Objection as part of the public procedure for the planned CREOS line
The Mouvement Ecologique and its Regionale Uelzechtdall have recently lodged an objection as part of the public procedure for the environmental impact assessment (EIA) for the planned modernisation of a high-voltage line on the Aach – Bofferdange and Bofferdange – Bertrange route. This was preceded by a lengthy dialogue with the members of the Regionale.
The Mouvement Ecologique recognises the necessity of planning this high-voltage line, but on condition that it is carried out in an environmentally friendly manner. This is also because this project is intended to replace the existing line, some of which runs over or very close to residential areas, as well as the Heisdorf substation, which is located in the middle of residential areas. However, CREOS does not specify how the Heisdorf site is to be developed.
As essential as the construction of this pipeline is, our country needs a development policy vision that is compatible with the goals of sustainable development. This is currently not the case due to the desired growth. In this context, projects currently under discussion, such as the establishment of Google’s data centre, must also be critically scrutinised.
Specifically, the Mouvement Ecologique has formulated a number of objections:
- Absolutely inadequate preparation of the dossier
A public procedure should allow interested citizens to form an informed opinion about the impact of a project with its various route options. This requires a user-friendly and therefore comprehensible presentation as well as a clear synthesis of the dossier and the comparison of variants. This is in no form the case. This absolute lack of clarity and comprehensibility makes it almost impossible for a citizen to make a well-founded objective assessment or understand the impact of the various routes on the landscape, especially in the short time available.
- Lack of visualisation of the route variants
In 2024, it should also be a matter of course to use modern forms of visualisation of the impact of the project on the landscape and on the settlements in order to present such complex projects (3D film simulations with a dynamic course of the respective routes) and to make this accessible on the internet portal. This applies in particular – but not only – to the sections of the route that run closer to residential areas or locations of relevance to the landscape. After all, some sections of the route run around 200 metres away from houses. In our digital age, it is essential to use user-friendly forms of information instead of antiquated, difficult-to-understand visualisations. Unless, of course, the property developer wants to keep all options open when it comes to route design. This comment applies all the more to a project of this size, which has also been in the planning stage for years. Neither time nor financial reasons speak against such a visualisation.
- Unsatisfactory factual situation regarding the immission values of electric and magnetic fields and noise emission values
With regard to the proximity of certain partial routes to residential areas or more frequented locations, the Mouvement Ecologique is missing a calculation of the potential radiation values in the form of immission values. This means that the health impact cannot currently be assessed and it is also not possible to recognise whether the Luxembourg limits (and the precautionary values recommended by the Ministry of Health) will be respected or not.
The considerable need for improvement in this key area is also explicitly stated by the various ministries.
How is it possible that a dossier can enter the official procedure in which THE central element alongside landscape protection – safeguarding the health of local residents – has not been analysed and described anywhere near correctly? This is absolutely unacceptable.
- Inadequate presentation (and investigation?) of possible underground routes
The environmental impact studies do contain a theoretical discussion of “alternative underground routes (underground cable)” and an underground route was also analysed (section “Alzettetal-Steinseler-Plateau”). In conclusion, however, without being able to rely on various technical references, the report argues against an underground route. It has been shown abroad that such lines do have advantages when it comes to protecting housing estates or local recreation areas / open or protected parts of the landscape, e.g. the Steinseler (and Bourglinster) Plateau. The project organiser is probably also aware of this. In any case, an additional financial burden for a technical expense incurred cannot be a criterion for excluding underground solutions for partial sections, and the statements in the environmental impact study on an underground installation on certain partial routes are therefore extremely questionable in the opinion of Mouvement Ecologique as far as their technical validity is concerned.
- Lack of presentation of specific site-related measures to avoid and reduce impacts
The impact of the different variants on the natural environment also depends largely on the specific implementation in the planning and construction phase. The dossier lacks precision regarding the exact pylon locations as well as the current or newly created or wider access roads and the organisation of the respective construction sites during the construction phase.
- No consideration of the cumulative effect of projects on the environmental space
Taking the Steinseler Plateau as an example: According to our information, 2 wind turbines are being planned here. Even if possible exact locations are not yet known and the operator of these plants would be someone other than CREOS, the potential cumulative effect of certain variants of the high-voltage line and the two wind turbines should have been the subject of an environmental impact study and, if necessary, should have been an exclusion criterion for certain variants.
These cumulative effects should generally have been analysed along the entire route. From the point of view of landscape protection, but above all for the health of the people living there, the cumulative emissions should have been openly presented.
For many inhabitants of the Alzette valley and Bridel, the Steinsel plateau is an important local recreation area (walks, cycling…) thanks to its almost unspoilt landscape with its traffic-free or traffic-poor forest and field paths.
In principle, a landscape master plan should be drawn up for the entire plateau from Bridel to Mersch. The accumulation of selective projects without such an overall concept will inevitably lead to the recreational values of the plateau being called into question.
Comparable arguments can also be made for the Bourglinster Plateau.
Conclusions from the perspective of the Mouvement Ecologique
The non-transparent preparation of the dossier, the lack of conclusions and the lack of information as to which state objections CREOS intends to address and how, the non-existent visualisation of the various routes, the completely inadequate presentation of the resulting electric and magnetic fields, as well as all the other deficiencies mentioned are contrary to the objectives of a public procedure and thus to the legal requirements with regard to the environmental compatibility of such a major project with its potential impacts.
This means that there is no basis for a process of weighing up the various routes that is comprehensible to citizens.
Moreover, such a balancing of interests can only take place transparently if the criteria on which the balancing of interests should be based are discussed and disclosed. Such criteria are essential so that an objective weighting of different claims can take place: Protection of residents in the case of routes close to settlements, protection of free, open parts of the landscape and valuable nature conservation areas, protection of forests…. Based on these criteria, there should have been a transparent comparison of the different sections of the route in line with a SWOT analysis (strengths – weaknesses – opportunities – threats). But this is not the case either.
In this context, the Mouvement Ecologique has taken note of the opinions of the municipalities of Junglinster, Lorentzweiler, Steinsel and the ANF.
Apart from the fundamental comments mentioned above and the resulting reservations,
- The Mouvement Ecologique is in favour of the Bourglinster-East or Imbringen-East option, in line with the opinion of the nature conservation authorities and the municipalities of Junglinster and Lorentzweiler;betreffend der Trasse Alzettetal – Steinseler Plateau sehen wir Vorteile bei der Sichtweise einer Variante 7 bis zur Gemeinde Lorentzweiler;
- the Steinsel plateau – in accordance with the comments of the affected communities – should be kept completely free of any above-ground route as a local recreation area. A decision on the variant to be retained in the end must not be made here either without in-depth investigations and disclosure of facts.
Due to the aforementioned serious formal and substantive shortcomings of the dossier, which are contrary to the EU directive on the environmental impact study, the Mouvement Ecologique is calling for a new public procedure to be carried out with a revised dossier.
Subsidiarily, the Mouvement Ecologique insists that all of these documents must be available and made accessible to the public as part of the further authorisations still to be issued. This includes the authorisation procedure in accordance with the Commodo-Incommodo legislation as well as the nature conservation per
05.07.24