After the public presentation of the impact assessment study of the galvanising facility within Hansgrohe Ltd., which was held on May 20 in Valjevo, we expect the Ministry of Environmental Protection and the Ministry of Construction, Transport and Infrastructure to fully ensure the implementation of the laws that regulate the construction of facilities and environmental protection. We ask the competent authorities of the Republic of Serbia to clarify as soon as possible the dilemma that was not clarified at the public presentation: did the investor Hansgrohe Ltd. in Valjevo already build a facility for galvanising without approval of  the environmental impact assessment study and without a construction permit? Was the public hearing aimed at involving the public in the decision-making process or was it an attempt to cover up illegality?

Who is informed and who is not?

The public consultations were scheduled during the holidays, and the public presentation was postponed several times, so that the public was prevented from being informed in a timely manner about the date of the presentation:

“Procedures are important because they protect the public’s right to participate in environmental decision-making. They protect the public from the self-willed and arbitrary actions of state authorities”, said Miloš Veljović, legal advisor at RERI, and added that “The procedure was carried out in such a way as to confuse and discourage the public from participating in environmental impact assessment procedures, so that only the most persistent ones decided to attend the public hearing on May 20. The public presentation was first scheduled for May 17, then on that day was postponed first to June 7, and then to May 20. This was published in the newspaper on Saturday, May 18. In this way, the public is not informed, but misinformed.”

Photo 1. Miloš Veljović, RERI’s legal advisor at a public presentation in Valjevo

The impact assessment procedure for the construction of a galvanization facility within the factory complex for the production of faucets of the company Hansgrohe was not carried out in accordance with the regulations, bearing in mind that it is clearly prescribed what the notification should contain and when it should be published. In addition, the Ministry of Environmental Protection continues with the harmful practice of holding public consultations and hearings during the holiday period, leaving the public unacceptably little time to become familiar with the project and point out potential negative impacts on the environment. It is worrying that this kind of practice accompanies projects that have been declared as projects of importance for the Republic of Serbia.

What did we learn at the public presentation?

Little did we learn. Representatives of the interested public reasonably pointed out numerous shortcomings of the environmental impact assessment study, demanding clarifications from the investors and the authors of the study. However, they received mostly imprecise and vague answers from the mentioned persons, such as “We will check”, “We will check, then we will let you know”, which ultimately left the participants of the discussion with even more questions. For example, to the specific question – “Is zinc present in waste gases?”, the author of the study initially answered “We will check”, but after being friendly helped by the investor, he answered in English with “No”.

When asked specifically whether the facility has already been built, which can be seen in the presented photos, the director of the Hansgrohe Ltd. factory in Valjevo replied that he “sees a box” in the photos. In the above way, the purpose of the public presentation, where the participants should exchange opinions, present objections, comments, suggestions and ask questions regarding the project to the author of the study and the investor with the possibility of receiving clear answers to them, becomes meaningless.

Is the study being developed for a facility that has already been built?

In August 2022, Hansgrohe Ltd. was issued location conditions by the Ministry of Construction, Transport and Infrastructure for the appendage of the galvanisation facility and the construction of a sports field on cadastral parcel 18722, cadastral municipality of Valjevo in the village of Popučke. In December of last year, the same Ministry rejected this company’s request for a construction permit for this project because the Ministry of Environmental Protection did not provide approval of an environmental impact assessment study of the galvanising facility. In the documentation prepared by the Ministry of Environmental Protection and published on the official website within the public consultations, an extract from the situational plan is presented, in which the future facility where the galvanising process will take place is marked with the inscription “B1.G”. By looking at the satellite image publicly available through the Google Maps application, which dates from February 2024, the lines of the object can be seen, which according to their position and shape correspond to the object marked in the technical documentation as object B1.G, intended for the galvanisation process. Photos of the disputed facility taken at the beginning of May this year indicate that the disputed facility was built at the mentioned location.

Photo 2. Google Maps satellite image showing the built facilities of the Hansgrohe Ltd. factory at cadastral parcel 18722, cadastral municipality of Valjevo

“We in Valjevo want foreign investments, especially if they come from the countries of the European Union. We need jobs and new technologies. But we also need a European business culture that implies respect for the law”, says Slavica Pantić, legal advisor of the citizens’ association Local Response. She adds that it is important to comply with the Law on Planning and Construction. “The Ministry of Environmental Protection should apply environmental regulations in the interest of citizens, and investors should not commit criminal offences by constructing without a permit,” points out Slavica Pantić. Regarding the claim that the galvanising facility has already been built, the representative of the Ministry of Environmental Protection emphasised that the assessment of the claim as to whether there are illegalities in this case will await the report on the extraordinary inspection surveillance initiated by the Renewables and Environmental Regulatory Institute and the association Local Response from Valjevo before the competent ministries.

Salami slicing

The investor Hansgrohe Ltd. from Valjevo is resorting to the already established illegal practice of dividing a single project into several smaller ones. The investor tries to show that the construction of galvanisation facility and the earlier “projects” of the construction of the plant for the production of faucets within the same production complex, on the same cadastral parcel, carried out by the same investor in the same technological and production processes, which form a single functional unit, represent separate and independent projects, for which it is possible to create two or more separate environmental impact assessment studies. The company avoids a comprehensive environmental impact assessment with phased processes and tries to illegally present the impact of the entire project and production process as smaller than it is. It is important to note that we learned at the public presentation that, “if asked”, the Ministry of Environmental Protection would prohibit the artificial separation of the project.

Numerous material shortcomings of the study

The environmental impact assessment study for the galvanising facility of the faucet factory Hansgrohe Ltd. was not prepared in accordance with the regulations because the key data that the author of the study was obliged to provide in order to determine the current state of the environment and provide adequate environmental protection measures is missing. Thus, the study does not describe the treatment of waste gases and water containing metals such as nickel, chromium, zinc and copper, nor does it describe the management of waste sludge and solid waste. In addition, there is a lack of precise data on the amount of waste generated by the operation of the plant, and the location of the waste storage facility, its capacity, and the method of storing the chemicals used are not known.

A particularly significant shortcoming is the lack of complete and precise information on the chemicals used in the production process, and safety lists are not provided for all chemicals, while for some they are provided in English and German. Since the characteristics of all dangerous chemicals used in the production process are not shown, the public cannot know whether the risk of an accident and the consequences of an accident have been properly assessed, i.e., whether adequate remedial measures have been foreseen. Finally, there are no adequate measures to avoid, eliminate or reduce the project’s impacts on the environment due to inadequate description of the technological procedure and location, inadequate assessment of air and water emissions, impact on the quality of air, surface and underground water, soil and human health.

How does factory operation affect air quality?

Data on emissions into the air from individual facilities of this faucet factory are not complete because the mentioned emitters are not connected to technological processes. Their locations and physical characteristics, as well as the total emissions of all pollutants, are not shown

The environmental impact assessment study developer of the galvanising facility on the environment, the company Envico Ltd, refers to and uses data and considers measures from the Air Quality Plan of the city of Valjevo for the period from 2022 to 2027, which was not approved by the Ministry of Environmental Protection, nor was it adopted. The study developer could not have used data on emissions of polluting substances in the air in Valjevo, since the City of Valjevo does not have an up-to-date local register of pollution sources. In addition, for the purposes of the study, extraordinary air quality measurements were not performed in the wider area where the galvanising process will take place, but data from air quality monitoring, which is carried out with the help of measuring stations installed in the centre of Valjevo, was used.

The study did not answer the question of what effects the emissions from the Hansgrohe factory will have on the air quality in Valjevo, although according to the data of the Environmental Protection Agency, as well as according to local monitoring data, the air in Valjevo falls into the third category due to the excessive annual concentration of suspended dust particles – PM10 particles.

***

Galvanising is an electrochemical process of applying a thin metal layer to the surface of an object by passing a current through a chemical solution in which the object is immersed. Castings that are galvanised in this process are produced in a foundry and then machined. Nickel, chromium and copper are used for galvanising components that come from machining and polishing processes. Cyanide is used in the process of galvanising zinc with copper. The mentioned technological processes and faucet manufacturing procedures represent a unique and indivisible production process. That is why it is not possible to organise the production of faucets if all the facilities in which the said production takes place have not been built. In response to such a complex problem, investors in obtaining urban and technical documentation and construction practice salami slicing, the artificial separation of project implementation into smaller units in order to avoid environmental impact assessment or to conceal and reduce the total impact of all parts of the project, i.e. all production processes to the environment.

The recording of the public presentation that was held on May 20 can be found at this link: https://www.youtube.com/watch?v=C4iPKw2qg6w 

ostanite toku

Prijavite se za naše objave:

Some description text for this item

RERI is the organization founded with the aim to achieve objectives related to promotion and improvement of rights to healthy and preserved environment, sustainable management of natural and renewable energy resources.
Instagram Feed

© 2023 RERI – Renewables and Environmental Regulatory Institute | All Rights Reserved

to top