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This article was written by Dr. Alan Riley, Senior Fellow Institute for Statecraft*

There are a number of environmental questions surrounding the Nordstream 1 & 2 Pipeline Projects. 

Most of the discussion surrounding Nordstream 2 has focussed on the energy security, EU energy law and compliance with EU Energy Union policy issues. There is however another major and largely overlooked issue: The environment. The Baltic Sea is one of the most environmentally sensitive and fragile bodies of water on earth. There are a range of concerns from the route of both Nordstream 1 and 2 which takes the pipelines through two World War Two munitions dumps; to the security and environmental implications of concentrating 20% of Europe?s natural gas supply down one narrow undersea route; through to failures in the operation of the Environmental Impact Assessment process and the growing dangers from ageing chemical weaponry dumped in the Baltic Sea. The argument made here is that there are number of significant environmental concerns that must be addressed. This paper recommends a series of measures from the EU and the Member States from a distinct new route for NS2; to an independent second EIA assessment; to considering establishing a liability fund funded by Nordstream to compensate injured fisherman.

 It is clear that the Baltic Sea is a very environmentally sensitive body of water. In 2004 the International Maritime Organisation designated the Baltic Sea as a particularly sensitive sea area. This is an understandable decision as the mean depth of the Sea is only 54 metres and because of its enclosed nature with a shallow entrance at the Danish Kattegat of only 23 metres the complete renewal of the waters of the Black Sea takes over two decades. As a consequence the release of any chemicals or fossil fuels into the Sea is likely to be significantly more damaging in its impact on the environment than if such a release occurred in the Atlantic Ocean or North Sea.

The view could be taken however that whilst it is true that Nordstream 1 is the largest piece of infrastructure in the Baltic Sea, the environmental issues were successfully dealt with the 2009 Environmental Impact Assessment, and that same approach can be deployed for Nordstream 2. In fact Nordstream filed its first Environmental Impact Assessment for NS2 in April 2017 on similar lines to the NS1 EIA. However, the filing of an EIA does not deal with all the environmental issues. There are a number of questions that should be of concern to policymakers, regulators and the public.

The first question concerns the wisdom of building a second set of pipelines more or less in parallel with the NS1 route. This means that pipelines carrying approximately 20% of European natural gas supply are flowing along one undersea route. Some of the risks that flow from such a concentration of supply include the danger of vessels trawling or anchoring near the pipeline or an old mine or other piece of conventional weaponry going off near the pipelines. Any pipeline rupture for instance caused by anchoring or trawlering which then led to ignition caused by the proximity of the vessel that caused the rupture would be likely to lead to damage to all four pipelines causing significant supply disruption. The potential of disruption to supply by such events is not theoretical. In 2015 NS1 gas supplies was suspended while the Swedish Navy removed mines found close to the NS1 pipelines.

By so enhancing the vulnerability of Europe?s natural gas supply by the route concentration created by building NS2 next to NS1, Nordstream is creating for Europe the sort of energy security and environmental vulnerability that exists in the Straits of Malacca and the Straits of Hormuz. No state or group of states if seriously considering their own interests would assent to creating a man made ?Straits problem? with all the potential security and environmental problems that flow from having so much energy resource flowing through one narrow sea point.

This security view is reinforced by the environmental concern over the route of both Nordstream 1 and Nordstream 2. It remains perplexing how the original EIA in 2009 could propose and have accepted the current route of NS1. Given the environmentally sensitive nature of the Baltic Sea why build the pipeline in the Sea at all? It could have been built on land for example, by building a second Yamal pipeline through Belarus and Poland rather than through the Baltic Sea. Even if one was to build a pipeline through the Baltic Sea why did NS1 take a route directly through the World War Two munitions dumps in the Gotland and Bornholm Deeps? If a pipeline is to be built in the Baltic Sea surely it would be environmentally safer to build it through waters to the south of Gotland and Bornholm Deeps? Clearly that would mean that any pipeline would run through the exclusive economic zones of the Baltic States and Poland. Nordstream may not want to be subject to the regulatory processes of the Baltic States and Poland but that is not a credible argument in respect of an environmental assessment.

A second major issue is the Nordstream 2 environmental regulatory process. There is a real concern here that the NS2 process will operate in a silo where it deals entirely with NS2 with no reference to NS1. Regulators will be dealing with assessments and projections of the impact of NS2 when in fact there is the potential for a real world environmental impact assessment by assessing the environmental impact of NS1. The argument therefore is that before any NS2 regulatory process is commenced an independent assessment is required of the environmental impact of NS1 in order to be able to properly inform regulators of the potential environmental impact of NS2.

What also underpins the need for a full assessment of the environmental impact of Nordstream 1 is that the structure of the seabed changes over time due to the state of the sea, currents and other natural processes. These factors all put pressures on the NS1 pipelines and the infrastructure built to support the pipelines. Furthermore, if NS2 is built next to NS1 the sea and seabed will be subject to additional pressures which can only be assessed looking at the impact of all four pipelines.

These pressures at sea bed level also have an impact on the questions concerning the chemical and conventional weapons dumped at sea after World War Two. Helcom estimated in a 1994 report that more than 40,000 tonnes of chemical weapons were dumped after WW2. More recent studies suggest that the number is significantly greater and that 58,000 tonnes of chemical weapons were dumped in the Bornholm Deep alone. In addition, there was also a Soviet practice not just to dump weapons in the Bornholm and Gotland Deeps but also scatter weaponry across the sea bed (largely managed by sub-contractors).

The concern here is that the chemical munitions issue due to continuing pressures at sea bed level, corrosion of casing and trunks in which the chemical weapons are held and potentially the impact of the development of NS1 have made release of chemicals from the weaponry into the natural environment more likely. The passage of time is likely to increase the likelihood of releases of chemicals as seabed pressure and corrosion over 70 years bears down on the chemical munitions on the sea floor.

Pulling up chemical weapons such as mustard gas shells from the depths is no small issue. Such shells even if 70 or more years old are still potent. Even today fishermen across the Baltic Seas still pull up chemical weapons. Between 1995 and 2005 Danish fishermen recovered more than 100 chemical weapons, some of which caused injuries. In 2005 three Dutch fishermen were killed by an explosion from a conventional weapon they pulled up from the seabed.

A major concern therefore is that building NS1 and now NS2 through two major munitions dumps combined with the danger flowing from the age of the weaponry and natural pressures on the sea bed increase the danger to fisherman principally but also other workers and inhabitants of the coastal areas of the Baltic Sea.

A third factor is the concern that the EIA for Nordstream 1 2009 was defective. At the time the World Wildlife Fund produced a scathing critique of the EIA arguing that the negative implications for the marine environment were much more severe than alleged by Nordstream?s EIA. The WWF report found significant gaps in the evidence base, a tendency to minimise environmental impacts and the overlooking of a number of significant environmental issues. The concern is that these same flaws will appear in the EIA?s Nordstream 2 is now filing with the affected states. 

This fear is strengthened by a recent report from Greenpeace Russia regarding the location of the Russian landfall section of Nordstream 2. The focus of Greenpeace?s concern is the Kurgalisky nature reserve. The report argues that the selection of a route through the reserve overlooks numerous protected and threatened species. That the information provided by Nordstream does not provide a full picture of the southern part of the reserve the pipeline would pass through-which has the effect of underplaying the environmental impact. Other parts of the report raise concerns regarding the quality of the information which indicate for instance that the wildlife will be safely at a distance from the route of the pipeline, when in fact the legislative requirements for pipelines in Russia for a ?clean strip? in which the pipelines sit mean that the wildlife habitats will be destroyed.

Of further concern is that the Russian authorities appear now to be taking steps to reduce the size of the nature reserve so that the pipeline can be rolled out free of the regulations that bind the nature reserve. The report also notices that while on the German landfall side significant steps are being taken to reduce the environmental impact of the pipelines, no such attempts are being made on the Russian landfall side.

Nordstream may well be able to answer all these questions and they should be given the opportunity to do so. The EU and the Member States have also to consider their own interests. One clear interest is to insist that route concentration is both a security threat and raise environmental concerns-and that a different route for NS2 will have to be found which is not near NS1. The second issue is that before any permitting can be undertaken for NS2 a full independent assessment of the environmental impact of NS1 is required so that Member State regulatory authorities can assess the actual impact of a pipeline already in operation in the Baltic Sea. Third, for both NS1 and NS2 the Ramboll group has been paid by Nordstream to undertaken the EIA process. Given the concern expressed by a number of environmental NGOs as to the effectiveness of that process, transparency requires a full second assessment carried out by a wholly independent expert group chosen by the Member States or the EU on their behalf. Fourth, there is one environment, not a German or Russian environment, and damage to one part of the Baltic Sea is likely to affect other parts of the Baltic Sea. Therefore, the states affected by the proposed NS2 should insist on a common minimum environmental standard to be applied to all environmental processes and those processes should be subject to an independent international regulator. Finally, given the potential dangers to workers connected to the Baltic Sea and particularly fishermen pulling up munitions from the depths consideration has to be given in respect of how best to protect fisherman and other workers in sea related activities. An assessment is required of the potential extra danger of dislodging munitions caused by the development of NS1 and NS2. The danger needs to be properly assessed and if necessary a Nordstream funded liability regime established.

Just because the first set of Nordstream pipelines were built and were only subject to limited scrutiny should not be a reason why a proposed second set of pipelines should also be subject again only to limited scrutiny. Furthermore, the compound security and environmental consequences of route concentration-of having four pipelines carrying 20% of Europe?s gas supply has to be fully investigated and considered and alternative proposals recommended where justified.

* Dr Riley is an adviser to PGNIG and Naftogaz.

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