Please contact info@ecoperestroika.ru if you want to join the appeal.

More about this initiative can be seen here: Ecologists Appeal to Europe for Support Over Power Plant. St Petersburg Times, July, 21 2009.

Text, decribing the situation can be seen below  - you can use this text as a draft to write your own appeal, send it to the Russian authorities (see addresses at the end of the text).

Inquiry for the international EIA procedure in accordance with the Espoo Convention on Nuclear Power Plants planned by the Russian Federation for construction in the Baltic Sea Region (Baltic NPP in Kaliningrad Oblast and Leningrad NPP 2 in Leningrad Oblast)

We demand initiation of the international EIA procedure on the activity, proposed by the Russian Federation in the Baltic Sea Region: construction of 2 new NPPs, the Baltic NPP and Leningrad NPP 2 (units 3 and 4).

The procedure is set out in the international Convention on Environmental Impact Assessment in Transboundary Context (the Espoo Convention). We suggest you to approach the Russian side on implementing the Espoo Convention requirements in regard to these projects.

The UNECE Convention on Environmental Impact Assessment in a Transboundary Context (adopted 25 February 1991, Espoo, Finland, entered into force 10 September 1997) is a major international legislative document regulating transboundary Environmental Impact Assessment (EIA).

The Espoo Convention sets out mechanism for international cooperation to assess the environmental impact of all major projects at an early stage of planning. It also lays down the general obligation of States to notify and consult each other on all major projects under consideration that are likely to have a significant adverse environmental impact across boundaries. The Convention also sets out clear regulations concerning public participation and responsiveness to public opinion in EIA procedure.

In the list of activities of possible adverse environmental impact in Appendix I of the Espoo Convention, nuclear power stations are listed in paragraph 2b. Thus, nuclear power plant construction, specifically being located in near-boundary areas, falls under the Convention requirements.

The Baltic Nuclear Power Plant, with two 1200MW VVER-type units, is planned for construction in the Neman district of Kaliningrad Region of the Russian Federation, about 15 km from the Region’s border with Lithuania.

On April 16, 2008, a framework agreement between the Kaliningrad Region government and Russia’s Rosatom State Nuclear Energy Corporation proposing the construction of the Baltic NPP was signed. Yet, there is no official approval for the project by the Russian Federal government. Nevertheless, Rosatom is developing the EIA materials, and plans to have it approved by the state by the end of 2009.

The public hearings on the preliminary materials of the “Environmental Impact Assessment of Construction and Operation of Units 1 and 2 of Baltic NPP” are scheduled for July 24 in the town of Neman. The materials are currently being available for the public in the only hard copy in the town’s Cultural Center. The EIA materials development is planned to be completed September 2009.

The Leningrad Nuclear Power Plant 2, with four 1200MW VVER-type units, is planned for construction next to existing Leningrad NPP in Sosnovy Bor at the Baltic Sea coast in Leningrad Oblast of the Russian Federation in some 200 km from Helsinki.

The Leningrad NPP 2 is, according to Rosatom, a prototype for the Baltic NPP, meaning that Russian Federation plans to expand its unproven new reactor design in the Baltic Sea Region.

The proposed reactor type is based on a design only implemented at the Tianwan Nuclear Power Plant constructed by Rosatom in China, the first new reactor design worked out since the Chernobyl catastrophe of 1986, according to the developer.

The public hearings on the Leningrad NPP 2 units 3 and 4 held on June 16 in Sosnovy Bor were criticized by Russian environmental NGOs as an example of manipulations. The EIA documents presented at the hearings did not have sufficient information about nuclear waste and spent nuclear fuel management and about the NPP decommission. Rosatom demands that even in case of a heavy incedent the consequences will not be seen at the distance of 800 meters from the NPP. That is a dangerous mistake.

Due to the specific location of Kaliningrad Enclave, surrounded by European Union Member States, the transboundary nature of a possible negative environmental impact of the Baltic NPP is obvious. The same applies to the Leningrad NPP 2 as well, being located on the Baltic Sea coast, close to Finland.

In compliance with the Espoo Convention, a country where such a project originates is obliged to provide the public of the affected countries with equal opportunities to participate in the discussion and EIA procedure as those in the country of origin. The Convention also says that all affected countries must be notified as early as possible, and no later than the public of a country of origin is notified.

The Russian Federation has not ratified the Espoo Convention but signed it in 1991. By doing so, it took on a voluntary commitment to follow the Convention provisions as far as it does not contradict to Russia’s national legislation. Moreover, the EIA Regulations of the Russian Federation clearly states that, in relation to projects of transboundary effect, regulations provided by the Espoo Convention are to be observed in the first place.

The Nord Stream underwater gas pipeline via the Baltic Sea was the first project in which Russia has acted in accordance with Espoo Convention procedures. Moreover, to large degree due to efforts of the public and competent authorities of the affected countries, the international EIA procedure of this project became the largest one in the history of the Convention implementation (in particular, Nord Stream AG company has spent €100 million for environmental research and planning).

Most counties neighboring Russia both in Europe and in Middle Asia have ratified the Espoo Convention. They are not formally obliged to include Russia as a party of the Convention to the procedure of international cooperation in this regard.

However, in accordance with the Espoo Convention, notifications of nuclear power plant projects alone have been sent to the Russia’s authorized body, the Russian Ministry of Natural Resources and Environment, which has allowed for participation of Russian public in discussion of such projects as the Loviisa-3 Nuclear Power Plant in Finland, the Visaginas Nuclear Power Plant in Lithuania, and the Ostrovets Nuclear Power Plant in Belarus.

In June 2009, under the initiative of environmental NGOs, Ministries of Environment of Latvia and Lithuania approached the Russian side with request for information and notification in accordance with the Espoo Convention about the project of the Baltic NPP in Kaliningrad Region. No response received to date.

Taking into consideration the abovementioned, we suggest you to approach the Russian Ministry of Natural Resources and Environment as a respective body, and Rosatom, the developer of the Baltic and Leninigrad 2 Nuclear Power Plants, with an inquiry for notification about the proposed construction and operation of these plants in accordance with Article 3 of the UNECE Convention on Environmental Impact Assessment in a Transboundary Context. This will allow the beginning of an international environmental impact assessment process with participation of the public of neighboring countries.

Please send letters of inquiry for notification in compliance with the Espoo Convention and information about the Baltic and Leningrad 2 Nuclear Power Plants to:

Ministry of Natural Resources and Environment of Russian Federation

Vladimir Ivlev

Deputy Director of Department for International Cooperation

Focal Point of Espoo Convention

E-mail: ivlev@mnr.gov.ru

Rinat Gizatulin

Director of Department of State Environmental Policy

Victoria Venchikova

Department of State Environmental Policy

E-mail: vvr@mnr.gov.ru

Ministry of Natural Resources of the Russian Federation

4/6, B. Gruzinskaya Str.

Moscow, 123995,

Russia

Tel.: (7-095) 252 03 00

Fax: (7-495) 254 82 83; 252 67 47

E-mail: admin@mnr.gov.ru

Rosatom State Nuclear Energy Corporation

Valery Novak

Alternative Director

Energoatomproject Branch

Energoatom Concern OJSC

Dnepropetrovsky proezd 4a

Moscow 117545

Russia

Tel/Fax: (7-495) 660 50 01

E-mail: rosatom@pkf.rosenergoatom.ru

Sergey Obozov

Director General

Energoatom Concern OJSC

Bolshaya Ordynka 24/26

Moscow 119017

Russia

Tel.:(7-495) 239-2422

Fax: (7-495) 239-4603
E-mail: npp@rosatom.ru

Sergey Kirienko

Chief Executive

Rosatom State Corporation on Nuclear Energy

Bolshaya Ordynka 24/26

Moscow 119017

Russia

Tel: 8 (499) 949-42-54

Fax: 8 (499) 949-22-63

E-mail: rosatom@skc.ru