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Reference: SG/E/2024/03
Received Date: 25 January 2024
Subject: Poklečani Wind Farm
Complainant: Individual
Allegations: Environmental and Social impacts of the project
Type: E - Environmental and social impacts of financed projects/operations
Monitoring: Yes
Outcome*: No grounds
Suggestions for improvement*: Yes
Confidentiality: No
Admissibility*
Assessment*
Investigation*
Dispute Resolution*
Consultation*
Closed*
8/02/2024
12/06/2024
29/04/2025
18/06/2025
20/06/2025

* Admissibility date reflects the date the case was officially registered. All other dates pertain to the date in which a stage was completed.

Case Description

On 25 January 2024, the EIB Group Complaints Mechanism (EIB-CM) received a complaint from an individual regarding the Poklečani Wind Farm project in Bosnia and Herzegovina. The project consists of the construction and operation of an onshore wind farm located in a mountainous area in the Municipality of Posušje in the West Herzegovina Canton.

The complaint concerns alleged breach of several EIB environmental and social standards.

Work performed

After registering the complaint, the EIB-CM prepared an Initial Assessment Report, including its Addendum/Corrigendum.

Considering that complaint SG/E/2024/03 and complaint SG/E/2024/25 (see here): (i) originate from the same complainant; (ii) concern the same project; and (iii) contain similar allegations, the EIB-CM decided to address the two cases as part of the same case handling process and issue one conclusions report for both cases.

During the case handling, the EIB-CM had numerous exchanges with the relevant stakeholders, including the Energy Community Treaty Secretariat, about the application of the EIA and the Nature Directives to the project, and the accountability mechanism of KfW, which had also registered similar complaints about the project.

Conclusion

The reviewed evidence shows that the project is in line with the project-applicable standards, with possibly one exception. The competent authority did not publish the August 2023 screen-out decision. This is a requirement under the Environmental Impact Assessment (EIA) Directive. In practice, this did not have an impact on access to justice as a local non-governmental organisation is currently exercising the right to challenge the screen-out decision before a court.

With regard to other aspects, the project is in line with the project-applicable standards. For example, as required, the assessment of the project’s impact on the environment has been finalised at the level of the Federation of BiH (FBiH). Either, in agreement between the EIB and the promoter, or as requested by the EIB in line with the EIB Standards, additional assessments are currently under finalisation, furthering the assessment conducted at the FBiH level. Related to this, as required, specific measures are in place to ensure that the project-applicable standards are not breached. These measures are set out in various documents, such as the August 2023 screen-out decision and the May 2025 Environmental and Social Action Plan (ESAP).

The reviewed evidence shows that the EIB carried out its responsibilities as required. Although the EIB did not provide a risk categorisation for the project, which is not in line with the requirements, the reviewed evidence does not show that this had a material influence on the EIB’s appraisal. The EIB either requested or agreed with the promoter about carrying out additional assessments of the project’s impact and commented on these assessments. The EIB reflected the outcomes of the assessments in the May 2025 ESAP. The ESAP is attached to the financed contract, with specific measures to be implemented by the promoter. The EIB-CM considers the development of an ESAP for the project and its attachment to the finance contract as a good practice and encourages the EIB to develop an ESAP for future projects, when deemed necessary and especially for higher-risk category projects.

Outcome

No grounds

One Suggestion for improvement - The EIB-CM suggests that the EIB services remind the promoter of the obligation to have the screen-out decision published under the EIA Directive.

Monitoring

The EIB services reminded the promoter of the obligation to have the screen-out decision published under the EIA Directive. The promoter is planning to publish the screen-out decision on its website.

Project Information