26. Januar 2007

Baltic Environmentalists comment Gas Pipeline Project

Coalition Clean Baltic - the Network of the Baltic Sea Regions Environmental NGOs, published its comments on the Gas Pipeline Project today.

Here is the text of the press release, to be requested also from: Coalition Clean Baltic, Östra ?gatan 53, SE-753 22 UPPSALA, Sweden. Phone +46 18 71 11 70 Fax +46 18 71 11 75
E-mail: gunnar.noren@ccb.se, www.ccb.se.

CCB comments and request for studies to be included in the Environmental Impact Assessment for the planned
North European Gas Pipeline in the Baltic Sea,
under the Espoo Convention.

CCB has the following comments:

Environmental effects of the project
The initial environmental impact will be during construction. As the sea floor is not flat work will be needed to make a “road” for the pipeline. The environmental impact depends largely on how much dredging, blasting and removing of rocks that will have to be done. The big difference between really soft bottoms quickly changing to rocky bottoms will be demanding for the construction. Another physical problem might be the quick pulses of stronger currents on the bottom and the ice cover during winter for the beginning and ending of the pipe and the service station.

In the Gulf of Finland there are a lot of hazardous chemicals buried in the sediment (also in other parts of the Baltic Sea), specially cadmium, mercury, led, TBT and DDT. Very high concentrations and corresponding amounts in the sediments can be foreseen. According to the EIA program by Nord-Stream, the concentrations of heavy metals in the Gulf of Finland are very high according to Swedish standards (from considerable pollution (class 3 of 5) to very contaminated (class 5 of 5)). Therefore the option of removing contaminated sediments to the surface and handling/cleaning it on land should be included in the EIA.

Nord Stream mentioned the risk of dumped ammunitions to be found while constructing the pipeline. In different sources it is documented that ammunitions have been dumped before reaching the dump sites or accidentally distributed through fisheries activities. The available information on the exact position and amount of all dumped ammunitions is incomplete. Hence, CCB expects dumped ammunitions not only on registered dump sites but more or less all along the planned route of the pipeline.
The danger occurring from these old weapons is manifold: When they are intact they can explode by accident and release different toxic substances apart from the noise. When they are corroded and/or broken these toxic substance can be mobilised through the pipeline construction.

In case of explosions of ammunitions (accidentally or indented) there is a harmful influence on marine mammals and fish to be expected. In a circle of several kilometres radius around the detonation serious injuries of gas filled organs of animals are likely to occur.

The nutrient content in the sediments is also very high, and an estimation should be made of the amount that could be released during construction is needed. The impact on Baltic eutrophication can be adverse, and can indicate a final regime shift for the Baltic.

Note that several of governmental long term environmental monitoring stations will end up being under the pipeline. One should ensure that these can still operate and provide their data.

Underwater noise can also be a problem for the marine life, such as fish species and marine mammals, close to a gas pipeline when the pipeline is in use. The Environmental Imapct Assessment (EIA) must include a description of what kind of noise, incl frequences of the sounds and sound levels that can arise from the gas pipeline and the extent of disturbances during construction.

It is essential that the project parties are aware that the planned location of the gas pipeline will have on impact on Natura 2000 areas, such as the Hoburg bank area. All possible conflicts with sites designated for Natura 2000 network should be a subject of separate assessment to fulfil requirements of Article 6(3) and 6(4) of the Habitats Directive, which is not the case now.

The entire Gulf of Finland must be regarded as a gas pipeline environmental impact area, and not only the strip of two kilometers along the pipeline itself.

CCB request:

1. To monitor the content of hazardous substances and nutrients in the sediment in each spot where dredging is planned or needed, and estimate costs for removing of the dredged sediments up on land and handle it as hazardous waste, if the concentrations of contaminants are above permitted levels.

2. A detailed estimation of how much nitrogen and phosphourous, in different Baltic Sea sub-basins, that can be released when contructing the gas pipeline.

3. All research work and analyses on dumped ammunitions have to be applied for the total length of the planned pipeline.

4. The EIA has to describe, analyse and evaluate the effects of:
- Remobilisation and release of potential harmful substances from dumped ammunitions caused directly or indirectly by the pipeline construction - Blow up and accidentally explosion of dumped ammunitions - Pushing aside of found ammunitions - Salvage of found ammunitions - Re-dumping of found ammunitions (as far as foreseen)
5. A detailed safety and ammunition handling concept will have to be presented prior to the EIA. It should contain detection, going around (where ever possible), removal, handling and mitigation measures for explosions in the sea. For any activities Best Available Technologies (BAT) have to be employed. The guiding principle has be the minimisation of harmful effects for human beings and the environment.

6. The risks for marine mammals and fishes through detonations of dumped ammunitions have to be analysed and measurements to minimise the injuries (e.g. gas bubble curtains) have to be discussed. Nord Stream has to present a convincing security concept how they want to protect the marine environment against the harmful effects of possible explosions.

7. To study what environmental monitoring stations in the Baltic Sea that will be influenced by the planned location of the gas pipeline, and estimation of costs for moving the gas pipline outside the area of importance for long-term monitoring.

8. A description of what kind of noise, incl frequences of the sounds and sound levels that can arise from the gas pipeline, e g submarine sounds, and its impact on the Baltic Sea fauna.

9. A study that describes the impact of the gas pipeline (construction phase and operating phase) on the very vulnerable Ringed Seal population in the Russian Gulf of Finland (Vyborg Bay), and northern Gulf of Finland shores and archipelago area in Finland, and what actions can be taken to mitigate such impact.

10. To propose alternative locations of the pipeline accordingly to the Article 6 of Habitats Directive and relevant procedures, to ensure that Natura 2000 areas, e.g. Hoburgs bank in Swedish waters, will be safeguarded.

11. Description of the fish stocks and fisheries interests around the pipeline area, and evaluation of the impact of the pipeline construction and operation on fish stocks and fisheries interests.

12. To establish a liability fund with regard to the prevention and remedying of environmental damage which may occur during the construction, exploitation and decommissioning phase of the project.

13. Many islands in the Russian Gulf of Finland are very important nature sites and are intended to be included into the planned nature reserve “Ingermanlandskiy”. It is important to make sure that the area of these islands is not used for construction activities (e.g. as storage sites etc). The EIA should contain information that will guarantee the safeguarding of Russian islands in the Gulf of Finland.

14. To restrict Gas Pipeline construction activities in spring-summer fish spawning period in coastal areas in Russia and Germany (e.g. 15 April – 15 June according to fish protection legislation in Russia).

15. “Gazprom” company as the project leader, according to Russian environmental legislation, should organize public hearings in Russia as a part of the EIA and provide the results of the public hearing for state environmental expertise process.

Other options should be considered

In the EIA programme only two options are considered, the zero option of no pipeline and the option of building according to plans in the programme. There should be included other options as well, both on land (e g parallel with existing lines) and on the sea floor.

Environmental impact on the Baltic Sea ecosystem of the planned gas pipeline, in Russian waters, outside Russian land territories, around the Vyborg Bay

The gas pipeline will enter the Baltic Sea close to river Serga, west of the Vyborg Bay.
The following fish species are in these waters (see e g Nature Conservation Atlas of the Russian Part of the Gulf of Finland, published by Baltic Fund for Nature St Petersburg, www.bfn.org.ru). - Sea-trout (Red Book species in Russia). There are areas with high concentration of young sea-trout at the delta and outside river Ser’ga, in border waters between Russia-Finland and in the delta and outside river Virojki (in Finland) - River lamprey - sites with high concentration of migrating individuals, e g in the delta and outside Ser’ga River - Anadrom vendace - in Gulf of Finland waters - Twaite shad - along the northern coast of Gulf of Finland

Some bird species also have important areas in this region (e.g. Whooper swan, Caspian tern, Barnacle goose) These require special attention, and must be studied in the EIA.

The impact on natural values in Russian RAMSAR areas in the Gulf of Finland must be considered and described, and actions to mitigate such impacts should be suggested.

* The impact of the construction and operation of the gas pipeline on above-mentioned fish species must be described in details, and proposals for actions to avoid any impact on these species, must be suggested.
* The impact on smelt catches (one of the most important commercial fish species in the Gulf of Finland) in the waters where the gas-pipeline will be situated and adjacent Russian and Finnish waters must be considered carefully.

Environmental impact on the Baltic Sea ecosystem of the planned gas pipeline on Russian land territories around the Vyborg Bay and Leningrad oblast

The pipeline is planned to enter the Baltic Sea in Portovaya Bay and will accordingly cross 7 rivers coming from Nort-West via Finland to the Vyborg Bay.
In these river ecosystems we find Baltic Sea ecosystem species, using the river ecosystem for a part of its lifecycle, for spawning and breeding, and living the rest of its life-cycle in the Baltic Sea waters. Such species are e g Baltic salmon, Baltic sea-trout, Baltic whitefish (Coregonus) and river Lamprey (Lampetra).

The impact from the land construction of the pipeline on Russian land territories are most relevant to bring up and handle within the Espoo convention case, because such land construction can have adverse impact on Baltic Sea marine species and ecosystem.

* The EIA shall describe the location of the gas pipeline on Russian land territories from St Petersburg region to Portovaya Bay on detailed maps, and also describe the crossing of rivers to the Baltic Sea, possible changes of the river beds, and proposals for actions to avoid any impact on Baltic Sea river migrating species in such rivers.
Of special interest are the rivers on the Northern shores of the Russian Gulf of Finland, which have documented natural values, and the upper tributaries of the Luga river, the most important wild Baltic salmon river in Baltic Russia, South and South-West of St Petersburg where the gas pipeline may cross the Luga river system.

Monitoring of environmental impacts

In the presented EIA programme there is no plan for continuid monitoring of the environmental impacts of the pipe line after construction. Neither is it mentioned how the effects and impacts of the construction phase will be monitored. Such details must be presented, with a chance for other stakeholders to comment and influence the final decisions of monitoring and contingency procedures.

The use of expertise

The project is very extensive and the best expertise from different areas is needed. In the EIA programme is it not mentioned who will be the experts and how the studies will be executed. Such info must be provided and stakeholders must be given chance to influence the selection of best expertise.

Public Access of information about the project

The information and data already collected on the Baltic Sea bottom structures, sediment contamination etc, by Nord Stream must be accessible for the general public. Nord Stream data connected to the environmental impact of the project must be made publicly available. Maybe it could ease our concerns?

“Gazprom” company as the Russian project leader, according to Russian environmental legislation, should organize public hearings in Russia as a part of the EIA and provide the results of the public hearing for state environmental expertise process.

In case of accidents

The assessment of effects in case of an accident, for example a rupture of the pipe, should be included in the EIA. An evaluation should be made staing the devision of responsibility – in potential accident scenarios. What is the responsibility of the governments, the construction contractor and the operators and who will make the actual decisions on clean-up initiatives and in the handling of emergency situations.
The prevention and remedying of environmental damage should be paid by the consortium through an established liability fund.

Removal of the gas pipeline after its life-span of 30-50 years

All constructions in the Baltic Sea Region in waters and on land shall always be removed after its life-span.

* The EIA shall include a presentation of the costs for removal of the construction after 30-50 years, and how a reserve fund, with a “removal fee” included in the gas tariff system, must be constructed under the operation period to guarantee a future removal and restoration of the area.

The timetable
The timetable for the EIA is far too tight. We are concerned that there will not be enough time to discuss the quality assurance for all the necessary studies enabling a professionally produced EIA.

On-going process for stakeholder influence of the EIA
As many important facts and information on the details of how the EIA study will be performed are still not presented, an on-going consultation process with the Parties of origin within the Espoo convention and with other stakeholders interested in the EIA study, should be organised. One way could be to provide detailed info on the Nord Stream website regularily, and by organising regular meetings with all interested partners during 2007.

Environmental liability
Environmental liability of the project is very unclear now. EU rules on environmental liability with regard to the prevention and remedying of environmental damage (Directive 2004/35/CE) are not directly applicable for the project. However, the EU Member States (parties) in accordance to art. 14 of aformentioned directive can introduce a financial security intruments. Therefore, we believes all potentially project affected parties have right to demand a project liability fund.

On behalf of CCB

Gunnar Norén

Executive secretary