Environmental permit is an administrative document that lays down measures for the protection of all components of the environment: air, water and soil. In the process of issuing the urban permit, the investor for the project which is considered to have or may have a negative impact on the environment, must first obtain an environmental permit. Issuance of the permit is regulated by the Law on Environmental Protection and the Law on Amendments to the Law on Environmental Protection, art. 54-74 or art.17-29 (Official Gazette of the Federation of BiH No. 33/03 and 38/09)

Environmental permit is issued for new installations, before they are put into operation, and prior to the issuance of the environmental permit plants must go through the procedure of environmental impact assessment. The procedure for issuing permits for existing plants and facilities that have worked before the entry into force of the Law on Environmental Protection, is prescribed by specific regulations. The operator of such plants and facilities shall prepare the activity plan prior to applying for the environmental permit, with measures and deadlines for gradual reduction of emission (pollution) and to comply with best available technologies (BAT). Plan of activities is assessed by an expert commission, and if it is positively evaluated, the competent ministry issues a permit with a validity period of five years. In the process of environmental permitting and assessment of studies on the impact on the environment, the competent ministry informs and invites the public to a public hearing.

Although the deadline for obtaining environmental permits for plants of ArcelorMittal Zenica expired in October 2008, the permits were issued with considerable delay, and without public hearing. For some plants, public hearings were held, but no one from the ministry responded on our observations, nor did we get answers to our questions sent on 17.2.2009. The activity plans and environmental permits did not contain the "zero state" of environmental pollution, so it is impossible to evaluate the effects of implemented projects.

Eco forum has performed an independent analysis of the implementation of measures in the Action Plan, based on information available to us. With the aim of deeper analysis, we organized Roundtable on "Environmental permits ArcelorMittal Zenica 2009-2014", on June 26 2014. The round table was attended by Eco Forum activists, representatives of ArcelorMittal Zenica, Zenica Municipality, the Ministry of Tourism and Environment, Government of Zenica-Doboj Canton and the Inspection Directorate of FBiH.

Federal Ministry of Environment and Tourism has formed a commission to produce reports on the implementation of certain projects in the plan of activities on the basis of which they issued the environmental permit for plants of ArcelorMittal Zenica. This report was scheduled to be completed in May 2013, but it was completed only at the end of 2013, and will serve as a basis for developing new environmental permits. Of the anticipated 200 measures, 186 of them were realized, but costs and complexity of 14 unrealized measures far exceeds implemented measures. The most expensive and most complex projects are still in the implementation phase.

Federal Ministry of Environment and Tourism has prepared a draft of the new Law on Environmental Protection of FBiH, which provides for the issuance of IPPC. In addition to truly integrated water and urban planning consent being integrated in the permit, as required by adjusting the BiH legislation with the EU legislation, it is envisaged that an integrated permit includes more plants and facilities. For ArcelorMittal, this would mean issuing only one, integral (or more precisely, collective) environmental permit. Eco Forum considers that this approach is not acceptable and will strive that this provision of the law is changed before the adoption.

Representatives of the Ministry are at the Round Table said that in issuing new environmental permit they will not conduct a public hearing. Eco forum will insist yet to be included in the process of issuing the permit. Given that five environmental permits expire in November / December 2014, and the remaining 3 in November 2015, the Ministry announced that it will issue a joint permit probably mid-2015, to the expected adoption of the new Law on Environmental Protection.

Eco Forum addressed complaints to the Federal Ministry of Tourism and the environment in the context of public hearings about the draft of the new Law on Environmental Protection of FBiH in October 2014. The most important observations relating to the public participation in renewal of permits and the integrity of the permit.

If the plant / installation which has an environmental permit has not fulfilled all obligations from the permit, the only situation provided is "shutdown and closure of the plant," without an alternative solution. We already have the case of such facilities (ArcelorMittal Zenica), where obligations from prior consent are not fulfilled, and the issuance of new ones is planned. Who is responsible for non-compliance or for eventual closure? These are too serious issues, environmentally, economically and socially to be left incomplete without the participation of the public.

The term "integrity" in the draft of the new Law is completely misinterpreted. Instead of integrity in terms of the various permits, the concept of "collective license" is introduced for complex operators, without a clearly defined way of determining how the "collective" operation is determined. Collective permit should be issued only for technological units, regardless of location or operator.

At the end of 2014, the environmental permit for five plants, two of which are big polluters (blast furnace and BOF converter) have already expired, and none of the authorities reacted to it. Therefore, Eco forum decided on law suits against the responsibles.

Law on Air Protection of FBiH is envisaged that the data on air quality, and concentrations of pollutants in the air, are measured, recorded and the public must be informed in an appropriate and understandable way. Since its founding, the Eco Forum Zenica is trying to contribute to a better and more accessible information on air quality to citizens.

The first measurements of air quality in Zenica carried out by the Department for the Protection and Ecology at the Institute of Metallurgy "Kemal Kapetanović". The measurements performed by the Institute used methods that can give only daily averages, and with a delay of several days. Thus, the measurement results can be used only for subsequent analysis, and there was no possibility of applying intervention measures in episodes of high concentrations of air pollution. Emergency measures are taken if hour averages of concentrations of pollutants exceed a certain limit, so it is necessary to have measuring equipment that shows the hourly, not just daily averages.

In 2009, Zenica-Doboj Canton and University of Zenica acquired the mobile measurement stations, which then gave data on hourly concentrations. After some time, a station of the University started to give illogical data, and soon it was discovered that it was never calibrated. Today, that station is not used. Mobile measuring station owned by the Canton Government was used in all municipalities in the Canton, and it was not possible to use this data for Emergency measures in Zenica.

Data on the measurement results were published on the websites of the Municipality and Canton, but in a way that was not appropriate and understandable to citizens. Eco Forum occasionally used this information to graphically present it, we compared the data with the allowed limits and we published it on our website.

The data from the Canton website were in the form of tables with numbers, without comparisons with limit values:

On the website of the Municipality, the data were further hidden in WinRAR archive:

Eco Forum was showing the results of air quality measurements this way:

After the protest march, organized by the Eco Forum in December 2012, the three fixed measurement stations were purchased, along with three displays and the website monitoring.zenica.ba, where one can find information about air quality. This system was first used in December 2013, when due to excessive concentration of SO2 alarm episode was declared, emergency measures have been taken and the pollution was reduced within a few hours, although these days there was no wind, rain and similar phenomena that could contribute to pollution reduction.

During 2014, it was observed that the data the system displays are not always available, sometimes there is no communication between the server and measuring devices, and that the data is illogical, which caused us to question the validity of these results. It is not clear why the measuring station are located on the roof of the building, when the standards prescribed that these cells must be located on the ground level.

From the Municipality of Zenica in June 2014, we received information that the technical approval of the measuring cell has not yet completed, so that the measurement results should be taken with some reserve. Maintenance contract for this system was signed with the supplier of equipment (company DvokutPro Sarajevo) for the period up to May 2015, when it is expected that the Metallurgical Institute "Kemal Kapetanović" will take these jobs. By then it should be completed equipping and accreditation of the Centre for Monitoring Air Quality of Zenica Doboj Canton, for what they have already secured funding in the budget of Zenica Doboj Canton. After objections of Eco Forum on the number and arrangement of the measuring cells (measuring station on the roof instead on the ground level, and the lack of measurement on the right bank of the river Bosna - the villages of Gračanica, Pehare, Vraca), it was concluded that the Municipality will send to Eco forum a copy of the Studies made by the Polytechnic University Turin on building a system for monitoring air quality in Zenica, on the basis of which the locations were selected, in order to better discuss this issue. The establishment of the Centre of Metallurgy Institute will solve the existing problems of measuring equipment calibration, and the system will be connected with two mobile measuring stations.

Data on the air monitoring website are often not up to date, especially on weekends, when the pollution is higher

At the session of the City Council held on 20.11.2014 the two reports on the measurement of air quality in Zenica in the first half of 2014 were presented, one prepared by the department of Ecology of the Municipality / City of Zenica, and the other prepared by the Institute of Metallurgy "Kemal Kapetanović" in Zenica. The reports revealed that the data given by the measuring station owned by the Municipality / City of Zenica are significantly different from those given by the Institute.

Eco forum pointed out that monitoring stations are not set to the correct location, that after two years of use they have not yet been calibrated, which means that the data which are presented to the citizens is absolutely useless, and it is not known who was responsible for it. We pointed out the problems with the server monitoring.zenica.ba, which is often at a standstill and does not perform its function, then the non-use of mobile measuring stations owned by the Zenica-Doboj Canton and the University, and the failure to call representatives of the Eco Forum in sessions of the Emergency Team for the implementation of measures in cases of excessive pollution.

The diagram shows the differences in the number of registered number of days exceeding the daily average of sulfur dioxide in Zenica. The permitted number of overdrafts during the year is three. The measurements of urban monitoring system showed 20-50 overruns and measurements of the Institute show 110-130 overruns during only six months.

The diagram shows the differences in the results of measurements of monthly concentrations of sulfur dioxide, measured by the municipality (shown in yellow) and by the Institute (shown in blue). One can clearly see the differences in the results.

A website which should be updated and show the results of measurements per hour, shows the measured value, but it happens that data is delayed by several days. The picture shows how the communication between the metering station and server was interrupted on 19/11/2014, and two days later, when the concentration of sulfur dioxide exceeded the value for the declaration of emergency, it can be known only by those who see the city display.