The Belgrade Open School, Young Researchers of Serbia, World Wide Fund for Nature Adria – Serbia, Engineers for Environmental Protection, the BFPE Foundation for Responsible Society, and the Child Rights Center, all civil society organizations and members of the Working Group for the Development of the Draft Strategy for the Implementation of the Convention on Access to Information, Public Participation in Decision-making, and Access to Justice in Environmental Matters (Aarhus Convention), have decided not to attend meetings or participate in the activities of the Working Group in the upcoming period. The membership of these organizations in this working body of the Ministry of Environmental Protection will be suspended until the circumstances that led to the non-transparent and illegitimate process of issuing the Environmental Protection Conditions decision for the "Jadar" project by the Institute for Nature Conservation of Serbia are determined. Experts and organizations believe that this process undermines trust in institutions and creates the potential for endangering the country’s nature and biodiversity. This decision was also made in light of the current social circumstances, including student protests and demands for accountability from public officials. The way in which the aforementioned decision on environmental protection conditions was issued by the Institute for Nature Conservation is yet another consequence of the collapse of institutions in the Republic of Serbia. 

In order to prevent such decision-making from becoming common practice and to avert potential harmful consequences, we demand: 

• The resignation of the Acting Director of the Institute for Nature Conservation; 
  
  
• The determination of responsibility and sanctions against those responsible within the Ministry of Environmental Protection; 
  
  
• The issuance of a new decision on Environmental Protection Conditions for the "Jadar" project by the Institute, in accordance with the opinions of experts employed by the Institute; 
  
  
• A review and amendment of the legal framework for issuing environmental protection conditions, as well as the internal acts of the Institute, to ensure the consistent application of expert knowledge and to prevent the influence of other interests when preparing decisions on environmental protection conditions. 

It is evident that the rights guaranteed by the Aarhus Convention, which Serbia ratified in 2009, are being undermined. Civil society organizations have long pointed out various shortcomings of the competent authorities regarding public participation in decision-making processes: timely notifications and early public consultations regarding public policy documents are often absent, public debates are frequently held during holidays and vacation periods, which complicates real public participation, and there are noticeable cases of a lack of public debates in cities outside Belgrade, as well as short deadlines for public presentations of urban planning projects. We remind you that, at the end of last year, in the case of the "Jadar" project, the investor submitted a request for determining the scope and content of the environmental study, but only for a part of the project (underground exploitation), which is contrary to the requirements and prevents the evaluation of the entire plant's impact on the environment. According to data from the Commissioner for Information of Public Importance and Personal Data Protection regarding environmental information, the percentage of withheld information requested by citizens from competent authorities is high, which is concerning, given that these are critical pieces of information for public health. Moreover, in recent years, we have witnessed increasingly intensive negative media campaigns against environmental organizations, intimidation, and even the direct targeting and detention of activists, with a lack of adequate response from state authorities. We believe that such actions by the authorities violate citizens' fundamental rights to influence decisions regarding the environment, which goes against the goals of the Aarhus Convention. 

We emphasize that the Aarhus Convention is one of the most significant international agreements concerning the environment, requiring signatories to guarantee the rights of access to environmental information, public participation in decision-making, and access to justice on environmental matters, to protect the right of "present and future generations to live in a healthy environment." Article 74 of the Constitution of the Republic of Serbia also highlights the right of citizens to a healthy environment, timely and complete information about its state, and the duty of everyone to preserve and improve the environment. 

Considering the obvious erosion of these principles, we expect an urgent and adequate response from the Ministry of Environmental Protection in accordance with its competencies, to create conditions for our continued participation in the work of the Working Group. 

Signatories: 

Belgrade Open School 

Young Researchers of Serbia 

World Wide Fund for Nature Adria – Serbia 

Engineers for Environmental Protection 

BFPE Foundation for Responsible Society 

Child Rights Centre