REGIONAL STRATEGY FOR SUSTAINABLE HYDROPOWER IN THE WESTERN BALKANS Responses to Comments on the Final Report, Draft Principles for Sustainable Hydropower Development in the Western Balkans, and the Indicative List of Potential Projects for a Sustainable Development of Hydropower in the Western Balkans December 2017 to 31 August 2018 1. Introduction The purpose of this document is to provide an overview of the comments received until 31 August 2018 on the following documents: • Final Report • Draft Principles for Sustainable Hydropower Development in the Western Balkans • Indicative List of Potential Projects for a Sustainable Development of Hydropower in the Western Balkans (and the associated draft project summary sheets), as published on www.wbif.eu in December 2017 In the light of the comments received, the following points need to be recalled: A. Data After a scoping phase of the Study project, an intensive data collection campaign has followed as well as the establishment of operational contacts with relevant institutions and organisations. Data collection efforts continued until the first quarter of 2017, when the preparation of the background reports started at the same time with public consultations on the preliminary findings. As such, the Study outcomes/conclusions, are based on the data provided by key stakeholders up to the first quarter of 2017. Such outcomes/conclusions are thus dated, i.e. it reflects the information available at that point in time. Gaps in data availability/the reliability of data provided by relevant institutions/organisations was identified as a risk since the Scoping Phase, However, this did not prevent the Study from articulating the current status of the sector, the institutional, legal, and technical challenges; gaps in relevant data are duly reflected in the Study’s assessment of hydropower plants. B. Methodology The Multi-Criteria Analysis (MCA) tool has been discussed with stakeholders and agreed in October 2016. In addition, more details were provided in Podgorica, on 30-31 March 2017, and in Tirana, on 11-12 May 2017. The MCA was not the only tool used in the development of the indicative list of projects but was complemented by an expert assessment of factors which could not be quantified by the MCA (see details in the Final Report and Background Report 8). A preliminary screening excluded: a) projects already in construction; b) projects without a minimum dataset available c) projects below 10 MW capacity; d) less likely variants of a proposed project. Page | 1 Based on this screening, 136 were selected out of more than 480 projects. According to the MCA projects were then selected against four key indicators: Environmental (location of HPP candidate with respect to protected areas); Technical (contribution to generation adequacy); Technical Readiness (available technical documentation) Financial (specific investment per unit of electricity generated, €/GWh). For HPP candidates that scored more than 60 points at that stage a further detailed assessment was done against 30 indicators classified into five criteria groups (Technical adequacy, Financial viability, Social viability, Environmental acceptability and Realisation readiness). Candidates which scored 50 points and more, were designated as Group A, while the other candidates were designated as Group B. More details on the meaning of these criteria as well as on their weight (e.g. environmental and social criteria amounted for 40% of total score) may be found in the Reports mentioned above. Most importantly, the MCA was designed in light of (and not in spite of) the gaps in data availability and reliability and then proven to be a fact during the more detailed data collection phases. In addition, the MCA took into account relevant guidelines, assessment methods and best practices (e.g. Guiding Principles for Sustainable Hydropower Development in the Danube Basin, Hydropower Sustainability Assessment Protocol, etc.). C. Lists The list of potential rehabilitation and greenfield projects, as presented in the Final Report, does not constitute a green light to their construction but only to their further exploration of the technical, financial and environmental feasibilities of each individual project in light of the sustainability principles outlined in the Final Report. Such studies should be undertaken in parallel with the further designation of Natura 2000 sites and no-go zones by WB6 governments. D. Small hydropower Small hydropower plants have been excluded from the scope of the study for the following reasons: Their contribution to the global energy production and security of supply, or to the renewable energy sources targets, is extremely limited. In parallel, their impacts on the environment are severe, as they create multiple interruptions in water flows and fish passages, increase habitat deterioration and require individual road access and grid connections. Most of these small hydropower plants were commissioned after 2005, using state-support schemes (mainly feed-in tariffs) and these are expected to be gradually phased out after 2020 (with possible exclusion regarding small installations). It is therefore quite likely that the private sector’s interest in developing small hydropower plants will diminish accordingly. E. Next steps The Study conclusions on the inventories of hydropower plants are based on the data provided by key stakeholders up to the beginning of 2017. Such outcomes are still to be endorsed and will be subject to further discussion. Any further studies / assessments should be undertaken by the owners / developers of existing or future hydropower plants. Page | 2 2. Comments and Responses # Sender Contents Response 1 MINISTRY OF • Final Report: Comments gratefully acknowledged. MININGAND o Proposed changes with regard to the wording used for Kosovo as ENERGY, OFFICE well as on how the maps feature the border between SER & KOS; On the Final Report: FOR KOSOVO AND document sources used; • The references to Western Balkans 6 (WB6) beneficiaries are METOHIJA, PE o “Regarding hydrological data, the Study must specify for each in line with those established by the UN and in force within the EPS, MINISTRY OF participant, in particular, the availability of data in order to work EU, who is the Client for the Study. ENVIRONMENT OF on the improvement and in order to provide realistic ground for • The Final Report (as well as the background reports) reflect REPUBLIC OF future potential projects.” the data made available by relevant WB6 SERBIA • Indicative List: institutions/organisations. The purpose of the study was not o Lisina (28.6MW) to be called a pumped storage plant instead of to evaluate the availability of hydrological data in detail. HPP. However, Annex 1 to the Final Report identifies a series of o To add on the rehabilitation list: HPP Bistrica (102 MW) & HPP measures which should be considered for implementation by Zvornik (96 MW) beneficiaries, with support from international donors and . rehab works on HPP Djerdap 1 and in HPP Zvornik in national resources. progress (mechanical improvements). o To add on the greenfield list: HPP Potpec A4, HPP Djerdap 3, RHE On specific hydropower plants included in the draft list of projects: The Bistrica, Moravska and Ibarske HPP (no detailed reasons indicative list of projects reflects the results of the assessment provided). undertaken by the team on the basis of data provided by relevant • Draft Principles: “Established procedures should determine where to institutions/organisations up to the first quarter of 2017. More details operate, identifying no-go areas and tailoring activities in all other areas on the process (screening, MCA, expert assessment) and next steps can to local biodiversity and ecosystem services values” + “UNEP Convention be found in the general response to comments. on the Conservation of Migratory Species of Wild Animals (Bonn on 23 However, the following changes have been considered: June 1979) – Bonn Convention (Article 5 Paragraph 5h - elimination of, to • Lisina has been included in Vlasina HPP system. the maximum extent possible, or compensation for activities and obstacles which hinder or impede migration.” On the principles: Proposed revisions will be considered and included in the revised version of the Principles. 2 WWF ADRIA • Input information that went into this MCA matrix and scoring system Comments gratefully acknowledged. Please see general responses to remains consistently insufficient across all segments important to ensure comments. environmental protection and social acceptance of development, On the information available: • Stakeholder engagement throughout the entire process was insufficient to facilitate dialogue and lead to social acceptance of the results, including • As it may be noticed from the statistics available on the IRENA any potential development that may result from this exercise. and/or Energy Community webpages, the renewable energy mix in • It is commendable to see that the report promotes the need to undertake the region has gradually diversified, to include wind and solar. rehabilitation of existing hydropower plants. However, it does so only • More details on the role of the WBIF (and hence EU in such from the perspective of technical upgrades that deal with renewing developments) are provided in response#5 below. However, as equipment, and completely ignores the need to undertake indicated from the start of the Regional Strategy for Sustainable ‘environmental rehabilitation’ of existing