The Estonian Fund for Nature (EFN) submitted an appeal to the Administrative Court of Vaasa concerning the munitions clearance permit issued by Western Finland Permitting Authority. Nord Stream AG has acquired the permit for clearing munitions in the Finnish waters as a part of the Russian-German natural gas pipeline project. According to the EU environmental impact assessment (EIA) directive and Espoo Convention, such permit can not be issued before the EIA of the whole project has not been completed.

According to EFN, the parts of the permit decision concerning the transboundary impacts to Estonia contain incorrect statements on impact assessment and risk analyses. The permitting authority has trusted explanations of the developer, without their critical examination. Estonian state authorities and scientists have pointed out several aspects according to which EIA, and in particular, the munitions clearance application, provided by Nord Stream AG is incomplete and inaccurate. That EIA has not adequately assessed impacts of toxicants in sediments which are resuspended by the clearance of munitions, affecting wildlife and human health.

"The permit application concerning munitions clearance should be rejected as the environmental impact assessment is not finalized", says CEO of EFN Jüri-Ott Salm.

"Nord Stream AG is trying to split the project, using a practice referred to as "salami slicing" - splitting a large project to small parts to conduct them silently. The reports of the monitoring of the implementation of the EU EIA directive have brought examples of this practice as non-recommendable practice."

EFN has appealed to court in order to revise and halt the permit for munitions clearance until all international obligations have been fulfilled including provision of public with adequate environmental risk assessment.

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Nord Stream is a planned natural gas offshore pipeline from Vyborg in Russia to Greifswald in Germany by the company Nord Stream AG.

Estonian Fund for Nature was established in 1991 by biologists and conservationists and in close co-operation with WWF (World Wide Fund for Nature). EFN is non-governmental and independent nature protection organisation.

The Nord Stream pipeline construction is a subject to the environmental impact assessment in accordance with the Espoo Convention, national legislation of concerned countries, and HELCOM recommendations. In the present environmental impact assessments, Nord Stream AG has used models suitable for sea areas with homogeneous density of water masses. In the permit application, Nord Stream has suggested that wind is the main driver for diffusion and movement of sediments exposed by clearance of munitions, also. These methods, however, cannot be used for strongly stratified water bodies such as the Gulf of Finland where they lead to a false impression of the circumstances influencing transboundary impacts. Consequently, the whole understanding of the factors causing transboundary impacts in the permit is based on false premises.

The clearance of each munition will result in a crater on the seabed. According to Nord Stream AG the radius of the craters will be between two to eight meters and the depth 1-3 meters. The contaminants from the crater will be distributed in the water column. The chemical content and concentration of toxicants in these sediments is unknown. The information on contaminants from the upper 2-6 cm is investigated and in some occasions (less than 30 samples) from the depth of 30 cm. Nord Streami AG has stated that, dioxins are found only from the mouth of the Kymijoki River in Finland. According to the methodologically elaborate and detailed studies of Finnish scientists, the zone polluted with dioxins is known to extend gradually from the point source - the Kymioki River - to all sides, and have contaminated the sediments in one third of the Gulf of Finland in the depths deeper than 10 cm. In fact, the dioxin content in a single sample collected by Nord Stream in the summer 2009 from the Kymijoki toxic impact area reached 64 pg/g WHO TEQ from the depth of more than 12 cm, confirming the previous views of the dioxin distribution pattern.

The health risk analyses have failed to take into the account the accumulation of dioxins in the breast milk and their potential impact to infants, and the risks of related health problems including developmental malformations and cancer. Nord Stream AG has not taken into account the fact that due to toxicity of the Baltic Sea fishes, Finland and Sweden are already forced to follow the EU regulations for not exporting the Baltic herring and to promote the 200 g total monthly limit for individual consumption of the Baltic herring, salmon and sea trout. These concerns have been pointed out in the official statement of the Finnish Authority of Food Safety EVIRA presented in the context of the EIA. It has been also adequately stated in the statement of the Uusimaa Regional Environmental Centre of July, 2, 2009, but ignored during the further steps of the Nord Stream AG, and, unfortunately also by the Western Finland Permitting Authority who did not ask the opinion from EVIRA.

It is known to EFN that the opinions and positions of Finnish, Estonian and Swedish health authorities and scientists are mostly coinciding or compatible in this question. However, the promoters of the pipeline have continued the march towards the solution that may severely harm the children.

The statements of Nord Stream AG about the number of munitions to be cleared have been controversial. At first, Nord Stream AG claimed on public hearings that no more than 30 mines will be cleared. This has resulted in a permit application to explode 28 munitions. However, it became evident that Nord Stream have prepared an application for clearance of at least 70 more munitions west of Hanko. Moreover, in the Finnish EIA report Nord Stream AG has stated that on the pipeline route and anchor corridor, up to 600-900 munitions should be eliminated.

EFN has used all other opportunities for communicating the relevant information. However, the NGOs were suddenly cut off from the process of environmental impact assessment, with the attempt to formally end the process in a stage where the information is still incomplete and inadequate. In contrast to the statements of Nord Stream about the open consultations, the NGOs have never got an opportunity to express their opinions about the final version of environmental impact assessment. Thus, the only open channel for communicating the NGO opinions is submitting an appeal. The goal of EFN is to move towards more adequate assessments of environmental impacts and evaluation of risks by promoting citizen society and supporting the goals of the Aarhus Convention, the EU EIA directive and the EU Baltic Sea Strategy.

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