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Response: G20 ends public financing for international coal-fired power projects, we ask China to walk away from Western Balkan coal projects immediately.

China, the world’s top financier for the construction of international coal-fired power projects, still currently has over 1.7 GW of planned coal-fired power plants and the 350 MW Kostolac B3 coal-fired power project under construction in the Western Balkan countries in Southeast Europe.

OECD countries including the EU, Japan, Korea and others agreed last week to an immediate ban on various forms of government financial support for international coal-fired power plants by the end of 2021, making it the first internationally binding agreement to end export support of international coal-fired power plant projects [2].

Although China is not a member of the OECD, and is thus not bound by the agreement, earlier in October the Bank of China, a major bank with a track record of financing overseas coal projects, broke rank with other Chinese banks, becoming China’s first financial institution to end financing of new international coal-fired power plant and mining projects [3].

Since 2020 an increasing number of developing economies along the Belt and Road have taken big steps away from previously ambitious coal power expansion plans faciliated by China. Serbia and Bosnia and Herzegovina in Southeast Europe, however, continue to be a hotspot for Chinese state-owned enterprises (SOEs) in expanding their new coal projects, while Montenegro is currently deciding whether to go ahead with a controversial coal plant modernisation by China’s Dongfang Electric.

Chinese SOEs specializing in power generation are currently active in six coal-fired power projects in Bosnia and Herzegovina, Serbia and Montenegro, some with financial backing from China’s Export-Import Bank (China Eximbank) [4].

Xi’s September United Nations General Assembly pledge to pull out of new overseas coal-fired power plants further eroded the legitimacy of the planned Tuzla 7 project, a coal-fired power station with debt financed by China Eximbank which is still not yet being built, amid controversies over State aid, permitting procedures and changes to the technology being offered by Gezhouba.

Denis Žiško from the Aarhus Center Tuzla in Bosnia and Herzegovina, who monitors the planned Tuzla 7 project, says “this was risky business from the start for our country, starting when it accepted  €614 million loan from China Eximbank for a construction project that benefits first and foremost the Chinese companies and its workers.’’  Žiško added, “The question is why are Chinese authorities still pressuring our country to invest in a project that will and up as a stranded asset?”

“Chinese SOEs operate in utmost secrecy and make deals with our authorities and private investors on the construction of planned thermal power plants – such as the Ugljevik 3 coal-fired plant project. China National Electric Engineering Corporation secretly secured an Engineering, Procurement and Construction (EPC) contract without any public consultation or knowledge of the local communities,” said Majda Ibraković from the Center for the Environment in Bosnia and Herzegovina. “We demand that China stays true to its promise and exits from every planned coal-fired power project in Bosnia and Herzegovina, so our country is not further indebted to China’s state entities,” she added.

Zvezdan Kalmar from Serbia’s Center for Ecology and Sustainable Development (CEKOR) said: “Not only are all the Chinese coal projects in the Western Balkans non-compliant with the latest EU pollution control standards, but most are also plagued with irregularities in the environmental permitting and assessment studies.” Kalmar added, “China must immediately stop overseas coal projects whose construction began without acquiring cleared permits and meaningful public consultation; Serbia’s Kostolac B3 coal-fired plant that is under construction is such an example.’’

Wawa Wang, Director of Just Finance International said: “We welcome G20 and especially China’s commitment to ending public financing for international coal projects. Communities and citizen NGOs have long questioned the legitimacy and legality of Chinese SOEs’ coal-fired power projects in the Western Balkans and beyond. Our research shows China has still at least 13 GW of active and planned coal-fired power projects – some of which already financed but not yet built – around the world [5]. China would need to exit these active projects immediately for the commitment to have true climate saving impacts.”

Ioana Ciuta, energy coordinator at CEE Bankwatch Network said: “At this stage of the climate emergency we should have agreements on halting all fossil fuel financing, but we haven’t even cut off the lifelines for coal yet. The economies, the environment and public health only have to suffer if China leaves the door open for all these ill-advised coal projects in southeast Europe.”

 

ENDS

Denis Žiško, Aarhus Center Tuzla, Bosnia and Herzegovina. (E-mail: denis.z@bih.net.ba; Telephone: +387 61140655)

Majda Ibrakovic, Center for the Environment in Bosnia and Herzegovina (E-mail: majda.ibrakovic@czzs.org; Telephone: +387 51433140)

Zvezdan Kalmar, Center for Ecology and Sustainable Development, Serbia (E-mail: Zvezdan.kalmar@protonmail.com; Telephone:  +381 655523191)

Wawa Wang, Just Finance International, Denmark (E-mail: justfinanceinternational@protonmail.com; Telephone: +45 81949469)

Ioana Ciuta, CEE Bankwatch Network, Czech Republic (E-mail: ioana.ciuta@bankwatch.org; Telephone +40 724020281)

 

Notes:

[1] G20 Rome Leaders’ Declaration: link

[2] Reuters: In climate pledge, Xi says China will not build new coal-fired power projects abroad https://www.reuters.com/world/china/xi-says-china-aims-provide-2-bln-vaccine-doses-by-year-end-2021-09-21/

[3] Agreement reached at OECD to end export credit support for unabated coal-fired power plants: link

[4] Tuzla 7, Banovići, Ugljevik in Bosnia and Herzegovina, Kostolac B3 and Kolubara B in Serbia, and Pljevlja in Montengegro.

[5] ‘Adding Coal to Fire’ briefing: an overview on where China stands in 2021’s historic exit from international coal projects’: https://justfinanceinternational.org/2021/10/27/adding-coal-to-the-fire/

Pljevlja has unique opportunity to clean up its heating system

The current heating supply for the municipality of Pljevlja is based on wood and lignite, and is reliant on stand-alone furnaces, a few microgrids, and outdated stoves with poor filtering systems. This heating system is contributing to very high levels of pollution in the area – in 2018, 680 premature deaths were estimated to be caused by air pollution in Montenegro.  

Despite the fact that the coal power plant in Pljevlja is already operating illegally, the central government has announced a coal phaseout date only in 2035. In spite of these contradictions, local authorities are still relying on older existing plans for refurbishing the coal plant in Pljevlja and building a district heating system attached to the plant. Additionally, the 2030 national energy strategy envisages developing district heating systems based on biomass.  

But an analysis commissioned by CEE Bankwatch Network and conducted by experts at Plan Energi, an independent consultancy offering advice on energy planning, shows that with additional support from the government, better solutions are possible for the future of Pljevlja’s municipal heating.  

Having looked at several scenarios, the experts concluded that the optimal solution would involve the expansion of existing microgrids across the town centre, connecting them to an enlarged district heating grid, all the while replacing existing supply technologies with renewable ones, particularly solar in combination with seasonal heat storage and the utilisation of air-to-water heat pumps. For individual heating, some old boilers would be replaced by more efficient biomass ones, and complemented with energy efficiency measures. 

“The end of coal in Pljevlja presents the local community with an unprecedented opportunity to reshape its heating system in a modern, sustainable way. This is why the authorities should not be jumping to simple but outdated technologies – such as more lignite, gas or even biomass – but rather invest in future-proof, non-polluting solutions,” comments Natasa Kovacevic, Bankwatch district heating coordinator. 

“Our analysis shows that a diversified approach, involving renewable heating sources and technologies such as open space solar with seasonal storage, air-to-water heat pumps and other potential sources such as waste heat or geothermal, is preferable for Pljevlja,” Kovacevic says. “Relying on an increased share of biomass is the wrong solution as it involves the destruction of forests and biodiversity, and contributes to air pollution.”  

“It is clear that coal use has no future and that a coal-fired heating system cannot be sustainable on the long term, especially given the current situation with the coal plant at Pljevlja and the government’s plans to decarbonise the energy sector by 2035,” Diana Milev Cavor, from the Montenegrin NGO Ecoteam, says. “Pljevlja needs a sustainable and modern heating system that will contribute to solving the environmental and health problems we have accumulated here over the years.” 

Read the executive summary (in English) of the expert analysis here: Identification and analysis of possible sustainable heating solutions in Pljevlja in Montenegro – Bankwatch 

 

For more information, contact: 

Natasa Kovacevic 

Bankwatch district heating coordinator 

Phone: +38267030033 

Natasa.kovacevic@bankwatch.org 

 

Diana Milev Cavor 

Ecoteam project coordinator (Montenegro) 

Phone: +38267668817 

Diana.milev@yahoo.com 

 

 Notes for editors:  

More about PlanEnergi, the consultant authoring the analysis: Company profile – PlanEnergi. 

Bankwatch’s analysis of the health costs of air pollution in the Balkans, Comply or Close: Comply or Close 

New report: European Investment Bank hydropower failures necessitate tighter rules

The European Investment Bank has financed a series of damaging hydropower projects since 2010 (1) which underline the need to tighten its environmental and social standards, according to a new report published today by CEE Bankwatch Network and EuroNatur. 

The report examines eight hydropower schemes in central and eastern Europe (2) supported or currently being considered for financing by the EU’s house bank. It finds that neither the Bank’s current rules, nor its proposed new standards published for consultation in June 2021 (3), are sufficient to prevent the damage from such projects.

Andrey Ralev, Biodiversity Campaigner at CEE Bankwatch Network stated that ‘All of the plants examined have damaged, or will damage, areas which are supposed to be protected by law. Such areas need to be declared no-go zones for financing in the EIB’s Biodiversity and Ecosystems Standard, if they are to be truly protected’.

A particular problem is the Bank’s financing via intermediaries – chiefly commercial banks and national promotional banks. In southeast Europe alone, the EIB has provided at least 27 intermediated loans for hydropower plants since 2010, though the names of many of the projects remain unknown given that the Bank does not publish information on the final beneficiaries of such investments.

‘Financial intermediaries in southeast Europe clearly do not have the capacity to check hydropower projects’ compliance with the EIB’s standards and EU law. The EIB needs to stop abdicating responsibility for such investments and get involved in screening sub-projects itself,’ added Pippa Gallop, Southeast Europe Energy Advisor at CEE Bankwatch Network.

For example, the EIB financed the six small Tearce and Brza Voda plants in North Macedonia via the Development Bank of North Macedonia. The plants have been built in the heart of what is now the Shar Mountain National Park. They block the Bistrica and Brza Voda rivers, preventing movement of river fauna over stretches totalling 10 kilometres. The plants’ access roads have also most likely facilitated logging of pristine forest in the area.

‘In the case of the Tearce and Brza Voda plants, the EIB clearly assumed that the national authorities were willing and able to enforce environmental law. The Bank uses this excuse to absolve itself of proper checking and monitoring of its projects. But even in the EU this is clearly not always the case. As the EU’s own investment bank, the EIB needs to clearly set out how it will ensure that all projects comply with EU law, whether they are in the EU or not,’ explained Gjorgji Mitrevski of Eko-svest, North Macedonia.

‘If the EIB is really committed to tackling the ecological and climate crises, then it needs to scrap its old thinking and revamp how it finances projects’, added Bruna Campos, Senior Policy Manager at EuroNatur.

 

Contacts

 

Anja Arning, Head of Communications, EuroNatur 

anja.arning@euronatur.org  +49 7732 927213

 

Pippa Gallop, Southeast Europe Energy Advisor, CEE Bankwatch Network

pippa.gallop@bankwatch.org +385 99 755 9787 Skype: pippa.gallop

 

Andrey Ralev, Biodiversity Campaigner, CEE Bankwatch Network

andrey.ralev@bankwatch.org Skype: andreyyyyyyyyyy

 

Notes for editors

1. Due to a lack of clear information disclosure by the Bank it is impossible to say how many hydropower projects have been financed. 42 direct EIB energy sector investments signed since 2010 (see Financed Projects) appear to include the construction of new hydropower plants, but this does not include projects via intermediaries, on which the EIB publishes no information about final beneficiaries. 

2. The projects are:

  • Blagoevgradska Bistritsa 1-8, Bulgaria, impacting the Rila National Park and two Natura 2000 sites. The EIB supported the plant’s operation in 2012 once it had been built.
  • Ilovac, Croatia, built in the River Kupa Natura 2000 site.
  • Nenskra, Georgia, fiercely resisted by the local Svan indigenous people, also impacting an Emerald site and the proposed Upper Svaneti National Park. The EIB approved a loan in 2018, but has not yet signed it.
  • Mojanska 1-3, Montenegro, built in the Komovi Regional Park, with impacts on three Emerald sites and proposed Natura 2000 sites.
  • Bistrica (Tearce) 97-99 and Brza Voda 1-3, North Macedonia, both built in the Shar Planina Emerald site, also now protected in national law as the Shar Planina National Park.
  • Beli Kamen and Komalj, Serbia, built on the Crni Rzav river inside the Zlatibor Emerald site, also protected nationally as a Nature Park.
  • Tashlyk pumped storage completion project, Ukraine, which would damage the Bugzkyi Gard National Nature Park and Emerald site, a Regional Landscape Park and an Ichthyological Nature Reserve. The EIB has not yet approved financing for the project.

3. For more details, see https://consult.eib.org/consultation/essf-2021-en/

 

This publication was produced in collaboration with EuroNatur and RiverWatch in the frame of the Save the Blue Heart of Europe campaign, with financial support from MAVA Foundation.

The European Parliament at risk of losing sight of climate crisis by getting ready to support new fossil gas projects

On Monday, the lead MEPs from each political group will meet to agree the final deal on the Parliament’s proposals for the TEN-E revision before the vote in the ITRE Committee on 27 September. The latest proposals look set to allow continued funding of all gas projects featured on the EU’s fourth and fifth lists of “projects of common interest” (PCIs). The S&D are failing to challenge the conservative European People’s and European Conservatives and Reformists parties who are supporting this position.

Global Witness analysis has found that the new gas projects on the fifth list alone could emit 213 million tonnes of carbon dioxide each year, the same as Germany’s entire coal fleet in 2018. And nearly half a billion euros has been wasted already by the EU on PCIs that have failed, or are likely to.

Tara Connolly, Senior Gas Campaigner at Global Witness, said:

“We’ve had enough of empty rhetoric from those who say that they believe that climate change has to be addressed as a matter of urgency, but then fail to act when the meaningful measures that can make a difference are negotiated. With the climate crisis wreaking havoc across the world this summer, groups like the Socialists have been quick to call for action yet are now failing to heed their own calls.”

In addition to the ongoing support for fossil gas infrastructure, the Parliament is also planning to support projects that transport hydrogen. Through a process known as blending, the Parliament would allow small volumes of hydrogen to be mixed with large volumes of fossil gas, an immense loophole for gas companies cloaked in the guise of sustainability. At the same time, blending hydrogen and gas would increase consumer prices for today’s users, including those that are not likely to be the hydrogen users of tomorrow.

In its own TEN-E revision proposals the European Commission opted against future support, including funding, for any gas projects, whilst the Energy Council decided to continue support just two projects.

With the climate crisis causing ever-more severe flooding, fires and droughts, and with countries like Greece, Germany and Belgium hit particularly hard this summer, it is clear that fossil fuels have no future in Europe’s energy system.

MEPs should not shy away from their responsibilities to put in place a policy framework that phases out fossil fuels by 2035.

 

For more information please contact:

Paul Hallows, Communications Adviser at Global Witness: phallows@globalwitness.org | +32 484 22 50 43

Tara Connolly, Senior Gas Campaigner at Global Witness: tconnolly@globalwitness.org | +32 477790416

 

NOTES

[1] Global Witness analysis of emissions from gas projects which would be funded as part of the 5th PCI list. 

[2] Global Witness analysis of EU subsidies wasted on gas projects that have failed, or are likely to. Read more.

[3] Food and Water Action Europe and Climate Action Network Europe analysis of the €41 billion cost of planned fossil gas infrastructure that will become stranded assets. See more.

[4] E3G factsheet on hydrogen blending.

 

EU complicity in colossal, lawless air pollution from Balkan coal plants must prompt swift action – new report

The report, Comply or Close, launched to mark the International Day of Clean Air for blue skies, finds that nearly 12,000 of these deaths were due to breaches of legally binding pollution limits. More than half of these preventable deaths took place in the EU, which imports 8 percent of the electricity produced by these heavily polluting plants. 

Air pollution from coal plants in Serbia, Kosovo, Bosnia and Herzegovina, North Macedonia and Montenegro affects not only people in their own countries but also those in neighbouring EU countries, particularly in Romania, Hungary and Greece, according to the report. 

“This report lays bare the human toll from the continued breaches of coal-based electricity in the Western Balkans. Governments of the region must immediately begin a rapid and just transition to sustainable energy systems, with EU support,” said Pippa Gallop, Southeast Europe Energy Advisor at CEE Bankwatch Network. 

The Large Combustion Plants Directive – an EU directive to reduce emissions of dangerous substances, adapted for countries parties to the Energy Community Treaty – legally requires these countries to rein in air pollution from their power plants since 2018. Yet, as the report finds, in 2020, the Western Balkans’ 18 coal plants emitted two and half times as much sulphur dioxide (SO2) as all 221 coal power stations in the EU combined. 

The new report reveals the extent to which coal plants in the Western Balkans have not only been flouting the countries’ legal obligations, but also taking an immense toll on people’s lives in the region and beyond. 

According to the analysis, 3700 people have died in the Western Balkans and 7000 in the EU only because of Western Balkan coal power plants breaching pollution limits between 2018 and 2020. Nearly a thousand more people are estimated to have died in other regions due to choking air pollution from the same power plants. 

In the three years since air pollution limits became obligatory under the Energy Community Treaty, coal-fired power plants in Serbia, Bosnia and Herzegovina, North Macedonia and Kosovo have been emitting SO2 at levels that are at least six times the legal limit [1]. 

In Serbia alone, coal plants that are subject to the National Emissions Reduction Plan emitted in 2020 more SO2 than the entire EU coal power plant fleet.  

The same year, Bosnia and Herzegovina’s Ugljevik power plant was the region’s worst polluter, single-handedly breaching the combined SO2 ceiling for all four countries. The unit, just like Serbia’s Kostolac B, has a desulphurisation system fitted, but it has not been put to use. Worse still, an additional 700 MW of new lignite capacity is still planned at the Ugljevik power plant. 

All four countries with National Emission Reduction Plans – Serbia, Bosnia and Herzegovina, Kosovo and North Macedonia – are currently facing dispute settlement cases for failing to comply with the pollution limits in the Plans in 2018 and 2019. Another dispute settlement case was opened against Montenegro in April 2021 after the Pljevlja power plant continued operating beyond its 20,000 hours quota under the Large Combustion Plants Directive’s “limited lifetime derogation”. 

“Those Western Balkan Governments which have not yet done so, must set a date for an urgent coal phaseout”, said Davor Pehchevski, Balkan Air Pollution Campaign Coordinator at CEE Bankwatch Network. “For power plants which cannot be closed immediately, governments must limit their operating hours until emissions standards are met, in order to save lives”. 

“In parallel, investments in energy efficiency measures and renewable energy must be urgently stepped up, and plans for a just transition for coal workers and communities need to be drawn up together with all relevant stakeholders, especially the affected communities.” 

According to the report, the electricity generated by these coal plants and traded with the EU in 2020 — although making up a tiny fraction of EU electricity consumption — produced as much SO2 as half of the EU’s coal power plants combined.  

“As our report shows, when the EU trades electricity with its Western Balkan neighbours, it bears both the impacts and part of the responsibility for the resulting out-of-control air pollution. The EU must also help countries in the Western Balkans to move beyond coal by taxing fossil-fuel based electricity imports and ensuring effective enforcement of the Energy Community Treaty”, said Lauri Myllyvirta, Lead Analyst at the Centre for Research on Energy and Clean Air. 

“Western Balkan governments cannot dream of EU membership while ignoring pollution control rules. To avoid this kind of flagrant non-compliance, enforcement of the Energy Community Treaty must be made a priority. The European Commission and EU governments must introduce effective penalties”, concluded Ioana Ciuta, Energy Coordinator for the Western Balkans at CEE Bankwatch Network. 

The report findings, as well as additional context, can be found at https://www.complyorclose.org 

 

Contacts 

Pippa Gallop
Southeast Europe Energy Advisor, CEE Bankwatch Network
pippa.gallop@bankwatch.org
+385 (0)99 755 9787
Twitter: @pippagallop 

Ioana Ciuta
Energy coordinator for the Western Balkans, CEE Bankwatch Network
ioana.ciuta@bankwatch.org
+40724020281
Twitter: @unaltuser 

Davor Pehchevski
Balkan Air Pollution Campaign Coordinator, CEE Bankwatch Network
davor.pehchevski@bankwatch.org 
+38971264087
Twitter: @dpehche 

Lauri Myllyvirta
Lead Analyst, Centre for Research on Energy and Clean Air (CREA)
lauri@energyandcleanair.org
+358 50 3625 981
Twitter: @laurimyllyvirta

 

Notes 

[1] 2019 and 2020 editions of the “Comply or Close” reports:  

https://bankwatch.org/publication/comply-or-close-how-western-balkan-coal-plants-breach-air-pollution-laws-and-what-governments-must-do-about-it 

https://bankwatch.org/publication/complyorclose2020 

 

See as well: Mortality in top 10 most affected countries due to electricity imports and emissions exceedances (2018-2020)

The EU Bank about to fail becoming a responsible lender

The EIB Environmental and Social Sustainability Framework (EESF) is the framework that should guide all the bank’s operations so that it “actively contributes to sustainable development and inclusive growth”¹.

Despite its declared commitments to step up the positive impact of its operations, the draft EESF proposed by the EIB is substandard, according to comments from civil society groups sent to the bank. In particular, CSOs highlight how poorly human rights considerations are embedded in the proposed EIB framework. 

In 2020, a study from CEE Bankwatch Network and Counter Balance exposed the numerous human rights violations and environmental destructions linked to EIB-financed projects, from Kenya to Georgia and Bosnia-Herzegovina. In Nepal, a recent investigation showed that the EIB disbursed funds for a transmission line project despite the operation clearly breaching its own environmental and social standards, acknowledging claims made by local communities impacted by the project. 

Last month, echoing civil society demands, the European Parliament urged the EIB to “increase its monitoring of and reporting for its projects outside of the EU” and “strengthening human rights due diligence”. The two Parliamentary reports also asked the EIB to increase its presence on the ground and to have more staff focusing on development issues, for the bank to truly uphold the “do no significant harm” principle in all its operations.

Still, the bank did not address any of these demands. For instance the EIB still refuses to carry out dedicated Human Rights due diligence, and dismissed CSO demands for a more open and meaningful consultation process.

If the draft proposal is adopted as such, it would undermine the EIB’s social and environmental commitments and the bank would lag behind its peer institutions. Without  stringent due diligence and clear lines of responsibilities, the EIB could end up acting no better than the average commercial bank, CSOs warn. The EU’s house bank must not lose sight of its public mission to bring genuine benefits to the territories and people impacted by its operations.

The EIB is the financial arm of the European Union and is currently transforming into the ‘EU Climate Bank’. In addition, it is exploring plans to step up its development operations outside of Europe. Its macroeconomic power is becoming increasingly important, with the bank being at the heart of the financing of the European Green Deal and the EU recovery plans to address the economic impacts of the COVID-19 pandemic.

 

Xavier Sol, Director at Counter Balance, said: “Over the last years, the EIB has taken valuable commitments on climate and has become a major financial institution. Still, it is not walking the talk. What it proposes now is a weak set of environmental and social standards, for which the EIB would largely delegate its responsibilities to its clients. It is urgent that the EIB President Hoyer and the bank’s shareholders reverse this trend and ensure the EIB becomes a responsible lender and carries out proper due diligence”. 

Aleksandra Antonowicz-Cyglicka, Human Rights and Community Support Coordinator at CEE Bankwatch Network, said: “As an EU body, the EIB must stand by human rights. It must not be involved in projects which violate fundamental rights otherwise it undermines the EU’s global credentials. As proposed, the Environmental and Social Sustainability Framework does not safeguard human rights. We expect from the EIB’s management to improve its human rights due diligence and tighten requirements for project promoters”. 

Gaelle Dusepulchre, Permanent representative to the EU at FIDH EU office said : “Human rights and the principle of community led development should be the basic principles of operations for the EIB. The lack of clear responsibilities of the EIB and its clients to respect human rights is a real matter of concern. We urge the Bank to develop a comprehensive policy on human rights. This policy should put the Bank’s policies and operations in line with its human rights obligations, so that the EIB operations could truly benefit the ones to which they are supposed to benefit: the population”.

Catherine Gatundu, Head of resilient livelihoods and climate at Action Aid, said: “Considering the climate and development ambitions of the EIB, it is absolutely essential that women and communities are heard in decisions affecting their lives and environment. Urgent steps are needed to make this review process, and any investment decisions that follow, inclusive and meaningful, also for people living in the Global South”.

Ouafa Haddioui, Program Coordinator at Arab Watch Coalition, said: “While many EIB countries of operations of the EIB face a Human Rights crisis, the EIB proposal still lacks substantial progress to implement commitments on Human Rights. This may pave the way for damaging consequences on people’s conditions. It was also disappointing that the Public Consultation largely excluded local communities by being carried out only with the official EU languages”.

 

1. The ESSF is made of an overarching Policy document and of 11 Standards covering a variety of topics like public participation, rights of indigenous people or biodiversity protection.

*Several joint CSO contributions are available: