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FINAL

CONSULTATION PROCESS REPORT Biodiversity Management Plan for HEP Ombla Hydropower Project Impacts on the Proposed Paleoombla-Ombla Natura 2000 Site For HEP and the EBRD 30/04/2013 2013-05-24

Project number: 33209 Dated: 30/04/2013 2 Revised: 2013-05-24T00:00:00

Quality Management

Issue/revision Issue 1 Revision 1

Remarks First Draft for HEP / EBRD review

Final

Date May 2013 May 2013

Prepared by Jelena Oplanic Branko Radovanovic Tim Palmer Matt Clegg Scott Beaton

Jelena Oplanic Branko Radovanovic Tim Palmer Matt Clegg Scott Beaton

Signature

Checked by Scott Beaton Scott Beaton

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Authorised by Neal Barker Neal Barker

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Project number 33209 33209

Report number Draft Version 1 Final

File reference E09\projects\2012 E09\projects\2012

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Consultation Process Report Biodiversity Management Plan for HEP Ombla Hydropower Project Impacts on the Proposed Paleoombla-Ombla Natura 2000 Site

30/04/2013

Client Hrvatska Elektroprivreda d.d. Ulica grada Vukovara 37 10000 Zagreb Hrvatska

Consultant WSP Environmental Limited The Victoria 150-182 The Quays Manchester M50 3SP UK Tel: +44 (0)161 886 2400 Fax: +44 (0)161 886 2401 www.wspgroup.co.uk

Registered Address WSP UK Limited 01383511 WSP House, 70 Chancery Lane, London, WC2A 1AF

WSP Contacts Neal Barker Scott Beaton


Table of Contents

Information Disclosure and Stakeholder Consultation Process ......... 5

Documents / Information Available to the Public ............................... 5

Approach to Disclosure, Consultation and the Reponses Provided... 5

Consultation Meetings ....................................................................... 6

Question and Answer Responses ..................................................... 7

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Information Disclosure and Stakeholder Consultation Process The purpose of the disclosure and stakeholder consultation process was to ensure that the relevant stakeholders are presented with the findings of the Biodiversity Management Plan for Proposed Ombla Natura 2000 Site and that they have the opportunity to comment on and request clarifications with regards to the presented data, analysis and conclusions.

The public disclosure and consultation process was designed around both EU and national legislation and best practice such as the Aarhus convention. Consideration has been given to ensure that a reasonable timescale for disclosure and consultation has been provided to allow effective public participation as presented in this report.

Documents / Information Available to the Public In addition to the Environmental and Social Impact Assessment (ESIA) package documents for Ombla Hydro Power Plant project1 already available to the public, the following documents were uploaded on HEP’s website (http://www.hep.hr/hep/grupa/razvoj/Ombla.aspx) on 15th March 2013, which marked the formal start of the disclosure period lasting until 11th April 2013:

Habitats Directive Assessment and Biodiversity Management Plan for Proposed Paleoombla-Ombla Natura 2000 Site (in English and Croatian).

3D model representations.

Study on the Impact of the Construction of HE Ombla on the Ecological Network, ElektroProjekt (in Croatian).

Sectoral Study on the Impact of the Construction of HE Ombla on the Bat Fauna, OIKON (in Croatian).

Sectoral Study on the Impact of the Construction of HE Ombla on Cave Fauna, Hrvatsko biospeleološko društvo (in Croatian).

Sectoral Study on the Impact of the Construction of HE Ombla on Fish, Hrvatsko ihtiološko društvo (in Croatian)

Hard copies of the above documents were available on request at HEP’s offices in Dubrovnik and Zagreb.

Approach to Disclosure, Consultation and the Reponses Provided Comments on the above documents were received by HEP during the 30-day disclosure period through the email address: [email protected].

Representatives of the media in Zagreb2 and in Dubrovnik3 were invited to a briefing to announce the finalisation of the Appropriate Assessment and Biodiversity Management Plan for the Proposed Ombla Natura 2000 Site, the disclosure of documents and the upcoming consultation process. The briefing in Zagreb was held on 12th March 2013 in HEPs offices and the briefing in Dubrovnik was held on 14th March 2013 in Hotel Lero in Dubrovnik. 1 ESIA package documents produced as part of the Environmental and Social Due Diligence for Ombla Hydro Power Plant project have been available on HEP’s website since May 24th 2011. From May to October 2011, a series of meetings were held with authorities, interested NGOs and other organisations, the general public and the expert community. 2 Ve ernji list, Energetika net, T portal, Novi list, Lider press, Nova TV, RTL, HRT, HTV, Hrvatski radio, Jutarnji list, Slobodna Dalmacija, Jutarnji list, Poslovni dnevnik, HINA, Bloomberg 3 HRT, Nova TV, Dubrova ki TV, Dubrova ki vjesnik, Dubrovnik Times, Dubrova ki list, Novi list, Slobodna Dalmacija, Radio Dubrovnik, Radio Laus, Radio Soundset Ragusa, Dubrovnik portal, Kenova info, Portal oko / Glas grada, Dubrovnik net


Announcements for the disclosure and consultation process were published by the media and were also posted on HEPs website. Stakeholders were informed by email about the disclosure period, the availability of the above listed documents and submission of comments.

A total of 39 emails with multiple questions were received during the disclosure period mostly by HEP, with a few received by WSP/B&V and EBRD directly. Emails with comments and questions were submitted by individuals and several organisations / institutions, some in Croatian, some in English and some in both languages. The organisations / institutions included the following:

WWF Mediterranean Programme

NGO Save Ombla and her inhabitants

Friends of the Earth International / Zelena akcija

Ministry of Spatial Planning, Civil Engineering and Ecology of Republika Srpska

Zeleno Sunce

Zeleni Forum Rijeke dubrova ke

Eko Ombli i

Plavi val

Udruga Sunce

All received questions and comments, including those that were not directly related to the Biodiversity Management Plan, were summarised and grouped together with a view to avoiding repetition. They were translated from Croatian to English and vice versa to facilitate responses from the various responsible project team members. Based on the relevance of the question or comment to the Biodiversity Management Plan or the topic presented, a response has been provided by WSP / B &V, HEP or EBRD. In some cases, where the question or comment is deemed to be relevant to more than one organisation, a multiple response has been provided. Similarly, where the question has specifically requested a response from more than one of the organisations, a multiple response has also been provided.

Questions/comments and responses in both English and Croatian are being published on HEP’s website within this report (see Table 1: Question and Answer Responses).

Consultation Meetings The findings of the Biodiversity Management Plan for the Proposed Ombla Natura 2000 Site were first presented to the Croatian authorities on the 5th March 2013. Participants included the Minister of Environmental and Nature Protection and the Minister of Maritime Affairs, Transport and Infrastructure. Following that, the report and findings were also presented to representatives of the European Commission from the EU Delegation in Croatia and other Croatian ministry officials on the 6th March 2013.

A number of consultation meetings were then held in Dubrovnik, Sarajevo and Zagreb during the disclosure period. At these meetings, the findings of the Biodiversity Management Plan for the Proposed Ombla Natura 2000 Site were presented.

Stakeholders were directly invited to the relevant consultation meetings by email. Announcements about the meeting for the general public were made through the media and posters which were placed in several public places in Dubrovnik.

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The following meetings were held in the week 25th to 28th March 2013:

1. Dubrovnik local authorities (County and City) and representatives of the media – held on 25.03.2013 at 9:00 in the hall “Pape Ivana Pavla II”. The meeting was attended by a total of 8 participants, including the Mayor of Dubrovnik and representatives of 5 media4.

2. Dubrovnik local NGOs and expert organisations - held on 25.03.2013 at 12:00 in hotel Lero. The meeting was attended by 35 NGOs (4 representatives).

3. Dubrovnik general public – held on 25.03.2013 at 17:00 in the hall “Pape Ivana Pavla II”. The meeting was attended by 74 individuals, some of whom were representatives of NGOs and other interested organisations.

4. BiH (FBiH and Republika Srpska) authorities – held on 27.03.2013 at 10:00 in Hotel Europe in Sarajevo. The meeting was attended by 18 participants6

5. Zagreb NGOs – held on 28.03.2013 at 10:00 in HEP offices. The meeting was attended by one NGO7 (2 representatives).

Questions and comments were recorded at the meetings and are included in the next section.

Question and Answer Responses Table 1 below provides the questions, enquiries and comments that have been recorded during the consultation process. The sources of the questions are also indicated.

4 HRT (radio Dubrovnik), Slobodna Dalmacija, Dubrova ki vjesnik, Dubrova ki dnevnik (portal), Dubrovnik net (portal). 5 ECO Vimbula, Spasimo Omblu i njezine stanovnike, Sr je naš 6 BiH Ministry for Foreign Affairs, FBiH Ministry of Environment and Tourism, BiH Ministry of External Affairs, Republika Srpska Ministry for International Economic Relations, Elektroprivreda Republike Srpske, Public Institution “Vode Srpske”, Republika Srpska Ministry of Spatial Planning, Civil Engineering and Ecology, BiH Academy of Science, Public Enterprise “Elektroprivreda HZHB Mostar”, HPP Trebišnjica 7 Croatian Association of Professionals in Nature and Environmental Protection (HUSZPO)


Table 1: Questions and Answer Responses No. Question / Enquiry / Comment Source(s) Response Provided

Approach to Biodiversity Management Plan Study

1 Why have you not consulted Croatian literature in developing the Study? Meeting for NGOs in Dubrovnik

Out of the 35 references quoted in the Biodiversity Management Plan, 11 references are from Croatian authors including the Croatian Biospeleogical Society, O Bonacci, Croatian Ichthyological Society and the State Institute of Nature Protection.

2 Are you aware of the report that was written by the Croatian Biospeleogical Society from 2008, by which they expressed that the Project will have negative impacts and they do not propose any mitigation measures? The same organisation has now been included in the development of your Study and they have changed their opinions. How would you explain that? We remind you that this was an expert opinion then and now.

Meeting for NGOs in Dubrovnik

Emails (4 related)

The WSP and B&V's team were aware of the Croatian Biospeleogical Society's 2008 Statement. In preparing the Biodiversity Management Plan, the team used:

a) the ecology baseline surveys co-ordinated by ElektroProjekt which included inputs from the Croatian Biospeleogical Society and;

b) work undertaken by Croatian Biospeleogical Society as team members of the WSP team.

Also, note that, since 2008, a number of further counteracting mitigation measures have been developed. These are reported in Section 6 of the Biodiversity Management Plan. In addition, the Biodiversity Management Plan recommends enhancement measures in Section 6.8 and Compensatory Measures in Section 8. The Croatian Biospeleogical Society experts in our team were aware of these measures and helped determine them.

3 The Regulation on Ecological Network provides “guidelines for protection measures for the ecological network”, which include the following: Article 139 - not changing habitat conditions in caves, in areas above the caves and in their vicinity and Article 142 - preserving favourable conditions (darkness, humidity, ventilation) and peace (no visits and other human impacts) in caves. In accordance with these guidelines it is not appropriate to create new artificial habitats for species to migrate. Please comment.

Emails (4 related) The quoted measures are some of the proposed conservation objectives for the Paleoombla-Ombla SCI set by the SINP. These are listed in Section 3.3 of the Biodiversity Management Plan. The potential effects on these conservation objectives are described in Section 5.3. The counteracting mitigation measures, of which creating new habitat forms a part, are described in Section 6 and aim to reduce the adverse impact of the project.

All new subterranean habitat is being created within or adjacent to the proposed HPP infrastructure; therefore the creation of new artificial caves solely for the purpose of mitigation will be minimal.

These proposed mitigation measures are focussed on maintaining the ecological structure and function of the site i.e. its integrity, as defined within EC guidance as "the coherence of the site’s ecological structure and function, across its whole area, that enables it to sustain the habitats, complex of habitats and/or populations of species for which the site is or will be classified". The concept of integrity is transposed into Croatian Law by the National Ecological Network (Ordinance on establishment of national ecological network, NN 109/07) and the Nature Impact Assessment (NIA) procedure (Ordinance on nature impact assessment, NN118/09).

4 Pursuant to the Regulations on the assessment of the impact on nature (NN 89/07) for the project of building Ombla HPP, it is necessary to conduct an impact assessment on nature (NIA), with the impacts of the planned project on the ecological network, including direct, cumulative (combined) and indirect impacts, given the structure, function and

Emails (2 related) The potential adverse effects of Ombla HPP are set out in Section 5 of the Biodiversity Management Plan.

The scope of the Biodiversity Management Plan is specific to the requirements of the EU Habitats Directive and assesses all details relevant

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No. Question / Enquiry / Comment Source(s) Response Provided

conservation objectives for specified areas. It is necessary to list possible direct, indirect, temporary, permanent impacts of the Project on the conservation objectives and integrity of the ecological network. Have you listed these and where?

to that.

5 Reduction of biodiversity and destruction of certain species which can possibly happen with the construction of HPP Ombla, is contrary to the principles and strategic guidelines of the Strategy and action plan for the conservation of biological and landscape diversity (Narodne novine 143/08) and the Convention on Biological Diversity signed by Croatia. Therefore, mitigation measures mentioned in several places are in collision with what is written above and proposing them can only be construed as being unscientific and maybe even unethical.

Emails (2 related) The Biodiversity Management Plan has been prepared in accordance with the EU Habitats Directive.

6 Have the WSP/B&V experts been to Ombla and more specifically to Vilina Cave?

Public meeting in Dubrovnik

Yes. The WSP and B&V team consisted of 24 international and Croatian experts. In July 2012 and August 2012, a significant number of these international and Croatian experts visited Vilina Cave, Ombla Spring Cave and the Great Hall (via HEP's exploratory tunnel). In addition, our Croatian experts have visited the caves and the wider Ombla area on a further number of occasions.

7 Why have other experts not been involved in the Study? We propose that HEP organizes a public debate with experts who believe that the Project is harmful and dangerous, for the environment and the population, as well as the population living nearby the Ombla river. Such a meeting has not been organized since 1999, when the EIA was developed and has not involved experts who have a different opinion, such as Ognjen Bonacci, PhD – hydrology and karst hydrology, Ivo Lu , PhD - karst, Sre ko Boži evi , PhD – hydrology and speleology, Goran Mazija – engineer). That would be impartial and transparent.

Meeting for NGOs in Dubrovnik / repeated at the Public meeting

Emails (4 related)

The proposal to undertake the biodiversity management study that included a team of some 24 international and Croatian experts, was selected by HEP and EBRD following a competitive tender submission as the best overall proposal to undertake the project. The team was assembled to include a strong international team presence with expertise in the relevant fields supported with local experts that were involved in the ecological survey work and other local experts with strong credentials in their fields. As described in the introduction, there were a number of public and NGO-specific meetings at which any party could provide further information and their opinions.

8 Field assessments were carried out only for several days, within a period of a few months (March, May and June 2012). Due to such a short period of research, the results do not provide a full picture of the cave's condition and its biodiversity and the documents (Biodiversity management plan and Plan for HEP Ombla hydropower project impacts) were based on that research that was superficially done. Why didn’t assessments last at least one year, as this would enable research when the flow of water is lowest, leading to a discovery of other species?

Meeting for NGOs in Dubrovnik / repeated at the Public meetings

Emails (12 related)

The information used in preparation was wider than just the site surveys completed in March, May and June 2012. The summary of the baseline studies relevant to the proposed SCI features is listed in Table 4.1 of the Biodiversity Management Plan. The list of all information received is provided in Appendix D.

Any uncertainty due to lack of data is dealt with in the precautionary manner prescribed by the EU Habitats Directive.

It is also worth noting that the main channel is always flooded as it is below the crest level of the Komolac weir at its downstream.

Biodiversity Impacts – Bats

9 The study says: "Construction of Ombla HPP will have a negative impact on bats as a target conservation species and on integrity of the ecological network # HR2000186 Vilina Cave, however, the impact is assessed as acceptable with the prescribed measures to mitigate adverse impacts on the conservation objectives and integrity of the ecological network the proposed measures." This is not adequately elaborated but only assumes that the measures to reduce the damage are acceptable and sufficient to maintain populations of bats and maternity colonies in Vilina cave. Based

Email There is substantial detail on impacts and mitigation contained in the Biodiversity Management Plan, which also acknowledges uncertainty.



on these risks to populations of bats during the construction of the HPP, its operation and in crisis situations, the assessment suggests that there is a great likelihood that these populations will be jeopardized, if not destroyed because of habitat loss, disturbance, unplanned flooding and changes in the micro-climate.

10 Croatia has been a signatory of EUROBATS since 2000. This means that 35 strictly protected bat species in Croatia must not be touched, disturbed, let alone resettled. Why is EUROBATS not mentioned in the report? Have the experts contacted EUROBATS in developing the study and is there any feedback from them and proposed mitigation measures? Where can this feedback be found?

Meeting for NGOs in Dubrovnik, repeated at Public Meeting

Email (5 related)

The team of 24 experts that produced the Biodiversity Management Plan includes two experts who have contributed to EUROBAT initiatives. The team also used EUROBATS guidance in preparing this plan (see References Section).

As EUROBATS is a convention between nation states, Croatia is represented at the convention level by the Ministry of Environmental and Nature Protection and/or the State Institute of Nature Protection, both of which have been communicated with during this study.

11 Why are only five species of bats in Vilina Cave mentioned the Study, when many of our experts determined that there are seven species of bats in total (e.g. during winter there are two more bat species, as reported in the OIKON study - Rhinolophus blasii and R. hipposideros. Their number is vastly larger in the summer). Please comment the validity of the assessments and the report, in light of these facts?


Email (5 related)

As the scope of the Biodiversity Management Plan was derived from the EU Habitats Directive, it focuses on the designated SCI features listed in Table 3.1 of the report. These are two habitat features and five bat species features. All other species have not been designated as species features (by SINP).

The BMP has used the conservation objectives of the proposed SCI as the basis for its assessment and used a precautionary approach to assess potential changes in the habitat that has the potential to be utilised by all species of bats found in Vilina Cave. The areas of the Vilina Cave known to be used by bats at various times through the year are identified in Section 4.

12 Vilina Cave is one of the nine most important bat caves in Croatia and is the most important site for bats in the Dubrovnik area. Seven species of bats have been recorded here: Blasius horseshoe bat (Rhinolophus blasii), southern horseshoe bat (R. euryale), large horseshoe bat (Rhinolophus ferrumequinum), the lesser horseshoe bat (Rhinolophus hipposideros) Schreibers' bat (Miniopterus schreibersi) lesser mouse-eared bat (Myotis Blythii) and legged bat (Myotis emarginatus). According to the Croatian Red List of mammals Schreibers' bat is endangered (EN), and the southern Horseshoe and Blasius horseshoe bat are vulnerable species (VU), while the larger and lesser horseshoe bat and legged bat are potentially endangered species (NT). Vilina Cave has special significance for maternity colonies of four species of bats. All seven species of bats are protected by international regulations (Bonn and Bern, EUROBATS Agreement, the EU Habitats Directive) and by the nature protection law as a strictly protected species.

Email Thank you for your comment.

As discussed above, the scope of the Biodiversity Management Plan was derived from the EU Habitats Directive, it focuses on the designated SCI features listed in Table 3.1 of the report. These are two habitat features and five bat species features. All other species have not been designated as species features (by SINP).

13 "Although HEP claims that the Vilina Cave will be submerged, given that the lowest part of its sloping corridor between entrance hall and high hall, where a bat maternity colony of endangered species resides, is located within the dam and its ceiling is below 130 mN /m, we find that is still potentially possible that it will be submerged because of filtration through rock fractures. In this case, the survival of the existing colony of bats in the Vilina cave with envisaged intervention will be seriously threatened the existing maternity colony of bats would be lost for the surroundings of

Email There is substantial detail on impacts and mitigation contained in the Biodiversity Management Plan.

Impacts and risks associated with this are fully detailed in the Biodiversity Management Plan, specifically in Sections 5.2 to 5.4 and 6.3.

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Dubrovnik, which would be a violation of the existing Nature Protection Law (NN30/94) and international obligations under the agreement on the protection of bats (EUROBATS agreement) signed by Croatia, and a deliberate violation of the measures prescribed for this area under the Ecological Network. This undertaking would be acceptable from the point of bat conservation only in the case of building of the drainage system of the lowest part of the sloping corridor between the hall and the first high halls.”

14 The State Institute for Nature Protection stated in 2008 that the project can already be assessed as unacceptable intervention in nature, despite the mitigation measures proposed in the study on bats (Mrakov and Tvrtkovi , 2008). By carrying out this intervention, the ecological network would be irreversibly degraded, as the works are going to, directly and indirectly, change habitat conditions (immersion/drying of habitats and diversion of 90% of the main water flow in the tunnel for the HPP)." What do you think about that and what would you say about this opinion if you got one today?

Emails (5 related) There is substantial detail on impacts and mitigation contained in the Biodiversity Management Plan. We note that the statement cited in the comment was prior to the publication of the Biodiversity Management Plan in March 2013.

Biodiversity Impacts – Other Habitat and Species Features

15 In the Vilina Cave – Ombla Spring system a total of 68 cave species have been found that are endemic to the so-called South-dinaric biogeographic region, and many of these are endemic to the narrower area of Popovo polje and Dubrovnik coast (the so-called Paleoombla area). There are also 14 species that are endemic to the system Vilina Cave – Ombla Spring. Construction of HPP Ombla will flood the Vilina Cave, which has significant biodiversity (seven protected bat species, proteus angus, cave shrimp, shellfish and snails). Of the total of 49 recorded aquatic invertebrates (Tvrtkovi and Mrakov , 2008), 20 of them are troglobionata. Prominent among them are: shellfish Congeria kusceri (Appendix II. Habitats Directive) and cave worm (Marifugia cavatica) and pretneri cave shrimp (Spelaeocaris pretneri) that are on the Croatian Red List of subterranean fauna as a vulnerable species (VU). Of the 28 recorded terrestrial invertebrates, 15 are troglobionatic species, five of which are known to science just from the Vilina Cave – Ombla Spring. Caves which are not open to the public (8310) - this habitat type is protected under the Habitats Directive, and includes caves rich in endemic and endangered species. How will species that have been determined as being unique in the world be protected? Installing HPP Ombla will be a poor solution as it will destroy the river system. Please select an alternate geographic location for the power plant.


Emails (3 related)

As the scope of the Biodiversity Management Plan was derived from the EU Habitats Directive, it focuses on the designated SCI features listed in Table 3.1. These are two habitat features and five species features. As the species identified as being unique in the world are not designated by SINP as species features, these species are assessed in a similar fashion to all other species not designated, and have not been disregarded. That is, their habitat is assessed under the EU Habitats Directive and the results of this assessment are reported in the Biodiversity Management Plan.

16 The impacted area of Vilina Cave – Ombla Spring and the surrounding area between Dubrovnik and Slano form a single ecological unit, according to a new biospeleological study and it is a site of international importance for nature conservation under the name Paleoombla. It is a unique karst region through which rainwater from Popovo polje in the BiH underground drains to the Adriatic Sea, forms freshwater springs on the coast and the source of the shortest river in the World, Ombla. The majority of water passes through a relatively narrow belt – the Hum-fault and springs at the source of Ombla - and flows into the sea as the Dubrova ka river. This

Email There is a detailed description of the cave system and species in the Biodiversity Management Plan, and substantial detail on impacts and mitigation.



exceptional underground aquifer system is considered the richest cave fauna refugia in the world, as has already been confirmed in research for specific sections (Ozimec, 2008).

17 The locations Vilina špilja (Fairy Cave) (code: HR2000186) and cave system Vilina špilja – Izvor Ombla (Fairy Cave - Ombla source) (code: HR2000187) are areas of the ecological network declared by the Croatian Government Regulation on the National Ecological Network (NN No.109/07). The wider area Paleoombla - Ombla (code: HR2001010) is important for species and habitat types protected by the EU Habitats Directive and is a proposed Natura 2000 site.


18 More than 10% of the troglobionata are stenoendemic, and there is also an extremely large number of organisms not known to science before, which highlights the great value and responsibility to protect this area. Thanks to extensive research, the Vjetrenica cave in Bosnia has almost 40 new species and about 100 species of troglobionata. The cave was nominated for the UNESCO list of World Heritage Sites. In other caves and pits in this area twenty more species have been described, especially in the cave system Vilina Cave – Ombla Spring.


19 In research of the Croatian part of the Paleoombla area in 2008, 60 caves were found and only 20 of them were researched. In them the same species that live in Vjetrenica and some presumably new to science have been found. With Velebit and Biokovo, Paleoombla is a centre of endemism and one of the areas the richest in underground biodiversity in Croatia and abroad. Numerous caves of this area, especially Vilina Cave, are rich in archaeological and paleontological sites. The area is already affected by operations at Trebišnjica river and Popovo polje in Bosnia and Herzegovina which took four billion m3 of water necessary for the survival of the rich subterranean aquatic fauna (Mrakov and Tvrtkovi , 2008).”


20 Only 1% of the affected area has been assessed, while 99% of the affected area is in BiH which has not been assessed. Who knows how many other species would be found if this remaining 99% was assessed?


Emails (2 related)

Uncertainties with cave fauna are described and addressed in the Biodiversity Management Plan.

Whilst 99% of the Ombla catchment does lie within Bosnia-Herzegovina, the proposed Ombla hydropower only impacts on a small proportion of this 99%.

21 The results of the 2012 assessment show that Ombla is very rich in biodiversity, therefore the EIA study from 1999 is not valid as it states that no protected species have been found in Ombla and even if they have been, it is not their permanent habitat. The members of the Committee were aware of a list of fauna compiled by Branko Jalži , which contained 12 endemic and endangered underground species, which were not included in the EIA. The results of the 2012 assessment also refute claims that the Ombla fauna is not indigenous but that it arrived with the water from Popovo Polje and Trebišnjica.


Emails (12 related)

This comment does not relate to the Biodiversity Management Plan study that has been conducted.

The current study and Biodiversity Management Plan were intended to meet the requirements of the Habitats Directive. In Section 1.1, it is stated that “it was considered that some parts of the EIA reports were no longer representative of the current baseline conditions, and therefore may need to be reviewed and updated. In this regard, HEP agreed that further work should be undertaken that included analysis of existing data and conducting baseline ecology surveys, with the key aim of establishing an appropriate assessment baseline”.

22 The Sectoral Study on the Impact of Construction of HE Ombla on Cave Fauna states that the main feeder channel was not biospeleologically investigated. During the 3-month research, the presence of the Olm was


The process of removing the Olm Proteus anguinus (human fish) as a species feature of the proposed SCI was initiated by SINP in January 2013. With that removal, the Habitats Directive assessment focused on the

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not confirmed, because it was not allowed to dive in the main inlet channel during the lowest tide. Only one sample of water was taken in order to confirm the presence of the Olm, but due to a poor sample, the analysis could not be performed. The Olm (Proteus anguinus), a species from the list of target species of the conservation objectives of the ecological network was last found in the Spring Cave of Ombla in 1986.The Olm (Proteus anguinus) is protected under the Habitats Directive (Appendix II.) and the Croatian nature protection law, and is linked to underground water habitats. Why was the human fish (Olm Proteus anguinus) removed from the list of affected species? Why wasn’t the possibility of return of Proteus anguinus to this habitat taken into account? Was there any possibility of finding it if the research lasted longer and if it was thoroughly made? Why wasn't a new sample sent for investigation?

Emails (6 related) two designated habitat features and the five designated species features.

Information relating to Olm Proteus anguinus is included as Appendix A of the Biodiversity Management Plan.

The scientific literature indicates that the Olm Proteus anguinus is a relatively weak swimmer and therefore not typically found in fast flowing water such as the main deep cave passage. EU guidance is that a species should not be designated as a species feature unless there is a viable population in the SCI and there is no evidence to suggest there is.

The extent of the survey work that was conducted by ElektroProjekt is beyond the scope of the Biodiversity Management Plan.

23 Despite the insufficient research, the Sectoral Study on fish concludes the following: "Even with intensified efforts, no Olm presence has been recorded in the tested system. This is probably the result of the cementation of the Trebišnjica chutes (1970) that drastically changed the water regime of the Popovo polje (Popovo field) and the underground water at Ombla. The species is listed on the list of target conservation species for the ecological network in the Ombla area and the list of species proposed for Natura 2000 for the Paleo Ombla area.” This is just one example of how the conclusions in evaluating the acceptability of the HPP Ombla on the ecological network have been reached in a dubious manner. The Olm (Proteus anguinus) was left out of the study based on the fact that the last recorded sighting was in 1986, although the research in 2012 was limited in time and space because researchers were not able to dive in the main channel. The Olm is a target species for protection for this area, the National Ecological Network and the European ecological network Natura 2000, so leaving it out is legally unfounded since it was done without a systematic multi-year study.

Email The process of removing the Olm Proteus anguinus (human fish) as a species feature of the proposed SCI was initiated by the State Institute for Nature Protection in January 2013. With that removal, the Habitats Directive assessment focused on the two designated habitat features and the five designated species features.

The Olm was not “left out” of the study. Information relating to Olm Proteus anguinus is included as Appendix A of the Biodiversity Management Plan.

The scientific literature indicates that the Olm Proteus anguinus is a relatively weak swimmer and therefore not typically found in fast flowing water such as the main deep cave passage. EU guidance is that a species should not be designated as a species feature unless there is a viable population in the SCI and there is no evidence to suggest there is.

24 “It is stated that the species in question are not on the proposed list of species proposed for the conservation of the ecological network of the EU Natura 2000” (Elektroprojekt, Study on the Impact on the Ecological Network of HE Ombla, page 38). How can this conclusion be made when the species cannot be listed as they have never been found before and this does not mean that they will not be on the list in the future?

Email This is a question relating to the Elektroprojekt Study and is therefore beyond the scope of the Biodiversity Management Plan.

25 The subterranean fish Popovo field minnow (Delminichthys (Phoxinellus) ghetaldii) is endemic in Bosnia and Herzegovina and Croatia, and is listed in Appendix II of the Habitats Directive. The Croatian Red Book of Freshwater Fish categorises it as endangered (EN). The cave system Vilina Cave – Ombla Spring is the only location in Croatia, where this species was recorded. “While diving, several types of fish (of a smaller habitat) which could correspond to the ‘Popovska’ minnow were seen, however since the fish were not caught this finding was not confirmed” (Elektroprojekt, Study on the Impact on the Ecological Network of HE Ombla, page 40). Later, on page 44 it is written that “Popovska” minnow was caught – found, however that it is thin and its real status cannot be confirmed. Why haven’t additional studies been done?

Emails (2 related) It should be noted that Popovo Minnow has not been proposed as a special feature of the SCI by the SINP and as such it wasn’t appropriate to undertake more detailed assessment on this and other similar species not listed.




26 In the study on the impact on fish, it is not clear on what basis it is concluded that individual specimens of Delminichthys ghetaldii had been accidentally washed out of the Trebišnjica system. It also does not specify the size of the population found, and the research was conducted for only three months in 2012 (March, April and June) and was not conducted during low water. The conclusion is that the population is not native, and that the construction of the HPP will have no impact on it, which is a very bold conclusion with regard to the quality and timespan of the research. The study does not include an assessment on the impact of contamination of waters on Delminichthys ghetaldii, and no research has not been done on the impact of increasing the capacity of water extraction for drinking water, climate change or the possible salinization of the Ombla river, or the lack of research during low water periods.

Email As discussed above, the Popovo Minnow has not been proposed as a special feature of the SCI by the SINP and as such it wasn’t appropriate to undertake more detailed assessment on this and other similar species not listed.


27 The assessment carried out by the Croatian Biospeological Society points out that the negative impacts of the Project on habitat type H.1. karst caves and pits and the endemic species and cave shrimp Speleocaris pretneri, are contrary to the proposed guidelines for protecting the ecological network.

Emails (2 related) These impacts are discussed in the Biodiversity Management Plan.

28 As a result of the construction of the grout curtain, the flooding and other types of direct physical devastation, it is possible that there will be a distortion of the stability and cracking of cave ceilings and walls and not only in the directly affected area but wider, which will negatively impact habitats.

Emails (2 related) Discussed in Section 5.2.1 of the Biodiversity Management Plan.

29 A study for the City of Dubrovnik prepared by: Dr.sc. Marijana Cukrov, and M.Sc. Roman Ozimec, Expert study: natural features of the river Ombla, published in 2012, concludes that the construction of the HPP Ombla predicts flooding the entire cave system to the level of 7 m below the entrance to the Vilina Cave, which will destroy all terrestrial and aquatic cave habitat, except for the first 70 metres of the cave system, which according to current knowledge, includes over 3 km of cave channels. The study concludes: "We believe that the proposed construction of HPP Ombla is, from the ecological point of view, completely unacceptable and we appeal to the professionals and environmentally friendly public to use their authority and influence to prevent the construction of dam and irreversible destruction of the cave system."

Emails (3 related) The mitigation of the flooding of the cave system will be reduced but it is acknowledged that significant sections will still flood as set out in Section 5, 6, and 7.

The role of the project team was to prepare a report assessing the impacts of the projects under the EU Habitats Directive. The published report and the presentations in Croatia detailed the findings of this assessment. The decision on ultimate implementation of the project is for HEP to make, and for the appropriate Croatian government authorities to permit, oversee and regulate.

30 The Conclusion of the Study on the impact of construction of HPP Ombla on the ecological network states the following: For 17 recorded aquatic species there is a possibility of destruction of the population, which does not exclude the possibility of their survival in the remaining aquatic habitats, which altogether increase by raising the groundwater level. Specifically, most parts of the area of the middle levels, which is in present conditions periodically under water, will be permanently under water. Also, next to the Spring Cave a new habitat will be prepared for the reception of species from this area during the construction works and operation of HPP Ombla. Terrestrial species, will, due to this intervention, be less vulnerable due to the existence of habitat at higher levels of the cave system that remain dry, as well as the construction of new terrestrial cave habitats in the injection galleries 2 and 3. The flooding of the terrestrial habitat and


We note that the comment relates to the conclusions of the ElektroProjekt report (Study on the Impact on the Ecological Network of HE Ombla). The BMP sets out the conclusion of the assessment under the requirements of the Habitats Directive in Section 7. Section 7.2 documents the predicted residual effects and uncertainties associated with Ombla HPP with mitigation in place. An adaptive monitoring and management plan is presented in Section 9, should HEP and Croatian government determine that the project should go ahead.

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diverting underground water from the hinterland Ombla the turbines and raising the groundwater level will negatively affect populations of terrestrial and aquatic species in these habitats. The biggest impact will be on the terrestrial habitats on the lower level and much of the middle levels of habitats that are flooded.

31 The environmental impact on marine ecosystems due to leaching of fertilizers and pesticides has not been assessed.

Email This was not examined in the Biodiversity Management Plan, since HPP construction and operation would have no effect on leaching of fertilizers and pesticides.

32 What is the exact absolute (in m3) and relative surface area of the foreseen replacement habitats (as a percentage of the overall observed underground surface area and as a percentage of the overall observed underground surface area that will be flooded by the Project)

Email The mitigation of the flooding of the cave system are set out in Section 5, 6, and 7.

Mitigation Measures, Compensatory Measures and Management & Monitoring Programme

33 Is it realistically possible to relocate any species from one cave to the other, as proposed by the Biodiversity Report? Please provide examples, relevant to Ombla, from locations/projects with similar bio-eco-geological-speleological and morphological characteristics), of where this has been successful elsewhere in the World and within what time period.


Email

The Biodiversity Management Plan discusses the practicality of providing replacement cave habitat in Section 6.2.3; this gives a specific reference to Isaia et al (2011) which describes colonisation of man-made tunnels. The proposed mitigation measure allows for at least 12 months of colonisation of new subterranean habits directly linked to existing habitats. Translocation considered as an additional measure if required. Section 6.2.4 describes the uncertainty involved in this process and recommends a monitoring program to identify whether there is a need for translocation.

34 The effectiveness of the proposed mitigation and compensation measures in terms of priority species conservation is questionable mainly due to the lack of knowledge of the cave fauna ecology. How successful will the proposed mitigation measures be in relation to the Project HPP Ombla in a Natura 2000 site (an estimate in %)? Can you conclude that there are situations when mitigation measures will not be successful for preserving the biodiversity and habitats? What guarantees that mitigation measures will prevent endangering protected species?

Emails (6 related) Uncertainty in baseline data, the proposed measures and other aspects of the assessment have been dealt in a precautionary manner in accordance with the procedures set in the EU Habitats Directive.

In the Biodiversity Management Plan, the uncertainty related to the proposed counteracting mitigation measures is covered in Section 6. Table 6.3 summarises the uncertainties and hence provides detail of how the project intends to deal with these uncertainties.

35 Please explain the artificial habitat which is to be created in more detail: How will you move all species that have been found, i.e. which techniques and tools will be used (explain for each species individually)? How do you plan to keep all these species in the new artificial habitat? How can you guarantee that all these species will accept this type of artificial habitat? Having in mind the number of newly found species i.e. biodiversity, how large does the artificial habitat have to be to fulfil the conditions for the survival of all species, i.e. the temperature, the humidity, the darkness, water, food?

Emails (4 related) The artificial habitats proposed in the Biodiversity Management Plan include:

an Aquatic Cave Fauna Refuge (near the existing Spring Cave) - details of this are provided in Section 6.1.2

2. new subterranean habitat using the grouting galleries - details of this are provided in Section 6.2.3

3. new bat habitat within 2. (above) - details of this are provided in Section 6.8

The sections cited above contain all the details of the proposed artificial habitats currently available, including target conditions. These proposed mitigation measures are focussed on maintaining the ecological structure and function of the site - that is, its integrity. Uncertainty associated with the provision of new subterranean habitat is discussed in Section 7. The design and nature of these new habitats will be further informed by additional monitoring and data collection as outlined in Section 9 and Table 9.1.



36 What changes would this Project induce on the ecology network Natura 2000 site if the mitigation measures were not implemented?

Emails (3 related) See section 5 in the Biodiversity Management Plan.

37 The ecological network requirements talk about mitigation measures within NATURAL habitats, therefore the compensation measures, in the sense of creating artificial caves, as proposed by HEP, are not acceptable.

Email Elsewhere in the EU, mitigation measures for such impacts are routinely human-made. It is for the Croatian regulatory authorities to determine whether suitable compensatory measures are secured, if required.

38 How could HEP be informing everyone that the Study is acceptable and positive, while we now hear that, according to the Study, there are uncertainties and that mitigation measures have to be undertaken?


The Biodiversity Management Plan, which has been disclosed by HEP for public review, describes the uncertainty associated with the proposed mitigation measures.

39 If it is determined through monitoring during construction that the mitigation measures are not successful in preserving the environment will HEP stop implementation / will WSP/B&V, EBRD suggest to HEP to stop the Project?


Email (4 related)

WSP and B&V's role in the project was to prepare a report assessing the impacts of the projects under the EU Habitats Directive. The published report and the presentations in Croatia detailed the findings of this assessment. Decisions on whether to finance the project initially and during various steps of construction are for EBRD to make based on conditions that may be established regarding acceptable impacts. The decision on ultimate implementation of the project is for HEP to make, and for the appropriate Croatian government authorities to permit, oversee and regulate.

40 What will happen if any one of the species does not inhabit the artificial caves? Will the Project be stopped?


The details of implementation and monitoring of the mitigation have not yet been determined.

Water Impacts and 3D Modelling

41 The plan does not foresee compensation measures for the devastation of habitats of invertebrate cave fauna that will be caused by the hydro-accumulation

Emails (2 related) See section 8 of the Biodiversity Management Plan for information on compensatory measures.

42 Terrestrial fauna is adapted to the current short term flooding of the habitat, but it cannot be compared with permanent flooding of 75 to 130 m above sea level.

Emails (2 related) These impacts are discussed in the Biodiversity Management Plan.

43 The 3D model was not clearly presented, particularly the expected impacts in the three levels of underground caves and whether or not a new cave will be created for the bats.

After the meeting for public authorities in Dubrovnik

Within the Biodiversity Management Plan, the significant effects, mitigation and residual effects are detailed in the table in the Executive Summary at the beginning of the report. This table indicates whether the assessment has been able to determine whether there is 'no significant adverse effect'. This term is a specific legal term defined in the EU Habitats Directive. Further detail is given in Sections 5, 6 and 7 of the plan.

Also, the effects of Ombla HPP on Water Levels and Flows within the caves are detailed in Table 1.4 of the Biodiversity Management Plan and the creation of new bat habitat is proposed as an enhancement measure in Section 6.8.

The 3D model figures are presented in Appendix E.

44 What are the possible impacts of new accumulations and reservoirs on existing (natural) reservoirs; are landslides in Mokošica possible? Ph.D. Ognjen Bonacci (expert opinion, 19th January 1999), stated that the HPP Ombla EIA cannot be accepted as it does not consider the possibility of increasing landslides, land subsidence, and water flow disruptions


Emails (3 related)

This question is beyond the scope of the Biodiversity Management Plan.

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45 Prof. Bonacci claims that after HPP Ombla is constructed, the construction of the grout certain will cause changes in the circulation of fresh water leading to changes in the natural balance between sea water and fresh water; sea water will prevail and cause extensive ecological and other consequences. Please comment.



46 The geological maps from 1969 that were used as a basis for the Study do not cover all layers. The fact that there is a thermal spring nearby has not been taken into account. Not all cracks have been explored and water will flow through them. The Project is an adventure. Where will people from Mokošica be relocated to?


There are no plans to relocate people from Mokošica.

47 There are also uncertainties as to the impacts of the ‘reservoir’ of water that will be ‘caught’ with unknown pressure, very high in karst underground above the level of today’s spring and the network of cave channels and cavities.

Email There is relatively little uncertainty about such impacts. The pressures of the water in the newly saturated zone of the karst are based on water elevation, so are indeed well known.

48 Why hasn’t the source of the Ombla river been assessed? (Elektroprojekt, Study on the Impact on the Ecological Network of HE Ombla, page 17)?

Emails (4 related) As can be seen from the data register in Appendix D of the Biodiversity Management Plan, a large amount of data on Ombla was received. This included information on the sources of the water that flows out of Ombla spring such as dye tracing that shows the links to the sink holes in Popovo Polje and elsewhere. This background information is summarised in Section 1 of the plan.

49 Please provide a list of all drinking water springs from Pobrežje to Parež and mark the ones where you are continually monitoring the quantity of water flow during all seasons.

Email This question is beyond the scope of the Biodiversity Management Plan.

50 In the available documents, you yourself are claiming that there will be changes in the internal water flows within the mountain. We are seeking a precise answer as to where exactly will these changes occur (the location) and in which direction?

Email The change in internal flows that relates to the explored cave system is set out in Table 7.2 of the BMP.

51 How certain is it that the injected mass will close down many of the water sources, which are important for survival in these areas? How do you plan to compensate the local population, having in mind that they will have to move out as their agricultural properties will be destroyed and that water supply for certain settlements will stop? In 1979, after the earthquake, two springs used for drinking water and agriculture were forever lost.

Emails (2 related) It is not expected that there would be any effect on springs and agricultural properties. No one will have to be relocated.

52 What is the exact surface area which will be flooded by the Project (absolute - in m3 and relative - as a percentage of the overall observed underground surface area)

Email As there is no standard measure (in terms of volume, area, length, etc.) for cave habitat, the Biodiversity Management Plan has used cave passage length to quantify the habitats. The amount of impacts etc. are detailed in Tables 5.2 and 6.2.

General and Other

53 We have been hearing a lot of positive aspects of the Project, please inform us what are the negative impacts and threats in relation to the Project?

Meeting for public authorities in Dubrovnik

Within the Biodiversity Management Plan, the significant effects, mitigation and residual effects are detailed in the Table in the Executive Summary at the beginning of the report. This table indicates whether the assessment has been able to determine whether there is 'no significant adverse effect'. This term is a specific legal term defined in the EU Habitats Directive. Further detail is given in Sections 5, 6 and 7 of the report.



54 The study does not mention Project impacts outside of Natura 2000. For example, there is no mention of birds in the Biodiversity Study although birds are present at the Ombla spring and the Rijeka Dubrova ka area is home to many bird species. Has a birds assessment been done as per the EU Birds Directive? EBRD has suggested carrying out bird assessments before construction (PR6), what are the results of such assessments? Will noise and vibrations have an impact on birds?


Emails (4 related)

The scope of the Biodiversity Management Plan did not include assessment under the EU Birds Directive; the SINP has not designated the site under the Birds Directive.

55 The Habitats Directive prevents Projects which will harm habitats from implementation. In your opinion, is the implementation of this Project justified?


See response to comment 39.

56 Why was the presentation of the Study in the Ministry for Environment by WSP/B&V in November abruptly interrupted and stopped? Was the reason for the interruption because the media reported that the findings of the Study were negative?


At the time, only an Executive Summary was available for HEP review because the work was behind schedule. The presentation was postponed until the analyses and interpretation were complete and ready to be presented to the Ministry for Environment. Media coverage did not affect the work or its presentation.

57 According to the Manual on nature protected areas in Croatia, the area of Rijeka Dubrova ka has been considered a significant landscape since 1964 in which only activities that do not harm its appearance and beauty can be carried out.


Email

Whilst Rijeka Dubrova ka's characterization as a significant landscape maybe relevant for the wider project; it is not relevant to Biodiversity Management Plan. The Plan was intended to examine the proposed Natura 2000 area only.

58 In terms of the impact of construction of HPP Ombla on the National Ecological Network (NEN CRO) and the European ecological network (Natura 2000) it is important to note that the Study on the impact of construction of HPP Ombla on the ecological network is not designed well and leads to the wrong conclusions.


59 Artificial channels and creating artificial caves by the Spring Cave are mentioned as measures to reduce the damage. However these measures cannot be applied under the EU Habitats Directive, because the Vilina Cave–Ombla Spring system is classified as target habitat for conservation under Code 8310 Caves and Pits Closed to the Public and as such belongs in the National Ecological Network and the proposal for the European ecological network Natura 2000. Because this habitat has 14 endemic species that are found only in this cave, it is clear there is no way to reduce harm or and no existence of alternative habitats. Artificially constructed caverns and tunnels cannot be classified as habitat 8310 Caves and Pits Closed to the Public, which relates to natural speleological sites and cannot be counted as a substitute for the flooded and blocked up cave channels and interstitial habitats

Email The definition of Caves not open to Public (EU code 8310) as defined in the Interpretation Manual of European Union Habitats is provided in BMP Section 3 and the effectiveness of providing artificial subterranean habitats to offset predicted habitat change and loss is provided in BMP Sections 6 and 7. The BMP clearly identifies that, in accordance with the precautionary principle, the offsetting of impacts by providing artificial cave habitats with natural/semi-natural surfaces should only be applied to species found within the cave system and not be used to offset the loss of the extent of Cave habitat itself. It should however be noted that the evidence base suggests that fauna and flora of caves do not distinguish in such a certain way between natural caves and man-made tunnels and mines, whilst the Habitats Directive is not about the preservation of the caves as geological structures, but their biodiversity and the conservation of the habitats and species which they host. These considerations have been material to the conclusions made in the BMP.

60 In the EBRD's Environmental and Social Policy, Performance Requirement 6 states that 'critical' habitats and the species they contain require special attention (see PR6, para 13). In relation to these criteria, the Ombla complex is considered 'critical habitat'. The majority of bat species that use the Vilina Cave in the Ombla complex are listed as vulnerable on the Red List of the International Union for the Conservation of Nature (IUCN), however, one species of bats present, Miniopterus schreibersi (Schreiber's Bat), is listed on the IUCN's Red List as endangered in Croatia. It is also

Email It is noted that the project has indeed received “special attention”, as demonstrated by the preparation of the Biodiversity Management Plan to meet the goals and objectives of the Habitat Directive. We note the Plan identifies significant mitigation and compensatory measures that are intended to overcome adverse impacts.

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recognized that several species that use the cave systems are geographically restricted and endemic. For critical habitat, Performance Requirement 6 stipulates the conditions from PR 6, para 14. According to these criteria of the EBRD Environmental and Social Policy, it can be clearly concluded that the construction of HPP Ombla does not meet the EBRD's financing criteria. To begin with, a critical habitat, the Vilina Cave - Ombla Spring cave system would be drastically changed, mostly submerged, and cemented, and injected with compounds that may increase water pollution. There are high risks that apart from this habitat, a number of species, including endemic and endangered species that are on protection lists at European level may be destroyed.

61 We know that this is a seismologically sensitive area? Is it possible that earthquakes could provoke outbursts of water and flooding of the area? Ombla was not constructed before, because Dubrovnik and its surroundings are located in a zone prone to earthquakes (book: The Adria Microplate, gps Geodesy, Tektonics and Hazards). Ph.D. Ognjen Bonacci (expert opinion, 19th January 1999), stated that the HPP Ombla EIA cannot be accepted, as the formation of a permanent underground reservoir will aggravate seismic activity in an area that is prone to earthquakes. The EIA does not consider the impact of the groundwater reservoir on the tectonics of an area very prone to earthquakes. Trembling of the ground induced by raising the level of the river Ombla exist even now, however with construction of HPP Ombla, the trembling will increase in frequency and intensity. This has been proven in thousands of examples throughout the world (HPP Three Georges in China, HPP Mratinje, HPP Glava Zete near Danilovgrad, extraction of water for a golf course in Lorca which cause catastrophic earthquakes).

Meeting for NGOs in Dubrovnik, Meeting with BiH authorities

Emails (4 related)

It is not expected that seismic events would have major effects on water flows. Earthquakes could cause cracks in the grout curtain and this could allow some additional small flows of water, but they would simply emerge from the mountain as new springs or via Ombla Spring. There would be no large or sudden outflows.

The amount of water to be held inside the mountain should not be sufficient to cause any micro-seismic events.

62 Has safety of people been taken into account, not only environmental impacts? Residents of Rijeka Dubrova ka are concerned about living below a structure in the shape of an upside pyramid, worried everyday whether or not a rock will fall on their heads. The blasting, digging and concreting will be happening above our heads. Installing an underground power plant on the river Ombla near Dubrovnik, Croatia, will be a poor solution as people who live in this area will be put in danger. Is there a plan for managing, mitigating and preventing possible accidents, floods, catastrophes for the residents of Rijeka Dubrova ka, especially for those that live in the vicinity of the Project, on the river?

Meeting for NGOs in Dubrovnik, Meeting with BiH authorities

Emails (3 related)

There can be no floods or other related catastrophes during or after construction. Prior to construction, HEP and its contractors will develop traffic management plans, emergency response plans, and other programs to reduce the impact of expected and unexpected events and to minimise disruption of local residents.

63 Will EBRD approve the loan or not and will the opinion of the Ministry of Environmental and Nature Protection of Croatia – Minister Mihael Zmajlovi regarding the planned Project in a Natura 2000 area, be taken into consideration? We hope that, in deciding on the loan, the EBRD will take into account the concern of the residents, environmental organisations, general public and experts who are warning that the Project is harmful and dangerous.


Emails (3 related)

See response to comment 39. The EBRD will be guided by its 2008 Environmental and Social Policy.

64 Has a feasibility study been completed for the Project and if so, why has not it been published? Have EBRD experts carried out a feasibility study? Is it true that this study showed that the project is not economically justified and experimental? Is this still what the Bank thinks?


Emails (2 related)

It is noted that the technical aspects of the project were evaluated in 2011 by an international consultant. The evaluation showed the project could indeed be economically justified.



65 The conclusion of the study that was prepared for the EBRD by Tractabel Consultants and Projektni Bureau Split it is noted that "the project fails to recover any investment or running costs and could result in significant expense in a commercial sense," and that the project "could be made only if received substantial subsidies from the state." The study also notes that the problem could be solved by increasing electricity prices by as much as 200%! This was a study which leaked to the public and HEP and the EBRD claim that it was a draft, and that the final version is different. The final study was not presented to either the public nor to experts, which raises the question of whether HEP plans to make this investment profitable by selling electricity or – as has been rumoured – by selling water.


66 The Environmental Impact Assessment study for Ombla HPP was done and approved in 1999. The Environmental Protection Act of 2007 stated that approvals of EIA are valid for only two years. While it is true that the Act is not applied retroactively, for eight years (1999-2007), HEP had more than enough time to build a hydroelectric plant. Since this was not done, it is inappropriate to use an outdated EIA now.

Emails (2 related) The 2007 Act specifically did not apply to projects that had been approved before the Act was passed. As a result, the Ministry has not intervened and required a new EIA or new permitting process.

We note that the Biodiversity Management Plan, while not required by the Ministry of Environment or any Croatian law, was prepared to meet the goals and objectives of the Habitats Directive.

67 There are risks involved in using outdated, incomplete EIAs as a basis for the approval of the financing of costly infrastructure projects. There is high uncertainty in terms of environmental, social and economic risks linked to building an underground hydropower facility in an ecologically highly valuable as well as seismically active area

Emails (2 related) As noted in many responses above, the Biodiversity Management Plan assesses biodiversity risks. The response to comment 61 addresses seismic risks, while the response to comment 62 touches on social risks.

68 Is the EIA from 1999 adequate and is it scientifically valid? Has a new EIA or a Strategic Environmental Impact Assessment been carried out?


The EIA from 1999 remains legally valid, and no new EIA or SEA is required.

69 The best solution for the case of HPP project would have been to create an integrated and comprehensive Environmental Impact Assessment and to integrate the impact assessment on the ecological network. The impact assessment on the ecological network would then have been part of a standard administrative procedure, while at the moment it is outside of the legal framework.

Emails (2 related) See response to comment 68.

70 Ph.D. Ognjen Bonacci (expert opinion, 19th January 1999), stated that the HPP Ombla EIA cannot be accepted, as Ombla HPP is not a multipurpose hydro-power system

Emails (2 related) Thank you for your comment.

71 Ph.D. Ognjen Bonacci (expert opinion, 19th January 1999), stated that the HPP Ombla EIA cannot be accepted, as the construction of dam curtains within the cave and raising the water elevation for 130 m is questionable, and if this were to succeed, the water would spill over in the catchment Zaton and other sources.


72 Ph.D. Ognjen Bonacci (expert opinion, 19th January 1999), stated that the HPP Ombla EIA cannot be accepted, as the catchment area of Ombla is not 600 km2, it is more likely that the size is 800-900 km2.


As noted in the Biodiversity Management Plan, the Ombla catchment area is thought to be approximately 600 and 900 km2.

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73 Ph.D. Ognjen Bonacci (expert opinion, 19th January 1999), stated that the HPP Ombla EIA cannot be accepted, as the borders of the Ombla watershed in the direction of the Zaton spring are incorrectly identified in Study


74 Ph.D. Ognjen Bonacci (expert opinion, 19th January 1999), stated that the HPP Ombla EIA cannot be accepted, as the low waters of Ombla are not specified correctly and may fall below 4m3/s

Emails (2 related) This is not an issue for the biodiversity Management Plan, but rather for the economic and technical evaluation of the project.

75 Ph.D. Ognjen Bonacci (expert opinion, 19th January 1999), stated that the HPP Ombla EIA cannot be accepted, as a it is unclear whether it will be possible to effectively protect the quality of water used to as drinking water supply of Dubrovnik, during construction, especially during the injection of the grout curtains. The EIA does not include an assessment of purifying drinking water for the city of Dubrovnik (the cost of construction, type of treatment because of the specific risks of pollution). The EIA does not adequately assess the contamination of spring waters of Ombla river during construction and due to planned increased water level in the cave.

Emails (3 related) This issue is beyond the scope of the Biodiversity Management Plan.

76 Ph.D. Ognjen Bonacci (expert opinion, 19th January 1999), stated that the HPP Ombla EIA cannot be accepted, as it does not consider the impact on the local community

Emails (2 related) This issue is beyond the scope of the Biodiversity Management Plan.

77 Ph.D. Ognjen Bonacci (expert opinion, 19th January 1999), stated that the HPP Ombla EIA cannot be accepted as it does not take into account trans-boundary impact although the system Vilina Cave – Ombla Spring, as well as the River Ombla, are part of the Trebišnjica catchment area. Has all legislation regarding Trans Boundary impacts of the Project been consulted and followed? Have all relevant ministries and other bodies been involved in the process and informed?

Meeting with BiH authorities

Emails (2 related)

The Biodiversity Management Plan discusses potential effects in BiH. As noted in the Introduction to this comment-response document, HEP held a meeting with authorities in BiH to discuss the Plan.

78 Ph.D. Ognjen Bonacci (expert opinion, 19th January 1999), stated that the HPP Ombla EIA cannot be accepted as it does not examine the impact of increasing use (extraction) of water from 500 l/s to 1500 l/s for downstream ecosystem of river Ombla

Email (2 related) This issue is beyond the scope of the Biodiversity Management Plan.

79 Ph.D. Ognjen Bonacci (expert opinion, 19th January 1999), stated that the HPP Ombla EIA cannot be accepted as it does not assess the impact of the construction of access roads and terraces on the protected landscape of the river Ombla. What will the hill behind Ombla look like after all the access roads and facilities are constructed? The natural beauty will be destroyed.


Emails (3 related)

The proposed Natura 2000 area will not be affected by new access roads, so this is beyond the scope of the Biodiversity Management Plan.

80 Dr. Bonacci, in a letter to the Croatian Prime-Minister dated 8th December 1999 wrote the following: "The Croatian Government appointed me on 10th December 1998 as a member of EIA evaluation commission to assess the impact on the environment of the Ombla HPP. On 8th December 1999 I received a conclusion from the third session of the evaluation commission stating that I refused further work on the Evaluation commission. I must inform you that this statement is not correct. Apparently, it is a fact that the president of the Commission excluded me from the work, because I refused to accept the EIA study. As this is a high-




risk construction project both from the economical and ecological point of view, my negative attitude is quite clear and has been submitted to the Commission in writing.

81 Despite the fact that those responsible for the project in HEP and the European Bank for Reconstruction and Development were aware of the comments provided by Ph.D. Ognjen Bonacci (expert opinion, 19th January 1999), they decided not to re-do whole EIA, but just to assess the impacts on the ecological network.


82 Which permits have been obtained for the Project to date? Please list the exact number of final (not preliminary) construction permits and what they refer to exactly out of the total seven permits.

Meeting for NGOs in Dubrovnik repeated at the Public meeting

Email

For HPP Ombla project, the following licences / permits have been obtained:

Rješenje o prihvatljivosti zahvata za okoliš (30. studenog 1999. g.)

Mišljenje Ministarstva kulture o mjerama zaštite na faunu šišmiša (6. ožujka 2009. godine)

Lokacijska dozvola (2. svibnja 2006. godine)

Vodopravni uvjeti za izradu glavnog projekta za izgradnju HE Ombla (28. svibnja 2008.)

Na elna dozvola (2. srpnja 2010. g.) – with previous approval from Uprava za zaštitu prirode and Uprava za procjenu okoliša i industrijsko one iš enje

Gra evinska dozvola hidroelektrane Ombla, pristup elektrani (11. svibanj 2011. g.)

Gra evinska dozvola za hidroelektranu Omblu, ceste (23. svibanj 2011. g.)

Energetsko odobrenje za izgradnju (17. sije anj 2012. g.)

83 Whose property is Ombla? Meeting for NGOs in Dubrovnik


84 How many m3 of harmful materials will be injected to create the grout curtain? What is the price of one m3 of the grout mass with installation? What will be the ingredients of the grout?


Email (2 related)


85 Prof. Bonacci claims that the materials which will be injected to create the grout curtain will be toxic, neuro toxic, cancerous, irritating or corrosive. Using it is harmful for the environment and humans and it will harm fauna and endemic species. After construction, the pressure on internal walls will increase. Please give an expert opinion on these claims.


Email (2 related)

This issue is beyond the scope of the Biodiversity Management Plan.

86 Croatia has unlimited possibilities of using wind, sun and gas for energy. Why doesn’t HEP construct wind power plants instead of hydropower plants? HEP could work with Kon ar, shipyards and others to construct and install wind power plants and in that way encourage domestic production. On one hand, HEP is investing in an expensive and economically unfeasible project, while on the other hand companies are constructing wind power plants and selling as well as getting subventions,


Emails (3 related)

This Issue is beyond the scope of the Biodiversity Management Plan.

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from HEP, for a produced kWh of electricity. For the first time, HEP did not answer that constructing wind farms is unprofitable, and for the first time gave an honest answer that this is HEP’s policy, not to be monopolistic.

87 Have all affected landowners been contacted? Public meeting in Dubrovnik

This issue is beyond the scope of the Biodiversity Management Plan.

88 Has an analyses of the (sludge) been carried out? Where will it be deposited? Who will maintain the river bed having in mind that the last time this was done was 60 years ago?



89 Why are members of the Croatian government not present at this meeting (asked in the public meeting in Dubrovnik)? Why were representatives of the following institutions not present at the meeting: Ministry of Environmental and Nature Protection of Croatia, the State Institute for Nature Protection of Croatia and the Croatian Biospeleological Society?


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It is not known why individual agencies and organisations chose to come or not to come to the various meetings.

90 HEP to comment the article from ‘Globus’ in which it is stated that HEP did not accept WSP/B&Vs initial Study and made them change their findings regarding flooding? Was this the reason why the Study which was finalized in November was not disclosed to the public?


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No study was finalised in November. Rather, the work was behind schedule and only a partly complete Executive Summary and an incomplete 3D Model were available for review. The Biodiversity Management Plan and 3D Model were disclosed for public review when they were complete and considered to meet the goals and objectives of the Habitats Directive.

91 The hydropower plant turbines are radioactive and will contaminate the water which will be provided to citizens of Dubrovnik. The substation that will be constructed will also have an impact on the health of the population living nearby. Please comment.



92 Exactly how many wind and solar power plants which are operational does HEP have in Croatia?


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93 The Study concludes that the Project will not cause any negative environmental impacts in BiH. Would it be possible to get a more detailed response on the assessments which were carried out? Please provide the necessary documentation regarding the project HPP Ombla to relevant authorities and the general public on the territory of Republika Srpska. The provided information must include a description of the project with a particular focus on the position of the accumulation and the possibility of impacts on the environment in Republika Srpska, to determine whether further actions in accordance with the provisions of the Espoo Convention are needed.

Meeting with BiH authorities

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The scope of the Biodiversity Management Plan did not include assessment of environmental impacts in Bosnia-Herzegovina as it was an assessment of impacts under the EU Habitats Directive of the proposed Paleoombla-Ombla Site of Community Interest (SCI) which is located entirely in Croatia. Also, the EU Habitats Directive does not currently extend to Bosnia-Herzegovina as it is not an EU member state or an EU accession state.

The Biodiversity Management Plan does include a discussion on the impacts of water levels in Bosnia-Herzegovina in Section 1 - specifically Section 1.3.6 and Figure 1.6. To aid the reader, Figure 1.6 shows an indicative cross section from Ombla Spring to a point near the village of Hum in Bosnia-Herzegovina which is close to the entity border between Republika Srpska and the Federation of Bosnia and Herzegovina.

94 Is there approval from BiH for the Project? Public meeting in Dubrovnik


95 Is it true that EBRD’s banker lobbied with the Government for the Project on behalf of HEP?


No



96 Who is financing the substation and tunnel in Sr and how much will that cost? The Croatian Helsinki committee states that Ombla is being built in connection to the need of providing water for the golf course in Sr .

Public meeting

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97 Who was found responsible when the substation in Dubrovnik burned down (right after the warranty expired) and parts were removed (stolen) from the old one?

Public meeting

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98 The Project does not take into account the complexity of constructing in unexplored karst. The creation of the grout curtain from the surface to the underground impermeable barrier is not precisely defined and creates a lot of uncertainties. Previous negative examples include: the damn Sklope (Lika), in Buško Blato (Kr spring). A committee to determine irregularities in building the dam and accumulation in Dobra is being formed right now. The examples compared to HPP Ombla, from the Mediterranean to China, are located in rocks with different morphological characteristics.

Email This Issue is beyond the scope of the Biodiversity Management Plan.

99 Examples in practice have demonstrated that the grout curtains are not permanent, because as opposed to long-lasting concrete dams, over time they wear off and disappear.


100 HPP Ombla will produce only 1% of the electricity consumption in Croatia. The construction of Ombla HPP anticipates producing only 1.5% of energy, and thus will not significantly change the balance of energy production in Croatia. It represents yet an additional hydroelectric plant (Croatia has 34.9% of electricity production from hydropower plants, which are very sensitive to seasonal and climatic changes, and the construction of new hydropower plants will not change this trend).

Emails (2 related) This Issue is beyond the scope of the Biodiversity Management Plan.

101 Why doesn’t HEP invest in reducing the amount of energy loss. In Croatia, the loss is 16.18% while the average in the EU is 6.7% (4% in western Europe), while in the world it is at 9.8%. If this was addressed, there would be no need to construct HPP Ombla.


102 HEP is not the investor, tax payers are as they will have to finance all costs, including the repayment of the unfavourable loan for the production of even more expensive electricity.


103 To date, three independent studies have concluded that the project is more dangerous than useful.


104 If two or three aggregates were added to HPP Dubrovnik (its capacity increased), and used intelligently, everyone would have greater benefits with less risk.


105 70% of questions were not answered at the public debate; HEP abruptly stopped the public meeting

Email The questions relating to the BMP study were answered in the public meetings in the time available. Those that were not answered due to time availability including those unrelated to the study were recorded and have been included in this comment-response document. Where questions are beyond the scope of the Biodiversity Management Plan, these are for HEP to response separately as appropriate.

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106 HE Ombla is a cover for the development of coastal water bottling plant (suitable for filling water bags and specialized tankers) at the farthest southern point of Croatia, with adequate purity and capacity.


107 Are HPPs renewable sources of energy, because changes in the environment are neither renewable, repairable nor reversible?


108 How is it possible that Elektroprojekt d.d. is the author of the HPP Ombla EIA from 1999, and now the same company is assessing the acceptability of HPP Ombla’s impacts on the environment?

Email The Biodiversity Management Plan was prepared by WSP Environment & Energy, supported by Black & Veatch and local contractors. Elektroprojekt d.d. was responsible for some of the biological surveys conducted in 2012 but were not involved in the preparation of any part of the Biodiversity Management Plan.

109 Have you received confirmation of the acceptability of the Project with regards to environmental impacts or are you to request this confirmation from the Ministry of Environmental and Nature Protection of Croatia? Have you requested and/or received a main assessment of the Project’s impacts on the ecological network?


110 Article 10 of the Rules for Assessing the Acceptability of Plans, Programmes and Projects for the Ecological Network requires - Provision of information to and participation of the public and interested stakeholders on the process of the Main Assessment of the Plan or Programme is carried out as part of a public debate on the Strategic Study and the draft Proposed Plan or Programme. When will the provision of information and participation of the public and interested stakeholders take place as per Article 10? (on 25.03. contracted companies WSP and B&V had their public presentations)

Email The BMP study that has been conducted independently and is not subject to the provisions of the legislation cited. Nonetheless, the BMP study has included public participation as detailed in the BMP and this comment-response document.

111 Have archaeological assessments been done in Vilina Cave to determine whether archaeological artefacts or other objects of cultural value are present there? This is EBRD’s PR 8. If yes, please make these public.


112 Has the study on the slope stability been made public? Email This Issue is beyond the scope of the Biodiversity Management Plan.

113 What will happen with the chapel “Marijina navještenja na Izvoru” at the Ombla spring, constructed by the Dubrovnik engineer Paskoje Mili evi in 1480.


114 In line with rights to access to information, the general public needs to be acquainted with all opinions of the 4 independent experts who were contracted by the former Minister for Environmental and Nature Protection, of which 3 are negative in relation to the Project (one of the negative opinions concerned biodiversity). In following the Aarhus Convention, the opinions should be made publically available by the Government of Croatia, the Ministry and HEP.


115 Another shortcoming of the carried out research is that it focused on the large conduits and ignored the situation in cracks and epikarst, which form 999 parts per thousand underground cavities.

Emails (2 related) As the BMP was an assessment under the Habitats Directive, it focussed on the features relevant to that assessment i.e. the two habitat and five species features.

The assessment of flooding utilised previous modelling work undertaken for HEP, observation from boreholes in Croatia and Bosnia-Herzegovnia and published literature such as papers by Bonnacci and others. All these



sources take into account the various aspects of the karst.

116 Research is based on a compilation topographic plan of the cave system and not on a topographic draft of a standard accuracy.

Emails (2 related) The 3D models are based on the topographic plans that were made available. It is extremely unlikely that a more accurate topographic survey would change the conclusions of the BMP or those on flooding.

117 Is it true that HEP requested from the Croatian Biospeleogical Society that the members of the society do not speak publically and provide opinions on the results of the Ombla assessments, after they complete their study? If this is true, HEP crossed the line and tried to prevent the dissemination of scientific data and the Society accepted something that is morally unacceptable.

Emails (2 related) This question is beyond the scope of the Biodiversity Management Plan.

118 It is necessary to explore whether it would be justified to set a new level of protection for Paleo Ombla, in the transboundary area, at the national and international level.


119 The authorities should investigate the falsification of data used as a basis for approving the Ombla project and identify any gaps in the performance of public enterprises, state commissions, and the departments that have enabled this to happen.


120 The consultation procedures which HEP and the EBRD implemented during the period from 11.03.2013 to 10.04.2013 were not launched by the competent authorities responsible for the implementation of legislation relating to the national ecological network and NATURA 2000 (that is the Ministry of Environment and Nature Protection). Therefore it is quite unclear how the comments and complaints of citizens and experts will have an impact on the final decision and appeal process.

Emails (2 related) It is correct that Croatian authorities did not launch the disclosure and public consultation process for the Biodiversity Management Plan. This is because they have determined there is no legal basis for further consultations. Comments and complaints on the Biodiversity Management Plan will be taken into consideration as described in these responses.

121 The State Institute for Nature Protection, Croatia's expert body for nature protection addressed the Ministry of Environmental Protection and Spatial Planning on 7 November 2008 with the following opinion: there are new circumstances that require re-consideration and re-evaluation of the Ombla HPP project. Since NIA was not done as part of the EIA back in 1999, it is necessary to implement it now as a separate procedure.

Emails (2 related) This Issue is beyond the scope of the Biodiversity Management Plan. We note that the Plan was prepared in accordance with the requirements of the Habitats Directive.

122 The State Institute for Nature Protection further stated in 2008 that in the NIA process it is necessary to assess the possibility of alternative solutions to the intervention and conduct a determination of overriding public interest, or to determine whether, in this case, priority is given to public interest of the protection of nature or the public interest of producing electricity. This decision is based on the Nature Protection Law and it should be decided by the Croatian Government after public consultation. If the project is approved by the Government, although it is not acceptable to nature, it is necessary to develop compensation measures in accordance with the Law on Nature Protection and Regulation of NIA.

Emails (2 related) This Issue is beyond the scope of the Biodiversity Management Plan. We note that the Plan identifies a number of important mitigation and compensation measures.

123 We are asking that in line with the Aarhus convention, the EBRD required Environmental and Social Action Plan (PR 1 to PR10) is made publically available.

Email The Environmental and Social Action Plan that is part of the financing agreement between HEP and EBRD is available on www.ebrd.com and also on www.hep.hr

124 Is it possible to get a copy of the video taken during the NGO meeting held Email This Issue is beyond the scope of the Biodiversity Management Plan.

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in Dubrovnik on 25.03.2013?

125 The potential impact of allergic alohtong grass and other plants that are intended to be planted on the plateau of the hill Sr has not been assessed.


126 The study says the following: Since the only possible realistic alternative solutions for HPP Ombla is not to do anything, there is no need to analyze the impact of the project alternatives on conservation objectives and integrity of the ecological network. The described solution, i.e. the zero option, is always considered in good quality environmental impact studies and studies considering a project's impact on the ecological network. Furthermore, other alternative solutions do exist, but they are not considered by HEP. For example, the impact of building only a water purification facility – a necessary investment for the city of Dubrovnik – should be considered, as a water management measure. A nearby wind farm and/or solar energy and/or energy efficiency measures to reduce energy consumption could be considered as energy measures. Moreover, with regard to peaks in the use of electricity, HEP considers hydropower more acceptable for electricity generation than renewable energy sources in the strict sense of the term (not including hydropower with reservoirs), however it does not consider the seasonal nature of electricity consumption in Dalmatia, in which there is increasing consumption in the summer months when, due to greater and more frequent droughts, hydroelectric is least productive.

Email It is noted that the zero option, and all the other alternatives suggested in the comment, would have the same “zero” impact on the proposed Natura 2000 area. The Biodiversity Management Plan was concerned only with this area, so impacts of these other alternatives are beyond the scope of the study and the Plan.

127 In these studies, as in the old Environmental Impact Study for the construction of HPP Ombla, the impact of increases of pumped water from the Ombla Spring on the downstream ecosystem is not considered, nor are the changes in rainfall and water due to climate change over the next few decades.


128 The impact assessment has not considered the management and impact of sediment. Specifically in surface reservoirs for hydropower is known that river sediments fill reservoirs, which therefore have a limited lifespan, and it is possible that cleaning is needed. In the studies this issue is not addressed at all.


129 None of the documents presented by EBRD and HEP are a part of the procedures stipulated under the Act on the Protection of Nature or the Environmental Protection Act.

Email Croatian authorities have not required HEP to undertake further studies or procedures, or to prepare any additional documents. The Biodiversity Management Plan was one of the requirements in the Environmental and Social Action Plan that is part of the financing agreement between HEP and EBRD.

130 The unofficial translation into Croatian of the Biodiversity Management Plan for the area of HE Ombla and Assessment of the Impact of the Construction on the Ecological Network is not of sufficient quality and renders some explanations incomprehensible, thus limiting the possibility of participation and understanding among the population who do not use the English original.

Email We regret any difficulties that interested parties may have had in reading the Croatian translation. The translated document was prepared by a professional Croatian translation company, Prevoditeljski centar d.o.o., and this is the official version that is on the HEP website. The company is licensed by the Commercial Court in Zagreb for translation services.

131 Public participation in decision making about the project was neglected, questions were never answered satisfactorily orally or in writing, and

email We regret the commenter feels this way. HEP held extensive public consultations in 2011 and now on the Biodiversity Management Plans, and



professional opinions were ignored. has prepared responses to every comment that has been made on the various documents.

132 The construction costs of Ombla HPP are estimated at 152 million euros, and drawing parallels with the comparison of the real cost with the estimated cost of building Leš e HPP we conclude that the real costs would be at least 211 million euros, not even taking into account the greater complexity of construction within a cave system and the potential opening of new caverns during construction, and accordingly incurring additional costs in cementing them. Remediation of damages or assessment of any damage repair costs that may arise are not included in these figures. It also seems that 10 million euros for the construction of a water treatment plant for the city of Dubrovnik is not included even though HEP is promoting it as part of the Ombla project.

email This Issue is beyond the scope of the Biodiversity Management Plan.

133 HPP Ombla will significantly change the groundwater regime. When surface water is managed in karst areas, a variety of unforeseen and surprising situations occur, and it is impossible to predict the consequences of sudden changes in groundwater flow. Even subsidence of soil in karst areas in the upstream catchment Ombla may be expected. In addition, Dubrovnik is an unstable area, and in case of an earthquake of the magnitude of the one that happened in relatively nearby Ston in 1996, this reservoir is a potential time bomb. Although HEP hired an expert committee to review the sensitivity of the dam to earthquakes, which have confirmed that there is no danger, however, there is suspicion towards Ombla HPP among local people in this regard. Therefore, the cost of construction must also include the cost of insurance with an insurance company for the plant for all households and people potentially affected (in the area of the River Dubrovnik) in the case of earthquakes or other disasters at the Ombla HPP.

Email The commenter correctly notes that HEP commissioned an expert committee that concluded there was no significant danger. Thus, there is no need for further insurance.

134 HEP uses Grancarevo in BiH as an example of an underground hydroelectric plant, but in reality the situation is quite different for these two dams. Gran arevo is an above-ground dam that forms Bile ko lake and below the dam are the grout curtains to prevent the flow of underground water below the dam, while Ombla HPP is exclusively an underground dam, which makes Ombla more complex to create, manage and maintain.


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