Race to the bottom: dire air quality worsens as BiH government mulls new coal plant at Tuzla

It was a warm morning in early October, the sun bright and a faint smell of burnt coal in the air. The home heating season started late this year, after a prolonged summer. We were in Tuzla, Bosnia and Herzegovina, to install our dust pollution measurement equipment, exactly one year after our first-of-its-kind, independent monitoring was done here.

In 2016, our particulate matter (PM) monitoring results were eye-opening on a number of levels: not only were both PM10 and PM2.5 values above the recommended limits set in Bosnia and Herzegovina and by the World Health Organisation on almost all the days observed, but the levels also skyrocketed in the evenings. This trend raised concerns about whether pollution filters at the Tuzla power plant even functioned properly.


For the whole time, the PM10 values were always above the legal limit for the 24 hour average.


This year, we wanted to probe locals’ claims that pollution had been getting worse with time, and to determine if the high peaks recorded are indeed caused by the nearby Tuzla lignite power station and the associated facilities.

The monitoring equipment was placed in the same location as before, and for the whole nine days when it was in place, not once were the PM10 values below the legal limit of 50 micrograms/m3 for the 24 hour average. In fact, the average values during the observation period (10-19 October) were 40 per cent higher than for the same period in 2016.

Comparison of PM10 values in Tuzla, BiH, 2016 vs 2017.The values of PM2.5 measured were also higher than in the previous year by 10 per cent, and the concentrations were twice as much as the WHO’s recommendation of 25 micrograms/ m3 for the 24 hour period. The locals knew what they were talking about.

Comparison of PM2.5 values in Tuzla, BiH, 2016 vs 2017.If there is consensus in the medical world about anything related to PM pollution, it is that prolonged exposure to PM2.5 carries a high risk factor for heart and cerebral diseases, as well as premature mortality.


Since locals had not started heating their homes, the pollution couldn’t come from household stacks.


What is even more worrying is that October 2017 was much warmer than October 2016, meaning that in conversation with the locals of Tuzla, we learned that there was no reason to start heating their homes yet. So if the increased levels of PM were not originating from household stacks – which is the favourite pollution bugbear of the authorities, together with traffic – there must be another source of concern.

Where does the dust come from?

In the graph with PM10 emissions, three high peaks stand out: 11 October between 4-6 AM, 15 October between 4-9 AM, and 18 October between 7-9 AM. We looked at the meteorological data provided by our air pollution monitoring equipment for these specific intervals and came to a straightforward conclusion: depending on the wind’s direction, either the Tuzla coal power or the associated ash disposal site, or both, are responsible for the spikes.

We came to this conclusion because our equipment was placed south of the ash disposal site and north of the power plant. Therefore, when the wind blows from the north – as in the top half of the diagram – and the PM10 emissions are extremely high (up to 937 micrograms/m3 for an hourly value) we can point to the dried ashes blowing from the ash dump in the direction of the town. Similarly, when the wind is blowing from the south – the lower half of the diagram – and the PM10 emissions are high, it is obvious that the power plant’s chimney is the culprit.

What are the Bosnian authorities doing about it?

The air quality in Tuzla is dire and has attracted the attention recently from international media outlets including Euronews, BBC and RAI News, whose television crews have made their way to this town in the world’s second most polluted country.

Yet the Federal Government is set to give the green light to the state owned energy company, Elektroprivreda BiH, to build yet another unit at Tuzla’s power plant. The 450 MW proposed Tuzla 7 project would require additional coal capacity.

The project promoters claim that the new unit would be in line with the EU pollution standards, but the project’s environmental permit/EIA clearly suggests the project will not meet the EU’s recently-adopted Best Available Techniques (BAT) standards. Rather, the project is much more likely to result in an increase of coal that would need to be mined and an increase in ash production, which, as seen above, plays a critical role in aggravating local air pollution.

Local opposition to a new ash disposal site is high, and in April 2016 the local community representatives delivered a petition with 2100 signatures against the proposal to the Federal Ministry of Environment and Tourism. While some units will be shut down in the future, constructing unit 7 would still represent an overall capacity increase, the exact opposite of environmental improvement.

As the ten-year saga continues, plans to build Tuzla 7 at an estimated cost of EUR 722 million received a boost when the government recently indicated a contract for a loan from the Export and Import Bank of China (China Eximbank) could be signed soon, provided the State Aid Council also gives its consent for loan guarantees. The plant is expected to be built by China Gezhouba Group and Guangdong Electric Power Design, according to an EPC (Engineering, Procurement, Construction) contract signed in May 2016.

China’s ‘green policies’ in practice

China’s ‘Green Credit Directive’ and its key performance indicators require Chinese banks to assess, monitor and mitigate social and environmental impacts throughout the lifecycle of the project. However, the project’s planned ash disposal site Šički Brod is without an environmental permit, and yet, China Eximbank failed to factor in this irregularity its project appraisal. This has resulted in an unresolved legal challenge.

One thing is clear: China Eximbank’s client, Elektroprivreda BiH, is not fulfilling the required level of environmental and permitting obligations. For its part, China Eximbank has avoided disclosing the bank’s own due diligence on the project.

Local civil society representing the affected communities have since 2013 made efforts to alert China Eximbank and Chinese authorities overseeing overseas projects including Tuzla 7 about the non-compliance of these practices, but their complaints have fallen on deaf ears.

While the spirit of the Green Credit Directive and other recent ‘green policies’ launched jointly with China’s Belt and Road Initiative are laudable, if China Eximbank finances projects like Tuzla 7 and others in the pipeline, there won’t be much left to inspire confidence about China’s green leadership.

The only other thing more pressing than the impending cold season, temperature inversion and thus an escalation in air pollution in Tuzla, is the China+16 summit held next week in Budapest. During these high-level meetings, financing contracts are signed. But why would any government rush to throw their country’s public budget into such a long-term loan when so many problems with this project remain unaddressed? To be sure, the answer is not for the benefit of air quality and the health of local people.

A growing menace in Ukraine as proposed loan to agribusiness giant adds to conflict

Regular readers of this blog know Ukraine’s agribusiness conglomerate MHP as a company that is in constant conflict with the communities where it operates. In spite of repeated complaints from a number of villages and even violent attacks against active opponents of the company’s endeavours, MHP has received three loans worth USD 161 million since 2010 from the European Bank for Reconstruction and Development, and that sum is set to get bigger.

On 29 November, the bank will decide on another loan of USD 25 million, this time for a 10 MW biogas plant in Zaozerne in the Vinnytsa region. The plant is part of the broader expansion and development of a local Vinnytsa poultry farm, which is owned by an MHP subsidiary and includes the construction of 12 rearing facilities in addition to an existing twelve. The biogas plant and the new rearing facility – ‘Brigade’ 47 – are the two pieces of infrastructure at the source of conflict between MHP and the Zaozerne community.

Adding pollution to an already-polluted area

Zaozerne and the Vasylivka community are located about 10 kilometres from the town of Ladyzhyn and its coal power plant, which is one of the biggest polluters in the region, with the ash sludge from the plant deposited on land in Zaozerne. Brigade 47 and the biogas plant would only add more pollution to the area.

Despite the potential for a substantial increase in pollution, the cumulative impacts from the expansion have not been assessed. This would require an assessment of the facilities connected to the existing 12 brigades that house roughly one and a half million chickens a piece – the slaughterhouse and the wastewater treatment plant. Instead, the preliminary assessment for the biogas plant was based on baseline concentrations of air pollution roughly 30 kilometres from the proposed location of the new plant. The selection of this location necessarily downplays the cumulative pollution risks for these communities from the additional facilities

The project assessment also passes over the impacts from an extension of the biogas plant facility, the combined heat and power generation (CHP) station. While the preliminary EIA mentions a biogas plant, transport and co-generation facilities as one project, the impacts of co-generation are studied neither by MHP nor the EBRD. This is in breach of the bank’s standards.

This map shows the location of agribusiness enterprises and the communities that feel the impacts.

Divide and rule

As with both the Brigade 47 and biogas projects, MHP has shown particularly poor engagement with the local communities. Public hearings again were conducted in the smaller of the two relevant villages, Vasylivka. This means that the larger part of the community that resides in Zaozerne had no chance to be heard, as they were not informed about the public hearings, so they could not comment on the project’s design.

This follows developments in Spring 2017, when Zaozerne activists filed a court case to the Vinnytsya Administrative Court to cancel a ruling of the Head of the Tulchyn Rayon State Administration, which resulted in the current construction permits being granted. Locals also sent a petition to Ukraine’s president, condemning the actions of MHP’s owner, the oligarch Yuriy Kosyuk.

The court case was closed in August but in October the appeal court reopened the investigation. The Head of the Tulchyn Administration, however, filed a court case against four local activists and a local online media site. This in our in our view was done to intimidate and criminalise voices critical of the project, furthering the perceived contempt of MHP for local dissent. Locals have also reported instances of surveillance, pressure placed on relatives and visits from the state security services.

Too soon for a loan

Considering the legal irregularities in the local approval process and the incomplete impact assessment, approval of an EBRD loan for MHP’s biogas plant is premature. A decision on the project should be postponed at least until the Environmental and Social Impact Assessment for the full project (including the biogas plant and cogeneration) is developed, the cumulative impact assessments are completed and locals are allowed to freely express their opinion without intimidation.

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