Sample
letter
To:
Pedro Solbes
Commissioner for Economics and Finance
European Commission
pedro.solbes-mira@cec.eu.int
Justina Bermudez
Energy Advisor
Commissioner for Economics and Finance
justina.bermudez@cec.eu.int
SUBJECT: Cernavoda 2 NPP project, Romania
Dear Commissioner Solbes and Commissioner Bermudez,
I am writing to you regarding the European Commission's
proposal to use Euratom funding to support the completion of reactor
unit 2 at the Cernavoda nuclear power plant (C2). I would like to
share my concerns regarding such a project.
Besides environmental and safety concerns associated
with any nuclear project, please allow me to bring to your attention
a few economic and legal concerns associated with the C2 project:
* Since 1990, electricity demand has dropped to
such an extent that the country has an enormous energy surplus (installed
capacity is more than twice as large as operational capacity). Furthermore,
government forecasts regarding energy consumption in Romania in
the medium term count on an annual increase of end use demand of
about 2.5 per cent, which is not a dramatic growth. So why the need
for further power plants?
* Romania loses over 20% of its electricity during
transmission and distribution. Any upswing in demand could be covered
by the existing surplus and by simple investments into modern distribution
facilities.
* The Romanian government plans to export most
of the electricity produced at C2, but is there even any foreign
demand? Moldova has failed to pay for Romanian electricity over
the last few years, and there is no significant demand from other
countries.
* The Romanian government has not fulfilled the
requirements of the Espoo convention on Environmental Impact Assessment
in a Transboundary Context. Only Bulgaria was the only neighboring
to receive notification and summary documentation from the Romanian
government, in December 2002 -- a year after public consultations
were held in Romania. However, Espoo requires countries to notify
concerned parties as early as possible and no later than when
informing its own public about that proposed activity" (article
3.1). Also, the EIA document provided to Bulgaria is different from
the one presented in Romania and does not contain all required information.
Considering these circumstances and legal violations,
I ask you not to approve a Euratom loan for the completion of Cernavoda
unit 2 until the Romanian government can meet all requirements on
public consultations. This means meeting Espoo requirements by providing
EIA documentation to all potentially effected countries -- Bulgaria,
Moldova and Ukraine.
I also am calling on you to make public the economic
assessment study for the Cernavoda unit 2 completion project prepared
by the EIB, as there are strong doubts as to whether this project
even makes sense from an economic point of view.
Sincerely,
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