The complaint shows that Bosnia and Herzegovina is failing on its obligations under the Energy Community Treaty by permitting the Stanari lignite plant near Doboj to pollute two to three times more than the EU’s Large Combustion Plant Directive (2001/80/EC) allows. Energy Community countries such as Bosnia and Herzegovina are bound to implement this directive.

Bosnia and Herzegovina’s failure is all the more serious considering that from 2018 the Energy Community countries have committed, for new plants, to enforce Chapter III of the EU’s Industrial Emissions Directive (2010/75/EU) that replaces and is stricter than the Large Combustion Plants Directive. Under the legislation, Stanari counts as a new plant, so investments may have to be made into upgrading the plant almost as soon as it starts operation.

Center for Environment also argues that Bosnia and Herzegovina has breached its obligations relating to the project’s environmental impact assessment, as the changes in the project made since its environmental permit was issued are so large that they require a new assessment, which never happened.

Construction by Chinese contractor Dongfang started in 2013 but the project has been under development for many years, and has undergone a change of technology and capacity.

After the first environmental permit was issued in 2008, the project was changed from 410 MWe to 300 MWe, and from pulverised coal with supercritical steam parameters to subcritical steam parameters in a circulating fluidised boiler.

The Ministry of Environment in Republika Srpska argued during a meeting with NGO representatives in 2012 that smaller capacity equals smaller impact, that everything else in the project stayed the same, and thus that a new assessment was not needed. However this later turned out to be untrue, as closer examination of the environmental permits revealed a change of boiler technology and the implementation of an unusual dry cooling system, that lowered the net thermal efficiency from 43 to 34.1 percent – very low for a new plant. So, while there will be less power being generated, for each unit of electricity there will be higher emissions.

While it remains to be seen what will happen at Stanari as a result of Bosnia and Herzegovina’s failure to abide by its obligations, the case should serve as a warning for the numerous other lignite power plant projects planned in the western Balkans. Although nothing is known as yet of other cases where the emissions levels allowed in new permits are as blatantly non-compliant with the Large Combustion Plants Directive as at Stanari, there are still plenty of reasons for concern.

In Bosnia and Herzegovina alone, for the Banovici plant near Tuzla no emissions limits are stipulated at all in the environmental permit (only air quality limits), while for the Tuzla 7 plant the emissions limits are in compliance with the Large Combustion Plants Directive, but not with the Industrial Emissions Directive. In the case of Ugljevik III near Bijelina, the Industrial Emissions Directive limits are cited in the permit, but the environmental assessment provides no assessment of whether the technology proposed will actually enable the plant to meet those limits.

Meanwhile, in neighbouring Serbia, the Kolubara B emissions limits are non-compliant with the Industrial Emissions Directive, and similar problems look likely for the upcoming Kostolac B3 permit, as well as for the Pljevlja II plant in Montenegro.

From a global point of view, these are effectively trifling matters, as there is no filter in the world that stops lignite from being anything but unacceptable in terms of its climate impact. But people in the western Balkans ought to be concerned for both their lungs and their budgets.

Lax pollution limits mean pollution-related health problems in cities like Tuzla will be here to stay, while the cost of upgrading plants to adhere to the Industrial Emissions Directive may finally take an axe to the persistent idea that lignite as a power plant combustion fuel is cheap.

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