Open letter to the new minister of environment L. Solymos
SLOVAK UNION OF NATURE AND LANDSCAPE PROTECTORS
WORKING GROUP „Košice 2013“ (ZO SZOPK Košice 2013)
Ulica pokroku 7, 040 11 Košice, tel: +421 905 384171, email@example.com
Ing. László Solymos – minister of environment
Ministry of Environment of the Slovak Republic
Nám. Ľudovíta Štúra 1
812 35 Bratislava
Košice, 15 April 2016
We would like to congratulate you to your appointment as the new minister of environment of the Slovak Republic and we would like to wish you a lot of success in your work.
We are pleased with your press statement saying that as the new minister you would like to carry out open policy in the framework of so-called green partnership and to communicate with experts, unions and non-governmental organizations. We – the Slovak Union of Nature and Landscape Protectors, working group “Košice 2013” – would also like to contribute to this open communication. Our organization, besides several other activities aimed at environment protection in Košice (such as protection of trees and parks in the city or support of environment-friendly transport), is since 2013 strongly devoted especially to prevention of one of the biggest possible future dangers to the environment of the citizens of Košice and its neighbourhoods, i.e. to prevention of mining and processing of radioactive minerals in the Jahodná-Kurišková recreational area.
With regards to the above, we are unfortunately forced to state, that our efforts to prevent uranium mining and processing in Košice have been rarely greeted by willingness to help from the previous administration of the Ministry of Environment. On the contrary, even though the primary goal of the ministry of environment is (or at least should be) protection of the environment, in the previous years we were witnessing several decisions of the ministry, by which it was repeatedly acting so as to please companies trying to push through uranium mining in Košice instead of protecting the interests of the affected people and the affected municipalities who are strictly and resolutely against it. As an example illustrating this, we can mention the resolution of the ministry of environment dated 31 January 2013, by which it approved an extension of the licence for uranium exploration in the Čermeľ-Jahodná exploration area until 19 April 2015 without inviting the affected municipalities to participate in the proceedings and without taking into account their negative opinions. This way the ministry has broken the law (in response to the breach, an official protest has been raised by the general prosecutor's office). Other clear examples of inappropriate willingness of the ministry to help the uranium company are resolutions from June 2015 concerning the proceedings related to the company's application for a new exploration area named Kamenné (to be established in the same locality), by which the ministry excluded from the proceedings all the affected municipalities that expressed their wish to be officially recognized as the affected parties. (These resolutions were later canceled by the minister based on the municipalities' appeals, however, the minister didn't grant the municipalities the status of affected parties, he just returned the matter to the section that issued the original resolutions to be decided anew – the section hasn't issued new resolutions so far.)
What motivated us the most to write you this letter was the finding that the ministry of environment had on 7 April 2016 (i.e. already after you took the office) resumed the proceedings related to the application for a new exploration area Kamenné in the territory of the Jahodná uranium deposit (the application was formally declared for exploration of so-called Rare Earth Elements, but those are radioactive, too). The proceedings had been initiated by the Ludovika Energy uranium company already on 20 April 2015 and since 25 June 2015 it was suspended, even though according to § 23, sec. 11, letter f) of the Geological Act it could and should have been terminated as the initiator hadn't delivered to the ministry all the required documentation. We find such acting of the ministry (or, to be exact, of the geological section of the ministry) when by a mere suspension of the proceedings it left for the uranium company an open possibility to get a new exploration area and thus the control over the Jahodná-Kurišková uranium deposit for another 4 year as yet another example of a pro-uranium attitude of the ministry or its respective employees.
With regards to the above-mentioned resumed proceedings related to the application for a new exploration area Kamenné, we would like to ask you as the minister to ensure that the respective sections and employees of the ministry of environment will respect the negative opinions of the affected municipalities to establishing a new radioactive minerals exploration area in their territories and that based on these negative opinions the application will get rejected. We also expect that in the current proceedings as well as in all the possible future ones concerning exploration of radioactive minerals, the ministry will respect the status of the affected communities, regions and their municipal authorities as fully recognized affected parties, i.e. that it will not grant unequal privileges to the subject that applied for the exploration area as it has been doing until now.
In connection with the problem of endangering the environment of the city of Košice and its surroundings by uranium mining and processing, we would also like to bring to your attention the legal suit that the Ludovika Energy uranium company filed at the Regional Court in Bratislava against the decision of the Ministry of Environment of the Slovak Republic not to extend the licence for their previous exploration area Čermeľ-Jahodná, established in 2005 (and expired in 2015) for further 10 years, i.e. until 2025. Based on this legal action, Ludovika Energy is threatening by a compensation claim (a ransom) of 23 million EUR. We believe that – provided that the court's decision will be legal and objective and that the defense of the ministry will not be intentionally too weak – this court complaint hasn't got a slightest chance to be successful since the valid Geological Act explicitly states that the ministry “may extend”, i.e. NOT “must extend” an exploration area. Neither the Slovak Republic nor the Ministry of Environment has never promised the uranium company to allow mining at Jahodná. Taking into account the attitude of the public, which has been strictly against uranium activities in Košice already since their very beginning in 2005, Ludovika Energy were free to decide to terminate this dead-end project of theirs much earlier and not to waste the financial funds of their foreign owners anymore – if they didn't do so, it is just their own fault. There is absolutely no reason why their business loss should be compensated by the state. We would like to believe that the Ministry of Environment led by you will guarantee an efficient defense of the interests of citizens in this matter and that it will not let unfounded compensations to be paid to uranium gamblers.
At the end of our letter we would also like to draw your attention to the 2014 amendment of the geological law, initiated by your predecessor-minister, that is supposed to be able to prevent uranium mining but in practice it doesn't prevent the mining, it just defines conditions under which mining can be allowed. The fact that the uranium company instead of terminating their activities at Jahodná filed in 2015 an application for a new exploration area and a new geological licence most clearly illustrates that they don't consider the legislation change powerful enough and an efficient obstacle in their efforts to push the mining through. Shortly after the amendment was approved, our organization pointed out several flaws that it suffers from at https://uran-kosice.webnode.sk/news/stanovisko-k-novele/
Thank you very much in advance for your help and support of citizens fighting against uranium mining and processing!
In case of further questions, please do not hesitate to contact us.
(We are also ready to meet you regarding this topic in person should you be willing to do so.)
Slovak Union of Nature and Landscape Protectors
JUDr. Mgr. Ladislav Rovinský,
chairman of the „Košice 2013“ Working Group
1. General Prosecutor's protest against the resolution of the Ministry of Environment dated 31/1/2013
2. Resolution of the ministry of environment excluding the Košice-Sever municipality from the proceedings about the application to establish a new exploration area Kamenné
3. Resolution of the Minister of Environment about the appeal of Košice-Sever
1. Committee for Agriculture and Environment of the National Council of Slovak Republic
2. European Parliament members representing the Slovak Republic
3. selected media