Blog entry

For the last 120 days, the European Bank for Reconstruction and Development (EBRD) has made the Environmental and Social Impact Assessment (ESIA) for the 10-kilometre Prenj motorway tunnel, its approach roads and the Konjic bypass available on its website for public comments. Project promoter JP Autoceste and the EBRD also organised Open Days on the project in early June, providing additional opportunities for questions and comments.

Given that this high-risk project would cost at least EUR 1 billion, to be financed with loans from the EBRD and European Investment Bank (EIB); that another section south of Mostar has become bogged down in disputes about the routing and expropriation; and that this section is in a sensitive area, long planned to be a National Park, we’ve taken a detailed look at the assessment. 

A great deal of work has been put into the voluminous documentation, but several elephants in the room still need to be addressed.

Risks from lack of public consultation on the routing 

As the EBRD’s Independent Project Accountability Mechanism (IPAM) has confirmed, the Federation of Bosnia and Herzegovina (FBiH) adopted the project-level spatial plan in 2017 without consulting the public on the final routing of the motorway. This means that subsequent consultations on the environmental impact assessments for these sections – including Prenj – cannot be regarded as meaningful, because they are not taking place at a stage when all options are open regarding the project. 

For example, in 2023, when the Aarhus Centar Sarajevo submitted comments on the routing as part of the FBiH-level consultation on Prenj, the study authors responded that the subject of the study was the route set by the 2017 spatial plan. 

Yet under EBRD and EIB rules, if the project is to be allowed to expropriate property, damage an Emerald site and damage critical habitats, it has to be proven, among other things, that the mitigation hierarchy – ‘avoid, minimise, mitigate’ has been followed; that there are no feasible alternatives and that meaningful public consultations have taken place. 

This is a bigger issue than the ESIA study that needs to be resolved by the FBiH government. And the EIB and EBRD need to make it clear that this is a condition for financing.

Forest cutting, river channelling and high embankments in the Bijela canyon Emerald site

The assessment confirms there will be impacts on the stunning Bijela canyon Emerald site, but, intentionally or not, does not clearly describe and visualise them. From what we can piece together, the damage includes:

• cutting an unquantified number of hectares of old, well-preserved beech forest, home to the rare white-backed woodpecker;
• channelling the upper part of the Bijela stream underneath a large embankment for more than 1.2 kilometres and outside the embankment for a further 600 metres;
• construction of other 20-metre-high embankments for the motorway to run along and a ‘landscaping’ area (ie. disposal site) for the disposal of dug-out waste from the Prenj tunnel and other tunnels. 

The ‘Appropriate Assessment’ part of the ESIA admits that these will fragment the site and that not all the impacts can be mitigated. Other habitats and species subject to protection under the EU Habitats and Birds Directive beyond the Bijela site would also be affected by the project, although some species present in the project area, like the otter, Balkan chamois and wildcat, are not assessed. 

Instead of analysing whether the project can go ahead at all with its current design, based on EBRD, EIB and Habitats Directive criteria, the Appropriate Assessment assumes it can, and jumps straight to mitigation and compensation measures. The same is true for the Critical Habitats assessment, whose purpose is similar but uses different criteria. Neither of these assessments demonstrates compliance with EBRD and EIB rules, and both rely too much on offsetting, which rarely works in reality.

Moreover, too many biodiversity studies are left to be done after the ESIA is completed, and underground fauna is not examined at all. These go beyond what can be considered pre-construction checks, as their results should influence the whole assessment.

Alternatives assessment needs to address high-risk sections 

The alternatives section describes well those routings that have already been examined and rejected, but needs to be updated to respond to the problems with the current routing.

It takes for granted the idea that a full-profile motorway has to be built, and dismisses the zero alternative out of hand. The current situation is indeed untenable for Konjic and Jablanica as the main bottlenecks on the route, but variants in between ‘no project’ and ‘full profile motorway’ need to be examined, for example building only bypasses. 

More detailed variants also need to be examined for the most sensitive parts of the route – the Bijela canyon and the area around the village of Podgorani near Mostar, where residents are concerned about the motorway running above their peaceful village and have proposed an alternative that involves lengthening the Prenj tunnel but shortening the overall route. The Podgorani area is also environmentally sensitive, with a Golden Eagle’s nest having been found in the Klenova Draga gorge nearby.

Even if such variants have been examined and rejected, the public does not know this unless they are described in the study. And as described above, establishing whether alternatives exist is a key condition for compliance with several EBRD and EIB requirements. 

Lack of compensation for people living right next to the motorway

The expropriation corridor for the project is 50 metres – only as wide as the motorway itself. People who live or have land outside this zone get no compensation at all unless they manage to make a successful complaint to JP Autoceste or the EBRD/EIB complaint mechanisms. This corridor is set narrowly to save public money and because people have different opinions on whether they want to live next to the motorway or not. But we still believe this is too narrow and that the system is too binary. 

There needs to be standardised compensation for people with houses – and to a lesser extent land – within a set number of metres each side of the motorway, due to depreciation of their property value, noise, vibrations and pollution, even if they are not expropriated. According to the EBRD’s Environmental and Social Policy, if people living alongside the Corridor Vc experience loss of land and assets, or restrictions on their use, leading to loss of income sources or other means of livelihood – ‘the client will offer compensation to affected persons at full replacement cost, and other assistance as may be necessary to help them improve or at least restore their standards of living and livelihoods.’

Confusion on vulnerable groups

One of the IPAM findings for the section south of Mostar was that the EBRD had not ensured that vulnerable groups had been properly identified during the project development. And so far this ESIA is in danger of repeating the same mistake. This can lead to undue impacts to their livelihoods and problems during the expropriation process.

In our understanding, this has happened partly because the provisions in the FBiH expropriation law regarding vulnerable people have a different purpose and different criteria than the EBRD and EIB policies, which causes confusion. 

The FBiH law classifies vulnerable people in order to decide whether they qualify for an additional fee during expropriation, but the EBRD and EIB require their identification for a different and wider purpose: to ensure they are properly consulted and any specific needs taken into account during the project development. These two differing concepts seem to be conflated in this ESIA and need to be differentiated. 

For example, the assessment does not consider war returnees vulnerable, and it may be that there is indeed no particular reason to offer them an additional expropriation fee. But given their experience of repeated upheavals and trauma, their enhanced connection to the land, and sense of home and heritage, they should be treated as vulnerable for the purposes of the EBRD and EIB policies, and extra care should be taken with consultations with them.

Such a risky project needs solid foundations

A lot can go wrong building a two-pipe 10-kilometre motorway tunnel in karst terrain, especially in an era of accelerating climate chaos when unparalleled storms and floods can hit at any moment. Building the tunnel alone is estimated to take five years, and that’s if everything goes well and there are no major surprises with underground water flows.

It’s up to the people of Bosnia and Herzegovina to decide whether such an expensive and risky project is the best use of scarce public funds at this time. But it’s also up to the EBRD and EIB to make sure that their standards are not breached in the process.

This may still be possible, but the current information in the ESIA package isn’t sufficient to prove that these standards are met. The banks must act now to ensure the assessment is improved. Either better solutions must be found for the Bijela valley and Podgorani, or it must be proven, with much more evidence, why the current ones are the best possible.