Complaints to the Energy Community over the construction of hydropower plants on the Neretva River in Bosnia and Herzegovina15. September 2020. /
In the upper course of the Neretva river, a genetically unique species of endemic brown trout of the Adriatic haplotype survives, and their preserved habitats indicate the need for protection. For this reason, hydropower construction projects are a very poor choice and there is no public interest and justification for further investment in hydropower projects in this area.
Due to the violation of the rules of the Energy Community regarding the planned construction of hydropower plant (HPP) “Ulog” and both phases of HPP “Gornja Neretva” within which the construction of seven small hydropower plants (SHPP) on the Neretva River, Environmental Center and Aarhus Center in BiH, along with international organizations RiverWatch, EuroNatur, CEE Bankwatch and ClientEarth, have filed complaints with the Energy Community.
The seven SHPPs planned in both phases of the HES “Gornja Neretva” project, together with HPP “Ulog” (35 MW), practically represent a complex series of power plants that continuously stretch over several kilometers of the Neretva River, destroying its entire upper the flow. The environmental impact studies of these plants also contain a number of shortcomings, as most of the biodiversity data used were actually taken from locations where these projects were not planned at all. The studies speculate which species are present in these locations, and the negative impacts on individual species such as otters, bears, wolves and various birds that depend on a healthy fish population have not been consistently analyzed. Namely, the environmental impact study must specifically identify, describe and appropriately assess the immediate effects of the project, but must also include an analysis of the cumulative environmental effects that the project may produce, when considered jointly with other projects.
However, the competent authorities, which are otherwise responsible for ensuring and conducting an adequate assessment, have failed to anticipate the degree of complexity of the adverse environmental impact in this area, which is, among a number of other irregularities, the main reason for these complaints.
“The construction of all planned plants practically means that they will continuously stretch from about eight kilometers from the source to 38 kilometers from the source (a total of as much as 30 km) with only one distance of two kilometers between Ulog and Uloški Buk. Bearing in mind that HPP ‘Ulog’ practically reaches the entity border with FBiH, this means that these hydropower plants would directly affect three quarters of the river to the entity border. If these plans continue, the upper Neretva will be completely transformed from a river into a series of reservoirs and pipelines, which is not only contrary to the undertaken obligations, but also completely unacceptable “, said Nina Kreševljaković, legal advisor of the Aarhus Center in BiH from Sarajevo.
In May, the Center for the Environment and the Aarhus Center also filed a lawsuit in an administrative dispute against the decision of the Ministry of Physical Planning, Construction and Ecology of the RS, by which the holder of the project “MHE Marvel” d.o.o. Kalinovik releases the obligation to conduct an impact assessment and obtain a new environmental impact study for the HES “Gornja Neretva” Phase I project, since it has ceased to be valid.
However, while this lawsuit is still pending, the investor in HPP Ulog, which is planned downstream on the same river, began blasting the riverbed in June and preparatory work that has serious consequences for the upper Neretva.
“Among other ambiguities, we also know that the economic justification of the HES ‘Gornja Neretva’ project is threatened by the construction of a transmission line about 40 kilometers long. No impact study mentions any assessment of the cumulatively harmful impact of all HPPs on the Neretva Basin or this infrastructure, and the transmission line and network connection are mainly funded by the state, so it is not clear what impact its construction and deforestation associated with construction would have on living environment and society,”said Viktor Bjelic, vice president of the Center for the Environment.
Download as PDF :