The City of Doboj has issued operating permits for 104 small solar power plants developed by Etmax at Crkveno Brdo near Podnovlje, despite an unresolved dispute over ownership of the project land. The approvals allow the facilities to move toward commercial operation while leaving legal liability for authorities and the wider support scheme.
The permits were granted on 29 June 2026 after months of opposition from residents and environmental groups. The dispute covers both the installations’ proximity to residential properties and the legality of a land transfer from the Podnovlje Agricultural Cooperative to the City of Doboj before its subsequent sale to Etmax.
Supreme Court ruling challenges land transaction underpinning approvals
In April, the Supreme Court of Republika Srpska overturned an earlier decision by the Doboj District Court and questioned the legality of the original land transaction. The ownership issue remains subject to further proceedings, but local authorities proceeded with operating approvals before the dispute was resolved.
Each installation is understood to have capacity of up to 150 kW, implying a combined portfolio maximum of about 15.6 MW. The fragmentation into multiple small plants may allow each unit to qualify under an applicable feed-in tariff framework, supporting predictable revenues over a 15-year support period.
Feed-in tariff revenue estimates and potential compensation exposure
Estimated annual revenue is about €20,000 per facility, which would total roughly €2.08 million per year across the portfolio. Over 15 years, the nominal revenue envelope would exceed €31 million, aligning with estimates that compensation claims could surpass €32 million.
Claims tied to a longer 25–30-year technical operating life could be higher, depending on recognised damages, operating costs, financing assumptions and any duty for the developer to mitigate losses. Indicative development and construction expenditure for a fragmented 15.6 MW portfolio is estimated at €11 million–€17 million, depending on equipment specification, grid works, terrain and transaction costs.
Lenders, insurers and permitting scrutiny amid unresolved title issues
The potential legal exposure may be larger than unrecovered construction costs because it could include lost subsidised revenue rather than only investment already spent. The risk allocation is described as difficult: Etmax may argue reliance on public authority decisions during land acquisition, approvals and construction.
Authorities could face questions about whether permits should have been issued while ownership proceedings remained unresolved. Lenders and insurers are expected to focus on whether title risk was disclosed, whether legal opinions included qualifications, and whether compensation mechanisms would remain effective if the underlying transaction is found unlawful.
Operating permits versus land-rights due diligence in bankability assessments
The case also highlights that operating permits cannot replace a complete land-rights audit for renewable projects. Even where technical requirements are met, projects may still be unbankable if cadastral records, ownership transfers, easements or access rights are contested.
The issue in Republika Srpska is framed around credibility of its renewable permitting framework, with a compensation claim above €32 million potentially creating a material cost for public institutions. It could also lead to closer scrutiny of other developments structured through multiple small generating units and influence how banks evaluate projects relying on municipal land transactions and long-term regulated support.
The plants now have operating approvals, but unresolved title disputes leave economic ownership of project value uncertain. The central risk described in the case shifts from construction and commissioning toward litigation, compensation claims and enforceability of the revenue framework.
