What is a public participation process without the public? It's nonsense. But it's going to become bitter reality in the case of the public participation process on the completion of the two nuclear reactors at Khmelnytsk and Rivne in Western Ukraine.
Why public participation at all? To provide a public participation process is one of the requirements of the European Bank for Reconstruction and Development (EBRD) which is considering financing the completion of the two reactors with a loan of $190 million.
During the next four months Energoatom, Ukraine's state nuclear company, has to give interested people in Ukraine and other countries the opportunity to ask questions and give comments on this nuclear project by phone, fax, mail, e-mail and at public meetings. All comments and questions will be submitted to the EBRD and will be taken into account when the EBRD makes its final decision to give the loan – or not to give it.
In an article published in the Post on Sept. 1, Len Green, an EU consultant and advisor to Energoatom, was quoted as saying: 'I worked in the United Kingdom in the energy sector and can testify that this campaign of public consultation is by far one of the most impressive I have ever seen.'
We can't tell what Mr. Green has seen before in the United Kingdom, but we can tell, that there is nothing impressive, but chaotic about the first 16 of the 120 days long public participation process:
1. There haven't been advertisements or radio or TV announcements on the start of the PPP in order to publish the addresses, phone numbers or e-mail addresses which enable the public to take part in the public participation process. So actually few in this country except those professionals who are dealing with this issue yet knows how to get involved in the public participation process.
2. People in the city of Rivne – those few people who know about the public participation process – had to wait 15 days until they got access to the Environmental Impact Assessment (EIA) documentation in the Information Centre at the Rivne Oblast Administration.
3. Even now, 16 days after the official launch of the public participation process, the full version of the EIA has not been sent out to the registered environmental organizations. More than that the EIA is expected to cost about $100 (which is equal to more than the half of an average Ukrainian salary). Much cheaper (about $20 or 10 percent of an average Ukrainian salary) will be a CD-ROM. So, environmental organizations have 'only' to buy a computer with a CD-ROM drive. Energoatom also refused to publish the EIA on a World Wide Web site in the Internet because of 'technical reasons'. This is at least a strange explanation for a company which is running nuclear power plants.
4. Several environmental organizations which have been registered by Energoatom have not been notified about the start of the public participation process, because Energoatom's database was accidentally corrupted and has to be rebuilt now to repeat this notification process.
5. Public hearings will be organized not in the cities of Rivne and Khmelnytsk, but in the cities of Kuznetsovsk and Neteshin, which to reach from the cities of Rivne and Khmelnytsk takes about two three hours by public transport (and about $8 both ways, which is too much for the majority of people).
Also Energoatom is considering scheduling the public hearings for November or even December as 'final hearings'. To have the hearings close to the end would mean they lose their function as a catalyst for the public participation process.
This chain of mistakes and delays, taken together, gives the impression either of ignorance and lack of professionalism or of the unwillingness of Energoatom to have a true broad public participation process based on openness and transparency. That means that Energoatom is far from fulfilling the criteria of the EBRD.
Why is Greenpeace so concerned about all those details? It is because Greenpeace is taking the official EBRD policy very seriously and because we are convinced that the EBRD is, according to its own guidelines, not allowed to approve the loan for this nuclear project.
Greenpeace and other environmetal organizations will prove that in the coming weeks. The main reasons why the EBRD cannot give financing for the reactors are: The completion of the Rivne and Khmelnytsky nuclear reactors is not the least cost option as required by the EBRD. As an independent expert panel commisioned by the EBRD and led by Prof. John Surrey (University of Sussex) has shown in its least cost study, it is much more economic to invest the same amount of money into energy efficiency measures and the rehabilitation of thermal power plants. The completion of the two reactors is not financially viable, because it is unlikely that Energoatom will ever be able to pay the EBRD loans back while it is receiving cash payment for only 3.6 percent of the electricity it supplies.
The completion of the reactors – in the form which is officially proposed now – is not meeting the highest Western nuclear safety standards as required by the EBRD.
There is no real public participation process as required by the EBRD.
It's not only that Ukraine has proved by the tragic experience of the Chernobyl catastrophe how dangerous nuclear power is. It is also clear that Ukraine simply doesn't need more power plants.
Ukraine has an installed capacity of 54 GW while the peak capacity level was in 1997 at 27 GW. The electricity shortages are caused by low efficiency and a deficit of fuel, not of power plants. So nobody needs those additional nuclear power plants.
Nobody? Some people need the nuclear power plants very much: Energoatom and the Western nuclear industry which wants to 'help' Ukraine to build the two reactors – for hundreds of millions dollars of course.
(Tobias Muenchmeyer is the international coordinator of the Greenpeace nuclear campaign)
What is a public participation process without the public? It's nonsense. But it's going to become bitter reality in the case of the public participation process on the completion of the two nuclear reactors at Khmelnytsk and Rivne in Western Ukraine.
Why public participation at all? To provide a public participation process is one of the requirements of the European Bank for Reconstruction and Development (EBRD) which is considering financing the completion of the two reactors with a loan of $190 million.
During the next four months Energoatom, Ukraine's state nuclear company, has to give interested people in Ukraine and other countries the opportunity to ask questions and give comments on this nuclear project by phone, fax, mail, e-mail and at public meetings. All comments and questions will be submitted to the EBRD and will be taken into account when the EBRD makes its final decision to give the loan – or not to give it.
In an article published in the Post on Sept. 1, Len Green, an EU consultant and advisor to Energoatom, was quoted as saying: 'I worked in the United Kingdom in the energy sector and can testify that this campaign of public consultation is by far one of the most impressive I have ever seen.'
We can't tell what Mr. Green has seen before in the United Kingdom, but we can tell, that there is nothing impressive, but chaotic about the first 16 of the 120 days long public participation process:
1. There haven't been advertisements or radio or TV announcements on the start of the PPP in order to publish the addresses, phone numbers or e-mail addresses which enable the public to take part in the public participation process. So actually few in this country except those professionals who are dealing with this issue yet knows how to get involved in the public participation process.
2. People in the city of Rivne – those few people who know about the public participation process – had to wait 15 days until they got access to the Environmental Impact Assessment (EIA) documentation in the Information Centre at the Rivne Oblast Administration.
3. Even now, 16 days after the official launch of the public participation process, the full version of the EIA has not been sent out to the registered environmental organizations. More than that the EIA is expected to cost about $100 (which is equal to more than the half of an average Ukrainian salary). Much cheaper (about $20 or 10 percent of an average Ukrainian salary) will be a CD-ROM. So, environmental organizations have 'only' to buy a computer with a CD-ROM drive. Energoatom also refused to publish the EIA on a World Wide Web site in the Internet because of 'technical reasons'. This is at least a strange explanation for a company which is running nuclear power plants.
4. Several environmental organizations which have been registered by Energoatom have not been notified about the start of the public participation process, because Energoatom's database was accidentally corrupted and has to be rebuilt now to repeat this notification process.
5. Public hearings will be organized not in the cities of Rivne and Khmelnytsk, but in the cities of Kuznetsovsk and Neteshin, which to reach from the cities of Rivne and Khmelnytsk takes about two three hours by public transport (and about $8 both ways, which is too much for the majority of people).
Also Energoatom is considering scheduling the public hearings for November or even December as 'final hearings'. To have the hearings close to the end would mean they lose their function as a catalyst for the public participation process.
This chain of mistakes and delays, taken together, gives the impression either of ignorance and lack of professionalism or of the unwillingness of Energoatom to have a true broad public participation process based on openness and transparency. That means that Energoatom is far from fulfilling the criteria of the EBRD.
Why is Greenpeace so concerned about all those details? It is because Greenpeace is taking the official EBRD policy very seriously and because we are convinced that the EBRD is, according to its own guidelines, not allowed to approve the loan for this nuclear project.
Greenpeace and other environmetal organizations will prove that in the coming weeks. The main reasons why the EBRD cannot give financing for the reactors are: The completion of the Rivne and Khmelnytsky nuclear reactors is not the least cost option as required by the EBRD. As an independent expert panel commisioned by the EBRD and led by Prof. John Surrey (University of Sussex) has shown in its least cost study, it is much more economic to invest the same amount of money into energy efficiency measures and the rehabilitation of thermal power plants. The completion of the two reactors is not financially viable, because it is unlikely that Energoatom will ever be able to pay the EBRD loans back while it is receiving cash payment for only 3.6 percent of the electricity it supplies.
The completion of the reactors – in the form which is officially proposed now – is not meeting the highest Western nuclear safety standards as required by the EBRD.
There is no real public participation process as required by the EBRD.
It's not only that Ukraine has proved by the tragic experience of the Chernobyl catastrophe how dangerous nuclear power is. It is also clear that Ukraine simply doesn't need more power plants.
Ukraine has an installed capacity of 54 GW while the peak capacity level was in 1997 at 27 GW. The electricity shortages are caused by low efficiency and a deficit of fuel, not of power plants. So nobody needs those additional nuclear power plants.
Nobody? Some people need the nuclear power plants very much: Energoatom and the Western nuclear industry which wants to 'help' Ukraine to build the two reactors – for hundreds of millions dollars of course.
(Tobias Muenchmeyer is the international coordinator of the Greenpeace nuclear campaign)
