Croatia HPPs and breach of EIA SEA framework, NGOs
The EIAs for the ﬁve case studies in Croatia were prepared by the same consultancy, “Elektroprojekt”, which was originally founded in 1949 in Zagreb under the name “Hidroelektroprojekt”. The promoting company for the schemes is Hrvatska Elektroprivreda.
HPP Kosinj and HPP Senj (2) are two large schemes which are being promoted separately, but are located on the same river. The original design work for both projects was carried out in the 1960s (or possibly earlier). EIAs were prepared in 1986 but the schemes were not developed. In 2008, the Ministry of Environmental Protection, Physical Planning and Construction (MEPPPC, now Ministry of Environment and Nature Protection) issued a decision that the old studies were invalid. The promoter began additional survey work in 2012 and, in 2013 the Ministry of Environment issued instructions on the content of mandatory EIAs under Annex I of the regulations since the proposed storage capacity for HPP Kosinj alone was in excess of 300 million m3.
The proposed HPP Ombla, in the Dubrovnik spatial plan is another long standing project which was subjected to an EIA in 1999. The search for development funding began and the European Bank for Reconstruction and Development (EBRD) initially agreed to advance a loan of €123 million, representing 80% of the construction cost, subject to a condition that a biodiversity assessment of the area should be undertaken. Intensive lobbying followed from more than 30 NGOs, and in 2013 EBRD decided not to ﬁnance the project. The promoter undertook further environmental studies in the same year but in November 2014 MoE issued a decision noting that “it is not possible to exclude the possibility of signiﬁcant adverse eﬀects on the conservation objectives and integrity of the ecological network” and requiring a full ecological assessment. This assessment has subsequently been rejected by the Ministry of Environment and Nature Protection.
Investors were invited to tender for construction of SHPP Ilovac, in the spatial plan of Karlovac County, in March 2010. Five months later a public debate on an EIA was announced to take place between 24th June and 25th July, 2010. Four months later, in November 2010, the Ministry of Environment granted an environmental licence. The procedures relating to the EIA were contested by NGOs and CSOs and the decision to approve was subsequently modiﬁed twice by MoE although it ruled in 2012 that it was not necessary for the promoter to carry out further EIA studies. Construction of HPP Ilovac began in 2014.
HPP Lešće on the river Dobra is another large scheme designed in the 1960s and an EIA was prepared in 1986. The scheme was ﬁnally constructed in 2010, based on the original permits with no new surveys in the intervening period. The approving authority was the former Community of Municipalities, whose legal successor is the Karlovac County. No records exist of the 1986 EIA. The turbines of HPP Lešće have an installed capacity of 42 MW and the dam is 52.5 metres high. It has ﬂooded the Dobra canyon which had high landscape value and was a habitat for a number of threatened species such as the Danube salmon which spawned in the shallow gravel beds (only breeding place in Croatia). The 32 caves associated with the canyon provided a refuge for a number of unique subterranean species as well as to the long-ﬁngered bat. The Lešće project features in current campaigns against new dams in Croatia involving a number of NGOs who are supported by Zrinka Cvitešić, a prominent Croatian actress. A freshwater projects oﬃcer for WWF1 has described HPP Lešće as “A really bad example, where the investor submerged 12 km of a beautiful canyon together with habitats of several endangered and protected species. The initial estimated cost of the project was 60 million euros which has grown to over 100 million euros, and that’s without the necessary mitigation measures for the local community, which now has to contend with the consequences – downstream erosion, polluted water and ﬂooded ﬁelds”.
source: WWF & SEE Change Net
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