July 11, 2002
Mr. Ian Gillespie
Export Development Canada
Ottawa, Ontario K1A 1K3
Dear Mr. Gillespie,
We are writing to urge you to refrain from extending support for the Cernavoda 2 nuclear reactor in Romania. There are key questions that remain outstanding on this project, questions that need to be answered before a public financial institution approves its support.
Question#1: Is Romania in violation of the Espoo Convention?
The Convention on Environment Impact Assessment in a Transboundary Context (Espoo, 1991) stipulation the obligations of Parties to assess the environmental impact of certain activities 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. Romania and all neighbouring states, with the exception of Yugoslavia have ratified the Espoo Convention. The Cernavoda nuclear power plant (NPP) is close to the Bulgarian border, so it is communication with Bulgaria that is of most interest. According to colleagues in Bulgaria, the Bulgarian Ministry of Environment and Waters have confirmed that they have not received any written documentation or any notification through Espoo Convention contact person on Cernavoda NPP. It therefore appears that Romania is in violation of Article 3, para 1 on notification.
EDC’s extension of support at this time would therefore condone the violation of international law.
Question #2: Has host country laws in regards to Environmental Impact Assessment been followed, as a minimum?
According to Romanian environmental protection law, the government has to consult locally affected communities on the final EIA, yet public consultations on an EIA have not taken place. According to local contacts, this is because the Romanian government has yet to finalize it own EIA. EDC and others are reviewing the EIA prepared by SNN/AECL, instead of one completed by the government and reviewed by local communities. EDC’s extension of support before the completion of the Romanian government’s EIA is premature.
I look forward to hearing your response to our request.