(stamp)
Beo Čista Energija d.o.o. BelgradeNo.: 152/2019
Date: 03.10.2019
Belgrade
Republic of Serbia
Ministry of Environmental Protection
No.: 353-02-1302/2019-03
Date: 30.09.2019
Belgrade
Pursuant to Article 5a of the Law on Ministries (Official Gazette of the RS, nos. 44/14, 14/15,
54/15 and 96/15 – other law, 62/2017), Articles 18 and 24 of the Law on Environmental Impact
Assessment (“Official Gazette of the RS”, nos. 135/04, 36/09), Article 136 (1) of the Law on
General Administrative Proceedings (“Official Gazette of the RS”, no. 18/16), and Article 23 (2) ofthe Law on Public Administration (“Official Gazette of the RS”, nos. 79/05, 101/07 and 95/10 and
99/14), at the request of the project developer, “Beo Čista Energija” d.o.o., Belgrade, the Ministryof Environmental Protection hereby issues the following

DECISION
1. Approval is hereby granted for the Environmental Impact Assessment Study for the projectof construction of the cogeneration plant using municipal waste and landfill gas “Vinča” oncadastral plots 981/1, 987/2, 988, 968/1, 969/3, 969/4, 2693/1, 992/2, 967/2, 966/1, 967/1,992/1,
990/3, 991/3, 990/1, 991/6, 991/2, 991/1, 1005/1, 994/1, 995/3, 996/10, 1015/3, 1014/3, 1013/4,
1013/10, 1005/3, 1013/8, 1013/6, 990/4, 990/5, 1008/8 and parts of cadastral plots: 1008/3,
2693/5, 989/2, 965/1, 1108/3, 2693/4, 966/2, 966/2, and 993 of Cadastral Municipality of Vinča,
in the territory of Municipality of Grocka, City of Belgrade.
2. The project developer is obliged to implement the environmental measures specified in the
Impact Assessment Study referred to in point 1 of this Decision (Chapter 8 of the relevant Study).
3. The project developer is obliged to comply with other requirements and approvals issued by
the competent authorities and organizations in accordance with separate law.
4. The project developer is obliged to implement an environmental monitoring program –monitoring system (Chapter 9 of the relevant Study).
5. The project developer is obliged to commence the implementation of the project within two
years from the date of receipt of this Approval Decision. The Decision and the Study shall be an
integral part of the technical documentation required for obtaining the permit or approval forcommencing the project.
6. The costs of proceedings shall be specified in a separate Decision.

1

REASONING
The project developer, “Beo Čista Energija” d.o.o. Belgrade, on 20 June, 2019, filed to the Ministryof Environmental Protection an application for approval of the Environmental Impact Assessment
Study for the project of construction of the cogeneration plant using municipal waste and landfill
gas “Vinča” on cadastral plots: 981/1, 987/2, 988, 968/1, 969/3, 969/4, 2693/1, 992/2, 967/2,
966/1, 967/1,992/1, 990/3, 991/3, 990/1, 991/6, 991/2, 991/1, 1005/1, 994/1, 995/3, 996/10,
1015/3, 1014/3, 1013/4, 1013/10, 1005/3, 1013/8, 1013/6, 990/4, 990/5, 1008/8 and parts ofcadastral plots: 1008/3, 2693/5, 989/2, 965/1, 1108/3, 979/1, 2693/4, 966/2, 966/2, and 993 of
Cadastral Municipality of Vinča, in the territory of Municipality of Grocka, City of Belgrade,undertaken by company “Dvoper” d.o.o., Belgrade.
The Environmental Impact Assessment Study was undertaken entirely in compliance with theDecision on scoping of the Environmental Impact Assessment Study of the project of constructionof the cogeneration plant using municipal waste and landfill gas “Vinča” on cadastral plots: 981/1,
987/2, 988, 968/1, 969/3, 969/4, 2693/1, 992/2, 967/2, 966/1, 967/1,992/1, 990/3, 991/3, 990/1,
991/6, 991/2, 991/1, 1005/1, 994/1, 995/3, 996/10, 1015/3, 1014/3, 1013/4, 1013/10, 1005/3,
1013/8, 1013/6, 990/4, 990/5, 1008/8 and parts of cadastral plots: 1008/3, 2693/5, 989/2, 965/1,
1108/3, 979/1, 2693/4, 966/2, 966/2, and 993 of Cadastral Municipality of Vinča, in the territory of
Municipality of Grocka, City of Belgrade, number 353-02-815/2018-03 dated 9 May 2019.
Pursuant to Article 20 of the Law on Environmental Impact Assessment, public review (“public
consultation”) was provided, a presentation was organized and a public debate was conductedwith regard to the relevant Study – as advertised in the daily newspaper “Politika” on 28 June2018 and at the official Ministry’s website http://www.ekologija.gov.rs/obavestenja/procenauticaja-na-zivotnu-sredinu/. Public review was arranged at the premises of the Ministry ofEnvironmental Protection and the Municipal Administration of the Municipality of Grocka. The
public debate was held on 23 July 2019 at the Municipal Administration headquarters of theMunicipality of Grocka.
The public debate, in addition to delegates from the Ministry of Environmental Protection and fromthe local self-government - the City of Belgrade and the Municipality of Grocka, representativesof the project developer and experts who undertook the Study, was also attended by members of
the public concerned – representatives from the “Centre for Ecology and Sustainable
Development” from Subotica, Citizens' Associations “Right to the City” (Pravo na grad) and “Let's
Not Drown Belgrade” (Ne da(vi)mo Beograd), the Bird Protection and Study Society of Serbia,
media representatives and other citizens.
Representatives from the Citizens' Association “Right to the City”, “Let's Not Drown Belgrade”,
and the “Centre for Ecology and Sustainable Development” from Subotica raised a number ofcomments regarding potential air pollution by waste organochlorine gases such as dioxins andfurans during the operation of the relevant plant, the lack of expert capacity to monitor thesesubstances and keep them within legally allowed limits, the use of diesel fuel and calculation ofwaste gas emissions, groundwater pollution, the amount of municipal waste required for theoperation of the plant and its proportion to total waste generated annually in the City of Belgrade,the cost of the entire project, and finally, the compliance of this project with the IPPC Directive of
the European Union and the national law implementing this Directive.
During the course of the public consultation, the following entities submitted comments/objections
to the relevant Environmental Impact Assessment Study:•

Centre for Ecology and Sustainable Development, Subotica•

Citizens’ Association “Right to the City” from Belgrade,2•Citizens’ Association “Let's Not Drown Belgrade”,•

The Bird Protection and Study Society of Serbia,•

Petar Denčić from Belgrade.

Pursuant to Articles 22, 23 and 24 of the Law on Environmental Impact Assessment, in theDecision no: 353-02-1299/2019-03 dated 03.07.2019, a Technical Committee was establishedwith the task of reviewing this Environmental Impact Assessment Study, supporting
documentation and opinions submitted by authorities, organizations and public concerned.
After the meeting held on 16 August 2019, the Technical Committee compiled the Evaluation
Report for the relevant Study, stating that it was not undertaken entirely in accordance with the
Law on Environmental Impact Assessment (“Official Gazette of the RS”, nos. 135/04, 36/09) and
the Rulebook on the Scoping of the Environmental Impact Assessment Study (“Official Gazetteof the RS”, no. 69/05). At the meeting it was concluded that the relevant Study shall be corrected
and supplemented in accordance with the submitted opinions, i.e. comments/objections from thepublic concerned.
After submitted the supplemented and revised Study on 20 September 2019, the TechnicalCommittee held its second working meeting on 27 September 2019. Before the meeting,members of the Technical Committee analyzed all parts of the Study which were amended indetail, as follows:
1. Deliver Location Requirements with the electronic seal.
Location Requirements with electronic signature are annexed to the Study.
2. The Requirements obtained in the process of drafting the Amendments to the Detailed
Regulation Plan of Vinča Sanitary Landfill are attached to the Study. It is necessary to submit
the Requirements obtained for design and connection in the process of obtaining Location
Requirements. Please attach the Requirements so that the electronic signature of the
responsible organization is visible.
The Requirements obtained for design and connection in the process of obtaining Location
Requirements with electronic signature are attached to the Study.
3. Deliver a positive decision of the Review Committee on acceptance of the project.
Review Committee’s decisions on project acceptance are attached to the Study.
4. Data on the distance of vulnerable facilities within this project from Belo Brdo, Veteranska
Villa and other archeological sites is missing, although the table lists a number of otherfacilities and their distance.
Belo Brdo archeological site is 3km away from the Vinča landfill complex, to the southeast. The
precise location of Veteranska Villa was neither specified by the competent Institute for
Immovable Cultural Goods, as stated in the Study – page 11 of the Study.
5. Revise Chapter 2.5 – Climate characteristics with meteorological data using new, current
maps.
Chapter 2.5 has been amended to comply with comment – page 23 of the Study.
6. Was heat energy needs analysis of surrounding facilities in surrounding settlements
conducted, as well as technical solutions and cost-effectiveness of heat transport given the
distance of the settlement?
3

It is not the subject of the environmental impact assessment. The Study does not examine
economic cost effectiveness of the project and its parts.
7. What data (the source CEEFOR was stated) was used to determine the existing quantity oflandfill biogas? Is this an estimate or investigation?
The quantity of landfill gas was obtained by modeling. The graphs show production of biogas fromthe “old” and the “new” landfill. The following graphs show for each landfill (old and new) thecollection and production of biogas estimated by SIMCET software.
Figure 45 – Production and collection of biogas from the “old” landfill, in the Study
Figure 46 - Production and collection of biogas from the “new” landfill, in the Study
Old landfill:- Biogas production reaches the maximum value of flow of 5500 Nm3/h (with 50% of CH4) in
2020, and then logarithmically decreases, reaching the value close to zero in 2060;- From 2020 to 2035, biogas flow ranges between 1900 Nm3/h and 300 Nm3/h with average
flow of about 830 Nm3/h.
New landfill:- Apart from the production at the beginning (2390 Nm3/h in 2022), biogas production reaches
the maximum value of flow of 2070 Nm3/h (with 50% of CH4) in 2050, and then logarithmicallydecreases to 300 Nm3/h in 2056, and close to zero in 2090;- From 2020 to 2053, biogas flow ranges between 300 Nm3/h and 1400 Nm3/h with average
flow of about 1000 Nm3/h – pages 114, 115 of the Study
8. Was it prepared – proposed schedule of consumption of existing quantities of municipal waste
as a fuel which is already in the landfill, with using newly arrived quantities of waste once theincineration plant is commissioned?
The project does not propose the use of waste from the existing landfill to be rehabilitated,
recultivitated and closed. For newly arrived quantities of waste, which are to be treated in the EfWplant, a temporary sanitary landfill for municipal waste is proposed, as described in a separate
study: New landfill with accompanying facilities.
9. In mechanical treatment of municipal waste, in its pre-treatment or post-treatment, is dust
which occurs treated as potentially explosive (since part of starting raw materials is certainlyof organic origin) and appropriate dust extraction systems and equipment must be incompliance with EU ATEX directives (2014/34/EU – regarding equipment and 1999/92/EU –regarding workers/owners), and the Rulebook on equipment and protection systems intended
for use in potentially explosive atmospheres (“Official Gazette of the RS”, no.1/13)?
There is no ATEX zone in the waste reception area. Dust occurring from loading operations in thereception bunker, and in the bunker itself, is maintained at a low level as continuing air exhaustfrom these areas is proposed for waste incineration process in the boiler plant. Thus, it is ensured
that the waste bunker is always under negative pressure and there is no emission of dust andodors to the surrounding area.
In post-treatment of waste streams from waste incineration process, there is a recommendation
for ATEX zone in the activated carbon system (a part of the System for reduction of organic
pollutant emission from flue gases), which will be addressed in detail in the subsequent phase of
project design documentation development, which will establish and address all ATEX zones in
the plant, in keeping with valid legal regulations.
10. In the textual documentation and drawings of the Study, please indicate all dust extraction
systems (that is, industrial ventilation and filtration system), which are used to control the4

impact of plant emitters on the ambient air. For example: Flue gas treatment system for the
EfW plant, ash transport, slag transport, material separation, etc.
At the end of Chapter 3.6.2, the following text has been added:
Dust extraction system – industrial ventilation and filtration
In the waste reception phase, the reduction of dust emission to the environment is provided byprimary exhaust of air from the waste bunker, which is transported to the boiler plant, for the needsof burning waste.
Duct which occurs in the waste incineration process in the EfW plant shall be extracted from thesystem by means of bag filters. Dust is then collected from storage under the bag filter in silos
through the enclosed transport system. Reduction of dust emission from incinerator bottom ash(IBA) is performed using water sprinkler system.
The Study and its annexes contains P&I diagrams showing combustion air system, IBA systemand bag filter system – page 120 of the Study.
11. Is there a duct extraction system for treatment and dispatch of the bottom ash from the
combustion chamber of the EfW plant, as there are several transferring places from conveyor,
sieve, mixer...? If the duct extraction system is not proposed, please specify the reason. If it
is proposed, please specify its technical characteristics.
Cooled incinerator bottom ash is extracted using a wet extractor below the boiler grate, so there
is no dust emission. The extractor is also equipped with a vapor extraction system, thus providing
exhaust of any particles in the zone of discharging bottom ash on lower transporters. When thebottom ash is deposited in the IBA zone prior to final disposal, dust emission is controlled by water
spraying.
The figures show the IBA system and central vacuum system of the plant. The figures areprovided in the Study and its annexes – pages 122, 123 of the Study.
12. Specify technical characteristics of each dust extraction system (industrial ventilation andfiltration system) required for the evaluation of validity of the Study in part describing thecontrol of impact of plant emitters on the ambient air. The following characteristics of each of
the systems shall be in particular specified:a. Total capacity, that is, flow of exhaust air (m3/h),b. List of all places – sources of pollution where exhaustion from processing equipment iscarried out, with proposed air quantity to be exhausted (m3/h),c. Proposed dust extractor (filter) with its filter are (m2),d. What type of filter elements is proposed (bags, patrons, packages)?
e. What is the method applied to empty the filter from collected dust and what is further
manipulation with it?
f.

Exhaust fan: capacity (m3/h), total pressure (Pa) and power (kW).

There are two sources of emission of particulate matter from the EwF plant: from the waste
reception bunker and during waste reception, and from the stake after flue gas treatment. Dustemission from the waste reception area is mitigated by primary air suction which is transported tothe boiler plant for waste incineration process. Dust emission form the stake is mitigated bycomprehensive flue gas treatment system (more specifically bag filters). Dust emission from thestake is continuously monitored by the continuous emission monitoring system. Detailed technicalcharacteristics of the comprehensive filter-ventilation system are an integral part of the extensive
project design documentation and cannot be shown in this extent in a study. For illustration5

purpose, a table showing Dust extraction system with bag filter is provided, as well as extracts
from the part of the technical documentation in annexes to the Study – page 124 of the Study.
13. What are guarantees that the proposed dust extractors (filters) in each of the mentioned
system will treat pollutants to below limit values as prescribed by the Law (20 mg/m3)? What
are specific technical-technological measures proposed in dust extraction systems?
Particulate matter emission is monitored, in accordance with the monitoring plan and legal
regulations, and it is guaranteed that the emissions will be below 10 mg/Nm3 according to the
EPC Contract. This is in compliance with the EU Directive on Waste Incineration. As far as the
BEP plant, the guaranteed dust emission is 100 mg/Nm3 according to the PPP Contract.
Guarantees that the proposed dust extractors (filters) in each of the mentioned system will treat
pollutants to below limit values as prescribed by legislation are regular monitoring of pollutant
emissions from the plant, monitoring reports which are, in accordance with regulations,communicated to the competent authorities and control by the competent authorities for control
and supervision (inspection service).
The proposed dust extraction systems are by themselves specific technical-technologicalmeasure intended for reducing pollutant emissions from the plant – page 125 of the Study.
14. Does in the NOx control building, control of other gases and particles should and may be inplace (page 48)?
DeNOx building includes only the urea storage and injection system which is used to neutralize
NOx separated during waste incineration. The actual removal of NOx occurs only in a furnace –boiler plant. Therefore, the DeNOx building includes only urea detection – page 49 of the Study.
15. Data is missing, from where raw water is obtained (page 64)?
Pages 74 and 95 of the Study contain the answer to the given comment, in subtitles:“Technical water line”
As raw water for various uses in the Functional unit 1/1, potable water from the public Belgrade
water supply system will be used”.
“Water supply”
The facilities within the plant do not have connection to the public water supply system. The
Functional unit 1 will be supplied with water through internal connection to the water supply
system of the entire landfill complex in Vinča, which is connected to the Belgrade water supply
system.
The Study describes in detail the origin and use of raw water.
16. In the overview showing generated waste treatment technologies, there is no data about what
is done and how used saturated activated carbon is treated (page 103)? Define measure forpreventing the adverse environmental impact which involves regular replacement of filter
filling, in particular filters with activated carbon on the EfW plant and oxidizing catalytic
converter on the BEP plant.
In the EfW plant, spent activated carbon injected in the form of powder is collected together withresidues in APCr silo. APCr is then stabilized and disposed to the landfill for residues produced
after waste treatment in the EfW plant (which is the subject of other project, i.e. other impact
assessment study). In the BEP plant, activated carbon is disposed into big big-bags - page 107of the Study.
Chapter 8.4 proposes following measures:-

The project developer is obliged to regularly replace filter filling, in particular of activatedcarbon filters in the EfW plant and catalyst converter on the BEP plant.
6-Filter filling shall be replaced by equipment supplier or authorized repair service provider.

-

Used (contaminated) activated carbon shall be temporarily stored in hazardous waste storage
on the Operational platform (which is the subject of other project, i.e. other impact assessment
study), until its delivery to operators possessing appropriate permit for this type of waste
management.

17. It is stated that the project developer is obliged to contact the competent Ministry for
determining the obligation about the type of SEVESO document. The legislation prescribes:
that the project developer himself determines, based on the type and quantity of dangerous
substances, what document he shall develop, and inform the competent authority thereabout.
The mentioned obligation in Chapter 73. has been amended to read:“The project developer is obliged, based on prior notification about the type and quantities ofdangerous (Seveso) substances and chemicals which are present or may be found in the plant,
to contact the Ministry for determining the obligation of the type of SEVESO document to be
drafted for the relevant plant.” Page 252
The same measure is given in Chapter 8.4.
18. Is blockage of the main process plant proposed in case of an accident or failure in appropriate
duct extraction system (for example, cracking of filter element in the filter, halt in the dust
extractor, etc.) Specify what is done and how.
Bag filters are designed into 8 compartments: If in the dust collection/transport system,
halt/accident is identified, or if exceeding output concentrations are detected in the continuous
emission monitoring system, then the compartment where the problem occurred, can be isolatedwith dumpers (for example, penetration of bag filter or clogged duct collector). The load of the
EfW plant can be reduced to adjust flue gas flow after closing one or more compartments of thebag filter – page 532 of the Study.
19. Is monitoring and further treatment proposed not only for emission exceeding, but also for theincident itself and how?
The following has been added in Chapter 9.2:
Monitoring in case of accident and post-accident monitoring- All performances of the plant and the detection and alarm system in case of accidents areregistered in DCS and signaled to operators in the plant.
- Monitoring of main environmental factors during the accident duration is mandatory.
- After accident, compile a report on the accident occurred with obligatory measures to preventthe occurrence of the same or similar accident- Depending on the scope and effects of the accident, conduct post-monitoring of environmental
factors affected by the accident.
- The project developer is obliged to provide funds for remediation of accident andconsequences caused by the accident, in accordance with developed design of remediationof accident consequences – page 277 of the Study
20. Although it is estimated that solidificate will be non-hazardous waste, please add the following
measure: Characterize solidificate, and define final disposition according to established waste
character. The same applies to stabilized bottom ash from EfW plant combustion chamber.
The following measures have been added in Chapter 8.4:-

Characterize solidificate, and define final disposition according to the established waste
character.

7-Characterize stabilized bottom ash from the boiler plant (IBA) and define final disposition
according to the established waste character.

21. Specify procedure for replacing filter units for gas treatment from the BEP plant and bag filters
for flue gas treatment.
Bag filters in the EfW plant shall be replaced during planned overhaul - filter bag replacement.
Three filters for landfill gas in the BEP plant use activated carbon: the filter is filled with activatedcarbon from the top, while spent activated carbon is removed through the bottom. The absorption
rate is monitored, and when adsorption rate falls below 80%, it must be refilled. The procedure
involves discharge of 50% of filter filling height and refilling to 100% so the filling top would fall tothe silo bottom. This ensures full utilization of absorption properties of activated carbon filling page 125 of the Study.
The following measures have been added in Chapter 8.4:-

Replace bag filters in the EfW plant during planned overhaul – filter bag replacement.

-

Three filters for landfill gas in the BEP plant use activated carbon: the filter is filled withactivated carbon from the top, while spent activated carbon is removed through the bottom.
The absorption rate is monitored, and when adsorption rate falls below 80%, it must be refilled.
The procedure involves discharge of 50% of filter filling height and refilling to 100% so thefilling top would fall to the silo bottom.
Excerpt from offer submitted by “Teknogrup” providing additional details is attached.

22. These factors point to the toxic potential of one PCDD or PCCF congener in relation to thetoxic effect of 2,3,7,8-TCDD (Tetrachlorodibenzodioxin), which is a congener with the highest
toxicity. The Industrial Emissions Directive (IED) sets I-TEFs for 17 PCDD/PCDF congeners,
including 2,3,7,8-TCDD [24, EU 2010], [49, CEN2006].
If there is a need to cover dioxin-like PCB, it is recommended to use unit ng WHO-TEQ/m3,
which is toxic equivalent according to the World Health Organization (WHO-TEFc, which isalso called toxic equivalency factor of the World Health Organization), in addition to I-TEF,
also includes toxic equivalency factors for 12 dioxin-like PCB. The another difference between
the two concepts is that WHO-TEQ differs from I-TEF in several PCDD/PCDF [50, Van derBerg et al.2006], [51, CEN 2010].
At the EfW plant’s emitter - stack, continuous monitoring/sampling of dioxins and furans influe gases is proposed. In addition, samples of flue gases will be analyzed by an accredited
laboratory in keeping with the monitoring program. The contractor guarantees performancesof the EfW plant for the stated parameters as max up to 0.1 ng(1-TEQ/m3) as defined by the
EU Directive on Waste Incineration /page 274 of the revised Directive.
Comments submitted by Citizens Association “Right to the City / Let’s Not Drawn Belgrade:
1. There is no logical justification for the decision that rehabilitation and energy utilization oflandfill gas from the existing landfill are examined by the same Study as the EfW plant, asthese are two different projects. It would be more meaningful to have one study covering the
EfW plant, namely the incinerator, and new landfills as it is planned for waste from theincinerator to be disposed at the new landfill.
The answer stating that the landfill rehabilitation is not the subject of the Environmental Impact
Assessment Study is accepted. The scope of a study is defined by the Location requirements,
8technical documentation developed at Preliminary Design level (PD) and the scope of future
construction permits, pursuant to the Law on Planning and Construction and the Law on
Environmental Impact Assessment Study.
The Law on Planning and Construction allows projects to be implemented in phases. Accordingly,
in order to obtain the requirements and approvals from holders of public powers, twoenvironmental impact assessment studies were undertaken, as well as the Existing Landfill
Rehabilitation and Remediation Project. According to the legislation, public consultation andpresentation of the Environmental Impact Assessment Study of the EFW plant and new landfill
with accompanying facilities were provided. The Study presents technical solutions andappropriate protection measures in terms of reducing potential emissions from this complex.
2. The Study does not include power stations and transmission lines, nor the wastewater
treatment plant. Without these elements, the incinerator and landfill gas fired power plantcannot operate! The Study must include all facilities closing the technological process and arenecessary for its functioning.
The answer stated that the project boundaries have been defined by project design
documentation developed within the Preliminary Design, as stated in the answer to the previous
comment. The mentioned line facilities represent connection facilities, as water supply andsewage networks, electricity and other, and they are the subject, or not, of other studies, pursuant
to legal regulations and decisions issued by competent authorities.
Transmission lines and power stations are also part of other detailed regulation plans (twoindividual detailed regulation plans), followed by strategic environmental impact assessment
studies and they are not sited on the cadastral plots of this project. Development and preparationof these detailed regulation plans, strategic environmental impact assessment studies and latter
technical documentation and environmental impact assessment (if decided so in legally defineddecision-making procedure) are in progress and part of other procedures.
The wastewater treatment system is extensively described and is part of the environmental impact
assessment study for the landfill, pursuant to the location requirements and prepared technicaldocumentation. Please look more carefully the text of the Study.
3. On 16 December 2018, the Secretariat for Environmental Protection of Belgrade City
Administration announced “Public consultations for environmental and social impact
assessment for the Vinča Energy-from-waste plant, construction of the new landfill andremediation of the existing landfill (ESIA)” and public debate scheduled for 20 December 2018(http://www.beograd.rs/lat/gradskioglasi-konkursi-i-tenderi/1756002-javne-konsultacije-zaprocenu-uticaja-na-zivotnu-sredinu-i-socijalna-pitanja-za-postrojenje-Vinča!)
However, the content of this Study differs significantly from the content of the mentioned ESIA
Study. Apart from differing in the subject of the impact environmental assessment (the ESIA
covers all proposed facilities within the Vinča complex, given the fact that that is the only right
way to determine the impact of works in the Vinča complex on environmental factors), it isobvious that even for those parts considered by this SIA, not all data, that the project
developer obtained and examined for the ESIA, are shown. In this way, the public and theTechnical Committee of the Ministry of Environmental Protection has been left deprived ofsome of the crucial information necessary to assess the impact of the proposed works onenvironmental factors.
9

The answer stated that the ESIA document is not subject of the environmental impact assessment
procedure pursuant to Serbian legislation. The content of ESIA is defined by banks that need to
be informed in detail about projects for which they need to decide whether or not they want tofund them. The approval of ESIA document is given by banks and it is not binding for the project
developer in terms of the implementation of that project, it only influences whether the given bankwill participate in funding the project. On the other hand, the content of EIA documents is definedby the legislation of the Republic of Serbia and as such is not the same document in content as
the ESIA study. The approval of EIA documents is given by the Ministry of Environment andfurther implementation of the project depends on its outcome.
The procedure for this particular ESIA study was initiated earlier and during the procedure it hada large number of reviews and analyses of the document itself with the potential to influence thedevelopment of the text and the scope of survey, resulting in many things being amended andadopted on the fly, before the public debate was held for this study.
On the other hand, the procedures for EIA studies started a little later than the procedure for ESIA,
but within the legally defined procedure it was not possible to significantly amend the text of the
document before the public debate. Therefore, some of the results and information obtained in
the meantime were not included in the text for public debate, which has now been corrected in
the new version of the document.
4. As the mentioned ESIA document was already the subject of public debate in the procedure
conducted by the European Bank for Reconstruction and Development (EBRD), and as in thispublic debate procedure comments on it were furnished, to which the project developer
provided answers and significantly amended the ESIA document accordingly, it is not clear
why here considered Study contains old data.
Although it is clear that the EBRD procedure does not have to necessarily correspond to RS
regulations, we still believe that the aim of presenting the old version of the Environmental
Impact Assessment Study is only to hassle the public in terms of additional time loss on writing
the same comments on the Study content, for which the project developer already agreed thatthey would be changed, supplemented or correctly presented.
As in the previous answer, the ESIA is not subject of the environmental impact assessment
procedure according to Serbian legislation.
5. The Environmental Impact Assessment Study does not contain requirements issued by publiccompanies based on which it is possible to determine with certainty that the technology
described is in compliance with regulations. Namely, the attachments of the Study containrequirements issued during the development of the Detailed Regulation Plan of “Vinča”
Sanitary Landfill (“Official Journal of City of Belgrade”, no.86/18), but not requirements
acquired for obtaining Location Requirements of the Ministry of Construction, Transport andInfrastructure, number: 350-02-0085/2019-14 dated 25 April 2019.
The answer stated that requirements and approvals were obtained in early and mid-2019, andthey are attached to the Studies. If an inadvertent error has occurred, it will be corrected.
6. The Study describes the existence of and resettlement plans for the informal settlement
located on the existing landfill body. However, this settlement was resettled more than 6months ago! The aim of the Environmental Impact Assessment Study is to analyze anddescribe the impact on the population before these impacts are realized, not after. On theother hand, given that the Study does not contain data on the resettlement process,resettlement results and current living conditions of the resettled population, it is clear that this10

is a carelessness of the project developer to really assess the impact of the proposed projecton the affected population.
The answer stated, as it is stated in the Study, that the City of Belgrade is responsible forresettlement of Roma families to free the space for construction of proposed facilities, as well as
to inform and provide assistance to the affected population. The Assembly of the City officiallyadopted the Resettlement Action Plan which obligates the City to fulfill all requirements definedby legal regulations, but also requirements put before the City by international financial institutions(IFIs) which will participate in financing the project.
According to the latest information obtained by the City, the relocation status is following:
All families which meet the requirements laid down by the Law on Housing and Building
Maintenance were provided adequate housing support and placed in already built apartments of
the City of Belgrade in accordance with the Resettlement Plan for households living in the informal
settlement located at the landfill site, and for income restoration of collectors of secondary raw
materials (waste pickers) at the Vinča landfill. To individuals not having personal documents, theCity of Belgrade provided assistance in obtaining them. Persons older than 16 years were
provided assistance in obtaining an identity card. Parents were assisted in obtaining birthcertificates for children below 16 years of age. Prior to the resettlement, all children below 14
years of age were enrolled in preparatory preschool program and primary school, in accordancewith mandatory preschool and primary education as defined by positive regulations of RS. School
attendance is regularly monitored in cooperation with school principals, teachers and theSecretariat for Education. After resettlement, all medical records of the persons covered by the
project were transferred to primary health care centers at new locations. Those not having medical
records were provided assistance in registering and obtaining records in primary health carecenters.
Families are work-engaged at the Vinča landfill as collectors, they pay costs of housing from theirown income. Prior to the resettlement, families were informed on costs of using apartments, thatis, households were presented that they will be obliged to pay rent (unless they move to their own
apartment or house) and costs of bills, but also that the City will help them through subsidies tosettle these costs, and that the City will help them in obtaining personal documents, enrollingchildren in schools, healthcare, social protection and finding a job:
The City of Belgrade, the city of Šabac and the municipality of Vladimirovci will provide assistancethe persons covered by this project in restoring and improving their income through the following
measures:---

Seasonal job offers;
Job offers in city utility companies;
Job offers through public work programmes;
Job offers in cooperation with the NES (development and implementation of individual
employment plans, job search training, and courses of retraining and adult education, job
opportunities available, mediation in finding employment, entrepreneurship incentive anddevelopment services, special programs for individuals belonging to vulnerable andharder-to-employ groups)
Offering assistance in employment and self-employment within available programs andprojects of NGOs and other organizations (e.g. IPA 2016 EU Support for Roma Inclusion– Strengthening local communities for Roma inclusion, funded by the European Union andimplemented by the Permanent Conference of Towns and Municipalities, in cooperation
with local governments throughout Serbia);
Offering adult education and craft training courses;
11-

Offering jobs during the construction phase of the project, at the Vinča landfill, and later
during the operational phase of the new landfill;- Offering jobs involving collection and sorting of secondary raw materials at other locations
where PUC Gradska Čistoća operates (e.g. at sites of future recycling centers)
Since the families were relocated from the informal settlement next to the Vinča landfill in
September 2018, the Working Group has been monitoring the implementation of the Resettlement
Plan for at least two years after resettlement in cooperation with all other organizational units
involved in the implementation of the Resettlement Plan.
7. The Study does not contain requirements issued by Belgrade Institute for Protection ofCultural Monuments, i.e. it contains a letter of the Institute dated 23 March 2018 in which theInstitute makes reference to the requirements of the Institute P 2249/14 dated 23 July 2014
to be used for amendments to the Detailed Regulation Plan of “Vinča” Sanitary Landfill.
However, these requirements are not attached to the Study.
The answer stated that the Requirements of the Belgrade Institute for Protection of Cultural
Monuments were obtained on 29 March 2019, under number 350-02-00104/2019-14 and are
attached to the Study.
8. The Study does not contain all mandatory parts as stipulated by the Rulebook on Scoping of
the Environmental Impact Assessment Study (“Official Gazette of the RS”, no.89/05). It isparticularly important to note here that the Study does not contain the copy of the map showing
cadastral plots on which the proposed development is to be built, with drawn-in disposition of
all facilities.
The answer stated that the copy of the map showing cadastral plots is attached to the Study.
9. The Study does not contain all attachments listed in the section “List of technicaldocumentation” on page 247 of the Study, making it impossible to verify the information listed
in the content of the Study.
The answer stated that the list of technical documentation includes the list of all design volumes,
technical and planning documentation, which were used to describe the plants and define theimpacts and measures provided for by the project, which were cited as the source of informationin the Study. Law does not provide for to make available complete technical and planningdocumentation for review in the process of undertaking the impact assessment study, but an
excerpt from the project with main details, based on which is possible to see what is the subjectof the study. The complete technical documentation is submitted to the authority responsible for
issuing the construction permit.
10. The Study does not examine any alternative solutions for waste management in a way whichmeets the aim of this environmental impact assessment procedure. The Study must examine
at least one alternative solution for waste treatment not involving incineration, for example,
recycling + MBT + new landfill for stabilized waste.
The statement is not true. A study is undertaken for a precisely defined project based on aPreliminary Design (PD) developed in accordance with specially issued location requirements forthe elaboration of technical documentation and connection for a specific Schematic Design,
issued by the competent authorities (Article 12 of the Law on Environmental Impact Assessment,“.the request referred to in paragraph 2 of this Article shall be enclosed with the following
documentation: 2) preliminary design, i.e. excerpt from preliminary design ... 4) requirements andapprovals of other competent authorities and organizations obtained in accordance with aseparate law ..”) . Therefore, pursuant to the Law on Planning and Construction, it is not possible12

to consider several completely different project solutions at this level of development of technicaldocumentation.
What can be done only is to describe alternative solutions which were considered at previous
levels of technical documentation preparation, which has been done in this Study, or to present
alternative measures which may be implemented, as defined in Article 2 of the Law on
Environmental Impact Assessment “environmental impact assessment means a prevention
measure of environmental protection, based on the elaboration of a Study, and conducting of
public consultations and analyses of alternative measures, with the aim of collecting data, andforecasting adverse effects of specific projects on the environment and human health, flora andfauna, soil, water, air, climate and landscape, material and cultural resources and cumulative
effects of these factors, and of determining and proposing measures that may be implemented toprevent, reduce or offset such adverse effects, having in mind the feasibility of these projects(hereinafter: impact assessment)”.
Alternative solutions are described in Chapter 4 of the Study.
11. The Study does not present basic data on the quantity and composition of municipal waste
collected annually in Belgrade and quantities projected for the future, which is the main
starting data in assessing the impact of the proposed facilities on the environment. Annex IV
to Directive 2011/92/EU, as amended by Directive 2014/52/EU, which is binding for Serbia
starting from 1 January 2019, requires to be included: “(c) a description of the main
characteristics of the operational phase … for instance, energy demand and energy used,nature and quantity of the materials and natural resources used…”. Since in the incineration
plant is planned to incinerate natural resources, the Study must be supplemented with thedescription of waste composition and quantity.
The answer stated that starting data on estimated waste quantity generated and collected in therelevant territory has been given as part of tendering documentation and defined within the Study
developed by company FICTHTNER. The comment is not true; it is not proposed in the EfW plant
to incinerate any natural resources.
12. The facilities analyzed in this Study should be compared against the new BREF standard
which was adopted in the EU on 17 June 2019, and not with the 2006 document, as the project
developer did. Considering the fact that project is planned to be funded by financial institutions
EBRD, EIB and IFC, it must comply with the newest BREF standard. In addition, it cannot be
considered justified to build a plant which does not comply with the latest standards onenvironmental protection and protection of human health.
The answer stated to see the answer defined in agreement with EBRD:“The current project (design) fulfills the requirements for emission limit values defined under the
Emissions Directive (IED) 2010/75/EU. At the time of undertaking ESIA/EIA documents, theofficially adopted BREF for waste incineration was the BREF document adopted in August 2006,
and the same version is still in force. All installations falling under the Industrial Emissions
Directive 2010/75/EU should comply with the requirements of the official documents adopted by
the European Commission. Therefore, in ESIA/EIA documents, comparisons have been madewith the only currently valid and obliging emission limit values from waste incineration, that is, the2006 BREF. Theoretically, if in the coming period, including the period after the EfW plant is built,
other document defining emission limit values/BREF comes into force, the project will, if not
13

(claimed by nobody) inevitably be complied with the new requirements which the Government of
the Republic of Serbia decides to transpose and adopt as criteria defined in Serbian legislation.
The proposed energy-from-waste plant includes technological solutions and design which weredeveloped in a way to enable possible necessary changes and adjustments in line with possible
new BREF requirements, as may be transposed in Serbian legislation”.
13. The Study does not contain data on annual diesel fuel quantity required for the operation of
the plant.
The response stated that the annual diesel fuel quantity required for the operation of the plant(mobile equipment within the entire complex in Vinča) should be around 475 m3/annually. Also,
according to the management and maintenance plan, around 300 m3 of additional fuel can beused in the EfW plant.
14. The Study does not contain expected emissions of harmful substances produced after
treatment, but only limit values.
The answer stated to see Tables 17 an d18 of the Study.
15. What is expected cost for households of this project?
This issue is not the subject of this Study.
16. “Nearby the existing landfill (to the north) there is an informal settlement consisting of huts
without basic infrastructure (water supply, sewer...).” “In the north part of the proposed landfill
complex, immediately next to the existing landfill fencing, there is an informal settlement.
Families living in this informal settlement collect and sort secondary raw materials, and thensell them to purchasers... The Action Plan provides for the resettlement of families living in
the informal settlement located at the Vinča landfill site, as described in detail in Chapter 5.1!”
The Study describes the existence of and resettlement plans for the informal settlement locatedon the existing landfill body. However, this settlement was resettled more than 6 months ago! The
aim of the Environmental Impact Assessment Study is to analyze and describe the impact on the
population before these impacts are realized, not after. On the other hand, given that the Study
does not contain data on the resettlement process, resettlement results and current living
conditions of the resettled population, it is clear that this is a carelessness of the project developer
to really assess the impact of the proposed project on the affected population.
As this is repeated comment, please see the answer to the comment no. 7.
17. In the answer from EBRD, we got information that: “The nearest free-standing structure in the
Vinča settlement based on orthographic analysis is at a distance of 1050 m (SE from theexisting landfill, near the cemetery).” On the other hand, measurement using available tools(GIS, Belgrade Land Development Public Agency) shows that this distance is less than 1000
m. This has been also confirmed by IFC consultant, in the document Environmental and Social
Scoping Study for the Belgrade EfW Project in Serbia (Fichtner, April 2007) where it is clearlystated that the distance between the Vinča landfill and the nearest settlement is only 800 m.
The Study has been amended to comply with the observed fault.
18. Precisely specify the distances of the proposed complex (not only the existing landfill) frompumping stations, the distance from the boundary of water supply source protection andprotection measures for water areas from the impact of the project. Specify the distance ofthe planned complex from the boundary of the alluvial plain zone which is affected by high14

level of groundwater and surface water/floodplains (Master Plan of Belgrade, Map 7 – Water
and water areas) and protection measures for water areas from the impact of the project.
The answer made reference to the attached requirements issued by “Belgrade Waterworks andSewerage”.
19. The Study only copies data for the period 2000 - 2015, and shows them aggregately, without
drawing conclusions of actual importance for this Study. How does the Study relate to thepost-2105 period which witnessed increasing oscillations in maximum and minimum values of
the analyzed climate characteristics?
The answer stated that Chapter 2.5 of the Study has been supplemented with new data. When
the Study was undertaken, much data for later years was not publicly available.
20. The diagram of mean monthly air temperatures for Belgrade weather station (for the period
2000-2015) does not show data mentioned in the name of the diagram. View of averagetemperatures is missing, by month, for each year between 2000 and 2015, which would show
a trend of temperature increase.
The answer stated that Chapter 2.5 of the Study has been supplemented with new data. When
the Study was conducted, much data for later years was not publicly available.
21. Also, average monthly temperature in October cannot be lower than in November. We alreadycommented this during the public consultations which EBRD made available for public review
and we hoped that the project developer would correct this novice mistake.
The response stated that Chapter 2.5 of the Study has been supplemented with new data. When
the Study was conducted, much data for later years was not publicly available.
22. “…According to the Climate Atlas of Yugoslavia for the 1931-1960 period, the annual numberof foggy days in Belgrade is 39. ... Source: Ecological Atlas of Belgrade, City Institute for
Health Protection Belgrade, 2002).”
Data in the Study must be relevant and current. Neither the 1931-1960 period nor 2002 iscurrent, nor they provide exact overview of the situation regarding smog in Belgrade, which isworsening. The Study should be supplemented with current information on smog in Belgrade.
The response stated that Chapter 2.5 of the Study has been supplemented with new data. When
the Study was conducted, much data for later years was not publicly available.
23. There is no drawing showing position of each of the individually listed natural protected area.
There is no drawing showing distances between the proposed facilities and each of theindividually listed protected natural area. The distance of the proposed complex in Vinča fromthe boundary of ecological network area of particular ecological importance “Confluence of
the Sava and the Danube rivers” which is also declared as an international IBA (important birdarea, RS017IBA) is inaccurate! If there were a map with precisely drawn in boundaries ofprotected areas, it would be clear that the distance of the proposed complex from theboundary of the IBA is 180m (one hundred eighty meters), and not 9 km as specified in the
Study. This information was presented in the response of EBRD to the comments on the ESIA
Study prepared by the project developer for bank loan approval process.
The Study has been revised to comply with this comment, and current data has been entered in.
24. Data on health status must be supplemented with the impact assessment of pollution sourcein air, water and soil on the population health? Also, it must be supplemented with acomparative analysis of Serbian population health and population of the region and the EU,
more specifically, with the incidence and mortality rate of most common diseases, in order to15

have a clear insight into the population health status. For example, Serbia is on the 18th placein Europe in cancer incidence, but it holds the 2nd place in cancer mortality rate (Serbian
Medical Society, 2017). Unless supported by the above additional analysis, data presented
in the Study cannot be considered relevant data for actual impact assessment of the proposeddevelopment on the health of population of Belgrade and Serbia.
The answer stated that all available data on health is shown in the Study.
25. “Waste combustion plant is designed for continuous operation with a fuel of minimum calorificvalue (MCV) ranging from 6,000 kJ/kg to 12,000 kJ/kg and for combustion of solid municipal
waste.”
What is the current calorific value of municipal waste in Belgrade? How much it will be whenthe effective separate collection system of plastics, paper and biodegradable waste
introduced? Supplement the Study with this data which may be of key relevance for the
analysis of auxiliary diesel fuel quantity which will be required for the plant operation.
It is estimated that calorific value of municipal waste in Belgrade ranges between 7,500 kJ/kg
and 8,500 kJ/kg. These values are also consistent with experiences of other countries with similar
standard of living. It is important to mention that the EfW plant is designed to receive significantly
higher spectrum of municipal waste and that the waste crane includes several cycles of waste
mixing to get homogenized before reaching the grate.
In this phase, it is not possible to determine the exact impact of waste separation and recycling,
as it depends on applied waste collection guidelines. Waste separation may either reduce total
quantity of municipal waste by removing materials having higher calorific values (plastics, fabrics,
etc….) or increase by removing materials having lower calorific values (organic waste, glass,cans, etc.). Experiences in other countries which underwent the same policy changes show thatmunicipal waste remain quite stable before and after the changes, as both previously mentioned
impacts cancel each other out. Regardless of good practice, the plant has been designed with avery high range of operation in order to manage any future variations in municipal waste.
Auxiliary diesel fuel is required only for plant start up and shut down to bring the furnace to sucha high temperature as to burn hazardous gases from waste. Once the plant starts operating,waste is enough to maintain fire. It is expected to have maximum 1 cold start and 6 regular (hot)starts every year, representing maximum fuel consumption of 40m + 6 x 24m = 184 tons of fuel.
This value is less than 0.3% of energy combusted in the EfW plant, while 97.7% of energy will be
generated from waste.
26. “All waters, polluted and unpolluted, from this part of the landfill complex, are discharged into
internal channeling systems which are at the border of Functional unit 1 connected toappropriate systems of the other part of the landfill complex, such as the Leachate treatment
plant and the Waste (sanitary-foul) water treatment plant. The mentioned plants are subjectof other project.”
The mentioned plants must be covered by this Study because the plants examined by thisStudy cannot operate without the wastewater treatment system.
The answer stated that the Impact Assessment Study for the EfW plant describes the wastewater
treatment system as inseparable part of the overall system at the complex, but details about it
were not provided in the Study as the system itself is not covered by the Construction Permit for
the EfW plant, but the Construction Permit for the landfill. Detailed description of the wastewatercollection and treatment system is given in the Impact Assessment Study for the landfill.
16

27. Table 17: Are these values before treatment? If so, are these post-treatment values shown in
nm3 for 30 min or 24-hour average? Table 18 shows only limit values, but not expected values.
Supplement the Study with expected emission values at the exit from the stack into theatmosphere? If the values specified in Table 17 are after treatment, they are not in compliancewith the 2006 BREF values.
The answer pointed to Table 17 – it is about expected values of flue gas quality parameters before
treatment process – input design parameters, and Table 18 – it is about maximum expected
emission values.
28. Pollutant emission limit values are not in compliance with the new BREF document on waste
incineration which was adopted in June 2019. This pertain to all mentioned substances,
except for CO and TOC. This means that the technology applied to the waste incineration
plant in Vinča will be outdated even before it is even built! What is the reason of using thisoutdated technology? Is it simply cheaper for the operator? Where is the population health inall of this, as in this way it will be exposed to excessive pollution?
Why build a plant which, at the time of construction, is already not in compliance with the best
available techniques? Legal obligations set minimum, not maximum requirements, and it is
not clear why the new standards, when already available and adopted, are not complied with?
This behavior poses additional obligations for the developer, and does not provide maximum
protection to the population. Even opposite.
The answer stated that the current project (design) fulfills the requirements for emission limit
values defined under the Emissions Directive (IED) 2010/75/EU. At the time of undertaking
ESIA/EIA documents, the officially adopted BREF for waste incineration was the BREF document
adopted in August 2006, and the same version is still in force. All installations falling under the
Industrial Emissions Directive 2010/75/EU should comply with the requirements of the official
documents adopted by the European Commission. Therefore, in ESIA/EIA documents,
comparisons have been made with the only currently valid and obliging emission limit values fromwaste incineration, that is, the 2006 BREF. Theoretically, if in the coming period, including theperiod after the EfW plant is built, other document defining emission limit values/BREF comes
into force, the project will, if not (claimed by nobody) inevitably be complied with the newrequirements which the Government of the Republic of Serbia decides to transpose and adopt as
criteria defined in Serbian legislation. The proposed energy-from-waste plant includes
technological solutions and design which were developed in a way to enable possible necessarychanges and adjustments in line with possible new BREF requirements, as may be transposed in
Serbian legislation”.
29. “After mixing and completed reaction, tank trucks will transport stabilized APCr to the newinert waste landfill, outside of planning unit KP1t, within the Vinča landfill complex, which is
not the subject of this Study. The newly designed inert waste landfill is the subject of anotherproject – New landfill with accompanying facilities in Vinča”.
Since the EfW plant cannot operate without provided landfill for by-products of waste
incineration in the EfW plant, the landfill for incineration residues must be included in thisStudy. After all, if this landfill is covered by another study, what is the reason for not presenting
the conclusions of that study in this Study?
The comment is relevant, the mistake was made in the text of the Study and the text has been
amended. Stabilized APCr is not transported to the inert waste landfill, but to the landfill intended
for residues from the EfW plant.
30. Table 19 should show the compliance of proposed technologies and facilities with the BAT
Conclusions adopted in June 2019, not with the 2006 document. For some points in the right17

column, comment whether it is complied with BREF or not, or is it applicable or not, is missing.
For some points, conclusions are obvious from the text, but for some are not, therefore thistable should be supplemented and conclusions specified.
The answer to this comment is part of the answer for the previous comment.
31. What is gross electrical efficiency, and what is gross energy efficiency of the plant?
The answer stated that gross electrical efficiency of the plant is 25.9%, while gross heat efficiency
is 21.6% (from heat energy exported to the central heating plant Konjarnik). Total energy
efficiency is 47.5% in total.
32. “Flue gases emissions must meet all requirements in terms of limit values, as prescribed by
Directive EU 2010/75/EC on Industrial Emissions (IED)” – we assume that this refers to Annex
V of Directive. The question is whether flue gases emissions comply with the limit values
specified in adopted BAT Conclusions from June 2019?
The answer to this comment is part of the answer for the previous comment.
33. It is not clear why the Study does not examine any non-incineration alternative, withrehabilitation of the existing non-sanitary landfill, the construction of new landfill and MBT
plant. Separate collection, recycling and composting can be combined with MBT for residual
waste, after which treated waste may be disposed at the new landfill. This solution can help
avoid the so-called “lock-in”, that is, the situation in which investment of (public) money into alarge plant prevents in the future the change of public policies in the field of waste
management. Examine at least one non-incineration solution and compare results and overall
impact with the solution proposed in this Study.
The answer stated that one of alternative methods of municipal solid waste management is its
energy utilization by thermal procedure. Valid legal regulations do not prohibit the application of
the mentioned method, of course, with defined restrictions and appropriate measures ofenvironmental protection, human safety and health, as well as for any other technical solution.
The Study shows, among other things, technical solutions for reduced green gas emissions.
On the other hand, a study is undertaken for a precisely defined project based on a Preliminary
Design (PD) developed in accordance with specially issued location requirements for theelaboration of technical documentation and connection for a specific Schematic Design, issued
by the competent authorities (Article 12 of the Law on Environmental Impact Assessment, “.therequest referred to in paragraph 2 of this Article shall be enclosed with the following
documentation: 2) preliminary design, i.e. excerpt from preliminary design ... 4) requirements andapprovals of other competent authorities and organizations obtained in accordance with aseparate law ..”) . Therefore, pursuant to the Law on Planning and Construction, it is not possible
to consider several completely different project solutions at this level of development of technicaldocumentation.
What can be done only is to describe alternative solutions which were considered at previous
levels of technical documentations preparation, which has been done in this Study, or to present
alternative measures which may be implemented, as defined in Article 2 of the Law on
Environmental Impact Assessment “environmental impact assessment means a prevention
measure of environmental protection, based on the elaboration of a Study, and conducting of
public consultations and analyses of alternative measures, with the aim of collecting data, andforecasting adverse effects of specific projects on the environment and human health, flora andfauna, soil, water, air, climate and landscape, material and cultural resources and cumulative
effects of these factors, and of determining and proposing measures that may be implemented to18

prevent, reduce or offset such adverse effects, having in mind the feasibility of these projects(hereinafter: impact assessment)”.
Alternative solutions are described in Chapter 4 of the Study.
34. Data on compounds analyzed from the sample SS5 and the sample SS10 is missing in Table.
The answer stated that these are sediments and they are covered by the part dealing with surface
water and sediments.
35. It is missing the explanation about two selected soil samples SS3 and SS6 which will beanalyzed for the presence of polychlorinated dibenzodioxin (PCDDS) and polychlorinateddibenzofuran (PCDF). If the samples SS3 and SS6 correspond to the measuring points ofSurface soil 3 and Surface soil 6, there is a need for an additional explanation why these two
measuring points were selected to be tested for the presence of highly carcinogenic
compounds in soil, as these two sampling points are the furthest from the existing landfill body,that is, the source of pollution.
The answer stated that a representative of Egis company, accredited for soil sampling, sampled
soil at points SS3* and SS6* for the analysis on polychlorinated dibenzodioxins PCDDs andpolychlorinated dibenzofurans PCDF, and the analysis was conducted by internationallyaccredited laboratory Alcontrol (now Sinlab). These points were selected based on logicalreasoning that is was important to determine the concentration in soil which is the closest to
agricultural land and on the path of dispersion in their direction. It is not logical to take samples
next to the landfill body.
36. The answer of EBRD to previous comments states that SS3 and SS6 were selected as
sampling points due to their location with respect to prevailing winds and seclusion from roads
and other activities, but it is still not clear why the sampling points were not closer to the landfill.
It seems to us that this is an avoidance of responsibility for measuring PCDD and PCDF, inparticular after the great fire, having in mind that incineration of waste in open fields is one of
the major sources of PCDD and PCDF.
The answer to this comment is part of the answer for the comment no. 36.
37. Compare the position of SS3 and SS6 with the prevailing winds map.
The answer to this comment is part of the answer for the comment no. 36.
38. Since it is stated that “the sampling was conducted on 29 March 2018 by “Anahem” laboratoryfrom Belgrade, at 10 measuring points – 7 for soil and 3 for sediment. Samples were analyzed
to establish physical-chemical and micro-biological parameters by the same laboratory, while
detection of asbestos, at 5 out of 10 points, was conducted by laboratory Institute “Mol” fromStara Pazova, who and within what investigation sampled polychlorinated dibenzodioxins anddibenzofurans on 15 March?
The answer to this comment is part of the answer for the comment no. 36.
39. For PM10, NOx and Benzene there is no space for annual emission increase! It is utterly
irresponsible to approve the construction and build a new source of pollution with the current
values of pollutants not being reduced. Whose responsibility is it and what plan will be applied
if benzene levels from vehicles is not reduced?
The answer stated that air quality is not the same as emissions to air.

19

Therefore, as part of the Study, comprehensive air quality model was developed to assess theactual impact of the facilities given the site topography, daily weather conditions, and calculationof all pollutant sources, such as traffic on the site – Each performed dispersion modelling program
lasted 5 days.
The model was based on the current design which complies with the valid Industrial Emissions
Directive (IED) 2010/75/EU in terms of emission limit, that is, currently applicable legal
regulations.
At the time of EIA and Preliminary Design development, the officially adopted BREF for waste
incineration was from August 2006; and the same version is still effective.
Results of this modeling show that:-All Serbian standards in the field of air quality are complied with (including SO2 / NO2 / Dust –PM10 / CO / Benzene / Metals, such as lead)- Concentrations of air pollutants are:• Significantly below Serbian standards on air quality:- Concentration of SO2 = 42 times less than Serbian standard- Concentration of Pb = 33 times less than Serbian standard• And/or with marginal contribution compared with very high baseline value- NO2 – 9% of additional contribution compared with baseline value- PM10 = <1% of additional contribution compared with baseline value
Therefore, new BAT standards will not affect the above conclusions.
As regards benzene emissions from vehicles, emission per vehicle will automatically reduce, as
new vehicles manufactured will use advantages of new/better technologies; even if EURO 5 and6 thresholds won’t be introduced with the same speed as in the EU countries, mechanical effectof car renewal will result in less polluting cars in Belgrade.
40. Waste management: “Stabilized material will be in a solid form, thus preventing release to air
and the process will bind heavy metals, thus preventing penetration of substances into soil
and water environment.”
The answer to this comment is part of the answer for the comment no. 42.
41. Here it should be described where it will be taken, and how concrete erosion will be prevented.
Concrete-stabilized ash is not permanently stabilized, it is expected after several years to start
releasing compounds into soil and water.
Stabilization of APC residues is recognized in the EU as the best available technique (BAT) since
BREF for Waste Management exists.
Stabilization of APC residues with hydraulic binder was developed in France 1993 and confirmed
for application by Regulation from 31 December 1992 / 1 April 1995 and it is applied at 5 locations
in France to enable the acceptance of APC residues (also for all hazardous particulate waste) at
landfills. This stabilization process has been applied at 13 locations in total in France since 1 April
1998.
This process involves reducing the solubility of waste (soluble fraction) to the threshold set undervalid regulation and crystalizing salts and heavy metals in a stable form for a long-term period.
Up to date, more than 10 MT of waste has undergone this procedure, and almost 5 MT of APC
residues has been stabilized and stored over almost 25 years.
2042. Rehabilitation of the old landfill is not part of this project, therefore reduced emission of
methane from the landfill cannot be seen as an advantage of this project. The project
developer needs to decide what the subject of this Study is, because it is irresponsible tojuggle with positive effects of one process, and ignore (cumulative) effects when it suits him.
Rehabilitation of the old landfill is not part of this Study, but extraction and utilization of landfill gas
after having passed previously built degassing wells (“biotrns”) is.
43. What are the assumptions for avoided emissions? They are very high, so it seems to be
assumed that coal would be an alternative, and they are the same until 2075. It cannot expect
for coal to be an alternative all way until 2075 because at the EU level it is planned to reduce
emissions from the energy sector to zero by 2050. This comparison is unrealistic and harmful.
The answer stated that it is free interpretation and not relevant for the Study.
44. The new BAT Conclusions on Waste Incineration requires monitoring of following emissions
to air: continuously of NOx, NH3, SO, SO2, HCl, HF, dust, Hg, and TVOC, with N2O andBenzo[a]pyrene once every year and As, Cd, Co, Cr, Cu, Mn, Ni, Pb, Sb, Tl, V, PBDD/F, anddioxin-like PCBs once in every six months. The Study states that only NOx, SO2 and dust will
be monitored. The operation of the plant, if its construction approved, should be monitored inaccordance with the BAT Conclusions.
The answer stated that monitoring will be completely organized in keeping with legal regulations,and regularly controlled by inspection, in a way all other industrial facilities are controlled in the
country.
The monitoring plan will be also defined in detail in documentation which will be prepared for
obtaining IPCC permit, and then approved by the Ministry after trial period and prior to issuing of
the Exploitation Permit.
45. How is it planned to monitor dioxin and furan emissions, as in Serbia there is no laboratory
conducting such analyses?
The answer stated that monitoring of dioxin and furan emissions will be carried out in keepingwith legally defined obligations, by applying standard procedure of sampling and analysis. At thismoment, in Serbia, there are laboratories accredited for sampling, but not for determining theconcentration of these compounds in gases. According to regular practice in Serbia and EU(representatives of cement industry in Serbia which use waste as alternative fuel also implement
this practice), samples will be taken by accredited laboratories and then, in a standard definedway, will be sent to an accredited laboratory abroad which will conduct analysis and deliver anofficial report. This situation is not uncommon in many countries.
Also, this does not mean that some of laboratories in Serbia won’t be accredited in future.
Laboratories undergo an accreditation process every year, and the scope of accreditation is not
the same every time.
46. The new BAT Conclusions require to test water from FGC every month and ashes once every
three months, in order to check whether waste is completely incinerated. The Study does not
mention any of these requirements!
The answer to this comment is part of the answer for the comment no. 45.
47. How is it proposed to prevent diffuse dust emissions during extraction and storage ofincineration ash?
The answer stated that dust created during the EfW process (that is, in the furnace / boiler) is
extracted using bag filters. Dust is then collected from storage under the bag filters into silos for21

residues through enclosed residue transport system. Hot, burnt out bottom ash is discharged fromthe lower end into a water-filled ash discharger, where it is quenched at 80-90°C, thus enabling
to extract bottom ash without dust and without odor. In IBA zone for treatment and storage(outside), water is sprayed over the bottom ash if becomes dry due to weather conditions to avoid
spreading of dust.

Comments submitted by Bird Protection and Study Society of Serbia
1. The Institute for Nature Conservation of Serbia states in its issued Decision that the scope of
amendments to the Plan does not cover important ecological areas and ecological corridorsof international importance of the ecological network of the Republic of Serbia. However, thementioned Plan for which the Decision has been issued actually falls into a bird importantarea, that is, the area of ecological network “Confluence of the Sava and the Danube rivers(RS017 IBA)”, that is, parts of the following plots 2669/2, 2669/11, 512/2, 512/3, 513/2, 512/1,
514/4, 513/1, 538/1, 538/3, 538/4, 539/1, 539/2, 538/2, and 2670/3. At the same time, thePlan itself states that the area of the ecological network “Confluence of the Sava and the
Danube rivers (RS017 IBA)” is covered by its scope (Section 3. Legal and planning basis,
page 5). The Decision issuing authority disregarded this, and for this reason the document
does not contain, but should have requirements that would prescribe obligations to determine
the properties of the site with regard to strictly protected and protected species, particularly
since such conditions are prescribed for other aspects of natural values in point 3), stating theobligation to determine the geological, hydrogeological and hydrographic properties of thesite. Likewise, in analogy with point 30), which stipulates that if the contractor, during works,
encounters geological-paleontological documents or mineralogical-petrological structures,
which are presumed to have the property of a natural good, the contractor is obligated to
inform the Ministry of Environmental Protection and take appropriate measures, we consider
that it is also necessary to stipulate such an obligation in the case of finding strictly protected
species when undertaking the environmental impact assessment study. The basis for this isin the Law on Nature Protection (“Official Gazette of the RS”, nos. 36/2009, 88/2010, 91/2010- corr., 14/2016 and 95/2018 - other law), which states in Article 4 (1) 27) that protected natural
goods include strictly protected wild species.
The comment is not addressed to the organization which undertook the Study, but to theorganization which issued the requirements.
2. In addition, the planning basis – the General Regulation Plan of the building area of the local
self-government unit – Unit XX, Municipalities of Grocka, Palilula, Zvezdara and Voždovac –(settlements: Kaludjerica, Leštane, Boleč, Vinča and Ritopek) – Text (“Official Journal of theCity of Belgrade”, no.66/17) states that its scope include Environmental unit Vinčanska pond
- (recorded natural good), which is part of the ecological network area, with an area of about
71.0 ha, as visible in the drawing as well, where the area of the ecological network in thescope of Amendments to the Detailed Regulation Plan of “Vinča” Sanitary Landfill is evenlarger than the area on the above listed plots on which the “Confluence of the Sava and the
Danube rivers (RS017 1VA)” is sited. Among the acts listed in the legal basis in the decision
issued by the Institute for Natural Conservation of Serbia there is no Regulation on Ecological
Network (“Official Gazette of the RS”, no. 102/2010), which is the reason why the Decision22

does not contain requirements specifying protection measures for the ecological network, i.e.
protection measures for the protection zone listed in Annex 3 to the Regulation.
The comment is not addressed to the organization which undertook the Study, but to theorganization which issued the requirements.
3. In view of the above mentioned, we consider it necessary for the INCS to issue a supplemental
decision on requirements, which would constitute a framework for mandatory site
investigations (pursuant to the Law on Environmental Impact Assessment and the Rulebook
on Scoping of the Environmental Impact Assessment Study), in order to appropriately collectdata on natural values of the area - protected species as protected natural goods, ecosystems
being part of the ecological network, on which the project can have an impact (either this or
its next phase, which is not the subject of the study, falls into the area of the ecologicalnetwork) in the environmental impact assessment study of the project, as well as to propose
measures to prevent, reduce or offset effects.
Also, we consider unacceptable and contrary to the Law on Environmental Impact
Assessment the practice that data on the site, environmental factors, potential impacts, etc.
which would be substantially complementary to the study, is collected after the completion of
the environmental impact assessment process.
The comment is not addressed to the organization which undertook the Study, but to theorganization which issued the requirements. Site investigations have been carried out from theend of 2017 to the present and the Study was created in accordance with investigation
conclusions. Some investigation results were not included in the text of the Study which was madeavailable for public consultation only for the reason the document was in the procedure and it was
not possible to amend it, with the scope of investigations presented in that version of the document
being in accordance with the requirements specified in the legislation of the Republic of Serbia.
The Study has been supplemented with information that was not presented in the first version of
the document.
4. The listed plots and the drawings in the Study (in several places, starting from the front page)
do not coincide, so it is not clear whether the omitted plots (referring to the communal pathleading to the Vinča pond) are part of the project or not, though the Study states that they arepart of the Detailed Regulation Plan on the basis of which the requirements were obtained
from the INCS. Whichever of these two cases is, particularly given the phase of the project
involving the construction of retaining structure and lagoons and water treatment plant, it isnecessary to present the impact on nearby important ecological areas since the impacts do
not end at theoretical boundaries of the area covered by the plan.
The plots listed in the studies are plots defined by the Location Requirements and represent the
only plots on which the facilities defined by the projects, for which a building permit will be issued
and for which these two environmental impact assessment studies have been undertaken, will bebuilt. The rehabilitation of the existing landfill is not the subject of the environmental impact
assessment study and the problem of rehabilitation is solved through the Existing Landfill
Rehabilitation Project, according to the legislation of the Republic of Serbia. The said
Rehabilitation Project was approved by the Ministry of Environment in July 2019.
5. The research cited in the Study conducted by the Bird Protection and Study Society of Serbia(BPSSS) refers to only one-day field visit to the existing landfill and its surroundings in spring2018 and as such it cannot be considered sufficient to show “baseline state” for the purposesof the environmental impact assessment study, as BPSSS, which developed the report,
responsibly claims. The report (as it is titled) is preliminary and should serve as an outline of23

a project task that would be implemented following what BPSSS, as a member of BirdLife
International, considers good practice for assessing the impact of large projects, especiallywhen it comes to ecological network sites or protected species for which the same sites aredesignated as such. Since the proposed research was not conducted and there is no data in
the Study in support of other bird research at all, and it concerns only a small fragment of theannual, i.e. seasonal changes of the ornithofauna at the Vinča landfill, “which together with
the nearby areas of the ecological network is known as one of the largest aquatic bird
gathering sites in Serbia (and among larger seagull gathering sites in the region), BPSSS
considers this partial presentation to be an example of erroneously or incompletely
established factual situation and as such constitutes the basis for challenging a possible
decision approving the study.
The answer stated that for the purpose of conducting the environmental impact assessment study,in the aforementioned wider area of the Vinča landfill, bird monitoring was carried out throughout
one calendar year, within 4 campaigns. Relevant ecological data on locally distributed species
and specificities associated with the subject area was collected.
Preliminary research was conducted in April 2018 (Bird Research at the Vinča Landfill,
Preliminary Report, Bird Protection and Study Society of Serbia, Novi Sad, April 2018, authors M.
Šćiban, N. Stanojević). It was followed by several studies: in September / October 2018 (Birdstudy at the landfill and its surroundings Vinča, Belgrade during the bird migration from September
to October 2018, October 2018, League for Ornithological Action of Serbia, author: D. Simić) and
December 2018 (Bird study at the Vinča landfill and its surroundings in Belgrade in December
2018, January 2019, League for Ornithological Action of Serbia, author: D. Simić). In October
2018, the available literature and field data were summarized in the Review of previous birdobservations at the Vinča landfill and surrounding areas (published by Dragan Simić, League for
Ornithological Action of Serbia).
Monitoring of bird populations continued during May and June 2019 (Study of Bird Breeding at
the Vinča landfill in Belgrade in the period May-June 2019, Preliminary Report, July 2019, D.
Simić, M. Raković).
A summary of the results of these studies is presented in the supplemented Study.
6. For these reasons, we are of opinion that the Study cannot be approved, that the Study failed
to fulfill the obligation to conduct comprehensive research of all aspects of the environmenton the site (the time period of one year was available for that), and to collect data on thecurrent state, failed to present the actual cumulative impact with other projects or phases of
implementation of the same project even when a request for screening (determining whether
the study is required) or scoping of the study was made, as well as alternative solutions incase the impact on aspects of natural values observed during this new research is not
acceptable (the possibility that the study does not even take into consideration), and if so,presents precise measures to prevent, reduce and offset effects, for which other parties
concerned will have the possibility of timely access and opinion.
The stated view is false and represents a personal view on the need to reject the study, and it
was created by unilaterally observing the issues without essential understanding of the technicalsolutions and mutual relation of all described environmental factors, stated measures andlegislation defining the next phases in implementation and operation of an infrastructure projectin accordance with legal regulations governing environmental protection and planning andconstruction.
24

Comments submitted by “Center for Ecology and Sustainable Development”, Subotica
1. In our opinion, it is not possible to separate the impact assessment of the power plant and thelandfill, as they are interconnected, the energy-from-waste plant is proposed to be fueled bywaste, but also to produce bottom ash (ash and slag) which will be disposed into the landfill
body, thus creating permanent and massive pollution effects with bottom ash. The issue ofprotecting the ash from scattering and polluting the environment has not been successfully
solved even in EPS plants in Kolubara, Kostolac and Obrenovac ash disposal sites, and we
see no good reason why it would be considered possible to solve this issue here in a morefavorable way.
The answer stated that the Law on Planning and Construction allows projects to be implemented
in phases. Accordingly, in order to obtain requirements and approvals of holders of public powers,
two environmental impact assessment studies have been undertaken, as well as the Project of
the existing (old) landfill body rehabilitation and remediation. In keeping with legal regulations,public consultation and presentation of the Environmental impact assessment study of the power
plant and new landfill with accompanying facilities were carried out. The Study shows technicalsolutions and appropriate protection measures from the aspect of reducing air pollution causedby diffuse emitters from the relevant complex.
2. In our opinion, it is unacceptable to start designing the plant applying the old BAT documentfrom 2006, since Serbia, as a member of the Energy Community of South East Europe isobliged to apply latest BAT precisely because the plant when this BAT becomes effective still
does not have permits required to consider the design process completed.
The answer stated that the current project (design) meets the requirements in terms of emission
limit values defined under the Emissions Directive (IED) 2010/75/EU. At the time of preparing
ESIA/EIA documents, the officially adopted BREF for waste incineration was the BREF document
adopted in August 2006, and the same version is still effective. All installations falling under the
Industrial Emissions Directive 2010/75/EU should comply with the requirements of an official
document adopted by the European Commission. Therefore, in the ESIA/EIA documents,
comparisons were made with the only currently valid and obliging emission limit values from waste
incineration, namely the 2006 BREF. Theoretically, if in the coming period, including the period
after the EfW plant is built, other document defining emission limit values/BREF becomes
effective, the project will, if not (which nobody states) inevitably be complied with the newrequirements which the Government of the Republic of Serbia decides to transpose and adopt as
criteria defined through Serbian legislation.
The proposed energy-from-waste plant includes technological solutions and design choice whichwere designed in a way to enable possible necessary changes and adjustment in line withpotential future new BREF requirements, which may be transposed in Serbian legislation.
3. We think that alternative scenarios were not properly assessed and that an attempt to present
the need for incinerator as inevitable cannot actually be considered valid especially whentheoretically proposed required quantity of waste (over 340,000t per year) is taken into
account, implying that this plant will, instead of solving the issue of emissions from the landfill,
actually produce significant additional amount of greenhouse gases, thus affecting theimmediate environment with dangerous gas and other emissions and establishing technology
in conflict with climate targets as well.
One of alternative methods of municipal solid waste management is its energy use by thermal
procedure. Valid legal regulations do not prohibit the application of the mentioned method, ofcourse, with defined restrictions and appropriate measures of environmental protection, human25safety and health, as well as for any other technical solution. The Study shows, among otherthings, technical solutions for reducing green gas emissions.
On the other hand, an environmental impact assessment study is undertaken for a precisely
defined project based on a Preliminary Design (PD) developed in accordance with specially
issued location requirements for the elaboration of technical documentation and connection for a
specific Schematic Design, issued by the competent authorities (Article 12 of the Law on
Environmental Impact Assessment, “.the request referred to in paragraph 2 of this Article shall be
enclosed with the following documentation: 2) preliminary design, i.e. excerpt from preliminary
design ... 4) requirements and approvals of other competent authorities and organizations
obtained in accordance with a separate law ..”) . Therefore, based on the Law on Planning andConstruction, it is not possible to consider several completely different project solutions at thislevel of development of technical documentation.
What can be done only is to describe alternative solutions which were considered at previous
levels of technical documentation preparation, which has been done in this Study, or to present
alternative measures which may be implemented, as defined in Article 2 of the Law on
Environmental Impact Assessment “environmental impact assessment means a prevention
measure of environmental protection, based on the elaboration of a Study, and conducting of
public consultations and analyses of alternative measures, with the aim of collecting data, andforecasting adverse effects of specific projects on the environment and human health, flora andfauna, soil, water, air, climate and landscape, material and cultural resources and cumulative
effects of these factors, and of determining and proposing measures that may be implemented toprevent, reduce or offset such adverse effects, having in mind the feasibility of these projects(hereinafter: impact assessment)”.
Alternative solutions are described in Chapter 4 of the Study.
4. In our opinion, it is necessary to start establishing such a waste management plan which will
respect the so-called waste hierarchy, by closing the landfill currently operating in Vinča,
provide complete landfill gas exhaustion from this landfill, and at the same time start solving
the separation of recyclable and compostable waste in the future, thereby eliminating need
for waste incinerator. We also think that this plant (energy-from-waste plant) will endanger thenational goals of EU accession due to distorted strategic orientation towards recycling,
reducing waste disposal. This project will, in our opinion, artificially generate the need for
waste import as it was already several time repeated during the public debate on the necessityof this project.
The answer stated that this project is not in collision with the National Waste Management
Strategy nor principles of waste hierarchy. Primary selection and secondary separation ofmunicipal solid waste is under competence of local government. The project and theEnvironmental Impact Assessment Study do not state the need for importing municipal or any
other waste.
In the study, Chapter 3.2 states as follows:This statement is not correct. Please see Chapter 3.2. of the EIA Study for the landfill:
Waste Management Hierarchy (Waste Management Law):- Prevention- Preparing for reuse- Recycling- Other recovery operations (recovery for energy production, etc.);- Disposal.

26

Prevention of waste generation in the City of Belgrade is conducted through activities defined at
the national level, and is reflected in, primarily, through applying the principle of cleaner production
concept, circular economy, defining by-products, end-of-waste status, and other. Intense efforts
have been made to raise the population awareness about the importance of prevention for over
10 years.
Preparing for reuse and recycling start with relatively well-organized primary selection system
which operates in the City of Belgrade. Primary selected secondary raw materials are collected
through a wide network of secured and placed collection dumpsters in the city of Belgrade.
Primary selected secondary raw materials are transported to existing municipal waste collection
centers where secondary separation is carried out at the separation line (Ada Huja, New
Belgrade).
Decision of the Mayor of Belgrade no. 501-4180/16-G dated 17 June 2016 determined locations
for establishing new waste collection centers - recycling centers and transfer stations. The City ofBelgrade budget for 2019 allocated funds for the procurement of equipment and equipping of two
more recycling centers with a separation line and other necessary equipment. Recycling centers
also collect special types of waste pursuant to the Law.
The 2019 Budget also provided for the procurement of additional dumpsters for the separate
municipal waste collection system (paper, plastic, metal, glass, mixed municipal waste), additional
underground dumpsters, numerous machinery and vehicles for waste collection and collection ofsorted secondary raw materials, roll-off dumpsters, baling presses with a capacity of 100 t, withthe aim of upgrading the existing system and expanding the coverage of the territory with a waste
collection service.
Procurement contracts are made between suppliers and PUC “Čistoća”. This construction projectof new landfill and other facilities also proposes the installation of a construction waste treatment
line.
Other recovery operations (energy recovery from waste, etc.). The landfill is to be built at the sitewhere the existing landfill is already located at which the entire amount of collected mixed
municipal waste is disposed. Instead of such a solution, the project involves a modern energyfrom-waste plant, as well as a biogas plant using landfill gas from the body of existing and new
mixed municipal waste landfill.
In the future, in the City of Belgrade, only amount of mixed municipal waste remained after primaryand secondary waste selection, recovery and treatment at construction waste treatment plants,
energy recovery from waste and energy recovery from landfill gas, as well as after separation ofgreen waste from the maintenance of green spaces and cutting down of trees done by PUC“Zelenilo” at special locations, will be disposed.
5. Due to extreme risk of air pollution from this plant, we consider that it is not acceptable topropose only periodic air quality measurements.
The statement is not true. The Environmental Impact Assessment Study proposes continuous,control and periodic measurements of air quality, in keeping with valid legal regulations.
6. We think that it is necessary to determine the danger from ash which will be produced andsince this ash is a necessary by-product of this plant operation, it is not acceptable to adopt
this study until it shows in detail amounts, dispersion models and potential effects of bottom
ash content on the environment and health.
27

The answer stated that dispersion modeling of particulate matter was carried out and presented
in the Environmental Impact Assessment Study. Bottom ash from the EfW plant shall be disposed
into newly designed cells in keeping with valid legal regulations and EU Directives.
7. We think that benefits of reducing GHG have been overstated given that there is much greater
potential for savings in the case of establishing the waste reduction system, composting, and,in general, the principle of cyclic approach to resources.
Benefits from GHG reduction are not overstated and they have global importance. The relevant
project is not inconsistent with the establishment of the waste reduction system and principles ofcircular approach to resources.
8. The issue of measurement and protection from dioxins and furans has not been adequately
addressed in the Study.
The answer is given in Chapter 3.2.6.1. of the Study.
9. Given the enormous adverse impact this plant could have on national EU accession process,we believe that better solution is to use landfill gas with closing the old landfill and establishingsuch a Waste regulation system which will not allow Serbia to practically forever rely on
burning municipal waste with simultaneous uncontrolled production of dangerous bottom ash.
This statement is not true. The project proposes the extraction of landfill gas from the existing
landfill body and its valorization, including the closure of the landfill.
Suggestions regarding subchapters containing description and status of flora and fauna,biodiversity, natural goods of particular importance, (protected) rare and endangered plant andanimal species and their habitats and vegetation, the impact assessment of the project on theliving world, natural values and protected natural goods have been accepted in the Study. The
mentioned parts are a little better addressed in the revised Study, scientific names of plants andbirds are revised, IBA (Important Bird Area) “Confluence of the Sava and the Danube rivers”,
RS0171BA, which is an integral part of the Serbian ecological network, is more adequately
described.

Comments submitted by Petar Denčić from Belgrade
1. General aspect: 1. Sustainable development: the project represents an activity sitting at thebottom of the waste management hierarchy. The proposed project adversely affects thefollowing sustainable development goals:
This statement is not true, given that Chapter 3.2 of the Study for the landfill project contains:
Waste Management Hierarchy (Law on Waste Management):-

Prevention
Preparing for reuse
Recycling
Other recovery operations (recovery for energy production, etc.);
Disposal.

28

Prevention of waste generation in the City of Belgrade is conducted through activities defined at
the national level, and is reflected in, primarily, through applying the principle of cleaner production
concept, circular economy, defining by-products, end-of-waste status, and other. Intense efforts
have been made to raise the population awareness about the importance of prevention for over
10 years.
Preparing for reuse and recycling start with relatively well-organized primary selection system
which operates in the City of Belgrade. Primary selected secondary raw materials are collected
through a wide network of secured and placed collection dumpsters in the city of Belgrade.
Primary selected secondary raw materials are transported to existing municipal waste collection
centers where secondary separation is carried out at the separation line (Ada Huja, New
Belgrade).
Decision of the Mayor of Belgrade no. 501-4180/16-G dated 17 June 2016 determined locations
for establishing new waste collection centers - recycling centers and transfer stations. The City ofBelgrade budget for 2019 allocated funds for the procurement of equipment and equipping of two
more recycling centers with a separation line and other necessary equipment. Recycling centers
also collect special types of waste pursuant to the Law.
The 2019 Budget also provided for the procurement of additional dumpsters for the separate
municipal waste collection system (paper, plastic, metal, glass, mixed municipal waste), additional
underground dumpsters, numerous machinery and vehicles for waste collection and collection ofsorted secondary raw materials, roll-off dumpsters, baling presses with a capacity of 100 t, withthe aim of upgrading the existing system and expanding the coverage of the territory with a waste
collection service.
Procurement contracts are made between suppliers and PUC “Čistoća”. This construction projectof new landfill and other facilities also proposes the installation of a construction waste treatment
line.
Other recovery operations (energy recovery from waste, etc.). The landfill is to be built at the sitewhere the existing landfill is already located at which the entire amount of collected mixed
municipal waste is disposed. Instead of such a solution, the project involves a modern energyfrom-waste plant, as well as a biogas plant using landfill gas from the body of existing and new
mixed municipal waste landfill.
In the future, in the City of Belgrade, only amount of mixed municipal waste remained after primaryand secondary waste selection, recovery and treatment at construction waste treatment plants,
energy recovery from waste and energy recovery from landfill gas, as well as after separation ofgreen waste from the maintenance of green spaces and cutting down of trees done by PUC“Zelenilo” at special locations, will be disposed.
2. Quality education – numerous generations have been educated for environmental
preservation and resource protection, that recycling is the way to achieve it, and incinerationin this case provides justification for a negative attitude of the population towards theirenvironment.
The answer to this comment is given in the answer for the comment 1.
3. Affordable and clean energy – it is proposed to subsidize energy generation, which transfers
the cost of production to all citizens. Generating energy from waste is considerably more
expensive compared to other forms of energy generation.
29

Not the subject of the Study.
4. Industry, innovation and infrastructure – the project development includes CO2 emission in
the air and contribution to the climate change, thus affecting economic and social developmentin Serbia. The project negatively affects the innovation process as it puts pressure on theeconomy in terms of increasing production inputs.
The answer stated that the impact on climate change is presented for the entire project proposedat the site of Vinča landfill complex and it covers all relevant facilities, as follows:-

Cogenerated plant using municipal waste and landfill gas
New landfill
Existing waste landfill after its closure, remediation and recultivation.

Please view the following chapters of the Study:-

Chapter 6.3 – Impact of the project on climate change of the Study
Chapter 6.4 – Other potential risks and impacts (Impact of the project on climate change) of
the Study for the landfill

Those chapters clearly explained and demonstrated that:“The project will positively affect greenhouse gas emission, owing to generation of electricity andheat energy and major reduction of CO2 emission from the old landfill.”
5. Sustainable cities and communities- the project affects the pollution of the city and the creationof jobs which will not negatively affect resources.
Covered by the Study, Chapter 5.1 and other chapters
6. Responsible production and consumption – the project will contribute to a decline in economic
activity due to consumption of non-renewable resources, the impression of further indivisibility
and inefficiency of production processes and competitiveness on the market.
If we accept the definition that sustainable energy is providing energy that that meets the needsof the present without compromising the ability of future generations to meet their own needs,
which is replenishable within a human lifetime and causes no long-term damage to theenvironment.
Considering the nature of municipal waste and the conclusion from the EIA Report showing that
demonstrated technology and solution will be applied with limited impact on the environment, we
confirm that the proposed projects provide sustainable energy solutions for the population ofBelgrade thanks to electricity and heat these projects generate.
Also, see the answer to the comment no. 1.
7. Climate action – available solutions which are affordable and adjustable enable communities
to move forward cleaner and greener energy. The project with its negative impact, primarily
on climate, moves the city away from acceptable economic models.
The answer to this comment is part of the answer for the comment no. 4.
8. Sustainability: the project is not complied with the EU commitment defined in the EU Action
Plan for the Circular Economy. The Study takes as an example EU Directives which are basis
for national legislation as well. These EU Directives are being amended and adjusted to therequirements specified in the EU Action Plan for the Circular Economy which involve major
reductions in waste generation, 100% of recyclable plastics by 2030 and full application of the30waste management hierarchy. The Waste Management Strategy of Serbia mentions“establishment of economic instruments and mechanisms necessary in order to ensure thesystem for investments into long-term sustainable activities”. Serbia, as a candidate countryfor EU membership, will have to adjust to the requirements of the Circular Economy. The
proposed project represents an activity form the domain of linear economy.
This statement is not true.
The National Waste Management Strategy 2010-2019 (2010) and Proposal of Waste
Management Strategy 2015-2030 (planned for 2016) establish the framework for final waste
reduction and sustainable waste management. The Proposal of Waste Management Strategy
2015-2030 proposes following targets:••••

Reduce disposal of biodegradable waste at landfills by 25% by 2022, 50% by 2026 and 65%
by 2030;
Achieve at least 60% of reuse and 55% of recycling of packaging waste by 2025;
Achieve at least 50% of recycling of municipal waste by 2030;
Improve the specific waste streams management system (waste tires, used batteries, wasteoils, waste vehicles) to achieve 4 kg per capita of separately collected waste vehicles by 2019
and at least 45% of batteries and accumulators by 2016.

The Energy-from-waste plant is planned for 340.000 t/y, covering only 67% of projected residual
waste or compared to a total solid waste quantity of 750.000 t/g, including waste to be recycled
and composted, only 45% of the projected waste in 13 municipalities covered by the project for
Belgrade. As there is no plan for other waste in power plants in Serbia at this moment, this
proposed project does not hinder the capability for Serbia to achieve the above mentioned targetof 50%. More importantly, achieving this target highly depends on the separate collection system
which is out of the project scope. Achieving the collection rate will be subject to establishing anadequate collection system by the municipality which is out of the scope of this project and these
EIA studies. According to the PPP Contract, there is no concept of minimum guaranteed tonnage
to be delivered by the City.
The City of Belgrade is currently conducting a procedure for selecting a consultant to develop
Local Waste Management Plan 2021-2030, in order to continue establishing the system andorganization for managing municipal, inert and non-hazardous waste in a manner which ensure
minimum risks and dangers for the environment and conditions for waste generation prevention,
reuse and recycling of waste, use of useful properties of waste, disposal, if other adequate
solution does not exist, as well as raising awareness about waste management.
Also, the Ministry of Environment is in the process of drafting the Waste Management Strategy
2020-2029.
Also, see the answer to the comment no.1.
9. Special aspects:
Adverse impact on soil, groundwater, watercourses and their self-purification ability. Loadgenerated in the old landfill body remains to negatively affect the environment by continuing to
use the landfill for gas extraction.
This statement is not correct at all, namely the truth is completely opposite of what is stated. The
Study clearly defines that one of the project major benefits is control and improvement of the31

quality of effluent currently discharged into the environment, in keeping with all legally defined
standards, and above.
The existing landfill body will be rehabilitated according to the Existing Landfill Rehabilitation and
Recultivation Project which was approved by the Ministry in July 2019; landfill gas will be in acontrolled way extracted from the body of the old and new landfill, and used, surplus of leachate
will be in a controlled way extracted, all leachate will be treated by the wastewater treatment
system prior to discharge into the environment.
10. Incineration residues, particularly their most toxic components, represent a new load on theenvironment and hard-to-solve ecological problems. The new (sanitary) landfill proposed on
the Vinča site, immediately next to the old landfill, represents an additional load which will be
impossible to control due to unrehabilitated old landfill.
The statement is not correct. Please see a part of the text describing mutual position and relation
between the existing and the new landfill, but also the project of construction of sanitary landfill
with all elements of protection from external impacts.
11. Geological and hydrogeological investigations state not enough collected data over a longer
period of time. The map is hydrogeologically unsuitable for the project.
As regards the comment that the soil is unsuitable for the project, the situation is actually opposite
as low water permeability of the soil is extremely suitable for the development of the proposed
infrastructure involving the New Landfill.
An important parameter for the Vinča landfill is the permeability of soil beneath the landfill bottom
which can modify the infiltration rate. Infiltration values have been measured within old and recent
studies conducted on periphery of the site at several locations upstream and downstream of thelandfill. Based on geotechnical investigations carried out on periphery of the disposal site,
maximum and minimum permeability values are 10-8 and 10-9 m/s, respectively. Permeability
can be further reduced by taking into account a clogging phenomenon that is often observed on
surfaces of ponds. Another phenomenon is the possible and probable saturation of the soil withwater beneath the landfill bottom, which prevents further infiltration and thus creates an artificiallyreduced permeability value.
The shown data is part of the “Geological - geotechnical study for engineering and constructionof the new landfill and rehabilitation of the existing solid municipal waste landfill Vinča”(ENERGOPROJEKT HIDROINŽENJERING a.d. Beograd, December 2017) and other mentioned
technical documents the results of which are impossible to show all in the environmental impact
assessment study, but they are certainly attached to it as required documentation in the procedureof obtaining construction permit and represent basic data in design development. Their content
and results are certified with signature and seal of responsible persons; so it is a little irresponsible
to make arbitrary criticism without thorough inspection of the content of these studies and project
documentation in the entirety.
12. The project will adversely impact on water supply to the population of Vinča settlement, which
are supplied with drinking water from the Danube River, into which wastewater from the
project site will be discharged.
The answer to this comment is part of the answer to the comment no. 9. Also, see therequirements issued by the Public Utility Company “Belgrade Waterworks and Sewerage”, issued
in the integrated procedure, no. V-163/2019 dated 13 March 2019 and no. V-2016/2019 dated 26
March 2019.
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13. Leachate and seepage from the landfill have a direct contact with the Ošljanska pond which
is a part of the special importance area “Confluence of the Sava and Danube rivers”.
The statement is not true. Once the proposed project is completed, only treated leachate withquality in compliance with valid Serbian regulations will be discharged directly into the Ošljanski
creek.
14. Proposed remediation of the terrain will affect other neighboring areas, primarily IBA. Due tothe mobility of the fauna, loads can be put on other ecosystems. No genetic studies on floraand fauna situation is mentioned.
The answer is provided in Chapters 5.5 and 6 in both Studies.
15. The project will have negative effects on the population health. Belgrade stands out in Serbia
by the highest mortality rate, due to primarily industrial facilities and traffic. The project will
have an increasing effect on these two types of pressure.
The Study concluded that project’s impacts are not expected to be of such magnitude they could
cause significant cumulative effects. It is demonstrated in detail in Chapters 6 and 7of the Study.
16. The project is of unlimited period and does not contain provisions on action after thedecommissioning.
Conclusion: numerous negative effects at the given site and project unsustainability for alonger period represents a basis for negative evaluation of the Study.
In developing documents for obtaining the integrated permit (IPPC), pursuant to the Law on
Integrated Environmental Pollution Prevention and Control, the project developer shall develop
and submit a Plan of environmental protection measures after the termination of operation andclosure of the plant. An integrated permit is compulsory and obtaining the Exploitation Permit for
using the plant and landfill is conditioned on this permit, pursuant to the legislation of the Republicof Serbia.
On the basis of the above stated, the Technical Commission concluded that the reasoned
comments from the previous Report on Study Review were accepted, namely, the Study was
supplemented and amended to comply with the given comments. In this regard, the relevant
Environmental Impact Assessment Study contains all the elements based on which it can beevaluated the suitability of proposed measures to prevent, reduce or offset potential adverse
effects of the project on the current state of the environment in and around the site during the
project implementation, in the event of accidents, and upon decommissioning of the project, as
well as environmental impact monitoring programme.
The Decision and the relevant Environmental Impact Assessment Study represent an integral partof the technical documentation, in keeping with Article 18 of the Law on Environmental Impact
Assessment (“Official Gazette of the RS”, no. 135/04).
This Decision is final in the administrative proceedings.
Legal remedy: This Decision may not be appealed against. The project developer and the publicconcerned may initiate administrative proceedings by lodging an appeal to the competent court
within 30 days after receipt of this Decision, that is, from the day of its publication in the public
media outlets.
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MINISTER
Goran Trivan

Deliver to:-

Project developer-

Bird Protection and Study Society of Serbia, 6/43 Partizanskih baza Str., 2100 Novi Sad,-

Centre for Ecology and Sustainable Development, 15/13 Korzo Str., 24000 Subotica,-

Citizens' Association “Right to the City” (“Pravo na grad”), 36 Bulevar ArsenijaČarnojevića, 11070 Belgrade,-

Citizens' Association “Let's Not Drown Belgrade” (“Ne da(vi)mo Beograd”), 106 Cvijićeva
Str., 11000 Belgrade,-

Petar Denčić, from Belgrade, 316 Bulevar Kralja Aleksandra, 11050 Belgrade,-

Sector for Environmental Monitoring and Prevention-

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