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Anti-Atom-Bündnis in Berlin und Potsdam

In Polen läuft derzeitig eine öffentliche Konsultation zum "Polnischen Kernenergieprogramm".

Falls jemand schnell noch eine Einwendung nach Polen schicken möchte, hier etwas Inspiration. Ihr könnt gerne auch richtiges Englisch daraus machen. Und gerne in Berlin, Brandenburg, Mecpom und Sachsen weiterverteilen. Einwendungsschluss in Polen ist schon „vor dem 21. August“. Ich habe auch erst vor ein paar Tagen davon erfahren.


Viele Grüße,

Brigitte Artmann




To Ministerstwo Klimatu

Ul. Wawelska 52/54, 00-922 Warszawa

Tel (+48 22) 36-92-900

E-mail: Diese E-Mail-Adresse ist vor Spambots geschützt! Zur Anzeige muss JavaScript eingeschaltet sein!

Only by e-mail

Subject: Submission - Konsultacje publiczne projektu uchwały Rady Ministrów w sprawie aktualizacji programu wieloletniego pod nazwą „Program polskiej energetyki jądrowej"/ Polish Nuclear Energy Programme 2020


Dear Madam and Sir,


Please confirm receipt of my submission.

Some days ago I heard that there is a consultation “Polish Nuclear Energy Programme 2020” done only in Poland. I was told, that the end of this national consultation should be already “before” the 21st August 2020. Unfortunally I cannot read or speak Polish.

The „Program polskiej energetyki jądrowej" (PPEJ 2020) is a plan and programme relating to the environment as defined under the Aarhus Convention.

According to the Aarhus Convention art. 7, Poland is obliged to make “appropriate practical and/or other provisions for the public to participate during the preparation of plans and programmes relating to the environment, within a transparent and fair framework, having provided the necessary information to the public.”

Nuclear power plants in Poland will affect the Baltic Sea either directly if built at the sea shore, or by the rivers. The following source term from the University in Vienna proofs that a nuclear fallout of the planned NPP Lubiatowo at the Baltic Sea will contaminate Germany - when the winds will change to the east or north.

Picture - Source: IMGW, University of Vienna,

Therefore, as a member of the German public concerned, I demand a transboundary Strategical Environmental Assessment (SEA) procedure under the Espoo Convention and the Aarhus Convention.

By doing only a national consultation and not a transboundary SEA, Poland is violating the Aarhus Convention, the Espoo Convention and European Law:

Aarhus 3(9): Within the scope of the relevant provisions of this Convention, the public shall have access to information, have the possibility to participate in decision-making and have access to justice in environmental matters without discrimination as to citizenship, nationality or domicile and, in the case of a legal person, without discrimination as to where it has its registered seat or an effective centre of its activities.

Espoo 2(6): The Party of origin shall provide, in accordance with the provisions of this Convention, an opportunity to the public in the areas likely to be affected to participate in relevant environmental impact assessment procedures regarding proposed activities and shall ensure that the opportunity provided to the public of the affected Party is equivalent to that provided to the public of the Party of origin.

SEA Protocol 3(7): Within the scope of the relevant provisions of this Protocol, the public shall be able to exercise its rights without discrimination as to citizenship, nationality or domicile and, in the case of a legal person, without discrimination as to where it has its registered seat or an effective centre of its activities.

The SEA Directive also prescribes a transboundary SEA for "any modification" of plans and programmes. New basic documents have been included in the PPEJ 2020 (e.g. PEP 2040, the EU Green Deal), time-frames have been modified, financial and economic argumentation and organisational set-up have been modified, as well as many other factors.

The SEA of the PPEJ from 2014 has taken public participation insufficiently into due account. This should have been repaired in this modification of the PPEJ, but it has not. According to Aarhus Convention art. 6(8), public participation concerning the environment has to be taken into due account.

The Aarhus Convention then stipulates that articles 6 (3, 4 and 8) shall be applied. The Aarhus Convention, art. 6(3) prescribes “reasonable time-frames for the different phases, allowing sufficient time for informing the public in accordance with paragraph 2 for the public to prepare and participate effectively during the environmental decision making.”

Given the fact that nuclear power is an “ultra-hazardous activity”, the Aarhus Convention Compliance Committee concluded in its findings ACCC/C/2013 /91, par. 75: “It is clear to the Committee that with respect to nuclear power plants, the possible adverse effects in case of an accident can reach far beyond State borders and over vast areas and regions. For decision making that relates to complex and ultra-hazardous activities such as nuclear power plants, it is therefore important to secure public participation appropriate to that activity with respect to these areas and regions both within and beyond the State borders of the Party concerned.”

This supports the case for a transboundary procedure, and certainly highlights the need for delivering documentation at least also in English and German.

Yours sincerely,


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