Call for thorough Strategic Environmental Assessment of the E40 inland waterway project


CCB has repeatedly drawn the attention of the Contracting Parties to the obligation to follow relevant international EIA procedures in case of large infrastructure projects that are planned within the BSR.

To our understanding and knowledge, according to Articles 3, 7 and 17 of the Helsinki Convention, such procedures should be equally applicable to planned projects within the sea itself, as well as within its catchment area e.g. offshore exploration of mineral resources, construction of underwater pipelines, laying cables, construction of ports, navigation canals and inland waterways, as well as other large-scale developments. Respective scale and project type threshold for *EIA/SEA is set by e.g. UNECE Convention on Environmental Impact Assessment in a Transboundary Context, Directive 2001/42/EC on the assessment of the effects of certain plans and programmes on the environment (SEA Directive), Directive 2014/52/EU on the assessment of the effects of certain public and private projects on the environment, national legislation.

As CCB informed already in 2016, the Governments of Poland, Belarus, and Ukraine are currently working on the development of a joint project on backed by EU-funded EMMA “flagship” project under the EUSBSR.

The idea of E40, as well as other inland waterway routes is strongly supported by recently published “Assumptions for the development plans of inland waterways in Poland for 2016-2020 with 2030 perspective” that suggests canalisation of river flows (e.g. Vistula, Odra, Bug Rivers) and construction of navigation routes from Baltic to Black Sea.

From the environmental point of view, it is absolutely unacceptable, as it will

  • a) destroy natural flow of rivers and their ecological functions as important habitats;
  • b) open up the gateway for all kind of biological invasions and
  • c) lead to severe hydrological changes within river basins due to flow regulation.

It will have transboundary implications not only for the countries directly affected (within one river basin) but for the whole BSR. Such developments should at least undergo Strategic Environmental Assessment (SEA) before being put forward for financing with EU money.

SEA requirement under Directive 2001/42/EC equally applies to the project on construction of the navigation canal across the Vistula Spit.

“Restoration of the E40 Waterway on the Dnieper-Vistula Section”, the first phase of which was funded by the European Union under the ENPI within the framework of the CBC Program Poland-Belarus-Ukraine 2007-2013. Currently, this initiative is As in many cases such development projects often refer to the needs of implementation of the European Agreement on Main Inland Waterways of International Importance (AGN), it is important to remind that alike process in the Danube River basin has led to adoption by the International Commission for the Protection of the Danube River (ICPDR) of the Joint Statement on Guiding Principles on Development of Inland Navigation and Environmental Protection in the Danube River Basin. The principles clearly state the need for SEA in case of such large-scale inland waterways projects.

Meanwhile, NGOs from Vistula, Pripyat, and Dniepr river basins have initiated in 2017 a joint campaign addressing the proposed E40 project.

Action requested

The Meeting is invited to

  • take note of the information;
  • call the Governments of Poland, Belarus, and Ukraine to undertake thorough SEA of the proposed E40 project and to provide the public with access to both information and decision-making with regards to the aforementioned project (via public consultation);

Call for thorough Strategic Environmental Assessment of the planned E40 inland waterway

The Belarus environmental alliance has called on the European Union to block the planned construction of the E40 waterway between the Baltic and the Black Sea.

The Belarus environmental alliance has sent an appeal against the projected E40 waterway to the European Union and other international organizations. The environmentalists are urging the organizations to support a petition to terminate the project, which would connect the Baltic and the Black Sea. The appeal was sent on behalf of forty-two non-governmental organizations and a number of local residents from three nations: Belarus, Ukraine, and Poland. Online petitions have been signed by 25,910 Belarusians and Ukrainians, and by 23,371 Poles.

The defenders of the Pripyat River invite investors’ attention to highly adverse consequences of E40 project implementation and call for ultimate abandonment of plans to fund the project. The appeal was sent to the governments of three countries, the European Parliament, the Secretariats of the Århus and Espoo Conventions, and to several investment banks.

The construction project involves major changes to the stream conditions of the Rivers Vistula, Muchaviec, Pina, Pripyat and Dnieper, and the Dnieper-Bug Canal, all of which would make up the waterway. New levees and dams could appear on the pristine rivers, their course straightened and their banks covered in concrete.

The developers call the project a “reconstruction” of the waterway, as design work started in late 2013 and still continues. However, the rivers are currently not navigable by the vessel category in question, so implementation of the project would require a large amount of river development, which would cause significant interference with the river ecosystems.

We want to draw the attention of the European Parliament, Poland, Belarus and Ukraine, and other keysEuropean institutions to the issue, and to demonstrate that any decision to be made on the project mustinvolve the participation of the public and independent experts”, – Volha Kaskevich, head of the Bahna organization and campaign coordinator, says.

“Besides, the project is transboundary in nature and falls under international conventions, so requirements for the project must meet European standards and its adverse consequences must be considered in a comprehensive way. Project representatives have refused to provide us with the complete package of documents including a feasibility study. An environmental impact assessment for this nation [Belarus] has not been performed to date, and local residents or representatives of the conservation areas have not been informed about an upcoming plan to build a waterway across Belarus’ most important environmental network of designated natural areas. We have personally informed government agencies about the upcoming plans and received negative feedback and statements of concern from these institutions including the National Academy of Sciences, the Central Research, and Institute for Complex Use of Water Resource, the Polesye State Radiation-Ecological Reserve, and others”.

The NGOs, such as APB BirdLife Belarus, Bahna, Ecohome, Center for Environmental Solutions, Green Network, Foundation for a Clean Pripyat and Time of the Earth, launched the Stop E40! campaign after residents of the Polesye region began to approach Belarusian environmental organizations in June 2016 with requests to collect signatures under a petition against the E40 waterway and provide their expert opinion.

The river protection campaign saw the launch of the Stop E40! awareness-raising website, where experts have presented their assessments of the E40 idea while focusing on the economic and environmental sides of the project. Special emphasis was given to radiation safety, as the E40 would cross areas affected by the Chernobyl nuclear disaster.

“The project is fraught with the greatest danger for Ukraine,” – Aleksey Vasilyuk of the Environment People Law charity comments.

“After the Chernobyl accident, which came at the beginning of the spring flood, the Pripyat washed a huge amount of contaminated sand into the Kiev Reservoir. Thanks to prompt engineering measures, the radioactive sand and silt were buried at the bottom of the reservoir. For over thirty years, there has been no navigable channel, because if we disturb the sediments, we are sure to send the contaminated silt flowing down to Kiev. For that reason, Ukraine has even abandoned the project of a beltway across the reservoir. Besides that, the entire reservoir cascade in that area is part of the Emerald Network. The Dnieper course is home to two nature reserves, six national parks, and more than twenty conservation areas. On top of that, the entirety of the Pripyat delta is included in the Chernobyl Radiation and Environmental Biosphere Reserve, established by Ukrainian President Petro Poroshenko in 2016”.

The WWF Poland office has been working on the subject for years and voices its concerns publicly: “The Polish government plans to build a ‘water highway’ under the slogan, ‘develop the greenest transport ever”, says Edyta Jaszczuk, a junior freshwater protection officer with WWF Poland.

“Growth in navigation along the Vistula River would involve the construction of nine dams between Warsaw and Gdansk. This spells ruin for the mid-channel of the beautiful river with a pan-European character, which would be replaced with a series of artificial reservoirs filled with toxic blue-green algae in summer and dangerous ice jams in winter.

“The E40 waterway construction would lead to enormous destruction of the wildlife along the banks of the Bug River, one of the most valuable natural rivers in Europe in terms of size, as well as the Pripyat River in Belarus, one of the most important European natural rivers.”

Any company or private individual can join the campaign against the construction of the E40. Organizations can express their opinions by filling out the form on our website, and individuals, by signing the online petition.

As spearheads, campaigners and local residents, we need your opinions, to keep you updated on potential threats, and to ensure that your opinions are properly considered when decisions are made.

Twenty Belarusian non-governmental organizations have signed the petition: APB BirdLife Belarus, Bahna, Ecohome, Centre for Environmental Solutions, Time of the Earth, Foundation for a Clean Pripyat, Ecopartnership, Ekamajsterni, Center for the Ethical Attitude Towards Nature, Lew Sapieha Foundation, Land Reform, Post Education Center, In the Name of Life Center for Cancer Patient Support, Lawtrend Center for Law Transformation, Minsk Cycling Association, Office for European Expertise and Communications, ACT, Kryly Halopa Theater, Brest Fortress Development Foundation, and Za Velobrest.

Thirteen Ukrainian NGOs have signed: Park Friends, Kray, National Ecological Centre of Ukraine, Green Future Wildlife Protection Brigade, Pechenegs Environmental Group, Ukrainian Nature Conservation Group, Nikopol Chapter of the International Dnieper Foundation, Western center of the international center for scientific culture Ukrainian branch, Green World Ukrainian Environmental Association, charitable foundation for children’s relief from the Chernobyl aftermath and Ekosphera. The international charity Environment Law People has started an independent inquiry into the environmental components of E40-related risks.

In the European Union, this stance against the construction of the Е40 was shared by the European Wilderness Society, Greenpeace CEE, Fundacja Dzika Polska, France Nature Environnement (Agir pour l’environnement), Ramsar International and Wetlands International, WWF Poland, Coalition Clean Baltic, Rivers without Borders. RiverWatch and European Wilderness Society have published letters of support.

A full list of the institutions that have been sent letters expressing the stance is here: the World Bank, the European Bank for Reconstruction and Development, the Chancellery of the Prime Minister Poland, the Administration of the President of the Republic of Belarus, the Administration of the President of Ukraine, the Council of Ministers of the Republic of Belarus, the Verkhovna Rada of Ukraine, the Cabinet of Ministers of Ukraine, the European Commission, the European Parliament, the Secretariat of the Convention on Environmental Impact Assessment in a Transboundary Context, and the Secretariat of the Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters.

© Bahna
© Bahna
© Bahna