SUBMITTED ANSWERS TO THE CONSULTATION QUESTIONS
Public consultation on the list of potential
Projects of Energy Community Interest (PECI)
In line with the Energy Community Secretariat's commitment to transparent and interactive policymaking, this
document aims at providing an overview and general impression of the answers submitted to the Secretariat
in the context of the public consultation on the Projects of Energy Community Interest. The statements and
opinions expressed in the document do not necessarily reflect those of the Energy Community Secretariat
and the Task Force on the Energy Strategy.
Consultation period:
From 07/03/2013 to 29/04/2013
In general
The Secretariat received 47 contributions on the public consultation on the list of potential Projects of Energy
Community Interest (PECI).
The contributions will be displayed in four categories
NGOs
Industry
Ministries and other governmental bodies
Civil society
NGOs
Your Details
Title:
Ms.
First name:
Ana
Last name:
Rankovic
Name of organization:
NGO Fractal
City:
Belgrade
Country:
Serbia
Email: *
[email protected]
Phone No:
+381 (0) 11 3243 372
General Comments
You are invited to provide your general comments in this section
Western Balkan countries should become compliant with EU Directives, Regulations, and Strategies in a timely manner. Since
1
energy projects take many years to come “on-line” and have a life span of at least 30 or 40 years ECT countries should not be
investing in projects now which will have to be reversed in the future or lead to carbon lock in which would be expensive to
reverse in the medium term. Instead, they need to start now with planning energy sectors aiming towards decarbonisation and
massive greenhouse gas emissions reductions. Financial mechanisms and baking from EU public financing institutions such as
the EBRD and EIB should set the tone for investments rather than following existing markets, halt investments in fossil fuel
projects of all kinds – which are effectively subsidized given that they confer a benefit on the recipient - and instead set the pace
that is needed to improve the transmission network, energy efficiency and savings, and renewable energy projects. Related to
above, criteria for evaluation of projects should consider the following: It is welcome that the CO2 price is taken into account in
the calculations, however the pricing used by the ECTS hired consultants goes only up to EUR 16.90 per tone in 2022. Such a
price will not lead to significant CO2 reductions in the EU, and cannot ensure that PECIs will be in line with a trajectory of 80-95%
GHG cuts by 2050. Thus it is necessary to introduce additional elements into the calculation – either higher carbon prices and/or
a shadow carbon price. Qualitative information on the environmental and/or social impact of the projects should be taken into
consideration during the assessment, as outlined on the PECIs open day in Belgrade. Citizens in region (tax payers) are bearing
negative externalities of present structure of production and enormous costs on health, quality of soils, pollution of water,
acidification of soils, social costs of resettlement, etc. Health costs of burning certain kinds of fuel (mainly coal)and other costs
which are currently NOT counted in the calculation– but which can be significant and may change the whole economic picture of
a project – must be properly included in the cost-benefit analysis and/or the analysis of change in socio-economic welfare. Public
acceptance is also of serious importance. Local communities should be considered as very important and unavoidable actor in
energy sector and should be involved in any significant future energy planning that will occur. Projects that are marked with PECI
label by the ECTS must demonstrate a proactive and efficient mechanism for support of local communities through a serious
consultation process. Categorization and eligibility criteria for PECIs stretch beyond PCIs on EU level to include also electricity
generation projects. However, as outlined on the PECIs open day in Belgrade, the whole Energy Community region has vast
potential for savings. Considering also the increasing levels of energy poverty, the demand-side energy efficiency projects need
to be made eligible in order to push forward investments into this crucial area. In order to emphasise the regional aspect and
cooperation, projects which make use of economies of scale by being implemented in several areas at once need to be
incentivised and developed.
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
On EU side, the regulation says that every 2 years the PCIs list needs to be updated. The same approach is required for PECIs.
PECI fast-tracking, that may follow in 2014 - as outlined in on PECIs open day in Belgrade, must not lead to weakening of
environmental standards, but other problems in implementation should rather be addressed. This can be done through the
selection of only the highest quality and best-planned projects, that result from thorough and transparent planning processes in
which a wide range of stakeholders included to ensure widespread buy-in. Insisting on the highest standards of projects
transparency, e.g. tender processes would also help to stop delays related to suspicions of irregularities. PECI projects to be
given a stamp of approval by the ECTS – an EC funded institution –should also be subject to best practices in transparency and
accountability.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG022
Comments on the project:
EG022 Kolubara B CO2 emissions – constructing new lignite power plants will take Serbia in the opposite directionfrom EU
energy and climate policy and make it difficult or impossible to meet GHG reduction targetsfor 2030 and 2050. Change in
socio-economic welfare –negative impacts and threats to habitat and local community caused by the implementation of this
project include massive pollution of all parts of the environment (water, air and land) and related health costs. Expansion of
coal mining in the Kolubara lignite mine is necessitating the resettlement of thousands of families, including 1180
households from the village of Vreoci. After years of struggle and protests, the inhabitants of Vreoci are now facing strong
pressure from Kolubara mining company to take or leave whatever compensation the company offers. In the meantime,
corruption has been uncovered in the process, with an EPS board member receiving an inflated sum of compensation for a
house in the vicinity of the mine. Facilitation of RES – The project is far from facilitating the deployment of renewable
energy, this investment would crowd out financing and other resources for the development of renewable energy, not to
mention energy efficiency measures. Regional interest –It is rather planned as a Serbian project; considering its
weaknesses and no regional interest it should not receive the PECI label.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG023
Comments on the project:
EG023 Kostolac B3 CO2 emissions – constructing new lignite power plants will take Serbia in the opposite directionfrom EU
energy and climate policy and make it difficult or impossible to meet GHG reduction targets for 2030 and 2050. Change in
socio-economic welfare – Health problems and social costs also need to be taken into account for this project (see
2
http://www.env-health.org/IMG/pdf/heal_report_the_unpaid_health_bill__how_coal_power_plants_make_us_sick_finalpdf.pdf for information on health costs of coal in Serbia). Facilitation of RES –
Far from facilitating the deployment of renewable energy, this investment would crowd out financing and other resources for
the development of renewable energy, not to mention energy efficiency measures. Regional interest –It is rather planned as
a Serbian project; considering its weaknesses and no regional interest it should not receive the PECI label.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG024
Comments on the project:
EG024 Nikola Tesla B3 CO2 emissions – constructing new lignite power plants will take Serbia in the opposite direction
from EU energy and climate policy and make it difficult or impossible to meet GHG reduction targets for 2030 and 2050.
Change in socio-economic welfare – expansion of coal mining in the Kolubara lignite mine is necessitating the resettlement
of thousands of families, including 1180 households from the village of Vreoci. After years of struggle for respect of the
decisions listed in the government resettlement programme (2007 to 2012), the inhabitants of Vreoci are now facing strong
pressure from Kolubara mining company to take or leave whatever compensation the company offers. So far, only 200
households have been moved, and only 350 households got part of the money (about 30% of the whole price) in advance.
In the meantime, corruption has been uncovered in the process, with an EPS board member receiving an inflated sum of
compensation for a house in the vicinity of the mine. http://bankwatch.org/bwmail/55/kolubara-mine-mired-crime-andcorruption Facilitation of RES – Far from facilitating the deployment of renewable energy, this investment would crowd out
financing and other resources for the development of renewable energy, not to mention energy efficiency measures.
Regional interest –It is rather planned as a Serbian project; considering its weaknesses and no regional interest it should
not receive the PECI label.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG016
Comments on the project:
EG016 HPPs Brodarevo Serbia Electricity Generation Change in socio-economic welfare - Negative impact and threat
caused by the implementation of this project is linked to pollution of the environment (water, land and biodiversity), as well
as to cultural heritage and economic/tourism activity of inhabitants. The project has been challenged and opposed by local
communities, with huge support of citizens from across Serbia. Local communities should be considered as very important
and unavoidable actor and should be involved in any significant future energy planning that will occur. Projects that are
marked with PECI label by the ECTS must demonstrate a proactive and efficient mechanism for support of local
communities through a serious consultation process.
Your Details
Title:
Mr
First name:
Zoran
Last name:
Mateljak
Name of organization:
WWF - Mediterranean Programme
Job title:
Project Coordinator
City:
Mostar
Country:
Bosnia-Herzegovina
Email: *
[email protected]
General Comments
You are invited to provide your general comments in this section
3
WWF's mission is to “build a future in which humans live in harmony with nature”. This is our guiding principle and therefore we will
strongly support an energy policy, which is in line with long-term sustainable development combined with strict, legally-binding
biodiversity safeguards and a nature protection policy that preserves biodiversity treasures. WWF's energy vision is set out in The
Energy
Report
100%
Renewable
Energy
by
2050.
(http://wwf.panda.org/what_we_do/footprint/climate_carbon_energy/energy_solutions/renewable_energy/sustainable_energy_report/).
The Energy Report shows that l00% renewable energy is technologically possible and economically feasible at a global scale, and will
bring many benefits such as less carbon and other pollution, better human health and providing universal access to clean energy for
the poor. Success of such a comprehensive decarbonisation of energy supply in next decades is highly linked to simultaneous
achievements of upscaling energy saving & efficiency and conservation in all societal energy-consuming sectors. Harmful impacts
from small and large dams: Dams for hydropower production can bring substantial benefits, however the impacts of dams on the
environment, in particular on freshwater ecosystems and on people’s livelihoods are always significant, while their benefits are often
overestimated and the social and environmental costs underestimated. It is crucial to avoid the adverse social and environmental
impact of such infrastructure and to ensure investors’ and tax payers’ money is used effectively. Badly located and designed projects,
exaggerated forecasts for returns and reputational risk have made many dam projects risky investments. Following a set of
recommendations forwarded by the World Commission on Dams (WCD), including comprehensive needs and options assessments,
stakeholder involvement and the avoidance or minimisation of environmental and social impacts, will significantly reduce investment
risk. In addition, the impact of the fragmentation of small rivers by hydropower facilities should not be underestimated. A series of
small hydropower plants can be more destructive to freshwater ecosystems than one well sited large plant with adequate mitigation
measures. Sustainability principles for investment in sustainable hydropower: a. Proposals for new hydropower plants must meet
internationally recognised sustainability standards e.g. World Commission on Dams guidelines. New hydropower plants should only
be considered if, after a thorough assessment, they prove to be the best option, including when compared against energy efficiency,
energy savings and other renewable energy sources. b. Energy Community should encourage and respect the designation by the
governments of “No-go” areas for hydropower schemes — large or small — on the remaining unregulated rivers (or their tributaries)
in areas of high conservation value (see the No-go section in the next chapter). c. Decisions regarding the location of hydropower
plants should be made in order to minimize the environmental impacts in the whole river basin. Efficient hydropower sites that
minimize the area flooded per unit of energy produced should be favoured (but taking into account the point above). d. Mitigation
measures, such as environmental flow regimes, habitat restoration and protection, fish ladders, can significantly reduce the impact of
hydropower projects and should always be planned for. e. Wherever possible, the capacity of existing hydropower plants should be
increased and existing infrastructures refurbished (optimized) in order to minimize the need for new plants. Optimisation should also
be linked to environmental improvements. f. Small hydropower plants, which can supply rural areas in developing countries with
renewable energy, must include mitigation measures and their cumulative impact must be considered. g. The Energy Community
should encourage governments to prioritise a sound energy mix, including energy efficiency measures and various renewable energy
solutions, to balance environmental and social impacts and foster energy security.
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation of
priority projects?
In general: 1. A Regional Energy Strategy focusing on energy savings/efficiency and renewable energy sources according to the
European Union's 2050 energy targets, that would be endorsed by all parties to the Energy Community Treaty (ECT) and followed by
national action plans developed accordingly and consistently among each other to enhance the energy output and efficiency in the
region. 2. Alignment with the EU acquis (legal framework) in the following sectors: energy, environment, water and procurement.
More specifically: 3. Energy infrastructure development or retrofitting should be implemented according to strict sustainability criteria
and Strategic Environmental Assessments (SEAs) as foreseen under the EU acquis, to effectively protect the existing biodiversity
with special focus on endangered ecosystems and species. It should also include potential areas for restoration of ecosystems like
rivers or wetlands. To that purpose: a. Nature protection zones from which infrastructure development is excluded, notably energy
facilities, incl. renewable energy sources such a hydro or wind, should be defined. b. Where infrastructure development is permitted, it
should be done according to internationally recognised good practice, incl. thorough SEAs and Environmental Impact Assessments
(EIAs) c. Civil society and affected populations need to be involved according to the provisions of the Aarhus Convention or the
relevant EU Directives The above measures have to become the legal basis for spatial planning and related regulations. 4. A binding
energy savings plan should be developed including an implementation plan with finance mechanisms and put into force by national
law. It needs to aim at the maximum energy savings for all countries parties to the ECT. In particular it should: a. reduce the need for
production with all the related environmental impacts and costs, b. be accompanied by investments for high level job creation and
regional added value, c. reduce emissions to help mitigate climate change and to improve the health situation of affected populations,
d. reduce energy expenditure in the domestic and business sectors, e. reduce the dependence on energy imports and the related
financial outflow. 5. A binding decarbonisation plan for the energy sector has to be adopted. Regarding the goal of decarbonisation of
the energy sector, spending of public money for fossil and nuclear power generation has to be phased out rapidly and no new
facilities should be planned. Relevant regulation should be developed and enforced. According to climate/energy science (e.g.:
http://www.sei-international.org/publications?pid=1318) coal and oil use for electricity production has to be phased out by 2035, which
is not even half way of the operational time of any additional capacity. Under this condition a cost/benefit analysis can never be
positive. 6. With regard to hydropower specifically, comments under above Sections 1, 2 and 3 are all relevant. Additionally, WWF
would recommend the adoption and use of specific sustainability criteria based on the EU acquis, the World Commission on Dams
Report (http://awsassets.panda.org/downloads/wcd_dams_final_report.pdf) as well as international financial institutions' (IFIs)
sustainability standards and norms. 7. Funding of energy infrastructure projects by (public) European financial institutions, such as the
EIB and EBRD, but also other IFIs, should be approved only after proper screening of projects, not only according to the classical
cost/benefit analysis approach, but including environmental and social costs. Moreover, no funding should be approved if a project
has not undergone successfully a thorough SEA and EIA or is located in a natural exclusion zone (as discussed in Section 3
paragraph a).
4
Project Comment Form
Project number (ID and code) as indicated in the list:
EG002
Comments on the project:
WWF would like to share its concerns with regard to the negative environmental aspects of the Sutjeska HPP project, the EIA of
which has stated thatthere were no environmental impacts, while local NGOs in the contrary have listed important shortcomings.
There are plans to build five small hydropower plants in and just outside of the borders of Sutjeska National Park in BiH or more
precisely in the Repubic of Srpska. Three of them are to be located on the river Hrcavka and two on river Sutjeska. The law of
Republic of Srpska, from 2010 envisaged construction of small hydropower plants in National Parks in extraordinary cases. EIA
was done by consultancy company “Projekt” from Banja Luka. The EIA did not find any negative impact on environment that can
not be fully addressed. The EIA recommends construction of these five small hydropower plants claiming that these
constructions are environmental friendly with excellent mitigation measures identified in the case that some negative impacts
should occur. Public hearings were held on 4th April in Gacko and 5th April in Foca. The NGOs from Republic of Srpska and
Federation of BiH strongly opposed the conclusions and recommendation of EIA. The main arguments against such
development are based on the fact that it is going to take place in National Park. Experiences on small hydropower plants of
Republic of Srpska are very limited. It is difficult to understand why the first ones are to be built in National Park. The initiative of
the local NGOs is to build first small hydropower plants in all other areas in order to gain knowledge and experiences before
taking any decision about the similar constructions in National Parks and other protected areas. Anyway, it is difficult to accept
arguments from EIA study about only temporary impacts of constructions that would happen just during the construction, and
later, once plants are put in operations, the impacts would be minimized or none. The main argument against such statement is
disturbance of endemic population of Balkan chamois. It is known that once disturbed, this population would leave and never
return to the previous habitat. There were several such cases during the recent war in the National Park Sutjeska. WWF is
therefore strongly against the construction of small hydropower plants in Sutjeska National Park and believes that the EIA study
is has an obvious bias towards hydropower investors.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG003
Comments on the project:
Below WWF would like to share its concerns over the huge potential environmental impacts of Dabar HPP, part of the larger
Upper Horizons hydropower scheme. Although the environmental goals of the Upper Horizons project are often put in the
forefront, from the fundamental project goals it is hard to tell what efforts will actually be made for reducing or preventing
negative impacts on the environment. It is probably thought that flood prevention and/or increase in minimal flows of Bregava
River in Stolac are the goals that satisfy the requirements for nature protection, but having in mind that both floods and droughts
are part of the natural cycle, it is unlikely that such defined goals would contribute to better environmental protection. In fact, the
arguments offered by advocates of the Upper Horizons project are based on numerous assumptions and uncertainties, which
will be elaborated further in the text. In addition there are also some legal and political uncertainties. Some background
information: Many reports and documents compiled by the Electrical Company of the Republic of Srpska show that an
underground connection between Dabar Field and Bregava River has been confirmed by means of a hydro-biological method.
The conclusion of the Study titled “Impact of the Redirection of Water from Dabar Field on Bregava’s Water Regime” (HET –
Institute for Exploitation and Protection of Karst Waters, 1985 is that there is a significant impact of water redirection from Dabar
Lake on the regime of Bregava River during a high water season, while this impact is non existent during a low water season.
The same conclusion was reached by Jaroslav Černi Water Management Institute. It turns out that with the redirection of water
from Dabar Field, the flows of Bregava River will decrease. Therefore, in order to improve the low-water regime of Bregava, the
following technical measures have been proposed: Repair of Bregava riverbed; Controlled discharge of water into Ponikva
ponor. Based on the above, it can be concluded that the project’s main ecological measure is to increase minimal flows of
Bregava River through Stolac. Two key issues should be raised and analyzed in a far greater detail than has been the case so
far: a. It is questionable whether the minimum flows of Bregava River through Stolac can be increased in summer months by
discharging water into Ponikva Ponor, simply because an existing study offers evidence that in summer the water from Ponikva
ponor doesn’t reach Bregava at all. b. The repair of Bregava Riverbed would only further upset the natural underground
streams. This raises the question of who would be deprived of the water and whether the repair of Bregava Riverbed would
prevent the drainage of water to, let’s say, Hutovo Blato? It’s not said where these waters would actually go to, although it is only
logical that a likely increase in water flows through Stolac would lead to a decrease in water at some other place or at least to a
new disturbance of natural water circulation! First we must establish the real underground connections between Ponikva ponor
and Bregava River. Namely, it is said that “in order to define the exact course of its underground stream, Ponikva ponor was
subjected to a dye tracing test on two occasions. Both times, a connection with the Bregava springs was established, that is, the
dye tracing of 14 May 1955, at the time of a low water season and again on 15 November 1955, during a high water season.
Kutske Jame were subjected to dye tracing in 1956, when the connection with Bregava River was established, as well as during
dye testing of Strupići ponor in 1972. Probably the key question that authors of this study should be asked is whether 14 May is
the period of low water levels. The available charts clearly show that this is not the case. This means that the connection
between Ponikva ponor and Bregava River during minimum water levels has actually never been established. The question that
imposes itself is based on what assumption was it concluded that minimum water levels of Bregava River can be increased by
releasing water into Ponikva Ponor? This question is particularly important because another study shows that the connection
between Ponikva Ponor and Bregava River in the period of low waters is non-existent. At the initiative of the WWF
Mediterranean Office, a dye-tracing test of Vrijeka stream was conducted by an independent expert team at the entrance to
5
Ponikva Ponor at 5.10 p.m. on 19 July 2010. Immediately before dye-tracing, a hydrometric measurement of Vrijeka flows was
performed on the profile of Ponikva Hydro-Station. The measured flow was Q =0.12 m³/s, which is not the value of low water
levels. However, contrary to expectations, at injecting dye-tracing substance into the stream of Ponikva ponor, the dye tinted
water did not appear at the Bregava spring. This leads us to conclude that the underground stream from Ponikva Ponor to the
Bregava spring runs through underground channels too deep for the hydro-geological barrier at the spring to exercise its
function and regulate the inflow of water to Bregava springs In the period of minimum water levels, the stream, without ever
coming to the surface, flows into the nearest and lowest erosion basis, which in this case is Derane depression, as was proved
by the presence of dye tinted water in springs along the edge of the depression. The water containing Na-fluorescent surged at
the springs of Drijen, Jelim, Orah and Jamica, all of which are located in the Derane depression in Hutovo Blato. Therefore, it is
not possible to unmistakably establish a connection between Ponikva Ponor and Bregava River or Hutovo Blato. In fact, it is not
possible to unmistakably establish connections between any of the ponors and springs in East Herzegovina. These connections
keep changing in dependence of the current level of ground water. This means that additional research and efficient monitoring
should be conducted before the construction of the Upper Horizons project continues. The central question for the Bregava
catchment is under what conditions in natural circumstances and where the water from Dabar Filed drains and under what
conditions and where the water from Dabar Field would go to once the Upper Horizons system has been completed. Given the
arguments and explanations offered so far, the answer to this question is quite uncertain. What is certain is that a large-scale
project such as this shouldn’t be based on assumptions and rough estimates, but rather on proven facts! Thus, in defense of
their case the authors of the Upper Horizon project refer to already established underground connections, arguing that, for
example, “Mlinica ponor in Lukovačko Field was subjected dye tracing in 1961, on which occasion a connection with the
permanent spring of Vrijeka and the temporary spring of Sušica on the north perimeter of Dabar Field.” In this, as well as other
similar cases, it is not known at what time of the year the research was conducted. The only thing that is known is that the
connection was established 50 years ago. However, it is possible that this connection exists only under specific conditions,
relative to the annual amount of precipitation or the time of the year, etc. Therefore, it would be irresponsible to base an
important project such as the Upper Horizons on only one dye tracing experiment conducted 50 years ago. The preservation of
Vrijeka
Project Comment Form
Project number (ID and code) as indicated in the list:
EG004-1
Comments on the project:
WWF would like to share its concerns over this project's significant potential environmental impacts, explained below. This
hydropower plant is on the territory of Croatia but the main constructions and water are coming from BiH i.e. Republic of Srpska.
The current capacity of the headrace tunnel from Trebinje to Dubrovnik I is 90m3/s of water, and the plan is to increase this
capacity to 210m3/s. Bearing in mind that the average flow of Neretva after Mostar is less than 200m3/s, this would be akin to
diverting the flow of the entire Neretva River. One of the priorities of Energy company of Republic of Srpska (ERS) is to
cooperate with Croatian energy company (HEP) and to finalise the Hydropower system of Trebisnjica by diverting waters
through the Upper Horizons project to the Bilecko reservoir and further down to the turbines of the future Dubrovnik II
hydropower plant. Because the water would be directed from 295 meters m.a.s.l. to the turbine which is at sea level, this would
be a highly profitable project. The controversy of this idea in Croatia is that the water that would drive turbines at Dubrovnik II is
actually the water of the Neretva Delta. This means that most of the water that would naturally reach the Neretva Delta (by
underground connections or various surface flows), upon completion of the Trebisnjica hydropower system would be diverted to
the Adriatic Sea near Dubrovnik. There are a million and six hundred thousand tangerine trees just within the Croatian part of
the Neretva Delta. The farmers harvest 40,000 tonnes of mandarins in Croatia each year and they cover the whole tangerine
market in Croatia. The main threat to this production is salt water intrusion. Therefore the Neretva Delta farmers desperately
need fresh water from Neretva especially during the summer. If the water is diverted from the Neretva Delta and goes to the
Dubrovnik II hydropower plant, farmers and their annual income of over €20 million would be highly threatened. Nevertheless,
the main controversy of such water diversion for electricity production purposes concerns Nature Park Hutovo Blato. Hutovo
Blato has been proclaimed a Wetland of International Importance under the Ramsar Convention. Bosnia and Herzegovina have
committed to protect Hutovo Blato at an international level. Government and non-government organisations concerned with
environmental protection, especially in Federation of BiH and Croatia, are opposed to the finalisation of the Trebisnjica
hydropower system and the Upper Horizons project. The World Wide Fund for Nature Mediterranean Programme Office (WWF
MedPO), an international NGO, has initiated the process of identification of solutions that would be acceptable to key
stakeholders in the area. The overriding objective is to protect the wetlands of Hutovo Blato as a habitat for numerous species of
flora and fauna. There was an EIA study conducted by “Rider Boskovic” institute from Zagreb, Croatia several years ago. This
EIA only considered impacts of cold fresh water on the marine environment once that fresh water reaches sea near Dubrovnik.
Thus this EIA only considered one of the potential impacts and moreover one of the less possible impacts. The EIA that would
consider all impacts and with the much larger scope has not been developed yet.
Your Details
Title:
Ms
6
First name:
Angela
Last name:
Klauschen
Name of organization:
WWF International - Mediterranean Programme
Job title:
Sr Policy Officer
City:
Rome
Country:
Italy
Email: *
[email protected]
General Comments
You are invited to provide your general comments in this section
WWF's mission is to “build a future in which humans live in harmony with nature”. This is our guiding principle and therefore we will
strongly support an energy policy, which is in line with long-term sustainable development combined with strict, legally-binding
biodiversity safeguards and a nature protection policy that preserves biodiversity treasures. WWF's energy vision is set out in The
Energy
Report
100%
Renewable
Energy
by
2050.
(http://wwf.panda.org/what_we_do/footprint/climate_carbon_energy/energy_solutions/renewable_energy/sustainable_energy_report/).
The Energy Report shows that l00% renewable energy is technologically possible and economically feasible at a global scale, and will
bring many benefits such as less carbon and other pollution, better human health and providing universal access to clean energy for
the poor. Success of such a comprehensive decarbonisation of energy supply in next decades is highly linked to simultaneous
achievements of upscaling energy saving & efficiency and conservation in all societal energy-consuming sectors. 1. Not every country
or region will be able to produce domestically all renewables needed. Population density, inadequate weather conditions, biodiversity
conservation priority areas, etc. may not allow for that. Therefore, unmitigated trade of clean renewable energy and most energyefficient products across borders is necessary. In the case of electricity that means substantive cross-border grid infrastructure to
accommodate the flow of green electrons most cost-effectively. 2. Energy saving and efficiency are prerequisites to achieve a
renewable energy future. Also renewables have limits. May those be derived from the water and land availability for bioenergy and
hydropower or from the material needs for energy conversion technologies of wind and solar, such as demand for Rare Earth
minerals, more copper for grid infrastructure and lithium for batteries. Energy efficiency and material efficiency need to be part of a
clean energy world. Solutions exist in every sector to deliver substantive energy and material savings and their potential is still largely
untapped. 3. All renewables, in particular hydropower and bioenergies, must be planned, developed and managed sustainably in
order to avoid potentially adverse effects on livelihoods, food security, climate, biodiversity and ecosystems. 4. The use of fossil fuels
(coal, oil and gas) will need to decrease rapidly and be phased out in line with a pathway to 100% clean renewable energy. The IEA
suggests that maintaining a 50/50 chance to not overstep the 2-degree C threshold, the world must retire and leave below ground 2/3
of the present global fossil fuel reserves. Other scientists show that in order to stay well below 2-degree C that it be rather 80% of all
fossil fuel reserves that stay untouched. Unfortunately, the world is moving into another direction. Scientists also show that a 3-degree
and even 4-degree world with its disastrous consequences for human and nature as shown recently by the World Bank will have to
leave a large portion of fossil fuel reserves unburned. As those temperature options are unacceptable for WWF, to have a decent
chance to stay well below 2 degree, WWF demands to leave the large majority of the fossil fuels untouched and particularly those
with the largest carbon footprint. For the European climate and energy policy this means unacceptable risks of climate change can
only be avoided if developed countries reduce their greenhouse gas emissions by 40% by 2020 and by 95% by 2050. Achieving this
will increase the odds of staying below 2°C warming. WWF has a vision of a world that is powered by 100% renewable energy
sources by 2050. The EU is committed to reducing greenhouse gas emissions to 80-95% below 1990 levels by 2050. According to
the European Commission's estimates outlined in the “Roadmap for moving to a competitive low carbon economy in 2050”, the most
technologically and economically feasible means of achieving this, is a total decarbonisation of the energy sector by 2050. The
consequences for energy investments: To have a reasonable chance of staying within a 2°C rise for the global climate, the IEA has
stated that only zero-carbon utilities and infrastructure should be developed beyond 2017 since 80% of cumulative emissions
allowable between 2010 and 2035 are already locked-into existing power plants, factories, buildings and services - unless existing
infrastructure is scrapped before the end of its economic lifespan. In addition, it implies that investments that prolong the overall
lifetime emissions of a project actually add to the cumulative total annual GHG emissions. No coal- and lignite-fired generation: Given
the urgency of climate change there is no room for a policy that supports new coal and lignite fired generation in the EU power
system. This implies that coal and lignite fired generation should not be supported by the Energy Community. This no-coal-position
should include: a. coal ‐ fired combined heat and power (CHP): given the long plant lifetime and marginal efficiency gains, the risk of
failure of the EU decarbonisation goal by 2050 is too high. b. refurbishment, retrofitting and replacement of coal-fired plants. While
focussed refurbishment can limit the emissions of various types of particles and lead to an improvement of air quality in the area,
when refurbishment prolongs the lifespan of the plant it leads to an absolute increase in GHG emissions compared to energy saving
or renewable alternatives. It creates a high risk scenario to contradict the decarbonisation of the EU energy sector committed by
2050. c. CCS (carbon capture and storage) technology is in the medium term very unlikely to be technically effective and
commercially available as part of a competitive energy option, so CCS for coal should not be considered by the Energy Community.
d. The no-coal-position should also include coal mining operations and related activities. Unnecessary harmful impacts from small
and large dams: Dams for hydropower production can bring substantial benefits, however the impacts of dams on the environment, in
particular on freshwater ecosystems and on people’s livelihoods are always significant, while their benefits are often overestimated
and the social and environmental costs underestimated. It is crucial to avoid the adverse social and environmental impact of such
infrastructure and to ensure investors’ and tax payers’ money is used effectively. Badly located and designed projects, exaggerated
7
forecasts for returns and reputational risk have made many dam projects risky investments. Following a set of recommendations
forwarded by the World Commission on Dams (WCD), including comprehensive needs and options assessments, stakeholder
involvement and the avoidance or minimisation of environmental and social impacts, will significantly reduce investment risk. In
addition, the impact of the fragmentation of small rivers by hydropower facilities should not be underestimated. A series of small
hydropower plants can be more destructive to freshwater ecosystems than one well sited large plant with adequate mitigation
measures. Sustainability principles for investment in sustainable hydropower: a. Proposals for new hydropower plants must meet
internationally recognised sustainability standards e.g. World Commission on Dams guidelines. New hydropower plants should only
be considered if, after a thorough assessment, they prove to be the best option, including when compared against energy efficiency,
energy savings and other renewable energy sources. b. Energy Community should encourage and respect the designation by the
governments of “No-go” areas for hydropower schemes — large or small — on the remaining unregulated rivers (or their tributaries)
in areas of high conservation value (see the No-go section in the next chapter). c. Decisions regarding the location of hydropower
plants should be made in order to minimize the environmental impacts in the whole river basin. Efficient hydropower sites that
minimize the area flooded per unit of energy produced should be favoured (
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation of
priority projects?
In general: 1. A Regional Energy Strategy focusing on energy savings/efficiency and renewable energy sources according to the
European Union's 2050 energy targets, that would be endorsed by all parties to the Energy Community Treaty (ECT) and followed by
national action plans developed accordingly and consistently among each other to enhance the energy output and efficiency in the
region. 2. Alignment with the EU acquis (legal framework) in the following sectors: energy, environment, water and procurement.
More specifically: 3. Energy infrastructure development or retrofitting should be implemented according to strict sustainability criteria
and Strategic Environmental Assessments (SEAs) as foreseen under the EU acquis, to effectively protect the existing biodiversity
with special focus on endangered ecosystems and species. It should also include potential areas for restoration of ecosystems like
rivers or wetlands. To that purpose: a. Nature protection zones from which infrastructure development is excluded, notably energy
facilities, incl. renewable energy sources such a hydro or wind, should be defined. b. Where infrastructure development is permitted, it
should be done according to internationally recognised good practice, incl. thorough SEAs and Environmental Impact Assessments
(EIAs) c. Civil society and affected populations need to be involved according to the provisions of the Aarhus Convention or the
relevant EU Directives The above measures have to become the legal basis for spatial planning and related regulations. 4. A binding
energy savings plan should be developed including an implementation plan with finance mechanisms and put into force by national
law. It needs to aim at the maximum energy savings for all countries parties to the ECT. In particular it should: a. reduce the need for
production with all the related environmental impacts and costs, b. be accompanied by investments for high level job creation and
regional added value, c. reduce emissions to help mitigate climate change and to improve the health situation of affected populations,
d. reduce energy expenditure in the domestic and business sectors, e. reduce the dependence on energy imports and the related
financial outflow. 5. A binding decarbonisation plan for the energy sector has to be adopted. Regarding the goal of decarbonisation of
the energy sector, spending of public money for fossil and nuclear power generation has to be phased out rapidly and no new
facilities should be planned. Relevant regulation should be developed and enforced. According to climate/energy science (e.g.:
http://www.sei-international.org/publications?pid=1318) coal and oil use for electricity production has to be phased out by 2035, which
is not even half way of the operational time of any additional capacity. Under this condition a cost/benefit analysis can never be
positive. 6. With regard to hydropower specifically, comments under above Sections 1, 2 and 3 are all relevant. Additionally, WWF
would recommend the adoption and use of specific sustainability criteria based on the EU acquis, the World Commission on Dams
Report (http://awsassets.panda.org/downloads/wcd_dams_final_report.pdf) as well as international financial institutions' (IFIs)
sustainability standards and norms. 7. Funding of energy infrastructure projects by (public) European financial institutions, such as the
EIB and EBRD, but also other IFIs, should be approved only after proper screening of projects, not only according to the classical
cost/benefit analysis approach, but including environmental and social costs. Moreover, no funding should be approved if a project
has not undergone successfully a thorough SEA and EIA or is located in a natural exclusion zone (as discussed in Section 3
paragraph a). Please note that we will provide separate input on the PECIs.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG002
Comments on the project:
WWF would like to draw the attention on the controversial aspects of the Sutjeska project, the EIA of which has stated thatthere
were no environmental impacts, while local NGOs in the contrary have listed important shortcomings. There are plans to build
five small hydropower plants in and just outside of the borders of Sutjeska National Park in BiH or more precisely in the Repubic
of Srpska. Three of them are to be located on the river Hrcavka and two on river Sutjeska. The law of Republic of Srpska, from
2010 envisaged construction of small hydropower plants in National Parks in extraordinary cases. EIA was done by consultancy
company “Projekt” from Banja Luka. The EIA did not find any negative impact on environment that can not be fully addressed.
The EIA recommends construction of these five small hydropower plants claiming that these constructions are environmental
friendly with excellent mitigation measures identified in the case that some negative impacts should occur. Public hearings were
held on 4th April in Gacko and 5th April in Foca. The NGOs from Republic of Srpska and Federation of BiH strongly opposed the
conclusions and recommendation of EIA. The main arguments against such development are based on the fact that it is going to
take place in National Park. Experiences on small hydropower plants of Republic of Srpska are very limited. It is difficult to
understand why the first ones are to be built in National Park. The initiative of the local NGOs is to build first small hydropower
plants in all other areas in order to gain knowledge and experiences before taking any decision about the similar constructions in
8
National Parks and other protected areas. Anyway, it is difficult to accept arguments from EIA study about only temporary
impacts of constructions that would happen just during the construction, and later, once plants are put in operations, the impacts
would be minimized or none. The main argument against such statement is disturbance of endemic population of Balkan
chamois. It is known that once disturbed, this population would leave and never return to the previous habitat. There were
several such cases during the recent war in the National Park Sutjeska. WWF is therefore strongly against the construction of
small hydropower plants in Sutjeska National Park and believes that the EIA study is has an obvious bias towards hydropower
investors.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG003
Comments on the project:
WWF would like to raise the attention on the huge potential impacts implied by the Dabar HPP project, part of the large Upper
Horizons hydropower scheme, in the Neretva-Trebisjnica basin. Although the environmental goals of the Upper Horizons project
are often put in the forefront, from the fundamental project goals (see in Notes at the end of commentary) it is hard to tell what
efforts will actually be made to reduce or prevent negative impacts on the environment. It is probably thought that flood
prevention and/or increase in minimal flows of Bregava River in Stolac are the goals that satisfy the requirements for nature
protection, but having in mind that both floods and droughts are part of the natural cycle, it is unlikely that such defined goals
would contribute to better environmental protection. In fact, the arguments offered by advocates of the Upper Horizons project
are based on numerous assumptions and uncertainties, which will be elaborated further in the text. In addition there are also
some legal and political uncertainties. Many reports and documents compiled by the Electrical Company of the Republic of
Srpska show that an underground connection between Dabar Field and Bregava River has been confirmed by means of a
hydro-biological method. The conclusion of the Study titled “Impact of the Redirection of Water from Dabar Field on Bregava’s
Water Regime” (HET – Institute for Exploitation and Protection of Karst Waters, 1985 is that there is a significant impact of water
redirection from Dabar Lake on the regime of Bregava River during a high water season, while this impact is non existent during
a low water season. The same conclusion was reached by Jaroslav Černi Water Management Institute. It turns out that with the
redirection of water from Dabar Field, the flows of Bregava River will decrease. Therefore, in order to improve the low-water
regime of Bregava, the following technical measures have been proposed: - Repair of Bregava riverbed; - Controlled discharge
of water into Ponikva ponor. Based on the above, it can be concluded that the project’s main ecological measure is to increase
minimal flows of Bregava River through Stolac. Two key issues should be raised and analyzed in a far greater detail than has
been the case so far: a. It is questionable whether the minimum flows of Bregava River through Stolac can be increased in
summer months by discharging water into Ponikva Ponor, simply because an existing study offers evidence that in summer the
water from Ponikva ponor doesn’t reach Bregava at all. b. The repair of Bregava Riverbed would only further upset the natural
underground streams. This raises the question of who would be deprived of the water and whether the repair of Bregava
Riverbed would prevent the drainage of water to, let’s say, Hutovo Blato? It’s not said where these waters would actually go to,
although it is only logical that a likely increase in water flows through Stolac would lead to a decrease in water at some other
place or at least to a new disturbance of natural water circulation! First we must establish the real underground connections
between Ponikva ponor and Bregava River. Namely, it is said that “in order to define the exact course of its underground stream,
Ponikva ponor was subjected to a dye tracing test on two occasions. Both times, a connection with the Bregava springs was
established, that is, the dye tracing of 14 May 1955, at the time of a low water season and again on 15 November 1955, during a
high water season. Kutske Jame were subjected to dye tracing in 1956, when the connection with Bregava River was
established, as well as during dye testing of Strupići ponor in 1972. Probably the key question that authors of this study should
be asked is whether 14 May is the period of low water levels. The available charts clearly show that this is not the case. This
means that the connection between Ponikva ponor and Bregava River during minimum water levels has actually never been
established. The question that imposes itself is based on what assumption was it concluded that minimum water levels of
Bregava River can be increased by releasing water into Ponikva Ponor? This question is particularly important because another
study shows that the connection between Ponikva Ponor and Bregava River in the period of low waters is non-existent. At the
initiative of the WWF Mediterranean Office, a dye-tracing test of Vrijeka stream was conducted by an independent expert team
at the entrance to Ponikva Ponor at 5.10 p.m. on 19 July 2010. Immediately before dye-tracing, a hydrometric measurement of
Vrijeka flows was performed on the profile of Ponikva Hydro-Station. The measured flow was Q =0.12 m³/s, which is not the
value of low water levels. However, contrary to expectations, at injecting dye-tracing substance into the stream of Ponikva
ponor, the dye tinted water did not appear at the Bregava spring. This leads us to conclude that the underground stream from
Ponikva Ponor to the Bregava spring runs through underground channels too deep for the hydro-geological barrier at the spring
to exercise its function and regulate the inflow of water to Bregava springs In the period of minimum water levels, the stream,
without ever coming to the surface, flows into the nearest and lowest erosion basis, which in this case is Derane depression, as
was proved by the presence of dye tinted water in springs along the edge of the depression. The water containing Nafluorescent surged at the springs of Drijen, Jelim, Orah and Jamica, all of which are located in the Derane depression in Hutovo
Blato. Therefore, it is not possible to unmistakably establish a connection between Ponikva Ponor and Bregava River or Hutovo
Blato. In fact, it is not possible to unmistakably establish connections between any of the ponors and springs in East
Herzegovina. These connections keep changing in dependence of the current level of ground water. This means that additional
research and efficient monitoring should be conducted before the construction of the Upper Horizons project continues. The
central question for the Bregava catchment is under what conditions in natural circumstances and where the water from Dabar
Filed drains and under what conditions and where the water from Dabar Field would go to once the Upper Horizons system has
been completed. Given the arguments and explanations offered so far, the answer to this question is quite uncertain. What is
certain is that a large-scale project such as this shouldn’t be based on assumptions and rough estimates, but rather on proven
facts! Thus, in defense of their case the authors of the Upper Horizon project refer to already established underground
connections, arguing that, for example, “Mlinica ponor in Lukovačko Field was subjected dye tracing in 1961, on which occasion
a connection with the permanent spring of Vrijeka and the temporary spring of Sušica on the north perimeter of Dabar Field.” In
9
this, as well as other similar cases, it is not known at what time of the year the research was conducted. The only thing that is
known is that the connection was established 50 years ago. However, it is possible that this connect
Project Comment Form
Project number (ID and code) as indicated in the list:
EG004-1
Comments on the project:
WWF would like to share the concern with regard to environmental impacts o this project below. This Hydropower plant is on the
territory of Croatia but the main constructions and water is coming from BiH i.e. Republic of Srpska. The current capacity of the
headrace tunnel from Trebinje to Dubrovnik I is 90m3/s of water, and the plan is to increase this capacity to 210m3/s. Bearing in
mind that the average flow of Neretva after Mostar is less than 200m3/s, this would be akin to diverting the flow of the entire
Neretva River. One of the priorities of Energy company of Republic of Srpska (ERS) is to cooperate with the Croatian energy
company (HEP) and to finalise the Hydropower system of Trebisnjica by diverting waters through the Upper Horizons project to
the Bilecko reservoir and further down to the turbines of the future Dubrovnik II hydropower plant. Because the water would be
directed from 295 meters m.a.s.l. to the turbine which is at sea level, this would be a highly profitable project. The controversy of
this idea in Croatia is that the water that would drive turbines at Dubrovnik II is actually the water of the Neretva Delta. This
means that most of the water that would naturally reach the Neretva Delta (by underground connections or various surface
flows), upon completion of the Trebisnjica hydropower system would be diverted to the Adriatic Sea near Dubrovnik. There are a
million and six hundred thousand tangerine trees just within the Croatian part of the Neretva Delta. The farmers harvest 40,000
tonnes of mandarins in Croatia each year and they cover the whole tangerine market in Croatia. The main threat to this
production is salt water intrusion. Therefore the Neretva Delta farmers desperately need fresh water from Neretva especially
during the summer. If the water is diverted from the Neretva Delta and goes to the Dubrovnik II hydropower plant, farmers and
their annual income of over €20 million would be highly threatened. Nevertheless, the main controversy of such water diversion
for electricity production purposes concerns Nature Park Hutovo Blato. Hutovo Blato has been proclaimed a Wetland of
International Importance under the Ramsar Convention. Bosnia and Herzegovina have committed to protect Hutovo Blato at an
international level. Government and non-government organisations concerned with environmental protection, especially in
Federation of BiH and Croatia, are opposed to the finalisation of the Trebisnjica hydropower system and the Upper Horizons
project. The World Wide Fund for Nature Mediterranean Programme Office (WWF MedPO), an international NGO, has initiated
the process of identification of solutions that would be acceptable to key stakeholders in the area. The overriding objective is to
protect the wetlands of Hutovo Blato as a habitat for numerous species of flora and fauna. There was an EIA study conducted
by “Rider Boskovic” institute fnrom Zagreb, Croatia several years ago. This EIA only considered impacts of cold fresh water on
sea water environment once that fresh water reaches sea near Dubrovnik. The EIA therefore only considered one aspect of the
potential impacts and the one with less possible impacts. The EIA that would assess all impacts and within a much larger scope
has not been developed yet.
Your Details
Title:
Ms
First name:
Malgorzata
Last name:
Smolak
Name of organization:
ClientEarth
Job title:
Lawyer
Address:
Aleje Ujazdowskie 39/4
Postcode:
00-540
City:
Warszawa
Country:
Poland
Email: *
[email protected]
Phone No:
+48 22 307 01 84
General Comments
10
You are invited to provide your general comments in this section
Our main concern is focused on PECIs compliance with EU environmental policies and legislation. The Projects of Energy
Community Interest concept is to be based on the same main criteria and methodology as EU Projects of Common Interest. The
key difference is that EU PCI proposed transmission and storage projects and not generation projects. Electricity generation is a
great source of greenhouse gas emissions. In the context of EU’s 2050 decarbonisation policy and discussion on targets for
2030, the PECIs are in conflict with EU’s long-term energy and climate policy. Especially alarming is the proposal of coal/lignitefired generation projects which threaten to lock the countries concerned in carbon emissions for several years. Several countries
will be unable to significantly reduce CO2 emissions if they construct new fossil fuel plants. The countries’ future greenhouse
emissions need to be taken into consideration before giving PECI label to generation projects. Taking in consideration the
aspirations of the Western Balkans countries to join European Union, the PECIs should be in line not only with Energy
Community Treaty law but also with current and forthcoming acquis communautaire. The energy infrastructure projects are
designed for operation for several years. Those which are consulted now will be probably in operation when the Western Balkan
countries join European Union. The countries need to plan now energy sector to be in line with EU principles and targets.
Moreover, an objection of double standards could be raised if the energy infrastructure is promoted in the areas of weaker
environmental protection that those in UE. Thus, it is important to support merely the projects which are compliant with EU
standards and legislation. The formula of public consultation is our next concern. The opportunity for stakeholders to submit
additional project as potential PECIs within public consultation extends the deadline of open call for proposals far beyond 31
December 2012, in effect. What is the reason for non-respecting the timeframe for submission of PECIs proposals and extending
it in a furtive manner? Such confusion has further going consequences: a new public consultation should be conducted not only
for late submitted proposals but for all proposed project as some projects may interact between each other. To satisfy the aim of
public consultations all of the project must be the subject of public opinion assessment.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG013
Comments on the project:
The project is not compliant with the following criteria: Contribution to the implementation of Regional Energy Strategy’s
objectives It is said that the Kosova e Re is going to increase the electricity generation in regional electricity market (Albania
and Macedonia) after the construction of two 400kv interconnection lines. However, the lines can be constructed and
connected to Kosovo B - Kosova e Re itself is not of regional interest. Contribution to sustainable energy development
Construction of a new lignite-fired power plant will make impossible to meet CO2 reduction targets by 2050. It is probable
that emissions will exceed EU ambient air quality standards due to the location where the Kosovo e Re plant is planned.
Maturity of the project The Environmental Impact Assessment has not been conducted yet but it is already known that the
project would affect seriously water system.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG022
Comments on the project:
The project is not compliant with the following criteria: Contribution to the implementation of Regional Energy Strategy’s
objectives The project is considered as Serbian and not cross-border project. Contribution to sustainable energy
development Construction of a new lignite-fired power plant will make impossible to meet CO2 reduction targets by 2050.
Health and social costs were not taken into account for the project.
Project Comment Form
Project number (ID and code) as indicated in the list:
ET023
Comments on the project:
The project is not compliant with the following criteria: Contribution to the implementation of Regional Energy Strategy’s
objectives The project is considered as Serbian and not cross-border project. Contribution to sustainable energy
development Construction of a new lignite-fired power plant will make impossible to meet CO2 reduction targets by 2050.
Health and social costs were not taken into account for the project.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG024
Comments on the project:
The project is not compliant with the following criteria: Contribution to the implementation of Regional Energy Strategy’s
objectives The project is considered as Serbian and not cross-border project. Contribution to sustainable energy
11
development Construction of a new lignite-fired power plant will make impossible to meet CO2 reduction targets by 2050.
Your Details
Title:
Mr.
First name:
Anes
Last name:
Podic
Name of organization:
Eko akcija
Job title:
Project Coordinator
Address:
Radnicka bb
Postcode:
71000
City:
Sarajevo
Country:
Bosnia and Herzegovina
Email: *
[email protected]
Phone No:
+387 62 293 763
General Comments
You are invited to provide your general comments in this section
In our view, proposed PECI promote generation, instead of focusing on energy efficiency and energy saving, which would
decrease the demand for energy generation. According to Peter Johansen, a Senior Energy Specialist at World Bank, “one euro
invested in energy efficiency helps avoid an investment of 2,2 euro in generation”. Bosnia and Herzegovina does not have
development strategy nor energy strategy on state level, but also both entities are lacking development strategies, and therefore
nominated generation projects should not be listed as PECI. The generation projects which are nominated are based on an
unstable and unpredictable energy source (hydro). The available data regarding the hydrology is outdated, and also, the
influence of climate change on the hydrology is not taken into account. According to the Initial National Communication of BiH
under the UNFCCC it is expected that water availability will be reduced, and seasonal and territorial distribution of precipitation
changed. The proposed projects focus only on using the hydro potential for electricity generation, completely overlooking
possibilities that BiH has in energy generation from solar, wind and biomass sources. Regarding Methodology and criteria for
identification of projects of Energy Community interest, we have few comments. I. Contribution to the implementation of Regional
Energy Strategy’s objectives NGOs from across the region and the four largest groups in the EU Parliament have asked for the
Energy Community Regional Energy Strategy (ECRES) to be withdrawn on the basis that it is the current Regional Energy
Strategy conflicts with 2030 targets as in all scenarios, even the so-called 'sustainable' scenario, increases rather than decreases
in greenhouse gas emissions from the energy sector are expected. Since all the proposed PECIs derive their logic from this
flawed strategy, supporting electricity generation projects that have not been screened for their impact on a country's ability to
meet 2030 greenhouse gas targets and Regarding Methodology and criteria for identification of projects of Energy Community
interest, we have few comments. III. Security of supply - Through diversification of supply sources, supplying counterparts and
routes, a) Since all PECI generation projects for BiH are large hydro power plants (HPPs), and having in mind that already more
than 50% of electricity is produced in HPPs, we can not understand how proposed projects are passing this criteria. b) Since the
regional climate model RCM-SEEVCCC predicts significant drops in precipitation in the coming decades hydro needs to be very
carefully assessed as there is now consensus that we are heading for a 4 degree rises in global temperature, while large parts of
BiH with even higher higher changes than average global and regional forecasts. IV. Contribution to sustainable energy
development - Facilitation of the development of renewable energy sources It is already found by numerous respectable studies
that hydro power plants can have large negative impacts, both on environment and local communities, if not carefully planned
and developed. Having in mind existing practices in BiH, we are very concerned with it's potential outcomes. - Length of project
realization If this criteria are taken into account we believe that none of generation projects from BiH would not be awarded with
PECI status. Instead, we believe there should be projects of energy efficiency of new renewable energy sources, which have
much shorter project realization cycle.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG002
12
Comments on the project:
Hydro Power System of Upper Drina - HPP Buk Bijela, HPP Foča, HPP Paunci, HPP Sutjeska do not fulfill criteria for PECI
projects. Even though those four HPPs are grouped in one hydro power system, there is no EIA for whole power system,
but each HPP is assessed separately without cross-references (and very likely by different EIA developing companies), that
we consider as serious deficiency of the project. Also, there is no Strategic Environmental Assessment for all HPPs
(planned and operating) on whole Drina River, including Lower Drina (EG005) and Middle Drina HPPs (EG006). Having in
mind that Bosnia and Herzegovina did not complete list of potential Natura 2000 areas, and that Drina River watershed is
very rich in biodiversity and having large natural value (at the moment study for National Park Drina is drafted), SEA is of
crutial importance. Up to date, only EIAs for two HPPs (Buk Bijela and Foča) were done. Responsible Ministry of
Environment did not even publish information on public consultation on their web site. Many NGOs from BiH and
Montenegro are against Upper Drina project. All planned HPPs on Drina River, including Lower Drina (EG005) and Middle
Drina HPPs (EG006), are subject of political dispute between state government and entity government of Republic of
Srpska, for question whether Republic of Srpska can decide on use of waters of Drina River, that is in same time state and
entity border. Moreover, Government of Republic of Srpska during EIA procedure did not inform state government
(responsible for ESPOO convention) nor government of Montenegro, which is obligatory according to ESPOO convention,
considering HPP Buk Bijela, whose accumulation is reaching border with Montenegro. On Montenegro side of border begins
Tara River with its canyon that is protected as a part of Durmitor National Park and UNESCO MAB site, and is a tentative
UNESCO World Heritage Site.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG003
Comments on the project:
Hydro Power Plant Dabar is highly controversial project, that should not be on PECI list. There are numerous reasons, and
amongst others: HPP Dabar is part of larger project Upper Horizons, that enable transfer of waters from three periodically
flooded karst fields (Nevesinjsko, Dabarsko and Fatnicko) through channels and tunnels into Trebisnjica River. Before this
project, waters from these fields were naturally flowing underground into Trebisnjica River, but also Neretva River.
Environmental Impact Assessment (EIA) was never done for project Upper Horizons, even though potential negative impact
on environment are enormous. EIA for HPP did not take into account potential social and environment impacts of project
Upper Horizons. During public consultations on EIA for HPP Dabar, citizens and local NGOs (but also international NGOs,
such as WWF) submitted numerous complaints on EIA. Also, Federal Ministry of Environment and Tourism (FMET)
submitted comments on EIA. Most important comments were not considered and EIA was not amended upon them. In
September 2012 FMET initiated legal action against Ministry for Spatial Planning, Civil Engineering and Ecology of Republic
of Srpska, which is responsible for EIA procedure. Legal process is act6ive at the moment. If promoted as PECI, this project
can further contribute to political tensions between entity governments in Bosnia and Herzegovina. Complaints of concerned
public were not taken into account either. Most severe potential environmental impact would be in changed distribution of
water between two river basins and decrease in underground water flow to Neretva River. It would affect Buna river springs
(tentative UNESCO site), Hutovo blato (Ramsar site) and delta of Neretva River (important wetland ecosystem), but also
other aquatic ecosystems in lower Neretva area. HPP Dabar would also have serious social impact, with its distortion of
water supply in Bregava River region, and threatening developed agriculture production in Neretva River delta (in Croatia).
Even though impact on Neretva delta region is very likely provisions of ESPOO convention were not applied. Having in mind
that one of selection criteria for PECI projects is “Experience of project promoter”, we have to stress out that promoters of
HPP Dabar, Government of Republic of Srpska and Power Company of Republic of Srpska did not implement any project of
similar size in past 30 years. Also, having in mind independent reports on high corruption in institutions, we believe that HPP
Dabar, if kept on PECI list, could become huge embarrassment for Energy Community Secretariat.
Your Details
Title:
Mr.
First name:
Zoran
Last name:
Ivancic
Name of organization:
CPI Foundation
Job title:
Chairman of the Board
Address:
Cemaluša 7
Postcode:
71000
City:
Sarajevo
13
Country:
Bosnia and Herzegovina
Email: *
[email protected]
Phone No:
+38761165166
General Comments
You are invited to provide your general comments in this section
In our view, proposed PECI promote generation, instead of focusing on energy efficiency and energy saving, which would
decrease the demand for energy generation. According to Peter Johansen, a Senior Energy Specialist at World Bank, “one euro
invested in energy efficiency helps avoid an investment of 2,2 euro in generation”. Bosnia and Herzegovina does not have
development strategy nor energy strategy on state level, but also both entities are lacking development strategies, and therefore
nominated generation projects should not be listed as PECI. The generation projects which are nominated are based on an
unstable and unpredictable energy source (hydro). The available data regarding the hydrology is outdated, and also, the
influence of climate change on the hydrology is not taken into account. According to the Initial National Communication of BiH
under the UNFCCC it is expected that water availability will be reduced, and seasonal and territorial distribution of precipitation
changed. The proposed projects focus only on using the hydro potential for electricity generation, completely overlooking
possibilities that BiH has in energy generation from solar, wind and biomass sources. Regarding Methodology and criteria for
identification of projects of Energy Community interest, we have few comments. I. Contribution to the implementation of Regional
Energy Strategy’s objectives NGOs from across the region and the four largest groups in the EU Parliament have asked for the
Energy Community Regional Energy Strategy (ECRES) to be withdrawn on the basis that it is the current Regional Energy
Strategy conflicts with 2030 targets as in all scenarios, even the so-called 'sustainable' scenario, increases rather than decreases
in greenhouse gas emissions from the energy sector are expected. Since all the proposed PECIs derive their logic from this
flawed strategy, supporting electricity generation projects that have not been screened for their impact on a country's ability to
meet 2030 greenhouse gas targets and Regarding Methodology and criteria for identification of projects of Energy Community
interest, we have few comments. III. Security of supply - Through diversification of supply sources, supplying counterparts and
routes, a) Since all PECI generation projects for BiH are large hydro power plants (HPPs), and having in mind that already more
than 50% of electricity is produced in HPPs, we can not understand how proposed projects are passing this criteria. b) Since the
regional climate model RCM-SEEVCCC predicts significant drops in precipitation in the coming decades hydro needs to be very
carefully assessed as there is now consensus that we are heading for a 4 degree rises in global temperature, while large parts of
BiH with even higher higher changes than average global and regional forecasts. IV. Contribution to sustainable energy
development - Facilitation of the development of renewable energy sources It is already found by numerous respectable studies
that hydro power plants can have large negative impacts, both on environment and local communities, if not carefully planned
and developed. Having in mind existing practices in BiH, we are very concerned with it's potential outcomes. - Length of project
realization If this criteria are taken into account we believe that none of generation projects from BiH would not be awarded with
PECI status. Instead, we believe there should be projects of energy efficiency of new renewable energy sources, which have
much shorter project realization cycle.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG002
Comments on the project:
Hydro Power System of Upper Drina - HPP Buk Bijela, HPP Foča, HPP Paunci, HPP Sutjeska do not fulfill criteria for PECI
projects. Even though those four HPPs are grouped in one hydro power system, there is no EIA for whole power system,
but each HPP is assessed separately without cross-references (and very likely by different EIA developing companies), that
we consider as serious deficiency of the project. Also, there is no Strategic Environmental Assessment for all HPPs
(planned and operating) on whole Drina River, including Lower Drina (EG005) and Middle Drina HPPs (EG006). Having in
mind that Bosnia and Herzegovina did not complete list of potential Natura 2000 areas, and that Drina River watershed is
very rich in biodiversity and having large natural value (at the moment study for National Park Drina is drafted), SEA is of
crutial importance. Up to date, only EIAs for two HPPs (Buk Bijela and Foča) were done. Responsible Ministry of
Environment did not even publish information on public consultation on their web site. Many NGOs from BiH and
Montenegro are against Upper Drina project. All planned HPPs on Drina River, including Lower Drina (EG005) and Middle
Drina HPPs (EG006), are subject of political dispute between state government and entity government of Republic of
Srpska, for question whether Republic of Srpska can decide on use of waters of Drina River, that is in same time state and
entity border. Moreover, Government of Republic of Srpska during EIA procedure did not inform state government
(responsible for ESPOO convention) nor government of Montenegro, which is obligatory according to ESPOO convention,
considering HPP Buk Bijela, whose accumulation is reaching border with Montenegro. On Montenegro side of border begins
Tara River with its canyon that is protected as a part of Durmitor National Park and UNESCO MAB site, and is a tentative
UNESCO World Heritage Site.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG003
14
Comments on the project:
Hydro Power Plant Dabar is highly controversial project, that should not be on PECI list. There are numerous reasons, and
amongst others: HPP Dabar is part of larger project Upper Horizons, that enable transfer of waters from three periodically
flooded karst fields (Nevesinjsko, Dabarsko and Fatnicko) through channels and tunnels into Trebisnjica River. Before this
project, waters from these fields were naturally flowing underground into Trebisnjica River, but also Neretva River.
Environmental Impact Assessment (EIA) was never done for project Upper Horizons, even though potential negative impact
on environment are enormous. EIA for HPP did not take into account potential social and environment impacts of project
Upper Horizons. During public consultations on EIA for HPP Dabar, citizens and local NGOs (but also international NGOs,
such as WWF) submitted numerous complaints on EIA. Also, Federal Ministry of Environment and Tourism (FMET)
submitted comments on EIA. Most important comments were not considered and EIA was not amended upon them. In
September 2012 FMET initiated legal action against Ministry for Spatial Planning, Civil Engineering and Ecology of Republic
of Srpska, which is responsible for EIA procedure. Legal process is act6ive at the moment. If promoted as PECI, this project
can further contribute to political tensions between entity governments in Bosnia and Herzegovina. Complaints of concerned
public were not taken into account either. Most severe potential environmental impact would be in changed distribution of
water between two river basins and decrease in underground water flow to Neretva River. It would affect Buna river springs
(tentative UNESCO site), Hutovo blato (Ramsar site) and delta of Neretva River (important wetland ecosystem), but also
other aquatic ecosystems in lower Neretva area. HPP Dabar would also have serious social impact, with its distortion of
water supply in Bregava River region, and threatening developed agriculture production in Neretva River delta (in Croatia).
Even though impact on Neretva delta region is very likely provisions of ESPOO convention were not applied. Having in mind
that one of selection criteria for PECI projects is “Experience of project promoter”, we have to stress out that promoters of
HPP Dabar, Government of Republic of Srpska and Power Company of Republic of Srpska did not implement any project of
similar size in past 30 years. Also, having in mind independent reports on high corruption in institutions, we believe that HPP
Dabar, if kept on PECI list, could become huge embarrassment for Energy Community Secretariat
Your Details
Title:
MS.c
First name:
Lavdosh
Last name:
Ferruni
Name of organization:
Organic Agriculture Association
Job title:
Executive director
Address:
Rr. Sarasheri p20/10 Tirane
Postcode:
1000
City:
Tirana
Country:
Albania
Email: *
[email protected]
Phone No:
00355692099047
General Comments
You are invited to provide your general comments in this section
Organic Agriculture Association strongly opposes the project "Construction of a Gas terminal on Albanian coast and the gas
pipeline Albania-Italy. It is destroying part of the ecosystem of Adriatic seashore of Albania, It does not make economic sense
since the terminal is in Albania and than is transported in Italy. This is just transfer of the pollution to Albania. Further in the area
of building the terminal it is more relevant to build up a photovoltaic plant, which is the best alternative option, considering the
sunny days in coastal area of Albania. Alternative "no project" is again much better.
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
15
calculating external costs
Your Details
Title:
Mr
First name:
Garret
Last name:
Tankosić Kelly
Name of organization:
SEE Change Net on behalf of SEE SEP, CEE Bankvac
Name of organization:
SEE Change Net on behalf of SEE SEP, CEE Bankvac
Job title:
Principal
Address:
Branilaca Sarajeva 20/2
Postcode:
71000
City:
Sarajevo
Country:
Bosnia and Herzegovina
Email: *
[email protected]
Phone No:
00387 33 213 716
General Comments
You are invited to provide your general comments in this section
Dear Mr Kopač, We are writing to you with regard to the public consultation on the proposed Projects of Energy Community
Interest (PECIs), in the electricity, gas and oil sectors. Although many if not all of the undersigned groups will be submitting
comments to the consultation itself, we would like to jointly address several important matters about the process, scope and
selection criteria. • If EU PCI criteria are used to select PECIs then the kind of projects which are eligible as PECIs need to be
similar to the proposed PCI projects, ie. transmission and storage projects, not generation In 2012 the European Union launched
a call for Projects of Community Interest or PCI for European Union member states. These projects were exclusively for the
transportation and storage of electricity gas, oil, etc. The projects approved were expected to be “fast tracked” through the
planning and approval process. Now the Energy Community Treaty has launched a call for proposals under the acronym PECI or
Projects of Energy Community Interest. The selected projects are expected to be “fast tracked” in terms of approvals and will be
earmarked for support with EU funds. However claims that the PECI process is similar to the EU PCI process and that the PCI
criteria are therefore relevant for the selection of PECI projects are not credible, as electricity generation projects have also been
nominated. This is important because electricity generation is a large source of greenhouse gas emissions in almost all the
Energy Community Parties. Massive changes need to take place in the region's energy sector in the next few decades. In the
coming months an important new development will be taking place: the EU is expected to approve binding targets for greenhouse
gas emissions reductions by 2030. If the Energy Community countries are to join the EU they need to start now with planning
energy sectors aiming towards decarburization and massive greenhouse gas emissions reductions, due to the long life of energy
infrastructure, which can lock in carbon emissions. In smaller economies like many of the Energy Community Parties, one power
plant can make a massive difference to the energy sector of the country and a country's CO2 emissions. Indeed, it can mean the
difference between meeting greenhouse gas reduction targets and not meeting them. Slovenia has realized this too late with its
construction of the Sostanj unit 6 lignite plant, and other countries in southeast Europe need to learn from this mistake. The
current Regional Energy Strategy conflicts with 2030 targets as in all scenarios, even the so-called 'sustainable' scenario,
increases rather than decreases in greenhouse gas emissions from the energy sector are expected. Since all the proposed
PECIs derive their logic from this flawed strategy, supporting electricity generation projects that have not been screened for their
impact on a country's ability to meet 2030 greenhouse gas targets and the EU's 2050 decarburization policy risks supporting
investments which will either hinder the implementation of EU policy or have to be closed before the end of their lifetimes. Since
the PECI generation projects do not conform to the EU PCI model, and since they are based on a flawed Regional Energy
Strategy that has been criticized not only by NGOs but by four groups in the European Parliament, the 'generation' strand of the
PECI should be completely halted until such time as ALL the defects above are revised. Additionally, for future selection of
PECIs, demand-side energy efficiency projects need to be made eligible in order to push forward investments into this crucial
area, for which the whole region has vast potential and a huge need, given the increasing levels of energy poverty. While it may
not be obvious that such projects are of a regional nature, projects which make use of the cost-cutting potential of carrying out the
same activity in several areas could and should be developed. • Any additional proposed PECIs must be subject to additional
16
public consultation We note that in the public consultation an opportunity is given to submit additional projects as potential PECIs.
The original call for PECI proposals was made on 7th November 2012 to expire on 10th December and was later extended to
31st December 2012. This public consultation in effect extends the deadline for PECI project proposals. However as things
currently stand, the public would not have an opportunity to comment on the proposals which are submitted late, thus
undermining the point of the public consultation. Although we believe that the deadline for submitting PECIs should have been
respected and not extended by stealth, now that this is done, if any eligible new PECI projects are nominated, the Regional
Energy Strategy Task Force should hold a new public consultation of the same duration as the first one (8 weeks) and all
proposed projects should be open to re-evaluation as there may be synergistic effects between projects.
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
Fast-tracking of PECIs may be incompatible with ensuring the proper application of the EU environmental acquis and reduce
transparency and accountability The selected PECI projects are expected to be “fast tracked” in terms of approvals and will be
earmarked for support with EU funds. We would like to ask you for details about what exactly this fast-tracking will and will not
mean in practice? The region's track record for the application of environmental, planning, and procurement processes is wholly
inadequate (see EU Progress Reports), and we are concerned that fast-tracking may further weaken these processes if not very
carefully targeted. It should not be assumed that the involvement of the European public banks would ensure against such flaws,
as there are currently several on-going investigations by the EBRD's and EIB's complaint mechanisms regarding such issues in
projects in the Energy Community region, as well as an on-going OLAF investigation against the EIB regarding Sostanj 6.
Although the Energy Community parties have adopted EU Environmental Impact Assessment legislation, the legislation on nature
protection (eg. the Bird and Habitats Directives, Water Framework Directive) is far behind in its implementation and is not
required by the Energy Community. Yet energy infrastructure is being planned in areas which would have been better protected
had they been in the EU (eg. Ombla hydropower plant, Croatia, Boskov Most hydro plant, Macedonia), thus leading to double
standards. If PECI projects are to be given a stamp of approval by the ECTS – an EC funded institution – then they should also
be subject to best practices in transparency and accountability. In summary: • Only connection & storage projects may be
considered at this stage until such time as the Regional Energy Strategy has been reviewed and aligned with EU policies and
goals • The public consultation should be repeated if any new PECI projects are submitted during the current process. • During
the selection process, as well as compliance with Energy Community-backed environmental and energy legislation, particular
attention should be paid to possible conflicts between the proposed PECI projects and EU legislation that has not yet been
transposed in the region such as the Birds and Habitats Directives. • No fast tracking of any kind which would subvert the existing
poorly implemented legal framework on environment, planning and procurement in the region should be considered. • All tenders
should be entirely transparent from beginning to end in a web-based format supported by the ECTS and hosted on its website. •
Random projects should be open for external independent audit • Any future project calls under PECI should include energy
efficiency and energy loss reduction projects when re-launched, as the most crucial way to reduce energy poverty in the region.
We urge you to take action to ensure that PECIs become Projects of Every Citizens' Interest. Without such corrective actions the
PECI process risks being undemocratic, and disrespectful of EU legislation, policy and principles. Our SEE SEP network partners
will be submitting comments on individual PECI projects.
Your Details
Title:
Ms.
First name:
Pippa
Last name:
Gallop
Name of organization:
CEE Bankwatch Network
Job title:
Research Co-ordinator
Address:
Na Rozcesti 1434/6
Postcode:
190 00
City:
Praha 9 - Liben
Country:
Czech Republic
Email: *
[email protected]
Phone No:
+420 274 822 150
17
General Comments
You are invited to provide your general comments in this section
Our main concern relates to the need to develop an energy sector in southeast and eastern Europe which is in line with EU
environmental and climate policies and legislation, as well as one which addresses the increasing problem of energy poverty
through sparing and efficient energy use. We underline the need for the PECIs projects to be in line with current and forthcoming
EU legislation and policies on climate, environment, renewable energy and energy efficiency for two reasons: 1) EU accession
and the need to catch up with EU climate and renewables commitments. The Western Balkan countries all have aspirations to
join the EU. The EU's long-term energy and climate policy – as well as climate science – demands cuts of 80-95% in greenhouse
gas emissions by 2050 and almost total decarbonisation of the energy sector. In addition there are further discussions on 2030
targets ongoing on the EU level. The EU cannot afford to have newly acceding members holding up progress towards these
goals or watering down future policy making, yet energy infrastructure planned and constructed now will mostly still be in
operation when the countries accede. It is therefore of concern that several of the generation projects planned are coal or lignitefired, which threaten to lock countries in to this type of production for decades to come. Slovenia realised this too late with its
Sostanj 6 project, and other countries in the region should now learn from this mistake. Thus it is crucial that infrastructure given
the PECI label is in line with existing EU climate and renewables targets as well as targets which can be reasonably expected
during the coming years. Related to this is the point that the PECI projects can expect to receive backing from EU public
financing institutions such as the EBRD and EIB. It is crucial that these banks, which should set the tone for investments rather
than following existing markets, halt investments in fossil fuel projects of all kinds – which are effectively subsidies given that they
confer a benefit on the recipient - and instead set the pace that is needed to improve the transmission network, energy efficiency
and savings, and renewable energy projects. 2) Avoiding 'energy grabbing' or 'carbon leakage'. Although an increase in
interconnections is a generally desirable trend in the move towards smart electricity networks, when such projects facilitate
imports of electricity to the EU from countries with lower environmental and social standards or lower/no climate commitments,
they can result in people and the environment in those countries bearing the negative impacts of the projects, and diminishing the
effectiveness of the EU's own policies (especially on climate issues). While it may seem that importing electricity from renewable
energy projects in accession and neighbourhood countries is less problematic in this respect, it is not necessarily the case. This
is because enforcement of environmental legislation is less rigorous in the accession countries than in the EU and some aspects
of the acquis have not been transposed or implemented (eg. the Birds and Habitats Directives and the definition of Natura 2000
sites). Thus many highly valuable sites are threatened by construction projects such as hydropower plants. Another issue is that if
countries contractually commit themselves to export electricity from renewable energy to other countries, this diminishes the sites
available for developing renewable energy for local use, thus making it harder to develop their own renewables industry and meet
renewable energy targets. In terms of the PECIs criteria, these issues have several implications: - Several of the Energy
Community parties, due to their small size, would find it impossible to make significant CO2 emissions reductions during the
coming decades if they now construct new coal/lignite plants. Although 2050 targets are not yet binding, they are required by
climate science, and new coal generation projects should not be selected as PECIs as they will prevent such targets from being
met. - It is welcome that the CO2 price is taken into account in the calculations, however the pricing used by the consultants goes
only up to EUR 16.90 per tonne in 2022. Such a price will not lead to significant CO2 reductions in the EU, and cannot ensure
that PECIs will be in line with a trajectory of 80-95% GHG cuts by 2050. Thus it is necessary to introduce additional elements into
the calculation – either higher carbon prices and/or a shadow carbon price. - Projects aimed at diminishing the generation gap in
the Energy Community countries must be prioritised over those aimed at export to the EU. - It is welcome that qualitative
information on the environmental and/or social impact of the projects will be taken into consideration during the assessment, as
outlined on the open day, and we include some project-specific details of such issues below. It is also of concern that the health
costs of burning certain kinds of fuel (mainly coal) are NOT counted in the calculation. (During the Open Day it was initially
thought that health costs are included, however further communication with the consultant after the event revealed that this is in
fact not the case). These costs – which can be extremely significant and may change the whole economic picture of a project –
must be included in the cost-benefit analysis and/or the analysis of change in socio-economic welfare. In addition, for future
rounds of PECIs, demand-side energy efficiency projects need to be made eligible in order to push forward investments into this
crucial area. The whole Energy Community region has vast needs in this area, given the increasing levels of energy poverty. In
order to emphasise the regional aspect, projects which make use of economies of scale by being implemented in several areas at
once need to be developed.
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
We would add a word of caution here. There is a clear issue with the length of time taken to develop and implement infrastructure
projects in the region, and it is quite popular to blame environmental permitting procedures for these delays. While it is true that
some countries such as Croatia have complicated environmental permitting procedures for small installations, in many larger
projects the delays come not from the existence of the environmental permitting procedures themselves but from other factors
such as: - poor quality of the project itself (ie. politically-driven not needs-driven; outdated concept etc) and persistence in
pushing projects which have been around for decades but have too high environmental or social costs or are uneconomic - poor
quality project documentation that does not meet legal standards or enable widespread buy-in - lack of investor interest due to
corruption - lack of consistent sectoral planning that could convince investors, other political and economic actors and the public
that the project has widespread and long-term buy-in - delays by public authorities unrelated to environmental legal requirements
(eg. in preparing tender documentation). Currently the track record of the Energy Community countries in the application of
18
environmental, planning, and procurement processes is rather poor and we are concerned that fast-tracking may further weaken
these processes if not very carefully targeted. It should not be assumed that the involvement of the European public banks would
ensure against such flaws, as there are currently several on-going investigations by the EBRD's and EIB's complaint mechanisms
regarding such issues in projects in the Energy Community region, as well as an on-going OLAF investigation against the EIB
regarding Sostanj 6. Although the Energy Community parties have adopted EU Environmental Impact Assessment legislation, the
legislation on nature protection (eg. the Bird and Habitats Directives, Water Framework Directive) is far behind in its
implementation and is not required by the Energy Community. Yet energy infrastructure is being planned in areas which would
have been better protected had they been in the EU, thus leading to double standards. Therefore we propose that PECI fasttracking must not lead to weakening of environmental standards, but that other problems in implementation should rather be
addressed. This can be done through the selection of only the highest quality and best-planned projects, which have resulted
from thorough and transparent planning processes in which a wide range of stakeholders has been included to ensure
widespread buy-in. Insisting on the highest standards of transparency throughout projects eg. tender processes would also help
to stop delays related to suspicions of irregularities.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG001
Comments on the project:
WPP Dajc-Velipoje Although we very much support the development in wind power when appropriately located, this project
should not be prioritised because: a) it is planned to be sited in a Ramsar site, and has repeatedly been refused permission
by the Albanian Environment Ministry. This implies a negative change in socio-economic welfare due to lost value of the
Skadar lake area, but also slow progress in implementation or eventually a complete halt to the project. b) it is not designed
to meet local needs but rather for export to Italy. Thus it should not be counted either as contributing to security of supply
(because it is not contributing to Albania's security of supply – it may contribute to Italy's but this should not be the topic of
the Energy Community's strategy and priorities). Perhaps somewhat counterintuitively, we also suggest that it should not
gain points under facilitation of renewables, because it does not contribute to developing renewables in Albania's or the
Energy Community's electricity system, and indeed due to its location is likely to build up a negative picture of wind power
and contribute to a backlash against this form of power generation.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG002
Comments on the project:
Hydro Power System of Upper Drina - HPP Buk Bijela, HPP Foča, HPP Paunci, HPP Sutjeska Project costs/Change in
socio-economic welfare: The Upper Drina is an area of high natural value and beauty. Bosnia and Herzegovina has not
completed a list of potential Natura 2000 areas, but a study on creating a Drina National Park Drina is being drafted. Thus
several civil society organisations from BiH oppose the project, and any consideration of the project must be weighed
against losses in actual and potential income from tourism as well as the loss of biodiversity, natural beauty and clean
water. A Strategic Environmental Assessment, at the very least, would be of great importance here. Progress in
implementation: The planned HPPs on Drina River, including Lower Drina (EG005) and Middle Drina HPPs (EG006), are
subject to a political dispute between state government and entity government of Republic of Srpska on the topic of whether
Republic of Srpska can decide on the use of the Drina River, which forms both the state and entity border. Moreover, the
Government of Republic of Srpska during EIA procedure did not inform the state government (responsible for ESPOO
Convention) nor government of Montenegro, which is obligatory according to ESPOO Convention, considering that HPP
Buk Bijela's reservoir would reach the border with Montenegro. On the Montenegro side of border begins Tara River with its
canyon that is protected as a part of Durmitor National Park and a UNESCO MAB site, and is a tentative UNESCO World
Heritage Site. Even though these four HPPs are grouped in one hydro power system, there is no EIA for the whole power
system, but each HPP is assessed separately without cross-references, thus avoiding an assessment of cumulative
impacts. Likewise there is no Strategic Environmental Assessment for all HPPs (planned and operating) on whole Drina
River, including the Lower Drina (EG005) and Middle Drina HPPs (EG006). So far, only EIAs for two HPPs (Buk Bijela and
Foča) have been carried out. The responsible Ministry of Environment did not even publish information on the public
consultation on its web site in spite of the project's controversial status.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG003
Comments on the project:
Hydro Power Plant Dabar The Dabar HPP is part of the larger Upper Horizons project which is to enable transfer of water
from three periodically flooded karst fields (Nevesinjsko, Dabarsko and Fatnicko) through channels and tunnels into the
Trebisnjica River. Before this project, waters from these fields flowed naturally underground into the Trebisnjica River, but
also into the Neretva River. The Dabar HPP is a highly controversial project which should not be designated as a PECI for
the following reasons among others: Project costs/change in socio-economic welfare: In addition to monetary costs, the
enormous environmental costs of the project must be taken into account. The most severe potential environmental impact
19
would be due to the changed distribution of water between the two river basins and decrease in underground water flow to
the River Neretva. It would affect the Buna river springs (a tentative UNESCO site), Hutovo blato (a Ramsar site) and delta
of Neretva River (important wetland ecosystem), and also other aquatic ecosystems in lower Neretva area. HPP Dabar
would also have a serious social impact, with its distortion of water supply in the Bregava River region, and threatening
developed agriculture production in the Neretva River delta (in Croatia). Even though an impact on Neretva delta region is
very likely, the provisions of ESPOO convention have not been applied. Progress in implementation No EIA has been
carried out for the Upper Horizons project, in spite of the massive potential negative impact on the environment. For Dabar
HPP, the EIA did not take into account the potential social and environment impacts of Upper Horizons as a whole (ie. the
project was salami-sliced to make its impacts appear smaller). During public consultations on the EIA for HPP Dabar,
residents and local NGOs, as well as international NGOs such as WWF, submitted numerous critical comments on the EIA,
as did the Federal Ministry of Environment and Tourism. The most important comments were not considered and the EIA
was not amended in response to them. In September 2012 the Federal Ministry initiated legal action against the Ministry for
Spatial Planning, Civil Engineering and Ecology of Republic of Srpska, which is responsible for the EIA procedure. A legal
process is ongoing at the moment. Thus the project is not likely to be implemented swiftly, and may contribute to further
exacerbating political tensions between the entity governments in Bosnia and Herzegovina. In addition, it should be
stressed that the promoter of Dabar HPP, the Government of Republic of Srpska and Power Company of the Republic of
Srpska have not implemented any similar project for the last 30 years.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG008
Comments on the project:
Hydro Power Plants on River Vardar - 12 HPPs – This project is of Macedonian interest only, not of regional interest and
therefore should not be prioritised. Project costs/Change in socio-economic welfare: The project is estimated to cost around
EUR 1.2 million, although this may still rise as it is only at the pre-feasibility stage. Due to the large number of hydro-power
plants involved it will cause significant disruption and require the reconstruction and relocation of existing infrastructure such
as the railway in Veles, making it highly unlikely that it is economically feasible. Progress in implementation: Despite the
project being around since 1932, it is still currently at the stage of developing a pre-feasibility study. Chinese investors are
said to be interested in the project but have made no clear commitments so far. There is likely to be a serious impact on the
Important Bird Area and Emerald Site in Demir-Kapija which may cause difficulties with permitting.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG013
Comments on the project:
Kosova e Re power plant This project fails to satisfy several of the criteria or scores poorly compared to other alternative
options as follows: Regional interest – in the Energy Community list it is claimed that the project is of interest to Macedonia
and Albania if the corresponding transmission lines are built. However this is somewhat stretching the situation as the lines
can be built and connected to Kosovo B once refurbished if this is necessary for stabilization of the grid – there is no real
reason why Kosova e Re is itself of regional interest as opposed to the construction of transmission lines to connect existing
facilities. Project costs – stated at EUR 1.2 billion, it is questionable whether Kosovo can afford this investment, which does
not represent the least cost option for covering Kosovo's needs. Daniel Kammen, Professor at the University of California in
Berkeley and former World Bank 'Clean Energy Czar”, has shown that Kosovo has renewable energy capacities that could
deliver 34 percent of energy demand by 2025, while providing over 60 percent more jobs than a business as usual path,
with estimated cost savings of 5-50% relative to a scenario that includes a new coal power plant. If energy efficiency
programmes are put in place, losses are curbed, renewable energy is developed, and the existing Kosovo B plant is
rehabilitated,
the
study
finds,
there
is
no
need
for
a
costly
new
plant.
(See
http://coolclimate.berkeley.edu/sites/all/files/Kosovo20May2012.pdf). Building Kosova e Re would require Kosovo
consumers
(or
the
government)
to
service
over
a
billion
euro
in
debt
(http://action.sierraclub.org/site/DocServer/Reevaluating_Kosovo_s_Least_Cost_Options_for_Electricity.pdf?docID=8861)
at a time when they are also servicing debt for improvements in the Sibovc mine, Kosovo’s wasteful transmission and
distribution systems, and refurbishment of Kosovo B. Security of supply: While the plant is being depicted as necessary to
ensure the country’s energy security, up to 30 percent of available electricity in Kosovo today is wasted according to official
data, because of lack of energy efficiency programmes. This adds to the 37 percent of electricity losses (of which around 17
percent are technical and a result of an old grid and the other are commercial losses, i.e. theft). Thus, while the plant does
use local sources, it is not the least cost option to achieve the goals of a) reducing energy waste and b) meeting the
demand which remains. CO2 emissions: Kosovo currently produces 97-98 percent of its electricity from lignite but as it is
aiming to join the EU, it will have to adhere to ever stricter CO2 reduction targets. However this one coal power plant alone
will likely swallow up most of the country's carbon budget by 2050, leaving a choice between closing the plant earlier than
planned or paying penalties. Change in socio-economic welfare - The government has already had to freeze price rises for
electricity this year after protests, so it is questionable whether further rises to pay for the plant would able to be
implemented. The EUR 1.2 billion price tag for the plant also does not include the very high health costs of continued lignite
use in Kosovo. Kosovo currently has 835 early deaths per year and estimated direct costs of around EUR 100 million
annually due to air pollution, of which the lignite plants are responsible for a substantial proportion.
(http://siteresources.worldbank.org/INTKOSOVO/Resources/KosovoCEA.pdf) However, far from solving this problem, a new
20
lignite plant would perpetuate the health risks from coal for several more decades. Due to the location where the Kosovo e
Re plant would be built, it is likely that emissions will exceed EU ambient air quality standards, even if Kosovo B and Kosova
e Re meet EU emission standards. No reliable air quality monitoring is taking place, so it is difficult to prove that air quality
would be acceptable with a new plant. Progress in implementation: While the project is being pushed by the World Bank
and US government, it is still at a relatively early stage of implementation after being scaled down from a larger project after
failing to attract investors. The tender process is not yet complete, and the EIA study is not yet completed. The EIA in
particular looks set to bring up some difficult topics around water use (http://www.bicusa.org/wpcontent/uploads/2013/01/Kosovo+Water+Study.pdf) and resettlement (http://www.kosid.org/news/dr-ted-downing-presidentof-the-indr-finds-the-preparations-for-resettlement-for-the-kosovo-c-and-new-mining-fields-area-to-be-noncompliant-withinternational-standards). Facilitation of RES: It hardly needs to be said that planning to build a new coal plant in a situation
where 97-98 percent of electricity is already generated from lignite is not going to help to facilitate renewables. It is much
more likely that it will hinder their development by crowding out funding and resources.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG022
Comments on the project:
Kolubara B This project has the following weaknesses in relation to the assessment criteria: Regional interest – claiming
that the project is of regional interest is stretching the case somewhat. It is rather planned as a Serbian project, and thus
should not receive the PECI label. CO2 emissions – constructing new lignite power plants will take Serbia in the opposite
direction from EU energy and climate policy and make it difficult or impossible to meet GHG reduction targets for 2030 and
2050. Change in socio-economic welfare – expansion of coal mining in the Kolubara lignite mine is necessitating the
resettlement of thousands of families, including 1180 households from the village of Vreoci. After years of struggle for
respect of the decisions listed in the government resettlement programme (2007 to 2012), the inhabitants of Vreoci are now
facing strong pressure from Kolubara mining company to take or leave whatever compensation the company offers. So far,
only 200 households have been moved, and only 350 households got part of the money (about 30% of the whole price) in
advance. In the meantime, corruption has been uncovered in the process, with an EPS board member receiving an inflated
sum of compensation for a house in the vicinity of the mine. http://bankwatch.org/bwmail/55/kolubara-mine-mired-crimeand-corruption. Health problems and social costs also need to be taken into account for this project (see http://www.envhealth.org/IMG/pdf/heal_report_the_unpaid_health_bill_-_how_coal_power_plants_make_us_sick_finalpdf.pdf
for
information on health costs of coal in Serbia). Progress in implementation – as this project was begun in the 1980s, it is
unclear whether it really meets today's needs or standards such as Best Available Techniques. Even since it was
announced in Spring 2012 that the EBRD was interested in financing the project, little progress appears to be taking place.
Facilitation of RES – Far from facilitating the deployment of renewable energy, this investment would crowd out financing
and other resources for the development of renewable energy, not to mention energy efficiency measures.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG023
Comments on the project:
Kostolac B3 This project has the following weaknesses in relation to the assessment criteria: Regional interest – claiming
that the project is of regional interest is stretching the case somewhat. It is rather planned as a Serbian project, and thus
should not receive the PECI label. CO2 emissions – constructing new lignite power plants will take Serbia in the opposite
direction from EU energy and climate policy and make it difficult or impossible to meet GHG reduction targets for 2030 and
2050. Change in socio-economic welfare – Health problems and social costs also need to be taken into account for this
project
(see
http://www.env-health.org/IMG/pdf/heal_report_the_unpaid_health_bill__how_coal_power_plants_make_us_sick_finalpdf.pdf for information on health costs of coal in Serbia). Facilitation of RES –
Far from facilitating the deployment of renewable energy, this investment would crowd out financing and other resources for
the development of renewable energy, not to mention energy efficiency measures.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG024
Comments on the project:
Nikola Tesla B3 This project has the following weaknesses in relation to the assessment criteria: Regional interest –
claiming that the project is of regional interest is stretching the case somewhat. It is rather planned as a Serbian project, and
thus should not receive the PECI label. CO2 emissions – constructing new lignite power plants will take Serbia in the
opposite direction from EU energy and climate policy and make it difficult or impossible to meet GHG reduction targets for
2030 and 2050. Change in socio-economic welfare – expansion of coal mining in the Kolubara lignite mine is necessitating
the resettlement of thousands of families, including 1180 households from the village of Vreoci. After years of struggle for
respect of the decisions listed in the government resettlement programme (2007 to 2012), the inhabitants of Vreoci are now
facing strong pressure from Kolubara mining company to take or leave whatever compensation the company offers. So far,
only 200 households have been moved, and only 350 households got part of the money (about 30% of the whole price) in
21
advance. In the meantime, corruption has been uncovered in the process, with an EPS board member receiving an inflated
sum of compensation for a house in the vicinity of the mine. http://bankwatch.org/bwmail/55/kolubara-mine-mired-crimeand-corruption Facilitation of RES – Far from facilitating the deployment of renewable energy, this investment would crowd
out financing and other resources for the development of renewable energy, not to mention energy efficiency measures.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG025
Comments on the project:
The project fails to score on several of the criteria stated in Regional Energy Strategy of the Energy Community, specifically:
Security of supply: While the project is a cross-border one, it is aimed at energy exports to the EU rather than satisfying
Ukrainian needs. This is a clear case of carbon leakage, in which Ukraine emits the CO2 and bears the health and
environmental costs of the project, while neighbouring EU members can more easily meet their GHG reduction targets by
moving the emissions across the border. Enhancement of competition: Project promoter DTEK is the largest private energy
company in Ukraine and it has the potential to become a private energy monopoly through privatization of all thermal power
plants and some CHP plants. DTEK has already become a private monopoly in the electricity export from Ukraine as it
bought ‘Zakhidenergo’. DTEK is aiming to control the entire thermal energy sector, including coal mining and processing,
electricity generation, transmission and distribution. Project costs/change in socio-economic welfare: This project has
significant externalities, which do not appear to be taken into account by the proposed project assessment methodology –
mainly air and water pollution and adverse health effects for the local population. As the CO2 price in the assessment
methodology is low, it will also give an unrealisticly positive picture of the project. CO2 emissions: The current national
carbon target assumes a doubling of GHG emissions in 2020 compared to 2012. This target is a reflection of the national
policy to increase the use of coal in the energy sector and runs contrary to the EU's attempts to reduce GHG emissions.
Ukrainian environmental groups are calling on government to stabilize GHG emissions at the current level by 2020, while
construction of new coal units will lead to a clear increase of GHG emissions. Facilitation of RES: Construction of the new
coal powered units means locking electricity production into coal for another 30-40 years. Renewables face unfair
competition due to significant subsidies currently going to coal mining in Ukraine (in 2010 EUR 730 million - around 2% of
the state budget). Progress in implementation: the stated date of commissioning is 2019. This is questionable, considering
that as far as we are aware, not even a feasibility study has yet been carried out. In addition, DTEK is a young company
(established in 2002) and it has little to no experience in commissioning of new units. There has been hardly any positive
experience of constructing new power plant units in Ukraine since its independence in 1991. Thus delays and complications
seem highly likely.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG026
Comments on the project:
Dobrotvir TPP new unit The project fails to score on several of the criteria stated in Regional Energy Strategy of the Energy
Community, specifically: Security of supply: While the project is a cross-border one, it is aimed at energy exports to the EU
rather than satisfying Ukrainian needs. This is a clear case of carbon leakage, in which Ukraine emits the CO2 and bears
the health and environmental costs of the project, while neighbouring EU members can more easily meet their GHG
reduction targets by moving the emissions across the border. Enhancement of competition: Project promoter DTEK is the
largest private energy company in Ukraine and it has the potential to become a private energy monopoly through
privatization of all thermal power plants and some CHP plants. DTEK has already become a private monopoly in the
electricity export from Ukraine as it bought ‘Zakhidenergo’. DTEK is aiming to control the entire thermal energy sector,
including coal mining and processing, electricity generation, transmission and distribution. Project costs/change in socioeconomic welfare: This project has significant externalities, which do not appear to be taken into account by the proposed
project assessment methodology – mainly air and water pollution and adverse health effects for the local population. As the
CO2 price in the assessment methodology is low, it will also give an unrealisticly positive picture of the project. CO2
emissions: The current national carbon target assumes a doubling of GHG emissions in 2020 compared to 2012. This target
is a reflection of the national policy to increase the use of coal in the energy sector and runs contrary to the EU's attempts to
reduce GHG emissions. Ukrainian environmental groups are calling on government to stabilize GHG emissions at the
current level by 2020, while construction of new coal units will lead to a clear increase of GHG emissions. Facilitation of
RES: Construction of the new coal powered units means locking electricity production into coal for another 30-40 years.
Renewables face unfair competition due to significant subsidies currently going to coal mining in Ukraine (in 2010 EUR 730
million - around 2% of the state budget). Progress in implementation: the stated date of commissioning is 2019. This is
questionable, considering that as far as we are aware, not even a feasibility study has yet been carried out. In addition,
DTEK is a young company (established in 2002) and it has little to no experience in commissioning of new units. There has
been hardly any positive experience of constructing new power plant units in Ukraine since its independence in 1991. Thus
delays and complications seem highly likely.
Project Comment Form
Project number (ID and code) as indicated in the list:
ET009-1
22
Comments on the project:
The project consists of the ET009-2 and ET009-1 which together create a High Voltage DC electric line which will enable
export from Ukraine to Hungary. Burshtyn coal-powered thermal power plant (TPP) is the main energy source of the DTEK
Zakhidenergo company, that is going to be utilized with the construction of the proposed line. The 2000MW power plant is
one of the biggest air polluters in Ukraine (it was ranked 3rd biggest polluter in 2009). With hardly any other major energy
source on the Ukrainian side and an energy deficit on Hungarian side, it is clearly a one way export line. It is part of the
overall DTEK strategy to ‘export coal with electric wires’ publicly proclaimed by DTEK Director General Maksim Timchenko.
The planned reconstruction of the Burshtyn TPP assumes construction of a new coal-powered unit. This construction is
proposed as another project (EG025) on which we have commented above. Completing both the TPP upgrade and
transition line would mean locking consumption of the EU region into coal as an energy source for another 40-50 years.
Such a decision will contradict the sustainable development/CO2 criteria for the Energy Community priority projects, as well
as that of facilitation of RES, and will contribute to global climate change.
Project Comment Form
Project number (ID and code) as indicated in the list:
ET009-2
Comments on the project:
The project consists of the ET009-2 and ET009-1 which together create a High Voltage DC electric line which will enable
export from Ukraine to Hungary. Burshtyn coal-powered thermal power plant (TPP) is the main energy source of the DTEK
Zakhidenergo company, that is going to be utilized with the construction of the proposed line. The 2000MW power plant is
one of the biggest air polluters in Ukraine (it was ranked 3rd biggest polluter in 2009). With hardly any other major energy
source on the Ukrainian side and an energy deficit on Hungarian side, it is clearly a one way export line. It is part of the
overall DTEK strategy to ‘export coal with electric wires’ publicly proclaimed by DTEK Director General Maksim Timchenko.
The planned reconstruction of the Burshtyn TPP assumes construction of a new coal-powered unit. This construction is
proposed as another project (EG025) on which we have commented above. Completing both the TPP upgrade and
transition line would mean locking consumption of the EU region into coal as an energy source for another 40-50 years.
Such a decision will contradict the sustainable development/CO2 criteria for the Energy Community priority projects, as well
as that of facilitation of RES, and will contribute to global climate change.
Project Comment Form
Project number (ID and code) as indicated in the list:
ET017
Comments on the project:
400 kV OHL Pljevlja – Lastva This project is associated with the undersea cable project which is primarily aimed at
exporting electricity from Montenegro and other Balkan countries to Italy. Project costs/Change in socio-economic welfare:
The costs in terms of damage to biodiversity, areas of outstanding natural beauty and tourism are likely to be significant
from this project. This is partly because of the project itself and partly because of the generation capacity it is designed to
support. The planned transmission cable will go through Durmitor and Lovcen national parks (I zone of Durmitor NP and II
zone of Lovcen NP). The planned route of the transmission line passes through the protection zone of Durmitor NP – a
UNESCO World Heritage Site -, which requires strict protection under the Law for Nature Protection (Article 54). The same
law states that in a national park activities that threaten the authenticity of the park are prohibited (Article 39). The
Management Plan for Durmitor National Park, states that "Preservation, promotion and protection of nature, particular
values and immovable cultural assets in the protection zone defines the mode and degree of protection in which these
objects according to the Law for nature protection are strictly protected areas earmarked for scientific research organized,
controlled education, more strictly controlled public presentation, no activities that would in any way disturb the original
environment and immovable cultural property ". One of the categories under which the Durmitor and Tara have been
protected by UNESCO is their important visual and landscape impact. Landscape can be classified as highly sensitive non
tolerant to changes and is evaluated on the International level. The proposed route through the Durmitor and Tara River
canyon according to the ESIA will use the existing route of the 110 kV Zabljak - Pljevlja. However, the pillars of the existing
110 kV transmission line are approximately 20 and 25 metres high. To carry both lines (the existing 110 kV and and
proposed 400 kV) pylons of 40 to 50 metres height are planned. The height of trees in this area range from 12 to 15 meters
and therefore the transmission line will be visually obscured by trees from below, but will be very visible in the surrounding
landscape. In this way, it threatens one of the important criteria for which this area was declared as a highly important at the
international level. According to the ESIA the transmission line will pass through four Emerald areas and future Natura 2000
zones (Lovcen, Durmitor, rivers Komarnica and Tara). As well as the visual impact these will be subject to serious
disturbance during construction works. The planned route of the transmission line would also pass close to Lakes Slano and
Krupac – Important Bird Areas which will also be Natura 2000 areas in the future. The territory on which it is planned to build
a substation and a converter plant is a habitat (Juncetalia maritime) which is found in Annex 1 of the European Directive on
Habitats, which indicates its vulnerability not only in Montenegro but in all of Europe. Alternative routings: The envisaged
transmission line pathway does not make use of existing and envisaged infrastructure corridors: The DSP provides
unconvincing arguments in favour of the corridor path (the Bar – Boljare motorway corridor is not used because it crosses
the Skadar Lake National Park, but the proposed corridor - that crosses both Lovćen and the Durmitor and the Tara River
gorge was chosen instead). Moreover, the Risan – Žabljak highway corridor is ruled out because “400 kV transmission may
not follow a highway corridor because it is conditioned by the location of the converter facility and the targeted point of Cevo
23
defined by the ToR and the needs of the transmission grid”. This is unacceptable since it practically puts the terms of
reference for the DSP above the Spatial Plan of Montenegro. In addition, there would be severe impacts from the
associated generation facilities if they are ever built. The DSP lists the future power sources in Montenegro that this
transmission line would serve: Moraca HPPs, Komarnica HPP, Berane TPP, a wind power plant at Krnovo, as well as a
group of small hydros in the municipality of Šavnik. It also mentions Buk Bijela HPP on the River Drina, an older version of
which has already been halted once on the Montenegro level. Regarding economic benefits, according to preliminary
studies it is expected that the revenues of EPCG, the Montenegrin electricity company, would increase in the first year by
EUR 5 to 6 million, and during full use by EUR 10 to 11 million, promising that this revenue would be used to offset
transmission costs payable by Montenegrin consumers. However, there is no mention that this revenue is accrued by a
company in mixed ownership which at some point may become a fully private one, and that there is thus no guarantee at all
that there will be public benefits from this additional income. Security of supply: It appears that this project will benefit Italy's
security of supply more than Montenegro's, if indeed the associated generation infrastructure is constructed. Problems may
be caused by contracts requiring the Italian market to be supplied with electricity even at times when that electricity may be
needed in the Balkan region.The Detailed Spatial Plan for the project leaves open the issue whether the future power line
will be part of the Montenegrin transmission system: Apart from not being aligned with the power and transmission grid
facilities envisaged by the Spatial Plan of Montenegro, for the whole length of the transmission line there is only one
substation foreseen where power would be transferred to the domestic 220 kV, 110 kV or 35 kV grid. This could lead to the
conclusion that the whole transmission line is envisaged only for the transit of power from Montenegro, Serbia and Bosnia
and Herzegovina to Italy, in which case it does not constitute an improvement of the domestic transmission grid. The
documents that exist so far for this project, including the Detailed Spatial Plan (DSP) for the transmission line and related
undersea cable and the associated Strategic Environmental Assessment, fail to address the question of whether and why,
energy and economy wise, Montenegro needs the envisaged transmission line. A serious analysis of alternative solutions is
hindered by the lack of clear analysis of Montenegro's needs and the extent to which Montenegro does or does not have an
energy deficit or surplus. The Draft DSP for the transmission and the undersea line fail to refer to the excerpt from the
Energy Strategy of Montenegro that there is “a gap of many years in developing the country's own energy sources, a highly
pronounced import dependence for more than 1/3 of energy needs, a large share of untapped and energy quality potential”
and explain why building an undersea cable is considered a priority to contribute to solving these issues. It also fails to
consider different scenarios regarding the Kombinat Aluminijuma Podgorica (KAP), which had privileged power delivery of
around 1/3 of Montenegro's total energy generation until 2012. As of this year the plant owner is obliged to procure the
power in the open market, and its future is highly uncertain, so Montenegro may not have a large energy deficit issue for
domestic consumption in the medium term. These questions need to be cleared up before deciding on whether export is
feasible and/or desirable. Enhancement of competition: This project does not contribute to competition, and indeed
perpetuates the provision of large swathes of the energy system to single operators without competition or even in this case
a tender process. The project promoter is Crnogorski Elektroprenosni Sistem (CGES), the electricity transmission system
operator of Montenengro, which is partly owned by Italian company Terna. Terna was able to gain shares in transmission
company Crnogorski elektroprenos (CGES), without a tender at all, due to a law passed especially for the undersea cable.
An agreement between the Montenegrin Ministry of economy
Project Comment Form
Project number (ID and code) as indicated in the list:
ET023
Comments on the project:
The project description of DTEK Zakhidenergo's plan to complete the High Voltage DC transmission line from Ukraine to
Poland clearly states that it will allow ‘all capacities of Dobrotvir Thermal Power Plant (TPP) to be exported’. Dobrotvir TPP
is a coal-powered 600MW power plant. Completion of the transmission line is related to the EG026 project to complete new
units at Dobrotvir TPP. Construction of the line and new coal-powered units is a part of the overall DTEK strategy to ‘export
coal with electric wires’ publicly proclaimed by DTEK Director General Maksim Timchenko. Completing both the TPP
upgrade and transition line would mean locking consumption of the EU region to coal as an energy source for another 40-50
years. Such a decision will contradict the sustainable development/CO2/facilitation of renewables criteria for the Energy
Community priority projects, and will contribute to global climate change
Your Details
First name:
Denis
Last name:
Žiško
Name of organization:
Centar za ekologiju i energiju
Job title:
expert associate
Address:
M. i Ž. Crnogorčevića 8
24
Postcode:
75000
City:
Tuzla
Country:
Bosnia and Herzegovina
Email: *
[email protected]
Phone No:
++38735249310
General Comments
You are invited to provide your general comments in this section
In our view, proposed PECI promote generation, instead of focusing on energy efficiency and energy saving, which would
decrease the demand for energy generation. According to Peter Johansen, a Senior Energy Specialist at World Bank, “one euro
invested in energy efficiency helps avoid an investment of 2,2 euro in generation”. Bosnia and Herzegovina does not have a
development strategy or energy strategy on state level and also both entities are lacking development strategies, so
consequently nominated generation projects should not be listed as PECI. The generation projects which are nominated are
based on an unstable and unpredictable energy source (hydro). The available data regarding the hydrology is outdated, and the
influence of climate change on the hydrology is not taken into account. According to the Initial National Communication of BiH
under the UNFCCC it is expected that water availability will be reduced and seasonal and territorial distribution of precipitation
changed. The proposed projects focus only on using the hydro potential for electricity generation, completely overlooking
possibilities that BiH has in energy generation from solar, wind and biomass sources. Regarding Methodology and criteria for
identification of projects of Energy Community interest, we have few comments. I. Contribution to the implementation of Regional
Energy Strategy’s objectives NGOs from across the region and the four largest groups in the EU Parliament have asked for the
Energy Community Regional Energy Strategy (ECRES) to be withdrawn on the basis that it is the current Regional Energy
Strategy conflicts with 2030 targets as in all scenarios, even the so-called 'sustainable' scenario, increases rather than decreases
in greenhouse gas emissions from the energy sector are expected. Since all the proposed PECIs derive their logic from this
flawed strategy, supporting electricity generation projects that have not been screened for their impact on a country's ability to
meet 2030 greenhouse gas targets and Regarding Methodology and criteria for identification of projects of Energy Community
interest, we have few comments. III. Security of supply - Through diversification of supply sources, supplying counterparts and
routes, a) Since all PECI generation projects for BiH are large hydro power plants (HPPs), and having in mind that already more
than 50% of electricity is produced in HPPs, we cannot understand how proposed projects are passing these criteria. b) Since the
regional climate model RCM-SEEVCCC predicts significant drops in precipitation in the coming decades hydro needs to be very
carefully assessed as there is now consensus that we are heading for a 4 degree rises in global temperature, while large parts of
BiH with even higher changes than average global and regional forecasts. IV. Contribution to sustainable energy development Facilitation of the development of renewable energy sources It is already found by numerous respectable studies that hydro
power plants can have large negative impacts, both on environment and local communities, if not carefully planned and
developed. Having in mind existing practices in BiH, we are very concerned with its potential outcomes. - Length of project
realization If these criteria were taken into account we believe that none of generation projects from BiH would be awarded with
PECI status. Instead, we believe there should be projects of energy efficiency and of new renewable energy sources, which have
much shorter project realization cycle
You are invited to provide your general comments in this section
In our view, proposed PECI promote generation, instead of focusing on energy efficiency and energy saving, which would
decrease the demand for energy generation. According to Peter Johansen, a Senior Energy Specialist at World Bank, “one euro
invested in energy efficiency helps avoid an investment of 2,2 euro in generation”. Bosnia and Herzegovina does not have a
development strategy or energy strategy on state level and also both entities are lacking development strategies, so
consequently nominated generation projects should not be listed as PECI. The generation projects which are nominated are
based on an unstable and unpredictable energy source (hydro). The available data regarding the hydrology is outdated, and the
influence of climate change on the hydrology is not taken into account. According to the Initial National Communication of BiH
under the UNFCCC it is expected that water availability will be reduced and seasonal and territorial distribution of precipitation
changed. The proposed projects focus only on using the hydro potential for electricity generation, completely overlooking
possibilities that BiH has in energy generation from solar, wind and biomass sources. Regarding Methodology and criteria for
identification of projects of Energy Community interest, we have few comments. I. Contribution to the implementation of Regional
Energy Strategy’s objectives NGOs from across the region and the four largest groups in the EU Parliament have asked for the
Energy Community Regional Energy Strategy (ECRES) to be withdrawn on the basis that it is the current Regional Energy
Strategy conflicts with 2030 targets as in all scenarios, even the so-called 'sustainable' scenario, increases rather than decreases
in greenhouse gas emissions from the energy sector are expected. Since all the proposed PECIs derive their logic from this
flawed strategy, supporting electricity generation projects that have not been screened for their impact on a country's ability to
meet 2030 greenhouse gas targets and Regarding Methodology and criteria for identification of projects of Energy Community
interest, we have few comments. III. Security of supply - Through diversification of supply sources, supplying counterparts and
routes, a) Since all PECI generation projects for BiH are large hydro power plants (HPPs), and having in mind that already more
than 50% of electricity is produced in HPPs, we cannot understand how proposed projects are passing these criteria. b) Since the
regional climate model RCM-SEEVCCC predicts significant drops in precipitation in the coming decades hydro needs to be very
carefully assessed as there is now consensus that we are heading for a 4 degree rises in global temperature, while large parts of
BiH with even higher changes than average global and regional forecasts. IV. Contribution to sustainable energy development -
25
Facilitation of the development of renewable energy sources It is already found by numerous respectable studies that hydro
power plants can have large negative impacts, both on environment and local communities, if not carefully planned and
developed. Having in mind existing practices in BiH, we are very concerned with its potential outcomes. - Length of project
realization If these criteria were taken into account we believe that none of generation projects from BiH would be awarded with
PECI status. Instead, we believe there should be projects of energy efficiency and of new renewable energy sources, which have
much shorter project realization cycle
Project Comment Form
Project number (ID and code) as indicated in the list:
EG002
Comments on the project:
Hydro Power System of Upper Drina - HPP Buk Bijela, HPP Foča, HPP Paunci, HPP Sutjeska do not fulfill criteria for PECI
projects. Even though those four HPPs are grouped in one hydro power system, there is no EIA for whole power system,
but each HPP is assessed separately without cross-references (and very likely by different EIA developing companies), that
we consider as serious deficiency of the project. Also, there is no Strategic Environmental Assessment for all HPPs
(planned and operating) on whole Drina River, including Lower Drina (EG005) and Middle Drina HPPs (EG006). Having in
mind that Bosnia and Herzegovina did not complete list of potential Natura 2000 areas, and that Drina River watershed is
very rich in biodiversity and having large natural value (at the moment study for National Park Drina is drafted), SEA is of
curtail importance. Up to date, only EIAs for two HPPs (Buk Bijela and Foča) were done. Responsible Ministry of
Environment did not even publish information on public consultation on their web site. Many NGOs from BiH and
Montenegro are against Upper Drina project. All planned HPPs on Drina River, including Lower Drina (EG005) and Middle
Drina HPPs (EG006), are subject of political dispute between state government and entity government of Republic of
Srpska, for question whether Republic of Srpska can decide on use of waters of Drina River, which is at the same time state
and entity border. Moreover, Government of Republic of Srpska during EIA procedure did not inform the state government
(responsible for ESPOO convention) or the government of Montenegro, which is obligatory according to ESPOO
convention, considering HPP Buk Bijela, whose accumulation is reaching border with Montenegro. On Montenegro side of
the border, Tara River begins with its canyon that is protected as a part of Durmitor National Park and UNESCO MAB site,
and is a tentative UNESCO World Heritage Site.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG003
Comments on the project:
Hydro Power Plant Dabar is highly controversial project that should not be on PECI list. There are numerous reasons, and
amongst others: HPP Dabar is part of larger project Upper Horizons that enable transfer of waters from three periodically
flooded karst fields (Nevesinjsko, Dabarsko and Fatnicko) through channels and tunnels into Trebisnjica River. Before this
project, waters from these fields were naturally flowing underground into Trebisnjica River, but also Neretva River.
Environmental Impact Assessment (EIA) was never done for project Upper Horizons, even though potential negative
impacts on environment are enormous. EIA for HPP did not take into account potential social and environment impacts of
project Upper Horizons. During public consultations on EIA for HPP Dabar, citizens and local NGOs (but also international
NGOs, such as WWF) submitted numerous complaints on EIA. Also, Federal Ministry of Environment and Tourism (FMET)
submitted comments on EIA. Most important comments were not considered and EIA was not amended upon them. In
September 2012 FMET initiated legal action against Ministry for Spatial Planning, Civil Engineering and Ecology of Republic
of Srpska, which is responsible for EIA procedure. Legal process is act6ive at the moment. If promoted as PECI, this project
can further contribute to political tensions between entity governments in Bosnia and Herzegovina. Complaints of concerned
public were not taken into account either. Most severe potential environmental impact would be in changed distribution of
water between two river basins and decrease in underground water flow to Neretva River. It would affect Buna river springs
(tentative UNESCO site), Hutovo blato (Ramsar site) and delta ofNeretva River (important wetland ecosystem), but also
other aquatic ecosystems in lower Neretva area. HPP Dabar would also have serious social impact, with its distortion of
water supply in Bregava River region, and threatening developed agriculture production in Neretva River delta (in Croatia).
Even though impact on Neretva delta region is very likely provisions of ESPOO convention were not applied. Having in mind
that one of selection criteria for PECI projects is “Experience of project promoter”, we have to stress out that promoters of
HPP Dabar, Government of Republic of Srpska and Power Company of Republic of Srpska did not implement any project of
similar size in past 30 years. Also, having in mind independent reports on high corruption in institutions, we believe that HPP
Dabar, if kept on PECI list, could become huge embarrassment for Energy Community Secretariat.
Comments on the project:
Hydro Power Plant Dabar is highly controversial project that should not be on PECI list. There are numerous reasons, and
amongst others: HPP Dabar is part of larger project Upper Horizons that enable transfer of waters from three periodically
flooded karst fields (Nevesinjsko, Dabarsko and Fatnicko) through channels and tunnels into Trebisnjica River. Before this
project, waters from these fields were naturally flowing underground into Trebisnjica River, but also Neretva River.
Environmental Impact Assessment (EIA) was never done for project Upper Horizons, even though potential negative
impacts on environment are enormous. EIA for HPP did not take into account potential social and environment impacts of
project Upper Horizons. During public consultations on EIA for HPP Dabar, citizens and local NGOs (but also international
NGOs, such as WWF) submitted numerous complaints on EIA. Also, Federal Ministry of Environment and Tourism (FMET)
26
submitted comments on EIA. Most important comments were not considered and EIA was not amended upon them. In
September 2012 FMET initiated legal action against Ministry for Spatial Planning, Civil Engineering and Ecology of Republic
of Srpska, which is responsible for EIA procedure. Legal process is act6ive at the moment. If promoted as PECI, this project
can further contribute to political tensions between entity governments in Bosnia and Herzegovina. Complaints of concerned
public were not taken into account either. Most severe potential environmental impact would be in changed distribution of
water between two river basins and decrease in underground water flow to Neretva River. It would affect Buna river springs
(tentative UNESCO site), Hutovo blato (Ramsar site) and delta ofNeretva River (important wetland ecosystem), but also
other aquatic ecosystems in lower Neretva area. HPP Dabar would also have serious social impact, with its distortion of
water supply in Bregava River region, and threatening developed agriculture production in Neretva River delta (in Croatia).
Even though impact on Neretva delta region is very likely provisions of ESPOO convention were not applied. Having in mind
that one of selection criteria for PECI projects is “Experience of project promoter”, we have to stress out that promoters of
HPP Dabar, Government of Republic of Srpska and Power Company of Republic of Srpska did not implement any project of
similar size in past 30 years. Also, having in mind independent reports on high corruption in institutions, we believe that HPP
Dabar, if kept on PECI list, could become huge embarrassment for Energy Community Secretariat.
Your Details
First name:
Ines
Last name:
Mrdovic
Name of organization:
MANS (The Network for Affirmation of NGO Sector)
Job title:
Investigate Centre Coordinator
Address:
Dalmatinska 188
City:
Podgorica
Country:
Montenegro
Email: *
[email protected]
General Comments
You are invited to provide your general comments in this section
In principle, as a prospective EU Member we are concerned that Montenegro and other ETC countries, should become compliant
with EU Directives, Regulations, and Strategies in a timely manner. In the case of the energy sector we regard the 20/20/20
Targets and the 2050 Road Map as strategic goals required of all member states and since energy projects take many years to
come “on-line” and have a life span of at least 30 or 40 years we should not be investing in projects now which will have to be
reversed in the future or lead to carbon lock in which would be expensive to reverse in the medium term. Our specific concerns in
relation to this process: •If EU PCI criteria are used to select PECIs then the kind of projects which are eligible as PECIs need to
be similar to the proposed PCI projects, ie. transmission and storage projects, not generation Electricity generation is a large
source of greenhouse gas emissions in almost all the Energy Community Parties. Massive changes need to take place in the
region's energy sector in the next few decades. In the coming months an important new development will be taking place: the EU
is expected to approve binding targets for greenhouse gas emissions reductions by 2030. If the Energy Community countries are
to join the EU they need to start now with planning energy sectors aiming towards decarburization and massive greenhouse gas
emissions reductions, due to the long life of energy infrastructure, which can lock in carbon emissions. In smaller economies like
many of the Energy Community Parties, one power plant can make a massive difference to the energy sector of the country and
a country's CO2 emissions. Indeed, it can mean the difference between meeting greenhouse gas reduction targets and not
meeting them. The current Regional Energy Strategy conflicts with 2030 targets as in all scenarios, even the so-called
'sustainable' scenario, increases rather than decreases in greenhouse gas emissions from the energy sector are expected. Since
all the proposed PECIs derive their logic from this flawed strategy, supporting electricity generation projects that have not been
screened for their impact on a country's ability to meet 2030 greenhouse gas targets and the EU's 2050 decarburization policy
risks supporting investments which will either hinder the implementation of EU policy or have to be closed before the end of their
lifetimes. Since the PECI generation projects do not conform to the EU PCI model, and since they are based on a flawed
Regional Energy Strategy that has been criticized not only by NGOs but by four groups in the European Parliament, the
'generation' strand of the PECI should be completely halted until such time as ALL the defects above are revised. Additionally, for
future selection of PECIs, demand-side energy efficiency projects need to be made eligible in order to push forward investments
into this crucial area, for which the whole region has vast potential and a huge need, given the increasing levels of energy
poverty. While it may not be obvious that such projects are of a regional nature, projects which make use of the cost-cutting
potential of carrying out the same activity in several areas could and should be developed. General comments on energy
situation in Montenegro: - The PECI projects proposed by the Government’s energy policy which is to increase Montenegro’s
27
energy independence. However, this aspect of Government Policy needs to be balanced against other equally important
objectives which include maintaining the environment and quality of life of all citizens. -The project of underwater/submarine cable
between Montenegro and Italy is not required for citizens of Montenegro and must be halted. - No connection with future demand
and energy balances - The current losses and inefficient use of energy in Montenegro are largely responsible for the existing
deficit in supply over demand.The potential savings in generation, transmission and use could be at least 20% while energy
savings which do not require significant investment are estimated at 13% or 4.4 Peta Joules. The combined losses of 850 GWh
could be substantially reduced, but Montenegrin governemnt is not specific in setting targets for reduction and does not make it
clear whether such improvements have been factored into the modelling of future patterns of supply and demand. Up to 84MW
(270 GWh) representing 6.3% of the electricity requirement in 2012 can be achieved through rehabilitating existing power plants.
- It would be useful to evaluate the impact of say halving KAP’s demand and assuming KAP buys all its forecast demand from
outside Montenegro on the strategy and end user tariffs. - There is no real discussion of the future of Alumni plant Podgorica KAP and its impact on future energy requirements. Electricity consumption by KAP accounts for about 50% (44 %) of all demand
in Montenegro and any substantial change in this demand would have significant impact on the energy sector. KAP energy
supplying contract with EPCG had expired in January 2013. (October 2012) due to big depths this industry has, so all future
project and exports must include analyse with and without KAP operationalization.
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
Fast-tracking of PECIs may be incompatible with ensuring the proper application of the EU environmental "Acquis” and reduce
transparency and accountability The selected PECI projects are expected to be “fast tracked” in terms of approvals and will be
earmarked for support with EU funds. We would like to ask you for details about what exactly this fast-tracking will and will not
mean in practice? The region's track record for the application of environmental, planning, and procurement processes is wholly
inadequate (see EU Progress Reports), and we are concerned that fast-tracking may further weaken these processes if not very
carefully targeted. It should not be assumed that the involvement of the European public banks would ensure against such flaws,
as there are currently several on-going investigations by the EBRD's and EIB's complaint mechanisms regarding such issues in
projects in the Energy Community region, as well as an on-going OLAF investigation against the EIB regarding Sostanj 6.
Although the Energy Community parties have adopted EU Environmental Impact Assessment legislation, the legislation on nature
protection (eg. the Bird and Habitats Directives, Water Framework Directive) is far behind in its implementation and is not
required by the Energy Community. Yet energy infrastructure is being planned in areas which would have been better protected
had they been in the EU (eg. Ombla hydropower plant, Croatia, Boskov Most hydro plant, Macedonia), thus leading to double
standards. If PECI projects are to be given a stamp of approval by the ECTS – an EC funded institution – then they should also
be subject to best practices in transparency and accountability. Also the EU Climate Commissioner Connie Hedegaard has
recently urged the EBRD, the EIB and the World Bank to phase out lending to fossil fuels. Commissioner Hedegaard stated that
“she is particularly keen to see three international financial institutions – the European Investment Bank, the European Bank for
Reconstruction and Development, and the World Bank – join with their EU and OECD partners to take a lead role in eliminating
public support for fossil fuels. Together, these three institutions lend more than €130 billion ($168 billion) annually for projects in
Europe and beyond, and maintain a strong advisory role in beneficiary countries. This year provides an especially important
opportunity to use this potential for action." We strongly support this proposal and believe that the ECTS as an European
Commission funded institution should also apply this logic; especially for perspective member states
Your Details
Title:
Mr
First name:
Boris
Last name:
Jokic
Name of organization:
EKO ELEMENT
Job title:
Executive Director
Address:
Wagnerova 13
Postcode:
70230
City:
Bugojno
Country:
Bosnia and Herzegovina
Email: *
[email protected]
Phone No:
00 387 61 490 611
28
General Comments
You are invited to provide your general comments in this section
In our view, proposed PECI promote generation, instead of focusing on energy efficiency and energy saving, which would
decrease the demand for energy generation. According to Peter Johansen, a Senior Energy Specialist at World Bank, “one euro
invested in energy efficiency helps avoid an investment of 2,2 euro in generation”. Bosnia and Herzegovina does not have
development strategy nor energy strategy on state level, but also both entities are lacking development strategies, and therefore
nominated generation projects should not be listed as PECI. The generation projects which are nominated are based on an
unstable and unpredictable energy source (hydro). The available data regarding the hydrology is outdated, and also, the
influence of climate change on the hydrology is not taken into account. According to the Initial National Communication of BiH
under the UNFCCC it is expected that water availability will be reduced, and seasonal and territorial distribution of precipitation
changed. The proposed projects focus only on using the hydro potential for electricity generation, completely overlooking
possibilities that BiH has in energy generation from solar, wind and biomass sources. Regarding Methodology and criteria for
identification of projects of Energy Community interest, we have few comments. I. Contribution to the implementation of Regional
Energy Strategy’s objectives NGOs from across the region and the four largest groups in the EU Parliament have asked for the
Energy Community Regional Energy Strategy (ECRES) to be withdrawn on the basis that it is the current Regional Energy
Strategy conflicts with 2030 targets as in all scenarios, even the so-called 'sustainable' scenario, increases rather than decreases
in greenhouse gas emissions from the energy sector are expected. Since all the proposed PECIs derive their logic from this
flawed strategy, supporting electricity generation projects that have not been screened for their impact on a country's ability to
meet 2030 greenhouse gas targets and Regarding Methodology and criteria for identification of projects of Energy Community
interest, we have few comments. III. Security of supply - Through diversification of supply sources, supplying counterparts and
routes, a) Since all PECI generation projects for BiH are large hydro power plants (HPPs), and having in mind that already more
than 50% of electricity is produced in HPPs, we can not understand how proposed projects are passing this criteria. b) Since the
regional climate model RCM-SEEVCCC predicts significant drops in precipitation in the coming decades hydro needs to be very
carefully assessed as there is now consensus that we are heading for a 4 degree rises in global temperature, while large parts of
BiH with even higher higher changes than average global and regional forecasts. IV. Contribution to sustainable energy
development - Facilitation of the development of renewable energy sources It is already found by numerous respectable studies
that hydro power plants can have large negative impacts, both on environment and local communities, if not carefully planned
and developed. Having in mind existing practices in BiH, we are very concerned with it's potential outcomes. - Length of project
realization If this criteria are taken into account we believe that none of generation projects from BiH would not be awarded with
PECI status. Instead, we believe there should be projects of energy efficiency of new renewable energy sources, which have
much shorter project realization cycle.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG002
Comments on the project:
Hydro Power System of Upper Drina - HPP Buk Bijela, HPP Foča, HPP Paunci, HPP Sutjeska do not fulfill criteria for PECI
projects. Even though those four HPPs are grouped in one hydro power system, there is no EIA for whole power system,
but each HPP is assessed separately without cross-references (and very likely by different EIA developing companies), that
we consider as serious deficiency of the project. Also, there is no Strategic Environmental Assessment for all HPPs
(planned and operating) on whole Drina River, including Lower Drina (EG005) and Middle Drina HPPs (EG006). Having in
mind that Bosnia and Herzegovina did not complete list of potential Natura 2000 areas, and that Drina River watershed is
very rich in biodiversity and having large natural value (at the moment study for National Park Drina is drafted), SEA is of
crutial importance. Up to date, only EIAs for two HPPs (Buk Bijela and Foča) were done. Responsible Ministry of
Environment did not even publish information on public consultation on their web site. Many NGOs from BiH and
Montenegro are against Upper Drina project. All planned HPPs on Drina River, including Lower Drina (EG005) and Middle
Drina HPPs (EG006), are subject of political dispute between state government and entity government of Republic of
Srpska, for question whether Republic of Srpska can decide on use of waters of Drina River, that is in same time state and
entity border. Moreover, Government of Republic of Srpska during EIA procedure did not inform state government
(responsible for ESPOO convention) nor government of Montenegro, which is obligatory according to ESPOO convention,
considering HPP Buk Bijela, whose accumulation is reaching border with Montenegro. On Montenegro side of border begins
Tara River with its canyon that is protected as a part of Durmitor National Park and UNESCO MAB site, and is a tentative
UNESCO World Heritage Site.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG003
Comments on the project:
Hydro Power Plant Dabar is highly controversial project, that should not be on PECI list. There are numerous reasons, and
amongst others: HPP Dabar is part of larger project Upper Horizons, that enable transfer of waters from three periodically
flooded karst fields (Nevesinjsko, Dabarsko and Fatnicko) through channels and tunnels into Trebisnjica River. Before this
29
project, waters from these fields were naturally flowing underground into Trebisnjica River, but also Neretva River.
Environmental Impact Assessment (EIA) was never done for project Upper Horizons, even though potential negative impact
on environment are enormous. EIA for HPP did not take into account potential social and environment impacts of project
Upper Horizons. During public consultations on EIA for HPP Dabar, citizens and local NGOs (but also international NGOs,
such as WWF) submitted numerous complaints on EIA. Also, Federal Ministry of Environment and Tourism (FMET)
submitted comments on EIA. Most important comments were not considered and EIA was not amended upon them. In
September 2012 FMET initiated legal action against Ministry for Spatial Planning, Civil Engineering and Ecology of Republic
of Srpska, which is responsible for EIA procedure. Legal process is act6ive at the moment. If promoted as PECI, this project
can further contribute to political tensions between entity governments in Bosnia and Herzegovina. Complaints of concerned
public were not taken into account either. Most severe potential environmental impact would be in changed distribution of
water between two river basins and decrease in underground water flow to Neretva River. It would affect Buna river springs
(tentative UNESCO site), Hutovo blato (Ramsar site) and delta of Neretva River (important wetland ecosystem), but also
other aquatic ecosystems in lower Neretva area. HPP Dabar would also have serious social impact, with its distortion of
water supply in Bregava River region, and threatening developed agriculture production in Neretva River delta (in Croatia).
Even though impact on Neretva delta region is very likely provisions of ESPOO convention were not applied. Having in mind
that one of selection criteria for PECI projects is “Experience of project promoter”, we have to stress out that promoters of
HPP Dabar, Government of Republic of Srpska and Power Company of Republic of Srpska did not implement any project of
similar size in past 30 years. Also, having in mind independent reports on high corruption in institutions, we believe that HPP
Dabar, if kept on PECI list, could become huge embarrassment for Energy Community Secretariat.
Your Details
First name:
Miodrag
Last name:
Dakic
Name of organization:
Center for Environment
Job title:
President
Address:
Cara Lazara 24
Postcode:
78000
City:
Banja Luka
Country:
Bosnia and Herzegovina
Email: *
[email protected]
Phone No:
+387 51 433 142
General Comments
You are invited to provide your general comments in this section
In our view, proposed PECI promote generation, instead of focusing on energy efficiency and energy saving, which would
decrease the demand for energy generation. According to Peter Johansen, a Senior Energy Specialist at World Bank, “one euro
invested in energy efficiency helps avoid an investment of 2,2 euro in generation”. Bosnia and Herzegovina does not have
development strategy nor energy strategy on state level, but also both entities are lacking development strategies, and therefore
nominated generation projects should not be listed as PECI. The generation projects which are nominated are based on an
unstable and unpredictable energy source (hydro). The available data regarding the hydrology is outdated, and also, the
influence of climate change on the hydrology is not taken into account. According to the Initial National Communication of BiH
under the UNFCCC it is expected that water availability will be reduced, and seasonal and territorial distribution of precipitation
changed. The proposed projects focus only on using the hydro potential for electricity generation, completely overlooking
possibilities that BiH has in energy generation from solar, wind and biomass sources. Regarding Methodology and criteria for
identification of projects of Energy Community interest, we have few comments. I. Contribution to the implementation of Regional
Energy Strategy’s objectives NGOs from across the region and the four largest groups in the EU Parliament have asked for the
Energy Community Regional Energy Strategy (ECRES) to be withdrawn on the basis that it is the current Regional Energy
Strategy conflicts with 2030 targets as in all scenarios, even the so-called 'sustainable' scenario, increases rather than decreases
in greenhouse gas emissions from the energy sector are expected. Since all the proposed PECIs derive their logic from this
flawed strategy, supporting electricity generation projects that have not been screened for their impact on a country's ability to
meet 2030 greenhouse gas targets and Regarding Methodology and criteria for identification of projects of Energy Community
interest, we have few comments. III. Security of supply - Through diversification of supply sources, supplying counterparts and
30
routes, a) Since all PECI generation projects for BiH are large hydro power plants (HPPs), and having in mind that already more
than 50% of electricity is produced in HPPs, we can not understand how proposed projects are passing this criteria. b) Since the
regional climate model RCM-SEEVCCC predicts significant drops in precipitation in the coming decades hydro needs to be very
carefully assessed as there is now consensus that we are heading for a 4 degree rises in global temperature, while large parts of
BiH with even higher higher changes than average global and regional forecasts. IV. Contribution to sustainable energy
development - Facilitation of the development of renewable energy sources It is already found by numerous respectable studies
that hydro power plants can have large negative impacts, both on environment and local communities, if not carefully planned
and developed. Having in mind existing practices in BiH, we are very concerned with it's potential outcomes. - Length of project
realization If this criteria are taken into account we believe that none of generation projects from BiH would not be awarded with
PECI status. Instead, we believe there should be projects of energy efficiency of new renewable energy sources, which have
much shorter project realization cycle.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG002
Comments on the project:
Hydro Power System of Upper Drina - HPP Buk Bijela, HPP Foča, HPP Paunci, HPP Sutjeska do not fulfill criteria for PECI
projects. Even though those four HPPs are grouped in one hydro power system, there is no EIA for whole power system,
but each HPP is assessed separately without cross-references (and very likely by different EIA developing companies), that
we consider as serious deficiency of the project. Also, there is no Strategic Environmental Assessment for all HPPs
(planned and operating) on whole Drina River, including Lower Drina (EG005) and Middle Drina HPPs (EG006). Having in
mind that Bosnia and Herzegovina did not complete list of potential Natura 2000 areas, and that Drina River watershed is
very rich in biodiversity and having large natural value (at the moment study for National Park Drina is drafted), SEA is of
crutial importance. Up to date, only EIAs for two HPPs (Buk Bijela and Foča) were done. Responsible Ministry of
Environment did not even publish information on public consultation on their web site. Many NGOs from BiH and
Montenegro are against Upper Drina project. All planned HPPs on Drina River, including Lower Drina (EG005) and Middle
Drina HPPs (EG006), are subject of political dispute between state government and entity government of Republic of
Srpska, for question whether Republic of Srpska can decide on use of waters of Drina River, that is in same time state and
entity border. Moreover, Government of Republic of Srpska during EIA procedure did not inform state government
(responsible for ESPOO convention) nor government of Montenegro, which is obligatory according to ESPOO convention,
considering HPP Buk Bijela, whose accumulation is reaching border with Montenegro. On Montenegro side of border begins
Tara River with its canyon that is protected as a part of Durmitor National Park and UNESCO MAB site, and is a tentative
UNESCO World Heritage Site.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG003
Comments on the project:
Hydro Power Plant Dabar is highly controversial project, that should not be on PECI list. There are numerous reasons, and
amongst others: HPP Dabar is part of larger project Upper Horizons, that enable transfer of waters from three periodically
flooded karst fields (Nevesinjsko, Dabarsko and Fatnicko) through channels and tunnels into Trebisnjica River. Before this
project, waters from these fields were naturally flowing underground into Trebisnjica River, but also Neretva River.
Environmental Impact Assessment (EIA) was never done for project Upper Horizons, even though potential negative impact
on environment are enormous. EIA for HPP did not take into account potential social and environment impacts of project
Upper Horizons. During public consultations on EIA for HPP Dabar, citizens and local NGOs (but also international NGOs,
such as WWF) submitted numerous complaints on EIA. Also, Federal Ministry of Environment and Tourism (FMET)
submitted comments on EIA. Most important comments were not considered and EIA was not amended upon them. In
September 2012 FMET initiated legal action against Ministry for Spatial Planning, Civil Engineering and Ecology of Republic
of Srpska, which is responsible for EIA procedure. Legal process is act6ive at the moment. If promoted as PECI, this project
can further contribute to political tensions between entity governments in Bosnia and Herzegovina. Complaints of concerned
public were not taken into account either. Most severe potential environmental impact would be in changed distribution of
water between two river basins and decrease in underground water flow to Neretva River. It would affect Buna river springs
(tentative UNESCO site), Hutovo blato (Ramsar site) and delta of Neretva River (important wetland ecosystem), but also
other aquatic ecosystems in lower Neretva area. HPP Dabar would also have serious social impact, with its distortion of
water supply in Bregava River region, and threatening developed agriculture production in Neretva River delta (in Croatia).
Even though impact on Neretva delta region is very likely provisions of ESPOO convention were not applied. Having in mind
that one of selection criteria for PECI projects is “Experience of project promoter”, we have to stress out that promoters of
HPP Dabar, Government of Republic of Srpska and Power Company of Republic of Srpska did not implement any project of
similar size in past 30 years. Also, having in mind independent reports on high corruption in institutions, we believe that HPP
Dabar, if kept on PECI list, could become huge embarrassment for Energy Community Secretariat.
31
Your Details
Title:
PhD
First name:
Zamir
Last name:
Dedej
Name of organization:
Institute of Nature Conservation in Albania (INCA)
Job title:
President
Address:
Rr. Islam Alla, Pall. IVEA, Kati I
City:
Tirana
Country:
Albania
Email: *
[email protected]
Phone No:
+355 4 2231437
General Comments
You are invited to provide your general comments in this section
Our organisation is working in Albania for the sustainable hydropawer in the country, and suppport the mission and the statment
made by WWF in this regards, but also the position of our partners in other countries part of the network for the sustainable
energy production and conservation of nature resources. On the basis of the studies made and the information Albania is one of
those countries in the region that is able to produce domestically all renewables needed. On the other hand we beleive that a
transparent planning process and nature resources/biodiversity protection guided mechanism should lead the energy production
industry. Energy saving and efficiency are prerequisites to achieve a renewable energy future. In Albania is calculating that
aboput 40% of the production is lost and the NGOs network suport working towords the energy efficency rather that building new
hydropawers. INCA support the position of WWF concerning the sustainability principles for investment in sustainable
hydropower. That's the only way to achieve the goals of the energy secotr and conserve/protected in a proper way the
biodiversity and nature value of the country.
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
In this regard we still share the same opinion with our partners and WWF concerning general and specific approach. Our main
proposal, presented also to the DG Environment representatives in their recent mission in Albania, was the implementation of the
EU standards and related Directives in the HPP construction in Albania and also a general strategic assessment concerning the
place and construction of the energy production plants, in respect to the approved strategic plans of the country for nature and
biodiversity protection.
Your Details
Title:
Mr
First name:
Zvezdan
Last name:
Kalmar Krnajski Joviç
Name of organization:
Center for ecology and sustainable development
Job title:
Coordinator for energy and IFIs
Address:
Korzo 15/13
32
Postcode:
24000
City:
Subotica
Country:
Serbia
Email: *
[email protected]
Phone No:
+381655523191
General Comments
You are invited to provide your general comments in this section
Strategy for development of energy sector of Serbia is developed far from eyes of public in beginning of 2000thands. This
strategy is based on decades of lignite based development of electricity sector but in radically different energy/ economy sector
structure. In 1980 when strategy for development of energy generation projects was developed economy grew in levels of
6%/annually with ratio of Industry+services+transport counting for 75% and households consumption about 30%. In present time
households consumption counts for about 65/70% and all other sectors about 30%. With such bad structure it is impossible to
plan any sustainable economy of large lignite and hidro power plants in future. Serbia plans to poor in to development of new
lignite powered TPPs in up coming 5- 10 years about 4 billion EUR in new lignite capacities and about 1.5 in refurbishment of
existing ones to achieve level of standard that they can operate after 2017 when large combustion directive steps in power in
Serbia. In same time Serbia is planning to invest about 3 billion in environmental, technical improvements and extension of lignite
fields in Serbia. That does mean that Serbia plans to subsidize with about 7 billion EUR production and utilization of lignite and to
try to protect lignite capacities from direct market challenge which will lead to direct crowding out of other technologies and
resources in Serbia. Serbia needs completely new approach to energy sector based on energy savings that in EBRD view leads
to from 1000 to 10000 more cost effective impacts than producing new kW of energy generation capacity. Apart of that Serbian
fleet of houses is from 3/4 times more energy intensive than OECD and Eastern Europe average. With enormous potential for
solar, geo thermal and bio mas and positive economically impacts that can proceed from re industrialization based on bio mass
development (construction industry, furniture industry, bio mass utilization in energy and heat production, technical wood etc)
Serbia and whole region has potentially of carbon sinks that will in 2050 if right path is chosen now lead to negative CO2
emissions and region will become carbon neutral. Appart of that if carbon neutral path chosen region will become net exporter of
high value peak energy from pump storages, bio gas facilities and solar production. All that can lead to Serbia being net exporter
of electricity with negative Co2 sum. Bio mas should be utilized in local solutions with precautionary principle of sustainability of
bio mas consumed. Local communities should be considered as one of most promising actors in energy sector and should be
involved in any significant future energy planning that should ocure. In that sense we see that strategy of ECTS should be revised
starting this year to incorporate serious consultation process with local communities in region, and efficient and proactive
mechanism for support of local communities should be established in such consultation. Climate change and especially climate
change adaptation and mitigation should become one of main indicators for or against some of the projects. Beside that energy
(and fuel) poverty is most significant indicator of successfully of not so successfully energy sectors. With 100% of people in
Serbia (with statistically mistake of few tents of thousands of families below that line) spending average of 15.8% of income on
energy it is highly un likely that Serbia can keep up with such strucuture of energy sector present and planned in BAU as future.
We do not see that any completely independent state owned energy planning process can result in sustainable program and
sustainable “pipeline” of projects. Strong regional cooperation forum in energy sector with decision making power should be
established that will reflect interests of all participants in it. The use of fossil fuels (coal, oil and gas) will need to decrease rapidly
and be phased out in line with a pathway to 100% clean renewable energy. The IEA suggests that maintaining a 50/50 chance to
not overstep the 2-degree C threshold, the world must retire and leave below ground 2/3 of the present global fossil fuel reserves.
Other scientists show that in order to stay well below 2-degree C that it be rather 80% of all fossil fuel reserves that stay
untouched. Unfortunately, the world is moving into another direction. Scientists also show that a 3-degree and even 4-degree
world with its disastrous consequences for human and nature as shown recently by the World Bank will have to leave a large
portion of fossil fuel reserves unburned. • Proposals for new hydropower plants must meet internationally recognised
sustainability standards e.g. World Commission on Dams guidelines. New hydropower plants should only be considered if, after a
thorough assessment, they prove to be the best option, including when compared against energy efficiency, energy savings and
other renewable energy sources. • The Energy Community should encourage and respect the designation by the governments of
“No-go” areas for hydropower schemes — large or small — on the remaining unregulated rivers (or their tributaries) in areas of
high conservation value (see the No-go section in the next chapter). • Decisions regarding the location of hydropower plants
should be made in order to minimize the environmental impacts in the whole river basin. Efficient hydropower sites that minimize
the area flooded per unit of energy produced should be favoured (but taking into account the point above). • Mitigation measures,
such as environmental flow regimes, habitat restoration and protection, fish ladders, can significantly reduce the impact of
hydropower projects and should always be planned for. • Wherever possible, the capacity of existing hydropower plants should
be increased and existing infrastructures refurbished (optimized) in order to minimize the need for new plants. Optimisation
should also be linked to environmental improvements. • Small hydropower plants, which can supply rural areas in developing
countries with renewable energy, must include mitigation measures and their cumulative impact must be considered. • The
Energy Community should encourage governments to prioritise a sound energy mix, including energy efficiency measures and
various renewable energy solutions, to balance environmental and social impacts and foster energy security.
Comments about facilitation measures for PECIs
33
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
It is utmost challenging to advise on institutional setting for implementation of sustainable long term energy strategy for region. In
former Yugoslavia starting with 1974 economically space started to disintegrate and with that joint and common energy planning.
However energy, mining and other industries in socialist time have being exposed to market forces in bigger level than in present
time that, which inevitably have led to one of best technologies in world being used in for example lignite power plants in
Kolubara basin in Serbia, at the end of 1989. In those times there occurred number of cases that energy companies in SFRY
actually bankrupted due to pressure from market forces. Prices of lignite and electricity in that time where very close to the
economically ones and structure of consumption showed that industry, transport, services were the most important users and that
households practically used only about third of electricity. conflicts of 1990ties and significantly slow recovery of 2000 with
significant political risks still present are making situation in transition towards sustainable energy sector very risky enterprise.
Monopoly is systemic problem in region. That does mean that optimization of technologies and investment signals are distorted.
States in region (tax payers) are baring negative externalities of present structure of production and enormous marginal costs on
health, quality of soils, pollution of water, acidification of soils, direct health impacts, social costs of resettlement etc. State aid in
energy sector is one of main characteristics and EU and ECTS should take it on board as one of main drivers (obstacles) of
negative energy planning pattern in region. By promising state support states in region are providing that investments are being
falsely presented and economy of investment is being distorted. In most of cases in PECI projects submitted and according to
independent estimations price of electricity produced will be much higher than presented by governments in time when projects
are being promoted. Dependency on import will increase to non-precedent levels since about 70% of price in tone of lignite based
electricity is actually covering import. Therefore argument of energy independency fails to cover import dependency of countries
in sense of technology in lignite utilization and excavation. Therefore governments should prioritize sources that apart of
impoitrted technologies will not produce significant externalities (like bio mas, solar, geo thermal, wind etc) Significant interest of
governments in region to promote maximal generation capacities with tendency of becoming the leaders in region in electricity
production leads to projects exceeding any reasonable balances of future demand for energy. One of main driver is will to export
as much as possible electricity (especially high cost peak electricity towards EU- Italy, Hungary, Austria, Romania, Bulgaria and
further) which leads to fake optimism that low cost of environmental abatement (cost of climate change includied) in region will
not have long term economically consequences. It is not so. Therefore we recognize EU and governments in region as having
similar responsibility for current negative pathway selected by governments. None of countries in region haven’t ever developed
fully scale in depth analysis of Zero Carbon scenario in energy production. Also it is highly un likely that any of countries have
realistically assessed its future economically and energy demand growth, which can easily proven if one looks at the forecasts
from beginning of 2000nds and match it with levels achieved in period 2000-2013. It is easy to see that there is actually small or
no growth while consumption is growing, which is showing that first PECI should be EE program of scale in whole region that can
be led only by centralized pressure from EU and ECTS. How to arrange it institutionally? DG Competition should have prominent
role and DG Energy should scale up pressure on improvement of EE and especially de coupling of metering, collecting,
transmissions and distribution from monopolies, or rather state owned companies. State aid should completely be monitored and
targeted only towards EE, intelligent networks establishment and helpin local communities in region to increase their capacity to
plan and implement regional- of grid and small grid solutions. Countries should be encouraged to put in top of their agenda
protection of competition and reduction of consumption. Likewise some kind of moratorium on energy generation projects should
be in place at least for two years until these measures start to pick upo momentum. Main principles> - Shared responsibility with
EU and EU IFIs an ECTS - principle of solidarity of countries in region - principle of open and level headed playground for
technologies with strong social and local development mechanisms - Poverty reduction to 40% in 2020 and less than 20% in
2030 - Environmental impact decrease - Energy Efficiency first (moratorium on energy generation projects) - Decentralization of
production and consumption (increase of intelligent networks) and off grid and small grid solutions as principle For hidro projects
in Region there are several important indicators of sustainability that need to be taken seriously in to consideration henever such
projects is being assessed: In addition to enforcement of relevant environmental legislation (high standard SEA & EIA, full public
participation, non-deterioration principle etc), NGOs propose the following zonation criteria: 1. No go / exclusion zone: o High
ecological status; o good ecological status combined with hydromorphological class “slightly altered” or better o the core zone of
protected areas of IUCN category III and IV where river stretches or landscapes/catchments are preconditions for protection
status o River stretches / catchments that fall into core areas of IUCN category I and II protected areas 2. Non favorable o Good
ecological status but hydromorphological class is only “moderate” and there is no impoundment by a dam (excluding bottom sills).
o Ecosystem relevant unfragmented rivers or river sections, including those important for continuity (actually and potentially) and
for sediment supply o River stretches and catchment areas earmarked for restoration (e.g. floodplain restoration according to
Danube River Basin Management Plan) o Biodiversity hotspots (e.g. habitats for endemic species) o Protected areas other than
those defined for the exclusion category 3. Less favorable o River stretches and catchment areas of high landscape and/or
cultural value (landscape parks; scenic beauty etc) 4. Favorable o All those river stretches and catchment areas, where any of
the criteria of the other three categories do not apply
Project Comment Form
Project number (ID and code) as indicated in the list:
EG022
Comments on the project:
Project was started in socialist time before 1989. Economy of scale was different and resulted in feasibility of such project
according to WB estimations from 1991. However in those times environmental, social, health and climate change costs
where neglected in designing project. This capacity together with other from existing and planned fleet of TPPs in Kolubara
basin will consume as planned about 40 mt/a of lignite which will be emitting about 40mtCO2/a. That will be increase of
about 30% compared to present. With deteriorating qualities of lignite in basin (in sense of calorific value and
overburden/lignite ratio) and with significant planned need of spatial spread of lignite mines it will make economy of this and
34
other projects not feasible. Apart of that this project is contradicting state aid regulations of ECT and Eu since this project
would not be possible without state aid. Efficiency of project ≥37% is illegal. Kolubara B will consume about
5.976.000tlignite/a and needs about 9500kJ/kWh with lignites that will be in level of 6700kJ/kg of lignite guaranteed quality.
Minimal capacity for normal work will be 40% of capacity of block. Carbon Capture storage is not viable since on the level of
present technically knowledge there are no such geologically layers that can accept CO2 produced in this block It will
produce about 2100GWh/a according to technically documentation. According to EIA emission factor of Kolubara B will be
113,8 kgCO2/GJ which makes that Kolubara B will emit about 5-5.8 mtCO2/a which will make about 13+% of overall
emissions of EPS from large combustion in electricity production capacities. Environmental assessment of Kolubara region
absorbing capacity was done more than 10 years ago which makes assessments of potential of environment to absorb
emissions from this new TPP highly suspicious and questionable. This project will not have positive impact on other
countries in region of SEE since it will thorough distortion provided by state aid of Serbia send wrong signals to investors in
whole region. Apart of that it will further concentrate influence over regional energy market of Serbian energy monopoly with
clear results in increase of energy poverty in Serbia. Measures like social charts and lower tariffs for vulnerable groups will
not be able to cushion those impacts. Trans boundary impacts of NOx, Sox, acid rains etc isn’t measured especially on bio
mas and agriculture of other countries in region. Regarding argument that this plant will help facilitation of RES and new
technologies this project will clearly and significantly limit space for penetration of RES, and especially ability of State of
Serbia to support with state aid RES, EE measures of scale, introduction of intelligent networks and also subsidize
measures and projects in local communities that are willing to explore and implement small grid and off grid solutions. Much
higher efficiency and regulatory power for RES are having planned Gas power plants and pump storages envisioned in
Serbia, apart of already existing capacities. Also this project will put obstacle to utilization of Bio mas in transition of lignite
powered TPPs to partial bio mas fuel. Serbia is not assessing climate impacts of TPPs and especially emissions that will
occur as result of production of electricity from lignite. It is clear that Serbia will significantly increase carbon emissions and
that any advanced CO2 reduction will not be possible. In the case target of EU written in 2050 roadmap becomes obligatory
this and other TPPs online will “consume” all available CO2 and will distort any other sector still emitting CO2 in 2050. This
project is clearly contradicting 2050 roadmap, and in the case that CO2 allowances will achieve price of 20 EUR/t this
project , and other TPPs in Serbia will consume about 1 billion EUR yearly that makes economy of this project impossible.
Apart of that this project will increase import reliance, macro economically instability, will reduce possibility of development
of long term sustainable industry jobs in wood, EE, RES and other related industries, in non energy sectors (since bio mass
as main potential for job creation will be crowded out). Project will have negligible energy efficiency consequence since
main problem is demand side EE which would be crowded out since resources of state will be wasted on support for this
project that will start to produce surpluses of value (if ever) later than 2035. Socio economically benefits will be negative
since project is related to massive scale of water, air, soil pollution, resettlement of 3000 inhabitants related to mines
providing lignite for project (cost about 300 million EUR) It will decrease ability of government to support economically
development in local communities of Serbia. Depth of Serbia will go over 80% of GDP were it stands now. It is highly
unlikely that this project is bankable without direct subsidies of state and no private company will actually take on it without
direct guarantee for price of electricity collected ( in form of state aid). Experience from other large infrastructural projects in
Serbia are showing that in most of cases projects are being developed with 100% of time delay and with prices running
100% and more percent higher in the end of project development! State company of Serbia is having enormous commercial
and technically losses therefore adding to high risk in the project. Project is in early phase of technical documentation that
need to be revised since project design is very old. BAT should be envisioned that will kill economy of project since it will
rely on low quality lignites (more than40% efficiency) Large portions of society are against project and actively working
against it. local communities are complaining about present and future impact on environmental, health and other
conditions. EPS does not conducts scientific measurement of cost of emitting CO2 in Serbian circumstances. Given the
urgency of climate change there is no room for a policy that supports new coal and lignite fired generation in the EU power
system. This implies that coal and lignite fired generation should not be supported by the Energy Community. This no-coalposition should include • coal ‐ fired combined heat and power (CHP): given the long plant lifetime and marginal efficiency
gains, the risk of failure of the EU decarbonisation goal by 2050 is too high. • refurbishment, retrofitting and replacement of
coal-fired plants. While focussed refurbishment can limit the emissions of various types of particles and lead to an
improvement of air quality in the area, when refurbishment prolongs the lifespan of the plant it leads to an absolute increase
in GHG emissions compared to energy saving or renewable alternatives. It creates a high risk scenario to contradict the
decarbonisation of the EU energy sector committed by 2050. • CCS (carbon capture and storage) technology is in the
medium term very unlikely to be technically effective and commercially available as part of a competitive energy option, so
CCS for coal should not be considered by the Energy Community. • The no-coal-position should also include coal mining
operations and related activities.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG023
Comments on the project:
Block of 350 MW, second phase of already existing two blocks. Efficiency envisioned in level of ≥40%, for lignite of average
calorific value of about 7800kJ/kg of lignite. There is no technically potential to fore see CCS since geology of location is
against such plan. Block will emit about average of CO2 like other blocks in Serbia of that capacity. There is no possibility to
significantly reduce amounts of CO2 per MWh which means that it is expected to emit about 1000kg CO2/MWh. In all cases
regulating power of TPPs for RES is actually limiting factor of RES penetration, which means that EPS is highly interested to
keep RES production far below possible and economically viable values introducing limit for RES which is leading to
crowding out of interest of potentially investors in Serbia and other countries in region since much bigger margins of profit
are achievable by merchandising of massively subsidized lignite generated electricity. EPS is showing active role in blocking
RES penetration by advertising its high price and potentially burden on consumers thorough feed in tariffs in same time not
35
reporting high levels of subsidies, burden on public thorough subsidy for environmental improvement, subsidizing
resettlements related to coal production, not reporting high damages from acid rains on bio mas, agriculture, high bio
diversity losses in water beads servicing TPPs in Kolubara basin, high health cost from emissions from tPPs and last but not
least high costs of climate impacts of Co2 and other GHG. EPS and ministry never conducted serious and in depth
assessment of zero carbon electricity system of Serbia like one conducted in framework of EU 2050 road map. This project
will not have positive impact on other countries in region of SEE since it will thorough distortion provided by state aid of
Serbia send wrong signals to investors in whole region. Apart of that it will further concentrate influence over regional
energy market of Serbian energy monopoly with clear results in increase of energy poverty in Serbia. Measures like social
charts and lower tariffs for vulnerable groups will not be able to cushion those impacts. Trans boundary impacts of NOx,
Sox, acid rains etc isn’t measured especially on bio mas and agriculture of other countries in region. Regarding argument
that this plant will help facilitation of RES and new technologies this project will clearly and significantly limit space for
penetration of RES, and especially ability of State of Serbia to support with state aid RES, EE measures of scale,
introduction of intelligent networks and also subsidize measures and projects in local communities that are willing to explore
and implement small grid and off grid solutions. Much higher efficiency and regulatory power for RES are having planned
Gas power plants and pump storages envisioned in Serbia, apart of already existing capacities. Also this project will put
obstacle to utilization of Bio mas in transition of lignite powered TPPs to partial bio mas fuel. Serbia is not assessing climate
impacts of TPPs and especially emissions that will occur as result of production of electricity from lignite. It is clear that
Serbia will significantly increase carbon emissions and that any advanced CO2 reduction will not be possible. In the case
target of EU written in 2050 roadmap becomes obligatory this and other TPPs online will “consume” all available CO2 and
will distort any other sector still emitting CO2 in 2050. This project is clearly contradicting 2050 roadmap, and in the case
that CO2 allowances will achieve price of 20 EUR/t this project , and other TPPs in Serbia will consume about 1 billion EUR
yearly that makes economy of this project impossible. Apart of that this project will increase import reliance, macro
economically instability, will reduce possibility of development of long term sustainable industry jobs in wood, EE, RES and
other related industries, in non energy sectors (since bio mass as main potential for job creation will be crowded out).
Project will have negligible energy efficiency consequence since main problem is demand side EE which would be crowded
out since resources of state will be wasted on support for this project that will start to produce surpluses of value (if ever)
later than 2035. Socio economically benefits will be negative since project is related to massive scale of water, air, soil
pollution, resettlement of 3000 inhabitants related to mines providing lignite for project (cost about 300 million EUR) It will
decrease ability of government to support economically development in local communities of Serbia. Depth of Serbia will go
over 80% of GDP were it stands now. It is highly unlikely that this project is bankable without direct subsidies of state and no
private company will actually take on it without direct guarantee for price of electricity collected ( in form of state aid).
Experience from other large infrastructural projects in Serbia are showing that in most of cases projects are being
developed with 100% of time delay and with prices running 100% and more percent higher in the end of project
development! State company of Serbia is having enormous commercial and technically losses therefore adding to high risk
in the project. Chinese partners are very slowly advancing with project implementation, it is clear that project is having
significant problems related to economy and availability of fresh capital to EPS. Project is in early phase of technical
documentation that need to be revised since project design is very old. BAT should be envisioned that will kill economy of
project since it will rely on low quality lignites (more than40% efficiency) Large portions of society are against project and
actively working against it. local communities are complaining about present and future impact on environmental, health and
other conditions. EPS does not conducts scientific measurement of cost of emitting CO2 in Serbian circumstances. Given
the urgency of climate change there is no room for a policy that supports new coal and lignite fired generation in the EU
power system. This implies that coal and lignite fired generation should not be supported by the Energy Community. This
no-coal-position should include • coal ‐ fired combined heat and power (CHP): given the long plant lifetime and marginal
efficiency gains, the risk of failure of the EU decarbonisation goal by 2050 is too high. • refurbishment, retrofitting and
replacement of coal-fired plants. While focussed refurbishment can limit the emissions of various types of particles and lead
to an improvement of air quality in the area, when refurbishment prolongs the lifespan of the plant it leads to an absolute
increase in GHG emissions compared to energy saving or renewable alternatives. It creates a high risk scenario to
contradict the decarbonisation of the EU energy sector committed by 2050. • CCS (carbon capture and storage) technology
is in the medium term very unlikely to be technically effective and commercially available as part of a competitive energy
option, so CCS for coal should not be considered by the Energy Community. The no-coal-position should also include coal
mining operations and related activities.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG021
Comments on the project:
Large hidro power plant in protected naturally area. Much better solution would be retrofitting Djerdap I and II to the pump
storage technology that will expand regulatory power of EPS especially in sense of regulation management of RES in
Serbia and region. Public should be involved in consultation about this project, and especially Public of countries that are up
stream and down stream of the proposed project. Especially concern is problem of further deterioration of environmental
conditions in whole Danube river basin. Djerdap HPP is having notorious history of destruction of whole cities in former
Yugoslavia that should be avoided. project should be exposed to the market powers where project should internalize
negative environmental and social impacts and only then calculated. Project is not bankable since it is not possible to fully
cover environmental impacts,m therefore much better solution should be retrofit of Djerdap I and II in to pump storage. 1) In
order to reduce impact of existing hydropower infrastructure, the legislative framework and its enforcement need to be
strengthened where necessary to minimize negative impacts of hydropower, e.g. by guaranteeing ecological flow, outlawing
hydro-peaking in certain areas, or making facilities for sediment transport or fish (up- and downstream) migration aids
mandatory. The Swiss Law of Water Protection is one good example. Mitigation measures must be integral parts of
36
renewed and new hydropower concessions. NGOs must be given the right of complaint in case water ecosystems suffer
from violation of environmental laws as is the case in some European countries. By internalising environmental costs and
applying market based instruments harmful projects should be made unprofitable while careful planning and mitigation of
impacts paying off, The decommissioning of obsolete dams or of structures at locations critical for river continuity has to be
planned in a strategic manner, as is practiced in France for example. 2) Before an increase of hydropower capacity can be
discussed, a long-term energy policy needs to be defined aiming at phasing out fossil fuels and nuclear energy while
reducing overall energy consumption. Based on this policy, sustainable energy scenarios should be developed and
integrated on regional level. These scenarios show which role hydropower (considering its negative impacts) can play, what
energy savings and demand reduction can achieve; they define needs for grid upgrading (“Smart Grids”) and incorporate
rural development aspects.. 3) In case the long-term sustainable energy policy identifies a role for hydropower, the full
potential for optimising (upgrade, refurbish, possibly extend etc) existing hydropower infrastructure has to be exhausted
while lowering overall environmental impacts. Such technical mitigation measures (e.g. turbines with lower fish mortality
rates) adjusted to size and type of the plant can considerably increase energy production without deteriorating
environmental conditions. 4) Only if the optimisation potential has been exhausted and no environmentally better options
exist, new hydropower plants can be considered. They must be based on strategic pre-planning mechanisms to achieve
environmental integration and developed in cooperation with stakeholders (including NGOs), comprising the following
elements: • areas not suitable for new hydropower are to be defined and mapped under a basin-wide agreed set of
scientifically sound ecological, cultural and social criteria. The protection of these areas should be made legally binding
either at national and/or at regional/basin level. • Besides areas not suitable for new hydropower development, different
sensitivity classes should be defined that indicate decreasing ecological priority (and increasing acceptability for hydropower
developments). • Criteria for defining sensitivity classes in particular areas not suitable for new hydropower development
encompass: • Protected Areas of global, EU, and national status, including riverine landscapes of outstanding value (e.g.
national heritage, still intact sub-basins/valleys), • river systems featuring reference conditions, • Ecological aspects, paying
attention to the need of adapting to a changing climate (i.e. ecological status, hydromorphology, habitats and species of
global or EU importance outside of protected areas, national biodiversity strategy, endemism, “hot spots” such as river
stretches with actual or potential high fish species diversity), • Existing and potential longitudinal and lateral
continuity/connectivity with respect to upstream and downstream migration of fish and invertebrates (benthos), and
sediment transport. • SEAs have to become mandatory for new hydropower development plans. • Technical specifications
(operation, lay-out, size etc) for hydropower installations leading to lowest impact is also to be specified per river sections..
B) PROJECT LEVEL 1) Proper application of the EIA Directive with review by independent experts must involve (a) a
complete and proper list of environmental issues; (b) scientifically sound reports about the expected environmental impacts
and proposals of feasible environmental measures; (c) a legally binding text of concessions approved by the competent
authority; (d) proper implementation and monitoring, including necessary amendments. 2) Good practice and Best Available
Technique (BAT) with regard to environmental impact reduction for (1) avoiding, (2) mitigating and (3) compensating
impacts through proper location, design and operation has to be defined, making use of e.g. the revised IHA protocol, the
Greenhydro methodology, or criteria for the German renewable energy act. 3) By involving stakeholders, in particular local
communities, and NGOs from the start, their knowledge can be used for defining the best design and location and conflicts
become less likely. 4) Ecolables (such as the Swiss naturmade star) can reduce impact but require sufficient understanding
of river ecology and increase costs.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG019
Comments on the project:
project/s opposed massively by local communities and wide range of national and international experts and CSOs. project
will cause significant interruption of water systems, will cause significant bio diversity, destruction of important protected and
future protected area in region. project will cause high damages on local economy, potable water will be destructed, level of
phenol will increase directly endangering local communities. Apart of that land slides and erosion are highly probable. Local
communities will be exposed to high problems related to mud and river deposits. Globally large amounts of methane will be
emitted since HPPs will slow down significantly flow of river. fisheries will be interrupt, and especially concern is problem
with services and tourism industries that are directly opposing such large projects. electricity produced will be exported, in
same time project sponsor will benefit from feed in tariffs and will not be obliged to sustain all the costs occurring because of
the project. EIA and SEA procedures are flawed and communities arent consulted in serious and acceptable manner Local
communities are exposed to open and hidden pressure to accept project no matter for costs. General problem with project
is that cumulative impact of the project is not assessed and that such cumulative impacts should be assessed in sense of
social, ECONOMICALLY and environmental long term costs of the project. proclaiming project as public interest is not
acceptable since private (though foreign) investor will directly and exclusively benefit from it and local communities will have
only damages. Public interest and all the costs incured by projects are considered state aid and s such are illegal in ECT.
Local needs are much lower and only fraction of the project would in long term fully satisfy local needs. Local communities
are in favour of EE measures first, than planning generation project on IBAR river with much smaller capacity and potentially
impacts on the river, river bead and surrounding environment. 1) In order to reduce impact of existing hydropower
infrastructure, the legislative framework and its enforcement need to be strengthened where necessary to minimize negative
impacts of hydropower, e.g. by guaranteeing ecological flow, outlawing hydro-peaking in certain areas, or making facilities
for sediment transport or fish (up- and downstream) migration aids mandatory. The Swiss Law of Water Protection is one
good example. Mitigation measures must be integral parts of renewed and new hydropower concessions. NGOs must be
given the right of complaint in case water ecosystems suffer from violation of environmental laws as is the case in some
European countries. By internalising environmental costs and applying market based instruments harmful projects should
be made unprofitable while careful planning and mitigation of impacts paying off, The decommissioning of obsolete dams or
37
of structures at locations critical for river continuity has to be planned in a strategic manner, as is practiced in France for
example. 2) Before an increase of hydropower capacity can be discussed, a long-term energy policy needs to be defined
aiming at phasing out fossil fuels and nuclear energy while reducing overall energy consumption. Based on this policy,
sustainable energy scenarios should be developed and integrated on regional level. These scenarios show which role
hydropower (considering its negative impacts) can play, what energy savings and demand reduction can achieve; they
define needs for grid upgrading (“Smart Grids”) and incorporate rural development aspects.. 3) In case the long-term
sustainable energy policy identifies a role for hydropower, the full potential for optimising (upgrade, refurbish, possibly
extend etc) existing hydropower infrastructure has to be exhausted while lowering overall environmental impacts. Such
technical mitigation measures (e.g. turbines with lower fish mortality rates) adjusted to size and type of the plant can
considerably increase energy production without deteriorating environmental conditions. 4) Only if the optimisation potential
has been exhausted and no environmentally better options exist, new hydropower plants can be considered. They must be
based on strategic pre-planning mechanisms to achieve environmental integration and developed in cooperation with
stakeholders (including NGOs), comprising the following elements: • areas not suitable for new hydropower are to be
defined and mapped under a basin-wide agreed set of scientifically sound ecological, cultural and social criteria. The
protection of these areas should be made legally binding either at national and/or at regional/basin level. • Besides areas
not suitable for new hydropower development, different sensitivity classes should be defined that indicate decreasing
ecological priority (and increasing acceptability for hydropower developments). • Criteria for defining sensitivity classes in
particular areas not suitable for new hydropower development encompass: • Protected Areas of global, EU, and national
status, including riverine landscapes of outstanding value (e.g. national heritage, still intact sub-basins/valleys), • river
systems featuring reference conditions, • Ecological aspects, paying attention to the need of adapting to a changing climate
(i.e. ecological status, hydromorphology, habitats and species of global or EU importance outside of protected areas,
national biodiversity strategy, endemism, “hot spots” such as river stretches with actual or potential high fish species
diversity), • Existing and potential longitudinal and lateral continuity/connectivity with respect to upstream and downstream
migration of fish and invertebrates (benthos), and sediment transport. • SEAs have to become mandatory for new
hydropower development plans. • Technical specifications (operation, lay-out, size etc) for hydropower installations leading
to lowest impact is also to be specified per river sections.. B) PROJECT LEVEL 1) Proper application of the EIA Directive
with review by independent experts must involve (a) a complete and proper list of environmental issues; (b) scientifically
sound reports about the expected environmental impacts and proposals of feasible environmental measures; (c) a legally
binding text of concessions approved by the competent authority; (d) proper implementation and monitoring, including
necessary amendments. 2) Good practice and Best Available Technique (BAT) with regard to environmental impact
reduction for (1) avoiding, (2) mitigating and (3) compensating impacts through proper location, design and operation has to
be defined, making use of e.g. the revised IHA protocol, the Greenhydro methodology, or criteria for the German renewable
energy act. 3) By involving stakeholders, in particular local communities, and NGOs from the start, their knowledge can be
used for defining the best design and location and conflicts become less likely. 4) Ecolables (such as the Swiss naturmade
star) can reduce impact but require sufficient understanding of river ecology and increase costs.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG015
Comments on the project:
project/s opposed massively by local communities and wide range of national and international experts and CSOs. project
will cause significant interruption of water systems, will cause significant bio diversity, destruction of important protected and
future protected area in region. project will cause high damages on local economy, potable water will be destructed, level of
phenol will increase directly endangering local communities. Apart of that land slides and erosion are highly probable. Local
communities will be exposed to high problems related to mud and river deposits. Globally large amounts of methane will be
emitted since HPPs will slow down significantly flow of river. fisheries will be interrupt, and especially concern is problem
with services and tourism industries that are directly opposing such large projects. electricity produced will be exported, in
same time project sponsor will benefit from feed in tariffs and will not be obliged to sustain all the costs occurring because of
the project. EIA and SEA procedures are flawed and communities arent consulted in serious and acceptable manner Local
communities are exposed to open and hidden pressure to accept project no matter for costs. General problem with project
is that cumulative impact of the project is not assessed and that such cumulative impacts should be assessed in sense of
social, ECONOMICALLY and environmental long term costs of the project. proclaiming project as public interest is not
acceptable since private (though foreign) investor will directly and exclusively benefit from it and local communities will have
only damages. Public interest and all the costs incured by projects are considered state aid and s such are illegal in ECT.
Local needs are much lower and only fraction of the project would in long term fully satisfy local needs. Local communities
are in favour of EE measures first, than planning generation project on LIM river with much smaller capacity and potentially
impacts on the river, river bead and surrounding environment. 1) In order to reduce impact of existing hydropower
infrastructure, the legislative framework and its enforcement need to be strengthened where necessary to minimize negative
impacts of hydropower, e.g. by guaranteeing ecological flow, outlawing hydro-peaking in certain areas, or making facilities
for sediment transport or fish (up- and downstream) migration aids mandatory. The Swiss Law of Water Protection is one
good example. Mitigation measures must be integral parts of renewed and new hydropower concessions. NGOs must be
given the right of complaint in case water ecosystems suffer from violation of environmental laws as is the case in some
European countries. By internalising environmental costs and applying market based instruments harmful projects should
be made unprofitable while careful planning and mitigation of impacts paying off, The decommissioning of obsolete dams or
of structures at locations critical for river continuity has to be planned in a strategic manner, as is practiced in France for
example. 2) Before an increase of hydropower capacity can be discussed, a long-term energy policy needs to be defined
aiming at phasing out fossil fuels and nuclear energy while reducing overall energy consumption. Based on this policy,
sustainable energy scenarios should be developed and integrated on regional level. These scenarios show which role
38
hydropower (considering its negative impacts) can play, what energy savings and demand reduction can achieve; they
define needs for grid upgrading (“Smart Grids”) and incorporate rural development aspects.. 3) In case the long-term
sustainable energy policy identifies a role for hydropower, the full potential for optimising (upgrade, refurbish, possibly
extend etc) existing hydropower infrastructure has to be exhausted while lowering overall environmental impacts. Such
technical mitigation measures (e.g. turbines with lower fish mortality rates) adjusted to size and type of the plant can
considerably increase energy production without deteriorating environmental conditions. 4) Only if the optimisation potential
has been exhausted and no environmentally better options exist, new hydropower plants can be considered. They must be
based on strategic pre-planning mechanisms to achieve environmental integration and developed in cooperation with
stakeholders (including NGOs), comprising the following elements: • areas not suitable for new hydropower are to be
defined and mapped under a basin-wide agreed set of scientifically sound ecological, cultural and social criteria. The
protection of these areas should be made legally binding either at national and/or at regional/basin level. • Besides areas
not suitable for new hydropower development, different sensitivity classes should be defined that indicate decreasing
ecological priority (and increasing acceptability for hydropower developments). • Criteria for defining sensitivity classes in
particular areas not suitable for new hydropower development encompass: • Protected Areas of global, EU, and national
status, including riverine landscapes of outstanding value (e.g. national heritage, still intact sub-basins/valleys), • river
systems featuring reference conditions, • Ecological aspects, paying attention to the need of adapting to a changing climate
(i.e. ecological status, hydromorphology, habitats and species of global or EU importance outside of protected areas,
national biodiversity strategy, endemism, “hot spots” such as river stretches with actual or potential high fish species
diversity), • Existing and potential longitudinal and lateral continuity/connectivity with respect to upstream and downstream
migration of fish and invertebrates (benthos), and sediment transport. • SEAs have to become mandatory for new
hydropower development plans. • Technical specifications (operation, lay-out, size etc) for hydropower installations leading
to lowest impact is also to be specified per river sections.. B) PROJECT LEVEL 1) Proper application of the EIA Directive
with review by independent experts must involve (a) a complete and proper list of environmental issues; (b) scientifically
sound reports about the expected environmental impacts and proposals of feasible environmental measures; (c) a legally
binding text of concessions approved by the competent authority; (d) proper implementation and monitoring, including
necessary amendments. 2) Good practice and Best Available Technique (BAT) with regard to environmental impact
reduction for (1) avoiding, (2) mitigating and (3) compensating impacts through proper location, design and operation has to
be defined, making use of e.g. the revised IHA protocol, the Greenhydro methodology, or criteria for the German renewable
energy act. 3) By involving stakeholders, in particular local communities, and NGOs from the start, their knowledge can be
used for defining the best design and location and conflicts become less likely.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG024
Comments on the project:
Nikola Tesla B project planned to cost about 900 million EUR. Planned construction time about 5 years in ideal situion.
Planned date of commission is 2014. Project is significantly behind scheduled. Planned production of Nikola Tesla b3 is
about 5000GWh/a which will increase available electricity from TPPs in Nikola Tesla “basin”to 21500GWh/a. Consumption
of Nikola Tesla b3 will be about or more than 7 million t/a of lignite with 6608kj/kg ±5% homogenized lignite from about 600
km2 of lignite basin of Kolubara mining fields. Planned emission of CO2 from Nikola Tesla B3 will be according to EIA study
845kgCO2/MWh, present emissions from Kolubara basin blocks is from 1000 to 1100 kgCO2/MWh. However due
worsening of lignite qualities and deposits and due to large probability of significant stops due to abrasive impacts of sands
presents in Kolubara lignites it is highly probable that emissions factor will be much closer to 1000kgCO2/Mwh that
projected one, especially since such abrasive impacts are presenting more than 50% of all failures of blocks in Kolubara
basin. This block will emit about 7 mtCo2/a if planned parameters would be kept. Carbon Capture storage is not feasiblee
since on the level of present technically knowledge there are no such geologically layers that can accept CO2 produced in
this block. Only solution is transporting of CO2 to other parts of Serbia with better sediments. Block will consume about
9023MJ./kWh. Efficiency of block will be about 39,9%.. Minimal capacity of block will be 40% which is directly having impact
on the future structure of RES and need of this block and other blocks in system of EPS to have flat capacity utilization of
about and over 40% since with levels below those block can not function. In all cases regulating power of TPPs for RES is
actually limiting factor of RES penetration, which means that EPS is highly interested to keep RES production far below
possible and economically viable values introducing limit for RES which is leading to crowding out of interest of potentially
investors in Serbia and other countries in region since much bigger margins of profit are achievable by merchandising of
massively subsidized lignite generated electricity. EPS is showing active role in blocking RES penetration by advertising its
high price and potentially burden on consumers thorough feed in tariffs in same time not reporting high levels of subsidies,
burden on public thorough subsidy for environmental improvement, subsidizing resettlements related to coal production, not
reporting high damages from acid rains on bio mas, agriculture, high bio diversity losses in water beads servicing TPPs in
Kolubara basin, high health cost from emissions from tPPs and last but not least high costs of climate impacts of Co2 and
other GHG. EPS and ministry never conducted serious and in depth assessment of zero carbon electricity system of Serbia
like one conducted in framework of EU 2050 road map. This project will not have positive impact on other countries in
region of SEE since it will thorough distortion provided by state aid of Serbia send wrong signals to investors in whole
region. Apart of that it will further concentrate influence over regional energy market of Serbian energy monopoly with clear
results in increase of energy poverty in Serbia. Measures like social charts and lower tariffs for vulnerable groups will not be
able to cushion those impacts. Trans boundary impacts of NOx, Sox, acid rains etc isn’t measured especially on bio mas
and agriculture of other countries in region. Regarding argument that this plant will help facilitation of RES and new
technologies this project will clearly and significantly limit space for penetration of RES, and especially ability of State of
Serbia to support with state aid RES, EE measures of scale, introduction of intelligent networks and also subsidize
measures and projects in local communities that are willing to explore and implement small grid and off grid solutions. Much
39
higher efficiency and regulatory power for RES are having planned Gas power plants and pump storages envisioned in
Serbia, apart of already existing capacities. Also this project will put obstacle to utilization of Bio mas in transition of lignite
powered TPPs to partial bio mas fuel. Serbia is not assessing climate impacts of TPPs and especially emissions that will
occur as result of production of electricity from lignite. It is clear that Serbia will significantly increase carbon emissions and
that any advanced CO2 reduction will not be possible. In the case target of EU written in 2050 roadmap becomes obligatory
this and other TPPs online will “consume” all available CO2 and will distort any other sector still emitting CO2 in 2050. This
project is clearly contradicting 2050 roadmap, and in the case that CO2 allowances will achieve price of 20 EUR/t this
project , and other TPPs in Serbia will consume about 1 billion EUR yearly that makes economy of this project impossible.
Apart of that this project will increase import reliance, macro economically instability, will reduce possibility of development
of long term sustainable industry jobs in wood, EE, RES and other related industries, in non energy sectors (since bio mass
as main potential for job creation will be crowded out). Project will have negligible energy efficiency consequence since
main problem is demand side EE which would be crowded out since resources of state will be wasted on support for this
project that will start to produce surpluses of value (if ever) later than 2035. Socio economically benefits will be negative
since project is related to massive scale of water, air, soil pollution, resettlement of 3000 inhabitants related to mines
providing lignite for project (cost about 300 million EUR) It will decrease ability of government to support economically
development in local communities of Serbia. Depth of Serbia will go over 80% of GDP were it stands now. It is highly
unlikely that this project is bankable without direct subsidies of state and no private company will actually take on it without
direct guarantee for price of electricity collected ( in form of state aid). Experience from other large infrastructural projects in
Serbia are showing that in most of cases projects are being developed with 100% of time delay and with prices running
100% and more percent higher in the end of project development! State company of Serbia is having enormous commercial
and technically losses therefore adding to high risk in the project. Most important partner for this project recently announced
that it is not interested in project (german RWE) which means that project is in essence not feasible. Project is in early
phase of technical documentation that need to be revised since project design is very old. BAT should be envisioned that
will kill economy of project since it will rely on low quality lignites (more than40% efficiency) Large portions of society are
against project and actively working against it. local communities are complaining about present and future impact on
environmental, health and other conditions. EPS does not conducts scientific measurement of cost of emitting CO2 in
Serbian circumstances. Given the urgency of climate change there is no room for a policy that supports new coal and lignite
fired generation in the EU power system. This implies that coal and lignite fired generation should not be supported by the
Energy Community. This no-coal-position should include • coal ‐ fired combined heat and power (CHP): given the long plant
lifetime and marginal efficiency gains, the risk of failure of the EU decarbonisation goal by 2050 is too high. • refurbishment,
retrofitting and replacement of coal-fired plants. While focussed refurbishment can limit the emissions of various types of
particles and lead to an improvement of air quality in the area, when refurbishment prolongs the lifespan of the plant it leads
to an absolute increase in GHG emissions compared to energy saving or renewable alternatives. It creates a high risk
scenario to contradict the decarbonisation of the EU energy sector committed by 2050. • CCS
Project Comment Form
Project number (ID and code) as indicated in the list:
EG005-2
Comments on the project:
Project/s Massively opposed by Serbian, Bosnian and Montenegro public, with enormous impacts on border river, and with
especially negative impact on the local communities. opposed massively by local communities and wide range of national
and international experts and CSOs. project will cause significant interruption of water systems, will cause significant bio
diversity, destruction of important protected and future protected area in region. project will cause high damages on local
economy, potable water will be destructed, level of phenol will increase directly endangering local communities. Apart of that
land slides and erosion are highly probable. Local communities will be exposed to high problems related to mud and river
deposits. Globally large amounts of methane will be emitted since HPPs will slow down significantly flow of river. fisheries
will be interrupt, and especially concern is problem with services and tourism industries that are directly opposing such large
projects. electricity produced will be exported, in same time project sponsor will benefit from feed in tariffs and will not be
obliged to sustain all the costs occurring because of the project. EIA and SEA procedures are flawed and communities arent
consulted in serious and acceptable manner Local communities are exposed to open and hidden pressure to accept project
no matter for costs. General problem with project is that cumulative impact of the project is not assessed and that such
cumulative impacts should be assessed in sense of social, ECONOMICALLY and environmental long term costs of the
project. proclaiming project as public interest is not acceptable since private (though foreign) investor will directly and
exclusively benefit from it and local communities will have only damages. Public interest and all the costs incured by
projects are considered state aid and s such are illegal in ECT. Local needs are much lower and only fraction of the project
would in long term fully satisfy local needs. Local communities are in favour of EE measures first, than planning generation
project on DRINA river with much smaller capacity and potentially impacts on the river, river bead and surrounding
environment. Detail plans and EIA for building HE Buk Bijela and Foca at Drina river were not done in transparent way and
trasnboundary impact assessment to Montenegro is poorly analyzed. Legal procedures in EIA development were not
respected especially related to the transboundary impacts (art. 3 ESPOO convention) and public participation processes. It
is very important as predicted dams and accumulation might impact Tara river (Montenegrin no go area) and National Park
Durmitor which are identified as important sites at a global area (UNESCO World Heritage), European (Durmitor and Tara
River Emerald sites under the Bern Convention) and national level (national reservoir of nature Crna Poda and Piva) areas
a consequence. We hence strongly recommend careful and interdisciplinary research and analysis of the transboundary
impact after which a conclusion on the feasibility of the plants can be drawn. 1. The EIA states that the project on HE Foca
is expected to flood 163,30 ha at the borders with Montenegro, but the exact boundaries of the reservoirs are not clear; 2.
The trans boundary ecological baseline situation is not described, hence analysing the impact is not really possible to the
reader. 3. The project is located at the borders with Montenegro but no consultation has been held and no analysis of trans
40
boundary impacts have been done, as required by the Espoo Convention signed by Bosnia and Herzegovina and
Montenegro in 2009 and Serbia in about same time, hence no evidence is provided of lack of trans boundary impacts; 4.
According to the Stabilization and Association Agreement signed on 16 June 2008 by Bosnia and Herzegovina, the country
should take concrete steps to comply with the EU relevant legislation (e.g. Water Framework Directive, Habitats Directive).
In this sense, the EIA should further explain whether the project will be in compliance with EU legislation or not and if not
what are future steps to be taken. We call upon the Ministry of Physical Planning, Civil Engineering and Ecology of Republic
of Srpska , ministry for environment and energy of republic of Serbia to: 1. Analyse the transboundary impact and
substantiate it with baseline data. 2. Carry out a cross-border consultation on the trans boundary impact of Buk Bjela in
accordance with international agreements; 3. Verify the compliance of the Buk Bjela project with relevant EU legislation; 4.
Set up a mechanism to monitor the appropriate implementation of mitigation measures, eventually setting-up a monitoring
commission. 1) In order to reduce impact of existing hydropower infrastructure, the legislative framework and its
enforcement need to be strengthened where necessary to minimize negative impacts of hydropower, e.g. by guaranteeing
ecological flow, outlawing hydro-peaking in certain areas, or making facilities for sediment transport or fish (up- and
downstream) migration aids mandatory. The Swiss Law of Water Protection is one good example. Mitigation measures must
be integral parts of renewed and new hydropower concessions. NGOs must be given the right of complaint in case water
ecosystems suffer from violation of environmental laws as is the case in some European countries. By internalising
environmental costs and applying market based instruments harmful projects should be made unprofitable while careful
planning and mitigation of impacts paying off, The decommissioning of obsolete dams or of structures at locations critical for
river continuity has to be planned in a strategic manner, as is practiced in France for example. 2) Before an increase of
hydropower capacity can be discussed, a long-term energy policy needs to be defined aiming at phasing out fossil fuels and
nuclear energy while reducing overall energy consumption. Based on this policy, sustainable energy scenarios should be
developed and integrated on regional level. These scenarios show which role hydropower (considering its negative impacts)
can play, what energy savings and demand reduction can achieve; they define needs for grid upgrading (“Smart Grids”) and
incorporate rural development aspects.. 3) In case the long-term sustainable energy policy identifies a role for hydropower,
the full potential for optimising (upgrade, refurbish, possibly extend etc) existing hydropower infrastructure has to be
exhausted while lowering overall environmental impacts. Such technical mitigation measures (e.g. turbines with lower fish
mortality rates) adjusted to size and type of the plant can considerably increase energy production without deteriorating
environmental conditions. 4) Only if the optimisation potential has been exhausted and no environmentally better options
exist, new hydropower plants can be considered. They must be based on strategic pre-planning mechanisms to achieve
environmental integration and developed in cooperation with stakeholders (including NGOs), comprising the following
elements: • areas not suitable for new hydropower are to be defined and mapped under a basin-wide agreed set of
scientifically sound ecological, cultural and social criteria. The protection of these areas should be made legally binding
either at national and/or at regional/basin level. • Besides areas not suitable for new hydropower development, different
sensitivity classes should be defined that indicate decreasing ecological priority (and increasing acceptability for hydropower
developments). • Criteria for defining sensitivity classes in particular areas not suitable for new hydropower development
encompass: • Protected Areas of global, EU, and national status, including riverine landscapes of outstanding value (e.g.
national heritage, still intact sub-basins/valleys), • river systems featuring reference conditions, • Ecological aspects, paying
attention to the need of adapting to a changing climate (i.e. ecological status, hydromorphology, habitats and species of
global or EU importance outside of protected areas, national biodiversi
Your Details
First name:
Karl
Last name:
Schellmann
Name of organization:
WWF Austria
Job title:
Climate Change & Energy Expert
Address:
Ottakringer Strasse 114-116
Postcode:
1060
City:
Wien
Country:
Austria
Email: *
[email protected]
Phone No:
+43 676 83 488 249
General Comments
41
You are invited to provide your general comments in this section
The WWF vision demands to do everything possible to “build a future in which humans live in harmony with nature”. This is our
guiding principle and therefore we will strongly support an energy policy which is in line with a long-term sustainable development
combined with strict, legally binding biodiversity safeguards and a nature protection policy that preserves biodiversity treasures
untouched. Compared to 1990, the Europe 27 anthropogenic greenhouse gas emissions (GHG) have reduced by 7.7 %. A big
part of it caused by the economic collapse in the former Soviet Union countries. EU 27 now releases about 5 billion tonnes of
CO2equivalents annually. The biggest part of it is emitted by the public electricity and heat production. Coal, oil and gas are the
major sources. Therefore, the fundamental and rapid change of fossil-based energy supply towards clean, emissions- and wastefree sources lies at the heart of a climate-protecting and –resilient society. WWF fully supports the global scientific consensus of
the Intergovernmental Panel on Climate Change (IPCC). The more than 20-year long work of this body of the most outstanding
scientists has shown that human-induced Global Warming of more than 2 degree Celsius threatens the fragile balance of our
planet’s ecosystems, and could consign a quarter of all species to extinction. Associated sea level rise will threaten many coastal
areas and the existence of entire small island nations and put global food security at a very high risk just to name a few of key
potential impacts. We therefore support the various UN agreements and those by the Least Developed Countries in particular, to
stay well below 2 degree Global Warming. To have a decent chance to do this, GHG emissions will need to be reduced by 80%
by 2050 compared to 1990. Because some sectors of human activities, in particular agricultural land use, may have problems to
radically reduce GHG emissions that are intrinsically linked to necessary food production, the energy sector is most suitable for a
radical shift towards zero emissions. It generally has the potentials and the technologies to do so. Therefore, WWF’s global vision
is to reach l00% sustainable renewable energy by 2050. Science tells us that this is both possible and necessary to avoid
dangerous climate change and to eventually limit global warming to no more than 1.5 degree Celsius increase compared to preindustrial levels. But we should be clear on the science. Though it will avoid even larger, irreversible and very disruptive climate
impacts, even 1.5 degree of warming will unavoidably cause havoc in many places. WWF's energy vision is set out in The Energy
Report -100% Renewable Energy by 2050 (available at: www.wwf.at/de/energy-report/). The Energy Report shows that l00%
renewable energy is technologically possible and economically feasible at a global scale, and will bring many benefits such as
less carbon and other pollution, better human health and providing universal access to clean energy for the poor. Success of
such a comprehensive decarbonisation of energy supply in next decades is highly linked to simultaneous achievements of
upscaling energy saving & efficiency and conservation in all societal energy-consuming sectors. • Not every country or region will
be able to produce domestically all renewables needed. Population density, inadequate weather conditions, biodiversity
conservation priority areas, etc. may not allow for that. Therefore, unmitigated trade of clean renewable energy and most energyefficient products across borders is necessary. In the case of electricity that means substantive cross-border grid infrastructure to
accommodate the flow of green electrons most cost-effectively. • Energy saving and efficiency are prerequisites to achieve a
renewable energy future. Also renewables have limits. May those be derived from the water and land availability for bioenergy
and hydropower or from the material needs for energy conversion technologies of wind and solar, such as demand for Rare Earth
minerals, more copper for grid infrastructure and lithium for batteries. Energy efficiency and material efficiency need to be part of
a clean energy world. Solutions exist in every sector to deliver substantive energy and material savings and their potential is still
largely untapped. • All renewables, in particular hydropower and bioenergies, must be planned, developed and managed
sustainably in order to avoid potentially adverse effects on livelihoods, food security, climate, biodiversity and ecosystems. • The
use of fossil fuels (coal, oil and gas) will need to decrease rapidly and be phased out in line with a pathway to 100% clean
renewable energy. The IEA suggests that maintaining a 50/50 chance to not overstep the 2-degree C threshold, the world must
retire and leave below ground 2/3 of the present global fossil fuel reserves. Other scientists show that in order to stay well below
2-degree C that it be rather 80% of all fossil fuel reserves that stay untouched. Unfortunately, the world is moving into another
direction. Scientists also show that a 3-degree and even 4-degree world with its disastrous consequences for human and nature
as shown recently by the World Bank will have to leave a large portion of fossil fuel reserves unburned. As those temperature
options are unacceptable for WWF, to have a decent chance to stay well below 2 degree, WWF demands to leave the large
majority of the fossil fuels untouched and particularly those with the largest carbon footprint. For the European climate and energy
policy that means, unacceptable risks of climate change can only be avoided if developed countries reduce their greenhouse gas
emissions by 40% by 2020 and by 95% by 2050. Achieving this will increase the odds of staying below 2°C warming WWF has a
vision of a world that is powered by 100% renewable energy sources by 2050. The EU is committed to reducing greenhouse gas
emissions to 80-95% below 1990 levels by 2050. According to the European Commission's estimates outlined in the “Roadmap
for moving to a competitive low carbon economy in 2050”, the most technologically and economically feasible means of achieving
this, is a total decarbonisation of the energy sector by 2050. The consequences for energy investments: To have a reasonable
chance of staying within a 2°C rise for the global climate, the IEA has stated that only zero-carbon utilities and infrastructure
should be developed beyond 2017 since 80% of cumulative emissions allowable between 2010 and 2035 are already locked-into
existing power plants, factories, buildings and services - unless existing infrastructure is scrapped before the end of its economic
lifespan. In addition, it implies that investments that prolong the overall lifetime emissions of a project actually add to the
cumulative total annual GHG emissions. No coal and lignite fired Generation: Given the urgency of climate change there is no
room for a policy that supports new coal and lignite fired generation in the EU power system. This implies that coal and lignite
fired generation should not be supported by the Energy Community. This no-coal-position should include • coal ‐ fired combined
heat and power (CHP): given the long plant lifetime and marginal efficiency gains, the risk of failure of the EU decarbonisation
goal by 2050 is too high. • refurbishment, retrofitting and replacement of coal-fired plants. While focussed refurbishment can limit
the emissions of various types of particles and lead to an improvement of air quality in the area, when refurbishment prolongs the
lifespan of the plant it leads to an absolute increase in GHG emissions compared to energy saving or renewable alternatives. It
creates a high risk scenario to contradict the decarbonisation of the EU energy sector committed by 2050. • CCS (carbon capture
and storage) technology is in the medium term very unlikely to be technically effective and commercially available as part of a
competitive energy option, so CCS for coal should not be considered by the Energy Community. • The no-coal-position should
also include coal mining operations and relat
Comments about facilitation measures for PECIs
42
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
1. A binding energy saving plan has to be developed including an implementation plan with finance mechanisms and put into
force by national law. It needs to aim on the maximum energy saving potentials for all countries which are members of the Energy
Community as avoided energy consumption: a. reduces the need for production with all the related environmental impact and
costs b. needs investments with high level of job creation and regional added value c. reduced emissions what helps fighting
climate change and improves the health situation of the affected population d. reduces the energy costs for private people and
business sector e. reduces the dependence on energy imports and the related financial outflow 2. A binding decarbonisation plan
for the energy sector has to be adopted. Regarding the goal of decarbonisation of the energy sector, spending of public money
for fossil and nuclear power generation has to be stopped immediately by effective national law. According to climate/energy
science (e.g.: http://www.sei-international.org/publications?pid=1318) coal and oil use for electricity production has to phase out
by 2035 what is not even half way of the operational time of any additional capacity. Under this condition a cost/benefit analysis
can never be positive. 3. Spatial planning regulations have to be implemented based on strict sustainability criteria and Strategic
Environmental Assessments (SEAs) for energy production which effectively protect the existing biodiversity with special focus on
endangered ecosystems and species. It should also include potential areas for restoration of ecosystems like rivers or wetlands.
a. Landuse plans for all renewable energies should be developed which define nature protection zones without any energy
production, areas where energy infrastructure can be developed after a thorough EIA (environmental impact assessment) and
preferred development zones. b. These plans have to be developed with participation of civil society and affected populations. c.
They have to become the legal basis for spatial planning and related regulations. 4. For projects which fit under the conditions in
the paragraphs 1 to 3 above, clear and transparent rules for assessments and approvals by the authorities have to be used. 5.
For projects which fit under the conditions in the paragraphs 1 to 3 above, information about funding options should be provided
and national funding programs should be implemented.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG013
Comments on the project:
No investment in new capacity of coal based power or heat generation! There are huge external cost in health care, state
subsidies, technology dependence and environmental damage. Dust during mining and from chimneys is causing lung
diseases. Coal plants are the second biggest emitter of mercury, accounting for 24% of the global emissions. Fossil power
generation and low electricity prices are consuming high amounts of state subsidy money. All this external costs have to be
included in the calculation of a cost/benefit analysis. It is also not acceptable to build coal based plants with the condition of
a future CCS implementation. There is no clear evidence that in medium term CCS will be technically effective and cost
competitive. As the technology is still in development, there is no certainty about the right location of the plants. Thus CCS
is another highly incalculable risk of fossil fuels. Such destructive and high risk investments in fossil fuels would mislead the
limited funding which is highly needed for energy efficiency measures and renewable energies.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG022
Comments on the project:
No investment in new capacity of coal based power or heat generation! There are huge external cost in health care, state
subsidies, technology dependence and environmental damage. Dust during mining and from chimneys is causing lung
diseases. Coal plants are the second biggest emitter of mercury, accounting for 24% of the global emissions. Fossil power
generation and low electricity prices are consuming high amounts of state subsidy money. All this external costs have to be
included in the calculation of a cost/benefit analysis. It is also not acceptable to build coal based plants with the condition of
a future CCS implementation. There is no clear evidence that in medium term CCS will be technically effective and cost
competitive. As the technology is still in development, there is no certainty about the right location of the plants. Thus CCS
is another highly incalculable risk of fossil fuels. Such destructive and high risk investments in fossil fuels would mislead the
limited funding which is highly needed for energy efficiency measures and renewable energies.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG024
Comments on the project:
No investment in new capacity of coal based power or heat generation! There are huge external cost in health care, state
subsidies, technology dependence and environmental damage. Dust during mining and from chimneys is causing lung
diseases. Coal plants are the second biggest emitter of mercury, accounting for 24% of the global emissions. Fossil power
generation and low electricity prices are consuming high amounts of state subsidy money. All this external costs have to be
included in the calculation of a cost/benefit analysis. It is also not acceptable to build coal based plants with the condition of
a future CCS implementation. There is no clear evidence that in medium term CCS will be technically effective and cost
competitive. As the technology is still in development, there is no certainty about the right location of the plants. Thus CCS
43
is another highly incalculable risk of fossil fuels. Such destructive and high risk investments in fossil fuels would mislead the
limited funding which is highly needed for energy efficiency measures and renewable energies.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG024
Comments on the project:
No investment in new capacity of coal based power or heat generation! There are huge external cost in health care, state
subsidies, technology dependence and environmental damage. Dust during mining and from chimneys is causing lung
diseases. Coal plants are the second biggest emitter of mercury, accounting for 24% of the global emissions. Fossil power
generation and low electricity prices are consuming high amounts of state subsidy money. All this external costs have to be
included in the calculation of a cost/benefit analysis. It is also not acceptable to build coal based plants with the condition of
a future CCS implementation. There is no clear evidence that in medium term CCS will be technically effective and cost
competitive. As the technology is still in development, there is no certainty about the right location of the plants. Thus CCS
is another highly incalculable risk of fossil fuels. Such destructive and high risk investments in fossil fuels would mislead the
limited funding which is highly needed for energy efficiency measures and renewable energies.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG025
Comments on the project:
No investment in new capacity of coal based power or heat generation! There are huge external cost in health care, state
subsidies, technology dependence and environmental damage. Dust during mining and from chimneys is causing lung
diseases. Coal plants are the second biggest emitter of mercury, accounting for 24% of the global emissions. Fossil power
generation and low electricity prices are consuming high amounts of state subsidy money. All this external costs have to be
included in the calculation of a cost/benefit analysis. It is also not acceptable to build coal based plants with the condition of
a future CCS implementation. There is no clear evidence that in medium term CCS will be technically effective and cost
competitive. As the technology is still in development, there is no certainty about the right location of the plants. Thus CCS
is another highly incalculable risk of fossil fuels. Such destructive and high risk investments in fossil fuels would mislead the
limited funding which is highly needed for energy efficiency measures and renewable energies.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG026
Comments on the project:
No investment in new capacity of coal based power or heat generation! There are huge external cost in health care, state
subsidies, technology dependence and environmental damage. Dust during mining and from chimneys is causing lung
diseases. Coal plants are the second biggest emitter of mercury, accounting for 24% of the global emissions. Fossil power
generation and low electricity prices are consuming high amounts of state subsidy money. All this external costs have to be
included in the calculation of a cost/benefit analysis. It is also not acceptable to build coal based plants with the condition of
a future CCS implementation. There is no clear evidence that in medium term CCS will be technically effective and cost
competitive. As the technology is still in development, there is no certainty about the right location of the plants. Thus CCS
is another highly incalculable risk of fossil fuels. Such destructive and high risk investments in fossil fuels would mislead the
limited funding which is highly needed for energy efficiency measures and renewable energies.
Your Details
Title:
Spec.Sci Biology
First name:
Bjanka
Last name:
Prakljacic
Name of organization:
Center for Protection and Research of Birds
Job title:
Project coordinator for IPA projects
Address:
Piperska 370 A
44
Postcode:
18000
City:
Podgorica
Country:
Montenegro
Email: *
[email protected]
Phone No:
0038267450884
General Comments
You are invited to provide your general comments in this section
In principle, as a prospective EU Member we are concerned that Montenegro and other ETC countries, should become compliant
with EU Directives, Regulations, and Strategies in a timely manner. In the case of the energy sector we regard the 20/20/20
Targets and the 2050 Road Map as strategic goals required of all member states and since energy projects take many years to
come “on-line” and have a life span of at least 30 or 40 years we should not be investing in projects now which will have to be
reversed in the future or lead to carbon lock in which would be expensive to reverse in the medium term. Our specific concerns in
relation to this process: •If EU PCI criteria are used to select PECIs then the kind of projects which are eligible as PECIs need to
be similar to the proposed PCI projects, ie. transmission and storage projects, not generation Electricity generation is a large
source of greenhouse gas emissions in almost all the Energy Community Parties. Massive changes need to take place in the
region's energy sector in the next few decades. In the coming months an important new development will be taking place: the EU
is expected to approve binding targets for greenhouse gas emissions reductions by 2030. If the Energy Community countries are
to join the EU they need to start now with planning energy sectors aiming towards decarburization and massive greenhouse gas
emissions reductions, due to the long life of energy infrastructure, which can lock in carbon emissions. In smaller economies like
many of the Energy Community Parties, one power plant can make a massive difference to the energy sector of the country and
a country's CO2 emissions. Indeed, it can mean the difference between meeting greenhouse gas reduction targets and not
meeting them. The current Regional Energy Strategy conflicts with 2030 targets as in all scenarios, even the so-called
'sustainable' scenario, increases rather than decreases in greenhouse gas emissions from the energy sector are expected. Since
all the proposed PECIs derive their logic from this flawed strategy, supporting electricity generation projects that have not been
screened for their impact on a country's ability to meet 2030 greenhouse gas targets and the EU's 2050 decarburization policy
risks supporting investments which will either hinder the implementation of EU policy or have to be closed before the end of their
lifetimes. Since the PECI generation projects do not conform to the EU PCI model, and since they are based on a flawed
Regional Energy Strategy that has been criticized not only by NGOs but by four groups in the European Parliament, the
'generation' strand of the PECI should be completely halted until such time as ALL the defects above are revised. Additionally, for
future selection of PECIs, demand-side energy efficiency projects need to be made eligible in order to push forward investments
into this crucial area, for which the whole region has vast potential and a huge need, given the increasing levels of energy
poverty. While it may not be obvious that such projects are of a regional nature, projects which make use of the cost-cutting
potential of carrying out the same activity in several areas could and should be developed. General comments on energy
situation in Montenegro: - The PECI projects proposed by the Government’s energy policy which is to increase Montenegro’s
energy independence. However, this aspect of Government Policy needs to be balanced against other equally important
objectives which include maintaining the environment and quality of life of all citizens. - No connection with future demand and
energy balances - The current losses and inefficient use of energy in Montenegro are largely responsible for the existing deficit in
supply over demand.The potential savings in generation, transmission and use could be at least 20% while energy savings which
do not require significant investment are estimated at 13% or 4.4 Peta Joules. The combined losses of 850 GWh could be
substantially reduced, but Montenegrin governemnt is not specific in setting targets for reduction and does not make it clear
whether such improvements have been factored into the modelling of future patterns of supply and demand. Up to 84MW (270
GWh) representing 6.3% of the electricity requirement in 2012 can be achieved through rehabilitating existing power plants. - It
would be useful to evaluate the impact of say halving KAP’s demand and assuming KAP buys all its forecast demand from
outside Montenegro on the strategy and end user tariffs. - There is no real discussion of the future of Alumni plant Podgorica KAP and its impact on future energy requirements. Electricity consumption by KAP accounts for about 50% of all demand in
Montenegro and any substantial change in this demand would have significant impact on the energy sector. KAP energy
supplying contract with EPCG had expired in January 2013. due to big depths this industry has, so all future project and exports
must include analyse with and without KAP operationalization.
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
Fast-tracking of PECIs may be incompatible with ensuring the proper application of the EU environmental "Acquis” and reduce
transparency and accountability The selected PECI projects are expected to be “fast tracked” in terms of approvals and will be
earmarked for support with EU funds. We would like to ask you for details about what exactly this fast-tracking will and will not
mean in practice? The region's track record for the application of environmental, planning, and procurement processes is wholly
inadequate (see EU Progress Reports), and we are concerned that fast-tracking may further weaken these processes if not very
carefully targeted. It should not be assumed that the involvement of the European public banks would ensure against such flaws,
as there are currently several on-going investigations by the EBRD's and EIB's complaint mechanisms regarding such issues in
45
projects in the Energy Community region, as well as an on-going OLAF investigation against the EIB regarding Sostanj 6.
Although the Energy Community parties have adopted EU Environmental Impact Assessment legislation, the legislation on nature
protection (eg. the Bird and Habitats Directives, Water Framework Directive) is far behind in its implementation and is not
required by the Energy Community. Yet energy infrastructure is being planned in areas which would have been better protected
had they been in the EU (eg. Ombla hydropower plant, Croatia, Boskov Most hydro plant, Macedonia), thus leading to double
standards. If PECI projects are to be given a stamp of approval by the ECTS – an EC funded institution – then they should also
be subject to best practices in transparency and accountability. Also the EU Climate Commissioner Connie Hedegaard has
recently urged the EBRD, the EIB and the World Bank to phase out lending to fossil fuels. Commissioner Hedegaard stated that
“she is particularly keen to see three international financial institutions – the European Investment Bank, the European Bank for
Reconstruction and Development, and the World Bank – join with their EU and OECD partners to take a lead role in eliminating
public support for fossil fuels. Together, these three institutions lend more than €130 billion ($168 billion) annually for projects in
Europe and beyond, and maintain a strong advisory role in beneficiary countries. This year provides an especially important
opportunity to use this potential for action." We strongly support this proposal and believe that the ECTS as an European
Commission funded institution should also apply this logic; especially for perspective member states.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG002
Comments on the project:
Detail plans and EIA for building HE Buk Bijela and Foca at Drina river were not done in transparent way and trasnboundary
impact assessment to Montenegro is poorly analyzed. Legal procedures in EIA development were not respected especially
related to the transboundary impacts (art. 3 ESPOO convention) and public participation processes. It is very important as
predicted dams and accumulation might impact Tara river (Montenegrin no go area) and National Park Durmitor which are
identified as important sites at a global area (UNESCO World Heritage), European (Durmitor and Tara River Emerald sites
under the Bern Convention) and national level (national reservoir of nature Crna Poda and Piva) areas a consequence. We
hence strongly recommend careful and interdisciplinary research and analysis of the transboundary impact after which a
conclusion on the feasibility of the plants can be drawn. 1. The EIA states that the project on HE Foca is expected to flood
163,30 ha at the borders with Montenegro, but the exact boundaries of the reservoirs are not clear; 2. The transboundary
ecological baseline situation is not described, hence analysing the impact is not really possible to the reader. WWF and
Green Home are interested in receiving the baseline scenario documentations 3. The project is located at the borders with
Montenegro but no consultation has been held and no analysis of transboundary impacts have been done, as required by
the Espoo Convention signed by Bosnia and Herzegovina and Montenegro in 2009, hence no evidence is provided of lack
of transboundary impacts; 4. According to the Stabilization and Association Agreement signed on 16 June 2008 by Bosnia
and Herzegovina, the country should take concrete steps to comply with the EU relevant legislation (e.g. Water Framework
Directive, Habitats Directive). In this sense, the EIA should further explain whether the project will be in compliance with EU
legislation or not and if not what are future steps to be taken. We call BiH Government to: 1. Analyse the transboundary
impact and substantiate it with baseline data. WWF and Green Home are interested in receiving copies of the
documentation used for baseline analysis. 2. Carry out a cross-border consultation on the transboundary impact of Buk
Bjela in accordance with international agreements; 3. Verify the compliance of the Buk Bjela project with relevant EU
legislation; 4. Set up a mechanism to monitor the appropriate implementation of mitigation measures, eventually setting-up
a monitoring commission. WWF and GH are willing to engage in this process.
Project Comment Form
Project number (ID and code) as indicated in the list:
ET017
Comments on the project:
The project promoter is Crnogorski Elektroprenosni Sistem (CGES), the electricity transmission system operator of
Montenengro, which is partly owned by Italian company Terna. Terna was able to gain shares in transmission company
Crnogorski elektroprenos (CGES), without a tender at all, due to a law passed especially for the undersea cable. Agreement
between Montenegrin Ministry of economy, CGES and Terna is signed in November 2010. On publication of this contract
Montenegrin citizens has waited seven months. Some parts of the contract have been removed and estimate as
confidential. In the case of delay in the realization of one of the contracting parties shall be charged penalties. The right for
termination of the contract and paying damages is not available for the public as well as deadlines for the adoption of
planning decisions, obtaining building permits and the purchase of equipment. The documents that exist so far for this
project, including the Detailed Spatial Plan (DSP) for the transmission line and related undersea cable and the associated
Strategic Environmental Assessment, fail to address the question of whether and why, energy and economy wise,
Montenegro needs the envisaged transmission line. It is clear that energy export does bring benefits for Montenegro, but it
is not clear what these benefits are, what are the disadvantages. We therefore invite the you to reconsider following issues:
The first is about the environmental impact of the generation projects (mainly hydropower) that are envisaged. The second
is about the impact on the electricity market in the Western Balkans itself. Problems may be caused by contracts requiring
the Italian market to be supplied with electricity even at times when that electricity may be needed in the Balkan region.
Another issue is that Balkan countries – especially those wishing to enter the EU – need to develop their own
environmentally appropriate renewable sources of energy. Each country has a specific potential, and every renewables
installation that is bound by contract to supply electricity to Italy for the coming decades diminishes that potential and makes
it harder for the Balkan countries to increase the share of renewable energy in their own grids. The Detail Spatial Plan for
46
example leaves the issue whether the future power line will be part of Montenegrin transmission system open: Apart from
not being aligned with the power and transmission grid facilities envisaged by the Spatial Plan of Montenegro, for the whole
length of the transmission line there is only one substation foreseen where power would be transferred to the domestic 220
kV, 110 kV or 35 kV grid. This could lead to the conclusion that the whole transmission line is envisaged only for the transit
of power from Montenegro, Serbia and Bosnia and Herzegovina to Italy, in which case it does not constitute an
improvement of the domestic transmission grid. Regarding economic benefits, according to preliminary studies it is
expected that the revenues of EPCG, the Montenegrin electricity company, would increase in the first year by EUR 5 to 6
million, and during full use by EUR 10 to 11 million, promising that this revenue would be used to offset transmission costs
payable by Montenegrin consumers. There is no mention that this revenue is accrued by a company in mixed ownership
which at some point may become a fully private one, and that there is thus no guarantee at all that there will be public
benefits from this additional income. The DSP lists the future power sources in Montenegro that this transmission line would
serve: Moraca HPPs, Komarnica HPP, Berane TPP, a wind power plant at Krnovo, as well as a group of small hydros in the
municipality of Šavnik. The DSP also mentions the possible construction of the Buk Bijela HPP, thus overlooking the fact
that the project has already failed once and the protection of the Tara River has been reinforced by a Declaration of the
Parliament of Montenegro. The above energy sources are problematic for five reasons: • The possible future energy
sources are planned with the existing power system of Montenegro in mind , and it is far from clear that there will be
additional capacity for export. • These installations may never be built – the tender for the Moraca HPPs has already failed,
for example. • If they are built, several of these facilities will have highly negative environmental impacts. The Moraca and
Buk Bijela HPPs have been the most notorious in this respect. • The Balkans region is having more and more problems with
hydropower output in relation to the changing weather patterns and increased frequency of dry periods, thus making energy
planning involving hydropower very unreliable. • As the above mention on Berana TPP hints, once the line is in place, if it
has sufficient capacity it may also serve to export non-renewable energy to Italy, thus leaving the people of Montenegro to
bear the external costs and risks of energy sources such as coal or nuclear. In our opinion this project is not in accordance
with the principles of environmental sustainability. The reasons for this we have listed below: The planned project for
transmission cabal will going through a national parks Durmitor and Lovcen (I zone of NP Durmitor and II zone of NP
Lovcen). Planned route of the transmission line passes through the protection zone a NP Durmitor, which requires strict
protection under the Law for Nature Protection (Article 54). The same law states that a national park in prohibited acts and
conduct activities and carry out activities that threaten the authenticity of the park (Article 39); Management Plan for
National Park, Durmitor states that "Preservation, promotion and protection of nature, particular values and immovable
cultural assets in the protection zone defines the mode and degree of protection in which these objects according to the Law
for nature protection are strictly protected areas earmarked for scientific research organized, controlled education, more
strictly controlled public presentation, no activities that would in any way disturb the original environment and immovable
cultural property "; According ESIA transmission line will pass through four Emerald areas (Lovcen, Durmitor, rivers
Komarnica and Tara) as future Natura 2000 (which is one of steps that Montenegro will be EU member). The territory on
which plans to build a substation and a converter plant is habitat for specie (Juncetalia maritime) which is found in Annex 1
of the European Directives on habitats that indicates its vulnerability not only in Montenegro but in all Europe. The planned
route of the transmission line would pass close to Lakes Slano andI Krupac that representing IBA areas which will be
directly transferred to the Natura 2000 areas. One of the categories under which the Durmitor and Tara are declared for
UNESCO is their important visual and landscape impact. Landscape can be classified as highly sensitive non tolerant to
changes and it is evaluate on the International level. The proposed route through the Durmitor and Tara River canyon
according ESIA will used existing 110 kV Zabljak - Pljevlja. pillars of the existing 110 kV transmission line are height
approximately 20 and 25 meters. To receive both lines (existing and proposed 110 kV 400 kV) are planned combined
towers height of 40 to 50 meters. Height of trees in this area ranged from 12 to 15 meters and therefore the transmission
line will be visually obscured by trees, but will be very visible in the surrounding landscape. In this way, it threatens one of
the important criteria for which this area was declared as a highly important at the international level. A serious analysis of
alternative solutions is hindered by the lack of clear analysis of Montenegro's needs and the extent to which Montenegro
does or does not have an energy deficit or surplus. The Draft DSP for the transmission and the undersea line fail to refer to
the excerpt from the Energy Strategy of Montenegro that there is “a gap of many years in developing own energy sources, a
highly pronounced import dependence for more than
Your Details
Title:
Mr
First name:
Aleksandar
Last name:
Perovic
Name of organization:
Environmental movement OZON
Job title:
director
Address:
Serdara Jola Piletica bb
Postcode:
81400
47
City:
Niksic
Country:
Montenegro
Email: *
[email protected]
Phone No:
+382 40 241 063
General Comments
You are invited to provide your general comments in this section
In principle, as a prospective EU Member we are concerned that Montenegro and other ETC countries, should become compliant
with EU Directives, Regulations, and Strategies in a timely manner. In the case of the energy sector we regard the 20/20/20
Targets and the 2050 Road Map as strategic goals required of all member states and since energy projects take many years to
come “on-line” and have a life span of at least 30 or 40 years we should not be investing in projects now which will have to be
reversed in the future or lead to carbon lock in which would be expensive to reverse in the medium term. Our specific concerns in
relation to this process: •If EU PCI criteria are used to select PECIs then the kind of projects which are eligible as PECIs need to
be similar to the proposed PCI projects, ie. transmission and storage projects, not generation Electricity generation is a large
source of greenhouse gas emissions in almost all the Energy Community Parties. Massive changes need to take place in the
region's energy sector in the next few decades. In the coming months an important new development will be taking place: the EU
is expected to approve binding targets for greenhouse gas emissions reductions by 2030. If the Energy Community countries are
to join the EU they need to start now with planning energy sectors aiming towards decarburization and massive greenhouse gas
emissions reductions, due to the long life of energy infrastructure, which can lock in carbon emissions. In smaller economies like
many of the Energy Community Parties, one power plant can make a massive difference to the energy sector of the country and
a country's CO2 emissions. Indeed, it can mean the difference between meeting greenhouse gas reduction targets and not
meeting them. The current Regional Energy Strategy conflicts with 2030 targets as in all scenarios, even the so-called
'sustainable' scenario, increases rather than decreases in greenhouse gas emissions from the energy sector are expected. Since
all the proposed PECIs derive their logic from this flawed strategy, supporting electricity generation projects that have not been
screened for their impact on a country's ability to meet 2030 greenhouse gas targets and the EU's 2050 decarburization policy
risks supporting investments which will either hinder the implementation of EU policy or have to be closed before the end of their
lifetimes. Since the PECI generation projects do not conform to the EU PCI model, and since they are based on a flawed
Regional Energy Strategy that has been criticized not only by NGOs but by four groups in the European Parliament, the
'generation' strand of the PECI should be completely halted until such time as ALL the defects above are revised. Additionally, for
future selection of PECIs, demand-side energy efficiency projects need to be made eligible in order to push forward investments
into this crucial area, for which the whole region has vast potential and a huge need, given the increasing levels of energy
poverty. While it may not be obvious that such projects are of a regional nature, projects which make use of the cost-cutting
potential of carrying out the same activity in several areas could and should be developed. General comments on energy
situation in Montenegro: - The PECI projects proposed by the Government’s energy policy which is to increase Montenegro’s
energy independence. However, this aspect of Government Policy needs to be balanced against other equally important
objectives which include maintaining the environment and quality of life of all citizens. - No connection with future demand and
energy balances - The current losses and inefficient use of energy in Montenegro are largely responsible for the existing deficit in
supply over demand.The potential savings in generation, transmission and use could be at least 20% while energy savings which
do not require significant investment are estimated at 13% or 4.4 Peta Joules. The combined losses of 850 GWh could be
substantially reduced, but Montenegrin governemnt is not specific in setting targets for reduction and does not make it clear
whether such improvements have been factored into the modelling of future patterns of supply and demand. Up to 84MW (270
GWh) representing 6.3% of the electricity requirement in 2012 can be achieved through rehabilitating existing power plants. - It
would be useful to evaluate the impact of say halving KAP’s demand and assuming KAP buys all its forecast demand from
outside Montenegro on the strategy and end user tariffs. - There is no real discussion of the future of Alumni plant Podgorica KAP and its impact on future energy requirements. Electricity consumption by KAP accounts for about 50% of all demand in
Montenegro and any substantial change in this demand would have significant impact on the energy sector. KAP energy
supplying contract with EPCG had expired in January 2013. due to big depths this industry has, so all future project and exports
must include analyse with and without KAP operationalization.
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
Fast-tracking of PECIs may be incompatible with ensuring the proper application of the EU environmental "Acquis” and reduce
transparency and accountability The selected PECI projects are expected to be “fast tracked” in terms of approvals and will be
earmarked for support with EU funds. We would like to ask you for details about what exactly this fast-tracking will and will not
mean in practice? The region's track record for the application of environmental, planning, and procurement processes is wholly
inadequate (see EU Progress Reports), and we are concerned that fast-tracking may further weaken these processes if not very
carefully targeted. It should not be assumed that the involvement of the European public banks would ensure against such flaws,
as there are currently several on-going investigations by the EBRD's and EIB's complaint mechanisms regarding such issues in
projects in the Energy Community region, as well as an on-going OLAF investigation against the EIB regarding Sostanj 6.
Although the Energy Community parties have adopted EU Environmental Impact Assessment legislation, the legislation on nature
48
protection (eg. the Bird and Habitats Directives, Water Framework Directive) is far behind in its implementation and is not
required by the Energy Community. Yet energy infrastructure is being planned in areas which would have been better protected
had they been in the EU (eg. Ombla hydropower plant, Croatia, Boskov Most hydro plant, Macedonia), thus leading to double
standards. If PECI projects are to be given a stamp of approval by the ECTS – an EC funded institution – then they should also
be subject to best practices in transparency and accountability. Also the EU Climate Commissioner Connie Hedegaard has
recently urged the EBRD, the EIB and the World Bank to phase out lending to fossil fuels. Commissioner Hedegaard stated that
“she is particularly keen to see three international financial institutions – the European Investment Bank, the European Bank for
Reconstruction and Development, and the World Bank – join with their EU and OECD partners to take a lead role in eliminating
public support for fossil fuels. Together, these three institutions lend more than €130 billion ($168 billion) annually for projects in
Europe and beyond, and maintain a strong advisory role in beneficiary countries. This year provides an especially important
opportunity to use this potential for action." We strongly support this proposal and believe that the ECTS as an European
Commission funded institution should also apply this logic; especially for perspective member states.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG002
Comments on the project:
Hydro Power System of Upper Drina - HPP Buk Bijela, HPP Foča, HPP Paunci, HPP Sutjeska Project number (ID and
code) as indicated in the list: EG002 Comments on the project: Detail plans and EIA for building HE Buk Bijela and Foca at
Drina river were not done in transparent way and trasnboundary impact assessment to Montenegro is poorly analyzed.
Legal procedures in EIA development were not respected especially related to the transboundary impacts (art. 3 ESPOO
convention) and public participation processes. It is very important as predicted dams and accumulation might impact Tara
river (Montenegrin no go area) and National Park Durmitor which are identified as important sites at a global area (UNESCO
World Heritage), European (Durmitor and Tara River Emerald sites under the Bern Convention) and national level (national
reservoir of nature Crna Poda and Piva) areas a consequence. We hence strongly recommend careful and interdisciplinary
research and analysis of the transboundary impact after which a conclusion on the feasibility of the plants can be drawn. 1.
The EIA states that the project on HE Foca is expected to flood 163,30 ha at the borders with Montenegro, but the exact
boundaries of the reservoirs are not clear; 2. The transboundary ecological baseline situation is not described, hence
analysing the impact is not really possible to the reader. WWF and Green Home are interested in receiving the baseline
scenario documentations 3. The project is located at the borders with Montenegro but no consultation has been held and no
analysis of transboundary impacts have been done, as required by the Espoo Convention signed by Bosnia and
Herzegovina and Montenegro in 2009, hence no evidence is provided of lack of transboundary impacts; 4. According to the
Stabilization and Association Agreement signed on 16 June 2008 by Bosnia and Herzegovina, the country should take
concrete steps to comply with the EU relevant legislation (e.g. Water Framework Directive, Habitats Directive). In this sense,
the EIA should further explain whether the project will be in compliance with EU legislation or not and if not what are future
steps to be taken. We call BiH Government to: 1. Analyse the transboundary impact and substantiate it with baseline data.
WWF and Green Home are interested in receiving copies of the documentation used for baseline analysis. 2. Carry out a
cross-border consultation on the transboundary impact of Buk Bjela in accordance with international agreements; 3. Verify
the compliance of the Buk Bjela project with relevant EU legislation; 4. Set up a mechanism to monitor the appropriate
implementation of mitigation measures, eventually setting-up a monitoring commission. WWF and GH are willing to engage
in this process.
Project Comment Form
Project number (ID and code) as indicated in the list:
ET017
Comments on the project:
400 kV OHL Pljevlja - Lastva Project number (ID and code) as indicated in the list: ET017 Comments on the project: The
project promoter is Crnogorski Elektroprenosni Sistem (CGES), the electricity transmission system operator of
Montenengro, which is partly owned by Italian company Terna. Terna was able to gain shares in transmission company
Crnogorski elektroprenos (CGES), without a tender at all, due to a law passed especially for the undersea cable. Agreement
between Montenegrin Ministry of economy, CGES and Terna is signed in November 2010. On publication of this contract
Montenegrin citizens has waited seven months. Some parts of the contract have been removed and estimate as
confidential. In the case of delay in the realization of one of the contracting parties shall be charged penalties. The right for
termination of the contract and paying damages is not available for the public as well as deadlines for the adoption of
planning decisions, obtaining building permits and the purchase of equipment. The documents that exist so far for this
project, including the Detailed Spatial Plan (DSP) for the transmission line and related undersea cable and the associated
Strategic Environmental Assessment, fail to address the question of whether and why, energy and economy wise,
Montenegro needs the envisaged transmission line. It is clear that energy export does bring benefits for Montenegro, but it
is not clear what these benefits are, what are the disadvantages. We therefore invite the you to reconsider following issues:
The first is about the environmental impact of the generation projects (mainly hydropower) that are envisaged. The second
is about the impact on the electricity market in the Western Balkans itself. Problems may be caused by contracts requiring
the Italian market to be supplied with electricity even at times when that electricity may be needed in the Balkan region.
Another issue is that Balkan countries – especially those wishing to enter the EU – need to develop their own
environmentally appropriate renewable sources of energy. Each country has a specific potential, and every renewables
installation that is bound by contract to supply electricity to Italy for the coming decades diminishes that potential and makes
49
it harder for the Balkan countries to increase the share of renewable energy in their own grids. The Detail Spatial Plan for
example leaves the issue whether the future power line will be part of Montenegrin transmission system open: Apart from
not being aligned with the power and transmission grid facilities envisaged by the Spatial Plan of Montenegro, for the whole
length of the transmission line there is only one substation foreseen where power would be transferred to the domestic 220
kV, 110 kV or 35 kV grid. This could lead to the conclusion that the whole transmission line is envisaged only for the transit
of power from Montenegro, Serbia and Bosnia and Herzegovina to Italy, in which case it does not constitute an
improvement of the domestic transmission grid. Regarding economic benefits, according to preliminary studies it is
expected that the revenues of EPCG, the Montenegrin electricity company, would increase in the first year by EUR 5 to 6
million, and during full use by EUR 10 to 11 million, promising that this revenue would be used to offset transmission costs
payable by Montenegrin consumers. There is no mention that this revenue is accrued by a company in mixed ownership
which at some point may become a fully private one, and that there is thus no guarantee at all that there will be public
benefits from this additional income. The DSP lists the future power sources in Montenegro that this transmission line would
serve: Moraca HPPs, Komarnica HPP, Berane TPP, a wind power plant at Krnovo, as well as a group of small hydros in the
municipality of Šavnik. The DSP also mentions the possible construction of the Buk Bijela HPP, thus overlooking the fact
that the project has already failed once and the protection of the Tara River has been reinforced by a Declaration of the
Parliament of Montenegro. The above energy sources are problematic for five reasons: • The possible future energy
sources are planned with the existing power system of Montenegro in mind , and it is far from clear that there will be
additional capacity for export. • These installations may never be built – the tender for the Moraca HPPs has already failed,
for example. • If they are built, several of these facilities will have highly negative environmental impacts. The Moraca and
Buk Bijela HPPs have been the most notorious in this respect. • The Balkans region is having more and more problems with
hydropower output in relation to the changing weather patterns and increased frequency of dry periods, thus making energy
planning involving hydropower very unreliable. • As the above mention on Berana TPP hints, once the line is in place, if it
has sufficient capacity it may also serve to export non-renewable energy to Italy, thus leaving the people of Montenegro to
bear the external costs and risks of energy sources such as coal or nuclear. In our opinion this project is not in accordance
with the principles of environmental sustainability. The reasons for this we have listed below: The planned project for
transmission cabal will going through a national parks Durmitor and Lovcen (I zone of NP Durmitor and II zone of NP
Lovcen). Planned route of the transmission line passes through the protection zone a NP Durmitor, which requires strict
protection under the Law for Nature Protection (Article 54). The same law states that a national park in prohibited acts and
conduct activities and carry out activities that threaten the authenticity of the park (Article 39); Management Plan for
National Park, Durmitor states that "Preservation, promotion and protection of nature, particular values and immovable
cultural assets in the protection zone defines the mode and degree of protection in which these objects according to the Law
for nature protection are strictly protected areas earmarked for scientific research organized, controlled education, more
strictly controlled public presentation, no activities that would in any way disturb the original environment and immovable
cultural property "; According ESIA transmission line will pass through four Emerald areas (Lovcen, Durmitor, rivers
Komarnica and Tara) as future Natura 2000 (which is one of steps that Montenegro will be EU member). The territory on
which plans to build a substation and a converter plant is habitat for specie (Juncetalia maritime) which is found in Annex 1
of the European Directives on habitats that indicates its vulnerability not only in Montenegro but in all Europe. The planned
route of the transmission line would pass close to Lakes Slano andI Krupac that representing IBA areas which will be
directly transferred to the Natura 2000 areas. One of the categories under which the Durmitor and Tara are declared for
UNESCO is their important visual and landscape impact. Landscape can be classified as highly sensitive non tolerant to
changes and it is evaluate on the International level. The proposed route through the Durmitor and Tara River canyon
according ESIA will used existing 110 kV Zabljak - Pljevlja. pillars of the existing 110 kV transmission line are height
approximately 20 and 25 meters. To receive both lines (existing and proposed 110 kV 400 kV) are planned combined
towers height of 40 to 50 meters. Height of trees in this area ranged from 12 to 15 meters and therefore the transmission
line will be visually obscured by trees, but will be very visible in the surrounding landscape. In this way, it threatens one of
the important criteria for which this area was declared as a highly important at the international level. A serious analysis of
alternative solutions is hindered by the lack of clear analysis of Montenegro's needs and the extent to which Montenegro
does or does not have an energy deficit or surplus. The Draft DSP for the transmission and the undersea line fail to refer to
the excerpt from the Energy Strategy of Montenegro tha
Your Details
Title:
Ms
First name:
Aleksandra
Last name:
Bujaroska
Name of organization:
Front 21/42
Job title:
Environmental lawyer
Address:
Postcode:
50
City:
Country:
Email: *
[email protected]
Phone No:
General Comments
You are invited to provide your general comments in this section
It is our view that the proposed PECIs: • Do not promote integration of the region into the EU energy system; • Will not contribute
to the integration of the region into EU markets; • Do not enhance investment in modern transmission infrastructure which would
be in line with EU practices and targets; • Undermine EU accession of the countries of the region and diminishes their chances of
reaching EU targets in terms of energy generation from renewables, achieving energy efficiency and reducing GHG emissions; •
Contribute to “ghetto-ising” of the region and locking us into outdated and non-viable practices; • Promote generation, instead of
focusing on energy efficiency and energy saving first, which would decrease the demand for energy generation. According to
Peter Johansen, a Senior Energy Specialist at World Bank, “one euro invested in energy efficiency helps avoid an investment of
2,2 euro in generation”. Some Macedonian experts hold the opinion that by using the right energy efficiency measures
Macedonia could save as much energy as one block of TPP Bitola produces; • Promote and plan for exports without prior solving
of the in-country demand for energy. General comments on PECI projects nominated by Macedonian government: • The
generation projects which are nominated are based on an unstable and unpredictable energy source (hydro). The available data
regarding the hydrology is outdated, and also, the influence of climate change on the hydrology is not taken into account.
According to the Second National Communication on Climate Change “the overall water availability in the country for the year
2100 is expected to be reduced by 18% (estimate ranging from 13 to 23%. • The proposed projects focus only on using the hydro
potential for electricity generation, completely overlooking the possibilities that Macedonia has in generation from solar power and
wind power.
Project Comment Form
Project number (ID and code) as indicated in the list:
ET001-2
Comments on the project:
The project would support coal based infrastructure, thus locking the region in carbon intensive energy production which in
turn will result in not achieving the EU 2020 targets for reduction of emissions. Aside of this general comment, based on the
criteria for PECI listed in the Strategy document on pages 22-23, the project is not compliant with the following criteria: • III.
Security of supply - By using the lowest cost of available resources, while taking into account all externalities The project
supports coal-generated electricity which has an extremely high cost in externalities in terms of health costs, number of
deaths and social costs. • IV. Contribution to sustainable energy development – Facilitation of the development of
renewable energy sources As the project will connect to the Bitola thermal power plant, this project is non-eligible based on
this criterion, since it supports coal-dependency in Macedonia and the region, and coal is not and cannot be viewed as a
renewable source of energy. • IV. Contribution to sustainable energy development – Facilitation of replacing old and low
efficient technologies Instead of facilitating new renewables and new technologies, thus promoting the gradual phasing-out
of old and low efficient technologies, this project favours generation from coal, which is usually based on old and low
efficient technologies and locks the energy sector of the country into coal for as long as the Bitola thermal power plant is
operational. • IV. Contribution to sustainable energy development – Facilitation of reaching national carbon targets and
reducing GHG emissions As this project favours coal – generated electricity, not only will it not facilitate the reaching of
national carbon targets and reducing GHG emissions, but will increase them and thus reduce the chance of reaching
national carbon targets and reducing GHG emissions, and consequently, will reduce or seriously harm the chance of
reaching EU 2020 goals, possibly resulting in very high cost for purchasing carbon allowances. • IV. Contribution to
sustainable energy development – Contribution to economic development Viewed in the short term this project will
contribute to economic development. However, in the long term, it has a very negative economic impact due to it promoting
coal-generated electricity and promoting locking-in of carbon emissions for the life-duration of the thermal power plant. The
lock-in of emissions will cause high cost for buying carbon allowances after EU accession, thus seriously decreasing the
economic viability of the project. • V. Maturity of the project – Progress in realisation (feasibility study, EIA, FID, permits and
licences) The project is not in the same phase in Macedonian and in Albania. While in Macedonia it is already in the phase
of preparation of EIA study, it is only in feasibility study phase in Albania. Unless this project is jointly developed and is given
the same priority in both countries, it will result in locking in finances until the other country reaches the same maturity of the
project. Unless both countries find this project a priority and are working on its development seriously and jointly, it should
not be put as PECI. • VI. Commercial strength of the project – Level of public funding needed According to current plans, the
project on the Macedonian side will be funded by a combination of MEPSO’s funds and a credit line/bank loan, all of which
would be public money, since MEPSO is a state owned company.
Project Comment Form
51
Project number (ID and code) as indicated in the list:
EG007
Comments on the project:
Based on the criteria for PECI listed in the Strategy document on pages 22-23, the project is not compliant with the following
criteria: • I. Contribution to the implementation of Regional Energy Strategy’s objectives – Involves, and/or is developed with,
the cooperation of at least two Contracting parties, or between a Contracting Party and an EU Member State The project
does not involve two contracting parties. It was tendered several times, and although some EU based companies did apply,
they didn’t follow through. Chinese actors also expressed interest in the projects. • I. Contribution to the implementation of
Regional Energy Strategy’s objectives – Cross-border infrastructures The projects would include infrastructure that is only
relevant to Macedonia and therefore does not comply with this criterion. • III. Security of supply – Through diversification of
supply sources, supplying counterparts and routes The part about diversification of sources in this criterion is met, because
it is a difference from the usual case where coal is the main energy source. The part where this criterion is not met is these
two hydro power plants being very old projects which are based on hydrology data which are not relevant anymore,
therefore the security of supply they would give is very questionable. • IV. Contribution to sustainable energy development –
Facilitation of the development of renewable energy sources These two hydro power plants fall into the category of large
hydro power plants, the status of which as renewable energy sources is being under review at present by the European
Commission. It is our view that they do not facilitate development of renewable energy sources. • IV. Contribution to
sustainable energy development – Facilitation of replacing old and low efficient technologies The project is facilitating the
replacement of old and low efficient technologies, especially those related to coal-based generation, but the fact that the
project is being benched for approx. 30 years makes it alarmingly out-dated (the first project for Cebren dates from 1963
and the first feasibility study from 1973-74, while for Galiste the project dates from 1989-90, and a feasibility study dates
from 2003). • IV. Contribution to sustainable energy development – Contribution to economic development In our view, the
project does not comply with this criterion for several reasons. First of all, it does not contribute to economic development
because of its economical non-viability (It would take approx. 50 years for achieving return on investment, according to
some calculations even more (a speculation is 100 years of operation), which is why the investor who would take on this
project is granted operation rights of a fully operational hydro power plant (HPP Tikves) to cover the losses). Second, the
cumulative generation capacity would be at least 500MW, amounting to 2/3 of the largest capacity in Macedonia (which is
TPP Bitola of 675MW). In that case, if giving this project to a foreign investor, Macedonia could be exposed to vulnerability
in terms of price of the generated electricity. Third, although the hydro power plants would solve the problem of energy
imports if the hydrology is good, the fact that these projects are based on out-dated hydrology data remains and, in the very
likely case that the hydrology is not as good as foreseen in the project documentation, might result in locking in of finance
for building these power plants, and still needing energy imports. • IV. Contribution to sustainable energy development –
Economic, social and environmental viability The project does not comply with this criterion due to the fact that it is
economically not viable (It would take approx. 50 years for achieving return on investment, according to some calculations
even more (a speculation is 100 years of operation), which is why the investor who would take on this project is granted
operation rights of a fully operational hydro power plant (HPP Tikves) to cover the losses). The project would also have a
severe impact on the micro-climate in the Mariovo region, which is home to several endemic species and is an Emerald site.
• V. Maturity of the project – progress in realisation (feasibility study, EIA, FID, permits and licences) The project for these
two hydro power plants is very old – the project for HPP Cebren was first made in 1963 with a feasibility study made 10
years later (1973-74), while the project for HPP Galiste was made in 1989/90 with a feasibility study made in 2003. The two
projects have been tendered 6 times and although there were interested investors from EU countries, as well as from China,
they opted out of the investment. • V. Maturity of the project – Length of project realisation The date for commission of HPP
Cebren is set for year 2020 in the list of nominated PECI on the Energy Community website. This is highly unrealistic and
unachievable since according to project documentation the construction phase is 7 years and the tender procedure in 2013
fell through. Therefore, the date of commission listed in the PECI table on the Energy Community website is no longer
relevant since it cannot be achieved. • VI. Commercial strength of the project – Bankability The project would take too long a
time for starting profit generation, causing the state to be forced to grant the future operator rights to operate a fully
operational HPP Tikves for a period of 52 years in order to cover the losses.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG008
Comments on the project:
Based on the criteria for PECI listed in the Strategy document on pages 22-23, the project is not compliant with the following
criteria: • I. Contribution to the implementation of Regional Energy Strategy’s objectives – Involves, and/or is developed with,
the cooperation of at least two Contracting parties, or between a Contracting Party and an EU Member State The project
does not comply with this criterion because it does not involve two contracting parties. There is a potential interest from the
Chinese Corporation for water and energy (CWE) through a credit line obtained from the Chinese Investment Bank, but that
still does not help meet this criterion. • I. Contribution to the implementation of Regional Energy Strategy’s objectives –
Cross-border infrastructures The project does not comply with this criterion because all 12 HPPs in the project would be
infrastructures that are only relevant to Macedonia. • III. Security of supply – Through diversification of supply sources,
supplying counterparts and routes The part about diversification of sources in this criterion is met, because it is a difference
from the usual case where coal is the main energy source. The part where this criterion is not met is the project for these 12
hydro power plants is a very old one which is based on a hydrology which is not relevant anymore, therefore the security of
supply it would give is very questionable. • IV. Contribution to sustainable energy development – Facilitation of the
development of renewable energy sources The joint generation capacity of the project puts it in the category of large hydro
power plants, the status of which as renewable energy sources is being under review at present by the European
52
Commission. It is our view that this project does not facilitate development of renewable energy sources. • IV. Contribution
to sustainable energy development – Facilitation of replacing old and low efficient technologies The project is facilitating the
replacement of old and low efficient technologies, especially those related to coal-based generation, but the fact that the
project is present since year 1932 and is repeatedly being benched ever since then, makes it alarmingly out-dated (the first
project for the Vardarska Dolina system dates from 1932, and was revised in 1964. It is currently in the phase of
prefeasibility study). • IV. Contribution to sustainable energy development – Contribution to economic development The
project does not comply with this criterion for more than one reason. First of all, it does not contribute to economic
development because of its questionable economic viability and cost-benefit ratio - It would cost 1,2 billion euro to build,
would require changing the route of the railway in a certain part, would cause extreme environmental, as well as social
damage and the joint capacity of all 12 hydro power plants would be only 350MW. It is our opinion that the pre-feasibility
study for this project must be completely finished before even considering putting this project on the list of PECI. Second,
although the hydro power plants would help with the problem of energy imports if the hydrology is good, the fact that these
projects are based on out-dated hydrology data remains and, in the very likely case that the hydrology is not as good as
foreseen in the project documentation, might result in locking in of finance for building these power plants, and still needing
energy imports. • IV. Contribution to sustainable energy development – Economic, social and environmental viability The
project does not comply with this criterion due to the fact that it has severe environmental impact on the river Vardar (the
largest river in Macedonia) and on the surrounding area. It will also damage the Important Bird Area (IBA) and Emerald site
in Demir Kapija, which would mean compromising an Emerald site and a future Natura 2000 area. The railway passing
through the town of Veles would have to be relocated, causing problems with connectivity for the citizens of Veles and
exposing the project to severe opposition from local population. The economic viability of the project is also questionable
due to the fact that it is based on very old hydrology data which is not relevant at present. The economic viability can be
more realistically predicted only once the pre-feasibility study is completed. It is our opinion that until such a time, this
project should not be considered as a candidate for PECI. • V. Maturity of the project – progress in realisation (feasibility
study, EIA, FID, permits and licences) The project for these 12 hydro power plants is very old – the basic project originates
from year 1932 when it was discarded by the Committee of the League of Nations because it’s construction was neither
economically, nor technically viable. The project was revised in 1964. Since then, there was some interest for its
construction, but all investors have opted out due to non-rentability of the project. Currently it is at the stage of pre-feasibility
study, which puts it at very low maturity, although it has been present for more than 70 years. • V. Maturity of the project –
Length of project realisation The date for commission of the first two largest hydro power plants in the project (HPP Veles
and HPP Gradec) is set for year 2021 at the earliest, which is neither very realistic, nor achievable since the project is still at
a very early phase – pre-feasibility study. Therefore, it’s presence on the PECI list is questionable, especially when
considering the fact that the funds of 1.2 billion euro can be used for some other projects that would give faster results, such
as solar power plants.
Your Details
Title:
Ms
First name:
Sonja
Last name:
Zuber
Name of organization:
Analytica Gostivar, Association for Policy Research
Job title:
Research and Management Coordinator
Address:
Dame Gruev 7-8/3
Postcode:
1000
City:
Skopje
Country:
Macedonia
Email: *
[email protected]
Phone No:
+38923121948
General Comments
You are invited to provide your general comments in this section
It is our view that the proposed PECIs: • Do not promote integration of the region into the EU energy system; • Will not contribute
to the integration of the region into EU markets; • Do not enhance investment in modern transmission infrastructure which would
53
be in line with EU practices and targets; • Undermine EU accession of the countries of the region and diminishes their chances of
reaching EU targets in terms of energy generation from renewables, achieving energy efficiency and reducing GHG emissions; •
Contribute to “ghetto-ising” of the region and locking us into outdated and non-viable practices; • Promote generation, instead of
focusing on energy efficiency and energy saving first, which would decrease the demand for energy generation. According to
Peter Johansen, a Senior Energy Specialist at World Bank, “one euro invested in energy efficiency helps avoid an investment of
2,2 euro in generation”. Some Macedonian experts hold the opinion that by using the right energy efficiency measures
Macedonia could save as much energy as one block of TPP Bitola produces; • Promote and plan for exports without prior solving
of the in-country demand for energy. General comments on PECI projects nominated by Macedonian government: • The
generation projects which are nominated are based on an unstable and unpredictable energy source (hydro). The available data
regarding the hydrology is outdated, and also, the influence of climate change on the hydrology is not taken into account.
According to the Second National Communication on Climate Change “the overall water availability in the country for the year
2100 is expected to be reduced by 18% (estimate ranging from 13 to 23%. • The proposed projects focus only on using the hydro
potential for electricity generation, completely overlooking the possibilities that Macedonia has in generation from solar power and
wind power.
Project Comment Form
Project number (ID and code) as indicated in the list:
ET008-2
Comments on the project:
OHL 400kV Kosovo B (KS) – Skopje (MK) The project would support coal based infrastructure, thus locking the region in
carbon intensive energy production which in turn will result in not achieving the EU 2020 targets for reduction of emissions.
Aside of this general comment, based on the criteria for PECI listed in the Strategy document on pages 22-23, the project is
not compliant with the following criteria: • III. Security of supply - By using the lowest cost of available resources, while
taking into account all externalities The project supports coal-generated electricity which has an extremely high cost in
externalities in terms of health costs, number of deaths and social costs. • IV. Contribution to sustainable energy
development – Facilitation of the development of renewable energy sources As the project will connect Skopje to a new
coal-fired thermal power plant in Kosovo, this project is non-eligible based on this criterion, since it supports new coalgenerated energy, and coal is not and cannot be viewed as a renewable source of energy. • IV. Contribution to sustainable
energy development – Facilitation of replacing old and low efficient technologies Instead of facilitating new renewables and
new technologies, thus promoting the gradual phasing-out of old and low efficient technologies, this project favours
generation from coal, which is usually based on old and low efficient technologies and locks the energy sector of the country
into coal for the life-duration of a thermal power plant which is usually approx. 40 years. • IV. Contribution to sustainable
energy development – Facilitation of reaching national carbon targets and reducing GHG emissions As this project favours
coal –generated electricity, not only will it not facilitate the reaching of national carbon targets and reducing GHG emissions,
but will increase them and thus reduce the chance of reaching national carbon targets and reducing GHG emissions, and
consequently, will reduce or seriously harm the chance of reaching EU 2020 goals. • IV. Contribution to sustainable energy
development – Contribution to economic development Viewed in the short term this project will contribute to economic
development. However, in the long term, it has a very negative economic impact due to it promoting coal-generated
electricity and promoting locking-in of carbon emissions for the life-duration of the thermal power plant. The lock-in of
emissions will cause high cost for buying carbon emissions after EU accession, thus seriously decreasing the economic
viability of the project. • V. Maturity of the project - length of project realisation The project is not in the same phase in the
two countries, which would inevitably lead to locking-in of financial resources in either of the countries which begins
operations on this project first. While in Kosovo the planned date of commission for this project is year 2023, in Macedonia
the project is listed as long-term, leading us to believe that the commission date will be in the more distant future then year
2023. • V. Maturity of the project - Support from governments/local communities Although the project itself is not subject to
opposition, the coal-fired thermal power plants that it would connect to is very strongly opposed by the population of Kosovo
due to a very high cost in externalities (health, environmental, and social impact), low economic viability and locking-in of
carbon emissions. • VI. Commercial strength of the project – Level of public funding needed According to current plans, the
project on the Macedonian side will be funded by a combination of MEPSO’s funds and a credit line/bank loan, all of which
would be public money, since MEPSO is a state owned company.
Project Comment Form
Project number (ID and code) as indicated in the list:
ET001-2
Comments on the project:
400Kv OHL SS Bitola (MK) – SS Elbasan (AL) The project would support coal based infrastructure, thus locking the region
in carbon intensive energy production which in turn will result in not achieving the EU 2020 targets for reduction of
emissions. Aside of this general comment, based on the criteria for PECI listed in the Strategy document on pages 22-23,
the project is not compliant with the following criteria: • III. Security of supply - By using the lowest cost of available
resources, while taking into account all externalities The project supports coal-generated electricity which has an extremely
high cost in externalities in terms of health costs, number of deaths and social costs. • IV. Contribution to sustainable energy
development – Facilitation of the development of renewable energy sources As the project will connect to the Bitola thermal
power plant, this project is non-eligible based on this criterion, since it supports coal-dependency in Macedonia and the
region, and coal is not and cannot be viewed as a renewable source of energy. • IV. Contribution to sustainable energy
development – Facilitation of replacing old and low efficient technologies Instead of facilitating new renewables and new
54
technologies, thus promoting the gradual phasing-out of old and low efficient technologies, this project favours generation
from coal, which is usually based on old and low efficient technologies and locks the energy sector of the country into coal
for as long as the Bitola thermal power plant is operational. • IV. Contribution to sustainable energy development –
Facilitation of reaching national carbon targets and reducing GHG emissions As this project favours coal –
generatedelectricity, not only will it not facilitate the reaching of national carbon targets and reducing GHG emissions, but
will increase them and thus reduce the chance of reaching national carbon targets and reducing GHG emissions, and
consequently, will reduce or seriously harm the chance of reaching EU 2020 goals, possibly resulting in very high cost for
purchasing carbon allowances. • IV. Contribution to sustainable energy development – Contribution to economic
development Viewed in the short term this project will contribute to economic development. However, in the long term, it has
a very negative economic impact due to it promoting coal-generated electricity and promoting locking-in of carbon emissions
for the life-duration of the thermal power plant. The lock-in of emissions will cause high cost for buying carbon allowances
after EU accession, thus seriously decreasing the economic viability of the project. • V. Maturity of the project – Progress in
realisation (feasibility study, EIA, FID, permits and licences) The project is not in the same phase in Macedonian and in
Albania. While in Macedonia it is already in the phase of preparation of EIA study, it is only in feasibility study phase in
Albania. Unless this project is jointly developed and is given the same priority in both countries, it will result in locking in
finances until the other country reaches the same maturity of the project. Unless both countries find this project a priority
and are working on its development seriously and jointly, it should not be put as PECI. • VI. Commercial strength of the
project – Level of public funding needed According to current plans, the project on the Macedonian side will be funded by a
combination of MEPSO’s funds and a credit line/bank loan, all of which would be public money, since MEPSO is a state
owned company.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG007
Comments on the project:
Hydro Power Plants on Crna River – HPP Cebren and HPP Galiste Based on the criteria for PECI listed in the Strategy
document on pages 22-23, the project is not compliant with the following criteria: • I. Contribution to the implementation of
Regional Energy Strategy’s objectives – Involves, and/or is developed with, the cooperation of at least two Contracting
parties, or between a Contracting Party and an EU Member State The project does not involve two contracting parties. It
was tendered several times, and although some EU based companies did apply, they didn’t follow through. Chinese actors
also expressed interest in the projects. • I. Contribution to the implementation of Regional Energy Strategy’s objectives –
Cross-border infrastructures The projects would include infrastructure that is only relevant to Macedonia and therefore does
not comply with this criterion. • III. Security of supply – Through diversification of supply sources, supplying counterparts and
routes The part about diversification of sources in this criterion is met, because it is a difference from the usual case where
coal is the main energy source. The part where this criterion is not met is these two hydro power plants being very old
projects which are based on hydrology data which are not relevant anymore, therefore the security of supply they would
give is very questionable. • IV. Contribution to sustainable energy development – Facilitation of the development of
renewable energy sources These two hydro power plants fall into the category of large hydro power plants, the status of
which as renewable energy sources is being under review at present by the European Commission. It is our view that they
do not facilitate development of renewable energy sources. • IV. Contribution to sustainable energy development –
Facilitation of replacing old and low efficient technologies The project is facilitating the replacement of old and low efficient
technologies, especially those related to coal-based generation, but the fact that the project is being benched for approx. 30
yearsmakes it alarmingly out-dated(the first project for Cebren dates from 1963 and the first feasibility study from 1973-74,
while for Galiste the project dates from 1989-90, and a feasibility study dates from 2003). • IV. Contribution to sustainable
energy development – Contribution to economic development In our view, the project does not comply with this criterion for
several reasons. First of all, it does not contribute to economic development because of its economical non-viability (It would
take approx. 50 years for achieving return on investment, according to some calculations even more (a speculation is 100
years of operation), which is why the investor who would take on this project is granted operation rights of a fully operational
hydro power plant(HPP Tikves) to cover the losses). Second, the cumulative generation capacity would be at least 500MW,
amounting to 2/3 of the largest capacity in Macedonia (which is TPP Bitola of 675MW). In that case, if giving this project to a
foreign investor, Macedonia could be exposed to vulnerability in terms of price of the generated electricity. Third, although
the hydro power plants would solve the problem of energy imports if the hydrology is good, the fact that these projects are
based on out-dated hydrology data remains and, in the very likely case that the hydrology is not as good as foreseen in the
project documentation, might result in locking in of finance for building these power plants, and still needing energy imports.
• IV. Contribution to sustainable energy development – Economic, social and environmental viability The project does not
comply with this criterion due to the fact that it is economically not viable (It would take approx. 50 years for achieving return
on investment, according to some calculations even more (a speculation is 100 years of operation), which is why the
investor who would take on this project is granted operation rights of a fully operational hydro power plant (HPP Tikves) to
cover the losses). The project would also have a severe impact on the micro-climate in the Mariovo region, which is home to
several endemic species and is an Emerald site. • V. Maturity of the project – progress in realisation (feasibility study, EIA,
FID, permits and licences) The project for these two hydro power plants is very old – the project for HPP Cebren was first
made in 1963 with a feasibility study made 10 years later (1973-74), while the project for HPP Galiste was made in 1989/90
with a feasibility study made in 2003. The two projects have been tendered 6 times and although there were interested
investors from EU countries, as well as from China, they opted out of the investment. • V. Maturity of the project – Length of
project realisation The date for commission of HPP Cebren is set for year 2020 in the list of nominated PECI on the Energy
Community website. This is highly unrealistic and unachievable since according to project documentation the construction
phase is 7 years and the tender procedure in 2013 fell through. Therefore, the date of commission listed in the PECI table
on the Energy Community website is no longer relevant since it cannot be achieved. • VI. Commercial strength of the project
55
– Bankability The project would take too long a time for starting profit generation, causing the state to be forced to grant the
future operator rights to operate a fully operational HPP Tikves for a period of 52 years in order to cover the losses.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG008
Comments on the project:
Hydro Power Plants on River Vardar – 12HPPs Based on the criteria for PECI listed in the Strategy document on pages 2223, the project is not compliant with the following criteria: • I. Contribution to the implementation of Regional Energy
Strategy’s objectives – Involves, and/or is developed with, the cooperation of at least two Contracting parties, or between a
Contracting Party and an EU Member State The project does not comply with this criterion because it does not involve two
contracting parties. There is a potential interest from the Chinese Corporation for water and energy (CWE) through a credit
line obtained from the Chinese Investment Bank, but that still does not help meet this criterion. • I. Contribution to the
implementation of Regional Energy Strategy’s objectives – Cross-border infrastructures The project does not comply with
this criterion because all 12 HPPs in the project would be infrastructures that are only relevant to Macedonia. • III. Security
of supply – Through diversification of supply sources, supplying counterparts and routes The part about diversification of
sources in this criterion is met, because it is a difference from the usual case where coal is the main energy source. The
part where this criterion is not met is the project for these 12 hydro power plants is a very old one which is based on a
hydrology which is not relevant anymore, therefore the security of supply it would give is very questionable. • IV.
Contribution to sustainable energy development – Facilitation of the development of renewable energy sources The joint
generation capacity of the project puts it in the category of large hydro power plants, the status of which as renewable
energy sources is being under review at present by the European Commission. It is our view that this project does not
facilitate development of renewable energy sources. • IV. Contribution to sustainable energy development – Facilitation of
replacing old and low efficient technologies The project is facilitating the replacement of old and low efficient technologies,
especially those related to coal-based generation, but the fact that the project is present since year 1932 and is repeatedly
being benched ever since then, makes it alarmingly out-dated (the first project for the Vardarska Dolina system dates from
1932, and was revised in 1964. It is currently in the phase of prefeasibility study). • IV. Contribution to sustainable energy
development – Contribution to economic development The project does not comply with this criterion for more than one
reason. First of all, it does not contribute to economic development because of itsquestionable economic viability and costbenefit ratio - It would cost 1,2 billion euro to build, would require changing the route of the railway in a certain part, would
cause extreme environmental, as well as social damage and the joint capacity of all 12 hydro power plants would be only
350MW. It is our opinion that the pre-feasibility study for this project must be completely finished before even considering
putting this project on the list of PECI. Second, although the hydro power plants would help with the problem of energy
imports if the hydrology is good, the fact that these projects are based on out-dated hydrology data remains and, in the very
likely case that the hydrology is not as good as foreseen in the project documentation, might result in locking in of finance
for building these power plants, and still needing energy imports. • IV. Contribution to sustainable energy development –
Economic, social and environmental viability The project does not comply with this criterion due to the fact that it has severe
environmental impact on the river Vardar (the largest river in Macedonia) and on the surrounding area. It will also damage
the Important Bird Area (IBA) and Emerald site in Demir Kapija, which would mean compromising an Emerald site and a
future Natura 2000 area. The railway passing through the town of Veles would have to be relocated, causing problems with
connectivity for the citizens of Veles and exposing the project to severe opposition from local population. The economic
viability of the project is also questionable due to the fact that it is based on very old hydrology data which is not relevant at
present. The economic viability can be more realistically predicted only once the pre-feasibility study is completed. It is our
opinion that until such a time, this project should not be considered as a candidate for PECI. • V. Maturity of the project –
progress in realisation (feasibility study, EIA, FID, permits and licences) The project for these 12 hydro power plants is very
old – the basic project originates from year 1932 when it was discarded by the Committee of the League of Nations because
it’s construction was neither economically, nor technically viable. The project was revised in 1964. Since then, there was
some interest for its construction, but all investors have opted out due to non-rentability of the project. Currently it is at the
stage of pre-feasibility study, which puts it at very low maturity, although it has been present for more than 70 years. • V.
Maturity of the project – Length of project realisation The date for commission of the first two largest hydro power plants in
the project (HPP Veles and HPP Gradec) is set for year 2021 at the earliest, which is neither very realistic, nor achievable
since the project is still at a very early phase – pre-feasibility study. Therefore, it’s presence on the PECI list is questionable,
especially when considering the fact that the funds of 1.2 billion euro can be used for some other projects that would give
faster results, such as solar power plants.
Your Details
Title:
Ms
First name:
Iskra
Last name:
Stojkovska
56
Name of organization:
Front 21/42
Job title:
President
Address:
Vladimir Komarov 13/22
Postcode:
1000
City:
Skopje
Country:
Republic of Macedonia
Email: *
[email protected]
Phone No:
+389 2 3122 546
General Comments
You are invited to provide your general comments in this section
It is our view that the proposed PECIs: •Do not promote integration of the region into the EU energy system; •Will not contribute
to the integration of the region into EU markets; •Do not enhance investment in modern transmission infrastructure which would
be in line with EU practices and targets; •Undermine EU accession of the countries of the region and diminishes their chances of
reaching EU targets in terms of energy generation from renewable energy sources, achieving energy efficiency and reducing
GHG emissions; •Contribute to “ghetto-ising” of the region and locking us into outdated and non-viable practices; •Promote new
generation, instead of focusing on energy efficiency and energy saving first, which would decrease the demand for energy
generation. According to Peter Johansen, a Senior Energy Specialist at World Bank, “one euro invested in energy efficiency
helps avoid an investment of 2,2 euro in generation”. Some Macedonian experts hold the opinion that by using the right energy
efficiency measures Macedonia could save as much energy as one block of TPP Bitola produces; •Promote and plan for exports
without prior solving of the in-country demand for energy. General comments on PECI projects nominated by Macedonian
government: •The generation projects which are nominated are based on an unstable and unpredictable energy source (hydro).
The available data regarding the hydrology is outdated, and also, the influence of climate change on the hydrology is not taken
into account. According to the Second National Communication on Climate Change “the overall water availability in the country
by 2100 is expected to be reduced by 18% (estimate ranging from 13 to 23%). •The proposed projects focus only on using the
hydro potential for electricity generation, completely overlooking the possibilities that Macedonia has in generation from solar
power and wind power.
Project Comment Form
Project Comment Form
Project number (ID and code) as indicated in the list:
ET001-1
Comments on the project:
The project (OHL 400kV Kosovo B (KS) – Skopje (MK))would support coal based infrastructure, thus locking the region in
carbon intensive energy production which in turn will result in not achieving the EU 2020 targets for reduction of emissions.
Aside of this general comment, based on the criteria for PECI listed in the Strategy document on pages 22-23, the project is
not compliant with the following criteria: III Security of supply - By using the lowest cost of available resources, while taking
into account all externalities. The project supports coal-generated electricity which has an extremely high cost in
externalities in terms of health costs, number of deaths and social costs. IV. Contribution to sustainable energy development
– Facilitation of the development of renewable energy sources As the project will connect Skopje to a new coal-fired thermal
power plant in Kosovo, this project is non-eligible based on this criterion, since it supports new coal-generated energy, and
coal is not and cannot be viewed as a renewable source of energy. IV Contribution to sustainable energy development –
Facilitation of replacing old and low efficient technologies Instead of facilitating new renewables and new technologies, thus
promoting the gradual phasing-out of old and low efficient technologies, this project favours generation from coal, which is
usually based on old and low efficient technologies and locks the energy sector of the country into coal for the life-duration
of a thermal power plant which is usually approx. 40 years. IV Contribution to sustainable energy development – Facilitation
of reaching national carbon targets and reducing GHG emissions. As this project favours coal – generated electricity, not
only will it not facilitate the reaching of national carbon targets and reducing GHG emissions, but will increase them and thus
reduce the chance of reaching national carbon targets and reducing GHG emissions, and consequently, will reduce or
seriously harm the chance of reaching EU 2020 goals. IV Contribution to sustainable energy development – Contribution to
economic development Viewed in the short term this project will contribute to economic development. However, in the long
term, it has a very negative economic impact due to it promoting coal-generated electricity and promoting locking-in of
carbon emissions for the life-duration of the thermal power plant. The lock-in of emissions will cause high cost for buying
carbon emissions after EU accession, thus seriously decreasing the economic viability of the project. V Maturity of the
project - length of project realisation The project is not in the same phase in the two countries, which would inevitably lead to
57
locking-in of financial resources in either of the countries which begins operations on this project first. While in Kosovo the
planned date of commission for this project is year 2023, in Macedonia the project is listed as long-term, leading us to
believe that the commission date will be in the more distant future then year 2023. V Maturity of the project - Support from
governments/local communities Although the project itself is not subject to opposition, the coal-fired thermal power plants
that it would connect to is very strongly opposed by the population of Kosovo due to a very high cost in externalities (health,
environmental, and social impact), low economic viability and locking-in of carbon emissions. VI Commercial strength of the
project – Level of public funding needed According to current plans, the project on the Macedonian side will be funded by a
combination of MEPSO’s funds and a credit line/bank loan, all of which would be public money, since MEPSO is a state
owned company.
Project Comment Form
Project number (ID and code) as indicated in the list:
ET001-1
Comments on the project:
Based on the criteria for PECI listed in the Strategy document on pages 22-23, the project (Hydro Power Plants on Crna
River – HPP Cebren and HPP Galiste) is not compliant with the following criteria: I. Contribution to the implementation of
Regional Energy Strategy’s objectives – Involves, and/or is developed with, the cooperation of at least two Contracting
parties, or between a Contracting Party and an EU Member State The project does not involve two contracting parties. It
was tendered several times, and although some EU based companies did apply, they didn’t follow through. Chinese actors
also expressed interest in the projects. I. Contribution to the implementation of Regional Energy Strategy’s objectives –
Cross-border infrastructures The projects would include infrastructure that is only relevant to Macedonia and therefore does
not comply with this criterion. III. Security of supply – Through diversification of supply sources, supplying counterparts and
routes The part about diversification of sources in this criterion is met, because it is a difference from the usual case where
coal is the main energy source. The part where this criterion is not met is these two hydro power plants being very old
projects which are based on hydrology data which are not relevant anymore, therefore the security of supply they would
give is very questionable. IV. Contribution to sustainable energy development – Facilitation of the development of renewable
energy sources These two hydro power plants fall into the category of large hydro power plants, the status of which as
renewable energy sources is being under review at present by the European Commission. It is our view that they do not
facilitate development of renewable energy sources. IV. Contribution to sustainable energy development – Facilitation of
replacing old and low efficient technologies The project is facilitating the replacement of old and low efficient technologies,
especially those related to coal-based generation, but the fact that the project is being benched for approx. 30 years makes
it alarmingly out-dated (the first project for Cebren dates from 1963 and the first feasibility study from 1973-74, while for
Galiste the project dates from 1989-90, and a feasibility study dates from 2003). IV. Contribution to sustainable energy
development – Contribution to economic development In our view, the project does not comply with this criterion for several
reasons. First of all, it does not contribute to economic development because of its economical non-viability (It would take
approx. 50 years for achieving return on investment, according to some calculations even more (a speculation is 100 years
of operation), which is why the investor who would take on this project is granted operation rights of a fully operational hydro
power plant (HPP Tikves) to cover the losses). Second, the cumulative generation capacity would be at least 500MW,
amounting to 2/3 of the largest capacity in Macedonia (which is TPP Bitola of 675MW). In that case, if giving this project to a
foreign investor, Macedonia could be exposed to vulnerability in terms of price of the generated electricity. Third, although
the hydro power plants would solve the problem of energy imports if the hydrology is good, the fact that these projects are
based on out-dated hydrology data remains and, in the very likely case that the hydrology is not as good as foreseen in the
project documentation, might result in locking in of finance for building these power plants, and still needing energy imports.
IV. Contribution to sustainable energy development – Economic, social and environmental viability The project does not
comply with this criterion due to the fact that it is economically not viable (It would take approx. 50 years for achieving return
on investment, according to some calculations even more (a speculation is 100 years of operation), which is why the
investor who would take on this project is granted operation rights of a fully operational hydro power plant (HPP Tikves) to
cover the losses). The project would also have a severe impact on the micro-climate in the Mariovo region, which is home to
several endemic species and is an Emerald site. V. Maturity of the project – progress in realisation (feasibility study, EIA,
FID, permits and licences) The project for these two hydro power plants is very old – the project for HPP Cebren was first
made in 1963 with a feasibility study made 10 years later (1973-74), while the project for HPP Galiste was made in 1989/90
with a feasibility study made in 2003. The two projects have been tendered 6 times and although there were interested
investors from EU countries, as well as from China, they opted out of the investment. V. Maturity of the project – Length of
project realisation The date for commission of HPP Cebren is set for year 2020 in the list of nominated PECI on the Energy
Community website. This is highly unrealistic and unachievable since according to project documentation the construction
phase is 7 years and the tender procedure in 2013 fell through. Therefore, the date of commission listed in the PECI table
on the Energy Community website is no longer relevant since it cannot be achieved. VI. Commercial strength of the project
– Bankability The project would take too long a time for starting profit generation, causing the state to be forced to grant the
future operator rights to operate a fully operational HPP Tikves for a period of 52 years in order to cover the losses.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG008
Comments on the project:
Based on the criteria for PECI listed in the Strategy document on pages 22-23, the project is not compliant with the following
58
criteria: I. Contribution to the implementation of Regional Energy Strategy’s objectives – Involves, and/or is developed with,
the cooperation of at least two Contracting parties, or between a Contracting Party and an EU Member State The project
does not comply with this criterion because it does not involve two contracting parties. There is a potential interest from the
Chinese Corporation for water and energy (CWE) through a credit line obtained from the Chinese Investment Bank, but that
still does not help meet this criterion. I. Contribution to the implementation of Regional Energy Strategy’s objectives – Crossborder infrastructures The project does not comply with this criterion because all 12 HPPs in the project would be
infrastructures that are only relevant to Macedonia. III. Security of supply – Through diversification of supply sources,
supplying counterparts and routes The part about diversification of sources in this criterion is met, because it is a difference
from the usual case where coal is the main energy source. The part where this criterion is not met is the project for these 12
hydro power plants is a very old one which is based on a hydrology which is not relevant anymore, therefore the security of
supply it would give is very questionable. IV. Contribution to sustainable energy development – Facilitation of the
development of renewable energy sources The joint generation capacity of the project puts it in the category of large hydro
power plants, the status of which as renewable energy sources is being under review at present by the European
Commission. It is our view that this project does not facilitate development of renewable energy sources. IV. Contribution to
sustainable energy development – Facilitation of replacing old and low efficient technologies The project is facilitating the
replacement of old and low efficient technologies, especially those related to coal-based generation, but the fact that the
project is present since year 1932 and is repeatedly being benched ever since then, makes it alarmingly out-dated (the first
project for the Vardarska Dolina system dates from 1932, and was revised in 1964. It is currently in the phase of
prefeasibility study). IV. Contribution to sustainable energy development – Contribution to economic development The
project does not comply with this criterion for more than one reason. First of all, it does not contribute to economic
development because of its questionable economic viability and cost-benefit ratio - It would cost 1,2 billion euro to build,
would require changing the route of the railway in a certain part, would cause extreme environmental, as well as social
damage and the joint capacity of all 12 hydro power plants would be only 350MW. It is our opinion that the pre-feasibility
study for this project must be completely finished before even considering putting this project on the list of PECI. Second,
although the hydro power plants would help with the problem of energy imports if the hydrology is good, the fact that these
projects are based on out-dated hydrology data remains and, in the very likely case that the hydrology is not as good as
foreseen in the project documentation, might result in locking in of finance for building these power plants, and still needing
energy imports. IV. Contribution to sustainable energy development – Economic, social and environmental viability The
project does not comply with this criterion due to the fact that it has severe environmental impact on the river Vardar (the
largest river in Macedonia) and on the surrounding area. It will also damage the Important Bird Area (IBA) and Emerald site
in Demir Kapija, which would mean compromising an Emerald site and a future Natura 2000 area. The railway passing
through the town of Veles would have to be relocated, causing problems with connectivity for the citizens of Veles and
exposing the project to severe opposition from local population. The economic viability of the project is also questionable
due to the fact that it is based on very old hydrology data which is not relevant at present. The economic viability can be
more realistically predicted only once the pre-feasibility study is completed. It is our opinion that until such a time, this
project should not be considered as a candidate for PECI. V. Maturity of the project – progress in realisation (feasibility
study, EIA, FID, permits and licences) The project for these 12 hydro power plants is very old – the basic project originates
from year 1932 when it was discarded by the Committee of the League of Nations because it’s construction was neither
economically, nor technically viable. The project was revised in 1964. Since then, there was some interest for its
construction, but all investors have opted out due to non-rentability of the project. Currently it is at the stage of pre-feasibility
study, which puts it at very low maturity, although it has been present for more than 70 years. V. Maturity of the project –
Length of project realisation The date for commission of the first two largest hydro power plants in the project (HPP Veles
and HPP Gradec) is set for year 2021 at the earliest, which is neither very realistic, nor achievable since the project is still at
a very early phase – pre-feasibility study. Therefore, it’s presence on the PECI list is questionable, especially when
considering the fact that the funds of 1.2 billion euro can be used for some other projects that would give faster results, such
as solar power plants.
Your Details
Title:
Ms.
First name:
Nevena
Last name:
Smilevska
Name of organization:
Center for environmental research and information Eko-svest
Job title:
Project coordinator
Address:
11 Oktomvri 125/12
Postcode:
1000
City:
Skopje
Country:
Republic of Macedonia
59
Email: *
[email protected]
Phone No:
+389 2 3217 247
General Comments
You are invited to provide your general comments in this section
It is our view that the proposed PECIs: • Do not promote integration of the region into the EU energy system; • Will not contribute
to the integration of the region into EU markets; • Do not enhance investment in modern transmission infrastructure which would
be in line with EU practices and targets; • Undermine EU accession of the countries of the region and diminish their chances of
reaching EU targets in terms of energy generation from renewables, achieving energy efficiency and reducing GHG emissions; •
Contribute to “ghetto-ising” of the region and locking us into outdated and non-viable practices; • Promote generation, instead of
focusing on energy efficiency and energy saving first, which would decrease the demand for energy generation. According to
Peter Johansen, a Senior Energy Specialist at World Bank, “one euro invested in energy efficiency helps avoid an investment of
2,2 euro in generation”. Some Macedonian experts hold the opinion that by using the right energy efficiency measures
Macedonia could save as much energy as one block of TPP Bitola produces; • Promote and plan for exports without prior solving
of the in-country demand for energy. General comments on PECI projects nominated by Macedonian government: • The
generation projects which are nominated are based on an unstable and unpredictable energy source (hydro). The available data
regarding the hydrology is outdated, and also, the influence of climate change on the hydrology is not taken into account.
According to the Second National Communication on Climate Change “the overall water availability in the country for the year
2100 is expected to be reduced by 18% (estimate ranging from 13 to 23%. • The proposed projects focus only on using the hydro
potential for electricity generation, completely overlooking the possibilities that Macedonia has in generation from solar power and
wind power.
Project Comment Form
Project number (ID and code) as indicated in the list:
ET008-2
Comments on the project:
The project would support coal based infrastructure, thus locking the region in carbon intensive energy production which in
turn will result in not achieving the EU 2020 targets for reduction of emissions. Aside of this general comment, based on the
criteria for PECI listed in the Strategy document on pages 22-23, the project is not compliant with the following criteria: • III.
Security of supply - By using the lowest cost of available resources, while taking into account all externalities The project
supports coal-generated electricity which has an extremely high cost in externalities in terms of health costs, number of
deaths and social costs. • IV. Contribution to sustainable energy development – Facilitation of the development of
renewable energy sources As the project will connect Skopje to a new coal-fired thermal power plant in Kosovo, this project
is non-eligible based on this criterion, since it supports new coal-generated energy, and coal is not and cannot be viewed as
a renewable source of energy. • IV. Contribution to sustainable energy development – Facilitation of replacing old and low
efficient technologies Instead of facilitating new renewables and new technologies, thus promoting the gradual phasing-out
of old and low efficient technologies, this project favours generation from coal, which is usually based on old and low
efficient technologies and locks the energy sector of the country into coal for the life-duration of a thermal power plant which
is usually approx. 40 years. • IV. Contribution to sustainable energy development – Facilitation of reaching national carbon
targets and reducing GHG emissions As this project favours coal – generated electricity, not only will it not facilitate the
reaching of national carbon targets and reducing GHG emissions, but will increase them and thus reduce the chance of
reaching national carbon targets and reducing GHG emissions, and consequently, will reduce or seriously harm the chance
of reaching EU 2020 goals. • IV. Contribution to sustainable energy development – Contribution to economic development
Viewed in the short term this project will contribute to economic development. However, in the long term, it has a very
negative economic impact due to it promoting coal-generated electricity and promoting locking-in of carbon emissions for
the life-duration of the thermal power plant. The lock-in of emissions will cause high cost for buying carbon emissions after
EU accession, thus seriously decreasing the economic viability of the project. • V. Maturity of the project - length of project
realisation The project is not in the same phase in the two countries, which would inevitably lead to locking-in of financial
resources in either of the countries which begins operations on this project first. While in Kosovo the planned date of
commission for this project is year 2023, in Macedonia the project is listed as long-term, leading us to believe that the
commission date will be in the more distant future then year 2023. • V. Maturity of the project - Support from
governments/local communities Although the project itself is not subject to opposition, the coal-fired thermal power plants
that it would connect to is very strongly opposed by the population of Kosovo due to a very high cost in externalities (health,
environmental, and social impact), low economic viability and locking-in of carbon emissions. • VI. Commercial strength of
the project – Level of public funding needed According to current plans, the project on the Macedonian side will be funded
by a combination of MEPSO’s funds and a credit line/bank loan, all of which would be public money, since MEPSO is a
state owned company.
Project Comment Form
Project number (ID and code) as indicated in the list:
ET001-2
60
Comments on the project:
The project would support coal based infrastructure, thus locking the region in carbon intensive energy production which in
turn will result in not achieving the EU 2020 targets for reduction of emissions. Aside of this general comment, based on the
criteria for PECI listed in the Strategy document on pages 22-23, the project is not compliant with the following criteria: • III.
Security of supply - By using the lowest cost of available resources, while taking into account all externalities The project
supports coal-generated electricity which has an extremely high cost in externalities in terms of health costs, number of
deaths and social costs. • IV. Contribution to sustainable energy development – Facilitation of the development of
renewable energy sources As the project will connect to the Bitola thermal power plant, this project is non-eligible based on
this criterion, since it supports coal-dependency in Macedonia and the region, and coal is not and cannot be viewed as a
renewable source of energy. • IV. Contribution to sustainable energy development – Facilitation of replacing old and low
efficient technologies Instead of facilitating new renewables and new technologies, thus promoting the gradual phasing-out
of old and low efficient technologies, this project favours generation from coal, which is usually based on old and low
efficient technologies and locks the energy sector of the country into coal for as long as the Bitola thermal power plant is
operational. • IV. Contribution to sustainable energy development – Facilitation of reaching national carbon targets and
reducing GHG emissions As this project favours coal – generated electricity, not only will it not facilitate the reaching of
national carbon targets and reducing GHG emissions, but will increase them and thus reduce the chance of reaching
national carbon targets and reducing GHG emissions, and consequently, will reduce or seriously harm the chance of
reaching EU 2020 goals, possibly resulting in very high cost for purchasing carbon allowances. • IV. Contribution to
sustainable energy development – Contribution to economic development Viewed in the short term this project will
contribute to economic development. However, in the long term, it has a very negative economic impact due to it promoting
coal-generated electricity and promoting locking-in of carbon emissions for the life-duration of the thermal power plant. The
lock-in of emissions will cause high cost for buying carbon allowances after EU accession, thus seriously decreasing the
economic viability of the project. • V. Maturity of the project – Progress in realisation (feasibility study, EIA, FID, permits and
licences) The project is not in the same phase in Macedonian and in Albania. While in Macedonia it is already in the phase
of preparation of EIA study, it is only in feasibility study phase in Albania. Unless this project is jointly developed and is given
the same priority in both countries, it will result in locking in finances until the other country reaches the same maturity of the
project. Unless both countries find this project a priority and are working on its development seriously and jointly, it should
not be put as PECI. • VI. Commercial strength of the project – Level of public funding needed According to current plans, the
project on the Macedonian side will be funded by a combination of MEPSO’s funds and a credit line/bank loan, all of which
would be public money, since MEPSO is a state owned company.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG007
Comments on the project:
Based on the criteria for PECI listed in the Strategy document on pages 22-23, the project is not compliant with the following
criteria: • I. Contribution to the implementation of Regional Energy Strategy’s objectives – Involves, and/or is developed with,
the cooperation of at least two Contracting parties, or between a Contracting Party and an EU Member State The project
does not involve two contracting parties. It was tendered several times, and although some EU based companies did apply,
they didn’t follow through. Chinese actors also expressed interest in the projects. • I. Contribution to the implementation of
Regional Energy Strategy’s objectives – Cross-border infrastructures The projects would include infrastructure that is only
relevant to Macedonia and therefore does not comply with this criterion. • III. Security of supply – Through diversification of
supply sources, supplying counterparts and routes The part about diversification of sources in this criterion is met, because
it is a difference from the usual case where coal is the main energy source. The part where this criterion is not met is these
two hydro power plants being very old projects which are based on hydrology data which are not relevant anymore,
therefore the security of supply they would give is very questionable. • IV. Contribution to sustainable energy development –
Facilitation of the development of renewable energy sources These two hydro power plants fall into the category of large
hydro power plants, the status of which as renewable energy sources is being under review at present by the European
Commission. It is our view that they do not facilitate development of renewable energy sources. • IV. Contribution to
sustainable energy development – Facilitation of replacing old and low efficient technologies The project is facilitating the
replacement of old and low efficient technologies, especially those related to coal-based generation, but the fact that the
project is being benched for approx. 30 years makes it alarmingly out-dated (the first project for Cebren dates from 1963
and the first feasibility study from 1973-74, while for Galiste the project dates from 1989-90, and a feasibility study dates
from 2003). • IV. Contribution to sustainable energy development – Contribution to economic development In our view, the
project does not comply with this criterion for several reasons. First of all, it does not contribute to economic development
because of its economical non-viability (It would take approx. 50 years for achieving return on investment, according to
some calculations even more (a speculation is 100 years of operation), which is why the investor who would take on this
project is granted operation rights of a fully operational hydro power plant (HPP Tikves) to cover the losses). Second, the
cumulative generation capacity would be at least 500MW, amounting to 2/3 of the largest capacity in Macedonia (which is
TPP Bitola of 675MW). In that case, if giving this project to a foreign investor, Macedonia could be exposed to vulnerability
in terms of price of the generated electricity. Third, although the hydro power plants would solve the problem of energy
imports if the hydrology is good, the fact that these projects are based on out-dated hydrology data remains and, in the very
likely case that the hydrology is not as good as foreseen in the project documentation, might result in locking in of finance
for building these power plants, and still needing energy imports. • IV. Contribution to sustainable energy development –
Economic, social and environmental viability The project does not comply with this criterion due to the fact that it is
economically not viable (It would take approx. 50 years for achieving return on investment, according to some calculations
even more (a speculation is 100 years of operation), which is why the investor who would take on this project is granted
61
operation rights of a fully operational hydro power plant (HPP Tikves) to cover the losses). The project would also have a
severe impact on the micro-climate in the Mariovo region, which is home to several endemic species and is an Emerald site.
• V. Maturity of the project – progress in realisation (feasibility study, EIA, FID, permits and licences) The project for these
two hydro power plants is very old – the project for HPP Cebren was first made in 1963 with a feasibility study made 10
years later (1973-74), while the project for HPP Galiste was made in 1989/90 with a feasibility study made in 2003. The two
projects have been tendered 6 times and although there were interested investors from EU countries, as well as from China,
they opted out of the investment. • V. Maturity of the project – Length of project realisation The date for commission of HPP
Cebren is set for year 2020 in the list of nominated PECI on the Energy Community website. This is highly unrealistic and
unachievable since according to project documentation the construction phase is 7 years and the tender procedure in 2013
fell through. Therefore, the date of commission listed in the PECI table on the Energy Community website is no longer
relevant since it cannot be achieved. • VI. Commercial strength of the project – Bankability The project would take too long a
time for starting profit generation, causing the state to be forced to grant the future operator rights to operate a fully
operational HPP Tikves for a period of 52 years in order to cover the losses.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG008
Comments on the project:
Based on the criteria for PECI listed in the Strategy document on pages 22-23, the project is not compliant with the following
criteria: • I. Contribution to the implementation of Regional Energy Strategy’s objectives – Involves, and/or is developed with,
the cooperation of at least two Contracting parties, or between a Contracting Party and an EU Member State The project
does not comply with this criterion because it does not involve two contracting parties. There is a potential interest from the
Chinese Corporation for water and energy (CWE) through a credit line obtained from the Chinese Investment Bank, but that
still does not help meet this criterion. • I. Contribution to the implementation of Regional Energy Strategy’s objectives –
Cross-border infrastructures The project does not comply with this criterion because all 12 HPPs in the project would be
infrastructures that are only relevant to Macedonia. • III. Security of supply – Through diversification of supply sources,
supplying counterparts and routes The part about diversification of sources in this criterion is met, because it is a difference
from the usual case where coal is the main energy source. The part where this criterion is not met is the project for these 12
hydro power plants is a very old one which is based on a hydrology which is not relevant anymore, therefore the security of
supply it would give is very questionable. • IV. Contribution to sustainable energy development – Facilitation of the
development of renewable energy sources The joint generation capacity of the project puts it in the category of large hydro
power plants, the status of which as renewable energy sources is being under review at present by the European
Commission. It is our view that this project does not facilitate development of renewable energy sources. • IV. Contribution
to sustainable energy development – Facilitation of replacing old and low efficient technologies The project is facilitating the
replacement of old and low efficient technologies, especially those related to coal-based generation, but the fact that the
project is present since year 1932 and is repeatedly being benched ever since then, makes it alarmingly out-dated (the first
project for the Vardarska Dolina system dates from 1932, and was revised in 1964. It is currently in the phase of
prefeasibility study). • IV. Contribution to sustainable energy development – Contribution to economic development The
project does not comply with this criterion for more than one reason. First of all, it does not contribute to economic
development because of its questionable economic viability and cost-benefit ratio - It would cost 1,2 billion euro to build,
would require changing the route of the railway in a certain part, would cause extreme environmental, as well as social
damage and the joint capacity of all 12 hydro power plants would be only 350MW. It is our opinion that the pre-feasibility
study for this project must be completely finished before even considering putting this project on the list of PECI. Second,
although the hydro power plants would help with the problem of energy imports if the hydrology is good, the fact that these
projects are based on out-dated hydrology data remains and, in the very likely case that the hydrology is not as good as
foreseen in the project documentation, might result in locking in of finance for building these power plants, and still needing
energy imports. • IV. Contribution to sustainable energy development – Economic, social and environmental viability The
project does not comply with this criterion due to the fact that it has severe environmental impact on the river Vardar (the
largest river in Macedonia) and on the surrounding area. It will also damage the Important Bird Area (IBA) and Emerald site
in Demir Kapija, which would mean compromising an Emerald site and a future Natura 2000 area. The railway passing
through the town of Veles would have to be relocated, causing problems with connectivity for the citizens of Veles and
exposing the project to severe opposition from local population. The economic viability of the project is also questionable
due to the fact that it is based on very old hydrology data which is not relevant at present. The economic viability can be
more realistically predicted only once the pre-feasibility study is completed. It is our opinion that until such a time, this
project should not be considered as a candidate for PECI. • V. Maturity of the project – progress in realisation (feasibility
study, EIA, FID, permits and licences) The project for these 12 hydro power plants is very old – the basic project originates
from year 1932 when it was discarded by the Committee of the League of Nations because it’s construction was neither
economically, nor technically viable. The project was revised in 1964. Since then, there was some interest for its
construction, but all investors have opted out due to non-rentability of the project. Currently it is at the stage of pre-feasibility
study, which puts it at very low maturity, although it has been present for more than 70 years. • V. Maturity of the project –
Length of project realisation The date for commission of the first two largest hydro power plants in the project (HPP Veles
and HPP Gradec) is set for year 2021 at the earliest, which is neither very realistic, nor achievable since the project is still at
a very early phase – pre-feasibility study. Therefore, it’s presence on the PECI list is questionable, especially when
considering the fact that the funds of 1.2 billion euro can be used for some other projects that would give faster results, such
as solar power plants.
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Your Details
Title:
Mr
First name:
Oleg
Last name:
Savitsky
Name of organization:
National Ecological Centre of Ukraine
Job title:
energy campaigner
Address:
Gilyanska 126/23
Postcode:
01032
City:
Kyiv
Country:
Ukraine
Email: *
[email protected]
Phone No:
+38 044 353 78 42
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
Fast-tracking of PECIs may be incompatible with ensuring the proper application of the EU environmental "Acquis” and reduce
transparency and accountability The selected PECI projects are expected to be “fast tracked” in terms of approvals and will be
earmarked for support with EU funds. We would like to ask you for details about what exactly this fast-tracking will and will not
mean in practice? The region's track record for the application of environmental, planning, and procurement processes is wholly
inadequate (see EU Progress Reports), and we are concerned that fast-tracking may further weaken these processes if not very
carefully targeted. It should not be assumed that the involvement of the European public banks would ensure against such flaws,
as there are currently several on-going investigations by the EBRD's and EIB's complaint mechanisms regarding such issues in
projects in the Energy Community region, as well as an on-going OLAF investigation against the EIB regarding Sostanj 6.
Although the Energy Community parties have adopted EU Environmental Impact Assessment legislation, the legislation on nature
protection (eg. the Bird and Habitats Directives, Water Framework Directive) is far behind in its implementation and is not
required by the Energy Community. Yet energy infrastructure is being planned in areas which would have been better protected
had they been in the EU (eg. Ombla hydropower plant, Croatia, Boskov Most hydro plant, Macedonia), thus leading to double
standards. If PECI projects are to be given a stamp of approval by the ECTS – an EC funded institution – then they should also
be subject to best practices in transparency and accountability. Also the EU Climate Commissioner Connie Hedegaard has
recently urged the EBRD, the EIB and the World Bank to phase out lending to fossil fuels. Commissioner Hedegaard stated that
“she is particularly keen to see three international financial institutions – the European Investment Bank, the European Bank for
Reconstruction and Development, and the World Bank – join with their EU and OECD partners to take a lead role in eliminating
public support for fossil fuels. Together, these three institutions lend more than €130 billion ($168 billion) annually for projects in
Europe and beyond, and maintain a strong advisory role in beneficiary countries. This year provides an especially important
opportunity to use this potential for action." We strongly support this proposal and believe that the ECTS as an European
Commission funded institution should also apply this logic; especially for perspective member states.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG025
Comments on the project:
This project, promoted by Ukrainian private energy company DTEK, presumes replacing 4 out of 12 old units (185 MW
each) at Burshtyn TPP, which have already exhausted their lifetime, with new 800 MW coal unit. The project is in direct
conflict with the multiple criteria stated in Energy Strategy of the Energy Community, specifically: I. Contribution to the
implementation of Regional Energy Strategy’s objectives - Involves, and/or is developed with, the cooperation of at least two
Contracting Parties, or between a Contracting Party and an EU Member State Currently DTEK has no partners in EU
Member states, who declared their interest in participation in construction of new unit at Burshtyn TPP. II. Contribution to
regional market integration and enhanced competition. - Reduction of market concentration and facilitating access for new
market entrants. Project promoter - DTEK is the largest energy company in Ukraine and it has the potential to become a
private energy monopoly by privatization of all TPP and part of combined heat and power plants. DTEK has shown itself as
aggressive player on Ukrainian market buying out state owned energy generation companies. DTEK has already become a
private monopoly in strategic field of electricity export from Ukraine as it bought ‘Zakhidenergo’. DTEK is aiming to control
63
the entire thermal energy sector, including coal mining and preparation, electricity generation, transmission and distribution.
III. Security of supply - By using the lowest cost of available resources, while taking into account all externalities Projects of
new coal units at have significant externalities, which are usually not taken into account. These are air and water pollution,
GHG emissions and adverse health effects for local population. Security of operation of Ukrainian TPPs also should be
questioned after a blaze on Vuglegirsk TPP, which destroyed 4 units with total capacity of 1,2 GW on 29 March 2013. IV.
Contribution to sustainable energy development - Facilitation of the development of renewable energy sources Construction
of the new coal powered units means locking electricity production to coal for another 30-50 years. Renewables face unfair
competition, minding significant subsidies currently going to coal mining. Ukrainian energy sector is known for state
subsidies for the energy sector. In 2010 Ukraine have spent 730 mln Euro (around 2% of state budget) on subsidies to coal
sector. - Facilitation of reaching national carbon targets and reducing GHG emissions Current national carbon target
assumes doubling of greenhouse gases (GHG) emissions to 2020 comparing to 2012. This target is a reflection of the
national policy to increase use of coal in the energy sector. Ukrainian environmental groups are calling on government to
stabilize GHG emissions on current level, while construction of new coal units will lead to increase of GHG emissions. V.
Maturity of the project - Length of project realization Proposed date of commissioning is set on 2019. This term is
questionable, considering that DTEK has yet to make the whole set of project implementation measures, starting with
feasibility study. - Experience of project promoter DTEK is a young company (established in 2002) and it has little to no
experience in commissioning of new units. There is hardly any positive experience of constructing new power plant units in
Ukraine since it got independence in 1991. It makes it impossible to find people and companies with relevant experience in
the country. Taking into account all of the above, National Ecological Centre of Ukraine considers that this project should
not be earmarked for support with EU funds.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG026
Comments on the project:
Proposed project involves the construction of 3 coal-fired units with capacity of 225 MW each (675 MW total). Construction
of the unit five, first of the 3 units proposed to be built at Dorbotvir by DTEK, was started in 1991 and then abandoned few
years later. With some of the equipment already in place, it is questionable if the best available technologies can be utilized.
All three units are proposed to use the same old technology. The project does not comply with Energy Community criteria
for priority projects. Specifically: I. Contribution to the implementation of Regional Energy Strategy’s objectives - Involves,
and/or is developed with, the cooperation of at least two Contracting Parties, or between a Contracting Party and an EU
Member State Currently DTEK has no partners in EU Member states, who declared their interest in participation in
construction of new units at Dobrotvir and Burshtyn TPP. II. Contribution to regional market integration, and enhanced
competition. - Reduction of market concentration and facilitating access for new market entrants. DTEK has shown itself as
aggressive player on Ukrainian market buying out state owned energy generation companies. DTEK has already become a
private monopoly in strategic field of electricity export from Ukraine as it bought ‘Zakhidenergo’. III. Security of supply - By
using the lowest cost of available resources, while taking into account all externalities The proposed new units at Burshtyn
and Dobrotvir have significant externalities, which are not taken into account. These are air and water pollution, GHG
emissions and adverse health effects for local population. Security of operation of Ukrainian TPPs also should be
questioned after a blaze on Vuglegirsk TPP, which destroyed 4 units with total capacity of 1,2 GW on 29 March 2013. IV.
Contribution to sustainable energy development - Facilitation of the development of renewable energy sources Construction
of the new coal powered units means locking electricity production to coal for another 30-50 years. Renewables face unfair
competition, minding significant subsidies currently going to coal mining. Ukrainian energy sector is also known for state
subsidies for the energy sector. In 2010 Ukraine have spent 730 mln Euro (around 2% of state budget) on subsidies to coal
sector. - Facilitation of replacing old and low efficient technologies Project for Dobrotvir TPP presumes utilization of the old
unfinished energy unit structures. It makes utilization of best available technologies unachievable. - Facilitation of reaching
national carbon targets and reducing GHG emissions Current national carbon target assumes doubling of greenhouse
gases (GHG) emissions to 2020 comparing to 2012. This target is a reflection of the national policy to increase use of coal
in the energy sector. Ukrainian environmental groups are calling on government to stabilize GHG emissions on current
level, while construction of new coal units will lead to increase of GHG emissions. V. Maturity of the project - Progress in
realization (feasibility study, EIA, FID, permits and licenses) Project for Dobrotvir TPP has no feasibility study and its
execution have not been announced yet. - Support from governments / local communities Local communities are neither
interested in lifetime extension of old coal powered units at Dobrotvir TPP nor commissioning of new ones which utilize
outdated technology. The subjects of their concern are air and water pollution and related health issues. - Experience of
project promoter DTEK is a young company (established in 2002) and it has little to no experience in commissioning of new
units. There is hardly any positive experience of constructing new power plant units in Ukraine since it got independence in
1991. It makes it impossible to find people and companies with relevant experience in the country. Taking into account all of
the above, National Ecological Centre of Ukraine considers that this project should not be earmarked for support with EU
funds.
Your Details
64
Title:
Ms.
First name:
Biljana
Last name:
Stevanovska
Name of organization:
ORT-Training for Sustainable Development
Job title:
Director
City:
Skopje
Country:
Republic of Macedonia
Email: *
[email protected]
Project Comment Form
Project number (ID and code) as indicated in the list:
ET008-2
Comments on the project:
The project would support coal based infrastructure, thus locking the region in carbon intensive energy production which in
turn will result in not achieving the EU 2020 targets for reduction of emissions. Aside of this general comment, based on the
criteria for PECI listed in the Strategy document on pages 22-23, the project is not compliant with the following criteria: • III.
Security of supply - By using the lowest cost of available resources, while taking into account all externalities The project
supports coal-generated electricity which has an extremely high cost in externalities in terms of health costs, number of
deaths and social costs. • IV. Contribution to sustainable energy development – Facilitation of the development of
renewable energy sources As the project will connect Skopje to a new coal-fired thermal power plant in Kosovo, this project
is non-eligible based on this criterion, since it supports new coal-generated energy, and coal is not and cannot be viewed as
a renewable source of energy. • IV. Contribution to sustainable energy development – Facilitation of replacing old and low
efficient technologies Instead of facilitating new renewables and new technologies, thus promoting the gradual phasing-out
of old and low efficient technologies, this project favours generation from coal, which is usually based on old and low
efficient technologies and locks the energy sector of the country into coal for the life-duration of a thermal power plant which
is usually approx. 40 years. • IV. Contribution to sustainable energy development – Facilitation of reaching national carbon
targets and reducing GHG emissions As this project favours coal – generated electricity, not only will it not facilitate the
reaching of national carbon targets and reducing GHG emissions, but will increase them and thus reduce the chance of
reaching national carbon targets and reducing GHG emissions, and consequently, will reduce or seriously harm the chance
of reaching EU 2020 goals. • IV. Contribution to sustainable energy development – Contribution to economic development
Viewed in the short term this project will contribute to economic development. However, in the long term, it has a very
negative economic impact due to it promoting coal-generated electricity and promoting locking-in of carbon emissions for
the life-duration of the thermal power plant. The lock-in of emissions will cause high cost for buying carbon emissions after
EU accession, thus seriously decreasing the economic viability of the project. • V. Maturity of the project - length of project
realisation The project is not in the same phase in the two countries, which would inevitably lead to locking-in of financial
resources in either of the countries which begins operations on this project first. While in Kosovo the planned date of
commission for this project is year 2023, in Macedonia the project is listed as long-term, leading us to believe that the
commission date will be in the more distant future then year 2023. • V. Maturity of the project - Support from
governments/local communities Although the project itself is not subject to opposition, the coal-fired thermal power plants
that it would connect to is very strongly opposed by the population of Kosovo due to a very high cost in externalities (health,
environmental, and social impact), low economic viability and locking-in of carbon emissions. • VI. Commercial strength of
the project – Level of public funding needed According to current plans, the project on the Macedonian side will be funded
by a combination of MEPSO’s funds and a credit line/bank loan, all of which would be public money, since MEPSO is a
state owned company.
Project Comment Form
Project number (ID and code) as indicated in the list:
ET001-2
Comments on the project:
The project would support coal based infrastructure, thus locking the region in carbon intensive energy production which in
turn will result in not achieving the EU 2020 targets for reduction of emissions. Aside of this general comment, based on the
criteria for PECI listed in the Strategy document on pages 22-23, the project is not compliant with the following criteria: • III.
Security of supply - By using the lowest cost of available resources, while taking into account all externalities The project
supports coal-generated electricity which has an extremely high cost in externalities in terms of health costs, number of
deaths and social costs. • IV. Contribution to sustainable energy development – Facilitation of the development of
renewable energy sources As the project will connect to the Bitola thermal power plant, this project is non-eligible based on
this criterion, since it supports coal-dependency in Macedonia and the region, and coal is not and cannot be viewed as a
65
renewable source of energy. • IV. Contribution to sustainable energy development – Facilitation of replacing old and low
efficient technologies Instead of facilitating new renewables and new technologies, thus promoting the gradual phasing-out
of old and low efficient technologies, this project favours generation from coal, which is usually based on old and low
efficient technologies and locks the energy sector of the country into coal for as long as the Bitola thermal power plant is
operational. • IV. Contribution to sustainable energy development – Facilitation of reaching national carbon targets and
reducing GHG emissions As this project favours coal – generated electricity, not only will it not facilitate the reaching of
national carbon targets and reducing GHG emissions, but will increase them and thus reduce the chance of reaching
national carbon targets and reducing GHG emissions, and consequently, will reduce or seriously harm the chance of
reaching EU 2020 goals, possibly resulting in very high cost for purchasing carbon allowances. • IV. Contribution to
sustainable energy development – Contribution to economic development Viewed in the short term this project will
contribute to economic development. However, in the long term, it has a very negative economic impact due to it promoting
coal-generated electricity and promoting locking-in of carbon emissions for the life-duration of the thermal power plant. The
lock-in of emissions will cause high cost for buying carbon allowances after EU accession, thus seriously decreasing the
economic viability of the project. • V. Maturity of the project – Progress in realisation (feasibility study, EIA, FID, permits and
licences) The project is not in the same phase in Macedonian and in Albania. While in Macedonia it is already in the phase
of preparation of EIA study, it is only in feasibility study phase in Albania. Unless this project is jointly developed and is given
the same priority in both countries, it will result in locking in finances until the other country reaches the same maturity of the
project. Unless both countries find this project a priority and are working on its development seriously and jointly, it should
not be put as PECI. • VI. Commercial strength of the project – Level of public funding needed According to current plans, the
project on the Macedonian side will be funded by a combination of MEPSO’s funds and a credit line/bank loan, all of which
would be public money, since MEPSO is a state owned company.
Your Details
Title:
Mrs.
First name:
Elona
Last name:
Saro
Name of organization:
Environmental center for Development Education and Networking
(EDEN)
Job title:
Program officer in Public Information and Participation
Address:
Rr. Luigj Gurakuqi Nd. 33 H. 2 Ap. 13
City:
Tirana
Country:
Albania
Email: *
[email protected]
Phone No:
+355 4 22 39 619
General Comments
You are invited to provide your general comments in this section
The main concern we have for the development of the Energy sector in Albania is that the national policies are in line with the EU
Energy strategies and polices; the investments are pushed towards projects which promote generation from renewable first and
then energy efficiency and savings, which contributes to the sustainable development of the country and the region as well. It is
quite important to us that PECIs projects in Albania focus prior on the in-country demand for energy and then promoting and
planning for exports. In specific terms related with the PECI projects proposed by Albania our general comments are: o Three out
of four proposed projects (except the G001 and G002) at the moment are not open to public. There is randomly very few
information on them and we could not find complete data and project in none of the project promoter`s website and are still
waiting for those data after sending different request communications. Due to lack of information we have difficulties to fully
understand at what stage the projects are and if the legal procedures especially obliged by the environmental law frame are
followed. Given the circumstances we believe that the projects proposed are not transparent and to us as public at the moment
they represent only ideas which are not based on facts, feasibility studies etc. Thus they must be developed and give us the
possibility to know them better so we can comment on those projects in details according to the European Community Strategy
criteria. o We are pleased to discover that none of the projects proposed is focusing on hydro as possible energy source. There
are only 6 rivers in Albania and already 443 hydropower plants are planned to be constructed in those 6 rivers which is already
quite enough for biodiversity degradation, erosion etc. On the other hand we would like to keep focus that the project proposed
66
do not consider possibilities of energy generation form solar power considering high potentials that the country has to use this
energy source. o The last but not the least, the proposed projects do not have clear indication on what advantages and benefits
on energy situation in the country they will have, meanwhile it is clearly that most of the energy generated or stored will go for
export in conditions when the country is suffering bad energy situation.
Project Comment Form
Project number (ID and code) as indicated in the
ET001-1
list:
Comments on the project:
This project is not mature enough in the Albanian side. The project should go along at the same speed in Albania and
Macedonia and this did not happen so far. The project in the Albanian side is still in the feasibility study phase and does not
have Preliminary Environmental Impact Assessment yet. Other very important issue regards energy import and export: It is
still unclear in Albania if this transmission line is only designated to export energy to Italy or export/import from Macedonia.
Your Details
Name of organization:
Group for Legal and Political Studies (KOSID member)
Address:
Rexhep Luci 10/5
Postcode:
10 000
City:
Prishtina
Country:
Kosovo
Email: *
[email protected]
Phone No:
+381 (0) 38 227 944
General Comments
You are invited to provide your general comments in this section
It is KOSID’s hope that health costs will be considered by the task force and factored into the criteria. While the Energy
Community only considers PECIs that benefit at least two Contracting Parties, or at least one Contracting Party and one Member
State, the Energy Community should consider the potentially negative effects that energy generation projects have in the host
country. In the case of Kosovo e Re, its construction would have supremely detrimental health costs for the local community. It is
crucial to note that Kosovo e Re would be located directly outside of Prishtina, which is capital and largest city in Kosovo.
Project Comment Form
Project number (ID and code) as indicated in the list:
EG013
Comments on the project:
KOSID is strongly against the creation of Kosovo e Re for a number of reasons. The construction of Kosovo e Re does not
enhance competition and prolongs Kosovo’s reliance on a single-source. Sustaining Kosovo’s reliance on lignite coal would
not have the effect of prompting diversification efforts in Kosovo. In the long term, the construction of Kosovo e Re will only
prolong Kosovo’s reliance on single source and delay the energy crisis that will result from the absence of diversification in
the face of decade-long reliance on a non-renewable single energy source.
Comments on LISTED Projects (2)
In case you wish to comment on a project that is already included in the list, please use this table.
Project Comment Form
67
Project number (ID and code) as indicated in the list:
ET014
Comments on the project:
KOSID avidly supports the construction of a 400 kV transmission line between Kosovo and Albania. This transmission line
would support energy security in allowing Kosovo and Albania to buy and sell energy and would allow each state to ensure
their ability to meet energy needs during peak periods. This transmission line would also incentivize Kosovo to move away
from its single-source reliance on non-renewable lignite coal; Kosovo’s reliance on lignite coal is environmentally detrimental
with high CO2 emissions, is unsustainable, and prevents Kosovo from actively seeking opportunities to diversify energy
sources. In addition, this transmission line would support Kosovo and Albania in becoming a hub for energy in the region
and would prepare the energy suppliers in these countries for open market competition after 2015 (in accordance with the
Energy Treaty which states that in 2015, South Eastern Europe should have a common, free energy market).
Your Details
Title:
Mr.
First name:
Agron
Last name:
Demi
Name of organization:
GAP Institute for Advanced Studies
Job title:
Executive Director
Address:
Str.Mbreti Zog, 31/1
Postcode:
10000
City:
Prishtina
Email: *
[email protected]
Phone No:
+37744417634
Project Comment Form
Project number (ID and code) as indicated in the list:
EG013
Comments on the project:
Kosovo C should not be build. The proposed construction of new Kosovo C would lead to base load capacity that is three
times higher than existing demand in 2010 and four times higher when corrected for avoidable losses. Building Kosovo C
would require Kosovo consumers (or the government) to service over a billion euro in debt at a time when they are also
servicing debt for necessary improvements in the Sibovc mine, Kosovo’s wasteful transmission and distribution systems,
and refurbishment of Kosovo B. The initial cost estimates for electricity provided by Kosovo C were grossly underestimated,
subsequent documents have tripled expected rates. However, even these rates are likely to be unrealistically low as Kosovo
suffers from a peak load not baseload power deficit. Building a baseload power plant will require investors to recoup costs
over a small number of peak operating hours. It is feasible that tariffs up to four times higher than current rates would be
needed to service the total new investments.3 It’s important to note that coal plants are not designed to provide peak power
as they cannot be ‘turned on and off’ quickly. Hydro and wind, especially when combined with natural gas resources are far
more suited for this purpose. Reducing technical and non-technical losses to 5 percent (each) would reduce the needed
base load capacity by 20 percent which is far less than the capacity need suggested by the World Bank. Energy efficiency
efforts would reduce this need even further and allow a refurbished Kosovo B to meet base load generation needs through
2025 – even at a robust 4.5 per cent GDP growth rate. Moreover, analysis from Professor Dan Kammen former ‘Clean
Energy Czar’ at the World Bank found that a low-carbon path exists for Kosovo that integrates aggressive energy efficiency
deployment, use of both large and small-scale hydropower, solar, biomass and extensive use of wind energy while reducing
human and ecological damage. This path also provides 30% more jobs than a business as usual coal dominated path and
does so at an estimated cost savings of 50%. Due to the topography where the Kosovo C plant would be built, it is likely that
emissions will exceed EU and World Bank ambient air quality standards. However, recently released USAID documents
show that adequate air quality monitoring is not being undertaken. If accurate monitoring and modeling were being
conducted it would likely demonstrate that emissions from the both plants will cause unhealthy levels of air pollution, even if
Kosovo B and Kosovo C meet EU emission standards. Entrance to the EU while pursuing a plan inconsistent with the 2020-20 energy and climate mandate puts a poor nation at a severe economic disadvantage within the Union. We believe that,
as a consequence, it may be necessary to add Best Available Controls (BAT) to both the existing and proposed new
Kosovo units. This will add hundreds of millions of euro to the estimated cost of Kosovo C, for which no need has been
68
demonstrated. It may also be the case that a proper monitoring and modeling program will show that, even with BAT
controls, emissions from the Kosovo plant will cause exceedances of health-based ambient air quality standards.
Comments on the project:
Kosovo C should not be build. The proposed construction of new Kosovo C would lead to base load capacity that is three
times higher than existing demand in 2010 and four times higher when corrected for avoidable losses. Building Kosovo C
would require Kosovo consumers (or the government) to service over a billion euro in debt at a time when they are also
servicing debt for necessary improvements in the Sibovc mine, Kosovo’s wasteful transmission and distribution systems,
and refurbishment of Kosovo B. The initial cost estimates for electricity provided by Kosovo C were grossly underestimated,
subsequent documents have tripled expected rates. However, even these rates are likely to be unrealistically low as Kosovo
suffers from a peak load not baseload power deficit. Building a baseload power plant will require investors to recoup costs
over a small number of peak operating hours. It is feasible that tariffs up to four times higher than current rates would be
needed to service the total new investments.3 It’s important to note that coal plants are not designed to provide peak power
as they cannot be ‘turned on and off’ quickly. Hydro and wind, especially when combined with natural gas resources are far
more suited for this purpose. Reducing technical and non-technical losses to 5 percent (each) would reduce the needed
base load capacity by 20 percent which is far less than the capacity need suggested by the World Bank. Energy efficiency
efforts would reduce this need even further and allow a refurbished Kosovo B to meet base load generation needs through
2025 – even at a robust 4.5 per cent GDP growth rate. Moreover, analysis from Professor Dan Kammen former ‘Clean
Energy Czar’ at the World Bank found that a low-carbon path exists for Kosovo that integrates aggressive energy efficiency
deployment, use of both large and small-scale hydropower, solar, biomass and extensive use of wind energy while reducing
human and ecological damage. This path also provides 30% more jobs than a business as usual coal dominated path and
does so at an estimated cost savings of 50%. Due to the topography where the Kosovo C plant would be built, it is likely that
emissions will exceed EU and World Bank ambient air quality standards. However, recently released USAID documents
show that adequate air quality monitoring is not being undertaken. If accurate monitoring and modeling were being
conducted it would likely demonstrate that emissions from the both plants will cause unhealthy levels of air pollution, even if
Kosovo B and Kosovo C meet EU emission standards. Entrance to the EU while pursuing a plan inconsistent with the 2020-20 energy and climate mandate puts a poor nation at a severe economic disadvantage within the Union. We believe that,
as a consequence, it may be necessary to add Best Available Controls (BAT) to both the existing and proposed new
Kosovo units. This will add hundreds of millions of euro to the estimated cost of Kosovo C, for which no need has been
demonstrated. It may also be the case that a proper monitoring and modeling program will show that, even with BAT
controls, emissions from the Kosovo plant will cause exceedances of health-based ambient air quality standards.
Your Details
First name:
Mona
Last name:
Bricke
Name of organization:
Climate Alliance Germany
Job title:
European Coordinator
Address:
Marienstr. 19-20
Postcode:
10117
City:
Berlin
Country:
Germany
Email: *
[email protected]
Phone No:
+4917610563917
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
Project promotors were required to submit project information to the Energy Community Secretariat through PECI questionnaires,
by 31 December 2012. The questionnaire does not contain headings/questions that would allow a verification whether the
generation/storage projects meet the following criteria: - security of supply, by using the lowest cost of available resources, while
taking into account all externalities - facilitation of reaching national carbon targets and reducing GHG emissions - economic,
social and environmental viability - socio-economic benefit 1) The questionnaires are not available on the Energy Community
website for consultation. 2) While the consultant contracted to assess the PECI may have requested additional information from
69
the project promoters by 10 March 2013, this is not information the public has been offered access to. 3) The criteria used to
assess the PECI are part of the Regional Energy Strategy, but it is up to the consultant that was contracted to assess the PECI to
set the methodology for the assessment, including indicators and weighting. In order to be able to collect meaningful feedback
and comments on the proposed projects, we believe that detailed information needs to offer the basis for commenting, both
regarding the projects and the methodology. Thus, we propose the disclosure of project profiles and the assessment
methodology (including indicators and weights) to allow for independent assessments and the extension of the consultation
period.
Your Details
Title:
Mr
First name:
Martyn
Last name:
Osborn
Name of organization:
WBIF / WYG
Job title:
Energy Sector Key Expert
Address:
Koce Kapetana 47/3 floor
Postcode:
11000
City:
Belgrade
Country:
Republic of Serbia
Email: *
[email protected]
Phone No:
+ 381 60 543 00 33
General Comments
You are invited to provide your general comments in this section
There seems to be a lack of correlation between the PECI projects listed, and those that have been identified by WBIF country
managers and other experts. Some potential projects seem to be excluded from the lists, while other projects are new to us.
However, WBIF/IPF undertakes regular screening of potential energy projects in the 7 Western Balkan countries we operate in,
through the application rounds for grant support that happen twice per year. Of course, WBIF / IPF supports any initiative to
increase the rate at which infrastructure projects in energy are developed and subsequently implemented, this is the original
reason that led to the establishment of WBIF. Therefore, WBIF is more than happy to support all projects in the PECI process,
and can provide opinions and background on a number of projects in the PECI list.
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
One of the main obstacles faced within the WBIF, with respect to project development, is a lot of TA applications to undertake
feasibility studies - for electricity transmission lines, gas pipelines and so on - which demonstrate a technically and economically
feasible and viable project. Thereafter, the project developers are often slow in moving into main design, tender dossier
preparation and construction. This is often due to complicated administrative arrangements between operators, line ministries
and ministries of finance, in gaining an agreement to secure financing and actually build the project. Therefore, there a number of
viable projects that cannot be moved forward due to politics, differing perspectives & agendas and other factors in the country. It
seems that this issue, relating to capacity of sovereign states to absorb further debt and agreeing what to spend it on, is one to
the greatest barriers to increasing energy project rate of development. If positive PECI assessment leads to access to funds for
development, this is to welcomed by the beneficiary countries.
70
Your Details
First name:
cosimo
Last name:
montinaro
Name of organization:
cooperativa pescatori" lafolgore"
Job title:
presidente
Address:
via tevere
Postcode:
73026
City:
lecce
Country:
san foca frazione di melendugno
Email: *
[email protected]
Phone No:
0832881444
General Comments
You are invited to provide your general comments in this section
inizialmente(causa disinformazione) ero contrario alla realizzazione eventuale di tale opera sia per un eventuale impatto negativo
sull'esercizio della pesca in generale e quindi su alcuni sistemi di pesca,in particolare, riferendomi alle reti denominate(
menaidi)usate per la pesca delle sardine essendo questo sistema di pesca risalente agli inizi del novecento( la nostra tradizione
locale) che sotto l'aspetto del rischio ambientale. pero'dopo gli incontri/confronti che ho avuto con i miei tecnici
ambientalisti,ingegneri, biologi ecc.e i responsabili di t.a.p.mi sono convinto del contrario.
71
INDUSTRY
Your Details
Title:
Mr.
First name:
Andrea
Last name:
Stegher
Name of organization:
Snam S.p.A.
Job title:
Head of Business Development
Address:
Piazza Santa Barbara 7
Postcode:
20097
City:
San Donato Milanese
Country:
Italy
Email: *
[email protected]
Phone No:
+390237039024
General Comments
You are invited to provide your general comments in this section
A transparent discussion among international gas operators for developing new interconnections is of the foremost importance for
the development of an efficient and effective gas market, paving at the same time the way to improving security of supply and
optimization of infrastructure costs.
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
The choice between different options of gas supply should be made on the basis of objective criteria which should make these
options actually comparable. The availability of gas producers to ensure continuity and price stability is a parameter to be
considered as well as the reliability of the Gas Carrier (TSO) involved in the project. The TAP project has already gained
regulatory and legal/policy support confirming that the project is feasible and credible in all countries it crosses. The TAP project
(G22) involves TSOs - among which Snam Rete Gas - which guarantee a long-term commitment thanks to the experience in
securing and facilitating the transit of gas and to their capacity to achieve significant investments. The TAP project is considered
relevant for the European gas market and represents a development of strategic interest for the European Union as a whole. This
new infrastructure is a prerequisite to the creation of the South-North corridor, adding an important route of diversification to
current import supplies and possible upgrades for further gas volumes in the medium and long term.
Project Comment Form
Project number (ID and code) as indicated in the list:
G022
Comments on the project:
Snam Rete Gas states its availability to develop its National Transportation Network to connect the new TAP infrastructure
and to make available the required transportation capacity at the new Entry Point. Snam Rete Gas underlines that the final
investment decision to start the needed network developments shall be taken on the basis of the transportation contracts
that, according to the present regulation, have to be signed between Snam Rete Gas and the shippers at the end of an
Open Season procedure to be activated by interested parties.
Your Details
72
Title:
Mr.
First name:
Josef
Last name:
Winkler
Name of organization:
Axpo Trading AG
Job title:
Head International Logistics & Sales Gas
Address:
Lerzenstrasse 10
Postcode:
8953
City:
Dietikon
Country:
Switzerland
Email: *
[email protected]
Phone No:
+41 44 749 45 20
General Comments
You are invited to provide your general comments in this section
We welcome the work of the Energy Community in promoting the development of energy infrastructure for natural gas in South
East Europe.
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
We would welcome the Energy Community to implement the necessary regulatory framework which provides stability and
predictability to large infrastructure projects.
Project Comment Form
Project number (ID and code) as indicated in the list:
G022
Comments on the project:
Trans Adriatic Pipeline (TAP) - opens the Southern Gas Corridor enabling new and competitive gas supply from the Middle
East and the Caspian region to reach Italy and other Western European Markets (e.g. Germany, France) and provides
access to large gas reserves. It can be expanded from 10 to 20 bcm per year with only marginal investments. TAP is well
aligned with the development of the gas fields in Azerbaijan, i.e. Shah Deniz II and is one of the selected export routes for
Caspian gas to Europe; thus, it is ensured that the pipeline will be filled with gas. TAP will improves European security of
supply by diversifying the supply sources and routes and will create new capacity to the Italian gas market and thereby
enhances competition. It offers a significant physical reverse flow option and could be interconnected with the planned
Ionian Adriatic Pipeline (IAP – G008) and the Interconnector Greece - Bulgaria (IGB); this allows for the integration of the
Western Balkan Ring (WBR) and will significantly increase diversification in the South East Europee region. With view to the
Energy Community we consider that TAP meets all the requirements and criteria to become a Project of Energy Community
Interest (PECI) since it contributes to the goals of the Energy Community: 1. Creating a competitive and integrated energy
market TAP connects the natural gas markets of Italy and Greece and supplies gas to Albania; an interconnection with the
bi-directional IAP and IGB would allow for the gasification and integration of Albania, Montenegro, Southern Croatia and
Bosnia and Herzegovina and Bulgaria. This is particularly relevant for the countries who's energy mix is uncompetitive due
to its dependence on lignite and fuel oil for power generation, which are both environmentally and economically
unsustainable. End consumers benefit from TAP since it is shortest, most economical route for Caspian Gas to reach
European markets. It increases competition among suppliers in SEE (e.g. connection with Bulgarian market via reverse flow
on Kula/Sidirokastro or IGB). TAP was selected by the Shah Deniz consortium as the alternative for gas supplies to Italy
under eight openly communicated and transparent selection criteria and its capacity can easily be expanded to comply with
future increasing gas volumes coming from the Caspian region. 2. Attracting investments in energy TAP’s foreign direct
investment provides benefits to an economically depressed region and signals strong investor confidence; at the same time
it creates new opportunities to scale and market natural gas. 3. Providing secure and sustainable energy supply to
customers TAP increases the security of supply for South Eastern Europe by diversifying the sources of gas and by opening
73
up the Southern Gas Corridor. Its benefits for Security of Supply go beyond South East Europe and the Italian border:
Northern and Western European markets will benefit by being able to access the Southern Gas Corridor volumes via Italy
without significant further investments (reverse flow); thereby it diversifies the natural gas supply to Europe. TAP has up to
80% physical reverse flow which could be used in emergencies for South East Europe. Furthermore Italy, Greece and
Albania have already signed an Intergovernmental Agreement to support TAP; the project has a good backing due to strong
and well established European shareholders.
Project Comment Form
Project number (ID and code) as indicated in the list:
G008
Comments on the project:
The Ionian Adriatic Pipeline (IAP) meets all the requirements and criteria to become a Project of Energy Community Interest
(PECI). IAP will in fact be able to increase competition, security of supply, market integration and sustainability in an area
where these are much needed. Through its connection with TAP, IAP will be able to transport gas to Montenegro, Bosnia
and Herzegovina, Croatia and possibly the wider SEE region, fostering the integration of these energy markets with the rest
of Europe and competition in markets heavily dependent on one main supplier. In addition, IAP will be able to bring gas to
regions where power production is heavily dependent on highly carbon-intensive fossil fuels, thereby reducing carbon
emissions in these areas and contributing to the achievement of EU energy and environmental policy goals.
Your Details
Name of organization:
ASSOGAS
Email: *
[email protected]
Phone No:
General Comments
You are invited to provide your general comments in this section
ASSOGAS is an Italian Association founded in 1979 and operating in the national sphere to promote and protect natural gas
operators’ interests, in accordance with the principles of competition and free market. The Association currently represents 80
independent companies that are not linked with the dominant Italian and European operators. The heterogeneous nature of the
companies ASSOGAS represents allows the Association to satisfy the needs of a vast group of operators. We share the general
principles followed to draft the list of “potential Projects of Energy Community Interest in energy”. In particular, with regard to the
natural gas infrastructures, we appreciate the threefold aim of their proposed development, in the way it is expressed in the
“Energy Strategy of the Energy Community”: • “to help currently isolated regions to have access to natural gas supplies; • to
ensure continuous and secure supplies to Contracting Parties by having their network renovated and modernized; • to bring
natural gas from a new range of export markets via new routes to Contracting Parties”.
You are invited to provide your general comments in this section
ASSOGAS is an Italian Association founded in 1979 and operating in the national sphere to promote and protect natural gas
operators’ interests, in accordance with the principles of competition and free market. The Association currently represents 80
independent companies that are not linked with the dominant Italian and European operators. The heterogeneous nature of the
companies ASSOGAS represents allows the Association to satisfy the needs of a vast group of operators. We share the general
principles followed to draft the list of “potential Projects of Energy Community Interest in energy”. In particular, with regard to the
natural gas infrastructures, we appreciate the threefold aim of their proposed development, in the way it is expressed in the
“Energy Strategy of the Energy Community”: • “to help currently isolated regions to have access to natural gas supplies; • to
ensure continuous and secure supplies to Contracting Parties by having their network renovated and modernized; • to bring
natural gas from a new range of export markets via new routes to Contracting Parties”.
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
We feel the authorization process should be expedited in order to assist in the implementation of priority projects. The so-called
“red tape” is commonly known to be the most significant obstacle to the fulfilment of new infrastructural works. In coherence with
74
the aforementioned, the Italian Ministries of Economic Development and of Environmental Policies have recently approved the
National Energetic Strategy, referring to their future actions in order to fight this phenomenon that paralyses the implementation
process.
Project Comment Form
Project number (ID and code) as indicated in the list:
G022
Comments on the project:
We firmly encourage the development of such a project that would let the Italian and EU markets to diversify the supply
sources, granting a more effective security of supply. TAP’s project would also favour the creation of a South-European hub,
by enhancing the cross-border infrastructures, realising a more liquid market to the benefit of operators and end users.
Comments on the project:
We firmly encourage the development of such a project that would let the Italian and EU markets to diversify the supply
sources, granting a more effective security of supply. TAP’s project would also favour the creation of a South-European hub,
by enhancing the cross-border infrastructures, realising a more liquid market to the benefit of operators and end users.
Project Comment Form
Project number (ID and code) as indicated in the list:
G008
Comments on the project:
We believe that the building of this project would be functional to the construction of the Trans Adriatic Pipeline. It would act
as a support to the development of the pan-European market, in order to grant the interoperability of the different hubs.
Your Details
Title:
Mrs.
First name:
Cecilia
Last name:
Wagner
Name of organization:
Trans Adriatic Pipeline AG
Job title:
Advisor Partnership & Cooperation
Address:
Lindenstrasse 2
Postcode:
6340
City:
Baar
Country:
Switzerland
Email: *
[email protected]
Phone No:
+41 041 747 34 16
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
Energy infrastructure projects are generally capital-intensive. In order to successfully attract the required investment into the host
countries, it is necessary for these countries to provide a stable investment environment. This might require certain reforms to be
implemented in order to ensure that any barriers that inhibit investment are limited and that the necessary conditions are present.
The following are examples of conditions which are conducive to a more stable investment environment in the energy sector: •
Presence of independent regulator • Transparent tariff rules (i.e. tariffs are not cost-reflective) • Transparent access to capacity •
Stability in law or permitting regime • Stability in tax, import/export, currency Additionally, given the cross-boundary nature of
priority projects, their successful implementation will require close cooperation between the parties involved. The establishment of
75
a steering committee with representatives from each party can be an effective tool to provide the necessary coordination. The
Energy Community Secretariat should continue to provide its support in this respect as it has been doing to date and host
governments should ensure that high-level representation in this committee is in place.
Project Comment Form
Project number (ID and code) as indicated in the list:
G022
Comments on the project:
The TAP project has been designed with the purpose of transporting Caspian gas (1st phase: 10 BCM/yr, 2nd phase: 20
BCM/yr) into Italy via the territories of Albania and Greece and subsea across the Adriatic sea. TAP should be granted PECI
status as it will help the Energy Community reach the following objectives: Creating a competitive and integrated energy
market - TAP will support market opening and competition in the region by introducing a new transport route and a
diversified source of gas supplies. - TAP will build the first transmission pipeline linking Italy, Greece and Albania. This will
allow the integration of Albania (presently lacking interstate gas connections) into the regional gas market and contribute to
the development of this country’s domestic gas market. - In addition, TAP will contribute to the integration of the energy
markets in the region by enabling the realisation of the Ionian Adriatic Pipeline and the Western Balkan Ring, both regional
interconnectors. TAP will facilitate the realisation of these projects by enabling them access into a new and reliable source
of gas supplies. - Furthermore, the increased interconnectivity created by TAP between South Eastern Europe (SEE)
markets and the rest of the European gas markets will enhance regional cohesion, system reliability and interoperability
between transmission system operators in the region. It will also contribute to price convergence in the SEE area. Attracting
investment in energy - TAP will be one of the largest foreign direct investments ever made in Albania. By privately financing
(no government subsidies) and building a major piece of transmission infrastructure across the country, TAP will send a
strong confidence signal to other potential market investors looking to enter the energy sector. - TAP will contribute to the
development of a domestic gas market in Albania and is committed to provide the country with the necessary infrastructure
(pressure reduction and metering facilities) to have physical access to gas. By bringing in gas supplies into Albania and the
wider SEE region (via IAP, WBR), TAP creates new opportunities for additional energy investments in the midstream and
downstream sectors. Providing secure and sustainable energy supply to customers - TAP will contribute to a more secure
energy supply by opening the Southern Gas Corridor, thus leading to the diversification of gas sources and transport routes
going into SEE. - Moreover, TAP’s ability to expand from 10 BCM/yr to 20 BCM/yr means that further supply diversification
may be possible in the future when additional gas sources from the Caspian or Middle East come on stream. - TAP will also
contribute to regional security of supply by offering mechanisms to improve emergency response in the event of supply
disruptions. Specifically, TAP has designed its systems to accommodate physical reverse-flow and is also evaluating the
prospect to develop an underground gas storage facility in Albania. - In addition, TAP will promote sustainable energy in the
region by providing reliable access to natural gas. Gas-fired power plants could replace coal generation and contribute to
lower CO2 emissions. In addition, gas could be used to provide additional flexibility and backup generation to wind and solar
plants, thus facilitating the transition into a sustainable energy system. We believe the TAP project meets the criteria to be
considered a “Project of Energy Community Interest”. Furthermore, the project is well advanced and on track for
implementation. This recognition will enable TAP together with its regional partners to deliver the above described benefits.
Project Comment Form
Project number (ID and code) as indicated in the list:
G008
Comments on the project:
The Ionian Adriatic Pipeline (IAP) is a planned system running from Ploce, Croatia to Fier, Albania. IAP will be designed to
transport 5 BCM/yr. The project aims to establish a new supply route for natural gas from the Middle East and Caspian
region. IAP should be granted PECI status as it will help the Energy Community reach the following objectives: Creating a
competitive and integrated energy market - IAP will contribute to the integration of the regional energy market by
interconnecting the gas networks of Croatia, Bosnia and Herzegovina, Montenegro and Albania. This interconnectivity will
enhance regional cohesion and interoperability between transmission system operators, improve flexibility and contribute
towards price convergence in the SEE region. - IAP will improve market competition by enabling new gas sellers and
shippers to reach these markets, which are currently heavily dependent on a single gas source. Attracting investment in
energy - IAP will contribute to gasification of Albania and Montenegro by connecting these countries to the regional gas
network and linking them, via TAP, to a source of gas supplies. This will create opportunities to invest in the midstream and
downstream sectors and hence lead to the development of these markets. Providing secure and sustainable energy supply
to customers - By connecting to TAP, IAP will contribute to the diversification of gas sources and transportation routes into
the region, thus enhancing regional security of supply. - The regional interconnectivity created by IAP will lead to increased
resilience, thus making the region less vulnerable to supply shocks or shortages. - IAP will also contribute to sustainable
energy by supplying the region with gas, a low-carbon fuel which can replace coal generation and contribute to lower CO2
emissions. In addition, gas could be used to provide additional flexibility and backup generation to wind and solar plants,
thus facilitating the transition into a sustainable energy system. We believe the IAP project meets the criteria to be
considered a “Project of Energy Community Interest”. This recognition will bring IAP one step closer to its successful
realisation.
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Your Details
Title:
Mr.
First name:
Goran
Last name:
Kovacevic
Name of organization:
NIS j.s.c.
Job title:
Direcot of Economic Analysis of Investment Projects
Address:
Narodnog Fronta 32
Postcode:
21000
City:
Novi Sad
Country:
Serbia
Email: *
[email protected]
Phone No:
NEW Projects to be Added (1)
In case you consider that a project should be added to the list, please indicate the project details below. Please note that the aim
of this questionnaire is to get a general overview of the proposed project. Project promoter(s) may be required to submit further
information to allow for an extensive analysis.
Project Proposal Form
Type of project
Electricity generation
Contact information of the project promoter
Name of the company:
NIS j.s.c.
Activities of the company:
oil and gas exploration, exploitation, refining, sales, electricity production
(e.g. transmission, production etc.)
Contact person:
Nenad V. Pavlovic
Email address:
[email protected]
Phone Number:
+381214815054
Please indicate if there are other undertakings involved in the project:
Project Summary
Brief description of the project:
Small CHP plants are to be used for electricity generation for the market, as well as heat production for heating of the
process facilities and equipment at the drilling rigs Velebit , Sirakovo, Kikinda, Turija, Boka, Bradarac, and Srbobran.
Heating at the sites is currently provided from steam and/or hot water boilers fired by available flare gas. However, only a
small amount of flare gas is used in boiler plants while the largest portion is burnt at flambeaus. Thereby, small CHP shall
help reduce technical losses in oil production, increase cost effectiveness, while keeping the same or lower pollution of the
environment in the country and the region.
Nature of the project:
New infrastructure
77
Contracting Parties / EU Member States involved in / affected by the project:
Hungary, Romania
What are the impacts of the project on the neighbouring countries?
positive market effect, increased competitiveness, increased supply options
Are there interdependencies / complementarities with other projects submitted to the list in this consultation?
n/a
Technical details of the project:
Geographical location:
multiple locations in Serbia, Velebit, Sirakovo, Kikinda, Turija, Srbobran, Boka,
Bradarac
(please indicate the start/end coordinates and length if applicable)
Generation capacity:
CHP units with total electric capacity of 7.5 Mwe
(please describe the capacities of the project and indicating the units)
Add more if needed
Internal Combustion engines (IC) with associated heat exchangers; Main equipment incl. IC engines, C & I, electric
generator, IC engine coolers are placed in the container; Fare gas is used at all sites except site Srbobran where natural
gas is used; Both flare and natural gas are very rich in inertous gases (nitrogen and carbon dioxide) and cannot be sold to
the natural gas transmission system. Emissions of the polluting gases shall be reduced due to higher combustion efficiency
of IC engine compared to actual combustion at the flammables. In total 9 CHP units with total electric capacity of 7.5 Mwe
shall be installed in year 2013, namely Velebit 2 x 995 kWe, Sirakovo 1 x 850 kWe, Kikinda 1 x 995 kWe, Turija 1 x 999
kWe, Boka 350 kWe, Bradarac 300 kWe, and Srbobran 2 x 995 kWe. Generation output (GWh) 60 GWh annually
(please describe the capacities of the project and indicating the units)
Implementation status:
Permitting
Estimated project costs:
€ 9.2 million
(capital expenditure in million euros)
Planned date of commissioning (year)
2013
Details of the project:
How will this investment item facilitate market integration, elimination of isolated markets, competition and system flexibility?
Please specify in particular the impact on energy system-wide generation and transmission costs.
The potential for use of cogeneration as a measure to save energy is underused particularly in the Energy Community
Contracting Parties at present. Promotion of high-efficiency cogeneration based on a useful heat demand is a Community
priority given the potential benefits of cogeneration with regard to saving primary energy, avoiding network losses and
reducing emissions, in particular of greenhouse gases. In addition, in general efficient use of energy by cogeneration can
also contribute positively to the security of energy supply and to the competitive situation both in the Contracting Parties as
well as in the EU Member States. It is therefore necessary to take measures to ensure that the potential is better exploited
within the framework of the internal energy market. In the context of the applicable legislative framework, the development
of cogeneration contributes to enhancing competition, also with regard to new market actors.. Plants shall contribute to the
market competition at production and distribution levels. Last, but not least – the development of these specific CHP
generation capacities on oil and gas fields is a new approach for the Contracting Parties. Therefore, the successful
implementation of the projects can be used as best practice approach later by others.
How will the investment item facilitate sustainability, inter alia through the transmission of renewable generation to major
consumption centres and storage sites? Please specify in particular, which capacity of renewable generation will be
connected directly or indirectly (in GW/1000 km²). Please specify also the type of renewable generation capacity concerned
and specify whether it is existing renewable generation or planned.
The project is a unique and pioneering project of this type in the Republic of Serbia and in the Contracting Parties. It will
contribute to the improvement of production and use of energy and diversification of methods of electricity production and
consumption in Serbia and the region of SEE – due to this, Serbia is in position to provide special support to the projects’
development via the existing support schemes aiming at promotion of production and consumption of electricity. This will
78
contribute to the integration of existing electricity distribution and consumption system in the Republic of Serbia and the
region.
How will this investment item contribute to security of supply and secure and reliable system operation? Please specify in
particular for how many years the project will secure load growth for a given area of consumption. Please specify also the
size of that area of consumption (in TWh/year).
Why is this investment item particularly necessary for the implementation of the Energy Community Strategy?
Local electricity generation shall help distribution system in the area of the sites to operate in a more stabile manner and
improve the security of supply to the neighbouring consumers, including in terrirories of neighbouring countries, where this
is financially viable. Thus, the project development shall represent market integration in real terms. Further to these
arguments, the realisation of the project is also linked to the usage of locally available primary energy sources that
otherwise cannot be used either as energy carrier or as a raw material for other production.
Your Details
Title:
Dr
First name:
Thomas
Last name:
Kurschat
Name of organization:
E.ON-Ruhrgas AG
Job title:
Senior System Manager
Address:
Brüsseler Platz 1
Postcode:
45131
City:
Essen
Country:
Germany
Email: *
[email protected]
Phone No:
+49 201 184 7100
Project Comment Form
Project number (ID and code) as indicated in the list:
G022
Comments on the project:
TAP opens the southern gas corridor enabling new, competitive and sustainable supply from Middle East and the Caspian
region – a region with large gas sources – to Italy and other Western European Markets (e.g. Germany, France) and to the
SEE region. TAP can be expanded with marginal investment from 10 to 20 bcm/a to allow for a build-up of supply. TAP is
aligned with the development of gas fields in Azerbaijan (i.e. Shah Deniz II and other upstream projects) and is among the
preferred export routes for Caspian gas to Europe. Thus it is ensured that the pipeline will be filled with gas. TAP improves
European security of supply by diversifying sources and routes. TAP creates new capacity to European gas supply and
thereby enhances competition. TAP offers a significant physical reverse flow option. The planned Ionian Adriatic Pipeline
(IAP) and the Western Balkan Ring (WBR) could be connected to TAP in order to significantly increase diversification,
competition and security of supply for the less diversified countries in the SEE region. TAP is well supported by regional
governments as Italy, Greece and Albania have already signed an intergovernmental agreement. Due to strong and well
established European shareholders TAP offers good institutional and financial background.
Your Details
Title:
Division Director
79
First name:
Nikos
Last name:
Katsis
Name of organization:
DESFA S.A.
Job title:
Strategy & Business Planning
Address:
Messogion 357 - 359
Postcode:
152 31
City:
Halandri
Country:
Greece
Email: *
[email protected]
Phone No:
+30 210 6501528
General Comments
You are invited to provide your general comments in this section
The area of Southeastern Europe needs new infrastructure projects so as to enhance the Security of Supply as well as the
competition in the emerging gas markets of the region. The Project "Trans Adriatic Pipeline - TAP" is the one which fullfils all the
criteria mentioned above. The cooperation of TAP with all the transit countries in the region, as it was illustrated in the recent
Trilateral Intergovernmental Agreement among Greece, Albania and Italy, gives a strong signal that the project is feasible and
realistic, assuring significant advantages for all the relevant parties. DESFA supports the project and it is interested for co
operation with TAP in several levels.
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
It is important, the Regulations and Directives applied in the EU level to apply also in the region where Energy Community is
activated, taking of course into consideration the special features of the region. The EU Member States participating in the
Energy Community (like Greece) could transfer their knowledge for the efficient implementation and operation of new
infrastructure projects under a reliable regulatory regime.
Project Comment Form
Project number (ID and code) as indicated in the list:
G022
Comments on the project:
DESFA supports the TAP project as it is a realistic investment enhancing the Security of Supply and the competition in the
emerging gas markets of the region
Your Details
First name:
Azra
Last name:
Tukic
Name of organization:
"KTG Zenica" Ltd. Zenica
Job title:
acting General Director
Address:
Bulevar Kralja Tvrtka I, No 17
Postcode:
72 000
80
City:
Zenica
Country:
Bosnia and Herzegovina
Email: *
[email protected]
Phone No:
+38732
Phone No:
+38732
NEW Projects to be Added (1)
In case you consider that a project should be added to the list, please indicate the project details below. Please note that the aim
of this questionnaire is to get a general overview of the proposed project. Project promoter(s) may be required to submit further
information to allow for an extensive analysis.
Project Proposal Form
Type of project
Electricity generation
Contact information of the project promoter
Name of the company:
"KTG Zenica" Ltd. Zenica
Activities of the company:
Electricity generation
(e.g. transmission, production etc.)
Contact person:
Azra Tukic
Email address:
[email protected]
Phone Number:
+38732209000
Please indicate if there are other undertakings involved in the project:
Project Summary
Brief description of the project:
The project will be one of the largest investments in Bosnia and Herzegovina in the post-war period and will improve the
quality of life in Zenica and the Region alike. In addition, the plant will, in the heating season, replace the current
consumption of around 700 tons of coal per day thereby significantly contributing to pollution reduction. The gas fired plant
with an installed electrical capacity of 390MWel and an installed thermal capacity of 170MWth will have degree of flexibility
to cover the fluctuating power demand in Bosnia and Herzegovina. The technical plant concept of the Project is based on
two GTs with electrical output of approx. 126MWel, two HRSGs and one ST with the estimated maximum electrical output of
135MWel. The gas turbines will operate on natural gas fuel. The steam turbine will be equipped with steam extraction taps
to provide the required amount of steam to cover for the thermal requirements of 170MWth for the district heating system of
the city of Zenica.
Brief description of the project:
The project will be one of the largest investments in Bosnia and Herzegovina in the post-war period and will improve the
quality of life in Zenica and the Region alike. In addition, the plant will, in the heating season, replace the current
consumption of around 700 tons of coal per day thereby significantly contributing to pollution reduction. The gas fired plant
with an installed electrical capacity of 390MWel and an installed thermal capacity of 170MWth will have degree of flexibility
to cover the fluctuating power demand in Bosnia and Herzegovina. The technical plant concept of the Project is based on
two GTs with electrical output of approx. 126MWel, two HRSGs and one ST with the estimated maximum electrical output of
135MWel. The gas turbines will operate on natural gas fuel. The steam turbine will be equipped with steam extraction taps
to provide the required amount of steam to cover for the thermal requirements of 170MWth for the district heating system of
the city of Zenica.
Nature of the project:
New infrastructure
What are the impacts of the project on the neighbouring countries?
81
Project realization will ensure security of power supply and fortify the energy market in the Region.
Are there interdependencies / complementarities with other projects submitted to the list in this consultation?
No
Technical details of the project:
Geographical location:
Municipality of Zenica, Federation of Bosnia and Herzegovina, Bosnia and
Herzegovina
(please indicate the start/end coordinates and length if applicable)
Voltage:
220 Kv
(please describe the capacities of the project and indicating the units)
Generation capacity:
387, 5 MWh; 2 X GT 126 MW; 1 X ST 135,5
(please describe the capacities of the project and indicating the units)
Generation capacity:
387, 5 MWh; 2 X GT 126 MW; 1 X ST 135,5
(please describe the capacities of the project and indicating the units)
Add more if needed
1. Generation output (GWh) - 2, 301 GWh per year; 2. Response time - between 15 to 45 minutes, depending on a cold,
warm or hot start; 3. The plant will be in operation 30 years from the date o its commissioning.
(please describe the capacities of the project and indicating the units)
Implementation status:
Final Investment Decision (FID)
Estimated project costs:
350 to 400 Million Euros
(capital expenditure in million euros)
Planned date of commissioning (year)
between Q4 2015 and Q1 2016
Details of the project:
How will this investment item facilitate market integration, elimination of isolated markets, competition and system flexibility?
Please specify in particular the impact on energy system-wide generation and transmission costs.
B&H's vicinity to south-eastern and central European countries with electricity import demand makes KTG Zenica CHPP
very attractive with regard to electricity trading/export. KTG Zenica CHPP is the first Independent Power Production project
in B&H and would significantly contribute to the energy balancing of the region.
How will the investment item facilitate sustainability, inter alia through the transmission of renewable generation to major
consumption centres and storage sites? Please specify in particular, which capacity of renewable generation will be
connected directly or indirectly (in GW/1000 km²). Please specify also the type of renewable generation capacity concerned
and specify whether it is existing renewable generation or planned.
KTG Zenica CHPP is the only plant in the Region that could effectively balance the renewable generation with its fast and
flexible reaction time; the GE turbines of this kind are used on a wide range all over the world also for the balancing of the
grid.
How will this investment item contribute to security of supply and secure and reliable system operation? Please specify in
particular for how many years the project will secure load growth for a given area of consumption. Please specify also the
size of that area of consumption (in TWh/year).
It is state of art new technology that is needed in the Region, the plant will be reliable and secure source of power supply for
the Region and will operate approx. 30 years from the date of its commissioning.
Why is this investment item particularly necessary for the implementation of the Energy Community Strategy?
The purpose of KTG Zenica CHPP is to provide the Municipality of Zenica with reliable, long-term sufficient source of
thermal power for the district heating and to generate electrical power for feed-in into the B&H grid and for the export to
neighboring countries.
82
Why is this investment item particularly necessary for the implementation of the Energy Community Strategy?
The purpose of KTG Zenica CHPP is to provide the Municipality of Zenica with reliable, long-term sufficient source of
thermal power for the district heating and to generate electrical power for feed-in into the B&H grid and for the export to
neighboring countries.
Your Details
Title:
Mr.
First name:
Paul
Last name:
Shea
Name of organization:
Statoil ASA
Job title:
Principal Business Developer
Address:
Forusbeen 50
Postcode:
4035
City:
Forus
Country:
Norway
Email: *
[email protected]
Phone No:
+47 4765 3581
Project Comment Form
Project number (ID and code) as indicated in the list:
G022
Comments on the project:
The Trans Adriatic Pipeline (TAP) and the Ionian Adriatic Pipeline (IAP) provide substantial added value and advance all
three of the Energy Community’s stated objectives: 1. Creating a competitive and integrated energy market; 2. Attracting
investments in energy and; 3. Providing secure and sustainable energy supply to customers. The TAP project was
unanimously selected by the Shah Deniz consortium in February 2012 as the alternative for gas supplies to Italy under eight
openly communicated and transparent selection criteria. TAP remains in competition with Nabucco West on becoming the
pipeline project opening the Southern Gas Corridor, connecting the European Union with gas supplies from Azerbaijan and
the Caspian Region. This open competition, with a level playing field, seeks to ensure an optimal outcome for end
consumers and investors. TAP plays a decisively important role in connecting the natural gas markets of Italy and Greece
and for supplying gas to Albania. TAP also has up to 80% physical reverse flow which could be used in emergencies. TAP’s
regional importance was acknowledged on February 13th, 2013 when a tri-lateral intergovernmental agreement (IGA) was
signed in Athens, Greece, by ministers from the host countries providing TAP with the unconditional political support
required to underpin the feasibility of the project. An interconnection with the bi-directional IAP would carry the gas further
afield and allow for the integration of Albania, Montenegro, Southern Croatia, Bosnia and Herzegovina. This not only
increases the competitiveness of the energy mix, with natural gas as a source fuel for power generation, but also creates a
new source of raw material and a substitute product for industrial inputs. TAP is committed to providing Albania physical
access to the natural gas with pressure reduction and metering facilities. This access creates opportunities for further
investments in the gas sector and on December 24th 2012, the status of “National Importance” was granted to TAP by the
National Territorial Council chaired by the Albanian Prime Minister. With TAP’s initial transportation capacity of 10 bcm per
year, expandable to 20 bcm, TAP creates new opportunities to scale and market natural gas. End consumers would benefit
by TAP being the shortest route for Caspian Gas to reach European markets. TAP’s foreign direct investment would also
benefit an economically depressed region and signal strong investor confidence. TAP not only increases the security of
supply for South Eastern Europe – it also diversifies the natural gas supply and increases competition among suppliers.
Security of supply benefits do not stop at the Italian border; Northern and Western European markets will benefit by being
able to access the Southern Gas Corridor volumes via Italy without significant further investments. Statoil ASA recommends
that the Energy Community Strategy Task Force considers both the Trans Adriatic Pipeline (TAP) and the Ionian Adriatic
Pipeline (IAP) for selection as Projects of Energy Community Interest. Bjarne Lauritz Bull-Berg Vice President Business
Development Statoil ASA Philippe F. Mathieu Senior Vice President Business Development Statoil ASA
83
Your Details
Title:
Mr
First name:
Edib
Last name:
Bašić
Name of organization:
Elektroprivreda BiH d.d. – Sarajevo (EP BiH)
Job title:
Director of Project Implementation Unit (PIU)
Address:
Vilsonovo šetalište 15
Postcode:
71000
City:
Sarajevo
Country:
Bosnia and Herzegovina
Email: *
[email protected]
Phone No:
+38733751030
NEW Projects to be Added (1)
In case you consider that a project should be added to the list, please indicate the project details below. Please note that the aim
of this questionnaire is to get a general overview of the proposed project. Project promoter(s) may be required to submit further
information to allow for an extensive analysis.
Project Proposal Form
Type of project
Electricity generation
Contact information of the project promoter
Name of the company:
Elektroprivreda BiH d.d. – Sarajevo (EP BiH)
Activities of the company:
Power generation, distribution, trade and supply of electricity
(e.g. transmission, production etc.)
Contact person:
Basic Edib, Director of Project Implementation Unit (PIU)
Email address:
[email protected]
Phone Number:
+38733751030
Please indicate if there are other undertakings involved in the project:
Project Summary
Brief description of the project:
The wind farm Borisavac is planned to be located at about 19 km away from the town of Konjic, at an altitude of 1171 m
a.s.l. The estimated capacity of the site 48.0 MW, with a capacity factor of 22.6 % (95 GWh p.a.). Measurements according
to IEC 61400-12 is performed since July 2010.
Nature of the project:
New infrastructure
Contracting Parties / EU Member States involved in / affected by the project:
84
The project is currently still at a research stage, with available two year data records. The participation of other interest
parties is therefore expected in the time to come.
What are the impacts of the project on the neighbouring countries?
The project does not cross borders directly, however, it contributes to the diversity of the generation portfolio and
strengthening of the regional power market, promotion of RES and GHG emission redu
Are there interdependencies / complementarities with other projects submitted to the list in this consultation?
Technical details of the project:
Geographical location:
Mountain Prenj – Municipality of Konjic
(please indicate the start/end coordinates and length if applicable)
Transmission capacity:
110 kV HV overhead line, approx. 1 km from the loc
(please describe the capacities of the project and indicating the units)
Voltage:
110 kV
(please describe the capacities of the project and indicating the units)
Generation capacity:
48.0 MW, 16 wind turbines (3.0 MW/turbine)
(please describe the capacities of the project and indicating the units)
Add more if needed
Project name: WP Borisavac; Generation output: 95 GWh p.a.
(please describe the capacities of the project and indicating the units)
Implementation status:
Pre-feasibility
Estimated project costs:
Approx. 65 million €
(capital expenditure in million euros)
Planned date of commissioning (year)
2021
Details of the project:
How will this investment item facilitate market integration, elimination of isolated markets, competition and system flexibility?
Please specify in particular the impact on energy system-wide generation and transmission costs.
The project contributes directly to the integration of the internal energy market, as it increases the volume of trade and
contributes to the development of the regional market of renewable energy sources, as well as fosters further development
of the regional balancing market.
How will the investment item facilitate sustainability, inter alia through the transmission of renewable generation to major
consumption centres and storage sites? Please specify in particular, which capacity of renewable generation will be
connected directly or indirectly (in GW/1000 km²). Please specify also the type of renewable generation capacity concerned
and specify whether it is existing renewable generation or planned.
How will this investment item contribute to security of supply and secure and reliable system operation? Please specify in
particular for how many years the project will secure load growth for a given area of consumption. Please specify also the
size of that area of consumption (in TWh/year).
Why is this investment item particularly necessary for the implementation of the Energy Community Strategy?
The project ensures security of supply and a secure and reliable system operation by increasing power generation
capacities in an area where demand is higher that the available supply, which should reduce power exchange at the
85
interconnection lines. The project also increases competitiveness on the regional energy market.
NEW Projects to be Added (2)
In case you consider that a project should be added to the list, please indicate the project details below. Please note that the aim
of this questionnaire is to get a general overview of the proposed project. Project promoter(s) may be required to submit further
information to allow for an extensive analysis.
Project Proposal Form
Type of project
Electricity generation
Contact information of the project promoter
Name of the company:
Elektroprivreda BiH d.d. – Sarajevo (EP BiH)
Activities of the company:
Power generation, distribution, trade and supply of electricity
(e.g. transmission, production etc.)
Contact person:
Basic Edib, Director of Project Implementation Unit (PIU)
Email address:
[email protected]
Phone Number:
+38733751030
Please indicate if there are other undertakings involved in the project:
KfW Development Bank
Project Summary
Brief description of the project:
The wind farm Podvelezje is planned to be located at about 5 km away from the town of Mostar, at an altitude of 750 m
a.s.l. The estimated capacity of the site is 40.0 – 48.0 MW, with a capacity factor of 24.0% (84.1 – 100.9 GWh p.a.).
Nature of the project:
New infrastructure
Contracting Parties / EU Member States involved in / affected by the project:
The project involves participation of KfW in the project preparation and implementation phase.
What are the impacts of the project on the neighbouring countries?
The project does not cross borders directly, however, it contributes to the diversity of the generation portfolio and
strengthening of the regional power market, promotion of RES and GHG emission redu
Technical details of the project:
Geographical location:
Plateou Podvelezje – Municipality of Mostar
(please indicate the start/end coordinates and length if applicable)
Transmission capacity:
110 kV HV overhead line, approx. 1 km from the loc
(please describe the capacities of the project and indicating the units)
Voltage:
110 kV
(please describe the capacities of the project and indicating the units)
Generation capacity:
40.0 – 48.0 MW, 16 wind turbines (2.5 – 3.0 MW/tur
86
(please describe the capacities of the project and indicating the units)
Add more if needed
Project name: WP Podvelezje; Generation output: 84.1 – 100.9 GWh p.a.
(please describe the capacities of the project and indicating the units)
Implementation status:
Permitting
Estimated project costs:
Approx. 65 – 72 million €
(capital expenditure in million euros)
Planned date of commissioning (year)
2014
Details of the project:
How will this investment item facilitate market integration, elimination of isolated markets, competition and system flexibility?
Please specify in particular the impact on energy system-wide generation and transmission costs.
The project contributes directly to the integration of the internal energy market, as it increases the volume of trade and
contributes to the development of the regional market of renewable energy sources, as well as fosters further development
of the regional balancing market.
How will the investment item facilitate sustainability, inter alia through the transmission of renewable generation to major
consumption centres and storage sites? Please specify in particular, which capacity of renewable generation will be
connected directly or indirectly (in GW/1000 km²). Please specify also the type of renewable generation capacity concerned
and specify whether it is existing renewable generation or planned.
How will this investment item contribute to security of supply and secure and reliable system operation? Please specify in
particular for how many years the project will secure load growth for a given area of consumption. Please specify also the
size of that area of consumption (in TWh/year).
The project ensures security of supply and a secure and reliable system operation by increasing power generation
capacities in an area where demand is higher that the available supply, which should reduce power exchange at the
interconnection lines. The project also increases competitiveness on the regional energy market.
Why is this investment item particularly necessary for the implementation of the Energy Community Strategy?
With the ratification of the Treaty establishing the Energy Community, Bosnia-Herzegovina has taken over obligations
towards meeting targets of: creating a stable regulatory and market framework, creating a single regulatory space for trade
in Network Energy, enhancing the security of supply, improving the environmental situation in relation to Network Energy
and related energy efficiency and fostering the use of renewable energy. This project is a step forward towards
implementation of these goals as it incorporates most of the indicated scopes, particularly in terms of improving the
environmental situation, fostering the use of renewable energy and diversity of resource capacity. It also marks a step
forward towards market framework advancement, as it represents a specific energy source requiring a different approach to
power system regulation and regional market approach.
NEW Projects to be Added (3)
In case you consider that a project should be added to the list, please indicate the project details below. Please note that the aim
of this questionnaire is to get a general overview of the proposed project. Project promoter(s) may be required to submit further
information to allow for an extensive analysis.
Project Proposal Form
Type of project
Electricity generation
Contact information of the project promoter
Name of the company:
Elektroprivreda BiH d.d. – Sarajevo (EP BiH)
Activities of the company:
Power generation, distribution, trade and supply of electricity
87
(e.g. transmission, production etc.)
Contact person:
Basic Edib, Director of Project Implementation Unit (PIU)
Email address:
[email protected]
Phone Number:
+38733751030
Project Summary
Brief description of the project:
Wind Park – „WP Medvedjak“ The wind farm Medvedjak is planned to be located at about 25 km away from the town of
Bihac, at an altitude of 970 m a.s.l. The estimated capacity of the site is 33.0 MW, with a capacity factor of 25.6 % (74 GWh
p.a.). Measurements according to IEC 61400-12 are performed since end of yaer 2010.
Nature of the project:
New infrastructure
Contracting Parties / EU Member States involved in / affected by the project:
Bosnia - Herzegovina
What are the impacts of the project on the neighbouring countries?
the increase in installed generation capacity, due to high power demand and lack of available power supply, fortification of
security of supply and strengthening of the regional power market,RES promo
Technical details of the project:
Geographical location:
Latitude:44, 69˚ N, Longitude:16, 13˚ E
(please indicate the start/end coordinates and length if applicable)
Voltage:
110 kV
(please describe the capacities of the project and indicating the units)
Generation capacity:
cca 74 GWh p.a
(please describe the capacities of the project and indicating the units)
Implementation status:
Pre-feasibility
Estimated project costs:
Approx. 45 million €
(capital expenditure in million euros)
Planned date of commissioning (year)
2016
Details of the project:
How will this investment item facilitate market integration, elimination of isolated markets, competition and system flexibility?
Please specify in particular the impact on energy system-wide generation and transmission costs.
The project implementation will contribute to the share of renewable energy sources in the current generation portfolio mix
in Bosnia-Herzegovina, which now amounts 46%:54% in installed capacity in thermal and hydro power plants, respectively,
and in that way make it more competitive at the electricity market. Also, the project contributes directly to the integration of
the internal energy market, as it increases the volume of trade and contributes to the development of the regional market of
renewable energy sources, as well as fosters further development of the regional balancing market. The project
implementation will reduce generation and transmission costs, since there are no costs for the used energy resource, and
the generating unit will be located near a consumption center where demand is higher that the available supply, which
should reduce power exchange, as well as power losses at the interconnection lines.
How will the investment item facilitate sustainability, inter alia through the transmission of renewable generation to major
consumption centres and storage sites? Please specify in particular, which capacity of renewable generation will be
connected directly or indirectly (in GW/1000 km²). Please specify also the type of renewable generation capacity concerned
88
and specify whether it is existing renewable generation or planned.
The project implementation will contribute to the share of renewable energy sources in the current generation portfolio mix
in Bosnia-Herzegovina, which now amounts 46%:54% in installed capacity in thermal and hydro power plants, respectively,
and in that way facilitate sustainability, renewable energy sources promotion and GHG emission reduction.
How will this investment item contribute to security of supply and secure and reliable system operation? Please specify in
particular for how many years the project will secure load growth for a given area of consumption. Please specify also the
size of that area of consumption (in TWh/year).
The project implementation will add new cca 33 MW, i.e. 74 GWh per year, into the power system from renewable energy,
wind energy in particular, and in that way increase resource capacity, resulting in fortification of security of supply. This
project will increase power generation capacities in an area of consumption where demand is higher that the available
supply, which should reduce power exchange at the interconnection lines.
Why is this investment item particularly necessary for the implementation of the Energy Community Strategy?
With the ratification of the Treaty establishing the Energy Community, Bosnia - Herzegovina has taken over obligations
towards meeting targets of: creating a stable regulatory and market framework, creating a single regulatory space for trade
in Network Energy, enhancing the security of supply, improving the environmental situation in relation to Network Energy
and related energy efficiency and fostering the use of renewable energy. This project is a step forward towards
implementation of these goals as it incorporates most of the indicated scopes, particularly in terms of improving the
environmental situation, fostering the use of renewable energy and diversity of resource capacity. It also marks a step
forward towards market framework advancement, as it represents a specific energy source requiring a different approach to
power system regulation and regional market approach.
NEW Projects to be Added (4)
In case you consider that a project should be added to the list, please indicate the project details below. Please note that the aim
of this questionnaire is to get a general overview of the proposed project. Project promoter(s) may be required to submit further
information to allow for an extensive analysis.
Project Proposal Form
Type of project
Electricity transmission
Contact information of the project promoter
Name of the company:
Elektroprivreda BiH d.d. – Sarajevo (EP BiH)
Activities of the company:
Power generation, distribution, trade and supply of electricity
(e.g. transmission, production etc.)
Contact person:
Basic Edib, Director of Project Implementation Unit (PIU)
Email address:
[email protected]
Phone Number:
+38733751030
Project Summary
Brief description of the project:
HPP Kozluk Run-of-river hydropower plant with a water storage, plant inside the dam. Location: Drina river, 20 km
downstream from Zvornik. Connection point to transmission network: existing 110 kV over head transmission line, installed
capacity 67,2 MW.
Nature of the project:
New infrastructure
Contracting Parties / EU Member States involved in / affected by the project:
Bosnia - Herzegovina and Serbia
What are the impacts of the project on the neighbouring countries?
89
The project implementation will contribute to optimal utilization of the water catchment area of the Drina river. It will also
contribute to load balancing, considering planned WPP and PVPP projects,
Are there interdependencies / complementarities with other projects submitted to the list in this consultation?
Yes, with other HPP projects planned on Drina river (i.e. HPP Visegrad, HPP Bajina Basta, HPP Zvornik and future HPP
Tegare). EPS from Republic of Serbia, as a project promoter, submitted the project
Technical details of the project:
Geographical location:
20 km downstream from Zvornik town
(please indicate the start/end coordinates and length if applicable)
Voltage:
110 kV
(please describe the capacities of the project and indicating the units)
Generation capacity:
cca 354 GWh p.a
(please describe the capacities of the project and indicating the units)
Implementation status:
Pre-feasibility
Estimated project costs:
Approx. 128 million €
(capital expenditure in million euros)
Planned date of commissioning (year)
2018
Details of the project:
How will this investment item facilitate market integration, elimination of isolated markets, competition and system flexibility?
Please specify in particular the impact on energy system-wide generation and transmission costs.
Generated power will be shared in 50% to 50% between countries, which will contribute directly to the integration of the
internal energy market, as it increases the volume of trade and contributes to the development of the regional market of
renewable energy sources, as well as fosters further development of the regional balancing market. The project
implementation will reduce generation and transmission costs, since there are no costs for the used energy resource, and
the generating unit will be located near significant consumption cetres, so that its construction should reduce power
exchange, as well as transmission losses at the interconnection lines.
How will the investment item facilitate sustainability, inter alia through the transmission of renewable generation to major
consumption centres and storage sites? Please specify in particular, which capacity of renewable generation will be
connected directly or indirectly (in GW/1000 km²). Please specify also the type of renewable generation capacity concerned
and specify whether it is existing renewable generation or planned.
The project implementation will contribute to the share of renewable energy sources in the current generation portfolio mix
in Bosnia-Herzegovina, which now amounts 46%:54% in installed capacity in thermal and hydro power plants, respectively,
and in that way facilitate sustainability, renewable energy sources promotion and GHG emission reduction.
How will this investment item contribute to security of supply and secure and reliable system operation? Please specify in
particular for how many years the project will secure load growth for a given area of consumption. Please specify also the
size of that area of consumption (in TWh/year).
The project implementation will add new cca 67 MW, i.e. 354 GWh per year, into the power system from renewable energy,
hydro energy in particular, and in that way increase resource capacity, resulting in fortification of security of supply. Total
storage capacity is 49,8 hm3; with four units 4 x 17 MW security of supply will be increased.
Why is this investment item particularly necessary for the implementation of the Energy Community Strategy?
With the ratification of the Treaty establishing the Energy Community, Bosnia - Herzegovina has taken over obligations
towards meeting targets of: creating a stable regulatory and market framework, creating a single regulatory space for trade
in Network Energy, enhancing the security of supply, improving the environmental situation in relation to Network Energy
and related energy efficiency and fostering the use of renewable energy. This project is a step forward towards
implementation of these goals as it incorporates most of the indicated scopes, particularly in terms of improving the
environmental situation, fostering the use of renewable energy and diversity of resource capacity. Since this project is a
common project between Serbia and Bosnia-Herzegovina, its realisation will contribute to increase of renewable energy
production and regional market integration
90
NEW Projects to be Added (5)
In case you consider that a project should be added to the list, please indicate the project details below. Please note that the aim
of this questionnaire is to get a general overview of the proposed project. Project promoter(s) may be required to submit further
information to allow for an extensive analysis.
Project Proposal Form
Type of project
Electricity generation
Contact information of the project promoter
Name of the company:
Elektroprivreda BiH d.d. – Sarajevo (EP BiH)
Activities of the company:
Power generation, distribution, trade and supply of electricity
(e.g. transmission, production etc.)
Contact person:
Basic Edib, Director of Project Implementation Unit (PIU)
Email address:
[email protected]
Phone Number:
+38733751030
Please indicate if there are other undertakings involved in the project:
Republic of Serbia 50%; Bosnia and Herzegovina 50%
Project Summary
Brief description of the project:
Run-of-river hydropower plant with a water storage, plant inside the dam
Nature of the project:
New infrastructure
Contracting Parties / EU Member States involved in / affected by the project:
Republic of Serbia, at the border to Bosnia and Herzegovina
What are the impacts of the project on the neighbouring countries?
Generated power will be shared in 50% to 50% between countries ensuring the integration of the energy market
Are there interdependencies / complementarities with other projects submitted to the list in this consultation?
Yes, with other HPP projects on the river Drina (HPP Višegrad, HPP Bajina Bašta, HPP Zvornik and future HPP Kozluk). In
the “List of electricity generation projects” , ID Project code EG006.
Technical details of the project:
Geographical location:
Location: Drina river at the territory of Bratunac municipality, downstream of
HPP
(please indicate the start/end coordinates and length if applicable)
Transmission capacity:
400 kV OHTL Višegrad-Tuzla
(please describe the capacities of the project and indicating the units)
Voltage:
400 kV
(please describe the capacities of the project and indicating the units)
91
Generation capacity:
248.0 MW, 4 units (65 MW/unit)
(please describe the capacities of the project and indicating the units)
(please describe the capacities of the project and indicating the units)
Add more if needed
Project name: HPP Tegare; Generation output: 1025 GWh p.a.
(please describe the capacities of the project and indicating the units)
Implementation status:
Pre-feasibility
Estimated project costs:
Approx. 682 million €
(capital expenditure in million euros)
Planned date of commissioning (year)
2019
Details of the project:
How will this investment item facilitate market integration, elimination of isolated markets, competition and system flexibility?
Please specify in particular the impact on energy system-wide generation and transmission costs.
Generated power will be shared in 50% to 50% between countries ensuring the integration of the energy market
How will the investment item facilitate sustainability, inter alia through the transmission of renewable generation to major
consumption centres and storage sites? Please specify in particular, which capacity of renewable generation will be
connected directly or indirectly (in GW/1000 km²). Please specify also the type of renewable generation capacity concerned
and specify whether it is existing renewable generation or planned.
How will this investment item contribute to security of supply and secure and reliable system operation? Please specify in
particular for how many years the project will secure load growth for a given area of consumption. Please specify also the
size of that area of consumption (in TWh/year).
Total storage capacity is 590 hm3; with four units 4 x 65 MW security of supply will be increased
Why is this investment item particularly necessary for the implementation of the Energy Community Strategy?
Since this project is a common project of Serbia and B&H, its realisation will contribute to increase of renewable energy
production and regional market integration.
NEW Projects to be Added (6)
In case you consider that a project should be added to the list, please indicate the project details below. Please note that the aim
of this questionnaire is to get a general overview of the proposed project. Project promoter(s) may be required to submit further
information to allow for an extensive analysis.
Project Proposal Form
Type of project
Electricity generation
Contact information of the project promoter
Name of the company:
Elektroprivreda BiH d.d. – Sarajevo (EP BiH)
Activities of the company:
Power generation, distribution, trade and supply of electricity
(e.g. transmission, production etc.)
Contact person:
Basic Edib, Director of Project Implementation Unit (PIU)
Email address:
[email protected]
92
Phone Number:
+38733751030
Project Summary
Brief description of the project:
Wind Park – „WP Bitovnja“ The wind farm Bitovnja is planned to be located at about 30 km west of Sarajevo, at an altitude
of 1656 m a.s.l. The estimated capacity of the site is 45.0 MW, with a capacity factor of 30.4 % (120 GWh p.a.).
Measurements according to IEC 61400-12 is performed since July 2010. The Feasibility study for this location has been
completed in October 2012.
Nature of the project:
New infrastructure
Contracting Parties / EU Member States involved in / affected by the project:
B&H
Technical details of the project:
Geographical location:
43°47'55.25"N, 17°57'28.15"E
(please indicate the start/end coordinates and length if applicable)
Voltage:
110 kV
(please describe the capacities of the project and indicating the units)
Generation capacity:
45.0 MW, 18 turbines (2.5 MW/turbine)
(please describe the capacities of the project and indicating the units)
Add more if needed
Generation output (GWh) 120 GWh p.a.
(please describe the capacities of the project and indicating the units)
Implementation status:
Feasibility / FEED
Estimated project costs:
63
(capital expenditure in million euros)
Planned date of commissioning (year)
2018
Details of the project:
How will this investment item facilitate market integration, elimination of isolated markets, competition and system flexibility?
Please specify in particular the impact on energy system-wide generation and transmission costs.
The project contributes directly to the integration of the internal energy market, as it increases the volume of trade and
contributes to the development of the regional market of renewable energy sources, as well as fosters further development
of the regional balancing market.
How will the investment item facilitate sustainability, inter alia through the transmission of renewable generation to major
consumption centres and storage sites? Please specify in particular, which capacity of renewable generation will be
connected directly or indirectly (in GW/1000 km²). Please specify also the type of renewable generation capacity concerned
and specify whether it is existing renewable generation or planned.
The current generation mix of Bosnia-Herzegovina is represented by a 46%:54% thermo-hydro ratio in installed capacity.
This project would additionally contribute to the share of renewable energy sources in the current generation portfolio.
How will this investment item contribute to security of supply and secure and reliable system operation? Please specify in
particular for how many years the project will secure load growth for a given area of consumption. Please specify also the
size of that area of consumption (in TWh/year).
93
The project ensures security of supply and a secure and reliable system operation by increasing power generation
capacities in an area where demand is higher that the available supply, which should reduce power exchange at the
interconnection lines. The project also increases competitiveness on the regional energy market
Why is this investment item particularly necessary for the implementation of the Energy Community Strategy?
With the ratification of the Treaty establishing the Energy Community, Bosnia- Herzegovina has taken over obligations
towards meeting targets of: creating a stable regulatory and market framework, creating a single regulatory space for trade
in Network Energy, enhancing the security of supply, improving the environmental situation in relation to Network Energy
and related energy efficiency and fostering the use of renewable energy. This project is a step forward towards
implementation of these goals as it incorporates most of the indicated scopes, particularly in terms of improving the
environmental situation, fostering the use of renewable energy and diversity of resource capacity. It also marks a step
forward towards market framework advancement, as it represents a specific energy source requiring a different approach to
power system regulation and regional market approach.
NEW Projects to be Added (7)
In case you consider that a project should be added to the list, please indicate the project details below. Please note that the aim
of this questionnaire is to get a general overview of the proposed project. Project promoter(s) may be required to submit further
information to allow for an extensive analysis.
Project Proposal Form
Type of project
Electricity generation
Contact information of the project promoter
Name of the company:
Elektroprivreda BiH d.d. – Sarajevo (EP BiH)
Activities of the company:
Power generation, distribution, trade and supply of electricity
(e.g. transmission, production etc.)
Contact person:
Basic Edib, Director of Project Implementation Unit (PIU)
Email address:
[email protected]
Phone Number:
+38733751030
Project Summary
Brief description of the project:
Wind Park – „WP Vlasic“ The wind fpark Vlasic is planned to be located at about 8 km away from the town of Travnik, at an
altitude of 1700 m a.s.l. The estimated capacity of the site is 50.0 MW, with a capacity factor of 27.4% (120 GWh p.a.). Wind
potential measurements according to IEC 61400-12 are performed since November 2011.
Nature of the project:
New infrastructure
Contracting Parties / EU Member States involved in / affected by the project:
Bosnia-Herzegovina; EIB – European Investment Bank / WBIF – Western Balkans Investment Framework
What are the impacts of the project on the neighbouring countries?
RES promotion, the increase in installed generation capacity, due to high power demand and lack of available power
supply; fortification of security of supply and strengthening of the regional power m
Technical details of the project:
Geographical location:
Latitude:44, 28˚ N, Longitude:17, 63˚ E
(please indicate the start/end coordinates and length if applicable)
94
Voltage:
110 kV
(please describe the capacities of the project and indicating the units)
Generation capacity:
cca 120 GWh p.a
(please describe the capacities of the project and indicating the units)
Implementation status:
Pre-feasibility
Estimated project costs:
Approx. 63 million €
(capital expenditure in million euros)
Planned date of commissioning (year)
2016
Details of the project:
How will this investment item facilitate market integration, elimination of isolated markets, competition and system flexibility?
Please specify in particular the impact on energy system-wide generation and transmission costs.
The project implementation will contribute to the share of renewable energy sources in the current generation portfolio mix
in Bosnia-Herzegovina, which now amounts 46%:54% in installed capacity in thermal and hydro power plants, respectively,
and in that way make it more competitive at the electricity market. Also, the project contributes directly to the integration of
the internal energy market, as it increases the volume of trade and contributes to the development of the regional market of
renewable energy sources, as well as fosters further development of the regional balancing market. The project
implementation will reduce generation and transmission costs, since there are no costs for the used energy resource, and
the generating unit will be located near a consumption center where demand is higher that the available supply, which
should reduce power exchange, as well as power losses at the interconnection lines.
How will the investment item facilitate sustainability, inter alia through the transmission of renewable generation to major
consumption centres and storage sites? Please specify in particular, which capacity of renewable generation will be
connected directly or indirectly (in GW/1000 km²). Please specify also the type of renewable generation capacity concerned
and specify whether it is existing renewable generation or planned.
The project implementation will contribute to the share of renewable energy sources in the current generation portfolio mix
in Bosnia-Herzegovina, which now amounts 46%:54% in installed capacity in thermal and hydro power plants, respectively,
and in that way facilitate sustainability, renewable energy sources promotion and GHG emission reduction.
How will this investment item contribute to security of supply and secure and reliable system operation? Please specify in
particular for how many years the project will secure load growth for a given area of consumption. Please specify also the
size of that area of consumption (in TWh/year).
The project implementation will add new cca 50 MW, i.e. 120 GWh per year, into the power system from renewable energy,
wind energy in particular, and in that way increase resource capacity, resulting in fortification of security of supply. This
project will increase power generation capacities in an area of consumption where demand is higher that the available
supply, which should reduce power exchange at the interconnection lines.
Why is this investment item particularly necessary for the implementation of the Energy Community Strategy?
With the ratification of the Treaty establishing the Energy Community, Bosnia - Herzegovina has taken over obligations
towards meeting targets of: creating a stable regulatory and market framework, creating a single regulatory space for trade
in Network Energy, enhancing the security of supply, improving the environmental situation in relation to Network Energy
and related energy efficiency and fostering the use of renewable energy. This project is a step forward towards
implementation of these goals as it incorporates most of the indicated scopes, particularly in terms of improving the
environmental situation, fostering the use of renewable energy and diversity of resource capacity. It also marks a step
forward towards market framework advancement, as it represents a specific energy source requiring a different approach to
power system regulation and regional market approach.
NEW Projects to be Added (8)
In case you consider that a project should be added to the list, please indicate the project details below. Please note that the aim
of this questionnaire is to get a general overview of the proposed project. Project promoter(s) may be required to submit further
information to allow for an extensive analysis.
Project Proposal Form
Type of project
Electricity generation
95
Contact information of the project promoter
Name of the company:
Elektroprivreda BiH d.d. – Sarajevo (EP BiH)
Activities of the company:
Power generation, distribution, trade and supply of electricity
(e.g. transmission, production etc.)
Contact person:
Basic Edib, Director of Project Implementation Unit (PIU)
Email address:
[email protected]
Phone Number:
+38733751030
Project Summary
Brief description of the project:
The wind farm Rostovo is planned to be located at about 12 km away from the town of Bugojno, at an altitude of 1318 m
a.s.l. The estimated capacity of the site is 12.0 – 18.0 MW, with a capacity factor of 19.0 – 22.2 % (20 – 35 GWh p.a.).
Measurements according to IEC 61400-12 is performed since July 2010.
Nature of the project:
New infrastructure
Contracting Parties / EU Member States involved in / affected by the project:
B&H
Technical details of the project:
Geographical location:
44° 6'42.84"N, 17°33'21.96"E
(please indicate the start/end coordinates and length if applicable)
Voltage:
110 kV
(please describe the capacities of the project and indicating the units)
Generation capacity:
12.0 – 18.0 MW, 6 turbines (2.0 – 3.0 MW/turbine)
(please describe the capacities of the project and indicating the units)
Implementation status:
Pre-feasibility
Estimated project costs:
Approx. 15 – 23 mil. €
(capital expenditure in million euros)
Planned date of commissioning (year)
2016
Details of the project:
How will this investment item facilitate market integration, elimination of isolated markets, competition and system flexibility?
Please specify in particular the impact on energy system-wide generation and transmission costs.
The project contributes directly to the integration of the internal energy market, as it increases the volume of trade and
contributes to the development of the regional market of renewable energy sources, as well as fosters further development
of the regional balancing market.
How will this investment item contribute to security of supply and secure and reliable system operation? Please specify in
particular for how many years the project will secure load growth for a given area of consumption. Please specify also the
size of that area of consumption (in TWh/year).
96
The project ensures security of supply and a secure and reliable system operation by increasing power generation
capacities in an area where demand is higher that the available supply, which should reduce power exchange at the
interconnection lines. The project also increases competitiveness on the regional energy market
Why is this investment item particularly necessary for the implementation of the Energy Community Strategy?
With the ratification of the Treaty establishing the Energy Community, Bosnia- Herzegovina has taken over obligations
towards meeting targets of: creating a stable regulatory and market framework, creating a single regulatory space for trade
in Network Energy, enhancing the security of supply, improving the environmental situation in relation to Network Energy
and related energy efficiency and fostering the use of renewable energy. This project is a step forward towards
implementation of these goals as it incorporates most of the indicated scopes, particularly in terms of improving the
environmental situation, fostering the use of renewable energy and diversity of resource capacity. It also marks a step
forward towards market framework advancement, as it represents a specific energy source requiring a different approach to
power system regulation and regional market approach.
NEW Projects to be Added (9)
In case you consider that a project should be added to the list, please indicate the project details below. Please note that the aim
of this questionnaire is to get a general overview of the proposed project. Project promoter(s) may be required to submit further
information to allow for an extensive analysis.
Project Proposal Form
Type of project
Contact information of the project promoter
Email address:
[email protected]
Phone Number:
+38733751030
Project Summary
Brief description of the project:
Run-of-river hydropower plant Ustikolina, plant inside the dam Location: Drina river at the teritorry of Ustikolina and Goražde
municipalities Connection point to transmission network: Connection to 110 kV transmission line Foča-Goražde
Nature of the project:
New infrastructure
Contracting Parties / EU Member States involved in / affected by the project:
B&H, Serbia
What are the impacts of the project on the neighbouring countries?
contribution to the load balancing, considering planned WPP and PVPP projects
Are there interdependencies / complementarities with other projects submitted to the list in this consultation?
Yes, with other HPP projects on river Drina
Technical details of the project:
Geographical location:
Drina river at the teritorry of Ustikolina and Goražde municipalities
(please indicate the start/end coordinates and length if applicable)
Voltage:
110 kV
(please describe the capacities of the project and indicating the units)
Generation capacity:
60 MW, Total generation output (GWh) = 237/year
(please describe the capacities of the project and indicating the units)
97
Add more if needed
Total generation output (GWh) = 237/year Installed total capacity (MW) = 60 ; number of units = 3 ; installed capacity/unit =
20 MW
(please describe the capacities of the project and indicating the units)
Implementation status:
Feasibility / FEED
Estimated project costs:
139 mil €
(capital expenditure in million euros)
Planned date of commissioning (year)
2019
Details of the project:
How will this investment item facilitate market integration, elimination of isolated markets, competition and system flexibility?
Please specify in particular the impact on energy system-wide generation and transmission costs.
The location of the planned HPP is on border of Bosnia and Herzegovina with Serbia. HPP Ustikolina is one of the many
planned projects in EP B&H based on renewables in order to decrease dependence on fosill fuels, decrease CO2 and
pollutant emmissions. Generation facility is located nearby significant consumption cetres which would contribute
transmission losses decrease.
How will this investment item contribute to security of supply and secure and reliable system operation? Please specify in
particular for how many years the project will secure load growth for a given area of consumption. Please specify also the
size of that area of consumption (in TWh/year).
This HPP is planned to be installed on river Drina, the border of B&H with Serbia. Considering the expectations for large
amount of WPP and PVPP integration in both countries, this project would contribute balancing load, and reliability of
system operation in periods with lack of wind and solar energy.
Why is this investment item particularly necessary for the implementation of the Energy Community Strategy?
This facility is fully in line with the objectives defined in the Strategy. HPP Ustikolina has significantly good economic
parameters, and, implementation of this project, among others, will contribute maintaining affordable prices of electricity in
region, considering the fact that construction of new generating facilities might also result in higher prices of electricity.
NEW Projects to be Added (10)
In case you consider that a project should be added to the list, please indicate the project details below. Please note that the aim
of this questionnaire is to get a general overview of the proposed project. Project promoter(s) may be required to submit further
information to allow for an extensive analysis.
Project Proposal Form
Type of project
Electricity generation
Contact information of the project promoter
Name of the company:
Elektroprivreda BiH d.d. – Sarajevo (EP BiH)
Activities of the company:
Power generation, distribution, trade and supply of electricity
(e.g. transmission, production etc.)
Contact person:
Basic Edib, Director of Project Implementation Unit (PIU)
Email address:
[email protected]
Phone Number:
+38733751030
Project Summary
98
Brief description of the project:
Due to planned continuously operation of unit 6 in TPP Tuzla in year 2018, considering EU Directives of Emission limit
values of pollutants, it is necessary to install FGD system in TPP TUZLA - Unit 6 - 215 MW Current Polutants Emission
kg/MWh SO2 15,38375503 NOx 2,59383959 Dust 2,416201875 CO2 1026,848789 LIFETIME 15 YEARS
Nature of the project:
Upgrading existing
Technical details of the project:
Geographical location:
Location TPP Tuzla unit 6
(please indicate the start/end coordinates and length if applicable)
Transmission capacity:
Connection point to transmission network 220 kV
(please describe the capacities of the project and indicating the units)
Voltage:
220 kV
(please describe the capacities of the project and indicating the units)
Generation capacity:
215 MW
(please describe the capacities of the project and indicating the units)
Implementation status:
Pre-feasibility
Estimated project costs:
50 mil €
(capital expenditure in million euros)
Planned date of commissioning (year)
2017
Details of the project:
How will this investment item facilitate market integration, elimination of isolated markets, competition and system flexibility?
Please specify in particular the impact on energy system-wide generation and transmission costs.
Unit 6 is reconstructed and modernized and in order to ensure possibility to operate in next period, it is neccessary to
reduce pollutant emissions.
Why is this investment item particularly necessary for the implementation of the Energy Community Strategy?
Implementation of this project would be in line with the EU directives,
99
MINISTRIES, OTHER STATE BODIES
Your Details
Title:
Prof. As. Dr.
First name:
Stavri
Last name:
Dhima
Name of organization:
Ministry of Economy, Trade and Energy
Job title:
Head of Regulatiry and management Unit of Petroleum Projects and Contracts
Address:
Bilvd. "Deshmoret e Kombit" No. 2
Postcode:
1001
City:
Tirana
Country:
ALBANIA
Email: *
[email protected]
Phone No:
+ 355 4 2222245/74176; + 355 68 20 56 182
General Comments
You are invited to provide your general comments in this section
We express our interest on gas infrastructure projects: -. Trans Adriatic Pipeline (TAP) project (ID project code: G022) -. Ionian
Adriatic Pipeline (IAP) project (ID project code: G008), as the two projects together will contribute to the development of a gas
market in Albania and the wider region As well, we express our interest on infrastructure gas projects: -. Underground Gas
Storage (UGS) project (ID project code: G001) -. Eagle LNG project (ID project code: G002), because the UGS project will have a
concrete contribution on the improving the feasibility of the gas infrastructure projects, meanwhile the Eagle LNG project will
contribute direct on the possibilities for the gasification of Albania. We consider those energy infrastructure projects as crucial for
the achievement of regional energy policy goals in terms of competition, market integration, security of supply and sustainability,
as well. Considering TAP project as the most advanced and the most important project for Albania, we believe that attaining PECI
status will allow TAP project to get accelerated and coordinated permit granting and licensing procedures, coordinated regulatory
authorizations and coordinated tariff methodologies adoption, support from relevant European Union funds and pre-accession
funds (TAP open the Southern European Gas Corridor), degree of fulfilment of criteria for IFI's financing, increased visibility for
investors, among other benefits.
Your Details
Title:
DR
First name:
STELIOS
Last name:
ALIFANTIS
Name of organization:
MINISTRY FOR ENVIRONMENT ENERGY AND CLIMATE CHANGE
Job title:
HEAD, INTERNATIONAL RELATIONS DEPARTMENT,ENERGY SECTOR
Address:
MESOGEION 119
Postcode:
10192
City:
ATHENS
100
Country:
GREECE
Email: *
[email protected]
Phone No:
0030 2106969567
Project Comment Form
Project number (ID and code) as indicated in
G022
the list:
Comments on the project:
TAP should be appointed as Project of Energy Community Interest (PECI) as it will: - support market opening and
competition in the region by introducing a new transport route and a diversified source of gas supplies. - build the first
transmission pipeline linking Italy, Greece and Albania, allowing the integration of Albania (presently lacking interstate gas
connections) into the regional gas market and contribute to the development of this country’s domestic gas market. contribute to the integration of the energy markets in the region by enabling the realisation of the Ionian Adriatic Pipeline
and the Western Balkan Ring, both regional interconnectors. TAP will facilitate the realisation of these projects by enabling
them access into a new and reliable source of gas supplies. - enhance regional cohesion and interoperability between
transmission system operators in the region, thanks to increased interconnectivity created by TAP between South Eastern
Europe (SEE) markets and the rest of the European gas markets will. - contribute to price convergence in the SEE area. create new opportunities for additional energy investments in the midstream and downstream sectors. - contribute to a more
secure energy supply by opening the Southern Gas Corridor, thus leading to the diversification of gas sources and transport
routes going into SEE. - contribute to regional security of supply by offering mechanisms to improve emergency response in
the event of supply disruptions. Specifically, TAP has designed its systems to accommodate physical reverse-flow and is
also evaluating the prospect to develop an underground gas storage facility in Albania. - promote sustainable energy in the
region by providing reliable access to natural gas. Gas-fired power plants could replace coal generation and contribute to
lower CO2 emissions. In addition, gas could be used to provide additional flexibility and backup generation to wind and solar
plants, thus facilitating the transition into a sustainable energy system.
Your Details
Title:
Engineer
First name:
Pietro
Last name:
Conversano
Name of organization:
Confindustria Puglia
Job title:
General Manager
Address:
Via Tridente , 22 BARI
Postcode:
70125
City:
Bari
Country:
Italy
Email: *
[email protected]
Phone No:
+39 080 5010600
General Comments
You are invited to provide your general comments in this section
TAP project is a good opportunity for Puglia region due to many big located companies that need high power energy.
Comments about facilitation measures for PECIs
101
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
Puglia Region Government had already regulatory, laws and program defining the need to modify the energy Power Central
operating with carbon in gas. At Puglia are operating many local companies with high competences on gas energy sector both for
pipes and machinery equipments both for building plants.
Your Details
Title:
Mr
First name:
Artan
Last name:
Leskoviku
Name of organization:
National Agency of Natural Resources
Job title:
Head of Energy
Address:
Bll.Vasil Shanto
Postcode:
1001
City:
Tirana
Country:
Albania
Email: *
[email protected]
Phone No:
+355692149084
General Comments
You are invited to provide your general comments in this section
Albania Request to include in PECI two project: 1. Electricity interconnection Albania-Italy 2. Hydro power plant "Skavica" Drini
river
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
Focus on the regional project
NEW Projects to be Added (1)
In case you consider that a project should be added to the list, please indicate the project details below. Please note that the aim
of this questionnaire is to get a general overview of the proposed project. Project promoter(s) may be required to submit further
information to allow for an extensive analysis.
Project Proposal Form
Type of project
Electricity generation
Contact information of the project promoter
Name of the company:
National Agency of Natural Resources
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Activities of the company:
Strategy Project
(e.g. transmission, production etc.)
Contact person:
Artan Leskoviku
Email address:
[email protected]
Phone Number:
+355692149084
Please indicate if there are other undertakings involved in the project:
Project Summary
Brief description of the project:
New Hydro Power Plant Svavica Drini River with capacity 330 MW
Nature of the project:
New infrastructure
Contracting Parties / EU Member States involved in / affected by the project:
Albania and supply region wirh Renewable Energy
What are the impacts of the project on the neighbouring countries?
The benefits of this Project are estimated to be important both for the energy sector and the development of the economy as
a whole. The construction of the hydro power plants will make the power syst
Are there interdependencies / complementarities with other projects submitted to the list in this consultation?
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CIVIL SOCIETY
Your Details
Title:
Dr. Eng.
First name:
Gjergji
Last name:
Simaku
Name of organization:
Polis University, International School of Architecture and Urban Development Policies
Job title:
Lecturer, Expert on Energy - freelance
City:
Tirana
Country:
Albania
Email: *
[email protected]
Phone No:
++355682021939
General Comments
You are invited to provide your general comments in this section
I am an independent energy expert most experienced on policy, energy efficiency especially on building performance, regulatory.
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
1. EPBD-energy performance building directives 2. regulatory 3. energy efficiency
Your Details
First name:
Rinora
Last name:
Gojani
Name of organization:
Institute for Development Policy
Job title:
Researcher
Address:
Rruga Fehmi Agani no.50, A/4,
Postcode:
10000
City:
Prishtinë
Country:
Kosovo
Email: *
[email protected]
Phone No:
+38138224886
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Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
An even more transparent and open debate on developing the energy future in Kosovo is needed. Scientific and policy studies on
the overall energy potential that Kosovo has will contribute to achieving sustainable development in this field, whilst the best
European and international standards are securely implemented with the energy projects themselves. In Kosovo it is also evident
that there’s a need for additional studies and investment on different aspects of developing and diversifying the energy sector in
Kosovo. The studies need to be on the feasibility of renewable projects, Kosovo’s conditions for attracting energy investments,
energy efficiency, the impact of coal in the existing water supply chain, health and environment, etc. These projects will help to
strengthen the need for better social projects in the energy sector for Kosovo and the region. Finally, Kosovo and the region are
in dire need of independent experts with the ability to concretely and creatively tackle the numerous challenges the region faces
as it accelerates towards its goal to enter the developed world.
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
An even more transparent and open debate on developing the energy future in Kosovo is needed. Scientific and policy studies on
the overall energy potential that Kosovo has will contribute to achieving sustainable development in this field, whilst the best
European and international standards are securely implemented with the energy projects themselves. In Kosovo it is also evident
that there’s a need for additional studies and investment on different aspects of developing and diversifying the energy sector in
Kosovo. The studies need to be on the feasibility of renewable projects, Kosovo’s conditions for attracting energy investments,
energy efficiency, the impact of coal in the existing water supply chain, health and environment, etc. These projects will help to
strengthen the need for better social projects in the energy sector for Kosovo and the region. Finally, Kosovo and the region are
in dire need of independent experts with the ability to concretely and creatively tackle the numerous challenges the region faces
as it accelerates towards its goal to enter the developed world.
Your Details
Title:
Mr.
First name:
Darsei
Last name:
Canhasi
Name of organization:
Institute for Development Policy
Job title:
Research Assistant
Address:
Rruga Fehmi Agani no.50, A/4
Postcode:
10000
City:
Prishtina
Country:
Kosovo
Email: *
[email protected]
Phone No:
+38649560234
General Comments
You are invited to provide your general comments in this section
As for the efficiency shortcomings, the most efficient tool is the amend the energy efficiency law. The current law in force is
limited in many areas. There are no incentives for the private sector to rely on efficiency, no financial incentives for endconsumers, no time limits for the law articles etc. Thus, considering the current struggles to implement the secondary legislation,
INDEP recommends that law amendments are the best manner to help the implementation of the priority projects.
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You are invited to provide your general comments in this section
As for the efficiency shortcomings, the most efficient tool is the amend the energy efficiency law. The current law in force is
limited in many areas. There are no incentives for the private sector to rely on efficiency, no financial incentives for endconsumers, no time limits for the law articles etc. Thus, considering the current struggles to implement the secondary legislation,
INDEP recommends that law amendments are the best manner to help the implementation of the priority projects.
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
I would like to draw some comments based on the projects submitted at the Projects of Energy Community Interest for Kosovo.
Proposed projects about Kosovo fall in two categories, list of electricity generation projects, and list of electricity transmission
projects. The positive part is that the high losses during the energy generation and transmission are tackled from some of the
projects. While losses remain one of the core concerns of the energy situation in the country, it is engaging to realize that there
are proposed projects that, if implemented, will contribute towards improving the situation. However, I am concerned about the
effort towards the energy efficiency efforts of the projects. Kosovo is very behind with the efficiency targets and the basic
infrastructural structure is not in place.
Your Details
Title:
Mr.
First name:
Jan Willem
Last name:
Goudriaan
Name of organization:
European Federation of Public Service Unions
Address:
Rue Joseph II, 40 Box 5
Postcode:
1000
City:
Brussels
Country:
Belgium
Email: *
[email protected]
Phone No:
+ 32 2 250 10 80
General Comments
You are invited to provide your general comments in this section
On Democracy
An issue EPSU raised in the run up to the Energy Community was the democratic deficit. There is hardly any parliamentary
control of the work of the Energy Secretariat, Permanent high-level group and Ministerial Council at national or EU (European
Parliament) level. There are no regular reports to the EP that are considered in debate. The democratic control is absent at
regional level. There is not a regional energy parliament. This is not solved in the regional energy strategy paper. EPSU suggest
therefore that the Energy Community needs to ensure that the regional strategy and the selection of the Projects of Energy
Community Interest is subject to regional democratic control as a counterweight to the Ministerial Council. Reinforce the control of
the European Parliament over the regional strategy. A concrete way could be to establish an Energy Community parliamentary
group with MEPs and MPs from the Energy Community countries. Another suggestion is that a social economic council for
energy is created between employers, trade unions and governments.
The Ministerial Council (18 October 2012) committed to transparency and consultation of civil society over the regional energy
strategy. It is important that the Energy Community works on concrete mechanisms for such consultation following EU rules and
the Aarhus Convention (on access to information, public participation in decision-making and access to justice in environmental
matters. EPSU notes that the consultations should be comprehensive and include also the trade unions, anti-poverty groups (for
example via the European Anti-poverty Network) as well as environmental organisations. While unions have a specific role
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regarding the social strategy, they will also have positions on the energy strategy.
Comments about facilitation measures for PECIs
In your opinion what would be the most efficient regulatory, legal/policy and other measures that would help the implementation
of priority projects?
The Energy Community is working on criteria for Projects of Energy Community Interest (PECI). These criteria should assist in
selecting the appropriate projects for (common) investment. EPSU has the following comments: It is no clear to what extend
national parliaments will be consulted. Even less clear is to what extend trade unions, environmental organisations and others
(civil society) will be consulted over the selected projects and how they could feed in their positions.
Some projects could have an impact on employment in other countries for example. We suggest the Energy Community
establishes clear procedures for this. To ensure that various interests are taken into account EPSU suggests that a civil society
advisory board is established to be consulted on the projects.
The list of criteria for selection does lack specific ones to evaluate the social impact of projects. Building interconnectors between
countries or with EU Member States might impact on the need or not to build, renew or refurbish power plants. This has
employment consequences (as the building of the lines itself has positive aspects). An impact assessment board should address
such issues as well and consult with the trade unions on the selection and if a project is perceived to have certain consequences.
The framework for the projects should address that:
o The implementation (and hence selection of constructors and providers e.g) should respect the collective agreements
in force at the place of work as provided for in the ILO Convention 94, unless otherwise agreed with the trade unions at
the place of work. There is no need for cowboy companies that wish to operate outside of collective agreements. This
should be part of the framework.
o Consultation is to take place with the trade unions over the practical implementation to ensure health and safety,
quality and working conditions are respected. When projects are selected the companies that participate in the building
and operation of the infrastructure (PECI) should be licensed so training and qualifications are ensured contributing to
the quality of the project.
o We suggest that there is a formal as well as a content check on these criteria which involves a board whose members
can be selected from candidates proposed by different groups and including the trade unions.
o The EU framework for public procurement does foresee the possibility for the use of social and environmental criteria.
This should be integrated in the criteria.
o The full transparency of the contracts is needed so citizens can evaluate the value for money, if the projects contribute
to sustainable development and just transition, social and economic progress, will respect working conditions and social
rights of working people. It is one of the best guarantees to prevent corruption and cronyism and that tax payers money
is misused and abused.
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