The City of Doboj has issued operating permits for 104 small solar power plants developed by Etmax at Crkveno Brdo near Podnovlje, even though ownership of the project land remains disputed. The approvals allow the facilities to move toward commercial operation while leaving legal liability for the authorities and the wider support scheme.
The permits were issued on 29 June 2026 after months of opposition from residents and environmental groups. The controversy includes concerns about the installations’ proximity to residential properties and questions over the legality of a land transfer from the Podnovlje Agricultural Cooperative to the City of Doboj before its later sale to Etmax.
Supreme Court ruling challenges original land transaction
In April, the Supreme Court of Republika Srpska overturned an earlier ruling by the Doboj District Court. The higher court questioned the legality of the original land transaction underlying the project.
The ownership issue remains subject to further proceedings, but the local administration proceeded with operating approvals before the dispute was resolved. The operating permits therefore sit alongside an unresolved title question affecting the project’s underlying land rights.
Portfolio size, feed-in tariff structure, and revenue estimates
Each installation is understood to have capacity of up to 150 kW, giving a combined portfolio maximum of approximately 15.6 MW. Splitting a larger development into smaller units may enable each plant to qualify under an applicable feed-in tariff framework, with support spanning 15 years.
Estimated annual revenue is approximately €20,000 per facility, implying aggregate income of about €2.08 million per year. Over 15 years, the nominal revenue envelope would exceed €31 million, aligning with estimates that potential compensation claims could surpass €32 million.
The figures also reference a longer technical operating life of 25–30 years, which could increase claim levels depending on damages recognised and other factors. Any award would depend on recognised damages, operating costs, financing assumptions and the developer’s duty to mitigate losses.
Construction costs and risk exposure for lenders and insurers
Indicative development and construction expenditure for a fragmented 15.6 MW solar portfolio could range from €11 million to €17 million. The estimate depends on equipment specifications, grid works, terrain conditions and transaction costs.
The legal exposure is described as potentially larger than the original physical investment because it could include lost subsidised revenue rather than only unrecovered construction expenditure. This shifts risk away from construction and commissioning toward litigation, compensation and enforceability of the revenue framework.
Arguments over approvals issued during unresolved title proceedings
The case creates a risk allocation in which Etmax may argue reliance on public decisions during land acquisition, approvals and construction. Authorities could face questions about whether operating permits should have been issued while ownership proceedings remained unresolved.
Lenders and insurers are expected to focus on whether title risk was disclosed, whether legal opinions included qualifications, and whether compensation mechanisms remain available if a finding determines that the underlying transaction was unlawful.
Operating permits versus land-rights due diligence
The dispute is also presented as an example of why operating permits cannot replace a complete land-rights audit. Even where a renewable project is technically complete, it may still be unbankable if cadastral records, ownership transfers, easements or access rights remain contested.
Feed-in tariff eligibility can provide revenue visibility but does not address defects in land ownership. For Republika Srpska, the wider issue is described as the credibility of its renewable permitting framework in cases involving multiple small generating units.
A compensation claim above €32 million would impose material cost on public institutions and could lead to closer scrutiny of other projects structured through similar fragmentation. It could also affect future bank evaluations for projects depending on municipal land transactions and long-term regulated support.
The plants may now hold operating approvals, but unresolved title disputes leave economic ownership of project value uncertain. The central risk has moved from construction and commissioning to litigation, compensation and enforceability of the revenue framework.
