The company "Gener 2" published a text on Tuesday titled "10 facts on the legal and administrative status of the project in Velipojë", claiming that the "Blue Borgo" project is in compliance with the law and that the debate over property claims is based on "misinformation".
But official documents obtained by Citizens.al through institutions and field reports show that many unanswered questions remain about the project. Below are ten of them.
It is our responsibility to emphasize that our editorial team reached out to them on at least two occasions with requests for comment, but as of the publication of this article, there was no response.
1- Were the works of a year ago legal?
In March 2025, residents of Rrjoll clashed with a group of workers who were starting the development of the “Blue Borgo” project. The situation escalated after police intervention as residents denounced their claims that the “Gener 2” company was trying to take their land.
The company responded with a six-line statement. It confirmed that the project had begun development, but denied the allegations, insisting that everything was in compliance with the law.
"Gener 2" turns out to have obtained an implementation license for the project (NZ.4586/34) on September 16, 2025. While the construction permit decision was signed on August 8, 2025 and the permit was issued by the Territorial Development Agency (TDA) only on January 15, 2026 (Construction Permit No. 360/1).
This means that the preliminary works of 2025 were before the full conclusion of legal procedures.
2- Has the ownership status been fully verified?
"Gener 2" says that it has entered into a contractual relationship with "the party that appears as the holder of the property rights" and that it has not violated anyone's rights.
“[…] the project is based only on final decisions, certified at all levels of the judiciary,” one of the reactions said.
However, “Gener 2” has not shown a summary of these decisions, the underlying title of ownership, the chain of property transfers, or documents proving the legal certainty of the transactions.
In the construction permit layout, "Gener 2" appears as the designer along with Stefano Boeri's architectural studio, while the developer is another company owned by the Ulaj family, "ABA Blue Borgo," which implies that the third party is also an Ulaj venture.
In a project of this size, transparency over ownership is a key element for the credibility of the investment.
3- What is the Shkodra Prosecution Office investigating?
According to "Gener 2", there does not appear to be a single act suspending the continuation of the project.
"The property and the relevant process have passed the necessary review stages according to the relevant framework, and on this basis there is no legal obstacle to the normal continuation of the works," the company said.
However, the Shkodra Prosecution Office has confirmed to Citizens.al that there is an open criminal proceeding on this matter, based on the materials referred by SPAK (Procedure No. 390/2025 referred by the Special Prosecution Office on March 21, 2025) on the basis of the report made by residents for alleged falsification of property titles.
Although investigations are still ongoing, the fact that there is a criminal proceeding indicates that some aspects of the project are still under scrutiny by the justice system.
4- Why is there no sign with the permit displayed at the construction site?
After clashes and warnings from residents, a sign was placed on the side of the Shëngjin-Velipoja road, which, despite talking about the project, was not accompanied by the whitewashed and signed permit of the National Council for Territory and Water (KKTU).
The table shows that the investment is estimated at around 26.8 billion lek (280 million euros), that the works are expected to last 5 years (60 months), and when the "Gener 2" company received the implementation license.
The table does not have information on cadastral positions, 3-D views of the project, placement of structures to be built, topographic map, technical indicators for border property plots, property distances, construction intensity, land use coefficient, etc.
5- How informed was the local community?
The company says the project was presented in public consultations and that there were no objections.
According to the National Environmental Agency (NEA), a consultation was held for the project in September 2024, as part of the Environmental Impact Assessment (EIA) procedures.
The consultation is reflected in the non-technical summary of the environmental report, where the project is presented as a tourism development “with manageable environmental impact”.
But residents of the area have publicly stated that they only learned about the project when field work began.
This creates a contradiction between the official narrative and the perception of the local community as long as there has been no other clarifying reaction from public institutions.
6- How was the project exempted from the infrastructure impact tax?
The Municipality of Shkodra has confirmed to Citizens.al that the project is exempt from paying the infrastructure impact tax.
However, so far, the specific administrative act establishing this exemption for the "Blue Borgo" project has not been made public, nor has the detailed legal basis justifying it.
According to the local tax scheme, for a tourism investment of this size in Velipoja, the infrastructure impact tax rate is around 3% of the investment value.
If the publicly mentioned project value – around 280 million euros – is taken as a reference, then the potential infrastructure impact tax would amount to around 8.4 million euros.
Until the document justifying the exemption is published, it remains unclear how and on what basis a fiscal obligation of this magnitude was forgiven.
7- Does the project meet the "brand name" criteria for tax exemption?
The law on local taxes provides for a special exemption from the infrastructure tax for 5-star accommodation structures, a special status, but only if they are operated by an international "brand name" hotel brand.
So far, neither in the public communications of "Gener 2" nor in the documents made public by the institutions has there been any mention of any international hotel brand that will operate the "Blue Borgo" resort.
In the absence of this element, the question that remains is whether the project truly met the legal conditions for exemption from the infrastructure tax or not.
8- Why is the project not listed as a strategic investment?
The Albanian Investment Development Agency (AIDA) confirmed twice to Citizens.al that no decision has been made by the Strategic Investment Committee for the "Blue Borgo" project.
This means that the project does not have the formal status of strategic investor, a status that is often used to justify fiscal incentives or expedited procedures.
In this context, it remains unclear on what other legal mechanism the exemption from the infrastructure tax is based.
9- Does the project affect a protected area?
The area where the “Blue Borgo” resort is being built was part of the Buna River-Velipoja Protected Landscape, specifically in subzone 1b, where the second level of environmental protection was applied. This category aimed to preserve biodiversity and the natural landscape, allowing only economic and tourist activities that did not violate the protection objectives.
However, the amendments approved in 2024 (when the project was conceived) to the Law on Protected Areas included the concept of "tourism of excellence", which allows the construction of high-standard tourist accommodation structures even within protected areas.
Organizations such as the Center for the Preservation and Protection of the Natural Environment in Albania (PPNEA) have warned that this approach could pave the way for intensive tourism developments in territories that were previously primarily intended for conservation.
"Gener 2" itself has not spoken about this part and has not clearly guaranteed what measures it has foreseen to reduce the impact on the area's environment.
In this sense, the conflict in Rrjoll is not only related to a single resort, but also to a broader debate: whether protected areas should remain priority spaces for nature conservation or be transformed into tourist development areas.
10. If the documents are so clear, why aren't they all published?
In its public response, "Gener 2" states that it is ready to make the relevant documentation available.
However, despite Citizens.al's electronic requests, so far no press conference has been held by the investor and no complete file has been made public that includes: the act of exemption from the infrastructure tax, proof of the "brand name" partnership as an international hotelier, the list of conditions set by the KKT, and the documents proving their fulfillment.
Until these documents are made public, the "Blue Borgo" project will continue to remain not only a major tourist investment, but also a story with many open questions. /Citizens.al/
