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Minister Dennis Naughton. TD,

Department of Communications, Climate Action and Environment

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9 June, 2017

 

Re: Meeting of the Parties (MOP) to the Espoo Convention 13 June

 

Dear Minister,

 

We refer to the seventh session of the Meeting of the Parties (MOP) to the Espoo Convention on environmental impact assessment in a transboundary context, which will take place in Minsk from 13 to 16 June. There are a few issues we would like to draw your attention to.

 

As you know, subsequent to notifications from ourselves and from Bundestag member Sylvia Kotting-Uhl, the Espoo Convention Implementation Committee found that the UK violated international environmental law by failing to carry out a transboundary environmental impact assessment (EIA) in the case of Hinkley Point C. This must now be undertaken retrospectively. The Committee has recommended that the Parties request that the UK suspends work on the project until the transboundary EIA has been completed. Clearly this is vital, as otherwise a mockery would be made of the entire process. It is very important that the Meeting of the Parties adopts and endorse the Implementation Committee’s findings and recommendations in their entiretyAs you will be aware, Ireland failed to answer the Committee's direct question about transboundary impacts when it was investigating this matter. Therefore it is essential that you take a personal interest.

 

Ukraine has unexpectedly said that it is willing to carry out a transboundary EIA in connection with extending the lifetime of individual reactors. This development is a major opportunity to finally reach a binding arrangement for the Parties to the Espoo Convention which would require, in principle, a transboundary EIA to be undertaken in relation to lifetime extensions. We understand that Germany is pressing at EU level for an amendment of the EIA Directive and at international level for a clarification of the legal situation. Ukraine’s initiative must now be used to reopen negotiations regarding this objective and to build coalitions with countries which also fear the prospect of the long-term operation across Europe, of nuclear power plants which are already old and dilapidated today. Involvement in a transboundary EIA prior to lifetime extensions is a valuable instrument for governments and the public to raise concerns and discuss particularly severe problems. We would be grateful if you could clarify whether Ireland is supporting Germany in this regard.

 

We also wish to ask you to support Lithuania in Minsk regarding the lack of an EIA for the construction of a new nuclear power plant at Astravets, Belarus. Belarus is violating the Espoo Convention in several respects and Lithuania will be raising this subject in Minsk. We hope that you will press for compliance with the Convention and with the highest standards for the protection of public safety, health and the environment.

 

Thank you for your consideration of these points which we consider are consistent with your own concerns for nuclear safety and effective international environmental law. We are at your disposal to discuss further in advance of or during the MOP.

 

Sincerely yours,

 

Tony Lowes

 

Directors

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