Thanks to the activities of Nataša Milivojević, as well as members of the ecological association "Rzav - God Save Rzav", recently the construction of two small hydroelectric power stations on the territory of the Municipality of Arilje (in south-west Serbia) was stopped.

We would say the battle was won for the second time, but the "war" is certainly not over, since the construction of three large dam and 14 small hydroelectric power plants are planned for Veliki Rzav, its tributaries and other rivers. In her interview for CO-SEED Natasa Milivojević reveals that the construction of two small HPPs has stopped, but also points to a number of problems that accompany this issue.


Nataša Milivojević - The aim of the Ecological Association "Rzav-God Save Rzav" is to protect and improve the environment, biological and geological diversity, and implement measures that prevent unwanted changes in natural and cultural-historical assets or the destruction of significant landmarks. Protecting their diversity, uniqueness and aesthetic values and enabling traditional ways of use, which are also defined in the Spatial Plan of the Municipality of Arilje with regard to the protection and use of natural and immovable cultural goods. In all strategic documents of the Municipality of Arilje, Veliki Rzav has been presented as a resource for ecotourism and officials are committed to joining the European Union. So I want to use my right to remind everyone that environmental protection is one of the priorities in the development strategy of Europe! Such sustainable development does not exhaust resources for the generations who will come after us. If we consider that socio-economic development in Serbia is more important then protection of the environment; we can no longer talk about the concept of sustainable development and its basic principles.


The best example for these claims is the project of the HPP "Svračkovo" on Veliki Rzav (dam height 68 m, length of accumulation 9 km, maximum depth 54 m and total volume of 27 million cubic meters) and the catastrophic destruction of the cleanest river in Serbia (first category of quality water through its entire course), which was presented to the public as a project of "national interest", without prior analysis of economic justification, a feasibility study, alternative solutions, analysis of the scale of destruction of nature, and without respecting the principles of the Aarhus Convention. A project that represents just one of many such decisions in the last decades that has proved to be very harmful to the environment and not helpful for nearby communities. We wonder if the goal of such projects is the personal benefit of a few individuals?


At the end of the summer of 2017, the ‘Initiative for the Evaluation of the Entire Basin of the Veliki Rzav’ was accepted as having a natural potential for protection. During the autumn, the preliminary passage of the "Visoki canyon" was carried out, where one of the potential locations for the construction of SHPPs on this river was determined by the Cadaster of Small Hydro Power Plants in 1987, as well as the Spatial Plan of the Municipality of Arilje. The very inaccessible terrain and the definition of an area as a future protected area resulted in the fact that the document "Resolution on the conditions of nature protection" was not granted to the investor. So the construction of SHPPs on this site is no longer legally possible.


Interesting is the case, which was discovered by the Public Insight into the Urban Project of the potential location of SHPPs on Mali Rzav, in which, on several occasions, instead of "Mali Rzav," "Predolska Reka" is mentioned, and by pointing to "Resavska school", we managed to influence the Urban Design project not being adopted.


It should be noted that the overall profit that the Municipality of Arilje will have from all small hydro power plants on rivers and streams is about 800,000 dinars (less then 7,000 EUR) a year (data from the triple memorandum for construction of small hydro power plants). The damage to the environment made by only one such "small" hydroelectric plant outweighs this small benefit.


1. (Not) sufficient information to the public: The Law on Environmental Protection of the Republic of Serbia prescribes that everyone has the right to be informed about the state of the environment and to participate in the decision-making processes whose implementation could have an impact on the environment. When it comes to large, as well as small HPPs, the position of the World Commission for Dams is that: "No dam can be built without agreement with the local community, without respecting their demands and without respecting their will." As a country that has ratified the Aarhus Convention, Serbia guarantees its citizens the availability of information (the pillar of the Aarhus Convention) as well as access to administrative and judicial procedures (the third pillar of the Aarhus Convention). Based on the long-term monitoring of information related to environmental protection in the southwestern part of Serbia, I claim that in almost all procedures related to SHPP projects, the decision makers are avoiding having transparency of the processes. One example - On the website of the Municipality of Arilje in June 2017, a document on the planned construction of a SHPP was published in the category "Uncategorized Content" instead of in the category "News" or "Notice to Citizens.” It is clear that there was an attempt to hide information on the construction of the SHPP from the public.


2.(Non) Implementation of laws and regulations: It has been shown that the adoption and implementation of environmental regulations, as well as the extent of the change that the reform in this area brings, are highly dependent on other sectors such as construction and urban planning, and the energy sector. Cooperation between these sectors is very bad. Lack of inspection capacity, as well as lack of inspection supervision, political influence on decision-making, and possible corruption are some of the biggest problems in the field of water resources. Definitely, the existing capacities for monitoring, control and implementation of policies are not sufficient.


Definitely, existing capacities for monitoring and controlling environmental conditions and policy implementation are not sufficient. When it comes to the application of existing laws, civil society organizations should use information of public importance as a mechanism for pressuring administrative bodies and institutions, and in this way lead to a more lawful and proper work of authorities and parties in such proceedings. However, in Western Serbia, the limiting factor is the insufficient capacities of civil society organizations in the more intensive application of environmental laws and regulations, which favors non-transparency, concealment, as well as the transformation of illegal procedures to a state of finality and legality, and the possibility of defrauding administrative and judicial authorities.


3. (In) sufficient quality of the Environmental Impact Assessment Studies: When small hydropower plants are concerned with Environmental Impact Assessment Studies, they are very often missing cumulative effects on a single waterway, impact analysis on public health when large accumulations are concerned, and data on heavy metals. Where there are biodiversity data, they are either incomplete, obsolete or generalized. An exemplary example of what we are talking about is the quality of the Environmental Impact Assessment Study for the construction of the hydro-accumulation "Svračkovo".


Conclusion: During negotiations with the EU, Serbia needs to prove that it applies laws in practice, or that it has a clear plan for achieving full implementation of certain regulations after joining the EU. In this regard, the role of local self-government is crucial, as part of the competencies is transferred to it through domestic regulations.

 In order to enhance the capacities of local organizations to monitor and actively participate in decision-making processes related to the SHP, a consortium of organizations participating in the CO-SEED project (Serbia's Protection and Study Society, Belgrade Open School, Ekolosko Rzav-God Salo Rzav "" Flores ", PSK" Kolovrat ") will organize a meeting on the topic of SHP during the month of February. The event will bring together stakeholders from local communities affected by this problem, experts and other interested parties and will aim at networking and strengthening the capacities of local organizations and the JLS to adequately handle the SHP projects and the environmental impact assessment processes. "