LNG terminal by the Finish gulf

The planned terminal would consist of onshore storage tanks with a capacity of up to 320 000 CM, accompanying buildings and facilities and harbour suitable for the LNG tankers with the size of up to 165.000 CM LNG.

The project is located in the municipality of Paldiski by the Finnish Gulf. The area is important for sea birds and is included in the Natura 2000 network as a part of the Pakri Special Protection Area (SPA). The terminal and its use would compromise the protection of long-tailed ducks (Clangula hyemalis), a species whose numbers have rapidly declined in the Baltic Sea area but are still numerous on the Pakri SPA. It would harm the only habitat of black guillemots (Cepphus grylle) in Estonia. Valuable ecosystems on the land area would be also damaged and the project would visually ruin the Baltic klint – a steep seaside cliff submitted to UNESCO as a candidate site of World Natural Heritage.

The project is unique among PCIs as it is only one of alternative terminals in the region that would bring benefits aimed at by PCI rules. Parallel to it, large LNG terminals are also planned in Riga (Latvia), Tallinn (Estonia) and Inkoo (Finland). Any one of the four, which are listed as alternatives to the Paldiski terminal in the current PCI list, would be sufficient to improve security of supply in the region. This means that the realisation of this project is not unavoidable for the protection of common public interests. Nonetheless, the developer has (successfully) used the fact that the project is included in the PCI Unionlist to push the project forward and counter any and all opposition to it.

Environmental NGOs have extensively criticised the project, challenging decisions related to the terminal at national courts. Public participation in the planning of the terminal has been seriously limited. The main problem is that alternative locations outside the Paldiski municipality, which covers only about 100 km2, were not considered in the planning procedure. Therefore it was by no means guaranteed that the location chosen was the most suitable one. The Strategic Environmental Impact Assessment (SEA) has been formally carried out however its quality has also been challenged by the environmental NGOs.

In a J&E Case Analysis 3 projects forming part of the current Unionlist of Projects of Common Interest (PCI) in the area of energy infrastructure where analysed according to their compliance with the TEN-E Regulation and current transparency and public participation standards. The Estonian LNG Terminal by the Finish Gulf was one of them. The entire study is electronically available under: LINK

J&E Position and Recommendations

J&E recognizes the importance of developing and interconnecting energy grids in order to ensure successful implementation of the European energy policy. However, based on the current case studies, we might conclude that:

  • The regional groups in charge of drafting the initial PCI lists have failed to consult with members of the public, including publicly known opponents (even local authorities) to certain projects, when they put together the first PCI list;

  • On the EU level public participation did not compensate for the mistakes made by regional groups. Partly this may be attributed to the fact that national stakeholders did not – for whatever reason - participate at this stage;

  • Public participation in drafting the PCI list is crucial. The lack thereof can lead (and has led) to unjustified preferential treatment and allocation of public funds to harmful projects;

In order to avoid these problems in the future, J&E recommends to:

  • Ensure effective public participation on regional group level; the European Commission as the final decision-maker should take the initiative if regional groups fail to do so;

  • Provide members of the public with meaningful opportunities to participate in consultations on regional as well as on EU level, before the adoption of the final list. We urge the European Commission to pay attention to providing appropriate time-frames as well as giving proper consideration to submitted comments;

  • Include only projects that fulfil necessary criteria without reasonable doubt into the Union-wide PCI list.

J&E has communicated the above recommendations to relevant decision-makers, especially to the DG Energy. Their attitude has been forthcoming and the lay out of the second PCI designation process, which started in September2014 and will be concluded in autumn 2015 provides space for involvement of stakeholders other than project promoters, particularly NGOs. It is too early in the process to assess, whether the changes will allow for a real and effective participation, or have been mere formalities. J&E follows the process and participates in drafting the second EU-wide PCI list.

Justice & Environment, 17th November 2014