Public at a Distance – Democracy in Crisis

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Legally stipulated participation and recommendations

Recommendations for improvement of the process of participation in the procedure of adoption of planning documents

Public inspection of the draft of the planning document is announced in electronic form on the web site of the local government unit, on the web site of the handler of the planning document, and in daily and local newspapers. Common practice shows that small percentage of citizens visit the web pages of the local government units, while announcements published in daily newspapers reach only specific and limited number of citizens. Mere title of the planning document cited in the announcement often fails to indicate its reach, which is why citizens find it difficult to decide whether a specific announcement is of potential interest to them. Formally, announcements may contain graphic depictions of the area addressed by the planning document in preparation. However, as a rule, this opportunity is not used.

Escalation of citizens’ revolt most often comes from the fact that they had not been timely informed about the procedures which resulted in adoption of a contentious planning document. Additional efforts to increase the quality of informing citizens would in turn increase the prospects for satisfactory results of public consultations for all the participants whose lives may be affected by the planned interventions. Advantages of such approach justify additional investments in implementing this measure.

Additional methods include:

  • Direct informing of the residential communities affected by the planning document
  • Placing announcements of public inspection in community centers and all public buildings within the reach of the planning document in preparation,
  • Announcements on the radio or in specialized TV programs (for example „Belgrade Chronicle“ of the public broadcaster RTS)

Graphic documentation of the plan in preparation is displayed in a basement room of the Administration of the City of Belgrade, while its textual segment is most often directly accessible only in the presence of representatives of the plan’s handler (on working days, during the working hours). Although the regulations stipulate that the entire documentation of the adopted plans has to be made accessible to the public on the Internet, these legal provisions are not implemented.

Textual and graphic documentation of the draft plans is available on the web site of the Administration of the City of Belgrade, however, its overall availability varies from case to case. The graphics are available in formats which require specialized software, which makes their accessibility to the citizens additionally difficult.

Inspection of the planning documents in preparation takes place in the basement of the premises of the Administration of the City of Belgrade, in a way which fulfills the stark formal provisions. However, this room is inadequate for public inspection purposes. Documentation is displayed in the hall at the basement floor which does not fulfill the basic requirements of accessibility – it can be reached only by using the staircase. Equipment of this basement hall is not adapted to the activities taking place there. It is also used as storeroom of work documentation of the City Administration. Graphic material from the planning documents is displayed on the walls of the basement hall. Occasionally, there is no control of the displayed documents, which is why the drawings might fall off the walls. When several plans and urban designs are on display at the same time, there are no clear guidelines for orientation, which obstructs the citizens’ access to information. 

In Belgrade, as a rule, a representative of the handler of the planning documents is present and available to citizens on Tuesdays and Thursdays, between 12 and 18hrs. Existing regulations do not require that this person should be a member of the team which had prepared the displayed planning documents. For the citizens who are unable to visit the basement of the Administration of the City of Belgrade during these hours, there is no other possibility to get professional help in understanding the proposed planning solution from the formally responsible persons.

Although the activities taking place at the public session of the Planning Commission are colloquially called „public discussions“, this in fact not the case. The right to address the Planning Commission is granted exclusively to those representatives of the interested public who had previously submitted formal objections. At the public session, representative of the handler reads a brief overview of the submitted objection, accompanied by a prepared response. Submitter of the objection is then allowed to state his case. The Planning Commission’s final position on the objection is adopted at the part of the session which is closed for the public. It is clear that the public sessions of the Planning Commission offer no opportunities to discuss the proposed solutions. They are rather conceived as a formal conclusion of the procedure of public inspection – more precisely, that part of the procedure which is open for the public and informs citizens about the attitude of the plan’s handler towards the submitted objections. Thus conceived procedure of public inspection, which gives no opportunities for genuine exchange of opinions on equal terms, diminishes the chances for a positive outcome of the planning process.

Objections to the draft plans are submitted in a written form through the office of the responsible authority, and objections submitted by mail are also accepted. What the Secretariat does not accept (and this would considerably improve the participatory process) is introduction of an e-mail address by which citizens could also submit their objections.

Public sessions of the Planning Commission of the Belgrade City Assembly are not held in the same premises as the public inspections of planning documents, but in the adjacent building, on its 20th floor. The room is accessible only by the elevator, and cannot be considered as adequate for this kind of public events. On numerous occasions its capacity proved to be insufficient to accommodate all interested citizens in addition to representatives of the handler and responsible authorities.

Right to address the Planning Commission of the local government unit, during a public session of this authority, is granted only to those citizens who had previously submitted objections to the contents of the draft plan. Public sessions of the Planning Commission of the Belgrade City Assembly take place during the working hours of public institutions, that is, at a time which most of the citizens spend at their workplaces. Because of that, many citizens who had submitted objections cannot attend the public sessions and exercise their right to speak. Existing regulations do not allow citizens to appoint a proxy who would address the Planning Commission on their behalf, so in (Belgrade) practice this right is exercised selectively.

Agenda of a public session of the Planning Commission of the Belgrade City Assembly is not available to the public. Citizens are informed on the timetable of public sessions only via announcements of public inspection of draft plans. It often happens that consultations on several projects are planned for the same public session, and citizens are not aware of that. Moreover, citizens interested in public consultations on different drafts plans are invited to public sessions at the same time, as a rule, at 13hrs. This results in unnecessary waste of their time. They are forced, sometimes for hours, to wait for the discussion of the planning document they are interested in.

In practice, when the number of objections is high, the Planning Commission holds more than one public consultation on the draft of the planning document. The Commission has information on the number of objections considerably before the public session. Nevertheless, citizens are informed on the decision to hold another session only at the end of the current session, which makes it difficult for them to adequately plan their time. It has also been noted that the Commission limits the duration of the discussion in which interested representatives of the public have the right to explain a previously submitted objection.

Ban of unauthorized audio and video recording of the public sessions of the Planning Commission is still in force, in spite of the increasing number of requests to allow recording of such events. Besides, in spite of the fact that audio recordings of each public session are made by the responsible authorities, these recordings are not available to the public. Such practice reinforces citizens’ perception of the work of the authorities responsible for preparation and adoption of planning documents as non-transparent.

Regulations pertaining to procedure of preparation of planning documents recognize the need for repeating some of its segments, and stipulate the conditions for approaching such activities. However, they do not define more precisely the character of changes considered as highly important, as essential changes of the planning document. Decisions on the necessity to repeat certain steps in preparation of the draft plan – public inspection of the entire draft or one its segments – are left to the responsible authority i.e. the Planning Commission.

Nevertheless, in Belgrade, very few citizens are given an opportunity to comment about the changes of the draft plan adopted after the conclusion of the Planning Commission’s public session, in a repeated public inspection. This is the case regardless of whether or not the Planning Commission’s final decisions about the objections submitted by citizens and institutions affect the exercise of citizens’ rights.

At closed sessions held after the conclusion of public inspection, the Planning Commission adopts a decision about each submitted objection, which enters the public inspection report. Existing regulations do not oblige the responsible authorities to inform citizens on the contents of this report individually and in a timely manner, nor is it publicly available – which directly affects the legally prescribed possibility of requesting amendments to the plan.

Numerous difficulties related to this procedure would be notably avoided if the responsible authorities worked more on timely informing citizens about the outcomes of public inspection of the planning documents. These activities do not require considerable investments. Namely, visible positive effects of such measures would be accomplished by simple posting of verified public inspection reports on the web page which announces public inspections of planning documents.



For detailed explanation of each of these recommendations and more details on the relevant documents, see our publication and chapter Legally stipulated participation and recommendations, in Serbian, or the Serbian version of our web site.