Both the report and its presentation raise reasonable doubt whether full and complete data were provided to the evaluator from the Ministry of Environment to submit a qualified evaluation of the project for complex modernisation of the power plant Prunéřov II. The questions presented as outstanding (asbest, subsoil water, impact on the plant vicinity) were already answered and documented in the EIA process (see below).

CEZ feels that the Ministry of Environment stands the same position after this report as following the public hearing and completion of an independent expert opinion. The DNV evaluation report may be inaccurate, however, in consequence and overall it confirms the positive evaluation of the complex modernisation project and recommendation to issue a positive opinion as provided in the expert opinion to meet the EIA process requirements. Also the fact that the Ministry of Environment has all technical and environmental details available since December 2009 which are needed and aimed to issue an opinion on the complex modernisation project for the Prunéřov power plant as it was supposed to do in accordance with law by 4 January, 2010.

It is unsettling that just a few hours before the DNV evaluation study conclusions on the complex modernisation project of the power plant Prunéřov 2 are published, this confidential report is being in detail commented in the media by environmentalists. Therefore, the CEZ Company seeks an explanation from the Ministry of Environmental and the DNV Company how possibly such garbled information may be operated by environmentalists before it is presented to the stakeholders.

Opinion on the individual items of the evaluation report:

• Complex modernisation of the power plant Prunerov II will represent an increase of efficiency by 7.39% points. It should be noted that efficiency of the modernised units will be 40.19 %, or 40.3 – 40.7 %. Nor the fictitious supercritical solution proposed by non-governmental organisations using fuel from the Libouš mine would implement the efficiency of 42 % due to the location specific conditions. This fact was clearly presented by CEZ in the documentation and repeated in discussions with the Ministry of Environment and in the public hearing (the recording of which is available at the website of the Ministry of Environment) as well as in the discussion with DNV evaluators. No credible evidence proving the contrary was ever submitted.
• DNV assessed the theoretical technical capabilities to implement as low CO (carbon monoxide) emission concentrations as possible. This needs to be set against local conditions (air pollution) and in particular, the real importance (hazard / toxicity of the substance) of the given parameter and its relationship with other parameters of the project. Here it should be pointed out the CEZ efforts to reach the minimum Nox (nitrogen oxide) and SOx (sulphide oxide) emission concentration levels which is prioritized based on communications with the relevant authorities because NOx and Sox emissions are subject to more stringent regulation of the public administration (emission ceilings) than CO. The adherence to a non-binding BREF value would mean in practice that prioritised CO orientation would in fact increase NO_x emissions (based on physical and chemical patterns of the combustion process). However, it should be noted that the actually implemented CO concentrations will be lower than provided in the EIA documentation which is evidenced by the case of complex modernisation of the Tusimice power plant as being in process now.
• The information on air quality deterioration in the immediate vicinity of the power plant is not documented. On the contrary, considerable improvement is expected by comparison with the current situation which is documented by the dispersion study as part of the EIA documentation. The expected pollution situation after the modernisation of the Prunerov power plant was (of course) accepted and approved by the local population and local governments as well as the public administration and the relevant authorities responsible for public health protection as a principal change leading to improve the current state.
• The EIA documentation addresses the issue of asbestos and the method of disposal thereof when the project is implemented. One of multiple inputs, i.e. the asbestos absence study has been available to the public administration since it was made. A detailed survey of asbestos presence was carried out at the Prunerov power plant in the past and nearly all the asbestos was removed in compliance with the legislation. The remaining amount will be disposed within the modernisation project of the Tusimice power plant. There are standard procedures to remove asbestos (e.g. possible disposal at dumps) that are subject to measures, or the specified conditions applicable to all hazardous wastes in compliance with the current legislation. The originator of the expert opinion in the EIA process provides that “The implementation of the project will lead to improve the current state of water protection mainly as related to implementation of technical measures aimed to reduce the pollution released in waste water, in particular comprehensive measures intended to reduce the amount of dissolved anorganic salt (RAS) released into the environment”. The DNV opinion is thus contradictory to the published conclusions of the standard independent opinion whose originator is duly authorised in compliance with the Czech legislation. DNV even provides in the report that waste water treatment processes will be improved, and the amount of waste water will be reduced, and they will increasingly be reused, and new treatment stations will be built, and more attention will be paid to seepage water containing undissolved anorganic salt.

The amount of CO2 (carbon dioxide) is based on wrong assumptions regarding the relevance of BAT requirements – see above. DNV calculation is inaccurate since although they also were to consider the opinion provided within EIA, setting the efficiency requirement at 40.3 – 40.7 %, they miscalculated it only using the 40 % efficiency. Moreover, it should be accentuated that the statement of higher CO2 emissions in the submitted alternative is fictitious and only partly true. This statement would only be valid if the same life time was used in all modernisation alternatives for the power plant. This prerequisite, however, is not applied. The expected lifetime in the proposed alternative is 25 years. Any other, more expensive alternative would have to provide a longer life and the overall release of CO2 emissions would then be far higher than values in the submitted alternative. This is also confirmed by the DNV study.