Dear Sir or Madam, We are questioning the justification, appropriateness or reasonableness of carrying out an Environmental Impact Assessment (EIA) procedure for the operation of a mobile woodchip milling plant.  The mobile plant also processes waste wood, which means that such a plant is subject to an environmental permit. In the permit, the ARSO sets out the conditions on how the waste can be treated in the plant, so that it does not have a negative impact on environmental segments such as: air, water, noise. We consider it indisputably necessary to obtain such a permit. It is different, however, with the aforementioned procedure for obtaining environmental consent, which essentially determines the conditions under which the facility can be built and how it can be operated, but also in relation to the location where it is sited (permanent). The name of the installation itself defines its purpose or the way in which it is to be operated. Given that the installation is used in several locations, it is completely illogical to assess the impact of an installation only in a specific location (e.g. the headquarters of the operator of the installation), taking into account the use of the full rated capacity, as this may lead to a completely distorted load on a specific location. Furthermore, the content of the application for environmental consent is clearly and precisely defined in the Regulation on the content of the report on the environmental impact of the proposed development and the method of its preparation (Official Journal of the RS, No 36/09). Among other things, the Environmental Impact Report requires the identification of environmental zero states, the definition of the spatial characteristics of the operation, the identification of the relevant spatial acts, etc., which is impossible to identify or define for the operation of a mobile installation that operates in different locations that are not even predefined (depending on the demand).   In the light of the above, we propose that mobile installations be exempted from consideration in the same way as is provided for static, stationary installations that are site-specific in their spatial and environmental characteristics or conditions. The Ministry of the Environment and Spatial Planning or ARSO classifies the operation of a mobile plant as an operation referred to in point E.1.7.3 of Annex 1 of the Regulation on environmental operations subject to an environmental impact assessment (Official Journal of the Republic of Slovenia No 51/14), if it exceeds the nominal (theoretical) waste treatment capacity of 100 t/day.
NOTE FROM THE MINISTRY OF PUBLIC ADMINISTRATION: The Communication has been forwarded to the Ministry of the Environment and Spatial Planning for consideration and response. At the same time, please note that an invitation to the public to submit comments and suggestions on the draft Regulation on environmental impact assessment of environmental interventions has been published on the website of the Ministry of the Environment and Spatial Planning and is available at the following link:
http://www.mop.gov.si/si/medijsko_sredisce/novica/article/12455/6130/d21edc447e7bd8236c07c59080bbdb66/