One of the key arguments behind pushing this project further is that it will preserve about 3,000 working places in Šaleška valley, about 1,500 jobs in the Velenje lignite mine, about 700-800 in TEŠ itself and about 700-800 in related support companies. However, this means that with the EUR1,2 billion investment into saving about 3,000 jobs means an investment of about EUR400,000 into each one of these jobs. Investing the same amount of money into energy efficiency and renewables would certainly open more jobs, maybe not only in the region of Šaleška valley, but also elsewhere in Slovenia. The fact is also that in the long-term these jobs are going to disappear because the lignite mine will run out of lignite. What is done today to save these jobs will only postpone the real problem to the next generation, who will inevitably have to face it.

Operating TEŠ6 without carbon abatement will result in emissions of 3.1 metric tonnes CO₂ a year, which is close to being equivalent to all of Slovenia's emissions in 2050, if it cuts emissions by 80% in line with European targets. The agreed EU target is actually 80-95% reductions on 1990 emissions. The EIB and EBRD supporting this project with light conditions around CCS, or alternatives to coal, may leave an open door to many more coal projects. Although the project is promoted as an environmental investment, because it will reduce the emissions per produced kilowatthour, it is far from that.

The EIA The EIA does not examine any alternatives, as is required by the EU EIA Directive 97/11/EC. This does not only refer to alternative sites for a new thermal power plant or alternative coal technologies, but alternatives refer also to use of renewables, energy efficiency measures as well as considering the "do nothing" option. The EIA also does not elaborate on the impacts of CCS technology on efficiency, the environment, economic aspects, potential consequences of leakage or liability issues.

The CCS Directive Article 33 of the CCS Directive, Directive 2009/31/EC, requires that operators of combustion plants, like TEŠ 6, assess whether suitable transport options and storage sites for carbon dioxide produced by the plant are available. The investor, TEŠ, actually made a document called "CO2 Capture and storage potential of unit 6 of the Šoštanj Thermal Power Plant" that should allegedly have represented the CCS assessment. Nevertheless, a) the content of the document does not meet the requirements of Art. 33 of the CCS Directive, b) it was submitted in the wrong stage of the permitting process and c) the competent authorities have never assessed its quality, correctness and adequacy. Consequently, the conditions of Art. 33 of the CCS Directive have not been met. The Slovenian competent authorities did not require the effective rectification of the CCS study. They did not even include the incorrectly made assessment into the running proceedings on the environmental permit. They persisted on the fact that TEŠ 6 did not fall into the scope of Art. 33 of the CCS Directive.

The economic viability of the project The main problem of the proposed project is that its economic picture shows low reliability and high dependency on hidden state support. In October 2006, the Ministry of the Economy announced the project of constructing Block 6 and estimated the project value to be roughly EUR600 million. In September 2007 the project price tag reached EUR780 million, an increase of 30%. The investors then approached EIB with a request for a loan. Approximately two years later, in October 2009, the price tag is at EUR1.1 billion and the investors are not only applying for a loan, but are also considering an application of additional EUR200 million at the EIB.

A report, issued by the consultant CE Delft, reveals that there are several methodological mistakes in the calculations included in the investment plan. Lignite prices used are too low, the estimated lignite consumption in Unit 6 is artificially lowered from 2028 onwards, and CO2 costs are underestimated. An unsubstantiated claim of increasing mine efficiency in the investment programme resulted in an underestimation of lignite prices by the project promoters. The other unsubstantiated claim is that there will always be a demand in the market for the extra electricpower output produced by the new unit, a 1,000 gigawatthours.

A close analysis of the internal rate of return for TEŠ 6 shows that corrections for the methodological mistakes lower the rate from 7.59%, as stated in the investment plan, to 6.91%. The unsubstantiated assumptions in the investment programme open the door to even higher risk exposure. If all risks materialized, the rate would drop to near 5%. This is well below the threshold value of 7% aimed for by the project promoter and even further from the 9% value that was requested by the Slovenian government in April 2011.

Lack of public consultation Although according to the EU and Slovene legislation a project of TEŠ Unit 6 range would have to be a subject of a comprehensive public consultation, such a consultation was not done.

Irregularities in the tendering procedure The procurement notice for the execution of civil works for the main technological plant of the new Unit 6 of TEŠ had substantial shortcomings and lacked crucial information required by the Directive. This included criteria for selecting the applications and information about how and when the interested parties could lodge the appeal against the results of the tender. On top of that, the project promoter failed to send a notice to the Office for Official Publications of the European Communities, thus violating another article of the Directive. TEŠ also violated the Slovene Public Procurement Act, which transposes the obligations laid down in Articles 42 and 44 of the Directive. Consequently, some of the important information about the contract might not have reached all the tenderers who may have been willing to apply for the contract.

Sham procurement leads to fraud charges In 2014, Slovenian police arrested 10 people and charged them with fraud for their suspected roles in bilking customers out of EUR 284 million through scams and bribery related to construction of the Sostanj 6 lignite power plant project. According to reports by the Slovene Press Agency, the principal architects of the scheme worked for the main supplier of the plant’s equipment, Alstom, which is alleged to have made millions by changing contracts and inflating the cost of the project.

When the coal-burning plant was first proposed publicly as the “Slovene energy future” in 2006, the total projected cost to build it was estimated at EUR 690 million. By the time initial testing operations began in 2014, however, the price tag had more than doubled to EUR 1.43 billion.

The scam was funneled through Slovenia’s public procurement process, which should have opened contracts to build the plant to competitive bidding. Loopholes in the process and the assistance of government insiders, however, made it possible for highly suspect deals to be made under the table. According to information from the Slovenian criminal police, the consultant group that selected Alstom for the project, Sol Intercontinental, was actually a subsidiary owned by Alstom. Through this sham arrangement and other questionable business decisions, investigators determined, Alstom profited to the tune of almost EUR 285 million.

Because Slovenian state officials had signed repayment guarantees for 80 percent of the loans provided by the European Union development bank, Slovenian consumers and taxpayers pay will likely end up covering the costs of the overcharges accrued by Alstom (source corruptionincoal.org).