Based on the objections submitted by the Association of Young Researchers from Bor and the Renewables and Environmental Regulatory Institute (RERI), the Ministry of Environmental Protection rejected the request to decide on the need for environmental impact assessment of the project of Serbia Zijin Copper doo Bor and indicated to the investor that it is necessary to prepare a study on environmental impact assessment for the entire project, and not partially, for individual works within that project.
The Association of Young Researchers of Bor and RERI drew the attention of the public and the competent ministry to the fact that in this case we are dealing with the “salami slicing” scenario, that is, an artificial division of the project into smaller fractions in order to hide the overall impact on the environment.
Namely, Serbia Zijin Copper doo Bor addressed the Ministry of Environmental Protection on 10 December 2020 with a request to decide on the need to assess the environmental impact of the project which refers to the preparatory works involving excavation for construction, extension and reconstruction to increase the capacity of the copper smelter within the complex of the investor.
The investor pointed out in the request that “the project of preparatory earthworks does not require the preparation of an Environmental Impact Study”, failing to state that all works included in the request are preparatory works for construction of facilities and plants, such as desulphurization plant, sulfuric acid factory and sulfur storage- whose impact on the environment needs to be determined in the impact assessment process.
The Law on Planning and Construction clearly defines the meaning of the term construction of the facility, which includes: preliminary works, preparation and control of technical documentation, preparatory works for construction, construction of the facility and professional supervision during the construction of the facility. Therefore, the mentioned construction works are not a project for themselves, nor do they have any purpose on their own, apart from being preparatory works for the construction of other facilities.
The Association of Young Researchers from Bor and RERI pointed out that due to incomplete and inaccurate data and the separation of a single project, into several smaller ones, it is necessary to carry out the impact assessment procedure from the very beginning for the entire copper smelter capacity project, and not only for the current preparatory works.
The investor uses such activities to divide the single project into several separate units, avoiding the project as a whole to be evaluated, since it would undoubtedly draw the conclusion about potential negative environmental impacts and the need for preparation of an environmental impact assessment study.
The justification of these allegations was confirmed by the Ministry of Environmental Protection, which stated that the preparatory works are not an independent project, they are not fulfilling their purpose standing on their own- they are an integral part of the wider project and therefore it is it is necessary to do an impact assessment for the whole project of increasing the capacity of the copper smelter in Bor.
The Association of Young Researchers from Bor and RERI welcome this decision of the Ministry of Environmental Protection and remind that this is not the only and unique procedure in which investors are trying to avoid environmental impact assessment by splitting the project into several smaller ones, and emphasize that it is extremely important for the Ministry of Environmental Protection to continue with this practice and consistently implement regulations in the field of environmental protection.