As we already argued back in 2017 before the Administrative Court, and later before the High Administrative Court – which rejected our claims – the environmental impact assessment procedure for the Lećevica Waste Management Center (WMC) should have been initiated due to changes made to the project (link). Had the procedure been carried out then, it would have served its purpose, as it would have taken place before construction began and before any environmental interventions were made.
Today, the procedure is being conducted following an order from the European Commission, which warned the Regional Center for a Clean Environment that an environmental impact assessment is obligatory for the Lećevica Waste Management Center. This requires preparing a comprehensive environmental impact study that must examine all environmental consequences of the project, as well as propose appropriate environmental protection measures and monitoring programs.
The request to conduct the an environmental impact assessment procedure was submitted in May 2024, yet construction at the Lećevica site has been progressing simultaneously. The completed environmental impact study must undergo public consultation, which will run from 17 February to 18 March. During this period, all interested parties can submit comments and observations. A public hearing is scheduled for 5 March at 11:00 AM at the Multifunctional Center Fra Ante Konstantina Matasa, Trg Ante Bužančića Tice 4, Lećevica. Representatives of the project developer and the Study’s authors will be present to provide direct answers and discuss questions raised by those in attendance.
Meanwhile, construction at Lećevica continues at full speed – while the Study is still up for debate.
Ex-post environmental impact assessments: evaluating impacts after the project has already begun
Environmental impact assessment is meant to be carried out before a project begins! The very purpose of the procedure is preventive, to avoid environmental damage. The process ends with a decision on whether the proposed project is environmentally acceptable or not, and that decision can be challenged before an administrative court. It is unclear how effective judicial protection can even be in cases where the EIA procedure begins only after the project is already under way.
Unfortunately, this reversed and illogical practice is common in Croatia. A project is retroactively declared environmentally acceptable once it has already been built, even though it is then impossible to examine baseline environmental conditions and therefore impossible to accurately assess the project’s potential impacts.
Such practices undermine the basic provisions of the Aarhus Convention, EU directives, and the Environmental Protection Act, all of which are designed to prevent environmental harm. When procedures are carried out after the construction project is finished, the environmental damage has already occurred, and the precautionary principle becomes nothing more than an empty phrase.
WMC Lećevica is not the only example. We often receive reports from citizens about projects that were carried out without an EIA, even when one was clearly required by the Regulation on Environmental Impact Assessment. After inspection, investors are usually instructed to conduct an environmental procedure – even though the project has already been executed – especially in cases of illegal landfilling or coastal infill. Restoring the environment to its previous condition or compensating for the damage caused by unauthorized interventions happens in less than 1% of cases, despite being an entirely valid measure that inspectors are empowered to impose.
Government Action plan: acceleration over quality
Civil society organizations united in the Green Forum network have been warning for years about shortcomings in EIA procedures, including ex-post assessments and poor public information and participation. In October 2024, the government conducted a public consultation on its Action plan to improve the efficiency of these procedures, but the proposed measures focus mainly on speeding up processes, not improving their quality or transparency.
The Green Forum submitted comments highlighting the need for:
- A central portal where all projects requiring public participation are listed,
- Full digitalization of procedures so the public can directly comment on studies and receive official responses,
- Longer consultation periods, especially for complex projects such as the WMC Lećevica.
Naturally, the Green Forum strongly opposes ex-post EIA procedures.
WMC Lećevica: a project that fails to deliver a systemic solution
– Lećevica still does not represent a systemic solution and will not be able to meet the waste management needs of the entire county. What is needed is a sustainable waste management system at the local government level, with funding directed toward achieving self-sufficiency and greater independence in waste handling in towns and municipalities. In Croatia, we systematically neglect the key priorities of waste management: reducing waste generation, re-use, and establishing effective systems for separate collection, treatment, and recycling (LINK), – said Gabrijela Medunić-Orlić, Executive Director of Sunce.
Sunce invites all interested citizens and organizations to take part in the public consultation on the environmental impact study for the WMC Lećevica, open until 18 March. All relevant documents are available on official websites, and comments can be submitted electronically.
Ideally, this process should provide an opportunity to influence the future of waste management in our county and ensure sustainable solutions for all of us. However, in the case of Lećevica, it appears the only elements we can realistically comment on are the proposed environmental protection measures and the environmental monitoring plan because everything else seems already beyond our influence.
– Yet the Center will certainly affect us in the future: through increased waste-management costs, potential pollution from waste disposal and from handling the Center’s output product (refuse-derived fuel, RDF) as well as additional financial burdens resulting from poor waste management at both city and county levels, – Medunić-Orlić concludes.