and soil erosion, as well as due to possible lower annual quantities of water
available for agriculture.

34
including its goal on sustainable management of resources where both mitigation and adaptation to
climate change are recognised. However, the Programme does not include any specific measures to
support agricultural holdings to adapt to CC. As discussed earlier, in addition to IPARD, the Directorate
administers payments envisaged through the annual Agro-budgets which entail some measures that
can be (indirectly) linked to adaptation (e.g., support to compensate for damages from extreme
weather).

Capacity assessment

The Payments Directorate is an organisational unit of the MAFWR tasked with implementation of
measures that are part of programmes prepared and adopted by other MAFWR Directorates. As such,
it does not have a mandate for addressing CCA. While this is not likely to change in the future, the
Directorate has and will have an important role in implementing measures that provide direct financial
assistance to agricultural producers, including, expectedly, some adaptation measures (when they are
developed). The scores obtained through the present assessment (indicating low capacity for CCA)
should not be necessarily interpreted as a weakness but rather as a reflection of the Directorate’s role.
Even though insufficient for performance of their mandate, the Directorate has significant human
resources (for the execution and control of direct payments) and a potential to quickly develop
capacities for CCA through adequate trainings and exchanges. A specific strategic plan to address CCA
is not in place, but it is worth noting that some of the programmes implemented by the Directorate
(e.g. IPARD II) take into account gender issues (by applying less stringent criteria for the approval of
projects for female applicants).

The overall score for the Payments Directorate was 1.17, which indicates quite low capacities for CCA.
Some positive developments have been detected in the area of leadership and organisational capacity,
where the score of 1.37 was recorded. For the remaining assessed capacities – governance and policy,
data and analysis, and human resources – very low scores have been obtained, ranging from 1 to 1.17.
For human resources the assessment only took into account knowledge and skills related to CCA (and
the low score does not mean the institution is not able to perform its core mandate in a good way).

As regards the questions on financial resources, the discussion showed the Directorate (by being an
institution that works with beneficiaries and donors) had strong capacities in some areas, but an
opinion prevailed that taking into account these high scores would be misleading in terms of the
assessment of capacities for CCA. This in particular as the Directorate did not have a dedicated
budget for climate change adaptation activities. A similar situation was found for monitoring and
evaluation capacity (part 7.2 of the questionnaire).

Capacity gaps and needs

Significant gaps have been identified in almost all the assessed areas. The Directorate does not have
and is not likely to have a formal mandate to address CCA; consequently, adaptation is not
incorporated in the organisational structure and job descriptions. It is nevertheless necessary to
develop capacity of the relevant staff to follow up implementation of environmental protection and
adaptation measures. Staff of the Directorate is proactive and interested in acquiring knowledge that
would help them implement adaptation measures effectively, once such measures are designed and
integrated in the agriculture support programmes.

Useful training topics would be the on the potential role of different departments of the Payments
Directorate in the context of CCA measures implementation, as well as on the data needed for
adaptation planning and follow-up. Presentation of examples of adaptation measures in agriculture
would be also very useful.

35
2.20 Pluzine Municipality
An online meeting was organised on 8 February 2022 to discuss capacities of Pluzine municipality to
address climate change adaptation. The questionnaire was not used to conduct the assessment since
Pluzine is a small municipality with limited capacities overall, and with practically no experiences with
CCA. The key information on the municipality and the key points discussed are presented below.

Description of the institution and capacity needs

Limited capacities of the local self-government unit are consistent with the small size of Pluzine
municipality spreading over 853 km2 and having total population of 3,246 (at the last census). The
municipality has a large hydro-accumulation – Pivsko Lake – serving hydropower plant (HPP) Piva;
surface of the 42 km long lake is 12.5 km2. The HHP Piva has an installed capacity of 342 MW and is
operating since 1976. Peak production (of 1,286 GWh) was recorded in 2010 – the year when heavy
and prolonged rainfall, coupled with snow melting, caused the most serious floods on record in the
country (central and coastal regions were particularly affected). Another important economic activity
is tourism, with main attractions being linked to the Regional Nature Park Piva. Local authorities are
making efforts to support agricultural production to the greatest possible extent, however and despite
large pasture areas, agriculture is not playing an important role in the local economy; forestry is more
significant.

Local self-government in Pluzine municipality is organised through the two secretariats: for finances,
economy and local public revenues; and for governance and social affairs. Environmental
competences (which bear no reference to climate change adaptation) are handled through the
Secretariat for finances, economy and local public revenues. One person is covering the environmental
tasks25, which are predominantly linked to local environmental impact assessment procedures and
communication with the Ministry of ecology and the EPA. Preparation of Local Environmental Action
Plan is underway (likely to be developed with internal resources). Development of environmental
awareness raising programmes is also planned, targeting preschool and elementary school children.

Strategic development plan for Pluzine Municipality 2020 – 2025 and Spatial Urban Plan do not
address climate change. Local Biodiversity Action Plan was adopted in 2013, and there is a local Plan
for the protection from fires.

In executing its environmental competence, the Municipality has a good cooperation with national
level institutions. Cooperation with other stakeholders is weaker, and there is generally a low interest
of the public environmental matters. Cooperation with business sector could be improved (this
primarily refers to the Electricity Company of Montenegro – owner of Piva HPP). The Municipality is
occasionally involved in regional/ cross-border projects and initiatives, but international cooperation
is not well developed in principle.

Local government staff has had some opportunities to attend various trainings, some of them were
organised online (for example energy efficiency training). Association of municipalities is active in
providing assistance for capacity development.

Having in mind that mandate for CCA is not specified and that there were no significant activities in
this area, capacities of Pluzine Municipality to address adaptation issues can be assessed as low. To
address this, it would be necessary to provide general information on vulnerability and adaptation,
including advices on how to mobilise additional funds and expertise to support adaptation planning.

25
Tasks related to waste and water resources management are also handled by one staff member, and the
same applies for agriculture.

36
2.21 Ministry of Economic Development and Ministry of Health – Directorate
for Tourism Development Policies and Health Tourism Department
A joint interview was held on 9 February 2022 for representatives of the Directorate for Tourism
Development Policies (of the Ministry of Economic Development – MED) and the Department for
Projections and Planning for Health Tourism Development (of the Ministry of Health – MH). Even
though the forthcoming tourism development Strategy recognizes the need for CCA planning in the
tourism sector, the interviewees could not provide answers for part 3 of the questionnaire (could not
relate most of the questions with the way in which the draft Strategy was developed and the extent
to which it addresses CCA issues). For part 6 on financial resources capacity, the answers provided by
the interviewees were deemed insufficient for obtaining a representative capacity score. Part 7 of the
questionnaire (on the design, implementation and monitoring/ evaluation of CCA programmes and
services and on knowledge management) was not completed either due to the fact that the two units
are not directly involved in the provision of such services.

Description of the institution

The Law on tourism and catering (OGM 02/18, 013/18, 25/19, 67/19 and 76/20) calls for the
development of sustainable tourism26 which inter alia takes into account the need to protect the
environment and adapt to climate change.

Tourism Development Strategy and Action Plan by 2025 (draft) recognizes importance of CCA by
reinforcing the need for climate action encompassing efforts to reduce GHG emissions and strengthen
capacities for adaptation. The Strategy however does not include specific adaptation activities but
maintains focus on mitigation – development of green and safe tourism through e-mobility,
certification, etc. Climate change and adaptation are mentioned in the Programme of Development
of Health Tourism 2021 – 2023, but not considered in more detail: there is no analysis on how could
climate change impact health tourism development and what should be done to adapt to such
impacts.

Planned number of staff in the MED Directorate is around 20. In the MH Department, only one person
works on health tourism development policies notwithstanding the fact this type of tourism is seen as
very important for diversification of offer (which is a long-lasting priority of the ministries responsible
for tourism). There are no references to climate change adaptation in job descriptions for the staff of
the assessed institutions.

Capacity assessment

Mandate for CCA is provided through the Law on tourism and catering for the MED, further elaborated
(to some extent) in the new tourism development Strategy. For the MH’s Department for health
tourism development, mandate is less clearly defined. Commitment to address CCA is however
evident, and has contributed to somewhat higher than the average score (1.56) for policy/ governance
capacities. The average score for the tourism development institutions (the assessed MED Directorate
and MH Department) was 1.4. Capacity scores for leadership and organisation, and for availability and
use of CCA data, information and analysis were around the average level, while as lower capacity

26
In the definition of sustainable tourism provided in the Law, it is stated that it entails optimal use of natural
resources through implementation of policies and measures to mitigate effect of climate change, provide for
reduction of GHG emission and transition to a low-carbon economy, as well as for reduction of vulnerability of
natural and man-made systems to actual and expected climate change.

37
(1.21) was assessed for human resources, mainly due to insufficient number of staff and low
availability of training programmes so far.

Capacity gaps and needs

Significant gaps were identified across all the assessed elements, in particular for the access to and
quality of CCA information, use and generation of relevant data, management capacity, availability of
adequate numbers of trained staff at all levels, budgets and other areas. Lack of staff is in particular
evident in the MH Department for health tourism, while as lack of knowledge is found in both
ministries due to the fact that adaptation is a relatively new area in tourism development planning
and that learning programmes and sources are not widely available. Trainings with general
information on CCA and especially examples of good practices on integration of adaptation into
tourism development planning would be very useful.

2.22 Ministry of Agriculture, Forestry and Water Resources – Forestry


Directorate
The assessment interview was held on 11 February 2022. Part 3 of the questionnaire on strategic
planning was completed having in mind the existing documents (forestry policy and strategy) that take
adaptation into account. For the assessment of financial resources capacity, answers were provided
just for a part of the questionnaire. Interviewees were not able to address questions on the
implementation of CCA programmes and services and their monitoring/ evaluation, therefore the
assessment score was only derived for knowledge management capacity in the part 7 of the
questionnaire.

Description of the institution

The Forestry Directorate (full name: Directorate for Forestry, Hunting and Wood Industries) operates
within the MAFWR and comprises two sub-units responsible for the development and implementation
of forestry policies: Department for forestry, and Department for monitoring in forestry and hunting.
Total planned number of staff in the Directorate is 19 (but not all the positions are filled), of which
four in the Department for forestry and 6 in the monitoring Department.

The overall responsibilities of the Directorate include adoption of policies, preparation of laws and
strategic documents for forestry, hunting and wood industries, harmonisation with the EU legislation,
monitoring and management of forestry information system, planning and carrying out cooperation
with international organisation and donors, as well as with other national organisations, etc.
Department for forestry is inter alia tasked with formulation of forestry measures, preparation or
coordination of the development of strategic forestry plans, and for following up on their
implementation. Department for monitoring in forestry and hunting monitors activities that refer to
forestry stewardship and management, and changes in plant and animal stocks of significance for
forestry and hunting through inventories, forest management programmes and forest cadastres; it
also performs other activities relevant for monitoring.

Implementation of forestry policies is a responsibility of the Forestry Administration.

The key piece of legislation is the Law on forests (OGM 74/10, 40/11 and 47/15), which only contains
provisions on climate change mitigation. Unlike the Law on forests, the National Forestry Policy from
2008 pays due attention to CCA in forestry management, thus setting a mandate for forest
management institutions to develop and implement adaptation measures. CCA is further addressed

38
through the Strategy with Development Plan for Forests and Forestry 2014 – 202327, which
emphasises that forest management and development plans need to include adaptation measures in
order to increase resilience of forest ecosystems and to protect them from forest fires and other
threats.

CCA is integrated though several Forestry Strategy goals, including the following ones:

- Increase productivity, stability and resilience of forests to threats, and improve adaptation of
forests to climate change;
- Improve resilience of forests to climate change and other threats (linked to protection of
biodiversity and ecosystem services provided by forests); and
- Reduce the scale of burnt areas and destroyed biomass by 70% (linked to protection from fires
and adaptation to climate change).

Climate change impacts on forestry and the need for adaptation are also briefly addressed in the
IPARD Programme 2014 – 2020.

Capacity assessment

Mandate of the Forestry Directorate of the MAFWR to address CCA is not stipulated in the relevant
legislation yet the strategic documents and sectoral plans recognise importance of adaptation and
integrate measures and actions considered as responses to climate change. Due to a reasonably long
experience in dealing with CCA, capacities for governance and policy and for leadership and
organisation were assessed with relatively high scores of 1.78 and 1.75 respectively. This means that
in both areas, the Directorate has approached basic capacity: mandate for CCA has been set and
occasionally used to guide actions of the organisation, certain commitment to execute the mandate
exists, and basic organisational structure, management capacity and coordination to address CCA are
in place, even though at insufficient levels to ensure effective planning and implementation of
adaptation measures. A relatively high score (of 1.6) was also recorded for the knowledge
management capacity (part 7.3 of the questionnaire). The EU policies, international convention and
research projects as well as national sources (such as the Forestry Institute) have been identified as
the main sources of learning.

For the other assessed areas – strategic planning; data, information and analysis; human and financial
resources – lower capacities were identified with scores in the range of 1.25 to 1.33. The lowest score
was recorded for the Directorate’s access to and the use/ quality of CCA information, data and
analysis.

The overall score for the organisation was 1.46, indicating that certain progress and achievements in
the development of capacities to address CCA and that the organisation has reached the level of being
half the way between low and basic capacities.

Capacity gaps and needs

Several important gaps have been identified through the assessment process, including the availability
of human and financial resources, ability to implement adaptation programmes and services and
strategic directions integrated in the sector’s policies and plans, and ability to collect and interpret
necessary data. To allow for further development of capacities and for more effective implementation

27
The Strategy also recognizes significance of forests for climate change mitigation, pointing out that forests in
Montenegro act as a sink for around 4.6 million tonnes of CO 2 annually – close to total GHG emissions in 2003
(which were at the level of 5.3 million tonnes of CO2 equivalent).

39
of adaptation measures, a higher number of people is needed and a better understanding (followed
by adequate support) at the decision-making level. Necessary knowledge exists and/ or can be easily
mobilised – from national and/ or international sources. International cooperation and exchange of
experiences, in particular presentation of good practices, are always useful and are necessary under
current conditions.

An important gap was also identified as regards the lack of methodologies and defined procedures on
how to collect and monitor appropriate climate adaptation data, as well as for (the lack of) adaptation
indictors in forestry.

To address the identified gaps, trainings on monitoring and data collection methodologies and
adaptation indicators would be welcome, alongside with provision of up-to-date information on the
application of CCA measures in forestry. To the extent possible, the trainings should include decision-
makers.

2.23 Public Enterprise Morsko dobro


The assessment interview was held on 14 February 2022. Part 3 of the questionnaire was not
completed as the Public Enterprise Morsko dobro (PE MD) does not have a strategic plan on
adaptation. A limited number of answers was provided for part 6 (on financial resources) of the
questionnaire hence the score was not derived. Questions from parts 7.1 and 7.2 (on implementation,
monitoring and evaluation) were found inapplicable for the PE MD.

Description of the institution

PE MD is a public enterprise tasked with management of morsko dobro – the narrow coastal belt and
coastal sea designated as public maritime domain. The laws regulating its work include the Law on
public maritime domain (OGRM 014/92, 059/92, 027/94 and OGM 051/08, 021/09, 073/10, 040/11),
the Law on protection of marine environment (OGM 073/19), the Law on nature protection (OGM
54/16), and others. The main tasks of the PE Morsko dobro are:
- Protection and improvements in the use of public maritime domain;
- Preparation and administration of contracts on the use of public maritime domain;
- Construction and maintenance of infrastructure and infrastructural facilities.
Other competences of Morsko dobro include monitoring of bathing water quality, occasional coastal
erosion, sea water and sediment quality research, management of terrestrial protected areas, and
others. As of recently, PE MD is also tasked with marine protected areas management. The institution
has a staff of around 60; out of this number, four to six persons are working on sustainable
development issues.

There are no specific provisions on the role of PE MD in climate change adaptation planning. On the
other hand, Special Purpose Spatial Plan for the Coastal Area (SPSP CA) which provides overall
guidance for the work of Morsko dobro pays attention to vulnerability of marine and coastal
ecosystems to climate change28 and includes a set of recommendations and measures to reduce the
impacts of droughts, forest fires, torrential rains and strong winds. The coastal setback line at 100 m
distance from the shoreline was introduced through the Plan as a measure29 to protect coastal

28
The Plan uses vulnerability assessment conducted in the framework of the Coastal Area Management
Programme (CAMP).
29
In line with provisions of the Barcelona Convention’s Protocol on Integrated Coastal Zone Management in the
Mediterranean.

40
settlements and infrastructure from negative impacts of coastal processes. The Plan also promotes
development of green infrastructure.

Specific recent activities of the PE MD related to climate change impacts, vulnerability and adaptation
include analyses of impacts of coastal erosion on a number of beaches (in cooperation with Split
University from Croatia), dealing with coastal flooding issues in the protected area of Tivat Salina, and
workshops on the effects of climate exchange on coastal areas organised in cooperation with the
French Coastal Management Agency.

A good example is recent cooperation on the erosion of Ada Bojana beach in Ulcinj where a set of
emergency measures/ embankments has been implemented and there is an ongoing investigation on
designing a more permanent solution. The current activities are supported by the Ministry of Ecology,
Spatial Planning and Urbanism, implemented by international experts in cooperation with national
institutions (PE MD, IHMS, Water Administration). Limited availability of data emerged as an
important limitation in the process, highlighting importance of generation and maintenance of
adequate data for planning of appropriate responses for coastal processes that can be aggravated by
climate change. The PE MD is involved in Ada Bojana activities through provision of available data and
field observations.

Capacity assessment

The PE MD does not have an explicit mandate to address climate change adaptation issues and its
experiences in this area are rather limited. It is however evident that the impacts of climate change
on the coast and coastal infrastructure are intensifying and Morsko dobro is engaging in some activities
to address them within its competences for protection and improved use of public maritime domain.
It is expected that the institution’s role in CCA planning will increase over time.

Morsko dobro cooperates with national institutions and local authorities on the design and
implementation of specific actions related to CCA; cooperation with local level is mainly on a case-to-
case basis. The institution is a producer of data on bathing water quality, state of biodiversity in
protected areas, beaches, and (occasionally and for specific locations) on water, soil and air quality.
The PE MD collects fees from the users of public maritime domain and uses these revenues to fund
coastal developments and infrastructure (directly or in cooperation with local authorities) as well as
for protected areas management. Activities are monitored and evaluated, with results being
presented in the general seasonal and annual work reports, reports on the state of protected areas,
bathing water quality, and others. The main learning sources on the issues related to climate change
include projects and international institutions/ organisations. Morsko dobro has been involved in the
preparation of educational materials (for children) on a range of environmental topics including
climate change, and is integrating climate change in the awareness raising activities implemented to
mark certain dates and actions (e.g. the Coast Day, coastal clean-up day, wetlands day).

The PE MD is not a policy making institution and it does not have a clearly stated mandate to address
CCA issues. Consequently, the score of 1.25 was recorded for governance and policy, indicating low
capacity in this area. On the other hand, there is a commitment and organisational structure is
generally conducive for dealing with CC impacts, so the score of 1.69 was recorded indicating by far
stronger leadership and organisational capacities. The score for knowledge management capacities
(1.6) shows some positive developments too, while data and human resources capacities are still quite
low (with respective scores of 1.36 and 1.33). The overall capacity score was 1.41.

41
Capacity gaps and needs

In order to capacitate the PE MD to address complex issues of CCA in the coastal area, it would be
necessary to clearly define its mandate and responsibilities, and to reflect them in the organisational
structure and job descriptions. This should be followed by capacity building/ training activities aiming
first of all to introduce adaptation to the staff and improve the overall understanding and skills. An
important topic to be addressed through the trainings are data needs for adaptation planning in the
coastal areas, modelling/ use of models, and how could the existing data sets be improved (e.g. linking
of data, geo-referencing)30 to facilitate adaptation planning and implementation.

2.24 Ulcinj Municipality


The assessment interview was held on 17 February 2022 with representatives of the Secretariat for
communal affairs and environmental protection. The interviewees provided answers for the parts of
the questionnaire applicable to the current situation with addressing the CCA issues by the
Municipality (parts 1, 2, 4, 5 and 7.3). For part 6 on financial resources, the number of provided
answers was not sufficient to derive a representative score.

Description of the institution

Ulcinj is a coastal municipality with the total surface 261 km2 and population of 19,921 (at the last
census). The existing vulnerability assessments show that the low-lying coastal area, with Bojana river
delta and Skadar and Sasko lakes in the hinterland, represent a system that is particularly vulnerable
to climate change impacts. The main economic activity in the municipality is tourism; agriculture plays
an important role in rural areas.

Local self-government is organised through a number of Secretariats. Climate change responsibilities


are not assigned to either the Secretariat for spatial planning and sustainable development or the
Secretariat for communal affairs and environmental protection, which could be the local government
bodies to deal with CCA issues. The environmental Secretariat has a staff of 9, while as a total of 15
positions are envisaged; job descriptions do not include any references to climate change.

Strategic development plan for Ulcinj Municipality 2016 – 2020 does not consider climate change but
the Spatial Urban Plan does quite extensively. The Plan refers to the available vulnerability
assessments for Ulcinj area, recognising climate-related risks, in particular risks from flooding in the
context of climate change. Flood protection measures are proposed to address the identified risk.

Capacity assessment

Municipality of Ulcinj does not have a clearly stated mandate to address CCA issues but it has certain
competences and a strategic framework that allow for its engagement in CCA activities. Examples of
practical actions that could be considered as adaptation ones include cooperation on resolving Ada
Bojana erosion problems, pilot project for afforestation of bare areas and the background of Long
Beach, and others. With the exception of some public utilities (founded by the Municipality), the
institution does not generate data (CC related or other). For its work on CCA issues, the Municipality
relies to a significant extent on the data from the Spatial Urban Plan, while as data from other sources
is used as well. Reports on the implementation of different activities are prepared on an annual basis,

30
This as the experience with Ada Bojana case showed that much of the available data was not useable to
analyse the issues and propose adequate solutions.

42
and are submitted to the Municipal Assembly for adoption. The main sources of learning on
adaptation so far included relevant national documents and legislation.

Through the limited experiences in considering, planning and implementing activities aimed at
adapting to climate change, Ulcinj Municipality has made a modest progress in developing CCA
capacities, having the overall score of 1.38. The strongest capacities were recorded for leadership and
organisation (1.63), which means that the organizational structure, management capacity and
coordination and cooperation for addressing CCA issues is approaching basic level. On the other hand,
less progress has been identified for the areas of availability, quality and use of data, information and
analysis on CCA, human resources and knowledge management where the scores were in the range
of 1.2 – 1.3.

Capacity gaps and needs

There are significant gaps that need to be overcome in order to capacitate the Municipality of Ulcinj
to plan and implement CCA measure and activities effectively. A clearer formulation of mandate, new
employment (to fill currently vacant positions) and trainings are needed to that end. More support
from the central level would be welcome, as local self-government units often have quite limited
financial resources (initiative to address Ada Bojana erosion is a good example where central level
provided strong support). As regards the trainings, round tables and/ or seminars providing
opportunities for the municipal staff to get acquainted with the new achievements, analyses and
opinions on adaptation are needed.

3 Conclusions and recommendations


The assessment presented above allows for a number of conclusions and recommendations on the
capacities of a range of public sector institutions for adaptation planning and implementation as well
as on the capacity building and training needs.

Overall weak coordination and cooperation on CCA has been detected, where ad hoc approaches
(from project to project and/ or driven by individual interests and capacities) prevail. Capacity scores
were mainly in the range between low and basic, with very few institutions having a score of 2 or
higher for certain capacity elements. Strong capacities were not identified for any of the assessed
institutions (for any element). In such a context, preparation of the NAP gains importance as an
opportunity for setting up the framework for systemic and coordinated response by all the relevant
institutions. The identified training needs make a sound basis for the formulation of a capacity
development strategy for the next 2 – 5 years, the parts of which could be taken up by other projects
(current and forthcoming) addressing climate change adaptation.

The following specific conclusions can be drawn:

1. In interpreting results (scores) of the assessment it should be kept in mind that answers were
provided by a range of institutions with diversified mandates; assessing their capacity through
a single matrix was a challenging process. Different institutions were able to provide answers
for different parts of the questionnaire, depending on the areas of their work, individual
expertise and experiences. In some instances, capacities for execution of the core mandate
had an impact on the assessment of CCA capacities, mainly by driving the assessment scores
to somewhat higher levels.

43
2. Only two out of the 25 assessed institutions/ organisational units had a written plan or
strategy for adaptation, and only two reported their staff was using more than 25% of work
time on adaptation issues (one of the two for a limited period of time); hardly any institutions
had climate change responsibilities specified in the job descriptions. As regards budgets,
provisions for implementation of adaptation goals/ priorities were reported in one case only.

3. About half the assessment scores (for different institutions and capacity elements) were
below 1.5, indicating critically low capacities. The overall scores at or approaching basic
capacity level (scores higher than 1.7) were assessed for one fifth of the surveyed institutions/
their parts, while only in few cases (for some elements) the scores went above basic towards
strong capacity level.

4. By capacity element, the lowest average scores were recorded for human (1.39) and financial
resources (1.42), and for data, information and analysis (1.46). This means that overall, the
assessed institutions do not have adequate numbers of trained staff—at leadership,
management, and technical levels – to address CCA issues, while the availability of training
courses (through the education system and outside it) is insufficient. Moreover, funding for
CCA activities is not secured (in principle) and the ability of institutions to access finance is
low. Finally, the assessed institutions as a whole are not generating or using (not having access
to) quality climate change adaptation data, information and analysis.

5. Exceptions to the ‘rule’ of prevalent low institutional capacities are usually found in cases
when due to individual efforts/ interest and/ or through specific projects some breakthroughs
have been achieved; in some instances, individual capacities exceed the institutional ones.

6. Mandates (for CCA) are usually not clearly defined; international processes often act as a
driving force behind integration of CCA into policies and strategic documents. Overall, a low
level of integration of adaptation into legal frameworks and sectoral strategies31 was found,
with some visible improvements as of 2019.

7. As already mentioned, human resources were identified as the weakest point in the
institutions that are or will be shaping responses to climate change and adaptation measures
in Montenegro in the coming years. All the institutions reported lack of staff, and hardly any
had a situation where at least one staff member was spending a significant share of his/ her
time on CCA in continuity. Contact persons for adaptation are rarely assigned, almost never
formally.

8. Cooperation/ coordination was rarely assessed as effective.

9. As a rule, adaptation does not play an important role in priority setting and undertaking of
practical actions/ everyday management.

10. Capacities to design and implement adaptation programmes/ services also appeared as
critically low; capacities for monitoring and evaluation and for knowledge management were
assessed as somewhat higher (with scores closer to 2). It should be noted that only 7
institutions provided answers for the questionnaire parts 7.1 and 7.2 on the design and
implementation, and monitoring and evaluation; for part 7.3 on knowledge management, 17
institutions were able to provide feedback (which makes the overall results more
representative).

31
More details provided in the related analysis of relevant laws, strategies and plans.

44
11. Questions on mobilisation of funds through public private partnerships, sustainable finance
initiatives, green/ sustainable bonds, Environment, Social, Governance criteria and application
of climate or sustainability checks by banks were not answered by a vast majority of
interviewees, indicating these are new topics to many and that training on these aspects and
on the access to adaptation funding in general would be useful.

12. Gender, cultural and socio-economic factors and Just Transitions aspects are hardly ever
incorporated in adaptation planning/ activities of the assessed institutions.

13. No progress was detected as regards capacities to set realistic targets for appropriately chosen
CCA quantitative and qualitative indicators (i.e. all the institutions responding to the
respective question said they were not setting such targets at all).

14. Availability of staff for the trainings i.e. possibilities for many interviewees to set aside
necessary time to attend trainings is a limiting factor which should be taken into account when
designing the training programme; options to use flexible approaches (including online
training modules that can be taken at different periods of time) should be considered.

15. The trainings should be purposeful, aligned with tasks/ responsibilities of the trainees and
with available resources (numbers of staff that could attend); all trainings should include
practical examples to the extent possible.

16. The institutions that have reached somewhat higher capacity level for CCA include the
Department for applied meteorology of the IHMS, Climate change department of the MESPU,
Directorate for Protection and Rescue of the Ministry of Internal Affairs, Investment
Development Fund and Podgorica Municipality.

17. Low capacities have been identified for water management institutions, agriculture, tourism
and health sectors (with the exception of Public Health Institute for the latter), as well as for
local authorities (with the exception of Podgorica).

In the subsequent paragraphs, the key recommendations on the trainings/ training programme are
presented.

The delivery of trainings (eight two-day workshops for at least 75 individuals from public sector
institutions) could be organised in a way as to bring together individuals from different institutions
(including local level) for a range of topics, but also to ensure sessions are available for a more
homogenous audience and for more specialised topics. Good examples could be:

a) Training on adaptation programmes and services for agriculture for IHMS, Biotechnical
Faculty, Ministry of Agriculture – Agriculture and Payments Directorates, Extension Services,
local level extension services/ local agricultural secretariats;
b) Training on the generation, analysis and use of health data in the context of CCA for Public
Health Institute, Ministry of Health, hospitals and Health Centres management;
c) General approaches to adaptation for mixed audience.

The eight training events could encompass:

a. Three basic adaptation training sessions focusing on general information and


adaptation approaches for mixed audience, possibly with specific modules on the data
needed for adaptation planning in different sectors and access to adaptation funding;

45
b. Five specific trainings focusing on hydro-meteorological service, and on agriculture,
water management, health and tourism sectors.

Possible topics/ ideas32 for the trainings and other capacity building options include:

1. Adaptation indicators
2. Adaptation advocacy and communication
3. Green infrastructure
4. Health vulnerability assessments
5. Integration of adaptation topics in the university curricula for agriculture and forestry study
programmes
6. Networking with relevant research centres for adaption in agriculture; exchange options for
PhD students
7. Projections for different crops/ yields under various climate scenarios
8. Methodologies to monitor organic carbon content in soil
9. Adaptation measures in water resources measures with examples of the KTM 24 (Key Types
of Measures, as defined under the Water Framework Directive) from different countries
10. Mainstreaming adaptation into the next cycle of River Basin Management Plans preparation
11. Development of water information system with integration of topics relevant for adaptation
planning (with examples from other countries)
12. Assessment of climate change risks in attracting/ promoting foreign investments in the
framework of planned greening
13. Awareness raising activities for CCA in water resources management
14. Examples of adaptation measures in agriculture, climate-resilient agriculture
15. Data needs for planning of adaptation measures in agriculture
16. The EU agricultural policies and adaptation to CC; the role of Payment Agencies in the
implementation of adaptation measures
17. Methodologies for monitoring and data collection in forestry; indicators
18. State of the art knowledge on forestry adaptation measures
19. CCA policies and measures for the protection of marine and terrestrial ecosystems; CC impacts
on protected areas
20. Environmental monitoring and adaptation: options to expand monitoring programmes to
generate data relevant for adaptation planning
21. Mainstreaming adaptation into nature protection (studies of protection, guidelines and
conditions for nature protection)
22. General adaptation training for the member of the National Council on Sustainable
Development Working Groups
23. Capacity building for local authorities, transfer of experiences, good practice cases (nationally
and regionally)
24. Examples of adaptation measures for urban areas
25. Data needs and use in CCA adaptation planning for cities
26. Integration of adaptation into protection and rescue plans and linkages with Disaster Risk
Reduction
27. Integration of CCA into financing programmes (Eco-fund, Investment Development Fund)
28. Exchange of experiences among financing and investment institutions (Eco-fund, Investment
Development Fund, Foreign Investment Agency)
29. EU technical guidance on climate proofing for infrastructure projects
30. Improving access to adaptation funding

32
As gathered through the assessment process, pertinent not only for the eight training events but for the
Capacity Development Plan as well.

46
31. Cooperation for improved collection and access to statistical data of significance for
adaptation and climate change
32. Procedures for collection of data on fires
33. Adaptation in the context of protected area management
34. Methods for the assessment of marine ecosystem vulnerability of climate change; use of ICT
35. Attracting adaptation funds for local governments and examples of successful adaptation
measures
36. Integration of CCA into spatial planning
37. Examples of good practices in CCA adaptation in tourism sector
38. Adaptation planning in coastal areas and data needs

47
Annex 1: Overview of the assessment meetings
Overview of the assessment meetings held is provided in the table below

Meeting/s No of
No Institutions/ their departments
held on participants
Institute for Hydro-meteorology and Seismology - departments for applied
meteorology and climate change, air and water quality, hydrological 10 and 17-
1 7
monitoring, hydrography and oceanography, and UNCCD Focal Point Dec 2021

2 Public Health Institute 16-Dec-21 2


3 Ministry of Health - Public Health Directorate 17-Dec-21 2
4 Biotechnical Institute 20-Dec-21 3
Ministry of Agriculture, Forestry and Water Resources - Agriculture
5 17-Dec-21
Directorate 3
Ministry of Agriculture, Forestry and Water Resources - Water Resources
6 21-Dec-21
Directorate 3
7 Water Administration 21-Dec-21 3
Ministry of Ecology, Spatial Planning and Urbanism - department for
8 22-Dec-21 2
climate change
9 Ministry of Internal Affairs - Protection and Rescue Directorate 23-Dec-21 1
Ministry of Ecology, Spatial Planning and Urbanism - departments for
10 integrated management of marine and terrestrial ecosystems and for 23-Dec-21 2
sustainable development
11 Environmental Protection Agency 21-Dec-21 5
12 Environmental Fund 28-Dec-21 3
13 Investment Development Fund 29-Dec-21 1
14 Foreign Investments Agency 30-Dec-21 1
15 Podgorica Municipality 27-Dec-21 3
16 Statistics Administration Monstat 17-Jan-22 2
17 Regional Park Piva 27-Jan-22 1
18 Marine Biology Institute (online meeting) 28-Jan-22 5
19 Association of Municipalities 07-Feb-22 2
20 Agricultural Payments Agency 07-Feb-22 2
21 Pluzine Municipality (online meeting) 08-Feb-22 1
Ministry of Economic Development and Ministry of Health - Tourism
22 09-Feb-22 3
Directorate and health tourism Department
Ministry of Agriculture, Forestry and Water Resources - Forestry
23 11-Feb-22 2
Directorate
24 Public Enterprise Morsko dobro 14-Feb-22 2
25 Ulcinj Municipality 17-Feb-22 2
TOTAL NUMBER OF PARTICIPANTS 63

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Annex 2: Questionnaire used for the capacity gap assessment
To be annexed

49

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