Tuzla 7 lignite power plant, Bosnia and Herzegovina

For more than a decade, a new 450 MW unit has been planned at the Tuzla coal power plant in Bosnia and Herzegovina, owned and operated by the state-owned Elektroprivreda BiH.

Although it is usually cited as a replacement for existing units, Elektroprivreda BiH plans to close only units 3 and 4 by 2023 (total 310 MW), while units 5 and 6 would continue to operate. Thus Tuzla 7 would result in additional coal capacity compared to the current situation.

An Engineering, Procurement and Construction (EPC) contract worth EUR 785 million was signed with China Gezhouba Group Co. on 30 August 2014, but it was later admitted that the plant would not be economically feasible.

An annex to the contract signed on 04.05.2016 is reported to bring the cost down to EUR 722 million. However former EPBIH Director Amer Jerlagić in 2016 stated that neither the Banovići nor the Tuzla 7 plants appeared feasible given the low prices on the European electricity wholesale market.

A feasibility analysis by the Banja Luka-based Institute for Construction assumed that Tuzla 7 will have to start paying a carbon price only in 2034 and that it would only be EUR 7.1 per tonne, rising to EUR 12.12 per tonne in 2061. Considering the ETS price is over EUR 25 per tonne at the time of writing, this leads to a serious underestimate of the plant’s generation costs.

The assessment assumes annual carbon costs of EUR 2.7 million in 2034, rising to EUR 31.4 million in 2061. Yet even at 20 EUR/tonne, the annual cost would be EUR 51.87 million.

Moreover, the projected price at which coal would be sold by Elektroprivreda BIH’s mines to the Tuzla 7 plant is EUR 21.87/tonne. This is lower than 2013-2016 production price.

Given that the plant is promoted by a state-owned company, if it ends up as a stranded asset, it will be the public that pays.

The project’s dubious economics are a legal problem as well as a financial one. Bosnia and Herzegovina, under the Energy Community Treaty, is obliged to follow EU legislation on State aid, but the Federation of BIH has approved a loan guarantee for Tuzla 7 which appears to be illegal.

Such guarantees have to comply with certain conditions, such as not exceeding 80 per cent of the value of the loan. However the Tuzla 7 guarantee covers 100 percent of the loan, plus additional unspecified costs. There are conditions in which covering 100 per cent of the loan could be allowed, but they are not met here.

For this reason, the Aarhus Resource Center, Sarajevo, and Bankwatch submitted a complaint to the Energy Community Secretariat in September 2018. The Secretariat opened an infringement case against Bosnia and Herzegovina in March 2019, and EU Enlargement Commissioner Johannes Hahn warned the country that its decision raised serious questions, “not only about Bosnia’s commitment to international treaties and European rules under the Energy Community Treaty but also about the choice of the energy technology as well as about a sound cost-benefit analysis in a responsible and transparent manner”.

Bosnia and Herzegovina then requested a mediation process with the Energy Community Secretariat to resolve the issue, but no agreement was reached. Since the Federal government went ahead with signing the guarantee, the Energy Community Secretariat broke off the mediation process in December 2019 and continued with the infringement process in January 2020.

The Federation of BIH’s mines are also propped up by subsidies. They suffer from the lowest labour productivity in southeast Europe and have for years received subsidies for social welfare payment obligations towards the state. In general, it is not allowed to provide State aid for operating coal mines, only for closure. 

Closure is in any case inevitable in the medium term due to the need to phase out coal to tackle climate change and the increasingly poor economics of coal. No BiH politician has had the courage to face up to this political hot potato so far. Instead of planning for a managed and fair transition, they make misleading promises about safeguarding 3500 workplaces in the mines by building Tuzla 7, which is impossible.

After Tuzla 7’s initial environmental permit expired in November 2015, a new one was issued in July 2016. As it contained numerous weaknesses including a failure to include the ash dump in the project, NGO Ekotim filed a court case challenging the permit in September 2016. This was rejected in October 2019 on the outrageous ground that Ekotim is based in Sarajevo, while the project would be in Tuzla, and an appeal to the high court is under review as of January 2020.

In 2017 the EU updated its pollution control rules for large industrial plants through the so-called the LCP BREF. Tuzla 7 has not been designed in line with these standards, making it out of date before it is even built.

The Tuzla power plant takes cooling water from the Modrac Reservoir, the same source as much of the drinking water for Tuzla. This reservoir is fed mainly by the Turija and Spreča rivers and already suffers from pollution caused by coal production and separation. If the Banovici coal power plant is built – another project just a few kilometers away from Tuzla – it will directly compete with the Modrac Lake for water in drier periods.

The environmental permit for Tuzla 7 is incomplete as it does not cover any planned ash landfill. Article 71 of the Federation’s Law on Environmental Protection states that an environmental permit must include measures for managing waste produced by the facility in question.

The planned site at Šićki Brod was heavily opposed by the Lukavac municipality council and local communities. In April 2016 they presented a petition with 2100 signatures against the site to the Ministry of Environment and Tourism, and in 2019 protests ensured that the site was not included in the local spatial plans. So far, no replacement site has been confirmed.

In November 2013, the Center for Ecology and Energy from Tuzla launched a report on the health impacts of existing and planned coal thermal power plants in the Tuzla area. Using the WHO methodology, the study found that in 2013 in Tuzla existing power plants will have caused the loss of 4900 years of life, 131,000 lost working days and more than 170 hospitalisations due to cardiac and respiratory diseases.

Although the Tuzla coal plant is the largest source of pollution in the area, it should be taken into account that this situation is aggravated further by the cumulative impacts with other pollution sources.

The existing units at Tuzla are not compliant with the Large Combustion Plants Directive or Industrial Emissions Directive and need to be modernised in line with Bosnia-Herzegovina’s National Emissions Reduction Plan.

The ash dumps at Tuzla also brings hazards for the local population from dust blowing on windy days and water pollution, as well as soil pollution through food cultivated on some of the closed sections and sold on nearby markets. At the Divkovići dump, a pipe designed to divert dirty water to a treatment plant for cleaning is not used and polluted water enters local watercourses. These issues are not only a legacy of past practices, but a reflection of current ones, and until these are halted and the area remediated, new pollution sources should not be constructed in the area.