Document: Incinerator correspondence with EBRD #1, 14.10.2005

Letter from Green Action to EBRD, 14^th October 2005

Ms Vivian Nicoli
Senior Banker,
Municipal and Environmental Infrastructure Team
EBRD
1 Exchange Square,
London EC2A 2JN

Cc: Mr Davor Indić
Principal Banker,
Municipal and Environmental Infrastructure Team

Ref. No: 14/10/2005

Date: 14.10.2005

Dear Ms Nicoli,

I am writing to express our relief that the Environmental Impact Assessment for the Zagreb Municipal Solid Waste Incinerator has been rejected by the Croatian Ministry of the Environment, and to urge the EBRD to withdraw from this poorly thought out project. Green Action raised a number of objections to the project during the public hearing and we are satisfied that these have been mirrored in the comments made by the review board for the EIA. However, we are concerned that the company concerned may rush to complete another EIA before the concerns outlined by the EIA Commission have been properly addressed.

I enclose an analysis outlining our concerns with the incinerator. As you will see, these are complex issues which cannot be resolved in a short time, and we feel that the incinerator plans have been made very prematurely, without proper planning or implementation of the waste hierarchy principles. We are also extremely concerned about the lack of proper provisions for the disposal of the toxic outputs from the plant. We therefore ask the EBRD to reconsider its involvement in the project as this would send a clear message to Zagreb City Council that its waste management must take a much more responsible and sustainable direction and that such rushed projects are not acceptable. We would much prefer to see the EBRD investing in clean production, waste production, and non-toxic recycling projects.

Please do not hesitate to contact me if you have any questions or would like to discuss the matter further.

Yours sincerely,

Ms. Pippa Gallop
Bankwatch Programme Co-ordinator
Green Action

Letter from EBRD to Green Action, 24^th October 2005

Dear Ms. Gallop,

We would like to thank you for the letter dated 14.10.2005, and appreciate the outline of “Green Action’s” concerns with respect to the Zagreb waste incinerator project. As you are aware, the EBRD has been approached by the City of Zagreb to consider financing this project. The Bank has not made any commitments at this stage, and prior to making any decision the Bank would undertake a technical, legal and environmental due diligence of the project. Such a due diligence would address the issues raised in your letter and we would make specific reference to best practice as well as EU Environmental standards and regulations for such installations. Furthermore, pursuant to EBRD Environmental Policy and Procedures, similar projects would fall under Category A classification requiring an Environmental Impact Assessment inclusive of public consultations.

The issues raised in your letter will be of great benefit to us in terms of undertaking the due diligence in due course.

Yours sincerely,

Vivian Nicoli,
Senior Banker,
Municipal and Environmental Infrastructure