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Bosnia and Herzegovina: Center for the Environment challenges environmental permit for TPP Ugljevik 3

The Center for the Environment, a non-governmental organization, has once again contested the environmental permit granted to Comsar Energy RS for the construction of the coal-fired thermal power plant Ugljevik 3. The Center argues that the relevant Ministry has repeatedly suspended the permit issuance process, which it claims is legally prohibited. Despite these concerns, a new environmental permit was issued to the investor.

Following a lawsuit by the Center, the court annulled the permit in July 2024, directing the Ministry to await a decision from the RS Supreme Court. However, the Ministry halted the process again, delaying a final legal resolution. In response, the Center has filed a new lawsuit, seeking the cancellation of the permit and the suspension of further decisions until the Supreme Court makes its ruling.

The RS Government initially approved the construction of the second unit at TPP Ugljevik in March 2011, based on a letter of intent submitted by Comsar Energy Limited. The investor was chosen through an unsolicited bid without a public invitation. The planned TPP Ugljevik 3 will consist of two 300 MW units, with an estimated total project cost of 750 million euros. A joint venture agreement for the construction of the plant was signed between the RS Government and Comsar Energy in July 2011. Under the agreement, Comsar Energy is responsible for 90% of the funding, while the coal mine and TPP (RiTE) Ugljevik are expected to invest the remaining 10%. The RS Government will retain a 10% stake in the joint venture by contributing land and existing infrastructure at the site, while Comsar Energy will hold a 90% stake. The plant’s output is intended for export to foreign markets, ensuring it will not compete with the local power utility ERS. However, construction has yet to begin.

In 2018, Comsar Energy requested an extension of its concession from the RS Government for an additional 15 years, citing the unprofitability of the current 30-year concession due to lower electricity prices. As part of the request, the company proposed reducing the planned output from 600 MW to 350 MW. In early 2020, however, Comsar Energy reversed course, requesting an increase in the plant’s installed capacity to 700 MW. In early 2021, the RS Government once again granted Comsar Energy’s request, extending the deadline for the construction and operation of the coal-fired power plant to 44 years.

In June 2021, Chinese companies China Electric and Sunningwell International announced their agreement to construct TPP Ugljevik 3, marking their first European project. However, it remains unclear whether these companies will partner with Comsar Energy, the holder of the concession, or if they will take over the project entirely. Comsar Energy has stated that it is currently negotiating with strategic partners regarding the project, without offering further details.

In September 2022, Milorad Dodik, a member of the BiH Presidency from Serbia, stated that the RS Government would take over the two projects previously granted concessions to Russian company Comsar Energy, including the TPP Ugljevik 3 and the Mrsovo hydropower plant.

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