Mistake to avoid: assessing environmental impacts of parts of a larger (wastewater) project but not of the whole project

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Narrative

It is common practice to split large infrastructure projects into several sections, phases or parts. As a consequence environmental impacts are often not assessd systematically for the overall project but only for its elements one by one, or they are not even assessed at all. In Slovenia a controversial example for such a practice is the waste water canal "C0" in Ljubljana, which was split into several segments, for which the Municipality of Ljubljana, who is the investor of "C0", got building permits without the need to conduct an EIA. The project "C0" is controversial because it leads through a water protection area. However, due to the lack of EIA it is unclear what its overall impacts will be and whether there are less impacting alternatives. After immense political pressure the Slovenian environmental protection agency ARSO decided to finally require an EIA, even though large parts of "C0" have already been built. The Municipality of Ljubljana took legal measures against this decision, but at the time of writing (June 2023) the Slovenian adminstrative court had not made a decision, yet. Irrespective of the outcome of the court proceedings and the potential EIA, it is a mistake not to assess the overall environmental impact of a project before the project is implemented. Moreover, it is highly problematic if the responsible authorities of potentially harmful projects do not inform affected stakeholders actively about the decision not to conduct an EIA. In Slovenia it is common practice that such decisions are published only on online notice boards with short deadlines to react.

Financial data

The overall wastewater treatment project is worth ca. EUR 136 million (EUR 69 million from EU cohesion fund). Of this the canal "C0" is assessed at EUR 28 million (without VAT).

Recommendations

Ensure that for larger infrastructure projects (e.g. roads, waste and waste water, wind parks, transmission lines) EIAs are performed for the whole project, even if this is split into smaller elements. Moreover, ensure that stakeholders of projects, for which no EIA is foreseen, are informed well in advanced and given the chance to object decisions not to conduct EIAs.