Bosnia and Herzegovina: Environmental and social study for Prenj motorway tunnel needs to tackle the elephants in the room, 2 July 2024

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.

...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.

...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. 

...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.

...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.

...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.

...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.

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 improve