Document: Incinerator correspondence with EBRD #2, 16.11.2005

Letter from Green Action to EBRD, 16^th November 2005

Date: 16.11.2005

Ref: 14/11/05

Vivian Nicoli,
Senior Banker MEI
EBRD
One Exchange Square,
London
EC2A 2JN
Fax: +44 20 7338 6964

Cc: Mr Davor Indić
Principle Banker MEI
Fax: +385 1 6197 218

Dear Ms. Nicoli,

Re: Zagreb Municipal Solid Waste Incinerator

Further to our previous correspondence, we are concerned to see that the EBRD is continuing with the Zagreb Municipal Solid Waste Incinerator project in spite of the rejection of the EIA by the Ministry of the Environment’s review committee, and we once again ask the EBRD to withdraw from this premature and ill-conceived project.

During the last few weeks we have been extremely concerned to read that the Mayor of Zagreb, Milan Bandić, is planning to ask for assistance from the Croatian Prime Minister in order to move the project forward1, which appears to indicate disrespect for the EIA and construction permit process.

It is therefore also of concern that the EBRD has posted a procurement notice on its website for a ‘transaction advisor’ for the project. This sends an unwarranted message to the City Council that it is acceptable to continue with the project in spite of the rejection of the EIA. It also seems to send a message to the citizens of Zagreb that the established procedures are worthless and that the project will go ahead irrespective of their opinions, which we assume is entirely contrary to the impression that the EBRD would like to give.

We call upon the EBRD to withdraw from the project in order to send a clear message to the City Council that the opinions of experts and citizens must be respected, and that priority should be given to waste prevention, re-use and non-toxic recycling.

Yours sincerely,

Ms. Pippa Gallop
Co-ordinator for Monitoring International Financial Institutions,
Green Action
¹ “Zagreb će za spalionicu tražiti pomoć Vlade,” (Zagreb will ask the government for help for the incinerator”), Novi List, 20.10.2005

Letter from EBRD to Green Action, 22^nd November 2005

Dear Ms. Pippa Gallop,

Thank you for your letter dated 16.11.2005. The Bank is currently undertaking a due diligence of the project and is aware of the rejection of the Environmental Impact Assessment (EIA) for the waste-to-energy project by the Croatian Ministry of Environment.

In line with its Environmental Policy, the Bank classifies as category A such a waste-to-energy plant project and will require an EIA along with the associated public consultation. The EIA has to meet the EU EIA Directive and the EBRD’s Environmental Policy and Procedures.

Based on our preliminary review, the Bank agrees with the conclusions of the Ministry and believes that the EIA undertaken to date does not meet the EU environmental and Croatian procedural requirements. As part of the due diligence process, the Bank will undertake an independent study to ensure that any project it funds meets EBRD policy requirements.

The assignment referred to in the letter (“Transaction Advisor”) is for the technical and economic due diligence of the project and a separate environmental assignment is planned in due course. The due diligence process is a standard procedure for financial institution to ensure that an independent evaluation is made of each project. It is important to note that a large proportion of projects do not pass the due diligence stage and projects are not pursued for a variety of economic, technical and environmental issues.

We hope that you will be able to take part in the Environmental Impact Assessment procedure as we believe that the project needs to be evaluated independently so that the best waste management solutions for the City of Zagreb are applied.

Yours sincerely,

Vivian Nicoli,
Senior Banker,
Municipal and Environmental Infrastructure