The City of Doboj has issued operating permits for 104 small solar power plants developed by Etmax at Crkveno Brdo near Podnovlje, despite an unresolved dispute over ownership of the project land. The decision allows the facilities to move towards commercial operation but leaves a potentially significant legal liability hanging over 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 concerns both the proximity of the installations to residential properties and the legality of the transfer of land from the Podnovlje Agricultural Cooperative to the City of Doboj before its subsequent sale to Etmax.
In April, the Supreme Court of Republika Srpska overturned an earlier ruling by the Doboj District Court and questioned the legality of the original land transaction. The ownership issue remains subject to further proceedings, but the local administration proceeded with operating approvals before the dispute was resolved.
Each installation is understood to have capacity of up to 150 kW, placing the combined portfolio at a maximum of approximately 15.6 MW. Dividing a larger development into small individual plants may allow each unit to qualify under the applicable feed-in tariff framework, creating predictable revenues over a 15-year support period.
Estimated annual revenue of approximately €20,000 per facility would produce aggregate income of about €2.08 million a year. Across 15 years, the nominal revenue envelope would exceed €31 million, broadly explaining estimates that potential compensation claims could surpass €32 million. Claims based on the longer 25–30-year technical operating life of the assets could be higher, although any award would depend on recognised damages, operating costs, financing assumptions and the developer’s duty to mitigate losses.
Indicative development and construction expenditure for a fragmented 15.6 MW solar portfolio could fall in the region of €11 million–€17 million, depending on equipment specification, grid works, terrain and transaction costs. The legal exposure is therefore potentially larger than the original physical investment because it could include lost subsidised revenue rather than only unrecovered construction expenditure.
The case creates a difficult risk allocation. Etmax may argue that it relied on decisions by public authorities when acquiring the land, obtaining approvals and building the facilities. The authorities, in turn, could face questions about whether permits should have been issued while the ownership proceedings remained unresolved. Lenders and insurers will focus on whether title risk was disclosed, whether legal opinions contained qualifications and whether compensation mechanisms survive a finding that the underlying transaction was unlawful.
The dispute also illustrates why operating permits cannot be treated as a substitute for a complete land-rights audit. A technically complete renewable project may still be unbankable when cadastral records, ownership transfers, easements or access rights remain contested. Feed-in tariff eligibility provides revenue visibility, but it does not cure defects in land ownership.
For Republika Srpska, the wider issue is the credibility of its renewable permitting framework. A compensation claim above €32 million would impose a material cost on public institutions and could encourage closer scrutiny of other projects structured through multiple small generating units. It could also affect future decisions by banks evaluating projects that depend on municipal land transactions and long-term regulated support.
The plants may now possess operating approvals, but the unresolved title dispute leaves the economic ownership of the project value uncertain. The central risk has moved from construction and commissioning to litigation, compensation and the enforceability of the revenue framework.
