The key document that is meant to provide the framework for a just energy transition in Serbia is being drafted without a public consultation process., with limited opportunities for the public and civil society representatives to influence its content. Therefore, Belgrade Open School, Renewables and Environmental Regulatory Institute, and Foundation BFPE for a Responsible Society have decided not to further participate in providing comments on the documents created within the working group of the project "Just Transition Diagnostics." 

Over two years ago, the Ministry of Mining and Energy established a Working Group for the implementation of the Just Transition Diagnostics project in Serbia, which aims to facilitate dialogue in order to find a common response to how to reduce job losses, conduct timely reskilling of workers, and diversify sources of income in cities and municipalities dependent on coal production. The Working Group had not met since mid-2022 until last week, when a meeting was held about the new, significantly altered version of the "Just Transition Diagnostics" document with an Action Plan, which was provided to members just three days prior. Initially, the Working Group members were given only three working days, and after intervention by civil society representatives, they were given a total of seven working days to read and comment on the document. 

Moreover, it was decided that this crucial document would be adopted without conducting prior public consultations. The Action Plan is a measure included in the Integrated National Energy and Climate Plan (NECP), and its description specifies that consultations with stakeholders are crucial for the adoption of the Action Plan. However, the public, based on the description of this measure, which could be accessed during the public consultation and after the adoption of NECP, was unable to gain an adequate understanding of the content of the Just Transition Action Plan. Additionally, the deadline for adopting the Action Plan cannot exceed 90 days from the adoption of the NECP. Since the NECP was adopted at the end of July 2024, this deadline has already passed. 

The measures outlined in the Action Plan have far-reaching impacts on employment, education, the economy, and the environment, which makes it unacceptable for this document to be adopted without a public consultation process and without giving the public the opportunity to familiarize themselves with the measures and influence the content of the document. It is especially important for citizens in municipalities that economically depend on coal exploitation, as well as workers in the energy sector, to become familiar with the document, given that the "Just Transition Diagnostics" document recognizes 1,846 directly affected and up to 2,713 indirectly affected jobs. 

Civil society organizations do not wish to provide further legitimacy to this insufficiently participatory process by giving comments, as it does not offer the public a chance to influence the content of the Just Transition Action Plan. The participation of civil society representatives in the Working Group cannot satisfy the criterion of public participation in the adoption of the Just Transition Action Plan. Finally, this process is not in line with the standards and guidelines related to public participation established by the European Bank for Reconstruction and Development (EBRD), which is supporting this project. 

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