| Open letter to the President of Finland and the Prime Minister of Finland |
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Expression of Concern on the Environmental Impact of the Nord Stream pipeline to the Baltic Sea
"The Baltic Sea is the pride and joy of all the countries which border it, yet all of us have caused it much harm through our actions. The Baltic Sea has become very polluted very quickly and now has the dubious reputation of being the most polluted sea in the world. There are many bodies in the Baltic Sea region engaging in great and good work. Several programs and recommendations have been approved, most recently the ambitious plan of action of the Helsinki Commission (HELCOM), which aims to restore the Baltic Sea to a good ecological state by 2021. Any program, however good, has to be backed up by strong political commitment and a will to cooperate in order to be successful." Sharing these intentions and knowing your commitment to the Baltic Sea environment, we feel obliged to inform you on the growing scientific concern as regards of the evidence on the underestimation of the risks of the Nord Stream gas pipeline in the environmental impact assessments.In the process generalization of the information from comprehensive reports to the very brief memos, an impression of safety and low environmental impact of the subsea gas pipelines has been created. However, in case of the environmental systems, even a single weak aspect can be responsible for an extensive harmful impact. There are many of those aspects, and their discussion would require a special evaluation by an independent international interdisciplinary expert group. We would like to draw your attention to a statement of a relevant Finnish authority that has been mentioned in the statement of the Uusimaa Environmental Centre of July, 2, 2009: "The Finnish Food Safety Authority (Evira) considers the current environmental state of the Baltic Sea poor. The most significant and persistent contaminants affecting the Baltic Sea are dioxins and PCB compounds. The high concentrations of dioxins, PCBs, and organotin compounds show beyond doubt the Baltic Sea's extraordinary level of pollution in comparison with other parts of the world. [...] Evira states that the construction of the natural gas pipeline may increase the environmental load of the Baltic Sea from its current level. As the pipelines corrode, the compounds and materials used in manufacturing the pipeline may be released into the sea. Moreover, the detonations of wartime munitions will increase the toxic substance load of the environment, most likely in the form of higher lead and arsenic concentrations. As the pipelines corrode, the compounds and materials used in manufacturing the pipeline may be released into the sea. Moreover, the detonations of wartime munitions will increase the toxic substance load of the environment, most likely in the form of higher lead and arsenic concentrations. [...]. Evira proposes a number of procedures intended to ensure that no harmful substances are taken up by fish during the construction of the natural gas pipeline. They include avoiding munitions detonations, avoiding the use of the areas with the highest contaminant concentrations for construction activities, ensuring that the excavated soil is uncontaminated, and ensuring that the compounds and materials used in manufacturing the pipeline are suitable for a brackish water environment. Moreover, questions that must be resolved are related to compensation to be paid in case of accidents and for the project's negative impacts on fishing and recreational use of the area, and to the future responsibilities for the decommissioning of the pipelines." We consider it most alarming that this official warning by the Finnish Authority of Food Safety, EVIRA, was ignored in the following permitting procedures. In the light of the EU Commission Regulation EC 1881/2008 of 19 December 2006, and the HELCOM 2021 target "all fish safe to eat", we are very concerned about the additional toxicant load that will be released from the seabed sediments in course of the pipeline construction. From the analysis of Nord Stream´s EIA, it is evident that the impacts are underestimated and that the sample descriptions and statistical interpretations are inadequate. Another report, completed by the Finnish Institute of Marine Research (Implementation of the North European Gas Pipeline Project – Data Inventory and Further Need for Data for Environmental Impact Assessment, MERI - No. 5, 2006) has stated that ”sediments in the Gulf of Finland contain large deposits of heavy metals that in suitable conditions could be partially rereleased into the cycles of the marine ecosystems. Over the years some of these metal deposits will be transformed into hazardous compounds, so their release back into the marine ecosystem may result in very harmful effects.” We, the undersigned Estonian environmental organisations, having analyzed the public domain documents and relevant scientific publications, and having consulted the relevant commissions and councils of the Estonian Academy of Sciences, have found out, that we have sufficient scientific evidence about large gaps and inadequate assessments of impacts and risks in the environmental impact assessment reports of Nord Stream gas pipeline (Espoo EIA and Finnish EIA). According to this evidence, the uncertainties concerning the risks that may lead to local and regional ecological disasters, impacts to human health, and may cost human lives, are far too high. With this information in our possession, our organisations feel a deep responsibility to share it. We express our willingness to communicate it to an independent international expert group of highly qualified scientists and to warn all the governments for the potential consequences of the Nord Stream gas pipe project, where, from the scientific point of view, the environmental impact assessment is not finished. Especially, it concerns the chapter on assessment of trans-boundary impact to Estonia that is missing in all EIA reports presented by Nord Stream and the fact that the environmental impact assessment in the Russian EEZ has even not been officially sent to the affected parties for critical evaluation. Estonian environmental NGOs regret that the permitting authorities of some countries, including Finland, have given permissions to use their EEZ for building the two gas pipelines, without careful quantitative analysis of the scientific arguments presented by national and international organisations. It is known that the official EIA report on the Russian EEZ reached Finland less than few days before the permit was given, and that there was no sufficient time for its critical evaluation. It becomes evident from the documents that the permission is given in a hasty manner, without careful critical consideration of the developer´s statements on environmental safety. On Sunday, November, 22, 2009, Nord Stream AG planned to explode the first mine in the Gulf of Finland. The explosion was postponed for technical reasons, partly because of the risk to the marine mammals who could not be efficiently scared to a safe distance. According to the press, next attempt of explosion is planned for November, 24. 2009. It has been shown by the experts of the Estonian Academy of Sciences that the evaluation of the environmental impacts of the explosions was based on erroneous models that cannot be used for the multi-layered water column in the Gulf of Finland. For that reason, the efficiency assumed mitigation methods is overestimated and the high impacts and risks remain. As the Finnish Competent Authority finished the formal environmental consultations at a premature stage, without sufficient discussion of the scientific arguments, the only way to signal these problems for the Estonian NGOs was to appeal it in the court. Estonian environmental organizations call for a knowledge-based solution of the problem, including the following measures: (1) Setting up an international group of high-level scientific consultants that could investigate and objectively evaluate the completeness and adequacy of the scientific basis of the environmental statements in the EIA reports. (2) To halt the permitting processes until the scientific evaluation has been completed. (3) Negotiating with the developer, Nord Stream AG, on showing the good will and postponing any preparatory works of the Nord Stream pipeline, including those involving the seabed interventions until all the permissions become legal and binding. Honorable President and Prime Minister, November, 24. 2009
Yours truly, Jüri-Ott Salm CEO of Estonian Fund for Nature on behalf of following organizations: Estonian Naturalist Society, Estonian Fund for Nature, Estonian Green Movement-FoE, Estonian Student Society for Environmental Protection Sorex, Nõmme Road Society, MTÜ Läänerannik Estonian Fund for Nature: +372 7428 443, +372 52 95 933 Postal address P.O. Box 245, 51002, Tartu, Estonia Contact person: Jüri-Ott Salm, CEO of EFN
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Her Excellency, President of Finland, Tarja Halonen
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