Ms Nataša Uranjek, BSc of Agriculture, is an expert in the field of environmental protection in the Republic of Croatia and authorised person in the process of issuing integrated permits. She has successfully worked for twenty years in roles encompassing the legislative framework, practical application of regulations, and advisory work in this field. Her love of nature and awareness of the importance of environmental protection developed in childhood and later became the foundation of her professional path. During her career, she has worked in public administration, a large manufacturing company, and the consulting sector, and today she successfully runs her own company, Promo eko, which specialises in providing advisory services in the field of environmental protection and sustainable business. In addition, Ms Uranjek serves as Chair of the Environmental Protection Professional Group of the County Chamber of Commerce in Osijek and is also the Deputy Chair of the Environmental Protection Professional Services Association of the Croatian Chamber of Economy.
IED Serbia: Ms Uranjek, you are an authorised person in the process of issuing integrated permits in the Republic of Croatia. Could you explain the role of the authorised person and its significance in this process?
Ms Nataša Uranjek: It was the Law on Environmental Protection from 2007 that defined for the first time the concept of the authorised person in the Republic of Croatia, a professional legal entity that prepares paperwork for various procedures in the field of environmental protection, including documentation for obtaining an integrated permit. In order to acquire the status of an authorised person, a legal entity must have a professional team with many years of experience in preparing studies and a thorough knowledge of regulations in the relevant field.
In the early years of implementing the Industrial Emissions Directive in Croatia, operators could either prepare the application for an integrated permits themselves or engage an authorised person. However, practice showed that self-prepared applications often lacked the required quality and completeness of documentation. Therefore, the Regulation on Integrated Permits from 2014 introduced the obligation that the technical basis of the application must be prepared by an authorised person. The authorised person in the process of issuing an integrated permit prepares the technical documentation, assesses the installation’s compliance with Best Available Techniques (BAT), cooperates with the operator in collecting data, and shares responsibility with the operator for the accuracy of such data. This approach significantly improved the quality of applications and contributed to the more efficient implementation of the IED Directive in Croatia. From experience, I can say that, in addition to the core team, external collaborators are often engaged in practice to prepare certain parts of the documentation, usually geologists, architects, and biologists. In our case, this cooperation has proven extremely beneficial, and some of these experts have over time become permanent members of the team. The Ministry of Environmental Protection and Green Transition of the Republic of Croatia maintains and publishes a list of legal entities authorised to perform these tasks. At present, there are about one hundred authorised persons on the list, of which approximately one third are engaged in preparing documentation for integrated permits.
IED Serbia: Recently, within the framework of the project “Green Transition – Implementation of the Industrial Emissions Directive in Serbia (IED Serbia)”, you conducted a workshop dedicated to the application of general binding rules (GBRs) in the process of issuing integrated permits. In your opinion, what are the key aspects of the Croatian experience in this field that could be applicable in Serbia?
Ms Nataša Uranjek: General binding rules play an important role in the system of issuing integrated permits because they simplify and accelerate the process, both for the competent authorities and for operators. Based on predefined and standardised conditions that comply with the requirements of the Directive and with the Best Available Techniques, it is possible to make high-quality decisions within a shorter timeframe. This ensures greater consistency and transparency, while at the same time facilitating the monitoring and control of permit conditions, as the requirements are clear and uniform.
In Croatia, general binding rules were introduced as early as 2008 and apply to the intensive livestock farming sector, that is, pig and poultry farms, and the process of their further improvement continues. These rules have significantly facilitated the work of both companies and local authorities, as all necessary information is available and the process of permit preparation becomes more efficient and straightforward.
It is important to note that the Croatian system also provides realistic deadlines for existing installations for implementing certain environmental protection measures and introducing new technologies, which are adjusted to the complexity of the intervention and the level of required investment. This approach has proven practical and fair towards industry, as it enables progress while maintaining a high level of environmental protection.
The experience of Croatia shows that general binding rules contribute to more efficient implementation of the IED Directive, and their introduction in Serbia could have a similar effect – simplifying procedures, increasing legal certainty, and encouraging consistent application of the Best Available Techniques.
IED Serbia: You have extensive experience in the application of European Union environmental legislation and in the process of harmonising national legislation with European standards. What would be your advice to institutions and experts in Serbia who are facing similar challenges in the EU accession process?
Ms Nataša Uranjek: The experience of Croatia shows how crucial education and good preparation are in the process of harmonising with European Union legislation. During the pre-accession period, thanks to EU support, a series of training sessions were conducted for competent institutions, experts, and operators, which was of key importance for the successful implementation of the Industrial Emissions Directive.
At the beginning, many operators did not fully understand the importance of the integrated permit, nor had they obtained all the necessary preceding permits, such as water or usage permits. However, they soon became aware of the necessity of meeting these requirements, began serious preparations, and gradually introduced changes to their operations. Alignment with the Best Available Techniques (BAT) not only ensured compliance with regulations but also brought concrete benefits such as reduced water and energy consumption, decreased amounts of waste and wastewater, and generally more efficient and sustainable operations.
It is important for operators to begin preparations for the harmonisation process as early as possible, in order to have sufficient time to assess necessary investments and plan financial commitments. Understanding various BAT techniques and identifying those most suitable for the specific characteristics of the plant allows realistic planning of steps towards full compliance and facilitates the later process of obtaining the permit.
Serbia, just like Croatia, has the potential to successfully overcome all challenges on the path towards full implementation of European legislation. The key lies in education, timely access to information, and open cooperation between competent institutions, operators, and the expert community. Such a proactive and well-informed approach leads to a successful transition towards European standards, while safeguarding the environment and ensuring long-term benefits for both industry and society as a whole.