Uppsala, Sweden, 2021-06-01
Folketinget
Christiansborg
1240 Copenhagen K
Denmark
Transport Committee
Per Movritsen:
Lea Lykke Andersen:
General email:
Copy:
European Commission
Commissioner Virginijus Sinkevičius
Director General Florika Fink-Hooijer
Director General Charlina Vitcheva
Baltic Sea Parliamentary Conference
Schlossgartenallee 15, 19061 Schwerin Germany
Secretary General Bodo Bahr
RE: Adverse and large-scale environmental impacts of the Lynetteholm project
Dear Madame/Sir,
Coalition Clean Baltic, an international environmental NGO network, uniting 24 organizations from 11
countries of the Baltic Sea Region, would like to express its grave concerns about the proposed Lynetteholm
project in Copenhagen, that is currently under discussion in the Danish Parliament.
Despite being promoted as a flood protection and climate change adaptation measure, the project’s negative
environmental impacts, according to our knowledge, seriously outweigh its merits.
Most obvious and long-term impacts will occur due to traffic congestion for construction purposes as well as
disturbance of the seabed and dumping of sediments due to dredging and reclamation. However, the external
experts are seriously concerned that establishment of Lynetteholm could have disastrous consequences for
the whole Baltic Sea environment, leading to obstruction of one of three deep channels in Øresund and
blocking salt waters inflow to the Baltic Sea. The latter is vital important for bringing oxygen-rich North Sea
waters to oxygen-depleted bottom layers of the Baltic and thus, for balancing fragile and eutrophied Baltic
Sea ecosystem. Blocking this natural process is totally unacceptable given the current poor status of the Baltic
Sea environment and the efforts undertaken by all the coastal nations within HELCOM to improve it.
Henceforth, the environmental impacts of Lynetteholm project are far beyond the area of the construction
site in Øresund and should have been treated through multilateral transboundary EIA, carried out in line with
the Espoo Convention and other respective legislation. It was regretful to learn that only Sweden was
consulted about the project and that its predominantly
negative response,
including on dumping and risks to
Swedish Natura 2000 areas, have been neglected. Germany and some other Baltic countries were only
informed at this very late stage in the project development process, and only after urging requests.
To our understanding this also seriously contradicts with the obligations of Denmark in accordance with the
Helsinki Convention,
1992
(
Art.3,7,15,17, HELCOM Recommendations
40-1, 35-1, 18-2, 17-3),
as well as under
the Directive 2011/92/EU on EIA and Directive 2001/42/EC on SEA.
Given the above, we are calling the Danish Parliament to postpone the decision on the proposed Lynetteholm
project until proper transboundary EIA is carried out and necessary mitigation measures are devised and
agreed with all concerned and affected parties.
Aija Caune,
Chairperson
Coalition Clean Baltic
Mikhail Durkin
Executive Secretary
Coalition Clean Baltic
Coalition Clean Baltic (CCB),
Östra Ågatan 53, SE-753 22 Uppsala, Sweden
Tel:
+46 18 71 11 70 Coalition Clean Baltic CCBnetwork
E-mail:
[email protected]; www.ccb.se
Org. number:
802015-1281
CCB is a member of The World Conservation Union (IUCN)
Coalition Clean Baltic is a network of environmental NGOs sponsored by:
Ecohome, Belarus
IPO Ecopartnership, Belarus
APB Birdlife Belarus
Nerush, Belarus
Center for Environmental Solutions
Danish Society
for Nature Conservation
Estonian Green Movement
Estonian Water Association
Finnish Association for Nature Conservation
Bund für
Umwelt und Naturschutz Deutschland, BUND
Environmental Protection Club of Latvia, VAK
Latvian Green Movement
Lithuanian Fund for
Nature
Polish Ecological Club, PKE
Green Federation - GAJA, Szczecin, Poland
Western Pomeranian Society for Nature Conservation
Friends
of the Rivers of Ina and Gowienica Association
–
TPRIiG Friends of the Baltic, St Petersburg, Russia
Green Planet, Kaliningrad
Swedish Society for Nature Conservation
WWF Sweden
Association SOFIA
The Western Center of the Ukrainian Branch of the World
Laboratory
Ecoterra, Ukraine